Comment Analysis · Docket FS-2025-0001

FS-2025-0001-444824

Opposes rescissionA0 noneSubstance 5/24Posted September 17, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 21 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 USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I am an Oregon resident and a volunteer at the Bird Alliance of Oregon’s wildlife care center, and I am joining millions of Americans of all backgrounds in support of the Roadless Rule. As a birder and a volunteer wildlife rehabilitator, I have seen firsthand the devastation that the loss of habitat has had on our native wildlife. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a few examples of the benefits of retaining the Roadless Rule. Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds that supply clean water. Wildfire risk: wildfires are 4x more likely to start near roads; roughly 90% of wildfires are human caused and start within half a mile of a road — these facts directly contradict one of the Trump administration’s main rationales for rescinding the rule. Old growth & carbon storage: mature and old-growth forests are a critical buffer against runaway climate change. We should be protecting more forests, not gutting their protections. Additionally, these forests are far more resilient to wildfires than commercially logged forests. Roads are costly. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used (the existing road network already carries an $8.5+ billion maintenance backlog). The road network throughout national forests is already massive and should be reduced instead of expanded. I urge you to keep the Roadless Rule in place as it is. Thank you for your time.

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
- “critical habitat for countless imperiled species”
- “Northern Spotted Owl and Marbled Murrelet”
- “Roads fragment those forests, introducing predators and invasive species”
- “Salmon, trout, elk, and other species are also threatened when habitat is fragmented”
Water Quality Quantity
- “60 million Americans rely on national forests for drinking water”
- “intact forests filter water naturally”
- “important parts of watersheds that supply clean water”
Climate Carbon Storage
- “mature and old-growth forests are a critical buffer against runaway climate change”
- “protecting more forests, not gutting their protections”
- “far more resilient to wildfires than commercially logged forests”
Economic Impact Fiscal
- “Building new logging roads in remote backcountry areas is extraordinarily expensive”
- “leaving taxpayers with billions of dollars in long-term maintenance costs”
- “existing road network already carries an $8.5+ billion maintenance backlog”

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.