Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612252

From Winter Wildlands 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

Winter Wildlands Alliance (WWA) is a national non-profit conservation organization representing the interests of human-powered winter recreationists. We work to inspire and empower people to protect America’s wild snowscapes. Our alliance includes 38 grassroots groups across 16 states. Our community values roadless areas for the opportunities they provide for backcountry winter recreation, including skiing, snowboarding, and snowshoeing. Additionally, while these areas are protected from new road construction and timbering, their management is less restrictive than Wilderness, allowing for more flexible land management in these important places. Roadless areas exist across the country and are home to beloved winter backcountry recreation spots like Montana’s Hayalite Canyon, a world-renowned ice climbing destination; backcountry skiing at Washington Pass and Liberty Bell at the Headwaters of Washington’s Methow Valley; backcountry skiing, Nordic skiing, and snowshoeing in Utah’s Central Wasatch, a region which draws thousands of visitors each winter; backcountry skiing around Lake Tahoe and in the Sherwins next to the town of Mammoth California; and backcountry skiing and snowshoeing around Wyoming's scenic Teton Pass; and so many more special areas. Without the protections of the 2001 Roadless Rule, all of these areas are subject to new road construction, timber harvesting and commercial development which could fundamentally impact landscapes that provide critical ecosystem services and meaningful outdoor experiences. We write here to submit comments on behalf of 1,134Winter Wildlands Alliance members and supporters. Thank you for considering these comments from across our network.

Topics

Recreation Tourism Public Use
- “backcountry winter recreation”
- “beloved winter backcountry recreation spots”
- “meaningful outdoor experiences”
Environmental Protection Biodiversity
- “protect America's wild snowscapes”
- “critical ecosystem services”
- “subject to new road construction, timber harvesting and commercial development”

What it names

Roadless areas: Liberty Bell

Attachments

1 file from Winter Wildlands Alliance. Counts as 1,134 — 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.