In short: The comment establishes that the agency's DEIS analysis fails to reconcile its wildfire rationale with its own ignition data in Table 21, fails to project the impact of a 13-75% biodiversity fragmentation range across 40.1 million acres, and omits population-level projections for elk in the Bridger-Teton National Forest.
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
- “watch birds and other wildlife”
- “habitat fragmentation reduces biodiversity”
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- Forest Management Wildfire
- “wildfire rationale contradicts the agency's own data”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “roads bring fire risk, not fire relief”
- “letting that, and many other fires burn”
- Environmental Protection Biodiversity
- “largest intact temperate ecosystem in the world”
- “maintain the maximum sustainable biodiversity and ecological integrity”
- “40.1 million acres of potentially affected environment”
- Recreation Tourism Public Use
- “go into almost daily to hike”
- “direct stake in what the agency decides”
- “estimate effects on hunting opportunity”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal