Comment Analysis · Docket FS-2025-0001

FS-2025-0001-326786

Opposes rescissionA0 noneSubstance 6/24Posted September 7, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 12 submissions in its group. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

The comment

To 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 STRONGLY OPPOSE any action that would rescind or alter the 2001 Roadless Area Conservation Rule. Roadless areas provide essential habitat for native flora and fauna, that cannot be replaced. These areas provide migratory connections for big game and unaltered water resources for native fisheries. These areas provide free ecosystem services like groundwater supply protections, aquifer and drinking water protection, carbon sequestration, oxygen production, prevention of flooding and reduction of pollution. Millions of Americans and visitors from many nations regularly visit our national forests, providing important economic growth to those areas and providing recreational opportunities in unparalleled beautiful landscapes. The Roadless Rule protects vital drinking water resources, extensive landscape-scale wildlife habitat, and world-class recreational opportunities like hiking, biking, climbing, fishing, wildlife tracking and observation, photography, hunting and camping. For example, the Access Fund estimated that non-local rock climber tourists spent over $13.9 million annually and local climbers spent an additional $12.9 million visiting national park in North Carolina; and over $6.2 million has been spent annually in Colorado. This example shows millions of dollars spend to visit our national resources and that is only one type of recreation highlighted in only two US States. The US Forest Service’s own website posted an article about how recreation in these areas provides healthy economies with over $13.5 billion spent by visitors in 2020 in addition to providing “161,000 full and part time jobs, more than any other industry”. Rescinding the Roadless Rule would jeopardize public enjoyment of public lands and negatively impact local economies. In 2001 over 1.5 million Americans said yes to supporting the Roadless Rule. And again in 2025 over 98% of the 600,000 comments were received supporting keeping the Rule. The 2001 Roadless Rule already provides provisions for addressing hazard trees, and allows balanced forest management to prevent wildfires and invasive species controls. This Rule does not need to be rescinded to prevent wildfires as claimed by the US Forest Service. It has been documented that wildfires are 4x more likely to start in a roaded area (The Wilderness Society); that over 90% of wildfires started within a ½ mile of a road (Pacific Biodiversity Institute) and 84% of wildfires in the US are human cause (National Academy of Sciences); therefore, it is illogical to propose that more roads are needed to prevent wildfires. I would STRONGLY OPPOSE any measure that increases new roads through national forests that would make it easier to have trophy hunts of species like grizzly and wolf and cut down old growth forests. Unrestricted road access increases potential for poaching and leads to heavier hunting pressure and more crowded field conditions and increase road mortality and insurance costs for vehicle/wildlife collisions. Culturally important and indigenous cultural and spiritual practices sites would also be threatened and is an unacceptable implication of this Rule being rescinded. I personally enjoy travelling to our national forests for hiking, camping, rock climbing, wildlife observation and tracking, photography and general enjoyment of the outdoors. I frequently travel to enjoy these areas contributing to those local economies in doing so. With the national crisis in mental health, having access to roadless national forests is essential for physical, mental and emotional wellbeing. Our national forests were created as and are currently a public resource, not places to be monetized by a few individuals or corporations. 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. To be clear, I STRONGLY OPPOSE rescinding any portion of the 2001 Roadless Area Conservation Rule.

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. This rating is the one its shared letter earned.

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
- “essential habitat for native flora and fauna”
- “migratory connections for big game”
- “extensive landscape-scale wildlife habitat”
- “preserve native flora and fauna”
Water Quality Quantity
- “unaltered water resources for native fisheries”
- “groundwater supply protections”
- “aquifer and drinking water protection”
- “7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas”
Recreation Tourism Public Use
- “world-class recreational opportunities like hiking, biking, climbing, fishing”
- “non-local rock climber tourists spent over $13.9 million annually”
- “recreation in these areas provides healthy economies”
- “public enjoyment of public lands”
Forest Management Wildfire
- “The 2001 Roadless Rule already provides provisions for addressing hazard trees”
- “wildfires are 4x more likely to start in a roaded area”
- “over 90% of wildfires started within a ½ mile of a road”
- “illogical to propose that more roads are needed to prevent wildfires”

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.