In short: The comment documents that the rescission of the 2001 Roadless Rule is arbitrary and capricious because it contradicts scientific evidence that roads increase wildfire risk and habitat fragmentation, while the agency lacks the personnel and maintenance capacity to manage the resulting environmental impacts.
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
A3 weak: Substantive, but easier to set aside.
Owed an answer on 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.
- 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.
- 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.
- 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
- “clean drinking water flowing from our taps originated in national forests”
- “disrupts wildlife and watersheds”
- “increases siltation and other pollution”
- “guarantee that no watersheds will be negatively impacted by rescission”
- Wildlife Habitat
- “road building fragments habitat”
- “disrupts wildlife”
- “worsens the spread of invasive species”
- “conserving roadless areas was critical because road construction and logging were the activities most likely to harm the values”
- Forest Management Wildfire
- “more roads will not reduce the risk of fire, it will increase that risk”
- “Over 80% of wildland fires are human caused, and more roads means more people”
- “wildfires are four times more likely to start in roaded areas than in unroaded areas”
- “reduction in forest service personnel will make it impossible for the forest service to manage either additional roadbuilding activities”
- Governance Policy Process
- “arbitrary and capricious action of the USDA”
- “undertake a thorough environmental analysis of roadless areas”
- “develop and share a detailed plan for addressing its current backlog of road maintenance”
- “commit to providing a transparent and complete accounting of how public comments were considered”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest