In short: The comment places on the record that the Chichagof IRA in the Tongass National Forest contains properly functioning watersheds supporting salmon and that the DEIS must evaluate flood hazard potential of road construction in that area pursuant to Executive Order 11988.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Analytical gap, Legal.
Standard dismissals it defeats
- 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.
- 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.
- 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.
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.
- 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.
Topics
- Recreation Tourism Public Use
- “expedition guide”
- “pristine quiet places”
- “guests came back with countless stories and pictures”
- “experience they come looking for”
- Wildlife Habitat
- “passed bears and other animals”
- “abundance of food and nutrients”
- “productive salmon run”
- “world-class salmon populations”
- Water Quality Quantity
- “headwaters of the Pelican Creek”
- “alter natural drainage patterns”
- “increasing runoff velocity”
- “downstream flood risk”
- Environmental Protection Biodiversity
- “untouched and protected”
- “twenty-five years of roadless protection”
- “rescission would begin to unwind both”
- “Properly Functioning”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal