In short: The comment establishes that the proposed rescission of the Roadless Area Conservation Rule contradicts the agency's own fire science data (DEIS Table 21) and cost-benefit analysis, fails to address the legal deficiencies identified by the Ninth Circuit in prior state-by-state attempts, and ignores the statutory authority upheld by the Tenth Circuit under the Organic Act and Multiple-Use Sustained-Yield Act.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Analytical gap, Evidence, Legal.
Standard dismissals it defeats
- 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.
- 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.
- 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.
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.
- 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.
Topics
- 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”
- “Opening that landscape to new roads in the name of fuels management contradicts the agency's own ignition data”
- Wildlife Habitat
- “home to bull trout, Oregon spotted frog, northern spotted owl, white-headed woodpecker, redband trout, and elk”
- “largest intact temperate rainforest left on Earth”
- “over 12,930 miles of salmon-producing streams”
- Water Quality Quantity
- “depends on the water, recreation, and resources that forest provides”
- “Nine municipal watersheds are named in DEIS Table 2”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapRequest