RDC Comment Letter

Dear RDC Members and Supporters,

On August 29, 2025, the U.S. Forest Service (USFS) initiated an environmental impact statement (EIS) and rulemaking concerning management of inventoried roadless areas on approximately 44.7 million acres of National Forest System lands, including in Alaska. The proposed rule would rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244, 36 CFR Subpart B (2001)), which prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions. The USFS has opened a comment period on this action closing on Friday, September 19, 2025. RDC urges you to comment in support of rescinding the 2001 Roadless Rule. 

LINKS:

• Federal Register: https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands#  
  • PDF: https://www.govinfo.gov/content/pkg/FR-2025-08-29/pdf/2025-16581.pdf
• USDA Press Release: https://www.usda.gov/about-usda/news/press-releases/2025/08/27/secretary-rollins-opens-next-step-roadless-rule-rescission
• EO 14153, Unleashing Alaska’s Extraordinary Resource Potential: https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-alaskas-extraordinary-resource-potential/
• EO 14192, Unleashing Prosperity Through Deregulation: https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-prosperity-through-deregulation/
• Previous RDC comments on the 2001 Roadless Rule: https://www.akrdc.org/roadlessrulerepealfs-2021-0007-0006

TALKING POINTS TO CONSIDER IN YOUR LETTER:

• Rescission of the 2001 Roadless Rule aligns with President Trump’s Executive Order 14192, Unleashing Prosperity Through Deregulation to get rid of overcomplicated, burdensome barriers that hamper American business and innovation. It also supports Executive Order 14153, Unleashing Alaska’s Extraordinary Resource Potential which directs the Forest Service to exempt the Tongass National Forest from the 2001 Roadless Rule.
  
  
• The 2001 Roadless Rule prohibitions are unnecessary in places like the Tongass which can be adequately protected through the normal national forest land management process as intended by Congress in 1976 when it enacted the National Forest Management Act. 
  
  

• Congress enacted over 6.6 million acres of Wilderness and other restrictive land use categories prior to the promulgation of the Roadless Rule on the Tongass. The remaining areas, which the Roadless Rule restricts access to, were passed over so they could support local employment, including year-around timber manufacturing jobs in a region where there are minimal state or private timberlands available to the mills. 

• Application of the 2001 Roadless Rule has severely impacted the social and economic fabric of Southeast Alaska communities and violates the Alaska National Interest Lands Conservation Act and the Tongass Timber Reform Act. It has devastated the timber industry where sustainable harvests have plummeted and employment is now a fraction of what it was prior to enactment of the rule. 

• Under the 2001 Roadless Rule, road access to mineral claims has been made reliant on the subjective response to a project by Forest Service officials. The Tongass is a highly mineralized, 16.9-million-acre Volcanic Mass Sulfide (VMS) mining district that contains critical and rare earth minerals which are needed for national security. There are over 200 potential hydropower sites in Southeast Alaska.

• The Roadless Rule is a barrier to road access to mining claims, exploration, and development and hydropower development because the “reasonable access” the Rule provides does not necessarily mean road access. The Forest Supervisor can specify expensive helicopter access (even though there were no helicopters when the Mining Act of 1872 was enacted).  Leaving what is reasonable access up to the responsible Forest Service official to determine what is “reasonable access’ or when a road is “needed” is subjective and does not adequately protect access rights.
  
  
• Rescission of the Roadless Rule would only make an additional 186,000 acres of the 16.9-million-acre Tongass National Forest available for timber harvest, roughly 1%. 

HOW TO SUBMIT COMMENTS: Please submit a written comment SUPPORTING RESCISSION of the rule by September 19, 2025. 

Public comments can be submitted using the following methods:

• Online: Visit https://www.regulations.gov/document/FS-2025-0001-0001/comment, then click the “Comment” icon underneath the title, complete the required fields, and enter or attach your comments.  
• By Mail: Address your letters as follows.

Brad Kinder

Acting Director, Ecosystem Management Coordination

201 14th Street SW, Mailstop 1108, 

Washington, DC 20250–1124.