Comment Analysis · Docket FS-2025-0001

FS-2025-0001-273928

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The comment documents that the Linville Gorge Addition in Pisgah National Forest contains habitat for the Small Whorled Pogonia threatened by logging (IUCN-CMP 5.3), and asserts that the agency's proposal fails to provide a clear public interest showing or evaluate NEPA effects on this species and water quality, while citing substantial public opposition and scientific data on the conservation value of roadless areas.

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

Wildlife Habitat
- “degrading habitat for Small Whorled Pogonia”
- “308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas”
- “substantial decrease (-38) in the number of wildlife SCCs that are currently considered 'poorly represented'”
Water Quality Quantity
- “headwaters of our great rivers and the largest source of municipal water supply”
- “Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher”
- “vital for maintaining clean drinking water for communities across the country”
Public Opinion Support
- “more than 99.8% of submitters opposed the rescission”
- “76% of likely voters support the Roadless Rule compared to just 13% opposed”
- “More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025”
Recreation Tourism Public Use
- “hiking, rock climbing, and trail running”
- “peace tranquility and connection to our Earth”
- “jeopardizes nearly 58 million acres of undeveloped backcountry forestland”

What it names

National Forests: Pisgah National Forest
Roadless areas: Linville Gorge Addition

The comment

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

Dear Ms. Rollins, The 2001 Roadless Rule is doing exactly what it was designed to do — and I've seen the results on the ground. I have spend many hours in Linville Gorge, hiking, rock climbing, and trail running. Building roads leading to eventual logging would drastically change my experience and the peace tranquility and connection to our Earth that I and many other folks get out of visiting these wilderness areas. The Rule has preserved the conditions that make connections of this kind possible for twenty-five years; the Department should not rescind it without a clear showing that the public interest is better served by doing so — a showing the proposal does not make. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 5.3 - Logging & wood harvesting (IUCN-CMP 5.3) is actively degrading habitat for Small Whorled Pogonia (Isotria medeoloides, G2) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Moderate or 11-30% pop. decline severity across Large - restricted scope. Absent roads, Linville Gorge Addition functions as a refuge where Small Whorled Pogonia is buffered from 5.3 - Logging & wood harvesting. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Small Whorled Pogonia (Isotria medeoloides) in the Linville Gorge Addition Inventoried Roadless Area, including the documented threat of 5.3 - Logging & wood harvesting. "Of the 537 wildlife species of conservation concern in CONUS, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas (IRAs). The median IRA contains suitable habitat for 10 wildlife species of conservation concern, with a maximum of 62 wildlife SCCs. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA CONUS lands. If all IRAs were added to the protected-area system in CONUS, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas." — Global Ecology and Conservation (ScienceDirect), 2021 The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Rescinding the Roadless Area Conservation Rule would be an unjustified reversal of long-settled land management policy. With determination, Christian Rust