Comment Analysis · Docket FS-2025-0001

FS-2025-0001-306793

Opposes rescissionA0 noneSubstance 4/24Posted September 3, 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

Do NOT change the Roadless Rule! Our earth is already suffering so much chaos in the face of human-exacerbated climate change, we should be doing all we can to offset as much damage as we can. This was being done, and can be done, using proven scientific information, which does NOT support further eroding wild lands by removing the Roadless Rule. Current policy seems to be based on No Rule is Unbreakable if it profits a few, while destroying the environment for all. It is the government’s duty to help preserve our irreplaceable life-sustaining environment - basics, like clean water, air, safe food and habitat for all wild things. Your denying truth and science does not make it so. These are public lands, OUR lands, not your road to more riches. The 2001 Roadless Area Conservation Rule conserves over 58 million acres of multiple-use public lands managed by the U.S. Forest Service that provide some of the best places to hunt and fish in America. Repealing safeguards afforded by the Roadless Rule will jeopardize intact fish and wildlife habitat and I urge the U.S. Department of Agriculture to uphold strong protections for all roadless areas. Across the country, roadless areas provide irreplaceable habitat for native trout and salmon, big game, and other wildlife. The 2001 Roadless Rule generally prohibits new road construction and industrial logging, while at the same time keeping these public lands open to habitat improvement projects, hazardous fuels reduction, hunting, fishing, OHV riding, firewood cutting, grazing, and camping. The 2001 Roadless Rule already allows for balanced forest management, including timber harvest, to reduce the risk of uncharacteristic wildfire, as well as to restore habitat for sensitive fish and wildlife species. Importantly, hazardous fuels treatments in roadless areas are commonplace, helping protect at-risk communities and restoring forest health.

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
- “irreplaceable habitat for native trout and salmon”
- “big game, and other wildlife”
- “restore habitat for sensitive fish and wildlife species”
Recreation Tourism Public Use
- “keeping these public lands a great place to visit”
- “hunt and fish”
Forest Management Wildfire
- “balanced forest management”
- “reduce the risk of uncharacteristic wildfire”
- “take care of the roads we already have”

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.