Read the comments.

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

I live in Asheville, North Carolina and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, wildlife watching, and living in or near a National Forest community. Undeveloped National Forest lands matter to me because it’s important to protect the existing ecosystem. The land does not belong to us, they belong to the animals and beings that already live there. Lost Cove is one place that has shaped my views on this proposal. It is within the Linville Gorge Inventoried Roadless Area in Pisgah. I value this place because it’s quiet and I and connect with nature. I am concerned about wildlife habitat and landscape connectivity. They provide large connected habitats and ecosystems that can be hard to find in largely developed areas. I am concerned about clean water and healthy watersheds. Healthy and undeveloped watershed are crucial part of this world and habitat. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments. Thank you, Taylor D

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Three decades of fishing these places is the floor, not the ceiling. I want them around for the next three hundred decades, and that is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. I hike across Virginia, North Carolina, Montana and Colorado to find the beautiful landscapes of this country. I have fished Ramseys Draft Addition in the George Washington National Forest several times and prefer to maintain the pristine nature of that area. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, and the waters and terrain those areas protect are part of what I go looking for when I go out. In Montana I travel through country that includes the Bob Marshall Wilderness Complex, the North Absaroka area in the Gallatin National Forest, Hoodoo and Welcome Creek and Stony Mountain in the Lolo, the Sapphires and Upper East Fork in the Beaverhead-Deerlodge, and the vast connected landscapes of the Flathead and Lewis and Clark National Forests. In North Carolina the Pisgah holds Lost Cove and Wilson Creek. What I see in all of these places, and what I hope will still be there in generations that are not mine to witness, depends directly on whether this rule survives. The wildlife I look for when I am out, moose and bears and elk among them, are not incidental to this discussion. The agency's own record states that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. On moose, the agency's Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter, while the draft environmental impact statement separately notes that moose are drawn to road corridors for road salt, which increases human-moose interactions and conflict. These findings are the agency's own. I ask the agency to explain, specifically and on the record, how rescission serves the survival of these animals when its own analysis identifies roads as a driver of their mortality and displacement. On the question of wildfire, which the proposal cites as a reason to rescind the rule, 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 language is the agency's, not mine. The agency must reconcile this proposal with its own ignition data and explain why it is departing from those prior findings. On economics, the agency's record is equally candid: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million, all of this on top of a $6.9 billion road maintenance backlog the agency already cannot fund. How does an action whose own analysis cannot establish a net benefit justify expanding that road system? On the question of state-by-state approaches replacing the national rule, the agency's own record reflects its earlier rejection of the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach," a position the record documents at 70 Fed. Reg. at 25,656. The Ninth Circuit reviewed that substitution and found it wanting. The agency should address on the record how this proposal avoids those same deficiencies. On statutory authority, the Tenth Circuit has already spoken. Its own words: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. If the agency now takes a contrary position, it must state that position plainly and explain its legal basis. I oppose this rescission. The places I fish and hike, and the animals I go looking for in them, are worth more than a fraction of a percent of national timber output. The agency's own record makes that case. It should follow it. Leave public lands in public hands. It's uniquely American and deserves to stay that way. Sincerely, Jeff Zillgitt Arlington, VA

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mammals are what bring me into the backcountry. I keep a species life list, and the roadless areas of Pisgah National Forest in North Carolina and Superior National Forest in Minnesota are places I go looking for them: gray wolf, moose, Canada lynx, and black bear in the Superior's lake country around Phantom Lake, Hegman Lakes, and the South Kawishiwi River; black bear and the more than 30 endemic salamander species of the Southern Appalachians in the hollows and gorges around Wilson Creek, Harper Creek, Lost Cove, and Linville Gorge Addition. The agency is now proposing to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition. The proposal uses wildfire and fuels management as part of its justification for rescission. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is in the agency's draft environmental impact statement. The proposal moves toward more roads, not fewer, while citing fire risk as a driver. I ask that the agency explain, with specificity, why this proposal departs from its own prior findings on fire occurrence inside roadless areas, and that it reconcile the rescission with the ignition density data reported in its own DEIS Table 21, which shows far higher fire density on roaded land. The economics do not hold together either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I work hard and the government takes my money, and I want it going to things that actually benefit me and my community. The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. A range that includes a $92 million loss does not establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of approximately $73 million a year. The agency must reconcile its proposal with those figures and explain how opening 40.1 million acres to new road construction serves the public when the maintenance backlog already overwhelms what the agency can afford. Water is the most integral resource for the entire world. If we destroy it, we destroy ourselves. Across the Southern region alone, which includes North Carolina, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres protecting headwaters that flow to both the Atlantic and the Gulf. Fewer than 12 percent of those watersheds have impaired streams today. The agency has not explained how it proposes to keep that number from rising once road construction is permitted in areas currently protected. The agency must answer that question directly. The agency's own DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then goes nowhere. No projection across the 40.1 million acres of potentially affected environment follows from it. The Southern Appalachians where I look for mammals are among the most biodiverse temperate forests in North America, and the Superior's roadless areas are the hydrological engine of the entire Boundary Waters Canoe Area Wilderness system. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and show what that means for the species verified to live there. Finally, the agency's DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." That finding, like the fragmentation data, appears and is then left unresolved. No population-level projection for big game follows anywhere in the document. The agency must project what the proposed rescission means for big game populations and for the hunting opportunity that depends on them, and it must do so before this rulemaking advances further. Sincerely, Taylor Apel Ely, MN

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

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

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.

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

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

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

Subject: Strong Opposition to the Repeal of the 2001 Roadless Rule (Docket ID: FS-2025-0001) I am writing to express my strong opposition to the proposal to rescind or alter the 2001 Roadless Area Conservation Rule, and I urge the Forest Service to select Alternative 1 (No Action). As a resident of WNC, I deeply value our public lands for the outdoor recreation opportunities they provide. I regularly spend time in WNC’s Inventoried Roadless Areas, particularly Craggy mountain, Linville gorge, and Lost cove , to hike. These pristine, unroaded landscapes offer a rare and irreplaceable sense of solitude that cannot be found in fragmented forests. Opening these backcountry areas to timber harvesting and road construction will directly degrade the trail networks and natural beauty that support our local outdoor recreation economy. Furthermore, the agency’s claim that removing the rule will mitigate wildfire risk contradicts established science. New roads bring increased human activity, and research shows that wildfires are four times more likely to ignite near roads. Please protect the wild character of Western North Carolina's forests and leave the 2001 Roadless Rule fully intact.

Dear US Forest Service, I'm writing you to express my strong opposition to rescinding, weakening or rolling back of the 2001 Roadless Area Conservation Rule. As an avid user and advocate of Roadless areas like Wilson Creek and Lost Cove in NC, and Little Wilson Creek in VA, (both near my home in Boone, NC), I recognize their importance in providing clean drinking water, intact wildlife habitat, wildfire mitigation and making lasting outdoor memories. Roadless areas represent the best of the best forests within the National Forest system and should be kept that way for future generations. It's also a known fact that human caused wildfire ignition is heavily concentrated near roads rather than within remote Roadless areas. Rescinding the Roadless Rule could result in more wildfires than help mitigate them. I again urge the USDA and US Forest Service to abandon any proposal to rescind the Roadless Rule and instead maintain full protections for all currently designated Roadless Areas. Thank you for the opportunity to provide public comment. Sincerely, Ben Lucas

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The dense old wood forests, rolling hills, and untouched natural beauty of places like Lost Cove and Linville Gorge are why I visit the roadless areas of Pisgah National Forest. I go to photograph wildflowers, animals, and beautiful landscapes. I have hiked in Wilson Creek, Lost Cove, and Linville Gorge, and what I find there, every time, is the kind of peaceful place that cannot be rebuilt once it is gone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these places. It has held none to undo it. I want my kids and grandchildren to have these places to hike, fish, explore, and enjoy all of the beauty that is here. That is the full weight of my objection to Docket FS-2025-0001. The Nantahala and Pisgah National Forests together hold 32 inventoried roadless areas covering more than 150,000 acres. North Carolina as a whole holds 38 inventoried roadless areas totaling 172,416 acres. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the roadless areas of Nantahala-Pisgah protect the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, along with black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. I mentioned that roads would destroy animal habitat and that endangered species live in all of these areas. The verified record for this forest confirms exactly that. I ask that the agency address, specifically, how it weighs the irreversible habitat fragmentation of these documented species communities against any claimed benefit of rescission. The agency's own economic numbers do not support this action. The record before the agency states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal return, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million per year, set against recreation losses of at least $6.1 million per year and a net present value ranging from -$92 million to +$199 million, while the road system already carries a $6.9 billion maintenance backlog. No net benefit is established. I ask the agency to reconcile this proposal with its own numbers and explain how an action with such an unresolved economic range justifies expanding infrastructure the agency cannot currently maintain. The agency's handling of future plan amendments is procedurally indefensible. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot honestly ask the public to comment on a consequence it has simultaneously ruled outside its own analysis. Harper Creek and the surrounding Pisgah roadless areas sit directly in the path of the expanded harvest that foreseeable amendments would permit. I ask that the agency include a full analysis of the plan-amendment scenario, with projected acreage and road-construction impacts, before this rulemaking proceeds. The climate consequences of rescission are stated and then abandoned. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The DEIS then concludes that these lands will continue to sequester and store carbon without analyzing what logging and road construction actually do to that figure. That is not analysis; it is an assumption dressed as a finding. The agency must quantify projected changes in carbon storage and sequestration under each alternative before this rule can be finalized. Finally, the agency has reversed a factual finding without explaining why. "The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule." What has changed? The wilderness have not become less biodiverse. The roads have not built themselves back into wilderness. An agency that found local planning inadequate in 2001 owes the public a clear account of the evidence that reversed that conclusion. The agency has not provided one, and it must. Sincerely, [Mary Archer Vann [Banner Elk, North Carolina

Me and my friends spend a great deal of time hiking the Lost Cove roadless area in Western North Carolina. This is such a special place for it natural beauty and serenity. Removing the Roadless Rule status for this area would be such a tragedy for generations to come. With the population increase and the impacts of global warning, it is critical that we maintain these spaces in their natural form. Thank you for your consideration.

I would like to see the closed section of Pisgah forest road 464A to Lost Cove creek reopened. Traveled down there several times when it was open. Now at my age may not be able to expirence this area again otherwise.

Dear Secretary: As an outdoor enthusiast, I've learned to value what a rule can hold in place — especially when pressure to develop it never stops. I've hiked this trail and made memories with friends, now those friends have children and have made memories with them on this trail. Leave nature to the people who care about it. My friend took his kid on his first hike to Lost Cove, where their relatives are buried. Regarding the Lost Cove in the Pisgah National Forest, North Carolina: Road edge effects extend far beyond the road itself. A road's ecological impact reaches well past its physical footprint. Within 1 kilometer of roads, forests show 18.6 percent lower canopy cover, shorter trees, lower productivity, and substantially higher fragmentation. Effects extend up to 5 kilometers from the road, with a clear distance-decay pattern (Zhou et al. 2026). — Zhou et al., 2026 (https://doi.org/10.1038/s41467-026-69150-4) Rescinding the Roadless Rule would open the Lost Cove, 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 create a sense of wonder and natural beauty which is crucial to a child to have. We need to preserve this feeling for future generations. I've laid out why I think rescission is the wrong call, and I hope the Department takes that seriously. Earnestly, CommentID: RLC-20260912-GPK6D3

Please do not rescind the Roadless Rule. I am a proud native North Carolinian who has grown up visiting the mountains on a regular basis. As a child, my parents took me on day trips to explore the Lost Cove and Upper Wilson Creek area. As an adult, I have been a regular visitor to this area. It has been a joy to experience the wildlife, clean water, and gorgeous undisturbed forests. I hope that I can bring my grandchildren to witness these areas in the same pristine and peaceful condition. Mary Beth Bankson Durham, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The old-growth forests of the Southern Appalachians, including the roadless areas of the Pisgah National Forest in North Carolina, are among the last places where human infrastructure has not yet determined what survives. Public lands must be managed with a balance of public access, conservation, and wildlife in mind. What I need to understand from the Forest Service is how rescinding the 2001 Roadless Area Conservation Rule serves any part of that balance. North Carolina holds 38 inventoried roadless areas totaling 172,416 acres. The Pisgah alone contains 18 of those areas totaling 99,369 acres, including Lost Cove at 5,944 acres and Wilson Creek at 4,863 acres. These forests protect wild headwaters that flow to both the Atlantic and the Gulf, and they shelter species including black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. Our old-growth forests are already dwindling. With an ever-expanding need for urban sprawl and infrastructure, the opportunity to preserve forest untouched by human impact is severely dwindling. The agency must explain, specifically, how it plans to keep forests like Lost Cove and Wilson Creek intact for generations to come, and I ask it to provide that answer on the record. On the question of roads, the agency's own environmental record states this directly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless frames rescission partly as a wildfire and fuels management measure. Tax dollars should go toward maintaining existing roads and ensuring safe public access. The Forest Service is already behind on maintaining the roads it has. Creating new roads within a system of unmanaged, unmaintained roads is a public safety concern as well as an environmental concern. What is the justification for building new roads with funding that does not cover existing roads? I ask that the agency reconcile its current proposal with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal argues that state-specific approaches can replace one national rule. This argument has been litigated before. The agency previously expressed, in its own rulemaking record, dissatisfaction with the Roadless Rule's nationwide approach and replaced it with a state-by-state framework. The Ninth Circuit rejected that substitution. The agency has not explained how this proposal avoids the deficiencies that court identified, nor has it addressed its own prior finding that incremental local decision-making can erode nationally significant roadless values. I ask the agency to provide that explanation now. On the question of the agency's statutory authority, the proposal suggests the 2001 rule exceeded what Congress authorized. The Tenth Circuit addressed that question directly and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule was within the authority granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must address that holding and explain, with specificity, the legal basis for any position contrary to it. Finally, the alternatives analysis in this proposal is structured so that conservation cannot win. Protective alternatives were dismissed as inconsistent with deregulatory executive orders rather than evaluated on their merits. A purpose and need statement written as deregulation forecloses exactly the comparison NEPA requires. The agency should restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before reaching any final decision on rescission. The Southern Appalachians, and the people and species that depend on places like Lost Cove and Wilson Creek, deserve no less. Sincerely, Melissa North Carolina

Please, please, PLEASE retain the Roadless Rule. I have been fortunate enough to spend quality time in the Upper Wilson Creek/Lost Cove area and in other parts of Pisgah National Forest. My daughter's first job was doing conservation work in California for Americorps. Her experience exploring roadless areas in the West inspired her to accept another conservation job fighting invasive species and maintaining hiking trails. As I know and she is learning firsthand, it's important for so many reasons to keep these places wild, clean and relatively undeveloped. People from all walks of life and all economic backgrounds need places they can escape the noise and pollution of our sprawling metro areas and connect with nature. This is more true than ever as our nation gets divided into haves and have-nots--people who can afford luxury wilderness trips and those who depend on public lands. It's critically important for plants and wildlife to have uninterrupted expanses. New roads can fragment wildlife habitat, increase sedimentation and diminish the wild character of these lands. These places are formative in the lives of so many young people. This is priceless land that belongs to all of us. Cutting roads through these lands for the benefit of a few special interests will lead to their eventual destruction. Thank you for your consideration.