Comment Analysis · Docket FS-2025-0001

FS-2025-0001-570121

From Defenders of Wildlife

Opposes rescissionPosted October 5, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

The comment

Defenders of Wildlife informed its members and supporters of the opportunity to comment on the U.S. Department of Agriculture’s notice of proposed rulemaking to rescind the 2001 Roadless Area Conservation Rule. In response, 15,212 members and supporters submitted comments. Please find those attached.

Topics

Public Opinion Support
- “Defenders of Wildlife informed its members”
- “15,212 members and supporters submitted comments”
- “opportunity to comment on the U.S. Department of Agriculture's notice”

Attachments

6 files from Defenders of Wildlife. Counts as 15,212 — Counted from the files: The enclosed submissions were counted from the files themselves.

Enclosed submissions
Enclosed submissions
Enclosed submissions
Enclosed submissions
Enclosed submissions
Enclosed submissions

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.