In short: The comment documents specific deficiencies in the agency's analysis regarding wildfire risk, economic net benefit, and legal authority, citing the agency's own records and Tenth Circuit precedent to argue that the rescission of the Roadless Area Conservation Rule is inconsistent with the protection of specific species, water supplies, and statutory mandates in the Monongahela and Ocala National Forests.
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
- Wildlife Habitat
- “signs of wildlife are signs of a healthy ecosystem”
- “West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, and the northern long-eared bat”
- “Red-cockaded woodpeckers recovered there from 7 breeding pairs to 98 family groups”
- “Florida scrub-jay, found nowhere else on the planet, depends on surrounding scrub that roads would break apart”
- Water Quality Quantity
- “protecting headwaters that feed the Potomac and the drinking water of Washington, D.C.”
- “sits directly on top of the Floridan Aquifer”
- “Alexander Springs pumps 80 million gallons of crystal-clear water per day”
- “road construction a direct contamination pathway to the drinking water supply”
- 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”
- “far higher fire density on roaded land than inside the affected roadless areas”
- “I do not understand how opening these forests to new roads reduces fire risk”
- Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning -$92 million to +$199 million”
- “agency is already $6.9 billion behind on maintaining the roads it has”
- “How does expanding a road system already carrying a $6.9 billion maintenance backlog serve the public interest”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestAlternativeLegal