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I am writing to urge you to abandon the counterproductive proposed repeal of the Roadless Rule. The USDA’s draft environmental impact statement (DEIS) shows that that repealing the Roadless Rule is likely to cause economic and environmental harm to undeveloped backcountry forests, wildlife, water resources, and communities, while delivering little or no wildfire risk reduction and potentially increasing federal road maintenance costs. In other words, repealing the Roadless Rule is the worst of all outcomes – higher costs and lower benefits. My family and I live in an urban setting. But we understand that the well-being of our environment depends on preserving intact wild places that can maintain wildlife, preserve intact ecological balance, and provide ecosystem services, including absorbing storm surges and filtering drinking water supplies. We value being able to recreate in wild places. The Pisgah Forest and Croatan National Forest are important to us as North Carolinians – these wild places are an important part of the cultural contours of the state. We treasure the opportunity to visit these unspoiled places. Respectfully, Melissa Malkin-Weber

I spent my career as a forester and ecologist with the USFS, the USFWS and finally with the USDOT/FHWA. I retired 5 years ago with 33 years of federal service. During my career, I conducted field work to determine timber values, suitability of areas for timber harvest and the presence of federally listed plants and animals. I served on teams conducting NEPA analyses for a variety of project types in multiple landscapes. For 18 years, I was a liaison from the USFWS to the NC DOT and consulted on thousands of infrastructure projects for their impacts to streams and wetlands and endangered species. I won awards from both the FWS and the DOT for my work. At the end of my career, I was training State DOTs across the country in the applicability and implementation of the Endangered Species Act and NEPA and working as a subject matter expert to help solve problems with a nexus of transportation and the environment, particularly water resources and rare plants and animals. In my time away from work, I have hiked and enjoyed the National Forests from Washington to North Carolina and most of the nation in between. I have found great value and experience in roadless areas across the country. From the Salmo-Priest area on the Colville NF ——where I conducted my MS research—- to St Peter’s Dome on the Chequamegon NF and finally to my home state of NC and Catfish Lake on the Croatan NF and Harpers Creek on the Pisgah NF, these roadless areas are crucial to clean air, clean water and the survival of multiple species of plants and animals. From migratory birds and forest dwelling bats to endemic plants and salamanders, areas that are not impacted by roads provide habitat not available elsewhere in our national forests. With over 20 years of my career spent in transportation, I can attest to the permanent changes that road corridors, regardless of their classification, bring to the forest. Over decades, road corridors and culverts degrade and deposit sediment to streams and in extreme weather events cause further damage to both streams and the forest. In addition, these corridors provide travel routes for invasive species which can greatly alter habitat for native species. The scale of what roads have already done to the landscape is substantial. An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads — not just where roads exist, but where the edge effects, runoff patterns, and disturbance cascades from those roads reach (Forman & Alexander 1998). These roadless areas are habitat gems that should never be exploited for the limited resources that they can provide commercially, but instead should be conserved for their tremendous capacity as large habitat patches contributing to biodiversity and conservation of all species, including our own. DO NOT RESCIND THE ROADLESS RULE.

In reference to: 36 CFR Part 294 RIN 0596-AD66 I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Kelly Skonier. I was born and raised in North Carolina. This is where I still live, work and pay taxes. From a young age, I learned to love our natural forests and waterways, and to ‘leave no trace’ when hiking, camping, or otherwise exploring. I have family all across NC, from the mountains, to the piedmont and the coast, and across our great nation, from New England down to Florida, west to the suburbs of Seattle, and all in between. The Roadless Area Conservation Rule protects about 172,000 acres of national forest land in North Carolina, including areas in Pisgah National Forest, Nantahala National Forest, and the Croatan National Forest. The many hiking trails, beautiful waterfalls and scenic swampland that are parts of these lands are not only enjoyed by me, they also draw tourists to visit, bringing outside dollars into some more rural communities. They are also, obviously, natural habitats for many plants, animals and other living things. I believe these lands and those all across the country should remain protected under the Roadless Area Conservation Rule. I may not have gotten to visit them yet, but I believe they should be protected for when I can and for future generations. I understand the argument for roads to be able to prevent or fight wildfires. But I do not believe that any good-faith effort was put forth in proposing an acceptable change. As a layperson, without specialized advanced education in these areas, I do know that there are techniques using prescribed burns and logging with draft animals that are less detrimental to the ecosystem as a whole, while also providing some needed safeguards. According to pew.org “the findings from the USDA’s own draft environmental impact statement (DEIS) indicate that repealing the rule is likely to cause economic and environmental harm to undeveloped backcountry forests, wildlife, water resources, and communities, while delivering little or no wildfire risk reduction and potentially increasing federal road maintenance costs.” I believe that discussions with foresters, watershed specialists, and those who have studied the animals, insects and birds that live on these lands, to be able to preserve the lands as naturally as possible, is imperative before even considering any possibility of change. Moving forward with fully or partially rescinding the Roadless Area Conservation Rule when your own research points to increased costs and damages without much, if any, risk reduction seems obtuse or worse, spiteful. I believe fully or partially rescinding the Roadless Area Conservation Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Area Conservation Rule. I support the No Action alternative, Alternative 1. Thank you for your time and consideration of my comments. Sincerely, Kelly Skonier

Dear Department of Agriculture Leadership: From the vantage of a wildlife observer who has walked the boundary between roaded and roadless units of the same forest, I can attest that the difference is detectable across multiple taxa, and on that basis I oppose the proposed rescission. We have a duty to protect and preserve our nation’s wildlife and wild areas. Our unique fauna and flora is valuable. I often see beautiful bald eagles soaring in the blue sky. Symbols of freedom and America’s greatness. I find immense joy in spotting a rare animal, but also value every species and appreciate their contribution to the ecosystem and our country’s identity. If this rule is rescinded, species diversity and native flora and fauna will suffer. Wildlife enthusiasts, like myself, will suffer this loss as well, no longer able to access these protected wild areas and appreciate the unique nature. Regarding the Catfish Lake North in the Croatan National Forest, North Carolina: The Catfish Lake North IRA, Croatan National Forest, harbors documented occurrences of Green Sea Turtle (Chelonia mydas, G4, E, T). The presence of this E, T species in an area subject to a proposed federal action triggers an independent ESA Section 7 formal consultation obligation that the agency must discharge before proceeding. The "may affect" threshold under ESA Section 7 is deliberately low — it encompasses any reasonable possibility that the action affects the species, not a certainty of harm. Road construction in habitat occupied by Green Sea Turtle (Chelonia mydas, E, T) in the Catfish Lake North IRA clears that threshold by any reasonable measure. ESA Section 7 formal consultation for Green Sea Turtle (Chelonia mydas, E, T) in the Catfish Lake North IRA must be completed before the agency issues a final decision on rescission. The statutory framework does not permit the agency to finalize the action and consult afterward — consultation is a precondition, not a follow-up measure. "While roadless areas (at least 1 km away from a road) covered 80% of the Earth's terrestrial surface, more than half of these areas are patches of less than 1 square kilometer. Whether driven by resource extraction, colonization, or long-distance trade, building a road through a previously isolated region opens landscapes for further development." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Ibisch et al. 2016, 2016 These places matter. The Rule protects them. Keep the Rule. All the best, CommentID: RLC-20261007-YI05XZ

Re: RIN 0596-AD66 and Federal Register Number 2026-16965 I live in one of the watersheds which would be affected by USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). I write to note the inadequacy of August 2026 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS) and to register my opposition to alternatives 2 and 3 in the DEIS. Road building and timber harvest in relatively undisturbed forests degrades on-site and downstream water quality and impacts fish and wildlife habitat. The 2001 Roadless Rule applies to 20,743 acres in the Croatan National Forest (NF) of eastern North Carolina. The White Oak River tributaries where I fish have their headwaters in the Croatan NF, and I live within a mile of the forest and in the watershed of one of those tributaries. Because I am affected by forest management’s influence on local water and air quality, I examined the DEIS for an evaluation of the proposed rule recision. I found the water quality sections lacked forest-specific resolution, making the document unsuitable for informed local impact assessment. For example, the water quality section starts (page 108) with the statement “Roads have long been recognized as a substantial human-caused source of soil and water disturbances in forested environments.” However the DEIS’s characterization of the potentially affected environment (page 119) includes no specific information on existing water quality conditions in and downstream of Croatan NF or any other NF. Similarly, the DEIS alternatives analyses (page 123) has no forest-specific information on effects of the action, merely referencing that best management practices exist to make impacts less severe. For informed decision-making, the roadless areas like those in Croatan NF which would be affected by the proposed rule recision should be detailed with an environmental baseline (e.g., detailing what is known about the quality and use support of waters there now). The DEIS should also cover planned or reasonably foreseen road construction and timber harvesting impacts on a site-specific rather than generic basis. The proposed rule recision notes a return to local management and decision-making, so those managers can say, in a revised DEIS, what if any changes are anticipated locally with regards to roads and timbering such that site-specific impacts can be evaluated. As is, the generic DEIS is not useful. Deferring the analyses to future forest-specific land use plans, forest management plans, or permits is an unworkable substitute given the magnitude of lands affected by the proposed rule recision and that not all potential future changes have a well-advertised public participation process. Road construction is a major source of sediment run-off into surface waters, and excess sedimentation is one of the most significant local and national causes of water quality impairment. Rescinding a rule that protects tens of millions of acres from those impacts without an adequate analysis of the impacts is poor public policy — as illustrated above, in over 300 pages of the DEIS and all of its appendices, no answer was provided for water quality impacts of the proposal for the forest near me. I found the fire frequency and wildlife habitat sections similarly generic and unhelpful. I oppose rescinding the 2001 Roadless Rule (aka, I support Alternative 1 – No Action, 2001 Roadless Area Conservation Rule). The relatively undeveloped areas subject to the 2001 Roadless Rule are important for fish, wildlife, on and off-site water quality, and more. They should continue to receive the protections afforded by the 2001 Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Forest Service's own data says a human-caused wildland fire is nearly 5 times more likely on roaded land than inside a roadless area. I hike, camp, photograph, and cycle through national forests, including Croatan National Forest and Pisgah National Forest in North Carolina, precisely because they are what they are: unroaded, quiet, dark sky, and alive in a way that developed land is not. The proposal to rescind the 2001 Roadless Area Conservation Rule threatens places I know personally and values I believe belong to every generation. I oppose it. The agency's stated rationale includes wildfire and fuels management, yet the record it assembled says: "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 5 times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's own finding, drawn from its own draft environmental impact statement. The proposal doesn't explain how rescinding the rule advances fire safety when the agency's own ignition data points in the opposite direction. I ask that the agency to explain why this proposal departs from those prior findings, and that it reconcile the rescission with the fire density data reported in DEIS Table 21, which shows far higher fire occurrence on roaded land than inside the affected roadless areas. The economics do not support the proposal either. The agency's own record states: "there presently exists a backlog of about $8.4 billion in deferred maintenance and reconstruction on the more than 386,000 miles of roads in the Forest Transportation System." Do the math. We can't maintain the existing roads, thus we can't afford to build/maintain new ones. The agency must reconcile the proposal with those figures and explain, on the record, how expanding a road system already carrying that deferred maintenance burden serves the public interest. The proposal argues that state-level management can substitute for a national rule, yet the agency's own prior analysis found: "Local land management planning efforts may not always recognize the national significance of inventoried roadless areas and the values they represent in an increasingly developed landscape. If management decisions for these areas were made on a case-by-case basis at a forest or regional level, inventoried roadless areas and their ecological characteristics and social values could be incrementally reduced through road construction and certain forms of timber harvest. Added together, the nation-wide results of these reductions could be a substantial loss of quality and quantity of roadless area values and characteristics over time." North Carolina alone holds 172,416 acres across 38 inventoried roadless areas, including Pocosin Addition and Sheep Ridge Addition in the Croatan, places where the federally endangered northern long-eared bat depends on undisturbed pocosin habitat, where carnivorous plants grow in boot-sucking muck that my nephew still talks about years after our hike and that I have spent 20 years photographing. The agency must address its own finding that local decision-making erodes nationally significant values, and explain how this proposal avoids the deficiencies that led courts to reject the last state-by-state approach. The agency also cites administrative burden as justification, yet the record already contains this finding: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already includes exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions, has not quantified them, and has not explained why they outweigh values that are by the agency's own description irretrievable. It should do so. Across the Southern region, 378 municipal water intakes sit in watersheds containing roadless areas. Climate change and development are fueling water scarcity and water quality degradation. Watersheds fed by roadless areas help protect our nation's water supply, versus roads creating a water-quality issue. The DEIS itself acknowledges that roads and their facilities can produce up to 90% of the sediment from a timber sale. Using undeveloped roadless forests as part of a long-term water quality strategy is sound; trading them for short-term timber revenue is not. Managing responsibly means not allowing our natural resources to be used in political games. Public lands belong to the public, this generation and the ones that follow. I urge the agency to withdraw this proposal.

My name is William Barnes. I am writing to oppose the rescission of the Roadless Rule. I grew up in and around New Bern, North Carolina, just north of the Catfish Lake North Roadless Area in Croatan National Forest. My family worked fields in the spring, summer, and fall, and depended on hunting and fishing throughout the year. I've seen first-hand what deregulation does to our rivers. I remember the dread of not knowing if it was safe to eat what we caught in the Neuse River. I do not want to see this blatant exploitation of our resources continue until there's nothing left. A measured, iterative timeline of changes that would align our regulations with any challenges introduced by the Roadless Area Conservation Rule would be considered, but we have seen time and time again that the government is willing to do the easy work of destroying, but will not apply the effort required to protect and conserve. So here we are again facing reckless destruction on the whims of out of touch bureaucrats wearing a cheap veneer of good intent. In NC, we are still suffering from the absolute mess of 'reforming' mental health care before anything was in place to protect the people that needed support. My youngest brother is among those who have been unable to receive the help he needs in part because of that. So do not try to sell me on tearing everything apart with only a statement of good intent in exchange. This administration's efforts to destroy data collection laws to help obscure facts and further protect abusers from accountability also damages any confidence I held in the findings and arguments used to justify changes like this and you have proven time and again that you are incapable of writing responsible policy. As an example: DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding It Relies On (pp. 243, 318) The DEIS materially alters the 2020 Alaska Roadless Rule FEIS fish habitat finding it relies on, and the alteration removes the grounds most affected by this rulemaking. At page 318, in Appendix 4 (Review of the Final Environmental Impact Statement for the 2020 Alaska Roadless Rule), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)." The cited page is accurate as a locator, and the 2020 FEIS is listed in the DEIS's own references and publicly available. The problem is that page 3-138 does not say what the DEIS reports. The finding reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas." The source is in the record and the page cite is right; the defect is that the DEIS reports the source as saying something it does not say. Under 7 CFR 1b.7(f)(2)(v) the agency must make factual corrections, and under 1b.7(f)(3) it should cite where in the EIS or the supporting record the correction is accounted for. This is a rule-level question about what the DEIS says a source in its own record says, and about whether a conclusion premised on deleted protections can be carried forward. It is not answerable by deferral to site-specific analysis: no project-level NEPA document corrects the DEIS's restatement of its own source, and no project-level analysis can supply the programmatic conclusion that removing the T77 and Conservation Priority Area restrictions leaves fish-habitat effects "minimal." A conclusion stated without the record support it claims does not satisfy the hard-look requirement. See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). I re-state, for posterity and to be as clear as possible, that I oppose the rescission of the Roadless Rule.

I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. As a North Carolina climber and someone who spends a significant amount of time exploring our public lands, I value places where the experience is still defined by forests, mountains, streams, wildlife, and natural quiet rather than roads and development. These undeveloped landscapes are becoming increasingly difficult to find, and once they are fragmented by new roads, their character can be extremely difficult to restore. Here in North Carolina, our National Forest System lands include some of the most remarkable landscapes in the Southeast. The Nantahala and Pisgah National Forests of Western North Carolina provide the wild mountain environment that makes this region so special. The Croatan National Forest protects a very different but equally valuable landscape along our coastal plain. Roadless areas within these forests deserve continued protection. For climbers, hikers, paddlers, hunters, anglers, mountain bikers, campers, and others who recreate on public land, undeveloped areas provide something that developed recreation areas cannot fully replace: the opportunity to travel through a large landscape where natural features remain dominant. Protecting these places also protects the clean streams, wildlife habitat, viewsheds, natural soundscapes, and clean air that make outdoor recreation meaningful in the first place. My concern extends well beyond North Carolina. I strongly support preserving roadless National Forest lands throughout the American West as well. The scale may be different from the Southern Appalachians, but the principle is the same. Some portions of our public lands should remain wild, connected, undeveloped, and available for future generations to experience. I understand that National Forests must be actively managed and that individual forests face different ecological challenges. However, I do not believe eliminating the nationwide Roadless Rule is the right approach. The rule provides an important baseline of protection for places whose value comes in large part from the fact that they have not been fragmented by extensive road networks. The Roadless Rule helps conserve clean water, clean air, wildlife habitat, soundscapes, viewsheds, and opportunities for backcountry recreation. Those benefits belong to everyone, including people who may never visit every one of these forests themselves. As a North Carolinian and climber, I respectfully ask the Forest Service to retain the 2001 Roadless Area Conservation Rule and continue protecting inventoried roadless areas within North Carolina's National Forests and throughout the National Forest System. Keeping a place wild today preserves choices for generations that follow us. Once an undeveloped landscape is permanently altered, we cannot simply recreate what was lost.

I am writing to oppose the rescission of the Roadless Rule. This rule protects about 45 million acres of public lands from development – construction, logging, mining and possibly privatization. The reason for rescinding the rule is to purportedly better manage forests for wildfire risk, but in fact wildfires are more likely to break out near roads. Managing wildfire risk can be more effectively accomplished using other strategies. The Roadless Rule protects fragile ecosystems and watersheds. Healthy forests mean healthy salmon runs, upon which some rural communities depend on for their nutrition. Healthy watersheds mean good water quality which is critical for rural public water systems. Rural communities are in favor of leaving the rule in place because their economies or ways of life depend on outdoor recreation-based tourism including hiking, hunting and fishing. Building more roads can lead to more smoke from wildfires which negatively impacts tourism. In addition, building more roads increases the need for more road maintenance, which is already at a deficit. In North Carolina, over 170,000 acres are protected by the Roadless Rule. Some of the best fish and wildlife habitat in the US are found in these areas. The 20,000+ protected acres located in the Croatan National Forest contain unique flora and fauna. In addition to being crucial for wildlife and recreation, this acreage plays an important role in flood protection since it lies in a coast area. The Roadless Rule dates back to 2001 when it became law with bipartisan support. There is no good reason to rescind it.

The Croatan National Forest is one of the last wild stretches of land on the North Carolina coast, and it belongs to the public. I hike and camp there with my dog because it keeps us both healthy, physically and mentally. It is how we escape the world for a bit, together. I go specifically where cars cannot reach, because that is how wildlife persists. That is where I watch the endangered red-cockaded woodpeckers and the protected pygmy rattlesnakes, where I find the slowly reproducing turtles, where I see endemic carnivorous plants found nowhere else in the world, where I can hold still in a quiet place and let animals act naturally without humans and cars interfering. I am a naturalist, and I recognize how important biodiversity is, and how lucky we are to have such amazing wildlife in this country. The Croatan is imperative for future North Carolinians so they can enjoy these lands too. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record destroys its own justification for using wildfire as a reason to open roadless areas. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." North Carolina holds 172,416 acres across 38 inventoried roadless areas. Every acre of that land that gains a road gains exactly the ignition risk the agency's own findings document. I ask that the agency explain, in this proceeding, why the proposal departs from these prior findings and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as hollow. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal gain, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of between $5.2 and $11.4 million a year, set against recreation losses of at least $6.1 million a year, and a net present value that spans from -$92 million to +$199 million. My money should be spent maintaining what we already have and preserving it, not ruining our lands for someone else's profit. The agency is already $6.9 billion behind on maintaining the roads it has, running on a road budget of roughly $73 million a year. The agency must reconcile the proposal with that cost-benefit range and explain how any action whose own analysis cannot establish a net benefit justifies adding more road infrastructure to a system already failing under the weight of deferred maintenance. The agency argues that state-by-state approaches can substitute for a single national rule, but the record shows the agency's "dissatisfaction with the Roadless Rule" and its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. The agency has already attempted to substitute local decision-making for national protection and has already been found wanting for it. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. Finally, the proposal argues the 2001 rule exceeded statutory authority, but a federal appellate court has already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and MUSYA and ruled it did not create de facto wilderness. The agency should explain, with specificity, the legal basis for any position contrary to that holding. Across the Southern region alone, 378 municipal water intakes sit in watersheds containing affected roadless areas. The Croatan is not an abstraction. The wildlife I watch there, the quiet I go there for, the land that future North Carolinians deserve to inherit: none of it survives a road network built for timber revenues that the agency's own numbers cannot justify. Sincerely, Lauren Wilson North Carolina

Dear USDA, As a steward to our public lands, USFS is responsible for caring for and maintaining our National Forests. These are PUBLIC LANDS, and in 2001 the Roadless Rule was established with vast public support because Americans value wild places. Over 1.6 million comments and more than 15 months of development led to the original creation of the Roadless Rule, and that public support persists 25 years later. In 2019, a Pew Charitable Trust survey found that 75% of surveyed Americans supported the rule (regardless of political party or urban/rural residency) (Pew, 2019). Last year, you received over 220,000 public comments, and ~99% of them opposed the proposed change. I strongly oppose the rescission of the Roadless Rule. US National Forests are “Lands of Many Uses." The USFS already manages over 265,000 miles of roads for recreation, wildlife viewing, and timber harvest purposes. These roads allow people of all backgrounds to get outside, but not every scenic area needs roads. Over half of USFS land is already managed without the restrictions of Wilderness or Roadless Rule regulations (OnX, 2026), so it is in the public’s best interest to keep roadless areas set aside. Roadless areas attract outdoorspeople explicitly because they lack new road construction. These are scenic, quiet, natural places, often with abundant wildlife and clean air and water. They are places without roads for logging or mineral extraction and mining. They are also places with huge networks of existing trails. For a recreationist, roadless areas strike the perfect balance between wild and accessible. According to analysis by OnX, roadless areas contain over over 13,000 miles of trails accessible to motorized vehicles such as snowmobiles, motorbikes, and 4x4s, over 19,000 miles of hiking, biking, and ski routes, and over 3000 rock climbing areas (OnX, 2026). These are not empty wasted areas, and implementing further road construction would degrade the wilderness-like experience of outdoor recreationists who seek these areas out. Along with their inherent value to recreationists, these areas have strong economic value. A 2018 economic analysis assigned over $9 billion in economic benefits just from passive and recreational use, with the added benefit to local economies with strong outdoor industries (Hjerpe and Aldrich 2018). This summer, I had the wonderful experience of exploring a roadless section of Sequoia National Forest. In that subalpine meadow, I hiked through a relatively unfragmented ecosystem, encountering birds and wildlife that would be negatively impacted by roads. Even forest roads are a threat to wildlife. One of the biggest threats to biodiversity is habitat degradation and destruction, including fragmentation. A 2006 study in Nantahala National Forest found that even narrow, unpaved logging roads with relatively low usage had a negative impact on salamander abundance, and that impact extended outward from the roadway by at least 35 meters. Further, once roads have been built, it is nearly impossible to unbuild them, and the fragmentation and negative impacts to biodiversity can continue for decades after a logging road is decommissioned (Semlitsch et al. 2006). Multiple peer reviewed studies cast doubt on the argument that adding roads will improve fire management (Aplet et al. 2026, Kilbride et al. 2026, Johnston 2021, Healey 2020, Narayanaraj and Wimberly 2012). Healey (2020), synthesized 20 years of monitoring data, and found that the USFS had actually conducted more fuel management activities per unit area in roadless areas than in other parts of the National Forest System. Further, he found that forests with roads and roadless areas burned at similar rates over 31 years. Johnston et al. (2021) concurred, noting that fire severity was the same across both classifications of land. Finally, several authors have noted that human caused wildfire ignitions are higher in areas closer to roads (Narayanaraj and Wimberly 2011, Aplet et al. 2026). They note that there is a trade-off between higher ignition rates and ability to fight fires, leading to negligible overall impact. Increasing wildfire management is not a strong argument for rescinding the roadless rule. I come to this comment wearing many hats. I am a biologist. I am a hiker and runner and birder. I gravitate towards natural areas all over the country. I have had the privilege of exploring roadless areas in Utah’s Manti La Sal National Forest, California's Sequoia National Forest, Montana's Custer-Gallatin, and Wyoming's Medicine-Bow National Forest. I grew up walking seemingly endless boardwalks that veered in and out of the roadless portion of Croatan National Forest in North Carolina, and learning from my grandparents about the creatures that lived there. I love public lands, wildlife, and outdoor recreation. I firmly oppose the rescission of the Roadless Rule, and support Alternative 1, No Action. Thank you, Caroline sources attached

I live in Beaufort NC and we treasure the Croatan National Forest so much. with all of the growth in our area, more and more forests are being destroyed leaving no place for animal habitats, trees, plants, all of this that provides us with quality of life, oxygen, prevents flooding, places for people to enjoy nature. Please do not pass this new Roadless rules that will allow roads to be constructed right through these beautiful protected areas that we need so badly that are disappearing right before our eyes!

I wake up every morning to another blow to what is most important to me, protecting and preserving ecosystems globally and now in my own backyard. I love Eastern NC for it's wetlands, coastlands and especially it's forestlands. When will this grabbing of land for development stop? The Croatan National Forest ecosystem is fragile and home to many species of animals and birds and especially the Venus Flytrap and other such vegetation that is found nationally only in this area which is my backyard. We need to look to the future and preserve the wonders that exist here for future generations. Please keep the roadless law. Otherwise, rivers, forests, wildlife and residents of Eastern NC will suffer.

Repealing the roadless rule would be a death sentence to the beauty of North Carolina and only serves to make it easier for logging and other companies to profit off of what should be public lands. Instead of logging, we should be protecting areas North Carolinians enjoy for recreation and our native species use as habitat (a thing which is rapidly declining already.) The roadless rule also protects our water ways from pollution, protecting North Carolina's constituents. The Croatan National forest is one of the most beautiful places in NC and lovely even more for the wildlife it protects in its roadless areas. Outdoor recreation also benefits from the roadless rule, which encourages activities such as biking, hiking, kayaking, and many others. The roadless rule supports our rural communities by encouraging recreational tourism, and it protects our beautiful state's water, animals, and human inhabitants by ensuring we have pristine areas untouched by destruction caused by deforestation, logging, and construction. We must preserve our forests and waters now to protect and ensure our future. Our natural world is under attack in so many ways, I implore you to not repeal the roadless rule.

When I look at the Roadless Rule, I look at it through a coastal North Carolina lens. Croatan National Forest is not an abstract federal landholding and it is not a western mountain forest. It is a wet, flat, fire dependent coastal forest woven through Carteret, Craven, and Jones counties and connected to rivers, estuaries, shellfish waters, wildlife habitat, roads, and nearby communities. According to the Forest Service's official 2001 inventory, Croatan contains six inventoried roadless areas totaling 20,743.51 acres. Those areas include pocosins and other wetland landscapes where water, fire, and access have to be managed together. I understand why the Forest Service is talking about wildfire response, prescribed fire, forest health, restoration, and access. Those are legitimate management needs in Croatan. The Forest Service's own planning documents describe volatile pocosin fuels, Wildland Urban Interface areas, high water tables, flammable vegetation, ignitable organic soils, and access challenges. The question I want answered is not whether Croatan needs active management. It does. The question is what specific problem in each roadless area cannot be addressed under the authorities and exceptions that already exist, and what additional environmental cost would come with removing the national rule. Roads matter differently in this landscape. A new or reconstructed road across wet ground can change drainage, move sediment, require culverts and ditches, and create a maintenance responsibility that lasts well beyond the project that justified it. Croatan's own forest plan directs managers to minimize haul roads, avoid equipment operation under very wet soil conditions, and keep visible sediment out of streams. If expanded road access is part of the reason for rescission, the public should see the full road cost, including drainage, maintenance, restoration, and downstream water impacts. The downstream connection matters to us because these are working waters. According to NCDEQ, most impaired waters in the White Oak River Basin are associated with shellfish growing area classifications. Forest Service planning documents also recognize that waters in the Croatan landscape feed the White Oak, Newport, Trent, and Neuse river systems. A national conclusion that commercial fishing impacts are expected to be small does not answer the local question of what additional road building, ditching, or altered drainage could mean for a particular creek, river, shellfish growing area, or fishing community. This is also a community cost question. People in our region already live with flooding, road damage, drainage problems, storm recovery, and water quality closures. If greater federal management flexibility creates costs that later show up in a county road budget, a drainage system, a shellfish closure, or a family's property, those costs belong in the analysis too. My request to the Forest Service is to make this decision Croatan specific. For each of the six roadless areas, show what management action is currently limited, why existing exceptions are not enough, what roads or ground disturbance could reasonably follow, what the fire or restoration benefit would be, and what the hydrologic and downstream impacts could be. Croatan National Forest is defined by water as much as by trees. The final decision should reflect both.

I really hope we don’t lose the Croatan National Forest. It’s more than trees to us. it’s hunting, fishing, camping, exploring, and memories made with family and friends. These public lands are a huge part of Eastern NC, and I’d hate to see future generations lose the chance to enjoy them the same way we do.

I oppose rescinding the 2001 Roadless Area Conservation Rule and strongly support maintaining its protections for inventoried roadless areas on our National Forest System lands. The importance of the Roadless Rule goes far beyond simply keeping roads out of otherwise undeveloped areas. Its greatest value is protecting large, connected blocks of habitat from the fragmentation and cumulative impacts that accompany road construction and development. A road does not affect only the relatively narrow strip of land it occupies. Roads divide continuous habitat into smaller patches, increase edge effects, disrupt wildlife movement and dispersal, introduce additional human disturbance, and can facilitate invasive species and disease. Road networks can also alter hydrology, sediment movement, and water quality. The Forest Service's own analyses have identified these types of effects, including habitat fragmentation, barriers to wildlife movement, increased edge effects, and degradation of aquatic resources. This is particularly important in a landscape where habitat outside public lands is increasingly fragmented by development. As intact habitat becomes scarcer, the remaining large and relatively undisturbed areas on our National Forests become increasingly important for maintaining ecological connectivity, wildlife populations, and functioning ecosystems. The value of these areas cannot be adequately measured by the number of acres directly cleared for a road or timber operation. Fragmentation is also difficult, if not impossible, to reverse. Once a road network has divided an intact landscape and development has followed that access, removing the road later does not necessarily restore the original ecological function or reconnect the habitat in the same way. The Roadless Rule provides a national framework for retaining these relatively intact landscapes while still allowing the Forest Service to manage National Forest lands for multiple uses. Rescinding the rule would remove those nationwide protections and place greater responsibility for decisions about road construction and timber harvest in inventoried roadless areas at the individual forest and planning level. As someone who lives near the Croatan National Forest, I see the value of these remaining connected landscapes firsthand. But this issue is much larger than the Croatan. Across the country, roadless areas represent some of our remaining opportunities to maintain large, connected ecosystems before they become fragmented. Please retain the 2001 Roadless Area Conservation Rule and its protections for our nation's remaining inventoried roadless areas.

I'm writing to ask that you not overturn the Roadless Area Conservation rules. I'm a frequent visitor to Croatan National Forest. This is the only true coastal forest on the east coast of the United States. It is an irreplaceable treasure and must be protected for future generations. This unspoiled beauty is part of our birthright as Americans.

It is vital that we preserve our national forest areas for wildlife, for flora and fauna, for watershed, for recreation, and for the future. Please do not repeal! Croatan National Forest is one of the few areas for long leaf pine, pocossins, and plants like the pitcher plant and Venus flytrap.Do not repeal and build roads, log, and destroy our forests.

I a writing to express my support for maintaining the Roadless Area Conservation Rule. I live next to the Croatan National Forest in eastern North Carolina. This national forest is an irreplaceable piece of habitat that has already faced incredible pressure due to development. Please maintain the rule to ensure its continuity.