In short: The comment places on the record specific evidence that the Medicine Bow–Routt National Forest in southeastern Wyoming contains critical elk habitat and recreation resources protected by the Roadless Rule, and argues that rescinding the rule is financially impractical and does not reduce wildfire risk.
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
- Recreation Tourism Public Use
- “escape the noise and recreate on my undisturbed public lands”
- “allow every outdoor recreation opportunity you can think of”
- “outstanding hiking, climbing, backcountry skiing, and technical mountaineering”
- “15 miles of hiking trails on long weekends for backpacking trips”
- Wildlife Habitat
- “The best elk habitat is inside the Roadless boundary”
- “Moose, elk, and deer are abundant here”
- “about 58 percent of the current elk range is on land protected by the Roadless Rule”
- “important wildlife and wildfire management/mitigation activities”
- Forest Management Wildfire
- “Claims that rescinding the Roadless Rule is required to reduce wildfire risk are unfounded”
- “The rule already permits fuel‑reduction treatments”
- “wildfire ignitions occur roughly four times more frequently near roads”
- “support active, science‑based forest management to improve wildfire resilience”
- Economic Impact Fiscal
- “The Roadless Rule is also practical financially”
- “carries roughly $10.8 billion in deferred maintenance”
- “Adding more roads and long‑term upkeep would only increase those costs”
- “fixing the financial crisis our country is approaching with $40 trillion of national debt”
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal