In short: The comment documents that the proposed rescission of the Roadless Area Conservation Rule fails to adequately evaluate environmental consequences for the Rough Creek Roadless Area, specifically citing insufficient analysis of wildfire risk mitigation, wildlife habitat (Pinyon Jay and Bi-state Sage Grouse), and erosion, while urging the withdrawal of the proposal and the preparation of a Biological Opinion.
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 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
- Wildlife Habitat
- “critical area for the Bi-state Sage grouse”
- “Repealing the Roadless Rule would be a calamity for many endangered and sensitive species”
- “Pinyon Jay (Federal Register Document Number 2023-17726)”
- “Bi-state Sage Grouse have been confirmed nearby”
- Recreation Tourism Public Use
- “The attraction for me was that it is roadless”
- “Being able to explore roadless areas on foot or horseback or mule back is an American right”
- “We do NOT want to share all roadless areas with wheeled conveyences, bikes, or motorized vehicles”
- “exceptional opportunities for wildlife, solitude, adventure”
- Water Quality Quantity
- “Any new roads would be in very steep country and be highly subject to erosion”
- “Any attempt to repeal the roadless act must take into full consideration the watershed, fisheries, and wildlife”
- “environmental consequences to... erosion”
- Forest Management Wildfire
- “Punching in roads to decrease wildfire risk across the Rough Creek Roadless Area would be counter effective”
- “increase the chance of fire ignition as many “fire builder” people like to camp and recreate in this area”
- “fire control (to name a few) have not been fully evaluated”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternativeLegal