Comment Analysis · Docket FS-2025-0001

FS-2025-0001-541368

Opposes rescissionA3 weakSubstance 11/24Owed an answerPosted October 4, 2026 On Regulations.gov

Exact copy — Byte-identical to another submission. This comment stands for 2 submissions in its group.

In short: The comment documents the commenter's personal use of the Upper Wilson Creek, Lost Cove, and Harper Creek areas and requests the retention of the 2001 Roadless Rule and selection of the 'No Action' alternative, citing concerns about sediment contamination and loss of wildness.

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
- “swum in the sparkling clear and refreshing water”
- “streams and waterfalls are among the cleanest in the state”
- “roads are major sources of sediment that can contaminate these water sources”
- “harm the streams and waterfalls”
Environmental Protection Biodiversity
- “biodiversity that these Roadless Areas contain is extraordinary”
- “change the function of the ecosystem”
- “healthy forests and a degree of wildness”
- “wildlife that has inhabited it for much longer than humans”
Recreation Tourism Public Use
- “exploring in the Upper Wilson Creek Inventoried Roadless Area”
- “hiking, swimming, and camping”
- “how wild and peaceful they feel”
- “deep connection to the land”

What it names

Roadless areas: Harper CreekLost CoveWilson Creek

The comment

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

For as long as I can remember, I have spent my springs, summers, and falls exploring in the Upper Wilson Creek Inventoried Roadless Area. I’ve hiked to Hunt Fish Falls and Gragg Prong Falls and swum in the sparkling clear and refreshing water there. I’ve learned about indicator species and closely examined how these streams and waterfalls are among the cleanest in the state. These are some of my favorite places in the North Carolina mountains. The Forest Service has acknowledged that roads are major sources of sediment that can contaminate these water sources and change the function of the ecosystem. I’m concerned that opening roadless areas to additional road construction will very likely harm the streams and waterfalls that make Lost Cove and Harper Creek so special. One of the features of Roadless Areas that I love most is how wild and peaceful they feel. When I am out hiking and swimming in these areas I feel a deep connection to the land and the wildlife that has inhabited it for much longer than humans. The North Carolina mountains are among the oldest mountains in the world, and the biodiversity that these Roadless Areas contain is extraordinary. The existing Roadless Rule already allows some road construction and timber cutting when needed for public safety, resource protection and ecosystem restoration. I would like the Forest Service to explain why those exceptions are inadequate and why eliminating the rule nationwide is necessary. My experiences hiking, swimming, and camping in Upper Wilson Creek, Lost Cove and Harper Creek has shown me what we stand to lose. These places have clean water, healthy forests and a degree of wildness and solitude that is increasingly rare in our rapidly developing and urbanizing world. Please retain the 2001 Roadless Rule and select Alternative 1, the ‘No Action’ alternative.