Comment Analysis · Docket FS-2025-0001

FS-2025-0001-458419

Opposes rescissionA0 noneSubstance 3/24Posted September 21, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 11 submissions in its group; the sender added words of their own. 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

As a passionate advocate for our nation's public lands and waterways, I am writing to share my strong opposition to rescinding or altering the Roadless Conservation Area Rule. The protections currently provided for these 58.5 million acres of land across the United States not only conserve critical habitat for native species, but they also ensure that Americans, like myself, have undeveloped natural spaces to enjoy hiking, hunting, fishing, and so much more. One of my favorite places to visit is the ___________ [insert a specific roadless area or river in a roadless area here] near my home in ________. As a 37+ year resident and frequent vacationer in the NC mountains, I am deeply concerned with the idea of rescinding the Roadless Rule, which is extremely important to maintaining the health of our local drinking water resources. The Roadless Rule directly protects over 80,000 miles of rivers, some of which are right here in my back yard in the Catawba-Wateree River Basin. Our local water resources are already heavily impacted by stormwater runoff and erosion caused by rampant development throughout the region, so it is critical that we conserve the safe haven spaces currently protected by the Roadless Rule. I have seen this first hand when our cove on Lake Wylie was repeatedly polluted with run off when the woods behind us were clear cut for a major new development. Today I drove through Bat Cave and Chimney Rock in NC and witnessed the devastation still evident after Hurricane Helene. I strongly support maintaining the Roadless Rule as it is. Watershed protection is vital for the health and wellbeing of our communities now and for generations to come. The beauty of North Carolina is unmatched - do not destroy it through greed and/or misguided decision making. Sincerely, Janet Harlan

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

Water Quality Quantity
- “maintaining the health of our local drinking water resources”
- “directly protects over 80,000 miles of rivers”
- “conserve the safe haven spaces currently protected by the Roadless Rule”
- “Watershed protection is vital”
Recreation Tourism Public Use
- “undeveloped natural spaces to enjoy hiking, hunting, fishing”
- “One of my favorite places to visit is Wilson Creek”
- “public lands and waterways”
Wildlife Habitat
- “conserve critical habitat for native species”
- “protections currently provided for these 58.5 million acres”

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.