Comment Analysis · Docket FS-2025-0001

FS-2025-0001-457494

Opposes rescissionPosted September 21, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Environmental Protection Biodiversity
    • “protect ecosystems”
    • “un-fractured habitat for countless species of birds and animals”
    • “destroying and fracturing habitat and fragile ecosystems”
    • “critical to protect the remaining wilderness”
  • Recreation Tourism Public Use
    • “provide recreation for millions of people”
    • “hunted, fished, hiked, camped and experienced the Badlands”
    • “marveling at the dark skies and the quiet nights”
    • “outdoor activities North Dakotans hold near and dear”
  • Water Quality Quantity
    • “protect water quality”
    • “reduce erosion”
    • “ecosystems protect water quality”
  • Forest Management Wildfire
    • “doubt that eliminating the rule is necessary to address wildfire risk”
    • “existing rule provides flexibility for fuels mitigation”
    • “wildfire ignitions were roughly four times more likely near roads”

What it names

National Forests
Dakota Prairie Grasslands

The comment

The North Dakota Chapter of the Sierra Club is opposed to the repeal of the Roadless Area Conservation Rule. Since 2002, the Roadless Rule has protected the heart of our public lands, saved taxpayer dollars, and enjoyed overwhelming popularity with the general public. There is no reason throw away a successful, commonsense policy while offering nothing but baseless justifications for doing so. The rule, as it stands, helps to protect ecosystems. These ecosystems protect water quality, reduce erosion, and provide un-fractured habitat for countless species of birds and animals. They very same ecosystems provide recreation for millions of people (including motorized vehicles on designated trails and hunting opportunities). The roadless areas are managed as ecosystems, and often timber remains on these areas because they are so steep and rugged that they are uneconomical to log. Building taxpayer or timber sale funded roads to potential timber sales which are uneconomical to log is wasteful, destructive, and stupid. These sales often are not even bid because of their difficulty and poor logging economics. In areas which are not forested, the same roadless rule applies, only instead of timber, oil and gas extraction are the objective of roadless rule repeal. We don’t have to choose between protecting a 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. While this may be more expensive for the oil company, the North Dakota Chapter of the Sierra Club does not feel that the US taxpayer or oil and gas extraction fees should pay for roads which benefit only the oil and gas companies while destroying and fracturing habitat and fragile ecosystems. When analyzing potential impacts, it is very important to analyze the entire ecosystem, not the local/individual project level. The local/individual project level overlooks the cumulative impact that the national rescission will have on the environment (aka “death by a thousand cuts”). Members of the North Dakota Sierra Club have hiked, biked, hunted, fished and fished on the Little Missouri National Grasslands in North Dakota. We have viewed with awe the expansive plateaus and dissected drainage ways of the grasslands. We have forded the Little Missouri River many times to access trails and vistas. We have camped along the Maah Daah Hey Trail and in the campgrounds, marveling at the dark skies and the quiet nights, punctuated with the sounds of coyotes, and been serenated awake by the calls of birds (one avid birder awoke at dawn and counted 29 different bird calls before he exited his tent an hour later). We believe 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. 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. 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 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 North Dakota Chapter of the Sierra Club is opposed to the repeal of the Roadless Area Conservation rule and supports a NO ACTION alternative.

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