Comment Analysis · Docket FS-2025-0001

FS-2025-0001-578850

Opposes rescissionA0 noneSubstance 5/24Posted October 6, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 162 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

Water Quality Quantity
- “Protect water quality and drinking water”
- “keeping roadless forests and the watersheds they support intact”
- “protect clean water”
Wildlife Habitat
- “Protect wildlife and habitat”
- “impacts of additional roads and logging”
- “protect wildlife habitat”
Recreation Tourism Public Use
- “Safeguard outdoor recreation”
- “undeveloped places where people hike, camp, fish, hunt, ski”
- “experience nature”
Forest Management Wildfire
- “Take wildfire risks seriously before allowing more roads”
- “relationship between roads, access, and wildfire risk”
- “limiting new roads and logging”

The comment

FS-2025-0001-223869 To the U.S. Forest Service: I am writing to express my concern about the recent proposal to eliminate the Roadless Rule. I was disappointed to learn that the Forest Service is considering removing protections that have helped safeguard roadless areas. Our national forests belong to all of us. They protect clean water and wildlife habitat and give people across the country places to hike, camp, fish, hunt, ski, and experience nature. Regarding Docket FS-2025-0001, RIN 0596-AD66, the proposal to eliminate the Roadless Rule, I urge the Forest Service to keep these protections in place. For more than 20 years, the Roadless Rule has helped keep some of the wildest parts of our national forests intact by limiting new roads and logging. And once a road is built or a forest is logged, some of what makes a roadless area special can be difficult to restore. That's why I am urging you to: – Protect water quality and drinking water by keeping roadless forests and the watersheds they support intact. – Protect wildlife and habitat from the impacts of additional roads and logging. – Safeguard outdoor recreation and the undeveloped places where people hike, camp, fish, hunt, ski, and experience nature. – Take wildfire risks seriously before allowing more roads. The Forest Service has cited wildfire management as one reason for repealing the rule, while its own review also considers the relationship between roads, access, and wildfire risk. – Preserve these public lands for future generations instead of removing protections that have been in place for more than two decades. Decisions about our national forests will have lasting consequences. Please, I am asking you to do everything within your authority to ensure our national forests can keep these protections. Withdraw the proposal to repeal the Roadless Rule and keep these safeguards in place today and for generations to come. Thank you for considering my comments. Sincerely, Jennifer Baugh, 5351 S Peachwood Cir, Taylorsville Sincerely, Ms. Jennifer Baugh

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.