In short: The comment establishes that the agency's draft EIS contains internal contradictions regarding fire risk and economic benefits, and fails to provide necessary projections for water quality, biodiversity fragmentation, and big game populations across the 40.1 million acres affected by the proposed rescission.
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
- “Mammals are what bring me into the backcountry”
- “gray wolf, moose, Canada lynx, and black bear”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk survival rates increased during a road closure”
- Water Quality Quantity
- “Water is the most integral resource for the entire world”
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “roads and their facilities can produce up to 90 percent of the sediment”
- “protecting headwaters that flow to both the Atlantic and the Gulf”
- Economic Impact Fiscal
- “The economics do not hold together either”
- “timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year”
- “agency is already $6.9 billion behind on maintaining the roads it has”
- “A range that includes a $92 million loss does not establish a net benefit”
- Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “The proposal moves toward more roads, not fewer, while citing fire risk as a driver”
- “ignition density data reported in its own DEIS Table 21”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest