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E-M:/ ACTION ALERT! FS Road Policy Urgent Deadlines

Enviro-Mich message from "Liz Godfrey" <lizgodfrey@prodigy.net>

Sign on for the remaining roadless areas in Michigan!!
----- Original Message ----- 
From: Ed Lytwak <ELytwak@Defender.Defenders.org>
To: <actgreen@envirolink.org>
Sent: Thursday, April 27, 2000 12:08 PM
Subject: ACTION ALERT! FS Road Policy Urgent Deadlines

> April 27, 2000
> Folks,
> It all starts with roads. If all things are truly connected then it is
> roads that begin unraveling of the web of life. The good folks over
> at Pacific River Council have put together a great sign on letter for a
> very important comment period. As a group of 65 scientists recently
> said in a petition to the BLM, "the best way to preserve the ecological
> integrity of wild lands in the West is to protect remaining roadless
> areas." We say, even better is ripping roads out and creating more
> roadless areas, especially in that national sacrifice zone known as the
> East.
> Apologies for not getting this information to you sooner, but in this
> case better late than never. It is that important. So if you can speak
> for your group sign them on NOW --the deadline for the sign-on letter is
> tomorrow Friday April 28!  If you miss that deadline you can also send
> the letter in yourself with the deadline this coming Tuesday May 2. 
> There is an email address for comments. Thanks.
> Chris Champine             Ed Lytwak
> Acting Director       Policy Coordinator
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
> GREEN, GrassRoots Environmental Effectiveness Network, is a project of
> Defenders of Wildlife designed to serve grassroots wildlife and
> wildlands advocates. GREEN policy positions do not necessarily
> represent those of Defenders of Wildlife.
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
> 1) Sign your organization on to the Pacific River Council's Letter
> (copy below). Deadline is tomorrow, Friday APRIL 28.
> To sign-on, please send your name, position, and the name of your
> organization to:
> karen@pacrivers.org 
> by Friday, April 28.
> 2) Send in your own comments:
> ADDRESS:  Send written comments to USFS CAET, Attention: Roads, P.O.Box
> 221090, Salt Lake City, UT 84122.
> Send comments electronically to:
> roads/wo__caet-slc@fs.fed.us.
> Deadline: MAY 2
> 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.)
> 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
> 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:
> 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. 
> 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.  
> 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. 
> 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. 
> 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.
> 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.
> 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.
> 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.
> 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.
> "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.
> 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:
> No new roads should be allowed in roadless areas. No ORVs should be
> allowed in roadless areas. 
> 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. 
> The proposed exemption of the Tongass National Forest from the
> requirement to demonstrate a "compelling need" for  roadless area
> development is completely unacceptable. 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.
> 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: 
> all the previously inventoried roadless areas except those that have
> subsequently been deliberately roaded by the Forest Service, and
> 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. 
> 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
> BACKGROUND (From the Federal Register):
> FOREST SERVICE ROAD POLICY: In conjunction with a proposed rule the
> Forest Service is revising its administrative direction governing forest
> transportation planning and management. This action is necessary to
> ensure that the forest transportation system meets current and future
> land and resource management objectives and provides for attendant
> public uses of National Forest System lands; provides for safe public
> access and travel; allows for economical and efficient management; and,
> to the extent practicable, minimizes and begins to reverse adverse
> ecological impacts. The intended effects of this action are to ensure
> that decisions to construct new roads will be made only upon completion
> of a science-based road analysis; that emphasis will be given to
> decommissioning unnecessary classified and unclassified roads and to
> reconstructing and maintaining classified roads rather than constructing
> new roads, where supported by analyses; and that the availability of
> road maintenance funding will be considered when assessing new road
> construction. Public comment is invited and will be considered in
> adoption and issuance of the final directives. The Forest Service is
> proposing new rules that would revise regulations concerning the
> development, use, maintenance, and management of the national forest
> transportation system. This action is needed to reflect changes in
> public demand and use of National Forest resources; to better consider
> scientific information about the adverse environmental impacts of road
> construction; and to efficiently meet present and future management
> objectives in balance with available funding. In concert with the
> proposed revision of Forest Service road system administrative direction
> published elsewhere in this part of today's Federal Register, this rule
> will help ensure that additions to the Forest Service road system are
> those deemed essential for National Forest System resource management
> and use; that, to the extent practicable, construction, reconstruction,
> and maintenance of roads will minimize adverse environmental impact;
> and, finally, that unneeded roads are decommissioned and, where
> indicated, ecological processes are restored. 
> DEADLINE:  Comments must be received in writing by May 2, 2000.
> ADDRESSES:  Send written comments to USFS CAET, Attention: Roads,
> P.O.Box 221090, Salt Lake City, UT 84122.
> Send comments electronically to roads/wo__caet-slc@fs.fed.us.
> FOR FURTHER INFORMATION CONTACT:  Heidi Valetkevitch, Office of
> Communication, 202-205-0914. The FS road management website can be
> accessed at http://www.fs.fed.us/news/roads/
> Federal Register: March 3, 2000 (Volume 65, Number Page 11680-11683.
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
> GrassRoots Environmental Effectiveness Network (GREEN)
> DC Office:  1101 14th Street, NW, Suite 1400, Washington, DC  20005
>    (202) 682-9400  fax: (202) 756-2804
>    cchampine@defenders.org,   elytwak@defenders.org
> Visit our website at:  http://www.defenders.org/grnhome.html
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

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