Comment Analysis · Docket FS-2025-0001

FS-2025-0001-587219

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS and Cost Benefit Analysis fail to reconcile the minimal national production impact of the rescission with the projected local economic losses and maintenance backlogs, and that the regulatory flexibility certification improperly generalizes impacts on small entities without assessing specific local operators or reliance interests.

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

  • Recreation Tourism Public Use
    • “I backpack in Turkey Pen in the South Mills River area and hike along the Davidson River”
    • “My partner and I have paddled some stretch of almost every waterway in Western North Carolina”
    • “recreation losses of at least $6.1 million a year”
    • “outfitters, guides and tour operators as affected”
  • Environmental Protection Biodiversity
    • “among the most biodiverse temperate forests in North America”
    • “Verified species of these forests include black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat”
    • “sage grouse show strong site fidelity that limits how far they can adapt when habitat changes”
    • “protect so future generations can enjoy them as well”
  • Water Quality Quantity
    • “Headwaters here flow to both the Atlantic and the Gulf”
    • “378 municipal water intakes sit in watersheds containing affected roadless areas”
    • “Opening these lands to road construction puts all of that at risk”
  • Economic Impact Fiscal
    • “total timber volume affected by this rule is less than 0.5 percent of total United States production”
    • “net present value ranging from -$92 million to +$199 million”
    • “road system already carries a $6.9 billion maintenance backlog”
    • “reconcile the proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies expanding that road system”

What it names

National Forests
Pisgah National Forest
Roadless areas
South Mills River
Law cited
36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeAnalytical gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in North Carolina most of my life, I have come to know the wilderness here as something genuinely irreplaceable. I backpack in Turkey Pen in the South Mills River area and hike along the Davidson River. My partner and I have paddled some stretch of almost every waterway in Western North Carolina, and if we have not paddled it, we have most likely hiked along it. The South Mills River roadless area, 8,588 acres in the Pisgah National Forest, is part of what I mean when I say this place has not been touched by development. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres. North Carolina as a whole holds 38 inventoried roadless areas totaling 172,416 acres. These are not abstractions. They are the specific places I return to, and they need to be protected so future generations can enjoy them as well. Rescinding the 2001 Roadless Area Conservation Rule would end that protection, and I oppose it entirely. The agency's own record undermines the economic case for this rescission. The DEIS states that "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." Against that baseline, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, all while the road system already carries a $6.9 billion maintenance backlog. I ask the agency to reconcile the proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies expanding that road system. The Southern Appalachians, including the forests where I paddle and hike, are among the most biodiverse temperate forests in North America. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres. Verified species of these forests include black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The DEIS also names wild turkey and ruffed grouse among the game that requires complex forest structure with mast-producing trees, and notes that sage grouse show strong site fidelity that limits how far they can adapt when habitat changes. Headwaters here flow to both the Atlantic and the Gulf. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. Opening these lands to road construction puts all of that at risk. The agency has not shown how those losses would be made up. The rule as written already accommodates the permitting needs the agency invokes to justify rescission. The current 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)." Exceptions also exist for existing mineral leases and community wildfire protection. I ask the agency to identify, by name and by quantified burden, which specific operational needs are not already addressed by those existing exceptions before proceeding further. The regulatory flexibility certification attached to this proposal does not hold up. The agency 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. That conclusion is reached by spreading losses across every small firm in the sector nationally rather than examining the guides and outfitters who actually hold permits in the affected areas. The certification should be withdrawn, and the impact assessment should focus on those specific operators, not a national average. Finally, I am one of the reliance interests this proposal invites comment on and then fails to weigh. 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. My choices about where to live, where to paddle, and what to value in this landscape have been shaped by the protection this rule has provided. Why would anyone want to take away from that? It is selfish to trade the last untouched places for a fraction of a percent of national production. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Amanda Asheville, North Carolina

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