In short: The comment establishes that the DEIS is inadequate under NEPA because it fails to analyze the impact of invasive species on the Sierra Nevada Yellow-legged Frog in the Grouse Lakes Inventoried Roadless Area, and documents the commenter's professional experience and scientific evidence supporting the retention of the 2001 Roadless Area Conservation Rule.
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
- Wildlife Habitat
- “Forest-interior species are... the principal beneficiaries of the 2001 Rule”
- “Sierra Nevada Yellow-legged Frog... loses its primary buffer”
- “over a one-quarter decline in bird abundance”
- “more abundant with wildlife and not overrun with invasive plants”
- Environmental Protection Biodiversity
- “Invasive non-native/alien species/diseases”
- “destabilizes slopes and generates chronic sediment inputs”
- “retain the Rule in its existing form”
- “2001 Roadless Area Conservation Rule should remain in effect”
- Recreation Tourism Public Use
- “hiked the John Muir Trail and didn't see a road for weeks”
- “The solitude and ability to escape the hustle”
- “trip of a lifetime”
- Legal Regulatory Framework
- “burden of justification for rescission has not been met”
- “renders the DEIS inadequate under NEPA”
- “analysis is arbitrary”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceRequestLegal