In short: The comment establishes that the DEIS fails to disclose quantified critical habitat exposure figures for species whose recovery plans rely on roadless protection, specifically citing data for wolverine, Mt. Graham red squirrel, lynx, and Heliotrope milk-vetch, and asserts that ESA Section 7 requires species-specific formal consultation for Northern Myotis in the Pemigewasset Ext IRA.
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.
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
- “conserve our wildlife”
- “Northern Myotis (Myotis septentrionalis, G2, E)”
- “wolverine "in the highest vulnerability category to the proposed action"”
- “100 percent of its critical habitat overlaps with the action area”
- Environmental Protection Biodiversity
- “maintain the natural landscape for generations to come”
- “degrades habitat for Northern Myotis”
- “maintain natural ecological processes”
- “protect this land to conserve our wildlife”
- Recreation Tourism Public Use
- “hiking with my family and skiing in the area”
- “beautiful trails”
- “economy and tourism it brings”
- “feel at peace, enjoy nature”
- Legal Regulatory Framework
- “ESA Section 7 requires formal consultation”
- “The agency cannot satisfy it through a generic programmatic consultation”
- “I request the FEIS disclose”
- “keep the 2001 Roadless Rule in place”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Legal