Comment Analysis · Docket FS-2025-0001

FS-2025-0001-285911

Opposes rescissionA0 noneSubstance 6/24Posted August 29, 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
    • “fragment habitat, introduce disturbance, and eliminate roadless character”
    • “Fragmentation reduces biodiversity by 13 to 75 percent”
    • “buffering, cooling, and habitat-providing functions of intact interior forest are compromised”
  • Recreation Tourism Public Use
    • “land you have to earn on foot”
    • “appreciation we have gained for its undisturbed beauty”
    • “preserved as such”
  • Legal Regulatory Framework
    • “Department's obligation under the APA is to provide reasoned explanation”
    • “rescission should be denied”
    • “case for the Rule's retention”

What it names

National Forests
White Mountain National Forest
Roadless areas
Sandwich RangeWhite Mountain
Works cited
Haddad et al. 2015Haddad et al. 2015

The comment

Dear Secretary Rollins: As someone who knows the difference between land you drive to and land you have to earn on foot, I can tell you the 2001 Rule protects something that can't be reconstructed once it's gone. We hiked many areas of the White Mountains over the years and there is no comparison to the appreciation we have gained for its undisturbed beauty. The White Mountains are a national treasure and should be preserved as such. Allowing roads would be a disruption to its natural state that would take generations to recoup. The story recounted is, in substance, a case for the Rule's retention — one grounded not in regulatory theory but in the concrete experience of what roadless protection has made possible. Regarding the Sandwich Range in the White Mountain National Forest, New Hampshire: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Most remaining forest is already near an edge. Globally, 70 percent of remaining forest is within 1 kilometer of an edge, where the buffering, cooling, and habitat-providing functions of intact interior forest are compromised. Fragmentation reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs key ecosystem functions (Haddad et al. 2015). — Nick M. Haddad, Lars A. Brudvig, Jean Clobert, Kendi F. Davies, Andrew Gonzalez, Robert D. Holt, Thomas E. Lovejoy, Joseph O. Sexton, Mike P. Austin, Cathy D. Collins, William M. Cook, Ellen I. Damschen, Robert M. Ewers, Bryan L. Foster, Clinton N. Jenkins, Andrew J. King, William F. Laurance, Douglas J. Levey, Chris R. Margules, Brett A. Melbourne, A. O. Nicholls, John L. Orrock, Dan-Xia Song, John R. Townshend, 2015 · Science Advances (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Sandwich Range, White Mountain National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The White Mountains do not seem to currently be, or have been under assault due to its roadlessness therefore rescission is unnecessary. The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. Best, CommentID: RLC-20260829-2W61TS

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