Comment Analysis · Docket FS-2025-0001

FS-2025-0001-607478

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

In short: The comment documents that the agency's analysis lacks an economic assessment of timber extraction, citing the Tongass Timber Reform Act's elimination of subsidies, and asserts that ANILCA mandates the protection of subsistence resources for rural Alaskan communities.

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

Cultural Heritage Indigenous
- “protection of subsistence resources isn't a discretionary decision”
- “ANILCA clearly establishes these protections as being important to persons who live in rural communities in Alaska”
- “reliance on subsistence resources to sustain communities become more important not less”
- “protecting our subsistence resources for rural residents shouldn't be a second thought”
Governance Policy Process
- “Trump Administration does not have the best interests for the protection of our national resources in mind”
- “connected actions proposed by the Trump Administration”
- “limiting the National Environmental Policy Act (limiting or eliminating public comments)”
- “reversals of policies or laws will all be subject to legal challenges”
Economic Impact Fiscal
- “Missing from the potential impacts of lifting the Roadless Rule is any economic analysis for extracting timber”
- “eliminated the subsidies supporting the timber industry”
- “Without this subsidy it's very unlikely the timber industry will recover much of anything it has lost”
- “lifting the Roadless Rule is not needed to encourage mineral extraction”

What it names

National Forests: Tongass National Forest Tongass National Forest

The comment

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

Bill Tremblay P.O. Box 662 Petersburg, AK 99833 907-772-4461 To whom it may concern; I support the protections of the Roadless Rule. I was a Forest Service employee on the Tongass National Forest when the Roadless Rule was put in place during the Clinton Administration. I opposed the Roadless Rule for the Tongass NF initially because the Tongass had just completed a revision of its Forest Plan and I thought that plan had sufficient Standards and Guidelines to adequate protect the forest resources. I had actually started with initial scoping for the revision of the Forest Plan in 1988 and it took many years, the passage of the Tongass Timber Reform Act, and negotiations with the State of Alaska to produce a final product. When the Roadless Rule was put in place, the Alaska Governor wrote President Clinton directly to say the implementation of the Roadless Rule was a "stab in the back"; which I agreed with. However, I now think the rollback of the Roadless Rule protections is wrong as the Trump Administration does not have the best interests for the protection of our national resources in mind. There are several connected actions that lead me to approving keeping the Roadless Rule in place. First, was the acknowledgement that lifting the Roadless Rule restrictions will likely have an effect on the availability for subsistence resources. The protection of subsistence resources isn't a discretionary decision. The Alaska National Interest Lands Conservation Act of 1980 (ANILCA) clearly establishes these protections as being important to persons who live in rural communities in Alaska. As the Trump Administration takes actions that drive up costs for transportation, services, or products, the reliance on subsistence resources to sustain communities become more important not less. An Alaskan native saying is; "when the tide is out, the table is set". While this is true for persons who have lived here for generations, it's also true for rural residents who rely on resources in the saltwater and on the lands that provide habitat for birds, mammals, and plants that sustain our communities over time. If you look at maps, you'll realize that persons in southeast Alaska live in locations that rely on air or water transportation to receive services. There are no roads connecting our communities to the mainland (Canada) or to other states. Because of this, there is a heavy reliance on local resources. Proposed roads to the mainland have been planned for longer than the four decades I've lived here. However, the costs and difficulty of the terrain makes any road a task that will likely never be funded. Such as it is, protecting our subsistence resources for rural residents shouldn't be a second thought in this decision, it should be a priority. Other reasons for supporting the continuation of the Roadless Rule are based on connected actions. While the instructions note that one should specifically address the Roadless Rule, I can't ignore the connected actions proposed by the Trump Administration that are likely to make the relaxation of the Roadless Rule more impactful then that decision itself. (Having worked with scoping for many environmental analysis and environmental impact statements, (again, for almost 40 years) I know that connected actions are important to be considered in any final decision. While I won't go into much detail, the connected actions proposed by the Trump Administration include the changes to protection of threatened and endangered species (that changes definitions of the taking or harm to a protected or threatened species), the reversal of the Access and Travel Management Policy (that would open the forest to more motorized access by changing the forests back to being "open" rather than "closed"), and limiting the National Environmental Policy Act (limiting or eliminating public comments), The reversals of policies or laws will all be subject to legal challenges since all of them have been put in place through processes that include public input through the Federal Register. You can expect that any lifting of the Roadless Rule or these other policies or laws will command and extensive use of time and resources before they will have any effect. Something else to consider, lifting the Roadless Rule is not needed to encourage mineral extraction on a National Forest. ANICLA already provides "reasonable access" to existing mineral claims and private inholdings. Trying to use this as a talking point is pointless as it already exists. Missing from the potential impacts of lifting the Roadless Rule is any economic analysis for extracting timber from the forest. The Tongass Timber Reform Act of 1990 not only eliminated the two long-term timber sales, it also eliminated the subsidies supporting the timber industry ($45 million/year as allowed in ANILCA). Without this subsidy it's very unlikely the timber industry will recover much of anything it has lost.