Date: 9/25/25 7:49 am From: Jeffrey Short <bashman...> Subject: Re: Opportunity to Submit Comments to USDA and EPA on Environmental Decisions
Excellent comments! Glad we are going on-record against these proposed changes.
I may have missed the call for comments. Was there a notice to the listserv about these actions to solicit comments from us readers?
Perhaps there is a way to enhance the impact with more folks signing the response. Let’s consider how to efficiently do this for responses to the proposals in the Federal Register.
I want to note that I recently received a response from Senator Cotton about one of those postcards sent to solicit support for whatever good cause is being proposed. (Senator Boozman always sends a quick response--and follow-up if necessary; this the first response Cotton has sent to me in maybe 7 or 8 years. I think he finally has realized that we are his constituents!)
Jeff Short
From: The Birds of Arkansas Discussion List [mailto:<ARBIRD-L...>] On Behalf Of Kevin Krajcir
Sent: Monday, September 15, 2025 7:17 PM
To: <ARBIRD-L...>
Subject: Opportunity to Submit Comments to USDA and EPA on Environmental Decisions
Good evening everyone,
The Arkansas Audubon Society's Conservation Committee recently submitted two comments regarding environmental decisions being made by the US Dept of Agriculture (USDA) and the Environmental Protection Agency (EPA). The submission of these comments was approved by the AAS's board. We would now like to share these comments with you all in case you would like to prepare your own comments for submission on these two issues in support of birds and their habitats. In this email, I have also included details about how to submit your comments.
First, the USDA is considering rescinding their "Roadless Rule." This rule, established in 2001, limits road construction on designated public lands to minimize the environmental impact of those roads and subsequent actions. Some such public lands include portions of the near and dear Ozark and Ouachita National Forests. We know that habitat fragmentation (in the form of roads, etc.) can have detrimental effects on certain birds and other wildlife that depend on large swaths of in-tact forest. Rescission of the Roadless Rule would open millions of acres to industries such as logging, oil, and gas.
Here is AAS's draft comment on the "Roadless Rule" issue. Feel free to use it as a guide as you craft your own comment:
"This comment is from the Arkansas Audubon Society (AAS), an all-volunteer nonprofit
that has advocated for birds, their habitats, and the environment since 1955. The Roadless Rule protects 45 million acres of national forest lands in 36 states, including the Ozark and Ouachita National Forests in Arkansas. These lands provide wildlife with necessary habitat, including endangered and threatened species. Arkansas’s national forests are particularly important to the millions of migrating birds that pass through twice a year.
More roads will mean loss of habitat. Large, undisturbed tracts of habitat will also become fragmented, which especially harms forest-interior species, such as Wood Thrushes and Ovenbirds, that depend on large, contiguous tracts of forest with low levels of disturbance. These roads will also cause more stress and mortality of other wildlife and increase the chance of wildfires; research shows that nearly 85% of wildland fires in the US are caused by humans. Furthermore, the logging, oil, and gas industries that will be the primary users of these roads will cause even more environmental damage.
These roadless tracts contain most of the last pristine land in the US. These lands represent less than 2% of the total acreage in our country. Surely this is not too much to continue to protect from habitat degradation, wildlife loss, and pollution. In the last 50 years, 30% of the North American bird populations have disappeared. One of the chief causes is loss of habitat. Rescinding the Roadless Rule will only exacerbate population declines.
The AAS asks that the USDA and Forest Service withdraw the proposal to rescind the Roadless Rule."
Second, the EPA is taking comments regarding a potential decision to rescind the Endangerment Finding. This 2009 determination concluded that six major greenhouse gases endanger public health when present in the air above certain concentrations. This determination serves as the legal basis for the EPA's regulation of greenhouse gas emissions through the Clean Air Act, allowing the EPA to set emissions standards for cars, power plants, etc. Undoing this decision will severely limit the EPA's authority to regulate greenhouse gas emissions, which impact wildlife and the climate in addition to human health.
Comments on this decision are due by end of day on Monday September 22nd. You can submit your comment here: https://www.regulations.gov/document/EPA-HQ-OAR-2025-0194-0093. Be sure to include this docket ID number as part of your comment: EPA-HQ-OAR-2025-0194.
Here is the AAS's comment which can serve as an example for your use:
"Docket ID No. EPA-HQ-OAR-2025-0194
This comment is from the Arkansas Audubon Society (AAS) an all-volunteer nonprofit that has advocated for birds, their habitats, and the environment since 1955. AAS is opposed to the Environmental Protection Agency’s proposed rescission of the 2009 Endangerment Finding that a mix of six greenhouse gases constitutes "air pollution" that may reasonably be anticipated to endanger public health and welfare. Rescission of this finding would be a significant anti-environmental move. The mission of the EPA, as stated on its website in July 2025, is to protect human health and the environment. To rescind the Endangerment Finding will mean that the EPA is abandoning a major part of its mission.
Since 2009 scientific documentation provides ever-increasing evidence that greenhouse gas emissions are bad for public health. Rescission of this finding will weaken or eliminate greenhouse gas emissions standards for vehicles, powerplants, aircrafts, and other oil and gas operations. This, in turn, will cause air pollution to increase and exacerbate climate change, which threatens not only birds but also entire ecosystems, people, and our economy.
In the last 50 years, 30% of the North American bird populations have disappeared. Pollution and climate change are major contributing causes. At this point in Earth’s history, we do not need to make these problems worse.
The AAS requests that the EPA withdraw its proposal to rescind the 2009 Endangerment Finding. Let us continue to head forward in the direction of cleaner energy, not backward."
Thank you for considering these issues and for using your voice to speak up for the birds and our shared environment!
