In short: The comment places on the record specific evidence that the Bridger Range in the Gallatin National Forest contains cold-water streams supporting westslope cutthroat trout and that roadless conditions are necessary to maintain water temperature and sediment control, while citing scientific data to demonstrate that rescinding the 2001 Roadless Rule would increase the representation of imperiled species and underprotected ecosystems.
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
- “wildlife sightings of increasingly rare species that need their own space to thrive”
- “roadless areas provide undisturbed habitat for Montana's wild animals”
- “reduce the number of imperiled wildlife species considered "poorly represented" in protected areas by 38 species”
- Water Quality Quantity
- “Cold-Water Stream Integrity”
- “maintain riparian shading that keeps water temperatures cold enough for westslope cutthroat trout”
- “prevents sediment loading in spawning reaches and keeps dissolved oxygen levels stable”
- Environmental Protection Biodiversity
- “continued protection of these lands”
- “Roadless areas fill gaps in the existing protected-area network”
- “increase representation of underprotected ecosystem types, including temperate grasslands (+57%) and cool temperate forests (+52%)”
What it names
- National Forests
- Gallatin National Forest
- Roadless areas
- Cottonwood CreekRocky Mountain
- Works cited
- 10.1016/j.gecco.2021.e0194310.1111/csp2.288
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapRequest