Read the comments.

Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220 The recreation visitation figure supporting the Alternative 3 economics is unsourced, and the visitor-use citation it points toward does not resolve. Repealing the Roadless Act will devastate local economies including where I’ve spent much of my life, and currently vote, the northwest counties of North Carolina. Pisgah National Forest, Wilson Creek, Lost Cove and Harper creek are three designated areas that will be impacted. I’ve reviewed the arguments for and against rescission. Those for it seem specious and thinly veiled. Returning local well-paying jobs for timber harvesting to local communities? Wistful nostalgia for Paul Bunyan's days. And one of the most dangerous occupations. This will be mechanized, industrial clear cutting. With soil depleting, animal-and-plant life be-damned devastations. Their native state will not be recoverable in my lifetime, yours, your grandchildren, or ever for some species of plants and animals. We don’t need to go back to the 19th century so timber and mining companies can revert to their harmful practices but using massive modern machinery. Preserving the current state of these lands will be a legacy to be proud of. Defeating this rescission is an effort will trickle down the generations in a positive way. In stated terms for rescission regarding state sovereignty and local governments, the network of small businesses that thrive on use of these roadless areas for recreational hiking, hunting, fishing, camping and other activities is far more important than having corporations strip the resources out of their rural economies. This is an extremely important part of the economy in the NC High Country. In fact, many areas targeted are not roadless but provide enough access for recreational use. No new roads needed to add to the existing burden on the U.S. Forest Service to maintain the ones already in place because of budget constraints and limited resources. The people profiting will not be local. May not even be American, especially in mining? They certainly won’t be the families in Watauga and Avery counties who can’t afford European vacations but love being near, on and in local creeks and rivers. When those waterways are filled with silt, devoid of fish, slimed with algae, and never a Hellbender to be found again, someone will have some explaining to do about the thinly veiled excuses for changing the Roadless Act that has worked well so far in the 21st century. When these areas are irreparably damaged, what will happen then? Jobs? No. Tourists, hunters, anglers, backpackers and the small companies that support them? Gone. You can bet Washington will no longer be talking about wildfire management and access for forest management in the face of climate change, which involved administration officials supporting the rescission likely deny is even happening. Government overreach? The original Roadless act was a protective, responsible, ‘parental’ hand over lands millions of Americans use and love. We also love areas that can’t be used because they are wild and remote. We like them that way. The rescission would be a fist slammed down for an obvious massive giveaway to corporations. Neglectful of local communities, forest management, and unconcerned about the economic and recreational opportunities that will be lost. That’s abusive. There are almost 20,000 acres near my home in Blowing Rock, NC that will be affected in Pisgah National Forest, Wilson Creek, Lost Cove and Harper Creek. Other areas important to me are in the Nantahala and southern Pisgah region. Almost my entire adult life I have made some of my most cherished memories hiking, whitewater kayaking, trout fishing, and camping in the mountains of North Carolina. My entire life I’ve enjoyed the Blue Ridge Parkway; asphalt I do love. The USFS map showing areas that will be impacted are heavily dotted along the Parkway in NC. I can't imagine what rescission could do to the viewsheds. Encroachments from rapid development, loss of agrarian life, and too-narrow protected corridors has already changed it. Clear cutting, road building, mining, documented INCREASED wildfires after more roads will be awful. The Parkway is a CRITICALLLY important economic driver in our area. I love our southern Appalachian Mountains. Repealing the Roadless Act is a short-sighful obvious handout to corporate interests. There is no plausible significant benefit economically, ecologically, recreationally, for MILLIONS of Americans who use these lands. Or for the flora and fauna that make them so distinct in our southern Appalachians. Stay the course by keeping the Roadless Act intact. Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220

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 protection and integrity of our inventoried roadless areas. I frequently visit Linville Gorge, Wilson Creek, and Harper Creek near my home in Boone, North Carolina, and protecting these unfragmented landscapes is deeply personal to me. I depend on these watersheds for clean drinking water from my private well. My work in local government is also connected to tourism, which benefits from the beautiful, relatively untouched natural landscapes that make our region special. Beyond my work and daily life, I hike and fish on backcountry trails and value the pristine wildlife habitat that these roadless areas provide. These lands are more than places to visit. They are essential watersheds, wildlife habitat, recreational resources, and an important part of the character and economy of our communities. Once roadless landscapes are fragmented, their ecological and recreational values can be difficult or impossible to restore. I urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon any proposed rescission or weakening of the 2001 Roadless Area Conservation Rule and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment and for considering the perspective of those who live, work, and recreate in and around these public lands. Sincerely, Cory Cathcart Boone, NC

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 the the Linville Gorge, Wilson Creek, and Harper Creek areas of Pisgah National Forest near my home in Boone, North Carolina. I also travel frequently to enjoy our public lands across the nation, and for many years was lucky enough to call the White River National Forest of Colorado home. There aren't words to describe how deeply personal protecting these unfragmented landscapes is to me because not only do I depend on these watersheds for clean drinking water (I have a well, my parents have a spring fed tap), I also frequently explore the backcountry trails with my two dogs, and our community depends on the tourism that comes from the beauty of this ancient mountain region. I also put immeasurable value in our pristine wildlife habitats, that provide our unique biodiversity and enjoy the bears, fox, owls, deer, coyote, woodpeckers, hummingbirds, hellbenders, and countless other priceless species that I call neighbors. I BEG the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to listen to your citizens and abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Please place the natural value of our wild and beautiful nation above the material value in order to provide not only this generation but your children's generation, the opportunity to learn & grow from these unspoiled lands. We are all counting on you to see reason. Sincerely, McClure Jackson-Cathcart, RVT Boone, North Carolina

I am one of millions of Americans who value our public lands. I stand against rescission of the “roadless rule”. This rule, which was implemented after nearly 1 million public comments and over 600 stakeholder meetings, provides important protections for clean water as well as fisheries and wildlife habitat. The proposed rescission makes no financial sense, since the US Forest Service is severely underfunded and cannot currently maintain existing roads. The other premise behind the rescission is that new roads are needed to fight wildfires. USFS studies have proven that roads increase wildfire risk. Building roads in inventoried roadless area will have a significant impact on iconic species such as elk which depend on roadless areas of public lands and predator species like the grizzly bear. I am a North Carolinian and blessed to have national forests in each of the three geographic regions of the state. Pisgah and Nantahala National Forest contain abundant cold water fish habitat. Wild southern brook trout make their homes in the cold water headwater creeks of North Carolina’s high country. Specks as we call brook trout require highly oxygenated and sediment/pollution free waters to thrive. Building new roads would threaten these vital habitats. One area that I like to “blue-line” (the term we use for fishing the tiny creeks on USGS indicated by a blue line) is the Wilson Creek drainage. There are several areas that would be impacted by the rescission of the roadless rule. I’ll focus on one of the larger inventoried roadless areas that I am familiar with and why it would be infeasible to build roads there: Harper Creek is a 7,005-acre Inventoried Roadless Area in the Pisgah National Forest, in the Lower Wilson Creek watershed (HUC-12 030501010504), Grandfather Ranger District. This area is centered near 35.982N, 81.800W, with boundaries spanning roughly 35.948N to 36.014N latitude and 81.853W to 81.762W longitude. It drains into the Harper Creek. This IRA overlaps Wilson Creek Welcome Center, which could further affect the feasibility of road construction. 100 percent of this IRA (7,005 acres) has high erosion potential -- above 10 tons per acre per year based on the RUSLE model -- indicating high sensitivity to road building and other disturbance that could send sediment into downstream aquatic habitats. 22 percent of this IRA (1,569 acres) has a maximum road grade of 60% or greater, requiring high-cost engineered switchbacks or making conventional road construction infeasible. In North Carolina alone there are over 50 inventoried roadless areas totaling over 173,000 acres. I strongly encourage the Forest Service to keep our roadless areas wild, productive and accessible for generations to come and support the No Action Alternative.

To the U.S. Forest Service: I strongly oppose any changes to the 2001 Roadless Area Conservation Rule that would weaken the protections it affords to forests on lands that are owned by the American people. My home shares the South Toe River watershed with the Bear Wallow and Balsam Cone roadless areas in the Pisgah Ranger District in Yancey County, NC. In 27 years of hiking and camping, I have come to know these areas like beloved old friends. The 14,704 acres of land protected by these two roadless parcels were crucial to protecting our valley from the worst effects of Hurricane Helene. These areas undisturbed forest withstood over 30 inches of rain in 48 hours with many fewer landslides than elsewhere in the county. In the South Toe valley, no one died in a debris flow. Sadly, on the other side of the Black Mountain Range, in the Cane River valley, which is not protected by the Roadless Rule, at least three people died in debris flows. On hikes since Helene, I have observed dozens of instances where landslides began where logging roads cut into the natural slopes of the mountainsides. As a psychotherapist, I provide support to a client who lost her home to a debris flow in the Cane River Valley. Losing her home has exacted a major toll on her mental health, from which she still has not fully recovered two years later. Roadless areas protect not only native plants, animals, and other organisms, they also protect human life and wellbeing. While Yancey County suffered Helene's worst flooding, neighboring forests in Mitchell County suffered massive blow-downs. As discussed above, these disturbed areas are incredibly vulnerable to infiltration by exotic invasive plants. If the biodiversity of USFS forests in Mitchell County ends up being compromised long-term by invasive exotic plants, it is more important than ever to protect adjacent roadless areas, including Slide Hollow, Wilson Creek, Lost Cove, Harper Creek, Linville Gorge Addition, Dobson Knob, Woods Mountain, Mackey Mountain, Jarrett Creek, and Craggy Mountain. The grandchildren and great grandchildren of Yancey, Mitchell, Avery, McDowell and Buncombe residents, of the United States -- and of the world -- deserve to know what a healthy, biologically intact Southern Appalachian Forest looks, smells, tastes, sounds, and feels like. Hurricane Helene's flooding washed hellbender salamanders, lampreys, and tiny non-game native fish out of the river and onto our road. I'd never seen these elusive creatures up close before. Ten days after the storm, I witnessed huge hellbender climbing over boulders, possibly on an epic journey back to its home territory upstream. The purity of South Toe River water is a direct result of the protections to water quality provided by the Balsam Cone and Bear Wallow roadless areas. These roadless areas buffer the South Toe River's waters from sediment and other water pollutants, which allows the South Toe River to support rare and endangered salamanders, mussels, and fish that occur in only a select few other watersheds in North Carolina. I am a passionate naturalist, deeply concerned about the threat to native botanical biodiversity caused by exotic invasive plant species. I have observed with dread as publicly-owned forests in Western NC are increasingly choked with Asiatic Bittersweet, Kudzu, Japanese Stilt Grass, Japanese Barberry, Japanese honeysuckle, and other invasive exotic plants. Where these plants flourish, they create a monoculture of themselves, threatening forest plant communities unique to the Southern Appalachians, as well as all the rare and endangered animals, birds, spiders, insects, herps, fungi and other organisms that have adapted to live within or migrate through them. Fortunately, the relatively intact forests within the roadless areas at Bear Wallow and Balsam Cone appear to be fending off the worst invasive plant infestations. As the South Toe River Road has reopened, I have been dismayed to see new areas where invasive plants have begun to propagate, accelerated by the accidental introduction of seeds or plant material during road repair after Helene, and by extra sunlight where the South Toe River Road creates a break in the canopy. Right between Bear Wallow and Balsam Cone roadless areas, the South Toe River Road provides a perfect illustration of why roadless areas are imperative to preserve the remaining rich biodiversity of the Pisgah Ranger District. These are the stories I know, but I know that all over the US, every roadless areas is providing equally crucial ecological services, protecting equally wild ecosystems, and bringing joy, health, and well-being to citizens who live near or visit them. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to maintain full protections for all currently-designated inventoried roadless areas. Thank you for accepting my comment. Sincerely, Jessica Ruegg

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mammals are what bring me into the backcountry. I keep a species life list, and the roadless areas of Pisgah National Forest in North Carolina and Superior National Forest in Minnesota are places I go looking for them: gray wolf, moose, Canada lynx, and black bear in the Superior's lake country around Phantom Lake, Hegman Lakes, and the South Kawishiwi River; black bear and the more than 30 endemic salamander species of the Southern Appalachians in the hollows and gorges around Wilson Creek, Harper Creek, Lost Cove, and Linville Gorge Addition. The agency is now proposing to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition. The proposal uses wildfire and fuels management as part of its justification for rescission. 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." That finding is in the agency's draft environmental impact statement. The proposal moves toward more roads, not fewer, while citing fire risk as a driver. I ask that the agency explain, with specificity, why this proposal departs from its own prior findings on fire occurrence inside roadless areas, and that it reconcile the rescission with the ignition density data reported in its own DEIS Table 21, which shows far higher fire density on roaded land. The economics do not hold together either. 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." I work hard and the government takes my money, and I want it going to things that actually benefit me and my community. The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. A range that includes a $92 million loss does not establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of approximately $73 million a year. The agency must reconcile its proposal with those figures and explain how opening 40.1 million acres to new road construction serves the public when the maintenance backlog already overwhelms what the agency can afford. Water is the most integral resource for the entire world. If we destroy it, we destroy ourselves. Across the Southern region alone, which includes North Carolina, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres protecting headwaters that flow to both the Atlantic and the Gulf. Fewer than 12 percent of those watersheds have impaired streams today. The agency has not explained how it proposes to keep that number from rising once road construction is permitted in areas currently protected. The agency must answer that question directly. The agency's own DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then goes nowhere. No projection across the 40.1 million acres of potentially affected environment follows from it. The Southern Appalachians where I look for mammals are among the most biodiverse temperate forests in North America, and the Superior's roadless areas are the hydrological engine of the entire Boundary Waters Canoe Area Wilderness system. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and show what that means for the species verified to live there. Finally, the agency's 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, like the fragmentation data, appears and is then left unresolved. No population-level projection for big game follows anywhere in the document. The agency must project what the proposed rescission means for big game populations and for the hunting opportunity that depends on them, and it must do so before this rulemaking advances further. Sincerely, Taylor Apel Ely, MN

Secretary Rollins and Chief Schultz, U.S. Forest Service I write to oppose proposed rescission or restriction of the 2001 Roadless Area Conservation Rule. I reside in Madison Co, NC. My recreation activities (hiking, mountain biking, native plant exploration, bird watching) include frequent visits to both Pisgah and Nantahala National Forests. The stated rationales for the Roadless Rule change are unsupported. Fragmentation of existing roadless areas jeopardize those activities for me and countless numbers of American citizen visitors from our community and nationwide. Local concerns: 1. The DEIS violates 40 C.F.R. § 1502.15(b) in that it fails to consider post Hurricane Helene disaster impacts on our Forests including severe structural landslides and geological unstable slopes, among them at Craggy Mountain, Big Ivy, and Harper Creek. 2. Road construction clears riparian vegetation, exposing slopes that erode soil resulting in sediment entering streams, jeopardizing water quality throughout numerous potentially impacted areas throughout Pisgah and Nantahala Forests, including the South Mills River area in Pisgah. 3.Existing roadless areas throughout Pisgah and Nantahala Forests create habitat that protects numerous designated Federal endangered species or proposed Federal endangered species, including: (a) ESA-listed salmonids, (b) salamander species and (c) five species of bats. Nationally: 1. The DEIS states that the purpose of rescinding the Roadless Rule is "to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials." The DEIS posits that a "single, national blanket approach... constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service's multiple-use mission," and that the Roadless Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Nowhere are those assertions supported by empirical evidence in the DEIS. I formally request that the FEIS and the final regulatory analysis provide that empirical evidence. 2. The DEIS expressly acknowledges that considerable disturbances are caused by road construction, timber harvest and prescribed burning: common are "loss of vegetation, soil erosion and compaction, loss of soil productivity, increased potential for landslides, reduced transpiration... increased water runoff, reduced water quality, and periodically reduced air quality." I have noted above the impacts that concern me as to our Pisgah and Nantahala Forests. 2. The DEIS further states that "insufficient maintenance funding is a key reason for the lack of adequate road maintenance…" in National Forests. It defies logic to assert that building more roads for potential timber cutting makes sense when the cost/benefit assessment does not suggest economic benefit. (The DEIS cites Federal Highway Administration notes that "some data sources indicate construction costs in mountainous terrain can be 3 to 10 times more per mile than flat terrain.") The USFS should instead be laser-focused on securing from the Federal government the potentially billions of dollars need immediately to fund maintenance back log on existing roads. 3. The DEIS acknowledges the science that fragmentation reduces biodiversity with effects "greatest in the smallest and most isolated fragments." The impact on biodiversity in many of the small roadless areas targeted in the current maps far outweigh arguments in favor of the Rule repeal in those areas. 4. Further DEIS statements acknowledge evidence that roads produce more (human ignition) wildfires than roadless areas. Wildfires occur far less frequently in roadless areas. Fire management is needed because of roads. In sum, the proposed actions need to be fully evaluated in the Final Environmental Impact Statement, as required by Federal Law, to fully analyze and document the fragmentation of existing roadless areas & losses of critical natural habitat, water quality impacts due to future development, increases in wildfire damages and a quantifiable cost/benefit analysis of potential timber operations. For the foregoing reasons among others, the only action that should be taken with respect to the repeal proposal should be No Action. Sincerely, Penelope Glass

Pisgah National Forest and all the beauty it has been offering, especially Harper Creek, has much wonder with all its wildlife and water to community. The Forest Service should analyze sediment effects on the municipal water intakes before deciding rescinding the Roadless Rule.

My family and I have gone to Lost Cove and Harper Creek for decades. It is my kids' favorite place in the whole world, right here in North Carolina. These are both Wilderness Study Areas and Inventoried Roadless Areas. However, repealing the Roadless Rule would remove their roadless layer of protection, and that is a huge risk to this special place. The Upper Wilson Creek is a beautiful, wild area we MUST keep roadless. It helps provide a roadless buffer alongside the Lost Cove and Harper Creek WSAs. New roads can fragment wildlife habitat, increase sedimentation and diminish the wild character of these lands we treasure. Please do not change the rules and hurt this part of North Carolina we love so much.

RE: Strong Opposition to Rescinding 36 CFR Part 294 (Subpart B) I am writing as a Western North Carolina (WNC) resident, hiker, mountain biker, backpacker, angler, hunter, parent, and supporter of youth outdoor programs to express my strong opposition to the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (RACR). Our family, friends, local scouting groups, and outdoor enthusiasts rely on the remote headwaters, ridges, and valleys of the Nantahala and Pisgah National Forests for backcountry adventure and solitude. Safeguarding remaining wild tracts—such as Craggy Mountain, Snowbird, Harper Creek, and Panthertown Valley—is essential for our personal recreation, local water security, and ecological resilience. I urge the Department of Agriculture to withdraw this proposed rule based on the following key arguments: 1. Severe Economic Risks to Outdoor Recreation -Projected Economic Loss: In the draft economic analysis for FR Doc # 2026-16965, the Forest Service estimates an immediate $6.1 million annual loss in recreation-related economic value across affected areas if nationwide roadless protections are lifted. -Regional Impact: North Carolina outdoor recreation generates over $11.8 billion in economic output and supports 100,000+ jobs (U.S. BEA). In WNC counties, tourism driven by intact backcountry trails, mountain biking, hunting, and fishing is a vital economic driver. Opening Inventoried Roadless Areas (IRAs) to commercial logging infrastructure and roads threatens the authentic backcountry experience that draws millions of visitors and sportsmen. 2. Threats to Municipal Watersheds, Fisheries & Wildlife -Water Quality: Roadless areas safeguard high-elevation headwaters feeding municipal drinking water supplies. WNC features steep terrain and high precipitation; unpaved timber roads on these slopes accelerate soil erosion, siltation, and landslide risks during extreme storms, threatening water treatment infrastructure. -Native Fisheries: Headwater streams in roadless tracts harbor wild and native brook trout. Fine sediment from unpaved logging roads and stream crossings degrades spawning gravels and ruins cold-water aquatic habitats. -Hunting Habitats: Big and small-game hunting depend on undisturbed, contiguous forest blocks. Fragmenting remote habitats with industrial access roads increases human disturbance, reduces core wildlife ranges, and degrades backcountry hunting opportunities. 3. Biodiversity, Carbon Sinks & Ecosystem Integrity -Biodiversity Hotspots: The Southern Appalachians are globally recognized for endemic plant species and sensitive native populations, including Southern Appalachian salamanders that cannot survive microclimate changes caused by forest fragmentation. -Canopy Fragmentation: Linear road corridors create edge effects that dry out forest floors, disrupt wildlife migration, and serve as vectors for invasive plant and insect species. -Carbon Sequestration: Mature unroaded forests act as vital, stable carbon sinks. Commercial logging and road building disturb deep forest soils and biomass, releasing stored carbon. 4. Impact on Youth Education & Backcountry Heritage -Wilderness Classrooms: Roadless areas provide invaluable classrooms for local youth programs, scouting adventures, and wilderness backpacking trips. Experiencing solitude and learning Leave No Trace principles in unroaded backcountry teaches young people vital lessons in self-reliance and conservation. -Preserving Traditions: Hunting, fishing, backpacking, and non-motorized trail recreation connect us to an outdoor heritage rapidly disappearing elsewhere. Introducing industrial logging access diminishes the quality of these primitive experiences. 5. Road Maintenance Backlog & Wildfire Considerations -Deferred Maintenance: The U.S. Forest Service faces a nationwide deferred road maintenance backlog exceeding $3.2 billion. Stripping federal roadless protections to allow additional unpaved timber access roads in rugged, high-elevation terrain will worsen this burden, leading to neglected trails and failing culverts. -Wildfire Ignition Risks: While proponents argue logging roads aid fire management, ecological research demonstrates that human-caused wildfire ignitions increase significantly in remote areas once opened to vehicle access and industrial human activity. Conclusion The 2001 Roadless Area Conservation Rule has provided a balanced national baseline for protecting pristine national forest lands for over two decades. Rescinding this protection exposes our mountain landscapes, recreation economy, native fisheries, hunting grounds, municipal watersheds, and youth outdoor programs to unnecessary risk. For my family, our community, local scouts, anglers, hunters, outdoor enthusiasts, and future generations who cherish these public lands, I strongly request that the U.S. Forest Service withdraw FR Doc # 2026-16965 and maintain the 2001 Roadless Area Conservation Rule in full.

I am writing as a Western North Carolina (WNC) resident, hiker, kayaker, biker, backpacker, angler, parent, and supporter of youth outdoor programs to express my strong opposition to the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (RACR). Our family, friends, local scouting groups, and outdoor enthusiasts rely on the remote headwaters, ridges, and valleys of the Nantahala and Pisgah National Forests for backcountry adventure and solitude. Safeguarding remaining wild tracts—such as Craggy Mountain, Snowbird, Harper Creek, and Panthertown Valley—is essential for our personal recreation, local water security, and ecological resilience. I urge the Department of Agriculture to withdraw this proposed rule based on the following key arguments: 1. Severe Economic Risks to Outdoor Recreation -Projected Economic Loss: In the draft economic analysis for FR Doc # 2026-16965 (tel:2026-16965), the Forest Service estimates an immediate $6.1 million annual loss in recreation-related economic value across affected areas if nationwide roadless protections are lifted. -Regional Impact: North Carolina outdoor recreation generates over $11.8 billion in economic output and supports 100,000+ jobs (U.S. BEA). In WNC counties, tourism driven by intact backcountry trails, mountain biking, hunting, and fishing is a vital economic driver. Opening Inventoried Roadless Areas (IRAs) to commercial logging infrastructure and roads threatens the authentic backcountry experience that draws millions of visitors and sportsmen. 2. Threats to Municipal Watersheds, Fisheries & Wildlife -Water Quality: Roadless areas safeguard high-elevation headwaters feeding municipal drinking water supplies. WNC features steep terrain and high precipitation; unpaved timber roads on these slopes accelerate soil erosion, siltation, and landslide risks during extreme storms, threatening water treatment infrastructure. -Native Fisheries: Headwater streams in roadless tracts harbor wild and native brook trout. Fine sediment from unpaved logging roads and stream crossings degrades spawning gravels and ruins cold-water aquatic habitats. -Hunting Habitats: Big and small-game hunting depend on undisturbed, contiguous forest blocks. Fragmenting remote habitats with industrial access roads increases human disturbance, reduces core wildlife ranges, and degrades backcountry hunting opportunities. 3. Biodiversity, Carbon Sinks & Ecosystem Integrity -Biodiversity Hotspots: The Southern Appalachians are globally recognized for endemic plant species and sensitive native populations, including Southern Appalachian salamanders that cannot survive microclimate changes caused by forest fragmentation. -Canopy Fragmentation: Linear road corridors create edge effects that dry out forest floors, disrupt wildlife migration, and serve as vectors for invasive plant and insect species. -Carbon Sequestration: Mature unroaded forests act as vital, stable carbon sinks. Commercial logging and road building disturb deep forest soils and biomass, releasing stored carbon. 4. Impact on Youth Education & Backcountry Heritage -Wilderness Classrooms: Roadless areas provide invaluable classrooms for local youth programs, scouting adventures, and wilderness backpacking trips. Experiencing solitude and learning Leave No Trace principles in unroaded backcountry teaches young people vital lessons in self-reliance and conservation. -Preserving Traditions: Hunting, fishing, backpacking, and non-motorized trail recreation connect us to an outdoor heritage rapidly disappearing elsewhere. Introducing industrial logging access diminishes the quality of these primitive experiences. 5. Road Maintenance Backlog & Wildfire Considerations -Deferred Maintenance: The U.S. Forest Service faces a nationwide deferred road maintenance backlog exceeding $3.2 billion. Stripping federal roadless protections to allow additional unpaved timber access roads in rugged, high-elevation terrain will worsen this burden, leading to neglected trails and failing culverts. -Wildfire Ignition Risks: While proponents argue logging roads aid fire management, ecological research demonstrates that human-caused wildfire ignitions increase significantly in remote areas once opened to vehicle access and industrial human activity. Conclusion The 2001 Roadless Area Conservation Rule has provided a balanced national baseline for protecting pristine national forest lands for over two decades. Rescinding this protection exposes our mountain landscapes, recreation economy, native fisheries, hunting grounds, municipal watersheds, and youth outdoor programs to unnecessary risk. For my family, our community, local scouts, anglers, hunters, outdoor enthusiasts, and future generations who backpack and cherish these public lands, I strongly request that the U.S. Forest Service withdraw FR Doc # 2026-16965 (tel:2026-16965) and maintain the 2001 Roadless Area Conservation Rule in full.

For as long as I can remember, I have spent my springs, summers, and falls exploring in the Upper Wilson Creek Inventoried Roadless Area. I’ve hiked to Hunt Fish Falls and Gragg Prong Falls and swum in the sparkling clear and refreshing water there. I’ve learned about indicator species and closely examined how these streams and waterfalls are among the cleanest in the state. These are some of my favorite places in the North Carolina mountains. The Forest Service has acknowledged that roads are major sources of sediment that can contaminate these water sources and change the function of the ecosystem. I’m concerned that opening roadless areas to additional road construction will very likely harm the streams and waterfalls that make Lost Cove and Harper Creek so special. One of the features of Roadless Areas that I love most is how wild and peaceful they feel. When I am out hiking and swimming in these areas I feel a deep connection to the land and the wildlife that has inhabited it for much longer than humans. The North Carolina mountains are among the oldest mountains in the world, and the biodiversity that these Roadless Areas contain is extraordinary. The existing Roadless Rule already allows some road construction and timber cutting when needed for public safety, resource protection and ecosystem restoration. I would like the Forest Service to explain why those exceptions are inadequate and why eliminating the rule nationwide is necessary. My experiences hiking, swimming, and camping in Upper Wilson Creek, Lost Cove and Harper Creek has shown me what we stand to lose. These places have clean water, healthy forests and a degree of wildness and solitude that is increasingly rare in our rapidly developing and urbanizing world. Please retain the 2001 Roadless Rule and select Alternative 1, the ‘No Action’ alternative.

I grew up spending summers in western North Carolina's pristine forests, specifically near the Upper Wilson Creek, Lost Cove Creek and Harper Creek wilderness areas. I learned to fish, hike, climb, sleep in a tent, hang out by a campfire, and enjoy the serenity of nature in these places. I would like these areas to remain as undisturbed as possible. There are a sufficient number of roads to access private property and public hiking trails. We should keep and preserve what we have. We do not need additional development in beloved places, especially ones with as much biodiversity and history as in this part of Pisgah National Forest. As wildfires become more common and water becomes more scarce, more roads increase the risks to both. This proposed change would also come at considerable cost to the taxpayer with the necessity of new construction and maintenance. Let's preserve the beauty of our rural areas and natural ecosystems.

Over 230,000 of a total 800,000 acres in the White Mountains are protected by the Roadless Rule. These protected areas include some of the country’s most cherished hiking destinations, including my own. I have hiked the Welch-Dickey loop, where every turn is a new beautiful view that is protected by the Roadless Rule. I have experienced the silence and awe of being in a remote wilderness on the edge of Kings Ravine. I have shared high fives with out of breath friends on the summits of the Franconia Ridge, and have had the pleasure of teaching backcountry skills to women who have never before spent a night outside, only to learn what happens when you hike miles and miles into the woods without the sound of cars or light pollution from town, witnessing a forest breathe with its natural rhythm. I value many other areas in the nation protected by this rule, such as Harper Creek and Mt. Mitchell in North Carolina, Maple and Easy Pass in the North Cascades, trails surrounding Mt. Bachelor in Oregon, and the sweeping vistas on the peaks of remote Montana wilderness, though I have found work, entrepreneurship, and endless joy and comfort in the Roadless Rule areas surrounding me and my community in the White Mountains. So I will voice several of my concerns with rescinding the rule that protects these places for the following reasons: Our Lands: Lands protected by the Roadless Rule include old growth forests that are priceless and should be protected at all costs. They occupy only 1% of our forests, even though they regularly change the microbiome temperature by 2.5 degrees. They have multi layered canopies, undisturbed healthy topsoil, provide more net carbon storage than many other uses of land in the U.S., and hold religious and cultural significance. Additionally, our old growth forests can resist severe wildfires better than young or industrial tree plantations due to their thick bark, high moisture, and high canopies. Our Animals: The Roadless Rule in the White Mountains also supports the area's imperiled species like the northern long eared bat, Bicknell’s thrush, brook trout, Canada lynx, and American marten. Having continuous forest allows these species to remain undisturbed by structures, human interaction, and degradation of their current habitat and territories. Our Water: According to the EPA, over 600,000 people, including over 7% of NH residents, use the Merrimack River for drinking water, and it consists of water runoff from the unfragmented sections of the White Mountains. Keeping roads out of these areas helps prevent toxic runoff and heavy sedimentation from leaching into these crucial public water supplies. Our Economy: According to a study from 2017, outdoor recreation in the NH economy generated about $4.2 billion in direct output and directly supported over 33,000 jobs, making up a total of 3.5% of our state's GDP. It is also worth mentioning here that the Forest Service currently has over $10 billion in road maintenance backlog. If we reduce the quality of recreation with unnecessary construction, trail closures, or other unnatural nuisances, there is a lot of money on the line, and as a future business owner in the outdoor industry myself, I rely on this economy to open my doors in mid 2027. I am aspiring to open an outdoor recreation learning center and consignment outfitter. If our roadless areas in the western part of the WMNF are disturbed enough, it would not be possible for me to open my doors. New England Would Know: We have experienced what it is like to have cars, people, hotels, cafes, and stores at the summit of a mountain. In some ways, it is lovely that there is a way for less able bodied people to experience the alpine environment, though in most ways, it's a battle and the delicate alpine environment is quickly losing. There are plants, such as Diapensia lapponica, Bigelow sedge, Robbins cinquefoil, mountain cranberry, and mountain bilberry, on Mt. Washington and dozens of other surrounding alpine peaks that adapted to withstand rime ice, short growing seasons, 200 mph winds, snow, freezing rain, hail, etc. What these plants have not adapted to is footprints. Studies have shown the degradation of these plants and their struggles with overcrowding due to the introduction of human trampling and invasive species such as dandelions and 74 other non native plant species that are now found on these summits. It is as simple as walking in a yard with these plants and hopping in the car to take the auto road to where the seeds on your shoes can spread on the mountain. When no roads are present, one must hike from the base of the mountain and climb through less delicate terrain before approaching the fragile alpine plants, in which scenario the invasive seeds will most likely fall off before you get to the fragile areas. There is already enough access for necessary services, our ecosystem needs human reprieve and restoration instead of additional construction and roads.

I strongly oppose rescinding the Roadless Rule and jeopardizing the beautiful places in the United States that I've had the privilege of hiking, camping, and exploring. In the North Carolina mountains, I’ve hiked to Hunt Fish Falls and Gragg Prong Falls and swum in the incredibly clean, clear water alongside fish, snakes, and birds that call these waters home. In addition to protecting environments to preserve their tourist and recreational value, the Forest Service acknowledges that roads are major sources of sediment. By opening these roadless areas to additional construction, we will damage the streams and waterfalls that make Lost Cove and Harper Creek so special. While there are concerns, especially out West about wildfires, the Forest Service’s own analysis says rescission would result in only a ‘modest’ increase in wildfire prevention. I don't believe that a nationwide repeal of the rule is justified, especially when more roads can increase human-caused wildfire ignitions. I know that the existing Roadless Rule already allows some road construction and timber cutting when needed for public safety, resource protection and ecosystem restoration. This rule has been functioning as intended since 2001 and continues to allow for the environmental protection, water quality assurance, and public land access that we deserve as stewards of our public lands. I strongly oppose eliminating the Roadless Rule.

Request Alternative 1, NO ACTION. My family has been visiting the lost cove / upper Wilson creek area for 20 years every summer. Hiking cragg prong, hunt fish falls, Harper creek and other precious sights. Roadless rules should remain to preserve this special place.

I live in the Charlotte, North Carolina area, and the Catawba-Wateree River Basin is my local watershed. Roughly 50,000 acres in this basin, including Wilson Creek, Harper Creek, and the Linville Gorge Addition, would be opened to logging and road construction if this rule is rescinded. These lands protect the headwaters that feed the rivers my community depends on for drinking water and recreation. The science on this is not close. Forest Service research shows roadless watersheds function properly at nearly twice the rate of roaded ones. Road construction introduces sediment, spreads invasive species, and fragments habitat in ways that directly harm water quality and native aquatic species downstream. The rule already permits wildfire mitigation, grazing, and other active forest management, so rescinding it does nothing to solve the problems it's being framed as solving. It only removes a 25-year-old, broadly supported protection for land we cannot get back once it's roaded and logged. I ask that the Roadless Rule be left in place, without modification.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The dense old wood forests, rolling hills, and untouched natural beauty of places like Lost Cove and Linville Gorge are why I visit the roadless areas of Pisgah National Forest. I go to photograph wildflowers, animals, and beautiful landscapes. I have hiked in Wilson Creek, Lost Cove, and Linville Gorge, and what I find there, every time, is the kind of peaceful place that cannot be rebuilt once it is gone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these places. It has held none to undo it. I want my kids and grandchildren to have these places to hike, fish, explore, and enjoy all of the beauty that is here. That is the full weight of my objection to Docket FS-2025-0001. The Nantahala and Pisgah National Forests together hold 32 inventoried roadless areas covering more than 150,000 acres. North Carolina as a whole holds 38 inventoried roadless areas totaling 172,416 acres. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the roadless areas of Nantahala-Pisgah protect the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, along with black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. I mentioned that roads would destroy animal habitat and that endangered species live in all of these areas. The verified record for this forest confirms exactly that. I ask that the agency address, specifically, how it weighs the irreversible habitat fragmentation of these documented species communities against any claimed benefit of rescission. The agency's own economic numbers do not support this action. The record before the agency 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." Against that marginal return, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million per year, set against recreation losses of at least $6.1 million per year and a net present value ranging from -$92 million to +$199 million, while the road system already carries a $6.9 billion maintenance backlog. No net benefit is established. I ask the agency to reconcile this proposal with its own numbers and explain how an action with such an unresolved economic range justifies expanding infrastructure the agency cannot currently maintain. The agency's handling of future plan amendments is procedurally indefensible. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot honestly ask the public to comment on a consequence it has simultaneously ruled outside its own analysis. Harper Creek and the surrounding Pisgah roadless areas sit directly in the path of the expanded harvest that foreseeable amendments would permit. I ask that the agency include a full analysis of the plan-amendment scenario, with projected acreage and road-construction impacts, before this rulemaking proceeds. The climate consequences of rescission are stated and then abandoned. "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 DEIS then concludes that these lands will continue to sequester and store carbon without analyzing what logging and road construction actually do to that figure. That is not analysis; it is an assumption dressed as a finding. The agency must quantify projected changes in carbon storage and sequestration under each alternative before this rule can be finalized. Finally, the agency has reversed a factual finding without explaining why. "The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule." What has changed? The wilderness have not become less biodiverse. The roads have not built themselves back into wilderness. An agency that found local planning inadequate in 2001 owes the public a clear account of the evidence that reversed that conclusion. The agency has not provided one, and it must. Sincerely, [Mary Archer Vann [Banner Elk, North Carolina

Dear USDA Leadership: As an angler, I don't oppose road-building everywhere. I oppose road-building in country where the rule already said no, the science still says no, and the agency hasn't shown why the answer should change. The 2001 Rule has been a quiet, working piece of policy for two decades. The Department doesn't have to do anything dramatic — just leave it in place. Visiting the Wilson Creek and Harper Creek Wilderness Study Area is one of my favorite backpacking and fishing trips I've ever take. The remoteness was humbling. The Harper Creek Wilderness Study Area was one of the harder, more remote hikes I'd done at the time and gave me a great appreciation for how important it is to have these kinds of places. Regarding the Harper Creek in the Pisgah National Forest, North Carolina: “The area remains a Wilderness Study Area despite being recommended for full Wilderness designation by the U.S. Forest Service since 1987 and having bipartisan congressional support in the 1990s. On December 16, 2001, the area was protected under the Roadless Area Conservation Rule, which designated it as an Inventoried Roadless Area comprising 7,325 acres.” “Large-scale railroad logging commenced in the region around 1910. More significantly, the area became a major site for uranium prospecting from the 1950s through the 1970s. The North Harper Creek Prospect underwent extensive core drilling. Exploration identified uranium deposits in the Wilson Creek Gneiss, with speculative resources estimated at 4 to 8 million pounds of U₃O₈. The remoteness and expense of mining in this area is what has saved it.” “Influence of water exchange and dissolved oxygen in redds on survival of steelhead trout embryos. Survival of embryos relates positively to dissolved oxygen and apparent velocity of intragravel water, and positively to gravel permeability and gravel size. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1961 (https://doi.org/10.1577/1548-8659(1961)90[469:IOWEAD]2.0.CO;2)” “Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 (https://doi.org/10.1029/WR020i011p01753)” “Water and sediment inputs are fundamental drivers of river ecosystems, but river management tends to emphasize flow regime at the expense of sediment regime. Managing for a desired balance between sediment supply and transport capacity is not only tractable, given current geomorphic process knowledge, but also essential because of the importance of sediment regimes to aquatic and riparian ecosystems, the physical template of which depends on sediment-driven river structure and function. — BioScience / Oxford Academic, 2015 (https://doi.org/10.1093/biosci/biv002)” In earnest, CommentID: RLC-20260906-JAUUAF

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 the Pisgah forestlands near my home, specifically spending a great deal of time in the Wilson's Creek, Harper's Creek, and Lost Cove forests. Protecting these unfragmented landscapes is deeply personal to me because I value the pristine wilderness and backcountry trails that these areas provide. These forests are vital, not just for their natural beauty, but as essential havens for wildlife and for the quiet, undisturbed recreational experiences I cherish. Furthermore, these specific roadless tracts provide irreplaceable, contiguous habitat for numerous federally protected and vulnerable species. The unfragmented forest canopy, clean headwaters, and isolated ridgelines of areas like Wilson Creek and Harper Creek are vital to the survival of federally endangered and threatened species, including the Indiana Myotis, Northern Long-eared Bat, and Gray Myotis, as well as imperiled flora like the Blue Ridge Goldenrod and Carolina Hemlock. Road construction and industrial activity in these watersheds would directly disrupt sensitive habitats critical to species currently proposed for listing or under formal federal review, such as the Tricolored Bat, Bog Turtle, and Golden-winged Warbler. Preserving the 2001 Roadless Rule is an essential legal and ecological safeguard against the accelerated decline and fragmentation of these species' native Southern Appalachian ranges. 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 comment. Sincerely, Ken Gordon