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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I raised my boys in the Pisgah National Forest. I taught them to love and cherish our beautiful planet there, and we returned numerous times each year for rest, recreation, and to appreciate what North Carolina holds. Many days and nights spent camping in that area have been incredibly special to my family. I sincerely hope these places will be preserved for future families. That hope is why I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres, including places like Linville Gorge, where the last wild headwaters of rivers flowing to both the Atlantic and the Gulf begin, and where more than 30 endemic salamander species, black bear, hellbender, brook trout, cerulean warbler, and the northern long-eared bat live. These are among the most biodiverse temperate forests in North America. Anytime my family is outside, any wildlife sighting reminds us all that we share this planet with magnificent creatures. The loss of these roadless areas would not be an abstraction for my family. It would be personal. The agency's regulatory flexibility analysis certifies no significant impact on small businesses while the record says otherwise. "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 conclusion by averaging impacts across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. That method does not answer the question. I ask that the agency withdraw the certification and assess impacts on the specific small entities operating in the potentially affected roadless areas, not a national average. I am also writing as someone with a direct reliance interest in the rule. I raised a family around the Pisgah's roadless character, and that character shaped choices I made about where and how to do it. The agency itself invites this: "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." An agency reversing a twenty-year-old rule has a legal obligation to account for the reliance its prior policy created. This comment is one such interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. On fire, the agency's own data cuts against the proposal. I believe the risk of fire should be managed carefully, and I expected the agency's analysis to show that road access would help. It does not. "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 agency should quantify the expected increase in human-caused ignitions that new road access would bring and place that number honestly against whatever wildfire hazard reduction it claims. Roads enable development and contribute to contamination of the watershed. North Carolina holds 378 municipal water intakes in watersheds containing affected roadless areas, and these places are the headwaters of safe and clean drinking water for many residents. We cannot compromise our water supply in any way. I do not want a penny of my tax dollars used to despoil the Linville Gorge area. Seriously. The agency is already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. Building new roads into country that has none, under those conditions, makes no fiscal sense and creates permanent damage that a logged stand cannot match. A stand grows back. A road does not. On biodiversity, the agency's own science makes a finding it then declines to apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears and then nothing follows from it. No projection is applied to the 40.1 million acres of potentially affected environment. The agency should apply that cited range to the full affected acreage and explain what it means before finalizing any action. Prior generations had the foresight to set aside these public lands for health, recreation, and quality of life, including the more than 600 public meetings and 1.6 million comments that produced this rule. No equivalent process has been held to undo it. My boys should not inherit fewer of these places than I was given. Neither should theirs. Sincerely, Leigh Coulter Indian Trail North Carolina

Dear Forest Service Officials, As a public land hunter, angler, and conservationist, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I grew up in the North Carolina mountains where I learned to fish and mountain bike in the Pisgah National Forest. Since graduating college, I've spent the past 25 years hunting, fishing, working, and recreating in national forests across the lower 48 States including the Arapaho and Custer Gallatin National Forests. When I visit my mom and sister every year, I take my wife and two girls back to the Pisgah National Forest. When we visit my wife's mom in Utah, we visit the Uinta-Wasatch-Cache National Forest. The 2001 Roadless Rule has yielded these healthy and productive public lands that my family and I hunt, fish, bike, and hike. I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The 2001 Roadless Rule has successfully protected millions of acres of pristine national forest lands, safeguarding critical fish and wildlife habitats, ensuring clean water supplies, and preserving high-quality backcountry hunting and fishing traditions. Rescinding this durable baseline policy would fragment vital wildlife corridors, increase long-term management and road-maintenance backlogs, and permanently alter our remaining wild landscapes. Rather than dismantling a proven conservation framework, the USDA should select Alternative 1 (the No Action Alternative) and maintain full protections for our roadless areas. Sincerely, Mathew Levine Naples, NY

I am commenting on the USFS plan to rescind the 2001 Roadless Rule. The plan to rescind the Roadless Rule is ill-conceived and I urge selection of the No Action Alternative. The DEIS fails to address the protections and values the Roadless Rule provides and fails to adequately analyze the impacts road building and other resource disturbing activities would have on these areas. Roads are the primary cause of habitat fragmentation, sedimentation, and invasive species introduction in forest ecosystems. While the DEIS discusses the impacts from rescinding the Rule, it never addresses the “so what” question. In other words, recognizing there will be impacts doesn’t fully address what the consequences are from those impacts. I.e. the DEIS acknowledges sediment loading, from road building, impacts to water quality, but it never adequately analyzes how this would impact drinking water for communities that rely on these water sources. Implying BMPs will offset any impacts doesn’t fully analyze the negative impacts to water quality and how that would impact communities, fisheries, etc. The same goes for introduction of NNIS. The DEIS acknowledges building roads will lead to the introduction of NNIS but never adequately analyzes the impact that will have on native species, especially T&E species, or on the difficulty of forest regeneration with the introduction of NNIS. Roadless areas provide clean drinking water to many downstream communities. Peer-reviewed research published in PLOS Water found that these areas serve as the primary protection mechanism watersheds that supply drinking water to 25 million U.S. citizens. I live in Western North Carolina, and the South Mills River Roadless area in the Pisgah NF is source of drinking water to the city of Hendersonville. Allowing roads to be built in this area would degrade the water quality for that community. This area recieves a large amount of rainfall and intense rain events. No amount of BMPs can provide adequate protection to that situation. Roadless areas also provide world-class hiking and mountain biking trails, supports local businesses, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. Getting rid of the Roadless Rule puts all these incredible benefits at risk. I live in an area that is a gateway to the Pisgah NF. Our community relies heavily on tourism and a major draw is mtn biking, especially in the South Mills River roadless area. Allowing roads to be built in the area would negatively impact the backcountry nature of this area and enjoyment many gain from that experience. While the EIS claims getting rid of the Roadless Rule will help prevent wildfires, the facts don’t back that claim up. Wildfires are 4 times more likely to start near a road than in a roadless forest. Roads are ignition corridors, and about 89 percent of wildfires nationally are human-caused. Far from preventing wildfire, building roads boosts wildfire ignitions. The DEIS fails to adequately address this discrepancy. Additionally, the Roadless Rule already allows the Forest Service to do wildfire prevention work and fight fires in roadless areas. The rule does not prohibit wildfire fuel reduction work; projects like prescribed burning and vegetation thinning can and do take place within these protected zones. Nearly 2 million acres of roadless areas have received hazardous fuel treatments since the rule was adopted in 2001 The majority of these roadless areas contain steep slopes which makes road construction extremely expensive and exacerbates the impacts to soil and water resources. Opening these areas to road construction will only add to the issue the Forest Service has with road maintenance, which is severely underfunded. The Forest Service is not able to maintain the over 370,000 miles of road it currently has, and has a $5.4 billion deferred maintenance backlog for roads. It receives a fraction of the funding needed to maintain what it has, much less any new roads in rugged terrain. Unmaintained roads can lead to landslides and lower water quality, which threatens the health of entire ecosystems. The agency can’t afford what it has and should not worsen the situation by adding more roads. How will adding to the maintenance costs be addressed and resolved? The DEIS is written in a pre-decisional manner. It appears to be written to justify rescinding the roadless rule and downplays the value of these roadless areas while understating the impacts from opening these areas up to road construction. One of the main arguments that these areas need to be opened up to address wildfire potential just doesn’t hold water. The Roadless Rule has been in effect for 25 years, providing clean water for many municipalities, habitat for many plant and animal species needing unfragmented forest conditions and unmatched back country recreational opportunities. These values deserve to be protected.

Please do not resend the Roadless Rule. I am an individual living next to the Pisgah National Forest. It is habitat to so many animals and birds. I am close to a Peregrine Falcon nesting area. Roads into the area are adequate and we do not need to disturb habitats further. Do not do this. Thank you, Dorothy Griffith Linville, NC

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.

I am completely is against rescinding the roadless rule. I live near and recreate daily in the Pisgah National Forest in NC. Over 144 acres of our pristine blue ridge mountains are at risk. I hike, bike and camp in these mountains every weekend. I work at a local outfitters and constantly give advice on hikes and activities in Pisgah to locals and tourists alike. We love these mountains and want to protect what we have left. In addition to frequenting Pisgah, each year my husband and I go out west for at least three weeks at a time. Over the past 5 years, we’ve been able to see and experience so much of the US through public lands. We stay on BLM lands and cherish the wild experiences in the vast, undeveloped nature. It’s made us quite patriotic and given us a great appreciation for public lands and the protections in place. Throughout this comment, I will be citing only from your Roadless Rule Draft Environmental Impact Statement (DEIS). Rescinding the roadless rule will not meaningfully reduce wildfire risk. In fact, it's likely to increase it."The proportion of human-caused fires in Roadless areas is less than half on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads." (pg 86; see Aplet et al. 2026). USFS doesn't have the budget to maintain their existing road infrastructure, much less new ones. The Forest Service has a $7 billion deferred maintenance backlog, and an estimated $1.6 billion is needed annually to maintain existing roadways. In 2023, the USFS received <20% of this amount for road maintenance. (pg 42) The DEIS states "...revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." (pg 45) Rescinding Roadless may degrade critical resources with downstream consequences. Timber harvest increases soil erosion, compaction, and the probability of landslides. Landslides and debris flows are 6 to 9 times more likely adjacent to forest roads. (pg 111) Soil compaction can reduce seedling establishment and survival (pg 110). Removing trees and vegetation also reduces rainfall intercepted and transpired by plants. (pg 111) Rescinding Roadless could reduce biodiversity and damage critical habitat for endangered species. Roadless areas "overlap the range of more than 300 threatened, endangered, and proposed species; 79 final or proposed critical habitats managed by USFWS; and 19 critical habitats... listed under the ESA" (pg 160) The DEIS also estimates negative impacts to fish & game species such as elk, steelhead trout, and salmon (pg 141, 152). This can reduce critical food resources that rural and Indigenous communities rely on, and that people hunt! Recreation & tourism are more profitable than roadless timber. Rescinding Roadless could actually hurt local jobs and economies. In 2024, visitors to roadless areas spent $8.5 billion in local communities during their recreation visits (pg 212). Annual economic benefits within the potentially affected roadless areas are upwards of $1.5 billion for recreation, and $419 million for hunting, fishing, and wildlife viewing. (pg 214) Rescinding Roadless may degrade cultural resources and violate Indigenous sovereignty. Indigenous communities rely on roadless areas (i.e., Native land!) for food, medicine, ceremony, and more. "Increased road infrastructure may lead to unauthorized public access, vandalism, or desecration of sacred sites" (pg 201) "Roads and timber harvest may create barriers to treaty-reserved hunting, fishing, and gathering areas... [undermining] subsistence practices, economic development, and Tribal restoration goals... affecting fisheries that are central to Tribal diets, economies, and ceremonies... and diminishes hunting opportunities and violates the spirit of reserved hunting rights." (pg 202) "Roads act as vectors for invasive plant species, which can outcompete culturally significant native plants used for food, medicine, and ceremony." (pg 202) Thank you for your time and consideration. Please listen to the voices that call these lands home. If we’re the greatest country in the world, why can’t we protect the little natural spaces we have left? Protect our land.

When I returned from a trip to Alaska at the end of June 2024, it took weeks for the euphoric feeling of wildness to drain from my body. I live in the South Toe Valley of Yancey County, one of the most pristine river valleys in North Carolina, alongside the wildlands of the Black Mountains, but our thick forests and clean river suddenly felt miniscule and adulterated compared to the vastness and quality of Alaska’s wilderness. The Blacks harbor about 15,000 designated roadless acres (split between Balsam Cone and Bearwallow roadless tracts) but most of the entire state of Alaska is roadless. Imagine erasing 99% of the roads in the entire state of North Carolina; that’s what Alaska is like. Alaska’s vast roadless nature has long served as a reservoir of American wildness. When the bald eagle was all but extirpated from the continental US, a thriving remnant Alaskan population helped repopulate the rest of the nation. In addition to saving the bald eagle from extinction, we can thank Alaska for preserving and protecting trumpeter swans and timber wolves. Closer to home, that reservoir theory can be applied to the relatively modest patches of wild forest of North America’s eastern seaboard. The Southern Appalachians are fortunate to have one large tract of wilderness (the Great Smoky Mts NP’s 400,000 acres of roadlessness) but more modest roadless pockets in places like the Black Mountains play an increasingly important role in the sheltering of native species. Many Eastern species were lost or endangered when the forests were largely cleared between one and two hundred years ago. The remaining tracts of forest and their unique inhabitants have largely recovered and spread over the past century, thanks to the natural communities that found harbor in those wild refuges. Three months after returning from Alaska, my home in the mountains was hit by Hurricane Helene. Geologists have not determined the exact number of deadly landslides and debris flows that were instigated by roads, but experts in geomorphology who I’ve consulted say road scars on our mountains caused many, if not most, destructive landslides. When a road is constructed on a mountainous landscape such as ours, it changes the grade both above and below the roadbed, making those areas much more vulnerable to slope failure. These failures too often lead to deadly debris flows. When Helene came to this valley, we received a record-breaking 31” of rain in 48 hours. It was not a coincidence that not a single South Toe resident died in a debris flow. Several died in the paths of debris flows in the Cane River Valley – just on the other side of the Black Mountains where the USFS land is not protected under roadless statutes. Lastly, I run an ecotour business which employs myself and several part-time employees, and is utterly dependent on the Balsam Cone roadless area. I am a fee-paying, permitted guide and outfitter in the Pisgah NF; its roadless areas and the clean tributaries protected by them are the most valuable assets of my business. Ecotourism is increasingly becoming an essential part of our WNC economy. I would urge you to preserve the 2001 Roadless Area Conservation Rule. Thanks for taking all this into consideration!

Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220 The recreation visitation figure supporting the Alternative 3 economics is unsourced, and the visitor-use citation it points toward does not resolve. Repealing the Roadless Act will devastate local economies including where I’ve spent much of my life, and currently vote, the northwest counties of North Carolina. Pisgah National Forest, Wilson Creek, Lost Cove and Harper creek are three designated areas that will be impacted. I’ve reviewed the arguments for and against rescission. Those for it seem specious and thinly veiled. Returning local well-paying jobs for timber harvesting to local communities? Wistful nostalgia for Paul Bunyan's days. And one of the most dangerous occupations. This will be mechanized, industrial clear cutting. With soil depleting, animal-and-plant life be-damned devastations. Their native state will not be recoverable in my lifetime, yours, your grandchildren, or ever for some species of plants and animals. We don’t need to go back to the 19th century so timber and mining companies can revert to their harmful practices but using massive modern machinery. Preserving the current state of these lands will be a legacy to be proud of. Defeating this rescission is an effort will trickle down the generations in a positive way. In stated terms for rescission regarding state sovereignty and local governments, the network of small businesses that thrive on use of these roadless areas for recreational hiking, hunting, fishing, camping and other activities is far more important than having corporations strip the resources out of their rural economies. This is an extremely important part of the economy in the NC High Country. In fact, many areas targeted are not roadless but provide enough access for recreational use. No new roads needed to add to the existing burden on the U.S. Forest Service to maintain the ones already in place because of budget constraints and limited resources. The people profiting will not be local. May not even be American, especially in mining? They certainly won’t be the families in Watauga and Avery counties who can’t afford European vacations but love being near, on and in local creeks and rivers. When those waterways are filled with silt, devoid of fish, slimed with algae, and never a Hellbender to be found again, someone will have some explaining to do about the thinly veiled excuses for changing the Roadless Act that has worked well so far in the 21st century. When these areas are irreparably damaged, what will happen then? Jobs? No. Tourists, hunters, anglers, backpackers and the small companies that support them? Gone. You can bet Washington will no longer be talking about wildfire management and access for forest management in the face of climate change, which involved administration officials supporting the rescission likely deny is even happening. Government overreach? The original Roadless act was a protective, responsible, ‘parental’ hand over lands millions of Americans use and love. We also love areas that can’t be used because they are wild and remote. We like them that way. The rescission would be a fist slammed down for an obvious massive giveaway to corporations. Neglectful of local communities, forest management, and unconcerned about the economic and recreational opportunities that will be lost. That’s abusive. There are almost 20,000 acres near my home in Blowing Rock, NC that will be affected in Pisgah National Forest, Wilson Creek, Lost Cove and Harper Creek. Other areas important to me are in the Nantahala and southern Pisgah region. Almost my entire adult life I have made some of my most cherished memories hiking, whitewater kayaking, trout fishing, and camping in the mountains of North Carolina. My entire life I’ve enjoyed the Blue Ridge Parkway; asphalt I do love. The USFS map showing areas that will be impacted are heavily dotted along the Parkway in NC. I can't imagine what rescission could do to the viewsheds. Encroachments from rapid development, loss of agrarian life, and too-narrow protected corridors has already changed it. Clear cutting, road building, mining, documented INCREASED wildfires after more roads will be awful. The Parkway is a CRITICALLLY important economic driver in our area. I love our southern Appalachian Mountains. Repealing the Roadless Act is a short-sighful obvious handout to corporate interests. There is no plausible significant benefit economically, ecologically, recreationally, for MILLIONS of Americans who use these lands. Or for the flora and fauna that make them so distinct in our southern Appalachians. Stay the course by keeping the Roadless Act intact. Unsourced FY2024 Recreation Visitation Figure and Unresolved NVUM Citation at Draft EIS p. 220

I am expressing my objection to rescinding the roadless rule. It is important that sufficient areas of the National Forest are protected from overreach, overuse, damage to watersheds, unnecessary logging, and irresponsible forms of recreation that harm the natural environment. I live near Pisgah National Forest in Western North Carolina and am an avid outdoor person who strives to enjoy the beauty of nature without imposing strain on the fragile ecosystems that will be deeply and adversely affected by rescinding the roadless rule. Please take into account the overwhelming public objection to rescinding the roadless rule. People in our United States care about the environment and should be respected for these well considered and researched arguments to keep and hopefully expand the roadless areas of the National Forest System. Many public acres are already available for the other uses intended by this proposed reversal of the widely supported roadless rule. Share the public lands and maintain support for the roadless rule.

Hi, I’m Gwyneth, and I am an 18-year-old from North Carolina. I have been hiking, camping, and backpacking in Pisgah National Forest since I was born. Some of my fondest memories are of seeing the pristine, ancient forests. Building roads through these forests presents extreme risks for this area. There is such a small amount of undisturbed Appalachian forests; these areas are some of the most biodiverse in the US, and there is no good reason to disturb them. We need to stop putting temporary profits above permanent damage to these areas. Please don’t allow this bill to pass; please protect these forests for us and future generations.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My career in stream restoration has taught me something that seems lost on the agency proposing this rescission: damage to intact headwater systems is expensive and irreversible. I have had to seek federal funding to restore streams in urban and rural landscapes, including Cuyahoga Valley National Park. I know what erosion and sedimentation cost counties, states, tribes, landowners, federal agencies, and taxpayers long after the roads that caused them have served their purpose. Opening new roads into the roadless areas that protect the last unfragmented headwaters strikes me not as management but as the deliberate manufacture of future problems. These areas are a national treasure and hold the key to our shared future on Earth, in the context of our twin crises of climate change and biodiversity loss. I often travel to natural areas to watch birds, recreate, and find peace. I have hiked and worked across public lands in Utah, Idaho, Nevada, California, Oregon, and Washington since 2004. Annually, my family travels from Ohio to Allegheny National Forest and Pisgah National Forest to hike and bike. The 18 inventoried roadless areas of Pisgah, totaling 99,369 acres, include headwaters of the Atlantic and the Gulf, habitat for cerulean warblers, northern long-eared bats, hellbenders, brook trout, and more than 30 endemic salamander species found nowhere else on Earth. The agency's own record acknowledges 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. The agency has this finding in its own DEIS and has chosen not to treat it as decisive. I ask the agency to explain how that finding is outweighed by the justifications offered for rescission. Public lands should be managed to promote biodiversity and climate resiliency, protecting habitat for rare and listed species, reducing habitat fragmentation, and sustaining ecosystem services including clean air and water. The Pisgah and Nantahala roadless areas, combined with Utah's 4,013,529 acres across 222 inventoried roadless areas and the lands I have walked in six western states, represent the core of what remains of unfragmented forested habitat at national scale. Rescinding the 2001 rule trades that permanence for benefits the agency's own cost-benefit analysis cannot confirm. I ask the agency to reconcile the proposal with its own economic analysis, which 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 and a net present value spanning -$92 million to +$199 million, and to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. My tax dollars should support conservation and habitat protection, not the degradation of the last contiguous habitats protecting many listed and rare species. The wildfire rationale offered for this rescission sits in direct tension with the agency's own findings. The DEIS 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." Our western forests need adequate management to reduce the risk of widespread wildfire, and I support that goal, but deforestation is not the answer and neither is a road network that, by the agency's own data, elevates ignition risk. The agency must explain why the proposal departs from these findings and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I commented on this rescission in 2025 and received no response. I feel that legislators are not listening to or representing the interests of their constituents and are bowing to corporate interests aimed at gutting our shared natural resources. I want these places preserved and protected for other visitors and future generations. This docket deserves an answer to each of the points raised above. Sincerely, Ann Gilmore, Kent, Ohio 44240

Dear Chief Tom Schultz: I am writing to express my objection to rescinding the roadless rule. It is vital that these areas of National Forest Land be protected from the potential damage that would be likely if the roadless rule is rescinded. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Rare Plant Habitat in Cove Forest and Wetland Transition Zones — The area's diverse forest types—Rich Cove Forest, Acidic Cove Forest, and Canada Hemlock Forest—support multiple federally protected plants including Small Whorled Pogonia and Swamp Pink (both federally threatened), as well as critically endangered species like Green Pitcher Plant and imperiled Oconee Bells. These species occupy specific microclimates and soil conditions found in undisturbed cove forests and wetland-upland transitions; road construction and the associated fill, drainage, and soil disturbance would destroy the precise hydrological and edaphic conditions these plants depend on, and these conditions cannot be recreated once lost. Rescinding the Roadless Rule would open the South Mills River, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. It is important that sufficient areas of the National Forest are protected from overreach, overuse, damage to watersheds, unnecessary logging, and irresponsible forms of recreation that harm the natural environment. I live near Pisgah National Forest in Western North Carolina and am an avid outdoor person who strives to enjoy the beauty of nature without imposing strain on the fragile ecosystems that will be deeply and adversely affected by rescinding the roadless rule. Please take into account the overwhelming public objection to rescinding the roadless rule. People in our United States care about the environment and should be respected for these well considered and researched arguments to keep and hopefully expand the roadless areas of the National Forest System. Many public acres are already available for the other uses intended by this proposed reversal of the widely supported roadless rule. Share the public lands and maintain support for the roadless rule. Regards, Matthew Runningen Respectfully, CommentID: RLC-20261007-XUESWW

To the US Forest Service: My name is Laura Sparks and I’m a photographer based in Asheville, North Carolina. I’m writing asking you to not rescind the Roadless Rule. I care deeply about these public lands as my business depends on them! I spend a lot of time within Linville Gorge Wilderness and Pisgah National Forest (specifically Sam Knob, Black Balsam, and Flat Laurel Creek). And more importantly, as a person who simply loves the outdoors, I want to see these areas protected. WNC is very vulnerable after Hurricane Helene. Allowing any roads to be built opens this area up to more harm. I know many have argued that this will help to fight forest fires, but we know from research, that many forest fires are manmade. I worry that easier access to these lands will in turn cause wildfires, not prevent them. Our watersheds are also vulnerable with many protected species such as the Eastern Hellbender that are at risk of such a rule being rescinded. Please, I beg you, help keep these areas wild. It’s hard to find untouched wilderness these days and it would mean so much to so many to still be able to enjoy nature as it was intended. Thank you for the opportunity to make public comment. Sincerely, Laura Sparks

I am vehemently opposed to the proposal to fully or partially rescind the Roadless Rule. Sam Knob in Pisgah National Forest is a place that my family explores, recreates, and stewards. It’s a place full of delicate native plant life, animals, and trails. I have spent many years dedicated to learning about the biodiversity of this region and the ins and outs of native plant and animal life. I am a former student of the UNC botany program and a 4 year volunteer with the national parks service, where I act as a citizen scientist by gathering wildflower phenology data alongside a dedicated team of volunteers like myself. I live nestled amongst the Great Smoky Mountains, Nantahala, and Pisgah National Forests and I consider all three an extension of my own backyard. Our state is already overrun with unregulated development and urban sprawl. Wild spaces are sacred not only to North Carolinians, but to human civilization as a whole. Wild land like this is essential for our long term success and happiness. There is substantial research showing that logging is not beneficial to our forests. There is a three decade long study that shows correlation between logging and increased wildfires. Ultimately, logging will not help decrease wildfire numbers, in fact it would have the opposite effect. Building roads and disturbing ground leads to the spread of invasive, non native plants. These species can choke out and eventually annihilate native vegetation that supports a healthy and thriving ecosystem. This is also land that locals have fished, hunted and foraged for generations. We were predated by the Cherokee. This agency has obligations under the Constitution, treaty rights and federal law "to protect and preserve the inherent rights of American Indians into perpetuity," including access to lands, use of forest products, freedom to practice traditional religions, and protection of sacred sites. These are binding obligations. The last thing our area needs after Hurricane Helene is MORE destruction of our natural resources. Our land is still healing, and it cannot survive more disruption. The Forest Service should uphold this 25 year old ruling and protect our national forest for all North Carolinians and Americans.

I am writing in support of maintaining full, nationwide protections under the 2001 Roadless Area Conservation Rule. Proposals to rescind these vital protections—which would open previously closed backcountry areas to commercial road construction—represent an unacceptable risk to both public safety and fiscal responsibility in Pisgah National Forest and across the National Forest System. From a forest management standpoint, building roads into undeveloped areas creates an unnecessary fire liability. Decades of data show that wildfires are significantly more likely to start near roads than in undeveloped backcountry. A comprehensive, 30-year nationwide study analyzing all eight contiguous U.S. Forest Service regions found that wildfire ignition density is highest within 50 meters of roads, resulting in 7.99 fires per 1,000 hectares (Aplet et al., 2026). By contrast, ignition density drops drastically in protected Inventoried Roadless Areas to just 1.97 fires per 1,000 hectares (Aplet et al., 2026). Expanding the road network inherently expands human-caused fire risks into ecosystems currently protected by their remoteness. Furthermore, expanding the roaded footprint ignores the agency's severe infrastructure crisis. The Forest Service currently manages over 370,000 miles of existing roads and has faced a multi-billion dollar deferred maintenance backlog for more than a decade. It is fiscally irresponsible to authorize new road construction that the agency cannot afford to maintain, especially when those very roads create new, high-risk ignition zones that the agency will be forced to contend with. For the safety of our communities, the health of forests like Pisgah, and the responsible use of taxpayer dollars, I urge the agency upholds the Roadless Rule without exemptions. Sources Cited: • Aplet, G., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8). • U.S. Forest Service. National Forest System Infrastructure and Deferred Maintenance Records. U.S. Department of Agriculture.

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the the Linville Gorge, Wilson Creek, and Harper Creek areas of Pisgah National Forest near my home in Boone, North Carolina. I also travel frequently to enjoy our public lands across the nation, and for many years was lucky enough to call the White River National Forest of Colorado home. There aren't words to describe how deeply personal protecting these unfragmented landscapes is to me because not only do I depend on these watersheds for clean drinking water (I have a well, my parents have a spring fed tap), I also frequently explore the backcountry trails with my two dogs, and our community depends on the tourism that comes from the beauty of this ancient mountain region. I also put immeasurable value in our pristine wildlife habitats, that provide our unique biodiversity and enjoy the bears, fox, owls, deer, coyote, woodpeckers, hummingbirds, hellbenders, and countless other priceless species that I call neighbors. I BEG the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to listen to your citizens and abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Please place the natural value of our wild and beautiful nation above the material value in order to provide not only this generation but your children's generation, the opportunity to learn & grow from these unspoiled lands. We are all counting on you to see reason. Sincerely, McClure Jackson-Cathcart, RVT Boone, North Carolina

I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. As a Western North Carolina resident, I see firsthand how vital these protected spaces are to our community and our daily lives. My own children have grown up exploring the Pisgah National Forest—hiking its trails, swimming in its clear streams, camping under the stars, and developing a deep lifelong appreciation for nature. Stripping away roadless protections would directly threaten the future of the very places that define childhood and family life for so many of us in this region. Opening these undisturbed areas to road construction and logging would permanently scar and fragment the Pisgah. Decades of research show that new roads lead to immediate soil erosion, degrade the pristine water quality of our mountain watersheds, and invite invasive species that displace native wildlife. These wild, intact backcountry spaces are irreplaceable, and once they are broken up by development, they are gone forever. Rather than reversing protections that have successfully safeguarded our public lands for a quarter-century, the Forest Service should leave the current rule fully in place. I urge the agency to reject this rollback and choose the No Action Alternative so that future generations of North Carolina families can continue to hike, camp, and find peace in a healthy, intact forest.

Please do not charge or rescind the roadless rule. Rescinding the roadless rule will cause irreparable damage to public lands throughout the country, but particularly in my home state of North Carolina. Areas already negatively impacted by Hurricane Helene will be further damaged. Adding roads will increase the likelihood of fires from automobile traffic and use of land by individuals less likely to care for and protect the area. Sections of Pisgah National Forest will become less appealing for hiking and recreating and this will also negatively impact the tourism industries in areas already hurt by Helene. Please keep our public lands undeveloped as intended and preserve them as areas for public use, not private or corporate extraction.

Those of us that love the outdoors, love nature and want to spare it from exhaustive roads and people. Please don't go this route! I am writing about the Craggy Mountain Roadless Area in Pisgah National Forest, North Carolina. I have specific concerns about the rescission of Roadless Rule protections. Headwater Stream Networks Supporting Native Brook Trout: The Craggy Mountain roadless area encompasses the headwaters of seven major creek systems—Dillingham Creek, Bearwallow Branch, Carter Creek, Mineral Creek, Peach Orchard Creek, Sawmill Branch, and Waterfall Creek—that feed into the Big Ivy and Shope Creek watersheds, recognized strongholds for native Southern Appalachian brook trout. These headwater streams maintain the cold, clear water conditions that brook trout require for spawning and survival; the intact riparian forest and undisturbed streambed provide the stable, gravel spawning substrate and shade that regulate water temperature. The Eastern Hellbender (proposed federally endangered), a large aquatic salamander sensitive to sedimentation and temperature change, also depends on these clean, cold headwater conditions. Road construction in steep terrain directly threatens this entire network through erosion and canopy loss. Interior Forest Habitat for Bat Species and Canopy-Dependent Birds: The unfragmented northern hardwood and high-elevation red oak forests of Craggy Mountain provide interior forest conditions essential for three federally protected bat species: the gray bat (federally endangered), northern long-eared bat (federally endangered), and tricolored bat (proposed federally endangered). These species forage in the canopy and roost in tree cavities and under bark; they require large, continuous forest blocks to sustain viable populations. The cerulean warbler (near threatened, IUCN), a canopy-nesting songbird, similarly depends on the structural complexity and connectivity of unfragmented forest. Road construction fragments this interior habitat, creating edge effects that expose bats and birds to predation, reduce foraging efficiency, and allow invasive species and parasites to penetrate the forest interior. Invasive Species Establishment and Spread Along Road Corridors: Road construction creates disturbed soil and edge habitat that favor invasive plants over the specialized native flora of Craggy Mountain's rare plant communities. Hemlock woolly adelgid, an invasive pest already documented as a threat to eastern hemlock (near threatened, IUCN) across the Pisgah National Forest, spreads rapidly along road corridors and disturbed areas. Once established, invasive species alter soil chemistry, hydrology, and light availability, making it impossible for rare plants like Gray's lily and Oconee bells to persist. The road itself becomes a permanent vector for invasive seed dispersal, ensuring that native plant communities cannot recover even if road use eventually ceases. Sincerely, Robert Medina (local trail hiker and small time Real Estate Developer)

I support Alternative 1: Keep the Roadless Rule fully intact. I am an avid hiker, camper, and mountain biker in the George Washington and Jefferson National Forest in Virginia and West Virginia. This National Forest, my home National Forest, is part of the 45 million acres that will lose protections if the Roadless Rule is rescinded as described in Alternatives 2 and 3 of the Draft Environmental Impact Statement (DEIS). I seek out public lands like Pisgah National Forest as a destination for the solitude and high quality recreational opportunities. As an Environmental Scientist, I understand the urgent need to protect water resources like headwater streams, watersheds, and ecologically sensitive areas. These areas must remain protected and roadless to protect species like the Eastern Hellbender. We owe it to future generations to keep the Roadless Rule fully intact. For the reasons outlined above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the DEIS risks irreversible damage to water resources and ecologically sensitive areas that provide habitat for at-risk species like the Eastern Hellbender. We owe it to future generations to keep the Roadless Rule fully intact. I support Alternative 1 to Keep the Roadless Rule unchanged.