In short: The comment places on the record specific evidence that the agency's own DEIS Table 21 and cited literature (Sawyer et al. 2013) contradict the proposal's wildfire and wildlife justifications for rescinding the 2001 Roadless Area Conservation Rule, and documents a specific reliance interest in the rule's protections for recreation in Northern Arizona.
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
A2 moderate: Hard to dismiss — it shows cause and effect.
Owed an answer on Evidence.
Standard dismissals it defeats
- 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.
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.
- 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.
- 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.
- 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.
Topics
- Forest Management Wildfire
- “The wildfire rationale troubles me most”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “Roading those areas to reduce that risk is contradicted by the agency's own findings”
- Wildlife Habitat
- “The deer we look for in these forests depend on unroaded habitat”
- “roads built for extraction may alter mule deer migration routes”
- “Rescission puts the security and connectivity that sustain deer populations across all of that land at risk”
- Legal Regulatory Framework
- “The Tenth Circuit held that the 2001 rule was within the authority Congress granted”
- “The proposal reasserts doubts about statutory authority that courts already resolved”
- “I ask that the agency address that holding directly and explain on the record the legal basis for any contrary position”
- Recreation Tourism Public Use
- “We hike in the Flagstaff Forest for recreation”
- “My family has organized recreation and time in Northern Arizona public lands around the protection the 2001 rule provides”
- “I believe public land should be managed for conservation, recreation, and ecology”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal