Comment Analysis · Docket FS-2025-0001

FS-2025-0001-613538

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS fails to quantify the net increase in human-caused wildfire risk from new road access, contradicting its own Cost Benefit Analysis Table 4, and demands the withdrawal of the proposal to rescind the Roadless Area Conservation Rule under NEPA and the APA.

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, Evidence.

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
- “78% of human-caused wildfires on National Forests start within 1/2 mile of a road”
- “road construction in roadless areas is likely to lead to more human-caused wildfire”
- “USFS is dubiously promoting rescission of the Roadless Area Conservation Rule as wildfire protection”
- “quantify the expected increase in human-caused ignitions resulting from new road access”
Water Quality Quantity
- “protect the headwaters that supply my daily drinking water”
- “supply my town of Harrisonburg's Switzer Reservoir”
- “ecological and water impacts”
Recreation Tourism Public Use
- “support the outdoor recreation economy my community relies on”
- “Wild, roadless places like it are why I chose to live in and support the economy”
- “Degraded recreation quality”
Legal Regulatory Framework
- “fails to fulfill NEPA requirements (42 U.S.C. § 4321)”
- “avoid violation of the Administrative Procedure Act (5 U.S.C. § 706(2)(A))”
- “demand that the U.S. Forest Service withdraw the proposal”

What it names

National Forests: Coconino National Forest George Washington National Forest
Roadless areas: Southern Massanutten

The comment

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

Dear USFS Personnel, I support Alternative 1 and demand that the 2001 Roadless Area Conservation Rule be retained. I live near and visit on a weekly basis the roadless area on the western and southern sections of the Southern Massanutten roadless area in the Lee Ranger District of the George Washington National Forest of Virginia. Wild, roadless places like it are why I chose to live in and support the economy of the Shenandoah Valley. The Southern Massanutten and other nearby roadless areas protect the headwaters that supply my daily drinking water, including my town of Harrisonburg’s Switzer Reservoir, and these areas support the outdoor recreation economy my community relies on. The US Forest Service and cognizant state-level agencies already cannot keep up with the forested areas that already have roads. Please don’t add more roads. Please limit risk to personal property by keeping the Roadless Rule intact. Furthermore, rescinding the roadless rule poses an unacceptable risk to personal property and health that the USFS has yet to address adequately. My home was positioned within three miles of the 2019 Museum Fire in Flagstaff, Arizona, which burned 1,961 acres of the Coconino National Forest (1). I personally suffered from the increased smoke during the fire, and in 2021 heavy monsoon rains resulted in catastrophic flooding due to the reduced absorptive capacity of the Museum Fire burn scar (2). The Museum Fire was started by an excavator clearing trees in a forested area. Just one year after the Flagstaff floods of 2021, the Pipeline Fire was started in the same area just north of the town of Flagstaff, AZ by a man intentionally lighting toilet paper on fire in the forest despite "no campfire" signs being posted throughout the forest due to fire-prone conditions (3). The Pipeline Fire quickly grew to over 25,000 acres and resulted in evacuations and property loss. No less than 78% of human-caused wildfires on National Forests start within ½ mile of a road, and if the Roadless Rule is rescinded, road construction in roadless areas is likely to lead to more human-caused wildfire (4). The two cases recounted here shows that we cannot trust professionals or civilians to avoid starting forest fires, and that if people have easy access to the land via a road, the chances for catastrophic wildfire simply increase. I call on those who would advocate for rescinding the Roadless Area Conservation Rule to show that the likelihood of wildfire risk increasing after rescinding the Roadless Area Conservation Rule is at maximum 1/1,000,000. If this cannot be accomplished, it is arguably unconscionable to rescind the Roadless Area Conservation Rule. Where I live in Virginia, the risk of wildfire may be lower than in Arizona, but there is a substantial wildland-urban-interface and flammable forest material on the landscape. Each year in Virginia, more than 60 homes and other structures are damaged or destroyed by wildland fire (5). The USFS is dubiously promoting rescission of the Roadless Area Conservation Rule as wildfire protection, but its own effects analysis is in contradiction with its assertion of wildfire protection. The agency must quantify the expected increase in human-caused ignitions resulting from new road access and weigh it explicitly against the claimed reduction in wildfire hazard before that rationale can bear any weight. Problematically, the USFS's own Cost Benefit Analysis Table 4 (p. 30) lists among the qualitative unquantified costs of the Roadless Area Conservation Rule recission proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; and agency road maintenance burden." The agency says it cannot quantify reduced wildfire risk, and since ample data show that land with roads burns at a far higher human-caused rate than land without roads, I call on the USFS to get serious about quantifying the net wildfire effect of rescission before leaning on the wildfire reduction argument to justify the proposal to rescind. Considering the logic noted above and the fact that the August 20, 2026, DEIS fails to fulfill NEPA requirements (42 U.S.C. § 4321), I demand that the U.S. Forest Service withdraw the proposal to rescind the Roadless Area Conservation Rule to avoid violation of the Administrative Procedure Act (5 U.S.C. § 706(2)(A)). Numbered references: 1. 2019 Museum Fire (https://www.weather.gov/fgz/MuseumFire2019) 2. 2021 Flooding following Museum Fire (https://www.swfireconsortium.org/2022/03/25/post-fire-flooding-the-museum-fire/) 3. Pipeline Fire (https://www.fox10phoenix.com/news/pipeline-fire-man-pleads-guilty-starting-wildfire-flagstaff) 4. USA 2025, S_USA.FireOccurrence (https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point) 5. Wildfire in Virginia (https://www.dof.virginia.gov/wildland-prescribed-fire/learn-about-wildland-and-prescribed-fire/wildfire-in-virginia/)