Comment Analysis · Docket FS-2025-0001

FS-2025-0001-560588

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to consider post-Hurricane Helene disaster impacts and lacks empirical evidence supporting the rationale for rescinding the Roadless Rule, while documenting specific local risks to water quality, wildlife habitat, and recreation in Pisgah and Nantahala National Forests, and requesting a No Action alternative.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

Owed an answer on Analytical gap, 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.
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.

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.
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

Environmental Protection Biodiversity
- “fragmentation of existing roadless areas jeopardize those activities”
- “create habitat that protects numerous designated Federal endangered species”
- “fragmentation reduces biodiversity with effects greatest in the smallest and most isolated fragments”
Water Quality Quantity
- “exposing slopes that erode soil resulting in sediment entering streams”
- “jeopardizing water quality throughout numerous potentially impacted areas”
- “reduced water quality”
Recreation Tourism Public Use
- “My recreation activities (hiking, mountain biking, native plant exploration, bird watching)”
- “frequent visits to both Pisgah and Nantahala National Forests”
- “jeopardize those activities for me and countless numbers of American citizen visitors”
Forest Management Wildfire
- “roads produce more (human ignition) wildfires than roadless areas”
- “Wildfires occur far less frequently in roadless areas”
- “Fire management is needed because of roads”

What it names

Roadless areas: Craggy MountainHarper CreekSouth Mills River

The comment

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

Secretary Rollins and Chief Schultz, U.S. Forest Service I write to oppose proposed rescission or restriction of the 2001 Roadless Area Conservation Rule. I reside in Madison Co, NC. My recreation activities (hiking, mountain biking, native plant exploration, bird watching) include frequent visits to both Pisgah and Nantahala National Forests. The stated rationales for the Roadless Rule change are unsupported. Fragmentation of existing roadless areas jeopardize those activities for me and countless numbers of American citizen visitors from our community and nationwide. Local concerns: 1. The DEIS violates 40 C.F.R. § 1502.15(b) in that it fails to consider post Hurricane Helene disaster impacts on our Forests including severe structural landslides and geological unstable slopes, among them at Craggy Mountain, Big Ivy, and Harper Creek. 2. Road construction clears riparian vegetation, exposing slopes that erode soil resulting in sediment entering streams, jeopardizing water quality throughout numerous potentially impacted areas throughout Pisgah and Nantahala Forests, including the South Mills River area in Pisgah. 3.Existing roadless areas throughout Pisgah and Nantahala Forests create habitat that protects numerous designated Federal endangered species or proposed Federal endangered species, including: (a) ESA-listed salmonids, (b) salamander species and (c) five species of bats. Nationally: 1. The DEIS states that the purpose of rescinding the Roadless Rule is "to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials." The DEIS posits that a "single, national blanket approach... constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service's multiple-use mission," and that the Roadless Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Nowhere are those assertions supported by empirical evidence in the DEIS. I formally request that the FEIS and the final regulatory analysis provide that empirical evidence. 2. The DEIS expressly acknowledges that considerable disturbances are caused by road construction, timber harvest and prescribed burning: common are "loss of vegetation, soil erosion and compaction, loss of soil productivity, increased potential for landslides, reduced transpiration... increased water runoff, reduced water quality, and periodically reduced air quality." I have noted above the impacts that concern me as to our Pisgah and Nantahala Forests. 2. The DEIS further states that "insufficient maintenance funding is a key reason for the lack of adequate road maintenance…" in National Forests. It defies logic to assert that building more roads for potential timber cutting makes sense when the cost/benefit assessment does not suggest economic benefit. (The DEIS cites Federal Highway Administration notes that "some data sources indicate construction costs in mountainous terrain can be 3 to 10 times more per mile than flat terrain.") The USFS should instead be laser-focused on securing from the Federal government the potentially billions of dollars need immediately to fund maintenance back log on existing roads. 3. The DEIS acknowledges the science that fragmentation reduces biodiversity with effects "greatest in the smallest and most isolated fragments." The impact on biodiversity in many of the small roadless areas targeted in the current maps far outweigh arguments in favor of the Rule repeal in those areas. 4. Further DEIS statements acknowledge evidence that roads produce more (human ignition) wildfires than roadless areas. Wildfires occur far less frequently in roadless areas. Fire management is needed because of roads. In sum, the proposed actions need to be fully evaluated in the Final Environmental Impact Statement, as required by Federal Law, to fully analyze and document the fragmentation of existing roadless areas & losses of critical natural habitat, water quality impacts due to future development, increases in wildfire damages and a quantifiable cost/benefit analysis of potential timber operations. For the foregoing reasons among others, the only action that should be taken with respect to the repeal proposal should be No Action. Sincerely, Penelope Glass