Ask the US Forest Service to continue to protect Alaska’s Tongass National Forest from clearcutting by not adopting its proposed exemption from the Roadless Rule.

Submit your comment to the Forest Service by December 16, 2019. Click here to comment at This proposed rule change to exempt the entire Tongass National Forest from Roadless Rule protection is based on the Forests Service’s Draft Environmental Impact Statement, Alternative 6, found here.

Suggested Comment

The Tongass National Forest (TNF) is the largest intact temperate rainforest in the world. This forest is home to large and varied populations of wildlife and because of its cool wet forest floor stores more carbon per acre than any other forest on earth! At a time when we are threatened by global warming and the extinction of many species this is the last forest that should be made exempt from the Roadless Rule.

The Roadless Rule was adopted by the Forest Service in 2001 to protect our wild areas from development. It banned logging, road building and mineral extraction in the Inventoried Roadless Areas of national forests. It prevents habitat fragmentation and slows down global warming. Exempting the Tongass from this Roadless Rule protection is poor policy.

The proposed exemption would subsidize the lumber industry at the expense of the fisheries and tourism industries in Southeast Alaska. This is unjust and a money losing proposition. The tourism industry has been growing rapidly and is by far the most important industry in Southeast Alaska. It is flourishing because of the majestic fiords, mountains, glaciers, islands, tall trees and abundant wildlife that make up the Tongass.

In 2018 Glacier Bay (located near Juneau in the Tongass) was rated the best cruise ship destination in the world. The natural beauty and pristine environment of the TNF is what draws tourists to Southeast Alaska. Clearcutting does not attract tour boats. Maintaining the ban on logging in the roadless areas in the Tongass will allow the tourism industry to continue to flourish.

The fishing industry in Southeast Alaska that employs more than 12 times as many people as the lumber industry would also be damaged by the proposed Roadless Rule exemption. The cold, clean stream water that nourishes the salmon and trout in the TNF would be threatened with greater warming and sediment from logging.

According to Trout Unlimited the Tongass produces more salmon than all other national forests combined! The current Roadless Rule protection for the Tongass is needed to protect salmon. Improved forest maintenance and stream restoration rather than logging are better ways of improving the local economy.

A substantial majority of people in both national and local polls support keeping the Roadless Rule in the Tongass as do local indigenous groups. Over 2 million tourists visited Alaska in 2018, 2/3 of them visited the Tongass area.

Granting exemption to the Roadless Rule for the Tongass would open the door for other western states to seek exemptions.

The Forest Service should be researching ways to reimburse Alaska for protecting its forests through carbon credits not supporting more logging in old growth forests and wild roadless areas.

The Forest Service needs to choose Alternative 1 from its DEIS since this would keep the Roadless Rule fully intact in the Tongass National Forest.


The mission of the US Forest Service (FS) is to sustain the health, diversity and productivity of the nation’s forests in order to meet the needs of present and future generations. Among the most pressing concerns listed on the FS website are the loss of ecosystem services provided by its forests and the adaption of forest management to climate change.

The Tongass National Forest (TNF) in Southeast Alaska at 16.7 million acres is not only the largest US National Forest, it is the largest “intact” temperate rainforest on earth. Almost 90% of the TNF is either designated as wilderness or protected by the Roadless Rule.

The Roadless Rule protects 58 million acres of previously Inventoried Roadless Areas in US national forests.

Alaska petitioned the FS in 2018 to exempt the TNF from the Roadless Rule. The FS decided to support this petition and recently released a DEIS that evaluates 6 alternative exemptions. The FS is proposing that Alternative 6 be adopted. This would exempt all 9.4 million acres of roadless areas in the TNF from protection. Alternative 1 which would preserve Roadless Rule protection for the entire TNF is our preferred choice.

The Tongass was previously granted Roadless Rule exemption in 2003. This exemption was later rescinded in 2011 by the Alaska District Court and ultimately by the 9th Circuit Court of Appeals “because the FS had not justified its position”.

The TNF abuts the 15.8 million acre Great Bear Rainforest in British Columbia. While this forest has been more impacted by logging, today about 85% of its area is protected from logging, making protection of this combined US-Canadian rainforest even more important for preserving biodiversity.

Some of the old growth forest areas of spruce, hemlock and cedar in the TNF include giant trees (over 200 feet) that are over 800 years old. Unfortunately half of the old growth forest area in the TNF has already been logged. Half of the remaining old growth area (around 165,000 acres) is protected under the Roadless Rule. It is important to maintain roadless area protection of the old growth forests for their incredibly rich biodiversity, superior ability to absorb carbon and naturally greater resistance to wildfires (they are cooler and damper than other parts of the forest).

The TNF contains many islands, much water, dramatic fiords, tall mountains, rocks, glaciers, bogs, bears, wolves (some rare), mountain goats, deer, the endangered Marbled Murrelet, an endangered subspecies of Northern Goshawk, the largest Bald Eagle population in the world, over 100 rare plant species and many marine animals. All 5 Pacific salmon species spawn and thrive in the TNF as do many trout species. Protecting the many streams in the TNF is important for protecting the drinking water of Juneau, Sitka and other towns in the TNF.

The TNF accounts for 80% of the Panhandle or Southeast Alaska Region and is responsible for a large share of that region’s employment. This region has a population of 73,000, almost a tenth of the state’s population. In 2017 the tourism sector in the SE Alaska region employed 7,739 and was growing rapidly; the seafood industry employed 3,829, the mining industry 886 and the timber industry only 302.

Alaskan politicians have long pushed for opening the Tongass roadless areas to more logging claiming that it is necessary for job creation and economic growth. But there are much better ways to create jobs in this region. There is a backlog of salmon habitat restoration projects from previous periods of clearcutting as well as a backlog of general forest maintenance. Addressing permitting issues for the tourism and recreation sectors would also enable these sectors to grow faster.

The fishing industry is a much more important industry than the lumber industry in Southeast Alaska. Improving fishing industry potential would also benefit the fast growing tourism sector while promoting the lumber industry negatively affects both the seafood and tourism sectors.

Tourism is by far the most important sector in Southeast Alaska. The current population of all Alaska is only 736,000, less than 1/4 of 1% of the total US population, yet the state attracted over 2 million tourists between May and September in 2018 with over half of them arriving by cruise ship and 2/3 of them visiting the Tongass National Forest Region. Ecotourism is one of the fastest growing areas of tourism in Alaska.

The indigenous people of the Tongass provide another resource that could be used more effectively. The TNF provides a home for the Tlingit, Haida and Tsimshian people. They sustainably hunt and fish for their food in the forest and care for their sacred areas. Evidence cited in the recent U.N. Global Assessment Report on Biodiversity indicates that nature managed by indigenous people is generally in better health than that managed by national or state governments. Funding demonstration projects on the sustainable use of forest land by indigenous groups is yet another area for job creation.

Part of the TNF’s draw for tourists is its abundant wildlife. Yet the UN’s recent Global Assessment Report on Biodiversity and Ecosystem Services indicates that 1/3 of US species are at risk of extinction in the next couple of decades. Deforestation is a prime contributor to both biodiversity loss and global warming.

The UN’s Global Assessment Report on Biodiversity makes clear that more land needs to be protected from resource extraction and conversion ( forest to agriculture or development) if the extinction crisis underway is to be reduced. The report recommends stopping subsidies to the oil and gas, fishing, agriculture and forestry industries and initiating subsidies for reforestation and restoration of wetlands, prairies and other ecosystems. The FS proposal to exempt roadless areas in the Tongass from the Roadless Rule amounts to a huge subsidy for the lumber industry. Not what we need to protect biodiversity and fight global warming.

The TNF is especially valuable as a defense against global warming. Temperate rainforests have the densest concentrations of carbon in the world. Their incredibly deep bogs sequester many layers of carbon. Over the last 60 years Alaska has been warming at twice the rate of the rest of the US. Because temperate rainforests like the TNF are cooler and damper than nearby areas they are an important defense against global warming. The TNF should be a part of our national strategy for combating global warming. Other countries with carbon markets mitigate their carbon expenditures by paying Alaska to protect more forest land.

The only way to meet the Paris climate targets for reducing global warming is to shift to nature based planning. Deforestation is a prime cause of biodiversity loss as well as global warming. Reforestation is a prime tool for obtaining the IPCC goal of limiting global temperature increases to 1.5°C. It is also a prime tool for reaching the IPBES goal of protecting 30% of land from resource extraction and land conversion by 2030. Forest preservation can help combat the sea level rise and global warming that are already baked into our future by our past actions.

If this exemption from the Roadless Rule is allowed for Alaska other western states will demand exemption for themselves as well. We should not be handing over our public lands to private interests. In many cases timber companies have leased land in our national forests at a very low price. We must not subsidize the private lumber companies at the expense of the health of the rest of us.


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