In short: The comment documents that the agency's DEIS data (Table 21) contradicts the rescission's wildfire rationale by showing higher ignition densities on roaded lands, identifies an internal inconsistency in the small-business impact certification, and asserts a specific reliance interest in the protection of the Smith Umpqua, Hardesty Mountain, and Fairview roadless areas.
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
- Forest Management Wildfire
- “building roads into our forests will increase the risk of human-caused wildfires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- Recreation Tourism Public Use
- “places I visit on a regular basis to camp, hike, and bird watch”
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- Environmental Protection Biodiversity
- “cut down and destroy more of our forests and habitat for wildlife”
- “attack on our forests”
- “Leave our forests alone”
- Legal Regulatory Framework
- “Under the legal standards governing agency change of course, that kind of reliance must be identified and weighed”
- “The agency should withdraw the small-business certification”
- “reconcile the rescission with the ignition data in its own DEIS”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequest