RE: Strong Opposition to Rescinding 36 CFR Part 294 (Subpart B)
I am writing as a Western North Carolina (WNC) resident, hiker, mountain biker, backpacker, angler, hunter, parent, and supporter of youth outdoor programs to express my strong opposition to the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (RACR).
Our family, friends, local scouting groups, and outdoor enthusiasts rely on the remote headwaters, ridges, and valleys of the Nantahala and Pisgah National Forests for backcountry adventure and solitude. Safeguarding remaining wild tracts—such as Craggy Mountain, Snowbird, Harper Creek, and Panthertown Valley—is essential for our personal recreation, local water security, and ecological resilience.
I urge the Department of Agriculture to withdraw this proposed rule based on the following key arguments:
1. Severe Economic Risks to Outdoor Recreation
-Projected Economic Loss: In the draft economic analysis for FR Doc # 2026-16965, the Forest Service estimates an immediate $6.1 million annual loss in recreation-related economic value across affected areas if nationwide roadless protections are lifted.
-Regional Impact: North Carolina outdoor recreation generates over $11.8 billion in economic output and supports 100,000+ jobs (U.S. BEA). In WNC counties, tourism driven by intact backcountry trails, mountain biking, hunting, and fishing is a vital economic driver. Opening Inventoried Roadless Areas (IRAs) to commercial logging infrastructure and roads threatens the authentic backcountry experience that draws millions of visitors and sportsmen.
2. Threats to Municipal Watersheds, Fisheries & Wildlife
-Water Quality: Roadless areas safeguard high-elevation headwaters feeding municipal drinking water supplies. WNC features steep terrain and high precipitation; unpaved timber roads on these slopes accelerate soil erosion, siltation, and landslide risks during extreme storms, threatening water treatment infrastructure.
-Native Fisheries: Headwater streams in roadless tracts harbor wild and native brook trout. Fine sediment from unpaved logging roads and stream crossings degrades spawning gravels and ruins cold-water aquatic habitats.
-Hunting Habitats: Big and small-game hunting depend on undisturbed, contiguous forest blocks. Fragmenting remote habitats with industrial access roads increases human disturbance, reduces core wildlife ranges, and degrades backcountry hunting opportunities.
3. Biodiversity, Carbon Sinks & Ecosystem Integrity
-Biodiversity Hotspots: The Southern Appalachians are globally recognized for endemic plant species and sensitive native populations, including Southern Appalachian salamanders that cannot survive microclimate changes caused by forest fragmentation.
-Canopy Fragmentation: Linear road corridors create edge effects that dry out forest floors, disrupt wildlife migration, and serve as vectors for invasive plant and insect species.
-Carbon Sequestration: Mature unroaded forests act as vital, stable carbon sinks. Commercial logging and road building disturb deep forest soils and biomass, releasing stored carbon.
4. Impact on Youth Education & Backcountry Heritage
-Wilderness Classrooms: Roadless areas provide invaluable classrooms for local youth programs, scouting adventures, and wilderness backpacking trips. Experiencing solitude and learning Leave No Trace principles in unroaded backcountry teaches young people vital lessons in self-reliance and conservation.
-Preserving Traditions: Hunting, fishing, backpacking, and non-motorized trail recreation connect us to an outdoor heritage rapidly disappearing elsewhere. Introducing industrial logging access diminishes the quality of these primitive experiences.
5. Road Maintenance Backlog & Wildfire Considerations
-Deferred Maintenance: The U.S. Forest Service faces a nationwide deferred road maintenance backlog exceeding $3.2 billion. Stripping federal roadless protections to allow additional unpaved timber access roads in rugged, high-elevation terrain will worsen this burden, leading to neglected trails and failing culverts.
-Wildfire Ignition Risks: While proponents argue logging roads aid fire management, ecological research demonstrates that human-caused wildfire ignitions increase significantly in remote areas once opened to vehicle access and industrial human activity.
Conclusion
The 2001 Roadless Area Conservation Rule has provided a balanced national baseline for protecting pristine national forest lands for over two decades. Rescinding this protection exposes our mountain landscapes, recreation economy, native fisheries, hunting grounds, municipal watersheds, and youth outdoor programs to unnecessary risk.
For my family, our community, local scouts, anglers, hunters, outdoor enthusiasts, and future generations who cherish these public lands, I strongly request that the U.S. Forest Service withdraw FR Doc # 2026-16965 and maintain the 2001 Roadless Area Conservation Rule in full.