In short: The comment documents that the agency's Cost Benefit Analysis fails to establish a net benefit for rescinding the Roadless Area Conservation Rule in the Angeles National Forest, specifically citing a $6.9 billion maintenance backlog, negative net present value scenarios, and an improper small entity certification that ignores local operators in California's 4,389,760 acres of roadless areas.
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, Evidence, 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
- Economic Impact Fiscal
- “fiscal case for rescission does not hold together”
- “Most logging operations run at a net loss”
- “reconcile this proposal with its own Cost Benefit Analysis”
- “expanding a road network already carrying a $6.9 billion maintenance backlog”
- Forest Management Wildfire
- “there is already a provision in the existing roadless rule that allows for forest management roads”
- “Claiming this rule change is about protecting communities from wildfire is simply not true”
- “rule as written already permits road construction necessary for public health and safety”
- “identify specifically which burdens are not already addressed by the rule's existing exceptions”
- Recreation Tourism Public Use
- “recreation losses of at least $6.1 million a year”
- “people who hike, camp, and find any contact with nature”
- “places like Arroyo Seco and Strawberry Peak”
- “lost recreation benefit”
- Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “communities served by those intakes”
- “water users”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest