In short: The comment documents that the agency is ignoring available scientific data on the ecological integrity of roadless areas in New Hampshire, Pennsylvania, West Virginia, and Minnesota, specifically regarding migratory bird habitat requirements and watershed protection under the Migratory Bird Treaty Act.
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
A0 none: Counted, not answered.
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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
Topics
- Wildlife Habitat
- “wildlife habitat”
- “migratory bird species require large interior forest tracts”
- “fragmentation reduces patch size and breeding success”
- “sustain key refugia for biodiversity”
- Water Quality Quantity
- “Clean water is most closely linked to undisturbed natural ecosystems”
- “water quality and biodiversity decline as hydrological integrity is lost”
- “heavily sediment-laden streams”
- “Protecting watersheds”
- Environmental Protection Biodiversity
- “intact reference landscapes”
- “ecological integrity”
- “functional soils, hydrology, and food webs”
- “Don't strip out protections”
What it names
- Works cited
- 10.1098/rspb.2020.316410.1126/science.aaf716610.2489/jswc.66.3.78a
Attachments
8 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
- Own letter
- Own letter
- Own letter
- Own letter
- Supporting material
- Supporting material
- Own letter
- Supporting material
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal