I live in the mountains of western North Carolina, near the Pisgah National Forest, where these forests are part of my everyday life. I urge USDA to retain the 2001 Roadless Area Conservation Rule.
I understand USDA’s stated reasons for seeking greater local management flexibility, including wildfire, forest health, and vegetation management. I also understand that rescission would not itself authorize a particular road or timber project. My concern is that removing the Rule eliminates an important safeguard without adequately accounting for the long-term fiscal, economic, recreational, and ecological value of keeping these lands roadless.
According to the Forest Service’s own North Carolina Inventoried Roadless Areas map, approximately 173,000 acres of National Forest System land in North Carolina are Inventoried Roadless Areas. Approximately 142,000 acres are in a category where the underlying forest-plan designation allows road construction or reconstruction, making the Roadless Rule a meaningful additional protection.
Before removing that protection, I ask USDA to address the following:
Who will pay for additional roads over their entire lifetimes?
The proposed rule itself acknowledges a $6.9 billion deferred-maintenance backlog for National Forest System roads and bridges. The Forest Service’s 2012 Pisgah National Forest Transportation Analysis estimated that operating and maintaining its suggested road system to standard would require approximately $3.4 million annually. Although that figure is historical, it documents the longstanding difficulty and expense of maintaining mountain roads.
Before facilitating additional roads, USDA should calculate their full lifecycle costs: construction, drainage, inspection, maintenance, storm repair, reconstruction, bridges and culverts, and eventual decommissioning. Those costs should be weighed against the economic benefits USDA expects from additional timber harvesting or other activities.
What will additional roads cost our watersheds?
Forest Service research in the Southern Appalachians has identified forest roads as potentially important sources of erosion and sediment, with consequences for stream water quality. This is especially important in western North Carolina’s steep, wet terrain. USDA should analyze the cumulative effects of reasonably foreseeable additional roads on erosion, sedimentation, headwater streams, aquatic habitat, and downstream water quality.
What is the economic value of remaining roadless?
Western North Carolina’s forests already produce economic value. People travel here to hike, camp, fish, hunt, paddle, watch wildlife, and experience scenery, solitude, and relatively undeveloped landscapes. Their spending supports lodging, restaurants, retailers, guides, outfitters, and other small businesses in our mountain communities.
USDA’s own proposed rule acknowledges that additional roads could reduce opportunities for “quiet, remote and self-reliant recreation” and result in lost economic benefits. Those losses should be evaluated specifically for western North Carolina and the Southern Appalachians, not merely as national averages.
There is also an important asymmetry in this decision. Leaving a place roadless today preserves the option for future generations to reconsider its management. Building a road changes the landscape and creates continuing consequences and maintenance obligations.
Finally, I ask USDA to explain why complete nationwide rescission is necessary. If particular areas require intervention for wildfire protection, public safety, or forest health, could carefully tailored exceptions address those needs without eliminating the general protection?
Before adopting a final rule, USDA should disclose for North Carolina the acreage that would actually lose protections; reasonably foreseeable additional road mileage; lifecycle costs and who pays them; effects on water, wildlife, recreation, and scenic character; economic effects on recreation and tourism; and how those public costs compare with the economic benefits anticipated from rescission.
A standing forest has economic value. Clean water has economic value. Roadless watersheds, wildlife habitat, recreation, tourism, and avoiding unnecessary infrastructure liabilities all have economic value.
I am not asking the Forest Service to abandon responsible forest management. I am asking USDA to recognize that keeping some places roadless is itself a legitimate and valuable management choice.
For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule.
Sources: USDA Forest Service, Proposed Rule, 91 Fed. Reg. 53,827 (Aug. 20, 2026), Docket FS-2025-0001; USDA Forest Service, North Carolina Inventoried Roadless Areas map; USDA Forest Service, Pisgah National Forest Transportation Analysis Process Report (2012)USDA Forest Service Southern Research Station research on forest roads, erosion, sediment, and water quality in the Southern Appalachians.