“The Forest Service should not finalize the rescission of the 2001 Roadless Rule as proposed in this draft EIS…”

The Forest Service should not finalize the rescission of the 2001 Roadless Rule as proposed in this draft EIS. The document's Scope of the Analysis section flatly states that "none of the rulemaking alternatives propose specific actions that would cause irreversible or irretrievable commitments of resources," yet the same EIS discloses that the rescission is preliminarily found "likely to adversely affect" 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth timber removal are reasonably foreseeable. An agency cannot credibly disclaim any irreversible resource commitment while its own effects chapters predict exactly that. The draft EIS contains other unreasoned gaps. In the Hazardous Fuel Reduction discussion, the agency's own cited research (Healey 2020) found that "the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities," directly undercutting the purpose and need's claim that the Rule caused the current forest-health crisis. The Potentially Affected Environment section shows that existing land management plans already restrict timber harvest on 66.5 percent of the potentially affected IRAs regardless of the Roadless Rule's status, so rescission may deliver far less new access than claimed. And the Vegetation and Forest Management section admits that IRA timber harvest has averaged only about 500 acres a year, "inconsequential to overall nationwide" levels, over the more than two decades the Rule has been in effect. The agency should: (1) complete ESA Section 7 consultation and disclose the final Biological Opinion covering the 327 species and 71 critical habitats before finalizing this rule; (2) revise the Scope of the Analysis section to honestly analyze the irreversible and irretrievable commitments its own chapters describe; (3) reconcile the contradiction between the purpose and need's forest-health rationale and the Healey 2020 findings it cites; (4) quantify the marginal benefit of rescission given that land management plans already restrict two-thirds of the affected acreage; and (5) extend the comment period on this draft EIS, given that 99 percent of the 220,000-plus comment letters already received opposed the rescission.