Comment Analysis · Docket FS-2025-0001

FS-2025-0001-344799

Opposes rescissionA0 noneSubstance 6/24Posted September 12, 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

  • Water Quality Quantity
    • “part of a larger watershed that affects the health of the Connecticut River”
    • “provide essential headwaters, clean drinking water”
    • “help capture and filter water before it reaches streams and rivers”
    • “increase erosion, sedimentation, and runoff”
  • Wildlife Habitat
    • “wildlife habitat, biodiversity”
    • “fragmenting wildlife habitat”
    • “protect these lands for the people, wildlife, and communities”
  • Recreation Tourism Public Use
    • “opportunities for recreation and solitude”
    • “safeguarding clean water, healthy rivers, wildlife, recreation”
  • Environmental Protection Biodiversity
    • “Protecting the remaining roadless forests”
    • “climate resilience”
    • “long-term health of these forests”

The comment

Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination: I am writing to respectfully urge the Forest Service not to rescind the 2001 Roadless Area Conservation Rule. Protecting the remaining roadless forests in the White and Green Mountain National Forests matters to me because these forests are not isolated wilderness areas—they are part of a larger watershed that affects the health of the Connecticut River and the communities that depend on it. These forests provide essential headwaters, clean drinking water, wildlife habitat, biodiversity, climate resilience, and opportunities for recreation and solitude. Intact roadless forests also perform important work that is easy to take for granted: forest cover, healthy soils, wetlands, natural buffers, and undisturbed drainage systems help capture and filter water before it reaches streams and rivers. Opening these areas to additional road construction and increased logging would put those benefits at greater risk. Roads and intensified development can increase erosion, sedimentation, and runoff while fragmenting wildlife habitat and disrupting natural water systems. The consequences would not necessarily stop at the forest boundary; they could extend downstream to the Connecticut River and the communities and ecosystems that rely on its waters. For these reasons, I strongly urge the Forest Service to maintain the Roadless Rule and select Alternative 1—No Action—in the Draft Environmental Impact Statement. Maintaining consistent protections is the prudent choice for safeguarding clean water, healthy rivers, wildlife, recreation, and the long-term health of these forests. Once roadless forests are fragmented and their natural systems disrupted, those losses cannot easily be reversed. We have an opportunity now to protect these lands for the people, wildlife, and communities that depend on them—including future generations. Thank you for considering my comments and for the opportunity to participate in this important decision. Sincerely, Verena Harfst, Essex, CT 06426

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