Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 12 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.
In short: The comment establishes that the DEIS fails to apply cited fragmentation, elk survival, and carbon storage data to the 40.1 million affected acres, and documents the agency's own biological assessment finding that rescission will likely adversely affect 327 ESA-listed species without identified mitigation.
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
A2 moderate: Hard to dismiss — it shows cause and effect.
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.
- 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
- Environmental Protection Biodiversity
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “likely to adversely affect 327 ESA-listed species”
- “unbroken habitat”
- “unblemished by roads”
- Wildlife Habitat
- “elk survival rates increased during a road closure”
- “elk avoid roads and select unroaded habitat”
- “watch wildlife and birds”
- “project the effects on big game populations”
- Climate Carbon Storage
- “holding carbon”
- “contain about 5 percent of the stored forest carbon”
- “quantify the change in carbon storage and sequestration”
- “0.9 billion metric tons”
- Governance Policy Process
- “Every conservation alternative was eliminated by how the purpose was written”
- “forecloses the comparison NEPA requires”
- “restate the purpose and need”
- “analyse at least one protective alternative in full”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal