Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.
In short: The comment places on the record specific deficiencies in the DEIS regarding the lack of quantitative projections for habitat fragmentation, big game population effects, and carbon storage changes across 40.1 million acres, while citing specific DEIS findings and requesting an alternative that retains the 2001 Roadless Area Conservation Rule for five named national forests.
Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.
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
A3 weak: Substantive, but easier to set aside.
Owed an answer on Analytical gap.
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.
- 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.
- 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.
- 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
- “seen and taken photos of bear, moose, elk, deer and attempting photos of raptors”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk survival rates increased during a road closure and decreased when the gates were removed”
- “elk avoid roads and select unroaded habitat”
- Water Quality Quantity
- “clean water and clean air”
- “We need our watersheds to be a high priority for the Forest Service and BLM”
- “Logging and the extractive industries present too high of a risk to this valuable resource”
- “decades long drought out west and the way our distribution of water is managed has caused the disastrous current position in a water crisis”
- Climate Carbon Storage
- “standing forests where I watch wildlife are doing quiet work the whole time, holding carbon”
- “inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States”
- “quantify the change in carbon storage and sequestration under each alternative”
- Recreation Tourism Public Use
- “I enjoy the solitude, the scenic landscapes and the wildlife”
- “endless opportunities for hiking and camping”
- “It would be a devastating sight for me if a new forest road is added to this area”
- “We have thousands of Forest Roads already - there is no need to add any more”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal