In short: The comment places on the record a request for the agency to reconcile its economic analysis regarding timber revenue versus recreation losses and road maintenance backlogs, and to analyze an alternative retaining 2001 Roadless Rule protections for the Indian Peaks and Superior National Forest 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
- Recreation Tourism Public Use
- “fishing and hiking are excellent”
- “hiking and camping in the Indian Peaks adjacent area”
- “canoe trip with my friend and my goddaughter”
- “recreation losses of at least $6.1 million a year”
- Water Quality Quantity
- “preserve the pristine cleanliness of the watershed”
- “tragedy to put roads in such proximity to the watershed”
- “maintain the wilderness, the pure watershed”
- Wildlife Habitat
- “observed loons and a bald eagle”
- “fed birds and rodents in the wilderness”
- “maintain the... bird habitat”
- “habitat for biodiversity”
- Climate Carbon Storage
- “keeping additional carbon out of the atmosphere”
- “protecting ecosystems with large trees for their carbon stores”
- “resilience to drought and fire”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceLegal