Comment Analysis · Docket FS-2025-0001

FS-2025-0001-402579

Opposes rescissionA0 noneSubstance 7/24Posted September 14, 2026 On Regulations.gov

In short: The comment establishes that rescinding the 2001 Roadless Rule would permit road construction and ground disturbance in the Linville Gorge Addition of the Pisgah National Forest, which the commenter argues would fragment habitat and degrade water quality, while also documenting a discrepancy between Forest Service testimony and GIS data regarding the proximity of roadless areas to the Wildland-Urban Interface.

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

  • Water Quality Quantity
    • “waterfalls, rivers, and streams are a vital part of life”
    • “national forests supply drinking water to at least 124 million people”
    • “Roads are a major cause of water pollution”
    • “protects these headwaters, it is vital for maintaining clean drinking water”
  • Wildlife Habitat
    • “hundreds of species of wildlife here”
    • “fragment habitat, introduce disturbance, and eliminate roadless character”
    • “Without wildlife, bees, running water like rivers, streams and waterfalls, we are extinct”
    • “Clearing hundred year old trees and native wild flowers that help evolution is the dumbest thing”
  • Environmental Protection Biodiversity
    • “These mountains and forests are ALIVE and well, and they do not need human hands disturbing them”
    • “Nature is not to be messed with”
    • “jeopardizes 44.5 million acres of undeveloped backcountry forestland”
    • “Twenty-five years is a long time for a rule to survive legal challenge and still be standing. That durability means something. Keep it.”
  • Governance Policy Process
    • “A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres”
    • “The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction”
    • “calling it 'our primary concern'”
    • “Less than 5% of inventoried roadless area acreage is in close proximity to the WUI”

What it names

National Forests
Pisgah National Forest
Roadless areas
Linville Gorge Addition

The comment

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

Brooke L. Rollins and Tom Schultz, I've grown up in North and South Carolina since I was 2 years old. I'm now 36. Going hiking in the Blue Ridge mountains and beyond. Going to Western Carolina University, Lake Summit, Lake Jocassee and Lake Lure, Asheville for years of Yoga trainings and weekend hikes with friends. Watching the whole entire infrastructure change completely after the devastation that was Hurricane Helene. These mountains and forests are ALIVE and well, and they do not need human hands disturbing them. The waterfalls, rivers, and streams are a vital part of life in Linville Gorge and surrounding areas in the Mountains and hills of North Carolina. Not to mention the hundreds of species of wildlife here. If we do not have wildlife and don't protect their habitats, ours will surely implode soon after. We are already losing bees at alarming rates because of Data Centers and the sounds and frequencies they emit. Without bees, we die. If this rule is rescinded, I lose all sanity. Nature is not to be messed with. It is the most important thing that we have in this life. It brings us closer to God. It teaches us invaluable lessons we wouldn't learn otherwise in life. We are not the most important race in this world. Nature was here far before we ever existed. Why are we always trying to destroy what has only helped us?? Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Rescinding the Roadless Rule would open the Linville Gorge Addition, 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. These mountains are alive and well and have been here far before we ever existed or were even a thought. Humans are always trying to destroy what hasn't even hurt them. We are not the most important living thing on this earth. Without wildlife, bees, running water like rivers, streams and waterfalls, we are extinct as we know it. Clearing hundred year old trees and native wild flowers that help evolution is the dumbest thing we could do. And for what?? More money in pockets of people who already have too much??? If we continue to chase evil, karma will surely give you what you deserve. Nature is healing, nature is for everyone. Without it, we will cease to exist. Stay out of our Forrests and mountains. We have to leave Gods creation alone to teach us what we have yet to learn. We cannot try and change or manipulate something that is the wisest thing of all. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Twenty-five years is a long time for a rule to survive legal challenge and still be standing. That durability means something. Keep it. Yours truly, CommentID: RLC-20260914-40C4IV

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