Comment Analysis · Docket FS-2025-0001

FS-2025-0001-585111

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.

In short: The comment documents that removing the 2001 Roadless Rule in the Tongass National Forest would exacerbate economic losses, reduce subsistence opportunities, and harm ecosystems, while citing specific fiscal data and the existence of Alternative 1 as a preferred management approach.

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

A3 weak: Substantive, but easier to set aside.

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

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequestAlternativeLegal

Dear Joshua White, I have not been, however I am a Doctor of Medical Qigong Therapy which the 5 elements is part of our work- wood, water, fire, earth and metal- key to the health of our physical bodies, energetic bodies and our spiritual bodies is nature and the deep connection to our interconnectedness to mother earth and who we all are and will be. 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. Every bit of nature has a sacredness that can only exist as pure as it can be without human corruption. There is an urgency to keep as much of nature pure as possible for the climate and for the sake of the future generations to have forests and nature of all sorts in tact. As so much of it is shrinking UP UNTIL NOW- magic words. Up until now we have the chance to make the best possible choices for our planet and our people. 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. Keeping an urgency to protect wildlife and also to educate people its importance not only with climate but with the healing properties of time spent in nature. 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. Dr-Amba Dryg-Tobin