In short: The comment documents that the Bear Swamp IRA in Huron-Manistee National Forest contains 197 acres of Great Lakes Northern Pine-Oak Forest identified by NatureServe as habitat for the Indiana Myotis, and cites scientific evidence that road construction degrades wetland species diversity and bird densities, thereby establishing a specific ecological basis for opposing the rescission of the Roadless Rule.
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
A3 weak: Substantive, but easier to set aside.
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.
- 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
- “habitat for Indiana Myotis”
- “Road construction degrades this ecosystem”
- “destroying wildlife habitats”
- “reduced densities near highways”
- Environmental Protection Biodiversity
- “fracturing ecosystems”
- “Wetland species diversity is negatively correlated with paved-road density”
- “Great Lakes Northern Pine-Oak Forest”
- “rare federal protections that's working”
- Recreation Tourism Public Use
- “enjoyed exploring the many miracles of nature”
- “Being outdoors in a natural, roadless environment”
- “protect these spaces now so that many generations to come can experience the same joy”
- Cultural Heritage Indigenous
- “disrupt sacred and cultural sites”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence