The Public Record · Docket FS-2025-0001

Read the comments.

Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.

1 unique comments26 submissions
Position
  • Opposes rescission 100.0%
Answerability
  • A1 strong 0
  • A2 moderate 0
  • A3 weak 0
  • A0 none 1
Substance /24
Median 3middle half 3–3 · 1 scored
Topics raised
Count
Position
Answerability
Substance /24
Order
26 submissions in this letter's group · showing 1–20Clear all filters
  1. Opposes rescissionA0 noneSubstance 3/24Sep 24, 2026FS-2025-0001-478656
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    The Roadless Area Conservation Rule should be maintained and strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. Roads fragment wildlife habitat and threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. These are more important than logging or other motorized usages.
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  2. Opposes rescissionA0 noneSubstance 3/24Sep 23, 2026FS-2025-0001-475552
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I demand a better alternative that closes the industrial logging and livestock grazing loopholes that have existed for a quarter century, and will protect from the motorized and mechanized destruction on the horizon. I also urge that the less protective rules in Idaho and Colorado be made part of a strengthened national rule in order to protect our roadless and wilderness heritage. Other thoughts: Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile.
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  3. Opposes rescissionA0 noneSubstance 3/24Sep 22, 2026FS-2025-0001-469730
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. Roads lead to a variety of damage in the areas they cross. Existing roadless areas provide habitat for many threatened and endangered native species as well as migration corridors, but roads fragment wildlife habitat which directly threatens wildlife. Roads also threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas can instead provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. The Roadless Area Conservation Rule should be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas.
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  4. Opposes rescissionA0 noneSubstance 3/24Sep 21, 2026FS-2025-0001-453682
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    As an American, I strongly oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. If anything is done with the Roadless Area Conservation Rule, it should be STRENGTHENED to eliminate logging and roadbuilding loopholes and better protect roadless areas and adjacent Wilderness areas. Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened, endangered, iconic native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and other aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide recreation, like camping, hiking and backpacking, wildlife viewing and photography, and other activities. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than our country’s highways—with an estimated maintenance backlog of over $8.6 billion. Protect both American wildlife and the Roadless Area Conservation Rule. Thank you for meaningfully considering my comments.
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  5. Opposes rescissionA0 noneSubstance 3/24Sep 21, 2026FS-2025-0001-457264
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    As a Maryland nature lover who is extremely concerned about the rapidly accelerating climate crisis and the destruction of America's irreplaceable natural heritage, I passionately oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. America desperately needs it now more than ever to combat the destruction of our planet. If anything is done with the Roadless Area Conservation Rule, it must be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Public lands protect drinking water and provide drinking water for over 60 million Americans, while roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Catastrophic wildfires have been becoming more frequent and intense. The U.S. Forest Service has stated that 9 out of 10 wildfires are caused by people. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. You must withdraw this deadly rollback. If you don't, millions of innocent Americans will die in hurricanes, floods, famines, wildfires, droughts, and heat waves caused by the climate crisis. Our lives are in your hands.
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  6. Opposes rescissionA0 noneSubstance 5/24Sep 17, 2026FS-2025-0001-444699
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Dear elected officials: The Trump administration’s proposed rule and Draft Environmental Impact Statement (DEIS) would threaten more than 44 million acres of wild National Forest System lands. Yet the Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. It is essential to human, animal, and plant life that the roadless regions be maintained. Climate change is real; global warming is real. We must do everything possible to preserve nature: we are dependent on it. –Dr. Jeanne-Marie Zeck
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  7. Opposes rescissionA0 noneSubstance 3/24Sep 16, 2026FS-2025-0001-416335
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years.Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion.
    Full analysis of this comment →
  8. Opposes rescissionA0 noneSubstance 4/24Sep 16, 2026FS-2025-0001-417955
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Please STRENGTHEN the roadless rule! We need fewer roads for these reasons - roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile.
    Full analysis of this comment →
  9. Opposes rescissionA0 noneSubstance 4/24Sep 16, 2026FS-2025-0001-418015
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It has consistently helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. The rule is not broken and it's effectiveness cannot be denied. Rather than eliminate the Roadless Area Conservation Rule, it should be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. Roads are known to fragment wildlife habitat. Existing roadless areas provide quality habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities for an increasing number of users. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. Fix what currently exists instead of causing damage to roadless areas.
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  10. Opposes rescissionA0 noneSubstance 4/24Sep 16, 2026FS-2025-0001-419594
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I strongly oppose rescinding the Roadless Area Conservation Rule. It has helped protect precious Wilderness areas, on national forests for 25 years. If anything, the Roadless Area Conservation Rule should be strengthened to eliminate roadbuilding that leads to logging, mining, drilling and loopholes in order to access roadless areas and adjacent Wilderness areas that will destroy habitat for many threatened and endangered native species. And you must know that Roadless areas provide important migration corridors for both birds and mammals. Then there is the issue with roads that threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. However on the other hand, roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities, and most importantly undisturbed wildlife habitat. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. We can afford to withhold a few profit dollars so that nature can do what she does best: clean healthful living on all our parts.
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  11. Opposes rescissionA0 noneSubstance 3/24Sep 16, 2026FS-2025-0001-434621
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Animals deserve uninterrupted safe habitat from humans.
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  12. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-410990
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.This comment stands for all 26 submissions in its group.

    Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile.
    Full analysis of this comment →
  13. Opposes rescissionA0 noneSubstance 4/24Sep 15, 2026FS-2025-0001-411070
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. I urge you not to repeal the 2001 Roadless Area Conservation Rule. Thank you.
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  14. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-411493
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Please strengthen, don’t repeal, the roadless rule. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile
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  15. Opposes rescissionA0 noneSubstance 4/24Sep 15, 2026FS-2025-0001-411701
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Do not repeal the Roadless Rule! It should be strengthened, not erased.
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  16. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-411916
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion.
    Full analysis of this comment →
  17. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-412408
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile.
    Full analysis of this comment →
  18. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-412771
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    Thank you for the opportunity to comment on proposed changes to the Roadless Rule. I strongly oppose rescinding the Roadless Area Conservation Rule. If anything changes are made to the Roadless Area Conservation Rule, it should be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, including camping, hiking and backpacking, hunting and angling, wildlife viewing and photography. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads fragment wildlife habitat. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. These areas are the last true wilderness in our country. If removed, we will never get them back. Thank you for considering my comments.
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  19. Opposes rescissionA0 noneSubstance 4/24Sep 15, 2026FS-2025-0001-412796
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It provides critical protection for roadless areas, and adjacent Wilderness areas, on national forests and has done so for 25 years. The Roadless Area Conservation Rule should instead be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion.
    Full analysis of this comment →
  20. Opposes rescissionA0 noneSubstance 3/24Sep 15, 2026FS-2025-0001-412940
    PLACESTANDDOCGAPEVIDASKALTLAW

    Campaign — One letter sent by 10 or more people, copied or lightly reworded. See the letter, its submissions and topics.One of 26 submissions in its group.

    I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years.Roads fragment wildlife habitat. Existing Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud.roadless areas More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile.provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors.
    Full analysis of this comment →

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How it works. A large language model (an open-weight Qwen3.8 model) reads each substantive comment and copies, word for word, the passages that carry its analytical gap, evidence, request, alternative and connection to the place; it returns no scores. Code grades those passages 0–3 on eight dimensions — evidence, legal grounding, engagement with the environmental analysis, analytical gaps, alternatives, specific requests, position, and local knowledge — with legal grounding taken from a citation scan, not the model. For the strongest tenth on each side, the copied passages are checked against the comment and shown as exhibits. A comment counts as “substantive” when it clears a floor filter — it must show at least one substantive signal (a named entity, a specific citation, a stated analytical deficiency, or first-person testimony), which screens out one-line and purely conclusory submissions before any model scoring.

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