Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603505

Opposes rescissionA0 noneSubstance 9/24Posted October 7, 2026 On Regulations.gov

In short: The comment documents the commenter's personal standing in Pisgah National Forest and cites specific pages from the Roadless Rule DEIS to argue that rescinding the rule would increase wildfire risk, exacerbate soil erosion and landslides, harm biodiversity and tribal rights, and reduce economic benefits from recreation.

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

Environmental Protection Biodiversity
- “reduce biodiversity and damage critical habitat for endangered species”
- “overlap the range of more than 300 threatened, endangered, and proposed species”
- “negative impacts to fish & game species such as elk, steelhead trout, and salmon”
Recreation Tourism Public Use
- “I hike, bike and camp in these mountains every weekend”
- “Recreation & tourism are more profitable than roadless timber”
- “visitors to roadless areas spent $8.5 billion in local communities”
Tribal Sovereignty
- “violate Indigenous sovereignty”
- “Roads and timber harvest may create barriers to treaty-reserved hunting, fishing, and gathering areas”
- “diminishes hunting opportunities and violates the spirit of reserved hunting rights”
Forest Management Wildfire
- “Rescinding the roadless rule will not meaningfully reduce wildfire risk”
- “The incidence of human-caused fires generally increases with proximity to roads”
- “USFS doesn't have the budget to maintain their existing road infrastructure”

What it names

National Forests: Pisgah National Forest

The comment

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

I am completely is against rescinding the roadless rule. I live near and recreate daily in the Pisgah National Forest in NC. Over 144 acres of our pristine blue ridge mountains are at risk. I hike, bike and camp in these mountains every weekend. I work at a local outfitters and constantly give advice on hikes and activities in Pisgah to locals and tourists alike. We love these mountains and want to protect what we have left. In addition to frequenting Pisgah, each year my husband and I go out west for at least three weeks at a time. Over the past 5 years, we’ve been able to see and experience so much of the US through public lands. We stay on BLM lands and cherish the wild experiences in the vast, undeveloped nature. It’s made us quite patriotic and given us a great appreciation for public lands and the protections in place. Throughout this comment, I will be citing only from your Roadless Rule Draft Environmental Impact Statement (DEIS). Rescinding the roadless rule will not meaningfully reduce wildfire risk. In fact, it's likely to increase it."The proportion of human-caused fires in Roadless areas is less than half on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads." (pg 86; see Aplet et al. 2026). USFS doesn't have the budget to maintain their existing road infrastructure, much less new ones. The Forest Service has a $7 billion deferred maintenance backlog, and an estimated $1.6 billion is needed annually to maintain existing roadways. In 2023, the USFS received <20% of this amount for road maintenance. (pg 42) The DEIS states "...revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." (pg 45) Rescinding Roadless may degrade critical resources with downstream consequences. Timber harvest increases soil erosion, compaction, and the probability of landslides. Landslides and debris flows are 6 to 9 times more likely adjacent to forest roads. (pg 111) Soil compaction can reduce seedling establishment and survival (pg 110). Removing trees and vegetation also reduces rainfall intercepted and transpired by plants. (pg 111) Rescinding Roadless could reduce biodiversity and damage critical habitat for endangered species. Roadless areas "overlap the range of more than 300 threatened, endangered, and proposed species; 79 final or proposed critical habitats managed by USFWS; and 19 critical habitats... listed under the ESA" (pg 160) The DEIS also estimates negative impacts to fish & game species such as elk, steelhead trout, and salmon (pg 141, 152). This can reduce critical food resources that rural and Indigenous communities rely on, and that people hunt! Recreation & tourism are more profitable than roadless timber. Rescinding Roadless could actually hurt local jobs and economies. In 2024, visitors to roadless areas spent $8.5 billion in local communities during their recreation visits (pg 212). Annual economic benefits within the potentially affected roadless areas are upwards of $1.5 billion for recreation, and $419 million for hunting, fishing, and wildlife viewing. (pg 214) Rescinding Roadless may degrade cultural resources and violate Indigenous sovereignty. Indigenous communities rely on roadless areas (i.e., Native land!) for food, medicine, ceremony, and more. "Increased road infrastructure may lead to unauthorized public access, vandalism, or desecration of sacred sites" (pg 201) "Roads and timber harvest may create barriers to treaty-reserved hunting, fishing, and gathering areas... [undermining] subsistence practices, economic development, and Tribal restoration goals... affecting fisheries that are central to Tribal diets, economies, and ceremonies... and diminishes hunting opportunities and violates the spirit of reserved hunting rights." (pg 202) "Roads act as vectors for invasive plant species, which can outcompete culturally significant native plants used for food, medicine, and ceremony." (pg 202) Thank you for your time and consideration. Please listen to the voices that call these lands home. If we’re the greatest country in the world, why can’t we protect the little natural spaces we have left? Protect our land.