Comment Analysis · Docket FS-2025-0001

FS-2025-0001-398047

Opposes rescissionA0 noneSubstance 4/24Posted September 14, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 28 submissions in its group. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

The comment

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Most people when asked what they find most awe inspiring in this world reply nature. Wild places are sacred and should be left untouched for all of us to enjoy as well as the future generations that come after us. West Virginia has some of the most awe inspiring landscapes left in the country, if not the whole world! Protect them and keep them safe from the insatiable greed of corporate capitalists. They must be stopped and you have the power to do so. Use it. Sincerely, Denise Poling 88 Cheat Valley Hwy Parsons, WV 26287-8002 denise121255@gmail.com

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. This rating is the one its shared letter earned.

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
- “protecting important buffers”
- “wildlife habitat”
- “wild, unfragmented landscapes”
Recreation Tourism Public Use
- “irreplaceable opportunities for outdoor recreation”
- “left untouched for all of us to enjoy”
- “awe inspiring landscapes”
Water Quality Quantity
- “provide clean water”
- “safeguards treasured places”
Resource Development Extraction
- “opened to greater roadbuilding and commercial logging”
- “insatiable greed of corporate capitalists”

What it names

Roadless areas: Cheat MountainSeneca Creek

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.