Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606790

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's proposed rescission of the 2001 Roadless Area Conservation Rule lacks sufficient analysis to justify exposing predominantly old-growth and mature forests in the Pisgah and Nantahala National Forests to timber harvest, and fails to reconcile its forest health and fire management rationales with its own data showing minimal constraints on fuel treatments and comparable initial attack success rates in 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

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

Water Quality Quantity
- “rivers and watersheds that move through these lands supply drinking water”
- “water treatment for people in Haywood and surrounding counties”
- “puts all of that at risk”
Environmental Protection Biodiversity
- “how pristine and intact everything was”
- “exposing predominantly mature and old-growth forest to logging”
- “irreplaceable stands could be harvested”
Forest Management Wildfire
- “agency's stated rationale for rescission rests on a forest health argument”
- “initial attack success rates would be expected to increase”
- “reconcile its forest health rationale with those findings”
Governance Policy Process
- “agency's own document does not justify it”
- “agency must respond to this gap”
- “I do not trust that what is meant for the benefit and enjoyment of the people will be treated that way”

What it names

Roadless areas: Smoky Mountains

The comment

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

My family has been rooted in the mountains of Western North Carolina for generations. On a recent trip, my best friend and I hiked trails in both the Pisgah and Nantahala National Forests, staying with my great-grandmother's sister. We photographed trees, mountains, bodies of water, wildlife. What drew us was how pristine and intact everything was. The rivers and watersheds that move through these lands supply drinking water and water treatment for people in Haywood and surrounding counties near the Smoky Mountains. I am opposing the proposed rescission of the 2001 Roadless Area Conservation Rule because it puts all of that at risk, and the agency's own document does not justify it. The agency's data on forest composition undercut the case for opening these lands to timber harvest. In the section titled Implications for Forest Vegetation, Health, and Carbon, the document states that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest" in the operable areas most likely to be affected. Old and mature stands together make up the overwhelming majority of the timberland the rescission would open. The document identifies no old-growth-specific protections beyond general land management plan compliance before those irreplaceable stands could be harvested. The agency must respond to this gap: what analysis justifies exposing predominantly mature and old-growth forest to logging without a dedicated protection framework? The agency's stated rationale for rescission rests on a forest health argument that the document itself does not consistently support. In the section titled Rationale for the Proposed Rule, the agency states that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet elsewhere the document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency needs to reconcile its forest health rationale with those findings before treating rescission as a valid remedy. The fire management argument fares no better. Under the Fire Control section, the agency asserts that "With increased road access, initial attack success rates would be expected to increase." But the document's own data show 94.4 percent initial attack success in roadless areas compared to 97.2 percent on other forest land, and it acknowledges that less-than-full suppression strategy is applied more often in roadless areas, a factor the comparison does not isolate. The document also expects most new roads to be temporary timber spurs, not strategic fire access routes. The agency should separate the effect of roads from suppression strategy in the initial attack figures, and estimate how many fire-useful roads are actually expected given real funding constraints. I want my tax money flowing toward hiring new employees, maintenance, equipment, and resources for the agencies that actually protect these places. How are we supposed to steward and protect our public lands if we cut funding and freeze hiring for the people who are supposed to make that happen? Public lands are managed by individuals with histories in extractive industries, and combined with this proposal, I do not trust that what is meant for the benefit and enjoyment of the people will be treated that way. Leave the Roadless Rule intact. Degrading what is meant to be cherished and preserved is irresponsible and insulting to ourselves and to future generations who are supposed to receive these lands as well.