In short: The comment establishes that the agency's record fails to support the rescission of the Roadless Rule because the preamble concedes benefits are modest and budget-constrained, ignores serious reliance interests, and lacks quantified analyses of ignition risk, lifecycle road costs, and state-specific alternatives.
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, Alternative, 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
- Legal Regulatory Framework
- “The preamble's own findings do not support the action”
- “36 CFR 294.12(b) permits roads to protect public health and safety”
- “An agency reversing longstanding policy must assess serious reliance interests”
- “I request the No Action alternative, or a supplemental draft EIS”
- Forest Management Wildfire
- “The fire rationale does not match the geography”
- “access can increase human-caused ignition potential”
- “quantify change in ignition density, acres burned, and suppression cost”
- “The Department reports WUI overlaps 9.8 million acres”
- Economic Impact Fiscal
- “The economics do not favor the action”
- “count lifecycle cost of new permanent roads, capital plus perpetual maintenance”
- “roughly offset by recreation losses”
- “The 2001 Rule is fiscally conservative policy”
- Water Quality Quantity
- “include headwaters in the upper Skagit”
- “Roads are the dominant sediment source and driver of mass wasting”
- “quantify sediment delivery and culvert failure risk”
- “overlying critical habitat for listed salmonids”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal