In short: The comment places on the record specific data from DEIS Table 21 and the agency's own economic analysis to demonstrate that the proposal's wildfire and economic justifications are contradicted by the record, while simultaneously asserting that rescinding the 2001 Roadless Area Conservation Rule would violate obligations to maintain viable wildlife populations and functional corridors 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
- “pronghorn that run the longest land migration in North America funnel through it”
- “Grizzly bear, gray wolf, cutthroat trout, trumpeter swan, and sage grouse all depend on this landscape”
- “maintain viable wildlife populations and the functional corridors those populations require”
- “elimination of their migration patterns”
- Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile this rescission with the ignition data in DEIS Table 21”
- “far higher fire density on roaded land than inside affected roadless areas”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “projected timber revenue to the Forest Service of $5.2 to $11.4 million a year”
- “recreation losses of at least $6.1 million a year”
- “expand a road system already carrying a $6.9 billion maintenance backlog”
- Water Quality Quantity
- “325 municipal water intakes sit in watersheds containing affected roadless areas”
- “Wyoming holds 116 inventoried roadless areas totaling 3,243,958 acres”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceAlternativeLegal