Comment Analysis · Docket FS-2025-0001

FS-2025-0001-465755

Opposes rescissionA0 noneSubstance 4/24Posted September 22, 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

My name is Nancy Foster and I live in Durango, CO. I am submitting this public comment today to strongly urge the USDA to select Alternative A – the No Action Alternative – in the 2001 Roadless Rule Rescission Draft Environmental Impact Statement. This Alternative would preserve the 2001 Roadless Rule. I worry about the many public resources safeguarded by roadless areas like clean drinking water, wildlife habitat, recreation access, and cultural and archaeological sites. I camp, hike ride and paddle in these areas and there is nothing left in our country like them. When money is the driver everyone loses except for the companies and the government taking advantage of the land. Native people have been taken advantage of and this is one more invasion of their culture. My boys are climbers and this will impact their ability to climb. There aren't many places left people can afford to go or that they are so popular it is impossible to get permits. This will make it even more difficult. I ask the USDA to address all of the following problems before any decision is made: Vital for America’s Drinking Water: The US National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation, serving over 60 million people in 3,400 communities in 33 states. Recreation Spots at Risk: Since 2001, protected roadless areas have offered abundant outdoor recreation opportunities such as hunting, fishing, camping or other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. According to maps from Outdoor Alliance’s GIS Lab, roadless areas protect 11,337 climbing routes and boulder problems, more than 1,000 whitewater paddling runs, 43,826 miles of trail, and 20,298 mountain biking trails. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Trails traverse protected roadless areas. Important for Protecting Migration Corridors and Game Habitat: Roads fragment habitat and degrade migration corridors that game species like elk and mule deer rely on. Protected roadless areas help ensure these migratory game corridors remain intact and protected from roads and the industrial development roads enable. Millions Support the Roadless Rule: The Roadless Rule is a highly popular policy that is often celebrated as one of America’s most successful conservation measures. Prior to its enactment, more than 600 public hearings were held nationwide, and 1.6 million Americans weighed in to call for protection of these forestlands. More recently, more than 45 members of the House and Senate have signed onto legislation that would codify the Roadless Rule so that in the future, it could not be rolled back without an act of Congress. Policy Has Built-In Exceptions: The Roadless Rule is extremely flexible and allows for necessary forest management and the construction of roads as needed to address fires, floods, or other catastrophic events, and other circumstances like the need to connect communities. National forest managers routinely conduct forest stewardship activities within roadless areas such as prescribed burning and wildlife habitat improvement activities. Sign off! For these reasons, I urge the USDA to select Alternative A and retain the existing protections for Roadless Areas. Thank you for considering my comment. Nancy Foster Durango, CO

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

Public Opinion Support
- “highly popular policy”
- “600 public hearings were held nationwide”
- “1.6 million Americans weighed in”
- “45 members of the House and Senate have signed onto legislation”
Environmental Protection Biodiversity
- “successful conservation measures”
- “protection of these forestlands”
- “codify the Roadless Rule”

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.