Comment Analysis · Docket FS-2025-0001

FS-2025-0001-331636

Opposes rescissionA2 moderateSubstance 12/24Owed an answerPosted September 7, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to evaluate the impact of Roadless Rule rescission on the Appalachian Dragonhead Pogonia in the Linville Gorge Addition, specifically regarding the threat of invasive non-native species facilitated by road infrastructure, which constitutes a failure to consider an important aspect of the problem under NEPA.

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

Recreation Tourism Public Use
- “exploring and enjoying the roadless Wilderness”
- “rock climb, paddle, hike, mountain bike, and guide waterfall rappelling”
- “sense of safety and calm and rejuvenation”
- “inspiration and healing I get from looking over the wild expansive landscape”
Environmental Protection Biodiversity
- “habitat fragmentation and create edges”
- “spread of invasive alien plants”
- “Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3)”
- “Invasive non-native/alien species/diseases”
Water Quality Quantity
- “Increases in fine sediments are known to change grain size distribution”
- “degradation of spawning grounds”
- “sustained clogging”
- “negative impacts on embryo survival of gravel-spawning fish”
Legal Regulatory Framework
- “failed to consider an important aspect of the problem”
- “standard basis for finding an EIS inadequate under NEPA”
- “administrative record spanning more than two decades argues against rescission”

What it names

National Forests: Pisgah National Forest
Roadless areas: Linville Gorge Addition
Works cited: 10.1111/ddi.70002

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter

The comment

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

Dear Brooke L. Rollins, Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: To the Roadless Rule Rulemaking Docket: I am writing to advocate for the Roadless Rule. I have spent the best days of my life exploring and enjoying the roadless Wilderness. I rock climb, paddle, hike, mountain bike, and guide waterfall rappelling. I have noticed that the nearer I am to a road the more trash and graffiti I encounter. The animals are startled, and also I don't experience the same sense of safety and calm and rejuvenation. The Linville Gorge is one of my favorite places on earth. I climbed my first 500 foot trad route there and it changed my life. I was able to face my fears and overcome them successfully. I climbed above the birds and watched them play in the sunlight below me. I looked out over the roadless expanse of beautiful wilderness and it filled my soul with gratitude, peace, hope and presence. I have traveled to many places and I stay on the east coast to be near the Linville Gorge. The ability to experience a place that feels untouched connects me with something timeless, my self relience, my ability to persevere in a world of obstacles. Yes, others have been there before me, but the landscape remains the same and the inspiration and healing I get from looking over the wild expansive landscape would be completely destroyed by the sight of roads or manmade disruptions. "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” NatureServe threat assessment data document that Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3,) in the Linville Gorge Addition IRA, Pisgah National Forest, faces 8.1 - Invasive non-native/alien species/diseases at Moderate or 11-30% pop. decline severity across Large (31-70%) scope. Roads enable the equipment access, land conversion, and human activity that activate 8.1 - Invasive non-native/alien species/diseases. Without road infrastructure, the extractive and development pressures behind this threat category cannot reach Appalachian Dragonhead Pogonia habitat in Linville Gorge Addition. If the DEIS does not evaluate how rescission affects Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3) in Linville Gorge Addition with respect to 8.1 - Invasive non-native/alien species/diseases, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. An administrative record spanning more than two decades argues against rescission; the Department should act accordingly. With respect, CommentID: RLC-20260905-EKAHLJ