Comment Analysis · Docket FS-2025-0001

FS-2025-0001-595763

From The Conservation Alliance

Opposes rescissionPosted October 6, 2026 On Regulations.gov

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

The comment

**SEE ATTACHED PDF FOR FULL COMMENT WITH 113 BUSINESS SIGNATORIES** The Conservation Alliance and the Brands for Public Lands coalition write in strong opposition to the U.S. Department of Agriculture's (USDA) proposal to rescind the 2001 Roadless Rule. We urge USDA to select Alternative 1, the No Action alternative in the Draft Environmental Impact Statement (DEIS) for the final rule. As businesses whose livelihoods depend directly on the conservation of and access to America's national forests, we believe both Alternatives 2 and 3 will cause real, lasting harm to our businesses, the gateway communities we operate in, and the customers we serve. Retaining the 2001 rule reflects a quarter-century of bipartisan, nationwide consensus that has provided businesses like ours with the regulatory certainty to invest in retail partners, guiding permits, outfitting operations, and other gateway-community infrastructure. Rescinding the rule now would replace that stability with uncertainty about the future of the landscapes we depend on, and will undermine the consistency our business models rely on. Given the economic, recreational, and procedural concerns we have outlined in the attached PDF, TCA and the businesses signed on to this letter respectfully urge USDA to select Alternative 1, the No Action alternative and retain the 2001 Roadless Rule in its entirety. Outdoor businesses, gateway communities, and recreationists have built livelihoods and traditions around the durability of this protection across millions of acres of forests. We ask the agency to respect the overwhelming wishes of the public and prioritize long-term economic stability for businesses and communities: retain the rule. Thank you for considering our comments.

Topics

Economic Impact Fiscal
- “livelihoods depend directly on the conservation”
- “cause real, lasting harm to our businesses”
- “regulatory certainty to invest in retail partners”
- “prioritize long-term economic stability for businesses and communities”
Recreation Tourism Public Use
- “access to America's national forests”
- “guiding permits, outfitting operations”
- “gateway communities we operate in”
- “recreationists have built livelihoods and traditions”
Governance Policy Process
- “select Alternative 1, the No Action alternative”
- “bipartisan, nationwide consensus”
- “replace that stability with uncertainty”
- “respect the overwhelming wishes of the public”

Attachments

1 file from The Conservation Alliance. Counts as 116 — Counted from the files: The enclosed submissions were counted from the files themselves.

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.