Comment Analysis · Docket FS-2025-0001

FS-2025-0001-457911

Opposes rescissionA0 noneSubstance 6/24Posted September 21, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 32 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 Secretary Rollins, I urge you not to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). The nearly 45 million acres of intact, roadless national forests protected by the Ruleincluding approximately 4 million acres in Utahprovide irreplaceable benefits to communities, wildlife, and future generations. Roadless areas protect cultural sites and traditional resources important to Native American Tribes, watersheds that supply clean drinking water, and habitat for native fish and wildlife. They also offer outstanding opportunities for hiking, camping, hunting, fishing, climbing, mountain biking, birdwatching, and other forms of nonmotorized recreation. These intact forests also store carbon and help communities and ecosystems respond to a changing climate. Roadless national forests are also part of a larger network of connected public lands. They help link mountain ecosystems and headwaters with neighboring BLM lands, including the wilderness-caliber lands proposed for protection in Americas Red Rock Wilderness Act. This proposal is not necessary to preserve access to existing roads, trailheads, or recreation opportunities. Rather, rescinding the Roadless Rule would make it easier to build new roads and open some of our most intact public lands to commercial logging, mining, and other extractive development. New roads carry lasting consequences: they fragment wildlife habitat, erode soils, degrade streams and water supplies, spread invasive species, and increase human disturbance. They can also increase wildfire ignitions. The claim that rescinding the Roadless Rule will protect communities from wildfire is not supported by the best available science. The Rule already allows wildfire suppression and certain fuel-reduction work, including emergency road construction when necessary. We can protect communities from wildfire without sacrificing the last intact roadless forests to permanent roadbuilding and industrial development. Once again, I urge you to protect Americas forests, waters, wildlife, and public lands by withdrawing this proposal and leaving the Roadless Rule in place for future generations. With compassion for all species,

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
- “protect cultural sites and traditional resources”
- “habitat for native fish and wildlife”
- “fragment wildlife habitat”
- “spread invasive species”
Water Quality Quantity
- “watersheds that supply clean drinking water”
- “degrade streams and water supplies”
- “erode soils”
Recreation Tourism Public Use
- “outstanding opportunities for hiking, camping, hunting, fishing, climbing, mountain biking, birdwatching”
- “nonmotorized recreation”
- “preserve access to existing roads, trailheads, or recreation opportunities”
Forest Management Wildfire
- “The claim that rescinding the Roadless Rule will protect communities from wildfire is not supported by the best available science”
- “The Rule already allows wildfire suppression and certain fuel-reduction work”
- “increase wildfire ignitions”

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.