In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire risk, watershed protection, and carbon capture, citing the agency's own prior findings (FEIS Vol. 1 and 66 FR 3244) to demonstrate that the proposal's justifications for rescinding the 2001 Roadless Rule are contradicted by the existing administrative record.
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
- Water Quality Quantity
- “impact of further habitat degradation on vital watersheds”
- “watershed for the Lewis River, Wind River, Cispu River and Cowlitz River systems”
- “impact of rescinding the Roadless Rule on watershed management”
- Climate Carbon Storage
- “impact of rescinding the Roadless Rule on the capacity of mature and old growth forest stands to capture carbon”
- “guard over 100 tons per hectare of what scientists call “irrecoverable carbon””
- “mitigate climate change”
- Wildlife Habitat
- “impact of further habitat degradation”
- “213,000 acres of old-growth and recovering forest which would be opened to road building”
- “refuges for heat-sensitive species”
- Recreation Tourism Public Use
- “hiking and camping in the Gifford Pinchot National Forest are important recreational activities”
- “I live in the foothills of the Cascades within 30 miles of the Silver Star inventoried roadless area”
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal