In short: The comment establishes that the DEIS lacks site-specific analysis of ecosystem modifications affecting Suckley's Cuckoo Bumble Bee in the Secesh Inventoried Roadless Area, and requests that the 2001 Roadless Rule remain in effect.
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
- “Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Secesh Inventoried Roadless Area”
- “loses its primary buffer against 7.3 - Other ecosystem modifications”
- “Road construction fundamentally alters this baseline”
- “watching salmon spawn near Warm Lake”
- Recreation Tourism Public Use
- “spends time in the backcountry”
- “backpacking trail I planned my first solo backpacking trip on”
- “spend multiple days backpacking without seeing another soul”
- “wild and beautifully preserved”
- Legal Regulatory Framework
- “NEPA requires the agency to take a hard look”
- “The DEIS fails this standard”
- “Without the protections of the 2001 Roadless Area Conservation Rule”
- “Department should allow the 2001 Rule to stand”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapAlternative