Comment Analysis · Docket FS-2025-0001

FS-2025-0001-440974

Opposes rescissionA0 noneSubstance 2/24Posted September 17, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 47 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

Secretary Rollins, I urge you not to rescind the Roadless Rule. The 45 million acres of remote, wild and roadless forests across our country are the few pockets of unbroken forest where nature can flourish undisturbed. The longer that forests are left alone and the longer that trees are left to grow, the more time a fully-fledged, interconnected forest ecosystem has to develop. The older trees in these forests support endangered wildlife and while filtering and storing clean water that downstream communities depend on. Habitat connectivity is one of the most important functions of intact, roadless forests, providing migration corridors for species such as elk, deer, fishers, and salmon. Rescinding the Roadless Rule would fragment these landscapes, cutting off wildlife from breeding grounds, food sources, and seasonal ranges, and diminishing the ability of older forests to sustain resilient ecosystems and buffer against climate change. People rock climb, hike, bike, hunt, fish and ski in these remote places. These forests also provide cultural, recreational, and ceremonial value for communities and Tribes who depend on intact landscapes for traditional practices, gathering, and ceremony. Rolling back the Roadless Rule will not protect communities from wildfire and may in fact lead to more wildfires. Wildfires are four times as likely to start in areas with roads than in roadless forest tracts and 90 percent of all wildfires nationwide started within half a mile of a road. We shouldn’t jeopardize the wildlife, habitat connectivity, recreation and clean water that these beloved intact forests provide by opening them to road-building, commercial logging, mining and drilling. Please leave America’s last wild forests alone. Sincerely, Kaelin Stephens

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

Wildlife Habitat
- “support endangered wildlife”
- “Habitat connectivity is one of the most important functions”
- “providing migration corridors for species such as elk, deer, fishers, and salmon”
- “fragment these landscapes, cutting off wildlife from breeding grounds”
Water Quality Quantity
- “filtering and storing clean water that downstream communities depend on”
- “clean water that these beloved intact forests provide”
Recreation Tourism Public Use
- “People rock climb, hike, bike, hunt, fish and ski in these remote places”
- “recreational... value for communities”
Cultural Heritage Indigenous
- “cultural, recreational, and ceremonial value for communities and Tribes”
- “depend on intact landscapes for traditional practices, gathering, and ceremony”

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.