In short: The comment places on the record a specific geographic location (Mogan Ridge, Hoosier National Forest, Indiana) and documents a deficiency in the agency's analysis where the small-business certification contradicts the DEIS findings regarding lost recreation benefits and the misapplication of national expenditure data to local outfitters.
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
A3 weak: Substantive, but easier to set aside.
Owed an answer on Analytical gap.
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.
- 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.
- 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.
- 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
- “My family likes to hike and camp in areas where the night sky is bright”
- “We like to spend time in nature an refresh ourselves”
- “Great family conversations happen here in the quiet privacy”
- “I am an amateur photographer and especially enjoy the wildlife lookouts”
- Water Quality Quantity
- “our water sources are protected an filtered through natural unpolluted ground”
- “It is vital to help protect our watershed and maintain clean water”
- “It protects against the horrible flooding caused by asphalt and concrete”
- Wildlife Habitat
- “disturbs the birds and wildlife that has been untouched since Indiana was made a state”
- “maintain clean water and the trees and wildlife native to Indiana”
- “The remoteness and wilderness is the very reason we love it so much”
- Forest Management Wildfire
- “The claim roads are needed to fight fires, when roads are the cause of 90% of fires”
- “More roads mean more fires. That's documented historical statistics”
- “I don't like to think what would have happened I dry grass nearby”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal