In short: The comment documents the absence of environmental justice screening in the Draft EIS for a rule affecting 44.7 to 58 million acres, cites specific noise pollution data from Buxton et al. (2017) regarding protected areas, and requests a dedicated Environmental Justice section under NEPA 42 U.S.C. § 4332(2)(C) for communities near roadless areas in the Wasatch-Cache National Forest.
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, 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
- Climate Carbon Storage
- “quiet contribution to forest carbon retention”
- “rescission misses it anyway”
- “follow climate as I do”
- Wildlife Habitat
- “natural beauty and wildlife of this area deserves the utmost respect and conservation”
- “decrease in wildlife in an already dwindling population”
- “local wildlife areas be potentially threatened”
- Recreation Tourism Public Use
- “enjoying the wilderness right in my backyard”
- “lose access to isolated get-away locations”
- “Quiet, undeveloped recreation on roadless lands supports local economies”
- Governance Policy Process
- “Complete Absence of Environmental Justice Screening Methodology”
- “NEPA's hard-look mandate”
- “I request a dedicated Environmental Justice section”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence