In short: The comment documents that the Draft EIS fails to provide site-specific analysis of fire and fire suppression impacts on Greater Sage-Grouse in the Dome Peak IRA and contains an unreconciled internal contradiction regarding wildfire ignition densities in roadless versus roaded areas, thereby violating NEPA and APA standards.
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
A1 strong: Must be answered — it names the law.
Owed an answer on Analytical gap, Evidence, Legal.
Standard dismissals it defeats
- 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.
- 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.
- 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.
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.
- 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.
Topics
- Wildlife Habitat
- “critical spawning and rearing habitat for four federally endangered fish”
- “Greater Sage-Grouse in the Dome Peak IRA depends on the unroaded landscape”
- “Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations”
- Water Quality Quantity
- “headwaters of Hinman Creek, Coulton Creek, Lester Creek, Cabin Creek, and Farwell Creek”
- “network of cold, high-elevation streams that feed into the Elk River system”
- “cold water temperatures and clean spawning substrates maintained by intact riparian vegetation”
- Legal Regulatory Framework
- “NEPA requires the agency to take a hard look at the effects of rescission”
- “The DEIS fails this standard without site-specific analysis”
- “internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm”
- Forest Management Wildfire
- “it become more at risk of wildfire, threatening my home”
- “Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data”
- “IRA ignition density at 12 fires per million acres per year”
Attachments
1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal