Comment Analysis · Docket FS-2025-0001

FS-2025-0001-292200

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted August 31, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to account for network-level connectivity impacts on 28 shared species by analyzing Tusquitee Bald and Chunky Gal in isolation, and cites empirical evidence of habitat fragmentation and wildfire risks to argue that rescission of roadless protections should be denied.

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
    • “habitat for multiple threatened and vulnerable plant species”
    • “interior habitat—forest far from edges—that is essential for the Carolina northern flying squirrel”
    • “severing connectivity for species including Bog Turtle”
    • “drastic habitat loss and landscape fragmentation”
  • Environmental Protection Biodiversity
    • “globally rare ecosystems maintained by natural disturbance”
    • “unfragmented Northern Hardwood and High Elevation Red Oak forests”
    • “connectivity function sustaining 28 shared species”
    • “dismantle that protection”
  • Legal Regulatory Framework
    • “The Department's obligation under the APA is to provide reasoned explanation”
    • “that obligation has not been met, and rescission should be denied”
    • “The DEIS must analyze these IRAs jointly”
    • “systematically understates the ecological cost of rescission”
  • Forest Management Wildfire
    • “roads are where most human-caused wildfires start”
    • “historic grassy balds are globally rare ecosystems maintained by natural disturbance (historically fire)”

What it names

National Forests
Nantahala National Forest
Roadless areas
Chunky Gal (addition)Tusquitee Bald

The comment

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

To the U.S. Forest Service: Being a resident near roadless national forest means I've had years to observe what the 2001 Rule's protections actually do on the ground — and what I've observed is that they work, in the quiet, consistent way that good rules work. The record must take into account the rest of the story: roads are where most human-caused wildfires start. Tusquitee Bald's approximately 72 acres of historic grassy balds are globally rare ecosystems maintained by natural disturbance (historically fire) and represent habitat for multiple threatened and vulnerable plant species. Financially, the budget for the current roads is being stretched thin. Adding more roads adds more burden. The areas that sustain that connection are roadless precisely because the 2001 Rule has held; the proposal before the Department would dismantle that protection. Regarding the Tusquitee Bald in the Nantahala National Forest, North Carolina: Interior Forest Habitat for Federally Endangered Flying Squirrels and Bats — The area's unfragmented Northern Hardwood and High Elevation Red Oak forests provide interior habitat—forest far from edges—that is essential for the Carolina northern flying squirrel (federally endangered), which requires large, continuous… The 28 species shared between Tusquitee Bald and Chunky Gal (addition) illustrate that road impacts do not respect IRA boundaries. A road built in either area fragments the 11.8-mile corridor both populations depend on, severing connectivity for species including Bog Turtle (G2), Carolina Northern Flying Squirrel (T2), Eastern Hellbender (T2), Gray Myotis (G3), Indiana Myotis (G2), Northern Myotis (G2), Red-legged Salamander (G3), Rock Gnome Lichen (G3), Small Whorled Pogonia (G2), Tricolored Bat (G3), Virginia Spiraea (G2), Whooping Crane (G1). The impact is bilateral: construction in one IRA degrades the ecological function of both. Area-by-area analysis of Tusquitee Bald and Chunky Gal (addition) systematically understates the ecological cost of rescission because the connectivity function sustaining 28 shared species — including Bog Turtle (G2), Carolina Northern Flying Squirrel (T2), Eastern Hellbender (T2), Gray Myotis (G3), Indiana Myotis (G2), Northern Myotis (G2), Red-legged Salamander (G3), Rock Gnome Lichen (G3), Small Whorled Pogonia (G2), Tricolored Bat (G3), Virginia Spiraea (G2), Whooping Crane (G1) — exists only at the network level. The DEIS must analyze these IRAs jointly to capture impacts that isolated analysis misses entirely. "The effective MESH metric showed that after the construction of the highway, the area of forest, rangeland habitats and protected area will decrease by 20,537, 49,149, and 71,822 ha, respectively. Our findings revealed drastic habitat loss and landscape fragmentation associated with construction of the highway." — Mohammadi & Fatemizadeh 2021, Frontiers in Ecology and Evolution, 2021 The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. With best wishes, CommentID: RLC-20260830-BRZU9D

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