In short: The comment documents that the Roadless Rule has been used to close roads and trails in 12 Mile Canyon near Gunnison, Utah, and that standing dead timber near Wolf Creek Pass remains unharvested due to roadless designations, while asserting the commenter's standing as a professional geologist, local trail coordinator, and motorized user.
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
A0 none: Counted, not answered.
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.
- 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.
Topics
- Public Land Access Rights
- “I value motorized access to our forests”
- “I am for allowing access for timber harvesting”
- “I use motorized access in a truck, a UTV, on a motorcycle to access the forest”
- “anti access groups have used the roadless rule in countless lawsuits”
- Forest Management Wildfire
- “I am for allowing access for timber harvesting as well as fire mitigation operations”
- “Active fire management requires roads”
- “observed the large amount of standing dead timber”
- “This timber could be harvested in a salvage operation”
- Governance Policy Process
- “I am for allowing local rangers to make decisions on local forests”
- “rather than one size fits all managment directives from Washington DC”
- “Repealing this rule will safe the Forest money in the long run”
- “allow for more efficient and timely management”
- Recreation Tourism Public Use
- “constructing new trails for motorized and non motorized use”
- “More recreational opportunities require roads and trails”
- “close roads and trails that were used by me and my family”
- “300 plus members of the Utah Trail Machine Association”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal