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.

19,214
Name a National Forest
6,415
Name a roadless area
13,868
Sign a full City, ST ZIP
765
Cite law or regulation
8,051
Cite research or reports

National Forests named

113 of the 122 National Forests appear by name — commenters writing about specific ground they know, not abstractions.

19,214 comments name a forest
Tongass National Forest
16,023
White Mountain National Forest
926
Pisgah National Forest
291
Superior National Forest
285
Coronado National Forest
178
George Washington National Forest
111
Shawnee National Forest
105
Cherokee National Forest
98
Deschutes National Forest
86
Tahoe National Forest
79
The ten most-named National ForestsComments naming each

Roadless areas named

520 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.

6,415 comments name an area
Middle Fork
3,702
South Fork
3,693
Cheat Mountain — Monongahela National Forest
1,247
Seneca Creek — Monongahela National Forest
1,246
San Jose — Cibola National Forest
114
White Mountain
96
Rocky Mountain — Chattahoochee National Forest
85
South Mills River — Pisgah National Forest
72
Santa Cruz — Los Padres National Forest
63
Bear Swamp — Huron-Manistee National Forest
54
The ten most-named roadless areasComments 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.

63 distinct authorities cited
66 FR 3244
350
36 CFR 294
247
28 U.S.C. 1291 — not in the agency’s record
47
90 FR 42179
27
Executive Order 14225
20
463 U.S. 29
19
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.

162 distinct works cited
554Furniss et al. 1991 — Road Construction and Maintenance (1991) · in the agency’s record

126 of the 162 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.