Comment Analysis · Docket FS-2025-0001

FS-2025-0001-603444

From Prairie Rivers Network

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

These comments are submitted on behalf of Prairie Rivers Network and 658 people who signed a petition (the petition signers are named in the attached PDF) related to the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). The majority of our signers are Illinois residents who are particularly concerned about the impacts to the Shawnee National Forest in Southern Illinois. Prairie Rivers Network is an Illinois environmental nonprofit, and we are the state affiliate of the National Wildlife Federation. Our mission is to protect water, heal land, and inspire change. Protect Shawnee's Roadless Areas: Keep the Roadless Rule in Place We oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Shawnee National Forest, where the forest is already highly fragmented. The 10,666 acres of important roadless areas in the Shawnee provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Opening up areas of the Shawnee to more road construction means the spread of invasive species, further habitat fragmentation, erosion and sedimentation into pristine streams, as well as direct impacts to threatened and endangered species and all wildlife. We urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place.

Topics

What it names

National Forests
Shawnee National Forest

Attachments

1 file from Prairie Rivers Network. Counts as 654 — 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.

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