Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601816

From International Mountain Bicycling Association

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

In addition to an organizational comment submitted separately, the International Mountain Bicycling Association (IMBA) collected and has attached 326 unique letters as well as 853 signatures on the comment below. This totals comments submitted by 1,179 total individual citizens. In the attached document the 853 signatures are on pages 1-29 followed by the 326 unique letters on pages 30-142. As a mountain biker and constituent who cares about America’s public lands, I urge you to oppose the rescission of the 2001 Roadless Rule. The Roadless Rule is not an extreme protection, it is a practical balance. It shields 45 million acres of National Forest land from permanent road construction and industrial logging while still allowing mountain biking, hiking, motorized recreation, hunting and fishing. It explicitly allows for emergency fire suppression, prescribed burns, and fuels treatments near communities. What it prevents is permanent, irreversible development that would fragment trail networks and degrade the backcountry character communities depend on. Approximately 10,794 miles of trails open to mountain bikes fall within affected areas, part of a broader recreation network anchoring a $1.2 trillion outdoor recreation economy and 5 million American jobs. Please oppose this wholesale rescission. Do not remove protections without a clear replacement framework that continues to protect these 45 million acres of our public lands.

Topics

Recreation Tourism Public Use
- “fragment trail networks”
- “degrade the backcountry character”
- “$1.2 trillion outdoor recreation economy”
- “5 million American jobs”
Environmental Protection Biodiversity
- “shields 45 million acres of National Forest land from permanent road construction and industrial logging”
- “prevents permanent, irreversible development”
- “practical balance”
Governance Policy Process
- “oppose this wholesale rescission”
- “Do not remove protections without a clear replacement framework”
- “explicitly allows for emergency fire suppression, prescribed burns, and fuels treatments”

Attachments

1 file from International Mountain Bicycling Association. Counts as 853 — 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.