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For 25 years, the Roadless Rule has protected the last large, undeveloped parts of our national forests. These areas are a source of clean drinking water for communities downstream, critical habitat for fish and wildlife, and some of the best places Americans have to hunt, fish, hike, and camp. Once a road is cut through a roadless area, that value can't be recovered. The wildfire rationale doesn't justify a full repeal. The rule already allows road construction and tree-cutting to reduce fire risk and protect communities. Most wildfire-risk reduction work needs to happen near homes and towns, not in remote backcountry. Rescinding the rule entirely goes well beyond what fire management requires. The rescission also makes poor fiscal sense. As a CPA, I'd point out that the Forest Service already has a large backlog of deferred maintenance on its existing road system. Adding new roads creates long-term liabilities the agency can't fund, while increasing erosion, stream sedimentation, and the spread of invasive species. This rule has deep public support. The original rulemaking drew millions of comments, and the large majority favored protecting roadless areas. A decision this permanent deserves more than a short comment window. As a Tennessean, I want the roadless areas of the Cherokee National Forest kept intact for future generations. I urge USDA to withdraw this proposal and keep the 2001 Roadless Rule in place.

The Forest Service must keep the Roadless Rule. Allowing development throughout these protected forests completely disregards the people’s rights and the health of ecosystems we as humans depend on. There will be significant consequences to our water supplies, our health, biodiversity, endangered species and so much more. This rule protects over 60 million Americans from unsafe water, protects & provides habitats for over 1,600 threatened & endangered species, plants and animals. Harming or opening up development in Pisgah and Cherokee National Forest will impact my community and I directly. We as a community depend on a clean and safe water supply to drink, cook and bathe, which will be taken away with the impacts and effects of fracking, increased runoff, a depletion of groundwater and so much more. Additionally, animals such as the Bog Turtle, Timber Rattlesnake, and Northern Saw-Whet Owl are just a few amazing animals that will be put into further danger. Keep it roadless.

I am a concerned citizen, writing to express my deep opposition to the USDA's proposal to repeal the 2001 Roadless Area Conservation Rule. Without this rule, our National forests would be at risk of logging and other activity that would damage ecosystems, plants, animals and humans for many years to come. I am especially concerned about a black bear reserve in the Cherokee National Forest being opened to logging. Our National Parks and Forests are treasures that we must protect and cultivate for future generations. They should not be sold to the highest bidder, or opened up to activity that would damage the natural landscape, pollute the air and water, and harm endangered species. Please keep the Roadless Area Conservation rule in place. Thank you for your consideration.

Removal of the roadless rule would inflict immense damage on the wild areas of the most beautiful continent on the world. Wilderness has constantly been under attack on this continent from it's inception as a colony. It is our civic duty as Americans to protect the most beautiful areas of this nation and preserve these lands for our progeny. Rescission of this rule directly impacts me as areas of the Cherokee national forest would suddenly be allowed to be cut for timber, and otherwise be developed which irrevocably destroys the forests natural state that I personally enjoy and partake in. The Cherokee national forest is also a wildlife management area; logging and development would interfere with the deer, bear, turkey, and other important game and wildlife. If America loses the Roadless Rule, then it's last remaining untouched forests may never fully recover from the damage done to them. The lack of timber or industry listed as a reason to remove the Roadless Rule can be resolved without damaging more forests. Once these precious forests are cut, America will find itself in the same place it is now: without more forest to cut. Planned timber management can be invested in now to utilize the logging forests we already have. The Roadless Rule must not be removed for the protection of wilderness, wildlife and to keep America beautiful.

The Forest Service must keep the Roadless Rule. Allowing development throughout these protected forests completely disregards the peoples rights and the health of ecosystems we as humans depend on. There will be significant consequences to our water supplies, our health, biodiversity, endangered species and so much more. This rule protects over 60 million Americans from unsafe water, protects and provides habitats for over 1,600 threatened and endangered species, plants and animals. Harming or opening up development in Pisgah and Cherokee National Forest will impact my community and I directly. We as a community depend on a clean and safe water supply to drink, cook and bathe, which will be taken away with the impacts and effects of fracking, increased runoff, a depletion of groundwater and so much more. Additionally, animals such as the Bog Turtle, Timber Rattlesnake, and Northern Saw-Whet Owl are just a few amazing animals that will be put into further danger. Keep it roadless. 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.

The rationale for rescission does not hold up. The Roadless Rule already allows hazardous fuels reduction and other management needed to address wildfire risk. Removing it is not necessary for forest health. Instead, it would open about 45 million acres to road building and commercial logging. The Forest Service already struggles to maintain its existing road network. Adding more roads means more erosion, degraded water quality in streams that supply drinking water, and fragmented habitat for fish and wildlife. The public has spoken clearly. During the 2025 comment period, the agency acknowledged that about 99 percent of comments opposed rescission. A decision this significant deserves to reflect that consensus. It should not reverse 25 years of bipartisan protection under a shortened process with no public meetings. Please withdraw this proposal and keep the Roadless Rule in place, including for the roadless areas of the Cherokee National Forest, for my family and future generations. Sincerely, J.R. Ward Townsend, TN

My family and I love exploring Cherokee national forest. We love traveling around the country exploring new national forests and land. We need them to stay protected and preserved. We would love our future generations to be able to experience the same beauty we are able to. Please keep the roadless rule act in place!!!

The forest is a national resource that has benefits for all Americans even if they do not actively draw on it. The forest supply clean water into the waterways around them. This clean water helps dilute water that is contributed to water ways from outside the forest before it is harvested by municipalities down stream. In Washington County Tennessee municipal water is gathered from a spring that is charged by ground water coming from the mostly undisturbed Cherokee National Forest surrounding it. The spring is located at the base of Unaka Mountain in Unicoi County. This water is distributed in Washington and Unicoi Counties. Water for Washington County is also collected from the Nolichuckey River near Jonesburough Tennessee. This water benefits heavily from clean tributaries in the Cherokee and Pisgah forest. In this instance the forestry plans of two seperate forests would have an impact on water quality in the Nolichuckey River. The sale of timber from any region of the United State has an impact on timber prices for the whole of the market. Not only does it affect the value of timber currently being harvested but it also affects the value of timber assets being held privately. The sale of timber in one region affects values in other regions. What may be seen as a benefit for a local economy could also be a determent to the timber economy in another area. Management plans should have national oversite for their impacts outside of the region they are constructed for to assess any negative outcomes being produced in other areas of the country. The forests draw visitors from all over the country and the world. Roan Mountain in the Cherokee and Pisgah forest is an example of this. Decisions for an area like this should have oversite at a national level as any decision affects forest users from all around the country and the world and not just the population surrounding the immediate area, I believe firmly that the Roadless Rule should stay in effect. Management plans should have review on a national level because decision made in any area affect economies and populations in other areas.

I hunt in the Cherokee National Forest in Tennessee, where my family's land sits inside the national forest boundary. The roadless areas up there are the best hunting country left — big woods, no roads, game that acts natural. Opening those areas to roads and logging won't improve the forest; it will break up the habitat and push the hunting out. I'm against rescinding the Roadless Rule.

Dear Forest Service Leadership: I live in the Pisgah National Forest and near the Cherokee National Forest and I want these areas to remain roadless in order to protect life. My community's water comes from these drainages and our air quality is dependent upon the health of these forests. They are are living system that support our lives. They are not resources to be used or extracted. I live just down hill from Craggy Mountain and I hike in that area and all through the Pisgah Forest area. Being able to go where there are no roads, means we must walk and that means we connect with the forest, which is an essential part of being human. In addition, roads into this area will impact our water and the habitat for animals. Already human development is forcing bears into our communities where they learn to feast on human garbage and enter homes and cars. That is unfair for all. The value of a roadless area to our health and wellbeing is critical. On Craggy you get away from the sounds of traffic, the lights of the city, and the din of small engines at work. I remember camping in roadless areas where the silence at nights is filled with the sounds of nature, the stars are breathtaking, and the presence of wildlife is all around. That is precious and missing from so many people's lives. Don't take that away. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: 4.2 - Utility & service lines drives Unknown severity impacts across Small (1-10%) scope for Bog Turtle (Glyptemys muhlenbergii, G2, T, SAT) in the Craggy Mountain IRA, Pisgah National Forest. "From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar." — Ecology and Evolution (PMC), 2014 Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 4.2 - Utility & service lines on Bog Turtle. “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people. — Conservation Science and Practice (Wiley), 2020 (https://doi.org/10.1111/csp2.288)” I want you to know that there is more at risk here than there is to gain. I want you to ask yourself, "who benefits from a road into a roadless area?" If the answer is people who want to make money or further extract resources from our precious and essential forests, then your answer about building roads should be NO!! Sincerely, Cheri Torres CommentID: RLC-20261006-OPEH8V

Docket ID: FS-2025-0001 / RIN 0596-AD66 Proposed Action: Special Areas; Roadless Area Conservation (National Forest System Lands) [1] To the U.S. Forest Service Ecosystem Management Coordination staff, I am writing to express my strong opposition to the U.S. Department of Agriculture’s proposal to completely rescind the 2001 Roadless Area Conservation Rule. For a quarter of a century, this rule has successfully preserved 44.7 million acres of our country’s last remaining wild, unroaded public lands. As someone who deeply values America's natural heritage, I frequently visit and cherish our iconic public lands, including Great Smoky Mountains National Park, Muir Woods National Monument, Point Reyes National Seashore, Rocky Mountain National Park, and the Blue Ridge Parkway. While these specific sites are managed under national park protections, their ecological health, scenic integrity, and wilderness value depend entirely on the intact National Forest System lands that border them. The Draft Environmental Impact Statement (DEIS) fails to adequately consider how removing roadless protections from adjacent national forests—such as the Pisgah and Nantahala National Forests in North Carolina, the Cherokee National Forest in Tennessee, and the Arapaho-Roosevelt National Forests in Colorado—will degrade these world-class park landscapes. Specifically, I urge the Forest Service to keep the national Roadless Rule in place for the following reasons: •Impacts on Park Watersheds and Clean Water: Roadless national forests protect the headwaters and critical watersheds that supply clean drinking water to tens of millions of Americans and feed into our national park systems. Allowing new road construction and commercial timber harvesting near park boundaries will drastically increase soil erosion, stream sedimentation, and water degradation, directly threatening delicate aquatic ecosystems like those in the Appalachian and Rocky Mountain regions. •Fragmentation of Crucial Wildlife Corridors: Large mammals, migratory birds, and endangered species do not recognize bureaucratic boundaries. Intact roadless forest areas serve as essential sanctuary buffers and migration corridors connecting to our national parks. Paving new roads and introducing commercial logging equipment right up to park borders will fracture these fragile habitats, isolate wildlife populations, and accelerate biodiversity loss. •Fiscal Irresponsibility and Backlogs: The Forest Service already faces a staggering nationwide road and bridge deferred maintenance backlog of nearly $7 million (or up to $6 billion globally across all infrastructure types). It is fiscally reckless to eliminate a rule to build new, subsidized industrial logging and mining roads when the agency cannot afford to maintain the 370,000+ miles of roads it already manages. Taxpayer dollars should be spent on reducing this massive backlog and restoring existing infrastructure, not expanding it. •Degradation of Recreation and Scenic Values: Millions of people visit the Blue Ridge Parkway, the Smokies, and the Rockies for their unbroken vistas, quiet backcountry recreation, and wild spaces. Industrializing the surrounding national forests with new road networks and clearcuts will fundamentally mar the panoramic views, quiet atmospheres, and outdoor recreation economies that these regions rely on. • The USDA's own DEIS indicates that repealing the 2001 Roadless Rule is likely to cause significant environmental and economic harm to undeveloped backcountry forests, wildlife, and water resources, while offering little to no meaningful reduction in wildfire risk. I urge the Forest Service and the Department of Agriculture to reject the total rescission of the 2001 Roadless Rule. Please protect our shared public lands, downstream communities, and the wild buffers that keep our national parks whole. Sincerely, Elaine G. Jones 6015 Charing Pl. Charlotte, NC 28211

The true value of our natural resources in the United States of America cannot be fully understood and appreciated unless one has experienced these personally. Land, clean air, healthy trees, adequate and clean water, and wildlife that survive and thrive in our national forests deserve to be protected. Over past decades I have hiked in, boated in, skied, and camped in a number of our spectacular national forests: the Olympic National Forest, Mount Baker Snoqualmie NF, Okanagon-Wenatchee NF, the Cherokee NF in my native state, the Deschutes NF, the Finger Lakes NF, the Gifford Pinchot NF, the Huron-Manistee NF, the Idaho Panhandle NF, the Malheur NF, Mount Hood NF, the Pisgah NF, the Santa Fe NF, the Tongass NF, the Tonto NF, the Umatilla NF, the Umpqua NF, the Wallowa-Whitman NF, and the Willamette NF. In 2001 when the Roadless Rule was enacted, it allowed the NFS get somewhat caught up on maintenance of the 44.7 million acres of Inventoried Roadless Areas (IRAs). The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected than prior to the RR. The claims being made in the Proposed Rule do not « hold water. » It was local control (one of the purported justifications for rescinding the 2001 RR) that led to enormous harm in the Wolverine Fire of 2015 in Washington state. Local pressure by regional fire departments persuaded the Director of the Firefighting Operations, a staffer brought up from the Tonto NF, ordered a CPL (Community Protection Line) that ended up a 50-mile long, 300-foot wide CPL and cut 40% of the critical habitat for the endangered Northern Spotted Owl. Over 930 log trucks hauled out logs, with one tree being so large that it was the only tree on one of the trucks. In my view, it was criminal to do that much damage. The scientist on the Oka-Wen NF tried to persuade the fire director that the fire was not heading in the direction of the CPL cuts. « Managers continued logging even after weather conditions turned rainy and cool, and objections were raised by their own staff, who saw no emergency, internal records and emails to The Seattle Times by US Forest Service showed. The fire never came anywhere near. » (Lawsuit over firelines to curb forest firefighting tactics, August 22, 2016) Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational. By allowing access to more roads in the roadless areas, there would be a greatly increased likelihood of experiencing human and vehicle-related forest fires. Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic for logging or other forest treatments. In fact, fires are four times more likely to occur near roads than in roadless (DEIS, p. 87) Good water quality is also more available in IRAs because of limited disturbance. « Retaining the RR ‘provides the greatest protection of water quality’ for municipal water supplies. » (DEIS, p. 122) For these reasons, and in the hope that science and good evidence about the superb values of Roadless Areas in our USFS will prevail, I strongly oppose the Proposed Rescission of the 2001 Roadless Rule. I would appreciate your serious consideration of my comments. Another

We appreciate the opportunity to comment. The Tennessee Wildlife Federation (TWF, the Federation) is an 80-year-old Tennessee-based wildlife conservation non-profit founded by outdoor writers and sportsmen. Our mission is to lead the conservation, sound management, and wise use of Tennessee’s wildlife and great outdoors. The Federation is opposed to rescinding the 2001 roadless rule and is supportive of Alternative 1, no action. The 2001 Roadless Rule, which defines modern-day inventoried roadless areas (IRAs) and sets the framework for Forest Service management of these areas, was first introduced in response to a need for a national rule that offers a baseline of forest protection in addition to management at the unit level. The rationale for this rule introduction was concern for the cumulative impacts of roads and timber harvesting, management and fiscal constraints created by the National Forest Service (NFS) road network, and increased litigation costs that would be reduced by a nationwide policy. The Roadless Rule identifies 58.2 million acres, 30% of NFS lands, as IRAs, and outlines certain exceptions where forest road construction, reconstruction, and logging are permissible. In Tennessee, there are nearly 85,000 acres of IRA lands, which amounts to about 12% of our national forest area, mostly within Cherokee National Forest. These lands represent some of Tennessee’s wildest spaces, and the Federation has concerns about negative impacts to the health of the Tellico headwaters and remote trout streams if the protections outlined by the Roadless Rule were rescinded. The current rule allows for timber cutting and removal when necessary for normal active forest management activities as outlined by unit-specific forest management plans, which strikes a balance between ensuring that Tennessee’s IRAs are not overmanaged or overprotected. While the Federation appreciates the offering of a third alternative that allows for continued roadless rule protections for some forest lands classified as IRAs, this option is not viable for Tennessee. The intention of Alternative 3 is to remove prohibitions in Wildland-Urban Interface zones within 0.5 miles of an existing road, and for Tennessee, this alternative leaves only 642 acres under current Roadless Rule protection. The current Roadless Rule allows for a balanced forest management system in IRAs, and provides ample exemptions for activities such as wildlife habitat management, flood control, and wildfire prevention. Rescinding the rule would not significantly improve the Forest Service’s ability to perform these activities, but it would increase the risk of damaging habitat, increase sedimentation of waters, and decrease the overall quality of Tennessee’s wildest places. It is the Federation’s belief that there is enough flexibility in current rule that allows for sound forest and habitat management while balancing the necessity of keeping Tennessee's most remote places wild. Many of our IRA lands provide essential habitat, and the current rule has contributed to the overall health of many coldwater trout streams in Eastern TN. We respectfully urge the Department of Agriculture to follow Alternative 1 and keep the 2001 Roadless Rule in place to continue to maintain the balance between ensuring that Tennessee’s most wild spaces are well-managed while not being over-preserved.

Re: Docket No. FS-2025-0001 / RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule (36 CFR 294, Subpart B) I oppose the proposal to rescind the 2001 Roadless Area Conservation Rule, in whole or in part, and urge the Department to select the No Action alternative and retain 36 CFR 294 Subpart B. 1. Roads increase wildfire ignitions; they do not reduce them. The proposal cites wildfire risk as a primary justification, but the research points the other way. Balch et al. (2017, PNAS) found humans ignited 84% of U.S. wildfires from 1992–2012. Narayanaraj and Wimberly (2012, Applied Geography) found human-caused ignitions on national forest lands are concentrated near roads, and Syphard et al. (2007, Ecological Applications) found fire frequency is strongly tied to proximity to human infrastructure, including roads. Building roads into roadless areas expands the very access that drives ignitions. The proposal itself concedes that greater access can increase human-caused ignitions. Moreover, the existing rule already permits cutting small-diameter timber to reduce wildfire risk (36 CFR 294.13(b)(1)), so fuel treatment does not require rescission. 2. Roads fragment intact wildlife habitat. Trombulak and Frissell (2000, Conservation Biology) documented the broad ecological harms of roads: mortality, habitat fragmentation, altered animal behavior, invasive species spread, and chemical and sediment pollution. Research at the Starkey Experimental Forest (Rowland et al. 2000, Journal of Wildlife Management) showed elk consistently avoid areas near open roads, reducing effective habitat. Roadless areas provide secure big-game habitat and backcountry hunting opportunity that roaded forests cannot replace. 3. Roads degrade clean water and native trout habitat. The Forest Service’s own synthesis, Forest Roads: A Synthesis of Scientific Information (Gucinski et al. 2001, PNW-GTR-509), identifies roads as a major source of sediment delivery to streams. Assessments in the Interior Columbia Basin (Lee et al. 1997, PNW-GTR-405) found strong native salmonid populations associated with areas of low road density. Roadless areas are among the last strongholds for native cutthroat and bull trout and protect source waters for downstream communities. Once sediment and road crossings degrade these streams, recovery takes decades. 4. The Forest Service cannot maintain the roads it already has. The proposal itself acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. Every new road adds a long-term maintenance liability to an asset base the agency already cannot fund. The proposal’s own estimate of $5.2–11.4 million per year in timber revenue to the Treasury and Forest Service would take over 600 years to retire the existing backlog, even at the high end and with every dollar applied to it. Meanwhile, the agency estimates about $6.1 million per year in lost recreation benefits, largely offsetting projected revenue. From a cost-benefit standpoint, rescission adds liabilities without a credible funding source. 5. Logging and extraction are not needed here. The proposal describes management opportunities as “modest and localized” and anticipates no net change in domestic oil, gas, and coal production. If rescission produces no meaningful energy gain and limited timber, it offers little benefit in exchange for the permanent loss of intact forest. These areas are worth more standing, as habitat, watershed protection, and backcountry recreation, than cut. 6. Roadless areas buffer and connect designated wilderness, such as Citico Creek. The Citico Creek Wilderness in the Cherokee National Forest shows what protected, unroaded land can become. The Forest Service acquired this cut-over land in the 1930s and let natural processes heal it, producing a mature second-growth deciduous forest along Citico Creek with remnant old growth still present. Citico adjoins North Carolina’s Joyce Kilmer-Slickrock Wilderness, forming one of the largest blocks of intact forest in the Southern Appalachians. But wilderness boundaries alone cannot sustain these values. Wildlife ranges and watershed processes do not stop at a boundary line, and inventoried roadless areas provide the connected habitat, buffers, and travel corridors that keep wilderness from becoming an isolated island. Citico demonstrates that eastern forests recover when left unroaded; rescinding protections on similar roadless lands throughout the Cherokee and other national forests would forfeit that recovery. 7. Local planning is not an adequate substitute. Forest plans can be amended project by project, which invites the incremental degradation the 2001 Rule was designed to prevent. A consistent national standard provides durable protection that piecemeal planning cannot. For these reasons, I urge the USDA to withdraw the proposed rescission and keep the 2001 Roadless Rule in place.

I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Upper Bald River (9,202 acres), Cherokee NF, Tennessee - Joyce Kilmer Slickrock Add. (1,396 acres), Cherokee NF, Tennessee I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. Issue 4: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 5: Elk survival, in the agency's own citation I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. The 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. It may come as a surprise to the Forest Service that yes, elk are populating the Cherokee National Forest. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Axel Ringe 1940 Lafayette Road New Market, TN 37820

Public Comment on the Proposed Rescission of the Roadless Area Conservation Rule RIN 0596-AD66 / Docket FS-2025-0001 Dear Chief of the Forest Service and Forest Service Decision-Makers: We are writing to express our strong opposition to the proposed rescission of the Roadless Area Conservation Rule. Our family has property in Tennessee, as that is where we were raised, and for generations our family has spent time recreating at Watauga Lake and throughout the Cherokee National Forest. These forests, mountains, streams, and lakes are not simply places on a map to us. They are places where our family has gathered, explored, created memories, and developed a lasting appreciation for the natural world. Nestled in the Cherokee National forest, Watauga Lake is widely recognized as one of the cleanest in clearest lakes in the United States. Our children fish, water ski, tube and swim year and year in the lake. Our family hikes in the surrounding forests and trails. We cannot imagine what would happen if the Roadless Rule were to be repealed. We want our children and grandchildren to inherit these same places—not merely the memory of what they once were. The Roadless Rule provides an important layer of protection for some of the country’s remaining undeveloped National Forest lands. Maintaining these areas in their natural condition helps protect the character of the forests and watersheds that people rely upon for recreation, wildlife habitat, clean water, scenic beauty, and the opportunity to experience nature without extensive development. For families like ours who have returned to these places for generations, preservation is not an abstract concept. We have seen firsthand the value of having forests and shorelines that remain clean, natural, and accessible for recreation. We also understand that once undeveloped forest landscapes are fragmented by roads and development, their character can be difficult or impossible to restore. I am particularly concerned about what the loss of these protections could mean for places connected to the Cherokee National Forest and the Watauga Lake region. These public lands belong not only to people who visit them today, but also to future generations who have no voice in today’s decision. The Forest Service’s responsibility should include protecting the long-term public value of these lands—not simply considering what can be extracted or developed from them in the short term. National Forests provide benefits that cannot be adequately measured in timber receipts or immediate economic activity. They provide clean water, wildlife habitat, outdoor recreation, solitude, scenic landscapes, and places where families can form lifelong connections with the outdoors. For our family, that last point is especially important. We have generations of memories at Watauga Lake and in the surrounding forests. We hope our children and grandchildren will be able to make their own memories there decades from now. Preserving roadless areas is one way to ensure that future generations inherit forests that are still recognizable as the wild and beautiful places their parents and grandparents knew. I respectfully urge the Forest Service to withdraw the proposed rescission and retain the Roadless Area Conservation Rule. Please consider not only the immediate consequences of this decision, but the cumulative and irreversible consequences of changing the character of America’s remaining roadless forests. Once these places are substantially altered, future generations cannot simply vote to restore the landscape we choose to change today. The public lands of the Cherokee National Forest and the natural resources surrounding Watauga Lake are part of our family’s history. We ask that they also remain part of our family’s future. Thank you for considering our comments and for protecting these places for the generations who will come after us. Respectfully, M and J Arnold

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places that pull my family into the woods, Cherokee in NC among them, were built up slowly by forces that do not wait for agency rulemaking. Rescinding the 2001 Roadless Area Conservation Rule would put that inheritance at risk, and I oppose it. The Cherokee National Forest holds 18 inventoried roadless areas totaling 84,881 acres. Places like Citico Creek, Big Frog Mountain, and Bald River Gorge shelter black bear, hellbender, brook trout, Indiana bat, northern long-eared bat, and Virginia spiraea, among others, in a region where more tree species grow than in all of northern Europe. My family has gone to Cherokee and to parks far beyond it, from Yellowstone to Acadia, because we love being in nature and seeing the wildlife. What we photograph is just nature and all the diverse creatures and plants you see. These are not abstract values. They are the reason we go. The agency's economic analysis does not hold together. 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. That certification was reached by averaging projected losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits near the affected roadless areas. The agency concedes some of those firms may lose those receipts entirely. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in or adjacent to the potentially affected roadless areas, not the national average firm. The reliance question is equally unresolved. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Families who have planned trips, outfitters who have built businesses, and communities whose economies depend on recreation in roadless country have organized around the rule's stability for over two decades. This comment is one such reliance interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own data undercuts the proposal. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. I have not been directly affected by wildfire, but it is sad to see and hear other people who are. We as a community should want to do whatever we can to minimize these forest fires. Opening roadless areas to new road construction would, by the agency's own numbers, move ignition rates sharply in the wrong direction. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it explicitly against any claimed reduction in wildfire hazard before this rule can be finalized. The process question matters just as much. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare plan amendments out of scope and ask the public to comment on them. A logged stand grows back. A road does not. The Forest Service took more than 600 public meetings and 1.6 million comments to write the rule it now proposes to undo with none. That asymmetry alone is reason to pause. Beyond the process, no I do not think we should be building more things that cannot be properly maintained over time. You are destroying nature for no reason at that point and being irresponsible with money that could go to a better cause. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. Adding new roads into country that currently has none compounds that deficit while permanently altering the landscape. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action rather than walling it off. Future generations should inherit at least what we have. I do not think we should do anything less than everything in our power to let them experience the beauty of nature without destroying it. The record does not support rescission. Sincerely, Danielle Palm Winston Salem, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 For more than 20 years I've enjoyed mountain biking and hiking on the pristine trails in the Cherokee National Forest. I've also enjoyed paddling the Ocoee, Hiwassee, and Nantahala Rivers, and I know what those watersheds mean to the outfitters, guides, and towns across southeast Tennessee and western North Carolina who depend on clean, cold water. I am asking this agency to keep the 2001 Roadless Area Conservation Rule in place, and I am asking it to answer the specific questions this record raises. Start with fire. The agency justifies rescission partly on wildfire and fuels management grounds, but its own record says this: "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 the agency's own language. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain how this proposal departs from those prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement. The water I paddle runs out of those roadless headwaters. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres. Shining Rock, Linville Gorge, and the other roadless pockets of Nantahala-Pisgah protect wild headwaters flowing to both the Atlantic and the Gulf, along with salamander species found nowhere else on Earth. Across the Southern region, which includes Tennessee, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis acknowledges that roads change stream flows, water temperature, and channel shape, and that water in roadless areas today is largely unaltered. Rescinding this rule puts that condition at risk. I ask the agency to respond on the record to what road construction in these specific watersheds would mean for those 378 intakes and for the rivers that sustain the small businesses I named. The economics do not support this action. 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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. Meanwhile the road system already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those numbers and explain how expanding a road system it cannot currently maintain is responsible stewardship. The legal history here matters. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried replacing the national rule with a state-by-state approach before, and the Ninth Circuit identified deficiencies in that approach. The Cherokee holds 18 inventoried roadless areas totaling 84,881 acres, including places like Citico Creek and Big Frog Mountain that harbor black bear, hellbender, brook trout, Indiana bat, and the northern long-eared bat. These are areas of nationally significant value. The agency should explain how this proposal avoids the same deficiencies the court found the last time it went down this road. Finally, the regulatory flexibility certification fails on its face. 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. The certification reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the permit-holders actually operating in the affected areas. The outfitters and guides on the Ocoee, the Hiwassee, and the Nantahala are exactly those small entities. The agency should withdraw the certification and assess the impact on the businesses actually operating in these roadless areas, not a national average that obscures real harm. Public land should be managed for access to nature, wildlife habitat, healthy ecosystems, and clean water. By the agency's own words, this rescission is about reducing regulatory burden. That is not a good enough reason to give up protections that took decades to put in place. Responsible management means keeping what works.

I love our public lands. Our family has spent countless days playing, hiking, camping, backpacking in National Forests across the country. We raised four boys who love this country and its natural landscapes. We personally visit the Cherokee National Forest frequently as that is only 1-2 hours away from our home. We have hiked nearly every mile of the Citico Creek Wilderness and other areas within the Cherokee Nat'l Forest and feel that is a true jewel. There are enough forest roads already. The number of roads is more than the NFS can keep up with as it is now. Adding more roadways, cutting across sensitive habitat, causing erosion, harming wildlife, are serious concerns. The public does not support rescinding the Roadless Rule. The public are the ones who are intimately tied to these public lands. I desperately want the government to keep their hands off our lands (purchased and maintained by taxpayers, after all)! Me and my family do NOT support rescinding the Roadless Rule. 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.

The sunsets and foggy mountain mornings I photograph in the southern Appalachians belong to all of us. Once we destroy the landscape, we cannot get it back. That is why I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I hike in Cherokee National Forest, at Laurel Falls, Buffalo Mountain, and Max Patch Loop, where I take my family. I have been lucky enough to see hellbender salamanders in East Tennessee and Western North Carolina. The hellbender is a species native to the Southern Appalachians, and it needs to be preserved. The Cherokee holds 18 inventoried roadless areas totaling 84,881 acres, and the verified species list for that forest includes the hellbender, black bear, brook trout, Indiana bat, and northern long-eared bat. Once a species is gone, it cannot come back. That is not a philosophical point. It is a biological fact, and it should govern this decision. The agency's own record undermines the wildfire rationale for this rescission. The agency found that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies opening roadless areas in part on fuels management grounds, but the agency's own ignition data, reported in DEIS Table 21, shows far higher fire density on roaded land than inside the affected roadless areas. The agency must explain, in specific terms, why its current proposal departs from those prior findings and how it reconciles the rescission with that documented disparity. The economic case is equally weak. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects $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 ranging from negative $92 million to positive $199 million. The road system already carries a $6.9 billion maintenance backlog. A proposal whose own analysis cannot establish a net benefit, and whose resource contribution is less than half a percent of national production, does not justify expanding that backlog into 84,881 acres of Cherokee roadless land. The agency has not reconciled these numbers and should be required to do so before this proceeding closes. The proposal also overstates the regulatory burden the rule creates. The agency acknowledges that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Those exceptions already accommodate existing mineral leases, community wildfire protection plans, and public health and safety emergencies. The agency has not identified which specific operational needs fall outside those existing exceptions or quantified the burden of working within them. It should be required to do that accounting, on specific projects, before the rule is rescinded. Finally, the agency has quantified the biological consequences of its proposal and then failed to apply them. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record and stops there. No projection across the 40.1 million acres of potentially affected environment follows. The southern Appalachians are an evolutionary crossroads. More tree species grow in places like Citico Creek and Big Frog Mountain than in all of northern Europe. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency must apply its own cited fragmentation range to the full 40.1 million acres and account for what that means for the biodiversity of places like the Cherokee before this decision is finalized. Your job is to protect the land and maintain public access. Roads and profit are not the goal. My family goes to these forests because the land is intact. The agency should maintain the rule that keeps it that way. Sincerely, Kristin Wright