Nearly 1.2 million comments, letters and signatures on rescinding the Roadless Rule

Is this the final count?

Yes. Final as of Oct 8, 2026, 12:50 PM PT, when all six tests passed.

We call the count final when six things are true at once: a full day has passed since our check of the docket last found a new comment, a full pass over the docket finished inside the last hour (so a quiet day is one we actually watched), we have every comment regulations.gov counts on the proposed rule, none is waiting to be downloaded, none is waiting to be compared, and no attached file is waiting to be downloaded or has failed. All six held at Oct 8, 2026, 12:50 PM PT, and we declared the count final then, once: 390,064 posted at regulations.gov and 390,064 in our records. The declaration is saved; the page doesn’t work it out again each time it loads, and a late check doesn’t undo it. It comes off only if the record changes, meaning our count or regulations.gov’s count for the proposed rule moves. Then this section says Reopened, with the date and what moved, and the six tests run again.

The counts haven’t moved since the declaration. The tests still run each time the page loads, and right now they show: our last full pass over the docket finished 15.6 hours ago, and the test is one inside the last hour. That’s ours to chase and doesn’t change the record.

The docket as a whole, both comment periods and every document, stands at 613,926 comments at regulations.gov. That adds two different comment periods, so we take no share of it.

3 of the 390,064 posted comments have no text to read: 2 posted blank and 1 withdrawn at regulations.gov (comment 282826, comment 393788, comment 573775). We have all 3, and they’re left out of every share, because a share of what comments say can only be taken over comments that say something. We had 390,061 comments with their full text as of Oct 15, 2026, 10:35 AM PT; the figures are over 390,061 comments with text, each compared with the rest.

Adding it all up

The 1,197,510 at the top of this page is the 2026 column of the table in The count, and nothing from 2025 is in it. You may also see a total of about 1.6 million for this docket. Our own line adding both comment periods, before any overlap is removed, reads 1,735,038, and it’s labeled as that under the table. Neither it nor the 1.6 million is a count of people, and we take no share of either. Each sum adds three different things: comments posted at regulations.gov, letters a group uploaded as files on one comment, and signatures on petitions and sign-on letters uploaded the same way. The larger one also adds two comment periods held a year apart on two different documents, which nothing else on this page does. And the 1.6 million you may see for this docket has nothing to do with the 1.6 million comments on the 2001 rule, a figure from another rulemaking.

Posted comments and bundled signatures are different things. A posted comment is one entry the agency put on the docket under its own number. A bundled letter is one person’s letter that a group uploaded in a file with thousands of others. A signature is a name on a petition or a sign-on letter. One person can be all three, and can be in two groups’ files, and can have done it in both years. Each bundle is also one of the posted comment numbers. So the sum counts entries, and an entry isn’t a person.

What removing the overlap does, and what it can’t. Inside each comment period we measured three kinds of overlap: a name that repeats within a file or across bundles, matched on name and ZIP code or, where the file gives no ZIP code, on name and state; a one-of-a-kind letter in a bundle that was also posted on its own; and one file attached under two comment numbers. Taking all of it out of the 2026 column leaves 1,018,644; taking out only the name-and-ZIP matches among the names, the stronger test, leaves 1,065,971. Two people can share a name and a state, so the first figure can remove too much. And only 567,609 of the 807,446 entries in the 2026 files carry a name we can read, so for the rest no match was possible and the overlap we found is a minimum. Neither figure is a count of people. One overlap isn’t in either figure and can’t be: a person whose letter was posted under its own comment number and whose letter or name is also in a group’s bundle. The agency posts those comments without a name, so there’s nothing to match against the names in a file. What we could see is its outline. Of the 173,093 bundled letters in the 2026 files whose opening we could read, 44,592 open the way a posted comment does. We removed 614 of them, the ones whose opening appears once in the bundles and once among posted comments. The rest open like a form letter that thousands of people sent, and a shared opening doesn’t say the same person sent both. The largest file of names says as much itself: Earthjustice’s list, 98,985 names by our count, is of people who, in the comment’s words, “have submitted public comments.” So the 1,018,644 still counts any such person twice, and we can’t say how many there are. The overlap between the two comment periods hasn’t been measured at all: we haven’t checked whether someone who signed in 2025 signed again in 2026. So the two columns’ results aren’t added to each other here, and the 1,735,038 has nothing taken out of it.

Our count is higher than the filers’ own. Here’s why. On the 478 bundled comments in our 2026 count, we counted 807,446 letters and signatures. The 465 of them that state a count state 719,388. Most of the difference is one file. On comment 611258, Earthjustice’s list of names, the comment states 40,115, a number printed in the file, with no label, reads 99,082 and we counted 98,985 names, so our count on that one comment number is 58,870 above what its comment states. Another 32,042 of ours are on 13 comment numbers that state no count, 30,907 of them in Greater Yellowstone Coalition’s files. On the other 454 comment numbers that state a count and that we counted, ours comes to 676,419 against the filers’ 678,654.

What isn’t in these numbers. 14 of the 478 hold only scans, a layout our rules don’t read, or no file, and add nothing here. The 10 of them that state a count state 619 between them, 407 of that from Friends of the Inyo; each is on the 2026 bundle list under its filer’s count, and that figure is the filer’s, not ours. In 2025, regulations.gov serves 2 bundled files with zero bytes, so there’s nothing to open: Environmental Action (its comment states 25,537) and Environment America (its comment states 36,689). That’s 62,226 stated by the filers and not counted by us. 5 more 2025 comment numbers hold a scan or a layout our rules don’t read and add nothing. Both bundle lists are minimums, the 2025 one more so, because it comes from a search of the comment boxes alone. A file we couldn’t count is missing from the total, not counted as zero.

The agency has published one figure of this kind itself, for 2025. The proposed rule says that comment period drew “more than 220,000 comment letters on behalf of over 625,000 individuals and organizations” (91 FR 53827). We hold no such figure from the agency for the 2026 comment period. The 1.6 million on the 2001 rule were counted the same way, as comments received rather than posted; neither can be compared to a posted count.

Sources: the posted counts are regulations.gov’s, read Oct 15, 2026, 4:01 PM PT. The letters and signatures are our own count of the files on each bundled comment number, downloaded from regulations.gov between Oct 7, 2026, 9:55 AM PT and Oct 9, 2026, 11:08 AM PT and counted with fixed rules on Oct 9, 2026, 11:08 AM PT; a file those rules can’t read isn’t counted. The overlap was measured against the posted comments as we had them on Oct 9, 2026, 11:16 AM PT. Each sum is taken when this page is built, from those counts. No figure here is a filer’s, a coalition’s or anyone else’s tally.

Our own comment tools are in this record

More Than Just Parks, the public lands advocacy organization that publishes this report, ran two comment tools on this docket. We publish both: the Roadless Rule site, which we publish with the Sierra Club, and PLAN, the Public Lands Action Network. The Roadless Rule site has a comment builder. Every letter it writes opens with the line “Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001”, and a letter that raises issues also carries the sentence “I raise the following issues for the record and ask that the agency respond to each of them.” At least 1,786 comments in the 2026 record open with that line or carry that sentence (1,763 open with the line, 283 carry the sentence, 260 do both). PLAN’s page for this rule has a letter tool. Its letters carry no fixed line, so we can’t find them by their text; we count them from PLAN’s own records, which matched at least 37 of its letters to a posted comment. No comment is in both counts, so at least 1,823 of the 390,061 comments with text (0.47%) were written with one of our tools. Each count is a minimum: a writer who cut the line isn’t in the first, and a letter PLAN didn’t match isn’t in the second. Of the 1,823, 1,657 are one of a kind, 127 sit in groups of fewer than 20, and 39 make up one of the 177 campaigns, a 39-copy letter written with the builder, which isn’t one of the 18 groups’ campaigns traced by a page match. The download names that campaign as ours, linked to the builder, the way it names every other sponsor. The builder writes letters against the rescission. All of these are counted by the same rules as every other comment, and their stance is in the shares like everyone’s: that campaign is in the campaign shares as asking to keep the rule, and a comment outside a campaign is read on its own, the same way whoever wrote it. Both counts come from one scan of the record at Oct 8, 2026, 7:38 AM PT.

How we know, part by part

• The count. Every comment is compared with every other by its text. 3 posted comments have no text and are in no share, named above. The agency posts in batches after a deadline, and our check of the docket has found no new comment for a full day.
• What people asked for. 240,639 copies sit in campaigns whose example comment was read by machine, 31,568 in campaigns the desk read one by one (157 campaigns across both comment periods, read on Sep 28 and Oct 7, 2026). Each campaign in the download says which. Every comment outside a campaign was then read on its own; see Comments outside a campaign below.
• Who organized it. A campaign is traced when at least half of its example comment’s eight-word runs appear on the organization’s own page; each name links to that page, captured Oct 7, 2026 or, where the page has since changed, on the earlier date in the download. Sierra Club’s trace is also backed by the docket itself: its own comment 480496 carries the same letter after “Here is the comment that Sierra Club as an organization is sending to the agency”. A campaign written with our own builder is named from the builder’s line, not a page match, and is never counted among the traced.
• The bundle list, and why it may be incomplete. Three passes over the record as it stood on Oct 7, 2026. First, the comment box of every one of the 390,061 comments we hold from this period was searched for words saying the comment hands over other people’s comments, letters, names or signatures. The patterns touched 14,698 comment boxes; 13,875 of them quote a total from somewhere else (the agency’s count for 2025, the 2001 rulemaking, a poll, a vote in Congress) or are a brief’s companion uploads of exhibits, and were set aside by pattern; every other one was read. 357 of those read weren’t bundles: a commenter’s own letter, a brief with its exhibits, a joint letter signed by organizations, or a number quoted from somewhere else. Second, every comment number whose attached files run to 60 pages or more was read whatever its comment box says (329 of the 4,627 comment numbers with files held then). Third, the text of each of the 13,172 attached files that had text then was counted for sign-offs, address lines and email addresses, and every comment number whose files carry dozens was read. The second and third passes found 5 bundles whose comment box says only “See attached”; for those the filer’s name or count is quoted from its own cover letter in the file, and the row says so. On Oct 8, 2026 the desk went back to every comment number whose comment box names no sender, read the titles of its files and opened each file that has text. 3 rows are named from the file, because its letterhead, its cover letter or the head of its sheets names the sender, and each says so. On the other 30 comment numbers nothing in the files names one, or the files are scans we can’t read. A title is never taken as a name: where a file’s title carries a word or initials that could be a group’s, the row stays unnamed and prints the title as a title. 1 is left off because neither its words nor its files settle it (it says only "See cards." and carries 32 images of handwritten cards we could not read well enough to say whose they are). The three passes were last run over everything held on Oct 7, 2026, after the final batches posted. They aren’t rerun when the page declares Final; a later pass that changes the list is entered as a dated correction. A search only finds what it’s built to find, so this list isn’t complete and we don’t call it complete. Three kinds of bundle can still be missing: one under 60 pages made of scanned images, whose comment box says only “See attached”; one whose files aren’t fetched yet and whose comment box doesn’t say what it is; and any comment we don’t hold yet. If your group sent one that isn’t here, tell us the comment number and we’ll add it. 1 of the 478 comment numbers had no file downloaded when the figures were run, so the file and page columns are short. Page totals cover only the files that report a page count.
• Organizations and governments. Every attachment with readable text on the docket (5,941 files) was screened for a letterhead or a signature block; 816 signed organization letters were read by the desk on 2026-09-28 and the filer, its kind and the position the letter states were recorded. Each letter was read first at its opening and closing; the 140 that stated no position there were then read in full, and a position is recorded only where the letter states it in a sentence we can quote. A letter that never states one is marked as not stated rather than guessed. Individuals, agency exhibits and journal articles are left out. Reads are dated; the pass runs again after the close. The desk screened every attachment with readable text through September 28 (5,941 files across both comment periods) and read the 816 that carry an organization’s name or a signature block. On Oct 7, 2026 it went back for what was filed after that, the days when governments and trade groups tend to file: 2,547 comments with attached files were screened, 649 were read for who signs them, and 218 filers were added and 64 rows given a 2026 ask. On Oct 7, 2026 the desk reread all 179 rows that had a 2026 letter, the comment’s own text first: 9 turned out to be someone else’s document attached to an individual’s comment and came off, 1 was a duplicate, 2 had no 2026 letter of their own and went back to 2025 only, and the ask changed on 25. The 179 rows with only a 2025 letter haven’t all been reread: in a seeded draw of 40 of them, 4 were exhibits and came off and 2 had the wrong ask, so expect about one 2025 row in ten to be an exhibit until that pass is done. On Oct 7, 2026 a second outside read found three rows wrong, so the desk pulled all 167 rows with a 2026 letter of their own from the stored files once more, and the 2025 letters that read had named: 5 asks changed and 3 rows came off, each one person’s comment that the roster had read as a group’s. On Oct 7, 2026 a third outside read found one commissioner’s letter printed as a county board’s, so every row, 417 of them, was screened against its stored letter for the first person singular and each one raised was read: 1 row moved to the board’s own letter, 3 rows from 2025 were renamed for the one official who wrote them and 1 ask changed. On Oct 7, 2026 the desk read the filings of the last days: every 2026 comment with a file fetched after the first screen, and every comment posted from September 28 on with a file of any kind, 2,547 in all. 364 bundles and 73 uploads of exhibits were set aside, 649 passed a test for an organization’s name or words saying it speaks for a body and were read, and 354 were an organization’s or a government’s own filing. For each row written the sentence stating the ask is quoted from the stored letter and checked by script as a run of that text; 3 filers that already carried a 2026 ask were left as they were. One 2025 row came off as an exhibit (Virginia Department of Wildlife Resources: an unsigned comment that speaks of the agency in the third person). 71 more filings that last read raised aren’t on the roster, because the desk hasn’t settled who signs them or what they ask; a letter whose files are scans with no text is among the kinds it can miss. So the counts are still minimums. 6 filers whose first 2026 filing only asked for a longer comment period filed a position before the close, and their rows print it. For Green Climate we looked through the comment boxes and the openings of the attached files posted after its request and found no later filing. A row that reads “asked for more time” means we looked for a later filing and found none, not that the filer said nothing else. The rule, as applied: a letter one official writes as “I” is that official’s, even on a board’s letterhead, and a board is listed only on a letter its members sign or one that says the board acted. A group’s officer who writes “I” on the group’s behalf or in that office (“on behalf of the chapter and our members, I am writing”) is writing the group’s letter, and it stays the group’s. How a filer is matched across the two years: on Oct 7, 2026 every 2026 row that carried no 2025 letter, 325 of them, was checked against the 2025 rows by name and against the stored text of the 2025 record by the filer’s name forms, and the desk read each candidate. 101 had a 2025 filing after all: the State of Alaska, the State of Utah, the State of Oregon, the Washington governor and the attorneys general among them, each listed in 2025 under the office on its letterhead. An outside read of the rest then found one more, a signer of a joint letter we held, and it is counted here too. A 2025 letter we hold only as a scan (2,295 files) can’t be searched, so “no 2025 filing found” means not found in the text we hold. A filer is marked as filing in both where the desk holds a 2025 filing of its own, one that lists it as a signer or a named party, or one its counsel or its coalition filed for it (35 of the 231 are of the second and third kinds); the row says which and links the filing. The 2025 side of that match was read from the attached files with text and from every comment box of the 2025 record. A group that filed under another name or only in the comment box isn’t here; tell us and we’ll add it. The attachments were first screened on Sep 28, 2026, every 2026 row was reread on Oct 7, 2026, and the filings of the last days were read on Oct 7, 2026.
• Places and subjects. The word list for each subject is fixed and published with the method; every excerpt is copied from one comment in this comment period and checked against the stored text. The attached-files column reads “files on comments”: files whose text matches the list, and the comment numbers they hang on; it covers only files with text, 68% (13,511 of 19,904) of this window’s. This is a count of words, not a reading of arguments. A state is counted when its name appears as a word in the comment text; “Washington, D.C.”, the George Washington National Forest and the Sierra Nevada aren’t counted as states. A name is also left out where it reads as a street, a place in another state, a surname or a given name: a house number before it or Street after it, a comma and another state’s code after it, County after it, or Washington, Virginia or Georgia sitting in a signature. “Washington” meaning the capital can’t be told from the state by a rule and is still counted, so a state desk should read the comments before quoting that line.
• 2025 vs 2026. A comment posted before 2026 belongs to the scoping notice and one posted from August 20, 2026 on belongs to the proposed rule; nothing was posted in between. Two measures that aren’t ours and aren’t comparable to a posted count: the proposed rule says the 2025 window drew “more than 220,000 comment letters on behalf of over 625,000 individuals and organizations” (91 FR 53827), which counts signatures bundled inside letters, and the 1.6 million on the 2001 rule were counted as comments received, not posted.

The attachments

The briefs, the science, the county resolutions and the tribal letters arrive as attachments, and so do the bundled submissions: 181,932 of this window’s 337,640 pages (54%) sit in the 7,138 files held from the 478 comment numbers we have found that carry other people’s comments or signatures. Both page counts are from one read, Oct 15, 2026, 10:35 AM PT, when the files of 1 of those comment numbers hadn’t been fetched. Of the 19,904 files attached to comments in this window, 13,511 yielded text (798 of them only after optical character recognition), 2,510 are scans or photographs we haven’t recovered text from, and 3,881 are formats the platform doesn’t read, mostly images; 2 were fetched and came back with an error where the text should be. No attached file has failed to fetch. The page count is over the files that report one. The 2025 comment period carried 9,352 files and 144,075 pages.

Sources: every attachment’s file, page count and text status are on the platform, tied to the comment it came with. The campaign, subject and state figures are over comment text; the letterhead roster is read from the attached files with text, and its match of each 2026 filer against 2025 also reads every comment box of the 2025 record.

Method and limits

1. The record. Every comment and attachment on regulations.gov docket FS-2025-0001, pulled through the public API by a scheduled check and stored with its text. The check is scheduled every twenty minutes and didn’t run that often. From Aug 20 through Oct 6, 2026 it completed 279 full passes over the docket, none of them between Aug 21 and Sep 1 (12 days), and from Sep 2 on between 3 and 12 a day. A pass picks up every posting it hasn’t seen, whenever it went up, so a gap delays a comment reaching us and doesn’t lose it. In the 24 hours before this page last checked, it completed 1 full pass, the last at Oct 15, 2026, 4:32 AM PT. The agency keeps posting after a deadline, so each count carries the time it was taken.
2. Two comment periods, kept apart. A comment posted before January 1, 2026 belongs to the 2025 scoping notice (90 FR 42179); one posted on or after August 20, 2026 belongs to the proposed rule (91 FR 53827, extended by 91 FR 57841). Nothing was posted between September 21, 2025 and August 20, 2026. The comment rows don’t say which document they were filed on, so the posting date is the rule, and the 2025 count it yields (223,862) equals regulations.gov’s own count for the notice (223,862).
3. Campaigns. Exact duplicates are grouped by a hash of the normalized text. Near duplicates are found with 64-permutation MinHash over five-word shingles and verified at an estimated Jaccard similarity of 0.8 or higher. A group with 20 or more copies inside one comment period is a campaign in that period; a letter sent in both is counted in each by the copies posted there. The cutoff of 20 is a judgment call, and the download carries every campaign so a reader can cut it elsewhere. A group whose shared text is a cover note (“See attached file(s)”, or a sentence handing over files) isn’t a campaign: its comments are counted in their own box, 1,535 in 2026 and 638 in 2025, and in no form-letter figure. Which groups those are is a desk read of each group’s example comment. The rule is about text, not about who organized it: 11 of the 177 campaigns in this window are one short line that many people typed on their own (“I support the Roadless Rule.” 682 times, “Keep the roadless rule!” 74 times, “Do not rescind the roadless rule.” 52 times and “Please do not rescind the Roadless Rule” 32 times), 1,024 comments between them, 0.4% of the campaign copies (1,024 of 272,207). Nobody had to send those round for them to match.
4. Comments, not people. Since October 9, 2026 this page leads with the full 2026 count: the comments posted one by one plus the letters and signatures we counted inside bundles. Every other count, and every share, is of comments as regulations.gov posts them. A comment number that carries many people’s comments or signatures as attached files is one comment here, in the total, in the breakdown and in every share. The 478 bundles we have found are a minimum, from three passes described above: the words of every comment box we hold, every comment number with 60 pages or more of files, and the text of every attached file. The bundle table gives the filer’s own count, quoted from the comment’s text field or, where the box says only “See attached”, from the filer’s cover letter; none of those counts is ours. Our own count of the letters and signatures in the files is in Adding it all up, by comment period, with the overlap we measured. Neither the filers’ counts nor ours enter any share, and the letters inside the files haven’t been grouped into campaigns or classified.
5. One of a kind. A comment whose text has no near duplicate anywhere on the docket, in either comment period. Many are a form letter with enough of the writer’s own words added to fall below 0.8. A comment we hold but haven’t compared yet is counted as that, never as one of a kind.
6. Repeat postings. An exact text that carries an email address is one person’s signed letter. Where such a text is 90% or more of a campaign’s copies, the campaign is one letter posted repeatedly, and the page says how many there are: 51 of the 177 campaigns are nothing but one signed letter repeated (1,945 postings), and 126 are form letters many people sent. The email test misses signed letters without an address, so the count is a minimum.
7. Campaign stance. A campaign’s stance is that of its example comment, read by machine where the example has a classification and by the desk where it doesn’t (157 campaigns across both comment periods, read on Sep 28 and Oct 7, 2026; every campaign of 1,000 copies or more read in full). A campaign nobody has read is listed as not read and left out of every share. The keep share is always keep over keep plus rescind, with both printed.
8. Comments outside a campaign. The 104,719 one-of-a-kind comments and the 11,600 in groups of fewer than 20 copies were each read for a side by a language model, Claude Haiku 4.5, on October 12, 2026, with the same four sides the campaign reads use: keep the rule, rescind it, mixed, or no side stated. Each was sent as its first 2,000 characters and, when longer, its last 600, forty to a request; a request whose answer missed a comment, named one twice or gave a side outside the four was thrown away and sent again. A second read, by a larger model (Claude Opus) reading each comment in full and blind to the first answer, went over a random 220 drawn across the four sides and agreed with 177; on the comments the model read as keep or rescind they agreed with 137 of 140, and where they differed they mostly read keep where the model said mixed or no side, so the keep figure leans low, not high. A model can get a single comment wrong, so rely on the totals, not on any one comment.
9. Subjects and states. Counted by fixed word lists over the text typed into the comment box, the same lists for both comment periods; attached files are counted separately and only in the table in Places and subjects. A state’s name is dropped where it reads as a street, a town in another state, a county or a person’s name. The subjects: Wildfire; Drinking water and watersheds; Wildlife and habitat; Threatened and endangered species; Recreation; Hunting and fishing; Climate and carbon; Old growth and mature forest; Logging and timber; Mining, oil and gas; The Tongass; Tribes and treaty rights; Tribal consultation; Subsistence; Jobs and local economies; Cost to taxpayers; The road maintenance backlog; The draft EIS and NEPA; The no-action alternative by name; The comment period and hearings; Arbitrary and capricious, or the APA by name; Forest plans and NFMA; The cost-benefit and economic analysis; The Colorado and Idaho state rules; Invasive species; Forest health and active management; Local control; Multiple use; Motorized access; Evacuation and emergency access. The exact patterns are in the desk’s method file and go to any reporter who asks.
10. Organizations. A dated desk read of the attached files with text, described above, with every 2026 filer then matched against the 2025 record, its attached files with text and all 223,862 of its comment boxes; a filer counts as filing in 2025 on its own filing, as a signer or named party of a joint one, or through its counsel or its coalition, and the row says which. It finds groups that name themselves on a letter; an individual’s comment with another body’s document attached is an exhibit and not a filer. The screen was first run on Sep 28, 2026, every 2026 row was reread on Oct 7, 2026, the filings of the last days were read on Oct 7, 2026, a filer is in 2026 only with a comment of its own posted in 2026, and the list is a minimum for the 2026 comment period.
11. Attachments. Text is extracted directly where the file carries it and by optical character recognition where it’s a scan; 68% (13,511 of 19,904) of this window’s files have text.
12. When it’s final. No new comment found in 24 hours, a full pass over the docket finished inside the last hour, every comment regulations.gov counts on the proposed rule in our records, none waiting to be downloaded, none uncompared, and no attached file waiting or failed. A comment regulations.gov serves blank or marks withdrawn is kept and named, not waited for; shares of what comments say are taken over the comments with text. Final is declared once, at the first read where all six hold, and stored with its date and time; the sixth test, the recent full pass, applies only to that first declaration. Final comes off only when the count we hold or regulations.gov’s count for the proposed rule moves; the page then reads Reopened, says what moved and when, and runs the six tests again. The declaration doesn’t rerun the bundle passes: the bundle list was read Oct 7, 2026 and the bundled files were counted Oct 9, 2026, 11:08 AM PT, and a later pass that changes a figure is entered below as a dated correction.
13. Who publishes this. More Than Just Parks, a public lands advocacy organization. We publish the Roadless Rule site, with the Sierra Club, and PLAN, and both ran a comment tool on this docket. The disclosure above counts the comments written with them, at least 1,823 of the 390,061, and says how each was found. They’re counted by the same rules as every other comment.
14. What these numbers don’t show. They don’t give a stance share for the whole record, an identity for any individual commenter, or proof that comments written with our own tools changed anything. Posted comments aren’t the same as comments received. Neither period’s count can be compared with the agency’s 625,000 for 2025 or the 1.6 million on the 2001 rule, which count people and bundled signatures. The campaign table covers comments posted one by one, not everything a group sent. The bundle sums add what filers wrote; they don’t count people. And 1,197,510, 1,735,038, or any sum across the two comment periods, doesn’t count people, or comments alone: it adds posted comments, bundled letters and signatures, with nothing removed.
15. One snapshot behind every share. Every percentage on this page divides two numbers taken from the same snapshot of the record, stamped Oct 15, 2026, 10:35 AM PT: the comment counts, the campaigns, the subjects, the states, the attachments and the bundles’ files and pages. The roster shares are over the dated roster file. Three things are read when the page loads and stamped on their own, and none is the top or bottom of a share: the regulations.gov counts, what’s waiting to be downloaded or failed to download, and the check log.
16. Reproducibility. The breakdown by comment period is recalculated after each comparison run, last at Oct 15, 2026, 10:35 AM PT, and the page refreshes it every thirty minutes. The one-by-one reads are dated files, named above. The daily series is open to anyone; the campaign, state and bundle tables are behind a free sign-up, and the subject word lists go to any reporter who asks.

Corrections

October 7, 2026. Through October 6 this page added the docket’s two comment periods together in its headline and campaign figures, and it gave the keep share over every campaign copy while counting campaigns nobody had read as unclear. Both are fixed: every figure now names its comment period, unread campaigns are left out of the share and counted as unread, and every campaign of 1,000 copies or more has been read.

October 7, 2026, later the same day. A second read of this page found six things, all fixed. It never said that some comment numbers carry thousands of people’s comments or signatures as attached files; they’re now named, with each filer’s own count, and still counted as one comment each. The letterhead roster listed nine organizations that didn’t file (their documents were attached to someone else’s comment), and for filers in both comment periods it printed the 2025 letter’s ask under a 2026 heading; every 2026 row has been reread and now prints the 2026 filing’s ask. One 660-copy form letter was read as naming neither the rule nor the proposal when it asks for Alternative 1 by name; it’s counted as keep. The state lines changed method on October 7, from the classifier’s labels on the first 8,657 comments to a count over every comment’s text, which moved Montana from first to fifth, and that wasn’t logged here; the count now also leaves out street addresses, towns and people’s names that carry a state’s name. The method said the walk of the docket ran every twenty minutes through the comment period; it didn’t, and the method now prints what the run ledger shows. And the form-letter and one-of-a-kind shares were described as over comments “held and compared” when the denominator included comments not yet compared; the words now say so. Anyone who quoted a state line or a roster row from this page before this note should check it again.

October 7, 2026, a third time. A second outside read found four more things, and fixing them found a fifth. Three rows of the letterhead roster were wrong about a named filer: the Sigurd Olson Environmental Institute was listed as stating no position when its letter opposes both action alternatives; Baker County, Oregon’s 2025 letter was listed as mixed when it supports rescission, as its 2026 letter does, so the county didn’t change its position; and one man’s comment was listed as the Shoshone Conservation District’s. Rereading every 2026 row again also moved Mountain Capital Partners from not stated to rescind and the Wyoming Mule Deer Alliance from keep to not stated, and took off one more comment that was a person’s and not a group’s. The bundle list said it came from a search and held 31 comment numbers; a search of every comment box then found 454, Earthjustice’s among them, and most of the largest arrived in the last batches the agency posted. Comments that say only “See attached file(s)” had been grouped as form-letter campaigns, which put tribes’ and counties’ own letters in the form-letter share; they’re now counted in a box of their own, and the form-letter share is lower by that much. And a heading said the one-of-a-kind comments fell, when only their share is known to have; the count waits for the comments not yet compared. Anyone who quoted the bundle figures, the form-letter share or one of the roster rows named here should check them again.

October 7, 2026, a fourth time. A third outside read found three more things. The list of bundled submissions was called complete by its search, and it wasn’t. The search wanted a number directly before “comments” or “signatures”, so it missed Defenders of Wildlife’s 15,212 comments among others, and no search of words could find a set of 16,731 from the National Wildlife Federation Action Fund whose comment box says only “See Attached Files”. The list is now made three ways, by the words, by the size of the files and by what the files hold; it has 478 comment numbers where it had 454, it’s a floor, and the page no longer calls it complete. One commissioner’s own letter was printed as the Josephine County Board of Commissioners’ with a rescind ask. The board sent its own letter, approved at a public meeting on September 15, which supports the proposed rule’s objective on conditions; the row now quotes that letter and reads mixed. Three 2025 rows that named a county or its board for a letter one supervisor or commissioner wrote (Ventura County, Santa Barbara County and Ouray County) now name the official, and The Next Summit’s 2025 letter is read as keep, not mixed. And the attachments band gave the bundles’ share of the attachment pages as 49% by dividing a page count read at that moment by a total read ninety minutes earlier, while files were still arriving; read together it was 39%. Both numbers now come from one read, as every share on this page does, and the finality test now also waits for the attached files. Anyone who quoted the bundle count, the Josephine County row or that share should check them again.

October 7, 2026, a fifth time. A fourth outside read found three more things, and fixing them found a fourth, the largest. The letterhead roster printed seven filers as having only asked for more time. Six of them filed a position before the close, two tribes among them: the Organized Village of Kasaan and Ketchikan Indian Community are named parties to the comments of the Organized Village of Kake and others asking for the No Action Alternative, Friends of the Clearwater, Sky Island Alliance and the West Virginia Rivers Coalition each filed against rescission, and the seven attorneys general filed again as seventeen, asking the agency to withdraw the proposed rule. The same gap left the State of Utah, the National Association of Counties and the Wyoming County Commissioners Association, all asking for rescission, off the roster. The filings of the last days have now been read (218 filers added, 64 rows updated), and the roster counts on this page before this note were short by that much. The bundle list missed a second set from the National Wildlife Federation Action Fund (4,384 comments), because its files arrived after the list was made. Rerunning the three passes found that and more: a filter meant to set aside the agency’s own totals had treated any six-figure count as one, and it hid a single comment number carrying 165,473 public comments from the Natural Resources Defense Council. The list has 478 comment numbers where it had 471, and the filers’ own counts now add to 360,521 comments and 358,867 signatures where they had added to 190,600 and 356,912. The attachments band said 2 attached files had failed to fetch when 853 had: a fetch that died was in no count, and the finality test could pass without those files. Failed fetches are now counted, printed with the attachments and in the finality band, and held against the word Final; a bundle row no longer says “not fetched yet” where a fetch failed or no file is listed. Smaller things: the method now says that some “campaigns” are one short line many people typed, the sponsor table names the National Wildlife Federation Action Fund where it had named the federation, and a 2025 row for the Virginia Department of Wildlife Resources came off as an exhibit. Anyone who quoted the roster counts, a row for one of the filers named here, or the bundle sums should check them again.

October 7, 2026, a sixth time. A fifth outside read found that the roster called filers new who weren’t. The pass that added the last week’s filings marked 325 of the 455 as having no 2025 letter without matching them against 2025, so the State of Alaska, the State of Utah, the State of Oregon, the Washington governor and the attorneys general each read “Filed in both: No” while their 2025 filings sat on the same roster under the office on the letterhead. Every one of the 325 has now been matched against the 2025 rows and against the stored text of the 2025 record, and the desk read each candidate: 101 had filed in 2025, 67 on a filing of their own and 34 as a signer of a joint letter or through counsel or a coalition, and 19 doubled rows were folded into one. The heading read “325 of them new since 2025” and now says for how many we found no 2025 filing; the tiles read 16 new state filers, 44 local, 25 tribal and 37 industry, and “237 keep and 69 rescind” among new filers; the count of filers read in both years was 121 with 13 reading differently. All of those are recounted above. The 2025 letter of the State of Utah had been recorded as mixed; it says “the State supports the full rescission of the Roadless Area Conservation Rule” and is now recorded as asking to rescind. The Oregon and Washington governors’ 2025 letters were reread and stay mixed: Oregon asked for a targeted amendment and Washington asked the agency to keep the rule or explain how its values would be protected. One filer the roster carried twice in 2026 is now one row, so the count of 2026 filers is 454, not 455. The State of Nevada was printed as stating no position, with a quote that stopped one sentence short; read whole, its letter calls the rule a barrier and backs returning roadless decisions to forest plans, and the row now says rescind and quotes that sentence. Its 2025 letter, from the Department of Wildlife alone, argued against repeal. Friends of the Clearwater and Wilderness Watch were quoted with a sentence about their 2025 letters; that quote came off, and the rows now quote the sentence that carries their 2026 ask (the next note says why they didn’t at first). The page said “3 posted comments not yet in these figures” and that the count might still rise because of them. They’re two comments posted blank and one withdrawn, all three held; the page now names them, counts them as held, and says a count may rise only while a walk has listed something new inside a day. Smaller things: “1 attached files are”, a 0.4% printed without its two numbers, and the bundle method’s count of files with text, which is the count on the day of that pass.

October 7, 2026, a seventh time. A sixth outside read checked every filer printed with no 2025 filing, 224 of them, against the 2025 record and found one that had filed. The 2025 joint letter of six Wyoming groups is signed for the National Outdoor Leadership School by the director of NOLS Teton Valley, on a line the match had passed over. So 231 of the 454 filers in 2026 also filed in 2025, not 230; for 223 we found no 2025 filing, not 224; and among those it is 164 asking to keep the rule, not 165. The 2025 side gains the same filer: 410 filers in 2025, not 409, and 247 asking to keep among the 387 whose 2025 filing was read, not 246 among 386. The note before this one said the sentence carrying the 2026 ask of Friends of the Clearwater and Wilderness Watch was damaged in our stored copy. It wasn’t: a curly apostrophe and a line break had failed a strict match, and both rows now quote it. Three sentences of method still described the roster as a read of each filer’s own letter in the attached files; the match across the two years also reads the comment boxes and counts joint letters, counsel and coalitions, and the method now says so. The stamp at the top and the cite line printed the time the page was built; they now print the time the record was read. The open daily file’s 2026 rows add to 390,061 and didn’t say why that’s 3 short of the posted count; its header now names the comments with no text. And the word Final now takes a sixth test, that our walk completed a sweep of the docket inside the last hour, so a quiet day can’t be a day nobody looked.

October 8, 2026. A seventh outside read found one row of the bundle table wrong about who sent it and how much it holds. Comment 611258 was printed as naming no organization, with 40,115 signatures. Its comment box does name no one, but its one attached file is titled with Earthjustice’s name at regulations.gov and opens on its letterhead, and a line in the file says 99,082; our own count of the names in it is 98,985. The row now names Earthjustice from the file and prints all three figures, each labeled. The senders whose comment names none became 26, not 27; the named groups stayed at 39, because Earthjustice was already one of them. No sum moved: the filers’ stated totals still use the comment’s 40,115, and Adding it all up already carried our count of the file. That band now says two things it hadn’t: that our count of the bundled files is above the filers’ own and why, and that the overlap between comments posted one by one and names or letters inside bundles isn’t measured and can’t be. The same day the rule for Final changed. It was worked out again at every load, and one of its six tests, a sweep of the docket inside the last hour, failed most hours of an ordinary day, so the page would have read Final and Not final by turns with no number moving. Final is now declared once, with its date and time, and comes off only if a count moves. Two sentences had promised that the bundle passes would run once more before the page read Final; nothing does that on its own, and they now say when the passes last ran. Anyone who quoted the 40,115 for an unnamed sender, or 27 unnamed senders, should check the row again.

October 8, 2026, a second time. The fix above was to one row. The desk then went back to every bundle row printed as naming no organization, 26 of them, read the titles of their files and opened each file that has text, looking for a sender’s name. Two more rows had one. Comment 589094 was printed as a petition of REI Co-op members that names no sender, with 16,190 signatures. Its comment box does name no sender, but its file opens with a cover letter signed by an officer of REI Co-op, so the row now names REI Co-op from the file. The comment and the cover letter both say 16,190; our own count of the names in the file is 16,192. Comment 601559, 43 comments gathered in Georgia, is written on sign-up sheets headed Environment Georgia, and the row now names it from the file. The named groups are 41, not 39, and the senders whose comment names none are 24, not 26. No sum moved: both rows’ counts were already in the filers’ stated totals. Five other comment numbers have a file whose title carries a word or initials that could be a group’s: Cascadia Wildlands on 602029, OW on 505645, a4a on 603831, SEACC on 604325 and LPFW on 611481. Nothing inside those files names a sender, so the rows stay unnamed, and each row’s note, in the table above or in the download, gives the title as a title. We don’t name a group from a file’s title. Anyone who quoted 16,190 signatures from an unnamed sender, 39 named groups or 26 unnamed senders should check the rows again.

October 8, 2026, a third time. An eighth outside read found that this page names who ran the campaigns on this docket and never said its publisher ran comment tools on it. More Than Just Parks publishes the Roadless Rule site with the Sierra Club, and it has a comment builder, and PLAN, which has a letter tool on its page for this rule. The disclosure now says so, with the count of comments written with each (at least 1,786 and 37, read Oct 8, 2026, 7:38 AM PT), and the 39-copy campaign written with the builder, printed until now as traced to nobody, is named as ours in the download. No count, share or stance moved. The same read found five smaller things, all fixed. The bundle table called the 99,082 in Earthjustice’s file “the file’s own figure” when the file gives the number no label; the row now says that. One set of town hall statements from Houghton, Michigan, was counted among the senders whose comment names no organization, when its comment box says a forest ecologist for the Sierra Club Michigan Chapter submitted it on the speakers’ behalf; it’s now out of that count and described in the comment’s own words. The two other event bundles that stood on the same row name no one and stay, so the senders that name none are still 24, and the smaller bundles among them state 1,927 between them, not 1,942. On a phone, the three labeled figures on the Earthjustice and REI Co-op rows ran together as one line; each is on its own line now. The chart caption said “the 2000 rule” for the rulemaking the rest of the page calls the 2001 rule. And the method said how many sweeps the walk completed “in the 24 hours before these figures” when the 24 hours end at the page’s last read of the walk’s ledger, which can be later than the figures’ stamp.

October 10, 2026. On October 9 the line under the headline said that after removing every duplicate we could measure, the count was “still more than a million: at least 1,018,644.” That figure isn’t a floor, and it isn’t known to be over a million. It still counts twice anyone who posted a comment and is also on a group’s list, which can’t be measured, and Earthjustice’s comment says the 98,985 names on its list are of people who have already commented. The line now says so, and so does Adding it all up. No figure moved. The headline now rounds the 2026 sum the way a person would say it, with the exact sum on the line under it.

If a figure on this page is wrong, write ask@morethanjustparks.com and we’ll fix it and log it here.