Comment Analysis · Docket FS-2025-0001

FS-2025-0001-323516

Opposes rescissionA3 weakSubstance 8/24Owed an answerPosted September 7, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 86 submissions in its group. See the letter, its submissions and topics.

In short: The comment documents that the Roadless Rule protects specific New England landscapes (White and Green Mountain National Forests, Franconia Notch, Mt Moosilauke, Mt Chocorua, Presidential Range, White Rocks) and provides quantified benefits for drinking water (8.8% of VT, 7.3% of NH, 7% of MA residents) and wildfire risk reduction (fires 4x more likely near roads), while asserting that rescission would harm indigenous cultural sites and subsistence areas.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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
- “supports the region's native biodiversity, including imperiled species”
- “wildest, healthiest, and most intact landscapes”
- “protect at least 10% of the region for the benefit of biodiversity”
Water Quality Quantity
- “safeguards clean drinking water”
- “protect drinking water for 8.8% of Vermont residents”
- “water from sources that originate in Inventoried Roadless Areas”
Cultural Heritage Indigenous
- “essential for maintaining and strengthening indigenous culture”
- “jeopardizes culturally-important sites and subsistence use areas”
- “sustaining cultural and spiritual practices, including hunting, fishing, and gathering”
Recreation Tourism Public Use
- “Iconic landscapes protected by the Rule include places like New Hampshire's Franconia Notch”
- “famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas”

What it names

National Forests: White Mountain National Forest
Roadless areas: White Mountain
Works cited: 10.1186/s42408-026-00450-210.1371/journal.pwat.0000538

The comment

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

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). “Inventoried Roadless Areas” (IRAs) protected by the Roadless Rule represent many of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). Over 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, a record for public participation in federal rulemaking that still holds to this day.In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.

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: https://www.regulations.gov/bulkdownload.

Roadless.org — analysis of the public comment docket.
Media inquiries welcome — nicholas@wanderingnature.com.