In short: The comment establishes that the DEIS for the Big Laurel Branch Addition in the Cherokee National Forest, Tennessee, is deficient because it lacks quantified sediment yield modeling for road construction scenarios, and it requests the Department retain the Rule and reject the rescission proposal.
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
- Water Quality Quantity
- “These lands filter my water”
- “quantified sediment yield modeling for every road construction scenario”
- “32 million acres... high or very high importance for drinking water”
- “Roads can transform slower subsurface flow to rapid surface flow”
- Environmental Protection Biodiversity
- “preserve the wildlife and ecosystems I rely on”
- “one-quarter (24%) are threatened with extinction”
- “Decreased habitat connectivity has numerous well-documented effects on freshwater fish populations”
- “retention of the Rule to protect natural world”
- Forest Management Wildfire
- “limit wildfires that could kill, maim, or otherwise ruin the lives”
- “heat, water, fire, my landscape changing”
- “breaking a working part of a system that's already strained”
- Recreation Tourism Public Use
- “Every major milestone in my life has happened in nature”
- “playing in streams as a child”
- “learning how to forage when money was short”
- “The awe and majesty of the natural world seeps into every part of me”
What it names
- National Forests
- Cherokee National Forest
- Roadless areas
- Big Laurel Branch Addition
- Works cited
- 10.1029/95wr0349310.1038/s41586-024-08375-z10.3133/sir20235132
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal