Comment Analysis · Docket FS-2025-0001

FS-2025-0001-352511

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 12, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 26 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

In short: The comment places on the record that the draft environmental impact statement incorrectly attributes wildfire mitigation to the rescission of the Roadless Rule, contradicts this with Forest Service data on human-caused fires and road proximity, and documents specific tribal objections regarding the lack of required government-to-government consultation and the threat to cultural and subsistence resources in the Tongass National Forest.

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

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

Special Areas; Roadless Area Conservation Public Comment,Last year, more than 625,000 people from across the United States wrote to the USDA, urging the agency to keep the bipartisan 2001 Roadless Area Conservation Rule, which protects our forests from wildfires and corporate exploitation.Please do not rescind the Roadless Area Conservation Rule, Secretary Rollins. Allowing road construction and logging in these forests will destroy areas crucial to Native Tribes’ spirituality, culture, identity, and survival. These forests provide clean drinking water for more than 60 million U.S. residents and are crucial ecosystems for the wildlife that Tribal Nations depend on. The U.S. federal government has legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation before making decisions about ancestral Tribal homelands. If you take this step to rescind the Roadless Rule, you will violate Tribal sovereignty and therefore the U.S. Constitution. In your own draft environmental impact statement, the federal government incorrectly claims that rescinding the Roadless Rule is a solution to the wildfire crisis. But fires don’t start without cause, and the U.S. Forest Service itself has stated that 9 out of 10 wildfires are caused by people. In fact, fires are four times more likely to start near a road due to cigarettes thrown from car windows, abandoned camp fires, and hot under-carriages of cars igniting tall dry grass.Over the years, many Tribes have spoken out against repealing or making exceptions to the Roadless Rule. Many have done so in the past year, so I’m writing to lift up their voices and urge you to fulfill your obligations to them. The Central Council of the Tlingit and Haida Indian Tribes of Alaska wrote: “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life.” They explained that this step took place “without any prior consultation with our Tribe or other Southeast Alaska tribes” and called on the USDA to “suspend this decision until meaningful consultation is held with tribal nations, as required under federal law and trust obligations.”Gloria Burns, the President of the Ketchikan Indian Community in Alaska said: “We the people of Kichxáan are the Tongass. You cannot separate us from the land… This is an attack on Tribes and our people who depend on the land to eat. The federal government must act and provide us the safeguards we need or leave our home roadless… Without our lungs (the Tongass) we cannot breathe life into our future generations.”The President of the Organized Village of Kake in Alaska explained: “The remaining old growth timber is so important for providing shelter, the berries, and our medicines. It provides shade for our streams to keep them cool so our salmon can return year after year. We are the people of the forest and salmon people. Salmon has sustained us for thousands of years.” His Tribe also hunts deer and moose, which are rebounding after past clear-cut logging.And the President of the Organized Village of Kasaan in Alaska wrote: “The Roadless Rule has worked well for our Tribe and our community by helping to protect customary and traditional uses of our lands and waters, and the fish, wildlife, trees and plants. This helps us honor our ancestors and provide for current and future generations. It would be a grave mistake to roll back these protections. The Roadless Rule must continue to be upheld across the Tongass National Forest.”Please keep the 2001 Roadless Rule. If you want to make any changes, please meaningfully engage in decision-making with sovereign Tribal Nations, in order to honor your constitutional, trust, and treaty obligations to Tribes.Please do not end the Roadless Rule.Keep our promises to all US citizens and to the tribal Nations!!!Barbara SmithBarb Smithbarbaragaile31@gmail.com65 Ogden AveWhite Plains, New York 10605

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 Analytical gap, 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

Tribal Sovereignty
- “violate Tribal sovereignty and therefore the U.S. Constitution”
- “legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation”
- “without any prior consultation with our Tribe or other Southeast Alaska tribes”
- “honor your constitutional, trust, and treaty obligations to Tribes”
Cultural Heritage Indigenous
- “crucial to Native Tribes' spirituality, culture, identity, and survival”
- “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life”
- “helping to protect customary and traditional uses of our lands and waters”
- “This helps us honor our ancestors and provide for current and future generations”
Water Quality Quantity
- “provide clean drinking water for more than 60 million U.S. residents”
- “provides shade for our streams to keep them cool so our salmon can return year after year”
Wildlife Habitat
- “crucial ecosystems for the wildlife that Tribal Nations depend on”
- “providing shelter, the berries, and our medicines”
- “hunts deer and moose, which are rebounding after past clear-cut logging”
- “protect... the fish, wildlife, trees and plants”

What it names

National Forests: Tongass National Forest

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.