Dear Forest Service Leadership:
As an outdoor enthusiast, I know the value of what this rule protects — and it's not replaceable.
I live here in the mountains only 10 miles from Big Butt, Hicky Fork and Mill Creek. I hike these areas several times every year.
In 1972 three friends and I hiked up Big Butt, camped and gloried in the sunset. I moved here to continue that experience.
My community depends on that unroaded watershed for drinking water, trout fishing, and clean air.
Regarding the Bald Mountain in the Pisgah National Forest, North Carolina:
The Bald Mountain IRA, Pisgah National Forest, supplies water to downstream users who depend on its current quality. National forests provide drinking water to over 60 million Americans. The headwaters in this roadless area contribute to that supply precisely because road-generated sediment, the dominant non-point source pollution in national forests, is absent.
The Bald Mountain IRA, Pisgah National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently.
The DEIS must evaluate the cumulative effects of road construction in the Bald Mountain IRA, Pisgah National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation.
"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
The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests.
As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires.
This comment constitutes a formal objection to rescission of the Roadless Area Conservation Rule and a request for its retention.
In earnest,
CommentID: RLC-20261006-3PKHM7