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I am writing in order to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Area Conservation Rule. I have cared deeply for our national forests and public lands since I can remember. My family often recreated in national forests, and I went on my first camping trip in the Chattahoochee National Forest at just 3 months old! Throughout my life I have continued to be involved in our public lands and national forests, whether through recreation, work (I am a hydrologic technician at the Grand Canyon NP!), and even relying on it for drinking water in Flagstaff, Arizona. Our public lands and national forests are deeply engrained in my life and the lives of so many of my friends and neighbors here in Flagstaff. Because of this and so many other reasons, I strongly oppose the rescinding of the 2001 Roadless Rule. To begin, the Forest Service was established to protect forests and watersheds from logging and development. If that is truly the goal, developing roads is in clear and direct opposition to this goal. It has been proven that environmental fragmentation caused by road construction can be even more harmful to habitat than clearcutting. Additionally, roadless areas protect habitat for over 1500 at-risk species, protect old growth forests (which in turn protect and serve us!), and protect/provide clean drinking water to 60 million Americans. It is abundantly clear that this proposed decision is being made out of greed, not to uphold the standards with which the Forest Service has been tasked. Additionally, the claim that these roads will help reduce fire risk is absolutely preposterous. An overwhelming majority of fires are caused by humans, with the majority of those fires starting within a few hundred feet of roads. Additional roads would only increased the number of human caused fires. Additionally, new research is showing that wildfires are 4x more likely to start in roaded areas than in unroaded ones. The rule already allows exceptions for logging and road building for the purpose of reducing fire risk, so it is wildly misleading to claim fire risk reduction as a reason to rescind the rule when that is already allowed within the rule. The administration does not need to rescind the rule in order to build roads or log simply for fire risk reduction. They want to rescind the rule because the road building and logging would absolutely not be occuring to simply reduce fire risk but to increase logging in general. This would be a blatant misrepresentation of the goals of rescinding the rule and an obvious manipulation of wording to fool the public. It's a disgusting tactic and honestly embarrassing for the administration to be talking and lying in circles. The fiscal year 26 budget eliminates funding for wildfire suppression and management, so it is a joke and a lie for USDA to claim that this rule is genuinely for mitigating fire risk. Economically, the rescinding of this rule also makes no sense. Text within the rule already states that the Forest Service could not maintain its existing road system safely and to environmental standards. As budget and personnel cuts continue, how is it now economically feasible to maintain MORE roads? It's not. Also, most forest revenue these days come from recreation, NOT logging. More roads would degrade recreation opportunities, tightening an already tight budget. The Roadless Rule is one of the most popular rules ever implemented in USDA history. I am at a loss really for why it is even being considered to be rescinded. The rule received the most public comments in HISTORY at the time with 96% of those comments in support of the roadless protections. Updated polling supports the continued claim that this rule is extremely popular - 75% of Americans support it with only 16% in opposition. If the USDA is really the people's department like they claim, then maybe they should listen to the 75% of Americans that are still in support of this rule. These are just a few environmental, fire, and economic related reasons for why I feel the Roadless Rule should not be rescinded. It seems very obvious that this proposition is in the interest of a particular few, not the wellbeing of the majority or the environment. Before the agency move forward with any decision, I ask that they: 1. Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building and provide the results with full transparency. 2. Guarantee that no watersheds will be negatively affected by rescission and provide proof that this is the case (environmental and impact analysis will be helpful!!) 3. Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs and how this will fit into the plan for new road construction. 4. And commit to moving forward with full transparency, including a full account of how public comments were considered and concerns addressed. Thank you, Emma

Total comments: 25 Dear Chief Schultz, We, the undersigned business owners, urge you to stop the rescission of the 2001 Roadless Rule. The Roadless Rule protects 63 thousand acres of land in the Chattahoochee National Forest from the development of roads, logging, and mining. The protected forests provide habitat for wildlife, and filter the air and streams in Northern Georgia. These streams are the headwaters of three major Georgia rivers: the Chattahoochee, Conasauga, and the Etowah, which provide clean drinking water to millions of Georgians. These wild parts of our state help to attract tourists which contribute to the economy of the communities that serve as gateways to the Chattahoochee National Forest and the Blue Ridge Mountains. All of this could be put at risk if the Roadless Rule is rescinded. The air, water, and land could become polluted and scenic landscapes could be damaged for generations. Georgia’s nature is special, and we want to keep it safe. Please protect Northern Georgia by keeping the 2001 Roadless Rule in place. Sincerely, Maria Anderson, Owner, Das Ice Cream Cafe, Helen, GA Dawn Bender, Owner, Black Bear Mercantile LLC, Dahlonega, GA Haley Byers, Owner, The Storybook Market, Gainesville, GA Justin Cape, Owner, Outdoors With Cape LLC, Gainesville, GA Coco Cooper, Owner, Deerbird Boutique, Blue Ridge, GA Cindy Edmondson, Owner, Dahlonega Collective LLC, Dahlonega, GA Drew Friedrich, Owner, Cohutta Fishing Company, Blue Ridge, GA Jimmy Harris, Owner, Unicoi Outfitters LLC, Sautee, GA Lewis Hirsch, Owner, The Modern Fly Fishers, Atlanta, GA Tim Hitchcock, Owner, Helen Huggables, Helen, GA Kathryne Jones, Owner, Haggard Hiker Outdoors, Cleveland, GA James Kern, Owner, The Mason Jar Shoppe, Helen, GA Moe Lyons, Owner, Moe’s Record Shop, Gainesville, GA Trey McFalls, Owner, Shady Creek Expeditions, Clayton, GA Shannon Miles, Owner, NoFo Brew Co, Cleveland, GA Haley Nottage, Owner, Slice of Helen, Helen, GA Jackie Pressley, Owner, Hooch River Trading, Helen, GA Abbey Prieto, Owner, The Shack of Ellijay, Ellijay, GA Tara Prieto, Owner, The Shack of Ellijay, Ellijay, GA Martin Sherby, Owner, Racquets & Togs Tennis, Gainesville, GA Vicky Treadway, Owner, Steve’s Old Time Photo, Helen, GA Andrew Triner, Owner, Twigs and XXS LLC, Blue Ridge, GA Kristen Triner, Owner, Moonbeams & Mudpies, Blue Ridge, GA Pandra Williams, Owner, Beech Hollow Wildflower Farm, Scottdale, GA Lincoln Wright, Owner, Chatt St Tea Room, Helen, GA

I am an Environmental Engineer in the state of Georgia, currently employed in a regulatory field. The roadless areas closest to me are in the Chattahoochee National Forest, the Nantahala National Forest, and the Great Smoky Mountains. I spend a considerable amount of time recreating in these areas on my weekends and off hours. I have also taken trips across the country and recreated in roadless areas in Washington and California. I have experienced firsthand the beauty and value of these areas, and wish to highlight the importance in conserving them. I am writing this comment to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. According to the USDA Forest Service's own assessment, rescinding the roadless rule will NOT meaningfully decrease wildfire risk - it is actually more likely to INCREASE wildfire risk. Page 86 of the DEIS report states: "the incidence of human-caused fires generally increases with proximity to roads." Additionally, there is already an exception in the existing Rule for cutting and removing small timber as a means of reducing wildfire risk. Page 102 of the DEIS states that "timber projects are the primary motivation and funding source for new roads", NOT reducing wildfire risk. However, the Forest Service already lacks the budget to maintain its existing roads and infrastructure, with a current deferred maintenance backlog of $7 billion. The DEIS states, on page 45: "revenue generated by timber sales or other...activities would be used for some road-related system management but would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." So where is the money needed to build these proposed new roads, at an estimated cost of $2 million per mile (as stated in page 42 of the DEIS), coming from? Rescinding the Roadless Rule will have negative impacts on soil, water, and air quality. Increased timber harvests will increase soil erosion, compaction, and landslide probability. Page 120 of the DEIS states that there are 7,000 municipal water intakes within watersheds in designated roadless areas, supplying water to nearly 5 million people just within the Pacific Southwest. Water quality will be degraded by the addition of new roads, as roading and timber harvest degrade water quality by increasing sediment and nutrient runoff into streams, creating warmer and hypoxic conditions (page 117, DEIS). Removing tree canopies will alter the timing of spring snowmelt and runoff. Increases in timber harvest will also result in increased emissions from trucks and other equipment (page 128, DEIS). Page 160 of the report states that roadless areas "overlap the range of more than 300 threatened, endangered, and proposed species, 79 final or proposed critical habitats managed by the USFWS, and 19 critical habitats...listed under the ESA". The DEIS projects negative impacts that include habitat loss and degradation, introduction and spread of non-native and invasive species, increased human-wildlife conflict, and detrimental impacts to fish and game species. (Pages 142, 151, 152) Though the current administration is waging a war against the Endangered Species Act, the USFS IS CURRENTLY STILL REQUIRED to comply with the ESA. It is unclear how the USFS plans to do so when its own report states that rescinding the Roadless Rule will directly lead to noncompliance with the ESA. Circling back to the financial questions posed in the second paragraph, it is known that recreation and tourism are more profitable than roadless timber. In 2024, visitors to roadless areas spend $8.5 billion total in local communities (DEIS page 212). Meanwhile, timber harvest value in 2024 across ALL national forest land was just $151 million (DEIS page 220). Roadless timber is only expected to generate $2.2-$11.4 million dollars annually (DEIS page 220). Even a 1% loss in visitation to roadless areas due to rescission of this rule could lead to a projected loss of $9 million annually. So again I ask, who stands to profit from these timber harvests? Seemingly not the USFS, since we have covered that profits from timber harvests will not be enough to cover the costs of building the roads required for such projects, and likely not the local economies poised to lose millions tourism dollars either. If there is no clear benefit, financial or otherwise, to increased timber harvests, then why is it being proposed? Who stands to benefit? In the current era of constant threats to our natural environment and the health and financial wellbeing of the American people, we must place the highest importance on protecting and conserving what natural resources we have left. Due to the financial concerns and projected negative impacts on wildfire risk, soil quality, water quality, air quality, biodiversity, recreation, and tourism as outlined above, I must oppose the recission of the Roadless Rule, and urge all others to do the same.

To the Roadless Rule Rulemaking Team:Edit salutation I am writing as a naturalist and concerned citizen opposing the rescission of the Roadless Rule. The proposal would destroy the places and wildlife that I love. I am concerned about how it would affect the Chattahoochee National Forest, a place I go for peace, recreation, and wildlife appreciation. Boggs Creek in the Chattahoochee National Forest protects the headwaters of Dicks Creek and Cowrock Creek, which form the foundation of a cold-water stream network that supports species dependent on stable, unwarmed water. The hellbender (*Cryptobranchus alleganiensis*, near threatened, IUCN), a fully aquatic salamander that requires high dissolved oxygen and temperatures below 74°F, depends on the riparian shade and groundwater inputs that an intact, roadless headwater forest provides. The seepage salamander (*Desmognathus aeneus*, near threatened, IUCN) and Chattahoochee slimy salamander (*Plethodon chattahoochee*, imperiled, IUCN) occupy the saturated seepage zones and riparian margins of these headwater systems, where they are sensitive to both temperature fluctuation and hydrological disruption. Maintaining the roadless condition preserves the forest canopy and soil structure that regulate streamflow and temperature across the entire downstream drainage. Boggs Creek harbors multiple rare plant species adapted to the specific microclimates of Southern Appalachian cove forests and seepage zones: small whorled pogonia (*Isotria medeoloides*, federally threatened), mountain sweet pepperbush (*Clethra acuminata*, apparently secure, IUCN), mountain dwarf-dandelion (*Krigia montana*, vulnerable, IUCN), jewelled wakerobin (*Trillium simile*, vulnerable, IUCN), and mountain meadow-rue (*Thalictrum clavatum*, apparently secure, IUCN). These species occupy narrow ecological niches—seepage slopes, cove bottoms, and specific soil and moisture conditions—that are vulnerable to disturbance and slow to recover. The roadless condition protects the hydrological stability and undisturbed soil structure these plants require; once disrupted, the recovery of rare plant populations can take decades or longer, if restoration is possible at all.Edit personal connection We are already watching the decline of too many beloved species. The proposed rescission is a bad idea unsupported by science that would exacerbate and accelerate that loss. It will increase the introduction and spread of invasive species. It will increase erosion. It will negatively impact water quality. It will cause destruction in one of the things that most makes America great --- our wild and scenic spaces. I see no way that it benefits those of us who enjoy or live near the forests, only irreparable, irreversible loss.Edit what you lose Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land, expanding the six largest core protected areas in the lower 48 by an average of 25 percent. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including temperate grasslands and cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Please accept my entire formal comment attached as FS-2025-0001-223869_RLC-20261007-I1RDZT.pdf I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. Respectfully, Sarah E. Kelsey

"I am the Lorax and I speak for the Trees" I OPPOSE the Trump administration’s plans to rescind the Roadless Area Conservation Rule. The roadless areas in our national forests are a part of our American heritage that we pass on to our children and grand children and should be protected. As we celebrate the 250th birthday of the United States, my ancestors fought the British/Loyalist in the Battle of Kings Mountain in 1780 to defend our nascent country which meant I could grow up enjoying the Chattahoochee National Forest two hundred years later. Y'all should be protecting our forests, which are older than America, so that generations of Americans can have a similar experience that I did. The proposed repeal is being justified   as a wildfire-prevention measure, peer-reviewed evidence shows that increasing roadbuilding will only increase wildfires.  More than 80% of wildfires occur within  800 meters  of roads, according to recent research.  In addition, increasing timber production means cutting down larger, older trees, which are the most resilient to wildfire. Once an old-growth tree is cut and sold, it will take  hundreds of years to  replace it, and even longer for ecosystems to heal following clearcutting. Forests, especially older trees that absorb and store more carbon, sustain fish, birds, wildlife, and people; filter drinking water, and provide  recreational opportunities, which is why it is important for our national security to protect them from the harmful effects of climate change. As many as 414 animals and plants listed as endangered, threatened or proposed for listing under the Endangered Species Act have ranges that overlap with roadless areas. Americans just mourned the loss of our beloved bald eagle Jackie and celebrated Fat Bear Week, destroying our forests threatens our fellow Americans (e.g. eagles, owls, bears, etc.) that call those places their homes. Mama bears send their cubs up trees to protect them from harm and Americans want them to be safe too so they can be future Fat Bear champions. In addition to providing crucial wildlife habitat, roadless areas are very important for delivering clean water to fish-bearing streams and eventually into the faucets of many American homes. Our forests are revenue generators for our economy. They are places where many Americans go to hike, ride, bike, fish and hunt – activities that fuel a $1.2 trillion outdoor recreation economy that supports over five million jobs. A recent economic study found that roadless areas in the continental United States (excluding Idaho and Colorado, which are covered under separate rules) generate $24 billion in economic benefits. In contrast, sales of timber from National Forests represent about 1% of that figure. The benefits of this rule are so compelling that I am asking the Forest Service to KEEP this rule and not weaken it in any way. By doing this, we can promote wildlife conservation in this country and contribute to quality of life and economic security for our communities. A few quotes from our fellow Americans about protecting trees and nature: "To exist as a nation, to prosper as a state, and to live as a people, we must have trees." - Theodore Roosevelt, the 26th President of the United States who established the United States Forest Service “Nature itself is reduced at times to a bargaining chip, a commodity to be bartered for economic or political gain. As a result, God’s creation turns into a battleground for the control of vital resources.” - Pope Leo XIV, our fellow American "I am the Lorax and I speak for the trees" Dr. Seuss's The Lorax When I Am Among The Trees When I am among the trees, especially the willows and the honey locust, equally the beech, the oaks and the pines, they give off such hints of gladness. I would almost say that they save me, and daily. I am so distant from the hope of myself, in which I have goodness, and discernment, and never hurry through the world but walk slowly, and bow often. Around me the trees stir in their leaves and call out, “Stay awhile.” The light flows from their branches. And they call again, “It’s simple,” they say, “and you too have come into the world to do this, to go easy, to be filled with light, and to shine Mary Oliver, 1935-2019

To whom it may concern: My name is Johnathon Stutzman and I am writing today to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. As a wildlife biologist, I recognize the importance of roadless areas for the health and conservation of the species and ecosystems that we cherish in this country. One of the largest issues facing wildlife worldwide is the ever expanding influence of the anthropogenic world, especially roads. When you think about the negative influence of roads on wildlife, the most common images conjured are multiple lane highways that are impossible for just about every species to cross safely. But even quiet backcountry roads can have negative impacts on the wildlife surrounding them. Studies have found that even occasional human-related noises can cause wildlife to leave an area for prolonged periods of time. Additionally, adding new roads onto the landscape fragments intact, contiguous habitat that is currently providing pathways through which different wildlife species can move to find new food sources, mates, or migration routes. A lack of connected, contiguous landscapes is a major issue in our modernizing world and this rule change would only accelerate the destruction of our ecosystems. In addition to its negative impacts on sensitive species around the country, this proposal would also create undue burden on the already chronically underfunded U.S. Forest Service. USFS maintains more miles of roads than another entity in the United States, yet has seen downward trends in funding over the past few decades. This has left thousands of miles of roads poorly maintained and Americans are suffering the consequences of the lack of capacity. Taxpayers are also left to foot the bill for these roads that are only becoming more expensive to maintain as years of neglect pile up. As a resident of the Georgia piedmont, rescinding the Roadless Rule would hit particularly close to home. We are lucky enough to live close to the Chattahoochee National Forest, which is home to an incredible diversity of flora and fauna, some of which are found nowhere else on Earth. The southern Appalachians are a global biodiversity hotspot and the Roadless Rule currently protects much of it from harmful development, pollution, and logging. These areas are also where our communities go to recreate and enjoy the beauty of the natural world by hunting, fishing, hiking, birding, etc. In my duties as a wildlife biologist, I also visit many of these to conduct monitoring and research on how best to protect species that have persisted in the southern Appalachians for millennia before us. Rescinding the Roadless Rule would undermine the work of generations of Georgians who value these natural resources as the birthright of everyone in the state and region and go against the strong public support for Roadless Areas here in Georgia. For the reasons listed above, fully or partially rescinding the Roadless Area Conservation Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake and I am in strong support of Alternative 1, the No Action Alternative. These roadless areas need to be protected for the benefit of the flora and fauna living there, our communities, and future generations of Americans who should inherit a better world from those of us who have the power to create it.

To whom it may concern: My name is Emily Card and I am writing today to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. As a PhD student studying ecology, I recognize the importance of roadless areas for the health and conservation of the species and ecosystems that we cherish in this country. One of the largest issues facing wildlife worldwide is the ever expanding influence of the anthropogenic world, especially roads. The most common images conjured when thinking about the negative impacts of roads are multi-lane highways that are impossible for almost any species to cross safely. But backcountry roads can have negative impacts on the wildlife surrounding them too. Studies have found that even occasional human-related noises can cause wildlife to leave an area for prolonged periods of time. Additionally, adding new roads onto the landscape fragments intact, contiguous habitat that is currently providing pathways through which different wildlife species can move to find new food sources, mates, or migration routes. A lack of connected, contiguous landscapes is a major issue in our modernizing world and this rule change would only accelerate the destruction of our ecosystems. In addition to its negative impacts on sensitive species around the country, this proposal would also create undue burden on the already chronically underfunded U.S. Forest Service. USFS maintains more miles of roads than another entity in the United States, yet has seen downward trends in funding over the past few decades. This has left thousands of miles of roads poorly maintained and Americans are suffering the consequences of the lack of capacity. Taxpayers are also left to foot the bill for these roads that are only becoming more expensive to maintain as years of neglect pile up. As a resident of the Georgia piedmont, rescinding the Roadless Rule would hit particularly close to home. We are lucky enough to live close to the Chattahoochee National Forest, which is home to an incredible diversity of flora and fauna, some of which are found nowhere else on Earth. The southern Appalachians are a global biodiversity hotspot and the Roadless Rule currently protects significant portions of the region from harmful development, pollution, and logging. These areas are also where our communities go to recreate and enjoy the beauty of the natural world by hunting, fishing, hiking, birding, etc. Rescinding the Roadless Rule would undermine the work of generations of Georgians who value these natural resources as the birthright of everyone in the state and region and go against the strong public support for Roadless Areas here in Georgia. For the reasons listed above, fully or partially rescinding the Roadless Area Conservation Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake and I am in strong support of Alternative 1, the No Action Alternative. These roadless areas need to be protected for the benefit of the flora and fauna living there, our communities, and future generations of Americans who should inherit a better world from those of us who have the power to create it.

Secretary Rollins and Chief Shultz, Your plan to roll back the Roadless Area Conservation Rule would undermine tens of millions of acres of U.S. forests, wetlands, and canyons that belong to the American People. It is your role to protect these ecological treasures from the kind of development that would endanger them. Opening up our forests to destructive logging and road building will lead to water pollution of municipal water supplies from Sitka, Alaska to Atlanta, Georgia to Phoenix, Arizona and disrupt recreation areas used by hikers, paddlers, campers, fishermen, and hunters. It will threaten endangered species, disturb wildlife and interrupt vital corridors that allow migration. The Roadless Area Conservation Rule should be STRENGTHENED to protect Alaska’s Tongass National Forest - the largest temperate rainforest in the world, California’s Tahoe National Forest, segments of the Appalachian Trail, the Chattahoochee National Forest. As an avid hiker and camper who grew up in New Mexico, I have witnessed the power and beauty of these pristine environments. My father, who hiked and fished and camped in remote corners of our national forests introduced these special places to me. Because he was a geologist with a deep knowledge of biology, he helped me to understand how connected these natural places are to our well-being. If we destroy them or allow them to be destroyed, it will be at our own peril – and tragically, the peril of our children. The rollback of the Roadless Area Conservation Rule cannot stand. Thank you for your attention to this matter of vital national interest.

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: As an avid hiker and outdoorswoman, I am writing to strongly oppose repealing the roadless rule. I stand with the majority of Americans who support keeping the Roadless Rule - 76% according to the Pew Research Center, and over 90% of the comments during the last public comment period. Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Rescinding the Roadless Rule would open the Cedar Mountain, Chattahoochee 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. Areas protected by the Roadless Rule include more than 25,000 miles of trails - including the trail closest to my heart, and the most famous of our National Scenic Trails, the Appalachian Trail. Repealing the Roadless Rule would also impact a variety of other outdoor activities, including over 760 miles of whitewater routes, thousands of climbing and bouldering routes, world-class backcountry hunting grounds, and pristine fishing waters. These activities are not only beneficial for the economies of nearby, often rural communities, but also allow people an escape from industrial noise, traffic, and permanent roads. Eliminating the Roadless Rule is harmful to the environment in countless ways - impacting native species' habitats and migratory areas, worsening water quality, and harming endangered species' already limited populations, to name a few. The most concerning risk to me is the increased risk of wildfires. With higher temperatures and less water fall each year, we already have deadly wildlifes every year. Repealing the Roadless Rule has been touted as a way to reduce wildfires erroneously. The majority of fires are human-caused and the U.S. Forest Service data shows that 78 percent of human-caused fires on national forests begin within half a mile of a road. Bringing roads further into the backcountry means increased risk of more fires due to more humans having easier access to these remote areas. Additionally, thicker forests are better wind barriers to prevent the spread of wildfire, and older trees take longer to burn through than young trees. This comment joins the record in opposition to the proposed rescission action. Sincerely, Dr. Danielle Rustem

Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Serene, remote places matter. I camp and hike to experience nature, and I photograph the rivers, forest and wildlife of the Oconee-Chattahoochee National Forest across the wilderness areas. Turner Creek, Boggs Creek, Cedar Mountain, Helton Creek and Duck Branch, all inventoried roadless areas in the Chattahoochee National Forest in Georgia, are the kinds of places I go looking for that quiet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres. These include black bear, brook trout, cerulean warbler, hellbender and the northern long-eared bat. When I photograph wildlife in these wilderness areas, I am documenting something that took a very long time to persist here. We cannot ruin areas like this, because they are near impossible to bring back to the same state once activities are started. A logged stand grows back. A road does not. I also ride forest roads and OHV areas on my motorcycle, so I understand road management from the user side. The agency needs to direct resources to maintaining and improving existing infrastructure rather than expanding and creating a negative feedback loop of destroyed infrastructure. The agency's own record states: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Increasing the number of roads is only going to make the Forest Service's job harder. I ask that the agency name the specific funding source for any new road construction and maintenance in currently roadless areas and state the projected change in the deferred maintenance backlog that would result from this rescission. The economic case for rescission is not established. The agency's own Cost Benefit Analysis states: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." That range runs from a loss to a gain. It does not demonstrate a benefit. The cost column excludes road construction, maintenance and fuel treatment costs that the same document quantifies elsewhere. Our public land needs to prioritize recreational activities because they promote a healthier economy in the surrounding area. Too much emphasis is placed on destructive activities and unmaintainable development. The agency must place the Cost Benefit Analysis on the public docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind any claim that impacts could exceed a specific dollar threshold. The small-business certification does not hold up. The proposed rule 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. Across the Southern region, which includes Georgia, 378 municipal water intakes sit in watersheds containing affected roadless areas. Communities tied to clean water and recreation depend on what these roadless areas protect. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and assess the impact on the small entities who are actually operating in and around these roadless areas. Finally, the agency is asking the public to comment on consequences it simultaneously declares out of scope. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). I want my kids to inherit a healthier and better treed forest system than I did. I want the next generation to feel like they aren't constantly fighting for the survival of wilderness in the face of people trying to destroy our shared forest system. The agency cannot ask the public to do the analysis it has refused to do. It must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a direct component of this rulemaking before any final decision is made. Sincerely, Travis DeLoach Dahlonega, GA

The backcountry wilderness I hike is extremely important to me. Hiking through places untouched by roads, surrounded by wild forests, is where I feel most connected to the world around me and at peace. The 2001 Roadless Area Conservation Rule is what makes this possible, and its rescission under Docket FS-2025-0001 would cause irreversible damage. I oppose this proposal fully. Tusquitee Bald in the Nantahala National Forest, North Carolina, is one place I know from my own experience. I have many wonderful memories hiking there with my family. The old-growth forests, undisturbed watersheds, and the diverse community of endemic salamanders I’ve encountered there are part of what makes it special. The Southern Appalachians are among the most biodiverse temperate forests in North America, and the Nantahala holds 14 roadless areas totaling 52,304 acres. These roadless areas protect the last wild headwaters that flow to both the Atlantic and the Gulf, along with salamander species found nowhere else on Earth. The roadless rule must remain to preserve these forests, wildlife, and watersheds. The Lance Creek roadless area in the Chattahoochee National Forest in Georgia is home to Springer Mountain, the southern terminus of the Appalachian Trail. I’ve had the opportunity to hike that section of the A.T., and I hope someday to complete the entire trail. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres, and it is part of the wildest land in the southeastern United States. It is home to black bears, brook trout, hellbender, cerulean warbler, and the northern long-eared bat. Without the roadless rule, Lance Creek and the other roadless areas along the trail become vulnerable to compromised scenic views, fragmented habitats, and degraded water quality. I hope that when I do complete the trail, I will be hiking through wilderness and alongside wildlife that the rule has continued to protect. I fully oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. This rule protects irreplaceable land home to old growth forests, diverse wildlife, and watersheds. This rule protects the undisturbed wilderness where I hike, find connection, and peace. It protects the places that we all cherish. These public lands belong to the people. Please listen to our comments.

RE: RIN 0596-AD66, Docket FS-2025-0001 I live in Pooler, Georgia, and I grew up hiking and camping in Utah's national forests. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Please keep it in place nationwide, including in the Tongass National Forest. 1. USDA's own numbers show little benefit. The "Summary of Potential Impacts" section says new management chances would be "modest and localized." The highest timber revenue estimate is $11.4 million per year. The Forest Service already has a $6.9 billion backlog of road and bridge repairs. Even that highest estimate equals less than 0.2% of the backlog each year. New roads would add to a bill the agency cannot pay now. 2. Wildfire work is already allowed. The 2001 rule includes exceptions for cutting small trees to lower wildfire risk. The proposed rule also admits that more public access can increase human-caused fires (Summary of Potential Impacts, "Wildfire risk"). If the exceptions are too slow to use, USDA should speed up that review process. It should not remove the whole rule. 3. Georgia's roadless areas matter. Georgia has about 63,000 roadless acres in the Chattahoochee National Forest. These lands protect parts of the Appalachian and Benton MacKaye trails and help supply drinking water for millions of Georgians. Forest plans can be changed much more easily than a national rule. Protection for these places should not depend on each plan revision. 4. National forests belong to everyone. These lands belong to all Americans, not just the people near them. A national rule is the right tool for national lands. I grew up in Utah. I spent many weekends and summer days hiking, camping, and having cookouts in the Uinta-Wasatch-Cache National Forest. I thought easy access to national forests was normal in every state. Now that I live in Georgia, I know how rare these lands are. They matter for their beauty, and they also protect the water we drink, the air we breathe, and the plants and animals that live there. These benefits are hard to put a dollar value on, but USDA should still weigh them against the small timber gains. I also understand wildfire. This year, both Utah and Georgia saw dangerous fires. I know that fire is a natural part of a forest's life cycle, and that planned, controlled burns are an important tool for keeping forests healthy. Wildfires that people start by accident are different. Visitors often underestimate how fast a campfire or a tossed cigarette can get out of control. Roads bring more people into wild areas, and more people mean more human-caused fires. That is a risk USDA's own proposal admits. Please withdraw the proposed rule and keep the 2001 Roadless Rule.

As a horticulturist and nationally recognized authority on science-based gardening and environmental stewardship with 35+ years of experience. I oppose rescission. I live and work in the Atlanta, GA, area and often recreate in the Chattahoochee National Forest.

I write in opposition to the proposed rescission of the Roadless Area Conservation Rule. The proposal rests its justification largely on executive orders and administration policy priorities. Executive orders are statements of policy from a single administration. They are not law, and they are not a substitute for the reasoned analysis the Administrative Procedure Act requires. Rescinding a rule is itself rulemaking, and the agency must examine the relevant data and articulate a rational connection between the facts found and the choice made. A directive to reduce regulation does not supply that connection. Administration priorities change every four or eight years; the inventoried roadless areas this rule protects cannot be changed back. The 2001 rule was adopted after one of the largest public comment processes in the history of federal rulemaking, and it rests on findings about watershed protection, wildlife habitat, recreation, and the cost of maintaining an expanding road system the agency already could not afford. If the Forest Service now intends to reverse that judgment, it must explain what in the record has changed. Citing policy direction from the executive branch, without independent analysis of the resources at stake, is the kind of decision that fails arbitrary and capricious review because it relies on factors outside the statute and ignores important aspects of the problem. I write from Georgia, where this rule protects about 63,000 acres of inventoried roadless areas in the Chattahoochee National Forest, including Tray Mountain, Rabun Bald, the additions to the Cohutta Wilderness, and the slopes around Brasstown Bald, the highest point in the state. These areas sit within a two hour drive of metropolitan Atlanta and its seven million residents, and they carry the Appalachian Trail, the state's premier trout streams, and the headwaters that feed Georgia's drinking water supply. North Georgia is also one of the fastest growing recreation regions in the country, which makes the undeveloped character of these areas more valuable each year, not less. I hike and camp in these forests, and the recreation economy of the mountain counties depends on visitors who come for exactly the qualities that roads and logging would remove. Georgia's stake in this rule is concrete, and the proposal nowhere accounts for it. I urge the Forest Service to withdraw the proposal. If the agency proceeds, any final rule should rest on a current, independent evaluation of the roadless inventory and the long term public interest in it, not on executive orders that may be revoked as easily as they were issued.

I am opposed to eliminating the roadless rule. We need to maintain intact ecosystems. A few of the areas that would be affected are in my backyard. I’m privileged to live near the Chattahoochee national forest in Ga. Many people come to our area to recreate and enjoy the nature around them. They come to see nature that would be destroyed or largely negatively impacted if the roadless rule is eliminated. I hope these areas will be free from development and roads for generations to come. Please do not eliminate the roadless rule.

I strongly oppose eliminating the Roadless Rule. I live in the North Georgia mountains, surrounded by the Chattahoochee National Forest, and I spend a great deal of time hiking its trails and Forest Service roads. These public lands aren't an abstract issue to me. They're part of my community, my daily life, and one of the reasons I chose to live here. Roadless areas protect far more than scenery. They protect wildlife habitat, clean streams and watersheds, intact forests, and places where people can experience the quiet and wild character of our public lands. Once these areas are fragmented by new roads and development, we can't simply put them back the way they were. Our national forests belong not just to those of us fortunate enough to enjoy them today, but to generations who haven't had that opportunity yet. Protecting remaining roadless areas is a responsible and remarkably modest thing we can do for them. Please retain the Roadless Rule and continue protecting these public lands and natural resources.

I am one of many who oppose the Roadless Rule Rollback. The Roadless Rule protects our environment and continues to shape how humans live . As someone for whom roadless national forest is not a policy category but a physical place — a specific and irreplaceable landscape that I have accessed, observed, and relied upon — I am submitting these comments to oppose the proposed rescission of the 2001 Rule and to request that the Department's final record reflect the full weight of the public interest the Rule was established to protect. I’ve spent time near Miller Creek. To have construction of roads near Miller Creek would not only raise the risk of human started fires, it would also be endangering a long list of animal and plant species. It would destroy historical sites of indigenous peoples. The CCC conducted reforestation projects throughout the Chattahoochee National Forest to repair damage from previous industrial-era clear-cutting and mining. We do not need any more destruction for our future generations to fix. Among many days in these forests, one has stayed with me. Traveling into nature is an escape for my husband and I. After meeting in New York, every vacation we've shared has been to escape into nature. Hiking and visiting Miller Creek was one of our many trips into nature. My husband was born and raised in Georgia. He is a hiker, an explorer and a lover of nature. He has shown me the true value of nature. Exploring forests, camping and experiencing wildlife is a gift. Protected lands need to stay protected. Not only to preserve wildlife existing for our future generations, but to protect these indescribable experiences. Nature is an escape for any of us, but for many people, nature is a way of life. An actual means of existence. For indigenous individuals, nature is their ancestry, their life purpose to protect, and apart of their beliefs that plant species like the Grandmother trees are a part of their family lineage. The Grandmother trees being stripped from Arizona is causing irreversible damage to the desert landscape of Arizona. It is also destroying indigenous legacies. The Department should understand that the Rule's rescission would produce real and lasting consequences — not only for the lands themselves, but for the people whose lives have been shaped by access to them. Regarding the Miller Creek in the Chattahoochee National Forest, Georgia: Roadless areas are disproportionately important habitat for federally listed threatened and endangered plants and animals. Roadless areas hold habitat for over half of America's wildlife species of conservation concern. A study of 537 imperiled wildlife species in the contiguous U.S. found that 308 — 57 percent — have suitable habitat in one or more Inventoried Roadless Areas. The median roadless area provides habitat for 10 such species, with a maximum of 62 (Dietz et al. 2021). — Matthew S. Dietz, Kevin Barnett, R. Travis Belote, Gregory H. Aplet, 2021 · Global Ecology and Conservation (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Miller Creek, Chattahoochee 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. Construction runoff will lead to a large amount of sediment in the water, which will disturb aquatic life. Construction noise and air pollution will disturb animals on land and disturb their natural trails. Water moves through this landscape as both streams and subsurface flow, emerging in spring-fed seeps that support specialized, threatened plant and tree communities. Including Table Mountain pine and Flame Azalea. The understory in these moist forests is thick with great rhododendron and mountain laurel. The streams and seepage zones support aquatic and semi-aquatic wildlife. Including salamanders, eastern newts, and rainbow trout. In the forest, the federally endangered Northern Long-Eared Bat and federally endangered Gray bat hunt insects above the streams and in forest gaps. Here at Miller Creek, you’ll find everything from wild turkeys to monarch butterflies. There is a vast ecosystem and intricate workings of connectivity throughout and surrounding the areas of Miller Creek that cannot sustain construction of any kind. The Miller Creek roadless area, comprising 701 acres in Lumpkin County within the Blue Ridge Ranger District, is protected under the 2001 Roadless Area Conservation Rule and managed as part of the larger Chattahoochee National Forest established in 1936. The Rule should not fall; the Department should act to keep it in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have hiked and boated throughout my life in the Chattahoochee National Forest. I value these areas as places to show my children and grandchildren what untouched wild areas can look like. This area houses some of the only remaining wildlife corridors left in Georgia, and this is of great value to me as a taxpayer. Roads in those places would be a desecration, not to mention wholly unnecessary from a financial standpoint and of no public benefit. It is fiscally irresponsible to create new roads when we already carry a $6.9 billion backlog on the roads we have. The agency should make public the funding source for any new road construction and maintenance under this proposal, and project how the backlog will grow if this rescission moves forward. These roadless areas also protect critical watersheds that supply clean drinking water. Adding roads to these spaces will only further imperil our rights to clean drinking water. The public should be informed of what watershed conditions and sediment loads will look like in the Chattahoochee's roadless watersheds if the rule is rescinded. Sincerely, Claude Burnett Athens, Georgia