FS-2025-0001-607902

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Growing up in Greenville, SC, Pisgah National Forest was one of the closest and most beautiful places my family could go to hike and camp. We spent so much time wandering through the forests, having picnics, and swimming in the creeks there that it developed my love of western North Carolina and truly all national forests and parks in the Carolinas. As an adult I have hiked southern portions of the Appalachian Trail, tubed down Deep Creek, and gone white water rafting in the Nantahala National Forest. These are not abstract landscapes to me, and I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001. The roadless areas of the Nantahala and Pisgah are among the most biodiverse temperate forests in North America, protecting the last wild headwaters of rivers flowing to both the Atlantic and the Gulf. Verified species in these forests include black bear, brook trout, cerulean warbler, hellbender, northern long-eared bat, and more than 30 endemic salamander species. I have watched wildlife run out of places to live safely as development expands outside these boundaries. Deer are constantly hit and killed on roads. Bear encounters in western North Carolina are becoming more and more common. The agency's own record acknowledges what road-building does to bears with increased contact and conflict ultimately ending in bear mortality and habituation. I ask that the agency address on the record how rescission would affect bear and deer populations in the Nantahala and Pisgah, where road-driven conflict and habitat fragmentation are already documented pressures. Bird habitats are disappearing alongside everything else, and the agency's own science explains why roads are the mechanism. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The forests I grew up loving support the cerulean warbler and a full community of species that depend on unroaded interiors. The agency must explain what it makes of its own cited research before moving forward. South Mills River, 8,588 acres in Pisgah, holds the kind of interconnected creek systems where brook trout persist. Building roads and harvesting timber there would damage water clarity and native trout habitat in ways that cannot be undone on any human timescale. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The Deep Creek section of the Nantahala is enjoyed yearly by locals and visitors alike, and its pristine waters support both wildlife and local businesses. The agency should respond to these water supply risks with specificity, not generality. The Linville Gorge Addition, 2,809 acres in Pisgah, presents a concern that goes beyond the ordinary. Western North Carolina is still recovering from Hurricane Helene. Removing the logging and road construction ban on the steep, rugged slopes around the Gorge could significantly heighten the severity and frequency of landslides in the region, with long-term consequences for the Gorge itself, its panoramic views, and its recreational areas. The Wesser Bald roadless area, though smaller in acreage, houses the Appalachian Trail. That corridor should not be desecrated. I expect the agency to address the landslide and slope-stability risks specific to these areas under current post-storm conditions. The proposal justifies rescission partly on wildfire management grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" but the Cost Benefit Analysis weighs none. My connection to these forests, built across a lifetime and expressed in the choices I continue to make about where to hike, tube, raft, and simply be, is exactly the kind of reliance interest an agency reversing a two-decade-old rule is required to assess. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Naomi Morgan Columbia, SC Hopeful Western NC Retiree