In short: The comment documents that the agency's own DEIS and Cost-Benefit Analysis contain data contradicting the proposed rescission of the Roadless Area Conservation Rule, specifically regarding bird abundance, wildfire ignition rates on roaded lands, and the net economic benefit of road construction.
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, 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
- “bird richness declines with road presence”
- “road-noise experiments... cut bird abundance by over a quarter”
- “31% of species avoiding the noise entirely”
- “degrades the habitat and the soundscape”
- Forest Management Wildfire
- “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”
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- Economic Impact Fiscal
- “net present value ranging from -$92 million to +$199 million”
- “recreation losses of at least $6.1 million a year”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- Recreation Tourism Public Use
- “I hike and camp in the 29,660 acres of inventoried roadless area”
- “smell of spruce and fir trees, the sound of woodpeckers, warblers, and chickadees”
- “outfitters, guides, and tour operators as affected parties”
- “lost recreation benefit at a minimum of $6.1 million a year”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest