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facts that the agency found and its conclusions.” City of Los Angeles v. Fed.

Aviation Admin., 63 F.4th 835, 842 (9th Cir. 2023).

Plaintiffs contend that the Roadless Rule prohibits the use of growth

potential as a benchmark for determining what size qualifies as “small diameter

timber.” We disagree. The Roadless Rule does not define “generally small

diameter timber.” Rather, when promulgating the rule, the Forest Service

concluded that “[s]uch determinations are best made through project specific or

land and resource management plan NEPA [National Environmental Policy Act]

analyses,” in the context of ecological concerns. Special Areas; Roadless Area

Conservation, 66 Fed. Reg. at 3,257. Plaintiffs do not point to any rule provision or

text that could be construed as prohibiting the use of growth potential as a

benchmark. Nor do they explain why growth potential is not a reasonable

ecological factor for the Service to consider.

Plaintiffs also contend that the Service’s determination is arbitrary because

the revised memo did not provide a specific scientific citation for its factual finding

that the growth potential for Jeffrey Pine trees is 60–90 inches dbh.…