In short: The comment establishes that the DEIS fails to adequately evaluate the impact of rescinding the Roadless Rule on the Northwestern Pond Turtle in the Grindstone IRA by ignoring the specific threat of roads and railroads, citing NatureServe data and scientific literature to demonstrate that this omission renders the EIS inadequate under NEPA.
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, Evidence.
Standard dismissals it defeats
- 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.
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.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- 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.
- 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.
Topics
- Wildlife Habitat
- “loves our state for its wilderness areas and wonderful wildlife”
- “Northwestern Pond Turtle (Actinemys marmorata, G2, PT) in the Grindstone IRA”
- “Grindstone functions as a refuge where Northwestern Pond Turtle is buffered from 4.1 - Roads & railroads”
- “forests protecting both biodiversity and landslide risks to human society are important conservation targets”
- Environmental Protection Biodiversity
- “native flora and fauna”
- “abundance of birds”
- “High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians”
- “The Rule should remain in full force”
- Legal Regulatory Framework
- “If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle”
- “the agency has failed to consider an important aspect of the problem”
- “a standard basis for finding an EIS inadequate under NEPA”
- “the Department is urged to decline the proposed rescission action”