Read the comments.

Under "Effects of Alternative 2 - Proposed Action," the subsection "Municipal Water Use" at p. 131 reads in its entirety, as to the finding: "If additional road construction or timber harvest result in a decrease in water quality, and or reduce the efficacy of water treatment." That is a conditional clause with no main clause. It names a possible cause and stops before stating any consequence. Every sentence that follows it reports exposure - how many people draw water from these watersheds - not effect. Alternative 1 receives one sentence, at p. 130: "Alternative 1, in general, has little risk of potential adverse effects and provides the greatest protection of water quality." Alternative 3's discussion at p. 132 cross-references Alternative 2 and repeats the exposure count in Table 36. The result is that the DEIS discloses who is exposed and never discloses what happens to them. The DEIS supplies the mechanism itself, one page earlier, and does not carry it forward. At p. 130 it states: "Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation." Rescinding the prohibition permits road construction and timber harvest in the very watersheds the DEIS has already identified as containing municipal intakes. Increased sediment and turbidity in a surface-water source raise treatment cost and can exceed treatment capacity during storm and post-disturbance runoff, forcing intake shutdowns and reliance on alternate supply. That is the sentence the DEIS began at p. 131 and did not finish, and it is the finding the FEIS must make. The scale of what is undisclosed is the DEIS's own. At pp. 129-130 it reports that "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas" and that "Approximately 24 million people utilize water which originates within potentially affected inventoried roadless areas," with Table 35 breaking that out by region. For the Proposed Action the DEIS states that "The Intermountain Region is also affected in that over 1 million people receive water directly from watersheds containing inventoried roadless areas" (p. 131) - and then states no effect on them. The record contains a named, quantified system inside that figure. The Salt Lake City Department of Public Utilities told the agency (DEIS Vol. III, pp. 246-247) that "Our community opposes any federal action that could put our regional water quality at risk for 400,000 users throughout the Salt Lake City metropolitan area," that "The Wasatch Mountains east of Salt Lake City provide 60% of our daily water supply," and that "Protecting our water quality and our public health is the foremost responsibility of our work at SLCDPU." Table 35 puts the entire Intermountain Region, which covers Utah, at 1,118,900 people served by intakes; the single system documented in the agency's own record is 400,000 of them, roughly a third of the region's whole intake-served population. "Salt Lake" appears once in Volume I of the DEIS, in a list of references cited under Recreation. "Wasatch" does not appear in Volume I at all. The obligation to make this finding is stated by the agency, in this document. At p. 127 the DEIS says: "The Forest Service is required to manage National Forest watersheds that supply municipal water under multiple use prescriptions in land management plans (36 CFR part 219)." A rescission that removes the rule-level prohibition on road construction across watersheds holding more than 7,000 municipal intakes cannot be evaluated against that requirement on a record that states no effect for any alternative. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989); Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). The sentence that closes this section at p. 131 - "Most forest plans acknowledge the need for protections for municipal watersheds with plan components that have an overall management objective to maintain and improve watershed status" - does not supply the missing finding and cannot defer it. No plan component is identified, none is cited, and "most" concedes that some plans have none. The decision under review is made at the rule scale and made now: the prohibition either stands or is removed nationally, and the watersheds it currently covers either keep that protection or lose it on the effective date. Whatever a later project-level analysis may add, it cannot supply the effects disclosure NEPA requires for the decision actually before the agency.

I recently retired and plan to spend the next few years exploring our national parks. Rescinding the roadless rule will open pristine lands to motorized vehicles which will create pollution. Leave our pristine roadless places alone so the beauty in our parks will be preserved for my (and other’s) arrival!! Uncited National Forest System Wilderness Acreage Relied On for the Alternative 3 Recreation Substitution Finding The Draft EIS states, at page 195, under *Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule — Wilderness*: "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation, and the National Forest System sub-total is the one this comment concerns. The only scientific citation anywhere in that paragraph is Landres et al. 2015, which appears three sentences later and is attached to a different proposition — the five qualities the Forest Service and other wilderness-administering agencies read into "wilderness character" under Section 2(a) of the Wilderness Act. It is not offered in support of either acreage. The next citation in the passage, 36 CFR 219.7(c)(2) at page 196, is attached to the plan-level identification of recommended wilderness. Between them the Draft EIS also states that National Forest System wilderness areas "receive about 13 million visits each year or 8 percent of the visits to all lands in national forests," and that figure is uncited as well. The Draft EIS does not identify the inventory the 36.7-million-acre figure was drawn from, or the date as of which it was current. I do not contend the figure is numerically wrong. I contend that a reader of this Draft EIS cannot determine what it rests on, and that this matters because the Draft EIS puts the figure to work in its effects analysis rather than offering it as background. The same paragraph reasons that "Congressionally designated wilderness within the National Forest System offers many similar recreation opportunities as roadless areas (except for motorized and mechanized trail activities)," and the analysis of Alternative 3 relies on that comparison to treat the non-motorized recreation opportunities now afforded by inventoried roadless areas as remaining available on other National Forest System lands after rescission. The 36.7-million-acre figure is the quantity that makes that substitution appear sufficient: it is the measure of how much comparable land the agency says remains. If the figure is drawn from an inventory that predates subsequent designations, boundary adjustments, or transfers, or if it counts acreage the agency does not in fact manage for the qualities it invokes, then the extent of substitute opportunity is overstated and the effect of rescission on non-motorized recreation in inventoried roadless areas is correspondingly understated. Neither the reader nor the decisionmaker can test that, because the source is not given. This states an issue within the meaning of 7 CFR 1b.11(a)(23): rescission of the 2001 Roadless Rule is the action, the availability of comparable non-motorized recreation opportunity on other National Forest System lands is the reasonably foreseeable effect, and the National Forest System wilderness acreage is the sole quantity the Draft EIS offers to measure that effect. An unsourced quantity cannot support the finding it is used to support. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS name the source of the 36.7-million-acre National Forest System wilderness figure and the date as of which that source was current, and state, where the effects analysis relies on the figure, how it supports the finding that designated wilderness provides recreation opportunity comparable to inventoried roadless areas. I do not ask the agency to adopt any particular database; I ask that whatever source it used be identified, so that the figure is traceable. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. This is a single request and I join no other to it. If the agency's position is that no source can be identified, it should say so expressly and state the basis on which the figure was derived, so that the record shows what the Final EIS's account of the wilderness estate rests on. The provenance of a quantity the effects analysis relies upon is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable laws within the meaning of 7 CFR 1b.11(a)(53). An agency must articulate a satisfactory explanation for its action, including a rational connection between the facts found and the choice made, supported by evidence in the record. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

The No Action alternative is the only choice for Proposed Rule. Without the current Roadless Rule in place, our National Forests would have been fragmented. It would be a shadow of the current National Forest System that is envied across the world. It is also the economic generator of arguably the biggest contributor to the national GDP in the outdoor recreation industry. It supports communities more sustainably than extractive industries with their boom and bust economic cycles. Most tourism to the forests anymore is year round, providing a steady source of income to the gateway communities and their businesses. Without the Roadless Area Conservation Rule, some of the highest visited areas - ski areas, mountain lakes and rivers, open meadows, and rocky peaks would be exploited as the "cheaper" alternative for businesses wanting to maximize their profits at the expense of the landowners of the American Federal Lands Legacy. The Code Of Federal Regulations (36 CFR 219.10) defines the Forest Service as a multiple use management agency, balancing timber, wildlife, recreation, range and watershed resources. No where in the mission of the Forest Service does it say we are to maximize commercial value of public lands, provide land for data centers, allow private developments, etc. In fact, the motto of the Agency is "Caring for the Land and Serving the People" and there is a reason it is in that order. The CFR further states the Agency "....must provide for ecosystem services and multiple uses". The Agency has a sustainable use mandate. In my 32 year career with the Agency we pushed back on pipelines, highways, cell towers, windmill farms, and other encroachments because there were other locations available outside the National Forests. One thing needed for all of those things was new road access, which in many cases was fortunately limited by the Roadless Rule. We were just perceived as the cheaper alternative. Our national forest laws and policies guide us to provide sustainable use for the common good, for generations to come WHILE protecting natural systems. As NEPA, ESA, and other protections have been weakened, keeping the Roadless Area Conservation Rule intact is even more important. There is no scientific fact that rescinding the Roadless Rule will reduce wildfires. The Agency already can grant road access for projects that contribute to the management and goals of the Agency, like fire and timber. Having the Roadless Rule in place gives the Agency the ability to review project proposals, work to collaborate to move forward with the solution that can achieve the goals of the project proposal and protect the ecosystems that are so important for sustaining our communities and forests. Implementation of policies can always be streamlined in my opinion, but streamlining should never weaken or violate the reasons those lands were preserved for the national population.