Comment Analysis · Docket FS-2025-0001

FS-2025-0001-608839

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific local impacts in Western North Carolina, including sedimentation risks to 378 municipal water intakes and increased wildfire risk on roaded lands, while citing the agency's own record to demonstrate that the proposed rescission lacks economic justification and fails to reconcile with prior scientific findings.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Environmental Protection Biodiversity
- “Southern Appalachians are among the most biodiverse temperate forests”
- “protect the last wild headwaters”
- “more than 30 endemic salamander species found nowhere else on Earth”
- “wild Peregrin Falcon”
Water Quality Quantity
- “378 municipal water intakes sit in watersheds containing affected roadless areas”
- “sedimentation from harvest can promote excessive substrate movement”
- “negatively impact fish such as bull trout”
- “enjoy clean, safe water”
Forest Management Wildfire
- “Opening these forests to more construction and alteration will not diminish wildfire risk”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “Table Rock fire in 2014”
- “reconcile the rescission with this finding”
Economic Impact Fiscal
- “generating $17.8 billion dollars for the state”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning negative $92 million to positive $199 million”
- “road system already carries a $6.9 billion maintenance backlog”

What it names

National Forests: Pisgah National Forest
Roadless areas: Wilson Creek
Law cited: 36 C.F.R. Section 294.12

The comment

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

I oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. I was born and raised in Western North Carolina a state that has over 172,000 protected areas of forest, this acreage was and still is my back yard. The places I am writing about are real and specific. Just the other day, standing on Sam's Knob, I saw my first wild Peregrin Falcon. I have seen Monarch way stations along the Blue Ridge Parkway which would be affected by this recension. I have spent countless hours photographing these mountains, from the Linville Gorge Wilderness to Roan Mountain and the Shining Rock Wilderness. I photograph landscapes, flora, and fauna alike, including the region's salamander populations and trout. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the roadless areas of the Pisgah National Forest, all 18 of them totaling 99,369 acres, protect the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, along with more than 30 endemic salamander species found nowhere else on Earth. The trout I photograph depend on that protection directly. The agency's own record acknowledges that roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and that sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Wilson Creek alone covers 4,863 acres of Pisgah National Forest. It is an invaluable natural resource that allows so many families the space to recreate and enjoy clean, safe water. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. I ask that the agency explain what its analysis says about sedimentation risk to the specific drainages feeding those intakes, and that it respond to this question on the record. The proposal justifies rescission in part on wildfire grounds. I grew up in these forests and have seen the concerns being brought forward firsthand, with the Table Rock fire in 2014. Opening these forests to more construction and alteration will not diminish wildfire risk. Studies show the risk will increase. The agency's own record confirms it: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency reconcile the rescission with this finding and explain why it departs from its own prior conclusions about fire occurrence in its draft environmental impact statement. Western North Carolina is reliant on our roadless areas as economic drivers generating $17.8 billion dollars for the state. The proposal's own economic record undermines its rationale. The agency has acknowledged that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Projecting $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million, the agency's own cost-benefit analysis cannot establish a net benefit. The road system already carries a $6.9 billion maintenance backlog. The agency must explain how expanding that system under these numbers serves the public interest. The proposal also claims the rule creates unworkable permitting burdens. But the rule's text shows it already provides for exceptions: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens fall outside those existing exceptions. It should quantify them. I oppose this rescission. These forests are where I come from. The agency has not justified this action by its own numbers or its own science.