Comment Analysis · Docket FS-2025-0001

“I benefit from national forests in Virginia preserved by the 2001 Roadless Area Conservation Rule. These areas…”

Campaign: One letter sent by 10 or more people, copied or lightly reworded. It counts as one unique comment. The record does not say which organisation ran it.

Opposes rescissionA0 noneSubstance 6/24
  • 10 submissions
  • 10 versions of the text
  • 6 added words of their own

When it arrived

Submissions received each day. Tap or hover a bar for its count.

Aug 20Aug 29Sep 20

Aug 21: 5 submissions, 0 unique comments

What it names

National Forests
+ Los Padres National Forest+ Tahoe National Forest
Works cited
Johnston et al. 2023

Names marked + were added by senders and are not in the shared letter.

The letter

As sent in FS-2025-0001-225952, the comment that stands for the group.

I benefit from national forests in Virginia preserved by the 2001 Roadless Area Conservation Rule. These areas have a big impact on my life and Virginia will not be the same without the Roadless Rule protections that preserve the heart of these forests. According to the Southern Environmental Law Center, these are Virginia’s roadless areas by the numbers - nearly 332,000 acres (84%) of Virginia’s roadless areas are at risk if the Roadless Rule is rescinded. More than 310,000 of these at-risk roadless acres are in the Chesapeake Bay watershed. Over 2.5 million Virginians and millions more in D.C. get at least some of their drinking water from sources downstream of roadless area watersheds. The SELC continues that the threats to Virginia’s roadless areas include the George Washington and Jefferson National Forests, boasting nearly 394,000 roadless acres in the mountains of Western Virginia, more than any other state east of the Mississippi River. Roadless areas provide irreplaceable benefits, including clean drinking water, access to wild places, vital support for local economies, and essential wildlife habitat. Despite the Rule’s tremendous benefits and broad, bipartisan support, the U.S. Forest Service is working to throw it out. This unnecessary move would open up many acres to logging and development—putting Virginia’s roadless areas at risk, as well as the millions of Virginians who rely on them. And, the SELC writes, this is how the Roadless Rule benefits Virginia communities: Virginia’s robust outdoor recreation economy, over $14.4 billion in 2024, depends on the state’s roadless areas, which are world-class destinations for hikers, mountain bikers, anglers, etc. Virginia’s national forests are powerful economic drivers for local communities. In 2019, the forests’ recreation program contributed over $33 million to local economies, 43% of the forests’ total contributions and more than twice the contributions of forest products, minerals, and energy. Roadless areas are crucial for backcountry hunters and anglers. Hunting and fishing are not only a part of Virginia’s heritage—they’re a major contributor to Virginia’s economy, with a combined $4.6 billion impact. Our roadless areas contain headwaters for the Shenandoah, Potomac, James, and Roanoke River watersheds. These roadless watersheds contribute to the drinking water for over 2.5 million Virginians, including those in nearby communities like Harrisonburg and Staunton, as well as those in downstream cities like Richmond, Fairfax, and Newport News. Virginia’s roadless areas are a haven for wildlife such as black bear, deer, wild turkey, grouse, and hundreds of bird species. They also provide the clean, cold water that native brook trout require, and Virginia is reported to have the largest populations of brook trout south of the Mason-Dixon line. Roadless areas are also critical to Virginia’s biodiversity, containing habitat for 43 at-risk species, including bats, pollinators, freshwater mussels, and rare plants. They also host species that exist nowhere else on earth, like the Cow Knob salamander. The Roadless Rule is fire smart. It permits the Forest Service to both reduce wildfire risk and fight wildfires in roadless areas. Since most start within 50 yards of a road, building roads into new areas would increase fire risk. Rescinding the Roadless Rule in order to build more roads is an irresponsible use of taxpayer dollars. The Forest Service already has a staggering $9 billion maintenance backlog on its road network, which is double the size of the U.S. highway system. According to Ryan Henson of CalWild, roadless areas also act as fire buffers for communities and land managers since roadless areas experience far fewer human-caused fire starts than do areas with roads. Roadless Areas serve as recreation destinations for local communities and visitors alike, which benefits local economies. Contrary to assertions by the USDA, the 2001 Roadless Rule does not do any of the following: It does not impede national forest planning at the local level. Rather, the Roadless Rule is one of many overarching rules that guide local national forest staff. It does not harm local economies. In fact, it keeps drinking water clean for rural and urban communities alike here in Virginia, thereby helping decrease cost on water. Water for agriculture and domestic use and public land related visitation and tourism benefit rural communities thanks in part to the lands covered by the Roadless Rule. It does not impede fire suppression or risk reduction. To the contrary, the Forest Service is allowed to use all tools available for firefighting in roadless areas, including bulldozers and aircraft. Existing roads on the boundaries of roadless areas provide adequate access for fire risk reduction. The proposal would allow new road construction and the logging of our largest trees in roadless areas, despite the increased fire risk.
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Sharing & methodology

These results are meant to be shared.

Please cite us. This analysis is the intellectual property of Roadless.org and Nicholas Holshouser. You are welcome to reproduce it — every reproduction must include this citation:
Roadless.org and Nicholas Holshouser, “2001 Roadless Rule Revision — Public Comment Analysis,” https://roadless.org.

How it works. Position and topic classification is performed by a large language model (the open-weight Qwen3.8 27B) that reads each comment and labels its position — supports, opposes, or neutral — and the topics it raises. Copies and campaigns are found by hashes of the text and the overlap of six-to-eight-word phrases, grouped into text families; every unique figure counts one family once. Sentence embeddings (Qwen3) find reworded templates, shown under Organized campaigns, and cross-check the families; lexical, syntactic and stylometric features (TF-IDF, spaCy) score each comment’s originality for review. Neither decides a copy count. The full method is on the Methodologies page of roadless.org.

The full method. Every step, why it is done that way, its known limits and a glossary: Methodologies →

The data. The full canonical dataset — every comment on Docket FS-2025-0001 — is available from Regulations.gov's bulk download, the canonical source: https://www.regulations.gov/bulkdownload. Download the CSV directly (Regulations.gov keeps this link working until October 18, 2026): https://bulk-downloads.regulations.gov/mv4-z8fw-q5jx.csv.

Roadless.org — analysis of the public comment docket.
Media inquiries welcome — nicholas@wanderingnature.com.

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