Campaign — One letter sent by 10 or more people, copied or lightly reworded. This comment stands for 10 submissions in its group. See the letter, its submissions and topics.
Scored as the letter — The shared letter of a family, scored once for everyone who sent it.
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
- Water Quality Quantity
- “Watersheds, streams, rivers wetlands and aquiters and everything inbetween MUST be protected”
- “The Roadless Rule protects the watersheds of many of our National Wild and Scenic Rivers”
- “rivers that flow from the roadless areas into reservoirs are an important source of high-quality water for downstream communities and farms”
- Wildlife Habitat
- “important refuge for threatened and endangered fish, wildlife, and plants”
- “protect our wild places for recreation, fish and wildlife habitat”
- “For the health of the people, domesticated animals, wild animals and the environment at large”
- Recreation Tourism Public Use
- “provide outstanding opportunities for outdoor recreation in a primitive setting”
- “hiking, backpacking, whitewater boating, mountain biking, and even motorized recreation on existing legal trails”
- “The Roadless Rule does not limit public access”
- Forest Management Wildfire
- “It is not true that roadless areas increase wildfire threats”
- “Roads – not roadless areas – are a primary source of wildfire starts”
What it names
- Roadless areas
- Middle ForkSouth Fork