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group DEIS sign-on letter

The following is the cover letter and comments on the Forest Service's Roadless Area Conservation DEIS for which we are seeking sign-on from as many organizations as possible. During the scoping process, in excess of 300 organizations signed on to our comments and we would like to exceed that number this time around. Please feel free to post to other listservs and circulate within your other networks.

Organizations that are interested in signing on should send an e-mail to Lesley Keith at [email protected]. PLEASE include ALL of the following information (for each group signing) and send it in this format:

Title (if applicable)
Street Address
City, State, ZIP CODE
Phone number
Email (optional)

Lesley can also be called at 503-283-6343, Ext. 201 with this information.

July 12, 2000

Mike Dombeck, Chief
USDA Forest Service - CAET
P.O. Box 221090
Attn: Roadless Areas Proposed Rule
Salt Lake City, Utah 84122

Dear Chief Dombeck:

The Heritage Forests Campaign is an alliance of conservationists, educators, scientists, clergy, and ordinary Americans who are working together to ensure our unprotected scenic wilderness forests are permanently protected. As partners and supporters of the Campaign, we are submitting the attached comments on the proposed Roadless Area Conservation Rule and Draft Environmental Impact Statement, which were released in May 2000. We may also submit additional comments on behalf of ourselves or our respective organizations.

Over the past year, we and more than half a million other citizens have asked for a national policy that permanently protects roadless areas one thousand acres and larger on all national forests from logging, road building, mining, and other destructive activities. We were very encouraged by President Clinton's October 13 remarks and the Administration's intent to permanently protect what remains of our wild forest heritage across the National Forest System. In December, many of us wrote to you reiterating our support for strong and immediate protection for all roadless areas and expressing some concerns about the Forest Service's proposed process for implementing the President's plan.

While we appreciate the tremendous effort the Forest Service has made in developing the proposed rule and Draft EIS, we are very disappointed about three major deficiencies of the proposal. First, it does not prohibit logging within inventoried roadless areas. Second, it exempts the roadless areas in the Tongass National Forest from the national prohibition on road construction. Third, it provides no immediate protection for the uninventoried roadless areas greater than 1,000 acres. In addition, the policy does not protect roadless areas from mining or dirt bikes and other off-road vehicles.

These weaknesses cause the proposed policy to fall far short of the "strong and lasting" protection for roadless areas that President Clinton called for in October. However, as discussed in the attached comments, we believe that the information and alternatives contained in the Draft EIS provide a compelling scientific and legal basis for selection of a final policy that adequately protects roadless areas.

We strongly urge you to adopt a final rule and preferred alternative that is consistent with the following recommendations:

·Immediately prohibit road building and logging (for both commodity and non-commodity purposes) in all national forest roadless areas.

·Do not exempt the Tongass National Forest from the national prohibition on road building and logging. As America's largest national forest and the heart of the last great temperate coastal rainforest on earth, protection of the Tongass' roadless areas is a key test of our country's commitment to rainforest conservation.

·Provide interim protection from road building, logging, and other destructive activities for all non-inventoried roadless areas of 1,000 acres or more, pending local forest plan revisions.

·Permanently protect all roadless areas from all environmentally destructive activities, including mining, off-road recreational vehicle use, and ski area development.

President Clinton's roadless area directive represents an historic opportunity for the Forest Service to create a magnificent legacy of wild forestlands for present and future generations. We urge you to make the necessary changes in the final rule and EIS to realize this vision.



We believe that the Forest Service's proposed roadless area conservation falls far short of the directive that President Clinton presented on October 13, 1999, when he stated his desire to "provide strong and lasting protection" for the remaining roadless areas in the national forests. We commend the Forest Service for its extraordinary efforts to involve the public and to produce a draft environmental impact statement (DEIS) on the proposed policy. However, the Forest Service proposal does not fulfill the primary purpose and need identified in the DEIS -- to "immediately stop activities that have the greatest likelihood of degrading desirable characteristics of inventoried roadless areas."

In order to comply with the directive of the President to safeguard our remaining roadless forests, and to fulfill the purpose and need of the agency's action, the final policy must be significantly strengthened and improved. Fortunately, the DEIS provides the scientific and legal basis for producing a final policy that will substantially safeguard this magnificent natural legacy for present and future generations.

Indeed, as discussed below, the DEIS leads to the inescapable conclusion that in order to provide long-term, meaningful protection, the agency must adopt a stronger policy. The proposed prohibition on new roads provides uncertain protection for most roadless areas, and no protection at all for Alaska's Tongass National Forest. According to the DEIS, logging and road construction are the two activities that most significantly alter the characteristics of roadless areas. However, the proposed alternative reduces road construction in roadless areas by only 40%, and logging by only 27%. The policy alternative that prohibits both logging and road building in roadless areas in all national forests clearly will best meet the purpose and need as well as the President's directive to protect these areas.


We urge the Forest Service to select a final policy that prohibits all logging in roadless areas. While a road-building ban will effectively prevent commercial logging in some areas, it will allow logging in too many other areas where it is possible using helicopters, forwarders, cable yarders, and other equipment that does not require immediate road access. In fact, the DEIS estimates that nearly half of the roadless area timber slated for logging in the next five years outside Alaska could be logged without additional road construction.

Scientific and economic information contained in the DEIS argues convincingly for prohibiting logging as well as road building in roadless areas. The DEIS concludes that a wide array of environmental resources and values ranging from water quality to wildlife to recreation would all benefit from a ban on logging.

The effect of prohibiting roadless area timber sales on the timber industry and employment would be minimal. Forgoing the entire 220 million board feet of annual timber sale offerings in roadless areas over the next five years would result in only a 7% reduction in the Forest Service's planned timber sale program. The impact on total U.S. timber production, which averages about 83 billion board feet per year, would be miniscule about ¼ of 1%. Similarly, the DEIS estimates that a prohibition on roadless area logging would theoretically result in a loss of just 820 timber jobs, which is 3% of all national forest-based direct timber jobs and less than one-tenth of 1% of all U.S. wood products employment.

Forest Health and Fire

Despite acknowledging the environmental superiority of alternatives that prohibit logging, the Forest Service evidently concludes that the benefits of "forest health" logging in roadless areas outweigh the environmental damage. Specifically, the agency seems to believe that logging in roadless areas will "provide opportunities for achieving other multiple-use benefits, such as ? vegetative treatments to reduce the risk of wildland fire, and insect and disease infestations" (DEIS, p. 1-12).

We disagree that commercial logging of roadless areas is needed to reduce fire risk and cure insect and disease problems. According to scientists in the Sierra Nevada Ecosystem Project, logging is the single greatest cause of increased fire risk. The DEIS acknowledges "uncertainty" among fire researchers about the effects of timber harvest or thinning on fire risk, due to factors such as increased drying and wind (p. 3-156). Moreover, as documented in the DEIS, "Areas that are more highly roaded have a higher potential for catastrophic wildfires than inventoried roadless areas" (p. 3-157). In addition, "relatively few inventoried roadless areas are located near the Wildland-Urban Interface where high concentrations of people dwell, recreate, or work" (p. 3-154). Consequently, there is less need to be concerned about roadless area fires threatening human life or property.

Thus, it makes no sense for the Forest Service to use roadless areas as experimental sites for logging methods to reduce fire risk. The agency administers many millions of acres of previously roaded national forest land that have a higher fire risk and are closer to human settlements than the roadless areas. 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). Many roadless areas can be successfully treated with prescribed fire to reduce risk of high-intensity fire, thereby contributing to the agency's overall effort to reduce fire risk.


Any proposal to protect roadless areas that excludes the largest national forest from those protections is clearly inadequate. We are adamantly opposed to exempting the Tongass National Forest (or any other national forest) from the road building and timber sale prohibitions in the roadless area conservation policy. The Tongass exemption would allow up to 512 miles of road development and 539 million board feet of logging in roadless areas during the coming five years (DEIS, p. 3-232). Tongass roadless logging constitutes about half of the logging planned for roadless areas across the entire National Forest System. The DEIS explains why it is important to prohibit these destructive activities in the Tongass roadless areas:

·"The [Tongass] Forest's high degree of biological integrity and overall ecosystem health is largely due to the quantity and quality of the inventoried roadless areas" (p. 3-226).

·"Preserving roadless areas is central to maintaining a high degree of biological integrity?. [T]he loss of unroaded areas may pose a considerably higher risk of species existence and persistence" (p. 3-227).

·"The Tongass National Forest is unique because the majority of subsistence and game species, for example Sitka black-tailed deer, marten, wolf, brown bear, salmon, trout, and steelhead, are integrally linked to habitat qualities, including intact old growth and riparian habitats, provided by roadless areas" (p. 3-228).

Continued commercial logging of the Tongass roadless areas also makes no sense economically, since the federal government will lose millions of dollars through below-cost timber sales. According to the DEIS, timber sales in the Tongass National Forest result in a net revenue loss of $178 per thousand board feet of timber (p. 3-184). At that rate, offering 539 million board feet of Tongass roadless area timber sales over the next 5 years would result in a total net loss to the government of about $96 million. The DEIS estimates that continued roadless area logging in the Tongass National Forest would likely generate 298 timber-related jobs (p. 3-232). Thus, excluding the Tongass from roadless area protection could cost American taxpayers $322,000 per timber job on the Tongass over the next 5 years, or $64,400 per job per year.

The economy of Southeast Alaska is well along in a transition away from its historic dependence on timber. In 1999, the forest products industry produced just 3.4% of all jobs in Southeast Alaska, down from 13% in 1975. While timber employment has diminished considerably in recent years, the rest of the regional economy has grown. Between 1988 and 1997, total employment in the region grew by nearly 25%, exceeding the national average. Recreation and tourism have been particularly vibrant, as indicated by increases of 46% in retail trade and 48% in services between 1985 and 1995. A ban on roadless area logging would potentially decrease total employment in the region by just eight-tenths of 1%, a reduction that, over time, would be more than offset by job growth in other sectors. The Tongass National Forest, with its dramatic and undisturbed landscapes, provides most of the region's recreational and tourism opportunities and natural amenities. Accordingly, preserving the Tongass roadless areas is essential to the economic well-being of Southeast Alaska.

We reject the Forest Service's suggestion that the Tongass Timber Reform Act (TTRA) requires continued logging of the Tongass roadless areas. Section 101 of the TTRA directs the agency to "seek to provide a supply of timber from the Tongass National Forest which meets the annual market demand for timber from such forest?." However, this direction is subject to other applicable law and to providing for multiple use and sustained yield of all renewable forest resources. The courts have ruled that TTRA requires no set amount of logging. According to the Ninth Circuit Court of Appeals, "TTRA envisions not an inflexible harvest level, but a balancing of the market, the law, and other uses, including preservation." Alaska Wilderness Rec. & Tourism Assn. v. Morrison, 67 F.3d 723, 731 (9th Cir. 1995) (emphasis added). Moreover, the DEIS acknowledges that demand for Tongass timber "is less than proposed offer levels under current market conditions" (DEIS, p. 3-229). In fact, 44 million board feet of timber was exported from the Tongass last year due to lack of regional market demand.


We support effective and permanent protection for all roadless areas greater than 1,000 acres in the national forests. While the vast majority of roadless areas smaller than 5,000 acres have never been inventoried, there is broad scientific consensus on the importance of these areas. We were heartened in October when President Clinton directed the Forest Service to "determine whether long-term protection is warranted for any smaller 'roadless' areas not yet inventoried."

Unfortunately, the proposed policy provides no immediate protection for uninventoried roadless areas. Instead, it defers any consideration of such areas well into the future when local forest management plans are revised. Two of the "procedural" alternatives (Alt. C and D) included in the DEIS would speed up the potential recognition and protection of uninventoried areas by requiring their evaluation during project-level planning, such as for proposed timber sales. Alternative C would require consideration of uninventoried roadless areas in project planning but not in forest planning, while Alternative D would require the evaluations at both the project and forest plan levels.

We believe the final policy should incorporate the two-level evaluation of uninventoried roadless areas as provided in Alternative D, but with the important addition of project- level interim protection. Interim protection will prevent short-term destruction of valuable roadless areas and maintain options for long-term protection through the forest planning process. The Forest Service has adopted interim protection measures for old-growth forests and riparian areas at the regional level (i.e. the "eastside screens," CASPO, and PACFISH/INFISH). Similar protection should be extended to uninventoried roadless areas through this national rulemaking process.



We oppose hardrock mining, oil and gas drilling, and other mineral development in roadless areas. Mining has the potential to impact all of the ecological and amenity values of roadless areas from water quality to solitude. Mining access roads are as destructive as logging roads and are often driven deep into the most remote roadless area watersheds. Mine sites become permanent scars on the land. While the proposed road construction ban would effectively curtail at least some new oil and gas drilling, it would not limit hardrock mining conducted under the General Mining Law of 1872. We urge the Forest Service to utilize its full legal regulatory authority to protect roadless areas from mining. Areas that are threatened by mining should be segregated and withdrawn from mineral development, pursuant to Section 204 of the Federal Lands Policy and Management Act. In addition, the final rule should require Forest Service managers to conduct surface-use and valid existing rights determinations prior to any mining activity in roadless areas.

Off-Road Vehicles

We oppose the indiscriminate and environmentally destructive use of dirt bikes and other off-road motorized vehicles (ORVs) in roadless areas. ORVs have become increasingly damaging to roadless area values, as vehicles have become more powerful and numerous. Thousands of illegal "user-created" routes, many of them within roadless areas, have been established by repeated ORV use. While the National Park Service and Bureau of Land Management have recently taken actions to control ORV use at the national level, the Forest Service has not. We recommend that the final rule restrict ORV use to existing legal routes, impose a moratorium on any new ORV trail developments in roadless areas, require Forest Service managers to close user-created routes, and ban cross-country ORV travel in roadless areas. These national policy actions can be implemented in part through the project-level and forest plan revision processes, with added interim protection as discussed above (see section on uninventoried roadless areas). We also recommend that the final policy drop the reference to "motorized" dispersed recreation as a characteristic of roadless and unroaded areas to be considered in the forest plan revision process (p. A-27, § 294.13(a)(5)).

Ski Area Developments

We are pleased that the proposed prohibition on road building includes proposed ski area developments. Numerous proposals to expand or build downhill ski areas are threatening roadless areas, including Pelican Butte and Mount Ashland in Oregon, Copper and Beaver Creek in Colorado, and Sherwin and Mammoth/June in California. Ski area developments degrade water quality, disturb sensitive sub-alpine plant communities, sever important wildlife migration corridors, and destroy natural quiet and solitude. In addition, ski areas are increasingly being built or expanded primarily to attract real estate investments, rather than to meet recreational demand. Downhill skiing activity has been stagnant for the past decade, while second home construction near ski areas has boomed. The final policy must not create any special exemptions of any kind for new ski area construction or expansion.

Inventoried Roadless Areas

We are pleased that the draft policy includes roadless areas identified in the Southern Appalachian Assessment in the definition of inventoried roadless areas (p. A-8). However, the definition still omits many roadless areas both in the Southern Appalachians and elsewhere that have never been inventoried for one reason or another. Some areas, such as Dolly Sods in West Virginia and Lamb Brook in Vermont, were acquired by the Forest Service after the 1979 RARE II inventory and have not been inventoried in a forest plan or regional assessment. In Washington State, omitted roadless lands include entire areas such as Lookout Mountain (12,000 acres), lands adjacent to inventoried roadless areas such as Granite Mountain (27,000 acres), and lands adjacent to designated wilderness such as the Alpine Lakes Wilderness (75,000 acres). While it may not be possible to evaluate such areas in the final EIS, we recommend that the final policy direct the Forest Service to accord them interim protection and to include them in the roadless area inventory through project or plan revision processes.

Roads, Unroaded Areas, and Catastrophic Events

We are concerned about the possibility that roadless areas could be disqualified from protection due to the presence of unclassified "ghost" roads. We are pleased that the draft policy specifies that portions of inventoried roadless areas will be omitted only when a "classified road has been constructed" since the past inventory (p. A-27). The final rule should make it clear that the existence of user-created and other unclassified roads is not an appropriate reason to remove a roadless area from the inventory.

We are also concerned about the possibility for on-the-ground abuse of the proposed exemption of "catastrophic events" from the prohibitions (p. A-27, § 294.12(b)(1)). The draft policy states that the exception is not intended to cover "routine forest health activities, such as temporary road construction for thinning to reduce mortality due to insect and disease infestation" (p. A-9). However, Forest Service managers in the past have commonly viewed wild fire, blowdown, and other natural disturbances as "catastrophic events" that warrant salvage logging. The final rule should specify that salvage logging, either before or after natural disturbances, is prohibited in roadless areas.

Range of Alternatives

We are disappointed that the Forest Service did not consider an alternative that immediately prohibits the full array of destructive activities in roadless areas, as was requested in the vast majority of the over half-million scoping comments. In particular, the DEIS does not include an alternative that immediately and permanently prohibits all mining and off-road vehicle use (as well as road building and logging) in both inventoried and uninventoried roadless areas. We recognize that it may not be feasible, as part of the current rulemaking and EIS process, for the agency to collect sufficient data on all these destructive activities and uninventoried areas. We do not want the Forest Service to issue a supplemental EIS or undertake additional analyses that would delay completion of the roadless area rulemaking process. Nevertheless, as discussed above, we believe that the final policy and EIS can and should be strengthened in ways that will provide secure, interim protection while the necessary information is gathered. The DEIS contains sufficient information and analysis needed to create a sound final rule that provides adequate prohibitions, interim protections, and procedural safeguards for all roadless areas.
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