Read the comments.

October 5, 2026 Director, Ecosystem Management Coordination U.S. Department of Agriculture, Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 RE: Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule and Draft Environmental Impact Statement, Docket No. FS-2025-0001; RIN 0596-AD66 Dear Director: The City of Harrisonburg respectfully submits these comments in opposition to the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). The City requests that the Forest Service select the No Action alternative and retain the Roadless Rule. The Rule provides nationally consistent safeguards that generally prohibit road construction, road reconstruction, and timber harvesting in inventoried roadless areas, subject to limited exceptions. Those safeguards are essential to protecting the water resources, recreation opportunities, and community benefits on which Harrisonburg relies. Harrisonburg has a longstanding and direct interest in management of the George Washington National Forest (GWNF). In 2008, the Harrisonburg City Council adopted a resolution calling on the Forest Service to provide comprehensive management and protection of drinking-water resources within the GWNF. In 2010, the City reiterated that maintaining protection of its water resources was the most significant issue associated with the Forest Plan. Those concerns remain unchanged. The GWNF is integral to the protection of Harrisonburg's drinking-water supply. The City provides drinking water to more than 60,000 people and relies on surface-water intakes on the Dry River and North River; as well as constructing a new supply from the South Fork of the Shenandoah River. These supplies are fed by headwaters that flow from nearby roadless areas. The Skidmore Fork, Gum Run, Oak Knob, Little River, Ramseys Draft Addition, Crawford Mountain, and Elliott Knob Roadless Areas all help protect watersheds important to the City. The City's Dry River source illustrates the public value of maintaining these protections. The City's Comprehensive Plan identifies the source as minimally affected by development, of sufficiently high quality to require relatively little treatment, and positioned to provide gravity flow to the Water Treatment Facility. Protecting this type of high-quality source water avoids or reduces future treatment and energy costs borne by utility customers. Protecting drinking-water watersheds also supports long-term water-supply resilience for Harrisonburg and other Shenandoah Valley communities. Road construction and associated ground disturbance can increase erosion and sedimentation, adversely affecting streams and downstream water supplies. Rescinding the Roadless Rule would eliminate an important preventive safeguard. Local forest planning and site-specific environmental review should reinforce, not replace, the Rule's clear, nationally applicable protections for inventoried roadless areas. Roadless areas also provide significant recreation, habitat, and economic benefits to Harrisonburg and the surrounding region. They support hiking, mountain biking, hunting, angling, and backcountry experiences that draw visitors to the Shenandoah Valley and sustain local businesses. Their intact forests and cold, clean streams support wildlife, including native brook trout, while helping preserve the natural character that makes this region a destination for residents and visitors alike. The City recognizes the Forest Service's need to address wildfire, forest health, and other management needs. The existing Roadless Rule already includes exceptions and does not preclude all management activity. Rescission is neither necessary nor appropriate to preserve the ability to address site-specific risks. Any forest-management approach affecting roadless areas must continue to protect source-water quality and quantity and provide meaningful early coordination with the local governments that depend on those watersheds. For these reasons, the City of Harrisonburg strongly opposes rescission of the 2001 Roadless Area Conservation Rule and urges the Forest Service to retain the Rule. Maintaining these safeguards is a prudent and cost-effective means of protecting Harrisonburg's drinking-water supplies, supporting the regional recreation economy, and preserving important natural resources for current and future generations. Sincerely, Alexander Banks VI City Manager City of Harrisonburg