Comment Analysis · Docket FS-2025-0001

FS-2025-0001-432777

Opposes rescissionA0 noneSubstance 5/24Posted September 16, 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
    • “seeks out public land that hasn't been made easy”
    • “experience these places as they were originally meant to be experienced--quietly, reverently”
    • “spend time away from the busy lifestyle and noise of daily life”
    • “greater appreciation for roadless spaces”
  • Environmental Protection Biodiversity
    • “conserve currently existing species in need of these places in order to thrive”
    • “Intact roadless landscapes support functional soils, hydrology, and food webs”
    • “Connectivity, biodiversity, and microclimate buffering”
    • “Humans and other species alike rely on these areas as refuges and critical habitats”
  • Climate Carbon Storage
    • “Primary forests with the least disturbance history have the highest carbon storage”
    • “greater adaptive capacity in a changing climate”
    • “Intact forests provide ecosystem services that fragmented ones cannot”

What it names

National Forests
Pisgah National Forest
Roadless areas
Linville Gorge Addition
Works cited
10.3389/ffgc.2022.929281

The comment

Dear Secretary Brooke L. Rollins, As someone who specifically seeks out public land that hasn't been made easy, I want the Department to know that the 2001 Rule isn't regulatory excess — it's what keeps certain places worth going to. Rescission takes away the ability to experience these places as they were originally meant to be experienced--quietly, reverently. They allow millions of residents and tourists alike the ability to spend time away from the busy lifestyle and noise of daily life, and to gain a greater appreciation for roadless spaces and the desire to protect such spaces as to benefit future generations, and to conserve currently existing species in need of these places in order to thrive. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Intact forests provide ecosystem services that fragmented ones cannot. Primary forests with the least disturbance history have the highest carbon storage, the highest ecosystem-process levels, greater stability and recovery, and the lowest risk of loss. Connectivity, biodiversity, and microclimate buffering combine to give intact forests greater adaptive capacity in a changing climate (Rogers et al. 2022). — Rogers et al., 2022 (https://doi.org/10.3389/ffgc.2022.929281) 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. Roadless areas are necessary for both future enjoyment and future conservation. Humans and other species alike rely on these areas as refuges and critical habitats and need to be conserved and protected moving forward. Respectfully, Olivia Renna

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