Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603409

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the DEIS fails to quantify the increased human-caused wildfire ignition risk from new roads, contradicting its own data in Table 21 and pages 98, 109, and 113, and requests the retention of the 2001 Roadless Area Conservation Rule.

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

Forest Management Wildfire
- “human-caused wildfire ignitions increase with proximity to roads”
- “increasing road density is associated with increases in the probability, number, and frequency of wildfire ignitions”
- “targeted fuels reduction, prescribed fire, and other measures where science demonstrates that they can help protect communities”
- “distinguish between targeted management needed to address a specific wildfire threat and opening currently roadless landscapes to substantially greater road construction”
Scientific Research Evidence
- “The Forest Service's own analysis does not convincingly support that conclusion”
- “Table 21 reports a human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands, compared with only 3.0 in potentially affected inventoried roadless areas”
- “Forest Service research has found that the advantages roads may provide for positioning firefighting resources can be offset by increased human-caused ignitions near roads”
- “wildfire policy should be based on the evidence”
Environmental Protection Biodiversity
- “Roadless areas also protect watersheds, wildlife habitat, recreation opportunities, and large relatively intact landscapes”
- “Roads and the development they facilitate can permanently alter those landscapes”
- “protect wildlife habitat”
Recreation Tourism Public Use
- “spend a great deal of time hiking, biking, and recreating on our public lands”
- “recreation opportunities”
- “limiting additional ignitions”

The comment

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

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Chief Schultz: I am writing to urge the Forest Service not to rescind the 2001 Roadless Area Conservation Rule. I have lived in the Colorado mountains for 38 years and spend a great deal of time hiking, biking, and recreating on our public lands. I have also watched wildfire risk become an increasingly serious concern for mountain communities. For that reason, I am particularly troubled by the suggestion that rescinding roadless protections and allowing additional road construction would reduce wildfire risk. The Forest Service's own analysis does not convincingly support that conclusion. The Draft Environmental Impact Statement acknowledges that human-caused wildfire ignitions increase with proximity to roads. At page 98, the DEIS states that human-caused ignitions increase near roads because roads facilitate human access. At page 109, it further acknowledges that increasing road density is associated with increases in the probability, number, and frequency of wildfire ignitions. The DEIS's own data make this issue especially important. Table 21 reports a human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands, compared with only 3.0 in potentially affected inventoried roadless areas. That is approximately a 7.5-fold difference. Natural ignition rates are much closer: 16.8 compared with 8.5. In other words, much of the difference in wildfire occurrence between roaded and roadless lands is associated with human-caused ignition. This is not simply a theoretical concern. Forest Service research has found that the advantages roads may provide for positioning firefighting resources can be offset by increased human-caused ignitions near roads. More recent Forest Service research reports that human-caused ignitions account for more than 60 percent of recorded wildfires across the western United States. Despite this evidence, the DEIS concludes at page 113 that the net effect of new roads on fire occurrence is likely to be "small or insignificant," based in part on potentially improved response times and initial attack. That conclusion deserves much stronger support. The DEIS suggests that some new roads might be closed to public access, thereby limiting additional ignitions. But the proposed rescission does not appear to require a particular proportion of new roads to be closed, nor does the analysis quantify the expected increase in ignitions under different levels of road construction and public access. It therefore relies on a possible mitigating measure without demonstrating that the measure will occur or that it will offset the documented relationship between roads and human-caused wildfire. I support responsible forest management. I support targeted fuels reduction, prescribed fire, and other measures where science demonstrates that they can help protect communities and improve forest health. But those objectives do not require wholesale removal of roadless protections. The Forest Service should distinguish between targeted management needed to address a specific wildfire threat and opening currently roadless landscapes to substantially greater road construction and human access. Those are not the same policy. Before relying on wildfire reduction as a justification for rescission, the Forest Service should use the data already contained in the DEIS to quantify the likely change in human-caused ignition risk associated with additional roads. It should also identify what percentage of new roads it assumes would be closed to public access and analyze what happens if those closures do not occur. If the agency cannot demonstrate that increased suppression access outweighs increased ignition risk, it should not characterize rescission as a wildfire-risk-reduction measure. Roadless areas also protect watersheds, wildlife habitat, recreation opportunities, and large relatively intact landscapes. These values are particularly meaningful to those of us who live in and depend upon mountain communities. Roads and the development they facilitate can permanently alter those landscapes. I fully appreciate the need to confront wildfire risk. But wildfire policy should be based on the evidence. The evidence presented by the Forest Service itself does not establish that building more roads into currently roadless areas will make our forests or our communities safer. I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule rather than rescind it. Thank you for considering my comments. Sincerely, Erika Krainz Dillon, Colorado