In short: The comment documents that the agency's draft EIS and Cost Benefit Analysis contain internal contradictions regarding wildfire risks, economic net benefits, and small business impacts, and requests that the agency reconcile these findings, withdraw its regulatory flexibility certification, and weigh reliance interests before rescinding the Roadless Area Conservation Rule.
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
- Recreation Tourism Public Use
- “put that experience, and the land that makes it possible, at serious risk”
- “Additional roads in this area would interrupt the beauty and flow of the trail”
- “recreation losses of at least $6.1 million a year”
- “outfitters, guides and tour operators as affected”
- Forest Management Wildfire
- “undercuts the wildfire rationale offered for this rescission”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in DEIS Table 21”
- “far higher fire density on roaded land than inside the affected roadless areas”
- Wildlife Habitat
- “Bear habitat in these forests also carries documented sensitivity”
- “increased contact and conflict from open roads can ultimately end in grizzly mortality”
- “shooting, habituation and food reward all increase with the use of even secondary unpaved roads”
- Economic Impact Fiscal
- “The economic case for rescission is no stronger”
- “net present value ranging from negative $92 million to positive $199 million”
- “Forest Service road system already carries a $6.9 billion maintenance backlog”
- “action whose own Cost Benefit Analysis cannot establish a net benefit”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal