Comment Letter on the Alaska Roadless Rulemaking in the Tongass National Forest

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March 21, 2019

The Honorable Sonny Perdue
Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Avenue, S.W.
Washington, D.C. 20250

Re: Alaska Roadless Rulemaking in Tongass National Forest

Dear Secretary Perdue:

The Resource Development Council for Alaska, Inc. (RDC) is writing to urge you to select full exemption of the Tongass National Forest from the 2001 Roadless Rule as the Preferred Alternative in the Draft Environmental Impact Statement (DEIS) on the Alaska Roadless rulemaking process. 

RDC is a statewide business association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism industries. RDC’s membership includes all 12 land-owning Alaska Native corporations, local communities, organized labor, industry support firms, and thousands of Alaskans supporting responsible development of Alaska’s natural resources. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

By selecting a total exemption as the Preferred Alternative in the DEIS, your office would be maintaining the policy determination made by the U.S. Department of Agriculture (USDA) in 2003 and again in 2010. The rationale used for exempting the Tongass from the Roadless Rule 15 years ago has not changed and remains valid today. The one-size-fits-all rule has caused extensive damage to the economic and social fabric of Southeast Alaska communities and has decimated the forest products industry. 

The Preferred Alternative supporting a full exemption to the national rule is the best approach supporting the State of Alaska’s petition for rulemaking and the Purpose and Need statement in which the Forest Service began the process. Further, alternatives that remove Roadless designations in forest development Land Use Designations (LUDs) described in the Tongass Land Management Plan (TLMP) need to focus on “economic acres,” not just total acres removed. All forest development LUD acres do not produce economic timber projects and this is a key metric to consider as the analysis of the alternatives are made. Finding and producing enough economic timber sales to sustain the forest products industry is not feasible under the current rule and TLMP.

RDC has consistently supported exempting the Tongass from the Roadless Rule. We believe the economic health and longevity of Southeast Alaska would be strengthened if the Tongass were to be removed from the rule and managed as originally envisioned. We believe that tourism, fishing, mining, energy development, and a renewed timber industry can coexist to the benefit of all in the region.

As you know, Alaska and Southeast Alaska are very different than other states under Roadless designations. As a result, a state-specific rule should reflect these differences and unique characteristics. An Alaska-specific roadless rule should allow further road access for not only timber, mineral, tourism, and renewable energy, but access to resources important to residents for subsistence, recreation and other community, economic, cultural, and social activities.

The State of Alaska, the timber industry, and the mining industry continue to support a full exemption from the Roadless Rule in the Tongass. Six Alaska governors, both Republican and Democrat, have requested a total exemption.

In conclusion, RDC supports a healthy timber industry and a robust Southeast Alaska economy. This cannot be accomplished without lifting of the federal Roadless Rule in the Tongass. Application of the rule substantially impacts the social and economic fabric of Southeast Alaska and violates the Alaska National Interest Lands Conservation Act and the Tongass Timber Reform Act. RDC agrees with the State of Alaska that roadless conservation interests for the Tongass can be adequately protected under the TLMP and that the 2001 rule prohibitions are unnecessary.

Please select total exemption as the Preferred Alternative in the DEIS.


Carl Portman

Deputy Director

Senator Lisa Murkowski
Senator Dan Sullivan
Congressman Don Young
Chief Vicki Christiansen
Kyle Moselle