Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601286

Opposes rescissionPosted October 7, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Forest Management Wildfire
    • “wildfires were four times more likely to ignite within 50 meters of a road”
    • “Building roads into roadless areas to reduce wildfire makes no sense”
    • “Old trees are more fire resistant”
  • Climate Carbon Storage
    • “Old growth forests hold some of the densest carbon stores on the planet”
    • “Logging releases that stored carbon and replanting forests takes centuries”
    • “Big old growth also keeps adding carbon as they age”
  • Wildlife Habitat
    • “fragment habitat for brown bears, deer, and other wildlife”
    • “Roadless forests and standing old growth are irreplaceable”
    • “Old growth stabilizes steep slows, filters water and shades streams to improve the lives of Salmon”
  • Tribal Sovereignty
    • “Tlingit, Haida, and Tsimshian peoples depend on this land for food, cedar, and cultural sites”
    • “Any change must fully account for Tribal and subsistence use, with meaningful consultation”

What it names

National Forests
Tongass National Forest

The comment

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the USDA to keep it in place. I'm a documentary filmmaker in Port Townsend, Washington, currently making a film about the Tongass National Forest. Roadless forests and standing old growth are irreplaceable. As conditions shift across the country, longer, hotter fire seasons, warmer winters, and more extreme weather, we need more intact forest, not less. The proposal is framed around wildfire management, but the evidence points the other way. A 2026 study in Fire Ecology, covering national forest fires from 1992 to 2024, found that wildfires were four times more likely to ignite within 50 meters of a road than in roadless forest, and the result held in every Forest Service region. Even lightning fires were more common near roads, because openings in the canopy dry out the forest floor. Congressional Research Service data show about 89% of U.S. wildfires are human-caused. Roads bring people, and people bring fire. Building roads into roadless areas to reduce wildfire makes no sense. I am not anti-logging. We need wood but there is a good way to do it, and a bad way to do it. One aspect of the forest that needs to be carefully considered is that of old growth. Old growth forests hold some of the densest carbon stores on the planet. In their trunks, roots, and deep soils. Big old growth also keeps adding carbon as they age. Logging releases that stored carbon and replanting forests takes centuries. Many of the trees in the Tongass are 300-800+ years old. Once it is cut, no one alive will see it come back, in fact the next 7 generations will not. Old trees are more fire resistant. Old growth stabilizes steep slows, filters water and shades streams to improve the lives of Salmon which annually feed millions of species and people. Old growth shows what healthy forests look like without human disturbance, which makes it a reference for managing everything else. The Tongass is the only national forest where raw, unprocessed logs can be exported, and much of its timber has historically been shipped to Asia. Meanwhile the U.S. imports about 30% of the wood it uses. Opening the last intact old growth rainforest in the country to send raw logs overseas is not a good use of a public resource. Repeal would open nearly 45 million acres nationwide to road building and logging. Roads and clearcuts degrade salmon streams with sediment and warmer water, fragment habitat for brown bears, deer, and other wildlife, and raise landslide risk on steep, wet slopes like those in Southeast Alaska. These effects ripple through entire ecosystems and the fishing and tourism economies that depend on them. Finally, in the Tongass, the Tlingit, Haida, and Tsimshian peoples depend on this land for food, cedar, and cultural sites. Any change must fully account for Tribal and subsistence use, with meaningful consultation. For these reasons, I ask the USDA to withdraw the proposed rescission and keep the Roadless Rule in place.

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