In short: The comment places on the record that the DEIS fails to evaluate flood hazards for the Three Ridges IRA as required by Executive Order 11988, and documents that road construction in roadless areas increases wildfire ignition density and exacerbates the Forest Service's $15.6 billion deferred maintenance backlog.
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
- Forest Management Wildfire
- “peer-reviewed science shows the opposite”
- “wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads”
- “building roads into roadless areas is likely to result in more fires”
- “forests with higher levels of protection had lower severity values”
- Water Quality Quantity
- “drains into downstream floodplains”
- “road-generated increases in impervious surface, runoff volume, and peak flows”
- “increased sedimentation and peak flows that are higher and arrive more quickly after storms”
- “Road construction... converts permeable forest soils to compacted and paved surfaces”
- Recreation Tourism Public Use
- “spend as much time as they can on public lands”
- “roadless parts are what make the rest of it hold together”
- “most cherished memories”
- “unique places that are innately American”
- Economic Impact Fiscal
- “Building more roads in national forests would be a drain on taxpayers”
- “deferred-maintenance road backlog was estimated at $8.4 billion”
- “backlog has never dropped below $5 billion”
- “Adding new roads... would only deepen that hole”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal