Comment Analysis · Docket FS-2025-0001

FS-2025-0001-525100

Opposes rescissionA0 noneSubstance 4/24Posted October 1, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 16 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

I am an outdoor enthusiast who cherishes the backcountry recreation experiences provided by Roadless national forests across the Pacific Northwest and beyond. I’m writing to share my opposition to the administration’s effort to rescind the Roadless Area Conservation Rule. I oppose any plan alternative that rescinds Roadless protections and leaves our forests vulnerable to increased extraction and development through changes to local forest plans. Opening up backcountry forests to development would irreparably harm these beloved spaces and the sustainable outdoor access and recreation economy that depend on them. A sweeping rollback of the Roadless Rule is unpopular and unnecessary - 98% of public comments on the Notice of Intent opposing rolling back Roadless protections. Roadless protections are extremely important to the outdoor recreation community. Full rescission of the Rule would affect 45 million acres of national forests, including 2 million acres in Washington state, rolling back protections on 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater, and 10,794 miles of mountain biking nationally. Roadless areas are especially important to my own outdoor experiences on federally managed public lands, including programs and activities facilitated by outdoor education providers like The Mountaineers. The Roadless Rule protects our country’s forests and the values they support. In addition to backcountry recreation, Roadless Areas also protect the following values: -Intact old-growth forests for environmental health and climate resilience -Indigenous cultural rights and lifeways -Wildlife habitat -Clean drinking water for gateway communities At a time when public lands and communities across the West are increasingly impacted by large and intense wildfires, this policy is a step in the wrong direction. Opening intact backcountry forests to new roads is not a wildfire solution. It’s a move that would lead to more fire starts and more wildfires. According to the Forest Service, 9 out of 10 wildfires are caused by people. In addition, I also oppose a partial recession, including any attempt to exempt currently roaded areas and the Wildland Urban Interface. This type of recession would result in the loss of protections for approximately 50% of Roadless national forests. The Roadless Rule already includes appropriate exceptions to ensure local land managers have flexibility to address wildfire risk. Thank you for considering my comment.

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

Recreation Tourism Public Use
- “cherishes the backcountry recreation experiences”
- “sustainable outdoor access and recreation economy”
- “rolling back protections on 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater, and 10,794 miles of mountain biking”
Environmental Protection Biodiversity
- “Intact old-growth forests for environmental health and climate resilience”
- “Wildlife habitat”
- “irreparably harm these beloved spaces”
Water Quality Quantity
- “Clean drinking water for gateway communities”
Cultural Heritage Indigenous
- “Indigenous cultural rights and lifeways”

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.