Comment Analysis · Docket FS-2025-0001

FS-2025-0001-541334

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 4, 2026 On Regulations.gov

In short: The comment documents the specific ecological and economic deficiencies in the agency's analysis by citing DEIS data on species impacts and local economic contributions, while challenging the agency's timber supply justification with historical harvest data and requesting the adoption of the No Action alternative.

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.

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

Wildlife Habitat
- “Protecting wildlife is important to me”
- “adversely affect 327 threatened and endangered species”
- “habitat fragmentation reduces biodiversity by 13-75%”
- “need large expanses of unfragmented habitat to survive”
Recreation Tourism Public Use
- “recreate in the White Mountain National Forest”
- “find solace and a way to recreate and recharge”
- “outdoor recreation and enjoyment contributed $4.2 billion”
- “experience its beauty and solitude”
Economic Impact Fiscal
- “Logging will not offset the long-term economic losses”
- “timber harvest within potentially affected IRAs has averaged only about 500 acres per year”
- “trivial historical harvest level undercuts the claim”
- “supported over 33,000 jobs”
Environmental Protection Biodiversity
- “retain full Roadless Rule protections”
- “deeply value the unfragmented landscape”
- “protect 16 distinct ecosystems”
- “contribute to the biodiversity of the White Mountain National Forest”

What it names

National Forests: White Mountain National Forest
Roadless areas: Carr MountainCherry MountainDartmouth RangeKinsman MountainMt. Wolf - Gordon PondSandwich RangeWhite MountainWild River

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternative

Dear Secretary Rollins: I am writing to express my strong opposition to the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the agency to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. I live in Webster, NH, and my family has a camp in Pittsburg, NH. I regularly spend time and recreate in the White Mountain National Forest and deeply value the unfragmented landscape that these 15 roadless areas provide to New Hampshire and the citizens of the United States, including Carr Mountain (17,110 acres), Cherry Mountain (8,766 acres), Dartmouth Range (9,233 acres), Great Gulf Extension (15,110 acres), Jobildunk (3,660 acres), Kearsarge (4,554 acres), Kilkenny (28,766 acres), Kinsman Mountain (8,999 acres), Mt. Wolf - Gordon Pond (11,846 acres), Pemigewasset (32,255 acres), Pemigewasset Extension (15,840 acres), Presidential – Dry River Extension (10,555 acres), Sandwich Range (16,797 acres), Waterville (4,312 acres), and Wild River (46,878 acres). These undisturbed areas are a primary reason NH is such a special place to live. Protecting wildlife is important to me. I am an avid birder and one of my hobbies is monitoring and documenting wildlife. The DEIS states that eliminating the Roadless Rule would "adversely affect" 327 threatened and endangered species and 71 critical habitats for these species. In New Hampshire, these roadless areas protect 16 distinct ecosystems that provide diverse habitat for many species, including 5 federally listed and 19 species of concern. Many of these species need large expanses of unfragmented habitat to survive. The DEIS cites findings that habitat fragmentation reduces biodiversity by 13-75% and that bird richness declines with the presence of roads in forests. And it's not just the listed species; it's the hundreds of other species that contribute to the biodiversity of the White Mountain National Forest and make it such a treasure to the people of NH and those from around the country and world who visit to experience its beauty and solitude. It is critically important that roads do not further fragment what little area remains in New Hampshire, and across the United States. The wild, undisturbed areas of the White Mountain National Forest provide a sense of culture and natural heritage. These areas are part of an expanse of natural spaces where many people, including me, find solace and a way to recreate and recharge from the stress of modern life. The landscape is a part of who we are. According to a study by the Granite Outdoor Alliance, in 2024 outdoor recreation and enjoyment contributed $4.2 billion to the New Hampshire economy and supported over 33,000 jobs. This economic benefit expands beyond recreation to support retail, tourism, hospitality, and manufacturing. Logging will not offset the long-term economic losses we would incur by rescinding the 2001 Roadless Area Conservation Rule. The agency's own activity-tracking data show that timber harvest within potentially affected IRAs has averaged only about 500 acres per year, with volume inconsequential to overall nationwide harvest levels, across the 44.7 million acres covered by the rule. That trivial historical harvest level undercuts the claim that roadless prohibitions are a meaningful driver of the national forest health and timber supply problems the agency describes. The Forest Service should explain, with data, how opening land that has produced inconsequential harvest volume for over two decades will now deliver the promised benefits. For these reasons, I strongly urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon the proposed rescission and instead support Alternative 1, the No Action alternative. Thank you for the opportunity to provide public comment.