Comment Analysis · Docket FS-2025-0001

FS-2025-0001-528599

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 1, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS cites specific findings on habitat fragmentation, elk survival, and carbon storage but fails to project these effects across the 40.1 million acres of potentially affected environment, and requests that the agency quantify these impacts and identify unresolved administrative burdens before finalizing the rescission.

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, 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
- “Southern Appalachians are among the most biodiverse temperate forests”
- “sheltering salamander species found nowhere else on Earth”
- “Mushrooms and moths depend on intact forest structure”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
Climate Carbon Storage
- “climate consequences of rescission are stated and then dropped”
- “inventoried roadless areas contain about 5 percent of the stored forest carbon”
- “roughly 0.9 billion metric tons”
- “quantify the projected change in carbon storage and sequestration”
Governance Policy Process
- “agency's justifications do not hold up against its own record”
- “agency has not shown what burden remains”
- “A finding about survival rates is not analysis”
- “process that cites its own findings and walks away from them”
Water Quality Quantity
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “headwaters those forests protect flow to both the Atlantic and the Gulf”

What it names

National Forests: Nantahala National Forest
Roadless areas: Tusquitee Bald
Law cited: 36 C.F.R. Section 294.12

Attachments

5 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter
Own letter
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The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Tusquitee Bald is the most beautiful place I have ever seen, and I want it to continue to exist. That is why I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I photograph mushrooms and moths, both key players in our ecosystems, in the forests of North Carolina. I watch animals there. I live near this land and I do not want wildfires near my home. What the agency is proposing to undo is the protection that makes these things possible. Tusquitee Bald covers 13,670 acres in the Nantahala National Forest. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres, and 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, sheltering salamander species found nowhere else on Earth, black bear, hellbender, brook trout, cerulean warbler, and the northern long-eared bat. Mushrooms and moths depend on intact forest structure. Road building fragments that structure. The proposal to rescind the rule threatens all of it, and the agency's justifications do not hold up against its own record. The agency cites permitting and administrative burden as grounds for rescission, but the rule as written already contains the flexibility that justifies this complaint. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If community wildfire concerns, existing mineral leases, and public safety situations are already addressed by those exceptions, the agency has not shown what burden remains. I ask that the agency identify, specifically and with quantification, which administrative burdens are not already resolved by the rule's existing exceptions, and that it place that accounting in the record before any final action is taken. The biodiversity consequences of opening these lands to road building are not speculative. The agency's own document states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then abandoned. No projection follows for the 40.1 million acres of potentially affected environment. For a forest system that harbors more than 30 endemic salamander species and the ecological networks that sustain the fungi and invertebrates I photograph, a finding of that magnitude demands more than a footnote. The agency must apply that cited fragmentation range to the full 40.1 million acres of potentially affected environment and explain the result. The agency's record speaks just as plainly about large mammals. "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." That finding appears and goes nowhere. No projection of population-level effects on big game follows anywhere in the document, and no estimate of what rescission would mean for hunter opportunity is offered. A finding about survival rates is not analysis. The agency should project those effects before this rule is rescinded. Finally, the climate consequences of rescission are stated and then dropped. "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." Across the Southern Appalachians, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the headwaters those forests protect flow to both the Atlantic and the Gulf. The DEIS concludes that carbon storage will continue under each alternative, but it does not analyze what harvest and roading would actually change. Storing 0.9 billion metric tons is a fact that belongs at the center of this decision, not its margin. The agency must quantify the projected change in carbon storage and sequestration under each alternative. Tusquitee Bald deserves better than a process that cites its own findings and walks away from them. Sincerely, Amanda Schabdach Marble, North Carolina