In short: The comment places on the record a specific contradiction between the small-business certification and the DEIS's own cost-benefit analysis regarding lost recreation benefits, while identifying eight specific roadless areas and requesting site-specific environmental analysis and an alternative retaining the 2001 rule's protections.
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.
- 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.
- 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.
- 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.
Topics
- Recreation Tourism Public Use
- “I hike, camp, and backpack extensively trough roadless areas”
- “peace and freedom these lands offer is unparalleled”
- “hiked a portion of the Continental Divide Trail”
- “small outfitters and guides who work this same country”
- Environmental Protection Biodiversity
- “loss of biodiversity/wildlife habitat”
- “pristine wildlife habitat”
- “land and water degradation”
- “preserving this quintessentially American public asset”
- Forest Management Wildfire
- “increases the likelihood of destructive effects, such as wildfires”
- “evacuated from my home during the Hermits Peak-Calf Canyon fire”
- “does not need the increased fire risk”
- “burdens that come with it that the current proposals will force onto us”
- Governance Policy Process
- “ask that the agency disclose and analyze the site-specific environmental consequences”
- “small-business certification contradicts the analysis beside it”
- “ask that the agency withdraw the certification”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal