Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.
Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.
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. This rating is the one its shared letter earned.
Owed an answer on Analytical gap, Evidence, Alternative.
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
- Tribal Sovereignty
- “violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty”
- “government-to-government consultation with affected Tribes”
- “sacred sites and ancestral homelands”
- “treaty-reserved rights”
- Environmental Protection Biodiversity
- “327 ESA-listed species and 71 critical habitats would be negatively impacted”
- “irrevocable devastation it would cause”
- “destroys habitat”
- “sustain ecosystems Tribal Nations have relied on for generations”
- Forest Management Wildfire
- “could actually increase fire risk”
- “More roads will result in more human-caused fires in the backcountry”
- “Agencies already have authority to manage fuels and fight fires in roadless areas”
- “Livestock grazing spreads invasive grasses that exacerbate wildfires”
- Water Quality Quantity
- “pollutes clean water”
- “drinking-water sources”
What it names
- Roadless areas
- Hardesty MountainLost LakeMiddle Fork
- Works cited
- Furniss et al. 1991