April 26, 2000 CAET-USFS Attn: Roads Project PO Box 22300 Salt Lake City, UT 84122 RE: NATIONAL FOREST SYSTEM ROAD MANAGEMENT STRATEGY, ENVIRONMENTAL ASSESSMENT and Civil Rights Impact Analysis, Dated February 9, 2000 Dear Planning Team, Below are my general comments on the referenced Environmental Assessment (EA). I hope to send additional, more specific comments in the very near future. Due to the complexity of the issues detailed in three Federal Register Notices and the commingling of other initiatives, I would like to formally request that the comment period be extended a minimum of 180 days so that adequate time may be provided for the average citizen to study these proposals. My request for this extension is based on two significant facts: 1) that in order to fully understand and appreciate this document, there are well over 500 additional pages of referenced material that must be read and digested, all of it in bureaucratese. While this may not be a concern to professionally staffed anti recreation lobby, who apparently help prepare this document, to the public who must balance their document review time with full time jobs and family commitments, the burden is unreasonable. 2) I have submitted numerous FAX and phone requests for the complete EA documentation as per directions provided on your official government web site. To date, I have not received a complete copy to review. My comments are based on the Federal Register Notices and documentation provided on your web site. This lack of availability of government documents for public review inhibits the full disclosure concepts under NEPA guidelines. Given your agency's commitment, albeit still in draft, to solicit public input early in planning process and the lack of documentation for public review, I believe that a comment extension of a minimum 180 days is fully warranted in order to get the best up front public input. General Comments: - This document is a recipe for environmental and social disaster, if implemented as written the agency will attempt to force a rapidly growing number of visitors into a rapidly shrinking area of availability. Preliminary calculations would indicate user density would go from 4 visitors per mile of road today to at least 31 visitors per mile by 2045 (using the conservative 64% visitor use increase and the 77% decrease in road miles proposed). If this is the intent of the agency please explain the rationale. As I see it, this concentration of visitors will lead to more illegal trespass problems, greatly increasing the potential for resource damage as demand exceeds capacity, greater user conflicts, greater damage due to fire and insects, a significant reduction in user enjoyment of their public lands, and it will increase the rate of decline in the rural economies that rely on the national forests and their visitors as a key component of their economies. - When did the agency abandon traditional multiple use goals and under what federal register notice was that change promulgated? I can remember no public input opportunity, nor can I locate a Federal Register Notice, into the agency's shift away from the legislated multiple use of public lands policy by the public and toward feral preservation as espoused by the anti recreation lobby. Please provide the rationale and cite public input opportunity for this change in management philosophy. - Given that driving for pleasure is cited as the "SINGLE LARGEST RECREATIONAL USE OF NFS LANDS" (emphasis added)(p39) and a significant and continuing increase in that demand is also forecast in this document, explain how reducing opportunity through aggressive road decommissioning will accommodate these, seemingly, contradictory positions. I was unable to understand from the document how the agency plans to address the rapidly increasing demand for this recreational activity through reducing opportunity. - This document cites a need to "recognize and manage this changed usage..." (p7) with respect to the shift away from resource extraction (timber and mining primarily) and toward recreational use (driving for pleasure primarily). Please explain how closing roads and restricting access equates with management. It appears that the Washington office does not feel that professional field staff is up to managing this change in demand and is, therefore, defaulting to closure and restriction in hopes that the public will go elsewhere. - Only the proposed alternative and the required No Action alternative were considered for presentation. For a document of this magnitude and potential impact, additional alternatives should have been fully developed and evaluated. This lack of viable alternatives appears to be lip service to the process and that a preordained outcome was being simply pushed through the system. No true development, assessment, or evaluation of alternatives was preformed, simply the outcome presented. This is not consistent with agency proposed planning regulations, the guidelines of NEPA, nor is it in the best interest of the public. It is, therefore, unacceptable. One alternative not considered (for example) might be to use, as sound science, user density as a target metric rather than road density or site specific resource impact. Many, accredited and recent, studies of wildlife, for example, have concluded that it is human presence on the ground more than topographical disturbance (roads, tanks, etc) that actually stresses wildlife. By distributing users and user impacts, rather than concentrating them, as this proposed alternative would do, wildlife as well as environmental resources would be less impacted and therefore the desired outcome could be achieved not only without sacrificing public access, but with recreational opportunities actually enhanced for all users. - Given that the agency acknowledges a 1,300% increase in recreational road use since 1950, how did the agency develop the projected 64% increase by 2045? How does the public know that the road use increase won't be as significant over the next 50 years as it was over the last 50? What data was used to arrive at the decrease in the rate of increased use? Please provide trend analysis information so that the public can have confidence that the numbers presented do in fact originate from sound statistical science that accurately reflects the past, current, and projected future public use. As presented, the numbers appear to be derived without supporting documentation or explanation. - The agency should abandon the Chiefs unique and confusing definition of the term "road" and use the more reasonable and universal definition which already enjoys widespread acceptance and legal precedence. "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. - The agency should address equally all roads on managed properties and not discriminate between roads the agency attempts to maintain and those it does not. All roads, as generically defined above, should be a part of this inventory for (at a minimum): 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. - Please explain the prejudicial and misleading use of the term off road vehicle (various pages) in this document when the more accurate and less emotionally charged term OFF HIGHWAY vehicle has been used in agency plans for years and is, in fact, used on numerous instances in this document. This sudden and random shift in terminology, especially back to such a misleading and evocative term, raises questions to the agencys intent and the extent that the anti OHV lobby as influenced this document. - A significant and important use of forest roads has been omitted from the study. While many forest roads were constructed for extraction of resources, a significant number of other roads were constructed for fire safety purposes. In fact, many existing roads roads now longer used for extraction of resources now provide fire barriers and fire fighting access. The arbitrary decommissioning of forest roads without regard to fire prevention and fire fighting requirements would be detrimental to public safety. Thank you very much for the opportunity to comment. I would like to forward additional specific comments; however, the inability of the your Rocky Mountain Station Publication Branch to provide complete documentation inhibits my (and other public) ability to comment. Please allow me to fully participate in this process by extending the comment period for an additional 180 days and provide adequate documentation for public review, so I can provide well thought out and meaningful input to this document. I look forward to your response Sincerely,