In short: The comment documents specific recreational and habitat values in the Big Mountain, Telephone Draw, and Sam Knob roadless areas, and argues that the 2001 Roadless Rule should be maintained because new road construction would degrade water quality and increase wildfire risk, contrary to the agency's stated justification.
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
- Wildlife Habitat
- “jeopardize intact fish and wildlife habitat”
- “amazing habitat for native trout and salmon, big game, and other wildlife”
- “reduce pristine habitat that makes our public lands so great for hunting, fishing, and camping”
- Recreation Tourism Public Use
- “avid outdoorsman and lifelong flyfishing and hunting enthusiast”
- “best places to hunt and fish in America”
- “keep these public lands a great place to enjoy for all future Americans”
- Water Quality Quantity
- “negative impact on water quality”
- “sedimentation and erosion to reduce water and habitat quality”
- “pristine habit that allows trout to live in the Chattooga River”
- Forest Management Wildfire
- “stated reasoning of reducing wildfire risk does not hold merit”
- “over 70% of human caused wildfires on National Forest land start within 0.5 miles of a road”
- “more roads could result in even more forest fires, not less”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal