In short: The comment documents specific deficiencies in the agency's small-business impact analysis and requests site-specific environmental consequence disclosures for six named roadless areas in the White Mountain National Forest, citing agency data on water quality, sediment, and wildfire risk to support the need for an alternative retaining the 2001 rule's protections.
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, 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.
- 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
- Wildlife Habitat
- “We have seen bobcats, bears, fishers, otters, moose, porcupines”
- “wildlife is free to live undisturbed”
- “The absence of roads PROTECTS the forest and wildlife”
- “unfragmented woodlands and the wildlife inhabiting them”
- Water Quality Quantity
- “More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas”
- “24 million Americans drink water that starts there”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
- “Fewer than 12 percent of those watersheds have impaired streams today”
- Recreation Tourism Public Use
- “We hike the land, paddle the waters, leaving only footprints”
- “This is true wilderness and must remain so”
- “lost recreation benefit at a minimum of $6.1 million a year”
- “small outfitters and guides who work this same country”
- Governance Policy Process
- “The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule”
- “It has held none to undo it”
- “I ask that the agency disclose and analyze the site-specific environmental consequences”
- “I ask that the agency respond in the record to each of the issues raised”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceRequestLegal