Comment Analysis · Docket FS-2025-0001

FS-2025-0001-601755

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's proposal leaves the Tongass with zero acres of roadless protection, fails to analyze Tribal-proposed alternatives, and contains an internal inconsistency where the DEIS cites a 13-75% biodiversity loss from fragmentation without applying that finding to the 40.1 million acres of potentially affected environment.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Legal.

Standard dismissals it defeats

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

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.
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.

Topics

Tribal Sovereignty
- “Tribal consultation record makes the procedural posture of this rescission indefensible”
- “majority sentiment among consulted Tribal governments is opposition”
- “threat to inherent rights, Tribal sovereignty, cultural survival”
- “complete all 64 requested consultations and publish the Tribal Impact Summary Statement”
Environmental Protection Biodiversity
- “largest intact temperate rainforest left on Earth”
- “habitat fragmentation reduces biodiversity by 13 to 75 percent”
- “salmon streams, the Sitka black-tailed deer, the brown bear, the wolves, the bald eagle”
- “five species of Pacific salmon that anchor subsistence life here”
Climate Carbon Storage
- “roughly 44 percent of all the carbon stored by United States national forests”
- “intact temperate rainforest”
- “ecological health of ancestral homelands”
Legal Regulatory Framework
- “Ninth Circuit already reviewed that argument... and found it wanting”
- “local decision-making can incrementally erode nationally significant roadless values”
- “procedural posture of this rescission indefensible”
- “agency must address its own prior finding”

What it names

Law cited: Executive Order 14153

The comment

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

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tongass has shaped my life in Sitka in ways I am still learning to name. In two years here it has molded how I move through the landscape, what I am grateful for, how I eat, what I notice. The sheer grandeur of an intact temperate rainforest does that. It is hard not to be enamored, and even harder not to feel grateful for what the Tongass is: a main pillar of subsistence, culture, recreation, and ecosystem in Southeast Alaska. The Tongass makes life whole here. As someone who lives inside that wholeness, I submit these comments opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The forest I am writing from is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, more than 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. That means the salmon streams, the Sitka black-tailed deer, the brown bear, the wolves, the bald eagle, and the five species of Pacific salmon that anchor subsistence life here are all subject to what follows from that zero. The nine municipal watersheds named in DEIS Table 2, including Sitka, are also subject to it. I ask the agency to explain in specific terms what protection, if any, replaces the rule for those watersheds and that wildlife. The agency's own Tribal consultation record makes the procedural posture of this rescission indefensible. "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Tribal governments proposed alternatives, among them a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analyzed. I find it deplorable that the summary of that consultation arrives only after the comment period closes. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule is issued. The economic case for rescission is not established by the agency's own numbers. The agency acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal contribution, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with that record and explain how an action whose own analysis cannot establish a net benefit is justified. The legal foundation here is also troubled. The agency's record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-specific approaches can substitute for a national rule. The Ninth Circuit already reviewed that argument the last time the agency replaced the national rule with a state-by-state approach and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids those same deficiencies. Finally, the DEIS itself quantifies a consequence it does not then apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record. No projection across the 40.1 million acres of potentially affected environment follows from it. The agency should apply its own cited finding at the scale of the action it is proposing. I implore policymakers to visit Southeast Alaska, bring your kids, show them what an intact temperate rainforest looks like, gaze upon it with gratitude for all the life it supports, be humbled. A logged stand grows back. The agency should say plainly what does not. Sincerely, Zia NoiseCat Sitka, AK