In short: The comment documents specific reliance interests in the Potosi area of the Beaverhead-Deerlodge National Forest and identifies deficiencies in the agency's analysis regarding wildfire ignition rates (citing DEIS Table 21), small business impacts (citing a $6.1 million annual loss), and the failure to weigh reliance interests in the Cost Benefit Analysis.
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
- “thrill of watching a kingfisher dip and dive”
- “hike and camp frequently in national parks, national forests, BLM lands, and wilderness areas”
- “precisely because I do not have to deal with cars or other vehicles”
- “enjoy the peace and fruitfulness of a natural ecosystem”
- Economic Impact Fiscal
- “My town's economy depends on outdoor recreation”
- “threatens both what I go out there for and the economic base of the community”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “concentrated harm to the businesses that actually operate in these specific roadless areas”
- 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”
- “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”
- “Opening these areas to road construction would bring ignition rates closer to the roaded baseline”
- Water Quality Quantity
- “1,287 municipal water intakes across the Northern region”
- “sit in watersheds containing affected roadless areas”
- “real reliance on the protections the current rule provides”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest