In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule would negatively impact specific high-use recreational areas in Utah, including Rock Canyon, Mount Timpanogos, and the Alpine Loop in the Uinta-Wasatch-Cache National Forest, and argues that the wildfire-risk rationale is unpersuasive because increased road access may increase ignition 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
- “hiking Rock Canyon and climbing Mount Timpanogos”
- “heavily used for recreation precisely because they've remained wild”
- “change the character of some of the most-visited trails in the state”
- Forest Management Wildfire
- “I don't find the wildfire-risk rationale persuasive”
- “increased road access can increase ignition risk”
- “Targeted, science-based fuel treatments can address wildfire risk”
- Environmental Protection Biodiversity
- “undeveloped, close to growing communities”
- “protects only the portion set aside specifically for its undeveloped character”
- “a value that, once roads are built, cannot be restored”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal