Opposes rescissionA0 noneSubstance 2/24Posted August 23, 2026 On Regulations.gov
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
A0 none: Counted, not answered.
Still open to the agency
Alternative already eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
No cause and effect shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
“well documented in research on roadless areas and clean water”
“DellaSala, D. A. 2011, Journal of Soil & Water Conservation”
“Dominick A. DellaSala's 2011 synthesis”
What it names
Works cited
DellaSala et al. 2011
The comment
Repealing the Roadless Rule puts our drinking water at serious risk. Roads are the largest controllable source of sediment in our forests, something that has been well documented in research on roadless areas and clean water (DellaSala, D. A. 2011, Journal of Soil & Water Conservation, 66(3), 78A–79A).
And this isn’t just theoretical. Salem, Oregon had to spend roughly $100 million after sediment from logging-related disturbances contaminated its watershed.
Dominick A. DellaSala’s 2011 synthesis in the Journal of Soil & Water Conservation found that 3,400 communities across 33 states rely on national forests for their drinking water. That includes major areas like Los Angeles, San Francisco, Denver, and California’s Central Valley—which also produces food for the entire country.
This impacts far more people than those living next to a national forest. Roughly 124 million Americans depend on these watersheds. Repealing the Roadless Rule means opening the door to more roads, more logging-related disturbance, more sediment entering our watersheds, and ultimately putting clean drinking water for millions of Americans at risk.