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BLUE RIBBON COALITION, INC. November 11, 1999 USDA Forest Service--CAET Re: Additional Comments on Roadless NOI Dear USDA Forest Service: As you may already know, one of my main concerns in this whole roadless issue has been that important elements of the public recreation infrastructure including Forest Transportation System --level 2 roads -- and Forest Development Trails/Recreational Trails (4x4/ATV/OHV trails) have not been formally recognized, appreciated or protected in the Interim Road Rule. Instead you call them “unclassified” roads and I expect the same in whatever final road policy you come up with. While we can agree that illegal ghost roads/trails are important issues to deal with, the fact remains (despite good wishes, warm speeches, and non-specific Congressional testimony) that certain elements of the Forest Transportation System (level 2 roads) and Development Trails/Recreational Trails are now suspended in a rulemaking “limbo.” The goal of the Interim Rule might have been to address so-called ghost roads, but what the Rule has done is functionally illegitimize up to 80% of the Forest Transportation System and all of our legal and designated recreational roads and trails. Our legal and designated recreational roads and trails that have been formally adopted in either a Forest Plan or Forest Travel Management Plan must be identified and recognized in any FS road or transportation policy. In areas that you identify as “unroaded/roadless,” you must provide for trail maintenance (i.e. cutting out downed trees, fixing blowouts, minor re-routes, and re-routes to protect sensitive habitat). To better help you understand my concerns, please review my initial comments on the Roadless NOI that include my appeal to the Interim Road Rule where I go into great detail about recreational roads and trails. Thanks for your time and consideration. Maybe what is needed is a field trip out to the West where some of you can get on the ground where you can feel, taste, and experience many of our legal and designated recreational roads and trails that are now illegitimized as “unclassified roads.” I would be more than glad to help with any tour you might want to take. Sincerely,
Don Amador Western Regional Representative |