Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607366

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

In short: The comment documents that the DEIS fails to identify enforceable plan provisions equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds, contains internal contradictions regarding wildfire ignition data in Table 21, and presents economic projections that do not establish a net benefit, thereby requesting the withdrawal of the proposed rescission.

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”
- “supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts”
- “Roads bring trucks, petroleum, and sediment”
- “I would rather drink clean water”
Wildlife Habitat
- “moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and northern long-eared bat”
- “depend on forest that has not been fragmented by roads”
- “Building roads into this forest would be a terrible idea for every living thing”
- “Let the animals and people enjoy the forest”
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”
- “The proposal uses wildfire and fuels management as part of its justification for rescission”
- “Those two things point in opposite directions”
Legal Regulatory Framework
- “The DEIS does not identify a single enforceable plan provision that is equivalent”
- “The Ninth Circuit already reviewed that substitution and found it wanting”
- “explain how this proposal avoids the deficiencies identified in that prior litigation”
- “rescinding 36 CFR 294.12 and 294.13”

What it names

National Forests: White Mountain National Forest
Roadless areas: Carr MountainMt. Wolf - Gordon PondPemigewasset ExtSandwich RangeWhite Mountain
Law cited: 36 CFR 294.12

The comment

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean water and quiet forest: those are the two things the roadless areas of the White Mountain National Forest protect, and those are the two things this proposal would put at risk. I am asking the Forest Service to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The White Mountain's 16 inventoried roadless areas total 240,669 acres, including Carr Mountain, Sandwich Range, Pemigewasset Ext, Waterville, Jobildunk, and Mt. Wolf - Gordon Pond, and they are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911 authorized the federal government to purchase private land for national forests specifically because of what happened when New England's mountains were clearcut. That history is the whole argument for keeping these places intact. The moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and northern long-eared bat that live here depend on forest that has not been fragmented by roads. Wildlife migration, human recreation, the cooling shade of trees above clean streams: these are not abstractions. Building roads into this forest would be a terrible idea for every living thing, and I want the agency to explain what it believes justifies that consequence. On water, the agency's own analysis states: "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." Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. I would rather drink clean water. Roads bring trucks, petroleum, and sediment, and the agency's own record shows roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The proposal says forest plans will fill the gap left by rescinding 36 CFR 294.12 and 294.13, but the DEIS does not identify a single enforceable plan provision that is equivalent. I ask that the agency identify, forest by forest, which specific plan provisions would provide equivalent protection for municipal watersheds if this rule is rescinded. On wildfire, the agency's own record states: "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." The proposal uses wildfire and fuels management as part of its justification for rescission. Those two things point in opposite directions. The agency needs to reconcile this proposal with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the rescission departs from prior findings the agency itself produced. On economics, the agency's own record states: "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." The agency's own Cost Benefit Analysis 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. That range does not establish a net benefit. The road system the agency already maintains carries a $6.9 billion maintenance backlog. The agency must explain on the record how expanding that system is fiscally defensible when its own numbers cannot confirm a positive return. On legal history, the agency's record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-by-state approaches can replace national protection. The Ninth Circuit already reviewed that substitution and found it wanting. The agency should address how this proposal avoids the deficiencies identified in that prior litigation, and explain its own finding that local decision-making can incrementally erode nationally significant roadless values. Please leave the land alone. Let the animals and people enjoy the forest. Trees give us clean air and keep the Earth cool, and the rule that protects them should stay in place. Sincerely, Maya Plymouth, NH