In short: The comment establishes that the proposed rescission of the Roadless Rule would affect 14 listed or proposed species in the Sam Knob (addition) IRA in Pisgah National Forest, requiring ESA Section 7 consultation, and documents the commenter's direct recreational use of the area as a basis for standing.
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
- Environmental Protection Biodiversity
- “damage the fragile balance of native plants and animals”
- “14 listed or proposed species”
- “habitat-degrading road construction”
- “Habitat fragmentation strongly reduced species richness”
- Recreation Tourism Public Use
- “regularly travels on foot through areas designated as roadless”
- “favorite hiking trails”
- “360 degree view across this wilderness area is breath taking”
- “drawn to this area specifically because it does not have developed infrastructure”
- Legal Regulatory Framework
- “ESA Section 7 requires individual consultation”
- “DEIS must demonstrate that the agency has initiated or completed ESA Section 7 consultation”
- “federal action that may affect each of the 14 listed or proposed species”
What it names
- National Forests
- Pisgah National Forest
- Roadless areas
- Sam Knob (addition)
- Works cited
- 10.1007/s10980-025-02100-5Haddad et al. 2015Haddad et al. 2015
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapRequestLegal