Comment Analysis · Docket FS-2025-0001

FS-2025-0001-339202

Opposes rescissionA0 noneSubstance 8/24Posted September 9, 2026 On Regulations.gov

In short: The comment places on the record specific evidence of negative ecological impacts from road construction in the Cheaha B area of the Talladega National Forest, citing a 2025 study on bird density reduction and Clean Water Act Section 404 regulations regarding wetland discharge.

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
    • “quiet beauty, changing seasons and admiration of nature”
    • “solitude and peacefulness of hiking”
    • “without another person and no roads”
    • “devastating to see this area desecrated”
  • Wildlife Habitat
    • “degrade habitat quality”
    • “Road traffic had a consistent negative effect on territory densities”
    • “densities of breeding birds were significantly lower”
    • “directly alter roadless character”
  • Scientific Research Evidence
    • “I haven't found any viable science behind your decision”
    • “found substantial science to the contrary”
    • “Landscape Ecology (Springer Nature), 2025”
    • “Effect distances were positively associated with traffic intensity”
  • Water Quality Quantity
    • “Section 404 of the Clean Water Act”
    • “regulate the discharge of dredged or fill material”
    • “no discharge... if... the nation's waters would be significantly degraded”
    • “associated ground disturbance”

What it names

National Forests
Talladega National Forest
Roadless areas
Cheaha B
Works cited
10.1007/s10980-025-02100-5

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Supporting material

The comment

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

Dear Secretary Rollins, As an avid hiker in roadless areas within Alabama, I realize how much we all need these untouched areas for their quiet beauty, changing seasons and admiration of nature. Your proposed removal of the Roadless Rule would substantially damage what I and many others in Alabama enjoy. I have hiked, camped and spent many enjoyable years in the Talladega National Forest and the Cheaha Wilderness. It would be devastating to see this area desecrated by repealing the Roadless Rule. The solitude and peacefulness of hiking to McDill Point and Hernandez Peak via the Pinhoti trail by myself, without another person and no roads was an experience I will never forget. Regarding the Cheaha B in the Talladega National Forest, Alabama: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. 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. “Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded. — U.S. Environmental Protection Agency (https://www.epa.gov/cwa-404/permit-program-under-cwa-section-404)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” I haven't found any viable science behind your decision to rescind the Roadless Rule repeal. But I have found substantial science to the contrary of your repeal. Respectfully, Don Coker

Keep learning. Keep speaking up.The Roadless Rule depends on public engagement. Share what you've learned.

© 2026 roadless.org - Defending America's Last Wild Forests

Privacy Policy|Questions or concerns? noroads@roadless.org|Follow us: @defendroadless