In short: The comment establishes that the agency's analysis fails to account for net benefits as required by Executive Order 12866, while documenting specific economic losses from logging, threats to water quality in Southern California, and the increased wildfire risk associated with road construction.
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 Analytical gap, 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
- Recreation Tourism Public Use
- “climbed 140 peaks over 5000 feet”
- “43,000 miles of trails, 11,000 climbing routes, and 1,000 whitewater rafting runs”
- “Tourism would suffer, when people no longer visit former roadless areas that have been spoiled”
- Water Quality Quantity
- “most of our water supply originates in these Roadless Areas”
- “high quality water is essential to the success of businesses”
- “Opening these Roadless Areas to roadbuilding or mineral development threatens this clean water”
- Economic Impact Fiscal
- “USFS spent $388 million on its Forest Products program and only collected $41 million in receipts”
- “Tongass Forest logging program cost US taxpayers $1.73 billion”
- “Roadless lands generate a net benefit estimated to be $24 billion a year”
- Forest Management Wildfire
- “Roads are ignition corridors! 89% of wildfires nationally are human-caused”
- “The 2001 Roadless Rule DOES allow fuel treatments”
- “Fix what has already been built, before you build more roads”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal