In short: The comment places on the record specific data from the agency's own DEIS Table 21 and Cost Benefit Analysis demonstrating that roaded lands have higher fire density and that the economic benefits of rescission are offset by recreation losses and a $6.9 billion maintenance backlog, while citing Tenth Circuit precedent and the Organic Act to argue that the 2001 Roadless Rule remains valid and that the proposed state-by-state rescission repeats previously identified legal deficiencies.
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
- Water Quality Quantity
- “water stayed clear”
- “Opening these areas to roads and logging puts the water quality I depend on directly at risk”
- “286 municipal water intakes in watersheds containing affected roadless areas”
- “What happens on those unlogged ridges above Crescent Lake shows up in the water below”
- Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year”
- “net present value ranging from -$92 million to +$199 million”
- “Forest Service already carries a $6.9 billion maintenance backlog”
- Legal Regulatory Framework
- “Ninth Circuit reviewed that state-by-state replacement and found it wanting”
- “Tenth Circuit held... we REVERSE the district court's order”
- “found the 2001 rule within the authority Congress granted under the Organic Act and MUSYA”
- “explain how this proposal avoids the legal deficiencies identified the last time this path was tried”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal