Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612671

From Natural Resources Defense Council

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

Dear USDA Secretary Rollins, Please accept these 165,473 public comments from members and activists of the Natural Resources Defense Council (NRDC) in reference to FS-2025-0001. I oppose your plan to roll back the Roadless Area Conservation Rule. I urge you to reverse course and save forests. Opening up tens of millions of acres of U.S. forests in cherished public lands like California’s Tahoe National Forest and important segments of the Appalachian Trail to destructive logging and road building is reckless. Gutting the Roadless Rule would risk more polluted drinking water for over 25 million Americans, increased flooding, and more landslides. It would imperil recreation areas where people hunt, hike, camp, fish, climb, and paddle. It endangers irreplaceable habitat for iconic animals. And it would jeopardize the integrity of incomparable places like Alaska’s Tongass National Forest, the world’s largest intact temperate rainforest and the nation’s largest old-growth forest. If anything, the Rule should be strengthened to better protect all the extraordinary natural values of our essential forests. I am not letting our forests go without a fight. Preserve the Roadless Rule and protect national forests for communities who rely on them and for generations to come. Thank you. Sincerely, Jenell Walsh-Thomas National Digital Advocacy Campaign Manager, NRDC

Topics

Environmental Protection Biodiversity
- “endangers irreplaceable habitat for iconic animals”
- “jeopardize the integrity of incomparable places like Alaska's Tongass National Forest”
- “protect all the extraordinary natural values of our essential forests”
Water Quality Quantity
- “risk more polluted drinking water for over 25 million Americans”
- “increased flooding”
- “more landslides”
Recreation Tourism Public Use
- “imperil recreation areas where people hunt, hike, camp, fish, climb, and paddle”
- “cherished public lands like California's Tahoe National Forest”
- “important segments of the Appalachian Trail”
Resource Development Extraction
- “destructive logging and road building”
- “Opening up tens of millions of acres of U.S. forests”
- “Gutting the Roadless Rule”

What it names

National Forests: Tahoe National Forest Tongass National Forest

Attachments

7 files from Natural Resources Defense Council. Counts as 165,659 — Counted from the files: The enclosed submissions were counted from the files themselves.

Own letter
Enclosed submissions
Enclosed submissions
Enclosed submissions
Enclosed submissions
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.