Comment Analysis · Docket FS-2025-0001

FS-2025-0001-609634

Opposes rescissionPosted October 7, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Water Quality Quantity
    • “affect watersheds”
    • “increase runoff and sediment pollution affecting drinking-water supplies”
    • “headwaters and watersheds serving local communities”
    • “protect the forests, watersheds”
  • Environmental Protection Biodiversity
    • “fragment forests, alter wildlife habitat”
    • “intact wildlife habitat, biological diversity”
    • “protect the remaining roadless forests”
    • “intact mountain landscapes”
  • Recreation Tourism Public Use
    • “quiet recreation”
    • “scenic landscapes”
    • “places where future generations can experience Southern Appalachian forests with minimal infrastructure”
  • Forest Management Wildfire
    • “responsible forest stewardship”
    • “emergency response, wildfire response”
    • “ecological restoration”

What it names

Works cited
Furniss et al. 1991

The comment

I am a resident of Western North Carolina and am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I do not believe increased roadway development in our remaining roadless National Forest lands is beneficial to Western North Carolina or to the long-term public interest. Roads are not simply lines on a map. Once constructed, they fragment forests, alter wildlife habitat, increase erosion and sedimentation, affect watersheds, require continuing maintenance, and can facilitate additional development and extraction. Hurricane Helene should be an important consideration in evaluating this proposal. Western North Carolina has just experienced a devastating demonstration of what extreme rainfall, flooding and landslides can do to mountain infrastructure. According to the U.S. Geological Survey, Hurricane Helene and the preceding rainfall produced as much as 30.8 inches of rain in 72 hours in western North Carolina and more than 2,200 identified landslides. More than half of the identified landslides damaged structures, disrupted roads, or intersected rivers. The consequences for transportation infrastructure were enormous. The North Carolina Department of Transportation reported that Helene damaged approximately 9,400 sections of state-maintained roads, 846 public bridges, and more than 1,700 pipes and culverts, with estimated road and bridge repairs approaching $5 billion. The Blue Ridge Parkway alone identified at least 57 landslides across nearly 200 miles in North Carolina following the storm. These facts do not demonstrate that every road causes a landslide, nor do they eliminate the legitimate need for roads required for emergency response or essential forest management. They do demonstrate that road construction and maintenance in steep Appalachian terrain carry real and continuing risks and costs. In my view, those risks argue for greater caution about creating additional roads—not for weakening protections against them. This issue is particularly important in Western North Carolina. The Pisgah and Nantahala National Forests contain approximately 152,000 acres protected by the Roadless Rule, representing about 15 percent of these national forests. MountainTrue has documented that roadless lands also contain important headwaters and watersheds serving local communities. In Macon County, for example, portions of the Cartoogechaye Creek watershed that supplies the Town of Franklin occur within an Inventoried Roadless Area. MountainTrue notes that additional roads in such areas could increase runoff and sediment pollution affecting drinking-water supplies. The Forest Service itself documented substantial Helene damage to National Forest streams and watersheds, including erosion, flooding, landslides, sediment deposition and other impacts requiring restoration work. I recognize that the Forest Service must manage National Forest lands for multiple purposes and that circumstances may require emergency access, wildfire response, public safety measures, ecological restoration or other carefully justified activities. Protecting roadless areas does not mean preventing responsible forest stewardship. What I oppose is broadly removing the national protection that has kept these remaining intact landscapes relatively free from permanent road development. Once a road enters a previously roadless forest, the resulting fragmentation and alteration of the landscape cannot simply be undone. Roadless lands provide public benefits that are difficult to replace: clean water, intact wildlife habitat, biological diversity, scenic landscapes, quiet recreation, and places where future generations can experience Southern Appalachian forests with minimal infrastructure. For these reasons, I respectfully request that the Forest Service: Withdraw the proposal to rescind the 2001 Roadless Area Conservation Rule; Maintain existing protections for Inventoried Roadless Areas; Retain restrictions on routine road construction and reconstruction in these areas; and Continue allowing narrowly tailored activities necessary for public safety, emergency response, ecological restoration and responsible forest stewardship. Hurricane Helene has reminded Western North Carolina of the enormous consequences that extreme weather can have on mountain infrastructure. At a time when communities are still rebuilding roads, bridges, watersheds and other essential infrastructure, I believe the prudent course is to protect the remaining roadless forests rather than create additional permanent roadway obligations. Western North Carolina does not need more roads into its remaining wild forests. We need to protect the forests, watersheds, wildlife habitat and intact mountain landscapes that already provide substantial public value without requiring additional infrastructure. Thank you for considering my comments. Greg Dillingham, Marshall, N.C.

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