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I am writing to formally express my strong opposition to any effort to fully or partially rescind the 2001 Roadless Area Conservation Rule. As a resident of Upstate South Carolina, I have a deep personal and civic interest in the protection of our National Forests. My family and I regularly hike, kayak, and camp in the Pisgah, Nantahala, and Sumter National Forests, and our family owns property adjacent to the Sumter National Forest in Oconee County, South Carolina. These forests are essential resources for wildlife, recreation, clean water, and the long-term well-being of communities throughout the region. Allowing increased road construction, logging, and other development in inventoried roadless areas would result in permanent fragmentation of these landscapes and the loss of important ecological and recreational values. Our region has already experienced the consequences of forest disturbance, including erosion, landslides, and increased wildfire risk. Protecting intact forestlands is a critical component of protecting our watersheds and reducing these risks. The importance of these lands extends well beyond recreation. National Forests provide drinking water for numerous communities, support wildlife and hunting, and contribute significantly to local economies through tourism and outdoor recreation. Degradation of these forests would impose tangible costs on communities, residents, businesses, and future generations. I therefore respectfully urge the U.S. Forest Service and the U.S. Department of Agriculture to reject the proposed rescission contemplated under Alternatives 2 and 3 of the draft Environmental Impact Statement and to maintain strong, permanent protections for all inventoried roadless areas. These lands represent an irreplaceable public trust. Their protection is in the long-term interest of our communities, our natural resources, and future generations. Thank you for your consideration of my concerns and for your commitment to responsible stewardship of our National Forests.

As a conservationist, multi-state, multi-generational landowner, Master Naturalist, and former Georgia Native Plant Society President, I present my deep concerns on the consideration of removing the 2001 Roadless Area Conservation Rule that has stood firm across multiple circuits and implemented by both parties. Protecting the biodiversity of these pristine areas is paramount to me as a voting citizen whose parents taught me to love, respect, understand, respect science, education and cherish our land and wild places. Invasive species cost billions each year in the US alone. They are costing us personally, $1,000's of dollars each year and weeks and months of work to tackle species such as Johnson Grass introduced by a tenant farmer who mowed the sides of highways to collect free hay. The native plants on our farm, such as Christmas Fern, Red Chanterelles, Little Blue Stem, Solidago, Asters, Pawpaw, Milkweeds, Sparkleberry, Painted Buckeye, Shagbark Hickory, Broomsedge, are diminishing rapidly due to the introduction of invasive seeds transferred by tires and invasive feral swine. Invasives cost money and time to tackle reducing biodiversity by at least 25%. Feral swine are currently being illegally transported across the state for hunting clubs thereby increasing the problem. The more humans we introduce to the picture, the more equipment, the faster we will lose what has been protected. The science and studies exist proving that maintaining roadless wild spaces is the safest and most effective way to preserve biodiversity which is in collapse right now and far more important to me than climate change. Biodiversity protects our food systems, our natural balance in the food web which without, we will loose the rich diversity of insects, flora and fauna across all of our natural communities. The DOT is a perfect example of what happens to roadways with perpetual mowing and clearing of trees and understory by workers who are untrained in field biology and the native plant systems that exist on the roads. Their mowing equipment super-spreads invasive seeds that spread like wildfire to private lands and farms. It increases flash flooding across the hills and valleys which further spreads invasive species reducing water quality. Rescinding the Roadless Rule would open our parks to incalculable exposure of epic proportions that given how short staffed, underfunded and behind the proposal’s multi-billion-dollar road-maintenance backlog currently is, illustrates how unrealistic proposal is. For example Bee Cove, Sumter National Forest is a good example of how important temperature is to water quality. With canopy loss, particularly on slopes, you will see increases in soil erosion, stream sedimentation resulting in reduced aquatic life. The USFS assessment explicitly attributes the current Class 1 watershed condition rating to the absence of roads and resulting low sedimentation rates; road construction would reverse this condition and degrade the spawning substrate and water clarity that brook trout require for reproduction. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Allowing roads to be built for logging or mining equipment will have numerous devastating impacts: 1- Roads are the primary cause of the introduction of invasive, non-native species that can overwhelm native wildlife. 2- Roads increase sedimentation that seriously pollutes water quality, affecting not only fish, amphibian, and reptile life in the streams but ultimately groundwater that can impact the natural aquifers from which humans draw their drinking water. 3- Road stream crossings create a barrier to fish movement in national forests and restrict spawning and propagation of trout and other aquatic life. 4- Road construction introduces potential landslides and erosion that destroy established forest roots and slope stability resulting in potential floods and stream sedimentation. 5- The introduction of livestock can cause overgrazing which adversely affects species dependent on grasses for feeding or ground nesting, increasing runoff and soil compaction. 6- Roads can interrupt fires necessary for fire-dependent ecosystems while increasing the possibility of uncontrolled wildfires due to campsites or cigarettes thrown from vehicles. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. I urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System.

I strongly oppose the U.S. Department of Agriculture and Forest Service proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. The 2001 Roadless Rule safeguards clean drinking water for millions of people, protects vital old-growth carbon sinks, and maintains critical wildlife habitats and migratory corridors. Opening these 44.7 million acres of inventoried roadless areas to commercial logging and new road construction risks permanent environmental damage, increases human-caused wildfire risks, and adds to an already massive federal maintenance backlog. I personally care about and depend on these public lands. The roadless areas of Sumter national forest are particularly important. I urge the Forest Service to select Alternative 1 (No Action) to keep comprehensive roadless protections fully in place across all national forest inventoried roadless areas. Sincerely, Steven Pruitt Taylors, SC 29687

I strongly oppose the U.S. Department of Agriculture and Forest Service proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. The 2001 Roadless Rule safeguards clean drinking water for millions of people, protects vital old-growth carbon sinks, and maintains critical wildlife habitats and migratory corridors. Opening these 44.7 million acres of inventoried roadless areas to commercial logging and new road construction risks permanent environmental damage, increases human-caused wildfire risks, and adds to an already massive federal maintenance backlog. I personally care about and depend on these public lands. The roadless areas of Sumter national forest are particularly important. I urge the Forest Service to select Alternative 1 (No Action) to keep comprehensive roadless protections fully in place across all national forest inventoried roadless areas. Sincerely, Rachel Pruitt Taylors, SC 29687

Kristin Chapman of SC, I oppose the proposal "Special Areas: Roadless Area Conservation". I oppose rescinding the 2001 Roadless Rule. I occasionally hike in Sumter National Forest, and do not want the forest to be logged. I want the land to stay protected for wildlife, ecosystems, and so I can enjoy nature when hiking without disruption.

I am writing to declare my opposition to any attempt to fully or partially rescind the 2001 Roadless Area Conservation Rule. I reside in Upstate South Carolina, and spend time hiking, kayaking, and camping with my family in the Pisgah, Nantahala, and Sumter National Forests. In addition, my family owns a parcel of land adjacent to the Sumter National Forest in Oconee County, SC. The increasing fragmentation of these wild areas by extraction and road building will continue to erode the value of the land for wildlife habitat and for recreation. We have seen first hand here how logging and road building have left our mountain slopes vulnerable to landslides after Helene and to fires before that. We know that road building contributes to the frequency of fires and to the occurrence of human caused fire in places not previously vulnerable. I am concerned not only for the less quantifiable values above, but for the very real effects on the life of our communities. Many of our Upstate and mountain cities and towns really on the forests for our drinking water. Destruction of the forests, which follows road building as surely as night follows day, will increase runoff and reduce our ability to capture water for vital use. Pollution of our water will increase. Our neighbors in Oconee, who relay on hunting to supplement their food budget will have fewer game animals to hunt. Local businesses rely on tourism and recreation in the forests for their livelihood, and degradation of the quality of the forests will surely hurt them. I ask, as a resident, taxpayer, and constituent that the U.S. Forest Service and the USDA to abandon the proposed rescission under Alternatives 2 and 3 of the draft EIS and maintain full, permanent protections for all inventoried roadless areas.

Date: October 4, 2026 Attn: U.S. Forest Service, Department of Agriculture Re: Public Comment on Proposed Rescission of the Roadless Area Conservation Rule (Docket ID: FS-2025-0001) To Whom It May Concern, Please accept these formal comments regarding the proposed rescission of the Roadless Area Conservation Rule. As a resident of South Carolina with deep family roots and connections throughout the Southern Appalachian area, the ecological health of our regional national forests—including the Sumter National Forest (SC), alongside the Pisgah, Nantahala, Cherokee, and George Washington & Jefferson National Forests where my family resides—is vital to our quality of life and safety. I strongly oppose the wholesale rescission of the 2001 Roadless Rule and urge the agency to maintain current protections for Inventoried Roadless Areas (IRAs). Under the National Environmental Policy Act (NEPA), the Forest Service must address these specific localized data points and internal contradictions in its final decision: 1. Threats to Southern Appalachian Watersheds & Downstream Clean Water High-elevation IRAs act as natural filtration systems, supplying surface drinking water to over 10 million people across the Southeast. * Downstream Impacts on South Carolina: As an SC resident, I know the headwaters protected by upstream Appalachian IRAs feed major river basins flowing directly into my home state. Any upstream degradation compromises water quality and increases treatment costs for downstream communities. * Sedimentation Risks: Introducing logging roads into steep, high-elevation roadless zones will trigger immediate soil erosion and sediment runoff, degrading the headwaters of seven major regional river systems. 2. Disruption to a Global Biodiversity Hotspot The Southern Appalachians feature over 700,000 acres of protected roadless areas that act as essential, unbroken biological strongholds. * Aquatic Ecosystems: Road construction introduces harmful culverts, artificial barriers, and increased water temperatures that decimate genetically distinct native brook trout populations. * Habitat Fragmentation: IRAs provide continuous wildlife corridors for black bears, deer, and dozens of at-risk species that cannot withstand industrial logging corridors. 3. Scientific Contradictions Regarding Wildfire Management The primary justification for removing roadless protections is to increase access for wildfire mitigation. This directly contradicts the Forest Service’s own data: * Agency Findings: The Forest Service’s own 2020 monitoring study tracking 20 years of Roadless Rule implementation explicitly concluded that a lack of roads does not hinder forest health or prevent effective fire management. * Ignition Risks: Road networks are the primary vector for human-caused wildfires. Peer-reviewed data shows that roadless areas experience four times fewer human-caused wildfire ignitions than areas fragmented by roads. Removing protections will actively increase fire risks to nearby communities where my family lives. 4. Severe Economic Backlogs The Forest Service faces a staggering $10.8 billion deferred road maintenance backlog. The agency has not demonstrated how it can logically or safely manage an expanded road network in steep Appalachian terrain when it cannot maintain its existing infrastructure. Proposing an infrastructure expansion during federal funding contractions is fiscally unfeasible and threatens public safety due to neglected roads. Conclusion Because this rescission relies on an arbitrary wildfire rationale that contradicts agency science, ignores an insurmountable $10.8 billion infrastructure backlog, and jeopardizes downstream drinking water shared by South Carolina and neighboring states, the Forest Service must reject the proposal and maintain the 2001 Roadless Rule. Sincerely, Johnson/Brady/Westbrooks/Gerhardt Families Goose Creek SC 29445

I support keeping and fully enforcing the Roadless Area Conservation Rule, particularly because of what these protections mean for Western North Carolina and the Upstate of South Carolina the area I call home. The Pisgah and Nantahala National Forests contain some of the most important remaining undeveloped mountain landscapes in our region. These roadless areas help protect headwater streams, watersheds, wildlife habitat, scenic mountain landscapes, and opportunities for hiking, fishing, hunting, and solitude. They are also an important part of the natural heritage and quality of life that make Western North Carolina and the Upstate special. In the Upstate, roadless areas within the Sumter National Forest provide similar protections for portions of our mountain landscape and watersheds. As our region faces continued and rapid population growth, development pressure, and recovery from increasingly severe storms, protecting remaining intact forest is increasingly important. Once roads fragment these areas, the ecological and recreational qualities that make them valuable can be difficult to restore. I urge the Forest Service to retain the Roadless Area Conservation Rule and enforce its protections consistently. Our mountain forests, watersheds, wildlife, and future generations deserve to have these remaining undeveloped places protected

To the U.S. Forest Service: I am writing to express my strong opposition to the proposed rule to fully or partially rescind the 2001 Roadless Area Conservation Rule. As someone who lives in Anderson, SC and cares deeply about our public lands, unfragmented forests matter to me. I frequently recreate in or rely upon Sumter National Forest, Pisgah National forest and many other roadless areas across the country for clean drinking water, wildlife habitat, and backcountry recreation. Rescinding national protections and shifting management to local levels threatens critical ecosystems, watershed integrity, and climate resilience. Road construction and industrial activities fragment habitats in ways that are deeply harmful to the long-term health of our national forests. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to withdraw the proposed rescission and maintain full, permanent protections for all inventoried roadless areas. Sincerely, Adam Frialde Anderson, SC

Over fifty years ago, I testified at hearings conducted by the US Forest Service (USFS) in support of the Eastern Wilderness Areas Act which was enacted in early January of 1975, specifically in regards to the designation of the Kilmer-Slickrock Wilderness on the Nantahala National Forest in western NC. I was heartened twenty-five years later when the USFS adopted the Roadless Rule because doing so extended protections and multiple use benefits to unique, intact watersheds that might not merit designation as official wilderness. Almost 200,000 acres were designated roadless in NC and SC, including significant tracts like Ellicott Rock in SC’s Sumter NF, Snowbird Creek and Yellowhammer Branch in NC’s Nantahaka NF and Sam Knob and South Mills River in Pisgah NF. I have personal experiences in these and other Inventoried Roadless Areas (IRAs) and I am disturbed that after twenty-five years later, the USFS is now proposing to end the Roadless Rule. I urge you to choose the No Action alternative to keep the existing Roadless Rule in place. Let me elaborate. First of all, it has been established that wildfire risk is lower in IRAs compared to areas with roads and human impact. Last year, we had to evacuate our home at Caesar’s Head, SC, for a week due to the Table Rock Complex fire that came within half a mile. Burning over 15,000 acres and investigated as “human caused” and “exceptionally difficult", the firefighting cost exceeded $11million, making it the costliest in the state’s history - but no homes or lives were lost because the adjacent lands were either state parks and wildlife management areas or conservation easements that limited development and roads. The P&N’s argument that roadless areas need to be opened up to allow timber sales and thinning to reduce wildfires is baseless. IRAs are already open for thinning and fuel reduction activities, including highly effective practices for wildfire mitigation like hand piling and prescribed burning. Furthermore, there isn't a pressing need to do timber sales and thinning in IRAs because wildfire risk is actually lower in IRAs compared to areas with roads and more human activity. Rescinding the Roadless Rule would substantially increase the costs from catastrophic wildfires by converting fire-resilient roadless areas into fire-prone areas with roads. Second, The Roadless Rule also needs to be retained because it is an ecological approach to land management that protects areas that perform ecosystem services like water retention, groundwater recharge, and soil retention. It also serves to protect and conserve wildlife and provide hunting and fishing opportunities that often are more accessible to urban populations than designated wilderness areas. It is well known that more and more Increasing, people want to conserve wildlife, and they want to see wildlife when they visit public lands. In contrast, roads harm wildlife habitat, reduce security and cover, negatively impact reproduction, cause mortality, create barriers to movement, and reduce connectivity. Roads hurt huntable species, non-game species, and threatened and endangered species. And third, since the Roadless Rule was first proposed in 2000, the Forest Service has received over 1.2 million comments with over 95% of the letters in favor of the rule. During the recent 2025 public comment period, the Forest Service received more than 220,000 comment letters with over 99% urging retention of the Roadless Rule. The decision to move to a final EIS intentionally and knowingly disregards the will of the American people and violates the NEPA process. The Roadless Rule has been the will of the people for decades. I respectfully recommend the No Action alternative that keeps the Roadless Rule in place substantially. Thank you for the opportunity to comment.

The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am a resident of South Carolina and associated with the SCDES am very concerned about the proposal to undo the Roadless Rule because I value what this forest offers to our residence for tourism, health and the rich history of the state. Specifically I have been impacted by the Roadless Area in Bee Cove in Sumter National Forest (Southern Forest) With the Region Number 08. This area of 3,025 acres is rich with research opportunities and is personally important to me. Roadless areas provide important benefits to communities across the country, including clean drinking water, wildlife habitat, opportunities for outdoor recreation, and protection from the impacts of development. These lands are also an important part of the character and identity of many communities and provide places for people to hike, hunt, fish, camp, ski and otherwise enjoy the outdoors. I am particularly concerned that rescinding the Roadless Rule could increase development, reduce recreation opportunities, affect wildlife habitat, increase wildfire risk, or harm local economies that depend on outdoor recreation. As an environmental scientist it's within my interest to advocate for the conservation of these lands out of love for them and the benefits they offer to our residents. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service should not weaken those protections or open currently protected roadless lands to new development. I urge the Forest Service to pursue Alternative 1 and retain the existing Roadless Rule protections.

As an avid outdoorsman and lifelong flyfishing and hunting enthusiast, I am deeply concerned about the idea of removing the 2001 Roadless Area Conservation Rule. The 2001 Roadless Area Conservation Rule conserves over 58 million acres of multiple-use public lands managed by the U.S. Forest Service that provide some of the best places to hunt and fish in America. Repealing safeguards afforded by the Roadless Rule will jeopardize intact fish and wildlife habitat and I urge the U.S. Department of Agriculture to uphold strong protections for all roadless areas. Across the country, roadless areas provide amazing habitat for native trout and salmon, big game, and other wildlife. The 2001 Roadless Rule generally prohibits new road construction and industrial logging, while at the same time keeping these public lands open to habitat improvement projects, hazardous fuels reduction, hunting, fishing, OHV riding, firewood cutting, grazing, and camping. Some of my earliest fly fishing trips where I learned to fish, camp, and enjoy the outdoors was in the Big Mountain roadless area in Sumter National Forest on the Chattooga River in South Carolina. These trips with my dad and brother are great memories that are special due to the pristine habit that allows trout to live in the Chattooga River created by having a roadless area. These trips also spurred a lifelong passion for flyfishing and the outdoors that created another special trip last year when for my brother’s 30th birthday, the family got together in Dubois, Wyoming for another fly fishing trip in Shoshone National Forest. In the Telephone Draw roadless area, we had 2 days of great flyfishing and comradery. It was there that my wife caught her first trout on a fly rod, a memory I will cherish forever. Another special memory that occurred in the roadless area of Sam Knob in Pisgah National Forest was when I went backpacking with my childhood best friend before he went to join the military. Spending a few days in that area I know was important to both him and myself before not seeing one another for almost 2 years due to his deployments. If the 2001 Roadless Rule is rescinded, new road construction and associated logging will have a negative impact on water quality and reduce pristine habitat that makes our public lands so great for hunting, fishing, and camping. I want to make sure that my children will have the same opportunities to create memories as special as the ones I have on our public lands. There are currently over 370,000 miles of roads in the National Forestry System with a maintenance backlog of over $5 billion. We should be focusing on maintaining the roads we have to ensure that poor roads do not allow sedimentation and erosion to reduce water and habitat quality before even thinking about adding additional roads. Additionally, the stated reasoning of reducing wildfire risk does not hold merit when looking at the statistics. The USFS has shown that over 70% of human caused wildfires on National Forest land start within 0.5 miles of a road. Therefore, it stands to reason that more roads could result in even more forest fires, not less. Another primary reason the 2001 Roadless Rule was enacted, was the areas identified did not have economically profitable timber for harvest. Should we not look to harvest more timber in areas that already have roads and infrastructure before opening up some of the greatest resources that America has? Roadless areas have provided myself and my family with exceptional opportunities to experience some of the best fish and wildlife habits and hunting and angling opportunities in America. I strongly support maintaining the 2001 Roadless Area Conservation Rule to keep these public lands a great place to enjoy for all future Americans. Sincerely, Andrew Edwards Taylors, SC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The peace I found camping in the wild at Ellicott Rock is not abstract. It is the specific quiet of a Southern Appalachian forest where roads have not yet arrived, and where that quiet still belongs to birds. South Carolina holds 6 inventoried roadless areas totaling 7,598 acres, and two of them, each parcel of the Ellicott Rock area within Sumter National Forest, are part of what this rescission would unravel. Ellicott Rock 1 covers 301 acres. Ellicott Rock 2 covers 517 acres. Both deserve what the 2001 Roadless Area Conservation Rule has provided. I oppose the rescission. South Carolina draws people precisely because of its natural resources, and among those resources the variety of birds is remarkable. The forest holds them: Red-tailed Hawks, Sharp-shinned Hawks, Prothonotary Warblers, Pileated Woodpeckers, residents and migrants alike. The agency's own environmental review does not protect what it cites. The DEIS acknowledges that bird richness declines with road presence in forested habitat, and it cites road-noise experiments showing that bird abundance dropped by over a quarter, with 31 percent of species avoiding the noise entirely. These are the agency's own cited findings. Yet nowhere does the document project what opening these roadless areas to road construction would mean for the species that use them. The connection between cited science and actual decision runs dry. I ask that the agency explain, with specificity, how the bird populations that depend on the roadless areas in South Carolina will be affected under each alternative, and that it place a substantive answer in the record. The fragmentation problem is similarly unresolved. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is wide and consequential. No projection applies it to the 40.1 million acres of inventoried roadless land that would be affected by this rescission. Citing a finding and then declining to apply it is not analysis. I ask that the agency carry that fragmentation range forward and apply it to the 40.1 million acres of potentially affected environment before any final decision is made. The carbon accounting has the same problem. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The document then concludes that these lands will continue to sequester and store carbon, with no examination of what harvest and roading would actually do to that figure under the alternatives being considered. A conclusion reached without calculation is not a conclusion. The agency must quantify the change in carbon storage and sequestration under each alternative. The agency's stated rationale for rescission, that state-specific approaches can serve as adequate substitutes for a national rule, has a history the document does not honestly confront. The record states that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction did not survive judicial review the last time this agency dismantled the national rule in favor of state-by-state management, and the Ninth Circuit identified specific deficiencies in that approach. The agency's prior finding that local decision-making can incrementally erode nationally significant roadless values is part of that record. This proposal does not explain how it avoids those same deficiencies. I ask that the agency provide a direct answer to that question. We must protect our common home. The roadless areas in South Carolina, including the forest around Ellicott Rock where I camped, are part of a watershed system that, across the Southern region alone, supplies 378 municipal water intakes sitting in watersheds containing affected roadless areas. The agency has not demonstrated that state-level management will protect those intakes, those birds, or those forests with anything approaching the reliability the current national rule provides. The rescission should not proceed. Sincerely, Christopher Hall Aiken, South Carolina

I strongly oppose the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule, RIN 0596-AD66. I have grown up on the edge of the National Wild and Scenic Chattooga River and am a lifelong local, outdoor educator, and current graduate student. The threat this proposal presents to the Chattooga River and similar areas is not an abstract environmental issue to me—it is part of my home, my education, my work, and my understanding of what it means to care for a place. I have seen how these forests and waterways shape people’s lives, and I know how much they contribute to the character and well-being of our communities. The Roadless Rule protects some of the last remaining wild forests on our national forest lands by restricting new road construction and commercial timber harvest. Rescinding it would expose these places to roadbuilding, logging, erosion, habitat fragmentation, and development. That threat is especially urgent in the face of climate change. This was one of the hottest summers on record, with high numbers of ticks and other pests in the southeast. Our forests are already experiencing hotter temperatures, drought, worsening wildfire conditions, insect outbreaks, and other stresses. Intact forests store carbon, regulate water, reduce erosion, moderate local temperatures, and provide connected habitat that helps plants and animals adapt. Roads and logging can release stored carbon, dry and fragment forests, spread invasive species, and create additional wildfire ignition risks. It is monumentally foolish and shortsighted to open up these critical areas to logging and other forms of resource extraction. I am particularly concerned about Bee Cove in the Sumter National Forest and the broader Chattooga River watershed. Bee Cove’s forests, steep slopes, headwater streams, trout habitat, rare plants, and wildlife are part of an interconnected watershed that depends on intact forest cover. Roadless areas around the Chattooga help protect cold, clear water and provide undisturbed habitat for threatened and endangered species. USDA argues that rescinding the rule is necessary to reduce wildfire risk and improve forest management. But the current rule already allows carefully tailored actions for wildfire response, public safety, ecological restoration, and certain fuel-reduction treatments. Research also indicates that wildfire ignitions are much more common near roads than in roadless areas. Building more roads could increase fire risk and ecological damage while adding infrastructure the Forest Service already struggles to maintain. As an outdoor educator, I understand that access and responsible stewardship matter. But stewardship does not mean opening every intact landscape to industrial access. It means protecting the conditions that make these places resilient, meaningful, and capable of supporting future generations. I urge USDA to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule in full. As someone who has lived beside the Chattooga, worked to help others understand and care for the outdoors, and is now studying these issues as a graduate student, I am asking the Department to listen to local people who know what is at stake. Please protect Bee Cove, the Chattooga River watershed, and the nation’s remaining roadless forests before these irreplaceable places are damaged in ways that cannot be undone. Thank you for considering my comment, I am a real person who loves her country deeply, and is utterly dismayed at this turn of events. Please take action to prevent this from coming to pass, please read this and hear my voice among thousands of others all calling to protect our lands and waters.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Big Frog is an impressive and imposing wilderness . It is the last area near me where there are no roads, no cars, walking in and out is the only way. So much of my hiking and backpacking crosses forest service roads that are co-opted by ATVs and Jeeps, even the most remote places end up being overrun. A little further away, the Bee Cove and Big Mountain areas. I've gone to the Foothills Trail and Bartram Trall areas in and around the roadless areas in the Sumpter and Nantahala national forests for the last 12 years. One thin that is easily seen as you go through other areas that are not roadless, is how often you see the impact of people on these forests. I've seen the managed forests be logged, and I understand it. However, there needs to be some remaining old growth, more inaccessible wilderness. Losing these places would be a devastating blow. These forests are so unique because we accidentally saved them, and they aren't perfect, they weren't so amazing that they were preserved on principle, but their simple nature is why they are so special. They are a basic kind of place that soon will disappear too. Then what? we preserve the last handful? I tell my grandkids how "all the forests used to look like this one" I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Big Frog Addition (369 acres), Cherokee NF, Tennessee - Bee Cove (3,025 acres), Sumter NF, South Carolina I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The money doesn't add up The proposal justifies rescission in part on timber economics and employment grounds. The record before the agency 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." (66 FR 3244, national social and economic effects discussion (citing FEIS Vol. 1, 3-326 to 3-350)) "By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55)) "Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests)) I ask that the agency 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 that it explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Andrew Scales Chattanooga, TN

Dear Secretary Rollins and Chief Schultz: I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. As an outdoor enthusiast, I believe the administrative record supporting the 2001 Rule—developed over years of rigorous scientific analysis and extensive public engagement—represents a proportionality of process that the current proposed rescission has failed to match. The Department should seriously consider this deficit before proceeding. In particular, I request that the Department maintain protections for the Ellicott Rock roadless area in the Sumter National Forest. This area holds profound historical and geographical significance as the junction where Georgia, North Carolina, and South Carolina meet—a gathering place for people long before state borders were established. Located just two hours from my home in Greenville, South Carolina, it stands as a rare and irreplaceable wild landscape in the southeastern United States. My connection to Ellicott Rock is deeply personal. In 2016, I first visited this area with my 11-year-old son just before he joined BSA Troop 19 of Greenville. It was a magical experience defined by the total absence of motorized vehicles and the absolute presence of nature. Memories of swimming in the cold, clear river, catching and cooking crayfish, and hanging our first bear bag marked the beginning of a decade of outdoor adventures for us. Ellicott Rock is not just another busy, overrun destination crowded with gas-powered vehicles; it is a sanctuary. Rescinding the Roadless Rule would open Ellicott Rock to road construction and severe ground disturbance. A specific comment on this area is vital because the direct and indirect impacts of roads extend far beyond the asphalt or gravel surface itself: Landscape Fragmentation: Roads heavily impact the broader ecosystem. An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads due to edge effects, altered runoff patterns, and downstream disturbance (Forman & Alexander, 1998). Globally, while 80 percent of Earth's terrestrial surface remains roadless, most of that area is severely fragmented into patches smaller than one square kilometer (Ibisch et al., 2016). Persistent Environmental Degradation: Road construction permanently alters the physical environment. It compacts soil to roughly 200 times the density of undisturbed forest soil and alters at least eight major physical characteristics of the landscape. These disturbance patterns persist for decades; even logging skid trails show measurable damage 40 years after their last use (Trombulak & Frissell, 2000). The public deserves the right to experience Ellicott Rock and our nation's remaining roadless areas without the intrusion of motorized noise, soil erosion, and the siltation of pristine creeks and rivers. Because so little of our public land is set aside to preserve these roadless qualities, I urge the Department to withdraw the proposed action and allow the 2001 Roadless Area Conservation Rule to remain fully operative. Respectfully, CommentID: RLC-20260831-SF8CJY

Dear USDA Leadership: As someone who has spent a lot of time on public land in conditions ranging from trailhead crowds to genuine solitude, I can tell you the difference between roaded and roadless access isn't cosmetic. I have spent countless hours finding solitude in the deep forest. I’m a career driven woman in my early 30s and depend on the forest for time to unwind, disconnect and explore. To adventure in the wilderness as a guest is a great honor. This time helps me to perform in the fast paced environment in which I work, be a better member of my community, and connect to the world around me. One visit made that connection concrete. The first time I went backpacking was along the Chattooga river. I’ve made the best friends hiking in the Elliott wilderness area, and fell in love with the south east and found community here. I’ve since bought a home in Greenville and have plugged into the region which has given me so much peace and life! All of this started deep in the woods far from the nearest road. The Rule has served as the legal foundation for the preservation of places like those referenced above; its rescission would represent an unjustified departure from twenty-five years of settled policy. Regarding the Ellicott Rock 1 in the Sumter National Forest, South Carolina: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Road noise reaches deep into protected areas. Anthropogenic noise doubles background sound levels in 63 percent of U.S. protected area units and produces a tenfold increase in 21 percent of them. Elevated noise was found in habitats of endangered species, with 14 percent of critical habitats experiencing a tenfold sound increase. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use (Buxton et al. 2017). — Buxton, R. T., McKenna, M. F., Mennitt, D., Fristrup, K., Crooks, K., Angeloni, L., Wittemyer, G., 2017 · Science (https://doi.org/10.1126/science.aah4783) Rescinding the Roadless Rule would open the Ellicott Rock 1, Sumter 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. People travel from miles and across countries to hike the foothills trail. It’s well renown for its beauty and remote nature. There are species here that are found no where else in the world, and a breathtaking biodiversity. This trail brings people to the region and makes them stay. This helps our local economy. The cost of building roads here also means maintaining them. As a taxpayer I don’t want my hard earned tax dollars allocated to roads I do not want to be built in the first place. The public roads that exist in and around SC need these allocated resources as they are not well maintained today. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. This comment stands against rescission and for the preservation of the 2001 Rule. Most respectfully, CommentID: RLC-20260901-9E42JS

To the USDA Roadless Rule Rulemaking Team: As someone who has planned and completed extended non-motorized journeys into areas protected under the 2001 Rule, I respectfully submit that my interest in the Rule's continuation is well-founded in direct knowledge of what the Rule has preserved — knowledge that the Department should treat as substantive public comment, not merely as preference. I was born in a rural area, in the foothills the Appalachian mountains. My entire life has centered around enjoying the surrounding wilderness. Obviously some roads are good. But we have plenty already. Furthermore when people have too much easy access thats the areas that are mistreated. Trashed, graffitied, and also as I am sure you are aware, there are 4 times as many fires in forests with roads than roadless forests. Please uphold the protections for these wild places so dear to me Among many days in these forests, one has stayed with me. I always choose areas to hike without roads because there is peace there. The animals are relaxed and playful. I also am able to find a deep sense of calm and rejuvenation with doesn't happen with the sounds of motors around The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Ellicott Rock 1 in the Sumter National Forest, South Carolina: Headwater Protection for Native Brook Trout and Endemic Crayfish — The Upper Chattooga River headwaters originating in this 301-acre area represent some of the last refuges for native brook trout in South Carolina, a species highly vulnerable to siltation and temperature increases. The area also protects s… Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Stephen C. Trombulak, Christopher A. Frissell, 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Rescinding the Roadless Rule would open the Ellicott Rock 1, Sumter 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. Once this destruction has been done, it cannot be undone. I urge you to uphold protections. I do not want to live in a world where my quality of life has been so drastically reduced to never experiencing the peace, tranquility, rejuvenation, grounding, wonder, and absolute magic of untouched forest. The Rule should remain in full force; the Department is urged to decline the proposed rescission action. With kind regards, CommentID: RLC-20260901-UZX3J2

I live in Georgia, and travel and recreate often in North Carolina and Virginia. I find the wild areas, Pisgah National Forest, Jefferson National forest, Sumter national forest, and more, to be havens. Having served as a Chaplain in the US army I can say without a doubt that these places are spaces for our military brothers and sisters who need to have some space and move and reconnect with the army way. I cant imagine any gains that would offset the loss. I live oppose rescinding the 2001 Roadless Area Conservation Rule. Please select the No Action alternative and retain the rule. Georgia, North Carolina, and Virginia’s roadless areas protect clean water, wildlife habitat, intact forests, recreation and local economies. The rule already allows necessary work involving wildfire, disease and public safety. Removing these protections could increase road construction, habitat fragmentation, erosion and long-term maintenance costs. Please retain the Roadless Rule.

My name is Amelia Yook. I live near the Francis Marion Sumter National Forest. The forest and the roadless areas within it are everything I live for. I strongly oppose the repeal of the Roadless Rule. Repealing the Roadless Rule will open currently protected areas to road construction and timber harvesting. The amount of roadless areas left in the United States is extremely small. We have already lost too much. Opening roadless areas to timber harvesting will increase global warming, kill endangered species and lower air quality. Those are facts not opinions. No one will ever be able to undo this decision because the old growth trees will be gone. I suggest that you do everything in your power to keep the Roadless Rule in place and to save our world as we know it. The Roadless Rule is vital to the future of the natural world. The natural world is vital to our species as humans. If that does not mean something then nothing does.