In short: The comment documents that the agency's proposal to rescind the Roadless Rule fails to reconcile its wildfire management rationale with DEIS Table 21 data showing higher fire density on roaded lands, does not address prior legal deficiencies in local-rule approaches, improperly requests comment on out-of-scope plan amendments, and fails to quantify carbon storage impacts or account for water quality pressures in Utah's roadless watersheds.
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
- Environmental Protection Biodiversity
- “displace wildlife and wreck havoc on the immediate ecosystem”
- “logging harm streams, decrease fish”
- “preserve roadless values”
- Forest Management Wildfire
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile this proposal with the ignition data in DEIS Table 21”
- “fire density on roaded land than inside the affected roadless areas”
- Water Quality Quantity
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “Opening these watersheds to roads and timber operations adds pressure”
- “Colorado River allocation debate is already putting water in this region at serious risk”
- Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “quantify the change in carbon storage and sequestration”
- “roughly 0.9 billion metric tons”
What it names
- National Forests
- Dixie National Forest
- Roadless areas
- Bear Valley PeakBunker CreekLava BedsMineral CanyonTimbered Cinder Cone
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest