Comment Analysis · Docket FS-2025-0001

FS-2025-0001-594058

Opposes rescissionPosted October 6, 2026 On Regulations.gov

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

Topics

  • Environmental Protection Biodiversity
    • “protect the remaining wilderness”
    • “important remaining blocks of undeveloped public habitat”
    • “improve wildlife habitat”
    • “protect some of America's most wild places”
  • Recreation Tourism Public Use
    • “outstanding outdoor experiences that support the recreation economy”
    • “hunted, fished, hiked, camped and experienced the Badlands”
    • “outdoor activities North Dakotans hold near and dear”
    • “multi-user access”
  • 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”
    • “responsible management”
  • Water Quality Quantity
    • “provide clean water”
    • “protect some of America's most wild places that provide clean water”

What it names

National Forests
Dakota Prairie Grasslands

The comment

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

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