In short: The comment documents that the Draft EIS failed to include Tribal-proposed alternatives and that the current process lacks public meetings, while citing specific Forest Service data showing a 4x higher fire risk near roads to argue against the rule's rescission.
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
A2 moderate: Hard to dismiss — it shows cause and effect.
Owed an answer on Analytical gap, Evidence.
Standard dismissals it defeats
- 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.
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.
- 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.
- 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
- Water Quality Quantity
- “conserve fresh water”
- “94,000 miles of rivers are protected”
- “put the supply of drinking water for more than sixty million Americans at risk”
- Wildlife Habitat
- “Five of the eight species of western native trout rely on roadless areas”
- “Native Gila Trout use roadless areas for 99% of its habitat”
- “safe habitats and migration routes for grizzly bears, wolves, elk and mule deer”
- Tribal Sovereignty
- “robust input from the public and tribal nations”
- “The alternatives proposed by Tribal Governments were not included in the DEIS”
- “significantly alter Tribal access to treaty-reserved resources, sacred sites”
- Governance Policy Process
- “developed after a lengthy and thorough process”
- “Forest Service held 600 public hearings and received 1.6 million comments”
- “current process includes NO public meetings and an extremely short comment period”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence