Comment Analysis · Docket FS-2025-0001

FS-2025-0001-579229

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's draft EIS data (specifically Table 21) contradicts the proposal's wildfire rationale by showing higher human-caused ignition density on roaded lands, and asserts that the agency failed to properly assess reliance interests and local economic impacts on small entities in the Pisgah and Nantahala National Forests.

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
    • “black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat”
    • “wildlife can be seen in their own settings rather than in habitat that has already been lost to development”
    • “salamander species found nowhere else on Earth”
  • Forest Management Wildfire
    • “human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
    • “human-caused ignitions increase in abundance with proximity to roads”
    • “Older trees (~100 years) are the next generation of old growth and already possess qualities associated with large, old trees, such as large canopies, deep root systems, and thick, fire-resistant bark”
  • Recreation Tourism Public Use
    • “I love being able to camp in places that are quiet and undisturbed”
    • “Our children went to camp in those areas and grew to value their time in the backcountry there”
    • “protect wild spaces for them to escape to”
  • Legal Regulatory Framework
    • “Under the legal standards that govern agency change of course, reliance interests created by a prior policy must be assessed”
    • “The agency must explain why it departs from its own prior findings”
    • “The agency should withdraw the certification and assess impact on the small entities actually operating inside the potentially affected roadless areas”

What it names

Roadless areas
Wild River

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 The Pisgah and Nantahala national forests have been important to my family for the last 30 years. Our children went to camp in those areas and grew to value their time in the backcountry there. I love being able to camp in places that are quiet and undisturbed, where wildlife can be seen in their own settings rather than in habitat that has already been lost to development. The Southern Appalachians hold black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres and the Pisgah 18 areas totaling 99,369 acres. These are the places I am asking the agency to protect, and I oppose rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The proposal rests in part on wildfire and fuels management as a rationale for rescission. The agency's own record undercuts that rationale. Its draft environmental impact statement reports that human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency also found that "Older trees (∼100 years) are the next generation of old growth and already possess qualities associated with large, old trees, such as large canopies, deep root systems, and thick, fire-resistant bark." I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard. The wildfire analysis is not the only place where the agency's own data cuts against its conclusions. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires, yet the proposal does not resolve that tension. The agency must explain why it departs from its own prior findings and must reconcile the rescission with what its own DEIS Table 21 reports. On economics, "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The places I have camped and watched wildlife for thirty years support exactly those businesses. The agency should withdraw the certification and assess impact on the small entities actually operating inside the potentially affected roadless areas. My family's relationship to the Pisgah and Nantahala is itself a reliance interest the proposal invites and never weighs. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." Under the legal standards that govern agency change of course, reliance interests created by a prior policy must be assessed, not simply invited and then set aside. Kids today already face extra stress from the challenges of social media, unresolved global conflicts, and inadequately addressed climate change. We need to do everything we can to protect wild spaces for them to escape to. Those spaces include the roadless headwaters of Shining Rock and Linville Gorge, which protect the last wild river sources flowing to both the Atlantic and the Gulf along with salamander species found nowhere else on Earth. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Anna Cone Franklinville, NC

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