Every comment that clears a floor of substantive signal is scored 0–3 on eight dimensions, summing to a substance score out of 24, and rated for how hard it is for the agency to set aside. The two ratings answer different questions: a short comment that cites a statute can be hard to dismiss, and a long one with no hook can be easy. Counts are unique comments; every cell opens its comments.
Rows are substance bands; columns are answerability levels. Submissions are under each count.
A comment is owed an answer when it scores 2 or more on analytical gap, evidence, alternative or legal. A comment can qualify on more than one.
3,584 unique comments 5,891 submissionsUnique comments scoring 2 or more on each dimension.
The exhibits are the top tenth of each position by substance; within each, ranked by exhibit strength. Each opens with its scored passages shaded.