Comment Analysis · Docket FS-2025-0001

FS-2025-0001-533459

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 4, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 3 submissions in its group. See the letter, its submissions and topics.

In short: The comment documents that the agency's proposal to rescind 36 CFR part 294, Subpart B fails to analyze carbon sequestration impacts for the Tongass National Forest, applies a wildfire rationale inapplicable to temperate rainforests, and ignores Tribal opposition and subsistence review requirements under ANILCA Section 810.

Scored as the letter — The shared letter of a family, scored once for everyone who sent it.

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, Evidence, Alternative, 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

Climate Carbon Storage
- “impacts analysis leaves out carbon”
- “Tongass stores about 2.7 billion metric tons of carbon”
- “Logging old-growth rainforest releases carbon that takes centuries to recover”
- “quantify carbon losses forest by forest”
Tribal Sovereignty
- “Stewardship should be led by Tribes, not shifted onto them”
- “Most consulted Tribal governments oppose rescission”
- “co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent”
- “consistent with the federal trust responsibility under E.O. 13175”
Cultural Heritage Indigenous
- “ANILCA Section 810 subsistence hearings will be announced later”
- “full 810 analysis is complete”
- “effects on salmon watersheds”
- “Tribal guardian programs in Southeast Alaska”
Forest Management Wildfire
- “wildfire rationale does not apply to the Tongass”
- “Tongass is a temperate rainforest where large fires are rare”
- “Conditions in other forests should not be used to remove protections”
- “Exclude the Tongass from any rescission”

What it names

National Forests: Tongass National Forest
Law cited: 36 CFR part 294 E.O. 13175

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisEvidenceRequestAlternativeLegal

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.