Comment Analysis · Docket FS-2025-0001

FS-2025-0001-597214

From Michigan League of Conservation Voters

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 file, which is a comment letter urging the USDA to withdraw its proposal to eliminate the 2001 Roadless Area Conservation Rule. The letter is submitted by the Michigan League of Conservation Voters on behalf of our members in Michigan, as well as signed by over 400 individuals from Michigan and around the United States ("The Undersigned").

Topics

Attachments

1 file from Michigan League of Conservation Voters. Counts as 400 — Stated by the submitter: The number the submitter stated in the cover note, used where the files could not be read reliably.

  • 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.

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