Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604812

From Outdoor Alliance

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

Outdoor Alliance collected 67,193 comments on the USDA’s proposed rule on Roadless Area Conservation, which includes 14,744 unique comments and 52,449 signatures on the following comment. You can find the unique comments first, followed by the signatures. If you have any questions, please contact Tania Lown-Hecht, tania@outdooralliance.org. Thank you! Comment: I am an avid outdoor recreationist who regularly visits roadless areas on America's national forests and I support the No Action alternative in the current DEIS. I am deeply concerned with the idea of rescinding the Roadless Rule, which is extremely important to the outdoor recreation community and the outdoor recreation economy. The rescission would remove important protections for approximately 45 million acres of backcountry national forests, including more than 25,000 miles of trails, 10,000 climbing routes, nearly 1,000 miles of whitewater, and more than 10,000 miles of mountain biking. I strongly support maintaining the Roadless Rule as is. Outdoor recreation is a crucial part of our country's economy, and rescinding the Roadless Rule is unpopular and unnecessary.

Topics

Recreation Tourism Public Use
- “avid outdoor recreationist”
- “outdoor recreation economy”
- “25,000 miles of trails”
- “10,000 climbing routes”
Environmental Protection Biodiversity
- “remove important protections”
- “backcountry national forests”
- “maintaining the Roadless Rule”
Public Opinion Support
- “collected 67,193 comments”
- “52,449 signatures”
- “unpopular and unnecessary”

Attachments

2 files from Outdoor Alliance. Counts as 67,077 — Counted from the files: The enclosed submissions were counted from the files themselves.

Enclosed submissions
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.