Comment Analysis · Docket FS-2025-0001

FS-2025-0001-372347

Opposes rescissionA0 noneSubstance 8/24Posted September 13, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 15 submissions in its group. See the letter, its submissions and topics.

In short: The comment documents that the proposed rescission of the 2001 Roadless Rule is unsupported by the FY26 budget, which eliminates wildfire and forestry funding, and cites the Mt. Hood 2015 Travel Analysis Report to argue that road construction in the Mt. Hood National Forest would degrade water quality and recreation.

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

The comment

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

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I strongly oppose rescinding the 2001 Roadless Rule for the following reasons: The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary for fire safety. Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants. Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision- making power—rings hollow when no funding is allocated to meet those goals. Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans. For all these reasons, I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; Guarantee that no watersheds will be negatively affected by rescission; Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations.

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

Environmental Protection Biodiversity
- “Roadless areas protect habitat for 1,600 at-risk species”
- “roads fragment the landscape in ways that are even more ecologically harmful”
- “preserve old-growth forests hundreds of years old”
Water Quality Quantity
- “safeguard clean drinking water for 60 million Americans”
- “Guarantee that no watersheds will be negatively affected by rescission”
- “protect forests and watersheds from logging and development”
Public Opinion Support
- “Over 95% of these comments supported keeping roadless protections”
- “75% of Americans support the Roadless Rule”
- “rescinding the Roadless Rule directly ignores the will of the majority of Americans”
Forest Management Wildfire
- “more roads are likely to mean more fires”
- “wildfires are four times more likely to start in roaded areas”
- “zeroes out funding for Wildland Fire Management”

What it names

National Forests: Mt. Hood National Forest
Roadless areas: Warm Springs

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.