Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604462

Opposes rescissionA1 strongSubstance 16/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents that the agency's DEIS contains internal contradictions regarding wildfire ignition rates on roaded versus unroaded lands (citing Table 21) and fails to quantify downstream sediment impacts or identify specific forest plan provisions that would replace the water quality protections of 36 CFR 294.12 and 294.13 for 24 million people relying on roadless area watersheds.

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”
- “286 municipal water intakes sit in watersheds containing affected roadless areas”
- “skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion”
- “Approximately 24 million people use water originating within the potentially affected roadless areas”
Environmental Protection Biodiversity
- “pristine wilderness in the crown jewel of America”
- “Brook trout, moose, Canada lynx, Bicknell's thrush, the northern long-eared bat”
- “species that depend on the clean, cold, undisturbed water these roadless areas produce”
- “grave mistake ecologically”
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”
- “countless unmaintained FS roads, strewn with blown down trees, potholes, and rockfall”
- “single fire can devastate an ecosystem for decades to come”
Recreation Tourism Public Use
- “avid recreator and have enjoyed camping, hiking, backpacking, and fishing on public lands”
- “hiking the Pacific Crest Trail, 231 miles of which go through 71 roadless areas”
- “keep the wilderness wild for generations to come”

What it names

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

The comment

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

To whom it may concern: I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Dr. Amber Rock and I am a biologist who lives in Boston, MA. I am an avid recreator and have enjoyed camping, hiking, backpacking, and fishing on public lands since I was a child in southern California. Locally, I find time to to hike in the the Pemigewasset (32,255 acres) and Sandwich Range (16,797 acres) in White Mountain National Forest, New Hampshire in all four seasons. This summer I also had the privilege of hiking the Pacific Crest Trail, 231 miles of which go through 71 roadless areas across California, Oregon, and Washington. Our pristine wilderness in the crown jewel of America and rescinding the Roadless Area Conservation Rule in any capacity would be a grave mistake ecologically and financially; we owe it to ourselves to keep the wilderness wild for generations to come. While hiking the PCT, I had to miss parts of the trail due to fire and smoke. The proposal justifies rescission in part on the ground that new road access is needed for management. But the agency's own document states that "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." If we cannot maintain the roads we already have, and if those roads themselves drive fire ignition at the rate the agency has documented, the case for opening roadless areas to new construction does not hold. I have seen countless unmaintained FS roads, strewn with blown down trees, potholes, and rockfall, barely passable for a walker, let alone vehicles. I ask that the agency explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. After walking hundreds of miles of burn scars, I know first hand how a single fire can devastate an ecosystem for decades to come. The agency also argues administrative burden and permitting friction as grounds for rescission. The rule's own text, as the agency acknowledges, 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)." Those exceptions are broad. Which specific burdens are not already addressed by them? I ask that the agency identify those burdens by name and quantify them on the record, rather than asserting that the rule as written forecloses management it does not foreclose. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are 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 sit in watersheds containing affected roadless areas. The DEIS states that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number is documented and then, in the agency's own analysis, set aside without a projection of what it means downstream. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any final action is taken. The drinking water question does not stop there. The agency's own record states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The DEIS then asserts that forest plans address sources of public drinking water without identifying a single enforceable provision equivalent to what 36 CFR 294.12 and 294.13 currently provide. Brook trout, moose, Canada lynx, Bicknell's thrush, the northern long-eared bat: species that depend on the clean, cold, undisturbed water these roadless areas produce in New Hampshire and across the system. I ask that the agency identify, forest by forest, which plan provisions would replace those protections for municipal watersheds. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We built a federal land protection system from that lesson. Rescinding the Roadless Rule repeats the mistake the Weeks Act was meant to correct. The agency should say plainly why that history does not apply here. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, Amber Rock, PhD Boston, MA