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I am writing as a resident of Swain County, NC, a business owner, a member of the Nantahala Gorge Association and the executive director of Need MoreOoutdoors. Each and every one of these puts me in a position to realize the negative impact of the U.S. Forest Service's proposed rescission of the 2001 Roadless Area Conservation Rule. Two areas impact me directly: Cheoah Bald and Wesser Bald. Both the Cheoah Bald and the Wesser Bald areas form a significant portion of the forested mountain landscape experienced by visitors traveling through and recreating in the Nantahala Gorge. The area is specifically identified as an example of a roadless landscape associated with outdoor recreation. The significance of both impacted areas to recreation extends well beyond the river. The Appalachian Trail bisects the Cheoah Bald Roadless Area, connecting the Nantahala Gorge with one of the country's most important recreation resources. The Roadless Rule has provided a stable management framework for more than two decades. Removing that framework creates uncertainty about the future management and character of landscapes directly adjacent to our commercial operations and surrounding one of the region's most important recreation corridors. Commercial outfitters and guides nationally have similarly identified the character of roadless landscapes as an important component of customer demand and have raised concerns about the business uncertainty associated with broad rescission of the Rule. In an area such as ours: rural, surrounded by national forest/national parks, there is little opportunity for local children growing up. Working in and with these areas is an opportunity. Do not take that away from them. I recognize that the Forest Service must actively manage National Forest lands. There may be circumstances where targeted access is necessary for wildfire response, forest health, emergency response, community safety, or other legitimate management needs. My opposition to the roadless does not mean I oppose those activities. I do, however, believe those needs can be addressed through deliberate, site-specific decisions without eliminating the national baseline that has protected roadless landscapes for more than two decades. The Nantahala River, Appalachian Trail, Cheoah Bald, and surrounding National Forest lands function together as a recreation destination, an outlet for young people who need to spend time outdoors and in our forests, and an investment saving these areas for future generations. I thank you for the opportunity to comment. Sincerely, Juliet Jacobsen Kastorff Bryson City, NC 28713

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. My family's history is rooted in Southern Appalachia. In fact, my father and grandfather were themselves road builders. They constructed farm to market roads linking remote communities throughout the mountains of Western North Carolina, but they also understood the value of leaving land undisturbed. They taught me to respect the old growth trees that still remained standing and to understand how the streams and wetlands we lived alongside provided habitat for wildlife, both animal and plant. Our own livelihood was interconnected with the health of the forests, streams and rivers. As an avid hiker and advocate for preserving green spaces and protecting our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. The lands I am most fearful of losing are in the Pisgah and Nantahala National Forests, vast areas of which were already hard hit with Hurricane Helen in 2024. These are fragile ecosystems, among the most ecologically diverse in the world, and they deserve our careful stewardship. They also are a major source of our region's prosperity through ecotourism, drawing visitors the world over to be awed by the beauty of these ancient mountain ranges. Craggy Mountain, Bearwallow, Balsam, Bald Mountain, Linville Gorge in Pisgah, Snowbird, Wesser Bald, Deep Creek, Cheoah Bald -- all these are peaks and wilderness areas that are landmarks to us here in the region and they hold sacred places in our family's stories. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Rebecca Caldwell Retired Environmental Educator, The North Carolina Arboretum, and Board Member, Friends of the Jackson County Greenways

Public Comment on the Proposed Rescission of the Roadless Area Conservation Rule Docket No. FS-2025-0001 | RIN 0596-AD66 I am writing today to oppose the proposed rescission of the Roadless Area Conservation Rule of 2001 (Roadless Rule). This landmark Rule is commonsense, protects key ecological, community, and cultural values, and is integral to my and my family’s health and wellbeing. I am submitting these comments to express my personal views and to request that the United States Department of Agriculture keep the Roadless Rule intact. My home is in the Southern Appalachian Mountains, where our national forests are renowned for their globally significant biodiversity and for their recreational opportunities. I take my young sons hiking, foraging, camping, and swimming in our favorite roadless areas. We study plants, mushrooms, animal tracks, birds, salamanders, and geology in these roadless areas. They love to explore the forest’s waterways and we plan to teach them how to fish in these roadless areas. We delight in waterfalls and they learn self-confidence and self-reliance. They are learning to love to be outside and to understand the importance of being disconnected to technology, a critical element in today’s technology-laden existence. In particular, the inventoried roadless areas on the Nantahala-Pisgah National Forest where we visit the most that do not have additional layers of designated protection are Cheoah Bald, Tusquitee Bald, Mackey Mountain, the Black Mountains, and South Mills River. We are intimately connected to these places and my family depends on them to explore and connect to nature with no worries of roads and the commercial enterprises that they bring into our public lands. I understand that there are places where those do occur, but I appreciate that the Roadless Rule has created certainty for over 25 years around where that can and cannot occur, and that as a parent I can access these precious places to build precious memories as my children grow and learn. They are physical, emotional, and spiritual places for my renewal, respite, and inspiration. As a citizen and taxpayer of the United States, I value Roadless Areas for saving my tax dollars. As Taxpayers for Common Sense reports, “[r]epealing the Roadless Rule would cost taxpayers billions in subsidized road construction and maintenance, exacerbate taxpayer losses from money-losing timber sales, increase wildfire risks and the associated costs borne by taxpayers, and weaken the health of roadless areas that provide important commercial and recreational benefits to the American public.” I appreciate that Roadless Areas provide water filtering service for over 25 million people across the country, and that clean drinking water is an irreplaceable resource. Roadless Areas of the Chattahoochee National Forest provide a significant portion of the Chattahoochee River, the source of drinking water for the City of Atlanta, where I have over a dozen family members who rely on that water. Above all, I believe that the Roadless Rule should be maintained as it is for the inherent values these areas provide for themselves, the flora and fauna and the unfragmented wild nature therein. Nearly 450 threatened, endangered, and ESA proposed wildlife species depend on national forest roadless areas for their survival, and over 1,500 sensitive plant and animal species recognized by the Forest Service find habitat in Roadless Areas. The unfragmented nature of Roadless Areas provide connectivity and more resilient habitat. Roadless Areas are less likely experience invasive species infestation or human-caused wildfire. I am requesting that the U.S. Forest Service fully analyze the following elements in the Final Environmental Impact Statement: •the effects of rescinding the Roadless Rule on wildlife habitat connectivity and landscape fragmentation •cumulative effects at the landscape scale, rather than limiting analysis to the direct footprint of potential future road construction or timber-management activities •watershed, erosion, sedimentation, and aquatic-connectivity impacts associated with potential changes in road construction and management •meaningful government-to-government Tribal consultation and consideration of Tribal interests and knowledge throughout the decision-making process Thank you for the opportunity to provide my comments on the proposed rescission of the Roadless Area Conservation Rule of 2001. I am requesting that the U.S. Forest Service select the No-Action Alternative laid out in the DEIS and keep the Roadless Rule intact.

I am a long time resident of Western North Carolina and an active participant in the outdoor economy and outdoor recreation community. National Forests are important economic assets that attract visitors, support rural communities, help businesses recruit and retain employees, and provide the landscapes upon which many outdoor recreation businesses depend. I oppose the rescission of the Roadless Rule as it impacts the opportunities of those that rely on Public Lands. My concern is not with thoughtful, site-specific forest management. Rather, eliminating a durable national framework across millions of acres creates economic uncertainty for recreation businesses and communities that have made long-term investments around these public lands. The Nantahala and Pisgah National Forests encompass approximately 1.045 million acres. Within these forests are 33 Inventoried Roadless Areas encompassing approximately 152,000 acres. Of that total, approximately 123,243 acres—nearly 12 percent of the Nantahala and Pisgah National Forests—would lose existing Roadless Rule protections under the proposed rescission. These lands provide something increasingly difficult to replicate: large, substantially unfragmented landscapes within one of the most heavily visited outdoor recreation regions in the Southeast. The comparatively undeveloped character of these landscapes is itself part of the recreational experience our communities offer. North Carolina's roadless areas include landscapes associated with some of the state's most recognizable recreation destinations. The Cheoah Bald forms a prominent forested landscape immediately adjacent to the Nantahala River, one of the Southeast's best-known whitewater recreation destinations. Roadless Areas are associated with hiking, backpacking, mountain biking, climbing, hunting, fishing, and other forms of outdoor recreation throughout the Southern Appalachians. The economic value of these landscapes extends beyond businesses operating directly within their boundaries. Visitors traveling to Western North Carolina to paddle, fish, hike, mountain bike, climb, hunt, or explore National Forest lands also purchase lodging, meals, fuel, equipment, guide services, retail goods, and other services in nearby communities. This creates an estimated 48,000 jobs and $4.9 billion outdoor economy in Western North Carolina. The Nantahala River, which runs along the Cheoah Bald Roadless Area supports 12 permitted rafting outfitters, which combined facilitate over 100,000 commercial rafting guests on the river. Additionally, commercial canoe & kayak instruction permits and guided fly-fishing outfitters rely on the Nantahala. Over 10,000 non-commercial paddlers visit the Nantahala River annually. All of whom rely on the local businesses. America Outdoors Association reported strong concern among its outfitter and guide members regarding broad rescission and its potential effects on recreation businesses. Local Forest Service managers appropriately need flexibility and precision to address local circumstances. A more durable approach to precision would evaluate proposed changes according to local conditions, demonstrated management needs, economic impacts, and meaningful stakeholder participation. The Forest Service should also consider its existing infrastructure responsibilities and carefully evaluate the long-term maintenance obligations created by additional roads and the opportunity cost of directing limited resources toward new infrastructure rather than maintaining infrastructure already serving the public. Therefore, I support the Forest Service in the following solutions: retaining national safeguards for Inventoried Roadless Areas; providing meaningful opportunities for stakeholder participation and input before significant changes to individual roadless areas; Evaluating the economic consequences of changes to roadless-area management, with particular attention to recreation occurring within and adjacent to Inventoried Roadless Areas, permitted commercial operations, gateway communities, and businesses; allowing targeted, locally justified management actions where road construction or other activities are demonstrated to be necessary for wildfire mitigation, forest health, community safety, emergency response, or essential public access; prioritizing maintenance of existing National Forest infrastructure that supports public use and local economies; and, providing long-term regulatory predictability so businesses and communities can continue making investments based upon reasonable expectations around management of nearby public lands. The approximately 123,000 acres of Nantahala-Pisgah National Forest lands that would lose Roadless Rule protections include forested mountains, watersheds, trails, fisheries, scenic river corridors, and backcountry landscapes that contribute to Western North Carolina's identity as an outdoor destination. They are assets impossible to recreate elsewhere.

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. Our community relies upon the natural benefits of our wild, roadless spaces, particularly two inventoried roadless areas in the Nantahala National Forest: Wesser Bald (4,061 acres) and Cheoah Bald (7,795 acres). I own property that borders the Nantahala National Forst and any further clearing or development would significantly and negatively impact the area from a noise, pollution, and general beauty standpoint. I chose to live in a remote part of Western NC. I chose to border what was, and has been to date, “protected” land. That land needs to stay as is - roadless. Humans have destroyed so much natural habitat in the area, there is no reason to do more destruction. Our county relies on nature-based tourism for much-needed jobs and revenue to fund county services. Tourists that visit these wild, roadless spaces travel here because the forests are pristine, the scenery is iconic, the sounds of nature abound. Our county's quality of life, property value, and tourism all depend upon the integrity and protection of our inventoried roadless areas. Many endangered and protected species live in our forests, streams and rivers: wildlife that needs us (people) to make decisions that ensure the healthy forest ecosystems needed for food, shelter, and breeding. I personally depend on these forests and watersheds for clean drinking water. In addition, I kayak the rivers and lakes, and I value the wildlife habitats in our old growth forests. Cutting roads into these protected areas would only reduce the quality of life for plants, wildlife, and people. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Regards.

I oppose to proposal to rescind or alter the roadless rule. I am a senior at Western Carolina University with a major in Biology and a minor in Natural Resource Conservation and Management. I live in western North Carolina and appreciate the ecological value of the extensive forests in this area. If the roadless rule is rescinded, it will open up areas such as Cheoah Bald and the Graveyard Ridge Roadless Area to the construction of new roads. While habitat fragmentation is a significant ecological issue, I am also concerned about microplastics from car tires. Multiple studies have found that car tires are one of the main sources of microplastic pollution (https://www.researchgate.net/publication/374926390_Unraveling_the_Marine_Microplastic_Cycle_The_First_Simultaneous_Data_Set_for_Air_Sea_Surface_Microlayer_and_Underlying_Water) (https://pmc.ncbi.nlm.nih.gov/articles/PMC13327939/). By allowing the construction of roads in these areas, we will be introducing microplastics into the ecosystem that will persist for possibly hundreds of years, and eventually end up in our water supply. We do not yet fully understand the negative health risks of microplastics, so allowing them to enter our watersheds could have widespread health impacts for citizens. Additionally, chemicals used in tires such as 6PPD - quinone have been shown to be toxic to fish, including rainbow trout (https://pubs.acs.org/esthag/article-abstract/59/13/6771/3662914/Subchronic-and-Acute-Toxicity-of-6PPD-Quinone-to). Trout fishermen brought $1.34 billion dollars to our state in 2023 (https://www.ncwildlife.gov/ncwrc-trout-report-final/open). Rescinding the roadless rule will allow toxic tire chemicals to enter our headwaters, which will harm this industry.

I oppose rescinding the Roadless Rule. Specifically: 1. The Roadless Rule does adds clarity on the process and location of logging, which allows for more efficient, thoughtful approaches to public lands and takes greater care of how forests are managed. 2. If allowed in all 20 Western North Carolina roadless areas, the outcome would affect runoff, water supply, and endangered species, including in Swain County’s two roadless areas — Cheoah Bald and Wesser Bald. 3. Rescission-induced changes to sedimentation and water quality are expected to lead to a 31-70% Eastern Hellbender population decline, an iconic and already endangered species. 4. Other threats include habitat fragmentation, canopy removal, invasive species encroachment, and plant and amphibian habitat disruption. 5. The change could impact tourism. Based on a 2023 Made by Mountains WNC Outdoor Recreation Participation Survey, Swain County received $23,660,693 in labor income from outdoor recreation visits, which are dependent on natural scenery and unspoiled settings. For those reasons and to uphold the preservation of our most natural places, please reject removing this important protection of our wilderness areas.

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. I rely upon the natural benefits of our wild, roadless spaces, particularly two inventoried roadless areas in the Nantahala National Forest: Wesser Bald (4,061 acres) and Cheoah Bald (7,795 acres). I chose the unspoiled wilderness of Western North Carolina for my home. The tourists that visit these wild, roadless spaces (and supply our county with jobs and revenue) travel here because the forests are pristine and the scenery is iconic. Many endangered and protected species live in our forests, streams and rivers: wildlife that relies upon humans to make decisions that ensure the healthy forest ecosystems needed for food, shelter, and breeding. Our county's quality of life, property value, and tourism all depend upon the integrity and protection of our inventoried roadless areas. I personally depend on these unfragmented forests and watersheds for clean drinking water. In addition, I paddle the rivers and lakes, and I value the wildlife habitats in our old growth forests, streams and rivers. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Laura Heinsman

I strongly support keeping the Roadless Rule in place. As a Western North Carolina resident, these lands are deeply personal to me. For about five years, I spent every birthday in Linville Gorge, making some of my favorite memories hiking and camping there. Roadless areas like Linville Gorge, Craggy Mountain, Hickey Fork, Cheoah Bald, and Tusquitee Bald protect clean water, wildlife habitat, and the wild character that makes our region so special. I want my future kids to be able to visit these spots and create their own memories

FS-2025-0001-223869 - Maintain protections for roadless areas The 2001 Roadless Area Conservation Rule conserves over 58 million acres of multiple-use public lands managed by the U.S. Forest Service that provide some of the best places to hike, run, backpack, camp, hunt, and fish in America. Repealing safeguards afforded by the Roadless Rule will jeopardize intact wilderness recreation areas, as well as fish and wildlife habitat. Therefore, I urge the U.S. Department of Agriculture to uphold strong protections for all roadless areas. Across the country, roadless areas provide irreplaceable habitat for native trout and salmon, big game, and other wildlife, such as our beloved Eastern Hellbender, one of only three giant salamanders found in the world. It is a North Carolina state-listed species of special concern. Because hellbenders are a protected species, it is illegal to kill, harm, collect, harass or sell them. The hellbender also is a Species of Greatest Conservation Need in the North Carolina Wildlife Action Plan. As residents of Asheville in Western North Carolina, my spouse and I, as well as our friends and family, are very active, adventurous, outdoorsmen and women. It is a primary reason for settling in such a beautiful and remote part of the Southeastern United States. It is key to our region’s economy due to the proximity of these natural, pristine wilderness areas to Asheville, Hendersonville, Brevard, Boone, and other beautiful cities in our part of the country. Moreover, I am a proud Disabled Army Veteran who holds exploring and testing oneself in the great outdoors in the highest regard as a rugged individualist American in a country that has become too soft and familiar with all that is sedentary and comfortable in cities and suburbs that do not understand the importance of the 2001 Roadless Area Conservation Rule. We take hiking, running, backpacking, camping, fishing, and hunting in Western North Carolina’s 172,000 protected roadless acres in the Nantahala and Pisgah National Forests very seriously. We will not forget and we will advocate with all our might to vote against those politicians and to remove those administration appointees who act to strip protections from pristine Roadless Areas we regularly visit such as Craggy Mountain northeast of Asheville, Cheoah Bald and the Appalachian Trail south of Stecoah Valley, and our most prized local area, the South Mills River roadless tract in the Pisgah Ranger District, stretching from near the Blue Ridge Parkway down toward the Cradle of Forestry. The 2001 Roadless Rule generally prohibits new road construction and industrial logging, while at the same time keeping these public lands open to habitat improvement projects, hazardous fuels reduction, hunting, fishing, OHV riding, firewood cutting, grazing, hiking, running, backpacking, and camping. The 2001 Roadless Rule already allows for balanced forest management, including timber harvest, to reduce the risk of uncharacteristic wildfire, as well as to restore habitat for sensitive fish and wildlife species. Importantly, hazardous fuels treatments in roadless areas are commonplace, helping protect at-risk communities and restoring forest health. If rescinded, new road construction and associated industrial-scale logging will fragment fish and wildlife habitat, degrade water quality and quantity, and reduce backcountry hiking, running, backpacking, camping, hunting, and fishing opportunities on public lands. There are 370,000 miles of roads in the National Forest System with a maintenance backlog of approximately $10.8 billion, 55% of which is due to dilapidated roads that cause sedimentation and erosion that reduce water quality, create barriers to fish migration, and create public safety hazards. We need to take care of the roads we already have, not add more roads that we don’t have the funding or personnel to maintain. Roadless areas provide some of the best hiking, running, backpacking, and camping areas, fish and wildlife habitat, and hunting and angling opportunities for Americans of all walks of life, from all areas of the country. I strongly support maintaining protections for all roadless areas and keeping these public lands a great place to hike, run, backpack, camp, hunt, and fish. We are paying attention. We won't tolerate elected officials or political appointees who undermine our shared American legacy of public lands. We will remember all those strong, courageous American leaders who champion public lands and listen to the loud voice of strong American people. Be a courageous leader of rugged Americans, not a pusillanimous one susceptible to capitulation when pressured. Thank you for your service to our country and attention to this important issue.

One Nation Under God. A crucial principle in our pledge of allegiance, to our people, its culture, and the foundation of our country. Whether it's creation or evolution or a combination of both it is every human being's duty to uphold, preserve, and protect the places that gave us a foothold to adapt and thrive over thousands of years. Rescinding the Roadless Rule is a direct act of disrespect to God, Mother Nature, their creations, and our legacy as a species. All have provided far more for us over our history on this planet than the corporate logging and development operations that have ever so recently, drastically decimated our native flora, fauna, and wild habitats. God our creator and our evolutionary ancestors would be appalled at the destruction and carelessness that has been inflicted on our natural environment. And now you want to double down and abolish this law, HOW DARE YOU. Our governments, these bills, these laws, the legislation, the officials, all of it needs to stop being in favor of profit and consumption for corporate benefit and the short term incentives that follow. It is not sustainable, it is not morally sound, and it does not prioritize the longevity of our nation and its people. Most of all it does not take into account the priceless history of the lands that built our people and these 50 states. There is true tangible value in the services these places provide to average citizens. Plus the ecological and climate buffer they provide to our infrastructure and economy that would otherwise cost you millions without them. Rescinding the Roadless Rule will allow corporate entities the direct access and capability to destroy key old growth forests around the country. These old growth forests are at the very top of the funnel for naturally filtering drinking water for millions. Disrupting these areas would cause immense water quality issues nationwide that would need to be solved with more infrastructure and water treatment plants that would also cost millions. These forests are home to some of the world's rarest creations and endangered species. The Cheoah Bald Salamander is a small near extinct species found only on one mountain top in North Carolina that is protected by the Roadless Rule. Allowing what's left of this little 2 inch amphibian's lineage to live in a fraction of what they used to call home. These forests and the greater lands that surround them are also sacred to the indigenous tribes that called our country home long before it was ever drawn on maps. After all we've done we owe it to them to preserve the Roadless Rule. From a financial perspective the numbers have been run and the info is available to the public to research. It would cost us more to cut down, extract, and process the trees from these forests than the profit that would be yielded. Destroying our lands for an unprofitable industry. Due to the nation wide logging operations in the early 1900s that clear cut and destroyed almost all of our nation's forests, there are very few mega trees within these old growth forests today that equate to a significant profit. The trees you see from old black and white photos where there are 10 people standing side by side across. Trees on the west coast measuring 100 feet around the trunk alone and ones on the east coast up to 30 feet. All but a few are gone. Without the Roadless Rule there's no doubt they will all be gone. More money could probably be made from tourism and education, bringing people in to experience these places and teaching them what nature can create when respected and cared for. If you believe in or even take a liking to One Nation Under God, Creation, Evolution, Mother Nature, "making the world a better place for future generations", clean water, cute salamanders, fishing, camping, hiking, birdwatching, our country's history and foundations, any of it, please DO NOT RESCIND the Roadless Rule.

am writing as a resident of Western North Carolina to express my strong opposition to rescinding the 2001 Roadless Area Conservation Rule. This proposal is not an abstract national policy issue for those of us who live in Western North Carolina. The Roadless Rule protects roughly 152,000 acres within the Nantahala and Pisgah National Forestsplaces that are part of the landscape, identity, water systems, wildlife habitat, recreation opportunities, and outdoor economy of our region. These protections encompass or affect some of the places Western North Carolinians know and love, including Graveyard Fields and Graveyard Ridge, Laurel Mountain, South Mills River, the Black Mountains, Tusquitee Bald, Cheoah Bald, Overflow Creek, Wilson Creek, Woods Mountain, Snowbird, Sam Knob, Chunky Gal Mountain, and areas surrounding the Joyce Kilmer-Slickrock and Linville Gorge wildernesses. I am particularly concerned about the consequences of allowing substantially more road construction and associated development in these landscapes. Forest Service research has recognized that fragmentation of previously uninterrupted forests can harm wildlife habitat, while roads can contribute to erosion and impacts to water quality. Roadless forests also provide large, connected habitat and headwaters that are increasingly difficult to replace once fragmented. ? Clean water is especially important in the Southern Appalachians. These mountains contain headwaters and tributaries that feed communities throughout Western North Carolina. For example, the Little Indian roadless area contains headwaters of the Nantahala River and tributaries draining toward the Little Tennessee River watershed. Protecting undeveloped headwaters and limiting erosion and sedimentation should remain a priority. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

Re: Docket FS 2025 0001, RIN 0596 AD66 I live in Asheville, North Carolina, near the Pisgah and Nantahala National Forests. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I ask USDA to select the No Action Alternative and retain the current protections. Nearly 152,000 acres in Pisgah and Nantahala are inventoried roadless areas. These include South Mills River, the Black Mountains, Cheoah Bald, Dobson Knob, and upper Wilson Creek. These lands protect headwater streams, wildlife habitat, and the backcountry recreation that supports Western North Carolina’s economy and quality of life. The proposal’s own analysis undercuts the case for complete repeal. USDA says permanent roads could become permissible on 18.2 million acres. Timber management opportunities could expand across 4.8 million acres. The Forest Service already has a $6.9 billion maintenance backlog for roads and bridges. USDA also estimates that recreation losses could reach $6.1 million each year. Repealing a national protection while acknowledging these costs is poor land management. The wildfire argument does not justify complete rescission. The Roadless Rule already allows work needed to address wildfire, insects, disease, and public safety. The Forest Service can also conduct active management on substantial acreage outside inventoried roadless areas. The 2023 Pisgah Nantahala Forest Plan already gives local officials a place based management framework. Roads fragment habitat, increase erosion, add sediment to streams, create more human ignition points, and leave taxpayers with continuing maintenance costs. Those risks are especially serious in Western North Carolina’s steep and wet terrain. The draft environmental impact statement does not explain why complete repeal is necessary when narrower alternatives could preserve roadless protections while allowing legitimate emergency and restoration work. Please retain the 2001 Roadless Rule and select the No Action Alternative. If USDA believes changes are needed, it should develop a stronger alternative that preserves national protections while clarifying narrow exceptions for verified public safety and ecological restoration needs. Adam Wildheart Asheville, North Carolina

I am a concerned American citizen and taxpayer. Please reconsider this rule. The roadless areas I am asking this agency to protect are real places I know: the Joyce Kilmer Slickrock Add. in Cherokee National Forest, Tennessee; Brushy Ridge, also in the Cherokee; and Yellowhammer Branch Add., Deep Creek / Avery Creek Addition, Snowbird, and Cheoah Bald in Nantahala National Forest, North Carolina. These are the areas at stake for me, and I am writing because the proposed rescission of the 2001 Roadless Area Conservation Rule would expose them to road construction and extractive development that the rule has held back for more than two decades. The southern Appalachians are an evolutionary crossroads. The Cherokee National Forest holds 18 inventoried roadless areas totaling 84,881 acres, and verified species there include black bear, hellbender, brook trout, Indiana bat, Virginia spiraea, and the northern long-eared bat. More tree species grow in these small roadless pockets than in all of northern Europe. The Nantahala National Forest holds 14 inventoried roadless areas totaling 52,304 acres, and its verified species include black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. Snowbird, Cheoah Bald, and the other Nantahala roadless areas protect the last wild headwaters of rivers that flow to both the Atlantic and the Gulf, along with salamander species found nowhere else on Earth. These are not abstract ecological facts. They describe the condition of the land I am asking the agency to keep intact. The proposal justifies rescission in part on wildfire and fuels management grounds. That justification cannot be squared with the agency's own findings. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Tennessee alone sits within a Southern region where 378 municipal water intakes sit in watersheds containing affected roadless areas, and those intakes depend on the watershed integrity that road-free headwaters provide. The agency must explain why this proposal departs from its own prior findings, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency also claims the rule imposes undue administrative and permitting burden. The rule's own text answers that claim: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection are already written into the rule. The agency has not identified which specific burdens fall outside those exceptions, nor has it quantified them. I ask that it do so, with specificity, for each burden it claims the exceptions fail to address. The regulatory flexibility analysis certifies no significant economic impact on small entities. That certification conflicts with the analysis surrounding it. The proposal's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the DEIS names outfitters, guides, and tour operators as affected parties. The certification reaches its no-impact conclusion by spreading losses across every small firm nationally rather than assessing the guides and outfitters who actually hold permits in the affected areas, while conceding that some firms may lose those receipts. The agency should withdraw the certification and conduct a proper assessment focused on the small entities operating in the potentially affected roadless areas, not a national average firm whose relationship to Snowbird or Cheoah Bald is zero. Finally, the agency has invited reliance interests and then declined to weigh them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is itself a reliance interest. My connection to the Nantahala and Cherokee roadless areas, and my expectation that the 2001 rule would continue to protect them, is exactly the kind of interest the agency is legally required to identify and assess before changing course. The agency must weigh the reliance interests described in the comments it receives, including this one, and it must do so in a manner that appears in the final record, not merely in a solicitation that generates no response. Future generations deserve to live in a beautiful place. Please consider them, Lyndsey Lee Knoxville, Tennessee

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tellico and Hiawassee Rivers run clear because they begin in roadless watersheds. I paddle both rivers, and that clarity is not incidental. It is the direct product of keeping roads out of the headwaters. I have camped, hiked, and paddled in these roadless areas of the Cherokee and Nantahala National Forests for over 40 years. I am visiting the upper part of Joyce Kilmer this fall. I am writing because the Forest Service proposes to rescind the protection that makes these places what they are, and the agency's own numbers do not support doing it. The economic case for rescission collapses when you read the agency's own record. The DEIS states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." A rule affecting fractions that small does not justify dismantling protections that took decades to build. I ask the agency to reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million, and to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also has not shown that the rule prevents anything it actually needs to do. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency should identify which specific burdens are not already addressed by those exceptions, name them by category, and quantify them. That identification belongs in the record before any rescission is finalized. I guide backpacking trips into these areas and take adults out to view what lives here. The Cheoah Bald roadless area in the Nantahala is a high-elevation resting place for hundreds of thousands of migrant birds, including some of our most threatened species. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. With the severe decline in bird populations already underway, these undisturbed areas are not a luxury. They are a requirement for survival of the species that depend on them. I want the agency to explain what specific mitigation would prevent the population-level harm its own cited research describes. The Snowbird area in the Nantahala supports a large population of bears, deer, and grouse, and it does so because the lack of roads keeps it remote. The DEIS quotes the federal grizzly recovery plan: "the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads." The principle applies across bear habitat generally, and the Cherokee National Forest's verified species list includes black bear. Wildfire in eastern roadless areas is mostly human caused. More access means more ignition sources in ecosystems that have not been conditioned to recover from that frequency of fire. The agency has not addressed either of these feedback loops in its justification for rescission. Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have structured over 40 years of use, guiding, and planning around the expectation that these areas remain roadless. Joyce Kilmer is one of the few places where old-growth eastern deciduous forest can still be experienced. The Cherokee holds 18 inventoried roadless areas totaling 84,881 acres. That is the landscape my reliance is built on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely Wilfred M Post Powell TN 37949

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Being out in nature, among wildlife, in the peace and quiet is essential for my mental health. I hike and camp all over east Tennessee, western North Carolina, north Georgia, and southern Kentucky and Virginia. The roadless areas I am writing about sit inside that country: Joyce Kilmer Slickrock Add. in Cherokee National Forest, Brushy Ridge in Cherokee, and Snowbird, Cheoah Bald, Yellowhammer Branch, and Deep Creek / Avery Creek Addition in Nantahala National Forest. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres. The Cherokee holds 18 inventoried roadless areas totaling 84,881 acres. The southern Appalachians are among the most biodiverse temperate forests in North America. More tree species grow here than in all of northern Europe. The last wild headwaters of rivers flowing to both the Atlantic and the Gulf run through these forests, along with salamander species found nowhere else on Earth. The Cherokee has numerous species of wildlife. The Nantahala carries black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. These species need undeveloped land. So do I. We need natural, undeveloped land for our survival. That is not a philosophical position; it is a practical one. The agency's own record undermines the case for rescission at every turn. The proposal justifies rescission in part on wildfire and fuels management grounds. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal justifies rescission in part on timber economics and employment. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency needs to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency has tried replacing this rule with local decision-making before, and that attempt failed in court. The record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time it substituted a state-by-state approach for one national rule, and address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values. The proposal argues the 2001 rule exceeded the agency's authority. That question has already been litigated. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and explain the basis for any contrary position it now takes. We need clean water for the survival of every living species on this planet. Across the Southern region, which includes Tennessee, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the watersheds fed by these roadless areas have impaired streams today. Rescinding this rule puts that record at risk. The agency must address what happens to those intakes and to water quality in these specific watersheds if the protections fall. Sincerely, Suzanne Peters [Knoxville, TN]

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Photography of blue herons, woodpeckers, and ospreys is what brings me to these forests, and the places I am writing about, Joyce Kilmer Slickrock Add., Brushy Ridge, and Cheoah Bald, are where that kind of wildness still exists. I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The agency's own draft environmental impact statement gives me more than enough reason to say so. The biological harm the agency anticipates is not speculative. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats. The Cherokee National Forest, where both Joyce Kilmer Slickrock Add. and Brushy Ridge sit, carries verified populations of black bear, hellbender, brook trout, Indiana bat, Virginia spiraea, and the northern long-eared bat across 84,881 acres of inventoried roadless land. The Nantahala, home to Cheoah Bald, holds verified populations of black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat across 52,304 acres. These are the animals the agency anticipates adversely affecting. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule takes effect. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document and then disappears. No projection of what it means across the 40.1 million acres of potentially affected environment follows anywhere in the record. I photograph blue herons and ospreys along waterways in forests the agency's own record describes as an evolutionary crossroads, where more tree species grow than in all of northern Europe, and where the southern Appalachians protect salamander species found nowhere else on Earth. The scenery at Brushy Ridge and Cheoah Bald is, in my view, unmatched, and the wildness is the reason. That wildness is a function of habitat continuity. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what the numbers mean for the landscapes it is proposing to open. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. That finding is entered into the record and left there. No population-level effect on big game is projected anywhere in the document. What does the rescission mean for the animals that depend on these roadless areas as refuge? The agency should project the effects on big game populations before it proceeds. Carbon storage gets the same treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The document then concludes that these lands will continue to sequester and store carbon, a conclusion reached without any analysis of what harvest and new road construction would actually release. That gap is not a minor omission. The agency must quantify the change in carbon storage and sequestration under each alternative it is considering. Public land should be managed for wild animals to live peacefully. That is not a complicated position. The places I named, beautiful and wild as they are, depend on a rule the agency is proposing to remove while its own documents predict the harm that will follow. The record does not support that outcome. Sincerely, [Your Name] [Your City, State]

"I am a resident/supporter of Western North Carolina and I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. Please select the 'No Action' alternative and retain the rule. North Carolina's 172,000 acres of Inventoried Roadless Areas—including areas of Pisgah & Nantahala Forests, and beloved landmarks like Laurel Mountain, South Mills River, Cheoah Bald, and the Black Mountains—are critical for clean drinking water, local tourism, and biodiversity. Opening these Pisgah and Nantahala wild forest spaces to commercial timber harvesting and road building will cause irreversible ecological damage, Threaten our water supply, and will decimate Wild Life, bringing our Black Bears even more so into our neighborhoods. Keep the Roadless Rule intact." Helene has already done enough damage for 100 years. No Roads & No Logging please.

I am completely against this. It really feels like a money grab—timber companies just wanting to make a profit off land that belongs to all of us. I spent a lot of my time out there. Hiking the Appalachian Trail, sitting up at Craggy Mountain, walking through Linville Gorge. That land is where I go to get away. If they build roads into areas like Cheoah Bald and Tusquitee Bald, it will ruin creeks and drinking water, hurt the wildlife, and destroy the quiet trails that people travel from all over to see. They are trying to sell this as wildfire prevention, but I really believe it's just about letting private companies use our public land to make money. Please do not open these areas up. Leave our forests wild and keep the Roadless Rule.

I'm writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. Although I live out of state my family has deep roots in western North Carolina, where my father-in-law grew up in Avery County. I and my husband plan to retire there in a few years. Western North Carolina is a deeply treasured place for my entire family. We have a house in Avery County and return as often as possible to experience a landscape whose natural beauty truly must be seen to be believed. Desiring these 150,000 beautiful acres is a repugnant idea because places like this are what makes America truly unique. My fear though is that those currently in power care only about money and not beauty, so let's talk about the severe economic detriments that will follow if this proposal prevails. Framed as an economic opportunity for timber extraction, removing roadless protections is actually a profoundly poor financial decision for the region’s rural communities. Opening these backcountry areas to commercial logging and road building threatens the primary drivers of Western North Carolina's modern economy. The Outdoor Recreation and Tourism Economy: Tourism is the financial lifeblood of rural Western North Carolina, generating billions of dollars annually. Visitors travel from across the globe specifically for the pristine, undisturbed backcountry experience found in areas like Cheoah Bald, the South Mills River watershed, and the Black Mountains. Degrading these landscapes with clear-cuts and industrial roads would ruin the region's appeal, threatening thousands of small businesses, guides, hospitality workers, and local tax revenues. The Craft Beverage Industry: Western North Carolina is home to a world-renowned craft brewing and beverage cluster that relies entirely on clean, pure, unpolluted water. The Pisgah and Nantahala national forests act as natural filtration systems for municipal water supplies. Constructing logging roads through steep, erosion-prone mountain terrain will cause heavy sedimentation in local watersheds, drastically increasing water treatment costs for local municipalities and threatening the precise water quality that local breweries depend on. Property Values and Regional Talent Attraction: The stunning natural beauty of the Appalachian Mountains drives residential growth and attracts entrepreneurs, retirees, and remote workers to rural counties. This influx supports local real estate markets, construction industries, and professional services. Transforming protected backcountry into active timber extraction zones lowers adjacent property values and reduces the regional appeal that draws long-term economic investment. The Burden of Infrastructure Maintenance: Building and maintaining industrial logging roads in rugged mountain terrain is incredibly expensive. Long after timber companies harvest the resources and leave, the financial burden of managing eroded, failing infrastructure often falls back on public funds and local forestry budgets, draining resources away from critical community needs.Industrial logging in these rare roadless areas treats a irreplaceable public asset as a short-term commodity. The long-term economic value of keeping these forests intact—for clean water, tourism, and community resilience—vastly outweighs the temporary financial gain of a few timber contracts. I strongly urge you to protect Western North Carolina’s rural economies by maintaining the 2001 Roadless Area Conservation Rule in its entirety Sincerely, Jesse Christensen