In short: The comment establishes that the rescission of the Roadless Area Conservation Rule fails to account for the protection of 286 municipal water intakes in the White Mountains, contradicts the agency's own economic analysis showing a potential net negative benefit, and ignores the reliance interests of local residents who have organized their lives around these protected areas.
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
- “headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “flooding a region's water system with difficult to remove pollutants”
- “sheds water directly into the lakes region of the state”
- Environmental Protection Biodiversity
- “Carr Mountain area houses wetland and habitat that would be destroyed by logging”
- “history of ecological damage that ruined the economy's long-term health”
- “Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut”
- “intrinsic beauty”
- Recreation Tourism Public Use
- “one of the few places beginner backpackers can go to learn outdoor skills”
- “one of the most popular areas for people to visit”
- “decimate the thriving outdoor economy that New Hampshire enjoys”
- “recreation losses of at least $6.1 million a year”
- Economic Impact Fiscal
- “tightly tied with my state's ability to survive economically”
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning -$92 million to +$199 million”
- “expanding a road system already carrying a $6.9 billion maintenance backlog”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestLegal