Comment Analysis · Docket FS-2025-0001

FS-2025-0001-604325

From Southeast Alaska Conservation Council

Opposes rescissionPosted October 7, 2026 On Regulations.gov

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

The comment

The Tongass National Forest and its Roadless areas hold immeasurable value unique to our region, including world-class fish and wildlife, recreation, subsistence resources, and are the underpinning of many of the economic drivers for local communities. Last year, USDA issued a notice of intent to rescind the Roadless Area Conservation Rule nationwide. This action would have a direct and profound impact on us, our communities, economy, and all of those who live and work in the Tongass National Forest. The proposal to rescind the Roadless Rule is a huge leap backward and risks undoing much of the progress gained through hard compromise and collaboration in recent years. It turns its back to the region's economic strengths: fishing, tourism and outdoor recreation, which now account for 26 percent of regional employment and $2 billion to the local economy, and shortchanges the values that make the Tongass National Forest so unique and valuable to local residents and visitors alike. The Forest Service should abandon its proposal to rescind the Roadless Rule and, instead, maintain protections for roadless areas within the Tongass. Roadless areas on the Tongass include some of the most valuable lands in the forest. Many of the most important salmon streams are in roadless areas. Increasingly scarce winter deer range and prime bear habitat are often found in low elevation Roadless areas. Rescinding the Roadless Rule would negatively impact subsistence in the Tongass. Subsistence is not a peripheral interest that can be deferred until after a nationwide rule is repealed. In Southeast Alaska, the health of deer habitat, salmon watersheds, forest access patterns, and traditional gathering areas is tied to household food security, cultural continuity, and rural community well-being. Roadless areas offer the right combination of beautiful scenery, wild landscapes, fish and wildlife, and access that our growing tourism and recreation industry demands. The Roadless Rule's protections for these unique values give our communities a level of certainty of the direction of our economies and quality of life. The Tongass is a paradise — not just for Alaskans, but for all Americans. Roadless areas in the Tongass contain much of the region's most productive wildlife habitat, quality salmon habitat and clean water, and recreation opportunities. Any durable and long-lasting solution to the persistent land management challenges on the Tongass must be based on collaboration and care for the important fish, wildlife, recreation, subsistence and scenic values that make the Tongass unique among our public lands. The proposal to rescind the Roadless Rule fails on this measure. We encourage the Forest Service to listen to the overwhelming weight of public comment, the needs of local businesses and tribal governments, and to not rescind the Roadless Rule in the Tongass National Forest. Attached: 1089 unique signatures

Topics

  • Wildlife Habitat
    • “world-class fish and wildlife”
    • “most productive wildlife habitat”
    • “increasingly scarce winter deer range and prime bear habitat”
    • “quality salmon habitat”
  • Cultural Heritage Indigenous
    • “subsistence resources”
    • “traditional gathering areas”
    • “cultural continuity”
    • “household food security”
  • Recreation Tourism Public Use
    • “tourism and outdoor recreation”
    • “26 percent of regional employment”
    • “beautiful scenery, wild landscapes”
    • “recreation opportunities”
  • Water Quality Quantity
    • “most important salmon streams”
    • “salmon watersheds”
    • “clean water”

What it names

National Forests
Tongass National Forest

Attachments

1 file from Southeast Alaska Conservation Council. Counts as 1,081 — Counted from the files: The enclosed submissions were counted from the files themselves.

  • Enclosed submissions

Sharing & methodology

These results are meant to be shared.

Please cite us. This analysis is the intellectual property of Roadless.org and Nicholas Holshouser. You are welcome to reproduce it — every reproduction must include this citation:
Roadless.org and Nicholas Holshouser, “2001 Roadless Rule Revision — Substantive Analysis,” https://roadless.org.

How it works. A large language model (an open-weight Qwen3.8 model) reads each substantive comment and copies, word for word, the passages that carry its analytical gap, evidence, request, alternative and connection to the place; it returns no scores. Code grades those passages 0–3 on eight dimensions — evidence, legal grounding, engagement with the environmental analysis, analytical gaps, alternatives, specific requests, position, and local knowledge — with legal grounding taken from a citation scan, not the model. For the strongest tenth on each side, the copied passages are checked against the comment and shown as exhibits. A comment counts as “substantive” when it clears a floor filter — it must show at least one substantive signal (a named entity, a specific citation, a stated analytical deficiency, or first-person testimony), which screens out one-line and purely conclusory submissions before any model scoring.

The full method. Every step, why it is done that way, its known limits and a glossary: Methodologies →

The data. The full canonical dataset — every comment on Docket FS-2025-0001 — is available from Regulations.gov: https://www.regulations.gov/bulkdownload.

Roadless.org — analysis of the public comment docket.
Media inquiries welcome — nicholas@wanderingnature.com.

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