This report provides a summary of written public comments received for the Roadless Area Conservation Rule; National Forest System Lands in Alaska (Alaska-Specific Roadless Rule). The 45-day public comment scoping period following the Aug. 30, 2018 publication of the Notice of Intent of Proposed Rulemaking in the Federal Register (83 FR 44252) ended Oct. 15, 2018. This report captures consistent and frequent comment themes found in the range of perspectives in written comments received, but is not exhaustive of all written comments. Please refer to the original letters located in the project reading room (https://cara.ecosystem-management.org/Public//ReadingRoom?Project=54511) for additional written public comment detail.
The overall objectives of this report are to:
- Aggregate and summarize public comment themes.
- Identify input for developing the draft environmental impact statement.
- Identify other public concerns relevant to Alaska-Specific Roadless Rulemaking.
This report addresses these objectives throughout the following substantive sections:
- Public Comment Overview
- 2001 Roadless Rule
- Alaska-Specific Roadless Rule
- Southeast Alaska Timber Industry
- Roadless Area Management Recommendations
- Additional Scoping Period Comments
In August 2018, the U.S. Department of Agriculture (USDA) initiated an environmental impact statement (EIS) and public rulemaking process to address the management of inventoried roadless areas on the Tongass National Forest within the State of Alaska. This rulemaking is the result of a petition submitted by Governor Bill Walker’s administration in January 2018 on behalf of the State of Alaska, pursuant to the Administrative Procedures Act. The petition was accepted by the Secretary of Agriculture in April 2018. The intent is to evaluate the regulatory exemption set forth in the petition, as well as to evaluate other management solutions that address infrastructure, timber, energy, mining, access, and transportation needs to further Alaska’s economic development, while still conserving roadless areas for future generations. The Draft Environmental Impact Statement is estimated to be released in early summer 2019, to be followed by another public comment period. The Final Environmental Impact Statement is estimated to be released in spring 2020, with a final rule expected in June 2020.
Section 1 – Public Comment Overview
During the public comment scoping period following the Aug. 30, 2018 publication of the Notice of Intent of Proposed Rulemaking in the Federal Register (83 FR 44252) which ended Oct. 15, 2018, just over 144,000 entries were logged. This total quantity includes:
- Form letters: 32,500
- Petitions: 110,000 signatures
- Unique submissions: 1,400
The majority of comments received opposed changing the 2001 Roadless Area Conservation Rule (hereafter the 2001 Roadless Rule) for Alaska.
Commenters provided both support for and opposition to the three general alternatives for the proposed Alaska Roadless Rule identified in the Notice of Intent. These general alternatives and a summary of comments supporting and opposing each alternative are listed below.
- A No Action Alternative – the 2001 Roadless Rule remains in effect on the Tongass National Forest.
- No Action Alternative Support – Supporters of the current 2001 Roadless Rule, equivalent to the no action alternative, stressed concerns the Tongass National Forest’s ecosystem cannot support additional resource extraction and agency efforts should turn towards restoration of forest to a more pristine state.
- No Action Alternative Opposition – Commenters who are opposed to the 2001 Roadless Rule generally noted that the current rule is too restrictive for certain industries that rely on the Tongass National Forest to exist. They also state that current regulations and policies, such as the Tongass Land and Resource Management Plan, provide sufficient environmental protections.
- A Full Exemption Alternative — the 2001 Roadless Rule no longer applies to the Tongass National Forest.
- Full Exemption Support – Supporters of the full exemption alternative generally indicated the economic stability of Alaska is dependent on resource extraction and the Tongass National Forest can support both resource extraction and a thriving ecosystem.
- Full Exemption Opposition – Commenters opposed to the exemption alternative were generally supportive of maintaining current regulations, or making those regulations more restrictive, citing environmental concerns.
- An Alaska-specific Roadless Rule – an alternative
management regime for Alaska roadless areas.
- Alaska-Specific Roadless Rule Opposition – Commenters opposed to the Alaska-Specific Roadless Rule cited concerns that any change to the 2001 Roadless Rule (for Alaska) are unnecessary and not in the best interests of Alaska residents, industries that rely on the Tongass National Forest’s natural setting and environment, or the Tongass National Forest’s ecosystem.
- Alaska-Specific Roadless Rule Support – Commenters providing support for the Alaska-Specific Roadless Rule generally stated Southeast Alaska’s ecosystem and economy are dependent on the Tongass National Forest and should not be managed in the same way as other national forests.
Section 2 – Application of Existing 2001 Roadless Rule
The majority of comments received supported the existing 2001 Roadless Rule as expressed by support for a no action alternative or as opposition to the Alaska-Specific Roadless Rule or full exemption alternatives. The rationale for continuing to support the 2001 Roadless Rule is wide-ranging, but generally included the following themes. Additional detail about each theme follows this list.
- Existing 2001 Roadless Rule does not inhibit community development and economic growth.
- Tongass National Forest is of greater benefit to Alaskans as an intact ecosystem.
- Tongass National Forest is important to climate stabilization through carbon sequestration.
- Tongass National Forest should be respected as home to the Alaska Native community.
- Road construction and resource extraction are destructive to habitat.
- Maintenance of 2001 Roadless Rule is vital to tourism and fishing industries.
- Concern over purpose and need to modify the 2001 Roadless Rule.
Theme 1 – 2001 Roadless Rule Does Not Inhibit Community Development and Economic Growth
Commenters who wrote in support of the existing 2001 Roadless Rule stated the following reasons for their support of a no action alternative:
- 2001 Roadless Rule was adopted after intense analysis, thorough discussion, and with public support.
- 2001 Roadless Rule provides necessary protection for Tongass National Forest ecological health.
- 2001 Roadless Rule provides adequate opportunities for existing industries to continue operations within the Tongass National Forest and to initiate and develop new projects important for Southeast Alaska communities, and therefore does not inhibit community development and economic growth.
- Changes to the 2001 Roadless Rule would negate progress that has been made since implementation and set a negative precedent for enforcing environmental conservation regulations across the United States.
Theme 2 – Importance of the Tongass National Forest as an Intact Ecosystem
Commenters expressed support for maintaining the 2001 Roadless Rule on the Tongass National Forest because the forest is of greater benefit, locally and globally, as an intact ecosystem. Many commenters spoke specifically about the uniqueness of the Tongass National Forest as one of the last remaining old-growth temperate rainforests and this uniqueness should be protected. Additional benefits of the Tongass National Forest as an intact ecosystem include:
- Providing habitat to many plant and animal species, including some that are sensitive, threatened, or endangered.
- Clean water and habitats provided to fish and wildlife are essential to the ecological and economic health of Southeast Alaska communities and residents.
- Cultural significance to Alaska Native people.
- Providing spiritual and emotional benefits to residents and visitors.
- Effect on climate change by providing carbon sequestration benefits.
Theme 3 – Tongass National Forest is Essential to Climate Stabilization
Comments that were received in support of maintaining or increasing 2001 Roadless Rule protections on the Tongass National Forest were primarily centered on the function of the forest as a carbon sink. Comments provided views on both the benefits of old growth forests as a means of carbon sequestration in aiding climate stabilization, and the potential threat to the environment that could be posed if trees were utilized in a manner that released stored carbon to the atmosphere.
Theme 4 – Tongass National Forest as Home to Alaska Native People
Comments were received from members of Alaska Native Tribes indigenous to the Tongass National Forest, as well as from members of the public not affiliated with a Tribe, expressing concern that an increase in road construction, timber harvest, and industrial development on the forest would harm the cultural livelihood and spiritual well-being of Alaska Native Tribes, communities, and individuals. Related comments highlighted the vital role the Tongass National Forest plays in indigenous communities, for the harvest and use of natural resources for food, shelter, clothing, transportation, handicrafts, and trade, and also as a source of cultural and spiritual well-being.
Theme 5 – Road Construction and Resource Extraction is Destructive to Fish and Wildlife Habitat
Commenters in support of the 2001 Roadless Rule often discussed the negative impacts road construction, logging, and resource extraction have had on wildlife habitat across the Tongass National Forest and elsewhere. Highlighted negative effects generally included the following:
- Fragmentation of habitats by roads.
- Water quality impacts from sedimentation and polluted industrial runoff.
- Physical destruction of habitat.
- Long-term habitat impacts related to stem exclusion, loss of winter habitat, and other habitat concerns.
Commenters further stressed that fish and wildlife habitats cannot be easily recovered once physically destroyed by road construction or resource extraction.
Theme 6 – 2001 Roadless Rule Protections Support Tourism and Fishing Industries
Commenters noted industries, such as tourism, outdoor recreation, and commercial fishing provide a greater economic contribution to the economy of Southeast Alaska than the timber industry. Examples of how protections provided by the 2001 Roadless Rule are necessary for these industries and have supported Southeast Alaska communities include:
- Protecting habitat for commercial outfitter/guide activities such as hunting, fishing, and wildlife viewing.
- Protecting watersheds for commercial and subsistence fishing.
- Protecting landscapes that visitors come specifically to Southeast Alaska to view.
- Protecting species such as brown bears and bald eagles that visitors come to Alaska to view.
- Protecting unbroken wilderness and other wild landscapes that provide unparalleled opportunities for outfitter and guided outdoor recreation and ecotourism.
Theme 7 – Concern over Purpose and Need to Modify the 2001 Roadless Rule
Though comments in support of the 2001 Roadless Rule generally discussed the benefits of protecting the Tongass National Forest from road construction and timber harvest, commenters also expressed concerns about reconsideration of these protections. Comments varied, but generally included the following concerns:
- USDA Forest Service decisions favor corporations and industry.
- Any modifications that weaken restrictions appear to be driven by politics and industry pressure, not by science or public input.
- Southeast Alaska resident concerns, perspectives, and requests are not being given due consideration.
Commenters also noted that 2001 Roadless Rule regulations do not entirely prohibit road construction and timber harvest, referencing projects needed for Southeast Alaska economic growth and community stability that have been approved since implementation of the 2001 Roadless Rule.
Section 3 – Full Exemption From the 2001 Roadless Rule or Alaska-Specific Roadless Rule
The minority of comments received supported full exemption or modifying the 2001 Roadless Rule to create an Alaska-Specific Roadless Rule. These supporting comments were generally based on the benefits of increasing access or reducing the negative impacts of geographic isolation, including these themes. Additional detail about each theme follows this list.
- Remove 2001 Roadless Rule Application from Alaska
- Increased economic stability
- Utility access to remote areas
- Resource extraction
- Forest management
- Unique forest requires unique regulation
In addition to access, comments emphasized the Tongass National Forest’s unique physical and cultural landscape as a standalone reason for creating an Alaska-Specific Roadless Rule.
Theme 1 – Remove 2001 Roadless Rule Application from Alaska
Commenters stated local regulations and policies currently in place, such as the Tongass Land and Resource Management Plan, provide sufficient environmental protection while allowing industrial development and economic progress. These commenters generally did not request an exemption, but stated that the 2001 Roadless Rule should not be applied in Alaska.
Theme 2 – Roads Required for Economic Stability
Comments in support of modifying the 2001 Roadless Rule point to impacts on Southeast Alaska communities resulting from implementation of the Rule across the Tongass National Forest. Ways in which commenters described the negative impacts of the 2001 Roadless Rule on Southeast Alaska’s economy include:
- Limiting ability of rural communities to supplement income due to limited access to hunting and fishing grounds.
- Inhibiting development of renewable energy industries such as hydropower, wind power, and geothermal resources.
- Limiting resource extraction opportunities, which decreases job opportunities.
- Causing dependence on the tourism industry, which does not provide as much individual income as resource extraction employment.
- Forcing resource extraction and logging operators to reduce employment opportunities by relocating operations outside Alaska.
- Limiting access for tourism and commercial fishing projects.
Theme 3 – Community Isolation Increases Utility Rates
Commenters indicated the lack of road access has inhibited the ability of utility companies to expand to more remote locations. As a result, isolated communities have older utility systems or the cost of providing or servicing utilities that meet current standards is significantly higher than in areas with road access.
Theme 4 – 2001 Roadless Rule Negatively Impacts Resource Extraction Industry
Commenters in support of the economic benefits that resource extraction industries provide to Southeast Alaska indicate the 2001 Roadless Rule limits the viability of these industries, primarily through restricted access for the mining industry and restricted access and prohibitions on timber removal for the timber industry.
Theme 5 – Roads are Beneficial for Reasons Other than Industry
Commenters indicated access to the Tongass National Forest is required for environmental benefits including:
- Fire prevention management.
- Culling of over-ripe wood.
- Forest health management (i.e., removing deadfall from streams, addressing fungal problems).
- Access for tourists and those seeking outdoor recreation opportunities.
Theme 6 – Unique Forest Requires Unique Regulation
Whether in support of an Alaska-Specific Roadless Rule or removal of applicability of the 2001 Roadless Rule to the Tongass National Forest, commenters often highlighted the uniqueness of Southeast Alaska as a standalone reason for modified regulation. Commenters indicate the one-size-fits-all-approach (i.e., 2001 Roadless Rule) is not an appropriate management alternative due to the unique physical, ecological, and socioeconomic nature of the Tongass National Forest; others believe the people of Alaska should be the deciding factor in balancing resource management and environmental protection.
Section 4 – Southeast Alaska Timber Industry
Commenters specifically responded to the section of the Notice of Intent that identified potential accommodations that could be made for timber harvesting. Responses generally opposed Tongass National Forest timber harvest increase. The most notable reasons for this opposition included the following themes. Additional detail about each theme follows this list.
- Need for federal government and taxpayer subsidies.
- Timber industry as a minor economic contributor to Southeast Alaska’s economy.
- Export of Tongass National Forest timber to overseas markets impacts local employment.
- Timber industry decline impacted Southeast Alaska’s economy.
Theme 1 – Opposition to Subsidizing the Timber Industry
Commenters specifically referred to federal government subsidization of timber sales as a reason for opposing the effort to create an Alaska-Specific Roadless Rule.
Theme 2 – Timber Industry Makes Limited Contributions to the Southeast Alaska Economy
In addition to opposing subsidized timber sales, commenters who discussed timber industry accommodations generally stated Tongass National Forest timber harvest is no longer economically viable or necessary. Many commenters provided recent and historical statistics on the costs and benefits of timber operations to demonstrate the industry does not support regional or local economies. Others highlighted industries, such as tourism, outdoor recreation, and commercial hunting and fishing, provide significantly more benefits to the economy than timber, to the extent that ceasing timber operations entirely would be likely to have negligible effects overall.
Theme 3 – Overseas Timber Exports Impact Employment
Commenters indicated the timber industry does not provide significant employment in Southeast Alaska. These commenters generally indicated harvesting timber from the Tongass National Forest to ship to overseas markets does not provide enough benefit to Alaska to balance the ecological cost of forest impacts.
Theme 4 – Timber Industry Decline Impacted Southeast Alaska’s Economy
Comments supporting accommodations for the timber industry referenced the overall potential benefit for Southeast Alaska’s economy. These comments generally stated decline in timber harvest since 2001 Roadless Rule implementation has been detrimental to Southeast Alaska in the following ways:
- Significant job loss.
- Population decline.
- Increase in criminal behavior.
- School enrollment decline.
Section 5 – Roadless Area Management Recommendations
Commenters provided input regarding management options to be considered or incorporated into an Alaska-Specific Roadless Rule, including the following themes. Additional detail about each theme follows this list.
- Alternatives related to timber harvest
- Protection for Tongass 77 watersheds, The Nature Conservancy (TNC)/Audubon Priority Conservation Areas, and the Chugach National Forest
- Focus on sustainable industries
- Forest Service focus in managing the Tongass National Forest
- Requests for specific locations to be designated and protected as roadless
- Road construction allowances under specific circumstances
- Use of existing regulations as a template for modifications
Theme 1 – Alternatives Related to Timber Harvest
Commenters acknowledged the historical role the timber industry has played in Southeast Alaska’s economy. These commenters also provided suggestions specifically tailored to support future Tongass National Forest timber management and Southeast Alaska communities. Examples of these suggestions include:
- Cease old-growth timber harvest and focus on young-growth.
- Assist small local mills in converting to processing second-growth growth timber.
- Restrict logging operations to those areas in which roads have already been constructed.
- Focus timber harvest on dead and diseased trees.
- Conduct thinning in clear-cut areas.
- Rotate logging operations in those areas that have already been logged, or access logging sites by helicopter rather than road, and do not log in new areas.
- Allow only timber harvest activities that have been thoroughly reviewed by all parties affected.
Theme 2 – Tongass 77 Watersheds, TNC/Audubon Conservation Areas, and Chugach National Forest Protection
Commenters specifically requested areas known as the Tongass 77 watersheds and TNC/Audubon Conservation Priority Areas remain protected under the 2001 Roadless Rule or receive increased protections. Most of these requests explained watersheds in these areas are vital to the Tongass National Forest ecosystem and the Southeast economy as they contain a substantial portion of Alaska’s salmon, char, and trout spawning and rearing habitat. Comments were also received specifically requesting the Chugach National Forest continue to be protected under the 2001 Roadless Rule.
Theme 3 – Focus on Sustainable Industries Rather than Resource Extraction
Commenters who opposed changes to the 2001 Roadless Rule either requested additional restrictions be placed on resource extraction (i.e., logging, mining) or requested all resource extraction activities on the Tongass National Forest be prohibited. General suggestions for any modifications to allow Tongass National Forest road construction focused on more sustainable industries including tourism, outdoor recreation, and commercial fishing and hunting. Several commenters also provided suggestions for the use of taxpayer funds on the Tongass National Forest, requesting tax revenue funds be invested in existing road maintenance, trail and recreation cabin maintenance, fire prevention, and watershed and habitat restoration.
Theme 4 – Forest Service Focus in Managing the Tongass National Forest
Although commenters generally focused on activities they would prefer be allowed or prohibited across the Tongass National Forest, several provided input suggesting adjustments to Forest Service land management practices. These suggestions were varied, but generally included the following themes. Additional detail about each theme follows this list.
- Employ local loggers in watershed and habitat restoration efforts.
- Focus on proactive forest management.
- Develop primitive and semi-primitive recreation programs.
- Conduct watershed development and restoration.
- Restore fish and wildlife habitat.
- Conduct maintenance on existing road and trail systems.
- Engage the community and be more collaborative in making decisions that affect the forest.
- Invest in workforce development.
- Invest in community education to minimize ecosystem impacts from all forms of forest-management activity.
Theme 5 – Location-Specific Requests
Commenters requested specific geographic areas remain protected under the 2001 Roadless Rule, or receive increased protection as a potential Alaska Roadless Area, citing several reasons including protection of watershed and habitat, aesthetics and outdoor recreation, and availability of fish and game for subsistence lifestyle maintenance. All lands identified in the 2003 Supplemental Environmental Impact Statement (for the Tongass Land and Resource Management Plan revision) and nearly 200 specific geographic locations, spanning Southeast Alaska, were noted as needing additional protections.
Commenters also recommended several locations be removed from inventoried roadless areas with specific rationale related to connecting existing roads, developing hydroelectric projects, and to fully implement local and state government transportation plans.
Theme 6 – Conditional Activities
Comments related to activities on the Tongass National Forest generally focused on what should be allowed or prohibited. Some commenters provided additional suggestions for allowing activities under certain management conditions, including:
- Use of all-terrain vehicles for subsistence or recreation
- Development of hydroelectric power facilities under strict regulations focused on preservation of the ecosystem
- Logging operations that have undergone thorough community review, specifically for effects on salmon habitat
- Mining in areas that do not impact subsistence activities
- Infrastructure development assessed in relation to natural characteristics of existing landscape and ecosystem
- Projects that have undergone an elevated level of scrutiny, to include a cost-benefit analysis and/or conclusion that there would be no detriment to the Tongass National Forest ecosystem
Theme 7 – 2001 Roadless Rule Modification Based on Existing Regulations
Comments discussed regulations, policies, or practices currently in place for the management of roadless areas, both in the Tongass National Forest and nationwide. These comments requested that the Forest Service look to these regulations and policies — such as the Tongass Land Management Plan, state regulations in Colorado and Idaho, and the forest practices of the Menominee tribe — for guidance in developing roadless area regulations for the Tongass National Forest.
Section 6 – Additional Scoping Period Comments
Comments were received that discussed general viewpoints about an Alaska-Specific Roadless Rule, the rulemaking project scoping process, National Environmental Policy Act-related analysis and information, and other general input regarding the development of an Alaska-Specific Roadless Rule. Additional detail about each theme follows this list.
- Public process.
- Requests for specific analysis and information.
Theme 1 – Scoping Process Comments
Comments were received that expressed disappointment with the scoping process. Some of these comments reflected concern over the purpose and need for modifications to the 2001 Roadless Rule, and that the interests of the residents of Southeast Alaska and visitors to the Tongass National Forest receive appropriate consideration. Other comments spoke to the public comment process, specifically, and indicated displeasure there were not more public meetings or that the comment period was not of sufficient duration to allow full consideration. Comments related to the State of Alaska’s Citizen Advisory Committee were also received and reflected the view the committee had more industry representatives than members of the public – and a single Tribal member was designated to represent the interests of all Southeast Alaska Tribes.
Theme 2 – Requests for National Environmental Policy Act Analysis and Related Information
In response to the Notice of Intent’s discussion of issues that should be “analyzed in depth in the Draft EIS,” several comments requested that specific analyses be conducted or information be included in the environmental impact statement. Examples of these requests include the following:
- Impact on Alaska Native cultures and Tribal governments
- Biological assessments
- Fish and wildlife impacts
- Cost-benefit analysis of timber sales and road construction
- Information on taxpayer subsidies
- Cost of timber industry versus ecosystem service benefits
- Full disclosure of the economic value of the Southeast Alaska timber industry
- Increase in potential for fire risk
- Effect on local industries, especially commercial fishing and tourism
- Special use permit information and effects
- Effect on rural communities that rely on subsistence resources
- Assessment of State of Alaska’s Citizen Advisory Committee member appointments
- Effect of restoring roadless areas in which roads were previously constructed
- Impact to the Forest Service budget of implementation of the alternatives
- Net economic benefit to Southeast Alaska communities