Comment Analysis · Docket FS-2025-0001

FS-2025-0001-482136

Opposes rescissionA0 noneSubstance 6/24Posted September 25, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. This comment stands for 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

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. America is great because of our beautiful outdoor public lands. These roadless lands are valuable for the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. The agency should take Alternative 1, the No Action alternative, and leave current roadless protections in place. I am a mother with two children. As a family, we love to go hiking in the beautiful Oregon forests. My kids love to spot different types of birds and animals. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species. My kids deserve to have these wild places intact when they grow up. Once roads and clearcuts fragment these landscapes, the damage is permanent. More roads in the backcountry also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. My kids deserve to be safe from fires and not to breathe even more smoky air. Equally troubling is the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During last fall’s comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests. Do what's right for our future and chose the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, Karen Jacobson OR

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
- “wildlife habitat”
- “intact, resilient ecosystems”
- “refuge for vulnerable species”
- “biodiversity”
Water Quality Quantity
- “clean water”
- “filter and store clean water”
- “clean water sources”
Governance Policy Process
- “abridged and inadequate public comment process”
- “rushed process that limits and ignores input”
- “undemocratic and deeply irresponsible”
Recreation Tourism Public Use
- “recreation opportunities”
- “hiking in the beautiful Oregon forests”
- “outdoor recreation”

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.