In short: The comment establishes that the DEIS fails to analyze the specific loss of dispersed shooting, hiking, and camping opportunities due to road construction and associated regulatory buffers, and documents that the wildfire rationale is unsupported by data on human-caused ignitions and maintenance backlogs.
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.
- 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.
- 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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Topics
- Recreation Tourism Public Use
- “I hike, camp, and shoot on National Forest System lands”
- “removes far more shooting-capable ground than its physical footprint”
- “degrades hiking, camping, and general living”
- “recreational and natural value is partially derived from substantial natural darkness and quiet”
- Wildlife Habitat
- “new roads fragment habitat for bear, elk, and native trout”
- “roughly 25% of federally listed animal species have habitat in roadless areas”
- “area fragmentation degrades hiking, camping, and general living”
- Water Quality Quantity
- “Roads bring noise, dust, exhaust, and sediment into the air as well as headwaters”
- “headwaters serving tens of millions of Americans”
- Forest Management Wildfire
- “the wildfire rationale is unsupported”
- “human ignitions are roughly four times likelier near roads than in roadless country”
- “Access is not a constraint; workforce capacity and a $6.9 billion road maintenance backlog are”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceRequestLegal