In short: The comment documents that rescinding the Roadless Rule in the Shawnee National Forest would increase wildfire risk by contradicting Forest Service prescribed burning initiatives and degrade drinking water quality in the Ohio and Mississippi watersheds, while fragmenting critical recreational and ecological areas in Southern Illinois.
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
- “uncontrolled fire outbreaks are more common in forests with logging and roads”
- “Rescinding the roadless rule would result in a higher probability of wildfires”
- “directly contradicting the current initiatives of the Forest Service to reduce uncontrolled fires”
- Water Quality Quantity
- “excess pollution from the resulting work sites and water runoff on bare ground”
- “directly impact the drinking water quality for thousands of people”
- “within the watersheds of the Ohio and Mississippi river”
- Environmental Protection Biodiversity
- “Building roads would further fragment the forested ecosystems”
- “protect what little forests and remote areas we have left”
- “high environmental and cultural value”
- Recreation Tourism Public Use
- “I personally enjoy hiking and climbing”
- “high value of the remoteness of these wilderness areas”
- “ruined by the construction of roads within them”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest