FS-2025-0001-604501

Subject: Oppose Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and Department of Agriculture: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Raised in the Southern Appalachians, I developed a lifelong connection to the region’s public lands. I have regularly hiked, camped, and explored wild and roadless areas in the region, including the areas around Craggy Gardens and the Black Mountains and South Mills River. I now share exploring these landscapes with my own children. I am deeply concerned by the proposal to dismantle the core protection of the 2001 Roadless Area Conservation Rule. The agency’s proposal risks harming our wild places, to the detriment of communities, ecosystems, biodiversity, and climate resilience, and without credible evidence to back the justifications in the proposals. To the extent the Forest Service suggests that mitigating wildfire risk justifies the proposal, more roadbuilding also threatens to increase fire risk, and managers can already conduct measures to protect communities near neighborhoods without rescinding the rule. In addition, the idea of expanding the road network is problematic. The Forest Service cannot maintain its existing network of roads, resulting in a massive maintenance backlog. These deteriorating roads create environmental hazards, destabilizing slopes and acting as conduits for sediment into streams, which in turn impacts downstream water quality, stream habitat and river recreation. With a changing climate and the predicted increase in intense storm events over the coming decades, these unmaintained roads are already a problem. Building more roads in backcountry or roadless areas will exacerbate these problems. Roadless areas also contain unfragmented blocks of forest, which are home to large linkages of old growth forests, support rare ecosystems, and serve as carbon storage. Unfragmented forests on the Southern Appalachian landscape act as a biological reservoir in the region, providing refuge to animals and plants, including those that are threatened and endangered and face a series of other stressors. Eliminating protections for these areas and allowing roads and increasing management activities that disturb the landscape and forests would denigrate the quality of wild unfragmented mature forests, including those with old growth characteristics. More now than ever, in the face of a changing climate, these roadless areas play a key role combatting the effects of climate change, both in terms of mitigation through supporting carbon storage in mature forest ecosystems and by providing needed resiliency as a part of climate adaptation. This should compel the agency to steer management towards protecting roadless areas, enhancing protections for mature ecosystems and biodiverse-rich areas, and scaling down the existing system of roads in line with maintenance realities. Like thousands of other comments the agency has already received, I strongly oppose this rollback and request that the agency leave these wild and roadless areas protected. Therefore, I urge the agency to select the alternative that leaves this critical protection in place (no action).