In short: The comment documents that the proposed rescission of the Roadless Area Conservation Rule lacks proportionate administrative rationale and fails to adequately evaluate the direct, indirect, and cumulative effects on federally endangered bat species and Northern Myotis in the Linville Gorge Addition, specifically regarding habitat fragmentation and noise pollution impacts.
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
- Wildlife Habitat
- “Federally Endangered Bat Habitat and Acoustic Refugia”
- “unbroken canopy and absence of road noise create acoustic conditions essential for echolocation-dependent foraging”
- “Roads fragment intact habitat through cut-and-fill earthwork”
- “documented threat of 5.3 - Logging & wood harvesting on Northern Myotis”
- Environmental Protection Biodiversity
- “protections so hard fought for, for old growth trees, rare plants, and wildlife”
- “appreciation for the plants and animals that share our planet”
- “Conservation is at the heart of the American spirit”
- “removing protections such as the roadless rule go against everything that make this country great”
- Recreation Tourism Public Use
- “As an outdoor enthusiast”
- “spent countless hours of free time in the roadless backcountry”
- “brought me a deep peace and appreciation”
- “lose the ability to experience land as it's been for all of existence”
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gap