In short: The comment places on the record specific IUCN-CMP threat data for the Carolina Northern Flying Squirrel in the Bearwallow Inventoried Roadless Area, Pisgah National Forest, and cites peer-reviewed studies demonstrating that road construction causes habitat fragmentation, noise pollution, and population declines, thereby establishing a basis for opposing the rescission of the 2001 Roadless Area Conservation Rule.
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
A2 moderate: Hard to dismiss — it shows cause and effect.
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.
- 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.
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.
- 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
- “flora, fauna, and migratory species allowed to flourish”
- “Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus)”
- “decline in bird abundance and almost complete avoidance by some species”
- “Mammal and bird population densities declined with their proximity to infrastructure”
- Cultural Heritage Indigenous
- “As a Native American I consider this land part of my heritage”
- “This land should remain protected”
- “basis of my opposition to the proposed rescission”
- Environmental Protection Biodiversity
- “should never be open to logging, mining, or any destruction”
- “intact, unroaded condition of Bearwallow is the functional mechanism”
- “direct loss of habitat (by the conversion of the original land cover into an artificial surface)”
- “fragmentation of an ecosystem into smaller and more isolated patches”
- Public Health Wellbeing
- “valuable to my healing as someone diagnosed with PTSD”
- “values getting out into country that hasn't been made easy to access”
What it names
- National Forests
- Pisgah National Forest
- Roadless areas
- Bearwallow
- Works cited
- 10.1002/ece3.1049Benítez-López et al. 2010Ware et al. 2013
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: Analytical gapEvidenceLegal