In short: The comment documents that the Draft EIS contains an internal contradiction in the Air section of Chapter 3, where it makes a comparative finding on wildfire emissions while stating the supporting analysis was not performed, and asserts that the commenter has standing based on decades of use of the Rattlesnake Roadless Area in the Lolo 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.
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
- Recreation Tourism Public Use
- “backpacked with my daughter for over twenty years”
- “instructed hundreds of students in designated roadless areas”
- “lessen our enjoyment”
- “key feature of my life's work”
- Wildlife Habitat
- “Roadless Areas are needed so myriad birds and wildlife can exist”
- “provide intact refugia where wildlife and plant species can shift”
- “hasten ecosystem fragmentation and degradation”
- Scientific Research Evidence
- “New research confirms that we have more wildfires where there are more roads”
- “analysis the DEIS says was not performed”
- “unsupported by credible science”
- “sloppy, shady science”
- Climate Carbon Storage
- “buffer temperature extremes”
- “warming climate”
- “hasten ecosystem fragmentation and degradation”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest