Comment Analysis · Docket FS-2025-0001

FS-2025-0001-244729

Opposes rescissionA0 noneSubstance 6/24Posted August 22, 2026 On Regulations.gov

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

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

The comment

I am an avid outdoor recreationist, backcountry angler, spouse of a backcountry hunter whose hunts feed our family, daughter of a retired USFS and State wildland firefighter, and military spouse who regularly visits roadless areas on America's national forests all over this country and I support the No Action alternative in the current DEIS. For more than two decades, the Roadless Rule has conserved some of the most important fish and wildlife habitat in the National Forest System while allowing many of the management activities needed to maintain healthy forests. The rule does not prohibit hunting, fishing, grazing, recreation, habitat restoration, hazardous fuels reduction, wildfire mitigation, mining, or access to valid existing rights. Instead, it provides a common-sense framework for limiting new road construction in some of the nation's most intact backcountry landscapes. These roadless areas provide critical habitat for fish and wildlife, conserve clean water, and support the hunting and fishing opportunities that define America's outdoor heritage. These landscapes help maintain secure habitat for elk, mule deer, native trout, and countless other species that depend on large, unfragmented landscapes. They also protect headwater streams and watersheds that supply clean drinking water to communities across the country. Rescinding the rule will harm durable access and game migration, increase fire risk, and reduce opportunities for future hunters and anglers across the country. Additionally, the rescission would remove important protections for more than 25,000 miles of trails, 10,000 climbing routes, nearly 1,000 miles of whitewater, and more than 10,000 miles of mountain biking. USFS currently manages approximately 370,000 miles of roads and faces a deferred maintenance backlog of roughly $10.8 billion, with ~55% of that backlog tied to roads alone. Meanwhile, the proposed rule cites an annual National Forest System sawtimber harvest of just $5.2 to $11.4 million per year in revenue to the Treasury and Forest Service and $4.6 to $10.6 million per year in revenue to the timber industry if the rule were to be rescinded. This proposed action is not fiscally responsible. Building additional roads into currently roadless areas would create new long-term maintenance obligations while diverting resources from the existing infrastructure the agency already struggles to maintain. The Roadless Rule was developed through one of the largest public participation efforts in federal land management history, generating approximately 1.6 million public comments, 99% of which were in support of the rule. Any decision to weaken or eliminate these protections should be supported by clear evidence that doing so would improve land management outcomes without sacrificing wildlife habitat, watershed health, recreational opportunities, or fiscal responsibility. Because of this, I strongly support maintaining the Roadless Rule as is. Outdoor recreation is a crucial part of our country's economy and heritage, and rescinding the Roadless Rule would only be remembered as am embarrassing mistake in history books.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A0 none: Counted, not answered.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Wildlife Habitat
    • “conserved some of the most important fish and wildlife habitat”
    • “secure habitat for elk, mule deer, native trout”
    • “depend on large, unfragmented landscapes”
    • “conserving intact habitat”
  • Water Quality Quantity
    • “conserve clean water”
    • “protect headwater streams and watersheds”
    • “supply clean drinking water to communities”
  • Economic Impact Fiscal
    • “not fiscally responsible”
    • “create new long-term maintenance obligations”
    • “diverting resources from the existing infrastructure”
    • “deferred maintenance backlog of roughly $10.8 billion”
  • Recreation Tourism Public Use
    • “intact backcountry landscapes”
    • “backcountry opportunities we enjoy today”
    • “recreational opportunities”

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 — Substantive Analysis,” https://roadless.org.

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.

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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