Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606388

Opposes rescissionA3 weakSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

Small family — One letter sent by 3 to 9 people, copied or lightly reworded. This comment stands for 4 submissions in its group; the sender added words of their own. See the letter, its submissions and topics.

Carries the letter's score — A copy of a family's letter; it holds the score and answerability level of the letter it sent.

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. This rating is the one its shared letter earned.

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.
  • 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

  • Environmental Protection Biodiversity
    • “safeguarded the world's largest intact temperate rainforest”
    • “intact and healthy ecosystems”
    • “restoration, protection, and maintenance of the health of the ecosystems”
  • Economic Impact Fiscal
    • “industries built up around these same resources - sport fishing, guiding and hunting, commercial fishing, and tourism”
    • “fiscally irresponsible”
    • “subsidized the Tongass timber program at a rate of over $25 million per year”
  • Recreation Tourism Public Use
    • “fishing, hiking, camping, and reveling in the wonder of public lands”
    • “recreation and tourism opportunities that anchor the regions largest private sector industry”
    • “recreation infrastructure”
  • Cultural Heritage Indigenous
    • “subsistence and recreation driven by the wildlife and fish”
    • “subsistence harvesters have repeatedly testified through ANILCA 810 hearings”
    • “reduced subsistence opportunity and productivity”

What it names

National Forests
Tongass National Forest

The comment

Dear Joshua White, I was born and raised in Anchorage, Alaska, in a family shaped by the health and wellbeing of our lands. My childhood memories are full of fishing, hiking, camping, and reveling in the wonder of public lands. I have spent much of my adult life in these same places, and have grown to have a close relationship with the Tongass through my family purchasing and tending to 75 acres of land immediately adjacent to the national forest on Kupreanof Island. It is a deep and precious privilege to be shaped by the places we spend our time together, and to care for them for the rest of my life. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. I have had the experience of living in places across the West coast, and have known what it means to have no connection or proximity to intact and healthy ecosystems. It is an astoundingly precious thing to know what a place is like when it is whole, abundant, and cared for. The Tongass is singular in this regard, and the value of that touches so many dimensions of Alaskan and American life. From the subsistence and recreation driven by the wildlife and fish who call the forest home, to the industries built up around these same resources - sport fishing, guiding and hunting, commercial fishing, and tourism. These industries are sustained in perpetuity, consistently and reliably in a way that few if any other industries in our state are. To consider any action which would disturb or threaten these industries would be a grievous mistake, and one that Alaskans would be left to bear the brunt of. The prospect of building road systems and increased scale of logging would undeniably hurt the exact realities which make this place so valuable. I ask the Forest Service to retain the roadless rule. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. If anything, the greatest priority the Forest Service could hold is the restoration, protection, and maintenance of the health of the ecosystems and populations which inhabit the Tongass and other roadless areas within our National Forests. I say so with much gratitude for the work which has already been done, and the hope that this work will continue for generations. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Jonas Banta

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