In short: The comment documents that the Gila National Forest contains approximately 730,000 acres of Inventoried Roadless Areas and cites specific statutory gaps in the 2001 Roadless Rule regarding livestock grazing and mineral claims under the General Mining Law of 1872 and FLPMA Section 204.
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
A0 none: Counted, not answered.
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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
Topics
- Environmental Protection Biodiversity
- “exposing intact wildlife habitat and watersheds to additional logging”
- “Temporary roads can cause lasting harm to wildlife habitat, soils, and watersheds”
- “displace native wildlife”
- “fragment secure habitat”
- Water Quality Quantity
- “exposing intact wildlife habitat and watersheds”
- “Livestock can damage streams and springs”
- “remove riparian vegetation”
- “harm to... watersheds”
- Forest Management Wildfire
- “protected (unroaded) forests burn at lower intensity”
- “Roads can increase human-caused fire ignitions”
- “increase human-caused wildfire risk”
- “spread invasive plants”
- Resource Development Extraction
- “mining, and fragmentation”
- “prohibit new mineral leasing within these lands”
- “withdraw Inventoried Roadless Areas from mineral entry”
- “commercial logging”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal