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.

6,598
Name a National Forest
1,707
Name a roadless area
4,688
Sign a full City, ST ZIP
644
Cite law or regulation
7,833
Cite research or reports

National Forests named

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

6,598 comments name a forest
Tongass National Forest
3,976
White Mountain National Forest
863
Superior National Forest
250
Pisgah National Forest
234
George Washington National Forest
96
Coronado National Forest
86
Cherokee National Forest
83
Olympic National Forest
62
Los Padres National Forest
59
Huron-Manistee National Forest
59
The ten most-named National ForestsComments naming each

Roadless areas named

465 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.

1,707 comments name an area
Cheat Mountain — Monongahela National Forest
586
Seneca Creek — Monongahela National Forest
585
White Mountain
89
Rocky Mountain — Chattahoochee National Forest
71
South Mills River — Pisgah National Forest
67
Bear Swamp — Huron-Manistee National Forest
52
Laurel Mountain — Pisgah National Forest
49
Wilson Creek
36
San Jose — Cibola National Forest
34
Craggy Mountain — Pisgah National Forest
28
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.

57 distinct authorities cited
66 FR 3244
323
36 CFR 294
197
90 FR 42179
25
28 U.S.C. 1291 — not in the agency’s record
24
Executive Order 14225
20
Executive Order 14153
18
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.

137 distinct works cited
535Furniss et al. 1991 — Road Construction and Maintenance (1991) · in the agency’s record

107 of the 137 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.