Comment Analysis · Docket FS-2025-0001

FS-2025-0001-556871

Opposes rescissionA1 strongSubstance 18/24Owed an answerPosted October 5, 2026 On Regulations.gov

In short: The comment documents specific deficiencies in the agency's analysis regarding the quantification of administrative burdens outside existing carve-outs, the failure to weigh human-caused ignition data from DEIS Table 21 against wildfire hazard claims, and the omission of reliance interests in the Cost Benefit Analysis, while providing verified wildlife and water intake data for the White Mountain National Forest and Maine roadless areas.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

  • 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.
  • 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.
  • 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.

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.
  • 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.

Topics

  • Water Quality Quantity
    • “headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco”
    • “drinking water for communities across New Hampshire, Vermont, and Massachusetts”
    • “286 municipal water intakes depend on watersheds containing affected roadless areas”
  • Wildlife Habitat
    • “Moose, black bear, Canada lynx, American marten, brook trout, Bicknell's thrush, the northern long-eared bat”
    • “all verified in the White Mountain roadless areas”
    • “marveling at the new lives they support”
  • Recreation Tourism Public Use
    • “hiked together every year since 1995”
    • “paddled remote rivers in Maine for our honeymoon”
    • “learned rock climbing on many weekend trips to the White Mountain National Forest”
  • Forest Management Wildfire
    • “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas”
    • “human-caused ignitions increase in abundance with proximity to roads”
    • “quantify the expected increase in human-caused ignitions from new road access”

What it names

National Forests
White Mountain National Forest
Roadless areas
White Mountain
Law cited
36 C.F.R. Section 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests of New England are special in my life. My lifelong best friend and I have hiked together every year since 1995, often in or near national forests. My husband and I paddled remote rivers in Maine for our honeymoon, using the water to travel through pristine wilderness where there were no roads. My son learned rock climbing on many weekend trips to the White Mountain National Forest in New Hampshire when he was in college. It's a magical place that our family has returned to year after year. Its 16 inventoried roadless areas, totaling 240,669 acres, are what I am writing to protect. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask the agency to answer the specific questions this comment raises. The White Mountains were clearcut once. The Weeks Act of 1911 was passed precisely because of what happened to New England's mountains when that occurred, and the federal purchase authority it created is the reason these forests exist as public land today. Those 240,669 roadless acres are now the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. I have photographed those rivers and ponds, the ferns at their margins and the animals near them. Moose, black bear, Canada lynx, American marten, brook trout, Bicknell's thrush, the northern long-eared bat: all verified in the White Mountain roadless areas. I once spent a whole day photographing decaying trees, marveling at the new lives they support. The forest is not a single thing to be managed toward a single use; it is an interlocked system, and roads are not neutral to it. The agency cites permitting and administrative burden to justify rescission, but the rule as written already accommodates the situations that burden claims to address. It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The proposal does not explain which specific burdens fall outside those existing carve-outs for public health and safety, existing mineral leases, or community wildfire protection. I ask that the agency identify each such burden by category and quantify it with specificity, so the record reflects what the existing rule genuinely cannot handle. The fire data assembled by the agency's own analysts cuts directly against the direction the proposal takes. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. Maine's 5,988 roadless acres sit within an Eastern region where 286 municipal water intakes depend on watersheds containing affected roadless areas. If roads bring ignition rates closer to the roaded average, the downstream consequences for those intakes and for the communities they serve are not theoretical. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against any claimed reduction in wildfire hazard before this proceeding closes. Our public lands are sacred spaces and should be protected from development so these amazing places will be open for our children's children and beyond. That is not a sentiment; it is a reliance interest, and the agency invited exactly this. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Every trip my friend and I have planned, every river my husband and I paddled, every camping trip I took my son on, every photograph I made of a living or a decaying thing in those forests: all of it was undertaken with the understanding that the roadless rule meant those places would remain. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, and explain on the record how it has accounted for them. Sincerely, Jill Drew Sharon, CT

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