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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.

To the Roadless Rule Rulemaking Team: If you follow climate as I do — daily, reluctantly — the 2001 Rule's quiet contribution to forest carbon retention is hard to miss. The rescission misses it anyway. I am local to the Wasatch National Forest, these areas have been a huge part of my life enjoying the wilderness right in my backyard. I hope to raise my own family in this area, and I believe the natural beauty and wildlife of this area deserves the utmost respect and conservation. Not only this, but the utah's wildlife and outdoors are already under fire and deserve more protection than ever. Hiking to Red Pine Lake with my girlfriend, enjoying the cold water and cooler temperatures. Being isolated, away from all the noise of the city such as road noise, generators, and even the simple noises from a suburban city. With the roadless rule being removed, we could see a decrease in wildlife in an already dwindling population. We may also lose access to isolated get-away locations that many choose for a sanctuary. Regarding the Twin Peaks in the Wasatch-Cache National Forest, Utah: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Road noise reaches deep into protected areas. Anthropogenic noise doubles background sound levels in 63 percent of U.S. protected area units and produces a tenfold increase in 21 percent of them. Elevated noise was found in habitats of endangered species, with 14 percent of critical habitats experiencing a tenfold sound increase. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use (Buxton et al. 2017). — Buxton et al., 2017 (https://doi.org/10.1126/science.aah4783) Rescinding the Roadless Rule would open the Twin Peaks, Wasatch-Cache National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Rolling back the roadless rule is an ignorant action that will hurt many areas of the outdoors. The roadless rule is a necessary piece of law that protects some of the areas closest to all of our hearts. I am terrified to see my local wildlife areas be potentially threatened by a misguided attempt to take away our public lands. Complete Absence of Environmental Justice Screening Methodology (EJScreen/CEJST) Nationwide The Draft EIS provides no environmental justice screening for a rulemaking that could affect up to 44.7 to 58 million acres nationwide. The Purpose and Need section states only that the agency "prioritizes decisionmaking by local Forest Service officials informed by Tribes, State, and local communities," and the Socioeconomic discussion documents "starkly divergent impacts" between resource-dependent rural communities and recreation-dependent "gateway communities" facing "job losses, mill closures and economic instability." Nowhere is this divergence overlaid with EJScreen, the Climate and Economic Justice Screening Tool, or any comparable demographic analysis identifying low-income or minority populations affected by increased logging, road construction, or mineral leasing. NEPA's hard-look mandate, 42 U.S.C. § 4332(2)(C), requires analysis of the disproportionate community burdens the DEIS's own socioeconomic findings place at issue — a statutory duty unaffected by the January 2025 revocation of Executive Order 12898 — and EPA's 2025 Interim Environmental Justice Framework reflects continuing agency practice of exactly this screening. I request a dedicated Environmental Justice section, distinct from Tribal consultation discussion, screening communities near operable roadless areas, wildland-urban interface zones, and mineral-lease tracts under every alternative. The forests these rules cover deserve to stay roadless. I'm asking the Department to keep them that way. With respect, CommentID: RLC-20260905-GLIHTX

I am submitting this comment in strong opposition to rescinding the USDA Roadless Rule. As a Tribal member of the Pit River Nation, whose ancestral homelands span Shasta, Lassen, Siskiyou, and Modoc Counties, this rescission would directly harm our cultural resources, watersheds, and forest ecosystems. Removing the Roadless Rule would eliminate meaningful Tribal consultation, violating Executive Order 13175, which requires government‑to‑government engagement when federal actions affect Tribal Nations. It also conflicts with Executive Order 12898 by increasing environmental burdens on Indigenous communities without Tribal input. Roadless areas in the Shasta‑Trinity, Lassen, and Modoc National Forests contain our sacred sites, gathering areas, and traditional food and medicine resources. Opening these areas to road building and development will fragment habitat, damage watersheds, and threaten places our people have protected since time immemorial. The Pit River Nation is actively working toward the development of a Tribal Indigenous Forest Plan grounded in Pit River Nation ecological knowledge. Rescinding the Roadless Rule undermines this effort by removing protections and excluding Tribal voices from decisions affecting our homelands. I urge USDA to retain the Roadless Rule, uphold federal trust responsibilities, and ensure the Pit River Nation continues to have a formal role in managing and protecting our ancestral territories. Ida M. Riggins, Enrolled Tribal Member of Pit River Tribe idamriggins@gmail.com A longer formal letter referencing NEPA, NHPA Section 106, and trust responsibility A version tailored to Ajumawi or Atsugewi Bands A version that expands on the Indigenous Forest Plan and co‑management principles Just tell me what direction you want next.