Comments Needed on Forest Service's New Long Term Road Management Strategy - Deadline May 2

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. 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.

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:wildlandscpr@wildlandscpr.org

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:karen@pacrivers.org

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