Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602775

Opposes rescissionA2 moderateSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the DEIS fails to adequately analyze the downstream consequences of road construction on drinking water quality for specific communities (Hendersonville, NC), the impact of invasive species on T&E species, and the factual inaccuracy of the claim that road building reduces wildfire risk, while citing specific local impacts and peer-reviewed data to support the No Action Alternative.

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

Water Quality Quantity
- “Roadless areas provide clean drinking water to many downstream communities”
- “impacts to water quality, but it never adequately analyzes how this would impact drinking water”
- “source of drinking water to the city of Hendersonville”
- “degrade the water quality for that community”
Environmental Protection Biodiversity
- “Roads are the primary cause of habitat fragmentation, sedimentation, and invasive species introduction”
- “impact that will have on native species, especially T&E species”
- “habitat for many plant and animal species needing unfragmented forest conditions”
- “introduction of NNIS”
Recreation Tourism Public Use
- “world-class hiking and mountain biking trails”
- “Our community relies heavily on tourism and a major draw is mtn biking”
- “negatively impact the backcountry nature of this area”
- “unmatched back country recreational opportunities”
Forest Management Wildfire
- “Wildfires are 4 times more likely to start near a road than in a roadless forest”
- “Roads are ignition corridors”
- “The Roadless Rule already allows the Forest Service to do wildfire prevention work”
- “Nearly 2 million acres of roadless areas have received hazardous fuel treatments”

What it names

National Forests: Pisgah National Forest
Roadless areas: South Mills River

The comment

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

I am commenting on the USFS plan to rescind the 2001 Roadless Rule. The plan to rescind the Roadless Rule is ill-conceived and I urge selection of the No Action Alternative. The DEIS fails to address the protections and values the Roadless Rule provides and fails to adequately analyze the impacts road building and other resource disturbing activities would have on these areas. Roads are the primary cause of habitat fragmentation, sedimentation, and invasive species introduction in forest ecosystems. While the DEIS discusses the impacts from rescinding the Rule, it never addresses the “so what” question. In other words, recognizing there will be impacts doesn’t fully address what the consequences are from those impacts. I.e. the DEIS acknowledges sediment loading, from road building, impacts to water quality, but it never adequately analyzes how this would impact drinking water for communities that rely on these water sources. Implying BMPs will offset any impacts doesn’t fully analyze the negative impacts to water quality and how that would impact communities, fisheries, etc. The same goes for introduction of NNIS. The DEIS acknowledges building roads will lead to the introduction of NNIS but never adequately analyzes the impact that will have on native species, especially T&E species, or on the difficulty of forest regeneration with the introduction of NNIS. Roadless areas provide clean drinking water to many downstream communities. Peer-reviewed research published in PLOS Water found that these areas serve as the primary protection mechanism watersheds that supply drinking water to 25 million U.S. citizens. I live in Western North Carolina, and the South Mills River Roadless area in the Pisgah NF is source of drinking water to the city of Hendersonville. Allowing roads to be built in this area would degrade the water quality for that community. This area recieves a large amount of rainfall and intense rain events. No amount of BMPs can provide adequate protection to that situation. Roadless areas also provide world-class hiking and mountain biking trails, supports local businesses, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. Getting rid of the Roadless Rule puts all these incredible benefits at risk. I live in an area that is a gateway to the Pisgah NF. Our community relies heavily on tourism and a major draw is mtn biking, especially in the South Mills River roadless area. Allowing roads to be built in the area would negatively impact the backcountry nature of this area and enjoyment many gain from that experience. While the EIS claims getting rid of the Roadless Rule will help prevent wildfires, the facts don’t back that claim up. Wildfires are 4 times more likely to start near a road than in a roadless forest. Roads are ignition corridors, and about 89 percent of wildfires nationally are human-caused. Far from preventing wildfire, building roads boosts wildfire ignitions. The DEIS fails to adequately address this discrepancy. Additionally, the Roadless Rule already allows the Forest Service to do wildfire prevention work and fight fires in roadless areas. The rule does not prohibit wildfire fuel reduction work; projects like prescribed burning and vegetation thinning can and do take place within these protected zones. Nearly 2 million acres of roadless areas have received hazardous fuel treatments since the rule was adopted in 2001 The majority of these roadless areas contain steep slopes which makes road construction extremely expensive and exacerbates the impacts to soil and water resources. Opening these areas to road construction will only add to the issue the Forest Service has with road maintenance, which is severely underfunded. The Forest Service is not able to maintain the over 370,000 miles of road it currently has, and has a $5.4 billion deferred maintenance backlog for roads. It receives a fraction of the funding needed to maintain what it has, much less any new roads in rugged terrain. Unmaintained roads can lead to landslides and lower water quality, which threatens the health of entire ecosystems. The agency can’t afford what it has and should not worsen the situation by adding more roads. How will adding to the maintenance costs be addressed and resolved? The DEIS is written in a pre-decisional manner. It appears to be written to justify rescinding the roadless rule and downplays the value of these roadless areas while understating the impacts from opening these areas up to road construction. One of the main arguments that these areas need to be opened up to address wildfire potential just doesn’t hold water. The Roadless Rule has been in effect for 25 years, providing clean water for many municipalities, habitat for many plant and animal species needing unfragmented forest conditions and unmatched back country recreational opportunities. These values deserve to be protected.