Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.
In short: The comment documents that the proposed repeal of the Roadless Rule would cause irrevocable environmental and economic harm, including increased fire risk, flooding, and loss of visitor spending, and requests the rescission of the proposal in favor of a strengthened rule that eliminates logging and grazing loopholes and restricts motorized use.
Scored as the letter — The shared letter of a family, scored once for everyone who sent it.
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 Analytical gap, Evidence, 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
- Tribal Sovereignty
- “violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty”
- “government-to-government consultation with affected Tribes”
- “sacred sites and ancestral homelands”
- “treaty-reserved rights”
- Environmental Protection Biodiversity
- “327 ESA-listed species and 71 critical habitats would be negatively impacted”
- “irrevocable devastation it would cause”
- “destroys habitat”
- “sustain ecosystems Tribal Nations have relied on for generations”
- Forest Management Wildfire
- “could actually increase fire risk”
- “More roads will result in more human-caused fires in the backcountry”
- “Agencies already have authority to manage fuels and fight fires in roadless areas”
- “Livestock grazing spreads invasive grasses that exacerbate wildfires”
- Water Quality Quantity
- “pollutes clean water”
- “drinking-water sources”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestAlternative