Comment Analysis · Docket FS-2025-0001

FS-2025-0001-431921

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 16, 2026 On Regulations.gov

In short: The comment establishes that the agency's analysis of the rescission of the Roadless Area Conservation Rule fails to quantify carbon storage changes, reconcile its own economic data showing no net benefit, or explain the reversal of its 2001 finding that local planning was inadequate, specifically regarding the habitat and recreation values in Pisgah National Forest.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

  • 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.
  • 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.
  • 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.

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.
  • 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.

Topics

  • Environmental Protection Biodiversity
    • “most biodiverse temperate forests in North America”
    • “protect the last wild headwaters”
    • “black bear, hellbender, brook trout, cerulean warbler”
    • “irreversible habitat fragmentation”
  • Recreation Tourism Public Use
    • “peaceful place that cannot be rebuilt”
    • “hike, fish, explore, and enjoy”
    • “recreation losses of at least $6.1 million per year”
    • “untouched natural beauty”
  • Climate Carbon Storage
    • “contain about 5 percent of the stored forest carbon”
    • “roughly 0.9 billion metric tons”
    • “quantify projected changes in carbon storage”
    • “logging and road construction actually do to that figure”
  • Governance Policy Process
    • “held none to undo it”
    • “procedurally indefensible”
    • “declares changes to plans beyond the scope”
    • “reversed a factual finding without explaining why”

What it names

National Forests
Pisgah National Forest
Roadless areas
Harper CreekLost CoveWilson Creek
Law cited
66 FR 3244

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The dense old wood forests, rolling hills, and untouched natural beauty of places like Lost Cove and Linville Gorge are why I visit the roadless areas of Pisgah National Forest. I go to photograph wildflowers, animals, and beautiful landscapes. I have hiked in Wilson Creek, Lost Cove, and Linville Gorge, and what I find there, every time, is the kind of peaceful place that cannot be rebuilt once it is gone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these places. It has held none to undo it. I want my kids and grandchildren to have these places to hike, fish, explore, and enjoy all of the beauty that is here. That is the full weight of my objection to Docket FS-2025-0001. The Nantahala and Pisgah National Forests together hold 32 inventoried roadless areas covering more than 150,000 acres. North Carolina as a whole holds 38 inventoried roadless areas totaling 172,416 acres. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the roadless areas of Nantahala-Pisgah protect the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, along with black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. I mentioned that roads would destroy animal habitat and that endangered species live in all of these areas. The verified record for this forest confirms exactly that. I ask that the agency address, specifically, how it weighs the irreversible habitat fragmentation of these documented species communities against any claimed benefit of rescission. The agency's own economic numbers do not support this action. The record before the agency states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal return, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million per year, set against recreation losses of at least $6.1 million per year and a net present value ranging from -$92 million to +$199 million, while the road system already carries a $6.9 billion maintenance backlog. No net benefit is established. I ask the agency to reconcile this proposal with its own numbers and explain how an action with such an unresolved economic range justifies expanding infrastructure the agency cannot currently maintain. The agency's handling of future plan amendments is procedurally indefensible. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot honestly ask the public to comment on a consequence it has simultaneously ruled outside its own analysis. Harper Creek and the surrounding Pisgah roadless areas sit directly in the path of the expanded harvest that foreseeable amendments would permit. I ask that the agency include a full analysis of the plan-amendment scenario, with projected acreage and road-construction impacts, before this rulemaking proceeds. The climate consequences of rescission are stated and then abandoned. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The DEIS then concludes that these lands will continue to sequester and store carbon without analyzing what logging and road construction actually do to that figure. That is not analysis; it is an assumption dressed as a finding. The agency must quantify projected changes in carbon storage and sequestration under each alternative before this rule can be finalized. Finally, the agency has reversed a factual finding without explaining why. "The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule." What has changed? The wilderness have not become less biodiverse. The roads have not built themselves back into wilderness. An agency that found local planning inadequate in 2001 owes the public a clear account of the evidence that reversed that conclusion. The agency has not provided one, and it must. Sincerely, [Mary Archer Vann [Banner Elk, North Carolina

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