Comment Analysis · Docket FS-2025-0001

FS-2025-0001-264820

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

In short: The comment places on the record specific geographic opposition to the rescission of the Roadless Rule in the Pisgah and Nantahala National Forests, supported by three peer-reviewed scientific citations demonstrating that road development increases wildfire ignition risk and causes habitat fragmentation and biodiversity loss.

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

Environmental Protection Biodiversity
- “Southern Appalachian region is among the most biodiverse temperate areas on the globe”
- “richness and variety not only in the many species of plants, fungi, archaea, etc., but also the genetic diversity”
- “roads lead to habitat loss and fragmentation, including biodiversity loss”
- “conservation planning specifically for biodiversity can and does also preserve the ecosystem services”
Scientific Research Evidence
- “direct you to this peer-reviewed scientific article”
- “direct you to another peer-reviewed article”
- “Here is one more article to illustrate the point”
- “As those of you in charge of making these decisions tend not to be scientists”
Forest Management Wildfire
- “justification for reneging on the Roadless Rule has been "wildfire reduction"”
- “human-caused wildfires... tend to be started in much greater concentrations near roads”
- “road development is a net negative for ecosystem function”

What it names

Works cited: 10.1007/s40823-017-0020-610.1016/j.apgeog.2011.09.00410.1371/journal.pbio.0040379

The comment

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

Hello, I am a resident of Madison County NC, and a small business owner running a native plant nursery focused on the native plants of the Blue Ridge. For a number of years have spent time outdoors in the Pisgah and Nantahala National Forests here. I am writing to express my opposition to rescinding the Roadless Rule which conserves over 170,000 acres in North Carolina alone. As those of you in charge of making these decisions tend not to be scientists, I'd like to make sure you are aware of a number of facts before deciding the fate of this currently conserved land. As we know from the study of ecology, human beings exist in an interconnected web with all other living beings on the planet. Making changes to one part of the web inevitably creates changes across the web, oftentimes leading to a crescendo of affect to areas of that web that were not originally targeted. Some of the ecosystem services that human society depends upon for its very survival include filtration of air and water, erosion control, crop pollination, and nutrient cycling. You may or may not be aware that the Southern Appalachian region is among the most biodiverse temperate areas on the globe. The term biodiversity refers to richness and variety not only in the many species of plants, fungi, archaea, etc., but also the genetic diversity contained within individual species. I'd like to direct you to this peer-reviewed scientific article which describes how conservation planning specifically for biodiversity can and does also preserve the ecosystem services which we rely upon for survival: Chan KMA, Shaw MR, Cameron DR, Underwood EC, Daily GC (2006) Conservation Planning for Ecosystem Services. PLoS Biol 4(11): e379. https://doi.org/10.1371/journal.pbio.0040379 That article also has an extensive reference list at the end in case you'd like to brush up on the subject. I see that some of the justification for reneging on the Roadless Rule has been "wildfire reduction." I would also like to direct you to another peer-reviewed article showing that human-caused wildfires (the bigger, more damaging catagory) tend to be started in much greater concentrations near roads and in areas where roads are in high density: Ganapathy Narayanaraj, Michael C. Wimberly, Influences of forest roads on the spatial patterns of human- and lightning-caused wildfire ignitions, Applied Geography, Volume 32, Issue 2, 2012, Pages 878-888, ISSN 0143-6228, https://doi.org/10.1016/j.apgeog.2011.09.004. It is well documented that roads lead to habitat loss and fragmentation, including biodiversity loss. Of course as we are aware, the proposed development in our precious conservation areas will not end with just roads. Further development and habitat alteration will have its own consequences in turn. Here is one more article to illustrate the point that road development is a net negative for ecosystem function: Bennett, V.J. Effects of Road Density and Pattern on the Conservation of Species and Biodiversity. Curr Landscape Ecol Rep 2, 1–11 (2017). https://doi.org/10.1007/s40823-017-0020-6 As a citizen and member of the local business community, I oppose rescinding the Roadless Area Conservation Rule as it goes against the best interest of the human population of the United States of America.