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Copy of: AF&PA Request for 120 day extension on
Roadless NOI
Forestry and Wood Products Division
1111 19th Street, NW, Suite
800
Washington, D.C. 20036
Phone: 202.463.2452
Department Fax:
202.463.2708
November 11, 1999
Mr. Mike Dombeck
Chief, U.S. Forest Service
P.O. Box
96090
Washington D.C. 20090-6090
Dear Mr. Dombeck,
Re: Request for an Extension of the Public Comment Period on the NOI
for National Forest Roadless Areas
A Notice of Intent to prepare an environmental impact statement on
policies for National Forest Roadless Areas was published on October 19,
1999, requesting public comments to be submitted by December 20, 1999.
AF&PA requests a 120 day extension of the NEPA scoping period for the
following reasons:
The Chief of the Forest Service, under oath at recent congressional
hearings, was unable to clarify whether the proposal covers 40 or 60
million acres. In order for AF&PA, and other members of the general
public, to adequately respond during the scoping process, it is imperative
that the areas to be covered by the proposed policies be clearly and
specifically identified, by location and by area. Without that
information, the public cannot adequately comment on environmental, social
and economic issues that should be analyzed in depth in the environmental
impact statement, nor can they possibly provide comments on a adequate
range of alternatives. While some members of the public may have knowledge
of the location and extent of inventoried roadless areas on individual
forests, no national map or listing of areas and acreages by national
forest have been produced for consideration by the public during the
scoping process. Many potential environmental, social, and economic issues
are area or regionally specific and without maps, it will be impossible to
adequately identify these issues. Based on these considerations, we
request that the comment period be extended and spatial data on a national
basis be provided to the public prior to the close of the comment period.
The Chief of the Forest Service committed to Congress to hold public
hearings in the area of each National Forest at the recent hearings. We
believe that it is unrealistic and a burden on the interested public and
organizations to try to hold all of these 140+ meetings between now and
December 20. As an example, many of our members have direct interests in
several national forests, in some cases in more than one Region, and it
would be an undue burden to compress these hearings into a 30-day period
in multiple locations. We request that these local-level hearings be
scheduled during the 120-day extension period, with at least 15 days
advance notice published in the Federal Register.
This rule-making runs concurrently with the proposed rule for the land
management planning regulations. Our members have interests in both the
roadless area rule and the draft planning regulations. It is a burden on
the public and interested organizations to require they comment on such
complex regulatory proposals within a 60-day comment period. Our
organization requires more time than 60-days to adequately develop
substantive comments.
Based on the above facts and considerations, AF&PA requests that an
extension of 120 days be granted on the Roadless Area NOI and that the
Forest Service provide adequate public notice of hearings to be held on
each National Forest, as stated at the House Resources Committee hearing
on November 3, 1999.
If you have any questions about this request, please contact Bob Bierer
at 202-463-2753. Please advise us in writing of your decision regarding
our request as soon as possible.
Sincerely,
John Heissenbuttel
Vice President, Forestry and Wood Products
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