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I am commenting on the USFS plan to rescind the 2001 Roadless Rule. The plan to rescind the Roadless Rule is ill-conceived and I urge selection of the No Action Alternative. The DEIS fails to address the protections and values the Roadless Rule provides and fails to adequately analyze the impacts road building and other resource disturbing activities would have on these areas. Roads are the primary cause of habitat fragmentation, sedimentation, and invasive species introduction in forest ecosystems. While the DEIS discusses the impacts from rescinding the Rule, it never addresses the “so what” question. In other words, recognizing there will be impacts doesn’t fully address what the consequences are from those impacts. I.e. the DEIS acknowledges sediment loading, from road building, impacts to water quality, but it never adequately analyzes how this would impact drinking water for communities that rely on these water sources. Implying BMPs will offset any impacts doesn’t fully analyze the negative impacts to water quality and how that would impact communities, fisheries, etc. The same goes for introduction of NNIS. The DEIS acknowledges building roads will lead to the introduction of NNIS but never adequately analyzes the impact that will have on native species, especially T&E species, or on the difficulty of forest regeneration with the introduction of NNIS. Roadless areas provide clean drinking water to many downstream communities. Peer-reviewed research published in PLOS Water found that these areas serve as the primary protection mechanism watersheds that supply drinking water to 25 million U.S. citizens. I live in Western North Carolina, and the South Mills River Roadless area in the Pisgah NF is source of drinking water to the city of Hendersonville. Allowing roads to be built in this area would degrade the water quality for that community. This area recieves a large amount of rainfall and intense rain events. No amount of BMPs can provide adequate protection to that situation. Roadless areas also provide world-class hiking and mountain biking trails, supports local businesses, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. Getting rid of the Roadless Rule puts all these incredible benefits at risk. I live in an area that is a gateway to the Pisgah NF. Our community relies heavily on tourism and a major draw is mtn biking, especially in the South Mills River roadless area. Allowing roads to be built in the area would negatively impact the backcountry nature of this area and enjoyment many gain from that experience. While the EIS claims getting rid of the Roadless Rule will help prevent wildfires, the facts don’t back that claim up. Wildfires are 4 times more likely to start near a road than in a roadless forest. Roads are ignition corridors, and about 89 percent of wildfires nationally are human-caused. Far from preventing wildfire, building roads boosts wildfire ignitions. The DEIS fails to adequately address this discrepancy. Additionally, the Roadless Rule already allows the Forest Service to do wildfire prevention work and fight fires in roadless areas. The rule does not prohibit wildfire fuel reduction work; projects like prescribed burning and vegetation thinning can and do take place within these protected zones. Nearly 2 million acres of roadless areas have received hazardous fuel treatments since the rule was adopted in 2001 The majority of these roadless areas contain steep slopes which makes road construction extremely expensive and exacerbates the impacts to soil and water resources. Opening these areas to road construction will only add to the issue the Forest Service has with road maintenance, which is severely underfunded. The Forest Service is not able to maintain the over 370,000 miles of road it currently has, and has a $5.4 billion deferred maintenance backlog for roads. It receives a fraction of the funding needed to maintain what it has, much less any new roads in rugged terrain. Unmaintained roads can lead to landslides and lower water quality, which threatens the health of entire ecosystems. The agency can’t afford what it has and should not worsen the situation by adding more roads. How will adding to the maintenance costs be addressed and resolved? The DEIS is written in a pre-decisional manner. It appears to be written to justify rescinding the roadless rule and downplays the value of these roadless areas while understating the impacts from opening these areas up to road construction. One of the main arguments that these areas need to be opened up to address wildfire potential just doesn’t hold water. The Roadless Rule has been in effect for 25 years, providing clean water for many municipalities, habitat for many plant and animal species needing unfragmented forest conditions and unmatched back country recreational opportunities. These values deserve to be protected.

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

Subject: Oppose Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and Department of Agriculture: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Raised in the Southern Appalachians, I developed a lifelong connection to the region’s public lands. I have regularly hiked, camped, and explored wild and roadless areas in the region, including the areas around Craggy Gardens and the Black Mountains and South Mills River. I now share exploring these landscapes with my own children. I am deeply concerned by the proposal to dismantle the core protection of the 2001 Roadless Area Conservation Rule. The agency’s proposal risks harming our wild places, to the detriment of communities, ecosystems, biodiversity, and climate resilience, and without credible evidence to back the justifications in the proposals. To the extent the Forest Service suggests that mitigating wildfire risk justifies the proposal, more roadbuilding also threatens to increase fire risk, and managers can already conduct measures to protect communities near neighborhoods without rescinding the rule. In addition, the idea of expanding the road network is problematic. The Forest Service cannot maintain its existing network of roads, resulting in a massive maintenance backlog. These deteriorating roads create environmental hazards, destabilizing slopes and acting as conduits for sediment into streams, which in turn impacts downstream water quality, stream habitat and river recreation. With a changing climate and the predicted increase in intense storm events over the coming decades, these unmaintained roads are already a problem. Building more roads in backcountry or roadless areas will exacerbate these problems. Roadless areas also contain unfragmented blocks of forest, which are home to large linkages of old growth forests, support rare ecosystems, and serve as carbon storage. Unfragmented forests on the Southern Appalachian landscape act as a biological reservoir in the region, providing refuge to animals and plants, including those that are threatened and endangered and face a series of other stressors. Eliminating protections for these areas and allowing roads and increasing management activities that disturb the landscape and forests would denigrate the quality of wild unfragmented mature forests, including those with old growth characteristics. More now than ever, in the face of a changing climate, these roadless areas play a key role combatting the effects of climate change, both in terms of mitigation through supporting carbon storage in mature forest ecosystems and by providing needed resiliency as a part of climate adaptation. This should compel the agency to steer management towards protecting roadless areas, enhancing protections for mature ecosystems and biodiverse-rich areas, and scaling down the existing system of roads in line with maintenance realities. Like thousands of other comments the agency has already received, I strongly oppose this rollback and request that the agency leave these wild and roadless areas protected. Therefore, I urge the agency to select the alternative that leaves this critical protection in place (no action).

Dear Chief Tom Schultz: I am writing to express my objection to rescinding the roadless rule. It is vital that these areas of National Forest Land be protected from the potential damage that would be likely if the roadless rule is rescinded. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Rare Plant Habitat in Cove Forest and Wetland Transition Zones — The area's diverse forest types—Rich Cove Forest, Acidic Cove Forest, and Canada Hemlock Forest—support multiple federally protected plants including Small Whorled Pogonia and Swamp Pink (both federally threatened), as well as critically endangered species like Green Pitcher Plant and imperiled Oconee Bells. These species occupy specific microclimates and soil conditions found in undisturbed cove forests and wetland-upland transitions; road construction and the associated fill, drainage, and soil disturbance would destroy the precise hydrological and edaphic conditions these plants depend on, and these conditions cannot be recreated once lost. Rescinding the Roadless Rule would open the South Mills River, 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. It is important that sufficient areas of the National Forest are protected from overreach, overuse, damage to watersheds, unnecessary logging, and irresponsible forms of recreation that harm the natural environment. I live near Pisgah National Forest in Western North Carolina and am an avid outdoor person who strives to enjoy the beauty of nature without imposing strain on the fragile ecosystems that will be deeply and adversely affected by rescinding the roadless rule. Please take into account the overwhelming public objection to rescinding the roadless rule. People in our United States care about the environment and should be respected for these well considered and researched arguments to keep and hopefully expand the roadless areas of the National Forest System. Many public acres are already available for the other uses intended by this proposed reversal of the widely supported roadless rule. Share the public lands and maintain support for the roadless rule. Regards, Matthew Runningen Respectfully, CommentID: RLC-20261007-XUESWW

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation’s public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit many of these areas, including the Jarrett Creek, Mackey Mountain, Bearwallow, Balsam Cone, Craggy Mountain, and South Mills River areas near my home in Western North Carolina. I spend many hours in the forests in these areas - riding my bike, hiking, and running. The peace and quiet and connection with nature help keep me grounded and are essential to my well-being. I am happiest when I am in the forest, and I treasure having these wild places so close to my home. I am constantly reminded how lucky I am to be able to spend hours every week in these wild places where I encounter so many types of beautiful and interesting plants, insects, and wild animals. I encounter bears, deer, bobcats, snakes, rabbits, groundhogs, turkeys, fish, turtles, and many other critters in these areas. Being out in these wild places reminds me that I am only a tiny piece of such an incredible and immense world. These wild places untouched by development provide peace and solitude that is so rare in our world. These forests are irreplaceable, and the damage done by rescinding the protections in these areas would be devastating and irreversible. I have already seen massive damage to our area's forests from Hurricane Helene and how that has allowed for invasive species to flourish in some areas. I am also greatly concerned about the increased wildfire risk in my area. Undoing the protections in these areas would only cause further damage in a time when the land is just beginning to heal from Helene. Protecting these unfragmented landscapes is deeply personal to me because I recreate in these forests regularly, and I value the pristine wildlife habitats these wild areas contain. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment and for your time in considering my input on this important issue. Sincerely, Dorothy

To the U.S. Forest Service: I am an Asheville resident and someone who regularly recreates in the mountains and public lands of Western North Carolina. The forests surrounding Asheville are not just scenery to me, they are places where I hike, explore, recharge, and spend time with friends and family. They are part of what makes Western North Carolina feel like home. The Pisgah and Nantahala National Forests contain approximately 152,000 acres of Inventoried Roadless Areas, representing roughly 15% of the two forests. These areas include portions of the Black Mountains, South Mills River, Wilson Creek, Graveyard Fields, and other backcountry landscapes that are deeply important to the people who live and recreate here. I am writing to urge the Forest Service to reconsider its proposal to rescind the 2001 Roadless Area Conservation Rule and to maintain meaningful protections for the remaining roadless areas in our national forests. This issue is particularly important here in Western North Carolina. For Asheville and surrounding communities, the forests provide much more than opportunities for recreation. The Forest Service's own management plan recognizes clean and abundant water, healthy ecosystems, wildlife habitat, and opportunities for people to connect with the land as important priorities for the Pisgah and Nantahala National Forests. These forests contain headwaters and watersheds that support streams, rivers, aquatic species, and communities throughout Western North Carolina. As someone who spends time in these forests, one of the things I value most is the ability to get away from roads and development. There is a meaningful difference between hiking through an intact forest and hiking through a landscape increasingly shaped by roads, construction, and motorized access. Roadless areas provide opportunities for solitude and backcountry recreation that cannot simply be recreated once a road has been built. I recognize that the Forest Service has legitimate responsibilities to address wildfire, forest health, access, and other management challenges. However, those responsibilities do not eliminate the need to consider what could be lost by removing existing protections. Rescinding the Roadless Rule would change the baseline for future management decisions. Once roads are constructed into currently intact landscapes, the character of those places and the recreational, ecological, and watershed values they provide can be difficult or impossible to restore. This is especially significant for Western North Carolina as our communities and forests continue to recover from the enormous disruption caused by Hurricane Helene. The Forest Service has recognized the significant impacts Helene had on the mountains of Western North Carolina and National Forest System lands. At a time when our region is rebuilding and thinking seriously about resilience, protecting intact forests and watersheds deserves particular consideration. I also ask the Forest Service to recognize that roadless does not mean unmanaged. The existing Roadless Rule does not designate these lands as wilderness, and roadless areas can still be managed for legitimate stewardship needs under the existing framework. There are ways to address wildfire risk, forest health, habitat restoration, and emergency needs without eliminating broad protections for some of our remaining undeveloped public lands. For me, this issue ultimately comes down to what kind of public lands we want to leave for the next generation of Western North Carolinians. I want my community to continue to have forests where people can hike for miles without encountering a road, where streams and headwaters remain protected within intact watersheds, where wildlife has connected habitat, and where people can experience the Southern Appalachians without extensive development. These places are part of the identity of Asheville and Western North Carolina. They provide benefits to residents, visitors, wildlife, and communities throughout the region. I respectfully ask the Forest Service to retain the 2001 Roadless Area Conservation Rule and maintain meaningful protections for Inventoried Roadless Areas in the Pisgah and Nantahala National Forests. Thank you for considering my comment. Sincerely,
 Rose G. Asheville, North Carolina

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

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

Public Comment on the Proposed Rescission of the Roadless Area Conservation Rule Docket No. FS-2025-0001 | RIN 0596-AD66 I am writing today to oppose the proposed rescission of the Roadless Area Conservation Rule of 2001 (Roadless Rule). This landmark Rule is commonsense, protects key ecological, community, and cultural values, and is integral to my and my family’s health and wellbeing. I am submitting these comments to express my personal views and to request that the United States Department of Agriculture keep the Roadless Rule intact. My home is in the Southern Appalachian Mountains, where our national forests are renowned for their globally significant biodiversity and for their recreational opportunities. I take my young sons hiking, foraging, camping, and swimming in our favorite roadless areas. We study plants, mushrooms, animal tracks, birds, salamanders, and geology in these roadless areas. They love to explore the forest’s waterways and we plan to teach them how to fish in these roadless areas. We delight in waterfalls and they learn self-confidence and self-reliance. They are learning to love to be outside and to understand the importance of being disconnected to technology, a critical element in today’s technology-laden existence. In particular, the inventoried roadless areas on the Nantahala-Pisgah National Forest where we visit the most that do not have additional layers of designated protection are Cheoah Bald, Tusquitee Bald, Mackey Mountain, the Black Mountains, and South Mills River. We are intimately connected to these places and my family depends on them to explore and connect to nature with no worries of roads and the commercial enterprises that they bring into our public lands. I understand that there are places where those do occur, but I appreciate that the Roadless Rule has created certainty for over 25 years around where that can and cannot occur, and that as a parent I can access these precious places to build precious memories as my children grow and learn. They are physical, emotional, and spiritual places for my renewal, respite, and inspiration. As a citizen and taxpayer of the United States, I value Roadless Areas for saving my tax dollars. As Taxpayers for Common Sense reports, “[r]epealing the Roadless Rule would cost taxpayers billions in subsidized road construction and maintenance, exacerbate taxpayer losses from money-losing timber sales, increase wildfire risks and the associated costs borne by taxpayers, and weaken the health of roadless areas that provide important commercial and recreational benefits to the American public.” I appreciate that Roadless Areas provide water filtering service for over 25 million people across the country, and that clean drinking water is an irreplaceable resource. Roadless Areas of the Chattahoochee National Forest provide a significant portion of the Chattahoochee River, the source of drinking water for the City of Atlanta, where I have over a dozen family members who rely on that water. Above all, I believe that the Roadless Rule should be maintained as it is for the inherent values these areas provide for themselves, the flora and fauna and the unfragmented wild nature therein. Nearly 450 threatened, endangered, and ESA proposed wildlife species depend on national forest roadless areas for their survival, and over 1,500 sensitive plant and animal species recognized by the Forest Service find habitat in Roadless Areas. The unfragmented nature of Roadless Areas provide connectivity and more resilient habitat. Roadless Areas are less likely experience invasive species infestation or human-caused wildfire. I am requesting that the U.S. Forest Service fully analyze the following elements in the Final Environmental Impact Statement: •the effects of rescinding the Roadless Rule on wildlife habitat connectivity and landscape fragmentation •cumulative effects at the landscape scale, rather than limiting analysis to the direct footprint of potential future road construction or timber-management activities •watershed, erosion, sedimentation, and aquatic-connectivity impacts associated with potential changes in road construction and management •meaningful government-to-government Tribal consultation and consideration of Tribal interests and knowledge throughout the decision-making process Thank you for the opportunity to provide my comments on the proposed rescission of the Roadless Area Conservation Rule of 2001. I am requesting that the U.S. Forest Service select the No-Action Alternative laid out in the DEIS and keep the Roadless Rule intact.

Dear Secretary: I'm writing as an American with a strong belief in public lands. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Headwater Protection for Aquatic Species Dependent on Cold, Clean Water — The South Fork Mills River originates within this roadless area and flows through multiple tributary systems—Bradley Creek, Cantrell Creek, and Clawhammer Creek—that collectively form a Priority Watershed designated by the U.S. Forest Service for restoration and protection. The Eastern Hellbender, a proposed federally endangered salamander, depends on the undisturbed streambeds and cold water temperatures maintained by the intact forest canopy in this area. Road construction would remove streamside vegetation, allowing solar radiation to warm water and destabilize banks, directly degrading the specific habitat conditions this species requires to survive. Salmonid embryo survival. Fine sediment in spawning gravel reduces salmonid egg survival. In studied Pacific Northwest streams, when fine sediment exceeded 13% of redd composition, no steelhead or coho salmon eggs survived. Chinook salmon are the most susceptible to sediment loading, followed by coho, steelhead, and cutthroat trout (McHenry et al. 1994; Lotspeich & Everest 1983; EPA 2005). — U.S. Environmental Protection Agency, UNKN (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf); U.S. Environmental Protection Agency, 2005 (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf) Rescinding the Roadless Rule would open the South Mills River, 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. Roadlesso wilderness is a rare thing in this world and we can't get it back once it's gone. The Roadless Rule stays on the books. That's my position. Hopefully,

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

To the USDA Roadless Rule Rulemaking Team: In my experience as an outdoor enthusiast who has used roadless national forest as a recreational and restorative resource for many years, I have come to regard the 2001 Rule as one of the few administrative instruments capable of holding the line against the gradual conversion of interior forest to roaded and managed landscape. I have been enjoying roadless areas since I was a child. I took them for granted as a restorative place. I realize now they need to be protected against those who are driven only by greed & special interests. Once these areas are destroyed, they are gone forever. We must protect them. Roads bring noise & exhaust. I love breathing clean air & hearing only wildlife. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. 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. “A foundational, frequently-cited review documenting seven categories of negative road effects: mortality from construction, vehicle collisions, modified animal behavior, alteration of physical and chemical environments, spread of exotic species, and increased human use. Establishes the scientific rationale for keeping roadless areas roadless and is cited extensively across the roadless-rule literature. — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Foundational environmental analysis documenting 58.5 million roadless area acres and comprehensive effects on soils, water, fish/wildlife, and socioeconomics. Core scientific record behind the Roadless Rule. — (2000/2001) (https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5057900.pdf)” “Even-aged stands took on average 30 years to recover to pre-harvest buffering state after clear-cutting. Clear-cuts led to full coupling with open-air temperatures, eliminating microclimate buffering entirely. It can take decades for a clear-cut stand to reach the same buffering capacity as a forest with continuous tree cover. From biodiversity perspective, continuous tree cover can create more temporally stable microclimatic conditions and can thus aid in maintaining microrefugia and mitigate climate warming impacts. — ScienceDirect / Agricultural and Forest Meteorology, 2025 (https://doi.org/10.1016/j.agrformet.2025.110434)” My ask is simple: keep the 2001 Rule. Gratefully, CommentID: RLC-20261005-P0VG8F

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

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

Dear Ms. Rollins,Edit salutation As someone who has been on public land in all kinds of conditions and has noticed which policies have held and which have eroded, I'd put the 2001 Rule in the column of things that have genuinely held — and that's exactly why it should stay. I am an ecologist by training. I earned my M.S. in Conservation Ecology and Sustainable Development from University of Georgia's Odum School of Ecology. Since then, I have worked in evironmental advocacy. The health of our environment is very important to me both for sustaining important ecosytems and for the recreational opportunities.Edit customized opening I moved to Western North Carolina about 5 years ago, and one of the draws to the area was the vast public lands throughout the region. In particular, the South Mills River district of Pisgah National Forest is an important roadless area that we have enjoyed backpacking.Edit personal connection If this rule were to be recissinded, it would threaten our water quality downstream. The pristine water quality in these mountains is responsible for great aquatic habitat throughout the watershed. Sedimentation from road building would take away the opportunity for my kids to learn about and see salamanders and beautiful fish in our mountain streams. Our local economy would suffer as well, as outdoor recreation and tourism supplies the livlihoods of many in my community. Please see attachment for full comment.

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

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

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation’s public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I live in Asheville, NC and frequently visit numerous parts of Pisgah and Nantahala National Forests. These areas that I cherish are either directly protected by roadless designation (places like South Mills River, Linville Gorge, and Joyce Kilmer-Slickrock) or benefit from being located nearby to roadless areas. And in the wake of Hurricane Helene, the integrity of our roadless areas has become all-the-more important to Western North Carolina's continued recovery, including the quality of our water and the resilience of our ecosystems to natural disasters. On a more personal level, protecting these unfragmented landscapes is important to my continued recreational enjoyment as a hiker and backpacker, and important to my community's identity. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Molly Bruce

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in North Carolina most of my life, I have come to know the wilderness here as something genuinely irreplaceable. I backpack in Turkey Pen in the South Mills River area and hike along the Davidson River. My partner and I have paddled some stretch of almost every waterway in Western North Carolina, and if we have not paddled it, we have most likely hiked along it. The South Mills River roadless area, 8,588 acres in the Pisgah National Forest, is part of what I mean when I say this place has not been touched by development. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres. North Carolina as a whole holds 38 inventoried roadless areas totaling 172,416 acres. These are not abstractions. They are the specific places I return to, and they need to be protected so future generations can enjoy them as well. Rescinding the 2001 Roadless Area Conservation Rule would end that protection, and I oppose it entirely. The agency's own record undermines the economic case for this rescission. The DEIS 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 baseline, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, all while the road system already carries a $6.9 billion maintenance backlog. I ask the agency to reconcile the proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies expanding that road system. The Southern Appalachians, including the forests where I paddle and hike, are among the most biodiverse temperate forests in North America. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres. Verified species of these forests include black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The DEIS also names wild turkey and ruffed grouse among the game that requires complex forest structure with mast-producing trees, and notes that sage grouse show strong site fidelity that limits how far they can adapt when habitat changes. Headwaters here flow to both the Atlantic and the Gulf. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. Opening these lands to road construction puts all of that at risk. The agency has not shown how those losses would be made up. The rule as written already accommodates the permitting needs the agency invokes to justify rescission. The current rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions also exist for existing mineral leases and community wildfire protection. I ask the agency to identify, by name and by quantified burden, which specific operational needs are not already addressed by those existing exceptions before proceeding further. The regulatory flexibility certification attached to this proposal does not hold up. The agency certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected, and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That conclusion is reached by spreading losses across every small firm in the sector nationally rather than examining the guides and outfitters who actually hold permits in the affected areas. The certification should be withdrawn, and the impact assessment should focus on those specific operators, not a national average. Finally, I am one of the reliance interests this proposal invites comment on and then fails to weigh. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My choices about where to live, where to paddle, and what to value in this landscape have been shaped by the protection this rule has provided. Why would anyone want to take away from that? It is selfish to trade the last untouched places for a fraction of a percent of national production. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Amanda Asheville, North Carolina

I am writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule. As a resident of North Carolina, I am deeply concerned about the negative impacts this rollback will have on the more than 152,000 acres of protected, roadless land in the Pisgah and Nantahala National Forests. Repealing this rule will open up pristine, untouched ecosystems to commercial timber harvesting and costly road construction. I urge you to preserve the existing protections for the following reasons: • Drinking Water Protection: The Inventoried Roadless Areas in Western North Carolina protect vital headwaters for major rivers and creeks, including the Cullasaja River, Cartoogechaye Creek, and the Nantahala River. Millions of citizens downstream, including municipal water users as far as Charlotte, rely on these pristine areas for clean, filtered drinking water. Introducing logging roads will inevitably increase erosion and sediment runoff, threatening water security and human health. • Biodiversity and Aquatic Habitats: The Southern Appalachian forests are a globally recognized biodiversity hotspot. Increased sedimentation from new mountain roads will directly degrade critical trout streams and threaten sensitive native species like the native brook trout, hellbender salamanders, and freshwater mussels. • Backcountry Recreation and Tourism: Millions of visitors flock to WNC landscapes like Snowbird, South Mills River, and Graveyard Fields for quiet backcountry recreation, hunting, fishing, and hiking. Commercial logging and traffic noise will fundamentally alter the outdoor experience and harm the regional outdoor recreation economy.