In short: The comment establishes that the DEIS fails to evaluate the impact of rescinding the roadless rule on Leavenworth Desert-parsley (Lomatium roneorum) in the Entiat Inventoried Roadless Area regarding invasive species threats (IUCN threat 8.1), citing specific scientific data on infrastructure impacts and local ecological dependencies.
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
- 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
- “Mammal and bird population densities declined with their proximity to infrastructure”
- “The bear would not be in the area if there were roads”
- “Leavenworth Desert-parsley (Lomatium roneorum, G1)”
- “main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density”
- Water Quality Quantity
- “It provides us water food and habitat”
- “the water quality will decrease”
- “supports others downstream”
- Environmental Protection Biodiversity
- “Invasive non-native/alien species/diseases”
- “extractive and development pressures behind this threat category cannot reach”
- “Removing the roadless rule will ruin their future”
- Recreation Tourism Public Use
- “provides recreation for the area”
- “My brother wa able to hunt a bear to feed our family”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidence