In short: The comment documents the commenter's personal use of specific National Forest locations in Oregon (Columbia Gorge, White River Sno Park, Cinder Hill, Lost Lake) and cites the Federal Register notice (90 FR 42179) to argue that the proposed rescission of the Roadless Rule contradicts its stated wildfire mitigation purpose and threatens local recreation and natural resources.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Legal.
Standard dismissals it defeats
- 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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
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.
- 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.
- 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.
Topics
- Environmental Protection Biodiversity
- “created shelter for wildlife”
- “natural beauty for the next generation”
- “protect these lands because there is so little left to protect”
- “destroying one of the most photographed spots in Oregon”
- Recreation Tourism Public Use
- “I recreate in these areas that you want to log and mine”
- “snowshoe White River Sno Park every year”
- “camping at Cinder Hill campground”
- “annual girl glamping trip to Lost Lake Resort”
- Resource Development Extraction
- “opening up our National Forests to logging, mining, and other destructive pillaging”
- “Mining these USFS lands for oil or gas is also ridiculous”
- “sell our public lands to the highest bidders to pillage”
- “cut our last tree and mined our last well”
- Forest Management Wildfire
- “clear cuts... are just creating even more kindling”
- “drying out our soil and air by removing the trees”
- “contradict your purpose to rescind the Roadless Rule, the idea that it would prevent wildfires”
- “increasing its already high risk of rockslides”
What it names
- Roadless areas
- Lost Lake
- Law cited
- 90 FR 42179
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal