Comment Analysis · Docket FS-2025-0001

American Rivers

Campaign: One letter sent by 10 or more people, copied or lightly reworded. It counts as one unique comment.

Run by American Rivers — From the action page: https://act.americanrivers.org/page/101689/action/1

Opposes rescissionA0 noneSubstance 4/24
  • 20 submissions
  • 20 versions of the text
  • 12 added words of their own

When it arrived

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

Sep 2Sep 12Sep 22

Sep 21: 9 submissions, 0 unique comments

What it names

National Forests
+ Pisgah National Forest

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

The letter

As sent in FS-2025-0001-463754, the comment that stands for the group.

Dear All, More than 4.2 million miles of public roads crisscross the lower 48 states — enough to reach the moon and back almost nine times, according to an article published recently in the Conversation by two Montana University professors. Let that sink in. This leaves only about 5% of the U.S. as a roadless area or wilderness. • The 2001 Roadless Rule was issued in January 2001 by President Bill Clinton to maintain forest health and productivity for future generations. It applies to over 58 million acres across the country, excluding Idaho and Colorado, which have their own state-specific roadless rules. • For some species, roadless areas protect critical core habitat. This move would affect more than 7 million acres of critical habitat for endangered species and pose a catastrophic threat to 88 federally protected animals and plants across the country, including grizzly bears, Canada lynx, wolverines, spotted owls, and native fish. • Over half the suitable habitat for the relictual slender salamander, a critically imperiled species native to the Sierra Mountains of California, occurs in a roadless area. Nearly 40% of Mount Pinos lodgepole chipmunk, an imperiled subspecies of the lodgepole chipmunk, also live in roadless areas in California. • Research shows that every formal roadless area provides habitat for at least two wildlife species of conservation concern — those facing risks to their long-term survival — with the median roadless area supporting 10 of these imperiled species. Some Arizona roadless areas contain habitat for up to 62 of these species. • The non-profit American Rivers warned rolling back the roadless rule is a move, if finalized, would be the largest loss of protections for rivers on federal lands in U.S. history. Since 2001, the Roadless Rule has protected millions of acres of national forest lands that form the headwaters of some of the nation’s most critical drinking water sources. “Rolling back these public land protections gambles with our public drinking water supply,” said David Moryc, senior director of river protection for American Rivers. “We can’t have a strong and healthy nation without healthy rivers. And healthy rivers begin in healthy landscapes. When we fragment forests with more roads we increase wildfire risk, degrade water quality and all pay the price.” • Roadless areas safeguard more than 80,000 miles of rivers and streams, protecting fish and wildlife habitat and helping ensure clean drinking water for more than 25 million Americans, including residents of Denver, Atlanta, and Bozeman.
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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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