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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

Dear Mr. Schultz: These wild places are what has always offered me peace in way nothing else has. Here is where I am able to connect to nature, observe plants, animals and habitats in their natural state. Staying roadless keeps ecosystems intact for our generation and for our children who we also want to benefit from the type of peace and inspiration only found in wild places. Since moving to WNC 15 years ago my life has been transformed by nature connection. Through time in forests uninterrupted by roads, I am able to reconnect with myself on a deeper level. It’s here that my creativity and inspiration comes most alive and returns home to my human community. These places supply our water and many wild foods and medicine. It is here I reconnected with wisdom lost in recent generations and came to learn about deeply nutritious wild foods that feed my body and soul. I have worked as a wilderness guide in the past for kids and teens facing trauma recovery. In quiet roadless woods, we were able to reconnect with each other and nature without noise and distraction. It led to abundant healing for those children who will carry it forward into future generations and also brought such deep connection and healing to me. These experiences ripple out and change the mental health landscape of our culture and lead to a happier more fulfilled society. I fear the loss of species through the warming of waters a road brings. Bugs that feed fish and birds. Fish that feed bear and us. We need dense canopy to protect our waters and supply our food chain. I have a 6 year old who is obsessed with fishing. He is endlessly fascinated by different types of fish, which habitats they are found in, walking through streams with a pole and a net he learns so much about the natural world, life skills, science, etc. he is so young, yet even he knows waters are to be protected for the health of all. He knows this of land too. Please help him have at least the same amount of access to the wilderness as me. Don’t take these experiences, resources and joys away from our children! Regarding the Laurel Mountain in the Pisgah National Forest, North Carolina: Headwater Stream Integrity and Cold-Water Aquatic Habitat — The roadless condition preserves the hydrological function of major headwater systems including Mills River, Slate Rock Creek, Bradley Creek, and North Fork Mills River, which originate or flow through this 5,683-acre area. Intact headwater forests maintain stream temperatures, stabilize flow regimes, and protect spawning substrate for sensitive aquatic species including the Eastern Hellbender—a near-threatened salamander that requires clean, cold, fast-flowing water with intact riparian buffers. The absence of roads prevents sedimentation from cut slopes and stream-warming from canopy removal, conditions that would degrade the cold-water habitat these species depend on for survival. 31 Species move between Laurel Mountain and South Mills River for genetic exchange, demographic rescue, and seasonal resource access. Road construction fragments these movement pathways — severing the population connectivity that Bog Turtle (G2), Eastern Hellbender (T2), Golden-winged Warbler (G3), Gray Myotis (G3), Northern Myotis (G2), Pink-shell Azalea (G3), Rock Gnome Lichen (G3), Small Whorled Pogonia (G2), Swamp-pink (G3), Tricolored Bat (G3) and other shared species require to persist in both areas. The network connecting Laurel Mountain and South Mills River across 4.3 miles in Pisgah National Forest sustains 31 shared species, including Bog Turtle (G2), Eastern Hellbender (T2), Golden-winged Warbler (G3), Gray Myotis (G3), Northern Myotis (G2), Pink-shell Azalea (G3), Rock Gnome Lichen (G3), Small Whorled Pogonia (G2), Swamp-pink (G3), Tricolored Bat (G3). This connectivity function cannot be evaluated one IRA at a time — it emerges from the relationship between areas. The DEIS must analyze cumulative impacts across both IRAs or it mischaracterizes the ecological baseline. "Medium connectivity results in metapopulation dynamics, where local demography is largely independent among patches but recolonization balances local extinction events; high connectivity leads to high occupancy (recolonization and/or demographic rescue outweigh local extinctions) and little to no genetic differentiation. Severe fragmentation will leave patches isolated like islands, where local extinctions will no longer be counterbalanced by colonization." — Cheptou et al. 2017, Philosophical Transactions of the Royal Society B, 2017 The proposed rescission should not be finalized; the Roadless Area Conservation Rule should remain in effect for the good of all. All the best, CommentID: RLC-20261006-0USD0G

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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The trails in Pisgah National Forest are part of my life. I hike there three to four times a month, and I am filing this comment because the Forest Service proposes to rescind the 2001 Roadless Area Conservation Rule without a single public meeting and without weighing what that means for places like Craggy Mountain and Laurel Mountain, two inventoried roadless areas in the Pisgah that I know on the ground.

To the U.S. Forest Service: We are writing to express our strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As avid users and advocates for our nation's public lands, we rely heavily on the integrity and protection of our inventoried roadless areas. We frequently visit Craggy/Big Ivy, South Mills River-Laurel Mountain, Graveyard Fields, the Black Mountains, and Linville Gorge near our home in Asheville, N.C. Protecting these unfragmented landscapes is deeply personal to us because we depend on these watersheds for clean drinking water, hike the backcountry trails, and value the pristine wildlife habitats they support. We 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, Hanne & Glen Miska

Dear Secretary Rollins and Chief Schultz, As a kayaker and outdoor enthusiast, I am entering these comments to note that the proposed rescission of the 2001 Roadless Area Conservation Rule represents a fundamental reorientation of national forest management priorities — away from the long-horizon, public-value-centered framework the Rule embodies, and toward a project-by-project discretion that history suggests will not adequately protect roadless character. South Fork Mills River and the surrounding areas are places that I have visited with my family for generations. I hike and swim in this area frequently with my daughter and grandson. If this rule is rescinded I lose places that I go to for solace and to reconnect to nature and my family. Additionally, I am concerned about waterways that would be adversely affected as well as loss of precious habitat for bats, hellbenders, and many other species. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Bat Habitat Connectivity Across Elevational Gradients — This area's elevation range—from 2,600 feet at Turkeypen Gap to 4,600 feet at Laurel Mountain—creates a continuous forest corridor essential for four federally endangered bat species: the Gray Bat, Northern Long-eared Bat, and Tricolored Bat (proposed endangered), which forage and roost across multiple elevations throughout the year. The unfragmented canopy and intact forest structure provide the interior habitat these species require; roads fragment this corridor into isolated patches, forcing bats to cross open areas where they are vulnerable to predation and collision. The roadless condition preserves the connectivity that allows these species to move between seasonal habitats without exposure. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 9.3 - Agricultural & forestry effluents on Monarch. The DEIS must provide site-specific analysis of 9.3 - Agricultural & forestry effluents impacts to Monarch (Danaus plexippus) in the South Mills River IRA — not a programmatic discussion of roadless areas generally but a particularized assessment of this species in this place. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013

To the U.S. Forest Service and the U.S. Department of Agriculture: I am writing to express my strong opposition to any and all efforts to rescind, weaken, roll back, or otherwise reduce the protections provided by the 2001 Roadless Area Conservation Rule. As an avid supporter of our nation’s public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently benefit from several roadless areas, including Craggy Mountain, Laurel Mountain, South Mills River, near where my family and I and our neighbors live, work, and recreate in the Buncombe County area of NC. Protecting these unfragmented landscapes is deeply personal to me because my community depends on these watersheds for clean drinking water, my friends and neighbors hike the backcountry trails, and I value the pristine wildlife habitats. 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. My community also relies on the 2001 Roadless Area Conservation Rule to prevent deadly and costly wildfires. Thank you for the opportunity to provide public comment.

I live in Western North Carolina. I hike in Pisgah National Forest 3-4 times per month. I visit Nantahala National Forest several times a year. I cycle along the French Broad River. These forests and river are precious and need to be protected. As you are aware, hurricane Helene caused major damage to Pisgah in 2024. I witnessed the destruction first hand. There still are areas/trails that have not opened due to widespread damage. Looking at the topography of Pisgah, the high-elevation peaks in these roadless areas act as a giant natural filter providing clean, low-cost drinking water to millions of residents in Asheville, Charlotte, and down-stream communities. Stripping the blanket protections will lead to accelerated soil erosion, increased sediment runoff in mountain streams, and heavily inflated water treatment bills for local municipalities. Highly popular, unfragmented backcountry destinations like South Mills River, Laurel Mountain, Big Ivy, and the Blacks (adjacent to Mt. Mitchell) are all protected primarily by their roadless designation. These forests provide rare, deep-woods solitude that is rapidly vanishing along the East Coast. The Forest Service’s proposal would allow local managers to open up to 84% of North Carolina’s roadless areas to commercial timber road building.This directly threatens world-class trout fishing streams, backcountry hunting, hiking, and the multi-billion-dollar outdoor tourism economy that Western NC depends on. It would be irreversible and devastating! The Southern Appalachian mountains contain one of the most biologically diverse temperate forests on Earth, holding more native tree species than all of Europe combined. The roadless sections of Pisgah and Nantahala are vital "life rafts" and migration corridors for rare and threatened species, including the Eastern hellbender, Appalachian brook trout, and native black bears. Building infrastructure through these areas would fragment these sensitive ecosystems and accelerate the spread of invasive species. The federal proposal shifts oversight away from a national standard, leaving protections up to individual forest management plans. I have a deep concern that the Pisgah-Nantahala Forest Plan could leave thousands of acres vulnerable to industrial development if national safety nets are dropped. The Forest Service already faces a severe, multi-billion-dollar maintenance backlog on existing forest roads. It is financially reckless to build new commercial timber paths when the agency cannot afford to maintain the roads it already has. I implore the Agricultural Department to uphold the 2001 Roadless Rule. PLEASE protect the places that matter to me, my family and my community. If this rule is rescinded, the damage it will cause can never be reversed.

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I am David Thomas and I live in Brevard, NC. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections in full. I hike, fish, and bicycle in the Pisgah National Forest. Roadless areas around Laurel Mountain, which is specifically known as a backcountry mountain biking destination, plus South Mills River, Craggy Mountain, Lost Cove, Harpers Creek, Wilson Creek, and Graveyard Ridge above Graveyard Fields are deserving of continued roadless designation. New road construction is the dominant source of management-related sediment in forested watersheds. Forest Service Southern Research Station studies of national forest roads in the Southeast measured average soil losses of 276 tons per hectare from road sections, with eroded sediment traveling a mean of 30 meters downslope into the forest floor (Grace 2005; Grace and Elliot 2008). Because inventoried roadless areas contain few or no roads today, rescission would introduce precisely the sediment source the agency's own research identifies as the leading driver of stream sedimentation — directly threatening the cold-water trout streams of roadless areas like South Mills River in the Pisgah National Forest. The agency has not shown how it would prevent this sediment delivery if the national prohibition is removed. THe sediment directly impacts the downstream municipal water treatment of Mills River and Asheville North Carolina. Grace, J.M., III and Elliot, W.J. (2008). "Determining Soil Erosion from Roads in the Coastal Plain of Alabama." USDA Forest Service, Southern Research Station. https://www.srs.fs.usda.gov/pubs/ja/ja_grace032.pdf The wildfire rationale does not withstand scrutiny. The proposal frames rescission as necessary for fuel reduction. Wildfires are roughly four times as likely to start near roads. More roads mean more ignitions, not fewer. The 2001 rule already permits fuel treatments and forest-health work; it restricts road construction and commercial timber harvest, not active management. Rescission is not required to reduce fire risk. Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). "Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads." Fire Ecology, 22(1), Article 8. https://doi.org/10.1186/s42408-026-00450-2 I survived Hurricane Helene and saw the damage done to the Pisgah National Forest. The areas without roads are clearly visible to less damage as the forest has withstood centuries of storms. Increasing the roads is not an effective use of tax funds since tax dollars will have to repair the additional damage of continued erosion of increased traffic on roads. Building roads into steep, remote terrain creates enormous future liabilities for taxpayers. After Hurricane Helene, rebuilding just five miles of I-40 through the Pigeon River Gorge — mountain terrain comparable to Pisgah's roadless areas — is projected to cost $2.8 billion, nearly triple the initial estimate, with completion not expected until 2029 (NCDOT, 2026). Statewide, Helene damaged some 9,500 transportation sites across 5,000 miles of roads, with total repair costs estimated at $10 billion (NC State Auditor's dashboard, 2026). The Forest Service already faces a road maintenance backlog of nearly $6 billion. Authorizing new road construction in inventoried roadless areas would add miles of high-risk, high-maintenance road in steep terrain the agency cannot afford to maintain — let alone rebuild after the next extreme storm. The agency's cost-benefit analysis should account for these lifecycle and storm-repair costs, not just the timber revenue new roads might enable. The roadless areas protect resources no regulation can restore once lost. The protection of the municipal drinking water supplies of Mills River and Asheville is critical to the protection of drinking sources. The intact wildlife habitat and migration corridors, and the backcountry recreation experiences — including mountain biking, hunting, and fishing — that sustain rural economies. The agency's own analysis acknowledges potential losses to roadless character, recreation, habitat, and water quality if the overlay is removed. Those losses are effectively permanent. The 2001 rule was adopted after one of the largest public participation processes in the agency's history. Discarding it now, over the objections of the overwhelming majority of commenters, would undermine public trust in forest planning for a generation.

Helene hit us harder than almost anywhere, and two years later we're still among the least recovered. The creek on my land is still full of debris and its banks are severely washed out. I look at that every day. I know what happens when steep mountain slopes and waterways are damaged, and I don't want to see it happen to our public forests. Opening steep, storm-damaged slopes in the Black Mountains and across Pisgah to new roads and logging means more landslides, more sediment, and more destruction when the next storm comes. The headwaters of the South Mills River supply drinking water to 80,000 Henderson County residents. Protecting that watershed is the cheapest water treatment there is. The Roadless Rule already allows fuel reduction for wildfire, so removing protection across millions of acres goes far beyond fire management. These forests are the last public places we have left to heal and be in nature. Don't let my home, my neighbors' homes, and those places be damaged any further. Keep the Roadless Rule, and keep the South Mills River headwaters, Laurel Mountain, Craggy Mountain, and the Black Mountains protected. Gina Tines Chimney Rock area, NC

Dear Secretary Rollins: My sister has a home in Weaverville, NC, and my family hikes all the time there. We hiked along the Laurel river earlier this year, and it was one of the best places we've hiked. Bulldozed roadbeds would end these trips. No more family time doing something we love. Regarding Laurel Mountain in Pisgah National Forest, NC: Road construction in the Laurel Mountain IRA reduces visitation by degrading the solitude, clean water, wildlife, and backcountry character visitors value. Fewer visitors mean less spending at local outfitters, guides, lodges, restaurants, and gas stations, directly weakening the recreation economy near Pisgah National Forest. "Timber management has the potential to affect recreation experiences and opportunities in several ways: noise levels, log trucks sharing roads with sedans, changes to the landscape from clearcutting and slash piles, and additional roads. Road dust generated from vehicular traffic on 2,068 miles of unpaved Forest roads also adds particulates to the air. Road dust generated by recreational and logging vehicles accessing National Forest System lands through private land is perceived as a problem by some private landowners adjacent to the Forest." — USDA Forest Service Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "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 is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A). The ask is straightforward: maintain the Rule. With respect, Heather Disney

I am a resident in Western North Carolina and I am writing to express my deep Opposition to the Proposed Repeal of the 2001 Roadless Rule Protections for North Carolina's National Forests (Pisgah and Nantahala National Forests). I am also a survivor of Helene and my personal experiences witinessing the devastating impacts of that storm and understanding the vulnerablity our mountains, forests and watershed is no longer hypothetical but very real. I have chosen to live here and sincerely hope that these mountains and the environment can continue to sustain life in all of it's forms for my children as well as generations to come. I oppose the U.S. Forest Service's proposal to end the 2001 Roadless Rule. The repeal of these federal protections places 172,000 acres of pristine, Inventoried Roadless Areas (IRAs) within the Pisgah and Nantahala Forests at immediate risk of commercial logging, industrial development, and habitat-fragmenting road construction. These backcountry areas--including critical watersheds and iconic landscapes, like Linville Gorge, Laurel Mountain, and the South Mills River Watershed are invaluable to the state of North Carolina for several critical reasons: Watershed Protection and Climate Resilience: These 172,000 acres act as a vital natural filtration system that supplies clean drinking water to hundreds of thousands or residents across Western North Carolina. Maintaining intact, unfragmented forest floors is our best natural defense against catastrophic soil erosion and severe downstream flooding, which increasingly threaten our mountain communities. Economic Impact on Tourism and Recreation: Western North Carolina's multi-billion-dollar outdoor recreation economy relies directly on the wild, uninterrupted nature of these public lands. Opening these backcountry areas to industrial use will permanently degrade the world-class hiking, fly-fishing, and climbing experiences that draw visitors from around the globe and support local businesses. Irreplaceable Biodiversity: the Pisgah and Nantahala National Forests harbor unique, ancient ecosystems and endangered wildlife species that cannot survive the disruption brought by heavy machinery and road corridors. Relying solely on local shifting forest management plans does not offer the permanent, ironclad security that the 2001 Roadless Rule provides. While I am sharing with you my personal concerns with WNC, I am equally concerned for our national forests and public lands throughout our nation. My father grew up in the coal mining area of the Appalachian mountains in western Maryland and I have witnessed the devastating impact of logging and coal mining, stripping mountain tops and polluting water have had on the local economies. Those communities continue to suffer from poverty and toxicity. Surely we have learned from experience in our nation, the devastation of natural resources at the expense of the environment that we all need to sustain life. We need clean water, clean air and soil. We also need the beauty of this planet. We must protect it. I urge the U.S. Forest Service and the Department of Agriculture to reject this rollback and maintain the full, existing federal protections for North Carolina's backcountry. Thank you for your time and consideration of these public comments. Sincerely, Valerie Linn NC, 28803

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

To the U.S. Forest Service: I am writing because I strongly oppose any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user of our inventoried roadless areas, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit Craggy Mountain, Laurel Mountain, and several other roadless areas in Pisgah National Forest, since I live in Asheville. It is deeply personal and important to me to protect these untouched and undeveloped lands because I grew up hiking these when I was a child and still a tourist from out of state, and now for the past 12 years, I have been able to raise my own family by taking them out to these forests and mountain trails that are still pristine like when I was a kid. These backcountry trails and spaces also attract a lot of tourists still, which is vital to Buncombe County's economy, especially after Helene hit our tourism economy so hard. Our mountains and forests need care and protection, not destruction and logging. I urge the U.S. Forest Service and the USDA to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas.

On behalf of the City of Hendersonville City Council to maintain and protect the City's water supply watershed potentially impacted by the subject rule change: 1. Retain roadless area protections for the Laurel Mountain and South Mills River Roadless Areas or, at a minimum, complete a thorough, transparent, and site-specific environmental review of the effects of any repeal on the North Fork and South Fork Mills River watersheds before taking final action. 2. Fully evaluate, through the Environmental Impact Statement process, the potential impacts of road construction, mining, and timber harvesting within these roadless areas on water quality, water supply, flood risk, and wildlife habitat. City of Hendersonville City council resolution attached.

To the US Forest Service, I am a full time resident of the Asheville area. Folks drawn to this area come for many reasons, but one of the top reasons is Pisgah National Forest's robust and yet still diverse ecology that is on display for travelers of the Blue Ridge Parkway, backpackers, Mountain Bikers, and all in between. Areas that are within the Roadless Rule's reclassification boundaries are places like Laurel Mountain, South Mills River, & Wilson Creek are some of my most cherished backcountry routes for riding and hiking. These places brings me great peace with their quiet and undisturbed settings. Spend a day out in the Turkey Pen Gap trail network and you won't hear a chainsaw, motor bike, or anything but birds, the breeze, & water trickling down a little mountain ravine. Its magical to have this right out our front doors. A little place and reason to be proud of our country for what it protects and shares with its people. We in W. North Carolina have been through a lot over the past few years and nearly everyone with the means to do so has given back to the community or the damaged public lands in some way. Caring for these forest lands through trail work, invasive species management, & debris cleanup gives us a connection to place and it brings us into contact with our community. Caring for place feels like a rare thing. Please let the US government show it understands this. It will have lasting impressions especially on young people who are beginning to feel that nothing is sacred. My comments above are mostly personal and go less into the research. There are organizations in our area that have done the analysis of what is at stake with the reconsideration of the Roadless Rule and its impact on our mountains. Please weigh their comments. They are not decelerationists. They understand the resource demands of a growing world, but they are doing the wide boundary analysis that is vital when considering what ought to be done with these protected forest lands. Protecting watersheds and preserving robust ecosystems that are resilient to erosion were two of the main objectives behind the US forest service's founding. Please consider upholding the current roadless rule for our area. As they say when we win its temporary, when they (big timber, big oil, mining interests) its permanant. Let's please not give them another winning hand this year.

Dear Chief Tom Schultz: In my experience on public land, roadless areas stay intact because of protections like this one — not because development pressures stay away on their own. Over the last few years, I've used nature and hiking as a way to cope and heal through loss. Just earlier this year, I hiked a few different places in NC that were just breathtakingly beautiful. To think they want to add roads through these forest and animal's habitats who depend on their peaceful and untouched environment to sustain life, is disheartening and unimaginable. We, as humans, have gone this long without destroying that and we can continue on without doing it now. If this rule is rescinded, I lose my escape, my hobby, and confidence in our government. Regarding the Laurel Mountain in the Pisgah National Forest, North Carolina: Rescission of the Roadless Rule exposes Ovate Catchfly (Silene ovata, G3,) in the Laurel Mountain IRA, Pisgah National Forest, to intensified 4.1 - Roads & railroads, a threat already documented at Serious - slight severity across Small (1-10%) scope. Road construction in Laurel Mountain introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 4.1 - Roads & railroads. The agency must use the best available scientific data — including NatureServe conservation status ranks and IUCN-CMP threat classifications — when analyzing impacts of rescission on Ovate Catchfly (Silene ovata) in the Laurel Mountain IRA. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature) “Foundational environmental analysis documenting 58.5 million roadless area acres and comprehensive effects on soils, water, fish/wildlife, and socioeconomics. Core scientific record behind the Roadless Rule. — (2000/2001) (https://www.fs.usda.gov” “Assesses how well existing wilderness represents U.S. ecological systems and shows that adding inventoried roadless areas would substantially increase representation of underrepresented ecosystems — a quantitative argument for treating IRAs as integral to the broader conservation reserve network rather than a separate, lesser tier. — Dietz et al., 2015 (https://doi.org/10.1016/j.biocon.2015.02.024)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021” “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Strittholt & DellaSala, 2001 (https://doi.org/10.1046/j.1523-1739.2001.99577.x)” “Mammal and bird population densities declined with their proximity to infrastructure. The effect of infrastructure on bird populations extended over distances up to about 1 km, and for mammal populations up to about 5 km. Data were gathered from 49 studies on 234 mammal and bird species. The main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density. — Biological Conservation (ScienceDirect), 2010” “On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches). -(PMC), 2013” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups.” Rescinding the Roadless Rule would open doors that can't be closed again. I'm asking the Department not to open them. Regards, Megan

My name is Lylah Russell and I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I strongly encourage the USDA/National Forest Services to not take action to undo the Roadless rule. I believe that without it we would be making the habitat for endangered species unsustainable while destroying other wildlife's homes. It would also increase the likelihood for wildfires, be very cost ineffective and people may also lose their jobs (fishers and other jobs that rely on the Roadless Rule). Personally, I have spent a lot of time in Pisgah National Forest and many of the roadless areas there, including Harpers creek, Laurel Mountain, Graveyard Ridge and many more. I live in Western North Carolina and I am a student at a school that looks out onto Mt. Pisgah and several Roadless Rule areas. It would be very unfortunate for those areas to turn into roads. I strongly advocate for the Forest Services to withdraw this proposal and keep the Roadless Rule of 2001.

I urge you not to remove federal bans on logging, commercial development, and road construction in our backcountry areas here in Westeern North Carolina, including Linville Gorge, Laurel Mountain, and the South Mills River watershed. I have lived in this area for over 30 years and remain here because of these pristine, unspoiled tracts of nature. Thank you for taking into account my opinion. Sheila D. Dunn 200 Country Club Road Asheville, NC 28804 sheilagdunn@gmail.com 828-776-3661

To whom it may concern, I am writing to express my strong opposition to the US force services proposal to repeal the 2001 Roadless rule in North Carolina. Resending these federal protections places 172,000 acres of pristine inventoried Roadless areas within the Pisgah and Nantahala National Forest at intermediate risk of commercial logging, industrial development, and habitat–fragmenting road construction. These backcountry areas–including critical watershed's and iconic landscapes like the Linville Gorge, Laurel Mountain, in the South Mills River–are invaluable to the state of North Carolina for several critical reasons: 1. Watershed protection and climate resilience: These 172,000 acres act as a vital, natural filtration system that supplies clean drinking water to 100s of thousands of residence across Western North Carolina. Maintaining intact, on fragmented forest floors is her best natural defense against catastrophic soil erosion and severe downstream flooding, which increasingly threatened Iron Mountain communities. 2. Economic impact on tourism and recreation: Western North Carolina is multi billion dollar outdoor recreation economy relies directly on the wild, uninterrupted nature of these public lands. Opening these backcountry areas to do industrial use will currently degrade the world–class hiking, fly–fishing, and climbing experiences that draw visitors from around the globe and support local businesses. 3. The replaceable bio diversity: The Western North Carolina National Forest Harbor unique, ecosystem's and endangered wildlife species that cannot survive the disruption brought by heavy machinery and road corridors. Relying solely on local, shifting force management plans does not offer the permanent, I am glad security that the 2001 Roadless rule provides. I urged that he was forced service in the Department of agriculture to reject this rollback and maintain the full, existing federal protections for North Carolina's back country. Thank you for your time and consideration of this. Mark Hofmann, MD Asheville, North Carolina