In short: The comment documents that roadless areas in the Southwest Idaho Ecogroup (Boise, Payette, and Sawtooth National Forests) protect water quality and 80,000 miles of streams, and that new roads increase wildfire risk by 3x within 250m, citing specific EIS appendices and peer-reviewed studies to argue against repeal.
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 Evidence.
Standard dismissals it defeats
- 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.
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.
- 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.
- 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
- Water Quality Quantity
- “preserve water quality”
- “roadless areas have distinctly high water quality specifically because of the lack of disturbance from roads”
- “provides clean drinking water for an estimated 25 million people”
- Wildlife Habitat
- “fish habitat”
- “hunting grounds”
- “keep our uniquely wild land wild”
- Recreation Tourism Public Use
- “outdoor recreation”
- “providing a pilgrimage to wilderness for countless Americans”
- “keep these forests serving the American public”
- Forest Management Wildfire
- “building additional roads would provide more opportunities for human started wildfires”
- “ignition density is highest within 50m of roads”
- “building additional roads would merely provide additional opportunities for human caused ignition”
What it names
- Works cited
- 10.1371/journal.pwat.0000538
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisEvidence