SAF Roadless Area Comments to USDA Forest Service

SAF has submitted comment on the roadless area Notice of Intent (NOI) published in the Federal Register on October 19, 1999. SAF state and local chapters are encouraged to review the NOI and use the comments submitted from the national office as a base to craft their own comments. It is important that we track the comments and concerns of our membership. Please forward a copy (either electronic or paper) to the national office. If you require further assistance or have questions regarding the SAF process to take and submit positions from your chapter please contact Michael T. Goergen, Jr. at (301) 897-8720, ext. 116.

---

November 8, 1999

USDA Forest Service-CAET
Attention: Roadless Areas NOI
PO BOX 221090
Salt Lake City, Utah 84122

Dear Project Team Leader:

We write in response to the Notice of Intent (NOI) published in the Federal Register on October 19, 1999 on pages 56306 and 56307 (FR Doc. 99-27300). Based on the available alternatives presented on page 56307 under the heading "Proposal," we endorse the no action alternative (making no change in current policy). In addition to our preference of the no action alternative, we request a sixty-day extension (for a total of 120 days) on the comment period for this NOI. The issues before the Forest Service are too great for the public not to have adequate time to consider the implications of the alternatives the Forest Service presents.

The Society of American Foresters (SAF) believes that all decisions about the status of inventoried and un-inventoried roadless areas should be made through the forest planning process, at the national forest level. A rulemaking process that could affect all roadless areas through one national decision cannot address the unique forest conditions of each individual roadless area. Therefore, the Society of American Foresters, which represents more than 17,000 foresters throughout the nation, is strongly opposed to a unilateral decision to "protect" all roadless areas, which is the intent of this rulemaking process. (We note that there is no definition provided for the word "protect" and the SAF considers these lands protected already since they are national forests. SAF supports forest protection, but without definition we are concerned that managers implementing the policy will have little specific direction.)

This rulemaking process would be contrary to the Forest Service's emphasis on collaborative decision-making, the Forest Service planning process, and forest management in general. One need look no further than the Forest Service's proposed planning regulations to see how important the agency finds public involvement and collaborative decision-making at the local level. It is only appropriate to consider changing the status of roadless areas from multiple use management to some type of restricted use, on a case by case basis. In addition to being inconsistent with the planning process, this proposal would overturn existing forest plans, some of which have been developed quite recently. This is unacceptable. Citizens from all over the nation have worked to create these forest plans, they cost millions of dollars to develop, and through this possible decision these plans could become useless.

The rulemaking process also purports to address budgetary concerns. This is admirable. The Forest Service has a critical road management issue on its hands. However, we believe that issue should be addressed separately. Regardless of how serious the road maintenance backlog is, there may be times when the Forest Service will need to build a road into a roadless area. In fact, there are many recent examples of the Forest Service building roads into roadless areas for fire-fighting purposes. This proposal would prevent that access, and the condition of the forest would suffer. This is irresponsible stewardship of our national forests.

An extension of the comment period appears necessary considering the Forest Service's listing of "key concerns" members of the public noted in reaction to National Forest System Transportation System rule (64 FR 7290). The Forest Service presents some views the public expressed through that proposal, however, we believe the Agency has made a tremendous oversight by not including concerns about the prohibition of road building's effects on efforts to address forest health issues, and access for fire-fighting activities. The Society of American Foresters, the National Association of State Foresters, and others expressed these concerns, and they were not listed among the key concerns of the public. We believe the public needs to be informed of the importance of the national forest road system and the access it provides for activities that benefit ecosystem sustainability.

On page 56307 of the NOI, the Forest Service's proposal discusses developing a rule that would "initiate a two part process to protect roadless areas." The proposal lists several unacceptable alternatives. Rather than prepare a rebuttal on each alternative we would like to offer an alternative. The Society of American Foresters believes the Forest Service should develop an alternative that would give local managers a set of criteria to consider when entering roadless areas. This is far more appropriate because, as the Committee of Scientists' report points out, people could use the criteria to consider the unique nature of each roadless area, and evaluate options for desired future conditions. We would like to further develop this concept, but cannot do so in the allotted comment period.

The NOI also asks if the rulemaking should apply to the Tongass National Forest. Since we are opposed to the rulemaking process, we do not believe it should apply to the Tongass. Decisions about roadless areas in the Tongass National Forest were made in the Tongass Forest Plan. This is the appropriate level for all such decisions, therefore the rulemaking should apply to no national forest. Some will point to the unique nature of the Tongass as a reason for including it in the rulemaking process. This is precisely the reason it should not be included. Each and every roadless area is unique and should be addressed on an individual basis.

There is no doubt that there are roadless areas that should be removed from active forest management, however there are also roadless areas that need forest management. Management can be completed without building roads, but roads can, and often do reduce the cost of forest management operations. We note that one of the alternatives the Forest Service is considering would prohibit management all together. This could have disastrous consequences.

This proposed rulemaking process further demonstrates the need for legislative reform of the National Forest System. We must start with the mission of the Forest Service and the national forests. It is clear that the public, the Administration, and the Congress all have differing views about the purpose of the Forest Service and the lands for which it has stewardship responsibilities. Until we resolve these fundamental questions as a nation, efforts such as this rulemaking process will fail. Since this process basically circumvents almost every national forest's forest plan, it is clear that the planning process is broken as well. The Forest Service has made attempts to address this issue, but even if planning is improved, planning without a clear purpose is useless.

In addition to the issues we have addressed, the Society of American Foresters believes forest roads, properly constructed and maintained, are a critical part of forest management, emergency response, and recreation use, and are an increasingly important part of the rural transportation system. Roads should be constructed and maintained in an environmentally sound manner following standards, laws, and regulations. With the exception of wilderness, forest roads are an important asset in all forest ownerships, including the national forests, and should be seen as a capital investment.

The environmental laws and regulations that govern the activities of public natural resource agencies are intended to protect against environmental degradation that can result from poorly planned or constructed forest roads. As we have stated before, decisions about roads in all public forests should be made at the local level, under an overarching legal framework. The manager on the ground, with input from the public, is able to make decisions about roads based on existing laws and regulations, the values the public holds for the forest, and the needs of the individual forest.

Impacts on private, state, county, tribal, and other ownerships adjacent to federal lands should also be considered in the development of this policy. This is particularly true when the federal government is legally required to allow access across federal lands to other ownerships. When granting such access, the building of a road should not be linked to the forest management practices of the non-federal landowner.

Sincerely,

William H. Banzhaf
Executive Vice President

cc: Dan Glickman
   Mike Dombeck

---

Where to find the notice:
Federal Register: October 19, 1999 (Volume 64, Number 201)
Section: Notices
Page 56306-56307
From the Federal Register Online via GPO Access [http://www.access.gpo.gov/]

When comments are they due:
Comments should be received in writing by December 20, 1999.

Where to send your comments:
USDA Forest Service-CAET
Attention: Roadless Areas NOI
PO Box 221090
Salt Lake City, Utah 84122
E-mail: roadless/wo_caet-slc@fs.fed.us

Comments received in response to this solicitation, including names and addresses when provided, will be considered part of the public record on this proposed action and will be available for public inspection and copying.

For further information contact:
Scott Conroy
Project Team Leader
Attention: Roadless Areas NOI
USDA Forest Service
PO Box 96090
Washington, DC 20090-6090
(703) 605-5299

ABOUT THE SOCIETY The Society of American Foresters, with about 18,000 members, is the national organization that represents all segments of the forestry profession in the United States. It includes public and private practitioners, researchers, administrators, educators, and forestry students. The Society was established in 1900 by Gifford Pinchot and six other pioneer foresters. The mission of the Society of American Foresters is to advance the science, education, technology, and practice of forestry; to enhance the competency of its members; to establish professional excellence; and to use the knowledge, skills, and conservation ethic of the profession to ensure the continued health and use of forest ecosystems and the present and future availability of forest resources to benefit society. The Society is the accreditation authority for professional forestry education in the United States. The Society publishes the Journal of Forestry; the quarterlies, Forest Science, Southern Journal of Applied Forestry, Northern Journal of Applied Forestry, and Western Journal of Applied Forestry; The Forestry Source and the annual Proceedings of the Society of American Foresters national convention.

POLICY STATEMENT INDEX