Comment Analysis · Docket FS-2025-0001

FS-2025-0001-300479

Opposes rescissionA0 noneSubstance 5/24Posted September 1, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 20 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

The comment

Subject: Deep Opposition to the Proposed Repeal of the 2001 Roadless Rule Protections for North Carolina’s National Forests (Pisgah and Nantahala National Forests). To Whom It May Concern: I am writing to express my strong opposition to the U.S. Forest Service’s proposal to repeal the 2001 Roadless Rule in North Carolina. Rescinding these federal protections places 172,000 acres of pristine, Inventoried Roadless Areas (IRAs) within the Pisgah and Nantahala National Forests at immediate risk of commercial logging, industrial development, and habitat-fragmenting road construction. These backcountry areas—including critical watersheds and iconic landscapes like the Linville Gorge, Laurel Mountain, and the South Mills River—are invaluable to the state of North Carolina for several critical reasons: Watershed Protection and Climate Resilience: These 172,000 acres act as a vital, natural filtration system that supplies clean drinking water to hundreds of thousands of residents across Western North Carolina. Maintaining intact, unfragmented forest floors is our best natural defense against catastrophic soil erosion and severe downstream flooding, which increasingly threaten our mountain communities. Economic Impact on Tourism and Recreation: Western North Carolina’s multi-billion-dollar outdoor recreation economy relies directly on the wild, uninterrupted nature of these public lands. Opening these backcountry areas to industrial use will permanently degrade the world-class hiking, fly-fishing, and climbing experiences that draw visitors from around the globe and support local businesses. Irreplaceable Biodiversity: The Pisgah and Nantahala National Forests harbor unique, ancient ecosystems and endangered wildlife species that cannot survive the disruption brought by heavy machinery and road corridors. Relying solely on local, shifting forest management plans does not offer the permanent, ironclad security that the 2001 Roadless Rule provides. Wildlife – we have already degraded and limited habitat for wildlife for decades this will only continue to push wildlife/human interactions and confrontations ultimately ending in loss of wildlife. We cannot allow this rollback of protections of our IRAs to happen, we have got to stop the destruction of our wild places for profit. I urge the U.S. Forest Service and the Department of Agriculture to reject this rollback and maintain the full, existing federal protections for North Carolina's backcountry. Thank you for your time and consideration of these public comments. Sincerely, Mrs. Rogers

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

Water Quality Quantity
- “vital, natural filtration system that supplies clean drinking water”
- “natural defense against catastrophic soil erosion and severe downstream flooding”
- “devastation of our water source during Hurricane Helene”
- “Being without potable water for more than 2 months”
Recreation Tourism Public Use
- “multi-billion-dollar outdoor recreation economy relies directly on the wild, uninterrupted nature”
- “permanently degrade the world-class hiking, fly-fishing, and climbing experiences”
- “We lost tourism - our largest source of revenue - during and after Helene”
Environmental Protection Biodiversity
- “unique, ancient ecosystems and endangered wildlife species”
- “cannot survive the disruption brought by heavy machinery and road corridors”
- “heart-breaking thing for those that care about wildlife”
Forest Management Wildfire
- “Being subject to wildfires is another excellent reason for protecting our forests”
- “Continuous forests without being broken up by roads are important in the natural management of wildfires”

What it names

Roadless areas: Laurel MountainSouth Mills River

Sharing & methodology

These results are meant to be shared.

Please cite us. This analysis is the intellectual property of Roadless.org and Nicholas Holshouser. You are welcome to reproduce it — every reproduction must include this citation:

Roadless.org and Nicholas Holshouser, “2001 Roadless Rule Revision — Substantive Analysis,” https://roadless.org.

How it works. A large language model (an open-weight Qwen3.8 model) reads each substantive comment and copies, word for word, the passages that carry its analytical gap, evidence, request, alternative and connection to the place; it returns no scores. Code grades those passages 0–3 on eight dimensions — evidence, legal grounding, engagement with the environmental analysis, analytical gaps, alternatives, specific requests, position, and local knowledge — with legal grounding taken from a citation scan, not the model. For the strongest tenth on each side, the copied passages are checked against the comment and shown as exhibits. A comment counts as “substantive” when it clears a floor filter — it must show at least one substantive signal (a named entity, a specific citation, a stated analytical deficiency, or first-person testimony), which screens out one-line and purely conclusory submissions before any model scoring.

The full method. Every step, why it is done that way, its known limits and a glossary: Methodologies →

The data. The full canonical dataset — every comment on Docket FS-2025-0001 — is available from Regulations.gov's bulk download, the canonical source: https://www.regulations.gov/bulkdownload. Download the CSV directly (Regulations.gov keeps this link working until October 18, 2026): https://bulk-downloads.regulations.gov/mv4-z8fw-q5jx.csv.

Roadless.org — analysis of the public comment docket.
Media inquiries welcome — nicholas@wanderingnature.com.