Comment Analysis · Docket FS-2025-0001

FS-2025-0001-597404

Opposes rescissionA0 noneSubstance 10/24Posted October 6, 2026 On Regulations.gov

In short: The comment establishes that the proposal to rescind the 2001 Roadless Area Conservation Rule fails to adequately consider the economic value of conservation-based tourism and the costs of road maintenance in specific western North Carolina locations, while documenting the commenter's standing as a resident, user, and property investor in those areas.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Recreation Tourism Public Use
- “frequent user of the Pisgah National Forest”
- “regularly hike, backpack, fish, camp, and explore the backcountry”
- “premier outdoor recreation destination”
- “diminish the recreational experience that supports tourism”
Environmental Protection Biodiversity
- “fragment wildlife habitat”
- “introduce invasive species”
- “serve as critical habitat for wildlife”
- “preserve the remote forests”
Water Quality Quantity
- “contribute sediment to streams”
- “water quality and aquatic ecosystems are highly sensitive”
- “protect important public benefits... clean drinking water”
- “impacts... on water quality”
Economic Impact Fiscal
- “economic health of many mountain communities”
- “long-term financial obligations”
- “economic benefits that protected public lands provide”
- “negative economic impacts for western North Carolina”

What it names

National Forests: Pisgah National Forest
Roadless areas: Wilson Creek

The comment

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

Public Comment Opposing the Rescission of the 2001 Roadless Area Conservation Rule To Whom It May Concern: I am a North Carolina resident and frequent user of the Pisgah National Forest, the Wilson Creek Wild and Scenic River Area, and the Linville Gorge Wilderness Area. I am writing to strongly oppose the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule. My interest in this issue is both personal and economic. My family and I regularly hike, backpack, fish, camp, and explore the backcountry areas protected by the Roadless Rule. These lands provide some of the most outstanding recreational opportunities in the Southeast. In addition, I recently invested in a short-term rental property in western North Carolina that depends heavily on visitors who come to the region specifically to recreate in these public lands. The long-term viability of my investment, and the economic health of many mountain communities, depends on maintaining the natural character of these landscapes. The Roadless Rule protects undeveloped national forest lands from most road construction and large-scale timber harvesting activities. These protections have helped preserve the remote forests, clean streams, wildlife habitat, and scenic character that make western North Carolina a premier outdoor recreation destination. Rescinding the Rule would increase the potential for road construction, logging, and other disturbances in currently protected backcountry areas. Roads are among the most environmentally damaging forms of forest development. They fragment wildlife habitat, increase erosion, introduce invasive species, and contribute sediment to streams. These impacts are especially concerning in the steep terrain of the southern Appalachians, where water quality and aquatic ecosystems are highly sensitive to disturbance. The proposal also fails to adequately consider the economic value of conservation-based tourism. Visitors travel to western North Carolina to experience wild rivers, undeveloped forests, scenic overlooks, waterfalls, and backcountry trails. Communities across the region benefit from spending at lodging establishments, restaurants, outfitters, guide services, and local businesses. As a short-term rental owner, I see firsthand that many guests choose this area because of access to places such as Pisgah National Forest, Wilson Creek, and Linville Gorge. Degrading these landscapes would diminish the recreational experience that supports tourism and local economies. The Roadless Rule has also helped protect important public benefits that extend beyond recreation. Roadless areas provide clean drinking water, store carbon, reduce flooding impacts, and serve as critical habitat for wildlife. Once roads are built and forests fragmented, the ecological and recreational values that make these areas special can be difficult or impossible to restore. I am also concerned that the proposal does not fully account for the costs associated with expanding the National Forest road network. The Forest Service already faces a substantial backlog of road maintenance needs. Building additional roads in previously undeveloped areas could create long-term financial obligations while reducing the environmental and recreational values that the public currently enjoys. For these reasons, I respectfully recommend that the USDA: 1.Reject the proposal to rescind the 2001 Roadless Area Conservation Rule. 2.Maintain existing protections for inventoried roadless areas. 3.Fully evaluate the impacts of increased road construction and habitat fragmentation on water quality, wildlife, recreation, and tourism-dependent economies. 4.Recognize the substantial economic benefits that protected public lands provide to western North Carolina communities through outdoor recreation and tourism. In conclusion, the Roadless Rule has successfully protected some of our nation's most valuable public lands for more than two decades. As someone who regularly recreates in the Pisgah National Forest, Wilson Creek Wild and Scenic River Area, and Linville Gorge Wilderness Area, and as a recent investor in a tourism-dependent short-term rental property, I believe rescinding this rule would result in unnecessary environmental damage, diminished recreation opportunities, and negative economic impacts for western North Carolina. I urge the USDA to retain the Roadless Rule and continue protecting these irreplaceable landscapes for future generations. Thank you for considering my comments. Sincerely, Brad Smith North Carolina Resident