In short: The comment places on the record specific economic and safety data from the agency's own analysis—contrasting $5.2-$11.4 million in potential timber revenue against $6.1 million in lost recreation benefits and a $6.9 billion maintenance backlog—along with the fact that 76% of affected acres are outside the wildland-urban interface and that most Tribal governments oppose the rescission, to argue that the proposed rescission of the 2001 Roadless Area Conservation Rule is not justified.
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 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
- Recreation Tourism Public Use
- “grew up hiking in the White Mountain National Forest”
- “backcountry I walked as a kid is still backcountry”
- “lost economic benefit to recreationists”
- “places I hiked as a child are still there for the kids hiking now”
- Economic Impact Fiscal
- “return $5.2 to $11.4 million a year”
- “roughly $6.1 million in annual lost economic benefit”
- “$6.9 billion deferred maintenance backlog”
- “great deal to give up for very little”
- Governance Policy Process
- “not against local decisionmaking”
- “Idaho and Colorado operate under state-specific roadless rules”
- “petition for tailored provisions under 5 U.S.C. 553(e)”
- “Flexibility does not require repeal”
- Forest Management Wildfire
- “increase human-caused ignition potential”
- “only 24 percent of affected roadless acres overlap the wildland-urban interface”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal