In short: The comment documents the commenter's personal use of 19 specific National Forests and cites specific pages of the DEIS (p. 87 and p. 122) to argue that the Proposed Rule's claims regarding wildfire reduction and water quality protection are unsupported by scientific evidence.
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
- Forest Management Wildfire
- “claims being made in the Proposed Rule do not hold water”
- “Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational”
- “fires are four times more likely to occur near roads than in roadless”
- “Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic”
- Water Quality Quantity
- “adequate and clean water”
- “Good water quality is also more available in IRAs because of limited disturbance”
- “Retaining the RR 'provides the greatest protection of water quality' for municipal water supplies”
- Environmental Protection Biodiversity
- “wildlife that survive and thrive in our national forests deserve to be protected”
- “cut 40% of the critical habitat for the endangered Northern Spotted Owl”
- “The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected”
- Recreation Tourism Public Use
- “hiked in, boated in, skied, and camped in a number of our spectacular national forests”
- “The true value of our natural resources... cannot be fully understood and appreciated unless one has experienced these personally”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal