Comment Analysis · Docket FS-2025-0001

FS-2025-0001-448003

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted September 21, 2026 On Regulations.gov

In short: The comment documents that the draft EIS fails to disclose forest-level impacts for the White Mountain National Forest, specifically that the 2005 Forest Plan classifies inventoried roadless land as suitable for timber harvest, and requests that the Department adopt the No Action alternative or retain the 2001 Roadless Area Conservation Rule in areas where wildfire risk is not the primary management challenge.

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, Alternative.

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

Recreation Tourism Public Use
- “hike, backpack, and fish”
- “most used and valued backcountry in New England”
- “outdoor recreation economy depends on exactly the remote backcountry character”
- “directly degrade the experiences that bring millions of visitors”
Environmental Protection Biodiversity
- “integral to the landscape”
- “preserve roadless values”
- “retains the Roadless Rule's protections”
- “remained wild”
Water Quality Quantity
- “water-quality damage in the headwaters”
- “Pemigewasset, Saco, and Androscoggin rivers”
- “Wild River roadless area extends well beyond the designated Wilderness into surrounding watersheds”
Governance Policy Process
- “The White Mountain Forest Plan does not provide the protection the Department claims”
- “protections the plan does provide can be changed through future amendments”
- “analysis fails to disclose forest-level impacts”
- “public cannot meaningfully evaluate this proposal”

What it names

National Forests: White Mountain National Forest
Roadless areas: Sandwich RangeWhite MountainWild River

The comment

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

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Department to adopt the No Action alternative. I travel from Massachusetts to the White Mountain National Forest roughly 15 weekends a year to hike, backpack, and fish. The Pemigewasset Wilderness is where I fell in love with the outdoors. The roadless forest surrounding White Mountain Wildernesses is integral to the landscape. Roads or logging at their edges would change what it means to visit them. The White Mountain Forest Plan does not provide the protection the Department claims. The proposed rule asserts that local land management plans will adequately protect roadless values. In the White Mountain National Forest, the 2005 Forest Plan classified a substantial share of inventoried roadless land as suitable for timber harvest. Rescission would open those areas to road construction and logging under the current plan. Any protections the plan does provide can be changed through future amendments, while a national rule offers durability that a forest plan cannot. The affected lands include some of the most used and valued backcountry in New England. Roadless areas surround much of the Pemigewasset Wilderness, including the land visitors cross from Lincoln Woods and Crawford Notch. The Chocorua roadless area, next to the Sandwich Range Wilderness, contains some of the forest's most popular trails, including Champney Falls and Piper. The Wild River roadless area extends well beyond the designated Wilderness into surrounding watersheds. The Great Gulf area lies on the Northern Presidentials, home to the forest's most intensive trail system. Roads and logging here would directly degrade the experiences that bring millions of visitors to the White Mountains each year. The stated rationale does not fit the White Mountains. The Department justifies rescission largely by pointing to wildfire, drought, and insect outbreaks. USDA's own announcement describes high wildfire hazard in roadless areas as primarily a Western problem. The White Mountain National Forest is a wet northern hardwood and spruce-fir forest where those conditions are not the driving management challenge. Where fuel reduction or public safety work is genuinely needed, the 2001 Rule already includes exceptions for it. A rescission justified by Western fire conditions should not strip protections from eastern forests where that justification does not apply. The benefits are small and the costs are real. New Hampshire's multibillion-dollar outdoor recreation economy depends on exactly the remote backcountry character these areas provide. Out-of-state visitors like me bring money to New Hampshire towns that would not otherwise be spent there, on lodging, food, and gear. Meanwhile, the Forest Service already carries a multibillion-dollar deferred maintenance backlog on its existing roads. Building new roads in roadless areas when the agency cannot maintain the ones it has invites erosion and water-quality damage in the headwaters of the Pemigewasset, Saco, and Androscoggin rivers. Visitors and local businesses have relied on these protections. I have planned years of trips around the assurance that these areas would stay roadless. I keep returning to the Pemigewasset and Wild River areas precisely because they have remained wild. For a quarter century, visitors and the businesses that serve them have relied on that assurance, and the Department should weigh those reliance interests. The analysis fails to disclose forest-level impacts. The proposed rule and draft EIS present impacts largely at the national scale. The Department should disclose, forest by forest, how many inventoried roadless acres would become open to road construction and timber harvest under current plans, and where. The public cannot meaningfully evaluate this proposal without knowing which trails, watersheds, and backcountry areas would be affected. At a minimum, the Department should not apply rescission where its rationale does not hold. If the Department proceeds despite these concerns, it should adopt an alternative that retains the Roadless Rule's protections in national forests where wildfire risk is not the primary management challenge, including the White Mountain National Forest. For these reasons, I urge the Department to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule.