Comment Analysis · Docket FS-2025-0001

FS-2025-0001-475849

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 132 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.

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
- “Roads fragment wildlife habitat”
- “provide habitat for many threatened and endangered native species”
- “provide important migration corridors”
Water Quality Quantity
- “Roads threaten high-quality streams and rivers”
- “Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife”
- “increase the risk of landslides that suffocate streams and rivers”
Recreation Tourism Public Use
- “Roadless areas provide for recreation, like camping, hiking and backpacking”
- “hunting and angling, wildlife viewing and photography”
- “Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas”
Forest Management Wildfire
- “More roads will result in more human-caused fires in the backcountry”
- “more than 60 percent of human-caused fires... are ignited within 1/8-mile of the nearest road”

The comment

I oppose rescinding the Roadless Area Conservation Rule. It has helped protect roadless areas, and adjacent Wilderness areas, on national forests for 25 years. If anything is done with the Roadless Area Conservation Rule, it should be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. Roads fragment wildlife habitat. Existing roadless areas provide habitat for many threatened and endangered native species. Roadless areas also provide important migration corridors. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Roadless areas provide for recreation, like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. The Forest Service already has a huge road system—stretching 380,000 miles, which is longer than the country’s highways—with an estimated maintenance backlog of over $8.6 billion. As a backpacker, bow-hunter,rifle-hunter, outdoor nature & wildlife photographer and 8 year Vet of the USAF, USAF/AirNg and USN, I want to see wildlands and wildlife protected. We do Not need more human sprawl like more roads and more logging into roadless areas. One of the main things I valued serving the USA for is to protect all the great things we have in the USA, especially our wild areas and wildlife and their habitats. Thanks for your time and consideration on this matter.

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.