In short: The comment documents that the agency's proposal to rescind the Roadless Area Conservation Rule contains internal contradictions regarding wildfire ignition data, economic net benefits, and small entity impacts, and requests that the agency reconcile these discrepancies and weigh specific reliance interests in the Cleveland National Forest before proceeding.
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
- “I hike the Cleveland and Angeles National Forests for peace and recreation”
- “views near the Pacific Crest Trail from Eagle Peak”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- Environmental Protection Biodiversity
- “acorn woodpeckers I watch flying between snags in burn scars”
- “lush forest and stream habitat of Pine Creek”
- “Opening these places to road construction would change what they are”
- “unroaded habitat in the Cleveland National Forest”
- Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition data in its own draft environmental impact statement”
- “fire-adapted landscape”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “Cost Benefit Analysis the agency produced projects $5.2 to $11.4 million a year in timber revenue”
- “existing road system already carries a $6.9 billion maintenance backlog”
- “net present value ranging from -$92 million to +$199 million”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest