In short: The comment establishes that the rescission of the 2001 Roadless Rule is unsupported by scientific evidence regarding fire risk, water quality, and biodiversity, contradicts the overwhelming public opposition (99.8% of comments), and documents specific recreational and habitat dependencies across multiple national forests including Pisgah, Nantahala, White Mountain, Flathead, and Roosevelt.
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
- Environmental Protection Biodiversity
- “roadless areas protect habitat for roughly 1,600 at-risk species”
- “rescission would put roughly 400 imperiled species on a faster track toward extinction”
- “roads fragment landscapes in ways even more ecologically harmful than clearcuts”
- Water Quality Quantity
- “safeguarding drinking water for tens of millions of Americans”
- “cause significant soil erosion that raises water temperatures”
- “sends pollution downstream into watersheds that supply drinking water”
- Forest Management Wildfire
- “fires are about four times more likely to start near a road than in roadless forest”
- “roads bring more vehicle ignitions, campfires, and discarded cigarettes”
- “Fire risk runs the opposite direction from the agency's stated rationale”
- Recreation Tourism Public Use
- “backcountry that would lose its protection under this rule”
- “As a hiker, cyclist, and skier, I have watched all four of these landscapes”
- “degrade the trails, watersheds, and wildlife habitat that my family and I depend on”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence