DRAFT COMMENTS ON NEW PROPOSED FS ROAD POLICY FOR M/U LEADERSHIP
By Don Amador
March 9, 2000

Although this overview will speak to the new proposed Forest Service road policy, there are a number of concurrent agency planning schemes that are interrelated and rely on concepts, principles and policy from each other. There is a concerted effort to control management and planning of federal lands from Washington DC. Other national level policies under development include the 1) roadless area initiative, 2) the land management planning regulations, 3) the Forest Service strategic plan, and 4) the “unified watershed approach to management.”

Because of thousands of comments received from OHV recreationists and various legal challenges to the interim road rule, it does appear that the FS has heard our voice regarding “access” to public lands. The FS states in the document that it wants to change the nomenclature, “Consistent with the intent to shift emphasis from road development to environmentally sound access, the term ‘forest development transportation’ is revised throughout Part 212 to remove the word ‘development.’

However, later on in the road policy the term “environmentally sound access” appears that it could mean only the more passive forms of transportation (i.e. hiking and other non-motorized uses). This is particularly true in the agency’s new “unroaded and roadless” areas.

The FS does appear to amend the rather narrowly focused road definitions that existed in the interim road policy to one that could make more sense. There are new terms of a road -- a motor vehicle travelway over 50 inches, unless classified and managed as a trail -- and a road may be classified or unclassified. The FS also appears to make provisions for so-called “Jeep” recreational roads/trails by permitting “some trails to be over 50 inches wide as long as they are classified and managed as a trail.”

In the proposed Sec. 212.5, the FS now directs agency officials to identify the “minimum” transportation system needed to administer and protect National Forest System lands. By looking at such things as funding (remember the agency has not asked Congress for more funding despite increased user visits to the forest) and the current agency/administration concept that a “locked gate” is proper forest management, one can see that the FS could easily arrive at their goal of getting ride of 80% of the current FS road network. Many times in 1999, Chief Dombeck referred to the fact that they can only afford to maintain about 20% of the current road system.

By not asking Congress for adequate funding and by adopting “closed gate’ management prescriptions nation-wide, the FS could arrive at their goal of closing 80% of our forest road system

ROADED AREAS: This section take more than a passing swipe at our multiple-use lands (i.e. roaded) when it says that because of new resource issues (i.e. water/air quality, passive values, and other resource concerns) that “different” types of recreation are affected in different ways -- some positive and some negative!

ROADLESS and UNROADED AREAS: This section makes a more direct assault on multiple-uses of many lands that are now “roadless” and are, or will be shortly, “unroaded.” Again, the agency given its reluctance to ask for road and recreation appropriated monies from Congress will overlay its current management prescription (i.e. a closed gate, road ripping, etc.) onto millions of acres now used by multiple-use interests.

System trails under 50 inches in width that exist in our multiple-use areas will not preclude those areas from being counted as "roadless or unroaded" in the current planning efforts. This is one of our biggest threats because needed trail maintence may not, or will not, be allowed to occur if those trails are now in "roadless or unroaded areas."

The FS admits that this section will have effects on various types of “activities.” However, it will enhance the quality of “wilderness” type recreation on these lands. Much of these lands are now being used by the general public for traditional multiple-use recreation and resource management.

The FS’s own summary says it best...”the proposed regulations will permit a reallocation of funds to management activities that are consistent with present resource management directions.”

It appears that general recreation and resource uses will be seriously impacted by this proposal.