Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604311

Opposes rescissionA2 moderateSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the Draft EIS at page 220 contains an unsourced FY2024 recreation visitation figure and an unresolved NVUM citation supporting Alternative 3 economics, while identifying specific impacts to Pisgah National Forest, Wilson Creek, Lost Cove, and Harper Creek in North Carolina.

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.

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

Recreation Tourism Public Use
- “network of small businesses that thrive on use of these roadless areas for recreational hiking, hunting, fishing, camping”
- “Tourists, hunters, anglers, backpackers and the small companies that support them? Gone”
- “The Parkway is a CRITICALLLY important economic driver in our area”
- “hiking, whitewater kayaking, trout fishing, and camping in the mountains of North Carolina”
Environmental Protection Biodiversity
- “animal-and-plant life be-damned devastations”
- “native state will not be recoverable in my lifetime”
- “flora and fauna that make them so distinct in our southern Appalachians”
- “Preserving the current state of these lands will be a legacy to be proud of”
Water Quality Quantity
- “When those waterways are filled with silt, devoid of fish, slimed with algae”
- “never a Hellbender to be found again”
- “love being near, on and in local creeks and rivers”
- “soil depleting”
Economic Impact Fiscal
- “Repealing the Roadless Act will devastate local economies”
- “corporations strip the resources out of their rural economies”
- “The people profiting will not be local”
- “no plausible significant benefit economically”

What it names

National Forests: Pisgah National Forest
Roadless areas: Harper CreekHarper CreekLost CoveWilson Creek

The comment

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

Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220 The recreation visitation figure supporting the Alternative 3 economics is unsourced, and the visitor-use citation it points toward does not resolve. Repealing the Roadless Act will devastate local economies including where I’ve spent much of my life, and currently vote, the northwest counties of North Carolina. Pisgah National Forest, Wilson Creek, Lost Cove and Harper creek are three designated areas that will be impacted. I’ve reviewed the arguments for and against rescission. Those for it seem specious and thinly veiled. Returning local well-paying jobs for timber harvesting to local communities? Wistful nostalgia for Paul Bunyan's days. And one of the most dangerous occupations. This will be mechanized, industrial clear cutting. With soil depleting, animal-and-plant life be-damned devastations. Their native state will not be recoverable in my lifetime, yours, your grandchildren, or ever for some species of plants and animals. We don’t need to go back to the 19th century so timber and mining companies can revert to their harmful practices but using massive modern machinery. Preserving the current state of these lands will be a legacy to be proud of. Defeating this rescission is an effort will trickle down the generations in a positive way. In stated terms for rescission regarding state sovereignty and local governments, the network of small businesses that thrive on use of these roadless areas for recreational hiking, hunting, fishing, camping and other activities is far more important than having corporations strip the resources out of their rural economies. This is an extremely important part of the economy in the NC High Country. In fact, many areas targeted are not roadless but provide enough access for recreational use. No new roads needed to add to the existing burden on the U.S. Forest Service to maintain the ones already in place because of budget constraints and limited resources. The people profiting will not be local. May not even be American, especially in mining? They certainly won’t be the families in Watauga and Avery counties who can’t afford European vacations but love being near, on and in local creeks and rivers. When those waterways are filled with silt, devoid of fish, slimed with algae, and never a Hellbender to be found again, someone will have some explaining to do about the thinly veiled excuses for changing the Roadless Act that has worked well so far in the 21st century. When these areas are irreparably damaged, what will happen then? Jobs? No. Tourists, hunters, anglers, backpackers and the small companies that support them? Gone. You can bet Washington will no longer be talking about wildfire management and access for forest management in the face of climate change, which involved administration officials supporting the rescission likely deny is even happening. Government overreach? The original Roadless act was a protective, responsible, ‘parental’ hand over lands millions of Americans use and love. We also love areas that can’t be used because they are wild and remote. We like them that way. The rescission would be a fist slammed down for an obvious massive giveaway to corporations. Neglectful of local communities, forest management, and unconcerned about the economic and recreational opportunities that will be lost. That’s abusive. There are almost 20,000 acres near my home in Blowing Rock, NC that will be affected in Pisgah National Forest, Wilson Creek, Lost Cove and Harper Creek. Other areas important to me are in the Nantahala and southern Pisgah region. Almost my entire adult life I have made some of my most cherished memories hiking, whitewater kayaking, trout fishing, and camping in the mountains of North Carolina. My entire life I’ve enjoyed the Blue Ridge Parkway; asphalt I do love. The USFS map showing areas that will be impacted are heavily dotted along the Parkway in NC. I can't imagine what rescission could do to the viewsheds. Encroachments from rapid development, loss of agrarian life, and too-narrow protected corridors has already changed it. Clear cutting, road building, mining, documented INCREASED wildfires after more roads will be awful. The Parkway is a CRITICALLLY important economic driver in our area. I love our southern Appalachian Mountains. Repealing the Roadless Act is a short-sighful obvious handout to corporate interests. There is no plausible significant benefit economically, ecologically, recreationally, for MILLIONS of Americans who use these lands. Or for the flora and fauna that make them so distinct in our southern Appalachians. Stay the course by keeping the Roadless Act intact. Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220