Comment Analysis · Docket FS-2025-0001

FS-2025-0001-274743

Opposes rescissionA2 moderateSubstance 13/24Owed an answerPosted August 27, 2026 On Regulations.gov

In short: The commenter establishes that the rescission of the Roadless Area Conservation Rule would be devastating to the White Mountain region and would harm water quality, wildlife habitats, and economic benefits.

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, 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.
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
- “headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “ruining watersheds, causing erosion”
- “roads and their facilities can produce up to 90 percent of the sediment from a timber sale”
Recreation Tourism Public Use
- “hiking, skiing, paddling, and photographing this country”
- “The remoteness of Kilkenny is its greatest appeal”
- “More and more people are heading into these regions precisely because roadless character is worth seeking out”
- “These forests should be managed for all of us to enjoy”
Environmental Protection Biodiversity
- “The flora and fauna that inhabit this region need a place to thrive”
- “harming habitats”
- “I do not want to see that repeated [clearcutting]”
- “preserve the 2001 rule”
Legal Regulatory Framework
- “The Ninth Circuit has already reviewed that reasoning and found it wanting”
- “Tenth Circuit's holding that the 2001 rule was authorized under the Organic Act”
- “reconcile the proposal with its own cost-benefit analysis”
- “address its own prior finding that local decision-making can incrementally erode nationally significant roadless values”

What it names

National Forests: White Mountain National Forest
Roadless areas: Wild River

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The entire White Mountain region in New Hampshire and Maine is my playground. I have been hiking, skiing, paddling, and photographing this country since I was a small child, first camping in the Pemigewasset with my family and later through the Wild River, Kilkenny, and the other roadless areas of the White Mountain National Forest. The remoteness of Kilkenny is its greatest appeal, a true wilderne treat to behold. Losing any of it would be devastating. I oppose the rescission of the 2001 Roadless Area Conservation Rule. New Hampshire holds 15 inventoried roadless areas totaling 234,681 acres. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911, which authorized the federal government to purchase private land for national forests, was passed specifically because of what happened when New England's mountains were clearcut. I do not want to see that repeated. These forests should be managed for all of us to enjoy, not treated as a commodity. The flora and fauna that inhabit this region need a place to thrive. I've paddle the Magalloway and the Androscoggin, and photographed plants, animals, waterfalls, and amazing views. Clean water is life, and across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. I do not want to see my money wasted laying the forest bare for timber extraction, ruining watersheds, causing erosion, and harming habitats. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain how opening these watersheds to road-building serves the water quality that 286 downstream intakes in this region depend on, and it must do so specifically in light of its own sediment findings. The proposal justifies rescission partly on wildfire and fuels management grounds. The agency's own record states: "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 explain why the proposal departs from its own prior findings on fire occurrence in roadless areas and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside these areas. On the economics, the agency's own record states: "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." The agency must reconcile the proposal with its own cost-benefit analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified by figures this small. The proposal also argues that state-by-state approaches can replace the national rule. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed that reasoning and found it wanting. The agency must explain how this proposal avoids the deficiencies identified when the national rule was last replaced with a state-by-state approach, and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. A court that reviewed that question held: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that the 2001 rule was authorized under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and state clearly the basis for any position to the contrary. I have recreated in the Pemigewasset, the Wild River, and Kilkenny for decades. More and more people are heading into these regions precisely because roadless character is worth seeking out. I ask that the agency preserve the 2001 rule and answer each of these points before taking any further action. Sincerely, Lisa Melone South Berwick, ME