Comment Analysis · Docket FS-2025-0001

FS-2025-0001-290790

Opposes rescissionA0 noneSubstance 5/24Posted August 31, 2026 On Regulations.gov

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A0 none: Counted, not answered.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Environmental Protection Biodiversity
    • “fragment habitat for the many creatures”
    • “depend on large tracts of land for their survival”
    • “Keep the remaining acres free of roads and development”
  • Forest Management Wildfire
    • “reasoning given by the US Department of Agriculture for the need to provide road access for wildfire control is flawed”
    • “95% of wildfires are caused by people and that two thirds of human caused fires are along roads”
    • “thin forests for fire control, they could do this without roads”
  • Recreation Tourism Public Use
    • “dust and noise generated by traffic degrades the trail experience”
    • “noxious fumes often have an objectionable odor”
    • “experience at least a part of the country that I have experienced”
  • Resource Development Extraction
    • “reasoning given by the USDA for the need to provide road access for mineral extraction is flawed”
    • “Oil extraction can now be done from four miles away from the well site”
    • “Oil wells can be located further away from roadless areas”

What it names

National Forests
Dakota Prairie Grasslands

The comment

Keep the 2001 Roadless Rule as is. This rule provides long term protection of 58.5 million acres of which 280,000 acres are found in the USDA Forest Service Dakota Prairie Grasslands in North Dakota. We don’t need more roads in the North Dakota badlands or in any of the other 58.5 million acres protected by the 2001 Roadless Rule in the United States of America. The reasoning given by the US Department of Agriculture for the need to provide road access for wildfire control is flawed and doesn’t consider USDA Forest Service staff research indicating 95% of wildfires are caused by people and that two thirds of human caused fires are along roads. Also, the Department of Agriculture does not consider technology to perform the same tasks without roads. It is not uncommon on private land where road access is not an issue for helicopters and planes to be called on to put out wildfires. If the US Forest Service really wants to thin forests for fire control, they could do this without roads and move timber with helicopters. The reasoning given by the USDA for the need to provide road access for mineral extraction is flawed and does not recognize current and future technology. Oil extraction can now be done from four miles away from the well site and with technology improvements it will be done at greater distances in the future. Oil wells can be located further away from roadless areas and recreation areas and need not be located in current roadless areas. More roads will further fragment habitat for the many creatures that depend on large tracts of land for their survival. Currently the furthest distance from a road in the contiguous United States is 21 miles, and that is in Yellowstone National Park. Do we really need more roads? The Maah Daah Hey Trail, a USDA Forest Service managed trail, travels through both roadless and roaded areas. Where the trail intersects roads, dust and noise generated by traffic degrades the trail experience and where the trail is downwind from an oil well, noxious fumes often have an objectionable odor. Roads can also increase erosion, land degradation and waste on our public lands. When I am too old to hike trails in roadless areas I know there are millions more acres of roaded acres where I can drive. I want to know that there will be roadless areas undiminished. Keep the remaining acres free of roads and development. I want my nieces, nephews, their children, and their children’s children to experience at least a part of the country that I have experienced in my lifetime. Please keep the 2001 Roadless Rule as is. Thank you.

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