In short: The comment documents that the Draft Environmental Impact Statement fails to adequately consider the degradation of adjacent national park landscapes (specifically Great Smoky Mountains, Rocky Mountain, and others) caused by removing roadless protections from bordering national forests, citing the DEIS's own findings of significant environmental harm and lack of wildfire risk reduction.
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 Evidence.
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
- “protect the headwaters and critical watersheds”
- “supply clean drinking water to tens of millions”
- “increase soil erosion, stream sedimentation, and water degradation”
- Wildlife Habitat
- “Fragmentation of Crucial Wildlife Corridors”
- “essential sanctuary buffers and migration corridors”
- “fracture these fragile habitats, isolate wildlife populations”
- Recreation Tourism Public Use
- “unbroken vistas, quiet backcountry recreation”
- “fundamentally mar the panoramic views, quiet atmospheres”
- “outdoor recreation economies”
- Economic Impact Fiscal
- “Fiscal Irresponsibility and Backlogs”
- “staggering nationwide road and bridge deferred maintenance backlog”
- “fiscally reckless to eliminate a rule to build new... roads”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeRequestAlternativeLegal