In short: The comment documents specific deficiencies in the agency's analysis regarding the quantification of administrative burdens outside existing carve-outs, the failure to weigh human-caused ignition data from DEIS Table 21 against wildfire hazard claims, and the omission of reliance interests in the Cost Benefit Analysis, while providing verified wildlife and water intake data for the White Mountain National Forest and Maine roadless areas.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Analytical gap, Evidence, Legal.
Standard dismissals it defeats
- 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.
- 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.
- 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.
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.
- 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.
Topics
- Water Quality Quantity
- “headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco”
- “drinking water for communities across New Hampshire, Vermont, and Massachusetts”
- “286 municipal water intakes depend on watersheds containing affected roadless areas”
- Wildlife Habitat
- “Moose, black bear, Canada lynx, American marten, brook trout, Bicknell's thrush, the northern long-eared bat”
- “all verified in the White Mountain roadless areas”
- “marveling at the new lives they support”
- Recreation Tourism Public Use
- “hiked together every year since 1995”
- “paddled remote rivers in Maine for our honeymoon”
- “learned rock climbing on many weekend trips to the White Mountain National Forest”
- Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions from new road access”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest