In short: The comment establishes that rescinding the 2001 Roadless Rule would permit road construction and ground disturbance in the Linville Gorge Addition of the Pisgah National Forest, which the commenter argues would fragment habitat and degrade water quality, while also documenting a discrepancy between Forest Service testimony and GIS data regarding the proximity of roadless areas to the Wildland-Urban Interface.
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 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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
- 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
- “waterfalls, rivers, and streams are a vital part of life”
- “national forests supply drinking water to at least 124 million people”
- “Roads are a major cause of water pollution”
- “protects these headwaters, it is vital for maintaining clean drinking water”
- Wildlife Habitat
- “hundreds of species of wildlife here”
- “fragment habitat, introduce disturbance, and eliminate roadless character”
- “Without wildlife, bees, running water like rivers, streams and waterfalls, we are extinct”
- “Clearing hundred year old trees and native wild flowers that help evolution is the dumbest thing”
- Environmental Protection Biodiversity
- “These mountains and forests are ALIVE and well, and they do not need human hands disturbing them”
- “Nature is not to be messed with”
- “jeopardizes 44.5 million acres of undeveloped backcountry forestland”
- “Twenty-five years is a long time for a rule to survive legal challenge and still be standing. That durability means something. Keep it.”
- Governance Policy Process
- “A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres”
- “The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction”
- “calling it 'our primary concern'”
- “Less than 5% of inventoried roadless area acreage is in close proximity to the WUI”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal