Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.
In short: The comment documents the specific economic deficiencies of the proposed rule, citing a $6.9 billion road maintenance backlog and a $25 million annual subsidy for the Tongass timber program, while requesting the retention of the 2001 Roadless Rule (Alternative 1) to protect watershed integrity and subsistence opportunities in Southeast Alaska.
Scored as the letter — The shared letter of a family, scored once for everyone who sent it.
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, 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
- Environmental Protection Biodiversity
- “protecting the Pacific Northwest fishery, clean water and old-growth and legacy forests”
- “safeguarded the world's largest intact temperate rainforest”
- “protect watershed integrity and intact ecosystems”
- Water Quality Quantity
- “clean water”
- “Mining will pollute pristine waters that support the Alaskan fishery”
- “protect watershed integrity”
- Economic Impact Fiscal
- “fiscally irresponsible”
- “subsidized the Tongass timber program at a rate of over $25 million per year”
- “cost-benefit analysis for the economic impact of removing Roadless protections”
- Recreation Tourism Public Use
- “provides recreation and tourism opportunities that anchor the regions largest private sector industry”
- “expense of our tourism and outdoor recreation industries”
- “recreation infrastructure”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal