In short: The comment establishes that the rescission of the 2001 Roadless Rule in the Nantahala National Forest removes administrative safeguards for paddling, water quality, and wildlife habitat, and asserts that the DEIS fails to quantify the specific economic losses to tourism and local businesses resulting from road construction.
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, 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.
- 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
- Recreation Tourism Public Use
- “spend thousands of dollars on tourism”
- “rafting and camping to hiking”
- “threatens local tourism like rafting and hiking”
- “paddling in the Nantahala National Forest generates measurable economic activity”
- Water Quality Quantity
- “Stream crossings cause sedimentation that degrades water quality”
- “quality of life impacts to water systems”
- “dependent on those systems”
- “beautiful healthy forests and waterways”
- Wildlife Habitat
- “threatens the lands and wildlife I enjoy”
- “removes the only administrative safeguard for... wildlife habitat”
- “New motorized access displaces the backcountry character”
- “forests are turned into roads and timber lands”
- Economic Impact Fiscal
- “Many rural areas depend on tourism economies”
- “timber won't likely replace with rescission”
- “visitor spending, guide revenue, outfitter income, local business revenue”
- “Failure to do so violates NEPA's requirement to consider economic impacts”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisRequestLegal