***********************************************
WORLDWIDE FOREST/BIODIVERSITY CAMPAIGN
NEWS
ACTION ALERT: Showdown Near on U.S.
Roadless Plan
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Forest Networking a Project of Forests.org
http://forests.org/ -- Forest Conservation Archives
http://forests.org/web/
-- Discuss Forest Conservation
07/10/00
OVERVIEW & COMMENTARY
The battle to offer some protection to 43
million acres of America's
roadless forests is reaching a
culmination. The period to comment on
the proposal ends in one week, on July
17th, and the forces of
industrial resource extraction are waging
a powerful counter-
offensive. Please, even if you have never responded to an action
alert, take the time to do so here. Protecting remaining large
blocks of roadless ecosystems in America,
and around the World, will
be one of the greatest determinants of
whether ecological
sustainability will be achieved for the
benefit of generations to
come.
Truthfully, the U.S. roadless initiative
is inadequate in a number of
manners.
Yet, it does represent a major step forward. Please write
in support of the roadless initiative,
drawing from the extensive and
well-formulated background information
provided by the Endangered
Species Coalition in Item #2 below. Point out the following ways to
strengthen the proposal:
* Permanently protect all roadless areas
from all environmentally
destructive activities, including mining,
off-road recreational
vehicle use, and ski area development.
* Include the Tongass National Forest, the
largest national forest, in
prohibitions on road building and logging.
* Provide protection for smaller areas
(current limit is 5,000 acres),
including those of 1,000 acres or more.
Below is news
coverage of the major power struggle occurring, an
action alert on
the matter and significant background information to
use in buttressing
your personalized letter. We need to
win on this
one, so it is important that we all make a
strong final push.
g.b.
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RELAYED TEXT STARTS HERE:
ITEM #1
Title:
Showdown Near on Roadless Plan
Source:
Copyright c 2000 The Associated Press.
Date:
July 10, 2000
WASHINGTON (AP) - The fight between
Western Republicans and
environmentalists that has been looming
since President Clinton
announced a plan to protect 43 million
acres of forests is about to
begin.
The Senate this week is expected to take
up a proposal by Sen. Larry
Craig, R-Idaho, that would delay Clinton's
plan until 60 days after a
panel reviews the effort and submits a
report to Congress.
Environmentalists say Craig's proposal is
a thinly disguised attempt
to put off the plan until Clinton leaves
office, with the hope that
Republican George W. Bush is elected and
scraps the initiative.
Clinton is trying to use administrative
rulemaking to prevent road
building and other development on more
than one-fifth of all federal
forests. His plan, announced last October,
sets broad criteria for
logging, grazing and recreational
activities, and leaves it up to
local foresters to decide whether roads
should be banned on parcels of
5,000 acres or less.
Environmentalists call the effort a
crowning achievement of the
Clinton presidency and one of the most
important conservation moves of
the last century.
But Western Republicans, timber companies
and recreation interests say
the move would unfairly limit access to
public lands and hurt local
economies. They denounce the rulemaking as
an end run around Congress,
since the plan can be implemented without
lawmakers' approval.
Craig will offer an amendment to a $15.5
billion Interior Department
spending bill would take $1 million from
federal timber accounts to
pay for an advisory committee to study the
roadless initiative and
another proposal that would dictate when
new roads can be built.
Craig said such a committee needs to
review the rulemakings to ensure
they are done right and legally.
He and Rep. Helen Chenoweth-Hage, R-Idaho,
have held hearings of the
forest oversight subcommittees they chair
to argue that private
meetings between Clinton administration
officials and
environmentalists to discuss the roadless
proposal before the
initiative was announced violated laws
governing open meetings.
``The environmental community behind
closed doors convinced this
administration to pump out a roads
policy,'' Craig said. ``What I do
is simply reverse that process ... . I
just cannot believe anyone
serving in the U.S. Senate would condone a
closed-door process.''
While Craig and Chenoweth have been laying
the groundwork for a
challenge on Capitol Hill, Forest Service
officials have continued
with 400 planned public meetings
nationwide on the draft of the
roadless plan they unveiled in the spring.
A Forest Service spokesman said the
meetings - not more study - are
the best way to move forward.
``This represents to me a truly
fascinating turn of events - we're
desperately seeking debate on the substance
of an issue and others are
relentlessly turning back to and arguing
for more process,'' Chris
Wood said.
Marty Hayden, legislative director of
Earthjustice Legal Defense Fund,
said the Craig amendment would derail the
public process with ``hope
that the next administration is less
favorably disposed to protecting
roadless areas.''
Craig disagrees. One of his aides said
Agriculture Secretary Dan
Glickman could quickly appoint the review
panel and complete the study
and roadless initiative before Clinton
leaves office.
``Within reason, this is something that
could be done promptly,'' said
Mark Rey, a staffer at the Senate Energy
and Natural Resources
Committee.
Fights over environment-related amendments
to spending bills - so-
called anti-environmental riders - have
been common during the
Clinton years.
Thirteen spending bills, including the
interior measure, must pass
Congress each year to keep the government
operating. Lawmakers in both
parties view the bills as excellent
vehicles for key policy changes.
Clinton has usually won the fights over
environmental riders.
Republicans last year attached a rider to
the Interior bill to prevent
oil companies from paying higher royalties
for drilling on public
land, but during budget talks Clinton
forced the GOP to drop the idea.
Some riders have become law. Western
Republicans in 1995 convinced
Clinton to waive normal environmental
protections and block citizen
appeals of logging so dead and dying trees
at risk of burning could be
more quickly removed.
The public comment period on the proposed
roadless plan closes July
17. Then, administration officials will
start drafting a final rule
that could be in place this fall, provided
Craig's effort fails.
On the Net: Forest Service:
http://roadless.fs.fed.us/
ITEM #2
Title:
ACTION ALERT! ROADLESS
INITIATIVE
HFC SIGN ON LETTER & COMMENT LETTERS NEEDED!
Source:
Endangered Species Coalition
Defenders of Wildlife
Ed Lytwak, <ELytwak@Defender.Defenders.org>
Date:
July 7, 2000
Folks,
Its all about habitat. What makes the
Endangered Species Act perhaps
the toughest environmental law in the
world is its ability to protect
the habitat of endangered and threatened
species. The Clinton-Gore
Administration roadless initiative is a
historic opportunity to
strengthen protection for at least 40
million acres of roadless
habitat on America's national forests.
Habitat vital to the survival
of many endangered and threatened species
on the list as well as the
many candidates awaiting listing and the
sensitive species heading
toward trouble. Like so many of the ESA
battles these days, this one
is less about science and ecology and more
about politics. Although
the administration's roadless initiative
does fall short of providing
full protection for these areas and others
that need greater
protection, it is still a major step
forward and one that powerful
forces in Congress are determined to stop.
For that reason it is
absolutely crucial our voices be heard in
Washington. Below are
several things that you can do to help
make sure that these roadless
areas get the fullest protection possible.
Brock Evans,
ESC Executive Director
Chris Champine
GREEN Director
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
From the Endangered Species Coalition
powered by GREEN,
The GrassRoots Environmental Effectiveness
Network.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
WHAT YOU CAN DO:
1) Sign your group onto the Heritage
Forest Campaign letter below by
next Wednesday, July 12. Please send the
name of your group, your name
and title, and where your group is located
to elytwak@defenders.org
Remember the sign on letter closes July
12!
2) Send a separate comment letter from
your group or as an individual
citizen. Encourage your friends, family
and colleagues to do likewise.
If possible spread this alert as widely as
possible.
DEADLINE: Written comments must be
received by July 17, 2000.
ADDRESSES: Send written comments to the
USDA Forest Service--CAET,
Attention: Roadless Areas Proposed Rule,
P.O. Box 221090, Salt Lake
City, Utah, 84122.
Reviewers, who wish to send comment by
e-mail, may do so by accessing
the worldwide web at roadless.fs.fed.us
and selecting the comment
option.
Comments may also be sent via fax to
877-703-2494.
Heritage Forest Campaign sign on letter:
July 12, 2000
Mike Dombeck, Chief
USDA Forest Service - CAET
P.O. Box 221090
Attn: Roadless Areas Proposed Rule
Salt Lake City, Utah 84122
Dear Chief Dombeck:
The Heritage Forests Campaign is an
alliance of conservationists,
educators, scientists, clergy, and
ordinary Americans who are working
together to ensure our unprotected scenic
wilderness forests are
permanently protected. As partners and
supporters of the Campaign, we
are submitting the attached comments on
the proposed Roadless Area
Conservation Rule and Draft Environmental
Impact Statement, which were
released in May 2000. We may also submit additional comments on
behalf of ourselves or our respective
organizations.
Over the past year, we and more than half
a million other citizens
have asked for a national policy that
permanently protects roadless
areas one thousand acres and larger on all
national forests from
logging, road building, mining, and other
destructive activities. We
were very encouraged by President
Clinton's October 13 remarks and the
Administration's intent to permanently
protect what remains of our
wild forest heritage across the National
Forest System. In December,
many of us wrote to you reiterating
our support for strong and
immediate protection for all roadless
areas and expressing some
concerns about the Forest Service's proposed
process for implementing
the President's plan.
While we appreciate the tremendous effort
the Forest Service has made
in developing the proposed rule and Draft
EIS, we are very
disappointed about three major
deficiencies of the proposal. First,
it does not prohibit logging within
inventoried roadless areas.
Second, it exempts the roadless areas in
the Tongass National Forest
from the national prohibition on road
construction. Third, it
provides no immediate protection for the
uninventoried roadless areas
greater than 1,000 acres. In addition, the
policy does not protect
roadless areas from mining or dirt bikes
and other off-road vehicles.
These weaknesses cause the proposed policy
to fall far short of the
"strong and lasting" protection
for roadless areas that President
Clinton called for in October. However, as discussed in the attached
comments, we believe that the information
and alternatives contained
in the Draft EIS provide a compelling
scientific and legal basis for
selection of a final policy that
adequately protects roadless areas.
We strongly urge you to adopt a final rule
and preferred alternative
that is consistent with the following
recommendations:
* Immediately prohibit road building and
logging (for both commodity
and non-commodity purposes) in all
national forest roadless areas.
* Do not exempt the Tongass National
Forest from the national
prohibition on road building and logging.
As America's largest
national forest and the heart of the last
great temperate coastal
rainforest on earth, protection of the
Tongass' roadless areas is a
key test of our country's commitment to
rainforest conservation.
* Provide interim protection from road
building, logging, and other
destructive activities for all
non-inventoried roadless areas of 1,000
acres or more, pending local forest plan
revisions.
* Permanently protect all roadless areas
from all environmentally
destructive activities, including mining,
off-road recreational
vehicle use, and ski area development.
President Clinton's roadless area
directive represents an historic
opportunity for the Forest Service to
create a magnificent legacy of
wild forestlands for present and future
generations. We urge you to
make the necessary changes in the final
rule and EIS to realize this
vision.
Sincerely,
Brock Evans, Executive Director Endangered
Species Coalition
Washington, D.C.
Chris Champine, GREEN Director,
Washington, D.C.
BACKGROUND:
Federal Register notice (excerpts):
ROADLESS AREA INITIATIVE DEIS COMMENTS:
The Forest Service is
proposing new regulations to protect
certain roadless areas within the
National Forest System. This proposed rule
making would prohibit road
construction and reconstruction in most
inventoried roadless areas of
the National Forest System and require
evaluation of roadless area
characteristics in the context of overall
multiple-use objectives
during land and resource management plan
revisions. This proposal is
in response to strong public sentiment for
protecting roadless areas
and the clean water, biological diversity,
wildlife habitat, forest
health, dispersed recreational
opportunities, and other public
benefits provided by these areas. This
action also responds to
budgetary concerns and the need to balance
forest management
objectives with funding priorities. The
intent of this rule making is
to provide lasting protection in the
context of multiple-use
management for inventoried roadless areas
and other unroaded areas
within the National Forest System. The
Forest Service invites written
comments on this proposed rule and will
analyze and consider those
comments in the development of a final
rule.
DATES: Written comments must be received
by July 17, 2000.
ADDRESSES: Send written comments to the
USDA Forest Service--CAET,
Attention: Roadless Areas Proposed Rule,
P.O. Box 221090, Salt Lake
City, Utah, 84122. Reviewers, who wish to
send comment by e-mail, may
do so by accessing the worldwide web at
roadless.fs.fed.us and
selecting the comment option. Comments may
also be sent via fax to
877-703-2494.
A copy of the Draft Environmental Impact
Statement (DEIS), the DEIS
Summary, and other information related to
this rulemaking is available
at the roadless.fs.fed.us website.
Additional information is available at the
roadless.fs.fed.us website
as well as by calling the number listed
under the For Further
Information Contact heading.
FOR FURTHER INFORMATION CONTACT: Scott
Conroy, Project Director,
(703)605-5299.
The Federal Register notice and appendix
can be viewed on line at:
http://www.eswr.com/fs5100.txt
Federal Register: May 10, 2000 (Volume 65,
Number 91) Page
30275-30288.
COMMENTS OF THE HERITAGE FORESTS CAMPAIGN
ON THE PROPOSED RULE AND
DRAFT ENVIRONMENTAL IMPACT STATEMENT ON
FOREST SERVICE ROADLESS AREA
CONSERVATION
We believe that the Forest Service's
proposed roadless area
conservation falls far short of the
directive that President Clinton
presented on October 13, 1999, when he
stated his desire to "provide
strong and lasting protection" for
the remaining roadless areas in the
national forests. We commend the Forest Service for its
extraordinary
efforts to involve the public and to
produce a draft environmental
impact statement (DEIS) on the proposed
policy. However, the Forest
Service proposal does not fulfill the
primary purpose and need
identified in the DEIS -- to
"immediately stop activities that have
the greatest likelihood of degrading
desirable characteristics of
inventoried roadless areas."
In order to comply with the directive of
the President to safeguard
our remaining roadless forests, and to
fulfill the purpose and need of
the agency's action, the final policy must
be significantly
strengthened and improved. Fortunately, the DEIS provides the
scientific and legal basis for producing a
final policy that will
substantially safeguard this magnificent
natural legacy for present
and future generations.
Indeed, as discussed below, the DEIS leads
to the inescapable
conclusion that in order to provide
long-term, meaningful protection,
the agency must adopt a stronger
policy. The proposed prohibition on
new roads provides uncertain protection
for most roadless areas, and
no protection at all for Alaska's Tongass
National Forest. According
to the DEIS, logging and road construction
are the two activities that
most significantly alter the
characteristics of roadless areas.
However, the proposed alternative reduces
road construction in
roadless areas by only 40%, and logging by
only 27%. The policy
alternative that prohibits both logging
and road building in roadless
areas in all national forests clearly will
best meet the purpose and
need as well as the President's directive
to protect these areas.
LOGGING
We urge the Forest Service to select a
final policy that prohibits all
logging in roadless areas. While a road-building ban will effectively
prevent commercial logging in some areas,
it will allow logging in too
many other areas where it is possible
using helicopters, forwarders,
cable yarders, and other equipment that
does not require immediate
road access. In fact, the DEIS estimates
that nearly half of the
roadless area timber slated for logging in
the next five years outside
Alaska could be logged without additional
road construction.
Scientific and economic information
contained in the DEIS argues
convincingly for prohibiting logging as
well as road building in
roadless areas. The DEIS concludes that a wide array of environmental
resources and values - ranging from water
quality to wildlife to
recreation - would all benefit from a ban
on logging.
The effect of prohibiting roadless area
timber sales on the timber
industry and employment would be
minimal. Forgoing the entire 220
million board feet of annual timber sale
offerings in roadless areas
over the next five years would result in
only a 7% reduction in the
Forest Service's planned timber sale
program. The impact on total
U.S. timber production, which averages
about 83 billion board feet per
year, would be miniscule -about < of
1%. Similarly, the DEIS
estimates that a prohibition on roadless
area logging would
theoretically result in a loss of just 820
timber jobs, which is 3% of
all national forest-based direct timber
jobs and less than one-tenth
of 1% of all U.S. wood products
employment.
Forest Health and Fire
Despite acknowledging the environmental
superiority of alternatives
that prohibit logging, the Forest Service
evidently concludes that the
benefits of "forest health" logging
in roadless areas outweigh the
environmental damage. Specifically, the agency seems to believe
that
logging in roadless areas will
"provide opportunities for achieving
other multiple-use benefits, such as ...
vegetative treatments to
reduce the risk of wildland fire, and
insect and disease infestations"
(DEIS, p.1-12).
We disagree that commercial logging of
roadless areas is needed to
reduce fire risk and cure insect and
disease problems. According to
scientists in the Sierra Nevada Ecosystem
Project, logging is the
single greatest cause of increased fire
risk. The DEIS acknowledges
"uncertainty" among fire
researchers about the effects of timber
harvest or thinning on fire risk, due to
factors such as increased
drying and wind (p. 3-156). Moreover, as
documented in the DEIS,
"Areas that are more highly roaded
have a higher potential for
catastrophic wildfires than inventoried
roadless areas" (p.3-157). In
addition, "relatively few inventoried roadless areas are located near
the Wildland-Urban Interface where high
concentrations of people
dwell, recreate, or work" (p. 3-154).
Consequently, there is less need
to be concerned about roadless area fires
threatening human life or
property.
Thus, it makes no sense for the Forest
Service to use roadless areas
as experimental sites for logging methods
to reduce fire risk. The
agency administers many millions of acres
of previously roaded
national forest land that have a higher
fire risk and are closer to
human settlements than the roadless
areas. The DEIS states that the
no-logging alternatives would have a
"minor effect on the agency's
overall forest health program" and
that "the total acres needing
treatment compared to the acres actually
being treated are so small
that a direct effect cannot be
established" (p. 3-106). Similarly, the
analysis of effects on fire suppression
states that "the effect of
timber harvesting is insignificant, as is
the combined effect of no
timber harvesting with no road construction,
to the overall fire
suppression program" (p. 3-
156). Many roadless areas can be
successfully treated with prescribed fire
to reduce risk of high-
intensity fire, thereby contributing to
the agency's overall effort to
reduce fire risk.
TONGASS NATIONAL FOREST
Any proposal to protect roadless areas
that excludes the largest
national forest from those protections is
clearly inadequate. We are
adamantly opposed to exempting the Tongass
National Forest (or any
other national forest) from the road
building and timber sale
prohibitions in the roadless area
conservation policy. The Tongass
exemption would allow up to 512 miles of
road development and 539
million board feet of logging in roadless
areas during the coming five
years (DEIS, p. 3-232). Tongass roadless logging constitutes about
half of the logging planned for roadless
areas across the entire
National Forest System. The DEIS explains why it is important to
prohibit these destructive activities in
the Tongass roadless areas:
* "The [Tongass] Forest's high degree
of biological integrity and
overall ecosystem health is largely due to
the quantity and quality of
the inventoried roadless areas" (p.
3-226).
* "Preserving roadless areas is
central to maintaining a high degree
of biological integrity.... [T]he loss of
unroaded areas may pose a
considerably higher risk of species
existence and persistence" (p. 3-
227).
* "The Tongass National Forest is
unique because the majority of
subsistence and game species, for example
Sitka black-tailed deer,
marten, wolf, brown bear, salmon, trout,
and steelhead, are integrally
linked to habitat qualities, including
intact old growth and riparian
habitats, provided by roadless areas"
(p. 3-228).
Continued commercial logging of the Tongass
roadless areas also makes
no sense economically, since the federal
government will lose millions
of dollars through below-cost timber
sales. According to the DEIS,
timber sales in the Tongass National
Forest result in a net revenue
loss of $178 per thousand board feet of
timber (p. 3-184). At that
rate, offering 539 million board feet of
Tongass roadless area timber
sales over the next 5 years would result
in a total net loss to the
government of about $96 million. The DEIS estimates that continued
roadless area logging in the Tongass
National Forest would likely
generate 298 timber-related jobs (p.
3-232). Thus, excluding the
Tongass from roadless area protection
could cost American taxpayers
$322,000 per timber job on the Tongass
over the next 5 years, or
$64,400 per job per year.
The economy of Southeast Alaska is well
along in a transition away
from its historic dependence on
timber. In 1999, the forest products
industry produced just 3.4% of all jobs in
Southeast Alaska, down from
13% in 1975. While timber employment has
diminished considerably in
recent years, the rest of the regional
economy has grown. Between
1988 and 1997, total employment in the
region grew by nearly 25%,
exceeding the national average. Recreation
and tourism have been
particularly vibrant, as indicated by
increases of 46% in retail trade
and 48% in services between 1985 and
1995. A ban on roadless area
logging would potentially decrease total
employment in the region by
just eight- tenths of 1%, a reduction
that, over time, would be more
than offset by job growth in other
sectors. The Tongass National
Forest, with its dramatic and undisturbed
landscapes, provides most of
the region's recreational and tourism
opportunities and natural
amenities. Accordingly, preserving the Tongass roadless areas is
essential to the economic well-being of
Southeast Alaska.
We reject the Forest Service's suggestion
that the Tongass Timber
Reform Act (TTRA) requires continued
logging of the Tongass roadless
areas. Section 101 of the TTRA directs the
agency to "seek to provide
a supply of timber from the Tongass
National Forest which meets the
annual market demand for timber from such
forest...." However, this
direction is subject to other applicable
law and to providing for
multiple use and sustained yield of all
renewable forest resources.
The courts have ruled that TTRA requires
no set amount of logging.
According to the Ninth Circuit Court of
Appeals, "TTRA envisions not
an inflexible harvest level, but a
balancing of the market, the law,
and other uses, including
preservation." Alaska Wilderness
Rec. &
Tourism Assn. v. Morrison, 67 F.3d 723,
731 (9th Cir. 1995) (emphasis
added).
Moreover, the DEIS acknowledges that demand for Tongass
timber "is less than proposed offer
levels under current market
conditions" (DEIS, p. 3- 229). In fact, 44 million board feet of
timber was exported from the Tongass last
year due to lack of regional
market demand.
UNINVENTORIED ROADLESS AREAS
We support effective and permanent
protection for all roadless areas
greater than 1,000 acres in the national
forests. While the vast
majority of roadless areas smaller than
5,000 acres have never been
inventoried, there is broad scientific
consensus on the importance of
these areas. We were heartened in October when President Clinton
directed the Forest Service to
"determine whether long-term protection
is warranted for any smaller 'roadless'
areas not yet inventoried."
Unfortunately, the proposed policy
provides no immediate protection
for uninventoried roadless areas. Instead,
it defers any consideration
of such areas well into the future when
local forest management plans
are revised. Two of the
"procedural" alternatives (Alt. C and D)
included in the DEIS would speed up the
potential recognition and
protection of uninventoried areas by
requiring their evaluation during
project-level planning, such as for
proposed timber sales.
Alternative C would require consideration
of uninventoried roadless
areas in project planning but not in
forest planning, while
Alternative D would require the
evaluations at both the project and
forest plan levels.
We believe the final policy should
incorporate the two-level
evaluation of uninventoried roadless areas
as provided in Alternative
D, but with the important addition of
project- level interim
protection. Interim protection will prevent short-term destruction of
valuable roadless areas and maintain
options for long-term protection
through the forest planning process. The Forest Service has adopted
interim protection measures for old-growth
forests and riparian areas
at the regional level (i.e. the
"eastside screens," CASPO, and
PACFISH/INFISH). Similar protection should be extended to
uninventoried roadless areas through this
national rulemaking process.
OTHER CONCERNS
Mining: We oppose hardrock mining, oil and
gas drilling, and other
mineral development in roadless
areas. Mining has the potential to
impact all of the ecological and amenity
values of roadless areas -
from water quality to solitude. Mining access roads are as
destructive as logging roads and are often
driven deep into the most
remote roadless area watersheds. Mine
sites become permanent scars on
the land. While the proposed road
construction ban would effectively
curtail at least some new oil and gas
drilling, it would not limit
hardrock mining conducted under the
General Mining Law of 1872. We
urge the Forest Service to utilize its
full legal regulatory authority
to protect roadless areas from
mining. Areas that are threatened by
mining should be segregated and withdrawn
from mineral development,
pursuant to Section 204 of the Federal
Lands Policy and Management
Act. In addition, the final rule should require
Forest Service
managers to conduct surface-use and valid
existing rights
determinations prior to any mining
activity in roadless areas.
Off-Road Vehicles: We oppose the
indiscriminate and environmentally
destructive use of dirt bikes and other off-road
motorized vehicles
(ORVs) in roadless areas. ORVs have become
increasingly damaging to
roadless area values, as vehicles have
become more powerful and
numerous.
Thousands of illegal "user-created" routes, many of them
within roadless areas, have been
established by repeated ORV use.
While the National Park Service and Bureau
of Land Management have
recently taken actions to control ORV use
at the national level, the
Forest Service has not. We recommend that the final rule restrict
ORV
use to existing legal routes, impose a
moratorium on any new ORV trail
developments in roadless areas, require
Forest Service managers to
close user-created routes, and ban
cross-country ORV travel in
roadless areas. These national policy actions can be implemented in
part through the project-level and forest
plan revision processes,
with added interim protection as discussed
above (see section on
uninventoried roadless areas). We also recommend that the final
policy drop the reference to
"motorized" dispersed recreation as a
characteristic of roadless and unroaded
areas to be considered in the
forest plan revision process (p. A-27, '
294.13(a)(5)).
Ski Area Developments: We are pleased that
the proposed prohibition on
road building includes proposed ski area
developments. Numerous
proposals to expand or build downhill ski
areas are threatening
roadless areas, including Pelican Butte
and Mount Ashland in Oregon,
Copper and Beaver Creek in Colorado, and
Sherwin and Mammoth/June in
California. Ski area developments degrade water quality, disturb
sensitive sub-alpine plant communities,
sever important wildlife
migration corridors, and destroy natural
quiet and solitude. In
addition, ski areas are increasingly being
built or expanded primarily
to attract real estate investments, rather
than to meet recreational
demand. Downhill skiing activity has been
stagnant for the past
decade, while second home construction
near ski areas has boomed. The
final policy must not create any special
exemptions of any kind for
new ski area construction or expansion.
Inventoried Roadless Areas: We are pleased
that the draft policy
includes roadless areas identified in the
Southern Appalachian
Assessment in the definition of
inventoried roadless areas (p. A-8).
However, the definition still omits many
roadless areas both in the
Southern Appalachians and elsewhere that
have never been inventoried
for one reason or another. Some areas, such as Dolly Sods in West
Virginia and Lamb Brook in Vermont, were
acquired by the Forest
Service after the 1979 RARE II inventory
and have not been inventoried
in a forest plan or regional
assessment. In Washington State,
omitted
roadless lands include entire areas such
as Lookout Mountain (12,000
acres), lands adjacent to inventoried
roadless areas such as Granite
Mountain (27,000 acres), and lands
adjacent to designated wilderness
such as the Alpine Lakes Wilderness
(75,000 acres). While it may not
be possible to evaluate such areas in the
final EIS, we recommend that
the final policy direct the Forest Service
to accord them interim
protection and to include them in the
roadless area inventory through
project or plan revision processes.
Roads, Unroaded Areas, and Catastrophic
Events: We are concerned about
the possibility that roadless areas could
be disqualified from
protection due to the presence of
unclassified "ghost" roads.
We are
pleased that the draft policy specifies
that portions of inventoried
roadless areas will be omitted only when a
"classified road has been
constructed" since the past inventory
(p. A-27). The final rule
should make it clear that the existence of
user-created and other
unclassified roads is not an appropriate
reason to remove a roadless
area from the inventory.
We are also concerned about the
possibility for on-the-ground abuse of
the proposed exemption of
"catastrophic events" from the prohibitions
(p. A-27, ' 294.12(b)(1)). The draft policy states that the exception
is not intended to cover "routine
forest health activities, such as
temporary road construction for thinning
to reduce mortality due to
insect and disease infestation" (p.
A-9). However, Forest Service
managers in the past have commonly viewed
wild fire, blowdown, and
other natural disturbances as
"catastrophic events" that warrant
salvage logging. The final rule should
specify that salvage logging,
either before or after natural
disturbances, is prohibited in roadless
areas.
Range of Alternatives: We are disappointed
that the Forest Service did
not consider an alternative that
immediately prohibits the full array
of destructive activities in roadless
areas, as was requested in the
vast majority of the over half-million
scoping comments. In
particular, the DEIS does not include an
alternative that immediately
and permanently prohibits all mining and
off-road vehicle use (as well
as road building and logging) in both
inventoried and uninventoried
roadless areas. We recognize that it may
not be feasible, as part of
the current rulemaking and EIS process,
for the agency to collect
sufficient data on all these destructive
activities and uninventoried
areas.
We do not want the Forest Service to issue a supplemental EIS
or undertake additional analyses that
would delay completion of the
roadless area rulemaking process. Nevertheless, as discussed above,
we believe that the final policy and EIS
can and should be
strengthened in ways that will provide
secure, interim protection
while the necessary information is
gathered. The DEIS contains
sufficient information and analysis needed
to create a sound final
rule that provides adequate prohibitions,
interim protections, and
procedural safeguards for all roadless
areas.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Endangered Species Coalition
DC Office: 1101 14th Street, NW, Suite 1001, Washington, DC 20005
202) 682-9400 x131
fax: (202) 756-2804
cchampine@defenders.org,
elytwak@defenders.org
Visit our website at: http://www.stopextinction.org
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