In short: The comment places on the record specific deficiencies in the agency's analysis of small business impacts, reliance interests, wildfire ignition data, and sediment delivery for the Pyramid and West Slope Winds roadless areas, citing specific DEIS tables and Federal Register pages to support requests for site-specific analysis and an alternative retaining the 2001 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
- Legal Regulatory Framework
- “small-business certification contradicts the analysis”
- “reliance interests are invited and never assessed”
- “Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests”
- “ask that the agency withdraw the certification”
- Water Quality Quantity
- “clean, free-running rivers are the whole reason I go”
- “Road sediment is quantified and then set aside”
- “skid roads... are the main cause of soil erosion”
- “quantify projected sediment delivery to the more than 7,000 municipal intakes”
- Forest Management Wildfire
- “The agency's own fire data cuts against the proposal”
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “road access could increase the number and frequency of wildfires”
- “weigh it against the claimed reduction in wildfire hazard”
- Recreation Tourism Public Use
- “I hike and camp in these areas”
- “small outfitters and guides who work this same country help people like me get out there”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “I plan trips into these areas year after year”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal