Campaign — One letter sent by 10 or more people, copied or lightly reworded. This comment stands for 559 submissions in its group. See the letter, its submissions and topics.
Scored as the letter — The shared letter of a family, scored once for everyone who sent it.
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
- Wildlife Habitat
- “Roads fragment wildlife habitat”
- “provide habitat for many threatened and endangered native species”
- “provide important migration corridors”
- Water Quality Quantity
- “Roads threaten high-quality streams and rivers”
- “Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife”
- “increase the risk of landslides that suffocate streams and rivers”
- Recreation Tourism Public Use
- “Roadless areas provide for recreation, like camping, hiking and backpacking”
- “hunting and angling, wildlife viewing and photography”
- “Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas”
- Forest Management Wildfire
- “More roads will result in more human-caused fires in the backcountry”
- “60 percent of human-caused fires... are ignited within 1/8-mile of the nearest road”
- “95 percent are ignited within 1/2-mile”