Comment Analysis · Docket FS-2025-0001

FS-2025-0001-461314

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment establishes that the rescission of the 2001 Roadless Rule is inadequate due to the short comment period and lack of public hearings in Western North Carolina, while documenting that the rule protects headwaters for 1.5 million people and that local Forest Service staff acknowledge minimal impact from rescission in the region.

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
    • “protect mountain headwaters that supply drinking water”
    • “Road building on steep Appalachian slopes causes erosion and sediment pollution”
    • “threaten water quality”
    • “Intact forest holds soil and slows runoff”
  • Public Health Wellbeing
    • “Drinking water and public health”
    • “raise water treatment costs”
    • “clean water as a basic public health issue”
    • “increase landslide and flood risk for downstream communities”
  • Forest Management Wildfire
    • “The wildfire justification doesn't hold up”
    • “Roads are linked to increased human-caused wildfire ignitions”
    • “existing rule already allows exceptions for fuel reduction”
    • “not a targeted wildfire strategy”
  • Recreation Tourism Public Use
    • “enjoying the gorgeous forests of WNC”
    • “support hunting, fishing, recreation”
    • “tourism economy WNC depends on”
    • “Linville Gorge, Joyce Kilmer-Slickrock”

What it names

Roadless areas
Black MountainSouth Mills River

The comment

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

I'm a resident of Asheville, North Carolina, and my children and I have been enjoying the gorgeous forests of WNC - including Pisgah and Nantahala for years, and I strongly oppose rescinding the 2001 Roadless Rule. I urge the Forest Service to keep the rule in place and adopt the no-action alternative. Drinking water and public health: Roadless areas in the Pisgah and Nantahala National Forests protect mountain headwaters that supply drinking water to more than 1.5 million North Carolinians. Road building on steep Appalachian slopes causes erosion and sediment pollution, which raise water treatment costs and threaten water quality. As a Certified Community Health Worker, I see clean water as a basic public health issue, not something to trade for easier timber access. Helene showed us what's at stake: After Hurricane Helene, our region knows firsthand how fragile these steep watersheds are. Intact forest holds soil and slows runoff. New roads in these areas would increase landslide and flood risk for downstream communities that are still rebuilding. The wildfire justification doesn't hold up: Roads are linked to increased human-caused wildfire ignitions. The existing rule already allows exceptions for fuel reduction where needed. Removing protections from 44.7 million acres nationwide is not a targeted wildfire strategy. The Forest Service's own local staff say the change isn't needed here: The National Forests in North Carolina have stated that rescission would likely have minimal impact on current management because of steep terrain and remote locations. If the rule isn't blocking needed work in WNC, there's no justification for removing a permanent safeguard. These places are irreplaceable: Linville Gorge, Joyce Kilmer-Slickrock, Black Mountain Crest, South Mills River, and the 32 roadless areas in Pisgah and Nantahala support hunting, fishing, recreation, and a tourism economy WNC depends on, plus habitat for species like the eastern hellbender. The public has already spoken. The 2025 scoping period drew more than 220,000 comments, about 99% opposed. The short comment period and lack of public hearings in affected regions like WNC are inadequate for a decision of this scale. Please keep the Roadless Rule in place. Sincerely, Mon Bethelwood Tucker, CCHW Asheville, NC

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