In short: The comment places on the record specific evidence that road construction in the Craggy Mountain area of Pisgah National Forest generates significantly more sediment than undisturbed forest, thereby threatening local drinking water supplies and aquatic habitats, and asserts that the agency's proposed rescission lacks a sufficiently developed basis to overturn the 2001 Roadless 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
A3 weak: Substantive, but easier to set aside.
Owed an answer on 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
- Water Quality Quantity
- “degrade drinking-water supplies”
- “adversely affect the water quality”
- “fresh water sources”
- “sedimentation, and stream crossings”
- Wildlife Habitat
- “destroy natural habitats”
- “disastrous for wildlife habitats”
- “diversity of the plants and rare species”
- “native habitats”
- Recreation Tourism Public Use
- “outdoor recreation is a huge industry”
- “backcountry experiences”
- “scenic vistas”
- “keep the area as natural and pristine”
- Resource Development Extraction
- “open the area to more logging”
- “advantage only the logging and mining industries”
- “open these areas to logging and mining”
- “road construction and associated ground disturbance”
What it names
- National Forests
- Pisgah National Forest
- Roadless areas
- Craggy Mountain
- Works cited
- 10.1029/wr020i011p0175310.1111/j.1752-1688.2007.00016.x