Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604557

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

Environmental Protection Biodiversity
- “fragmented habitat”
- “recovery of species such as the hellbender salamander”
- “wilderness character that existed before it may take generations to recover”
- “Some places are worth more left wild”
Recreation Tourism Public Use
- “experience a landscape that has not been divided, paved, graded, developed, and commercialized”
- “They come to hike, backpack, hunt, fish, camp, watch wildlife, photograph waterfalls, climb ridges, and experience solitude”
- “diminishing the wilderness experience that brought visitors to the region”
- “experience something they cannot find in a parking lot or behind a ticket booth”
Economic Impact Fiscal
- “Communities throughout Appalachia increasingly depend on outdoor recreation”
- “A road through a previously roadless area doesn't necessarily help these communities”
- “Those costs ultimately fall on taxpayers”
- “Is the permanent environmental and financial cost worth whatever short-term benefit we believe the road will provide?”
Water Quality Quantity
- “altered watersheds”
- “Our streams have improved”
- “photograph waterfalls”

What it names

Roadless areas: Smoky Mountains

The comment

I strongly oppose any proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Jon Morgan, and I live in Blountville, Tennessee, in the heart of the Southern Appalachian region and within reach of both the Cherokee and Pisgah National Forests. These mountains are not an abstract concept to me. They are part of the landscape I live in, enjoy, and want my children and future generations to inherit. We need to be honest about what is at stake. For generations, we treated our public forests as if the resources they contained were unlimited. We logged these mountains aggressively, altered watersheds, fragmented habitat, and nearly lost iconic species such as the American chestnut, once one of the dominant trees of the Appalachian forest. Thankfully, we learned from those mistakes. Our forests have recovered. Our streams have improved. Wildlife has returned. Conservation efforts have helped make possible the reintroduction of elk to the Great Smoky Mountains and the recovery of species such as the hellbender salamander in places like Rocky Fork State Park. That progress did not happen because we built more roads. It happened because we protected the land. The roadless areas protected by this rule are not empty pieces of federal property waiting for someone to find a reason to develop them. They are some of the last remaining places where Americans can experience a landscape that has not been divided, paved, graded, developed, and commercialized. And that matters. The true beauty of America isn’t found in castles, ancient pyramids, or man-made monuments. America’s great treasure is the land itself. People travel to the Appalachian Mountains because they want to experience something they cannot find in a parking lot or behind a ticket booth. They come to hike, backpack, hunt, fish, camp, watch wildlife, photograph waterfalls, climb ridges, and experience solitude. They come because they have seen these mountains in photographs and want to stand in them themselves. If we continue putting roads through these places, we risk destroying the very thing people came to see. There is also an economic argument that cannot be ignored. Communities throughout Appalachia increasingly depend on outdoor recreation. Trail towns, outfitters, restaurants, hotels, campgrounds, gas stations, and small businesses benefit from visitors who come specifically to experience public lands. A road through a previously roadless area doesn’t necessarily help these communities. In some cases, it can actually hurt them by changing travel patterns, bypassing established communities, fragmenting trails, and diminishing the wilderness experience that brought visitors to the region in the first place. We should also remember that a road is not just a line on a map. A road requires construction, maintenance, bridges, drainage, erosion control, snow and storm management, and eventually rehabilitation. Those costs ultimately fall on taxpayers. Before we open additional roadless areas, we should be asking a very simple question: Is the permanent environmental and financial cost worth whatever short-term benefit we believe the road will provide? In many cases, I believe the answer is no. Once a road is constructed, the decision is essentially permanent. The trees can be cut down in a matter of days. The road can be built in months. But the wilderness character that existed before it may take generations to recover—if it ever does. We have enough developed land. We have enough roads. We have enough places where Americans can drive their vehicles, park, shop, and build. What we don’t have enough of is wilderness. The federal government should not treat every acre of public land as an opportunity for development. Some land should simply be protected because its value is greater left intact than it would ever be after development. That isn’t anti-growth. It is responsible stewardship. I urge you to reject any proposal that would weaken or rescind the Roadless Area Conservation Rule. Protect these lands not just for the people who hike them today, but for the children and grandchildren who will judge us by what we chose to preserve. We have already learned what happens when we take too much from these mountains. Let’s not make the same mistake twice. Some places are worth more left wild. The Appalachian Mountains are one of those places. Please protect them.