Comment Analysis · Docket FS-2025-0001

FS-2025-0001-397759

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted September 14, 2026 On Regulations.gov

In short: The comment places on the record specific evidence that road construction in the Craggy Mountain area of Pisgah National Forest generates significantly more sediment than undisturbed forest, thereby threatening local drinking water supplies and aquatic habitats, and asserts that the agency's proposed rescission lacks a sufficiently developed basis to overturn the 2001 Roadless Rule.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
  • 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.
  • 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.
  • 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
    • “degrade drinking-water supplies”
    • “adversely affect the water quality”
    • “fresh water sources”
    • “sedimentation, and stream crossings”
  • Wildlife Habitat
    • “destroy natural habitats”
    • “disastrous for wildlife habitats”
    • “diversity of the plants and rare species”
    • “native habitats”
  • Recreation Tourism Public Use
    • “outdoor recreation is a huge industry”
    • “backcountry experiences”
    • “scenic vistas”
    • “keep the area as natural and pristine”
  • Resource Development Extraction
    • “open the area to more logging”
    • “advantage only the logging and mining industries”
    • “open these areas to logging and mining”
    • “road construction and associated ground disturbance”

What it names

National Forests
Pisgah National Forest
Roadless areas
Craggy Mountain
Works cited
10.1029/wr020i011p0175310.1111/j.1752-1688.2007.00016.x

The comment

To the Roadless Rule Rulemaking Team: As an outdoor enthusiast, I am entering the record to observe that the 2001 Roadless Area Conservation Rule represents a considered administrative judgment that the public interest in roadless national forest — ecological, recreational, and watershed-related — outweighs the interests served by road-building authorization, and that the Department's proposed rescission has not offered a sufficiently developed basis for overturning that judgment. I am 74 years-old and have been enjoying the beauty of these Blue Ridge Mountains most of my life. I live near the Pisgah National Forest and have hiked with my children and grandchildren in the Craggy Mountain area and other parts of Pisgah Forest nearby. We have appreciated the diversity of the plants and rare species, the natural ecology, and the beautiful, clear streams and waterfalls and realize how important these places are as native habitats and our own fresh water sources. We live on the outskirts of Asheville, which draws its drinking water from that unroaded watershed. A rescission of the Roadless Rule could adversely affect the water quality. It would also open the area to more logging which would destroy natural habitats and scenic vistas. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) 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. I am deeply concerned that the rescission of the Roadless Rule will degrade the natural areas we love and depend on. Not only does it affect our watershed and could adversely affect our clean water which has been why national breweries have located here, but could be disastrous for wildlife habitats. These landscapes are central to our region's identity and economy. Outdoor recreation is a huge industry in western North Carolina and what draws so many people to the area. Removing the Roadless Rule could open these areas to logging and mining and destroy what makes this area unique and valuable for outdoor recreation and backcountry experiences. The rescission of the Roadless Rule seems to advantage only the logging and mining industries and not the people who live and visit here who want to keep the area as natural and pristine as possible. Roadless areas are some of the most special places we have left in the Southern Appalachians. Once roads go in, they may never be able to be restored. The roadless areas deserve protection. That's what the Rule gives them. Keep it. With thanks, Carolyn Hill CommentID: RLC-20260914-F9631P

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