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Roadless Area Conservation Hearings Complete!

The comment period is over and we now await a decision on the future of national forest lands-- the High Uintas, in particular-- that will be as important as any we've seen in many decades! Maybe a million comments were received by the Forest Service, most of them apparently supporting the protection of roadless areas. Let us hope the support is deep and not just broad and easily scripted with the use of a simple postcard! Nonetheless, both the proposal by the Forest Service and the response has been overwhelming.

Of course, we have worked hard and support the proposed Roadless Area Conservation Rule and Draft EIS (DEIS). This is what should have been initiated in the early 1970s with the first Roadless Area Review and Evaluation (RARE). The agency should have learned and set RARE II of the late 70s and early 80s in the proper motion but didn't. Along came forest plans and a sort-of-RARE III. Roadless areas were still brushed aside by far too many within the Forest Service, despite their obvious ecological importance and profound social import.

The Forest Service is to be commended for such an efficient and open process. While many suggest this is or could be the legacy of President Clinton because of his October 1999 directive to initiate this rulemaking, we still hope this will be the legacy of the Forest Service.

Nonetheless, the proposed rulemaking and DEIS are a bit too reticent to achieve that legacy and resolve all of the errors of previous roadless initiatives. This is clearly and plainly noted in the DEIS itself-- using the data prepared by the Forest Service the DEIS unambiguously notes roadless areas and their associated values will best be protected, with only a minimum short-term disturbance to other concerns, by selecting the alternative(s) which protects all roadless lands and prohibits commercial logging activities within those roadless areas.


The DEIS reveals that over the next five years 220 million board feet of annual timber sales would come from roadless areas. This is only about 7% of the planned timber program offered by the Forest Service. Of considerable importance this is a fraction of a percent of the total timber production in the United States. It is true and should not be denied by anybody that in some highly specific locales the reliance on roadless area timber sales is high and the impact of removing those sales w ill create some temporary discomfort. But the irony is that discomfort is coming, regardless, due to a long history of timber harvesting that has exceeded non-timber resource/value biological constraints, and will also result in the loss of roadless area values. This represents a loss on both sides of the proverbial coin and gives rise to the concern to protect roadless values because the opportunity to mitigate and respond to the loss of logging opportunities is high.

Very few communities in this day and age are so inelastic that they can't respond to new economic incentives-- the DEIS is also clear on this point. Neither the Ashley nor the Wasatch National Forest was proposing any meaningful roadless area timber sales-- due, in part, to your concerns and vigilance!-- and no local communities around the Uintas have any dependence upon roadless area timber.

While we understand the need for flexibility to assure public health and safety is not compromised by fire or catastrophic events where they may render harm outside the sphere of a roadless landscape, the DEIS is clear that roadless areas represent a low fire risk and are in far less need of forest health treatments than the areas already treated. Thus the DEIS and rule should make it clear that salvage logging should be prohibited after natural disturbance regimes.

Tongass National Forest

It would be a substantive mistake to leave the Tongass National Forest out of the immediacy of this process. It would be a continuation of the historical mistakes of the past roadless initiatives. Again the DEIS notes that the Tongass National Forest is so unique largely due to the "quantity and quality of the inventoried roadless areas."

Uninventoried Roadless Areas

Obviously we support the protection of uninventoried roadless areas-- most of these will be less than 5,000 acres. Our experience has shown that many of these areas are part of larger roadless areas chopped off for "manageability" or resource use . The literature suggests that even these smaller roadless areas, sometimes even as disjunct and isolated areas, would serve to enhance biodiversity and provide alternate habitat and corridors.

The DEIS fails, though, to actually protect these areas by deferring consideration until the forest plan is initiated and completed. That has been anything but a smooth and timely process! We would suggest protecting these through both the project-level analysis/planning (interim protection) as well as through the formal (permanent protection) forest planning revision planning process.

Off-Road Vehicles

This represents a significant and troubling issue. If roadless areas are open to motorized vehicles, including snowmobiles, the whole context of a roadless area is lost. It is no longer defined by natural disturbance regimes but by intensive motorized human use. Thus the final rule and DEIS need to end these kinds of uses within roadless areas. This is as important as ending logging in roadless areas. This should be done through project-level analysis/planning amendments of travel plans and/or forest plan revision. It is simply an oxymoron to speak of roadless areas while allowing motorized vehicles in these areas, arguing they don't need roads.

Mining and Leasing

The best way to handle this issue is through project level and forest planning decision using the restriction on road access to guide the context of mineral entry and leasing.

This proposal is, nonetheless, as profound a change in Forest Service policy as has ever been met, sweeping ever so slowly in the direction conservationists put us on over 100 years ago.

Dick Carter

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