|
|
| EXPLORE, ENJOY AND PROTECT THE PLANET |
|
|
September 2, 2001
USDA Forest Service-CAT Attention: Roadless ANPR Comments P.O. Box 221090 Salt Lake City, Utah 84122 RE: Advanced notice of proposed rulemaking; request for comment. National Forest System Land and Resource Management Planning Special Areas: Roadless Area Conservation Dear Chief Dale Bosworth; I was one of a group of 15 Sierra Club members from Oklahoma who attended and submitted comments at the June 20, 2000, public hearing on the Roadless Area Conservation Rule held in Mena, Arkansas. At that meeting, as at many other public hearings, the overwhelming majority of statements were in support of the Rule as published in the Federal Register on January 12, 2001. The meeting was preceded by the legally required notification of all interested parties and was highly publicized. Failure to attend or submit comments could only indicate lack of interest or diligence. We took time off work and drove four to six hours each way to attend that meeting. We are now perplexed and frustrated that the Forest Service is considering amending a rule developed after collecting comments from over 1.6 million people, 95% of which support the Rule, at over 600 public meetings. I am requesting that you:
Question 1: What is the appropriate role of local forest planning as required by NFMA in evaluating protection and management of Inventoried Roadless Areas? Comment: The local planning process has resulted in an unmanageable road maintenance backlog and the destruction of 2.8 million acres of roadless area. Current forest plans make 60% of the remaining roadless areas available for road construction, logging and other development. Without the Rule this loss of roadless areas will continue, particularly since the Bush administration is revising the planning regulations to limit public participation and environmental standards. Question 2: What is the best way for the Forest Service to work with the variety of States, tribes, local communities, other organizations and individuals in a collaborative manner to ensure that concerns about roadless values are heard and addressed through a fair and open process? Comment: As noted above, the Roadless Area Conservation Rule was the result of the most extensive public involvement of any federal rulemaking. The existing processes are working. Processes that de-emphasize the voice of the public, such as collaborative panels, are anti-democratic and should not be used as Forest Service planning procedures. Question 3: How should inventoried roadless areas be managed to provide for healthy forests, including protection from severe wildfires and buildup of hazardous fuels as well as to provide for the detection and prevention of insect and disease outbreak? Comment: Roadless areas are the most resistant forest areas with regard to wildfire and disease. The best strategy for controlling fire and disease is to protect roadless areas. The Forest Service has stated that less than 2% of the inventoried roadless areas are at risk to these threats and 98% of wildfires in inventoried roadless areas have been controlled without building roads. Further, the Rule allows exceptions for emergencies of this nature. Question 4: How should communities and private property near inventoried roadless areas be protected from the risks associated with natural events, such as major wildfires that may occur on adjacent federal lands? Comment: Communities should limit sprawl and development adjacent to wildlands. Choosing to construct facilities in fire or flood prone locations should be considered a voluntary risk undertaken for a benefit. Any public expenditures for thinning or other forms of logging should be limited to the urban-wildland interface of existing development.See also Question 3 above. Question 5: What is the best way to implement the laws that ensure States, tribes, organizations, and private citizens have reasonable access to property they own within Inventoried Roadless Areas? Comment: The Rule has no impact on this issue. Access by inholders is not changed. Question 6: What are the characteristics, environmental values, social and economic considerations, and other factors the Forest Service should consider as it evaluates IRA? Comment: The following values of roadless areas have been identified: Clean water, biological diversity, undisturbed landscape, recreation, scientific study, indigenous peoples cultural observances and fire and disease resistance. Since approximately 85% of the revenue generated from national forests derive from recreation activities, and less than two-tenths of one percent of the nation’s timber supply is in these areas, the most economic value can be generated by preserving the recreational values of roadless areas. Question 7: Are there specific activities that should be expressly prohibited or expressly allowed for IRA s through Forest Plan revisions or amendments? Comment: Road building, commercial logging, destructive ORV use and hard rock mining should all be prohibited from Inventoried Roadless Areas. The Rule addresses the first two issues and should be strengthened to address the latter two. Question 8: Should inventoried roadless areas selected for future roadless protection through the local forest plan revision process be proposed to Congress for wilderness designation, or should they be maintained under a specific designation for roadless area management under the forest plan? Comment: The Rule is not pertinent to this issue and no changes in it are required to address wilderness designation. Forest plans must evaluate wilderness potential of all roadless areas and recommend to Congress. The Rule does not change this, and offers protection to all roadless areas from commercial logging and road construction. Question 9: How can the Forest Service work effectively with individuals and groups with strongly competing views, values, and beliefs in evaluating and managing public lands and resources, recognizing that the agency can not meet all of the desires of all of the parties? Comment: As noted above, the Forest Service elicited the greatest public response ever received for a rulemaking on this Rule. The citizens have expressed an overwhelming support for the Rule. When it is implemented approximately 30% of national forest land will be protected as a natural legacy. The remaining 70% is open to logging, mining and drilling, which should satisfy those who disagree with the rulemaking. Question 10: What other concerns, comments, or interests relating to the protection and management of inventoried roadless areas are important? Comment: The Roadless Area Conservation Rule should be implemented without change and strengthened to stop damage to these areas by ORV use and hard rock mining. All timber sales in the Tongass National Forest that violate the Rule should be stopped immediately. This administration should defend the Rule against lawsuits and quit trying to weaken environmental safeguards and public participation processes in the development of forest plans. Thank you for the opportunity to comment. Paul Moore Conservation Chair Sierra Club Oklahoma Chapter 1611 S. Detroit Tulsa, OK 74120 cc: Rep. Brad Carson U.S. House of Representatives Washington, D.C. 20515 |
|
