Comment Analysis · Docket FS-2025-0001

FS-2025-0001-369203

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted September 12, 2026 On Regulations.gov

In short: The comment establishes that the Draft EIS fails to provide quantified projections for road construction, sedimentation, and landscape fragmentation for the Nantahala and Pisgah National Forests, contrasting this omission with the specific road-mile estimates provided for the Tongass National Forest in the same document.

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

Water Quality Quantity
- “supply clean drinking water”
- “degrade the headwaters that feed drinking water downstream”
- “cumulative watershed impact of new road construction”
- “downstream water quality for the communities”
Wildlife Habitat
- “last unfragmented habitat in the Southern Appalachians”
- “fragment habitat that brook trout, hellbenders, and black bear depend on”
- “wildlife there needs protecting”
- “nothing but me and the wildlife”
Recreation Tourism Public Use
- “support a regional outdoor economy”
- “hike, hunt, and fish these mountains regularly”
- “roadless character of these areas is exactly what makes them worth going to”
- “quiet beauty of the forest”
Legal Regulatory Framework
- “DEIS does not translate that purpose into a quantified projection”
- “no estimate of miles that would be constructed, no sediment delivery estimate”
- “programmatic and nationwide in nature”
- “rescission would lift the 2001 Rule's prohibitions”

What it names

National Forests: Tongass National Forest

The comment

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

I oppose the proposed rescission of the 2001 Roadless Rule as it applies to the Nantahala and Pisgah National Forests. These are not surplus lands. They are working forests that supply clean drinking water, support a regional outdoor economy, and hold some of the last unfragmented habitat in the Southern Appalachians. I am a longtime resident of Murphy, North Carolina, and I hike, hunt, and fish these mountains regularly. The Nantahala isn't scenery to me, it's where I spend my weekends. The roadless character of these areas is exactly what makes them worth going to. Being in these woods where no roads can reach, in the quiet beauty of the forest, with nothing but me and the wildlife, gives me a peace that nothing else compares to. We need these wild places preserved for our children. The wildlife there needs protecting, the clean water needs protecting, the wild, untouched forest needs protecting. New roads would fragment habitat that brook trout, hellbenders, and black bear depend on. They would degrade the headwaters that feed drinking water downstream, and open hunting and fishing grounds I currently rely on to logging traffic and development. I ask that the Forest Service address the cumulative watershed impact of new road construction in the Nantahala, not just the acreage affected but the downstream water quality for the communities that depend on these headwaters. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range — "a 4 to 10 percent increase in total sawtimber harvest" (p. 30) — and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining three quarters — roughly 30.8 million acres — receive none.