Comment Analysis · Docket FS-2025-0001

FS-2025-0001-355988

Opposes rescissionA0 noneSubstance 6/24Posted September 12, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 3 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.

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

Cultural Heritage Indigenous
- “The Black Hills are sacred to many Native tribes”
- “traditional religious ceremonies”
- “ancient (and fragile) rock art”
Water Quality Quantity
- “clean drinking water”
- “Madison and Minnelusa aquifers”
- “Undisturbed creeks in the Black Hills support our wild trout population”
Wildlife Habitat
- “destruction of wildlife habitat”
- “threaten our elk, mule deer, mountain lion, bighorn sheep”
- “protect endangered species”
Recreation Tourism Public Use
- “popular recreation areas”
- “conflicts among recreational users”
- “damage to existing trails”

What it names

National Forests: Black Hills National Forest Buffalo Gap National Grassland
Roadless areas: Beaver ParkCheyenne RiverFirst Black CanyonIndian CreekInyan KaraJim Wilson CanyonRed ShirtSand Creek

The comment

On behalf of the South Dakota Chapter of the Sierra Club, I write in strong opposition to the proposed elimination of the Roadless Rule, which has served America well for over 25 years. The Sierra Club is the oldest and largest environmental organization in the world, and has had an active chapter in South Dakota for more than 50 years. We value our wild and special places, and the species that depend on those places. The elimination of the Roadless Rule threatens 45 million acres, much of which is undeveloped, that are currently managed by the U.S. Forest Service. Among the precious areas which are protected by the rule are Sand Creek, Inyan Kara and Beaver Park in the Black Hills National Forest, and Indian Creek, Red Shirt, Cheyenne River, First Black Canyon and Jim Wilson Canyon in the Buffalo Gap National Grassland. The Black Hills National Forest, much loved by sportsmen and recreationists as well as local residents, already has over 7500 miles of forest system roads. The forest would actually be well-served if some existing roads were retired; degradation of our existing roadless areas would be a tragic mistake. The Black Hills are sacred to may Native tribes, including the Lakota, Nakota, Dakota, Cheyenne, Arapaho, Arikara, Hidatsa and Mandan peoples. In addition to providing areas for traditional religious ceremonies, the forest contains ancient (and fragile) rock art which would clearly be threatened by additional road construction. Eliminating protection for our roadless areas raises the threat of reckless over-logging, the destruction of wildlife habitat, popular recreation areas, and clean drinking water that much of western South Dakota and eastern Wyoming depends upon. Construction of additional roads will doubtless lead to more human-caused fires. The threat of off-highway vehicles (ATV's, UTV's, side-by-sides and dirt bikes) would inevitably increase conflicts among recreational users of the Black Hills. The Forest Service currently has difficulty enforcing necessary protections, and unauthorized OHV routes are already degrading the Black Hills with dust, noise, congestion and damage to existing trails. We do not need a regulatory change that significantly worsens these problems. There is an urgent need to protect clean drinking water at a time of increasing drought in our region. Groundwater in the Black Hills is an interconnected system, and the Madison and Minnelusa aquifers protect our environment and our quality of life. Undisturbed creeks in the Black Hills support our wild trout population. There is also a need to protect endangered species, and increased human access in motorized vehicles will threaten our elk, mule deer, mountain lion, bighorn sheep, wild turkey, northern goshawk and other vital species in our region. For all of these reasons, we implore our federal government to leave the Roadless Rule intact. Jeremiah (Jay) Davis Rapid City, SD Chair, South Dakota Chapter of the Sierra Club