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For 25 years, the Roadless Area Conservation Rule has protected some of America’s most wild places that provide clean water, habitat and outstanding outdoor experiences that support the recreation economy. Now, those protections are at risk. On August 18, U.S. Secretary of Agriculture Brooke Rollins announced that the U.S. Forest Service has proposed fully rescinding the 2001 Roadless Area Conservation Rule. The proposal was published August 20, opening a public comment period that ends September 21. The proposal could remove protections from more than 44 million acres of national forest roadless areas across 37 states. North Dakota’s roadless lands matter The Roadless Rule is critical to protect the remaining wilderness here in North Dakota. In the early 1970s, five hundred thousand acres on the Dakota Prairie Grasslands’ western-most Little Missouri National Grassland unit qualified for Wilderness designation. By 1977, when the second Roadless Area Review and Evaluation was complete, the number of acres eligible had been cut in half. With the signing in July 2002 of the current Land and Resource Management Plan for the Dakota Prairie Grasslands, less than 40,000 acres are managed by the Forest Service as “Suitable for Wilderness.” Undeveloped wild land is disappearing – fast. The Dakota Prairie Grasslands contain some of the most important remaining blocks of undeveloped public habitat in the state, including roadless areas within the Little Missouri National Grassland. Do we want the remaining acres eliminated because we did nothing? These landscapes are critical for the outdoor activities North Dakotans hold near and dear. These are the same areas multi-users for generations of North Dakotans have grazed cattle, hunted, fished, hiked, camped and experienced the Badlands. Additional roads are not needed. This is your time to comment now to protect ND's remaining wild places! Roadless does not mean unmanaged The Roadless Rule does not prevent responsible management. It allows activities including grazing, fuels reduction, habitat restoration, and things we love like hunting, fishing, hiking, camping and other outdoor recreation. We don’t have to choose between protecting the Badlands landscape or having successful oil/gas development. Modern horizontal directional drilling also means that oil and gas resources can often be developed from existing road networks and centralized well pads, reducing the need to build new roads into currently roadless landscapes. We doubt that eliminating the rule is necessary to address wildfire risk. The existing rule provides flexibility for fuels mitigation and other management activities without requiring permanent new roads. Recent research also found that wildfire ignitions were roughly four times more likely near roads than in roadless forests. The Forest Service already manages roughly 370,000 miles of roads (2,800-plus miles of roads in the Little Missouri Grasslands) and faces an estimated $10.8 billion in deferred maintenance. Adding more roads means adding more long-term costs to tax payers. The Badlands Conservation Alliance supports best practices for science-based grassland and forest management, that includes efforts to improve wildlife habitat, address wildfire risk and provide responsible multi-user access. But eliminating the Roadless Rule is not the answer, and can in fact eliminate the remaining wild places that make the Badlands special. Sincerely, Shannon Straight, Executive Director Badlands Conservation Alliance 1605 E. Capitol Ave Bismarck, ND 58501

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests of Minnesota are worth more than any road that could be cut through them. That is not sentiment. It is a fact the agency's own numbers support, and I am filing this comment to make the agency defend its proposal against those numbers. Minnesota holds 16 inventoried roadless areas totaling 62,081 acres. I go to the forests of this state to enjoy the nature there. I take my dogs out into those places, and photographing them in that setting is one of my favorite things. One of theirs too. The diverse wildlife I encounter in those forests has a value beyond money, and yet, as I will show, it also brings in more than it costs. That makes the proposed rescission hard to justify on any ground, economic or otherwise. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those figures describe the ceiling of what rescission could gain. Against them, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of somewhere between $5.2 and $11.4 million a year, while projecting recreation losses of at least $6.1 million a year, with a net present value ranging from negative $92 million to positive $199 million. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with these figures and explain, with specificity, how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies that expansion. The proposal also claims that the current rule creates permitting and administrative burdens that rescission would relieve. The rule itself contradicts this. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for public health and safety, for existing mineral leases, and for community wildfire protection are already built into the structure being dismantled. I ask that the agency identify on the record which specific burdens are not already addressed by these existing exceptions, and quantify them. The proposal's regulatory flexibility analysis certifies no significant impact on small businesses. That certification sits beside a Cost Benefit Analysis that names outfitters, guides, and tour operators as affected parties and books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its no-impact conclusion by spreading that loss across every small firm in the sector nationally rather than looking at the outfitters and guides who actually hold permits in the affected areas. Minnesota's 62,081 roadless acres sit within watersheds that also include 286 municipal water intakes across the Eastern region, according to the DEIS. The communities and businesses drawing from those watersheds, and the guides and outfitters working in or near these areas, are not a national average. The agency must withdraw the small-business certification and assess the impact on the specific entities operating in and around the potentially affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my time outdoors, my choices about where to take my dogs, and my expectations for those forests around the protections this rule has provided. An agency changing course is required to account for the reliance its prior policy created. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including mine, before any final action is taken. Sincerely, Stacey Anthony Fargo, ND 58103