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From: Harlin Savage <[log in to unmask]> (by way of Rob Edward)
Subject: May 17 Comments on FS Roads Policy

Worried about Uncontrolled Motorized Recreation on National Forests?

Write a Letter to the Forest Service about the Long Term Road Management Strategy
Public Comment Deadline: May 17
Please Distribute Widely

Background
The U.S. Forest Service is revising its regulations concerning all road
management, on all National Forests.  On March 2, 2000 they released a
draft environmental analysis for addressing road construction and
reconstruction, decommissioning, maintenance and upgrades.

Over the past several decades, excessive road building on the National
Forests has occurred at the expense of ecosystem health.  For example,
roads are the number one source of erosion into National Forest streams,
and the greatest source of habitat fragmentation for wildlife.  To
reverse this, the Forest Service must stop building roads and
aggressively remove the most ecologically damaging roads first.

The proposed policy would simultaneously amend the transportation
management sections of Forest Service regulations (36 CFR 212) and the
Forest Service Manual (FSM 1920 and 7700).  The new policy proposes an
important shift in emphasis from "transportation development" to
"managing access within the capability of the land."

However, there are a number of areas where the proposed policy revisions
fall short of meeting the needs of aquatic and terrestrial ecosystems on
forest lands.

Key Points for Your Letter
Tell the Forest Service you support the direction the
Chief has taken if the following key issues are included as part of the
final policy.

1) The new policy must prioritize ecosystem values over resource
outputs.  As proposed, the policy defines the minimum road system as
what is "needed" to fulfill the current Forest Plans.  Current forest
plans, however, are not based on ecological sustainability.  The only
such direction is currently buried in Chapter 20, paragraph 28 of the
proposed Forest Service Manual revision.  Further, roadless values and
ecosystem protection must take priority in the new policy.  In your
comments let the Forest Service know that:

        a) road building, upgrading, decommissioning and maintenance decisions
must put the ecosystem first, and resource outputs second;
        b) the policy should provide specific, but over arching direction to
protect roadless values; and
        c)  the policy should promote ecosystem restoration and sustainability.

2) With extremely limited exceptions, no new roads should be built.  The
proposed policy calls for only a 13% reduction in new road construction.
 However, over 440,000 miles of roads already crisscross our National
Forests, with a maintenance backlog of over $8 billion.  The new policy
must include the following.

        a)  the focus of roads management must be on reversing the ecological
damage caused by both unneeded roads, and so called "needed" roads; and
        b)  new road construction should be strictly limited to already roaded
parts of the landscape, and only to enable retirement of more
ecologically damaging existing roads in the watershed.

3) The Forest Service must set default limits to road construction in
certain sensitive areas.  Forest Service Chief Mike Dombeck has
repeatedly stated that roads are the most significant thing you can do
to the landscape.  But all roads are not equal.  Substantial scientific
data supports the premise that roads simply are not appropriate in some
areas.  Urge the Forest Service to:

        a)   acknowledge that certain areas including unstable slopes,
sensitive watersheds and riparian areas, and wildlife migration
corridors are not ecologically appropriate for roads and neither the
agency nor the public need waste its time considering such options; and
        b)  establish criteria detailing where roads are inappropriate.

4) The new policy must take into account landscape level management.
The new policy fails to take into account road effects on a watershed or
landscape level.  Habitat connectivity must be a priority within the new
road management strategy.  This could be done by:

        a)  creating and implementing road density standards for wildlife and

fisheries with specific standards for road-sensitive species where such
information is available, and with road density reduction targets where
species-specific information is not available; and
        b)  using ground truth data as the basis of the Transportation Atlas,
which must include all roads and not simply classified roads; and
        c) prioritizing extensive road removal and revegetation in the most
ecologically significant areas.

5)  The policy must address road issues specific to off-road vehicle
use.  Off-road vehicle (ORV) use is intrinsically related to roads, yet
the policy fails to address the problems with ORVs.  If the Forest
Service wants to effectively manage transportation, then they have to
develop a process for effectively managing all motorized travel.  All
motorized use should be limited to designated routes.  To adequately
address ORVs, the policy should include the following four provisions:

        a)  prohibit cross country travel by ORVs;
        b)  demonstrate that existing or proposed ORV use does not result in
adverse environmental impacts;
        c)  permit ORV use only to the extent that monitoring and enforcement
are funded and implemented; and
        d)  prohibit motorized vehicle use in legislatively or administratively
proposed wilderness areas and other wilderness quality lands including
roadless areas.

Send your comments, by May 17, 2000 to:
USFS CAET
Attn: Roads
PO Box 221090
Salt Lake City, UT 84122
mailto:[log in to unmask]
[log in to unmask]
 
For more Forest Service information, or to get a copy of the Draft EA,
contact Heidi Valetkevitch, Office of Communication 202/205-0914; or go
to the FS website at http://www.fs.fed.us/news/roads/

For a more detailed analysis of the draft roads policy, contact
Wildlands CPR at 406/543-9551 or mailto:[log in to unmask]

Briefing materials on the roads policy and sample comments are available
on the Pacific Rivers Council's  web-site: http://www.pacrivers.org.
Or, you can request a hard copy of the book from our Eugene office:
541-345-0119 or mailto:[log in to unmask]

--
Harlin Savage
American Lands Alliance
2260 Baseline Road, Suite 205
Boulder, CO 80302
ph: 303-473-9525
fax: 303-444-5693
e-mail: [log in to unmask]
 

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