Tom Crimmins
12054 Avondale Loop Road
Hayden Lake, ID 83835

November 9, 1999

USDA Forest Service-CAET
Attention Roadless Areas NOI
PO Box 221090
Salt Lake City, UT 84122

Project Team Leader

The following comments are being provide in response to the Notice of Intent for the National Forest System Roadless Areas EIS published in the Federal Register October 19, 1999. Please include these comments in the record.

The EIS adopts the arbitrary definition of roads as classified and unclassified. This has been challenged and the challenge has not been resolved. These definitions have been subject to appeal and law suit under the Interim Road Rule. Until the issue is resolved in both of these challenges the Forest Service should not use these definitions in the current EIS.

The elimination of "unclassified" roads from consideration fails to recognize the large amounts of public access and recreation opportunities that are supported by these roads. The EIS must include an accurate and complete inventory of all existing unclassified roads before it will be possible to accurately determine the effects of any changes in the status of these roads.

A decision to eliminate road construction in Roadless areas is, in fact, a land allocation decision because it will preclude any future activities that require the use or construction of roads in the identified areas. As such, the process must follow the rules for planning decisions rather than simply NEPA.

This document, upon its release, must comply with the planning regulations in effect at the time. Therefore, this analysis should follow the procedures being established in the current proposed planning regulations. This will require the establishment of a committee of scientists to conduct a broad scale assessment of the issue prior to the development of this EIS. Failure to comply with these planning regulations will make the EIS invalid.

Any determination regarding roads, either classified or unclassified, must follow the guidance established in the recently released FS Road Analysis Procedure. This document clearly recognizes that an unclassified road is still a road and it requires a logical process to analyze any changes in road status. This document should follow this process. Failure to follow the procedures established for management of National Forest lands will invalidate the EIS.

The uniqueness of the many roadless areas included in the existing inventory and those to be identified at a later date suggest that a national policy to address all these areas is far too broad. The status of Roadless areas and their future management should be determined on a case by case basis through the Forest Service planning process for each National Forest and not as a national policy.

The EIS must consider all the social and economic effects of the future reductions in recreation opportunities caused by the decision. The effects must be determined for Phase 1, which will prohibit entry into the areas for the short term and for phase 2, which will set long term direction. While the discussion of Phase 2 in the NOI attempts to infer that this will just set criteria and procedures, it will, in fact, significantly limit the possible management alternatives that could be considered in the future. Therefore the effects of this limitation must be clearly and carefully analyzed and disclosed in this document.

The EIS must consider the social and economic effects on small rural communities from the loss of commodity production and recreation from these roadless areas. Since the proposed alternatives will not allow for the efficient management of these areas for commodity production, many small rural communities face a variety of social and economic impacts. The full range of these impacts must be analyzed and disclosed in this EIS.

This EIS must consider the added costs to small rural communities for health care, and law enforcement caused by the decision. This analysis must include the increased costs associated with the documented increases in amounts of spousal abuse, alcoholism and other effects resulting from the loss of jobs and economic support from these roadless areas if they are not made available for commodity production and motorized recreation. Since it is clear that the proposed alternatives will have an economic effect on local communities, and research has shown that communities and individuals under economic stress suffer from a decrease in general health and an increase in unlawful activities, the costs associated with these effects must be determined, analyzed and disclosed in this EIS.

This EIS must consider the added costs on a national level for health care, and law enforcement caused by the decision. This analysis must include the increased costs associated with the documented increases in amounts of spousal abuse, alcoholism and other effects resulting from the loss of jobs and economic support from these roadless areas if they are not made available for commodity production and motorized recreation. The effects mentioned above will also have an effect at the national level. Since individuals under economic stress will qualify for Medicare and Medicaid, The long-term effects of these increased costs on theses important programs must be determined, analyzed and disclosed in the EIS.

The EIS must consider the effects on the global environment that will result from the shift of potential commodity production from roadless areas to other countries with significantly less environmental controls. There is nothing to indicate that the demand for timber and other commodities that might be produced from these roadless areas in the future will decline. Therefore, the production will be shifted to other lands and to other countries. Since foreign countries do not have the same level of environmental protection controls, the impacts from foreign production will increase. The overall effects of these increases must be analyzed on a global basis. In addition, the effects of cross border pollution from Mexico and Canada in to the US must be determined. In addition, the EIS must disclose the long-term projected timber yields from private and other lands within the country and the projected yields that will be shifted to foreign production.

This EIS must consider the effects of the reduction in the potential growth and improved quality of family based motorized recreation resulting from any decision. A number of studies have found that motorized recreation is a family activity. It serves to bring families together and to provide youth an alternative activity to reduce potential detrimental behaviors. The proposed alternatives will reduce the future opportunities for motorized recreation to expand into these roadless areas in the future and will therefore reduce the quality and availability of these opportunities in the future. This EIS must consider these issues and the long-term effects of this decision.

The EIS must recognize that the inventoried and uninventoried roadless areas currently provide a level of motorized recreation on the unclassified roads. In order to be accurate, this use must be recognized. Therefore, any decision to restrict use these roads must be based on a thorough and complete inventory of all existing facilities and existing use levels. Without making this determination, it will be impossible to accurately determine the true impacts from the proposed alternatives.

In order to contain a full range of alternatives, this EIS must consider alternatives that will allow road construction and commodity production in existing inventoried and uninventoried roadless areas under existing or more restrictive environmental regulations. The ecological conditions in these roadless areas may be preserved through development of an effective management plan and a diligent implementation of environmental protections. These possibilities must be analyzed and disclosed in the EIS.

This EIS must consider the environmental effects of failing to recognize, manage and maintain the unclassified roads that currently exist in the roadless areas if these roads are left open and the loss of recreation opportunities if they are eliminated. The NOI recognizes that roads currently exist in these identified roadless areas. Failure to effectively maintain and monitor these existing roads is a violation of nearly all existing Forest and Resource Management Plans. If this failure to act continues under any of these alternatives this information must be disclosed and the environmental effects of this failure must be analyzed.

This EIS must consider the economic effects on national economy, the auto manufacturers and OHV manufacturers resulting from the perception that National Forest lands will be less accessible after the decision. Currently the largest selling class of Automobile is the Sport Utility Vehicle and light truck. The marketing for these vehicles emphasizes the desire and capability for people to get out into the backcountry. The fastest selling off-highway vehicle is the ATV. Marketing of these vehicles also capitalizes on the public's ability to access remote areas. Any decision to reduce the public's ability to access remote areas that are identified as roadless will have an effect on the sales and marketing of these vehicles. The degree of impact and the over-all economic effects of any changes in the sales of these vehicles must be identified, analyzed and disclosed in this EIS.

This EIS should exempt all roadless areas that have been reviewed and analyzed during the normal forest planning processes and considered unsuitable for Wilderness and available for commodity production. The current NOI identifies the possibility of exempting the Tongass National Forest from analysis because of the completion of the Tongass Management Plan. Not only should the Tongass NF be exempt from this analysis, all National forests that have completed management plans that have addressed the conditions and status of inventories roadless should be exempt from this process.

This EIS must consider if, in fact, the protection of unroaded characteristics and benefits, for each area, is truly in the best interest of the nation and the people since a large amount of land is already preserved in this condition. The NOI limits the possible alternatives too only those that will result in preservation of roadless areas. This decision assumes that such action is in the best interest of the nation. In actuality, this determination has not been made through any public process and therefore, this EIS must make that determination prior to any subsequent analysis process.

This EIS must identify and quantify all existing routes within roadless areas that may qualify as a public right-of-way under RS 2477 even though no assertions have been made to date. This action will be necessary to accurately analyze the potential future environmental conditions should assertions be made at a later date. The NOI admits to the existence of roads in the roadless areas. Since there is a good possibility that many of these roads may have a historical contest and could qualify as public rights-of-way under RS 2477, it is important to identify these routes if a complete analysis of potential impacts is to be made. If these routes are not identified at this time, even if no assertion has been made, it will not be possible to determine or predict the long-range ecological conditions that will exist in the future.

This EIS must analyze the complete effects on rural community schools and roads resulting from the loss of revenue from forgone commodity production on areas preserved as roadless. Existing law passes a part of the National Forest revenues derived from commodity production to the counties for support of schools and roads. Any decision that limits potential commodity production will decrease the amounts of funds available for these purposes. The potential effects of this decline in revenues could be significant. They could include reductions in the quality of education received by the current school children with all of its long-term implications. They could also include the need to increase state and local sales or property taxes to offset the reductions. These tax increases could have a long-term effect on individuals living on fixed incomes by reducing their ability to own property and support themselves. All of these implications must be analyzed and disclosed in this EIS.

The EIS must address the effects on the Forest Service's ability to protect National Forest land that will result from FS budget reductions if current legislation is passed to require the Forest Service to make up for the loss of revenue from forgone commodity production on areas preserved as roadless. Proposed changes in the law addressing the support of schools and road from NF revenues will require the Forest Service to make up any shortfall in the funds available from national forest commodity production from the agency budget. If this occurs, it is reasonable to assume that other NF programs may suffer. This could result in further reductions in the ability to maintain Forest Service roads, trails and facilities. It could also reduce the funds available for wildlife or fisheries enhancement projects. The long-term effects of this potential budget reduction caused by eliminating production from the roadless areas need to be identified, analyzed and disclosed in this EIS.

The Notice of Intent clearly indicates that a decision to protect the roadless character of inventoried roadless areas has already been made. This is a violation of the NEPA requirement to analyze a "full range of alternatives" since any alternative that could lead to development in roadless areas is precluded. It is critical that any analysis that is conducted on this issue be in full compliance with the requirements of NEPA. The scope of the document should include the possibility of development of any of the roadless areas.

The NOI admits that roads actually exist in inventoried roadless areas by including the statement that road construction will be restricted in "unroaded portions of inventoried roadless areas." This admission that roads exist in roadless area casts a cloud on the accuracy of the process used to identify these roadless areas. This process must be corrected prior to any decisions being developed that relies on the existing identification of roadless areas. All roadless areas need to be reinventoried to ensure that they are truly roadless and the boundaries should be adjusted to ensure that existing roads are excluded.

Because of the fact that the Forest Service is currently involved in a significant number of rule making and planning efforts, including the Roads Analysis Process, the revision of the Planning Rules, numerous individual Forest Plan revisions as well as this effort, the ability for the public to provide meaningful comments is being seriously effected. Therefore, I request that you grant an extension of at least 60 days to the initial comment period for scoping of this EIS.

Thank you for your consideration. Please place my name on the mailing list for this document and send me any future newsletters, notifications or information. I would also like to receive a copy of the Draft EIS when it is issued. I look forward to hearing from you. If you have any questions or concerns, I can be reached at 208 762-2298.

Sincerely,

Tom Crimmins