In short: The comment documents specific deficiencies in the agency's analysis regarding prior Ninth Circuit and Tenth Circuit rulings, inconsistent economic findings regarding small entities and recreation benefits, and the failure to weigh stated reliance interests, while identifying specific California roadless areas and water intakes affected by the proposed 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
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
- Environmental Protection Biodiversity
- “Any old growth forest is something I would call sacred”
- “keep the national rule that protects them”
- “opposing the rescission of the 2001 Roadless Area Conservation Rule”
- Legal Regulatory Framework
- “Ninth Circuit struck it down”
- “Tenth Circuit found the 2001 rule was within the authority Congress granted”
- “explain why this action survives the statutory authority analysis”
- Water Quality Quantity
- “1,034 municipal water intakes sit in watersheds containing affected roadless areas”
- “communities whose water supply depends on intact roadless watersheds”
- Economic Impact Fiscal
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “People who make their living guiding others into these forests”
- “withdraw the small-business certification”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal