Comment Letter on Repeal of the Roadless Rule FS-2021-0007-0006

RDC Action Alert 

January 24, 2022 

Submitted via www.regulations.gov

Re: Special Areas; Roadless Area Conservation: National Forest System Lands in Alaska, FS-2021-0007-0006 

Dear Mr. Krueger:

The Resource Development Council for Alaska, Inc. (RDC) is writing to urge you to maintain a full exemption of the Tongass National Forest from the 2001 Roadless Rule as promulgated in a final rule in 2020 on the Alaska Roadless rulemaking process. 

RDC is an Alaskan trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor, and industry support firms. 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 maintaining a total exemption as promulgated in the final rule in 2020, 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 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. A one-size fits all rule does not account for Alaska’s uniqueness, needs, and limited surface infrastructure.

The 2001 Roadless Rule prohibitions are unnecessary in 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 (NFMA). The nationwide Roadless Rule usurped much of the land planning process mandated by the NFMA, particularly in Alaska. Exempting the Tongass from the Roadless Rule will not authorize any development activities, but it will enable the NFMA planning process to function as intended. Congress has already 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 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.

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 sustainable 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. 

Thank you for the opportunity to comment on this vital issue important to Alaska’s economic future.