In short: The comment establishes that the DEIS fails to account for increased landslide risks from climate change and logging, omits required ANILCA Section 810 subsistence evaluations, and ignores local economic and recreational dependencies on roadless watersheds in the Tongass National Forest.
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, Alternative.
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
- Tribal Sovereignty
- “A subsistence evaluation under ANILCA Section 810 is needed”
- “Removing protections from 9.3 million acres of Tongass inventoried roadless areas directly affects the subsistence resources rural Alaskans rely on”
- “I ask USDA to complete a Section 810 evaluation, with hearings in affected communities”
- Water Quality Quantity
- “community drinking water sources”
- “erosion from road building and logging-related landslides harms and can eliminate fish runs”
- “New roads and clearcuts above spawning habitat add sediment and debris to streams”
- Recreation Tourism Public Use
- “Visitors come to travel through remote, roadless country”
- “many local businesses (bear viewing, guided hikes, fishing charters and lodges) depend on abundant wildlife”
- “degrade the scenery visitors come for”
- National Security Public Safety
- “Landslide risk to public safety is increasing”
- “Logging and road building on steep slopes add to that risk”
- “Alaska's last four fatal landslides all occurred here”
What it names
- National Forests
- Tongass National Forest
- Roadless areas
- Douglas Island
- Works cited
- 10.1007/s10346-025-02663-z10.1093/jof/72.6.330
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapRequestAlternativeLegal