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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 value and depend on the integrity and protection of our inventoried roadless areas. I frequently visit areas such as Linville Gorge, Sam Knob, and Wilson Creek near my home in Polkville, NC. Protecting these unfragmented landscapes is deeply personal to me because I, along with many others, hike, mountain bike, and camp in these backcountry areas. Their unspoiled and pristine quality create unique wildlife habitats and offer a glimpse at the wild beauty that is unique to North Carolina and America. 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,
Marc William Stowe Polkville, North Carolina

I am writing in opposition to the rescinding of the 2001 Roadless Rule. I SUPPORT the Roadless Rule. I live in Morganton, NC where I visit two of the areas under threat of development of roads: Linville Gorge Wilderness Addition and Wilson Creek Wild and Scenic River. Here, I hike, run, mountain bike, and learn more about nature and the rich, unique ecosystems that make them what they are. My opposition to the Roadless Rule being rescinded comes largely from a biological and ecological concern. I believe what makes a lot of these Roadless Areas so unique and important is that they are largely void of human intervention and development. While autonomy of the local level can seem like a good idea, the Federal Rule allows for a blanket protection of the identified spaces. Roads: We don’t need any more roads. We have advanced technology and highly trained people on hand to access and rescue. Roads also increase human traffic, and according to the National Interagency Fire Center: “As of 2023, the 10-year average of human-caused fires account for 88 percent of all wildfires nationally.” https://www.nifc.gov/fire-information/fire-prevention-education-mitigation/wildfire-investigation Timber: Logging is detrimental to natural ecosystems, removing wildlife habitats and allowing for invasive species to take over, as well creating a monoculture of plantlife. Logging also lends to increased ground fuel, exacerbating the spread of wildfire by any cause. Logging will decrease what it is that brings people to recreate in these areas, thus boosting surrounding economies. What these areas actually need is public education on how to exist in these spaces. If we continue to open up wild areas to more roads and use, the natural world will suffer. Rescinding this feels like it ultimately will benefit the logging companies, and that’s not what I, nor the community of people who utilize these spaces want to see. Don’t do it!

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

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

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the the Linville Gorge, Wilson Creek, and Harper Creek areas of Pisgah National Forest near my home in Boone, North Carolina. I also travel frequently to enjoy our public lands across the nation, and for many years was lucky enough to call the White River National Forest of Colorado home. There aren't words to describe how deeply personal protecting these unfragmented landscapes is to me because not only do I depend on these watersheds for clean drinking water (I have a well, my parents have a spring fed tap), I also frequently explore the backcountry trails with my two dogs, and our community depends on the tourism that comes from the beauty of this ancient mountain region. I also put immeasurable value in our pristine wildlife habitats, that provide our unique biodiversity and enjoy the bears, fox, owls, deer, coyote, woodpeckers, hummingbirds, hellbenders, and countless other priceless species that I call neighbors. I BEG the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to listen to your citizens and abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Please place the natural value of our wild and beautiful nation above the material value in order to provide not only this generation but your children's generation, the opportunity to learn & grow from these unspoiled lands. We are all counting on you to see reason. Sincerely, McClure Jackson-Cathcart, RVT Boone, North Carolina

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

I oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. I was born and raised in Western North Carolina a state that has over 172,000 protected areas of forest, this acreage was and still is my back yard. The places I am writing about are real and specific. Just the other day, standing on Sam's Knob, I saw my first wild Peregrin Falcon. I have seen Monarch way stations along the Blue Ridge Parkway which would be affected by this recension. I have spent countless hours photographing these mountains, from the Linville Gorge Wilderness to Roan Mountain and the Shining Rock Wilderness. I photograph landscapes, flora, and fauna alike, including the region's salamander populations and trout. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the roadless areas of the Pisgah National Forest, all 18 of them totaling 99,369 acres, protect the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, along with more than 30 endemic salamander species found nowhere else on Earth. The trout I photograph depend on that protection directly. The agency's own record acknowledges that roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and that sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Wilson Creek alone covers 4,863 acres of Pisgah National Forest. It is an invaluable natural resource that allows so many families the space to recreate and enjoy clean, safe water. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. I ask that the agency explain what its analysis says about sedimentation risk to the specific drainages feeding those intakes, and that it respond to this question on the record. The proposal justifies rescission in part on wildfire grounds. I grew up in these forests and have seen the concerns being brought forward firsthand, with the Table Rock fire in 2014. Opening these forests to more construction and alteration will not diminish wildfire risk. Studies show the risk will increase. The agency's own record confirms it: "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." I ask that the agency reconcile the rescission with this finding and explain why it departs from its own prior conclusions about fire occurrence in its draft environmental impact statement. Western North Carolina is reliant on our roadless areas as economic drivers generating $17.8 billion dollars for the state. The proposal's own economic record undermines its rationale. The agency has acknowledged 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." Projecting $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million, the agency's own cost-benefit analysis cannot establish a net benefit. The road system already carries a $6.9 billion maintenance backlog. The agency must explain how expanding that system under these numbers serves the public interest. The proposal also claims the rule creates unworkable permitting burdens. But the rule's text shows it already provides for exceptions: "It 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)." The agency has not identified which specific burdens fall outside those existing exceptions. It should quantify them. I oppose this rescission. These forests are where I come from. The agency has not justified this action by its own numbers or its own science.

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

I urge the U.S. Forest Service not to repeal the Roadless Rule. The Forest Service should focus should be on the overall managing and improving habitats in these roadless areas rather than a narrow focus on road-building and timber harvests in remote areas that are sensate ecologically. I am a lifelong North Carolina Resident and have spent a lot of time in the Outdoors in my state and the neighboring state of Virginia. I believe strongly in the importance of maintaining areas of intact public lands across our entire county. Our intact public lands are already limited enough, and should be preserved. Many animal species listed or proposed under the Endangered Species Act live in the areas of wilderness included in the Roadless areas. I believe lowering protections established by the Roadless rule will cause detrimental effects to these species and that are already part of overly stressed wildlife populations. Regarding the argument for localizing these rules: Many of these populations are bird populations. Many birds are also seasonally migratory, managing local populations are often local to multiple areas of the country seasonally. With this in mind its important to have federal envelopment so that local decisions do not have disasterous effects on other areas viisited by migratory bird patterns. In my life I have had the great pleasure to spend time hiking and camping in the Wilson Creek area, a roadless area in western North Carolina. Sections of it included in the removal from the roadless area in Alternatives 2 and 3 on the proposed map also specifically concern me. Having spent time in this area I am certain that development and logging that the rule change will bring will detriment the outdoor experience for visitors in the area, and impact local tourism incomes negatively.

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 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

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

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. As a citizen who regularly visits and uses Pisgah National Forest (commonly Wilson Creek and Old Fort areas, among many others), I clearly understand that rescission of this rule would impact wildlife, clean drinking water, and recreation. It would also increase fire risk, add costs to an already financially strapped Forest Service, and increase the impact of invasive species. Public opinion has consistently been documented to be against diminishing roadless areas, and for their ongoing protection.

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

Pisgah National Forest French Broad River along with its surrounding streams like Wilson Creek and trails like French Broad Loop trail are important. If this area no longer is protected by the roadless rule more traffic would divide and make it difficult for animals to move around safely. More traffic brings more people and trash endangering the animals. People also increase the chance of wild fires. Worst of all this would give logging companies an opportunity to remove natural trees in an area. When natural trees are removed it affects wild life and terrain. Tree removal effects include erosion and allow contaminated runoff into rivers and streams.The rivers and streams provide water and income to local people. It will also increase flooding.The Forest Service should analyze and study the effects when more people have access to natural places. They should review how erosion affects flooding due to lack of natural ground and trees that absorb water. They should look into affects for locals. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

Public Comment Opposing the Rescission of the 2001 Roadless Area Conservation Rule To Whom It May Concern: I am a North Carolina resident and frequent user of the Pisgah National Forest, the Wilson Creek Wild and Scenic River Area, and the Linville Gorge Wilderness Area. I am writing to strongly oppose the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule. My interest in this issue is both personal and economic. My family and I regularly hike, backpack, fish, camp, and explore the backcountry areas protected by the Roadless Rule. These lands provide some of the most outstanding recreational opportunities in the Southeast. In addition, I recently invested in a short-term rental property in western North Carolina that depends heavily on visitors who come to the region specifically to recreate in these public lands. The long-term viability of my investment, and the economic health of many mountain communities, depends on maintaining the natural character of these landscapes. The Roadless Rule protects undeveloped national forest lands from most road construction and large-scale timber harvesting activities. These protections have helped preserve the remote forests, clean streams, wildlife habitat, and scenic character that make western North Carolina a premier outdoor recreation destination. Rescinding the Rule would increase the potential for road construction, logging, and other disturbances in currently protected backcountry areas. Roads are among the most environmentally damaging forms of forest development. They fragment wildlife habitat, increase erosion, introduce invasive species, and contribute sediment to streams. These impacts are especially concerning in the steep terrain of the southern Appalachians, where water quality and aquatic ecosystems are highly sensitive to disturbance. The proposal also fails to adequately consider the economic value of conservation-based tourism. Visitors travel to western North Carolina to experience wild rivers, undeveloped forests, scenic overlooks, waterfalls, and backcountry trails. Communities across the region benefit from spending at lodging establishments, restaurants, outfitters, guide services, and local businesses. As a short-term rental owner, I see firsthand that many guests choose this area because of access to places such as Pisgah National Forest, Wilson Creek, and Linville Gorge. Degrading these landscapes would diminish the recreational experience that supports tourism and local economies. The Roadless Rule has also helped protect important public benefits that extend beyond recreation. Roadless areas provide clean drinking water, store carbon, reduce flooding impacts, and serve as critical habitat for wildlife. Once roads are built and forests fragmented, the ecological and recreational values that make these areas special can be difficult or impossible to restore. I am also concerned that the proposal does not fully account for the costs associated with expanding the National Forest road network. The Forest Service already faces a substantial backlog of road maintenance needs. Building additional roads in previously undeveloped areas could create long-term financial obligations while reducing the environmental and recreational values that the public currently enjoys. For these reasons, I respectfully recommend that the USDA: 1.Reject the proposal to rescind the 2001 Roadless Area Conservation Rule. 2.Maintain existing protections for inventoried roadless areas. 3.Fully evaluate the impacts of increased road construction and habitat fragmentation on water quality, wildlife, recreation, and tourism-dependent economies. 4.Recognize the substantial economic benefits that protected public lands provide to western North Carolina communities through outdoor recreation and tourism. In conclusion, the Roadless Rule has successfully protected some of our nation's most valuable public lands for more than two decades. As someone who regularly recreates in the Pisgah National Forest, Wilson Creek Wild and Scenic River Area, and Linville Gorge Wilderness Area, and as a recent investor in a tourism-dependent short-term rental property, I believe rescinding this rule would result in unnecessary environmental damage, diminished recreation opportunities, and negative economic impacts for western North Carolina. I urge the USDA to retain the Roadless Rule and continue protecting these irreplaceable landscapes for future generations. Thank you for considering my comments. Sincerely, Brad Smith North Carolina Resident

I am writing to you as the Executive Director of the Northwest North Carolina Mountain Bike Alliance to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. We as an organization care deeply about our national forests because many of our members utilize the Grandfather District of Pisgah National Forest to recreate regularly. A great deal of what makes this area special is it's remote and secluded nature of the trails there. Furthermore roadless areas protect habitat for at-risk species, safeguard clean drinking water for many millions of Americans, and preserve old-growth forests hundreds of years old. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. The vast majority of wildfires are human-caused, and most ignite close to roadways. Research shows wildfires are more likely to start in roaded areas than in unroaded tracts. Please reconsider rescinding the Roadless Rule. It is vital for the protection of the Wilson Creek area of Pisgah National Forest; an area with the designation as a National Wild and Scenic River, and one that many of our members hold dear and want to see protected from further further logging and development. Thank you.

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.

I had the opportunity to backpack on the Mountain-to-Sea Trail in the Upper Wilson Creek Roadless Area. The untouched beauty of the area was a highlight for me. The creeks and streams were so clean and clear, much healthier than water sources I have seen in areas with many more roads. I don't think we should remove the protections and keep this beautiful spot a place for many more generations to come.