In short: The comment documents that the DEIS analysis contradicts the rationale for rescinding the Roadless Rule by identifying specific adverse impacts, including increased wildfire ignition frequency, an unmanageable $6.9 billion road maintenance backlog, adverse effects on 327 threatened and endangered species, and jeopardized drinking water quality for 24 million Americans.
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
- Water Quality Quantity
- “protects local communities' drinking water supply from contamination”
- “jeopardize the quality of drinking water for 24 million Americans”
- “increased soil erosion, runoff, and sediment pollution”
- “lives in a town that gets its water from a National Forest watershed”
- Wildlife Habitat
- “preserves critical wildlife habitat and migration corridors”
- “adversely affect 327 threatened and endangered species”
- “wildlife that feed our community and collective consciouses have habitat to thrive”
- “species such as mule deer and elk”
- Recreation Tourism Public Use
- “As an outdoorsman, public-land user”
- “areas where I've had some of my most formative experiences”
- “preserves some of the few remaining wild landscapes in the western US”
- “one of the reasons I live in Wyoming is because of our abundant roadless areas”
- Forest Management Wildfire
- “frequency and density of human ignitions are approximately four times lower in roadless areas”
- “opening the door to more road building, we can therefore expect more, not less, wildfire-sparking ignitions”
- “rescinding the Roadless Rule will decrease wildfire danger”
- “Forest Service has an existing road maintenance backlog”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal