Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602640

Supports rescissionA2 moderateSubstance 11/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the Tongass National Forest was improperly included in the 2001 Roadless Rule contrary to ANILCA's 'No More' clause, and documents that the current rule's access exceptions are subjective and fail to provide clear direction for future transmission projects, resulting in excessive construction and maintenance costs as evidenced by the Swan-Tyee Intertie.

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

A2 moderate: Hard to dismiss — it shows cause and effect.

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.
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.

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.
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

Governance Policy Process
- “those who know the land the best should be the shepherds of its future”
- “many important Alaskan decisions are made for us”
- “The Tongass was not supposed to be included in the 2001 Roadless Rule in the first place”
- “allowing for Alaskans to finally have the opportunity to make decisions on our forest as we see fit”
Legal Regulatory Framework
- “The No More clause of ANILCA (1326(a) was supposed to prevent such additional land set asides”
- “Congress had already set aside 5.7 million acres of Wilderness and 775,524 acres of Legislative LUD II Areas”
- “The Final EIS exempting the Tongass on October 29, 2020, pointed out that road construction would increase from 994 miles”
- “This exception is subjective and fails to provide clear direction”
Resource Development Extraction
- “a repeal of the Roadless rule would advance hydroelectric capabilities”
- “identified over 200 potential hydropower sites in Southeast Alaska”
- “excess power from Southeast Alaska can be exported to the Lower 48”
- “Only 186,000 more acres of the 16.9-million-acre Forest would be available for timber harvest”

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

I write today in support of the current recission of the 2001 Roadless Rule. I am a lifelong Alaskan who has spent my entire life being molded by the Tongass, and have come to realize just how lucky we are to grow up with something of this magnitude in our backyards. Its with this deep respect, that I believe those who know the land the best should be the shepherds of its future. The Roadless rule is something that works for lower 48 states, with minimal federal forestry land, but when you apply it to the southeast Alaska region, many important Alaskan decisions are made for us. The Tongass was not supposed to be included in the 2001 Roadless Rule in the first place. Congress had already set aside 5.7 million acres of Wilderness and 775,524 acres of Legislative LUD II Areas (Similar to Roadless Areas) in ANILCA and the Tongass Timber Reform Act of 1990 (TTRA). The No More clause of ANILCA (1326(a) was supposed to prevent such additional land set asides that were over 5,000 acres without an Act of Congress. The Tongass was thus not added to the 2001 Roadless Rule until the Record of Decision was promulgated. Fed. Reg. Vol. 85, Oct. 29, 2020, at pages 68690-68691. So, there is every reason to remove it from Roadless designation. The Final EIS exempting the Tongass on October 29, 2020, pointed out that road construction would increase from 994 miles under the No Action Alternative to 1043 miles (49 miles) under Exemption over the next 100 years. Only 186,000 more acres of the 16.9-million-acre Forest would be available for timber harvest. Fed. Reg. Vol. 85, Oct. 29, 2020, at page 68691 (middle column). Additionally, a repeal of the Roadless rule would advance hydroelectric capabilities for a region that sees some of the highest rainfall on average. The 1947 Waterpower of Southeast Alaska Report, conducted in part with the Forest Service, identified over 200 potential hydropower sites in Southeast Alaska. There is thus no reason why all Southeast Alaska should not be on hydropower. Moreover, excess power from Southeast Alaska can be exported to the Lower 48. On November 13, 2000, Congress authorized construction of a Southeast Alaska-wide intertie, which included the Tongass National Forest. Pub. Law 106-511, 114 Stat. 2365 (Nov. 13, 2000). Future hydropower and support facilities, such as those envisioned by Report #97- 01, are subject to the prohibition on road construction. See 66 Fed. Reg. at 3256 (“The final rule retains all the provisions that recognize existing rights of access and use. Where access to these facilities is needed to ensure safe operation, a utility company may pursue necessary authorizations pursuant to the terms of the existing permit or contract.”) (Emphasis added). This exception is subjective and fails to provide clear direction. Future transmission projects do not fall within that exception. The Swan-Tyee Intertie (STI) is an example of a transmission project that, because of no road access, resulted in exceedingly high construction costs. If road access is unavailable for construction, the utility is limited to the use of helicopters. Helicopters are extremely expensive. This resulted in a construction cost for STI of about $2 million dollars/mile. The STI is 57 miles long and the total construction cost including permitting, design, etc., was about $110 million. To put that in perspective, the proposed Kake-Petersburg (KPI) line, which has roads in place, has an estimated cost of around $45 million. The length of the KPI is about the same as the STI. Of more significance is the cost to maintain a line that is constructed without road access. The rights-of way (ROW) for these lines have to be maintained and brushed continually. The structures must be inspected on a rotating annual basis. With roads, this work can be done by a crew in a truck. Without roads, this work must be helicopter supported, which is very expensive. Moreover, transmission lines that do not have road access must also have helicopter pads near the structures. These pads must be maintained and brushed every couple of years. This work must be done by helicopter. For these reasons above, I support repealing the roadless rule, and allowing for Alaskans to finally have the opportunity to make decisions on our forest as we see fit. Thank you for your time.