In short: The comment establishes that roadless areas in the Chiricahuas and Sky Island ranges are critical for the habitat connectivity and population viability of wide-ranging threatened species like jaguars and mountain lions, citing specific ecological studies to argue that the 'may affect' standard is met for Section 7 consultation and that the Roadless Rule should not be rescinded.
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
- “roadless areas are crucial in maintaining habitat quality and connectivity”
- “critical for the population viability of large predators like mountain lions”
- “occupancy of rarer species like mountain lions increased farther from roads”
- “necessary to allow individuals to move freely throughout their home ranges”
- Environmental Protection Biodiversity
- “best interest of America's biodiversity and natural heritage”
- “57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas”
- “preserving undegraded habitat and maintaining connectivity”
- “sustain genetically diverse populations”
- Scientific Research Evidence
- “empirical research conducted throughout wild areas in the U.S.”
- “Baker and Leberg, 2018”
- “Trombulak & Frissell, 2000”
- “Decades of ecological research throughout North America confirm the value”
What it names
- Works cited
- 10.1016/j.gecco.2021.e0194310.1046/j.1523-1739.2000.99084.x10.1046/j.1523-1739.2001.99577.x10.1371/journal.pone.015422310.1371/journal.pone.0195436
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisEvidence