In short: The comment places on the record the specific geographic locations of the Graveyard Ridge, Sam's Knob, Cheowah Bald, Wesser Bald, and Tusquitee Bald roadless areas in North Carolina, documenting their recreational use and the commenter's personal connection to these specific sites.
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
- Environmental Protection Biodiversity
- “different species of plants, including ephemerals”
- “Roads are a vector for invasive species”
- “construction will damage the biodiversity”
- “degrade what brings people to these areas”
- Recreation Tourism Public Use
- “hiked the Graveyard Ridge area”
- “enjoy these places as they are now”
- “generations to come can experience them too”
- “accessible and used by many people”
- Forest Management Wildfire
- “Roads are also where most human-caused fires start”
- “rescinding the roadless rule will do more to cause fires than prevent them”
What it names
- National Forests
- Nantahala National Forest
- Roadless areas
- Tusquitee BaldWesser Bald
- Works cited
- 10.1016/j.biocon.2012.10.00810.1111/ddi.7000210.1111/oik.1107510.1186/s42408-026-00450-2
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal