Comment Analysis · Docket FS-2025-0001

FS-2025-0001-475211

Opposes rescissionA0 noneSubstance 5/24Posted September 23, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 22 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

As a hunter, angler, and public land owner, I urge the U.S. Forest Service (USFS) to reject the proposed rescission of the 2001 Roadless Rule. For more than two decades, the Roadless Rule has conserved some of the most important fish and wildlife habitat in the National Forest System while allowing many of the management activities needed to maintain healthy forests. The rule does not prohibit hunting, fishing, grazing, recreation, habitat restoration, hazardous fuels reduction, wildfire mitigation, mining, or access to valid existing rights. Instead, it provides a common-sense framework for limiting new road construction in some of the nation's most intact backcountry landscapes. Rescinding the rule will harm durable access, game migration, and opportunities for future hunters and anglers across the country. USFS currently manages approximately 370,000 miles of roads and faces a deferred maintenance backlog of roughly $10.8 billion, with ~55% of that backlog tied to roads alone. Meanwhile, the proposed rule cites an annual National Forest System sawtimber harvest of just $5.2 to $11.4 million per year in revenue to the Treasury and Forest Service and $4.6 to $10.6 million per year in revenue to the timber industry if the rule were to be rescinded. This proposed action is not fiscally responsible. Building additional roads into currently roadless areas would create new long-term maintenance obligations while diverting resources from the existing infrastructure the agency already struggles to maintain. Roadless areas provide critical habitat for fish and wildlife, conserve clean water, and support the hunting and fishing opportunities that define America's outdoor heritage. These landscapes help maintain secure habitat for elk, mule deer, native trout, and countless other species that depend on large, unfragmented landscapes. They also protect headwater streams and watersheds that supply clean drinking water to communities across the country. The Roadless Rule was developed through one of the largest public participation efforts in federal land management history, generating approximately 1.6 million public comments, 99% of which were in support of the rule. Any decision to weaken or eliminate these protections should be supported by clear evidence that doing so would improve land management outcomes without sacrificing wildlife habitat, watershed health, recreational opportunities, or fiscal responsibility. America's roadless areas remain some of our most valuable public lands. The Forest Service should focus on maintaining existing infrastructure, conserving intact habitat, and ensuring future generations inherit the same hunting, fishing, and backcountry opportunities we enjoy today. While I remain open to common sense, locally informed improvements to the Roadless Rule, Alternative 2 and 3 would remove protections from millions of acres and go far beyond the targeted reforms both I and Backcountry Hunters & Anglers have supported. I respectfully urge the Forest Service to adopt the no action alternative and keep the 2001 Roadless Rule in place. Don't bulldoze the backcountry. Defend the Roadless Rule.

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
- “conserved some of the most important fish and wildlife habitat”
- “harm durable access, game migration”
- “critical habitat for fish and wildlife”
- “secure habitat for elk, mule deer, native trout”
Water Quality Quantity
- “conserve clean water”
- “protect headwater streams and watersheds”
- “supply clean drinking water to communities”
Recreation Tourism Public Use
- “opportunities for future hunters and anglers”
- “hunting and fishing opportunities that define America's outdoor heritage”
- “backcountry opportunities we enjoy today”
- “Don't bulldoze the backcountry”
Economic Impact Fiscal
- “not fiscally responsible”
- “deferred maintenance backlog of roughly $10.8 billion”
- “create new long-term maintenance obligations”
- “diverting resources from the existing infrastructure”

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.