Comment Analysis · Docket FS-2025-0001

FS-2025-0001-275207

Opposes rescissionA0 noneSubstance 7/24Posted August 27, 2026 On Regulations.gov

In short: The comment documents that the Cheaha B area in Talladega National Forest contains federally endangered bat habitat and Indigenous marker trees, and that rescinding the Roadless Rule would expose these specific resources to road construction and associated ecological degradation.

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

A0 none: Counted, not answered.

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.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • 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.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • 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
    • “experience nature away from roads, traffic, and everyday distractions”
    • “quiet forests, wildlife, and challenging trails”
    • “encourages my children to explore, stay active, and appreciate these unique and diverse wild spaces”
  • Wildlife Habitat
    • “Three federally endangered bat species... depend on the unfragmented forest canopy”
    • “Logging skid trails extend road edge effects deep into the forest”
    • “acting as conduits for non-forest and invasive species and removing interior forest species”
  • Environmental Protection Biodiversity
    • “Talladega's roadless areas are not empty acres. They are living ecosystems”
    • “Protecting them is an investment in the forest and in generations yet to come”
    • “damage acid-loving native species”
  • Cultural Heritage Indigenous
    • “unusual marker trees... intentionally created by Indigenous peoples”
    • “living record of the people who traveled through and cared for these lands”
    • “cultural landscapes”

What it names

National Forests
Talladega National Forest
Roadless areas
Cheaha B
Works cited
10.1016/j.biocon.2012.10.008

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence

Dear Secretary Rollins and Chief Schultz: As someone who gets out there regularly and knows what roadless areas offer that other public land designations don't, I want the Department to understand that this isn't a minor policy adjustment — it's a substantive change to what's available. Roadless areas in Talladega National Forest have enhanced my appreciation for the outdoors by giving me and my family opportunities to experience nature away from roads, traffic, and everyday distractions. Being surrounded by quiet forests, wildlife, and challenging trails allows us to feel a stronger connection to nature and encourages my children to explore, stay active, and appreciate these unique and diverse wild spaces. One occasion in particular illustrates what that relationship means in practice. Walking along the trails, we sometimes encounter unusual marker trees—trees whose distinctive shapes or growth patterns were intentionally created by Indigenous peoples to mark trails, waterways, campsites, or other important locations. Seeing these trees in the forest makes the landscape feel like more than wilderness; it becomes a living record of the people who traveled through and cared for these lands long before modern trails existed. Their presence adds a sense of mystery and connection. The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Cheaha B in the Talladega National Forest, Alabama: Bat Hibernacula and Foraging Habitat Connectivity — Three federally endangered bat species—gray bat (*Myotis grisescens*), Indiana bat (*Myotis sodalis*), and northern long-eared bat (*Myotis septentrionalis*)—depend on the unfragmented forest canopy and cave systems within and adjacent to t… Logging skid trails extend road edge effects deep into the forest. Skid trails extend road edge effects on plant communities up to 60 meters into adjacent forest stands, acting as conduits for non-forest and invasive species and removing interior forest species. Road construction materials such as limestone gravel further alter soil pH and damage acid-loving native species (Avon et al. 2013). — Catherine Avon, Yann Dumas, Laurent Bergès, 2013 · Biological Conservation (https://doi.org/10.1016/j.biocon.2012.10.008) Rescinding the Roadless Rule would open the Cheaha B, Talladega National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Talladega's roadless areas are not empty acres. They are living ecosystems, watersheds, wildlife habitat, cultural landscapes, and places that inspire people to care about the world around us. Protecting them is an investment in the forest and in generations yet to come. The Department should let the Rule stand. Warm regards, CommentID: RLC-20260826-ZRQHH9

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