January 24, 2022
The Honorable Tom Vilsack
U.S. Department of Agriculture 1400 Independence Ave.
S.E. Washington, D.C. 20250
Dear Secretary Vilsack
We are writing in support of our millions of members, supporters, and to express our strong support for the U.S. Department of Agricultures proposal to repeal the Alaska-specific Roadless Rule and reinstate the Tongass National Forest’s Roadless Area Conservation Rule (Roadless Rule). We also support three other elements of USDA’s Southeast Alaska Sustainability Strategy (published July 15), which include consulting with Tribes in the region and funding investment opportunities that support Tribal and stakeholder priority.
In 2001, the Forest Service adopted the Roadless Rule to limit road building and commercial logging on more than 58.5million acres of National Forest System land in 38 states, including the Tongass National Forest. The rule gives flexibility for management activities like road connections between communities, hydropower, mining access roads and wildfire response. Over 95 percent supported roadless protections in the more than 1.6 million comments the USDA received during that rulemaking.
The overwhelming majority of 267,000 comments made on the Alaska Roadless Rule Draft EIS supported its continuation, including 96 percent in the 15,909 unique letters that were tabulated and tabulated by Forest Service. According to a 2018 Pew Charitable Trusts Poll, 75 percent of Americans support the 2001 Roadless Rule. It should not surprise that the overwhelming public support for roadless areas is due to their numerous environmental, economic, cultural, climate, and other benefits.
The Tongass National Forest is often referred to the National Forest System’s crown jewel. It is one the most important natural climate solutions we have available to combat climate changes, as the USDA Federal Register notice acknowledges. The Tongass National Forest is home to some of the most extensive areas of old-growth temperate rainforest remaining in the world. It holds between 20 and 25 percent of all carbon in all national forests, and approximately 8 percent of all U.S. forests. The vast majority of carbon in trees and soil, particularly old-growth forests, is released into our atmosphere as a greenhouse gas. According to the Intergovernmental Panel on Climate Changes’ (IPCC) most recent report on climate change, global deforestation is the largest source of carbon emissions from land use sectors. As the climate crisis, biodiversity crisis, and Alaska’s warming rate approach a point of no returns, it is vital that the Biden administration preserve the Tongass National Forest’s rich carbon stock as a model to other nations in order to combat climate change.
Tongass National Forest is also one the most biologically diverse, intact and intact temperate forests on Earth. Its vast, undeveloped areas are a great habitat for Sitka black-tailed and grizzly deer, bald Eagles, all five species Pacific salmon species, and other species that are otherwise endangered or threatened in the lower 48. According to the Intergovernmental Panel on Biodiversity and Ecosystem Services, one million species are at risk of extinction globally due to road building and clearcutting.
Protected roadless areas within the Tongass National Forest, and elsewhere, ensure clean drinking water for local communities. They act as a water filter network that captures rainfall and regulates runoff. This prevents pollutants from reaching waterways. This process can be interrupted by logging and road construction. According to the Forest Service, over 60 million Americans get their drinking waters from sources that are filtered through National Forest lands. The most pure water comes from headwaters that originate in wilderness areas and other roadless areas. The Tongass exclusion by the previous administration was a bad precedent, which could set the stage for additional state-specific rules elsewhere. This could put this valuable ecosystem service at danger for communities across the country.
Economically, maintaining strong roadless protections are also important. The Roadless Rule is an economic tool that saves taxpayers millions of money. It prevents expensive new road building and subsidizes logging. Southeast Alaska is known for its rugged terrain and remoteness, and has some the highest costs. Instead of fragmenting wildlife habitat by building new roads, the Forest Service should direct its limited resources to addressing the 371,000-mile network National Forest System roads, its $3.2 billion maintenance backlog, as well as restoration needs on the Tongass National Forests, which have 1.3 million acres more than any other national forests up and down the West Coast. Roadless area logging could also harm the region’s strong tourism and fishing industries which together contribute 26 percent to jobs and 21 percent to earnings annually. These industries and the entire region’s economic vitality will be supported by the restoration of Roadless Rule protection, particularly to the 2,000,000 acres of unutilized roadless areas in Development Land Use Designations.
During the Alaska roadless rulemaking process, the previous administration ignored the public and failed to consult meaningfully. The Tongass National Forest is home to the Alaska Native Tribes, who have relied upon its resources since the beginning of time and will reap the greatest benefits from the restoration of the Roadless Rule. The previous administration ignored the in-person meeting requests and comments of Alaska Native Tribes and continued with the rulemaking despite the lack any pretense of urgency. Due to the failure of federal governments to engage meaningfully in rulemaking processes with Tribes, several Alaska Native Tribes submitted petitions to USDA asking for new ruleseparate to the Roadless Rule and independent from the Alaska Roadless Rulemaking process. This was to better protect traditional homelands through effective and cooperative engagement with Tribes. In accordance with the expressed wishes of Alaska Native Tribes, and an overwhelming majority of people, the USDA should continue to reinstate the Roadless Rule on Tongass. The USDA should also be focusing its efforts on productive actions that support the Southeast Alaska region. This includes the Tribes request for better cooperative engagement and the collaborative Indigenous Guardians Agreement between the Forest Service of Alaska and Central Council of Tlingit & Haida Indian Tribes of Alaska.
We are reaffirming our support for the reinstatement of the Roadless Rule in Tongass National Forest, and the implementation of the entire USDAs Southeast Alaska Sustainability Strategie. Protecting the Tongass National Forest’s roadless areas and old-growth forests from logging and road construction is both environmentally and economically beneficial. It also protects these forests which have incomparable ecological and economic, recreational, and cultural value. We urge you to follow the wishes of the majority Alaskans, and the American public in general, and restore roadless protections for Tongass National Forest. We appreciate your consideration of these views.