Friction plays a key role in controlling the rheology of dense granular flows. Ertas and Halsey, among others, have proposed that friction and inelasticity-enabled structures with a characteristic length scale in such flows can be directly linked to such rheologies, particularly that summarized in the Pouliquen flow rule. In dense flows, gear states in which all contacts roll without frictional sliding are naively possible below critical coordination numbers. We construct an explicit example of such a state in D=2; and show that organized shear can exist in this state only on scales l < d/I, where d is the grain size and I is the Inertial Number, characterizing the balance between inertial and pressure forces in the flow. Above this scale the packing is destabilized by centrifugal forces. Similar conclusions can be drawn in disordered packings of grains. We comment on the possible relationship between this length scale l and that which has been hypothesized to control the rheology.