Comment Analysis · Docket FS-2025-0001

FS-2025-0001-408041

Opposes rescissionA0 noneSubstance 8/24Posted September 15, 2026 On Regulations.gov

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

In short: The comment establishes that rescinding the 2001 Roadless Rule is unnecessary for fire safety because the current rule already permits road-building for risk reduction, and it documents that the FY26 budget elimination of wildfire funding contradicts the agency's stated justification for the rescission.

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 am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I care deeply about our national forests. Our Forests are owned by the citizens of the United States not by politiicians. Then briefly state your position. I strongly oppose rescinding the 2001 Roadless rule because of the damage it will do to our forests and wildlife and our environment. Environmental Impacts • 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. Fire • 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 !!!! Clean Water • National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. CLEAN WATER IS A RIGHT ! • 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. Intact Landscapes • With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. • Only 3% of the world’s ecosystems remain intact. We can’t afford to abuse what little remains. Economic Considerations • 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. Thank you for your attention to my rights as an United States Citizen. These are our lands Elaine den Hoed

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

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.