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1962 YellowSubmarine
11,421 Posts
Discussion Starter · #1 ·
<font color="yellow">There are only 5 days left to submit your comments. Remember that written (or typed) hold a lot more weight than auto generated letters. If at all possible, submit a written letter, in addition to your "point and click" letter. Remember that the letters need to be postmarked by the 10th, and that "private" memtering postmarks are not counted by the FS as valid date stamps. Please get everyone you know to write and sign a letter...This may be our last chance!!!

PSD</font c>

If you have submitted your roadless area comments, thank-you.

If not, the deadline is fast approaching. All comments must be
received by Sept 10.

Use the easy to submit forms at:
http://www.outdoorwire.com (courtesy of OutdoorWire web site) http://www.icmj.com (courtesy of International California Mining Journal) http://capwiz.com/share/home/ (courtesy of Blue Ribbon Coalition)

send this letter (courtesy of Carla Boucher, United Four Wheel Drive):

USDA-Forest Service CAT
Attn.: Roadless ANPR Comments
P.O. Box 221090
Salt Lake City, UT 84122
[email protected]

August 29, 2001

Dear Roadless team,

Below please find my comments in response to the Forest Service
Advanced Notice of Proposed Rulemaking (ANPR) for the National Forest
System Land and Resource Management Planning; Special Areas; Roadless
Area Conservation, published in the Federal Register on July 10,
2001. Please adopt these comments into the formal record and utilize
them to determine the next steps in addressing management of roadless
values within the National Forest System.

Question 1: Generically speaking, forest planning as mandated by
NFMA is the appropriate arena for making determinations concerning
Roadless Area management. However;
* There must be regulations that aid Forest Supervisors and the plan
revision team that provide a consistent procedural approach to
Roadless Area management.
* Inventoried Roadless Area management decisions must not be
deferred to forest planning under the current planning regulations
adopted in the final rule issued on November 9, 2000.
* I can not possibly offer meaningful comments on the validity of
conducting roadless area management decisions through planning until
I clearly understand how "planning" will be conducted once the
planning regulations are revised. Therefore, if Roadless Area
management decisions are made through forest planning, this
rulemaking must be postponed until the Planning Rule changes are

Question 2: The best way to work with the variety of interests
concerned with management of Inventoried Roadless Areas is through
the procedural regulations suggested in Question 1 above. The Forest
Service can best work with a variety of interests by preparing
environmental analyses in conformance with NEPA.

Question 3: Each specific Inventoried Roadless Area should be
managed individually. The agency must preserve Inventoried Roadless
Areas in their exact condition as of the date of their designation as
Roadless Areas. Activities which alter the "snap shot" of the IRA
which lead to the agency's "suitability" recommendation are
prohibited, whether those activities be permanent road construction
or road decommissioning, obliteration, or closure. Therefore, the
agency is not only permitted to conduct forest health projects, even
those such as fuel load reduction through timber harvest, but is
required to do so in order to preserve the exact composition of the

Question 4: The Forest Service must make management decisions that
minimize the risk of catastrophic wildfires, insect and disease
outbreaks, and other management issues that effect the health of
neighboring forests, families, and communities.

Question 5: Until the agency has regains control over its resources,
including roads and other maintenance backlogs, the Forest Service
should avoid acquiring more property such as the private property
within inventoried roadless areas. Access route maintenance must be
a priority.

Question 6: When evaluating Roadless Areas, the Forest Service should consider
* The opportunity to provide for the nation's lumber needs
* The opportunity to provide for the nations's energy and other raw
mineral needs
* The opportunity to provide for the nation's pedestrian recreation
- how much of a need is there vs. how much of an opportunity already
exists; i.e. Designated Wilderness Areas managed by the U.S. Forest
Service comprise 18% of the total National Forest System. However,
only 4.25% of all forest visitors access Wilderness areas for their
recreational pleasure. Based upon agency statistics it would appear
as if the need for pedestrian recreation opportunities is low
* The opportunity to provide for the nation's motorized and
mechanized recreation - how much of a need is there vs. how much of
an opportunity already exists; i.e. Roads comprise just 2% of the
total National Forest System. However, 65% of all forest visitors
access roads to "drive for pleasure", recreation vehicle use per day
has increased 1000% between 1950 and 1996, and "the outlook is for
recreational road use to grow by an additional 64 percent by the year
2045". Based upon agency statistics it would appear as if the need
for motorized recreation opportunities is extremely high
* The remoteness of the roadless area (is it located near large
cities, how many miles is it from the nearest metropolitan area with
a population larger than 30,000)
* The improvements to the area (in what ways has the area been
"improved" or does the imprint of man exist - ways, roads, motorized
trails, camping facilities, buildings, cell towers, power lines,
other improvements),
* The acreage of the area (is it at least 5,000 acres in size),
* The management prescriptions of areas contiguous with the
Inventoried Roadless Area (is there a designated Wilderness
contiguous with the area, etc.)
* The current and historic uses of the area (is the area used for
canoeing, hiking, camping, cross-country skiing, OHV use, etc.),
* The economic impact upon local economies should any alternative
management decisions be implemented which change the composition of
the area or its historic uses,
* The water quality, wildlife habitat, air quality, and existence of
endangered species in the area,
* What management decisions are necessary to improve or maintain
desired levels for existing conditions (including roads, wildlife,
water, and air)
* The likelihood of catastrophic wildfire, or insect or disease outbreaks,
* The overall health of the area.

Question 7: The decision whether to expressly allow or expressly
prohibit activities should be made on a case-by-case basis at a
site-specific location.

Question 8: No change in roadless protection can occur until
Congress determines whether an area is unsuitable or suitable based
upon prior recommendations of the agency.

Under the forest plan, Inventoried Roadless Areas must be maintained
in exactly the same condition as they appeared when inventoried. The
agency has an equal obligation to preserve "suitable" characteristics
and "unsuitable" (developed/nonwild) characteristics.

Question 9: The most effective way to work with competing interests
is to let sound science be the guide to decision-making that is made
through public involvement.

Question 10:
* It is important for the public to be given information by the
agency on the impact that conformance with the Roads Policy will have
on management decisions made for Inventoried Roadless Areas.
* The Forest Service must address the cumulative impacts of three
related, yet uncoordinated rulemakings, regarding Planning,
Inventoried Roadless Area Management, and the Forest Transportation
* The agency must a make a commitment to the public to be unbiased
in its decision making and reporting. The role of the agency is to
present scientific evidence in an understandable format, not sway
public opinion.

Please consider these comments in determining management of
Inventoried Roadless Areas within our National Forests. It is an
honor to be able to partner with the agency in such an important
long-term decision. I look forward to working with the Forest
Service as this rulemaking progresses.



1962 YellowSubmarine
11,421 Posts
Discussion Starter · #2 ·
The good news is that the comment period on the Roadless policy has been
re-opened. The bad news is that we only have until September 10th to get
our comments in to the Forest Service.

Worse yet, anti-access forces are
bombarding the Forest Service with thousands of comments supporting the
Roadless Rule which limits public access to federal lands.

your comments to the Forest Service TODAY by visiting ARRA's web site
Action Center and clicking on the first Action Item.

Outdoor recreation
enthusiasts have been asking the Administration to re-open this comment
period because we do not support the Roadless policy hastily constructed by
the Clinton Administration. Now we must make sure that our voices are

If you cannot see the link above, visit ARRA's action center at http://www.responsiblerecreation.com/grassroots and click on the first
Action Item.

ARRA will continue to keep you informed on the Roadless issue
and other federal policies that affect our access to public lands and
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