In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule fails to analyze systemic Clean Water Act violations and specific ecological harms to the Shawnee National Forest, including sedimentation in the Belle Smith Springs and Morris Creek watersheds, increased wildfire risk, and threats to Indiana bat habitats.
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.
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
- Water Quality Quantity
- “severe, systemic violations of the Clean Water Act (CWA)”
- “choke out cold-water aquatic habitats, violating state anti-degradation policies”
- “unmanageable surge in nonpoint source pollution”
- “degraded water quality”
- Environmental Protection Biodiversity
- “vital bedrock of protection for our nation's last remaining wildlands”
- “ecologically disastrous”
- “fragmented Eastern forests”
- “vulnerable to piecemeale industrial exploitation”
- Forest Management Wildfire
- “significantly elevating the risk of catastrophic wildfire”
- “introduces fresh vectors for human-caused ignitions”
- “decreased soil moisture, desiccated forest floors”
- “massive multi-billion-dollar backlog in maintaining its existing 370,000 miles of roads”
- Legal Regulatory Framework
- “violations of the Clean Water Act (CWA)”
- “state anti-degradation policies”
- “removes a critical legal backstop”
- “proper cumulative impact analysis”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal