Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606917

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the DEIS for the Roadless Rule repeal contains contradictory evidence regarding wildfire risks and lacks commitments to fuel treatment, while citing specific local economic data from New Hampshire and executive orders to argue that the repeal undermines forest health and local control.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Analytical gap.

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.
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.
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.
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
- “White Mountains and the Lakes Region serve as the two primary anchors for New Hampshire's tourism economy”
- “visitors generate approximately $7.5 billion in total spending and support ~70,000 jobs”
- “folks visit and live here for the wild”
- “crown jewel of the AMT which spans 14 states with 16.9M visitors”
Forest Management Wildfire
- “DEIS shows that wildfires are 4x more likely in roaded areas than roadless”
- “no commitment in the DEIS to improve vegetation or fuel treatment management”
- “active wildland firefighters are being diverted to non-fire tasks”
- “repeal of roadless protections sets us back rather than advancing those goals”
Governance Policy Process
- “Executive actions are contrary to providing more local control as they remove state, local and public input”
- “give the president total control of those decisions”
- “decisions will raise questions of self-benefit and conflict of interest”
- “more public consideration of the pros and cons of alternatives is needed, not less”
Environmental Protection Biodiversity
- “logging industry's mismanagement and destruction in the Whites was the impetus for establishing the USFS”
- “It took over 100 years to restore these mountains and we don't want to go back”
- “National Forests are a treasured legacy that we must protect and pass down to future generations”
- “pristine Superior National Forest”

What it names

National Forests: Superior National Forest

Attachments

3 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.

Own letter
Own letter
Own letter

The comment

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

I live in New Hampshire and am very concerned about the repeal of the Roadless Rule. The White Mountains and the Lakes Region serve as the two primary anchors for New Hampshire's tourism economy, drawing the vast majority of the state’s 14.6 million annual visitors (6M to the White Mountains) from all 50 U.S. states and roughly 72 different countries. These visitors generate approximately $7.5 billion in total spending and support ~70,000 jobs. folks visit and live here for the wild. The Whites are also the crown jewel of the AMT which spans 14 states with 16.9M visitors. You may be aware that the logging industry's mismanagement and destruction in the Whites was the impetus for establishing the USFS. It took over 100 years to restore these mountains and we don't want to go back. The White House defends the repeal with the truly laudable goals of reducing wildfire risks, improving forest health and enhancing local control and flexibility however the brief and the accompanying Draft Environmental Impact Statement (DEIS) provide little evidence that the repeal promotes those goals and often show the opposite. Other actions by the Executive Branch also demonstrate the opposite. • The evidence in the DEIS is often contrary or missing. For instance, the DEIS shows that wildfires are 4x more likely in roaded areas than roadless. Further, the DEIS analysis shows that ~2x as much land is burned in roaded forest fires than roadless ones. There is no commitment in the DEIS to improve vegetation or fuel treatment management. •The DEIS shows that the new revenue from industry is insufficient to build the new roads or even offset the impacts from this administration's forest service cuts. Cuts have exacerbated fire risks, already deficient road/bridge repairs and insufficient forest management. ~6,000 USFS personnel have been eliminated. Due to support staff shortages, active wildland firefighters are being diverted to non-fire tasks like facility maintenance, cleaning, and grounds keeping instead of the fire line. Fire risks are further exacerbated by cuts to climate change research and resiliency, the leading contributor to the severity of wildfires according to the overwhelming majority of scientists around the world. • the sole logging project approval thus far does not demonstrate intent to improve forest health. The Lost River Project approved in 2025 with a threadbare environmental impact review is for 1,093 acres of commercial logging in the Western White Mountains with over 200 acres of clearcuts. • the "national emergency" justification for eliminating protections and the due process overrides in the 3/1/25 Timber Production Expansion executive order (14225), the 4/24/25 "American Mineral Production Expansion (14241), and the 1/20/25 Energy Expansion (14154) appear exaggerated and insincere. The president justifies the drilling regulation overrides in 14154 saying that regulations limit supply and weaken national security while allowing 55% of our country's domestic crude oil and natural gas (NGPL) products to be exported (EIA) and actively eliminating alternative energy sources. The lumber and mining emergencies were created with the trade wars we initiated, such as the trade war we started with Canada, currently our leading lumber supplier. Our lumber supplies would remain sufficient if we backed off our trade war and repaired our relationship with Canada. • Executive actions are contrary to providing more local control as they remove state, local and public input and decision from the permit process and give the president total control of those decisions. Little to no input to these incredibly consequential decisions is required and the decisions will raise questions of self-benefit and conflict of interest. a case in point was the executive branch's advocacy of Antofagasta PLC to build an a mineral mine in the headwaters to the pristine Superior National Forest despite the overwhelming objections of state and local authorities, indigenous tribes, and the citizens of Minnesota. In summary, the National Forests are a treasured legacy that we must protect and pass down to future generations as previous generations did for us. I think we all share the goals of reducing wildfire risks, improving forest health and enhanced local control and flexibility but repeal of roadless protections sets us back rather than advancing those goals. Executive orders for accelerated drilling, mining, and tree harvesting should be rescinded to de-escalate the emergency and allow for more thoughtful solutioning to meet these goals. Given the permanent impacts to current and future generations, more public consideration of the pros and cons of alternatives is needed, not less., not less. further reading: https://blogs.law.columbia.edu/climatechange/2026/09/03/several-key-problems-with-the-forest-services-proposed-repeal-of-the-roadless-area-conservation-rule/