In short: The comment establishes that the agency's Draft Environmental Impact Statement (DEIS) and Cost Benefit Analysis fail to quantify the increased wildfire ignition risk from new road access, reconcile the lack of net economic benefit with the proposed road expansion, or properly assess the impact on small businesses and reliance interests in the Bridger-Teton National Forest.
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 Analytical gap, 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
- Wildlife Habitat
- “Bears, elk, moose, and many other species depend on that landscape staying whole”
- “Losing the roadless character of the Bridger-Teton would fracture exactly the uninterrupted habitat these species require”
- “elk avoid areas near roads and select habitat away from them”
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- Recreation Tourism Public Use
- “home to countless world-class trails, including the Continental Divide National Scenic Trail”
- “recreation losses of at least $6.1 million a year”
- “My use of the Continental Divide National Scenic Trail and the wildlife habitat it passes through has been shaped by the protections this rule provides”
- “outfitters, guides and tour operators as affected”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected”
- Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “has not quantified the expected increase in ignitions from new road access or weighed it against the claimed reduction in wildfire hazard”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence