Comment Analysis · Docket FS-2025-0001

FS-2025-0001-342262

Opposes rescissionA0 noneSubstance 5/24Posted September 9, 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

  • Wildlife Habitat
    • “important habitat for the wildlife that breathes there”
    • “fragment this beautiful habitat, introduce disturbances”
    • “wildlife will lose their homes and the paths they take”
    • “Habitat fragmentation on breeding grounds is documented as a major contributor”
  • Recreation Tourism Public Use
    • “seek refuge away from the noise and chaos of modern life”
    • “Roadless areas anchor the primitive end of the Forest Service recreation spectrum”
    • “finding serenity within the nearby natural, beautiful landscapes will only prove more and more difficult”
    • “lose our most beloved trails and fragment the natural views”
  • Environmental Protection Biodiversity
    • “eliminate roadless character”
    • “population declines are widespread among North American migratory birds”
    • “protections in place to keep us humans and wildlife safe from unabated industrialization”
    • “destroy natural habitats”

What it names

National Forests
Six Rivers National ForestWhite Mountain National Forest
Works cited
10.1098/rspb.2020.316410.1126/science.aah478310.1371/journal.pone.0167259

The comment

I am a graduate of Stony Brook University with a B.S. in Coastal Environmental Studies. I know many relatives and friends, myself included, who seek refuge away from the noise and chaos of modern life every year. The White Mountain National Forest is not only an important habitat for the wildlife that breathes there, but also for people for all seasons of the year. New road construction, reconstruction, and associated developments fragment this beautiful habitat, introduce disturbances, and eliminate roadless character. We visit this forest to get away from modern developments and the constant hum of cars whizzing by. However, noise from roads reaches deep into protected areas. Anthropogenic noise doubles background sound levels in 63 percent of U.S. protected area units and produces a tenfold increase in 21 percent of them. Elevated noise was found in habitats of endangered species, with 14 percent of critical habitats experiencing a tenfold sound increase. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use (Buxton et al. 2017). — Buxton et al., 2017 (https://doi.org/10.1126/science.aah4783). Without the Roadless Rule, finding serenity within the nearby natural, beautiful landscapes will only prove more and more difficult. One of my family’s first hikes was Mount Lafayette in New Hampshire, where we took the Franconia Ridge Trail loop. That day marked itself as having the most amazing natural view of the Northeast I had ever seen, and it is the reason I am an environmentalist today! Without these amazing natural landmarks, I, my family and friends, and hikers from around the country could lose our most beloved trails and fragment the natural views that come with them - our reason for coming back and staying in the Northeast. Many people who value these wildernesses will be negatively affected. Roadless areas anchor the primitive end of the Forest Service recreation spectrum. Inventoried roadless areas are classified by the agency as supporting primitive and semi-primitive recreation — landscapes characterized by quiet, dispersed access, minimal infrastructure, and apparent naturalness. These conditions are what distinguish backcountry recreation from developed recreation and are not present in roaded areas (USDA Forest Service 2016; USDA Forest Service 2024). — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf); U.S. Fish and Wildlife Service, 2024 (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf). With the fragmentation and noise pollution associated with new roads and development, wildlife will lose their homes and the paths they take to get to and from them if the Roadless Rule cannot protect them. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf). Also, population declines are widespread among North American migratory birds. The Connecticut Warbler has declined 62 percent since 1966; the Cerulean Warbler is declining at roughly 4.4 percent per year; the Golden-winged Warbler has lost an estimated 22 percent of its Great Lakes habitat and 43 percent of its Appalachian habitat since the 1960s. Habitat fragmentation on breeding grounds is documented as a major contributor (Hallworth et al. 2021; NRCS 2016). — Hallworth et al., 2021 (https://doi.org/10.1098/rspb.2020.3164); USDA Natural Resources Conservation Service, 2016 (https://www.nrcs.usda.gov/sites/default/files/2022-12/Golden_Winged_Warbler_Strategy_8-7-16.pdf). This will only worsen if the Roadless Rule cannot protect their habitat. The Roadless Rule protects countless species - including us. In an age where environmental regulation and outreach is more important than ever, where the global climate crisis is evermore looming above our heads, and where those in power would seek to steal as much land and money as possible, there absolutely must be protections in place to keep us humans and wildlife safe from unabated industrialization! We cannot allow more development on the few natural landscapes that would destroy natural habitats and continue to remind us environmentalists what we live and fight for!

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