Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601497

Supports rescissionA3 weakSubstance 13/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the repeated reversals of the Roadless Rule status in the Tongass National Forest create regulatory unpredictability that hinders mineral exploration investment and execution, and supports the rescission of the 2001 rule in favor of project-by-project decision-making.

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

A3 weak: Substantive, but easier to set aside.

Owed an answer on 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

Resource Development Extraction
- “mineral exploration in Southeast Alaska”
- “difficult to raise investment for exploration”
- “mineral belts don't follow political or ownership boundaries”
- “New ones depend on new discoveries advancing”
Economic Impact Fiscal
- “average annual mining wage in Southeast was $134,545”
- “well-paying mining careers”
- “let people build a life without leaving Southeast”
- “significant cost to budget and schedule”
Governance Policy Process
- “unpredictability makes it difficult to raise investment”
- “status of the Tongass under the rule has been reversed four times”
- “decisions be made project by project”
- “reversed every few years”

What it names

Roadless areas: Greens Creek

The comment

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

Dear Director: I am submitting these comments as an individual who has worked in mineral exploration in Southeast Alaska since 2009, and has lived in Ketchikan, Prince of Wales Island and Juneau. I now work as an independent consultant to companies exploring in the region, and these comments are my own. My first work in Southeast was at the Niblack project on Prince of Wales Island, where I was Project Manager from 2009 to 2020. Niblack has tidewater access and roads on patented mining claims, which supported underground development and exploration drilling. The Tongass had been temporarily exempted from the Roadless Rule in 2003, and in 2009 the Forest Service approved exploration drilling at Niblack in a Decision Memo. When a federal court reinstated the 2001 rule on the Tongass in 2011, its judgment allowed the drilling approved in 2009 to continue. However, our drill sites had since been revised based on underground exploration results, so the Forest Service halted our helicopter-supported surface program on National Forest land mid-season. At significant cost to budget and schedule, we moved crews to another project and returned in the fall to drill only from patented claims. A separate 2012 authorization allowed surface drilling to resume, and that was the last field program I managed before the project went into care and maintenance. That is the practical effect of the rule on Tongass projects. Since 2009 I have watched the Tongass move in and out of the 2001 rule with court rulings and changes in administration. The status of the Tongass under the rule has been reversed four times, in 2003, 2011, 2020 and 2023. Approval of exceptions has also changed four times: the Secretary reserved it from 2009 to 2012, it was delegated to regional foresters in 2012 and 2018, and in 2021 pending decisions were elevated to the Department again (DEIS pp. 3 and 6). Each change resets the planning assumptions for projects on the forest. This unpredictability makes it difficult to raise investment for exploration in Southeast and even more difficult to execute programs when the money is raised. Companies and investors generally understand that exploration in Southeast works with helicopters and barges. Most of the programs I've managed in my career, in and outside of Alaska, have been helicopter-supported, because it isn't practical to build a road to a prospect without a proven resource. However, drill pads and landing zones require cutting trees, which in my experience can fall under the same scrutiny as road building in the Tongass. Access for developing and operating a mine comes later, when a project succeeds and needs a road to advance. The companies I work with in Southeast have projects on state, BLM and private land, where access is decided project by project. Southeast is a mineral district, and its mineral belts don't follow political or ownership boundaries. Inside a Tongass roadless area, a mining road also needs a discretionary exception, on top of the environmental review and plan approval it already requires. Whether a successful project can build a road depends on which side of that boundary it sits. I was the Director of the Center for Mine Training at the University of Alaska Southeast in Juneau, which prepares people from the region for well-paying mining careers. In 2025 the average annual mining wage in Southeast was $134,545, more than twice the regional average of $66,796 (Southeast Conference, Southeast Alaska by the Numbers 2026). Jobs like these let people build a life without leaving Southeast. The operating mines, Greens Creek, Kensington and Dawson, provide most of them today. New ones depend on new discoveries advancing, and on the Tongass that relies on access. I support Alternative 2, rescission of the 2001 rule. Not once while working in the Tongass for over 15 years did I encounter someone wanting to build a network of roads throughout the forest. The residents of Southeast Alaska are among some of the most environmentally aware people I have met and care deeply about protecting what they enjoy about living here. Every road would still require site-specific environmental review, consultation with Tribes, the subsistence protections of ANILCA and approval under the Forest Service's minerals regulations. I would rather those decisions be made project by project, by people who know the ground, than set nationally and reversed every few years. Thank you for considering these comments.