Read the comments.

Matthew Harris’s Roadless Rule Public Comment 36 CFR Part 294 Introduction: The U.S. Department of Agriculture is proposing to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) under the guise of trying to reduce fire risk. Though this action would certainly lead to increased fire risk as humans cause ~85% of wildland fires, most of these starting on road systems, so adding roads to remote forest would only exacerbate this issue (Source: 2000-2017 data based on Wildland Fire Management Information (WFMI) and U.S. Forest Service Research Data Archive). Furthermore, the areas this proposed revocation threatens, Inventoried Roadless Areas (IRAs), feature the second lowest wildland fire ignition density (1.97 fires/1000 ha) in all 8 contiguous-US Forest Service regions combined (Aplet et al. 2026). The only areas featuring a lower fire ignition density than IRAs are wilderness areas (1.75 fires/1000 hectares) which also act as roadless areas (Aplet et al. 2026). In fact, forest lands with the highest wildfire-ignition density are lands within 50 m of roads (7.99 fires/1000 ha; Aplet et al. 2026), demonstrating the proposition to rescind the roadless rule for wildland fire risk reduction has no factual bases as shown by the USDA’s own data. What’s substantive: Critically the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS) fails to adequately address the negative impacts removing the Roadless Rule would have on Alaska native communities by undermining subsistence practices. The DEIS states “Timber harvest and road construction can degrade these resources, undermining subsistence practices, economic development, and Tribal restoration goals.” The DEIS also recognizes “Subsistence use of fish and wildlife has been and continues to be an important component of the economies of Southeast Alaska communities. Removing the Roadless Rule could have impacts on the amount and distribution of subsistence resources”. But these impacts were not properly analyzed and addressed in the DEIS which stated “Roadless Rule (85 FR 68692) voluntarily considered a forest-wide evaluation in accordance with ANILCA Section 810. ANILCA subsistence hearings were conducted for the DEIS and proposed rule, consistent with Section 810 in 2019”. Neither during these hearings in 2019 nor in the DEIS was Executive Order 12898 explicitly mentioned or considered as it pertains to the legality of this decision. Executive Order 12898 requires federal agencies to identify and address disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority and low-income populations. Nowhere in the DEIS are the potential impacts to subsistence communities quantified and no alternatives are presented to minimize these impacts. Stripping protections from Inventoried Roadless Areas and opening them up to large scale resource extraction would have major consequences for Alaksa fish and wildlife resources with associated degradation to the livelihood of subsistence communities. These communities are particularly vulnerable to social and environmental change and are disproportionately impacted by the effects of climate change which threatens their food security and way of life (Brinkman et al. 2016; Herman-Mercer et al. 2019; Savo et al. 2016). For these reasons I urge the USDA Forest Service to consider the impacts the revocation of the 2001 Roadless Rule would have on Alaska native communities. Why it’s important to me: As a scientist, wildland firefighter, and nature lover forest are central to my way of life. Some of my most fond memories come from times exploring roadless areas while backpacking, backcountry skiing, and hiking. I know the importance of being able to find solitude and peace in untouched forests. So, I urge you to maintain the roadless rule and protect these forests, as we all have a right to clean air, fresh water, and the chance to sit under an ancient tree. References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-US national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(1), 8. Brinkman, T. J., Hansen, W. D., Chapin, F. S., Kofinas, G., BurnSilver, S., & Rupp, T. S. (2016). Arctic communities perceive climate impacts on access as a critical challenge to availability of subsistence resources. Climatic Change, 139, 413-427. Herman-Mercer, N. M., Laituri, M., Massey, M., Matkin, E., Toohey, R. C., Elder, K., ... & Mutter, E. (2019). Vulnerability of subsistence systems due to social and environmental change. Arctic, 72(3), 258-272. Savo, V., Lepofsky, D., Benner, J. P., Kohfeld, K. E., Bailey, J., & Lertzman, K. (2016). Observations of climate change among subsistence-oriented communities around the world. Nature Climate Change, 6(5), 462-473.