In short: The comment documents the commenter's opposition to the rescission of the 2001 Roadless Area Conservation Rule, citing the DEIS findings on sediment and water quality degradation and grizzly bear mortality risks, and requesting an explanation of how rescission aligns with the National Forest Management Act's multiple-use mandate and watershed protection mission.
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
- Recreation Tourism Public Use
- “quiet, uninterrupted scenery”
- “sense that natural processes can thrive”
- “enjoyment of preserved wild spaces”
- “forests I photograph and hike”
- Water Quality Quantity
- “drink water from the Willamette River”
- “protect watersheds”
- “sediment delivered to surface waters is a major source of water quality degradation”
- “clean water for people and ecosystems alike”
- Wildlife Habitat
- “banana slugs, rough-skinned newts, and garter snakes”
- “diversity of plant and animal communities”
- “increased contact and conflict from open roads in grizzly habitat”
- “grizzly mortality”
- Environmental Protection Biodiversity
- “old-growth forests”
- “conserving roadless areas was critical”
- “road construction and logging were the activities most likely to harm the characteristics and values”
- “preservation of public lands for multiple uses”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest