Comment Analysis · Docket FS-2025-0001

FS-2025-0001-575022

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 6, 2026 On Regulations.gov

Campaign — One letter sent by 10 or more people, copied or lightly reworded. One of 14 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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

A3 weak: Substantive, but easier to set aside. This rating is the one its shared letter earned.

Owed an answer on Analytical gap, Evidence.

Standard dismissals it defeats

  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

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.
  • 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.
  • 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.
  • 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.
  • 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.

Topics

  • Cultural Heritage Indigenous
    • “subsistence harvesters have repeatedly testified through ANILCA 810 hearings”
    • “removing the Roadless Rule will result in reduced subsistence opportunity and productivity”
    • “Roadless forests are critical for our subsistence foods”
  • Economic Impact Fiscal
    • “It will hurt our economies, like our visitor industry and commercial fishing”
    • “Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year”
    • “Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries?”
  • Environmental Protection Biodiversity
    • “safeguarded the world's largest intact temperate rainforest”
    • “Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience”
    • “fails the people, economy, and ecosystems of Southeast Alaska”
  • Recreation Tourism Public Use
    • “I depend on these places for recreation, health and artistic inspiration”
    • “It provides recreation and tourism opportunities that anchor the regions largest private sector industry”
    • “invest in recreation and young growth timber”

What it names

National Forests
Tongass National Forest
Roadless areas
Hoonah Sound

The comment

Dear Joshua White, The Tongass has been home for 30 years. From the berries we pick, to the fish we subsist on and the salmon my spouse fishes commercially we are connected by both what we put in our bodies and how we cover expenses. An example of how we live and love this place: We were married on a muskeg just above Goddard Hot springs. Our honeymoon was a slow 3 week boat trip circumnavigating Baranof Island -we fished, hiked, paddled kayaks, snorkeled for abalone in places including Kelp Bay, Fish Bay, Ushk Bay, Fick Cove, Hoonah Sound, Red Bluff Bay and we stopped to visit with our friends who have taught us so much about subsistence in Hoonah and Kake. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. Climate change! We can't have our heads in the sand. The Tongass is a long term high capacity carbon store and logging old growth releases carbon. Salmon! They fill our freezer. They've been harvested in SE since time immemorial. They're part of our rich ecosystem. We should do all we can to care for the salmon! And we need to think of future generations. This is another example of tax payer waste! There is no need to harvest old growth wood. This environment is what visitors come to see---why would you put that at risk? The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed— 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. Alternative 1 keeps the Tongass protected! It will protect the traditional practices of our friends and neighbors. It will protect our livelihood. It will protect the fish,, berries, deer that we harvest from intact forests. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Ms. Ellen Frankenstein

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