In short: The comment documents that the draft EIS fails to clearly define impacts to fish and wildlife habitat despite NFM Act priorities, cites a $6.9 billion deferred maintenance backlog as evidence of management capacity issues, and requests the USDA eliminate the proposal to rescind the Roadless Rule.
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 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
- “impacts to fish, wildlife, and their habitat were not clearly defined”
- “roads and habitat fragmentation... alter migration and habitual movement of animals”
- “increase the habitat value for wildlife”
- “put those fragile (and rare) benefits at risk”
- Recreation Tourism Public Use
- “recreating in these roadless areas”
- “hike, hunt, fish, and explore these gems”
- “recreationists who value its benefits to wildlife, ecosystem function, and seclusion”
- “negative impacts to those of us who recreate in these areas”
- Water Quality Quantity
- “fish-passage barriers located within my local national forest”
- “populations of threatened and endangered species left to fend for themselves”
- “guaranteed to remain fish-passage barrier free in perpetuity”
- “maintain and improve... watershed”
- Scientific Research Evidence
- “It is well documented that roads and habitat fragmentation... alter migration”
- “Kukuła K, Bylak A. Barrier removal and dynamics of intermittent stream habitat...”
- “Fullman TJ, Wilson RR... Mapping potential effects of proposed roads on migratory connectivity”
- “draft EIS states that the National Forest roads system has a backlog of $6.9 billion”
What it names
- Works cited
- 10.1002/eap.220710.1038/s41598-022-05636-7
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal