Read the comments.

I object to rescission of the roadless rule and support Alternative 1, no action, due to the impacts of invasive plant species. I live adjacent to public lands in Eastern Idaho and Western Wyoming where invasive plant species have become a serious concern. In my own experience, trails in Wilderness and Wilderness Study Areas like the Gros Ventre Wilderness, Southern Wyoming Range, and Palisades Wilderness Study Area have very few occurrences of species like Musk Thistle, Canada Thistle, and Spotted Knapweed while roads and trails open to motorized use have populations from occasional individuals to full-blown infestation. One grazing lease adjascent to our farm in Victor, Idaho, on BLM land with a road easement through it, is absolutely infested with Musk Thistle, threatening the economic viability of the lease, spread to the adjacent Targhee National Forest, and increased wildfire risk. It is an economic disaster happening in slow motion. For the specifics of the proposed rescission, my objection rests on the fact that Alternatives 2 and 3 would be in direct conflict with a standing executive order. This order, Executive Order 13751, commits agencies to avoid worsening the problem of invasive plant species and the USFWS’s own Biological Assessment makes clear that roads (and their construction) “create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition.” This analysis also states that 60 percent of taxa studied are threatened by invasive or non-native species. The DEIS does not include this finding, nor the 60 percent figure. The DEIS openly admits on page 116 that Alternatives 2 and 3 “could potentially increase the extent or the number of incisive plant species in the affected environment area." This contradiction must be resolved. All of this is to say the obvious: roads bring with them invasive plant species that, once established, are very difficult to deal with and cause significant economic damage. In my area, rescission of the roadless rule would threaten the economy of our valley which relies heavily on recreational tourism. It would also potentially increase wildfire risk. Our functional forest ecosystems are a resource we can't afford to lose.

Dear Forest Service Leadership: As a wildlife observer I recognize the 2001 Rule as the federal instrument most directly responsive to that fact; I write in opposition to the proposed rescission. Craggy Mountain is one of the first wild places I connected with in Western North Carolina. As a recent transplant from the west coast, I value the biodiversity that the Roadless Rule protects. From the northern red oak to the Dark-eyed Junco, the forest provides the wonders and rich landscape that only a roadless forest can offer. The DEIS analyzes non-native invasive plant species at pp. 114-116 and identifies roads as a vector at p. 150: "Road construction, routine roadside mowing, and the use of roads have been shown to facilitate the spread of non-native invasive plant species." This comment is directed at three specific defects inside that analysis. 1. The extent figure measures current infestation, not introduction risk in areas that are currently uninfested. The North Carolina Wildlife Resources Commission put the distinction to the agency directly: "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" (DEIS Vol. III, p. 210). On that record the low current percentage identifies the resource at risk; it does not bound the effect. The FEIS should correct the disclosure to state what the figure measures, what it does not, and what the acknowledged mapping gap does to it. 2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding. 3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive or non-native species." Neither that finding, nor the 60-percent figure, nor the 134-taxon denominator appears anywhere in the DEIS. The DEIS's invasive-plant section at pp. 114-116 does not mention listed species at all, and the DEIS's ESA discussion refers the reader away, stating that "the Biological Assessments contain the full evaluations for the ESA-listed species and designated critical habitat" (p. 169). The agency therefore holds, in one record, a quantified invasive-species threat to 60 percent of the listed plant taxa it analyzed and an invasive-species effects analysis for the action that permits the road construction - and connects them in neither document. Coffin et al. 2021 is a source the agency itself relies on. The FEIS should carry the Assessment's finding into the invasive-plant analysis and disclose the exposure of listed plant taxa by alternative. Compliance with Executive Order 13751. The DEIS opens this section by quoting the order, which "directs all Federal agencies to address invasive species concerns and refrain from actions likely to increase invasive species problems" (p. 114). It closes the same section by finding that alternatives 2 and 3 "could potentially increase the extent or the number of invasive plant species in the affected environment area" (p. 116). The agency cannot demonstrate compliance with an executive order it has itself invoked while the record's only quantified statement of invasive-species exposure for listed plants - 81 of 134 taxa, at Biological Assessment p. 344 - is absent from the analysis supporting the decision. This is a compliance concern within the meaning of 7 CFR 1b.11(a)(53), and it is owed a reasoned explanation in the final rule as well as a corrected analysis in the FEIS. The Roadless Rule belongs on the books. Hopefully,