Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601614

Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 67 submissions in its group. 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
- “ensured clean drinking water”
- “degrade drinking watersheds”
- “threaten water quality for fish species and the drinking water supply”
Wildlife Habitat
- “protected wildlife habitat”
- “damage... wildlife habitat”
- “disrupt wildlife corridors”
Recreation Tourism Public Use
- “boosted the economies through both outdoor recreation”
- “damage recreation areas, scenic views”
- “core reasons people choose to live, work, and recreate”
Forest Management Wildfire
- “More roads also mean more fires”
- “wildfires are four times more likely to ignite near roads”
- “erode forest resilience in the face of rapidly shifting wildfire regimes”

What it names

National Forests: Deschutes National Forest Ochoco National Forest

The comment

In Central Oregon, there are close to 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland. These areas have protected wildlife habitat, boosted the economies through both outdoor recreation and high quality of life, and ensured clean drinking water for nearly 25 years. As a frequent visitor to these public lands, I strongly oppose the USDA’s proposal to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across nearly 45 million acres of public lands managed by the US Forest Service nationwide. I urge you to choose the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Rescinding the Roadless Rule is impractical and dangerous. In Central Oregon, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and recreate in Central Oregon. More roads also mean more fires: research shows wildfires are four times more likely to ignite near roads. More roads will also degrade drinking watersheds. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country. Rescinding the Roadless Rule also makes our forests far less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Please abandon this misguided effort to repeal the Roadless Rule and instead strengthen protections for America’s roadless forests for all the clean water, climate resilience, recreation, and habitat for biodiversity they provide. Andrew Smith Bend, OR

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.