Comment Analysis · Docket FS-2025-0001

FS-2025-0001-566895

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the DEIS's conclusion regarding the lack of material effect of new roads on wildfire ignition rates is unsupported and contradicted by its own cited data, and that 30 of 64 tribal consultation requests are unaccounted for in the designated EO 13175 compliance record.

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
- “majority of wildfires are human caused and that the majority of them are started in places accessible to roads”
- “argument that we need to recind the roadless rule for wildfire management holds little water”
- “new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support”
Tribal Sovereignty
- “We need to do more than just "consult" with the tribes”
- “thirty of sixty-four tribal consultation requests are unaccounted for”
- “Executive Order 13175 compliance record”
Environmental Protection Biodiversity
- “significant impacts of humans on our National Forest and Wilderness areas”
- “areas most trashed, most harmed, most affected are those accessible by roads”
- “tired of the resource damage”
Climate Carbon Storage
- “reliance on fossil fuels... are putting us on a path to our own extinction”
- “stop thinking we are the king of the mountain”
- “learn how to stop thinking we are the king of the mountain”

What it names

Law cited: EO 13175 Executive Order 13175
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 knowledgeAnalytical gapEvidence

Over the last 13 years in particular I have seen and dealt with the significant impacts of humans on our National Forest and Wilderness areas. The areas most trashed, most harmed, most affected are those accessible by roads. I also know anecdotally and from reporting that the majority of wildfires are human caused and that the majority of them are started in places accessible to roads. So the argument that we need to recind the roadless rule for wildfire management holds little water for me. I am weary of picking up human shit, dispersing fire evidence in places where none are allowed and/or where common sense seems to fly out the window. I'm tired of the resource damage. Over the last couple decades it is also apparent that our practices of resource extraction, reliance on fossil fuels, and so on - all the things that are undeniably causing the climate change in ways that are inarguable anymore - are putting us on a path to our own extinction. We live on an exquisite planet. Spend a time in the woods near where I live and learn how precious and amazing it all is. We have much to learn from this place starting with how to stop thinking we are the king of the mountain. We need to do more than just "consult" with the tribes but perhaps get curious about how they lived here sustainably for thousands of years. And then there is the practicality of what is being proposed. We can not and do not maintain the Forest Service Roads we currently have. And even if we could we also do not have the manpower to manage more. Where will the money come from? Where will the employees come from. You have already gutted it. And in just a few minutes of research it's clear y'all simple do not know what you are doing, talking about and lack any kind of cogent plan. Additionally, the full gambit of folks who access National Forest Lands are opposed to this. Listen. Do what is right for generations to come. 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. Thirty of Sixty-Four Tribal Consultation Requests Undisposed in the Section Designated as the EO 13175 Compliance Record Re: Consultation accounting, Draft EIS Vol. I p. 17 — thirty of sixty-four tribal consultation requests are unaccounted for in the only section the Draft EIS designates as its Executive Order 13175 compliance record. 1. The Draft EIS's own figures. At Vol. I p. 17, under the heading "Consultation with Federally Recognized Tribes and Alaska Native Corporations," the Draft EIS states: "The Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled." Thirty of the 64 requests — 47 percent — are therefore neither held nor scheduled.