Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601480

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's regulatory flexibility analysis and wildfire risk assessment, citing DEIS data on ignition densities and habitat fragmentation, and asserts a direct reliance interest in the preservation of the Pisgah National Forest's roadless character.

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
- “more than 30 endemic salamander species, black bear, hellbender, brook trout, cerulean warbler, and the northern long-eared bat live”
- “These are among the most biodiverse temperate forests in North America”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “The loss of these roadless areas would not be an abstraction for my family”
Water Quality Quantity
- “last wild headwaters of rivers flowing to both the Atlantic and the Gulf begin”
- “North Carolina holds 378 municipal water intakes in watersheds containing affected roadless areas”
- “headwaters of safe and clean drinking water for many residents”
- “We cannot compromise our water supply in any way”
Recreation Tourism Public Use
- “returned numerous times each year for rest, recreation, and to appreciate what North Carolina holds”
- “Many days and nights spent camping in that area have been incredibly special to my family”
- “I sincerely hope these places will be preserved for future families”
- “books lost recreation benefit at a minimum of $6.1 million a year”
Legal Regulatory Framework
- “The agency's regulatory flexibility analysis certifies no significant impact on small businesses while the record says otherwise”
- “An agency reversing a twenty-year-old rule has a legal obligation to account for the reliance its prior policy created”
- “The agency should identify and weigh the reliance interests described in the comments it receives”
- “I ask that the agency withdraw the certification and assess impacts on the specific small entities”

What it names

National Forests: Pisgah National Forest

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I raised my boys in the Pisgah National Forest. I taught them to love and cherish our beautiful planet there, and we returned numerous times each year for rest, recreation, and to appreciate what North Carolina holds. Many days and nights spent camping in that area have been incredibly special to my family. I sincerely hope these places will be preserved for future families. That hope is why I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres, including places like Linville Gorge, where the last wild headwaters of rivers flowing to both the Atlantic and the Gulf begin, and where more than 30 endemic salamander species, black bear, hellbender, brook trout, cerulean warbler, and the northern long-eared bat live. These are among the most biodiverse temperate forests in North America. Anytime my family is outside, any wildlife sighting reminds us all that we share this planet with magnificent creatures. The loss of these roadless areas would not be an abstraction for my family. It would be personal. The agency's regulatory flexibility analysis certifies no significant impact on small businesses while the record says otherwise. "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 certification reaches its conclusion by averaging impacts across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. That method does not answer the question. I ask that the agency withdraw the certification and assess impacts on the specific small entities operating in the potentially affected roadless areas, not a national average. I am also writing as someone with a direct reliance interest in the rule. I raised a family around the Pisgah's roadless character, and that character shaped choices I made about where and how to do it. The agency itself invites this: "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." An agency reversing a twenty-year-old rule has a legal obligation to account for the reliance its prior policy created. This comment is one such interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. On fire, the agency's own data cuts against the proposal. I believe the risk of fire should be managed carefully, and I expected the agency's analysis to show that road access would help. It does not. "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 agency should quantify the expected increase in human-caused ignitions that new road access would bring and place that number honestly against whatever wildfire hazard reduction it claims. Roads enable development and contribute to contamination of the watershed. North Carolina holds 378 municipal water intakes in watersheds containing affected roadless areas, and these places are the headwaters of safe and clean drinking water for many residents. We cannot compromise our water supply in any way. I do not want a penny of my tax dollars used to despoil the Linville Gorge area. Seriously. The agency is already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. Building new roads into country that has none, under those conditions, makes no fiscal sense and creates permanent damage that a logged stand cannot match. A stand grows back. A road does not. On biodiversity, the agency's own science makes a finding it then declines to apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears and then nothing follows from it. No projection is applied to the 40.1 million acres of potentially affected environment. The agency should apply that cited range to the full affected acreage and explain what it means before finalizing any action. Prior generations had the foresight to set aside these public lands for health, recreation, and quality of life, including the more than 600 public meetings and 1.6 million comments that produced this rule. No equivalent process has been held to undo it. My boys should not inherit fewer of these places than I was given. Neither should theirs. Sincerely, Leigh Coulter Indian Trail North Carolina