Comment Analysis · Docket FS-2025-0001

FS-2025-0001-577793

Opposes rescissionA2 moderateSubstance 14/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents that the agency's draft EIS and Cost Benefit Analysis contain internal contradictions regarding wildfire risk, economic net benefits, and small entity impacts, and asserts the commenter's 30-year reliance interest in the White Mountain National Forest's 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

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
- “verified habitat for Bicknell's thrush, black bear, Canada lynx, American marten, moose, brook trout, and the northern long-eared bat”
- “bird richness declines with road presence in forested habitat”
- “road-noise experiments in a roadless area cut bird abundance by over a quarter”
- “protects their habitat is not a management adjustment”
Recreation Tourism Public Use
- “over 30 years of camping, hiking, and watching the world slow down”
- “recreation losses of at least $6.1 million a year”
- “Part of the fun of hiking is the effort and planning it takes to get to these areas”
- “My family has relied on these areas being protected for over 30 years”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “ignition data in DEIS Table 21, which shows far higher fire density on roaded land”
- “The proposal does not reconcile this finding with its stated rationale”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “road system already carries a $6.9 billion maintenance backlog”
- “net present value spanning -$92 million to +$199 million”
- “assess the impact on the small entities actually operating permits”

What it names

National Forests: White Mountain National Forest
Roadless areas: Pemigewasset ExtSandwich RangeWhite Mountain

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountain National Forest has been part of my life since I was a child, over 30 years of camping, hiking, and watching the world slow down the moment the cars and phones fall away. Streams, rivers, birds, and other critters replace all of it. That is unlike anything I can explain. It is pure bliss. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001), and I am asking the agency to answer specific questions this proposal raises. I hike and camp every year in the White Mountain National Forest, including the Pemigewasset, the Sandwich Range, the Pemigewasset Ext, and the Kearsarge areas. These are real places I know on foot. Standing on a summit and seeing miles of unbroken forest in every direction is something I photograph and carry home. Watching loons on the lakes, eagles and songbirds overhead, and bears on the trails is not a coincidence of luck: it is what intact forest does. The White Mountain's 16 inventoried roadless areas total 240,669 acres and include verified habitat for Bicknell's thrush, black bear, Canada lynx, American marten, moose, brook trout, and the northern long-eared bat. These are the species that share the trails I hike. Rescinding the rule that protects their habitat is not a management adjustment. It is a decision with permanent consequences for the wildlife and the wild character that makes these places worth going to. The agency's own draft environmental impact statement found that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch birds everywhere I hike in the National Forest. I ask the agency to explain in this docket what it intends to do with those findings, and why opening these areas to roads is compatible with them. Part of the justification offered for rescission is wildfire and fuels management. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal does not reconcile this finding with its stated rationale. I ask that the agency explain why it is departing from its own prior findings on fire occurrence, and that it square this proposal with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is not made by the agency's own numbers. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the road system already carries a $6.9 billion maintenance backlog. An action whose own analysis cannot establish a net benefit, measured against those numbers, demands a direct answer: how does the agency justify expanding that road system under these conditions? The Sandwich Range and the Kearsarge area are less traveled. That is exactly the point. Part of the fun of hiking is the effort and planning it takes to get to these areas. We do not need more roads. It has all the access it needs. The agency has proposed a regulatory flexibility certification finding no significant impact on small entities, while its own DEIS names outfitters, guides, and tour operators as affected and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. I ask that the agency withdraw that certification and assess the impact on the small entities actually operating permits in these areas, not a national average figure that obscures local harm. Finally, the proposal solicits reliance interests and its Cost Benefit Analysis weighs none. This comment is one. My family has relied on these areas being protected for over 30 years. My brother takes his family there every year. I think about my nieces and whether they will ever get to experience what real nature is and have an appreciation for it. The agency must identify and weigh the reliance interests that comments like this one describe, not invite them and then set them aside. Sincerely, Tina Campbell