Comment Analysis · Docket FS-2025-0001

FS-2025-0001-357405

Opposes rescissionA0 noneSubstance 4/24Posted September 12, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 49 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

I strongly support keeping the Roadless Rule in place and protecting our remaining roadless national forest lands. These forests are some of the only protected places left for wildlife habitat. It is some of most important places we have for clean drinking water, carbon storage, biodiversity, recreation, and protecting ecosystems that are increasingly threatened by climate change. Building roads into these areas can fragment wildlife habitat, disturb ecosystems, increase erosion and pollution, and open previously protected forests to additional development and resource extraction. USDA wants to remove the roadless rule because it exacerbates rising wildfire risks. However, studies from the WFMI show that nearly 85 percent of wildland fires in the United States are caused by humans. Human-caused fires result from campfires left unattended, the burning of debris, equipment use and malfunctions, negligently discarded cigarettes, and intentional acts of arson. Once these wild areas are fragmented, it is nearly impossible to restore them to what they were. Our national forests should be managed for more than short term economic gain. They provide benefits to communities, wildlife, future generations, and the entire country. I implore the federal government to maintain the Roadless Rule and continue protecting these irreplaceable public lands. We should be expanding the protection of our remaining wild forests, not making it easier to develop them. Please protect our national forests and keep them roadless.

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
- “protecting our remaining roadless national forest lands”
- “important places we have for wildlife habitat”
- “fragment wildlife habitat”
- “disturb ecosystems”
Environmental Protection Biodiversity
- “biodiversity”
- “protecting ecosystems”
- “open previously protected forests to additional development”
Water Quality Quantity
- “clean drinking water”
- “increase erosion and pollution”
Climate Carbon Storage
- “carbon storage”
- “threatened by climate change”

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.