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.
input for developing the draft environmental impact statement.
other public concerns relevant to Alaska-Specific Roadless Rulemaking.
This report addresses these
objectives throughout the following substantive sections:
- Public Comment Overview
Alaska Timber Industry
Area Management Recommendations
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
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
- Form letters: 32,500
The majority of comments received opposed changing the 2001 Roadless Area
Conservation Rule (hereafter the 2001 Roadless Rule) for Alaska.
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.
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.
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
Section 2 –
Application of Existing 2001 Roadless Rule
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
- Existing 2001 Roadless Rule does not inhibit community
development and economic growth.
National Forest is of greater benefit to Alaskans as an intact ecosystem.
National Forest is important to climate stabilization through carbon
National Forest should be respected as home to the Alaska Native
construction and resource extraction are destructive to habitat.
of 2001 Roadless Rule is vital to tourism and fishing industries.
over purpose and need to modify the 2001 Roadless Rule.
Theme 1 – 2001
Roadless Rule Does Not Inhibit Community Development and Economic Growth
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.
Roadless Rule provides necessary protection for Tongass National Forest
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.
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
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.
water and habitats provided to fish and wildlife are essential to the
ecological and economic health of Southeast Alaska communities and
significance to Alaska Native people.
spiritual and emotional benefits to residents and visitors.
on climate change by providing carbon sequestration benefits.
Theme 3 – Tongass
National Forest is Essential to Climate Stabilization
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
Theme 4 – Tongass
National Forest as Home to Alaska Native People
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
Theme 5 – Road
Construction and Resource Extraction is Destructive to Fish and Wildlife Habitat
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
- Physical destruction of habitat.
- Long-term habitat impacts related to stem exclusion,
loss of winter habitat, and other habitat concerns.
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
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
- Protecting habitat for
commercial outfitter/guide activities such as hunting, fishing, and
- Protecting watersheds for commercial and subsistence
- 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
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
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
access to remote areas
forest requires unique regulation
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
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
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
Theme 3 –
Community Isolation Increases Utility Rates
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
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
Theme 5 – Roads
are Beneficial for Reasons Other than Industry
indicated access to the Tongass National Forest is required for environmental
- Fire prevention management.
of over-ripe wood.
health management (i.e., removing deadfall from streams, addressing fungal
for tourists and those seeking outdoor recreation opportunities.
Theme 6 – Unique
Forest Requires Unique Regulation
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
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
Theme 1 –
Opposition to Subsidizing the Timber Industry
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
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
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
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
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
- Protection for Tongass 77 watersheds, The Nature
Conservancy (TNC)/Audubon Priority Conservation Areas, and the Chugach
- Focus on sustainable industries
- Forest Service focus in managing the Tongass National
- Requests for specific locations to be designated and
protected as roadless
- Road construction allowances under specific
- Use of existing regulations as a template for
Theme 1 –
Alternatives Related to Timber Harvest
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
small local mills in converting to processing second-growth growth timber.
logging operations to those areas in which roads have already been
timber harvest on dead and diseased trees.
thinning in clear-cut areas.
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.
only timber harvest activities that have been thoroughly reviewed by all
Theme 2 – Tongass
77 Watersheds, TNC/Audubon Conservation Areas, and Chugach National Forest
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
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
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
- 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 –
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.
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
Theme 6 –
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,
- Use of all-terrain vehicles for subsistence or
of hydroelectric power facilities under strict regulations focused on
preservation of the ecosystem
operations that have undergone thorough community review, specifically for
effects on salmon habitat
in areas that do not impact subsistence activities
development assessed in relation to natural characteristics of existing
landscape and ecosystem
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
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
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
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
- Information on taxpayer subsidies
- Cost of timber industry versus ecosystem service
- 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
- Assessment of State of Alaska’s Citizen Advisory Committee
- Effect of restoring roadless areas in which roads were
- Impact to the Forest Service budget of implementation
of the alternatives
- Net economic benefit to Southeast Alaska communities
Alaska Roadless Rule – Scoping Public Comment Summary.pdf