• The proposed roadless withdrawal is bad public policy which is being pursued for purely political reasons. It is inappropriate on all national forests. It is particularly unacceptable in the case of the Tongass National Forest, because the Tongass has just gone through an extensive, 11 year plan revision which cost the public more than $13 million. The 1997/99 Plan withdrew more than half of the land previously available for development in the Tongass.

• The 1999 Record of Decision, currently the subject of litigation alleging it to have been illegally adopted by Undersecretary Jim Lyons, placed many thousands of acres of unroaded areas off-limits to development, reducing the land available for timber production to approximately 10 percent of the Commercial Forest Land in the Tongass. This has already put serious restraints on the economy of Southeast Alaska. Additional roadless withdrawals would be economically devastating to the communities of the region.

• When the Alaska National Interest Lands Conservation Act (ANILCA) passed Congress in 1980, it placed into law an agreement between Congress and the Carter White House that any further conservation unit decisions in Alaska would be under the sole purview of Congress. This is the meaning of the several "no more" provisions of the Act. Any application to national forests in Alaska of the new roadless policy would violate the ANILCA agreement, creating de facto wilderness without an action of Congress.

• Alaska’s elected representatives have spoken with unanimity on this issue. The Governor, the Congressional delegation, members of the state legislature and many community leaders have all spoken out against the application of the roadless policy to the Tongass. Governor Knowles went so far as to say that it would be "a double cross" and "an outrage" were the policy to be applied to the Tongass. We agree, and urge the Forest Service to specifically exempt the Tongass from any further consideration of roadless "protections."

• Most of the non-roaded areas of the Tongass are already under some form of protection. These include Wilderness, Congressionally designated LUD II areas, administrative land use designations for non-development such as "remote recreation," and Wild and Scenic River designations. The only roadless acreages under consideration for protection in this proposed policy are those few areas currently left open for resource (primarily timber) extraction. The available timberlands have already been reduced to the point that mills have closed and more may yet be forced to close. Do not make the problem worse by applying the President’s roadless policy to the Tongass.

• Initially, President Clinton’s announcement of the withdrawal of roadless areas was to encompass some 40 million acres. His inclusion, however, of additional, smaller, non-inventoried unroaded areas may push that number to 60 million acres. Upwards of 13 million acres of that land is in Alaska!

• The proposed roadless withdrawal will exacerbate the existing forest health problem in the National Forest System, including serious disease and insect infestations, such as is occurring in the Chugach National Forest here in Alaska. Has the Forest Service identified the overlap between the 39 million acres at risk of catastrophic fire and the roadless and unroaded areas?

• The proposed policy seems to fly in the face of the forest-by-forest planning process established by the National Forest Management Act (NFMA). How is it appropriate to perform a nationwide "super-EIS" in 1 short year that will overturn decisions made through the land management plan process which involves local decisions based on public and agency review?

• There is no issue of science driving this proposed policy. The needs of wildlife, fish and the non-development sector of the public are fully met by the planning process mandated by NFMA and NEPA. The sole purpose of the roadless policy currently under consideration is to satisfy the increasingly virulent demands of radical environmental groups who want to stop all industrial activities on all public lands.