Comment Analysis · Docket FS-2025-0001

FS-2025-0001-593969

Opposes rescissionA0 noneSubstance 9/24Posted October 6, 2026 On Regulations.gov

In short: The comment establishes the commenter's 50-year residency in Sitka, Alaska, as a basis for standing and cites the proposed rule's timber synopsis to document that the agency's analysis of economic impacts is flawed by ignoring the $7 billion in deferred maintenance costs and the negative consequences for local businesses and ecosystems.

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

A0 none: Counted, not answered.

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.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
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.
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.

Topics

Environmental Protection Biodiversity
- “old-growth cathedral trees of this forest are well over 500 years old”
- “support essential habitat for countless salmon runs, brown bears, deer, and migratory birds”
- “pockets of old-growth timber that should never be cut”
- “end the practice of clearcutting the last of our great forests”
Water Quality Quantity
- “pristine streams and rivers that flow through the Tongass”
- “depend on clean, fresh water, filtered by the trees that buffer the waterways”
- “impacts on the environment, the waterways, the fish habitat”
Recreation Tourism Public Use
- “hundreds of thousands of visitors travel to Sitka to see and walk through the Tongass”
- “trails that the Forest Service should continue to maintain”
- “beauty and wonder that tourists come to see from all over the world”
- “wildlife viewing and guiding operations”
Economic Impact Fiscal
- “unlimited bounty of meals through the fishermen whose livelihoods depend on this sustainable resource”
- “seven billion dollars in deferred maintenance involving existing roads and bridges”
- “Lifting the Roadless Rule comes with a great cost to the American taxpayer”
- “impacts on businesses associated with our beloved forest”

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 Forest Service leaders, I've lived in Alaska for 50 years and treasure the public lands that are unique to this great state, including the Tongass National Forest, our largest temperate rainforest in the world. My home in Sitka is on the doorstep of this beautiful forest of Sitka spruce, western hemlock, alder, and yellow cedar. The old-growth cathedral trees of this forest are well over 500 years old. Such trees are magical to behold, leaving the observer awestruck. I'm surrounded by pristine streams and rivers that flow through the Tongass, supporting millions of spawning salmon each and every year. These healthy and robust populations of fish depend on clean, fresh water, filtered by the trees that buffer the waterways. These fish ultimately feed millions of people in Alaska, throughout the United States, and around the world. If we protect the forest and streams that are the birthplace of these salmon, we provide an unlimited bounty of meals through the fishermen whose livelihoods depend on this sustainable resource. You can't begin to put a price tag on a resource that can last forever if we only protect the forest that shelters that resource. This magnificent forest is also a place of great beauty and wonder. Each year hundreds of thousands of visitors travel to Sitka to see and walk through the Tongass National Forest along the many wonderful trails that the Forest Service should continue to maintain, as well as the public use cabins. Our fishing community and the many other towns in Southeast Alaska are united in their support of keeping the 2001 Roadless Area Conservation Rule in place. As Alaskans, we value the nine million acres that are protected from new road construction by this good rule. These acres support essential habitat for countless salmon runs, brown bears, deer, and migratory birds that depend the forest for nesting. These acres hold the beauty and wonder that tourists come to see from all over the world. These acres include pockets of old-growth timber that should never be cut. This proposed rule making document notes that there will be no impacts on businesses because the rule will not created new record keeping, reporting or compliance requirements. I find this statement laughable. If you allow new road building in the Tongass National Forest there will clearly be impacts on the environment, the waterways, the fish habitat, the beauty, and countless impacts on businesses associated with our beloved forest! Businesses include fishery operations, tourism operations, wildlife viewing and guiding operations, and impacts on all of the local communities who support keeping the Roadless Rule in place. These are physical, monetary, and environmental impacts that go far beyond the impacts of record keeping. Last, in your timber synopsis you clearly point out that the efficiency gains of lifting the Roadless Rule are entirely limited by the road costs, maintenance, funding gaps and the seven billion dollars in deferred maintenance involving existing roads and bridges. Lifting the Roadless Rule comes with a great cost to the American taxpayer. We have a chance to not make the mistakes of the past. We have chance to end the practice of clearcutting the last of our great forests in America. The Forest Service should focus on protecting our greatest forests such as the Tongass and the Chugach in Alaska, and keep the Roadless Rule in place. Thank you for extending the comment period and please keep the Roadless Rule in place. Sincerely, Debbie S. Miller P.O. Box 2808 Sitka, AK 99835