In short: The comment establishes the commenter's standing as a public lands user, community member, and business owner with intimate knowledge of specific roadless areas in Inyo County (including Yosemite, Bridgeport, Lee Vining, Mammoth, Bishop, Big Pine, and Lone Pine), and documents opposition to the rescission of the Roadless Rule based on local ecological values and wildfire risk data.
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
- Environmental Protection Biodiversity
- “wildlife habitat and connectivity, sensitive/endangered/threatened species, invasive species, biodiversity”
- “pristine place that should remain untouched”
- “biodiversity conservation”
- “cumulative loss and fragmentation of roadless landscapes”
- Forest Management Wildfire
- “96.2% of fires start within 800 meters of a road”
- “more roads mean more fires”
- “Wildfire risk reduction should not be used as a blanket justification”
- “Effective fire management should prioritize strategic, science-based, site-specific treatments”
- Water Quality Quantity
- “clean water”
- “clean water protection”
- “soil erosion”
- Recreation Tourism Public Use
- “recreation access”
- “solitude and landscape connectivity”
- “public lands user”
- “visiting a loved one who is always there”
What it names
- Roadless areas
- Aurora CraterCoyote NorthGlass MountainIndependence CreekLaurel McgeeLog Cabin SaddlebagMono CratersMt. HicksRock CreekSan JoaquinSoldier CanyonTioga LakeWheeler Ridge
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal