Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603208

Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov

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

  • Wildlife Habitat
    • “destroy the places and wildlife that I love”
    • “supports species dependent on stable, unwarmed water”
    • “hellbender (*Cryptobranchus alleganiensis*, near threatened, IUCN)”
    • “seepage salamander (*Desmognathus aeneus*, near threatened, IUCN)”
  • Water Quality Quantity
    • “protects the headwaters of Dicks Creek and Cowrock Creek”
    • “regulate streamflow and temperature across the entire downstream drainage”
    • “negatively impact water quality”
    • “hydrological stability and undisturbed soil structure”
  • Environmental Protection Biodiversity
    • “harbors multiple rare plant species adapted to the specific microclimates”
    • “small whorled pogonia (*Isotria medeoloides*, federally threatened)”
    • “increase the introduction and spread of invasive species”
    • “increase erosion”
  • Recreation Tourism Public Use
    • “place I go for peace, recreation, and wildlife appreciation”
    • “destruction in one of the things that most makes America great --- our wild and scenic spaces”
    • “benefits those of us who enjoy or live near the forests”

What it names

National Forests
Chattahoochee National Forest
Roadless areas
Boggs Creek
Works cited
10.1111/csp2.288

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

To the Roadless Rule Rulemaking Team:Edit salutation I am writing as a naturalist and concerned citizen opposing the rescission of the Roadless Rule. The proposal would destroy the places and wildlife that I love. I am concerned about how it would affect the Chattahoochee National Forest, a place I go for peace, recreation, and wildlife appreciation. Boggs Creek in the Chattahoochee National Forest protects the headwaters of Dicks Creek and Cowrock Creek, which form the foundation of a cold-water stream network that supports species dependent on stable, unwarmed water. The hellbender (*Cryptobranchus alleganiensis*, near threatened, IUCN), a fully aquatic salamander that requires high dissolved oxygen and temperatures below 74°F, depends on the riparian shade and groundwater inputs that an intact, roadless headwater forest provides. The seepage salamander (*Desmognathus aeneus*, near threatened, IUCN) and Chattahoochee slimy salamander (*Plethodon chattahoochee*, imperiled, IUCN) occupy the saturated seepage zones and riparian margins of these headwater systems, where they are sensitive to both temperature fluctuation and hydrological disruption. Maintaining the roadless condition preserves the forest canopy and soil structure that regulate streamflow and temperature across the entire downstream drainage. Boggs Creek harbors multiple rare plant species adapted to the specific microclimates of Southern Appalachian cove forests and seepage zones: small whorled pogonia (*Isotria medeoloides*, federally threatened), mountain sweet pepperbush (*Clethra acuminata*, apparently secure, IUCN), mountain dwarf-dandelion (*Krigia montana*, vulnerable, IUCN), jewelled wakerobin (*Trillium simile*, vulnerable, IUCN), and mountain meadow-rue (*Thalictrum clavatum*, apparently secure, IUCN). These species occupy narrow ecological niches—seepage slopes, cove bottoms, and specific soil and moisture conditions—that are vulnerable to disturbance and slow to recover. The roadless condition protects the hydrological stability and undisturbed soil structure these plants require; once disrupted, the recovery of rare plant populations can take decades or longer, if restoration is possible at all.Edit personal connection We are already watching the decline of too many beloved species. The proposed rescission is a bad idea unsupported by science that would exacerbate and accelerate that loss. It will increase the introduction and spread of invasive species. It will increase erosion. It will negatively impact water quality. It will cause destruction in one of the things that most makes America great --- our wild and scenic spaces. I see no way that it benefits those of us who enjoy or live near the forests, only irreparable, irreversible loss.Edit what you lose Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land, expanding the six largest core protected areas in the lower 48 by an average of 25 percent. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including temperate grasslands and cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Please accept my entire formal comment attached as FS-2025-0001-223869_RLC-20261007-I1RDZT.pdf I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. Respectfully, Sarah E. Kelsey

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