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.