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The following action alert was issued by National Audubon. Please review the materials below and decide if you want to add your voice on this important topic. From: LEAHY, Michael [mailto:MLEAHY@AUDUBON.ORG] Sent: Monday, May 08, 2000 3:51 PM To: FOREST-NEWS@LIST.AUDUBON.ORG Subject: Road Policy Comments due May 17
In addition to the Forest Service Roadless Area policy, the Forest Service is also establishing a Roads policy for managing its existing roads, and building new ones. We encourage you to join us in signing onto the comments below, or otherwise submitting similar comments to the Forest Service as described below. Thanks,
Mike Leahy Director, Forest Campaign National Audubon Society 1901 Pennsylvania Ave, NW, Suite 1100 Washington, DC 20006 202-861-2242x3019 FAX 202-861-4290 mleahy@audubon.org www.audubon.org/campaign/fh To subscribe to 'Audubon Forest News,' Audubon's email distribution list for information and action alerts on forest issues, ask Alix Davidson at adavidson@audubon.org to subscribe you. Dear Conservation Colleagues, Below is a formal comment letter on the National Forest road policy. We hope that other conservation organizations will join us in signing this letter. We feel that a strong statement for an ecologically sustainable National Forest transportation system will be made by a joint letter from a large contingent of the conservation community. Co-signers of this letter may submit additional comments under separate cover. (For logistical reasons we would like to limit this letter to organizations only, but if individuals would like to comment on the policy, please use this letter and submit comments under your name. Comments may be sent by mail to: USDA Forest Service, CAET, Attn. Roads, P.O. Box 22300, Salt Lake City, UT 84122, by fax to (801) 517-1021, or by e-mail. More information is available on the Forest Service's roads policy web-site: http://www.fs.fed.us/news/roads/) To sign-on, please send your name, position, and the name of your organization to karen@pacrivers.org. The comment deadline is May 17, 2000. Please circulate this letter to other groups you feel should sign-on. If you would like more information about the policy, the Pacific Rivers Council has prepared briefing materials that include a detailed analysis of the policy as well as information on the ecological effects of roads. The materials are available at www.pacrivers.org or e-mail karen@pacrivers.org for a hard copy. Sincerely, David Bayles Conservation Director Pacific Rivers Council Michael Anderson Senior Resource Analyst The Wilderness Society Mary Munson Public Lands Counsel Defenders of Wildlife --------------------- To: USDA Forest Service CAET, Attn. Roads P.O. Box 22300 Salt Lake City, UT 84122 Re: Formal Comments on the Proposed Forest Service Road Policy On March 3, 2000, the Forest Service proposed revisions to the regulations governing the National Forest road system and the manual that guides management of this system. The undersigned conservationists commend the Chief for taking this step and thank the Forest Service for the opportunity to submit comments on the transportation management sections of Forest Service regulations (36 CFR 212) and the Forest Service Manual (FSM 1920 and 7700). Co-signers of this letter may submit additional comments under separate cover. Over the past several decades, excessive road-building on the National Forests has occurred at the expense of ecological resources - fish, water, and wildlife. 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 should stop building roads and aggressively remove ecologically damaging roads, beginning with the worst first. The new roads policy proposes an important shift in emphasis from "transportation development" to "managing access within the capability of the land." This is a critical first step in recognizing that the more than 400,000 miles of roads currently crisscrossing the Forests are far more than the ecosystem can sustain. There are, however, a number of areas where the proposed policy revisions fall short of meeting the needs of aquatic and terrestrial ecosystems on forestlands: 1. With extremely limited exceptions, no new roads should be allowed. The focus of roads management should be on reversing the ecological damage caused by both unneeded roads and so called "needed" roads. 2. Road-building, operation and maintenance decisions should put ecosystem needs first. As proposed, the policy defines the minimum road system as what is "needed" to fulfill the current Forest Plans. This is a mistake - most current forest plans are based on commodity outputs, not on ecological sustainability. Therefore: * Resource objectives in all national forests should be revised to reflect what is known about ecological limits - including limits on both the location and number of road miles. * Target dates should be established for full-scale revision of forest plans nationwide. * In the meantime, road management decisions should be based on ecosystem protection and restoration needs, not on the need to meet existing forest plan outputs. The worst "needed" but ecologically damaging roads should be decommissioned. 3. If road-building is not banned outright, it should be recognized that some areas are not suitable for roads. Default limits to road construction are needed everywhere. There is substantial scientific documentation to support the premise that roads are simply not appropriate in some areas -- riparian areas, unstable slopes, sensitive watersheds, wildlife migration corridors, for example. Neither the agency nor the public need waste its time considering ecologically inappropriate options. 4. The policy should address transportation issues specific to off-road vehicle use. System off-road vehicle "trails" - as well as "user created roads" - cause enormous ecological damage. Many of these trails are in the worst possible locations, running alongside and through streams and deep into sensitive wildlife habitat. The policy should bring these recreational uses inside the same ecological sideboards as passenger vehicle roads. To adequately address ORVs, the policy should include the following provisions: * prohibit cross country travel by ORVs; * ORV use should be limited to system roads and trails designated and posted as open for ORVs; * demonstrate that existing or proposed ORV use does not result in adverse environmental impacts as a condition of any new trail construction, and if existing trails have these effects then they must be removed or relocated; * permit ORV use only to the extent that monitoring and enforcement are funded and implemented; and * prohibit motorized vehicle use in legislatively or administratively proposed wilderness areas and other wilderness quality lands including roadless areas. 5. Routine and emergency road maintenance should not be exempted from the application of the Roads Analysis. The policy relies on the Roads Analysis tool to make ecologically guided management decisions. 6. The success of the policy relies on the technical consistency and competency of the Roads Analyses. The technical background needed for a credible analysis team should be defined, and formal post-analysis technical review teams should be established. 7. Reduction of road maintenance and reconstruction impacts should not be limited to those that are "practicable". This language invites forests to avoid some hard but needed changes. 8. Exempting road work that is "listed in a schedule of proposed actions" undermines the new policy's intent. Exempting work that is already contracted or largely complete may be logical, but exempting all work that has ever been considered is not. 9. Require improved road monitoring and inspection program to include during- and post-storm inspections and maintenance, and more restrictive regulation of traffic during wet periods. 10. "Ghost" roads and trails, and user-created roads and trails should be closed immediately. Reopening of such roads and trails would be on a site-specific, case-by-case evaluation. 11. The Roads Atlas for each forest should map both authorized and unauthorized roads and trails. As part of the ground work for the atlas, each forest should document the type and extent of ecological damage done by unauthorized roads and trails. Comments on Roadless Areas: 12. No new roads should be allowed in roadless areas. No ORVs should be allowed in roadless areas. 13. The draft policy would establish procedural barriers to discourage new road construction in roadless areas, but it would not prohibit such construction. Before constructing or reconstructing a road in a roadless or unroaded area, the agency would have to (1) demonstrate a "compelling need" [such as for public safety, legally guaranteed access, or "critical resource restoration and protection"]; (2) prepare an EIS; and (3) obtain approval by the Regional Forester. There is no point in including these measures in the roads policy, since the roadless area rulemaking will be completed by the end of 2000. If necessary, the Forest Service can simply extend the current road building moratorium for a few months after it expires in September 2000. 14. The proposed exemption of the Tongass National Forest from the requirement to demonstrate a "compelling need" for roadless area development is completely unacceptable. 15. Some definitions in the draft policy could substantially reduce the existing and potential inventories of roadless and unroaded areas. These definitions should be revised to be inclusive of all current roadless areas. 16. The Forest Service needs to clear up the confusion over the relationship between inventoried roadless areas, unroaded areas, and classified roads. Roadless areas should be defined to include: (1) all the previously inventoried roadless areas except those that have subsequently been deliberately roaded by the Forest Service, and (2) similarly undeveloped lands (including small areas adjacent to designated wilderness and inventoried roadless areas) that were passed over in prior inventories or have subsequently been added to the National Forest System. (3) Additionally, unroaded areas should be defined as tracts with more than 1,000 acres of contiguous land that is generally free of roads suitable for standard (2-wheel-drive/low-clearance) highway vehicles. Consistent with current Forest Service roadless area inventory policy, both categories should provide greater leeway for roads and other development features in eastern national forests. Sincerely, David Bayles Conservation Director Pacific Rivers Council Michael Anderson Senior Resource Analyst The Wilderness Society Mary Munson Public Lands Counsel Defenders of Wildlife |
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