In short: The comment establishes that the rescission of the 2001 Roadless Rule is inadequate due to the short comment period and lack of public hearings in Western North Carolina, while documenting that the rule protects headwaters for 1.5 million people and that local Forest Service staff acknowledge minimal impact from rescission in the region.
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
- Water Quality Quantity
- “protect mountain headwaters that supply drinking water”
- “Road building on steep Appalachian slopes causes erosion and sediment pollution”
- “threaten water quality”
- “Intact forest holds soil and slows runoff”
- Public Health Wellbeing
- “Drinking water and public health”
- “raise water treatment costs”
- “clean water as a basic public health issue”
- “increase landslide and flood risk for downstream communities”
- Forest Management Wildfire
- “The wildfire justification doesn't hold up”
- “Roads are linked to increased human-caused wildfire ignitions”
- “existing rule already allows exceptions for fuel reduction”
- “not a targeted wildfire strategy”
- Recreation Tourism Public Use
- “enjoying the gorgeous forests of WNC”
- “support hunting, fishing, recreation”
- “tourism economy WNC depends on”
- “Linville Gorge, Joyce Kilmer-Slickrock”
What it names
- Roadless areas
- Black MountainSouth Mills River
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal