In short: The comment documents the commenter's local standing in Sitka, Alaska, based on subsistence use of deer and salmon, and cites the agency's economic analysis (comparing $4.6–$10.6 million timber benefits against >$100 million impacts and a $6.9 billion road maintenance backlog) to argue that the proposal to rescind the 2001 Roadless Rule is a net negative, while requesting the withdrawal of the proposal and that ANILCA Section 810 subsistence hearings occur prior to any final decision.
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 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
- Cultural Heritage Indigenous
- “ANILCA Section 810 subsistence hearings”
- “wild food has been at the center of how my family eats”
- “deer from the forest, salmon from the water”
- “where our food comes from”
- Wildlife Habitat
- “roadless parts of this forest are not empty space”
- “reason the deer and the salmon are still here”
- “what the deer and the salmon are worth to a household”
- “once gone, does not come back”
- Economic Impact Fiscal
- “best case for the timber industry at $4.6 to $10.6 million a year”
- “annual impacts that could exceed $100 million”
- “$6.9 billion backlog of maintenance on roads”
- “bad trade on its own terms”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapRequest