Comment Analysis · Docket FS-2025-0001

FS-2025-0001-279752

Opposes rescissionA0 noneSubstance 8/24Posted August 28, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 15 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment establishes opposition to the rescission of the 2001 Roadless Rule, citing specific ecological data (1,600 at-risk species, 60 million Americans' water supply), public support statistics (Pew survey), and the argument that full rescission is unnecessary due to existing provisions for fire risk reduction.

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: Analytical gapEvidenceLegal

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests because they provide all Americans recreational possibilities, beautiful intact landscapes, clean water, habitat protection and protection of old growth forests. Having grown up on the west coast I have seen firsthand what happens when national forests are not protected. Thus, I strongly oppose rescinding the 2001 Roadless Rule because of its environmental and economic impacts, impacts to wildlife and recreation, and the fact that the current rule already allows road-building and logging of smaller trees to reduce fire risk. Thus, a full rescission is unnecessary. The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. For example, 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 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. It’s worth noting that forest revenues today come primarily from recreation, not logging. There are simply not enough areas to accommodate current needs let alone those of future generations. With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. 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. Moreover, a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. Clearly, rescinding the Roadless Rule directly ignores the will of the majority of Americans. For all these reasons, public will, economic responsibility, ecological health, fire safety, and clean water, I strongly oppose rescinding the 2001 Roadless Rule. Please protect America’s remaining roadless areas for current and future generations.

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
- “Roadless areas protect habitat for 1,600 at-risk species”
- “roads fragment the landscape in ways that are even more ecologically harmful”
- “preserve old-growth forests hundreds of years old”
Water Quality Quantity
- “safeguard clean drinking water for 60 million Americans”
- “Guarantee that no watersheds will be negatively affected by rescission”
- “protect forests and watersheds from logging and development”
Public Opinion Support
- “Over 95% of these comments supported keeping roadless protections”
- “75% of Americans support the Roadless Rule”
- “rescinding the Roadless Rule directly ignores the will of the majority of Americans”
Forest Management Wildfire
- “more roads are likely to mean more fires”
- “wildfires are four times more likely to start in roaded areas”
- “zeroes out funding for Wildland Fire Management”

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.