Comment Analysis · Docket FS-2025-0001

FS-2025-0001-541650

Opposes rescissionA3 weakSubstance 6/24Owed an answerPosted October 4, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 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 am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, docket FS-2025-0001, and to ask the Forest Service to select the no-action alternative. About 91 percent of Oregon roadless forest, some 1.66 million acres, sits in municipal watersheds serving roughly 800,000 people, and roads send sediment into the cold streams that marbled murrelets and coho depend on. More than 625,000 comments came in during 2025, a 2026 Pew poll found 76 percent of voters want the rule kept, and the agency faces an 11.2 billion dollar road-maintenance backlog while proposing to build more. Roadless national forests are among the best remaining habitat for species already in trouble, giving refuge to hundreds of vulnerable wildlife species (Dietz et al., 2021). On the Oregon coast that means salmon, elk, and seabirds like the marbled murrelet, all of which depend on unroaded, unfragmented forest and the cold, clean streams that roads degrade. Roadless forests store carbon far out of proportion to their size. On national forest lands, inventoried roadless areas hold about 22 percent of the mature-forest carbon and 27 percent of the old-growth carbon (Birdsey et al., 2025). Logging them releases carbon we cannot afford to lose and cannot quickly get back. Outdoor recreation is a major Oregon industry, supporting about 192,000 jobs, 16 billion dollars in spending, and 12.4 billion dollars of the state economy (Oregon Parks and Recreation Department, 2022). Roadless backcountry is the setting for much of the hunting, fishing, and hiking that sustains it, and new roads and logging trade a recurring economy for a one-time cut. I grew up camping, fishing, hiking, and photographing wildlife in this forest. It was—and still is—a huge part of what fostered my love for and connection to nature. Those childhood experiences shaped my understanding as an adult of what it means to live in reciprocity with the natural world, and taught me to deeply value wild spaces beyond anything monetary—for both the people who find connection within them and the other species who call them home. For these reasons I ask the Forest Service to withdraw the proposal and retain the 2001 Roadless Rule. 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

A3 weak: Substantive, but easier to set aside. This rating is the one its shared letter earned.

Owed an answer on Analytical gap.

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

Water Quality Quantity
- “sits in municipal watersheds serving roughly 800,000 people”
- “roads send sediment into the cold streams”
- “cold, clean streams that roads degrade”
Wildlife Habitat
- “best remaining habitat for species already in trouble”
- “giving refuge to hundreds of vulnerable wildlife species”
- “depend on unroaded, unfragmented forest”
Climate Carbon Storage
- “Roadless forests store carbon far out of proportion to their size”
- “hold about 22 percent of the mature-forest carbon”
- “Logging them releases carbon we cannot afford to lose”
Recreation Tourism Public Use
- “Outdoor recreation is a major Oregon industry”
- “Roadless backcountry is the setting for much of the hunting, fishing, and hiking”
- “trade a recurring economy for a one-time cut”

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.