WMI Comments on the Proposed Forest Service Transportation Policy

WMI Comments on the Proposed Forest Service Transportation Policy

The WILDLIFE PARTNERS LIST is a service of the Wildlife Partners Network organizations and is intended to improve communications about important national natural resource issues, especially relating to wildlife and wildlife habitat conservation on public and private lands.

POSTINGS TO THE WPN LIST ARE THE STATEMENTS OF INDIVIDUAL ORGANIZATIONS AND DO NOT NECESSARILY REFLECT THE OPINIONS OF THE OTHER MEMBERS OF THE WILDLIFE PARTNERS NETWORK.

The Wildlife Partners Network List is administered by the Izaak Walton League of America and was made possible by a generous contribution from Wildlife Forever.

The following comments were submitted by the Wildlife Management Institute on the proposed Forest Service Transportation Policy currently under review and open for comment until May 2, 2000

April 26, 2000

USFS CAET
Attention: Roads
P.O. Box 221090
Salt Lake City, UT 84122

The Wildlife Management Institute, founded in 1911, is a non-profit organization staffed by experienced resource management professionals dedicated to improving the management of wildlife and wildlife habitat. We are providing comments on the Administration of Forest Development Transportation System, Prohibitions, and Use of Motor Vehicles Off Forest Service Roads (36 CFR Parts 212, 261, and 295).

We applaud the U.S. Forest Service’s (FS) attempt to base transportation management decisions on a deliberative science-based protocol, recognizing the importance of capacity of the land to support road construction, maintenance and use and landscape-level issues in applying the protocol. By setting forth a process for these decisions, broader participation will be achieved and, potentially, better decisions will be made. As described in the March 3, 2000 Federal Register, there are weaknesses as well as strengths, and we provide the following comments:

We endorse the need for a complete inventory of unclassified roads and a science-based roads analysis.
We encourage a shift from the policy that the transportation system is used to develop the forests and grasslands to a policy where the transportation system is designed to fit the capability of the land.
We suggest the FS remove the term "development" from various references like "forest transportation development roads." The term implies all areas of the forest will be developed with road for resources use.
We support the use of seasonal and temporary closures of permanent roads to reduce the cost of management and maintenance, the impacts on water quality and soil erosion, and the disturbance of wildlife and their habitats.
We recommend that roads only be constructed to serve a need or purpose for either management or access and not just simply for the purpose of building roads. Road construction and maintenance on National Forests and Grasslands traditionally has been driven by budgets, and often there has been more money available for construction than for road management, maintenance, enforcement or obliteration.
We endorse the three primary actions of the proposed road management strategy to help find an appropriate balance between safe and efficient access for all forest road users and protection of healthy ecosystems.
We recommend the adoption of a policy that all areas (roaded or unroaded) on the National Forests and National Grasslands are closed to motorized vehicles unless posted open. The current policy of “open unless posted closed” has encouraged the creation of many unplanned and unclassified roads and trails, perpetuated needless damage to existing road and adjacent resources, and has had significant impacts on wildlife and their habitats. Exception to this policy can be made for legitimate resource uses such as firewood and game retrieval.

A reasonable and sound general model for transportation management is established in Alternative 2 of the BLM-FS EIS for off-highway vehicle analysis for U.S. forests in Montana, North Dakota, and portions of South Dakota (Oct. 1999). This alternative appropriately incorporates standards which recognize environmental and economic concerns, as well as pragmatic issues involving established uses and priority needs, such as handicapped access and administrative and management needs.

The proposed policy appropriately favors management and maintenance of necessary existing roads and facilities over the development of additional trafficways (Title 7700, Ch. Zero). The goal of a "minimum system" of transportation facilities is appropriate in that it recognizes the adverse effects of excessive road development, as well as the fiscal climate under which the FS likely will manage the road system in the foreseeable future. The establishment of the "capability of the land" as a standard for considering road development, temporary and seasonal road closures, and decommissioning plans is also appropriate and will help to ensure long-term viability of multiple use values in the nation's forests.

The environmental protections reflected in the proposed changes to Section 7702 need to be balanced with consideration of benefits associated with fire management and certain resource uses for which roads may be necessary.

Also in Section 7710.32, the proposed policy appropriately recognizes the need to eliminate unclassified roads in roadless areas; it is critical that this same recognition be applied to areas where roads are deemed necessary and desirable. Unclassified roads should not be allowed to persist in national forest or grassland areas.

The decommissioning of unclassified and unnecessary classified roads is a key component of this proposed policy. We are concerned, however, that enacting such closures will prove excessively difficult and frequently impossible at the local level, unless certain predetermined supportive actions are taken. Such actions should include (but are not limited to):

consultation with local governments and resource users;
consultation with appropriate U.S. courts to develop mutually acceptable closure procedures that will be supported in cases of road closure violations;
providing adequate FS staff for monitoring and enforcement of vehicle operation restrictions;
providing fiscal support for equipment and materials necessary for road closures and reclamation; and
providing administrative support for temporary and seasonal road closure actions as functional alternatives where appropriate.

Decommissioned roadbeds should be fully reclaimed, and necessary funding for these efforts must be acquired. Reclamation should include re-contouring, drainage restoration, and re-vegetation relying on native wildlife-benefiting vegetation. Reclamation should also address visual impacts of roads, both for user benefits and for deterring further unauthorized traffic. Appropriate partial reclamation should be implemented for those roads selected for conversion to foot, equestrian, or cycle trails.

The proposed policy's emphasis on restructuring of necessary existing roads is sound and supportable; but analyses of these situations must consider the potential for increasing traffic by improving existing roads. Traffic increases may diminish wildlife and recreational values of affected forests and grasslands. Primitive and semi-primitive dispersed recreational opportunities should be recognized among primary purposes of FS lands, and implementation of the overall roads policy should reflect these purposes.

The Service's practice of applying NEPA analysis to decisions regarding transportation facilities is appropriate. The preparation of an environmental assessment should be contemplated for most or all projects that involve construction or major renovation of FS roads. This process can involve the public in making the necessary tradeoffs between competing values that are consequences of changing the road system.

Renovation and construction of transportation facilities must be done using best management practices for water quality preservation, soil stabilization, and accommodation of sensitive species' needs, including the appropriate timing of work to avoid disturbing such species' life cycles. Cumulative impacts on drainages, wildlife habitat fragmentation, surface water quality and other parameters must, of course, be carefully assessed in documented analysis processes.

Thank you very much for considering our views.

Sincerely,

Rollin D. Sparrowe
President

The Wildlife Partners Network is a coalition of conservation organizations that work cooperatively to share information about current national conservation policy, primarily dealing with wildlife and wildlife habitat conservation. The Partner organizations include: Boone and Crockett Club, Foundation for North American Wild Sheep, Izaak Walton League of America, National Wild Turkey Federation, Rocky Mountain Elk Foundation, Ruffed Grouse Society, Wildlife Forever, Wildlife Management Institute and The Wildlife Society.

For more information about WPN contact the WPN Coordinator.

The Wildlife Partners Network List is administered by the Izaak Walton League of America and was made possible by a generous contribution from Wildlife Forever.

For specific questions about this listserve, please contact us, or for technical questions or problems with this list, please contact technical support.

Back to Index Page