Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The largest intact temperate rainforest left on Earth is my backyard. I grew up as a lifelong Alaskan, and since my parents bought land near Petersburg, the Tongass National Forest has been the wild place I explored and returned to. I have stood next to massive Sitka spruce trees and walked vast stretches of muskeg. I camp there with my family on our property in summer, just a few hundred feet from the forest boundary. Alaska is not the last frontier if it is not wild, and this rescission takes that character away.
The Tongass holds 9,339,575 acres across 110 inventoried roadless areas, over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by US 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. The fish I catch in summer from roadless watersheds are vital for the livelihoods of Alaskans, and the fishing, hunting, and tourism industries that my fellow Alaskans depend on are renewable only as long as the land stays wild.
The agency's own numbers cannot justify this action. The record before the agency states 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." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. I ask the agency to reconcile the proposal with its own Cost Benefit Analysis and explain how an action that cannot establish a net benefit in its own record justifies what follows.
The Sitka black-tailed deer I see in this forest face documented harm from road construction. The agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations in Alaska by preserving old-growth winter shelter. The DEIS cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed, and that the danger is disrupted migration and lost unroaded security. Bears face a parallel threat. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. These are the agency's own cited findings, applied to animals I share this forest with. The agency must explain, with specificity, what equivalent protection replaces the rule for these populations in the Tongass after the exclusion takes effect.
The DEIS also acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent," that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. Wide-ranging mammals have, in the agency's own words, "suffered habitat loss and the extirpation or fragmentation of their populations." The wolves and bald eagles of the Tongass are not abstractions to me. They are part of what makes this place worth protecting. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and enter those projections into the record.
The drinking water question is equally unresolved. The agency states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Petersburg is among the nine municipal watersheds named in the DEIS. The agency also acknowledges that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity," yet no projection of sediment delivery to those intakes follows. The agency must quantify projected sediment delivery to those municipal intakes and identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for the watersheds that will lose roadless protection.
This forest is not an abstraction or a statistic. It is where I am from. I oppose this rescission and expect these questions answered in the final record.
Sincerely,
Joseph Ransdell-Green
Fairbanks, AK