Comment Analysis · Docket FS-2025-0001

“Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA…”

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 rescissionA3 weakSubstance 8/24
  • 86 submissions
  • 86 versions of the text
  • 76 added words of their own

When it arrived

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

Aug 23Sep 7Oct 6

Sep 1: 25 submissions, 0 unique comments

What it names

National Forests
White Mountain National Forest
Roadless areas
White Mountain+ Green Mountain
Works cited
10.1186/s42408-026-00450-210.1371/journal.pwat.0000538+ Andrews et al. 2015

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

The letter

As sent in FS-2025-0001-323516, the comment that stands for the group.

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). “Inventoried Roadless Areas” (IRAs) protected by the Roadless Rule represent many of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). Over 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, a record for public participation in federal rulemaking that still holds to this day.In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.
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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: https://www.regulations.gov/bulkdownload.

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

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