Comment Analysis · Docket FS-2025-0001

FS-2025-0001-429009

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 16, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

In short: The comment establishes that the DEIS fails to evaluate the impact of rescinding the 2001 Rule on the federally listed Monarch butterfly in the Cheaha A area of Talladega National Forest, specifically regarding the threat of logging and wood harvesting, which constitutes a failure to consider an important aspect of the problem under NEPA.

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

  • Recreation Tourism Public Use
    • “joys of hiking where you cannot see, hear, smell, or feel the touch of 'civilized man'”
    • “restore my body, mind and soul”
    • “lose that total seclusion that I crave”
    • “sense that there is still somewhere I can go where I see our great country unspoiled by man”
  • Wildlife Habitat
    • “absence of wildlife at ease in their natural habitat”
    • “densities of breeding birds were significantly lower”
    • “Monarch (Danaus plexippus), ranked G4 by NatureServe”
    • “negative impacts on embryo survival of gravel-spawning fish”
  • Water Quality Quantity
    • “Increases in fine sediments are known to change grain size distribution”
    • “degradation of spawning grounds”
    • “sustained clogging”
    • “sedimentation of fines on coarse bed material”
  • Forest Management Wildfire
    • “roadless areas are far less susceptible to wildfires”
    • “federal argument is bogus”

What it names

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

The comment

Dear Chief Tom Schultz: I am an avid hiker in Alabama. I know the joys of hiking where you cannot see, hear, smell, or feel the touch of “civilized man”. I also know the abrupt, jarring experience of suddenly coming upon a road - the trash, the sound of engines, the absence of wildlife at ease in their natural habitat. The facts show, from my understanding, that roadless areas are far less susceptible to wildfires so that federal argument is bogus. My hiking trips into the forest, where I restore my body, mind and soul, would be gone. I would lose that total seclusion that I crave, the sense that there is still somewhere I can go where I see our great country unspoiled by man. As an outdoor enthusiast who understands what it means to travel in country that has been kept outside the road system by regulatory protection rather than by geographic inaccessibility, I submit that the proposed rescission of the 2001 Rule would remove a protection whose absence would be felt concretely and irreversibly across the national forest landscape. Regarding the Cheaha A in the Talladega National Forest, Alabama: "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “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)” Monarch (Danaus plexippus), ranked G4 by NatureServe and federally listed (PT), is present in the Cheaha A IRA, Talladega National Forest, where it confronts 5.3 - Logging & wood harvesting at Moderate or 11-30% pop. decline severity across Restricted - small scope. The roadless character of Cheaha A currently prevents the infrastructure penetration that initiates 5.3 - Logging & wood harvesting. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Monarch. If the DEIS does not evaluate how rescission affects Monarch (Danaus plexippus, G4) in Cheaha A with respect to 5.3 - Logging & wood harvesting, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. Let the roadless areas remain what they are. Thank you. CommentID: RLC-20260916-2SDMDU

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