Comment Analysis · Docket FS-2025-0001

FS-2025-0001-272189

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted August 26, 2026 On Regulations.gov

In short: The comment places on the record that the Chichagof IRA in the Tongass National Forest contains properly functioning watersheds supporting salmon and that the DEIS must evaluate flood hazard potential of road construction in that area pursuant to Executive Order 11988.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.

Topics

  • Recreation Tourism Public Use
    • “expedition guide”
    • “pristine quiet places”
    • “guests came back with countless stories and pictures”
    • “experience they come looking for”
  • Wildlife Habitat
    • “passed bears and other animals”
    • “abundance of food and nutrients”
    • “productive salmon run”
    • “world-class salmon populations”
  • Water Quality Quantity
    • “headwaters of the Pelican Creek”
    • “alter natural drainage patterns”
    • “increasing runoff velocity”
    • “downstream flood risk”
  • Environmental Protection Biodiversity
    • “untouched and protected”
    • “twenty-five years of roadless protection”
    • “rescission would begin to unwind both”
    • “Properly Functioning”

What it names

National Forests
Tongass National Forest
Law cited
16 U.S.C. 160016 U.S.C. 1608Executive Order 11988

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapLegal

To the U.S. Department of Agriculture: In my work as an expedition guide, I have spoken with enough guests to know that what they come to Alaska and pristine quiet places for is precisely the character of land that the 2001 Rule has protected. I have spent the past 5 years up in Alaska taking clients to see the beauty and the productivity of an isolated roadless place. I have passed bears and other animals on the trail who do not threaten me because they have an abundance of food and nutrients and we are just passing by together. One visit made that connection concrete. Just last week, we were taking guests along a river bed near Port Althorp and getting to show them what a productive salmon run looks like. We showed them how the dead salmon end up in the forest and return nutrients back to the forest from the water. We passed a bear who was readily on their way to the salmon, wanting nothing to do with us. These guests came back with countless stories and pictures and an understanding of what the world looks like when it is untouched and protected. This is exactly the experience they come looking for when they come travel here. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Chichagof in the Tongass National Forest, Alaska: Headwater Networks Supporting Pacific Salmon Fisheries — The Chichagof IRA contains the headwaters of the Pelican Creek, Lisianski River, Kadashan River, Neka River, and other major drainages that support world-class salmon populations. These watersheds are classified as "Properly Functioning". Roads authorized by rescission in the Chichagof IRA, Tongass National Forest, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. The DEIS must evaluate the flood hazard potential of road construction in the Chichagof IRA, Tongass National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608)." — USDA Forest Service This comment joins the record in opposition to the proposed rescission action. With concern, CommentID: RLC-20260824-UUV9QX

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