FS-2025-0001-607872

To Whom This May Concern: I must voice my concern and objection, whole heartedly, to the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B). I have read the Department’s objectives and feel that any final rule must safeguard The Tongass National Forest in Alaska. The Tongass needs evaluation on its own terms rather than funneled into a fixed and immovable nationwide rollback. This is wrong on several levels. The Tongass is a coastal temperate RAINFOREST, not an interior, dry, or western type forest. Further, it does not have the fuel accumulation or catastrophic fire behavior this rescission has been used to justify exempting The Tongass from The Roadless Rule. Extending a rationale rooted in wildfire and fuel-load management, to a forest with an entirely different ecology, is disastrously inconsistent (also incorrect) with the Department's own reasoning. USDA needs to provide forest-specific evidence showing how its wildfire/forest-health rationale actually applies to The Tongass, and where it does not. The Tongass should be removed from the final rescission. While my central concern in these comments is The Tongass, the rule-making is national in scope. The 2001 Roadless Rule protected roughly 58.5 million acres of inventoried roadless land across the National Forest System. Under this new proposal, essentially all of it, aside from the existing state-specific rules for Idaho and Colorado, would lose federal roadless status. This proposed rescission reaches ecologically important land far outside Alaska: old-growth and roadless terrain in the Pacific Northwest, high-elevation backcountry throughout the Rocky Mountains, Sierra Nevada roadless areas in California, and roadless tracts in the Southern Appalachians. By USDA's own estimates, up to 18.2 million acres would become eligible for new permanent roads, 4.8 million acres of forest would open to expanded timber harvest, and 9.8 million acres of wilderness-urban interface would become newly eligible for fuel treatment. This would have impacts that extend well past the regions where the wildfire rationale might reasonably apply. I raise this to show that a single, nationwide justification risks being applied to forests it was never built for—and The Tongass, as a temperate rainforest, rather than a fire-prone western forest, is the starkest example. The USDA should perform forest-specific analysis for every affected forest. The Tongass is among the most significant such interests anywhere in the National Forest System: It holds an old-growth, temperate rainforest that serves as a major carbon sink and Tribal representatives have raised this directly in consultation, along with the need for an ANILCA Section 810 subsistence analysis before any decision. It provides critical habitat for bald eagles and other species that depend on intact, un-fragmented old growth and undisturbed watersheds. Its salmon-bearing watersheds and subsistence resources are directly linked to the well-being, food security, and cultural practices of Tribal and Alaska Native communities. These are concrete, well-documented interests specific to this landscape, and USDA is obligated to weigh them accordingly. The Tribal consultation record already favors continued protection. USDA's own consultation summary reflects that most Tribal governments opposed the proposed rescission, viewing it as a threat to inherent rights, Tribal sovereignty, cultural continuity, and the ecological integrity of ancestral homelands, with inadequate government-to-government consultation cited as a central concern. Substantial weight must be given to the documented opposition of the Tribal governments consulted on this rule-making. Conduct comparable forest-specific impact analysis for other significantly affected national forests, rather than relying on one blanket nationwide rationale for all 58.5 million acres covered by this rescission. I have traveled in and around Alaska, and had the great fortune to have visited and hiked in The Tongass. I ask that The Tongass National Forest be removed from any final rescission of roadless protections or, at minimum, adopt a Tongass-specific management framework grounded in scientific ecological knowledge and Tribal co-stewardship. Thank you for consideration of my deep concern for all forests of this nation that have historically been pillaged without careful forethought to the consequences -- all in the name of “maximizing potential” of our precious environmental treasures. The Tongass is absolutely one of those gems and deserves all the protections that The Roadless Rule has provided in the past. We must think of the future of this planet and what generations to come will have been left to discover and marvel at. I implore the USDA to, please, take care of our lands. Stop the exploitation. They need and deserve protection. Wendy Stoner-Lincoln Wiscasset, Maine