In short: The comment documents opposition to the rescission of the 2001 Roadless Area Conservation Rule in Montana, asserting that the agency failed to explain why existing authorities are insufficient and requesting the retention of the rule to protect recreation, water, and wildlife.
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
A0 none: Counted, not answered.
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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
- 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
- “public lands are central to our communities, outdoor recreation, and local economy”
- “Intact forests provide places to bike, hike, ski, and experience the outdoors”
- “permanently change the character of backcountry trails”
- “communities that depend on outdoor tourism”
- Environmental Protection Biodiversity
- “protecting clean water, wildlife habitat, and the landscapes”
- “Roads and logging can fragment habitat, increase erosion”
- “evaluate the long-term and cumulative effects on watersheds, wildlife”
- Water Quality Quantity
- “protecting clean water”
- “increase erosion”
- “evaluate the long-term and cumulative effects on watersheds”
- Forest Management Wildfire
- “I recognize the need to address wildfire risk and forest health”
- “explain why existing management authorities and exceptions are insufficient”
- “consider targeted alternatives that preserve roadless protections”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapRequestAlternative