Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601655

Opposes rescissionA1 strongSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the proposed rescission of the 2001 Roadless Rule is unjustified because existing regulations already permit necessary wildfire mitigation, the economic and recreational benefits of the White Mountain National Forest outweigh the fiscal costs of new road construction, and the agency's analysis underestimates recreation losses while ignoring the $6.9 billion maintenance backlog.

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, Alternative, 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

Forest Management Wildfire
- “wildfire management benefits do not justify the environmental, recreational, and fiscal costs”
- “The Rule already allows substantial wildfire risk management”
- “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule”
Recreation Tourism Public Use
- “Harm to Scenic Value and Recreation”
- “reduce opportunities for quiet, remote and self-reliant recreation”
- “supports 30,000 jobs and contributes $4 billion to the state's economy annually”
Economic Impact Fiscal
- “New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog”
- “fiscally irresponsible to open areas to taxpayer-funded road expansion”
- “Limited Forest Service resources would be better directed toward maintaining existing infrastructure”
Environmental Protection Biodiversity
- “New roads fragment habitat, increase erosion and sedimentation”
- “open these delicate ecosystems to extractive industrial activities”
- “places them at risk from commercial timber harvesting”

What it names

National Forests: White Mountain National Forest
Roadless areas: Sandwich RangeWhite Mountain
Law cited: 66 Fed. Reg. 3244 91 Fed. Reg. 53829

The comment

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

Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains