Comment Analysis · Docket FS-2025-0001

FS-2025-0001-296916

Opposes rescissionA0 noneSubstance 5/24Posted September 1, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 18 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

To the U.S. Forest Service and Department of Agriculture, My name is Reid Anderson, I live in Conifer CO, and I am writing to oppose the proposed repeal of the 2001 Roadless Area Conservation Rule. For more than 25 years, this rule has helped protect some of our country's most intact national forests from unnecessary road construction, commercial logging, and industrial development. Repealing it would make it much easier to open millions of acres of public land to new roads, timber harvests, and future oil, gas, mineral, and coal development. New roads do much more than change the landscape. They fragment wildlife habitat, increase erosion, threaten clean water, create pathways for invasive species, and make previously remote areas more vulnerable to development and other damaging extraction processes. We should not weaken protections for our threatened intact forests at a time when they are increasingly important for wildlife, recreation, clean water, and carbon storage. Wildfire mitigation and forest health work can be done without dismantling protections across tens of millions of acres. Forests are ABSOLUTELY ESSENTIAL in our fight against climate change. Please show us you care in this fight. Public lands belong to all of us, and once these forests are logged, drilled, or developed, we cannot simply restore what was lost. Therefore, I urge the USDA and U.S. Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place. Thank you for considering my comment and for protecting our public lands from development.

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
- “fragment wildlife habitat”
- “create pathways for invasive species”
- “protect some of our country's most intact national forests”
Water Quality Quantity
- “threaten clean water”
- “increase erosion”
- “important for... clean water”
Resource Development Extraction
- “commercial logging”
- “future oil, gas, mineral, and coal development”
- “damaging extraction processes”
Climate Carbon Storage
- “important for... carbon storage”
- “threatened intact forests”

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.