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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The American idea of a frontier still means something to me. I have hunted my whole life, and the work required to hike or paddle into country that remains unroaded is part of the value. Putting more roads into these forests increases pressure and erodes the ability to distance yourself from those who rely on vehicles. Roadless areas in the Croatan National Forest, including the Pocosin Addition, Sheep Ridge Addition, Catfish Lake North, Catfish Lake South, and Pond Pine B units, represent the Public Trust set aside for exactly this kind of recreation, and the rescission of the 2001 Roadless Area Conservation Rule would damage or destroy what makes them worth seeking out. I have fished my entire life as well, and what roadless protection means in practice is less-pressured fisheries and cleaner water. North Carolina holds 38 inventoried roadless areas totaling 172,416 acres, and across the Southern region, which includes North Carolina, 378 municipal water intakes sit in watersheds containing affected roadless areas. Opening these forests to road construction does not leave those values intact. I ask that the agency address, specifically and on the record, what happens to water quality in the watersheds draining the Croatan units when the buffer that roadless designation currently provides is removed. One of my best bird sightings was a Swainson's Warbler, a species that requires old-growth bottomland hardwood habitat. The Roadless Rule protects exactly those habitats, and the agency's own record supports what anyone who has spent time watching birds in unroaded forest already knows. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. There is plenty of accessible timber already available in the Croatan, and the agency must explain why fragmenting the remaining roadless habitat is necessary when its own evidence documents this degree of harm to bird communities. The proposal attempts to justify rescission partly on wildfire management grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain why the proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS. The economic case for rescission is equally unsupported by the agency's own analysis. The 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 projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, a net present value spanning negative $92 million to positive $199 million, and a road maintenance backlog already sitting at $6.9 billion. The agency has not established that a net benefit exists, and I ask directly how expanding a system it cannot afford to maintain is justified by numbers it cannot resolve in favor of the action. The proposal also argues for state-by-state alternatives to a national rule, but the agency's own record acknowledges 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 must confront its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it must explain how this proposal avoids the legal deficiencies that ended the last attempt to replace the national rule with a state-by-state framework. Finally, the proposal's challenge to the statutory authority underlying the 2001 rule is contradicted by the courts that already examined 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." The agency must address that court's holding that the 2001 rule fell within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. Any position to the contrary requires a legal explanation the agency has not yet provided. Sincerely, Elliott Lupton Havelock, NC 28532