Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604372

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment places on the record specific geographic impacts in Western North Carolina (Pisgah and Nantahala National Forests, Linville Gorge, Craggy Mountain, Black Mountains, South Mills River headwaters) and cites a 2026 Fire Ecology study and the 2001 EIS to demonstrate that the proposed rescission's wildfire rationale is contradicted by evidence showing higher ignition density near roads and no difference in large fire size between roaded and roadless areas.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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.
  • 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.
  • 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.
  • 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

  • Forest Management Wildfire
    • “wildfire rationale is contradicted by the evidence”
    • “wildfires were four times more likely to ignite within 50 meters of a road”
    • “prohibiting road construction would not increase acres burned”
    • “Repeal is not a wildfire solution”
  • Wildlife Habitat
    • “Seventy percent of roadless areas are home to native trout or salmon”
    • “Hellbenders, warblers, and trout depend on them”
    • “roads and logging fragment these lands”
  • Water Quality Quantity
    • “protects drinking water in 354 municipal watersheds”
    • “headwaters of the South Mills River”
    • “Roadless areas protect water”
  • Public Opinion Support
    • “more than 99% of comments opposed repeal”
    • “164 members of Congress have urged the Department to retain the rule”
    • “Leading conservation organizations... all oppose this rescission”

What it names

Roadless areas
Craggy MountainSouth Mills River

The comment

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

To the U.S. Department of Agriculture and the Forest Service: I write in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I urge the Department to adopt Alternative 1, No Action, and keep the Roadless Rule fully in place. I equally oppose Alternative 3, which would open most inventoried roadless areas in the East to logging. The wildfire rationale is contradicted by the evidence. A peer-reviewed study published in Fire Ecology in January 2026 found that from 1992 to 2024, wildfires were four times more likely to ignite within 50 meters of a road than in forest without motor vehicle routes. Ignition density in Inventoried Roadless Areas was 1.97 fires per 1,000 hectares, compared with 7.99 near roads. Fires that escaped initial attack, the ones that become large and catastrophic, showed no meaningful size difference between roaded and roadless areas. The Forest Service reached the same conclusion itself: its 2001 environmental impact statement found that building roads into roadless areas would likely increase human-caused fires, and that prohibiting road construction would not increase acres burned or the number of large fires. The rule already allows hazardous fuels reduction and other management where needed. Repeal is not a wildfire solution. Roadless areas protect water and wildlife. The Roadless Rule protects drinking water in 354 municipal watersheds. Seventy percent of roadless areas are home to native trout or salmon. These benefits cannot be rebuilt once roads and logging fragment these lands. The public has spoken, repeatedly. The original rule followed 600 public meetings and 1.6 million comments gathered over 18 months. In the 2025 comment period, more than 99% of comments opposed repeal. 164 members of Congress have urged the Department to retain the rule. Leading conservation organizations, including The Wilderness Society, Sierra Club, Trout Unlimited, Earthjustice, the Natural Resources Defense Council, Outdoor Alliance, and MountainTrue, all oppose this rescission. A short comment window with no public meetings is not adequate for a decision of this scale. This is personal for me. I am a native of Western North Carolina. About 15% of the Pisgah and Nantahala National Forests are Inventoried Roadless Areas, places like Linville Gorge, Craggy Mountain, the Black Mountains, and the headwaters of the South Mills River. Hellbenders, warblers, and trout depend on them. These mountains and the protected forests within them are worth more to me than almost anything. They are, without doubt, one of the most valuable jewels in our nation's possession, and they, along with the countless other forests across our nation, deserve our protection and stewardship. As Wendell Berry wrote, "There are no unsacred places; there are only sacred places and desecrated places" We must not allow our public lands to become desecrated. Please retain the 2001 Roadless Rule in full. Sincerely, Matthew Metcalf Asheville, North Carolina

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