Comment Analysis · Docket FS-2025-0001

FS-2025-0001-598192

Opposes rescissionA3 weakSubstance 10/24Owed an answerPosted October 6, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 20 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.

The comment

Dear Joshua White, I live and play in the Pacific Northwest and I love the wilderness areas that are protected and flourishing in the area. One of my favorite areas is in North Idaho in the Shoshone Range. For the past 25 years I have spent a week there every summer and it is my happy place, the mountains, rivers, creeks and looking out at solid pine trees for as far as the eye can see is such a blessing. The clear river full of fish and the elk herd that roams through the meadow as well as the moose and deer that are always in the area are priceless and I wish everyone had a chance to see such things even once in their lifetime. The Roadless Rule helps protect these special areas for human enjoyment and safe animal habitat. The 2001 Roadless Rule has safeguarded more than 44 million acres of our national forest lands for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economies, and ecosystems that depend on these forests. I worry about the potential habitat destruction resulting from logging and roadbuilding. Old-growth forests are essential for the survival of the northern goshawks, northern spotted owl and other wildlife. I worry about biodiversity loss, which is happening all over this beautiful land and the Roadless Rule is helping to preserve that biodiversity. I also worry about ecological integrity, the overall health of the forest ecosystem that could be compromised, affecting not only wildlife but also the forest's ability to provide clean air and water. These lands are protected for a reason and ruining them for a little bit of resources is not healthy for the rest of our country. This is what is at stake. National forests are the backbone of life and livelihood for communities across the country. They provide clean drinking water for millions of Americans, support fish and wildlife habitat, are home to sacred and cultural sites and offer recreation and tourism opportunities that sustain rural economies. Removing the Roadless Rule would put these benefits at risk. National forests should not be managed on the premise that roadbuilding will reduce wildfire, insects, and disease. Wildfire risk to communities is best addressed by hardening homes and treating fuels in the wildland-urban interface, not by opening remote backcountry. Roadbuilding and timber harvest will not reduce insects and disease; they will exacerbate these issues by reducing climate resilience, and new roads increase the risk of human-caused fires Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. The Forest Service should be investing in active forest management practices, wildfire risk reduction, forest health maintenance and ecosystem integrity. Healthy roadless areas are supporting the local wildlife and promoting healthy ecosystems. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Americans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Jennifer Stolz

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

A3 weak: Substantive, but easier to set aside. This rating is the one its shared letter earned.

Owed an answer on Evidence.

Standard dismissals it defeats

Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
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.
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

Environmental Protection Biodiversity
- “safeguarded more than 44 million acres”
- “support fish and wildlife habitat”
- “fails the people, economies, and ecosystems”
Economic Impact Fiscal
- “fiscally irresponsible”
- “$6.9 billion backlog in road maintenance”
- “subsidized the Tongass timber program at a rate of over $25 million per year”
Forest Management Wildfire
- “Wildfire risk to communities is best addressed by hardening homes”
- “Roadbuilding and timber harvest will not reduce insects and disease”
- “new roads increase the risk of human-caused fires”
Water Quality Quantity
- “provide clean drinking water for millions of Americans”
- “Removing the Roadless Rule would put these benefits at risk”

What it names

National Forests: Tongass National Forest

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.