In short: The comment places on the record a request to rescind the 2001 Roadless Area Conservation Rule effective 09/18/2026 and a declaration of policy citing specific sections of the Surface Transportation Reauthorization Act of 2021 (Sections 119, 134, 149, 167, 175, 176, and 202) to fund highway and tribal transportation programs.
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
- Legal Regulatory Framework
- “Requesting the Exception for the Application for the Associated land management planning process”
- “confirming the commitment by Petitioner as a cooperating agency in any environmental analysis for rule-making processes to Rescind to 2001 Roadless Area Conservation Rule”
- “Please accept this Direct Final Rule Determination and Declaration of Policy of Rule-Making policy under the Administrative Procedure Act”
- Governance Policy Process
- “Submission of voluntary Petition under the Federal Advisory Committee Act”
- “sustain the multiple use of renewable resources in perpetuity while maintaining the long term health and productivity of the land”
- “to be carried out by the Secretary of the Department of Transportation”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal