Comment Analysis · Docket FS-2025-0001

FS-2025-0001-591874

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the presence of Paulownia tomentosa in the Wesser Bald area of the Nantahala National Forest and requests that the final EIS and rule quantify the incremental risk and cost of invasive species establishment under Alternatives 2 and 3, or explain the exclusion of this category from the Cost Benefit Analysis.

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
    • “protect the area from the invasion of non-native species”
    • “value hiking in areas where only native species are growing”
    • “displacing fern, moss, and lichen communities sensitive to disturbance”
    • “Roadless areas are priceless and irreplaceable”
  • Recreation Tourism Public Use
    • “I hike the trails of the Wesser Bald area”
    • “treasure the view from the summit of Wesser Bald”
    • “lose the experience of hiking in an undisturbed area”
    • “found a lifelong value in many roadless areas”
  • Governance Policy Process
    • “In the final EIS: supplement the Non-Native Invasive Plant Species analysis”
    • “In the final rule: add an invasive-species establishment and treatment line to Table 1”
    • “state on the record why an estimate is available for those categories and not for this one”

What it names

National Forests
Nantahala National Forest
Roadless areas
Wesser Bald

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Own letter

The comment

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

Dear Secretary: I have found a lifelong value in many roadless areas across the country. This rule matters in a way that's hard to separate from everything I do outdoors. Intact land is irreplaceable. Roads end that. I hike the trails of the Wesser Bald area, treasure the view from the summit of Wesser Bald and want to protect the area from the invasion of non-native species. I have seen Paulownia tomentosa (Princess Tree), an invasive species, growing in the Wesser Bald vicinity. I am concerned that road building in the Wesser Bald area could contribute to its spread. I value hiking in areas where only native species are growing. If roads were built in this area, I lose the experience of hiking in an undisturbed area. Regarding the Wesser Bald in the Nantahala National Forest, North Carolina: Road disturbance changes soil in ways that favor invaders. Road construction alters soil pH, nutrient availability, moisture, and bulk density. These changes create conditions in which non-native plants outcompete native species — particularly displacing fern, moss, and lichen communities sensitive to disturbance I request two specific actions, in two forums. In the final EIS: supplement the Non-Native Invasive Plant Species analysis with an alternative-specific estimate of the acreage at incremental risk of invasive establishment under alternatives 2 and 3 and of the associated detection and treatment cost, using the same programmatic assumptions applied to recreation and passive use values in the Cost Benefit Analysis; or state on the record why an estimate is available for those categories and not for this one, and identify the specific design features and management requirements relied on to conclude that invasives “are not expected to greatly increase.” In the final rule: add an invasive-species establishment and treatment line to Table 1 of the Cost Benefit Analysis, or explain in the preamble why that category is excluded from the quantified cost column when the analysis identifies it at p. 27 as an effect of road construction. Roadless areas are priceless and irreplaceable. They represent a heritage we have received and are obligated to protect in perpetuity. I want the Department to understand that opposition to this rescission is genuine, and I'm one more voice adding to it. Yours sincerely, Stewart Stokes CommentID: RLC-20261006-PF7EAV

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