Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.
In short: The comment establishes that rescinding the Roadless Rule would permit road construction and associated ground disturbance in the Craggy Mountain area of the Pisgah National Forest, North Carolina, which would fragment habitat and eliminate roadless character.
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
- Recreation Tourism Public Use
- “Roadless country is the reason I go out there at all”
- “love taking my children to hike and explore the natural beauty”
- “enjoy no roads”
- “unspoiled terrain is what makes the view so awe inspiring”
- Environmental Protection Biodiversity
- “fragment habitat, introduce disturbance, and eliminate roadless character”
- “ecologically affected by roads, accounting for edge effects, runoff patterns, and downstream disturbance”
- “Rescinding the Roadless Rule would open the Craggy Mountain... to road construction and associated ground disturbance”
- “protecting inventoried roadless areas”
- Scientific Research Evidence
- “An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads”
- “Roughly 80 percent of Earth's terrestrial surface remains roadless, but most of that area is fragmented”
- “Forman & Alexander 1998; Ibisch et al. 2016”
- “Selva, 2016”
What it names
- National Forests
- Pisgah National Forest
- Roadless areas
- Craggy Mountain
- Works cited
- 10.1126/science.aaf716610.1146/annurev.ecolsys.29.1.207
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal