Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603976

Opposes rescissionA1 strongSubstance 14/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the rescission of the Roadless Area Conservation Rule fails to account for the protection of 286 municipal water intakes in the White Mountains, contradicts the agency's own economic analysis showing a potential net negative benefit, and ignores the reliance interests of local residents who have organized their lives around these protected 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, 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 that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities”
    • “286 municipal water intakes sit in watersheds containing affected roadless areas”
    • “flooding a region's water system with difficult to remove pollutants”
    • “sheds water directly into the lakes region of the state”
  • Environmental Protection Biodiversity
    • “Carr Mountain area houses wetland and habitat that would be destroyed by logging”
    • “history of ecological damage that ruined the economy's long-term health”
    • “Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut”
    • “intrinsic beauty”
  • Recreation Tourism Public Use
    • “one of the few places beginner backpackers can go to learn outdoor skills”
    • “one of the most popular areas for people to visit”
    • “decimate the thriving outdoor economy that New Hampshire enjoys”
    • “recreation losses of at least $6.1 million a year”
  • Economic Impact Fiscal
    • “tightly tied with my state's ability to survive economically”
    • “total timber volume affected by this rule is less than 0.5 percent of total United States production”
    • “net present value spanning -$92 million to +$199 million”
    • “expanding a road system already carrying a $6.9 billion maintenance backlog”

What it names

National Forests
White Mountain National Forest
Roadless areas
Carr MountainSandwich RangeWhite 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 gapEvidenceRequestLegal

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The protected areas of the White Mountains are my literal home and my spiritual home as well as being tightly tied with my state’s ability to survive economically. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record of Docket FS-2025-0001. I live in the White Mountains region of New Hampshire and regularly go out into the woods for a hike or camping trip. The Carr Mountain area, at 17,110 acres in the White Mountain National Forest, is one of the few places beginner backpackers can go to learn outdoor skills, an important American legacy. The Carr Mountain area houses wetland and habitat that would be destroyed by logging, flooding a region's water system with difficult to remove pollutants. The Sandwich Range, at 16,797 acres, is one of the most popular areas for people to visit. It has an intrinsic beauty and sheds water directly into the lakes region of the state, one of the main tourist attractions in New Hampshire. These places have already seen a history of ecological damage that ruined the economy's long-term health. That history is not abstract. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We are being asked to forget that lesson. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Logging in Carr Mountain and the Sandwich Range does not stay in those units. It enters the water. I ask the agency to explain how it will protect those 286 intakes and the downstream communities that depend on them if this rule is rescinded. 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." Building new roads that the agency has yet to prove it can maintain, in order to facilitate logging that yields fractions of a percent of national production, makes no sense. It would also decimate the thriving outdoor economy that New Hampshire enjoys, tanking our viability as a state. I ask that the agency reconcile the proposal with its own economic analysis, which 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 and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also claims the rule imposes permitting and administrative burdens that justify rescission. But the rule as written states that 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 rule already accommodates the situations the agency says require relief. The agency must identify which specific burdens are not already addressed by these existing exceptions and quantify those burdens in this proceeding. Finally, 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. This comment is one such interest. I have organized my life around these protected areas. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Molly McCahan Plymouth, NH

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