“I oppose the proposal to remove and reserve 36 CFR part 294, Subpart B (§§ 294.10–294.18). USDA should adopt…”

I oppose the proposal to remove and reserve 36 CFR part 294, Subpart B (§§ 294.10–294.18). USDA should adopt the No Action alternative. At a minimum, it should keep roadless protections on the Tongass National Forest. [1–2 sentences about who you are and your connection to the Tongass.] 1. The impacts analysis leaves out carbon. The "Summary of Potential Impacts" covers roads, timber, wildfire, recreation, fishing, and minerals, but not carbon or climate. For the Tongass, that is a major gap. A peer-reviewed study (DellaSala et al., 2022, Land 11(5):717) estimated that the Tongass stores about 2.7 billion metric tons of carbon, roughly 20% of all forest carbon in the National Forest System. Inventoried roadless areas hold just over half of it. Logging old-growth rainforest releases carbon that takes centuries to recover. USDA's own Tribal input summary notes that Tribes raised the forest's "global climate significance" as a carbon sink, but the proposal never responds to that point. Recommended change: The final EIS and cost-benefit analysis should quantify carbon losses forest by forest, including for the Tongass, before any final decision. 2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission. 3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule. 4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska [name specific programs if you can] are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175. 5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically. For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule.