Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603109

From Virginia Wilderness Committee

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

October 6, 2026 RE: RIN 0596-AD66 Docket number FS-2025-0001 Dear Secretary Rollins, My name is Cathryn McCue, of Virginia, and I currently serve as vice president of the board of Virginia Wilderness Committee, a 501-c-3 nonprofit organization. Our mission is to: permanently protect the best of Virginia's wild places for future generations, foster understanding and appreciation of Wilderness, and promote enjoyment and stewardship of our last remaining wildlands. Organized in 1969, the Virginia Wilderness Committee (VWC) works closely with the congressional delegation from Virginia and others to pass federal legislation under the 1964 Wilderness Act, to provide permanent protection to outstanding wild areas on public land in Virginia. VWC has been instrumental in passing legislation designating all existing wilderness areas in the George Washington & Jefferson National Forests and in Shenandoah National Park. Regarding the proposed action under Federal Register Number 2026-16965 (CFR 36 CFR Part 294), I respectfully submit the attached comment which VWC offered as a petition which our members and other interested members of the public could sign. Per the information the FAQ of Regulations.gov (https://www.regulations.gov/faq?anchor=find), we had apprised those signers, and we expect, that EACH of these 178 names will be officially and individually counted as a “received comment” on this docket. Excerpt from the FAQ: “When uploading Attachments to the Regulations.gov Comment Form, users are asked, “Did you attach files with multiple Comment submissions?" If the user indicates "Yes," they are prompted to provide the number of Comments the Attachment represents. The Comment will have one Comment ID, but will count as multiple Comments. That number is incorporated into the Overall Comment Count. While Comments representing multiple submissions will be reflected in the Overall Comment Count, they will not automatically be reflected in the Number of Comments Posted because a Comment representing multiple Comment submissions will only be posted one time. As a result, the Docket may reflect that the Number of Comments Received is greater than the Number of Comments Posted, even if all of the Comment submissions, including Comment submissions with an Attachment(s) containing multiple Comment submissions, have been posted.” Attached are two PDFs. One contains the public comment petition language which these 178 individuals signed on to. In short, we object to the proposal to repeal the Roadless Area Conservation Rule and strongly urge the administration to keep the current rule which is vital for protecting America’s natural heritage for the benefit of current and future generations. The second PDF contains the names, email addresses, and city and state of residence of the 178 people who signed onto this petition. Thank you, Cathryn McCue, Board, Vice President Virginia Wilderness Committee

Topics

Environmental Protection Biodiversity
- “permanently protect the best of Virginia's wild places”
- “protecting America's natural heritage”
- “outstanding wild areas on public land”
Recreation Tourism Public Use
- “promote enjoyment and stewardship of our last remaining wildlands”
- “foster understanding and appreciation of Wilderness”

What it names

Law cited: 36 CFR Part 294

Attachments

2 files from Virginia Wilderness Committee. Counts as 178 — Counted from the files: The enclosed submissions were counted from the files themselves.

Own letter
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.