Opposes rescissionA0 noneSubstance 5/24Posted September 7, 2026 On Regulations.gov
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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Dear USDA Leadership:
As an angler, I don't oppose road-building everywhere. I oppose road-building in country where the rule already said no, the science still says no, and the agency hasn't shown why the answer should change. The 2001 Rule has been a quiet, working piece of policy for two decades. The Department doesn't have to do anything dramatic — just leave it in place.
Visiting the Wilson Creek and Harper Creek Wilderness Study Area is one of my favorite backpacking and fishing trips I've ever take. The remoteness was humbling.
The Harper Creek Wilderness Study Area was one of the harder, more remote hikes I'd done at the time and gave me a great appreciation for how important it is to have these kinds of places.
Regarding the Harper Creek in the Pisgah National Forest, North Carolina:
“The area remains a Wilderness Study Area despite being recommended for full Wilderness designation by the U.S. Forest Service since 1987 and having bipartisan congressional support in the 1990s. On December 16, 2001, the area was protected under the Roadless Area Conservation Rule, which designated it as an Inventoried Roadless Area comprising 7,325 acres.”
“Large-scale railroad logging commenced in the region around 1910. More significantly, the area became a major site for uranium prospecting from the 1950s through the 1970s. The North Harper Creek Prospect underwent extensive core drilling. Exploration identified uranium deposits in the Wilson Creek Gneiss, with speculative resources estimated at 4 to 8 million pounds of U₃O₈. The remoteness and expense of mining in this area is what has saved it.”
“Influence of water exchange and dissolved oxygen in redds on survival of steelhead trout embryos. Survival of embryos relates positively to dissolved oxygen and apparent velocity of intragravel water, and positively to gravel permeability and gravel size. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1961 (https://doi.org/10.1577/1548-8659(1961)90[469:IOWEAD]2.0.CO;2)”
“Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 (https://doi.org/10.1029/WR020i011p01753)”
“Water and sediment inputs are fundamental drivers of river ecosystems, but river management tends to emphasize flow regime at the expense of sediment regime. Managing for a desired balance between sediment supply and transport capacity is not only tractable, given current geomorphic process knowledge, but also essential because of the importance of sediment regimes to aquatic and riparian ecosystems, the physical template of which depends on sediment-driven river structure and function. — BioScience / Oxford Academic, 2015 (https://doi.org/10.1093/biosci/biv002)”
In earnest,
CommentID: RLC-20260906-JAUUAF