The Public Record · Docket FS-2025-0001

Read the comments.

Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.

24 unique comments25 submissions
Position
  • Opposes rescission 100.0%
Answerability
  • A1 strong 0
  • A2 moderate 8
  • A3 weak 4
  • A0 none 3
Substance /24
Median 9middle half 8.5–11.5 · 15 scored
Topics raised
Count
Position
Answerability
Substance /24
Order
24 unique comments naming Linville Gorge Addition · showing 1–20Clear all filters
  1. Opposes rescissionOct 7, 2026FS-2025-0001-607902
    Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Growing up in Greenville, SC, Pisgah National Forest was one of the closest and most beautiful places my family could go to hike and camp. We spent so much time wandering through the forests, having picnics, and swimming in the creeks there that it developed my love of western North Carolina and truly all national forests and parks in the Carolinas. As an adult I have hiked southern portions of the Appalachian Trail, tubed down Deep Creek, and gone white water rafting in the Nantahala National Forest. These are not abstract landscapes to me, and I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001. The roadless areas of the Nantahala and Pisgah are among the most biodiverse temperate forests in North America, protecting the last wild headwaters of rivers flowing to both the Atlantic and the Gulf. Verified species in these forests include black bear, brook trout, cerulean warbler, hellbender, northern long-eared bat, and more than 30 endemic salamander species. I have watched wildlife run out of places to live safely as development expands outside these boundaries. Deer are constantly hit and killed on roads. Bear encounters in western North Carolina are becoming more and more common. The agency's own record acknowledges what road-building does to bears with increased contact and conflict ultimately ending in bear mortality and habituation. I ask that the agency address on the record how rescission would affect bear and deer populations in the Nantahala and Pisgah, where road-driven conflict and habitat fragmentation are already documented pressures. Bird habitats are disappearing alongside everything else, and the agency's own science explains why roads are the mechanism. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The forests I grew up loving support the cerulean warbler and a full community of species that depend on unroaded interiors. The agency must explain what it makes of its own cited research before moving forward. South Mills River, 8,588 acres in Pisgah, holds the kind of interconnected creek systems where brook trout persist. Building roads and harvesting timber there would damage water clarity and native trout habitat in ways that cannot be undone on any human timescale. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The Deep Creek section of the Nantahala is enjoyed yearly by locals and visitors alike, and its pristine waters support both wildlife and local businesses. The agency should respond to these water supply risks with specificity, not generality. The Linville Gorge Addition, 2,809 acres in Pisgah, presents a concern that goes beyond the ordinary. Western North Carolina is still recovering from Hurricane Helene. Removing the logging and road construction ban on the steep, rugged slopes around the Gorge could significantly heighten the severity and frequency of landslides in the region, with long-term consequences for the Gorge itself, its panoramic views, and its recreational areas. The Wesser Bald roadless area, though smaller in acreage, houses the Appalachian Trail. That corridor should not be desecrated. I expect the agency to address the landslide and slope-stability risks specific to these areas under current post-storm conditions. The proposal justifies rescission partly on wildfire management grounds, but 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." The agency must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" but the Cost Benefit Analysis weighs none. My connection to these forests, built across a lifetime and expressed in the choices I continue to make about where to hike, tube, raft, and simply be, is exactly the kind of reliance interest an agency reversing a two-decade-old rule is required to assess. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Naomi Morgan Columbia, SC Hopeful Western NC Retiree
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  2. Opposes rescissionOct 7, 2026FS-2025-0001-608142
    To the Roadless Rule Rulemaking Docket: As someone who knows how rarely strong protective rules get rebuilt once rescinded, I oppose this action on practical grounds. I have spent my entire life exploring wilderness areas such as the Linville gorge, and I fear for the health of both the forest and its downstream communities if the rule is rescinded. If this rule is rescinded, I will lose a place where I recreate, and my water quality will be lower. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Headwater Protection for Five Creek Systems — The Linville Gorge Addition contains the headwaters of Irish Creek, Back Creek, Mountain Creek, Reedys Fork, and Russell Creek—a network of cold-water streams that drain into the Linville River watershed, which the U.S. Forest Service classifies as Functioning Properly. These headwater streams provide spawning and rearing habitat for native fish species and maintain the cold temperatures and clean substrates that aquatic life in the broader watershed depends on. Road construction in headwater areas causes sedimentation from cut slopes and exposed soil, which smothers spawning gravels and reduces water clarity—impacts that propagate downstream and degrade water quality across the entire drainage network. Rescinding the Roadless Rule would be a mistake the public — and the land — would be living with for generations. I'm asking the Department not to make it. Kind regards, CommentID: RLC-20261007-4UW221
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  3. Opposes rescissionOct 6, 2026FS-2025-0001-575958
    To Whom It May Concern at the U.S. Forest Service: In my experience on public land, what makes the roadless areas different isn't scenery — you can have scenery with a parking lot — it's the absence of the infrastructure that changes the relationship between the land and whoever's in it. As a 4th generation North Carolinian, the mountain region is my escape, and the place my family chooses time and time again because it quite literally soothes our souls. Opening up swaths of protected national forest to new roads would have such a detrimental impact on some of our most beloved places. Our kids go to summer camp in one area of Pisgah, and while they were there this past summer my husband and I rented a cabin in Linville gorge and spent a long weekend hiking and exploring one of the very regions that is currently under threat. We kept remarking at the utter quiet surrounding us, such a rare treasure these days. And one to guard!! Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Rescinding the Roadless Rule would open the Linville Gorge Addition, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I find it hard to believe that anyone thinking critically about this situation could see anything other than unnecessary destruction. Please listen to the voices speaking for this cause- we have seen so much harm come to our precious ecosystems both far and near and urge you to protect this land that is our collective treasure. Yours sincerely, Julie Smith
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  4. Opposes rescissionOct 6, 2026FS-2025-0001-594987
    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
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  5. Opposes rescissionA2 moderateSubstance 14/24Owed an answerOct 6, 2026FS-2025-0001-596003
    PLACESTANDDOCGAPEVIDASKALTLAW
    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
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  6. Opposes rescissionA2 moderateSubstance 11/24Owed an answerOct 5, 2026FS-2025-0001-559957
    PLACESTANDDOCGAPEVIDASKALTLAW
    To the U.S. Department of Agriculture: In reading the proposed rescission against the federal climate record, I find the Department's stated rationale insufficient to justify the loss of contributions to forest carbon, watershed integrity, and ecological connectivity the Rule has performed and continues to perform. I am a law student at UNC Chapel Hill and a member of the Environmental Law Project. I went to law school in North Carolina with a desire to protect the state I grew up in. Linville Gorge is one of the many places that has served as inspiration for me. I remember visiting Linville Gorge as a child and being amazed by the natural beauty and biodiversity. Just last semester I was able to go camping near Linville Gorge. It served as an escape from the stresses of law school for me and reminded me why I am going to law school in the first place. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Headwater Protection for Five Creek Systems — The Linville Gorge Addition contains the headwaters of Irish Creek, Back Creek, Mountain Creek, Reedys Fork, and Russell Creek—a network of cold-water streams that drain into the Linville River watershed, which the U.S. Forest Service classifies as Functioning Properly. These headwater streams provide spawning and rearing habitat for native fish species and maintain the cold temperatures and clean substrates that aquatic life in the broader watershed depends on. Road construction in headwater areas causes sedimentation from cut slopes and exposed soil, which smothers spawning gravels and reduces water clarity—impacts that propagate downstream and degrade water quality across the entire drainage network. 6.1 - Recreational activities requires infrastructure access to operate at scale. Roads are the prerequisite — they deliver the machinery, chemical inputs, and repeated human intrusion that transform this threat from latent to active in areas like Linville Gorge Addition. A programmatic analysis is insufficient. The DEIS must evaluate 6.1 - Recreational activities impacts to Small Whorled Pogonia (Isotria medeoloides, G2) at the scale of the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, with specificity adequate to inform the decision. "Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams." — River Research and Applications (Wiley), 2026 The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. Beyond the headline fights over wildfire, recreation, and water, the Roadless Rule plays a quieter but essential role in federal land law and ecological assessment. Section 7 of the Endangered Species Act requires the Forest Service to consult before any action that may affect listed species — and the rule's road-construction prohibition has shielded countless management decisions from triggering that consultation. The rule also props up federal forest planning: peer-reviewed analyses of forest plan adequacy consistently find that forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards for sensitive species and intact landscapes. And state-level conservation rankings (NatureServe and others) repeatedly identify roadless areas as concentrated in the rarest, most threatened ecosystems in the lower 48 — the kinds of places where a road, once built, cannot be undone. I'd rather see the Department focused on strengthening forest protections, not rolling them back. This proposal moves in the wrong direction. Best, Madeline Watts
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  7. Opposes rescissionOct 4, 2026FS-2025-0001-532698
    I am submitting this comment regarding the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in North Carolina and visit Linville Gorge and the surrounding Pisgah National Forest frequently. It is one of the places in North Carolina that I return to again and again for hiking, photography, scenic drives, and simply spending time in an undeveloped mountain landscape. I am particularly concerned about what rescission could mean for the Linville Gorge Addition Inventoried Roadless Area, approximately 2,800 acres adjoining the Linville Gorge Wilderness. While I understand that rescinding the Roadless Rule would not itself authorize road construction or timber harvesting, it would remove the nationwide protections currently applicable to this area and leave future decisions more dependent on forest-level planning and individual project decisions. One of the defining characteristics of Linville Gorge is the continuity of the landscape. From places around the Chimneys, Shortoff Mountain, Table Rock, and the surrounding ridges, you can look across miles of largely unfragmented forest. That undeveloped character is a major part of why I continue to visit the area. My concern is not simply whether the congressionally designated Wilderness boundary itself remains intact. Development immediately outside that boundary can still affect the experience of the larger landscape through forest fragmentation, road construction, erosion and sedimentation, noise, and changes to viewsheds and wildlife habitat. I have attached photographs from my visits to illustrate the character of the area that I believe should be considered when evaluating the effects of changing protections for the Linville Gorge Addition and similar inventoried roadless areas. Based on my experience using this area, I support retaining protections that preserve the Linville Gorge Addition's roadless and undeveloped character. If USDA moves forward with rescission of the nationwide rule, I ask that it specifically evaluate how equivalent protections for places such as the Linville Gorge Addition would be maintained under individual forest plans and future project-level decisions. Thank you for considering my comments and the perspective of people who regularly use these National Forest lands.
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  8. Opposes rescissionOct 4, 2026FS-2025-0001-533729
    I know Linville Gorge and have been there many times. If the “Linville Gorge Addition” is carried out, a protection that limits new roads would be removed. These roads can cause erosion and sediment in the water and soil. I ask the Forest Service to analyze these effects and keep the rule. Protect our forests and keep them intact!
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  9. Opposes rescissionA2 moderateSubstance 9/24Owed an answerSep 28, 2026FS-2025-0001-484521
    PLACESTANDDOCGAPEVIDASKALTLAW
    To the Department of Agriculture: As an outdoor enthusiast, I write to address the Department's proposed rescission of the 2001 Roadless Area Conservation Rule, a regulatory action that, in my assessment, lacks proportionate administrative rationale relative to the documented public interest the Rule was promulgated to serve. Over the course of my 31 years of life, I've spent countless hours of free time in the roadless backcountry of western North and South Carolina. The time I've spent in Linville Gorge and surrounding areas like it has brought me a deep peace and appreciation for the plants and animals that share our planet. It has given me a window into the soul of the planet that we inhabit. Without the roadless rule, we lose the ability to experience land as it's been for all of existence, as made by our Creator. We lose the connection we have to our earth in its truest form. We also lose the protections so hard fought for, for old growth trees, rare plants, and wildlife. Conservation is at the heart of the American spirit, pioneered by our rugged former President Theodore Roosevelt, and removing protections such as the roadless rule go against everything that make this country great. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Federally Endangered Bat Habitat and Acoustic Refugia — Four federally endangered bat species—gray bat (*Myotis grisescens*), northern long-eared bat (*Myotis septentrionalis*), Virginia big-eared bat (*Corynorhinus townsendii virginianus*), and the proposed endangered tricolored bat (*Perimyotis subflavus*)—forage and roost within the roadless area's intact forest canopy. The unbroken canopy and absence of road noise create acoustic conditions essential for echolocation-dependent foraging; roads introduce artificial light and noise that disrupt bat navigation and reduce foraging efficiency. The montane forest structure here, spanning from low-elevation rocky summits to Carolina hemlock forests, provides the diverse insect prey base and roosting microhabitats these species require year-round. 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 5.3 - Logging & wood harvesting on Northern Myotis. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Northern Myotis (Myotis septentrionalis) in the Linville Gorge Addition Inventoried Roadless Area, including the documented threat of 5.3 - Logging & wood harvesting. "We document over a one-quarter decline in bird abundance and almost complete avoidance by some species between noise-on and noise-off periods along the phantom road and no such effects at control sites—suggesting that traffic noise is a major driver of effects of roads on populations of animals. We replicated the sound of a roadway at intervals during the autumn migratory period using a 0.5 km array of speakers within an established stopover site in southern Idaho." — Proceedings of the Royal Society B: Biological Sciences (PMC), 2013. Twenty-five years of it working ought to count for something.
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  10. Opposes rescissionSep 28, 2026FS-2025-0001-484721
    To the Roadless Rule Rulemaking Team: For an outdoor enthusiast who understands the difference between what is accessible now and what may be foreclosed by near-term administrative action, the proposed rescission of the 2001 Rule is not an abstraction — it is a regulatory change whose consequences I expect to observe directly within the landscape I use. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Microclimate buffering recovers slowly after clearcutting. A 2025 study of boreal forests found that even-aged stands took roughly 30 years to recover the temperature-buffering capacity of unharvested forest. During that recovery period, the cooling effect of intact canopy is eliminated — exactly when species most need it during summer heat extremes (Starck et al. 2025). — Starck et al., 2025 (https://doi.org/10.1016/j.agrformet.2025.110434) Rescinding the Roadless Rule would open the Linville Gorge Addition, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. A foul waste of energy sources. Rescinding the Rule opens the door to damage that won't be undone. Don't open it. Warm Regards, Geri Soll
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  11. Opposes rescissionSep 21, 2026FS-2025-0001-455455
    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.
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  12. Opposes rescissionSep 21, 2026FS-2025-0001-455677
    Dear Chief Schultz: As a North Carolinian and American, I value tremendously our virgin lands and forests as a place of mental rest, physical activity away from noise except for the refreshing noise of nature and animals, and a gift for our future generations that must be maintained in their present state. The Department's proposed recession would deprive future generations of this gift as well as destroy the quiet peacefulness of parks and forests for people and for wildlife. I am adamantly opposed to this. I hike and run weekly in Umstead Park, preserved forest land outside Raleigh. I also go as often as I can to the mountains to hike and refresh. These places of total quiet in nature are necessary for my mental health. And that is what so many of my family and friends say. We NEED to preserve these gifts untouched by roads and industry. Hiking with my daughters in the Appalachians is a treasured gift as we decompress in the silence of human noise and the songs of birds. Listening to and seeing the crystal clear waters of rivers and creeks offers total relaxation. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: I have hiked the Linville Gorge trails, among others in Western NC. Your name is Forest SERVICE - not Forest "Destroyer" who sells out to greedy industry. I cannot fathom that the pristine lands of our country, valued by so many and depended upon by so many, could be sold out to the "highest bidder". They belong to the people, not individual industries. They are an asset of this country to be protected for ALL Americans to enjoy both now and in the future as they are, not cut up by destructive roads to serve a few industries. How selfish! There is something that cannot be replaced by entering a quiet forest in Western NC to hike, rest, enjoy a view, and commune in silence knowing that you are surrounded by wildlife that is at home and protected in a totally natural setting mostly untouched by humans except those who appreciate and treasure it for what it is. The many-faceted destructive results of allowing roads into pristine forest and land is a huge concern. Run-off of dirty water from roads into clean creeks and rivers, the re-routing of those creeks leading to the death of aquatic wildlife, bringing in invasive species leading to the destruction of native foliage and trees, the destruction of sacred tribal sites, disturbing noice from machinery and vehicles - this cannot be allowed! Ten maintained trails provide access to the gorge floor and rim overlooks, ranging from 0.75 miles to 2.8 miles. Keep industry roads out! It appalls me that the Forest SERVICE would allow forests to be destroyed by roads and the resulting dust, noise, and dirt runoff. How can you allow the degradation of lands that belong to all Americans for recreation, hunting, livelihood? How can you allow the degradation of lands that are needed for our dwindling wildlife? How can you allow the degradation of pristine lands needed for clean water? I value our American wild lands as they are. We owe it to future Americans to keep them as they are so they can enjoy them. You have no right to go down a slippery slope of gradually allowing them to be torn apart by the rescission of the Roadless Rule. Recreation opportunities depend entirely on the absence of roads. Hiking here means true backcountry travel—steep, unmarked descents, stream crossings, and self-reliance. Hunters access remote ridges and hollows on foot, finding game. Recreation enthusiasts support the surrounding businesses of our wild places. The only thing that will grow and survive roads invading pristine lands is industry greed. Please do not allow this! Earnestly, CommentID: RLC-20260920-B9V1IE
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  13. Opposes rescissionA0 noneSubstance 5/24Sep 16, 2026FS-2025-0001-432777
    PLACESTANDDOCGAPEVIDASKALTLAW
    Dear Secretary Brooke L. Rollins, As someone who specifically seeks out public land that hasn't been made easy, I want the Department to know that the 2001 Rule isn't regulatory excess — it's what keeps certain places worth going to. Rescission takes away the ability to experience these places as they were originally meant to be experienced--quietly, reverently. They allow millions of residents and tourists alike the ability to spend time away from the busy lifestyle and noise of daily life, and to gain a greater appreciation for roadless spaces and the desire to protect such spaces as to benefit future generations, and to conserve currently existing species in need of these places in order to thrive. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Intact forests provide ecosystem services that fragmented ones cannot. Primary forests with the least disturbance history have the highest carbon storage, the highest ecosystem-process levels, greater stability and recovery, and the lowest risk of loss. Connectivity, biodiversity, and microclimate buffering combine to give intact forests greater adaptive capacity in a changing climate (Rogers et al. 2022). — Rogers et al., 2022 (https://doi.org/10.3389/ffgc.2022.929281) Rescinding the Roadless Rule would open the Linville Gorge Addition, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadless areas are necessary for both future enjoyment and future conservation. Humans and other species alike rely on these areas as refuges and critical habitats and need to be conserved and protected moving forward. Respectfully, Olivia Renna
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  14. Opposes rescissionA0 noneSubstance 7/24Sep 14, 2026FS-2025-0001-402579
    PLACESTANDDOCGAPEVIDASKALTLAW
    Brooke L. Rollins and Tom Schultz, I've grown up in North and South Carolina since I was 2 years old. I'm now 36. Going hiking in the Blue Ridge mountains and beyond. Going to Western Carolina University, Lake Summit, Lake Jocassee and Lake Lure, Asheville for years of Yoga trainings and weekend hikes with friends. Watching the whole entire infrastructure change completely after the devastation that was Hurricane Helene. These mountains and forests are ALIVE and well, and they do not need human hands disturbing them. The waterfalls, rivers, and streams are a vital part of life in Linville Gorge and surrounding areas in the Mountains and hills of North Carolina. Not to mention the hundreds of species of wildlife here. If we do not have wildlife and don't protect their habitats, ours will surely implode soon after. We are already losing bees at alarming rates because of Data Centers and the sounds and frequencies they emit. Without bees, we die. If this rule is rescinded, I lose all sanity. Nature is not to be messed with. It is the most important thing that we have in this life. It brings us closer to God. It teaches us invaluable lessons we wouldn't learn otherwise in life. We are not the most important race in this world. Nature was here far before we ever existed. Why are we always trying to destroy what has only helped us?? Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Rescinding the Roadless Rule would open the Linville Gorge Addition, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. These mountains are alive and well and have been here far before we ever existed or were even a thought. Humans are always trying to destroy what hasn't even hurt them. We are not the most important living thing on this earth. Without wildlife, bees, running water like rivers, streams and waterfalls, we are extinct as we know it. Clearing hundred year old trees and native wild flowers that help evolution is the dumbest thing we could do. And for what?? More money in pockets of people who already have too much??? If we continue to chase evil, karma will surely give you what you deserve. Nature is healing, nature is for everyone. Without it, we will cease to exist. Stay out of our Forrests and mountains. We have to leave Gods creation alone to teach us what we have yet to learn. We cannot try and change or manipulate something that is the wisest thing of all. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Twenty-five years is a long time for a rule to survive legal challenge and still be standing. That durability means something. Keep it. Yours truly, CommentID: RLC-20260914-40C4IV
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  15. Opposes rescissionA2 moderateSubstance 12/24Owed an answerSep 7, 2026FS-2025-0001-331636
    PLACESTANDDOCGAPEVIDASKALTLAW
    Dear Brooke L. Rollins, Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: To the Roadless Rule Rulemaking Docket: I am writing to advocate for the Roadless Rule. I have spent the best days of my life exploring and enjoying the roadless Wilderness. I rock climb, paddle, hike, mountain bike, and guide waterfall rappelling. I have noticed that the nearer I am to a road the more trash and graffiti I encounter. The animals are startled, and also I don't experience the same sense of safety and calm and rejuvenation. The Linville Gorge is one of my favorite places on earth. I climbed my first 500 foot trad route there and it changed my life. I was able to face my fears and overcome them successfully. I climbed above the birds and watched them play in the sunlight below me. I looked out over the roadless expanse of beautiful wilderness and it filled my soul with gratitude, peace, hope and presence. I have traveled to many places and I stay on the east coast to be near the Linville Gorge. The ability to experience a place that feels untouched connects me with something timeless, my self relience, my ability to persevere in a world of obstacles. Yes, others have been there before me, but the landscape remains the same and the inspiration and healing I get from looking over the wild expansive landscape would be completely destroyed by the sight of roads or manmade disruptions. "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” NatureServe threat assessment data document that Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3,) in the Linville Gorge Addition IRA, Pisgah National Forest, faces 8.1 - Invasive non-native/alien species/diseases at Moderate or 11-30% pop. decline severity across Large (31-70%) scope. Roads enable the equipment access, land conversion, and human activity that activate 8.1 - Invasive non-native/alien species/diseases. Without road infrastructure, the extractive and development pressures behind this threat category cannot reach Appalachian Dragonhead Pogonia habitat in Linville Gorge Addition. If the DEIS does not evaluate how rescission affects Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3) in Linville Gorge Addition with respect to 8.1 - Invasive non-native/alien species/diseases, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. An administrative record spanning more than two decades argues against rescission; the Department should act accordingly. With respect, CommentID: RLC-20260905-EKAHLJ
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  16. Opposes rescissionA0 noneSubstance 4/24Sep 3, 2026FS-2025-0001-310648
    PLACESTANDDOCGAPEVIDASKALTLAW
    I have been recreating in the forests in our country for the last decade and it has changed my life. Being in our last truly protected areas, as a living being, is an essential human right, and changes the way that we relate to our world. One place that particularly had a strong effect on me was in the linville gorge addition, with its intense and incredible vertical ascents, it is a truly breathtaking place. unfortunately, building roads in this type of area makes it breathtaking in a different way, vehicle exhaust makes it unpleasant and at times unsafe to be a hiker/pedestrian in the area, and laying down roads adds to heat and discomfort in our natural refuges, in a planet that is already heating. it also disturbs life for our neighbors, nameley the soil which takes thousands of years to form, and the creatures living within in. it will increase roadkill deaths, and encourage trash deposition as well. lets please keep special areas like linville gorge wild, healthy, and beautiful. no roads!
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  17. Opposes rescissionA2 moderateSubstance 15/24Owed an answerAug 31, 2026FS-2025-0001-289787
    PLACESTANDDOCGAPEVIDASKALTLAW
    To the Roadless Rule Rulemaking Docket: As someone who has come to understand public land through years of actually being on it, I'd say the 2001 Rule is one of the policies that's done what it said it would do. Linville Gorge is a beautiful area that brings people from all over to recreate and explore. I have enjoyed hiking, fishing, and rock climbing in this area and in many other spots in Western North Carolina my whole life. This land is important to me. Altering this land would hurt the people who spend time there like I do and potential tourism in the area. One visit made that connection concrete. My first time in Linville Gorge experiencing the wilderness was breathtaking, the views and the river blew me away. Spence Ridge and Conley Cove trails are amazing resources to have access to. The Department should find in what precedes this section a demonstration that the Rule operates in practice as its framers intended: as a durable safeguard for landscapes on which the public actively depends. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 7.1 - Fire & fire suppression (IUCN-CMP 7.1) is actively degrading habitat for Monarch (Danaus plexippus, G4) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Moderate or 11-30% pop. decline severity across Restricted (11-30%) scope. The intact, unroaded condition of Linville Gorge Addition is the functional mechanism that currently limits 7.1 - Fire & fire suppression to its assessed severity and scope. Road construction removes this constraint and permits escalation. The absence of site-specific analysis for Monarch (Danaus plexippus) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, constitutes a gap in the administrative record that exposes the final decision to legal challenge. The DEIS must evaluate 7.1 - Fire & fire suppression at the documented severity and scope. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 “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). — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 (https://doi.org/10.1186/1735-2746-10-23)” “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people. — Conservation Science and Practice (Wiley), 2020 (https://doi.org/10.1111/csp2.288)” I urge the Secretary to decline this rescission and preserve the existing roadless area protections. With best wishes, CommentID: RLC-20260830-P5HY0E
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  18. Opposes rescissionA3 weakSubstance 11/24Owed an answerAug 28, 2026FS-2025-0001-279863
    PLACESTANDDOCGAPEVIDASKALTLAW
    To the U.S. Department of Agriculture: As a resident of a community whose local planning documents treat adjacent roadless National Forest as a fixed and protective landscape context, I submit that the Department's proposal would introduce a degree of land-use uncertainty that local plans have not accounted for and cannot easily absorb. I have grown up exploring these forests and understand the dire effects that logging and rampant out of state (and some misguided instate) developers have to the local ecosystem. I am staunchly opposed to rescinding any environmental protections in favor of industries that are unable or unwilling to determine sustainable ways of progressing without the destruction of our important wild areas. The shortsightedness of this rescention is staggering. The nonmarket value embedded in connections of this kind — to watershed, to forest, to a place known across years — does not appear in the proposal's economic analysis and should not be treated as though it does not exist. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 8.1 - Invasive non-native/alien species/diseases (IUCN-CMP 8.1) is actively degrading habitat for Bog Turtle (Glyptemys muhlenbergii, G2) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Serious or 31-70% pop. decline severity across Large (31-70%) scope. The roadless character of Linville Gorge Addition currently prevents the infrastructure penetration that initiates 8.1 - Invasive non-native/alien species/diseases. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Bog Turtle. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 8.1 - Invasive non-native/alien species/diseases as it affects Bog Turtle (Glyptemys muhlenbergii) specifically within the Linville Gorge Addition IRA, Pisgah National Forest. "The mortality of wildlife resulting from collisions with vehicles is considered one of the main negative effects of roads on numerous species. Roadkill can increase the risk of local extinction by reducing effective population size and genetic diversity, while also limiting demographic and genetic rescue mechanisms. Estimates can reach to 340 million of birds killed on the roads in USA, 194 million birds, 29 million mammals in Europe and 17 million of birds and mammals in Latin America." — Scientific Data (Nature), 2024 “Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams. — River Research and Applications (Wiley), 2026 (https://doi.org/10.1002/rra.70075)” “Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Fire Ecology (Springer Nature), 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The Department should treat the Rule's twenty-five-year record as the baseline against which any replacement must be measured, and on that measure the proposal falls short. Respectfully, Concerned Constituent
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  19. Opposes rescissionA3 weakSubstance 9/24Owed an answerAug 28, 2026FS-2025-0001-283192
    PLACESTANDDOCGAPEVIDASKALTLAW
    To the U.S. Department of Agriculture: In my time out there, I've seen what happens to country after a road is cut through. I oppose this rescission. Growing up in Charlotte, NC, I have visited Western NC many many times. The Appalachian Mountains are honestly my favorite place in the world, and they're so special because they include so much untouched wilderness. One visit made that connection concrete. The most spiritual experience of my life was while i was by myself next to a river in the woods of Western NC. The whole reason I visit WNC as often as I do is because I want to get out of the city and into the woods. I cant do that if roads are cut through the wilderness! The account and the context in which it is situated both point to the same conclusion: the Rule should remain in force. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: Headwater Protection for Five Creek Systems — The Linville Gorge Addition contains the headwaters of Irish Creek, Back Creek, Mountain Creek, Reedys Fork, and Russell Creek—a network of cold-water streams that drain into the Linville River watershed, which the U.S. Forest Service classifies as critically important to the area. Carolina hemlock and Turkey beard, the species confirming Carolina Hemlock Forest (Typic Type) in the Linville Gorge Addition IRA, occupy microhabitats defined by undisturbed canopy cover, stable soil moisture, and intact organic soil horizons. Road corridors sever the continuity of these conditions, expose interior habitat to edge-adapted competitors, and create permanent vectors for invasive species introduction that degrades the characteristic floristic composition of this Imperiled community. The documented presence of Carolina hemlock and Turkey beard in the Linville Gorge Addition IRA provides the DEIS with species-level evidence of Carolina Hemlock Forest (Typic Type). This evidence obligates the agency to analyze road construction impacts on the specific floristic composition and microsite conditions sustaining this Imperiled community in Pisgah National Forest, not merely on the broader Southern Appalachian Ridgetop Pine Forest classification. "Soil compaction that follows the clearing of tropical forest for cattle pasture is associated with lower soil hydraulic conductivity and increased frequency and volume of overland flow. The frequency of stormflow doubled in pasture compared with undisturbed forest, while the volume of stormflow increased 17-fold. Overland flow generation in the forest was spatially limited and observed only very near the stream channel, whereas in pasture it occurred over large areas, suggesting that deforestation alters fundamental mechanisms of stormflow generation." — ScienceDirect / Journal of Hydrology, 2010 “In a review of 215 research studies conducted between 2011 and 2015, road networks have the ability to isolate populations, disconnect resource networks, and cause the irreversible degradation of habitat at a landscape scale. The majority of studies (38%) explored the indirect effects of roads on wildlife, including displacement, fitness consequences, and road crossing ability of wildlife, yet only 10% of studies considered the implications of road networks on wildlife populations. — Springer Nature / Current Landscape Ecology Reports, 2017 (https://doi.org/10.1007/s40823-017-0020-6)” “Many native forest plant and animal species require undisturbed interior forest habitats to persist and do not fare as well near stand edges adjacent to disturbances. Disturbance edges were characterized as having higher soil moisture content, higher soil temperature, and a thinner organic matter layer compared to the forest interior (> 10 m). The interior habitat indicator values show that less than 30% of the Cold Lake area is currently classified as undisturbed due to over 6000 km of linear disturbances including roads. — Springer Nature / Plant Ecology, 2024 (https://doi.org/10.1007/s11258-023-01393-3)” Withdrawal of the proposed rescission is the appropriate administrative outcome. With urgency, Bunny L
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  20. Opposes rescissionA2 moderateSubstance 11/24Owed an answerAug 27, 2026FS-2025-0001-273928
    PLACESTANDDOCGAPEVIDASKALTLAW
    Dear Ms. Rollins, The 2001 Roadless Rule is doing exactly what it was designed to do — and I've seen the results on the ground. I have spend many hours in Linville Gorge, hiking, rock climbing, and trail running. Building roads leading to eventual logging would drastically change my experience and the peace tranquility and connection to our Earth that I and many other folks get out of visiting these wilderness areas. The Rule has preserved the conditions that make connections of this kind possible for twenty-five years; the Department should not rescind it without a clear showing that the public interest is better served by doing so — a showing the proposal does not make. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 5.3 - Logging & wood harvesting (IUCN-CMP 5.3) is actively degrading habitat for Small Whorled Pogonia (Isotria medeoloides, G2) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Moderate or 11-30% pop. decline severity across Large - restricted scope. Absent roads, Linville Gorge Addition functions as a refuge where Small Whorled Pogonia is buffered from 5.3 - Logging & wood harvesting. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Small Whorled Pogonia (Isotria medeoloides) in the Linville Gorge Addition Inventoried Roadless Area, including the documented threat of 5.3 - Logging & wood harvesting. "Of the 537 wildlife species of conservation concern in CONUS, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas (IRAs). The median IRA contains suitable habitat for 10 wildlife species of conservation concern, with a maximum of 62 wildlife SCCs. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA CONUS lands. If all IRAs were added to the protected-area system in CONUS, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas." — Global Ecology and Conservation (ScienceDirect), 2021 The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Rescinding the Roadless Area Conservation Rule would be an unjustified reversal of long-settled land management policy. With determination, Christian Rust
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