In short: The comment places on the record specific deficiencies in the agency's analysis regarding wildfire ignition density (citing DEIS Table 21), grizzly bear mortality risks (citing the federal grizzly recovery plan), and small entity economic impacts (citing the Cost Benefit Analysis), while requesting the adoption of a 'no action alternative' to preserve the 2001 Roadless Rule.
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
- “Challenging myself with survival in the wild is an instrumental part of my fulfilled life”
- “I walk the wilderness to connect with my innermost human spirit”
- “I do not want to be among the last Americans to experience wilderness”
- “I strongly advocate for a formal, affirmative policy for wilderness areas of 'Keep it Wild'”
- Water Quality Quantity
- “form the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco”
- “drinking water for communities across New Hampshire, Vermont, and Massachusetts”
- “Roads change what a watershed delivers downstream”
- “explain to the communities drawing from these headwaters what standard it applied”
- Wildlife Habitat
- “increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality”
- “shooting, habituation and food reward all increase with the use of even secondary unpaved roads”
- “contributes the western extension of the largest intact temperate ecosystem in the world”
- 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”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “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 placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal