Places & Citations

2001 Roadless Rule Revision

Public comments don’t just take positions — they name real places and cite real law and real science. Every such mention is extracted exactly as written and counted: the forests and inventoried roadless areas commenters know personally, where commenters tell us they live, the statutes and rules they invoke, and the studies they put in front of the agency. Every figure on this page counts distinct voices. Where thousands of people sent the same campaign letter, what that letter names counts once — so these are measures of how widely something is independently raised, not of how large a mailing list is.

5,508
Name a National Forest
2,914
Name a roadless area
967
Sign a full City, ST ZIP
1,612
Cite law or regulation
1,327
Cite research or reports

National Forests named

118 of the 122 National Forests appear by name — commenters writing about specific ground they know, not abstractions. Counts are distinct voices: where thousands sent the same campaign letter, the names in it count once, so a forest ranks by how many people independently wrote it rather than by how large one campaign was (109,054 submissions name a forest in total).

5,508 voices name a forest
Tongass National Forest
1,061
White Mountain National Forest
559
Pisgah National Forest
512
George Washington National Forest
260
Olympic National Forest
234
Los Padres National Forest
162
Superior National Forest
152
Tahoe National Forest
137
Allegheny National Forest
132
Ocala National Forest
130
The ten most-named National ForestsDistinct voices naming each

Roadless areas named

794 distinct inventoried roadless areas appear by name. Forest shown when the name is unambiguous; a name shared by several areas is counted once, as written. Names an area shares with a National Forest or mountain range ("White Mountain") are model-reviewed in context — a mention judged to be the forest or range is excluded here, every verdict kept with its rationale. Counts are distinct voices: a campaign letter’s names count once however many people signed it (15,734 submissions name an area in total).

2,914 voices name an area
White Mountain
346
Rocky Mountain — Chattahoochee National Forest
170
Green Mountain
158
Craggy Mountain — Pisgah National Forest
105
South Mills River — Pisgah National Forest
96
Wilson Creek
88
Smoky Mountains — Sawtooth National Forest
82
San Joaquin
73
Middle Fork
72
Rock Creek
70
The ten most-named roadless areasDistinct voices naming each

The law they invoke

Commenters cite the Roadless Rule’s own regulations, the executive orders driving the rescission, and the statutes and case law behind them — by name and section. Every written form of a citation (“36 CFR Part 294”, “36 C.F.R. § 294.12”) rolls up to the instrument it cites; the exact variants are kept underneath.

88 distinct authorities cited
36 CFR 294
843
28 U.S.C. 1291 — not in the agency’s record
365
66 FR 3244
173
7 CFR 1
61
Executive Order 14225
56
Executive Order 14153
55
The most-cited legal authoritiesComments citing each

The science they bring

Commenters put studies, reports, and data in front of the agency — some from its own DEIS record, cited back to it; some it has never considered.

284 distinct works cited
171Furniss et al. 1991 — Road Construction and Maintenance (1991) · in the agency’s record
78Andrews et al. 2015 — Reptiles (2015) · in the agency’s record

229 of the 284 cited works do not appear in the agency’s own DEIS record — new information the public has placed before it. The full accounting — which authorities, which works, cited how, by whom — is maintained comment by comment, each mention traceable to the exact text that produced it.

Follow the citations over: the bibliography publishes both lists in full — the works commenters cite and the agency’s own DEIS references — and the annotated DEIS walks the agency’s draft analysis issue by issue, with sample comments on each identified issue.

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 — Places & Citations,” https://roadless.org.

How it works. Place names, legal citations, and referenced works are extracted by deterministic exact matching against curated reference lists — no model in the loop — so every count is reproducible and auditable down to the literal matched text in each comment.