In short: The comment documents specific deficiencies in the agency's analysis regarding small business impacts, reliance interests, wildfire ignition data, habitat fragmentation projections, and big game population effects for the Upper Bald River and Joyce Kilmer Slickrock Add. roadless areas, while requesting site-specific analysis and an alternative retaining the 2001 rule's protections.
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
- Wildlife Habitat
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- “watch wildlife and birds”
- Forest Management Wildfire
- “human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “road access could increase the number and frequency of wildfires”
- “fire shapes every trip I plan”
- Recreation Tourism Public Use
- “I hike and camp in these areas”
- “small outfitters and guides who work this same country”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “I plan trips into these areas year after year”
- Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “reliance interests are invited and never assessed”
- “Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests”
- “ask that the agency withdraw the certification”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal