Comment Analysis · Docket FS-2025-0001

FS-2025-0001-610751

Supports rescissionA1 strongSubstance 8/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the 2001 Roadless Rule conflicts with prior congressional designations under ANILCA and TTRA, has caused severe economic and employment losses in Southeast Alaska, and restricts access to mineral and energy resources, thereby supporting the rescission of the rule specifically for the Tongass National Forest.

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

A1 strong: Must be answered — it names the law.

Owed an answer on Legal.

Standard dismissals it defeats

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.
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.
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.

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.
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.

Topics

Economic Impact Fiscal
- “timber employment in Southeast Alaska is now a fraction”
- “damaged the social and economic fabric of communities”
- “support local employment, including year-round timber manufacturing jobs”
- “give Southeast Alaska communities a real chance at economic stability”
Resource Development Extraction
- “stands in the way of mineral and energy development”
- “volcanogenic massive sulfide deposits that contain critical and rare earth minerals”
- “more than 200 potential hydropower sites”
- “access to these resources depends on the subjective judgment”
Legal Regulatory Framework
- “consistent with Executive Order 14192”
- “implements Executive Order 14153”
- “conflicts with both ANILCA and TTRA”
- “fails to protect access rights established in law”
Governance Policy Process
- “forest planning process designed to weigh conservation and use on a forest-by-forest basis”
- “one-size-fits-all national rule”
- “subjective judgment of individual Forest Service officials”
- “creates uncertainty that discourages investment”

What it names

National Forests: Tongass National Forest
Law cited: Executive Order 14153 Executive Order 14192

The comment

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

To the U.S. Forest Service: I write in strong support of rescinding the 2001 Roadless Area Conservation Rule, particularly as it applies to the Tongass National Forest. [Personal line, e.g.: "As a lifelong Alaskan who has worked for decades on resource development in this state, I have seen firsthand what this rule has cost Southeast Alaska communities."] Rescission is consistent with Executive Order 14192, Unleashing Prosperity Through Deregulation, which directs agencies to remove overly complicated and burdensome barriers to American business and innovation. It also implements Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, which specifically directs the Forest Service to exempt the Tongass from the Roadless Rule. The Roadless Rule's blanket prohibitions were never necessary on the Tongass. When Congress enacted the National Forest Management Act in 1976, it established a forest planning process designed to weigh conservation and use on a forest-by-forest basis. That process is fully capable of protecting the Tongass's important ecological values without a one-size-fits-all national rule. Congress has also already struck the balance on the Tongass. Before the Roadless Rule was adopted, Congress designated more than 6.6 million acres of the forest as Wilderness and other restrictive land use categories through the Alaska National Interest Lands Conservation Act (ANILCA) and the Tongass Timber Reform Act (TTRA). The lands Congress left out of those designations were left out deliberately, so they could support local employment, including year-round timber manufacturing jobs in a region where almost no state or private timberland is available to supply the mills. The Roadless Rule effectively overrode that congressional judgment, and in doing so it conflicts with both ANILCA and TTRA. The consequences have been severe. Sustainable timber harvests on the Tongass have plummeted, and timber employment in Southeast Alaska is now a fraction of what it was before the rule took effect. The loss of these jobs has damaged the social and economic fabric of communities that have few alternatives for year-round work. The rule also stands in the way of mineral and energy development that matters to the entire nation. The Tongass is highly mineralized, including volcanogenic massive sulfide deposits that contain critical and rare earth minerals needed for national security. Southeast Alaska also has more than 200 potential hydropower sites that could provide clean, affordable, renewable power to the region. Under the Roadless Rule, access to these resources depends on the subjective judgment of individual Forest Service officials. The "reasonable access" the rule guarantees to mining claims does not necessarily mean road access. A Forest Supervisor can instead require costly helicopter access, an outcome that the authors of the Mining Act of 1872 could never have contemplated. Leaving it to an individual official to decide what access is "reasonable," or when a road is "needed," creates uncertainty that discourages investment and fails to protect access rights established in law. Finally, the practical footprint of rescission is modest. Rescinding the rule would make only about 186,000 additional acres of the 16.9-million-acre Tongass available for timber harvest, roughly 1 percent of the forest. That is a small and reasonable change that would restore the balance Congress intended and give Southeast Alaska communities a real chance at economic stability. I urge the Forest Service to finalize rescission of the 2001 Roadless Rule. Sincerely, Sarah Ward Anchorage, AK