Read the comments.

To the U.S. Forest Service: I oppose any efforts to roll back the 2001 Roadless Area Conservation Rule. As fan and user of public lands, I rely on the protection of our roadless areas. I regularly visit Bearwallow Mountain, Craggy Mountain, Sam Knob, and Linville Gorge near my home in Asheville. 

 Protecting these wild areas is deeply personal to me because I hike the backcountry trails and depend on them for my physical and mental health. I love the wildlife and am an advocate for trees. — especially the old growth trees. These natural preserves provide us with clean drinking water, healthy air, and are important recreation and outdoor engagement areas for locals and visitors alike. 

I urge the U.S. Forest Service and the U.S. Department of Agriculture 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. Best, Alli Marshall

To the U.S. Department of Agriculture and the Forest Service: I write in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I urge the Department to adopt Alternative 1, No Action, and keep the Roadless Rule fully in place. I equally oppose Alternative 3, which would open most inventoried roadless areas in the East to logging. The wildfire rationale is contradicted by the evidence. A peer-reviewed study published in Fire Ecology in January 2026 found that from 1992 to 2024, wildfires were four times more likely to ignite within 50 meters of a road than in forest without motor vehicle routes. Ignition density in Inventoried Roadless Areas was 1.97 fires per 1,000 hectares, compared with 7.99 near roads. Fires that escaped initial attack, the ones that become large and catastrophic, showed no meaningful size difference between roaded and roadless areas. The Forest Service reached the same conclusion itself: its 2001 environmental impact statement found that building roads into roadless areas would likely increase human-caused fires, and that prohibiting road construction would not increase acres burned or the number of large fires. The rule already allows hazardous fuels reduction and other management where needed. Repeal is not a wildfire solution. Roadless areas protect water and wildlife. The Roadless Rule protects drinking water in 354 municipal watersheds. Seventy percent of roadless areas are home to native trout or salmon. These benefits cannot be rebuilt once roads and logging fragment these lands. The public has spoken, repeatedly. The original rule followed 600 public meetings and 1.6 million comments gathered over 18 months. In the 2025 comment period, more than 99% of comments opposed repeal. 164 members of Congress have urged the Department to retain the rule. Leading conservation organizations, including The Wilderness Society, Sierra Club, Trout Unlimited, Earthjustice, the Natural Resources Defense Council, Outdoor Alliance, and MountainTrue, all oppose this rescission. A short comment window with no public meetings is not adequate for a decision of this scale. This is personal for me. I am a native of Western North Carolina. About 15% of the Pisgah and Nantahala National Forests are Inventoried Roadless Areas, places like Linville Gorge, Craggy Mountain, the Black Mountains, and the headwaters of the South Mills River. Hellbenders, warblers, and trout depend on them. These mountains and the protected forests within them are worth more to me than almost anything. They are, without doubt, one of the most valuable jewels in our nation's possession, and they, along with the countless other forests across our nation, deserve our protection and stewardship. As Wendell Berry wrote, "There are no unsacred places; there are only sacred places and desecrated places" We must not allow our public lands to become desecrated. Please retain the 2001 Roadless Rule in full. Sincerely, Matthew Metcalf Asheville, North Carolina

Those of us that love the outdoors, love nature and want to spare it from exhaustive roads and people. Please don't go this route! I am writing about the Craggy Mountain Roadless Area in Pisgah National Forest, North Carolina. I have specific concerns about the rescission of Roadless Rule protections. Headwater Stream Networks Supporting Native Brook Trout: The Craggy Mountain roadless area encompasses the headwaters of seven major creek systems—Dillingham Creek, Bearwallow Branch, Carter Creek, Mineral Creek, Peach Orchard Creek, Sawmill Branch, and Waterfall Creek—that feed into the Big Ivy and Shope Creek watersheds, recognized strongholds for native Southern Appalachian brook trout. These headwater streams maintain the cold, clear water conditions that brook trout require for spawning and survival; the intact riparian forest and undisturbed streambed provide the stable, gravel spawning substrate and shade that regulate water temperature. The Eastern Hellbender (proposed federally endangered), a large aquatic salamander sensitive to sedimentation and temperature change, also depends on these clean, cold headwater conditions. Road construction in steep terrain directly threatens this entire network through erosion and canopy loss. Interior Forest Habitat for Bat Species and Canopy-Dependent Birds: The unfragmented northern hardwood and high-elevation red oak forests of Craggy Mountain provide interior forest conditions essential for three federally protected bat species: the gray bat (federally endangered), northern long-eared bat (federally endangered), and tricolored bat (proposed federally endangered). These species forage in the canopy and roost in tree cavities and under bark; they require large, continuous forest blocks to sustain viable populations. The cerulean warbler (near threatened, IUCN), a canopy-nesting songbird, similarly depends on the structural complexity and connectivity of unfragmented forest. Road construction fragments this interior habitat, creating edge effects that expose bats and birds to predation, reduce foraging efficiency, and allow invasive species and parasites to penetrate the forest interior. Invasive Species Establishment and Spread Along Road Corridors: Road construction creates disturbed soil and edge habitat that favor invasive plants over the specialized native flora of Craggy Mountain's rare plant communities. Hemlock woolly adelgid, an invasive pest already documented as a threat to eastern hemlock (near threatened, IUCN) across the Pisgah National Forest, spreads rapidly along road corridors and disturbed areas. Once established, invasive species alter soil chemistry, hydrology, and light availability, making it impossible for rare plants like Gray's lily and Oconee bells to persist. The road itself becomes a permanent vector for invasive seed dispersal, ensuring that native plant communities cannot recover even if road use eventually ceases. Sincerely, Robert Medina (local trail hiker and small time Real Estate Developer)

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. As an avid user and advocate for our nation’s public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit many of these areas, including the Jarrett Creek, Mackey Mountain, Bearwallow, Balsam Cone, Craggy Mountain, and South Mills River areas near my home in Western North Carolina. I spend many hours in the forests in these areas - riding my bike, hiking, and running. The peace and quiet and connection with nature help keep me grounded and are essential to my well-being. I am happiest when I am in the forest, and I treasure having these wild places so close to my home. I am constantly reminded how lucky I am to be able to spend hours every week in these wild places where I encounter so many types of beautiful and interesting plants, insects, and wild animals. I encounter bears, deer, bobcats, snakes, rabbits, groundhogs, turkeys, fish, turtles, and many other critters in these areas. Being out in these wild places reminds me that I am only a tiny piece of such an incredible and immense world. These wild places untouched by development provide peace and solitude that is so rare in our world. These forests are irreplaceable, and the damage done by rescinding the protections in these areas would be devastating and irreversible. I have already seen massive damage to our area's forests from Hurricane Helene and how that has allowed for invasive species to flourish in some areas. I am also greatly concerned about the increased wildfire risk in my area. Undoing the protections in these areas would only cause further damage in a time when the land is just beginning to heal from Helene. Protecting these unfragmented landscapes is deeply personal to me because I recreate in these forests regularly, and I value the pristine wildlife habitats these wild areas contain. 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 and for your time in considering my input on this important issue. Sincerely, Dorothy

I am writing in support of the Roadless Rule, rescission of which would be shortsighted, environmentally detrimental, and economically irresponsible. I live near the Craggy Mountain, Bearwallow, and Balsam Cone roadless areas on the Pisgah National Forest. Construction of roads in these natural areas would: - Add sediment to headwater streams and contribute to increases in water temperature, which would harm populations of native brook trout and other aquatic organisms that are critical drivers of recreation dollars and also important components of intact freshwater communities. - Reduce water quality in watersheds that supply drinking water to communities in the area, raising costs for water treatment. - Lead to new populations of non-native invasive species along road corridors, which would harm sensitive habitats and increase the already-astronomical direct and indirect costs resulting from the spread of non-native invasive species in the US. -Fragment critical areas of intact forested habitat, which is vital for the survival of native wildlife. -Cause irreversible harm to sensitive high-elevation habitats, which are important refugia for threatened and endangered species. -Damage the wild character of these important places, reducing their appeal as recreational destinations and thereby draining the local economy of important tourism dollars. These are just a few examples of how rescission of the Roadless Rule would have a detrimental effect on a few of the inventoried roadless areas nearest to me. Please retain the Roadless Rule.

Hello, I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. I live in Leicester, NC, a rural farming community northwest of Asheville, NC. The public lands in this area are critical to our community, driving tourism, one of the biggest economic drivers in our region. The majority of the people I know who live here – my neighbors, friends, and family members – are avid outdoorsmen/women and spend time in our local state and national forests and public lands, including roadless regions such as South Mills River, Laurel Mountain, Graveyard Ridge, and Craggy Mountain. I am a trail runner and a leader in the North Carolina Mountain Trail Runners organization. Many of our members and I are long-distance ultra runners and utilize the surrounding public lands to train for races. Many of us are also frequent hikers/backpackers. Our community is based on our love and enthusiasm for nature, and our local roadless regions directly support and grow that community. This rule is particularly close to my heart, since my wife and I eloped and got married in Linville Gorge, one of the roadless regions. We make an annual camping trip back to the Gorge to celebrate our love and to reconnect. Please do not put that at risk by rescinding the roadless rule. I urge you to maintain full protections for all currently designated inventoried roadless areas. Protect our lands, protect our communities. Thank you for the opportunity to provide public comment. Sincerely, Alex Harvey

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

I am writing to submit a comment on the Notice of intention to rescind the 2001 Roadless Rule. I am and avid outdoor enthusiast and I care deeply about our national forests because I use many areas that are protected by the Roadless Rule in my local area including Mackey Mountain, Balsam Cone, Bear Wallow, Craggy Mountain, South Mills River, and Jarrett Creek. Rescinding the Roadless Rule will is likely to result in an expansion of the 386,000+ miles of existing roads that the Forest Service already has to maintain if the stated goals of expanding logging and mining are to be achieved. Business will expand the road network to exploit and extract resources and will then leave the maintenance of these roads to the Forest service. This will exacerbate the $8.4 billion in deferred maintenance that the Forest Service already has(USDA Forest Service 2001 EA). Where will this money come from? Taxpayers will be required to foot the bill for the future maintenance of this expansion of the forest service road network. The returns for this expenditure are not clear. Studies have shown that counties with protected federal lands have faster growing populations, per capita income, and employment than counties without (Izon et al. 2010; Holmes & Hecox 2002). This growth is in recreation related industries like lodging, dinning, and professional services. The wilderness recreation industry generated an estimated $574 million annually with much of this going to local communities(Loomis 2000). This is also sustainable growth where as logging tends to only provide short term economic benefits to local communities. The Roadless Rule protects important wild lands that will be irreplaceable if they are exploited for extractive industries and will likely result in long term economic harm to the local communities that lose out on revenue from wilderness recreation. Personally Curtis creek in the Pisgah national forest is one of my favorite camp grounds and is a place where I have created lasting memories hiking and backpacking with my wife. It is surrounded by land that is protected by the Roadless Rule and allowing logging on this land would forever change the character of the land and degrade the quality of this site. Turkey Pen gap is where I went on my first backpacking trip and discovered my love of backpacking. The majority of this trip was spent in the South Mills River area that is covered by the Roadless Rule. Rescinding the Roadless Rule puts these areas that I love in danger for little to no gain. For this reason I strongly oppose the USDA Forest Service’s proposed rescission of the Roadless Rule.

Dear U.S. Forest Service: I am writing to express my vehement opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user of and advocate for our nation's public lands, I rely on and cherish the integrity and protection of our inventoried roadless areas. I frequently visit the Craggy Mountain Wilderness near my home in Asheville, North Carolina. Protecting these unfragmented landscapes is deeply personal to me both becuause I depend on these watersheds for clean drinking water and I frequently hike the backcountry trails. I beseech the U.S. Forest Service and the U.S. Department of Agriculture to permanently scrap the proposed rescission, and instead maintain full protections for all currently designated, inventoried roadless areas. Thank you for the opportunity to provide public comment. Best, Hunter

Dear Secretary Rollins and the U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge you to retain the rule in its entirety. The wildfire rationale does not hold up • The Forest Service’s own draft environmental impact statement found that repealing the rule would deliver little or no wildfire risk reduction while increasing federal road maintenance costs. • Ninety-five percent of wildfires are started by people, and nearly two-thirds of those ignite along roadsides. Building more roads would likely increase, not decrease, fire starts. • The analysis projects only a 5–10% increase in timber harvest—adding roughly $5–11 million a year to a $288 billion industry—a trivial gain against the loss of protections for nearly 45 million acres. The timber production argument is contradicted by current industry conditions • U.S. sawmill capacity has dropped 6% in a single year, production has fallen for two straight quarters, and the mill workforce is at its lowest level since 2010. • Thirty-five hardwood sawmills closed in 2025 alone, and the industry has lost around 40,000 jobs since 2022. • Here in South Carolina, Canfor closed its Darlington sawmill in June 2025, and Interfor recently curtailed production at its Summerville plant, laying off about 90 workers. • The problem is demand, not supply. Weak housing construction and collapsing pulpwood markets mean there are no buyers for additional timber. Opening more forest to harvest does not create markets that do not exist. The rule protects critical resources and has broad public support • It safeguards drinking water for roughly 25 million Americans across 82,000 miles of streams. • Removing the national baseline would fragment wildlife habitat and shift decisions to local plans without guaranteed public involvement or environmental review at that scale. • The rule has survived 25 years of litigation. In the 2025 notice-of-intent period, more than 600,000 comments were submitted, over 99% opposing repeal. Personal connection to these landscapes I have spent time in the roadless areas of the Pisgah and Nantahala National Forests in North Carolina (including Big Ivy, South Mills River, Craggy Mountain, and Wilson Creek) and in the Francis Marion and Sumter National Forests in South Carolina (including the Andrew Pickens district). I have also spent time in the Pike-San Isabel National Forest near Buena Vista, Colorado, where the Collegiate Peaks, Mount Massive, and Mount Elbert roadless areas provide world-class backcountry recreation. While Colorado’s lands remain protected under the state’s own 2012 roadless rule, the principle matters everywhere: these places are irreplaceable. Once roads and logging enter them, their character is gone forever. I respectfully request that the Forest Service select the alternative that retains the Roadless Rule as is. Sincerely, Robert Howell Greenville, SC

I would like it to be known that the most special places on this planet are the ones least touched by humans. I was born and raised in the United States of America, a proud American, and honestly all of my fondest experiences are in remote areas of this beautiful country. It’s beauty comes from the untouched landscapes. I stand for keeping the Roadless Rule in place. As I mentioned, because I cannot emphasize it enough, I am passionate about the natural, untouched beauty of this country, and this planet. I have long been a landscape photographer, having gone to school for photography, specifically to photograph the landscape of our beautiful areas. I also partake heavily in outdoor pursuits, away from the chaos of cities. It cleanses me, and provides a reset to my system to endure the daily stresses of our society. I've lived in Michigan, and explored the Manistee National Forest, where Bear Swamp is now threatened by this potential rescinding of the Roadless Rules Act. I’ve lived in Colorado a good part of my life exploring in the backcountry, and summiting many 14ers, including the now endangered Mt. Antero. Then there’s Wyoming, where I’ve backpacked in the Teton National Forest, Montana, Idaho, Utah, California, and New Mexico. I’ve hiked along all three major trails systems that are threatened as well, which include, The Pacific Coast Trail (and John Muir Trail), the Continental Divide, and the Appalachian Trail. I’m living in western North Carolina where I now call home, and I frequently hike and bike in areas that are currently protected by the Roadless Rule Act, like South Mills River (bordering the Cradle of Forestry, the birthplace of forestry), Bearwallow, Craggy Mountain, Laurel Mountain, Linville Gorge, Sam Knob, to name a few. I can’t imagine experiencing the same joy, wonder, and awe that I have if these places were to be developed in any way, or in other words touched by humans in any destructive manner, including roads or otherwise. Not only that, but the impact it would have on the ecosystems, and the biodiversity, including all of the native plants and animals, it would be devastating. I’ve also worked in the outdoor industry, and it is largely because of my passion for the outdoors. I know firsthand that it is a thriving industry, and it is for the reason of having places like the ones that are currently protected under the Roadless Rules Act (Wilderness recreation and passive-use values are economically substantial. Economists estimate Western wilderness areas hold passive-use value — the value people place on knowing an area remains intact — at roughly $168 per acre. Wilderness recreation alone generates an estimated $574 million annually in economic value, based on an average of $39 per recreation day. Road construction in roadless areas would not destroy these values everywhere at once, but it would change the conditions on a substantial share of acreage where they currently exist (Loomis 2000; Izon et al. 2010)). There is a reason the Act was put into place, and the reason is to support something that is greater than all of us, even though it is a part of all of us. I am in full support of keeping the Roadless Rule Act in place. It is serving a need that goes far beyond humans. The old growth in many of the forests that are now threatened by the rescinding of the Roadless Rules Act, are likely a part of the reason that global warming hasn’t expedited any faster that it already has (old-growth forests store 35 to 70% more carbon, including in the soils, compared to logged stands — DA et al., 2022 (https://doi.org/10.3389/ffgc.2022.979528)). These forests are also home to many endangered species, and other animals who continue to lose their territory to human development. We need to keep the Roadless Rules Act in place, for all life, including this one planet that we all share. There is much to lose, including but not limited to, home to many endangered species, a wealth of biodiversity, carbon sinks for our planet to sustain, outdoor pursuits that provide rejuvenation to so many, no matter the color or their skin, or who they vote for, and once it’s gone, it can never be replaced. I’m concerned that the rescinding of the Roadless Rule is for reasons that reach far beyond mere wildfire protection, and more for profit. I believe that there are better alternatives to go about wildfire protection and mitigation, while keeping the Roadless Rule in place. I strongly urge your consideration to keep the Roadless Rule in place.

Dear Secretary Rollins and the U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge you to retain the rule in its entirety. The wildfire rationale does not hold up • The Forest Service’s own draft environmental impact statement found that repealing the rule would deliver little or no wildfire risk reduction while increasing federal road maintenance costs. • Ninety-five percent of wildfires are started by people, and nearly two-thirds of those ignite along roadsides. Building more roads would likely increase, not decrease, fire starts. • The analysis projects only a 5–10% increase in timber harvest—adding roughly $5–11 million a year to a $288 billion industry—a trivial gain against the loss of protections for nearly 45 million acres. The timber production argument is contradicted by current industry conditions • U.S. sawmill capacity has dropped 6% in a single year, production has fallen for two straight quarters, and the mill workforce is at its lowest level since 2010. • Thirty-five hardwood sawmills closed in 2025 alone, and the industry has lost around 40,000 jobs since 2022. • In South Carolina, Canfor closed its Darlington sawmill in June 2025, and Interfor recently curtailed production at its Summerville plant, laying off about 90 workers. • The problem is demand, not supply. Weak housing construction and collapsing pulpwood markets mean there are no buyers for additional timber. Opening more forest to harvest does not create markets that do not exist. The rule protects critical resources and has broad public support • It safeguards drinking water for roughly 25 million Americans across 82,000 miles of streams. • Removing the national baseline would fragment wildlife habitat and shift decisions to local plans without guaranteed public involvement or environmental review at that scale. • The rule has survived 25 years of litigation. In the 2025 notice-of-intent period, more than 600,000 comments were submitted, over 99% opposing repeal. I have a deep personal connection to these landscapes. I have spent time in the roadless areas of the Pisgah and Nantahala National Forests in North Carolina (including Big Ivy, South Mills River, Craggy Mountain, and Wilson Creek) and in the Francis Marion and Sumter National Forests in South Carolina (including the Andrew Pickens district). I have also spent time in the Pike-San Isabel National Forest near Buena Vista, Colorado, where the Collegiate Peaks, Mount Massive, and Mount Elbert roadless areas provide world-class backcountry recreation. While Colorado’s lands remain protected under the state’s own 2012 roadless rule, the principle matters everywhere: these places are irreplaceable. Once roads and logging enter them, their character is gone forever. I respectfully request that the Forest Service select the alternative that retains the Roadless Rule as is. Sincerely, Matt Lugar

To the U.S. Forest Service: I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service and USDA to retain the existing rule and select the No Action alternative. I am a Western North Carolina native, ecological artist, and environmental educator living in Asheville. Inventoried roadless areas such as Craggy Mountain, Sam Knob, and the lands surrounding Linville Gorge have shaped my relationship with these mountains and inspired much of my life’s work. I visit these places to hike, observe, learn, and create. This summer, I returned to Linville Gorge and was once again awed by its majesty: the immense sweep of the landscape, its rugged rock formations, and the diversity of life held within its forests. These places are far more than scenic backdrops. They are living, interconnected communities that provide habitat for native plants and wildlife, protect water quality, and offer people the increasingly rare experience of quiet, wonder, and immersion in an intact landscape. My artwork grows from close observation of the relationships among native plants, fungi, animals, forests, and the larger landscape. I have attached a photograph from my visit, along with my oil painting *Wiseman’s View*, inspired by Linville Gorge. Together, they reflect both the extraordinary character of this intact landscape and the lasting influence these public lands have on my artistic practice. Road construction and commercial timber harvest could fragment these ecological relationships and diminish qualities that cannot easily be restored once lost. The proposed rule itself acknowledges potential tradeoffs with quiet, remote recreation, as well as the possibility of increased road construction and timber-management opportunities. In Western North Carolina, these forests also sustain outdoor recreation, tourism, environmental education, clean water, and the sense of place that is central to our communities. I recognize the need for thoughtful, science-based forest management. However, the Roadless Rule already contains limited exceptions for necessary management activities. Rescinding a nationwide conservation standard is not appropriately tailored to those needs. Local forest plans and project-by-project review are not equivalent protections and would shift the burden of defending these landscapes onto individual communities while allowing incremental losses over time. Please withdraw the proposed rescission and maintain full protections for all currently designated inventoried roadless areas. These public lands belong to all Americans, and their ecological, cultural, recreational, and inspirational value should be safeguarded for generations to come. Thank you for considering my comment. Jenna Marie Kesgen Asheville, North Carolina

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Blue ghosts are fireflies native to Southern Appalachia. In order to find a mate, they need total darkness so males can locate the softly glowing females in the understory. My Entomologist wife and I travel every summer to Pisgah National Forest, where for a few weeks each year you can see thousands of these insects glowing together in the woods. That single fact tells you what rescinding the 2001 Roadless Area Conservation Rule would cost people like me: a quiet, safe, and genuinely wild place, replaced by the uncertainty that comes when roads open land that has so far stayed closed. The agency's own record makes the wildfire case against this proposal better than I can. The DEIS 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." The proposal nonetheless justifies rescission partly on fuels management grounds. I ask that the agency explain, in terms specific to the 18 inventoried roadless areas totaling 99,369 acres in the Pisgah alone, why it is departing from its own prior findings, and that it 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 economic justification is no stronger. 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." Set against that, the 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, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit, and it does not account for a road maintenance backlog already sitting at $6.9 billion across the national forest system. I bike in the Pisgah area of Mills River. I hike Pisgah because the natural areas provide a safe, quiet environment. The value of those uses does not vanish because it is hard to book. I ask that the agency reconcile the proposal with its own numbers before proceeding. The small-business certification compounds the problem. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Bearwallow, a 4,113-acre roadless area in Pisgah, is the kind of place where that economy runs: a mountaintop meadow with panoramic views of Western North Carolina, unique enough that we take guests there for morning hikes precisely because of the experience it offers. The guides and outfitters serving visitors at places like Bearwallow and the 2,657-acre Craggy Mountain area are not a national average. The regulatory flexibility analysis reaches its no-impact conclusion by spreading the expenditure loss across every small firm in the sector nationally, rather than assessing the permit holders operating in the affected areas. That is the wrong denominator. The agency should withdraw the certification and assess the impact on the small entities actually working in these roadless areas. Finally, 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 one such interest. North Carolina holds 38 inventoried roadless areas totaling 172,416 acres, and across the Southern region 378 municipal water intakes sit in watersheds containing affected roadless areas. People have organized their summers, their guest experiences, and their expectations of what Pisgah will be around protections the 2001 rule put in place. An agency changing course must assess the reliance interests its prior policy created, not merely invite comments about them and then ignore them in the analysis. The agency must identify and weigh the interests described in the comments it receives, including this one, before any final action. Sincerely, [Your Name] [Your City, State]

Dear Tom Schultz, My comment is submitted from the standpoint of a resident near national forest roadless areas — someone with a direct, ongoing, geographic stake in what the 2001 Rule does and what its rescission would undo. I live in a very rural forested area directly connected to Craggy Mountain. Our water ways, watersheds, and all ecological systems are attached and affected by each others. My family, our 5 kids and two dogs, all rely on the safety of the forest around us to sustain our beautiful life. As a board member of a local non-profit supporting this community I have a deep seated commitment and dedication to protect the safety of this area fro our community. There are countless heartbreaking stories I can share related to the horrific events that unfolded the hours, days, weeks, months and years after Hurricane Helene destroyed our immediate area. Coutless community members lost lives, loved ones, and all of their wellbeing and security. We work hard every day to help support those who were directly affected. The safety of this area is pivotally attached to the adjacent roadless areas and ecosystems that support them. Our drinking water is directly sourced from these areas around us. During the aftermath of Hurricane Helene, access to clean drinking water saved our lives. We rely on it to survive here, and in times when we are cut-off from the surrounding areas it is essential for every day life to continue. During the winter we lose access to our road systems for weeks at a time every year. Attached is my full comment with cited evidence and information. The forests protected by this rule aren't in decline because of it — they're intact because of it. That's the relevant fact here.

Dear Secretary Rollins and Chief Schultz, Getting away from road noise is exactly what I go to public land for, and the 2001 Rule is a big part of why that's still possible in so many places. Spending time hiking Craggy Mountain is what made me fall in love with Asheville when I first moved here. Being able to quickly get away from the city, into the clean brisk air, seeing the beauty of the Blue Ridge mountains spread out across the skyline is truly an indescribable feeling. I remember sitting at the top of Craggy Gardens, a sea of clouds below us. It was so incredibly peaceful and serene. If the roadless rule is rescinded, I lose the ability to find quiet spaces away from the city. I lose my escape. I lose the ability to connect with nature, to have amazing once in a lifetime experiences with wildlife like this past weekend seeing elk up close in a pristine landscape. The reason I go on hikes is to get away from road noise. To see and experience the undeveloped beauty of our country's incredible landscapes. I should be able to go hiking in Craggy Gardens, camping in Yellowstone, or exploring the Santa Rita Mountains near my grandmother's home, without hearing loud engines, without seeing the desctruction of the healthy ecosystems that make our country America the Beautiful. Allowing clear-cutting of forests on publlc land will greatly reduce the natrual carbon sink that the forests provide. This will have an immediate negative effect on climate warming and biodiversity loss. We know too well the impacts of climate warming in Asheville, after suffering the devastation brought on by Hurricane Helene. The microrefugia have already suffered immense canopy loss due to the hurricane. Rescinding the roadless rule would have truly devastating impacts on the biodiversity of the region. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "Wilderness"): "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for. Rescinding protections for roadless areas would be a step backward that I don't think the Department can justify — to the public, to the record, or to the forests themselves. I trust that you will act in the best interest of our forests, wildlife, and people like me, and protect our roadless areas. Thank you for keeping the roadless rule intact. With appreciation, CommentID: RLC-20261006-6GXJTA

Dear Tom Schultz, Growing up and living near and exploring Craggy Mountain is wonderful and I wouldn't trade it for the world I spend my spare time wandering and foraging on and around Craggy. Craggy belongs to us, the public, and to the wildlife who depend on it for survival. It is not for sale or development! Taking away the roadless will ruin and take away these experiences from me. It will take critical habitat from wildlife. It will harm my aquifer and it will take away income as I rely on the tourist drawn to the trails and pristine beauty of Craggy Mountain. As a working artist it will destroy my inspiration. It will also increase rather than decrease fire risk Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 7.1.2 - Suppression in fire frequency/intensity in the Craggy Mountain IRA. NEPA requires the agency to take a hard look at the effects of rescission on Gray's Lily (Lilium grayi) in the Craggy Mountain IRA. The DEIS fails this standard without site-specific analysis of 7.1.2 - Suppression in fire frequency/intensity at the severity and scope documented by NatureServe. "The mortality of wildlife resulting from collisions with vehicles is considered one of the main negative effects of roads on numerous species. Roadkill can increase the risk of local extinction by reducing effective population size and genetic diversity, while also limiting demographic and genetic rescue mechanisms. Estimates can reach to 340 million of birds killed on the roads in USA, 194 million birds, 29 million mammals in Europe and 17 million of birds and mammals in Latin America." — Scientific Data (Nature), 2024 “Human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, dominated an area seven times greater than that affected by lightning fires, and were responsible for nearly half of all area burned. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Sixty percent of the total land area of the coterminous United States was dominated by human-started wildfires, whereas only 8% of the area was dominated by lightning fires. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” The Department should keep the Roadless Rule in place. I think the record supports that, and so does the public. In earnest, CommentID: RLC-20261006-C5H9RX

I am an avid whitewater rafter, hiker, overall nature enthusiast, and Gen Z voter that lives and recreates in the beautiful Western NC. I am writing to oppose the repeal of the Roadless Rule (RIN: 0596-AD66). The administration claims that repealing this rule will allow for "necessary" wildfire prevention measures to be taken. However, there have been multiple studies conducted that state that, under the current rule, protected and unprotected lands burn at similar rates. The claim that recinding this rule will solve the issue of rampant wildfires is simply not backed science. Should these protections be stripped, more than 152,000 acres of WNC alone will become vulnerable to logging, degrading water quality, and other forms of habitat loss. Places like the Art Loeb Trail, Joyce Kilmer Memorial Forest, and the Craggy Mountain Wilderness area draw droves of tourists every year to our historic mountains, feeding local economies. Trout fishing is a billion-dollar industry in our state. Repealing this rule puts our waterways at risk of severe pollution and may further impact our fisheries that have already seen climate-related problems. The Blue Ridge Parkway is known for its expansive views of rolling green mountains, and serves as one of the most accessible ways for people to experience the beauty of WNC and Western VA. Should the roads in these areas expand beyond the Parkway, how would these views be impacted? If we open up these places to road construction, these beautiful landscapes may lose their appeal, altering the economies of the small towns that are almost totally reliant upon tourism as well as harming local plant and wildlife. While I understand the importance of reducing wildfire impacts across our nation, I do not believe that a total, or even partial, repeal of the Roadless Rule is the way to do so. Plant and animal life in our nation has already been met with an incredible amount of strife within the last months. Between the gutting of the Endangered Species Act and the reduction in acreage in places like Bears Ears Monument and Big Bend NP, we have already placed so many species in a vulnerable position. In a time of innovation, why can we not find more flexible ways of applying the Roadless Rule or more creative means of wildfire prevention? There simply has to be another way. This is one thing that a majority of the American population can agree on; a rarity in this day and age. Opposition to this repeal comes from both sides of the increasingly divided political spectrum. I urge you to listen to the American people. We do not want this. We want protected land. We want clean water. We want the Roadless Rule to stay.

I am writing to express my firm opposition to any proposal that would rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. For over two decades, rigorous research has proven that intact roadless areas are essential for wildfire mitigation, clean water security, and climate resilience against extreme weather. We cannot afford to repeat the ecological missteps seen in heavily deforested regions globally and domestically. Preserving these uninterrupted landscapes is both an ecological necessity and a vital economic safeguard. In North Carolina, our 32 designated Roadless areas drive robust local economies—a role that is especially critical in Western North Carolina as our communities continue recovering from Hurricane Helene. As a resident of Candler, NC, who has spent over 15 years exploring the Craggy Mountain area in the Pisgah National Forest, protecting these wild spaces is deeply personal to me. The long-term costs of habitat fragmentation far outweigh any temporary financial gains from deregulation. I urge the U.S. Forest Service and the USDA to uphold full protections for all inventoried roadless areas to safeguard these irreplaceable lifelines for future generations. Thank you for considering my comment.

Dear Secretary Brooke L. Rollins, Our public lands are a valuable asset to Asheville, all of Western Carolina, and our entire country. Roadless area allow the forest environment to flourish, making it safer for wildlife and reducing the trash tossed from cars and protecting against fires from inconsiderate campers. Craggy Mountain is the first place we take visitors. The trail from Douglas Falls to the Pinnacle is a wonder. The pinnacle offers spectacular 360° views that are superb. Please help protect the roadless areas! Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 Rescinding the Roadless Rule would open the Craggy Mountain, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Our roadless areas are essential to clean water, healthy forests, and safe wildlife. The roadless areas deserve protection. That's what the Rule gives them. Keep it. Thank you, Doug Barlow