Opposes rescissionA0 noneSubstance 4/24Posted September 2, 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 eliminatedThe agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Already addressedThe 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 decisionThe agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Misreads the proposalThe agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
Not requiredThe agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference notedThe 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 shownThe agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scopeThe agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantiveThe agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
I urge the U.S. Forest Service to select the No Action Alternative and retain the 2001 Roadless Area Conservation Rule. As a North Dakota resident, I value the roadless areas within the Dakota Prairie Grasslands, including the Little Missouri National Grassland. I've lived in North Dakota my entire life and grew up camping and hiking on the land. Rescinding the Rule is unnecessary and costly:
- It is not required for oil and gas development. Modern horizontal directional drilling allows resources to be accessed from existing road networks and centralized well pads without new roads into roadless areas.
- It is not required for wildfire mitigation. The current Rule already permits fuels reduction and habitat restoration. Research also shows wildfire ignitions occur roughly four times more often near roads than in roadless forest.
- It adds cost, not value. The Forest Service already manages about 370,000 miles of road nationally, with $10.8 billion in deferred maintenance. New roads mean new long-term liabilities for taxpayers.
Less than 40,000 acres of the Dakota Prairie Grasslands remain managed as Suitable for Wilderness, down from roughly 500,000 acres eligible in the early 1970s. These lands support grazing, hunting, fishing, and recreation that generations of North Dakotans depend on. I ask the Forest Service to protect what remains and reject this proposal.