Dear Chief Schultz:
I am writing to oppose rescinding the 2001 roadless rule. I’m an avid hunter and outdoorsman. The public land where I hunt and get meat to feed myself, where I enjoy spending my time is better off without more roads.
Many times I have hiked around and swam in Sarah’s Creek in the Chattahoochee National Forest. Wildlife is abundant, the water is clean. Places like this need to be preserved and cared for, for us and future generations.
If the roadless rule is rescinded, then areas like Sarah’s Creek will lose their wild character. There are relatively few places like this remaining, especially in Georgia.
Regarding the Sarah's Creek in the Chattahoochee National Forest, Georgia:
Road construction generates more sediment per unit area than any other land use on national forest lands. The Sarah's Creek IRA, Chattahoochee National Forest, has none of this sediment loading because it has no roads. Rescission of the Roadless Rule removes the regulatory barrier that prevents the introduction of the single most damaging non-point source pollutant into this watershed.
Road construction on slopes in the Sarah's Creek IRA, Chattahoochee National Forest, intercepts subsurface flow through cut slopes, converting distributed hillslope drainage into concentrated surface runoff. This interception reduces downslope baseflow — the sustained groundwater contribution that maintains stream volume during dry periods — while simultaneously increasing peak flows during storms. The result is a flashier, less stable hydrological regime.
The DEIS must provide watershed-level analysis specific to the Sarah's Creek IRA, Chattahoochee National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity.
"Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C."
— Restoration Ecology (PMC/Wiley), 2022
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.
“Literature synthesis shows roaded landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity. — DellaSala, 2011 (https://doi.org/10.2489/jswc.66.3.78A)”
Please let the Rule stand on its record.
Best regards,
CommentID: RLC-20260921-MUS2BE