FS-2025-0001-472963

Dear Secretary Rollins: My sister has a home in Weaverville, NC, and my family hikes all the time there. We hiked along the Laurel river earlier this year, and it was one of the best places we've hiked. Bulldozed roadbeds would end these trips. No more family time doing something we love. Regarding Laurel Mountain in Pisgah National Forest, NC: Road construction in the Laurel Mountain IRA reduces visitation by degrading the solitude, clean water, wildlife, and backcountry character visitors value. Fewer visitors mean less spending at local outfitters, guides, lodges, restaurants, and gas stations, directly weakening the recreation economy near Pisgah National Forest. "Timber management has the potential to affect recreation experiences and opportunities in several ways: noise levels, log trucks sharing roads with sedans, changes to the landscape from clearcutting and slash piles, and additional roads. Road dust generated from vehicular traffic on 2,068 miles of unpaved Forest roads also adds particulates to the air. Road dust generated by recreational and logging vehicles accessing National Forest System lands through private land is perceived as a problem by some private landowners adjacent to the Forest." — USDA Forest Service Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "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 is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. 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 ask is straightforward: maintain the Rule. With respect, Heather Disney