Comment Analysis · Docket FS-2025-0001

FS-2025-0001-571736

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to adequately analyze the impact of new road construction on wildfire ignition rates in the Strawberry Peak area of the Angeles National Forest, specifically by ignoring the Santa Ana Winds and contradicting its own cited data on road proximity and fire risk, while also failing to address the effects on the Southern California Puma population.

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
- “Santa Ana Winds”
- “human caused ignitions increase in abundance with proximity to roads”
- “road density is linked to human-caused wildfires”
- “amplifies the fire risk roads bring to wilderness areas”
Wildlife Habitat
- “fragment habitats and increase road mortality of wildlife”
- “effects on health, population and distribution of the Southern California population Puma Con Color”
- “core habitat”
- “listed species”
Environmental Protection Biodiversity
- “untrammeled wilderness”
- “wellspring of our health and imagination”
- “most precious for our future generations”
- “local ecology”
Legal Regulatory Framework
- “7 CFR 1b.7(f)(2)(iii)”
- “5 U.S.C. §§ 553 and 706(2)(A)”
- “DEIS's conclusion that new road construction will have no material effect”
- “supplement the wildfire occurrence effects analysis”

What it names

National Forests: Angeles National Forest
Roadless areas: Strawberry Peak
Law cited: 7 CFR 1b
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

Dear Chief: I am a wildlife artist making work about local ecology that I share in educational settings. I rely on research, conversations with biologists and my daily visits to the national forest. Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer to oppose the proposed rescission, the rationale for which the field evidence does not support. My opposition rests on several issues, chief among them fire. I will note ahead of that arguement below, that rescinding the Roadless Rule will fragment habitats and increase road mortality of wildlife. Your analysis, its failure to consistently and adequately address core habitat, as well as improperly aligned data regarding management plans for listed species, fails to address the effects on health, population and distribution of the Southern California population Puma Con Color. I request that it do so. Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire. 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. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation. If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire. Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom. Do the right thing. DO NOT RECIND THE ROADLESS RULE. All the best, Christian Kasperkovitz