Comment Analysis · Docket FS-2025-0001

FS-2025-0001-440663

Opposes rescissionA0 noneSubstance 6/24Posted September 17, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 34 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

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

Dear Forest Service – I'm writing to strongly oppose the proposed rescission of the 2001 Roadless Rule. This rule protects 58.5 million acres of our National Forest System from road building, large-scale logging, and industrial development, and protects habitat that wildlife, including wolves, grizzly bears, and other carnivores, depend on to survive and recover. Roadless areas are not "off-limits" or "unproductive," as this proposal asserts. They are functioning ecosystems that protect clean drinking water, store carbon, and give wide-ranging species the connected, undisturbed habitat they need. Building roads into these areas doesn't just fragment that habitat. Building Roads into previously roadless areas open the door to poaching, which is a problem in my area next to the Pikes Peak National Forest, along with related illegal activities such as bear baiting, and unregulated predator killing in places that have been safe for over a generation. I urge the Forest Service to withdraw this proposal and keep the Roadless Rule fully in place and not succumb to the negative political pressure of this moment but rise to the ideals that originally created our vast roadless spaces. Thanks for the consideration, Mike

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

Wildlife Habitat
- “habitat that wildlife, including wolves, grizzly bears, and other carnivores, depend on to survive and recover”
- “connected, undisturbed habitat they need”
- “fragment that habitat”
Water Quality Quantity
- “protect clean drinking water”
Environmental Protection Biodiversity
- “functioning ecosystems”
- “protects 58.5 million acres of our National Forest System from road building, large-scale logging, and industrial development”
Climate Carbon Storage
- “store carbon”

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.