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Original comment deadline for Trumps proposed revocation of the 2001 Roadless Rule (deadline extended to 10/6/26)

September 21 @ 9:30 pm - 9:59 pm

Prairie Hills Audubon Society — Action Alert
The Roadless Rule Is on the Chopping Block

USDA proposes to erase road and logging protections on roughly 45 million acres of national forest — including inventoried roadless areas here on the Black Hills National Forest.

THE ORIGINAL COMMENT DEADLINE WAS: Monday, September 21, 2026. It got EXTENDED till October 6, 2026 

Comment here: https://www.regulations.gov/commenton/FS-2025-0001-223869
Federal Register notice: https://www.federalregister.gov/d/2026-16965
91 Fed. Reg. 53,827 (Aug. 20, 2026) · RIN 0596-AD66 · Docket FS-2025-0001

By mail: Director, Ecosystem Management Coordination, USDA Forest Service, 201 14th Street SW, Mailstop 1108, Washington, DC 20250-1124. Reference RIN 0596-AD66.
Is this scoping, or comment on a rule? It is both at once.

This is not scoping. Scoping already happened — USDA published its Notice of Intent on August 29, 2025 and gave the public 21 days, drawing more than 220,000 comment letters on behalf of over 625,000 individuals and organizations. What is open now is a single combined comment period on three documents released together: the proposed rule itself, the Draft Environmental Impact Statement, and the cost-benefit analysis. One comment can address all three, and comments on the DEIS are the ones that build the NEPA record. This is the last public comment opportunity before a final rule.

Links to Prairie Hills Audubon Society’s comments are at the bottom

Read the documents yourself

There are more than three. The core set is the proposed rule, the 333-page Draft EIS, and the cost-benefit analysis — but the agency also released a preliminary biological assessment and a Tribal consultation summary, and both matter.

What the proposal would do

Remove and reserve 36 C.F.R. part 294, subpart B — the entire 2001 Roadless Area Conservation Rule — which has barred road construction, road reconstruction, and most timber harvest in inventoried roadless areas since January 2001.
The 2001 rule covered 58.5 million acres. Because the Idaho and Colorado state-specific roadless rules are unaffected, roughly 45 million acres across 38–39 states are at stake.
Management of inventoried roadless areas would fall to individual forest plans, where a forest supervisor or regional forester may later amend the plan to allow roading and logging.
By the agency’s own numbers in the DEIS and cost-benefit analysis: about 18.2 million acres (45.5%) are lands where forest plans already allow roads and only the Roadless Rule prohibits them; about 4.8 million acres become newly available for timber harvest; recreationists could lose an estimated $6.1 million per year in economic benefit; total annual impacts could exceed $100 million.

Why South Dakota should care

In our region – the Black Hills National Forest, Custer-Gallatin National Forest , Buffalo Gap National Grasslands, Grand River National Grasslands, Little Missouri National Grasslands and  Thunder Basin National Grasslands contain inventoried roadless areas.  In the Black  Hills, roadless and wilderness areas provide protection from the endlessly aggressive logging in the rest of the forest.   Strip roadless areas out and their fate rests entirely on the Black Hills forest plan — a plan already under enormous pressure from timber-target politics, and Plan Revisions that PHAS has been contesting since the 1997 Plan Revision appeal. Rescission also removes a nationwide backstop at exactly the moment when the Endangered Species Act’s habitat protections are being narrowed (see our companion alert) and when the Forest Service is separately proposing to open more of the forest road and trail system to motorized use.
The process itself is worth commenting on

When the Roadless Rule was written in 2000–2001, the agency allowed 129 days of comment and held more than 400 public meetings; over 1.6 million comments came in. When the Bush administration tried to replace the rule in 2005, it gave two comment periods, each over 100 days.
This time the agency gave 30 days and has scheduled no public hearings anywhere except Alaska (those are ANILCA section 810 subsistence hearings, required by a different statute).
Earthjustice, on behalf of the Wilderness Society, Sierra Club and roughly a dozen other groups, formally asked USDA to extend the comment period to at least 120 days — to December 21, 2026 or later — and to hold hearings around the country. The agency has responded with an extra two weeks for commenting.
USDA’s own Tribal summary reports that the majority sentiment among Tribal governments consulted is opposition, and that Tribes raised the failure to fulfill trust responsibilities through adequate government-to-government consultation. Several requested alternatives the agency did not analyze, including a strengthened roadless rule and a Traditional Homelands Conservation Rule.

Pre-written comment tools from national groups

Each of these lets you add your own words. Please do add them. Form letters get counted; substantive, personal, place-specific comments must be individually addressed by the agency and are what hold up in court. If you can only do one thing, personalize the first paragraph.
National Audubon Society act.audubon.org/a/save-roadless-areas-2026
Sierra Club sierraclub.org/save-roadless-rule-protect-our-forests
NRDC action.nrdc.org/letter/5017-roadless-rule-052826
Defenders of Wildlife defenders.org/roadless-rule
National Wildlife Federation support.nwfactionfund.org/page/101819/action/1
Roadless.org roadless.org — comment-drafting tool plus a library of two dozen peer-reviewed studies with DOIs and key findings you can cite directly
Earthjustice statement earthjustice.org/press/2026/conservationists-blast-federal-proposal-to-bulldoze-forestlands

Also call your delegation

The durable fix is legislative. The Roadless Area Conservation Act (H.R. 3930 / S. 2042, 119th Congress) would write the Roadless Rule into federal law so that no administration could repeal it by regulation. Ask Senator Thune, Senator Rounds and Representative Johnson to cosponsor it, and to press USDA for a longer comment period and public hearings in the West. U.S. Capitol switchboard: 202-224-3121.
Companion action — the other half of the one-two punch

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Two days after the roadless proposal, the Forest Service opened a second national rulemaking: a rewrite of the Travel Management Rule (36 C.F.R. parts 212 and 261). It would drop the national “minimization criteria” that currently require the agency to minimize damage to soil, water, wildlife and habitat when designating motorized routes, and replace them with a presumption that existing roads, trails and areas are open unless the agency documents a reason to close them. It expressly reaches section-line access on the national grasslands. Comments due Wednesday, September 23, 2026.
91 Fed. Reg. 54,686 (Aug. 24, 2026) · Docket FS-2026-0100
Federal Register: federalregister.gov/d/2026-17211 ·

Comment: regulations.gov/commenton/FS-2026-0100-0001

Prairie Hills Audubon Society · P.O. Box 788, Black Hawk, SD 57718 · 605-787-6466 · phas.wsd@rapidnet.com · phas-wsd.org

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Here are links to the PHAS comments on the Roadless Rule Revocation.
LETTERS

1)The first is our unique original letter,

    2) the second a “sign-on” letter from John Muir Project we joined.

https://phas-wsd.org/wp-content/uploads/PHAS_Roadless_Rule_Comments_FINAL_V7.pdf

ATTACHMENTS
The PHAS original letter had 19 attachments. I have learned that just giving a bibliography or giving links/URLs to references
does not get them into the Administrative Record, so I have started doing attachments.  I had notice the professional
groups doing this and did not understand why…now I do

Details

  • Date: September 21
  • Time:
    9:30 pm - 9:59 pm