In short: The comment documents specific local hazards in the Kaibab National Forest and Grand Canyon region, citing the 2025 Dragon Bravo Fire and subsequent Bright Angel Canyon flash floods as evidence that rescinding the 2001 Roadless Rule would exacerbate wildfire risk and soil erosion.
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 the fragile ecosystems surrounding Grand Canyon National Park”
- “irreversible environmental harms that can never be undone”
- “strip-mining the roadless protections... will inevitably lead to severe soil erosion”
- “Roadless areas serve as a vital buffer zone for wildlife corridors”
- Water Quality Quantity
- “prioritize landscape-scale conservation and watershed protection”
- “severe soil erosion into vital municipal and ecological streams”
- “denuded landscapes cause immediate, lethal debris flows”
- “elevated hydrologic risks”
- Recreation Tourism Public Use
- “visit, hike, and deeply enjoy these protected wild areas”
- “I want that exact same opportunity to exist for future generations”
- “quiet, remote, and backcountry recreation values”
- “protect the fragile ecosystems... for hikers alike”
- Forest Management Wildfire
- “repealing the Roadless Rule actually increases the risk of wildfire starts”
- “Industrial logging roads do not stop modern megafires”
- “catastrophic Dragon Bravo Fire charred nearly 150,000 acres”
- “climate-resilient infrastructure and emergency systems”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal