Comment Analysis · Docket FS-2025-0001

FS-2025-0001-537983

Opposes rescissionA0 noneSubstance 3/24Posted October 4, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 99 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
- “preserving irreplaceable wildlife habitats”
- “sustain sensitive fish, bird and wildlife species”
- “need these intact ecosystems to survive”
Climate Carbon Storage
- “older trees absorb and store more carbon”
- “mitigate climate change”
- “absorb and store carbon, helping us to fight climate change”
Water Quality Quantity
- “sources of clean water”
- “filter drinking water”
- “provide clean, clear drinking water for communities”
Recreation Tourism Public Use
- “recreation areas for future generations”
- “extraordinary landscape for numerous backcountry recreation activities”
- “provide recreational opportunities”

What it names

National Forests: Tongass National Forest

The comment

I oppose the Trump administration’s plans to rescind the Roadless Area Conservation Rule. The roadless areas in our national forests are an American treasure. For a quarter century, the Roadless Rule has protected them from roadbuilding and logging, preserving irreplaceable wildlife habitats, sources of clean water, and recreation areas for future generations. The Trump administration’s proposal to repeal the Roadless Rule threatens all these benefits. This rollback would harm forests like the Tongass National Forest, where the Roadless Rule protects over 9 million acres of the 17-million-acre forest from industrial logging and damaging roadbuilding.     Although the proposed repeal is being justified in part as a wildfire-prevention measure, peer-reviewed evidence shows that increasing roadbuilding will only increase wildfires. More than 80% of wildfires occur within 800 meters of roads, according to recent research.  In addition, increasing timber production means cutting down bigger, old trees, which are the most resilient to wildfire. Once an old-growth tree is cut and sold, it will take hundreds of years to replace it, and even longer for ecosystems to heal following clearcutting. Since older trees absorb and store more carbon than their younger counterparts, it is especially important that we keep these forests standing right now while we have the greatest ability to mitigate climate change.    Forests are not a crop to be used to line the pockets of industry executives. They sustain fish, birds, wildlife, and people; filter drinking water; provide recreational opportunities; and absorb and store carbon, helping us to fight climate change. Carving up these forests with roads and logging means we lose those benefits. These lands belong to all Americans, not the timber industry. The pristine lands protected by the Roadless Rule provide an extraordinary landscape for numerous backcountry recreation activities; sustain sensitive fish, bird and wildlife species that need these intact ecosystems to survive; provide subsistence to Tribes; and provide clean, clear drinking water for communities. Without protection for these roadless lands, all of those benefits will be jeopardized. I urge you to keep the Roadless Rule in place and protect our forests. This is the US people’s land - please do not destroy the habitat & ecosystem that serves us all. Sincerely, Connie McDonald Chicago, IL

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.