Comment Analysis · Docket FS-2025-0001

FS-2025-0001-270427

Opposes rescissionA0 noneSubstance 7/24Posted August 25, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 23 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment documents specific opposition to the rescission of the 2001 Roadless Rule in Wyoming and Colorado, citing habitat loss, water quality degradation, increased wildfire risk, and fiscal irresponsibility, while urging the adoption of the 'No Action' alternative.

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

Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal

As someone who cares about our Roadless forests in Wyoming and Colorado, I urge the Forest Service to retain the 2001 Roadless Rule by adopting the “No Action” alternative. I strongly oppose rescinding the Roadless Rule because: Wyoming and Colorado’s roadless areas provide some of the best fish and wildlife habitat in the country, including core habitat for elk, mule deer, grizzly bear, and other iconic species. Roadless areas provide some of the best opportunities in the country for backcountry recreation. From fly fishing to camping to backcountry skiing — public lands users know the opportunities for both solitude and adventure often improve the further you get from roads. I have personally been able to experience these untouched lands when I go backpacking through these areas and keeping them intact is so important to me. Roads contribute to erosion, sedimentation, and contaminants flowing into waterways. More roadbuilding in roadless areas could impact aquatic habitat, putting our world-class trout fisheries at risk. Additionally, many Wyoming and Colorado communities depend on clean water from roadless areas. In an area that is already experiencing water insecurity, we have to protect these clean water sources. Rescinding the Roadless Rule is fiscally irresponsible: The USFS already services roughly 370,000 miles of roads, and maintenance is costly. The deferred maintenance cost the Forest Service faces already exceeds $10 billion. Removing Roadless Rule protections and adding roads will increase the already-massive maintenance backlog and likely increase the risk of wildfire ignitions. Research shows that fires are much more likely to occur where there are roads. The Roadless Rule was developed through years of public participation and has wide-reaching public support — 99% of the public support the rule. The Roadless Rule protects some of our nation’s most important forests and wild places. I strongly oppose the rescission of the Roadless Rule and urge the U.S. Forest Service to adopt the “No Action” alternative.

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
- “best fish and wildlife habitat in the country”
- “core habitat for elk, mule deer, grizzly bear”
- “impact aquatic habitat”
Recreation Tourism Public Use
- “best opportunities in the country for backcountry recreation”
- “solitude and adventurous experience”
- “fly fishing to camping to backcountry skiing”
Water Quality Quantity
- “Roads contribute to erosion, sedimentation, and contaminants flowing into waterways”
- “communities depend on clean water from roadless areas”
- “putting our world-class trout fisheries at risk”
Economic Impact Fiscal
- “Rescinding the Roadless Rule is fiscally irresponsible”
- “deferred maintenance cost the Forest Service faces already exceeds $10 billion”
- “adding roads will increase the already-massive maintenance backlog”

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.