In short: The comment establishes that the proposed rescission of the Roadless Rule lacks sufficient analysis for the Linville Gorge Addition in Pisgah National Forest, specifically arguing that a programmatic analysis is insufficient and that the DEIS must evaluate recreational activity impacts on the Small Whorled Pogonia and headwater stream integrity.
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
- Water Quality Quantity
- “Headwater Protection for Five Creek Systems”
- “Road construction in headwater areas causes sedimentation... which smothers spawning gravels and reduces water clarity”
- “Stream fragmentation is a leading threat to freshwater fish diversity”
- “threaten drinking water sources”
- Environmental Protection Biodiversity
- “loss of contributions to forest carbon, watershed integrity, and ecological connectivity”
- “destroy wildlife habitat”
- “shielded countless management decisions from triggering that consultation [Endangered Species Act]”
- “concentrated in the rarest, most threatened ecosystems”
- Climate Carbon Storage
- “loss of contributions to forest carbon”
- “An increase in these industrial activities would worsen climate change”
- “federal climate record”
- Recreation Tourism Public Use
- “destroy recreation areas”
- “reminded me why I am going to law school in the first place [referring to Linville Gorge escape]”
- “44.5 million acres of undeveloped backcountry forestland”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal