Comment Analysis · Docket FS-2025-0001

FS-2025-0001-423455

Opposes rescissionA0 noneSubstance 9/24Posted September 16, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 38 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

Dear U.S. Forest Service Chief Tom Schultz, I’m writing to urge you to choose Alternative 1 and keep the 2001 Roadless Rule intact. For 25 years, the rule has safeguarded nearly 45 million acres of backcountry across U.S. national forests. These roadless areas provide numerous benefits to the American public, from clean air and water to vital wildlife habitat and diverse recreation opportunities — all while still allowing responsible forest management. Rescinding or altering this rule puts these lands at risk by opening the door to logging, oil-and-gas drilling, and other development. It will also fragment habitat, introduce invasive species, increase wildfire risk, and bring noise and light pollution. At a minimum, I insist that you extend this comment period to at least 90 days and hold hearings across the U.S. in all areas affected, so the public can fully weigh in. This proposal does not have my support. I urge you to choose no-action and uphold the Roadless Rule. Two of my favorite places at risk in southern Arizona are the Rincon and Chiricahua mountains within the Coronado National Forest. I have taken multiple backpacking trips through the Rincons—along the Douglas Spring Trail and up Turkey Creek Trail on the eastern side of the range. Reaching Manning Camp is a special experience, offering a reliable, natural water source and incredible panoramic views. What I treasure most about both the Rincons and the Chiricahuas is their wild, untouched nature compared to more heavily developed local ranges like the Catalinas. These roadless areas safeguard critical high-desert watersheds and provide vital migration corridors for threatened species. Building roads into these remote spaces does not aid fire management—it introduces human ignition sources, invasive fire-prone grasses, and habitat fragmentation to places that are already facing severe climate pressure. Opening inventoried roadless lands in these ranges to development would be devastating, not only to community members who seek the solitude of these spaces, but also to the unique flora and fauna that rely on them. Let's leave these wild places wild. Sincerely, Brenna Troy 2503 E Blacklidge Dr Tucson, AZ 85716-1801 brenna.troy@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
- “vital wildlife habitat”
- “fragment habitat, introduce invasive species”
- “unique flora and fauna that rely on them”
Water Quality Quantity
- “clean air and water”
- “safeguard critical high-desert watersheds”
- “reliable, natural water source”
Recreation Tourism Public Use
- “diverse recreation opportunities”
- “multiple backpacking trips”
- “seek the solitude of these spaces”
Governance Policy Process
- “extend this comment period to at least 90 days”
- “hold hearings across the U.S.”
- “choose Alternative 1 and keep the 2001 Roadless Rule intact”

What it names

National Forests: Coronado 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: https://www.regulations.gov/bulkdownload.

Roadless.org — analysis of the public comment docket.
Media inquiries welcome — nicholas@wanderingnature.com.