Comment Analysis · Docket FS-2025-0001

FS-2025-0001-385966

Opposes rescissionA1 strongSubstance 11/24Owed an answerPosted September 14, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 10 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 specific data regarding the Forest Service's $6.9 billion maintenance backlog and the 5% fuels treatment rate in high-hazard roadless areas to argue that rescinding the 2001 Roadless Area Conservation Rule is fiscally reckless and likely to increase wildfire risk, while also identifying specific watersheds and species that would be impacted.

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

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and to urge the Department of Agriculture to retain the rule by selecting the No Action alternative. I am an outdoors enthusiast and find our earth to be the most exhilarating space rock and find it troubling that it's not being cared for and protected. I grew up in Utah camping with my father in the High Uintahs, where we would go fishing together. I grew up watching and seeing beavers making dams, deer, elk, bobcats to name a handful, on these trips. Then, when older, began backpacking near Ogden, Wasatch mountain range, Escalante, Zion NP, and Havasupie. Then, moved further West and slept under the stars in the Sierra Nevada's falling a sleep to frogs croaking. Now days, i find Goat Rocks, Indian Heaven Wilderness, Mount Hood and the Blue Mountains as my go backpacking in the Pacific North West. All these places have unique roadless wilderness areas for true exploration, pristine waters, wildlife, solitude and breath taking views. Free from roads, city lights, mining noises, and pollution. Here are the facts: The Forest Service already carries a deferred maintenance backlog of roughly 6.9 billion dollars for its roads and bridges, and it is funded to maintain only about a fifth of the more than 370,000 miles of road it already manages. This rescission opens up to 18.2 million acres to new road construction the rule currently prohibits. Building more roads the agency cannot afford to maintain is fiscally reckless and shifts the long term cost onto taxpayers. The rescission is justified as a wildfire measure, but the record does not support that. The agency's own analysis shows only about 5 percent of high hazard roadless areas have received fuels treatment since 2014, which reflects a budget and staffing shortfall, not a barrier created by the rule. The proposed rule also concedes that greater access can increase human caused ignition potential, and most wildfires on Forest Service land are started by people. Removing road protections is more likely to raise fire risk than lower it. In 2001 the Department found that a national prohibition was the best means to protect these areas, after receiving more than a million public comments. The Department must give a reasoned explanation for reversing that longstanding position, and must account for the reliance interests built up over 25 years of protection, including those of communities, recreation businesses, Tribes, and downstream water users. The proposed rule does not adequately do so. These areas protect 354 municipal watersheds and supply drinking water to roughly 25 million people, and they provide habitat for more than 220 species listed as threatened or endangered and 1,930 sensitive species. Roadless areas also buffer designated Wilderness, and stripping protection from the lands around Wilderness degrades those places even though the Wilderness boundaries never move. The Snake River and the Columbia River Basin area is seeing lower than ever Salmon runs. This is because of toxins in the water. Also, the Bull Run watershed area provides water to millions. Let's continue to protect these water ways! Finally, this rescission would make it far easier to route powerlines, pipelines, and water conveyance through roadless corridors by removing the road construction barrier that has kept most such infrastructure out. The Department cites Executive Order 14154 on energy as a reason for the action. The public deserves a full analysis of the industrial infrastructure this could enable, not an assurance that the effects would be modest. For these reasons, I ask the Department to: retain the 2001 Roadless Area Conservation Rule by selecting the No Action alternative; fully analyze the fiscal, wildfire, water, wildlife, and infrastructure effects described above; and complete meaningful Tribal consultation before any decision is made. The time in NOW to continue to preserve these wilderness areas to be free from easy access from people starting fires, adding toxins into water ways, power lines to be erected, and destruction of wildlife habitat. We need to be stewards of the planet, our lovely exhilarating land, for our future generations today. DeAnn Jeremy

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

A1 strong: Must be answered — it names the law.

Owed an answer on Evidence, Legal.

Standard dismissals it defeats

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.

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.
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.

Topics

Water Quality Quantity
- “protect 354 municipal watersheds”
- “supply drinking water to roughly 25 million people”
- “downstream water users”
Wildlife Habitat
- “habitat for more than 220 species listed as threatened or endangered”
- “1,930 sensitive species”
- “wild burros”
- “buffer designated Wilderness”
Forest Management Wildfire
- “record does not support that”
- “only about 5 percent of high hazard roadless areas have received fuels treatment”
- “greater access can increase human caused ignition potential”
- “Removing road protections is more likely to raise fire risk”
Economic Impact Fiscal
- “deferred maintenance backlog of roughly 6.9 billion dollars”
- “funded to maintain only about a fifth”
- “fiscally reckless”
- “shifts the long term cost onto taxpayers”

What it names

Roadless areas: Snake River
Law cited: Executive Order 14154

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.