In short: The comment establishes that the agency's DEIS data contradicts the wildfire rationale for rescinding the Roadless Rule, identifies a record gap regarding reliance interests and small business impacts, and requests the retention of the 2001 Roadless Area Conservation Rule to protect jaguar corridors and water quality in the Coronado National Forest.
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 Analytical gap, 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
- Wildlife Habitat
- “corridors connecting the sky islands”
- “Jaguars have been documented crossing”
- “Elegant trogon, Mexican spotted owl, Gould's turkey, Arizona treefrog, ocelot”
- “connective tissue has not been cut”
- Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land”
- “agency's own data runs directly contrary to that logic”
- “quantify the expected increase in human-caused ignitions”
- Water Quality Quantity
- “739 municipal water intakes sit in watersheds containing affected roadless areas”
- “economic consequences of degrading those watersheds”
- “drinking-water sources”
- Economic Impact Fiscal
- “lost recreation benefit at a minimum of $6.1 million a year”
- “concentrated harm on the small businesses actually operating in these forests”
- “withdraw its small-entity certification”
- “outfitters, guides, and tour operators actually holding permits”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequest