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”