In short: The comment documents the commenter's personal connection to specific national forests in Georgia and Utah, cites the agency's own 'Summary of Potential Impacts' to argue that timber benefits are negligible compared to the Forest Service's repair backlog, and requests the withdrawal of the proposed rescission of the 2001 Roadless Area Conservation Rule.
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 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.
- 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
- “help supply drinking water for millions of Georgians”
- “protect the water we drink”
- “Georgia has about 63,000 roadless acres... protect parts of the Appalachian and Benton MacKaye trails”
- Forest Management Wildfire
- “The 2001 rule includes exceptions for cutting small trees to lower wildfire risk”
- “more public access can increase human-caused fires”
- “planned, controlled burns are an important tool for keeping forests healthy”
- Recreation Tourism Public Use
- “grew up hiking and camping in Utah's national forests”
- “hiking, camping, and having cookouts in the Uinta-Wasatch-Cache National Forest”
- “These lands belong to all Americans”
- Economic Impact Fiscal
- “highest timber revenue estimate is $11.4 million per year”
- “Forest Service already has a $6.9 billion backlog of road and bridge repairs”
- “New roads would add to a bill the agency cannot pay now”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeAnalytical gapEvidenceRequestAlternativeLegal