Comment Analysis · Docket FS-2025-0001

FS-2025-0001-446870

Opposes rescissionA0 noneSubstance 7/24Posted September 18, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the Roadless Rule would specifically impact the Sandwich Range in the White Mountain National Forest by enabling road construction that fragments habitat for federally listed species like the Northern Long-eared Bat and Canada Lynx, while citing scientific data on tree damage and public support for maintaining the area as roadless.

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
    • “federally endangered Northern Long-eared Bat”
    • “federally threatened Canada Lynx”
    • “disruption of valuable habits for plants and animals”
    • “resident birds (including rare species of thrushes)”
  • Environmental Protection Biodiversity
    • “diverse biological species that intertwine into a critical ecosystem”
    • “natural barrier to reduce the advancement of invasive species”
    • “appreciated the current biodiversity and unique undisturbed discoveries”
    • “hidden glacial erratics tucked away in older growth forests”
  • Recreation Tourism Public Use
    • “provides respite but also a reserve for valuable natural resources”
    • “scenic views through all four seasons”
    • “welcoming respectful visitors”
    • “walked the same public land for years”
  • Public Opinion Support
    • “more than 99.8% of submitters opposed the rescission”
    • “76% of likely voters support the Roadless Rule”
    • “bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents”
    • “More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act”

What it names

National Forests
White Mountain National Forest
Roadless areas
Sandwich RangeWhite Mountain
Works cited
10.1186/1735-2746-10-23

Attachments

1 file. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

  • Supporting material

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

To Brooke L. Rollins and Tom Schultz, As someone who has walked the same public land for years, I notice what changes. Roads change everything. As I have visited dozens of national forests across the country, the White Mountain National Forest in the state of New Hampshire is an extension of what I call home. This includes the Sandwich Range which to me provides respite but also a reserve for valuable natural resources that should remain undisturbed. It is full of diverse biological species that intertwine into a critical ecosystem including acting as a natural barrier to reduce the advancement of invasive species heading northward in the state. I have had many visits to this area and over my years there I have appreciated the current biodiversity and unique undisturbed discoveries. This includes hidden glacial erratics tucked away in older growth forests, wetland habits with resident birds (including rare species of thrushes), and scenic views through all four seasons that are experienced here. This eden provided a benefit for its nautural residents but also visitors like me. We would lose so much as this area is not asking for more disruption including disruption of valuable habits for plants and animals. This would also have a negative impact on future generations and for those closer residents that welcome respectful visitors. Regarding the Sandwich Range in the White Mountain National Forest, New Hampshire: Interior Forest Habitat for Bat and Bird Communities — The Sandwich Range's unfragmented expanse of Northern hardwood-conifer and high-elevation balsam fir forest provides the interior forest conditions required by the federally endangered Northern Long-eared Bat and the federally threatened Canada Lynx. These species avoid forest edges and require large, continuous blocks of mature forest away from human disturbance. The roadless condition preserves the acoustic and structural integrity of the forest interior—the absence of road noise, light, and edge effects—that allows these species to forage, roost, and move through the landscape without the behavioral disruption and increased predation risk that fragmentation causes. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) 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. Roadless areas should remain roadless. I object with this proposal. There is not one reason that provides a positive future for our forests and public lands in New Hampshire and beyond. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. This comment joins the record in opposition to the proposed rescission action. Best regards, Zachary Allen CommentID: RLC-20260918-A5A26V

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