Comment Analysis · Docket FS-2025-0001

FS-2025-0001-509581

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted September 29, 2026 On Regulations.gov

In short: The comment establishes that the DEIS's conclusion that new roads have no material effect on wildfire ignition rates is unsupported and contradicted by its own data, specifically citing Tables 18 and 21 to show that human-caused ignition density is 7.5 times higher on non-roadless lands than in IRAs.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap.

Standard dismissals it defeats

  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Wildlife Habitat
    • “destruction of treasured wildlife”
    • “sight of a black bear family”
    • “howling coyotes, rustling birds and scratching land mammals”
    • “amazing moments found only on our protected lands”
  • Forest Management Wildfire
    • “80% of wildfires occuring closest to roads”
    • “human caused ignitions increase in abundance with proximity to roads”
    • “Road density is linked to human-caused wildfires”
    • “jeopardize human life”
  • Scientific Research Evidence
    • “Unsupported and Uncited Conclusion”
    • “contradicts the DEIS's own cited findings and its own data”
    • “Table 18 (p. 95) reports all-cause ignition density”
    • “Table 21 (p. 98) decomposes that figure by cause”

What it names

Works cited
Balch et al. 2017Cardille et al. 2001Chen and Jin 2022Narayanaraj and Wimberly 2012Parisien et al. 2016

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

I am a certified Master Naturalist and frequent outdoor visitor to state parks, natural areas and national parks in my home state of Texas. I've spend many overnights camping outdoors within earshot of howling coyotes, rustling birds and scratching land mammals. The wonder of hiking within sight of a black bear family is not soon forgotten, but can only happen if the sight, sound and destruction of cars and trucks occur far, far away from park trails. Recinding the Roadless Rule will precipitate the destruction of treasured wildlife and amazing moments found only on our protected lands. Also, as our planet warms and drought becomes commonplace, the destruction of land and property by wildfires has grown exponentially. With 80% of wildfires occuring closest to roads, the destruction by fire will grow even higher. We can't afford to lose these protected lands and jeopardize human life! Stop the destruction, KEEP the Roadless Rule as it stands. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests.

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