Comment Analysis · Docket FS-2025-0001

FS-2025-0001-270684

Opposes rescissionA0 noneSubstance 3/24Posted August 26, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 11 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

Dear Secretary Rollins, I urge you not to rescind the 2001 Roadless Area Conservation Rule and strongly advocate for the "No Action Alternative" in the Environmental Impact Statement. The Roadless Rule is an extremely successful and popular management tool that ensures nearly 45 million acres of our most pristine national forests remain wild. Here in Utah, it protects over 323,000 acres of the Wasatch Mountains from unnecessary development, preserving the ecosystems and multi-billion dollar outdoor recreation economy we rely upon. By rescinding this rule, our forests would be vulnerable to large-scale commercial logging and road-building that would permanently damage our fragile watersheds, wildlife habitat, and dispersed recreation economy. These are the places where Utahns hike, ski, hunt, and seek solitude, from Millcreek Canyon, Mount Aire, and Grandeur Peak, to the pristine backcountry ski terrain in Beartrap Fork, Willow Heights, and White Pine Gulch. Preservation of these lands from roadbuilding is of utmost importance to our economy, watershed, and dispersed recreation opportunities. The stated justification that new roads are necessary for wildfire mitigation is fundamentally flawed and ignores the best available science. In fact, roads increase the number and frequency of wildfires as half of our fires are human caused. Rather than protecting us, rescinding the rule would force firefighters into high-exposure suppression assignments in rugged terrain, pulling scarce resources away from where they are most needed: protecting our at-risk homes and communities. Furthermore, the Roadless Rule has never prohibited fuels treatment projects or wildfire suppression. Here in the Wasatch, we have already proven that we can safely manage dense fuel loads and protect the Wildland Urban Interface without commercial logging. Through Shared Stewardship Projects in Parley's, Millcreek, Big Cottonwood, and American Fork Canyons, land managers successfully utilize science-based treatments like prescribed burns, slash-piles, and lop-and-scatter to manage fuels within Inventoried Roadless Areas. This holistic, inter-agency approach is the way forward. We do not need new roads or commercial timber development to keep our communities safe; we need adequate resources for our local ranger districts to continue their successful stewardship work. Please uphold this effective conservation measure by selecting the No Action Alternative to protect America's last wild forests for generations to come. Sincerely, Ian Wade & Ginger McKenna

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

Environmental Protection Biodiversity
- “preserving the ecosystems”
- “wildlife habitat”
- “pristine national forests remain wild”
Recreation Tourism Public Use
- “multi-billion dollar outdoor recreation economy”
- “dispersed recreation opportunities”
- “pristine backcountry ski terrain”
Water Quality Quantity
- “permanently damage our fragile watersheds”
- “protects over 323,000 acres... from unnecessary development”
Forest Management Wildfire
- “roads increase the number and frequency of wildfires”
- “science-based treatments like prescribed burns”
- “ignition density is lowest in... Inventoried Roadless Areas”

What it names

Roadless areas: White Pine

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.