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 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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
Topics
- Forest Management Wildfire
- “Rescinding the Roadless Rule will make wildfires even more dangerous”
- “Building new roads is likely to increase fire ignitions”
- “wildfires are almost twice as likely to occur in roaded areas”
- “Constructing roads into roadless areas would simply increase the number of fires”
- Climate Carbon Storage
- “Climate adaptation needs intact landscapes”
- “Forest canopies cool the ground beneath them”
- “daily maximum temperatures average roughly 4°C cooler”
- “peak cooling exceeding 5°C during heatwaves”
- Environmental Protection Biodiversity
- “animals who lose their homes”
- “The 2001 Rule keeps them intact”
- “intact landscapes”
- “relationship”
What it names
- Works cited
- 10.1016/j.apgeog.2011.09.00410.1111/ele.7009610.1186/s42408-026-00450-2
Attachments
6 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
- Supporting material
- Supporting material
- Supporting material
- Supporting material
- Supporting material
- Supporting material