We have some serious reservations about how this process has begun. The Notice of Intent (NOI), published in the Federal Register, raises important questions:

SUMMARY

1. NOI is unclear on whether proper NEPA procedures will be followed. The agency must clarify and state under which rules it will proceed (such as 36 CFR Part 217).

2. We question the purpose and need of a uniform top-down national policy to protect roadless and unroaded areas. We feel protection is best addressed by local land managers in individual unit plans.

3. The NOI has failed to acknowledge the issues and concerns presented by the recreation community during the IRR process.

4. The NOI suggests an unbalanced range of alternatives at the beginning of the scoping period, as opposed to formulating alternatives in response to issues identified during scoping per NEPA.

5. We request a clarification and re-statement of the NOI to address these procedural concerns, as well as a 90 day extension to the comment period. The BlueRibbon Coalition is committed to participating in a fair and balanced process. We need assurances at this initial stage that this will take place.

DISCUSSION

We assume that the process will follow National Environmental Policy Act (NEPA) procedures. This needs to be clarified, since the NOI only makes a passing reference to NEPA.

We must make sure the agency follows its own rules. Forest Service failed to follow NEPA when it established the Interim Road Rule (IRR). BlueRibbon and other organizations filed appeals on the IRR (which contained a procedurally flawed Environmental Assessment (EA) and Finding of No Significant Impact (FONZI)). Our appeals were ignored. The Frontiers for Freedom and the United Four Wheel Drive Association filed suit against the IRR. These suits and appeals cited serious NEPA errors.

This is not a minor technical point. We need assurances that the agency intends to follow its own rules (such as 36 CFR Part 217 for programmatic plans)in this process.

The NOI states that National Forest roadless (and unroaded) areas need protection in the form of a policy that establishes national criteria and procedures. We question this purpose and need.

We contend that top-down "criteria and procedures" will shackle local land managers and inhibit them from making decisions that will benefit the resource and provide the goods and services needed from our National Forests. As such, we question whether such a rule can conform to the mandates of the National Forest Management Act and the Sustained Yield Multiple Use Act as well as the other laws under which the Forest Service operates.

The NOI cites the public's comments on the Interim Roadless Rule (IRR) as one rationale for proceeding with this national roadless protection process. It notes the volume of comments. It fails to mention that a significant number of the cited 80,000 comments were received as a result of a national campaign by environmental groups prior to the opening of the IRR comment process.

BlueRibbon and other recreation and resource groups participated vigorously in the IRR process. None of our comments are acknowledged in the NOI such as:

* The wholesale disenfranchising of thousands of miles of road as they become "unclassified" and lands become "unroaded".
* The importance of primitive roads and the unique recreation experience they provide.
* The importance of providing for diverse and dispersed recreation.
* The loss of public access to public lands.

The NOI ignores our comments. This does not give us confidence that our issues will be sufficiently addressed during this scoping period.

The NOI suggests possible alternatives to be considered in the draft environmental impact statement. It is highly irregular to "suggest" alternatives prior to the scoping process. The NEPA process mandates that issues are identified during the scoping process, and alternatives are subsequently developed that respond to the issues.

The presentation of alternatives at this stage indicates that the agency has hard-wired the draft EIS to assure a specific outcome. We are concerned that NEPA, which is designed to result in a fair and balanced decision, is being short-circuited.

The suggested action alternatives all support prohibition of activities to a varying degree. We are extremely concerned about the third suggestion which prohibits the implementation of all activities! This extreme suggestion presented by the agency at this early stage is highly irresponsible!

In any case, the suggested alternatives are unbalanced, an insufficient range, and a violation of NEPA. We will request addition of other alternatives that respond to active management of these roadless and unroaded lands, for example:

* Provide for the acknowledgment of primitive roads that provide recreation challenge and opportunity for a variety of motorized uses.
* Provide for the conversion of roads and construction of trails for a variety of recreational uses.
* Provide for the construction of temporary roads for resource extraction, which as you realize, can be crucial for forest health.

However, it should be made clear that NO alternatives will be considered until the end of this scoping period.

The BlueRibbon Coalition is committed to participate fully in a fair and equitable process. We must be assured that the process is truly fair. The NOI gives us serious concerns in this regard.

We request clarification by the agency that a proper NEPA process has been initiated and will be followed. We request a re-statement of the NOI that reflects a possible variety and scope of issues that will be addressed in the DEIS, and does not suggest alternatives. Due to the complexity and scope of the proposal, and the muddle created by the flawed NOI, we request an additional 90 days in the scoping period so that issues can be properly identified.

Adena Cook, Public Lands Director
BlueRibbon Coalition
P.O. Box 1427
Idaho Falls, ID 83403
Phone: 208-524-3062; Fax: 208-524-2836
e-mail: bradena@sharetrail