In short: The comment places on the record a specific objection to the DEIS's failure to identify enforceable provisions in forest plans equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds, citing data on 24 million people and 7,000 intakes, and requests site-specific analysis of environmental consequences for ten named roadless areas in Arkansas.
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, 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
- “Twenty-four million people's drinking water is asserted away”
- “The water is for all of Mankind”
- “asserting control over natural aquifers”
- “identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds”
- Environmental Protection Biodiversity
- “Cardinal and hummingbirds and all of the Heavenly Father's wing animals are to soar high not be in a cage”
- “disclose and analyze the site-specific environmental consequences”
- “effects of the road construction and timber harvest it would newly allow”
- “retain the 2001 rule's protections”
- Legal Regulatory Framework
- “I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule”
- “ask that the agency respond to each of the issues raised in this comment”
- “analyze in the DEIS an alternative that retains the 2001 rule's protections”
- “provide a reasoned explanation for it on the record”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisAnalytical gapEvidenceRequestLegal