Comment Analysis · Docket FS-2025-0001

FS-2025-0001-578173

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 42 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

Environmental Protection Biodiversity
- “safeguarded the world's largest intact temperate rainforest”
- “jeopardizing the small amount of untouched land we have left”
- “Protect the land and the animals and people who live on it”
Economic Impact Fiscal
- “fiscally irresponsible”
- “Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year”
- “cost-benefit analysis for the economic impact of removing Roadless protections”
Cultural Heritage Indigenous
- “subsistence harvesters have repeatedly testified through ANILCA 810 hearings”
- “removing the Roadless Rule will result in reduced subsistence opportunity”
- “Roadless forests are critical for our subsistence foods”
Recreation Tourism Public Use
- “provides recreation and tourism opportunities that anchor the regions largest private sector industry”
- “expense of our tourism and outdoor recreation industries”
- “investing in restoration, road and trail maintenance, and recreation infrastructure”

What it names

National Forests: Tongass National Forest

The comment

Dear Joshua White, Hello there, I'm Margie and I grew up in Sitka, Alaska in the Tongass. Growing up as an only child with a single mother, one of my greatest joys was being out in the wilderness with my mother. We would spend hours pouring over charts and mapping interesting routes we could take our little boat. Discovering secret beaches that looked like perfect places to find glass balls, or hidden waterfalls that we knew hadn't been seen by human eyes in decades, or maybe longer. We fished to fill our freezer and our bellies, set crab pots, dug clams, and ate healthfully and well. As I grew I began using the outdoors in new ways, exploring hunting deer, hiking with friends, and camping to "get out of town". Now due to family and other concerns, we live in Vermont. It makes me laugh when people call this area "rural" and "wild". They have no idea what the true meaning of rural is here in New England. There is no true wilderness here. All the land is privately owned or "protected" by private land trusts. We can't let that happen to Alaska. Alaska is one of the very very few areas in the United States, and maybe in the world, where true wilderness exists. These areas in Alaska are absolute gems, treasures, that are precious beyond measure. And once desecrated, cannot ever return to their virgin state. Revoking the Roadless Rule that had protected this area is a mistake. It would expose this fragile ecosystem that is so unique and pristine to irreversible damage and exploitation. I support continued Roadless Rules to protect Alaska's untouched wilderness areas. I will support Roadless Rules until the day I die. Margie Kearns Ferry 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. Revoking the Roadless Rule exposes old growth forests, animals, and whole ecosystems to irreversible damage. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. 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. The Forest Service should invest in measures to protect the virgin forests. They should spend time and money rehabilitating burn or logging areas, partnering with local groups that repopulate struggling wildlife, or educating people on the benefits of old growth 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. Margery Ferry