Opposes rescissionA0 noneSubstance 5/24Posted September 12, 2026 On Regulations.gov
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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Remain Roadless
The USDA rescinded the 2001 Roadless Rule, opening 45 million acres of our healthiest, intact forests to commercial logging and timber companies; a decision across 35 states that cuts deep in this administration’s ongoing death by a thousand cuts public lands management.
Our forests protect watersheds, retain snowpack, filter air and water, and hold wildlife biodiversity that is the very character of the American West. Healthy forests are synonymous with healthy rivers here in Colorado, especially as we endure our 26th year of megadrought.
Shall we trust commercial logging to responsibly manage Alaska’s Tongass NF and her stunning cycle of life in salmon and 800 year old growth? How about New Mexico’s Upper Gila River headwaters - the southwest’s last wild river, and home to endangered Gila Trout, the Southwest willow flycatcher, and 330 native wildlife species? What of Greater Yellowstone’s massive elk migration?
This ruling fails to see the intrinsic value of wild forest and intact animal and plant communities in a natural cycle of life. For our part, we hike, climb, hunt, fish, camp, and steward the timeless dance of life through seasons. Don’t break the cycle.
Subsidizing commercial logging while propping up more motorized recreation invites more wildfire and degrades the wild character of our wildest remaining forests. Keep the Roadless Rule, bring back the 6,000 furloughed USFS employees, and let the USFS manage our forests using good science.
Dave Showalter, conservation photographer and author focused on the American West.