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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking nearly 900 miles of the Appalachian Trail, and camping across the Chattahoochee, Pisgah, and Nantahala National Forests, has made plain to me what this proposal would put at risk. I strongly oppose revisions to the roadless rule that would open up more of these forests to motorized traffic. That expansion is not necessary for recreational or timber extraction reasons, and I am filing this comment to place that opposition in the federal record alongside the specific analytical failures the agency has not resolved. The Chattahoochee holds 23 inventoried roadless areas totaling 63,351 acres, including the wildest land in the southeastern United States at the southern end of the Appalachian chain, where black bears still roam and brook trout hold in the coldest headwater streams. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres and the Pisgah 18 areas totaling 99,369 acres, protecting the last wild headwaters of rivers that flow to both the Atlantic and the Gulf, along with salamander species found nowhere else on Earth. These are the forests through which I have moved on foot. Verified species across these landscapes include hellbender, cerulean warbler, the northern long-eared bat, more than 30 endemic salamander species, and brook trout, none of which will benefit from the road access this proposal enables. The rule I am asking the agency to retain has protected them, and it has protected the experience of encountering them without the intrusion of motorized traffic. The first problem in the supporting analysis is foundational. "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." That certification is reached by spreading the expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The analysis then concedes that some of those firms may lose those receipts. A certification built on a national average, not on the businesses actually operating in places like the Chattahoochee, Nantahala, and Pisgah roadless areas, does not satisfy what the Regulatory Flexibility Act requires. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Second, the agency invited comment on reliance and then performed no assessment of what it received. "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." This comment is exactly such an interest. The Appalachian Trail passes through forests protected by the 2001 rule, and the nearly 900 miles I have walked along it represent a direct, concrete reliance on the character that rule has maintained. An agency changing course is obligated to identify and assess the reliance interests its prior policy created before it acts. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Third, the agency's own fire data argues against the proposal rather than for it. "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 effects analysis then concedes that road access could increase the number and frequency of wildfires. That is a nearly eightfold difference in ignition density between roaded and roadless land, and the agency has not translated it into a projected increase tied to this specific proposal. How can the agency claim a net wildfire benefit while declining to quantify the expected increase in human-caused ignitions that its own data show follow from road construction? The forests I have walked through, the brook trout streams and salamander hollows of the Southern Appalachians, deserve better analysis than this proposal provides. I urge the agency to retain the 2001 Roadless Area Conservation Rule without rescission. Sincerely, Ren and Helen Davis Brookhaven, GA 30319 [Your City, State]

Protect the national forests and wildlife refuges. Ther is NO VALID reason to end the "roadless rule." The parks were not set up to benefit commercial or investment speculator interests nor for sports games. We much KEEP the roadless rule in place. Sincerely, D. M. Smith, Athens, GA 30606

The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am deeply concerned about the proposal to rescind the Roadless Rule. 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. 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. Sincerely, Shelby Watson 2350 Bernard Rd NW Atlanta, GA 30318-1169 swatson4016@gmail.com

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. Growing up in East Tennessee our family enjoyed back packing & car camping which most of our vacations centered around. As a child we played in the creeks, hiked to many waterfalls creating a deep love for our roadless areas. Snowbird Creek was one of our favorite areas and we still return there as it has so many sweet memories of precious time with my Father. As an adult we live in the North Ga Mountains and we continue to hike & camp and are grateful the roadless areas are right out our back door. Please preserve these areas for our children & grandchildren so that they too can experience the joy of the beautiful nature we are so blessed to have. Protecting these unfragmented landscapes is deeply personal to me because we depend on these watersheds for clean drinking water, we treasure hiking the backcountry trails and value the pristine wildlife habitats. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment and for standing up for our forests, and for your passion to protect our public lands. Sincerely, Laura Anderson Hiawassee, GA 30546

Dear Director, I am writing to formally voice my strong opposition to the proposed nationwide repeal of the 2001 Roadless Conservation Rule. As a resident of Georgia, I am deeply concerned about the future of the 56,000 acres of roadless forest within the Chattahoochee National Forest that stand to lose protection under this proposal. I currently hike portions of the Appalachian Trail on a weekly basis and these areas are in need of serious protection. I also host tourist on my farm so they may explore the roadless areas that are important to other hikers and nature lovers. These areas are vital to my business. Inventoried Roadless Areas around iconic landmarks like Blood Mountain, Tray Mountain, and the Cohutta Wilderness are vital to our state. They provide irreplaceable habitats for wildlife, safeguard the headwaters of our municipal drinking water, and support a thriving outdoor recreation economy that benefits local rural communities. While I support proactive fire management, the original 2001 rule already contains clear exceptions allowing the Forest Service to thin fuels and fight active fires. A blanket repeal is an unnecessary step that exposes our last remaining pristine wild spaces to commercial logging and permanent road development. I urge the Forest Service to maintain the nationwide 2001 Roadless Rule protections to ensure these lands remain intact for future generations. Sincerely, Dr. Gilda Lyon, EdD Morganton, GA 30560

Dear U.S. Forest Service Chief Tom Schultz, I’m writing to urge you to choose Alternative 1 and keep the 2001 Roadless Rule intact. For 25 years, the rule has safeguarded nearly 45 million acres of backcountry across U.S. national forests. These roadless areas provide numerous benefits to the American public, from clean air and water to vital wildlife habitat and diverse recreation opportunities — all while still allowing responsible forest management. Rescinding or altering this rule puts these lands at risk by opening the door to logging, oil-and-gas drilling, and other development. It will also fragment habitat, introduce invasive species, increase wildfire risk, and bring noise and light pollution. At a minimum, I insist that you extend this comment period to at least 90 days and hold hearings across the U.S. in all areas affected, so the public can fully weigh in. This proposal does not have my support. I urge you to choose no-action and uphold the Roadless Rule. Our government thrives when there is order and procedure, please ensure that you follow these orders and procedures and hold yourselves to the highest standard of public service. Sincerely, Erin Taylor 78 Buckfield Ln Folkston, GA 31537-9193 lunaleigh@gmail.com

Subject: Public Comment in Opposition to the Proposed Nationwide Repeal of the 2001 Roadless Rule (Docket ID: FS-2025-0001) Dear Director, I am writing to voice my strong opposition to the proposed nationwide repeal of the 2001 Roadless Conservation Rule. As a resident of Georgia, I am deeply concerned about the future of the 56,000 acres of roadless forest within the Chattahoochee National Forest that stand to lose protection under this proposal. Inventoried Roadless Areas around iconic landmarks like Blood Mountain, Tray Mountain, and the Cohutta Wilderness are vital to our state. They provide irreplaceable habitats for wildlife, safeguard the headwaters of our municipal drinking water, and support a thriving outdoor recreation economy that benefits local rural communities. I urge the Forest Service to maintain the nationwide 2001 Roadless Rule protections to ensure these lands remain intact for future generations. Sincerely, Theodore Doll Sautee Nacoochee, GA 30571

Please oppose the repeal of the Roadless Area Conservation Rule. Here in Georgia alone there are 23 areas within the Chattahoochee National Forest that would be impacted by this. Those 23 areas in GA are part of 58.5 MILLION ACRES national forests. Twenty-three GA areas and 58.5 million acres nationally That 99% of people want to protect. Twenty-three GA areas and 58.5 million acres nationally that are critical habitat for species at risk. Twenty-three GA areas and 58.5 million acres nationally protect our drinking water and keep us safe. Twenty-three GA areas and 58.5 million acres nationally that we don’t have to pay to upkeep roads on. We already have 370,000 miles of roads with a multi-billion-dollar maintenance backlog. Studies show that wildfires are 4x as likely to ignite in areas with roads than in roadless areas. Just this month the US national debt hit $40 billion. Adding more roads will just add to that debt. Taxpayers will have to support and maintain those roads. Taxpayers will have to pay to put out the wildfires. Oppose the repeal of the Roadless Area. Oppose these additional expenses. Instead, let’s keep these natural areas to help support our economy. Outdoor recreation generates $730 billion annually. I am one of those people who spends a good part of my expendable income on outdoor recreation. I hike, I kayak, I bird-watch, I volunteer to conduct bird research I naturalize I camp. I have done ALL of those things in Chattahoochee National Forest and other forests across the country. I currently have a son enlisted in the Navy. Someone who chose to defend and serve our country. The greatest week of my life was last year when I was able to drive part-way across the country with my son as he moved from one duty station to another. The entire way we camped and hiked and visited natural lands. Places we went to intentionally because they were natural and didn’t have roads. Protect our memories. Protect our drinking water. Protect our lands. Oppose this change. Tracey Muise 368 Eady Creek Road Barnesville, GA 30204

As a citizen of Georgia and a professional wildlife biologist, I oppose rescinding the 2001 Roadless Area Conservation Rule. Truly wild areas are vanishing, and the US National Forests are some of the only areas remaining in the developed world that still have significant acres of wilderness. These areas are vital to preserve wilderness ecosystems and the plants and animals that depend on these large tracts of land for survival. Increased road construction in these protected areas creates edge effects that fragment forests, increase the presence of nest parasites like brown-headed cowbirds, increase invasive and exotic species in the landscape, and impact native species that require large areas of undisturbed habitat. Additionally, as a hiker and hunter in Georgia, these areas provide quiet and remote areas away from the noise associated with human development. Roads in these areas would reduce the aesthetics and quality of outdoor recreational activities enjoyed by many residents of Georgia. We hike, hunt, and recreate in these areas to get away from urban life, and we do not want to see roads built into these areas that will increase ecosystem disturbance or that would affect the character of these areas. Georgia’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 to protect these vital wilderness ecosystems. Gregory W. Lee 3665 Forest Grove Road Valdosta, GA 31606

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am a U.S. citizen and conservationist who is in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Boggs Creek (2,073 acres), Chattahoochee NF, Georgia (Appalachia Mountains) (I live here in Georgia and hike in the forests with my dog and appreciate its function as a wildlife corridor) - Bearwallow and other forests in Pisgah National Forests in NC (Appalachia Mountains) (I visit the Western North Carolina forests like Pisgah every summer to cool off from the Atlanta heat and love going on hikes with my family and appreciate the black bear habitat and wildlife corridors provided). - Chugach National Forest (5,439,110 acres), Chugach National Forest, Alaska (I loved getting to go to Alaska for conservation research in 2024 and hiking in the Chugach National forest. It’s gorgeous there. I didn’t get to see any grizzlies or moose there but I know they live there, and I love that). - Tongass National Forest near Glacier Bay NP and Juneau and Hoonah, Alaska (in visiting the Alaska Bay area for conservation research in 2024, I loved hiking around Hoonah on a Native Alaskan led wildlife tour and enjoying the forests around Juneau and Glacier Bay for photography and hiking – I saw my first ever wild coastal brown bear there! photo attached...we have enough roads to be able to see wildlife sometimes, but they need spaces away from vehicles too) - Bridger Teton and Custer-Gallatin in Montana near the National Parks (in visiting these park regions several times over the years, including in 2023 for conservation research, I learned from my interviewees just how important these forests are as wildlife corridors outside of the national parks like Yellowstone and Grand Teton to help eventually connect grizzlies from the greater yellowstone ecosystems up through the Glacier National Park/Blackfeet area and Canadian Rockies bear populations. These bears require large intact ecosystems to survive and thrive for longevity. And the wild bison need places to roam outside of the parks where they are less likely to get shot or run over. ) 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: We already have enough public lands roads to wrap around the earth many times, and we have so much backlog of expensive road maintenance projects in our national forests already. How is this prudent financially or in terms of labor power and resources to maintain even more roads? Are you planning on expanding the federal government and its budget (adding to the trillions of dollars in U.S. national debt) to pay for and maintain more roads in national forests? In interviewing many conservation experts for my In Tune to Nature radio show, I have helped educate a lot of Americans about road ecology and corridor ecology, and I have seen the evidence that roads are some of the most destructive things we can build in terms of harming wild animals (and wild animals are not thriving - -most are declining) – from roads fragmenting habitats and isolating populations for mating and feeding, to getting hit by vehicles and causing accidents, to noise pollution that interrupts feeding and breeding, to other types of soil, water, and air pollution that harms wildlife and habitats, and to introducing more humans into areas where wild animals had more of a haven/refuge from interference and surveillance and attacks. From a utilitarian/cost benefit analysis, how are these roads beneficial to wildlife in comparison to how they are harmful and life-threatening? Wild animals are the major stakeholders in reality. Most major wildfires are started in human areas, where there are roads, so building more roads is likely to increase wildlife risks not reduce them. A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. An agency reversing its own factual finding owes a reasoned explanation for the change. I ask that the agency identify the evidence for the reversal and respond to its own prior finding. 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, Carrie P. Freeman, PhD Atlanta, GA 30316