Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591540

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to apply its own data on the relationship between road proximity and human-caused wildfire ignitions to the cost-benefit analysis and Alternative 2 effects assessment, specifically by excluding the identified ignition hazard from the Net Present Value calculation and failing to disclose the assumed proportion of roads closed to public access.

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
- “critical to reducing severe wildfire”
- “Building roads into currently roadless areas makes these areas more vulnerable to wildfire”
- “human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands against 3.0 in the potentially affected inventoried roadless areas”
- “The DEIS contains multiple errors and inaccuracies in its analysis of wildfire risk”
Legal Regulatory Framework
- “Under 7 CFR 1b.7(f)(1) the agency must analyze substantive issues”
- “The DEIS must disclose what proportion of roads constructed under Alternative 2 is assumed to be closed to public motor vehicle use”
- “The Net Present Value presentation at Economic Analysis p. 29 must disclose that it excludes the increased human-caused ignition cost”
- “This is not deferrable to site-specific decisions”
Economic Impact Fiscal
- “Road building in forest lands is expensive and timber sales have never repaid the costs of building roads”
- “it would cost us financially”
- “Rescission provides no benefit to most Americans”
- “The Net Present Value at p. 29 is described as using 'maximum potential costs and benefits,' yet it carries no line for the ignition hazard”

What it names

Law cited: 7 CFR 1b 7 CFR 1b.11(a)(23)
Works cited: Cardille et al. 2001Narayanaraj and Wimberly 2012

The comment

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

I strongly oppose the rescission of the 2001 Roadless Rule for US National Forests. Rescission of the Roadless Rule would provide numerous harms to human, wildlife, and conservation values across the United States. Road building in forest lands is expensive and timber sales have never repaid the costs of building roads in our National Forests. Rescission of the Roadless Rule would not only cost US citizens enormously in terms of lost recreation and lost benefits of conserving forests, it would cost us financially. Rescission provides no benefit to most Americans. Among the many benefits of the Roadless Rule, it is critical to reducing severe wildfire. The majority of wildfires are started by people. Building roads into currently roadless areas makes these areas more vulnerable to wildfire. The DEIS contains multiple errors and inaccuracies in its analysis of wildfire risk that must be corrected. One critical error is that the DEIS clearly demonstrates the relationship between roads and wildfire but fails to apply this relationship to cost-benefit accounting. The DEIS finds at p. 94 that "[t]he incidence of human-caused fires generally increases with proximity to roads," and at p. 98 that "these analyses indicate 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 (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." Table 21 puts numbers to it: human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands against 3.0 in the potentially affected inventoried roadless areas. Figure 15 plots reported ignition density by distance to roads within those same areas. The Economic Analysis supplies the exposure distribution at p. 18: 51.5 percent of affected roadless acreage lies within one mile of a road, and 30.8 percent within a half mile. The DEIS contains a measured roaded-versus-roadless ignition differential, and the acreage distribution against which either could be applied. It applies none of them. In the Alternative 2 effects analysis the finding is restated and then set aside: "Road 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). However, not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." However, the DEIS nowhere states what share of roads constructed under Alternative 2 would be closed to public motor vehicle use, so no determination can be made about the effects of those closures. The cost-benefit analysis does not account for increased wildfire ignition despite claiming that it accounts for maximum costs. The Economic Analysis states at p. 26 that "[w]ith increased road construction, there could be increased hazard (which carries a cost) from human-caused ignitions," and that "[i]f there is an increase in public road access, the number and frequency of wildfires could rise." Having identified the cost, the analysis excludes it from the accounting. The Net Present Value at p. 29 is described as using "maximum potential costs and benefits," yet it carries no line for the ignition hazard. That is a factual error, independent of whether the excluded category can be monetized. Three corrections are required, all possible without new data collection. First, the Alternative 2 effects analysis must either apply Figure 15's ignition-density function and Table 21's differential to the road construction reasonably foreseeable under the alternative, or explain why the agency declines to do so. Under 7 CFR 1b.7(f)(1) the agency must analyze substantive issues, and the roads-to-ignitions relationship is an issue within 7 CFR 1b.11(a)(23) by the DEIS's own statement of the cause-and-effect relationship at p. 98. This is not deferrable to site-specific decisions: the rule-level decision removes the prohibition that presently prevents the roads, and the ignition exposure follows from the rule-level acreage, not from any single project. Second, the DEIS must disclose what proportion of roads constructed under Alternative 2 is assumed to be closed to public motor vehicle use, identify what in the proposed rule text secures that closure, and, if nothing does, withdraw the conclusion that depends on it. Third, the Net Present Value presentation at Economic Analysis p. 29 must disclose that it excludes the increased human-caused ignition cost identified at p. 26, or that cost must be included. I do not ask the agency to reach any particular conclusion about wildfire. I ask that the analysis either use the data it has assembled or say plainly that it has not, so that the record shows which. Thank you.