In short: The comment documents that the agency's proposed rescission fails to quantify specific permitting burdens not addressed by existing exceptions, ignores reliance interests and municipal water intake data, and contradicts its own DEIS data regarding human-caused wildfire ignition densities in 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
- Recreation Tourism Public Use
- “Hiking and camping is one of the most important and meaningful ways my family and I connect”
- “It disturbs me to my core to think this forest could be stripped of its wilderness”
- “To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences”
- Wildlife Habitat
- “habitats of living creatures paved over”
- “The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander”
- “Road access will not leave any of this intact”
- Water Quality Quantity
- “protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C.”
- “polluted with runoff from roads”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “The agency claims new road access will reduce wildfire hazard. Its own numbers say the opposite”
- “I ask that the agency quantify the expected increase in human-caused ignitions from new road access”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest