Comment Analysis · Docket FS-2025-0001

FS-2025-0001-580448

Opposes rescissionA2 moderateSubstance 15/24Owed an answerPosted October 6, 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 that the agency's proposal to rescind the Roadless Area Conservation Rule fails to reconcile its justification with its own DEIS data on wildfire risks and economic costs, uses an incorrect denominator for small business impact analysis, and ignores specific reliance interests in Pisgah National Forest.

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

Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “reconcile the rescission with the ignition data in DEIS Table 21”
Recreation Tourism Public Use
- “quiet, safe, and genuinely wild place”
- “recreation losses of at least $6.1 million a year”
- “I bike in the Pisgah area... I hike Pisgah because the natural areas provide a safe, quiet environment”
- “guides and outfitters serving visitors at places like Bearwallow”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “net present value spanning -$92 million to +$199 million”
- “road maintenance backlog already sitting at $6.9 billion”
- “Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year”
Governance Policy Process
- “The agency must identify and weigh the interests described in the comments it receives”
- “The regulatory flexibility analysis reaches its no-impact conclusion by spreading the expenditure loss across every small firm”
- “An agency changing course must assess the reliance interests its prior policy created”

What it names

National Forests: Pisgah National Forest
Roadless areas: Craggy Mountain

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 Blue ghosts are fireflies native to Southern Appalachia. In order to find a mate, they need total darkness so males can locate the softly glowing females in the understory. My Entomologist wife and I travel every summer to Pisgah National Forest, where for a few weeks each year you can see thousands of these insects glowing together in the woods. That single fact tells you what rescinding the 2001 Roadless Area Conservation Rule would cost people like me: a quiet, safe, and genuinely wild place, replaced by the uncertainty that comes when roads open land that has so far stayed closed. The agency's own record makes the wildfire case against this proposal better than I can. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on fuels management grounds. I ask that the agency explain, in terms specific to the 18 inventoried roadless areas totaling 99,369 acres in the Pisgah alone, why it is departing from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification is no stronger. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Set against that, the Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit, and it does not account for a road maintenance backlog already sitting at $6.9 billion across the national forest system. I bike in the Pisgah area of Mills River. I hike Pisgah because the natural areas provide a safe, quiet environment. The value of those uses does not vanish because it is hard to book. I ask that the agency reconcile the proposal with its own numbers before proceeding. The small-business certification compounds the problem. 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. Bearwallow, a 4,113-acre roadless area in Pisgah, is the kind of place where that economy runs: a mountaintop meadow with panoramic views of Western North Carolina, unique enough that we take guests there for morning hikes precisely because of the experience it offers. The guides and outfitters serving visitors at places like Bearwallow and the 2,657-acre Craggy Mountain area are not a national average. The regulatory flexibility analysis reaches its no-impact conclusion by spreading the expenditure loss across every small firm in the sector nationally, rather than assessing the permit holders operating in the affected areas. That is the wrong denominator. The agency should withdraw the certification and assess the impact on the small entities actually working in these roadless areas. Finally, 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. This comment is one such interest. North Carolina holds 38 inventoried roadless areas totaling 172,416 acres, and across the Southern region 378 municipal water intakes sit in watersheds containing affected roadless areas. People have organized their summers, their guest experiences, and their expectations of what Pisgah will be around protections the 2001 rule put in place. An agency changing course must assess the reliance interests its prior policy created, not merely invite comments about them and then ignore them in the analysis. The agency must identify and weigh the interests described in the comments it receives, including this one, before any final action. Sincerely, [Your Name] [Your City, State]