|
|
|
|
|
|
|
|
|
|
|
|
|||||
| Recreational Access and Conservation - Conservation and Public Service Activities | Short Cuts | ||||
| | Introduction | News | Notices | Activities | Education | Forums | Columns | Links |
Edited by: John Stewart |
|||||
Public Comment: Roadless Area Conservation Draft Environmental Impact Statement Comments
The Forest Service is accepting public comments until July 17, 2000 on the Roadless Area Conservation Draft Environmental Impact Statement. The 4x4Wire is providing the following comments ready to send via e-mail.
Enter your e-mail address, name and address and send one of these comment letters. (All fields required)
USDA Forest Service
CAET Attn: Roadless
PO Box 221090
Salt Lake City, UT 84122
E-mail: roadlessdeis@fs.fed.us
Dear Chief Dombeck:
The only acceptable choice for your Roadless Initiative is Alternative A, "No Action." Since that alternative is never taken seriously, it makes this whole exercise a waste of my time and of the Forest Service's resources. WITHDRAW THE RULE!
You are not telling the whole story, Mr. Dombeck. While the Roadless Initiative acknowledges that off-highway-vehicle recreation belongs in roadless areas (subject to a whole host of conditions), that's not the whole story. The Roadless Initiative EIS and proposed rule is not a stand alone document. It's only a part of a Clinton/Gore natural resource agenda that is designed to keep the public off the public land.
Two other important parts are the revised Transportation Plan and the revised Forest Planning Rules. The Transportation Plan is designed to close 80% of the roads in our national forests. The revised Forest Planning Rules places restoring ecosystems to a pre-Columbian condition as the primary goal for which all national forests must be managed. That would mean virtually no human use allowed!!
With these two other pieces of the national resource agenda puzzle in place, it doesn't matter that OHVs have gained some legitimacy in roadless areas. We won't be able to get there, and if we can, there will be so many conditions that a trail has to meet that the trail won't be there, either.
The Roadless Initiative says that planning will occur on the local level. But the new planning rules jury rig the process in favor of ecosystem preservation, special interest group access, and top-down meddling.
This three-piece puzzle process may be designed to puzzle the public, but the public is capable of putting the pieces together. The Roadless Initiative is an insubstantial document that sugar coats sinister underpinnings. Come clean with the American public, Mr. Dombeck. Tell them that the Clinton/Gore administration really wants the public off the public land.
I believe the American public deserves better. Stop all this nonsense!!! Go back to the drawing board and honestly explain to the American public how their recreation access will be affected by these proposals. Our public lands should be preserved FOR the public instead of FROM the public.
USDA Forest Service
CAET Attn: Roadless
PO Box 221090
Salt Lake City, UT 84122
E-mail: roadlessdeis@fs.fed.us
Dear Chief Dombeck:
Below are my, initial, general comments on the above referenced Draft Environmental Impact Statement (DEIS). I hope to send additional, more specific comments in the very near future and as such, I would like to formally request that the comment period be extended a minimum of 120 days. Given your agency's commitment to solicit public input within the scope of NEPA, I believe that a comment extension is fully warranted in order to get the best up front public input.
General Comments:
Page S-35, section heading "The Forest Service Roads System", identifies recreation as the "...single largest use or activity supported by the Forest Service transportation system, accounting for 90% of dailytraffic...". Your documentation also concedes that roads do exist in the inventoried "roadless" areas and current use of these roads would be allowed to continue under the preferred Prohibition Alternative #2 which prohibits road construction or reconstruction within unroaded portions of inventoried roadless areas. The DEIS does not provide a clear definition as to the maintenance of these existing roads which are allowed to continue supporting existing activities.
The definitions of "reconstruction" and "maintenance" are ambiguous and lead to confusion as to the intent of the proposed rule. The "...act of keeping fixed assets in acceptable condition..." which is an acceptable maintenance activity is easily construed to a "rebuilding" activity which is prohibited.
Recreation is cited as the "SINGLE LARGEST USE OF NFS LANDS" and a significant and continuing increase in that demand is forecast. The NATIONAL FOREST SYSTEM ROAD MANAGEMENT STRATEGY, ENVIRONMENTAL ASSESSMENT and Civil Rights Impact Analysis, Dated February 9, 2000 is defined as a companion to this DEIS and calls for aggressive road decommissioning activities. I am unable to understand from these documents how the agency plans to address the rapidly increasing recreational demand for Forest access through the adoption of the preferred Alternatives of this DEIS with the contradictory approaches of these documents. For a document of this magnitude and potential impact, additional alternatives should have been fully developed and evaluated that ensure the Forest management is done in a consistent manner within the scope of this proposed rule and the NFS Road Management Strategy.
Given the significant number of acres involved, the maps included with the DEIS lack sufficient detail to determine the boundaries of the identified "inventoried roadless" areas and the inclusion (or proximity) of existing roads. The generic maps provide a pictorial display of areas and do not identify existing roads and landmarks to determine the boundaries. Without definative boundaries, it is impossible to assess the impact on local property owners and adjecent communities.
I request that the Roadless rule be withdrawn. Let wilderness land be maintained as wilderness, let multi-use land remain as multi-use.
USDA Forest Service
CAET Attn: Roadless
PO Box 221090
Salt Lake City, UT 84122
E-mail: roadlessdeis@fs.fed.us
Dear Chief Dombeck:
I wish to inform the Forest Service of my concern with the current Roadless area proposed rule. The plan to limit any future roads to only the current roads that are now in place effectively limits the ability of the Forest Service to properly administer the land as a true multi-use public resource. The plan as currently proposed will set aside 54 million acres now available as multi-use public land and set them aside to be administered basically as wilderness land. That is not what this land should be used for. This publicland should continue to be administered as multi-use land, not wilderness land.
The National Forest system currently has 22% of its 192 million acres already set aside as wilderness or natural areas. If this proposed rule is adopted, an additional 28% of the National Forest land would be set aside as permanent roadless areas. That would severely restrict the public's access to 50% of the total National Forest land. That, in my opinion, is too much public land with severely limited access - public land that is available to only a very small minority of Americans.
This proposed rule also greatly limits the ability of the Forest Service to manage forest resources far into the future. Proper forest planning needs to consider the local social, economic, recreation and resource situation based on proper science over a 30-year or longer timeframe. This proposed rule assumes that all forests are a static resource that will never require any future changes. This proposed rule assumes that only the areas that now have roads will ever require future roads and that the areas that currently do not have roads are best managed as wilderness. This proposed rule assumes that the best land use control should come directly from Washington D.C. These assumptions simply are not correct. Forests change, social needs change, land management requirements change - and the resource management people need the ability to adjust to these changes.
I request that the Roadless rule be withdrawn. Let wilderness land be maintained as wilderness, let multi-use land remain as multi-use.
USDA Forest Service
CAET Attn: Roadless
PO Box 221090
Salt Lake City, UT 84122
E-mail: roadlessdeis@fs.fed.us
Dear Chief Dombeck:
Dear Chief Dombeck:Below are my, initial, general comments on the above referenced Draft Environmental Impact Statement (DEIS). I hope to send additional, more specific comments in the very near future and as such, I would like to formally request that the comment period be extended a minimum of 120 days. Given your agency's commitment to solicit public input within the scope of NEPA, I believe that a comment extension is fully warranted in order to get the best up front public input.
General Comments:
The agency should abandon the unique and confusing definition of the term "road" and use the more reasonable and universal definition which already enjoys widespread acceptance. "Any way, travel way, two track, trail, path or other means of approach, except those whose purpose is for foot traffic only as evidenced by NEPA documentation." (i.e. the Appalachian Trail is a formally designated walking-only way). This publicly accepted definition is much more clearly understood by the 1.7 million visitors (and growing) who use these roads every day. This definition was proposed within the out o court settlement agreement between the United Four Wheel Drive Association and the Forest Service in reference to this DEIS's companion document, the NATIONAL FOREST SYSTEM ROAD MANAGEMENT STRATEGY, ENVIRONMENTAL ASSESSMENT and Civil Rights Impact Analysis, Dated February 9, 2000 which also restricted the use the terminology and definitions of road, classified road, unclassified road, or unroaded in forest planning, project implementation outside Roadless areas, or for road obliteration or closure purposes until the Forest Service subjects the definitions to public comment. The correct definition of a "road" is critical to the success of this management plan and the liberal definition applied appears to conflict with other management documents which is sure to cause more confusion and controversy.
On page A-24 of the Draft Environmental Impact Statement, SUMMARY and PROPOSED RULE, you will find a section called: CIVIL JUSTICE REFORM ACT. It reads "The proposed revision: (1) preempts all state and local laws and regulations that are found to be in conflict with or that would impede its full implementation". A side note is that this clause appears in all proposed revisions the USFS has made since September, 1999.
My concern is that if this language is allowed to remain, RS 2477 will be impacted. Congressional action granted RS 2477 Right-of-Ways. This language, in my opinion would give the USFS license to bypass the law through administrative action. In addition, this language would allow the Federal Land Managers to ignore Public Access claims and close access routes without adhering to the NEPA and existing use, condition, user group agreements (both formal and informal), RS 2477 protections, environmental impacts, and any and all other considerations which might reasonably impact a decision on future road maintenance and use.
I request that the Roadless rule be withdrawn. Let wilderness land be maintained as wilderness, let multi-use land remain as multi-use.
USDA Forest Service
CAET Attn: Roadless
PO Box 221090
Salt Lake City, UT 84122
E-mail: roadlessdeis@fs.fed.us
Dear Chief Dombeck:Please accept these comments on the Roadless Area Conservation Draft Environmental Impact Statement (DEIS). Please consider these comments in your deliberations and include them in the Record
The only acceptable and truly viable alternatives are the 'No Action' Prohibition Alternative 1 and the 'No Action' Procedural Alternative A. These alternatives leave management decisions to be made in the Forest Plans. That is where they should be made.
No data is presented to support the assertion that the existing road system is having a significant negative affect on the environment or to quantify that impact. Neither have they considered alternatives, such as doing the maintenance job and constructing roads to minimize the need for maintenance. Many of those roads are gated, used only to support periodic management activities; many need little maintenance because of good drainage and stable surfaces. This infrastructure was designed to facilitate management, protection and access by the American public. It is needed, sound and, for the most part, a valuable asset for the national forests.
The rule making process is not the proper vehicle for making land management decisions. Rules normally support laws passed by Congress, but these rules conflict with or bypass laws already on the books, National Environmental Policy Act (NEPA) and the National Forest Management Act (NFMA), for example.
Under the discussion of threatened and endangered species Prohibition Alternative 1, No Action, is shown as having the greatest potential loss of habitat and adverse effects because of “road construction and ground disturbance.” “No Action” doesn’t equate with road construction. Under existing planning rules, policies and laws we must protect habitat of listed species. What is ignored in the rush to prevent roads is that for some species proactive management of habitat may be a positive factor. All that the other alternatives do is take away the consideration of valuable management tools, limiting options. The negative effects actually lie with the other alternatives and their inflexible prohibitions.
| Contacts: | Related Links: |
| Please support 4x4Wire by visiting our featured sponsors | ||||||
|
||||||
|
| 4X4Wire Portal | About 4x4Wire | Search 4x4Wire | TrailTalk Forums | Advertiser's Guide | |
