In short: The comment documents the presence of the Southern Mountain Yellow-legged Frog in the Arroyo Seco IRA of the Angeles National Forest and asserts that rescinding the Roadless Rule without completing ESA Section 7 consultation violates the Endangered Species Act.
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
A3 weak: Substantive, but easier to set aside.
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.
- 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.
- 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.
- 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
- “documented occurrences of Southern Mountain Yellow-legged Frog”
- “Roads are not built because the rule prohibits them”
- “Habitat fragmentation strongly reduced species richness”
- “Rescission removes that barrier and enables the full suite of habitat-altering activities”
- Recreation Tourism Public Use
- “public's experience of federal land is not mediated by motorized access”
- “enjoy the outdoors as a way to disconnect from the bustle of city life”
- “no screens and we didn't have to listen to cars zooming by”
- “quiet, remote, and backcountry recreation values”
- Legal Regulatory Framework
- “triggers an independent ESA Section 7 formal consultation obligation”
- “failure to consult is an independent basis for setting aside a federal action”
- “unjustified departure from twenty-five years of settled policy”
- “The Department should let the Rule stand”
What it names
- National Forests
- Angeles National Forest
- Roadless areas
- Arroyo Seco
- Works cited
- Haddad et al. 2015Haddad et al. 2015
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal