Comment Analysis · Docket FS-2025-0001

FS-2025-0001-567190

Opposes rescissionA0 noneSubstance 3/24Posted October 5, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. This comment stands for 17 submissions in its group. See the letter, its submissions and topics.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

The comment

Please do not rescind the 2001 Roadless Area Conservation Rule. This rule is integral to maintaining healthy wildlife populations and habitat and provides irreplaceable recreation opportunities for Americans. This rule was overwhelmingly popular when it was put in place and remains so today. The Roadless Rule was developed through one of the largest public participation efforts in federal land management history, generating approximately 1.6 million public comments, 99% of which were in support of the rule. Roadless does not mean unmanaged and this current rule does not prohibit hunting, fishing, grazing, recreation, habitat restoration, hazardous fuels reduction, wildfire mitigation, mining, or access to valid existing rights. Adding roads to an already overloaded maintenance backlog does not make fiscal sense and is a bad deal for wildlife and people alike. USFS currently manages approximately 370,000 miles of roads and faces a deferred maintenance backlog of roughly $10.8 billion, with ~55% of that backlog tied to roads alone. The idea that building roads into the backcountry will help with fire suppression is unsupported and in fact will lead to more fires. Keep this rule in place so that future generations of Americans can enjoy the wilds that define our country. I respectfully urge the Forest Service to adopt the no action alternative and keep the 2001 Roadless Rule in place. Don't bulldoze the backcountry. Defend the Roadless Rule.

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.

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
- “maintaining healthy wildlife populations and habitat”
- “bad deal for wildlife and people alike”
- “Defend the Roadless Rule”
Recreation Tourism Public Use
- “irreplaceable recreation opportunities for Americans”
- “future generations of Americans can enjoy the wilds”
- “Don't bulldoze the backcountry”
Economic Impact Fiscal
- “Adding roads to an already overloaded maintenance backlog does not make fiscal sense”
- “deferred maintenance backlog of roughly $10.8 billion”
- “bad deal for wildlife and people alike”
Forest Management Wildfire
- “building roads into the backcountry will help with fire suppression is unsupported”
- “will lead to more fires”
- “hazardous fuels reduction, wildfire mitigation”

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.