In short: The comment establishes that the current public comment period and lack of public meetings are insufficient for stakeholder review, and proposes a state-level rulemaking alternative for Montana as a more effective method for managing roadless areas.
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 Alternative.
Standard dismissals it defeats
- 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.
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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
Topics
- Governance Policy Process
- “Revisions to the rule should be informed by hosting public meetings and listening to local stakeholders”
- “Rescinding the rule with no public meetings and a three-to-four-week comment period is insufficient”
- “we request the Forest Service to offer a longer comment period for this DEIS, public meetings, and other forms of stakeholder engagement”
- “instead of relying on expensive and time-consuming forest-by-forest updates to Forest Plans, that the Forest Service reconsider the merits of state-level rulemaking”
- Forest Management Wildfire
- “We support forest restoration, fire risk reduction, commercial harvesting, and timber stand improvement”
- “better enable the Forest Service to increase active management in areas where it makes sense”
- “strategically modify the management of Inventoried Roadless Areas”
- Economic Impact Fiscal
- “We believe the Forest Service must be fiscally responsible in recognizing their deferred maintenance backlog”
- “the need to maintain their roads to standard”
- “help sustain the forest products industry”
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative