Comment Analysis · Docket FS-2025-0001

FS-2025-0001-487146

Opposes rescissionA0 noneSubstance 2/24Posted September 28, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 21 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

Dear Special Areas: Roadless Area Conservation, I'm writing asking you not to repeal the 2001 Roadless Area Conservation Rule. For more than two decades, this important policy has safeguarded 58 million acres of irreplaceable habitat for wildlife like elk and cold-water fish species, guaranteed fresh water to tens-of-millions of Americans, and protected Indigenous areas that provide subsistence hunting and gathering of food.The richness of our nation's ecosystems are a critical part of our national heritage and the Forest Service has a responsibility to ensure that future generations will enjoy the iconic species of our nation's forests and grasslands. Nearly 450 threatened and endangered species depend on roadless areas for their survival. In addition, our national forest system provides drinking water to nearly 90% of the people served by public water systems in the West and provides the water to farmers in California and Arizona who grow 90% of the winter vegetables consumed in the United States. Roads increase sediment and runoff that destroy watersheds. The Roadless Rule also supports areas that are important for Indigenous ceremonies and food gathering. Tribal treaty rights must be centered and upheld in any revision of the 2001 Roadless Rule. In short, there is simply no reason for a repeal of this important conservation policy.Sincerely, Madeline Von der linden Sincerely, Ms. Madeline Von der linden

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
- “safeguarded 58 million acres of irreplaceable habitat for wildlife like elk and cold-water fish species”
- “Nearly 450 threatened and endangered species depend on roadless areas for their survival”
- “ensure that future generations will enjoy the iconic species of our nation's forests and grasslands”
Water Quality Quantity
- “guaranteed fresh water to tens-of-millions of Americans”
- “provides drinking water to nearly 90% of the people served by public water systems in the West”
- “Roads increase sediment and runoff that destroy watersheds”
Cultural Heritage Indigenous
- “protected Indigenous areas that provide subsistence hunting and gathering of food”
- “supports areas that are important for Indigenous ceremonies and food gathering”
- “Tribal treaty rights must be centered and upheld in any revision of the 2001 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.