In short: The comment establishes that the rescission proposal conflicts with the agency's own data in DEIS Table 21 regarding fire density, fails to quantify specific management burdens not covered by existing exceptions, and improperly certifies no significant impact on small entities by using national averages rather than local data for the Dixie National Forest.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Analytical gap, Evidence, Legal.
Standard dismissals it defeats
- 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.
- 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.
- 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.
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.
- 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.
Topics
- Wildlife Habitat
- “birds I watch and the elk I look for depend on unroaded habitat”
- “bird richness declines with road presence”
- “elk avoid areas near roads and select habitat away from them”
- “less wildlife remain”
- Forest Management Wildfire
- “risk of vehicle-caused wildfire grow”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in its own DEIS Table 21”
- “More roads mean... more fire risk”
- Water Quality Quantity
- “Boulder Mountain is the source of the water for the well that serves my home”
- “1,466 municipal water intakes sit in watersheds containing affected roadless areas”
- “drawn my water from a well fed by Boulder Mountain”
- Economic Impact Fiscal
- “books lost recreation benefit at a minimum of $6.1 million a year”
- “certifies no significant impact on small entities”
- “economic stakes for the specific businesses and communities tied to these places are not captured by a national average”
- “outfitters, guides and tour operators as affected”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest