Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.
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
- Wildlife Habitat
- “concerned about wildlife habitat and landscape connectivity”
- “Roads can fragment habitats, hurting animal behavioral patterns”
- “rich ecosystems that have innumerable benefits”
- Water Quality Quantity
- “concerned about clean water and healthy watersheds”
- “Runoff from poorly managed roads can significantly damage ecosystems”
- “affect habitats, leading to the death of animals and plants”
- Recreation Tourism Public Use
- “connection to National Forest lands includes hiking and backpacking and camping”
- “opportunities for people to learn about and appreciate nature”
- “value its immense beauty - towering mountains, snow-capped, pristine alpine lakes”
- Governance Policy Process
- “urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule”
- “select the No Action Alternative”
- “How would USDA ensure that roadless values are protected through individual forest plans”