We're all "off-roaders" in one way or another.
From the kid playing with a Tonka truck in a sandbox, to an equestrian, to a
rockcrawler on the Terminator. Yes even Mountain Bikers are off-roaders. It's
just too bad that the largest Mountain Bike Assoc. forgot that when they hopped
in bed with the Sierra Club. I don't feel the least bit sorry for the selfish bastards
who thought that the move would grant them some form of immunity from Sierra's
Gestapo-like land grab tactics, but I do feel sorry for the general membership
now that Sierra has done an about face and (suprise, suprise) stabbed them all
in the back. Well guys and gals, welcome back to the real world, with
the rest of off-roaddom. We hold no grudges, and welcome all that you have to
offer in the fight to keep our public lands free and accessible for
"ALL" recreationalists. Now that you've had a chance
to taste the bitter pill that motorized OHV users have had to swallow, you
understand our anger, and from whence it comes. The collective "We" of the off-road world are
facing yet another asinine threat to our sport, and it is truly one that all
users of public lands can oppose. This time, from a Sierra Club backed US
Forrest Service assault on our lands and freedom. Time is of
the essence in this matter, and if you've never written your politicos before, I
cannot possibly emphasize the importance in doing it now.
From: Eric J. Lundquist, Esq.
Government Relations Department
The American Motorcyclist Association
As you may know, the Forest Service yesterday announced
that it was extending the comment period for the Road issue. Comments have until
March 30. There will also be 24 public meetings about the issue all across the
nation coming up on this. The following is the service's press release and the
public meeting list. Forest Service Extends
Public Comment Period On Road Construction Proposal, and Announces Public
Meetings WASHINGTON (February 24, 1998) - The USDA Forest Service
today announced that the public comment period on a proposed interim regulation
to temporarily suspend road construction in National Forest roadless areas has
been extended until March 30. The interim road construction suspension is
proposed to last for no longer than 18 months or until a long term
Transportation Policy is finalized, whichever comes first. A concurrent proposal, published January 28 with a March
30 public comment deadline, calls for consideration of a major overhaul of the
entire National Forest road system and the development of a long-term
Transportation Policy. The Agency also announced today the location of 25 public
"open houses" scheduled nationwide to help people better understand
the two Forest Service proposals and assist the public in submitting comments
for consideration "Public input is vital to the development of a
Transportation Policy that meets the needs of the American people for national
forest access, while protecting the environment," said Robert Joslin,
Deputy Chief of National Forest System lands for the Forest Service.
"Forest roads provide many social, economic and environmental values, but
they leave a lasting imprint on the landscape. The Forest Service transportation
system is also a long-term, high-level financial commitment and we simply cannot
afford to maintain all the roads we have." "In addition, we are currently reviewing the most
up-to-date science pertaining to the effects of roads on the environment,"
said Tom Mills, director of the Pacific Northwest Research Station in Portland.
"Our science review will be the foundation for the long-term transportation
policy. Once it is complete, the scientific information will be provided to our
land managers so they can more effectively collaborate with the public in making
future decisions about road management." The Forest Service road system is extensive. An estimated
373,000 miles of authorized roads and an estimated 60,000 miles of unplanned and
unmanaged "ghost roads" traverse the 191 million acre National Forest
System. The Forest Service estimates that current funding allows only 40% of the
roads to be maintained to the standards they were designed
for. The current backlog of unmet maintenance needs exceeds $10 billion. Additional information on these proposals is available
from all Forest Service offices, and is found in the Federal Register on
February 27, 1998. Public Meetings for
Interim Roadless Rule and Long-term Transportation Policy Development Alaska
March 10, 2-7 PM, Ted Ferry Civic Center, 888 Venetia Ave., Ketchikan.
Contact: Dave Arrasmith, 907-228-6304. March 11, 2-7 PM, Spenard Community
Recreation Center, 2020 West 48th Ave., Anchorage.
Contact: Anne Jeffery, 907-271-2508. California
March 21, 9-5 PM, Sacramento Convention Center, 1400 J St., Sacramento.
Contact: Christie Kalkowski, 415-705-1841. Colorado
March 17, 2-5 PM, 2-8 PM, Grand Junction Hilton, 743 Horizon Drive,
Grand Junction.
Contact: Matt Glasgow, 970-874-6674 . March 17, 2-7 PM, Rocky Mountain Region
Headquarters, USDA Forest
Service,
740 Simms, Golden. Contact: Lynn Young, 303-275-5346. Georgia
March 26, 5-9 PM, Sheraton Hotel, 1850 Cotillion Dr., Atlanta.
Contact: Angela Coleman, 404-347-7226. Idaho
March 19, 1-7 PM, Idaho Panhandle National Forests, 3815 Schreiber Way,
Coeur d'Alene.
Contact: Brad Gilbert, 208-765-7438. March 21, 10-3 PM, Boise Center on the
Grove, 850 West Front, Boise.
Contact: Brian Harris, 208-373-4106. Minnesota
March 19, 6-9 PM, Earle Brown Continuing Education Center, University of
Minnesota, St. Paul Campus, 1890 Buford Ave., Rm 280, St. Paul.
Contact: Mary Nordeen, 218-335-8658. Montana
March 12, 3-8 PM, Helena National Forest, 2880 Skyway Dr., Helena.
Contact: Jerry Adelblue, 406-449-5201, ext 264. March 14, 10-5 PM, Ruby's Reserve Street
Inn, 4`825 N. Reserve St.,
Missoula.
Contact: Barb Beckes, 406-329-3809. March 23, 6:30-9:30 PM, Libby City Hall,
952 East Spruce St., Libby.
Contact: Joan Dickerson, 406-293-6211. New Hampshire
March 18, 6-9 PM, New Hampshire Technical College, 11 Institute Dr.,
Concord.
Contact: Colleen Mainville, 603-528-8796. New Mexico
March 18, 3-7 PM, Holiday Inn Mountain View, 2020 Menaul NE,
Albuquerque.
Contact: Al Koschmann, 505-842-3370. North Dakota
March 12, 9-3 PM, Expressway Suites, 180 E. Bismarck Expressway,
Bismarck.
Contact: Steve Williams, 701-250-4443. Oregon
March 16, 10-4 PM, Doubletree Hotel Lloyd Center, 1000 NE Multnomah,
Portland.
Contact" Patty Burel, 503-808-2221. March 17, 10-4 PM, National Guard Armory,
875 SW Simpson, Bend.
Contact Carrie Sammons, 541-383-5536. March 18, 10:30-4:30 PM, Reston Hotel,
2300 Crater Lake Hwy, Medford.
Contact Steve Waterman, 541-858-2213. South Dakota
March 16, 3-8 PM, Pactola District Office, Black Hills National Forest,
803 Soo San Drive, Rapid City. Contact Glen McNitt, 605-673-3104. Utah
March 21, 10-3 PM, Provo Park Hotel, 101 West, 100 North, Provo.
Contact Lola Murray, 801-342-5137. Virginia
March 24, 6-9 PM, George Washington/Jefferson National Forest, 5162
Valley Point Parkway, Roanoke, VA. Contact Donna Wilson, 540-265-5100. Washington
March 17, 10-4 PM, Ramada Inn at Northgate, 2140 N. Northgate Way,
Seattle.
Contact Lorette Ray, 425-744-3571. March 18, 10-4 PM, Four Seasons Inn, 11
West Grant Road East, Wenatchee.
Contact Paul Hart, 509-662-4314. Washington, DC
March 19, 2-7 PM, Holiday Inn Capitol, 550 C St SW
Contact: Alan Polk, 202-205-1134. Wyoming
March 19, 2-7 PM, Parkway Plaza Hotel, 123 West E St., Casper.
Contact Stan Sylva, 307-777-6087.
Contact: Alan Polk 202/205-1134 http://www.fs.fed.us/news/
The
Blue Ribbon Coalition is not taking this
serious threat to our freedom lying down. In a Feb. 24th letter to the USFS,
BRC's Adena Cook blasted the proposed policy on nearly every count, pointing out
the illegalities, contradictions with existing policies, and inconsistencies
found throughout the document. February 24, 1998 Director, Ecosystem Management Coordination Staff
Mail Stop 1104
USDA Forest Service
P.O. Box 96090
Washington, DC 20090-6090
RE: Temporary Suspension of Road Construction in Roadless Areas
Dear Director: The BlueRibbon Coalition is a nationwide organization
representing 500,000 motorized and mechanized recreationists, equestrians, and
resource users. We work with land managers to provide recreation opportunities,
preserve resources, and promote cooperation with other public land users. We
have several concerns with your published proposal to impose an 18 month
moratorium on road construction and reconstruction in "roadless"
areas. Lack of Comment Opportunity The announcement in the Federal Register was preceded with
much speculation, fanfare, and controversy. Although we had heard that some sort
of pronouncement with regard to management of roadless of areas was imminent, we
were unable to respond since the exact nature of your proposal was unknown until
the Federal Register notice was published. The road and road reconstruction announcement declared a
brief 30 day comment period. This short period is grossly insufficient to
distribute the announcement, inform concerned publics about the need to comment,
analyze the document, and provide substantive comment. Additionally, the road and road reconstruction moratorium
was accompanied by a separate Advanced Notice of Proposed Rulemaking (ANPR) that
announced the Forest Service's intentions to revise its management of the
National Forest Road System. This ANPR had a separate comment deadline and a
request for different comments. The distinction between the two Federal Register
announcements has been unclear to the public. This confusion has been compounded
by the short deadline times. The brevity of the comment period and the complexity of
the announcements call into question the sincerity of your request for public
comment. We wonder if the decision to proceed with the moratorium has not
already been made. RARE II Roadless Areas The announcement states that the interim rule would apply
to areas inventoried as roadless in RARE II. This pronouncement turns the clock
back to 1978 and negates 20 years of National Forest management and planning. RARE II identified roadless areas. Those areas were then
designated Wilderness in subsequent legislation or released in various ways.
Even if there was little release language, those lands were addressed in Forest
Plans and allocated for a variety of uses. Even in Idaho and Montana, where RARE
II roadless lands have not been addressed by Wilderness legislation, those lands
have been managed by Forest Plans for a variety of uses.
Some of those lands have been recommended for Wilderness, some have been
allocated for other uses. ALL have been evaluated during a sometimes protracted
public process per NEPA, appealed, appeals resolved or litigated, and
subsequently managed. If some of the former RARE II lands have been roaded or
roads planned, then these actions and decisions have been the result of a public
process and intense analysis, and tiered to a programmatic Forest Plan. These
actions and decisions have been governed by APA, NFMA and NEPA. As such, RARE II
"roadless" lands no longer exist, but are now part and parcel of other
land allocations prescribed in the various Forest Plans. Your proposed interim rule voids all of these Forest
Plans, all of the public processes, and all of the decisions relating to roads
that have occurred on these lands since 1978. It is contrary to the principles
of National Forest management that have preceded it. As such, it is likely
illegal. Wilderness Buffer Zones The proposed interim rule states that it will apply to
lands adjacent to designated Wilderness areas. The above concern about negating
the direction established in Forest Plans also applies to these lands. Many
Wilderness bills prohibit "buffer zones", which will result with the
application of this interim rule. Additionally, lack of maintenance on roads leading to
designated Wilderness will have an adverse impact on recreationists seeking to
visit these areas. It will make our Wilderness areas essentially inaccessible. Unroaded Areas Adjacent to 5,000
Acre Roadless Areas This land category should not exist. If such lands are
adjacent to an already roadless area, then they would be, by definition, a part
of the roadless area. Low density road areas and other
"unique" areas "Low density" is not defined, nor are
"ecologically unique" areas sufficiently defined. Their vagueness
assures that the moratorium could possibly be applied to any patch of National
Forest land anywhere. The disclaimer, "The agency does not anticipate that
Regional Foresters will create a new inventory of roadless areas...", gives
us little assurance that this will not actually occur. The cited example of roadless areas in the Southern
Appalachian Area Assessment does, in fact, contain+ roads. Many of these roads
are likely still part of county road systems and not under the jurisdiction of
the Forest Service. Effect on
National Forest Public Access and Recreation The proposed moratorium does not define
"maintenance". As previously discussed, the land areas covered by the
moratorium are subject to a variety of interpretations. The Forest Service
elsewhere has cited a backlog in road maintenance and the need to upgrade
certain roads to a higher passenger vehicle standard. The management direction that these facts portend strikes
a chill into the heart of millions of recreationists who enjoy a backcountry
experience on primitive roads. We fear that these roads, which provide a premier
experience and disperse use will become impassible and abandoned. The Forest Service cites recreation visitation at 1.7
million and then claims that these visitors need high standard roads. This is an
assumption without basis in fact. An unknown but large number of visitors enjoy
access by primitive roads, the challenge of travel on such routes, the
trailheads that they access, the solitude that a dispersed road system provides. The direction set forth in the moratorium could render
this road system impassible. The premier experience these roads offer would
vanish. Compliance with National Forest Management Act (NFMA),
Administrative Procedures Act (APA), and National Environmental Policy Act (NEPA) The proposed moratorium blithely claims that it will not
change "any land, and resource management plan, any land allocation
decision or other management activity or use within roadless areas in which road
construction or reconstruction are temporarily suspended". Yet it acknowledges and proceeds to do just that as it
states, "some currently planned land management projects that are dependent
on new road construction...may not be implemented in the time frame currently
planned....some projects may proceed in an altered form. Some projects may
eventually be altered..." The mere postponement of a management action makes
significant changes in that action. For example, if a road approved to be built
to harvest diseased timber is delayed and the timber subsequently burns, then
the delay is significant. Suits can and have been filed on the grounds of
"unreasonable delay" in such situations. If projects proceed in altered form or are eventually
altered, then a NEPA process must be followed that changes the decision. The
moratorium preordains the outcome of the decision, tainting the process. The proposed moratorium is attempting to make
site-specific modifications to decisions (already completed through the NEPA
process) in a broad-based programmatic way, in violation of planning processes
and all without the benefit of NEPA. The proposed moratorium's failure to sufficiently discuss
its compliance with APA, NFMA, and NEPA makes it illegal. Conclusion The proposed road construction and reconstruction
moratorium cavalierly dismisses the laws and subsequent planning processes that
have been the foundation of National Forest Service management. It, instead,
dives into issues that should properly be a part of site-specific management of
individual units; for example, citing problems with erosion (present in some
cases, not all), water quality (only when certain conditions are present next to
streams), and exotic plants (not present everywhere or they would not be
exotic). As such, this is the worst example of top-down micro-management that
has yet come forth from the Clinton administration. It totally undermines the
professionalism for which the Forest Service has been famous. Hopefully, it will
be recognized as such and will be withdrawn. Sincerely, Adena Cook, Public Lands Director
Phone: 208-522-7339; Fax: 208-524-2464 | 
