FS-2025-0001-521972

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I am David Thomas and I live in Brevard, NC. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections in full. I hike, fish, and bicycle in the Pisgah National Forest. Roadless areas around Laurel Mountain, which is specifically known as a backcountry mountain biking destination, plus South Mills River, Craggy Mountain, Lost Cove, Harpers Creek, Wilson Creek, and Graveyard Ridge above Graveyard Fields are deserving of continued roadless designation. New road construction is the dominant source of management-related sediment in forested watersheds. Forest Service Southern Research Station studies of national forest roads in the Southeast measured average soil losses of 276 tons per hectare from road sections, with eroded sediment traveling a mean of 30 meters downslope into the forest floor (Grace 2005; Grace and Elliot 2008). Because inventoried roadless areas contain few or no roads today, rescission would introduce precisely the sediment source the agency's own research identifies as the leading driver of stream sedimentation — directly threatening the cold-water trout streams of roadless areas like South Mills River in the Pisgah National Forest. The agency has not shown how it would prevent this sediment delivery if the national prohibition is removed. THe sediment directly impacts the downstream municipal water treatment of Mills River and Asheville North Carolina. Grace, J.M., III and Elliot, W.J. (2008). "Determining Soil Erosion from Roads in the Coastal Plain of Alabama." USDA Forest Service, Southern Research Station. https://www.srs.fs.usda.gov/pubs/ja/ja_grace032.pdf The wildfire rationale does not withstand scrutiny. The proposal frames rescission as necessary for fuel reduction. Wildfires are roughly four times as likely to start near roads. More roads mean more ignitions, not fewer. The 2001 rule already permits fuel treatments and forest-health work; it restricts road construction and commercial timber harvest, not active management. Rescission is not required to reduce fire risk. Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). "Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads." Fire Ecology, 22(1), Article 8. https://doi.org/10.1186/s42408-026-00450-2 I survived Hurricane Helene and saw the damage done to the Pisgah National Forest. The areas without roads are clearly visible to less damage as the forest has withstood centuries of storms. Increasing the roads is not an effective use of tax funds since tax dollars will have to repair the additional damage of continued erosion of increased traffic on roads. Building roads into steep, remote terrain creates enormous future liabilities for taxpayers. After Hurricane Helene, rebuilding just five miles of I-40 through the Pigeon River Gorge — mountain terrain comparable to Pisgah's roadless areas — is projected to cost $2.8 billion, nearly triple the initial estimate, with completion not expected until 2029 (NCDOT, 2026). Statewide, Helene damaged some 9,500 transportation sites across 5,000 miles of roads, with total repair costs estimated at $10 billion (NC State Auditor's dashboard, 2026). The Forest Service already faces a road maintenance backlog of nearly $6 billion. Authorizing new road construction in inventoried roadless areas would add miles of high-risk, high-maintenance road in steep terrain the agency cannot afford to maintain — let alone rebuild after the next extreme storm. The agency's cost-benefit analysis should account for these lifecycle and storm-repair costs, not just the timber revenue new roads might enable. The roadless areas protect resources no regulation can restore once lost. The protection of the municipal drinking water supplies of Mills River and Asheville is critical to the protection of drinking sources. The intact wildlife habitat and migration corridors, and the backcountry recreation experiences — including mountain biking, hunting, and fishing — that sustain rural economies. The agency's own analysis acknowledges potential losses to roadless character, recreation, habitat, and water quality if the overlay is removed. Those losses are effectively permanent. The 2001 rule was adopted after one of the largest public participation processes in the agency's history. Discarding it now, over the objections of the overwhelming majority of commenters, would undermine public trust in forest planning for a generation.