Comment Analysis · Docket FS-2025-0001

FS-2025-0001-566347

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to quantify the increase in human-caused ignitions resulting from road construction in Alternatives 2 and 3, despite possessing data showing a four-fold difference in ignition density between roaded and unroaded lands, and requests a supplemental analysis to compare this adverse effect against the claimed initial attack benefits.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Forest Management Wildfire
- “road access drives ignitions”
- “ignition density is approximately four times greater on other NFS lands”
- “predicts that converting unroaded acres to roaded acres increases human-caused ignitions”
- “estimate the expected change in human-caused ignition density”
Legal Regulatory Framework
- “NEPA requires the agency to disclose the basis for the environmental conclusions”
- “42 U.S.C. Sec. 4332(2)(C); Idaho Sporting Congress v. Thomas”
- “compliance with applicable law”
- “supplement the wildfire analysis”
Scientific Research Evidence
- “InFORM Fire Occurrence Data Record and the MTBS burned-area dataset”
- “Aplet, Hartger & Dietz (2026) find ignition density lowest in designated wilderness”
- “The DEIS has the data to estimate its magnitude. It does not do so.”
- “quantitative basis for it appears”

What it names

Law cited: 137 F.3d 1146 137 F.3d 1146 42 U.S.C. Sec. 4332 7 CFR 1b.11(a)(53)

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

The wildfire analysis establishes, from the agency's own data, that road access drives ignitions. P. 94 states that "the incidence of human-caused fires generally increases with proximity to roads," and it discloses its basis: the InFORM Fire Occurrence Data Record and the MTBS burned-area dataset, with primary comparisons focused on 2014-2024. P. 97 it reports the result - "ignition density is approximately four times greater on other NFS lands compared to the potentially affected IRAs and wilderness. Most of this difference is due to the greater density of human-caused ignitions within other NFS lands (Table 21)." Among fires with causes determined, 77 percent in wilderness and 74 percent in potentially affected IRAs were naturally ignited, against a 57 percent human-caused majority on other NFS lands. Aplet, Hartger & Dietz (2026) find ignition density lowest in designated wilderness (1.75 fires per 1,000 ha) and Inventoried Roadless Areas (1.97), and highest within 50 m of roads (7.99). The cause-and-effect link to this analysis is direct. Alternatives 2 and 3 remove the prohibition on road construction and reconstruction across the potentially affected IRAs. The DEIS's own measured relationship - human-caused ignition density rising with road proximity, by a factor of about four between unroaded and roaded NFS lands - predicts that converting unroaded acres to roaded acres increases human-caused ignitions on those acres. The DEIS has the data to estimate its magnitude. It does not do so. In the Fire Control discussion of Alternative 2 at p. 111, the DEIS analyzes only the benefit: "With increased road access, initial attack success rates would be expected to increase. Additional roads would provide safer, more effective, and more efficient containment opportunities, potentially reducing fire sizes and durations." No corresponding estimate of the ignition increase appears anywhere in the Alternative 2 effects analysis. The ignition side surfaces once, at p. 113, in the Alternative 3 discussion: "Alternative 3 has the same concern about new roads increasing ignitions, and these ignitions would be closer to communities, where they could potentially cause more damage. However, the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." That sentence carries no citation, no analysis and is a netting conclusion with one side of the ledger measured to a factor of four and the other side never estimated at all. The offset the DEIS relies on is bounded by its own finding. At p. 104 the DEIS reports that "[d]ata from the FODR for fires occurring between 2014-2024 indicate that initial attack success rates are high (more than 90 percent) for all land designations," with the differences across designations described as a trend rather than a gap (Table 24). If initial attack already succeeds on more than nine of ten fires everywhere, the improvement new roads can deliver is bounded at under ten percentage points of containment on fires that start. The DEIS performed the ignition-density comparison at the national scale, across all potentially affected IRAs, in support of a national rulemaking. Having quantified the baseline nationally, the agency cannot defer the corresponding effect to future site-specific analyses while relying on an unsupported national conclusion that the net effect is insignificant. The statement at p. 112 that "[t]he magnitude of these beneficial effects would depend on site-specific decisions regarding the amount and layout of the expanded road network" applies with equal force to the adverse effects, and the DEIS estimates neither. NEPA requires the agency to disclose the basis for the environmental conclusions it draws and to connect its data to those conclusions. 42 U.S.C. Sec. 4332(2)(C); Idaho Sporting Congress v. Thomas, 137 F.3d 1146, 1150 (9th Cir. 1998). Under 7 CFR 1b.11(a)(53) this comment bears on reasonably foreseeable impacts, on the choice among alternatives, and on compliance with applicable law. I request that the Forest Service supplement the wildfire analysis to estimate, using the InFORM FODR analysis already performed for Table 21, the expected change in human-caused ignition density and ignition count within the potentially affected IRAs under Alternatives 2 and 3, given the road mileage and road-access changes the alternatives make possible; that it state that estimate in the same units as the initial-attack benefit it credits at pp. 111 and 113 so the two can be compared; and that it either support the conclusion that "the net impact of new roads on fire occurrence is likely small or insignificant" with that comparison or withdraw it from the FEIS. If the agency retains the conclusion, it should identify where in the FEIS or the supporting record the quantitative basis for it appears.