THE DRAFT EIS
Alternatives
The DEIS presents and evaluates the
Proposed Rule through three sets of alternatives, each consisting of
three "action" alternatives and one "no action" alternative. The
Proposed Rule is a combination of Alternative 2 (Prohibitions),
Alternative B (Procedures), and Alternative T3 (Tongass National
Forest).
The three "Prohibition" alternatives focus on immediate
regulatory limits on road building and logging in inventoried
roadless areas. Alternative 2 (the Forest Service's preferred
alternative) bans road construction and reconstruction in all
inventoried roadless areas, except for the four types of
circumstances specified in the Proposed Rule (see above).
Alternative 3 bans new roads and "commodity-purpose" logging, but
allows "stewardship-purpose" logging in roadless areas. An example
of stewardship logging is thinning dense timber stands in advance of
prescribed burning (p. 2-5). Alternative 4 bans road building and
all forms of logging in roadless areas, but would allow firewood and
Christmas tree cutting.
The DEIS does not consider an alternative favored by
conservationists that would prohibit all environmentally damaging
activities, including off-road vehicle use and mining, in all
roadless areas greater than 1,000 acres. The DEIS states that there
is insufficient data on ORV use and impacts in roadless areas and on
uninventoried areas upon which to evaluate the effects of a
national-level prohibition (p. 1-11).
The three "Procedural" alternatives direct local agency managers
to consider additional protection of roadless and unroaded areas
through forest plan revisions and/or project-level planning.
Alternative B (the Forest Service's preferred alternative) would
require the evaluation as part of forest plan revisions, but not at
the project level. Alternative C would require roadless area
evaluations in project planning, but not in forest planning.
Alternative D would require the evaluations at both the project and
forest plan levels. These local processes would not necessarily
result in any new limitations on logging, ORVs, and mining in
roadless areas or any protection of uninventoried areas.
The three "Tongass" alternatives provide other, mostly procedural
options to deal with inventoried roadless areas in the Tongass
National Forest, in lieu of the restrictions imposed by the
Prohibition alternatives. Alternative T2 would require project-level
evaluations of roadless areas pending a forest-wide evaluation of
potential roadless area protection in 2004. Alternative T3 (the
Forest Service's preferred alternative) would require a forest-wide
evaluation of roadless area protection in 2004, but no project
evaluations. Alternative T4 would ban road building in roadless
areas within four land use classifications in the current Tongass
forest plan.
Road Building, Logging, and Economic Impact
Over the
next 5 years, the Proposed Rule would prohibit approximately 39% of
the road construction and reconstruction planned in inventoried
roadless areas - 564 miles out a total of 1,444 miles planned
nationally (p. S-36). The remaining roads would be exempt from the
road-building prohibition either because they are in the Tongass
National Forest (512 miles, 35% of the total) or they are covered by
one of the Proposed Rule's four exemptions (368 miles, 26% of the
total). Thus, the Proposed Rule would allow 61% of the planned
new road development in roadless areas to proceed, largely due to
the exemption of the Tongass from the road-building prohibition.
Of the 564 road miles that would be banned, 294 miles are
logging roads and the remainder are for non-logging purposes such as
new ski areas, irrigation projects, and utility lines (pp. 3-18 and
3-19).
The Proposed Rule does not directly prohibit logging, but it
would indirectly prevent the Forest Service from logging in roadless
areas where it is only feasible with roads. The DEIS estimates that
about 300 million board feet (mmbf) of timber sales planned for the
next 5 years would be prevented by the Proposed Rule's partial
road-building ban (p. S-29). Thus, only about 27% of the 1.1
billion board feet of the planned roadless area timber sales in the
next 5 years would be affected by the Proposed Rule, or 2% of the
projected timber sale volume on all national forest lands. Of
the 800 mmbf of timber that could be logged under the Proposed Rule,
539 mmbf would come from the Tongass National Forest, which is
exempt from the prohibition on new roads. A prohibition on all
logging in inventoried roadless areas, including those in the
Tongass, would result in only a 7% reduction in the Forest Service's
planned timber sale program (p. S-18). The impact on total U.S.
timber production, of which less than 5% currently comes from
national forest lands, would be miniscule - less than ½ of 1%.
According to the DEIS (p. 3-114), an average of 112 mmbf of
roadless area timber was sold annually between 1993-1999. Under the
Proposed Rule, the annual average timber sale volume from roadless
areas would be 168 mmbf. Thus, compared to recent history, the
amount of logging in roadless areas anticipated in the next five
years could increase by 50%.
Regarding logging in the Tongass National Forest, the DEIS
estimates that the federal government will lose millions of dollars
through below-cost timber sales in roadless areas. According to the
DEIS, timber sales in the Tongass result in a net revenue loss of
$178 per thousand board feet of timber (p. 3-184). If the Tongass
National Forest sells 539 mmbf of roadless area timber over the next
5 years as planned, the total net loss to the government, according
to the Forest Service, would be about $96 million. This is
likely a conservative estimate, since the agency typically
underestimates the costs of its timber program.
The impacts of roadless area logging on employment are
negligible. A prohibition on logging in all roadless areas
nationwide would result in a loss of only 820 timber jobs, which is
about 3% of all national forest timber jobs (p. S-19). Roadless
area logging in the Tongass National Forest would generate 298 of
those timber-related jobs (p. 3-232). Thus, excluding the Tongass
from roadless area protection will cost American taxpayers $322,000
per timber job on the Tongass over the next 5 years, or $64,400 per
job per year.
The Forest Service addresses both the socio-economic benefits and
the potential adverse effects of roadless area protection. The
economic impact analysis evaluates the effects of the alternatives
on people's "wildland values," including ecosystem services and
non-use values (pp. 3-161 to 3-166). In addition, the DEIS estimates
the potential impacts of logging and job reductions on dozens of
specific rural communities and assesses the economic resiliency of
each community (pp. 3-209 to 3-222).
Forest Health, Fire, and Environmental Effects
Given
the negligible adverse economic impacts of prohibiting logging in
roadless areas, it is difficult to discern a science-based rationale
in the DEIS for selecting a preferred alternative that bans new
roads but allows logging. For virtually all of the environmental
resource issues evaluated in the DEIS, the alternatives that ban
either commodity-purpose logging or all logging are rated as
superior to the more limited road-building ban alternative. The
ban on all logging and roads is considered the best for fish
habitat, water quality, and plants (pp. 3-86, 3-91, 3-26, 3-31),
while the ban on commercial logging is rated best for biodiversity,
wildlife habitat, and threatened and endangered species (pp. 3-68,
3-76, 3-96).
The DEIS suggests that the road-building ban was chosen as the
preferred alternative because it would "provide opportunities ... to
reduce the risk of wildland fire, and insect and disease
infestations" (p. 1-12). However, the analysis of fire risks in the
DEIS lends scant support to this rationale. For example, the DEIS
states that the no-logging alternatives would have a "minor effect
on the agency's overall forest health program" and that "the total
acres needing treatment compared to the acres actually being treated
are so small that a direct effect cannot be established" (p.
3-106). Similarly, the analysis of effects on fire suppression
states that "the effect of timber harvesting is insignificant, as is
the combined effect of no timber harvesting with no road
construction, to the overall fire suppression program" (p. 3-156).
The DEIS contains a good discussion of the adverse effects of roads
and logging on fire suppression, noting that areas with roads
"actually have a higher potential for catastrophic wildfires than
inventoried roadless areas" (p. 3-157).
Access
The DEIS repeatedly clarifies that the
prohibition on road construction will have no effect on recreational
and other forms of access to national forest lands. In addition, the
Proposed Rule specifically allows maintenance of previously
constructed roads in roadless areas. Following are some examples
from the DEIS:
- Motorized Recreation - "Prohibiting road construction and
reconstruction in the unroaded portion of inventoried roadless
areas would not affect existing motorized recreation
opportunities" (p. S-38).
- · Mining - "Construction and reconstruction of roads,
considered reasonable and necessary for locatable mineral
exploration and development would be allowed as a right of access
guaranteed by the General Mining Law of 1872" (p. S-39).
- Inholdings and Special Uses - "Under all alternatives, the use
and occupancy of NFS lands as part of a valid existing right would
be accommodated in all inventoried roadless areas and other
unroaded areas" (p. 3-140).
- Hunting and Fishing - "Existing access to hunting and fishing
opportunities in inventoried roadless areas would be maintained"
(p. 3-177).
- Livestock Grazing - "Prohibiting road construction in
inventoried roadless areas would not affect existing routes of
access to grazing allotments" (p. 3-178).
- Road Closures - "The agency has determined it will not
consider closure and decommissioning of any roads as part of this
national proposal" (p. 2-18).
If you have questions about this analysis or the DEIS, please
contact Mike Anderson, (206)
624-6430 x227.
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