Dear Secretary Rollins,
I have relied on the protections in the 2001 Roadless Area Conservation Rule for years, enjoying the National Forest interior with the confidence that this land would stay as it is. The proposed rescission would not simply adjust a policy. It would change the basic character of public land that the outdoor recreation community depends on.
I, my parents, grandparents and great grandparents have lived within a mile of this National Forest for over a hundred years, and I have personally run and hiked over a thousand miles on the trails of North Massanutten on both the Western and Eastern ridges of Fort Valley. The place I know from those miles looks the way it does because the Roadless Rule has held, and there is no other regulatory mechanism to hold that line if it is rescinded. Quiet and solitude are part of what makes this forest a place of rest and renewal, and road construction, along with the traffic it brings, would degrade that experience directly, apart from any ecological damage. Rescission would not open the forest to us, we already have the access we need. It would introduce disturbance into a place whose value depends on staying undeveloped.
This is not just personal to me. It reflects real ecological and regulatory concerns that belong in the rulemaking record for the Northern Massanutten Inventoried Roadless Area of the George Washington National Forest, Virginia.
The roadless condition is currently protecting a rare and vulnerable plant community, even as it already faces some pressure. Mudhole Bog, a Special Biological Area here, is recognized by the Virginia Division of Natural Heritage, which has recommended extending its protected boundary specifically to safeguard the groundwater recharge area that feeds the seep. Vehicle traffic and camping already occur at the gate where the Mudhole Gap road meets Forest Road 66, near that recharge area, at the limited scale the current closure allows. Removing the Roadless Rule's restrictions on new construction and reconstruction would let that access expand well beyond its current footprint, increasing pressure on a groundwater system the state has already flagged as needing more protection, not less. Road construction more broadly introduces sediment, alters hydrology and delivers contaminants to adjacent habitats, harms that follow directly from increased recreational road access. This area, along with the nearby Signal Knob Shale Barren, supports rare Central Appalachian plant communities that persist despite pressure from invasive species like Emerald Ash Borer, Hemlock Woolly Adelgid, Tree-of-Heaven, Japanese Stiltgrass and Garlic Mustard, and staying roadless prevents the disturbed corridors that invasive species use to establish and spread.
A programmatic-level analysis cannot resolve these concerns. The DEIS needs to evaluate how increased recreational road access would affect the northern long-eared bat, a federally endangered species known to occur in Virginia forests, at the scale of this roadless area specifically, with enough detail to actually inform the decision. This is a site-specific concern, not a general one: a 2025 study in Landscape Ecology found that road traffic reduced breeding bird densities by an average of 25 percent within roughly 650 meters of a road, with the effect growing larger as traffic increased (https://doi.org/10.1007/s10980-025-02100-5). This is exactly the kind of impact a programmatic review misses.
My family has cared for this land for over a hundred years, using it for quiet recreation without ever needing it developed further, and the rare plant communities that define it are still here because of that restraint. The rulemaking record does not offer an adequate justification for undoing it. The Department should decline to proceed and let this forest remain a place for quiet recreation, not further road construction.
Most respectfully,
John Lawrence