Comment Analysis · Docket FS-2025-0001

“I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I…”

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 8/24
  • 15 submissions
  • 15 versions of the text
  • 13 added words of their own

When it arrived

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

Aug 20Sep 8Sep 17

Aug 20: 5 submissions, 1 unique comments

What it names

National Forests
Mt. Hood National Forest
Roadless areas
Warm Springs

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

The letter

As sent in FS-2025-0001-372347, the comment that stands for the group.

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I strongly oppose rescinding the 2001 Roadless Rule for the following reasons: The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary for fire safety. Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants. Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision- making power—rings hollow when no funding is allocated to meet those goals. Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans. For all these reasons, I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; Guarantee that no watersheds will be negatively affected by rescission; Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations.
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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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