Comment Analysis · Docket FS-2025-0001

FS-2025-0001-358169

Opposes rescissionA0 noneSubstance 6/24Posted September 12, 2026 On Regulations.gov

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

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

  • Recreation Tourism Public Use
    • “Quiet, undeveloped recreation on roadless lands supports local economies”
    • “We lose some of the most beautiful areas for hiking”
    • “irreplaceable lands for... our enjoyment”
  • Wildlife Habitat
    • “Recreation disturbance has measurable effects on wildlife”
    • “irreplaceable lands for wildlife”
    • “brings additional disturbance through dust, soil compaction, and vegetation damage”
  • Environmental Protection Biodiversity
    • “roadless areas function as a qualitatively distinct public resource”
    • “The forests don't need fewer protections”
    • “The Roadless Rule should stay”

What it names

National Forests
Pisgah National ForestSix Rivers National Forest
Roadless areas
Craggy Mountain
Works cited
10.1371/journal.pone.0167259

The comment

Dear Ms. Rollins: In my years as an outdoor enthusiast accessing the interior portions of national forests, I have observed that roadless areas function as a qualitatively distinct public resource, and it is from this vantage that I oppose the Department's proposed rescission of the 2001 Rule. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf) Rescinding the Roadless Rule would open the Craggy Mountain, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. We lose some of the most beautiful areas for hiking and wildlife in the US. These are irreplaceable lands for wildlife and our enjoyment and for generations that come after us. The forests don't need fewer protections. The Roadless Rule should stay. Gratefully, Simon Neuwahl

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