In short: The comment documents a specific discrepancy between the agency's justification for rescinding the Roadless Area Conservation Rule and its own DEIS data (Table 21) showing higher human-caused ignition densities on roaded lands, while also identifying a failure in the regulatory flexibility analysis to properly assess impacts on local small entities and reliance interests.
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
- Forest Management Wildfire
- “more access roads could lead to more human-caused wildfires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “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”
- Water Quality Quantity
- “Clean water depends on the same land”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “Trees filter water and reduce runoff”
- Recreation Tourism Public Use
- “Camping and hiking in the Jefferson National Forest has been part of much of my life”
- “These and other roadless areas offer a place to I can feel peaceful in a hectic world”
- “I have organized my recreation, my health, and my sense of what public land is for around the protections the 2001 rule provides”
- Legal Regulatory Framework
- “The agency is obligated, under the legal standards that govern rule changes, to identify and weigh the interests described in the comments”
- “The agency must withdraw that certification and analyze the impact on the businesses actually operating where the rule would take effect”
- “I ask that it explain, plainly and on the record, why this proposal departs from those prior findings”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest