Comment Analysis · Docket FS-2025-0001

FS-2025-0001-295622

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted September 1, 2026 On Regulations.gov

In short: The comment documents that the agency's draft environmental impact statement fails to project specific population-level effects on big game, quantify carbon storage changes, or apply cited biodiversity fragmentation ranges to the 40.1 million acres of affected environment, while identifying specific locations (Joyce Kilmer Slickrock Add., Brushy Ridge, Cheoah Bald) and requesting species-by-species disclosure of mitigation for 327 ESA-listed species.

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.

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
- “adversely affect some ESA-listed species and their designated critical habitats”
- “verified populations of black bear, hellbender, brook trout, Indiana bat”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “elk avoid roads and select unroaded habitat”
Climate Carbon Storage
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “roughly 0.9 billion metric tons”
- “quantify the change in carbon storage and sequestration”
- “what harvest and new road construction would actually release”
Recreation Tourism Public Use
- “Photography of blue herons, woodpeckers, and ospreys is what brings me to these forests”
- “the wildness is the reason”
- “scenery at Brushy Ridge and Cheoah Bald is, in my view, unmatched”
- “managed for wild animals to live peacefully”
Governance Policy Process
- “ask that the agency disclose, species by species, how the likely adverse effects... will be avoided or mitigated”
- “ESA consultation be completed and published before any final rule takes effect”
- “The record does not support that outcome”
- “No projection of what it means across the 40.1 million acres... follows anywhere in the record”

What it names

National Forests: Cherokee National Forest
Roadless areas: Brushy RidgeCheoah BaldJoyce Kilmer Slickrock Add.

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Photography of blue herons, woodpeckers, and ospreys is what brings me to these forests, and the places I am writing about, Joyce Kilmer Slickrock Add., Brushy Ridge, and Cheoah Bald, are where that kind of wildness still exists. I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The agency's own draft environmental impact statement gives me more than enough reason to say so. The biological harm the agency anticipates is not speculative. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats. The Cherokee National Forest, where both Joyce Kilmer Slickrock Add. and Brushy Ridge sit, carries verified populations of black bear, hellbender, brook trout, Indiana bat, Virginia spiraea, and the northern long-eared bat across 84,881 acres of inventoried roadless land. The Nantahala, home to Cheoah Bald, holds verified populations of black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat across 52,304 acres. These are the animals the agency anticipates adversely affecting. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule takes effect. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document and then disappears. No projection of what it means across the 40.1 million acres of potentially affected environment follows anywhere in the record. I photograph blue herons and ospreys along waterways in forests the agency's own record describes as an evolutionary crossroads, where more tree species grow than in all of northern Europe, and where the southern Appalachians protect salamander species found nowhere else on Earth. The scenery at Brushy Ridge and Cheoah Bald is, in my view, unmatched, and the wildness is the reason. That wildness is a function of habitat continuity. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what the numbers mean for the landscapes it is proposing to open. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. That finding is entered into the record and left there. No population-level effect on big game is projected anywhere in the document. What does the rescission mean for the animals that depend on these roadless areas as refuge? The agency should project the effects on big game populations before it proceeds. Carbon storage gets the same treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The document then concludes that these lands will continue to sequester and store carbon, a conclusion reached without any analysis of what harvest and new road construction would actually release. That gap is not a minor omission. The agency must quantify the change in carbon storage and sequestration under each alternative it is considering. Public land should be managed for wild animals to live peacefully. That is not a complicated position. The places I named, beautiful and wild as they are, depend on a rule the agency is proposing to remove while its own documents predict the harm that will follow. The record does not support that outcome. Sincerely, [Your Name] [Your City, State]