In short: The comment documents the commenter's support for the No Action alternative, citing specific scientific literature to argue that rescinding the Roadless Rule would cause unmitigated significant impacts on 45 million acres of backcountry, violating NEPA mitigation requirements.
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
- Environmental Protection Biodiversity
- “protect large, relatively intact blocks of habitat”
- “conserve biological diversity”
- “maintain native plant and animal communities”
- “reduce habitat fragmentation”
- Wildlife Habitat
- “provide important habitat for our threatened, endangered, and sensitive species”
- “preserve intact ecosystems, wildlife movement corridors”
- “maintain an important network of relatively undisturbed habitat”
- “serve as a refuge for native species”
- Recreation Tourism Public Use
- “outdoor recreation”
- “opportunities for recreation and solitude”
- “Outdoor recreation is a crucial part of our country's economy”
- Water Quality Quantity
- “clean drinking water”
- “watershed functions”
What it names
- Works cited
- 10.1126/science.1138141U 2001
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal