Comment Analysis · Docket FS-2025-0001

FS-2025-0001-582383

Opposes rescissionA2 moderateSubstance 16/24Owed an answerPosted October 6, 2026 On Regulations.gov

In short: The comment documents the commenter's direct economic and personal reliance on the White Mountain National Forest, cites specific data from the DEIS and Cost Benefit Analysis to highlight deficiencies in the agency's economic and fire risk analyses, and requests that the agency reconcile these figures, withdraw the small-business certification, and quantify the increase in human-caused ignitions.

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

Recreation Tourism Public Use
- “hike on trails throughout the White Mountain National Forest every week”
- “recreation losses of at least $6.1 million a year”
- “preserving our wilderness and sharing resources for responsible recreation”
- “outfitters, guides and tour operators as affected”
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 across the Eastern region”
- “taste mountain water clarified by running over the granite landscape”
Economic Impact Fiscal
- “The economic case for rescission does not hold”
- “net present value spanning -$92 million to +$199 million”
- “road system this proposal would expand already carries a $6.9 billion maintenance backlog”
- “certifies no significant impact on small entities”
Forest Management Wildfire
- “Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land”
- “human-caused ignitions increase in abundance with proximity to roads”
- “quantify the expected increase in human-caused ignitions from new road access”
- “weigh it honestly against any claimed reduction in wildfire hazard”

What it names

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

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The ravens riding thermals above Franconia Ridge have kept me alive. That is not a metaphor. I hike on trails throughout the White Mountain National Forest every week, including in the Pemigewasset Wilderness, the Sandwich Range Wilderness, and the Presidential Range Dry River and Great Gulf Wilderness areas. I work for a locally-owned retail store that equips people to recreate safely in these mountains and helps build community through running, biking, and skiing outings. My partner owns a gas station and deli just south of the Presidential Range. These places are my livelihood and my life, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. I have dealt with bouts of depression for most of my life. Over the last decade I have seen multiple therapists and spent months in outpatient treatment facilities, spending more than $20,000 before insurance on medical care. No pharmacist or therapist has rivaled what the wilderness of the Pemigewasset does for me. The vastness of Franconia Ridge triggers all five senses. I gaze at the ravens riding thermals above the summit. I feel winds that raise the hair on my arms. I taste mountain water clarified by running over the granite landscape. The aroma of balsam firs triggers a nostalgia for the white Christmases of my youth. I pet the underside of Labrador Tea leaves, a softness akin to the bumble bees I left behind below tree line. If making America healthy is a priority of this administration, preserving our wilderness and sharing resources for responsible recreation within them needs also to be prioritized. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911 authorizing federal purchase of private land for national forests was passed specifically because of what happened when New England's mountains were clearcut. The agency is now proposing to undo the protection those lessons produced. I ask that it explain how rescission squares with that history and with its obligations to the 286 municipal water intakes across the Eastern region that sit in watersheds containing affected roadless areas. The economic case for rescission does not hold. The agency's own record states that "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." Against that marginal gain, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million, all while the road system this proposal would expand already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile those numbers and explain how an action whose own analysis cannot establish a net benefit justifies that expansion. The small-business certification has the same problem. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The store I work for and the one my husband owns are exactly the small entities the certification ignores. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the businesses permitted in the affected areas. It should withdraw that certification and assess the entities who would actually bear the cost. Finally, the agency's own fire data argues against the proposal. "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." The streams and waterfalls I drink from, the balsam firs whose smell keeps me grounded, the moose, black bear, Canada lynx, and Bicknell's thrush that share these 240,669 acres with me: all of it is more exposed to fire under this proposal than protected. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire hazard before this rule goes any further. Sincerely, Kelsey O'Connell North Conway, New Hampshire