Comment Analysis · Docket FS-2025-0001

FS-2025-0001-334546

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 20 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

Subject: Keep the 2001 Roadless Rule Intact (Docket FS–2025–0001 or RIN 0596-AD66) Dear U.S. Forest Service, I am writing to urge you to keep the Roadless Rule in place and oppose the proposed rescission. Instead of an overly broad repeal, the agency should pursue targeted improvements to the Roadless Rule that strengthen wildfire resilience and recreation access, while keeping its strong safeguards in place. I care deeply about roadless areas because I value wilderness, clean water, wildlife diversity and the opportunity for solitude. I love the Sierra because it provides amazing opportunities for finding peace and wellbeing. We NEED it, and so does wildlife. We, and they, can’t live without it. These places are irreplaceable for wildlife, clean water, cultural values, and humans. The lands protected by the Roadless Rule were identified for their critical role in safeguarding clean water, providing wildlife habitat, preserving Tribal cultural resources, and offering cherished backcountry experiences. They also sustain thriving recreation economies while supporting community safety through wildfire prevention, firefighting access, and road maintenance. It concerns me that the Forest Service emphasis on greater “local flexibility” does not necessarily mean greater local engagement. In the Eastern Sierra, for example, the Forest Service is again considering exploratory gold drilling near Hot Creek, a popular recreation and fly-fishing area. Yet the process this time does not require a public comment period. WHY NOT? Removing the Roadless Rule does not guarantee stronger local control. Instead, it would shift significantly more responsibility to local plans and project-level decisions at a time when agency capacity and opportunities for public involvement are declining. Many forest plans are outdated, categorical exclusions are being used more broadly, all while federal priorities are pushing for increased resource extraction. This will not lead to wise forest planning or usage. The Forest Service already manages roughly 380,000 miles of roads across the National Forest System, much of which it does not have the resources to maintain. More roads could increase forest fragmentation, erosion, invasive species, and wildfire risk. In California, about 86% of wildfires are human-caused, with ignition risk four times higher near roads. For the past 25 years, the Roadless Rule has struck the right balance: allowing managers to reduce fuels and protect communities while maintaining a consistent national safeguard against unnecessary new roads. Please REJECT this broad repeal and PRESERVE the Roadless Rule. Sincerely, Lynn Schardt Garden Valley, CA

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

Water Quality Quantity
- “rely on clean Sierra Nevada water for drinking”
- “safeguarding clean water”
- “drinking-water sources”
Recreation Tourism Public Use
- “backpack and fish with my family”
- “peace and quiet time”
- “away from roads and civilization”
- “popular recreation and fly-fishing area”
Wildlife Habitat
- “roaming for wildlife without roads”
- “where they can get run over”
- “forest fragmentation”
Governance Policy Process
- “does not necessarily mean greater local engagement”
- “process this time does not require a public comment period”
- “agency capacity and opportunities for public involvement are declining”

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.