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 comments on the above referenced Environmental Assessment (EA), I 
offer these comments on behalf of the membership of the Tierra del Sol 4 Wheel 
Drive Club of San Diego.  We are a committed group of outdoor recreationalists 
who believe that responsible motorized recreation can be enjoyed in harmony 
with responsibly managed public land.  Because we are a volunteer non-profit 
organization with no funded staff positions, I would like to request that the 
comment period for this EA be extended for an additional 180 days.  My request 
for this extension is based on the fact 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 agency-speak
.  While this may not be a concern to the professionally staffed anti 
recreation lobby, who apparently help prepare this document, to the general 
public who must balance their document review time with full time jobs and 
family commitments, the burden to respond thoughtfully and intelligently in 
the time allotted is unreasonable.  Given your agency’s commitment, albeit 
still in draft, to solicit public input early in planning process, I believe 
that a comment extension is fully warranted in order to get the best up front 
public input.  Additionally, complete copies this EA have been very difficult 
to obtain when the requesting process as defined on the Forest Service 
internet web page established expressly to support this document, was followed.

Our comments are presented below in two categories, starting with comments of 
a general nature followed by section specific comments.

General Comments:
•	First and foremost, the process by which you developed these proposals 
disturbs us.  We take strong exception to the unprecedented actions of the 
agency in secretly soliciting and relying on the advice of a narrow spectrum 
of special interest groups in the development of road rules and policies to be 
submitted for public comment.  That these special interests are not 
acknowledged in the document by name is especially suspect.  Whether or not 
the agency is ultimately found to have violated the Federal Advisory Committee 
Act and other statutes, the credibility and reputation of the agency has been 
seriously damaged.  By choosing to solicit only one point of view, the agency 
has produced an unbalanced proposal, demonstrated a predisposition clearly 
inappropriate to the federal administrative process, and shredded public 
confidence in the notice and comment procedure required by law.

•	The tone and content of this document clearly shows an arbitrary and 
capricious bias against all forms of motorized recreation to the point that 
alternatives that could enable a positive motorized recreational experience 
while preserving resources are not even identified.

•	The proposed alternative appears to be crafting a new category of public 
lands, somewhere between multiple use and designated Wilderness.  It appears 
to be somewhat analogous to the Wildlands Project’s buffer and wildlife 
corridor areas.  If this is the case, public input should be solicited to 
gauge support for this new designation before this document attempts to 
implement it.

•	It is remarkable that neither the draft land management planning regulation, 
the roadless area proposal nor the proposed transportation rule and policy 
contain a coherent explanation of their interaction or integration.  These 
major policy proposals each seem to envision a separate, duplicative, process 
using a universally undefined "science-based road analysis".  We believe that 
this separate process is contrary to the concept of one integrated plan set 
forth in Sec. 6 of the Forest and Rangelands Renewable Resources Planning Act 
(RPA).  We also believe you should clarify how doing away with the "Forest 
Development Transportation Plan" will conform to the requirements of Section 
10 of the RPA.

•	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 into the agency’s shift away from traditional multiple use 
of public lands 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.

•	We are concerned by the bias against roads reflected in the overall proposal 
and in the regulatory impact statement.  The bias is evident throughout the 
proposals but the most egregious example is the statement in the first 
paragraph of "Supplementary Information", which states "...few land impacts 
are more lasting than those associated with road construction...".  It doesn't 
take much of an imagination to visualize the greater impacts associated 
natural catastrophes such as hurricanes, floods, tornadoes, volcanic 
eruptions, wildfire in heavy fuels, and many others. Without adequate road 
access for fire management, insect and disease control and response to other 
natural catastrophes, significant adverse impacts on soils, water quality and 
wildlife, including threatened and endangered species will result.  The 
failure to prepare an Environmental Impact Statement to analyze these direct 
and very substantial consequences violates the national Environmental Policy 
Act.

•	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.  That no true development, assessment, or evaluation of alternatives 
was preformed, simply the outcome presented, is not consistent with agency 
proposed planning regulations, the spirit 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 drives 
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 “made up” without supporting documentation or explanation.

•	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 (see above comment) 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 behind concentrating users.  As I see it, this concentration of 
visitors will lead to more illegal trespass problems, greatly increased 
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.

•	These proposals contain no reasonable quantification of effects.  No 
economic effects are quantified.  The proposed rule cites the Forest Service 
Handbook in the contention that documentation by an environmental impact 
statement is not necessary.  We point out that the FSH does not preempt NEPA.  
There are significant environmental effects probable with this proposal.  Just 
considering the annual timber harvest potential foregone (which we believe is 
a low estimate) would require an EIS under the intent of NEPA.  The proposal 
requires that road construction and reconstruction in roadless and unroaded 
areas would require an EIS.  Any individual action in these circumstances 
would be a relatively minor action compared to the proposal.  This proposal 
therefore needs an EIS to document fully its effects, physical and economic, 
on the environment.

•	The agency should abandon the Chief’s unique and confusing definition of the 
term “road” and use the more reasonable, universal and legally accepted 
definition, which already enjoys widespread acceptance.   “Any way, travelway, 
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. 

•	Please explain the use of the prejudicial and misleading 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 agency’s intent and the extent 
that the anti OHV lobby has influenced this document. Further, we are 
concerned about the philosophical shift reflected in the proposal to adopt the 
term "Forest Service Roads".  These are not Forest Service Roads.  They are 
roads financed by public money and managed by the Forest Service for the 
benefit of the American people.  It is important that the leadership of the 
Agency understand this important distinction.  If they did, maybe they would 
be less cavalier in their approach to denying the public access to these lands.

•	We find that the language is often ambiguous and will lead to contention 
with the public as well as internally.  An example is in the definition of an 
unroaded area concerning its potential size:  "The size of the area must be 
sufficient and in a manageable configuration to protect the inherent values 
associated with the unroaded condition".   Many of our group has experience 
with past delineation of roadless areas, and we can assure you that this kind 
of vague, wishy-washy language will generate no end of problems.  We urge you 
to clarify the language throughout the proposal to reflect consistency with 
the legal terms defined by the Wilderness Act of 1964.

•	The proposal indicates a belief that its adoption would have a positive 
effect on fire and forest pest management.  How did you determine the 
perceived positive effects of the proposal on fire prevention, fire 
management, and insect and disease control?  To the contrary, a review of fire 
control costs over the last 15 years shows a disproportionate share of the 
costs, outside of southern California, were associated with suppression of 
fires in substantially unroaded areas.  Additionally, while many of the roads 
were originally constructed for resource extraction purposes, they now serve 
as fire suppression barriers and fire fighting access roads.  Elimination of 
these roads would have a significant negative effect on fire management 
capability and public safety.

•	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 redefined 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.  As in previous proposals, no quantification is made of 
the "other unroaded areas".   Since many roads are being defined out of 
existence, the size of this category seems destined to grow.  Indeed, proposed 
FSM 7703.1 a. (3) states:  "However, maintenance of unclassified roads in 
roadless and unroaded areas is inappropriate as such activity would lead to 
defacto road development."  This not only indicates vast ignorance or blatant 
disregard of the possible off-site effects of precluding action to correct 
drainage and run-off problems; it also eliminates options for future 
management decisions.  This provision is counter-productive and should be 
eliminated.

•	The finding in the regulatory impact report that the impacts on recreation 
are ambiguous - some positive and some negative depending on the type of 
activity - is disingenuous.  Only a very, very small portion (less than 2%) of 
National Forest  Recreation use is associated with wilderness areas.  The 
proposal is overwhelmingly negative to the vast majority (the greater than 
98%) of recreation users. 

Specific Comments:

1) P 2  “This action (referring to 64 Fed Reg 56306 (1999)) has narrowed the 
need and scope …”

Explain how the, so-called, “roadless” initiative “narrowed the scope” of the 
NF Road Management Strategy.  Did road miles decrease or is the agency simply 
ignoring existing roads based on their being within these arbitrary “roadless” 
areas?

2) P2  “The agency also needs to develop a complete inventory …”

Shouldn’t the inventory of existing roads be done first in order to accurately 
understand the total miles of roads in use, condition, types and quantity of 
use, etc?

Hasn’t this already been done?  What were the results of previous inventories? 
Did they not agree with the premise set forth in this document and now the 
data needs to be recollected to fit the hypothesis?

3) P2 “After an extensive public involvement process …”

Public involvement has been a sham with no meaningful information available 
from the agency, no consideration of public desire for meaningful input, an 
absurd time line, in short, it was a mockery of the public involvement 
process, bypassing the NEPA guidelines.

Public access to complete docmetation packages has been sporadic.  Procedures 
outlined on Forest Service web pages established to support this initiative 
have failed to result in documents delivered to the public upon request.
4) P3 First Bullet

How will the “comprehensive inventory” be accomplished?  Provide schedule, 
cost, milestones, etc.  What provision will be included for public 
participation in the inventory?

Define the term “important” as it relates to the management and use of the 
national forest system. Resources that have been used and enjoyed by local 
families may be held in much greater import by those who enjoy them than by 
those who do not.

5)  P3 Second Bullet

Decommissioning should NOT be the #1 priority before fully understanding the 
public’s use, interest, and desire for roaded recreation.  It is totally 
inappropriate to predetermine the outcome of an ASSESSMENT document. 

Define how the term “unneeded” will be applied in the road decommissioning 
context.  Will all high clearance roads become “unneeded” by the public 
despite the overwhelming public demand for the resource?

6) P3 Fourth Bullet

Define the term “multiple scales”

7) P3 Fifth Bullet

Why are these areas called “roadless” when the agency acknowledges the 
existence of, and the potential need for, additional roads?  This leads to 
confusion among the casual public and undermines the credibility of the agency 
among the entire public.  If it is a regulatory issue add a parenthetical 
where the existence of roads in these areas are openly acknowledged.  Add this 
in every case this misleading term is used.

8) P3&4 “Environmental Consequences”

Currently planned road construction and, especially, reconstruction should be 
executed as planned to minimize growth in the maintenance backlog and to 
minimize potential resource degradation where road impacts are chronic rather 
than catastrophic.

9) P4 First Paragraph “...which shifts road management emphasis from 
transportation development to managing environmentally sound access...”

This is an admirable goal which is worthy of support providing that 
historically used access routes are protected and does not result in a loss of 
recreational opportunity or access.  I would suggest that the term “motorized 
recreational” be inserted after the term “sound” in the above sentence since 
this is supposed to be about roads which, at least, implies motorized use.

10) P4 First Paragraph “The proposed action would … ”

The agency should NOT predetermine that a “minimum transportation system” is 
the desired goal of this assessment.  That objective does not adequately  
provide for current recreational use and will certainly not meet the rapidly 
growing demand for recreational access.  The goal should be to identify a 
transportation system, or rather a recreational resource or infrastructure 
that is adequate to address current and expected future needs of the public.  
Allow room in the plan for management of the dynamic system.

11) P4 Decommissioning “ … would reduce access for off-road and some high 
clearance vehicles.  Additional …”

Agency data acknowledges that motorized access is the single largest and one 
of the most rapidly growing uses of public land.  Reducing opportunity and 
concentrating use is wholly inconsistent with demonstrated public interest.  A 
much better outcome would be to provide a mechanism for limited reconstruction 
to mitigate current or anticipated negative environmental impacts.  An 
increase in system wide opportunities would result in a dispersion of users 
and decrease the likelihood and severity of resource damage.  The proposed 
reduction in opportunity will lead to increased user concentration for all 
user groups and that will result in increased user conflict, increased 
resource damage and a reduction in user satisfaction.

12) P4 Reconstruction

This paragraph supports my above comment, in order to better protect 
resources, use must be distributed rather than concentrated.  Demand is a 
documented fact, demand is not decreasing, and the agency challenge is to 
accommodate the customer’s increasing demand while protecting resources. The 
proposed approach of concentrating use by eliminating access is counter 
productive to meeting the needs of the public.

13) P5 “Between the time the proposed policy became effective …”

This is a PROPOSED alternative and should not have already been implemented, 
formally or covertly.  The agency should strongly emphasize to local forests 
currently preparing plans that this policy is NOT to have been considered 
implemented while under this process.

14) P5 “The effects of the road management strategy on roadless or other 
unroaded areas would be short term … “
This strategy, if implemented as written, will NOT result in short term 
effects, rather, the effects would be in perpetuity.  They may be further 
addressed in a subsequent EIS, but the decisions and management direction 
stemming from this proposed policy will certainly be long term, unless, of 
course, the agency assumes 100% of the so-called “roadless” areas will be 
designated Wilderness by Congress or executive fiat in the very near future.  

15) P5 Cumulative impacts

Reduced timbering may be the most obvious and well documented economic impact 
but it is not the “...most tangible cumulative effect...”.  An extensive 
infrastructure of private enterprise has developed around the public lands to 
support the millions of forest visitors who chose primitive recreation on 
public land, especially those who choose, or who require, mechanized access.  
To dismiss this impact is misleading the public and serves to further 
undermine the credibility of the EA.

16) P6 Relationship …

No evidence has been presented to conclude that long-term environmental 
productivity is related to road decommissioning.  This statement is 
prejudicial and misleads the public to believe that roads and public use are 
inconsistent with long term environmental protection and productivity.

Define the term “environmental productivity”.

17) P7 Need for Action “ … the agency estimates …”

This illustrates the need for adequate primitive roaded recreational 
opportunities, not a continued reduction in opportunities as this policy 
advocates.  The agency is assuming that resource damage will occur, will occur 
at an unacceptable rate and level, and that this damage is solely the result 
of roaded recreation rather than resulting from the approach of concentrated 
use.  Rather than following its self stated policy of protecting our 
resources, the agency is advocating a policy that further degrades the areas 
most in need of relief while excluding the public from other areas with 
existing infrastructure for managed access.  This is unacceptable.

18) P7&8 Funding

Not all roads need to be maintained to transportation standards.  A graded 
maintenance program should be developed, with user groups input, to identify 
the need and level of maintenance required for specific roads. This could 
serve to greatly reduce the maintenance burden on the agency while also 
satisfying the various road users interests and needs.

19) P8 Second Paragraph

Roads not meeting current safety and environmental protection should clearly 
be addressed.   However, mitigation and reconstruction should be the first 
option explored as a remedy.  Decommissioning should be held as a last resort 
for any road, regardless of it’s origin.

20) Third Paragraph

These so-called “roadless” areas already contain miles of roads currently in 
use by the public for primitive recreational access.  These existing roads 
must be acknowledged publicly and protected as a recreational resource.

21) P10 “ … the FS convened focus groups with external stakeholders … “

Provide a complete list of all “external stakeholders” who were consulted in 
the development of this policy.  Include a summary of the content, extent and 
process used for the collection of this input as well as when, where and how 
the input was solicited and provided.  Referencing another document is not 
adequate.

22) P10 Fourth Bullet

The “need” for new road construction is very subjective and might include, 
among other things, increasing the public’s recreational access, dispersing 
use by increasing opportunities for primitive motorized recreation, joining 
two dead end roads into a loop road opportunity or a myriad of other potential 
needs.  Fire service roads for public safety are another valid need for new 
road construction.  It should be made very clear that there are many reasons, 
some not so obvious but still legitimate, that a road might be needed.

23) P12 Definitions

The agency should abandon the Chief’s unique and confusing definition of the 
term “road” and use the more reasonable and universal definition, which 
already enjoys widespread, including legal, acceptance.  “Any way, travelway, 
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. 

24) P18 Fourth Bullet

Decommissioning should not be the predetermined outcome or first priority of 
agency road decisions, nor should use rate be the primary driver for 
maintenance and reconstruction.  Many factors, such as recreational value, the 
potential for environmental damage, etc. should also weigh heavily into 
maintenance and reconstruction decisions.

25) P19 First Bullet

Add recreational needs to the list of considerations for decision making.

26) P19 Second Bullet

Add direction that no existing roads (as defined above) are closed, 
decommissioned, or otherwise restricted until after the comprehensive 
inventory of use and condition is completed and the results presented and 
reviewed by the public.  It is only reasonable that a meaningful and 
comprehensive road inventory be accomplished and completed without being 
affected by closures and other restrictions during its development. 

27) P19

Recreation should be included in the list of criteria to be evaluated for 
impact of proposed road decisions.  Elsewhere in this document, recreation is 
recognized as a valid forest use.  Recreation should be fully integrated into 
all planning for future and existing roads.

28) P20 Table 4

The decommissioning of existing roads would occur if  “no longer needed”. 
Define the term “needed” to include the need for primitive recreational 
access, both motorized and non-motorized and public safety (fire service 
roads).  Needs are many and should be clearly defined with all potential uses 
being considered fully and fairly.

29) P20 Second Paragraph 

The revised policy must not be implemented nor the pace of decommissioning 
increased until the comprehensive inventory of use and condition is completed 
and the results presented and reviewed by the public.  In fact, no 
decommissioning should be conducted until the comprehensive inventory of use 
and condition is completed and the results presented and reviewed by the 
public.

30) P21 Second Paragraph “Key roads needed for recreation …”

How will roads be determined as “key”?  Define the criteria that will be used 
to define the term “Key roads”. 

31) P21 Second Paragraph

Define the degree that “key roads” will be “restored and improved” as a result 
of this policy.  The agency must expressly note that “Key roads needed for 
recreation” should include roads of all road classifications and maintenance 
levels.  Every road that is key to recreation is not a paved or graded gravel 
smooth surface road.  Most, in fact, are high clearance, poor transportation 
quality roads that help to ensure a good primitive recreational experience.

32) P 22&23 Table 5 and Figure 2

Define headings as footnotes (i.e. what specific activities goes into the term 
“Forest Management”)

33) P21 First Paragraph

The road system on FS managed lands impacts all other aspects of NF 
management, to fragment the issues into several smaller, individual EAs allows 
for inconsistency and confusion. This EA should not defer any transportation 
or road issues to other documents.  Additional alternatives should have been 
developed and evaluated, including concepts such as: managing the road system 
as recreational infrastructure rather than as a traditional transportation 
system, user maintenance and/or reconstruction in lieu of decommissioning, 
reopening routes in order to disperse users and decrease impacts. 

34) P24 Alternatives Considered but Not Analyzed in Detail

One alternative for a document of this magnitude and impact is absurd.  
Clearly, there was not an adequate effort to consider any alternative but the 
preordained proposed alternative.  Why was there no consideration given to 
managing user density rather than concentrating visitor impacts?  Why was 
there no consideration given to creating an intelligent, well designed road 
system, using existing roads, that does meet both the current and future user 
needs while being protective of the environment?  Is there no interest in the 
agency to manage public lands for the public?  To abandon that charge is to 
eliminate both the public’s recreation and the agency’s purpose.

35) P25 Decommissioning, Paragraph 1

Mitigation and remediation should always be considered as the first choice 
before decommissioning.  Once a road is decommissioned it is much more 
difficult and expensive to replace should future management decisions require 
it.  Also, it is much more expensive to decommission a length or segment of 
road than to mitigate whatever damage may be associated with the road and by 
mitigating, the recreational resource remains.
36) P25 Decommissioning, Paragraph 2

It is improper to assume that more roads will be decommissioned before the 
inventory is complete, before comments on this document are received and 
evaluated, and before the other pending EA/EISs associated with FS roads and 
travel management are complete and all legal questions are resolved.

37) P26 Reconstruction

Road reconstruction should be undertaken in a graded manner, with the agency 
doing only what is needed for safety and resource protection without changing 
the nature and characteristics of the original road.  Not every road in the 
agency system should be suitable for standard passenger car travel or meet 
transportation standards, some are needed as primitive, high clearance roads 
to allow the motorized recreationist the same solitude and primitive back 
country experience that hikers enjoy in designated wilderness.

38) P26 Reconstruction

Road reconstruction should occur in close cooperation with affected user 
groups to preserve the nature of the original road.

39) P27 NFS Land

Specify acreage of designated WSAs, and other restricted use areas, in 
breakout and in figure 3 – WSAs and other restricted areas are not typically 
managed for multiple use and as such should be clearly indicated that 
restrictions (often severe) exist.  To omit these areas misleads the public 
regarding their recreational opportunities and understates the acreage that 
is, or may, not be available for public recreation.

40) P30 Paragraph 1 “Additional road decommissioning could further reduce 
vehicle access … “

First, thank you for finally acknowledging that vehicle access has been 
reduced and that this plan will further impact the number one segment of FS 
customers. Please go on to explain how “further” reductions to access by 
motorized vehicles is consistent with a 1,300 % increase in motorized 
recreational use (P7) and an expected continued growth.  All of this growth, 
both past and future, despite the ongoing and accelerating closure policy 
currently underway.  The agency’s own research documents an overwhelming 
demand by the public, for whom you only manage, not own, the land, for 
increased motorized access. Despite this documented research, the agency 
chooses to accelerate the REDUCTION in opportunity?  Clearly this logic is not 
sound and therefore, this document is fatally flawed and must be withdrawn 
before additional tax dollars are wasted.

41) P38 Noxious Weeds, “Road construction and reconstruction present the 
greatest opportunity for infestations of noxious weeds and invasive plants to 
spread.”  And, “Generally, the greatest possibility for infestations is in 
roaded areas.”

Please present the citation for the research that supports this assertion, 
preferably legitimate research and not special interest pseudo-science and 
dogma.  Please compare that data with similar supporting science that 
addresses noxious weed or invasive plant infestations in non-motorized areas, 
including designated wilderness.  Noxious weed propagation enjoys many 
mechanisms, to arbitrarily assign blame to one segment of the users and to 
then use that blame to reduce their opportunities is beyond absurd and could 
be considered agenda driven.

42) P39 Recreation  “In fact, driving for pleasure is the SINGLE LARGEST 
RECREATIONAL USE OF NFS LANDS …” (emphasis added)

Given this fact, one that is reiterated in most individual forest plans, why 
has the agency made no attempt to evaluate an alternative that would both 
address the public’s desire while reducing resource impact?  In other words, 
why has the agency not evaluated a management alternative?  This document, 
especially in context with the several preceding agency documents, makes it 
appear that the agency is not interested in managing public lands, in 
minimizing resource impacts, or in managing transportation issues, rather, it 
appears the agency is only interested in eliminating road miles regardless the 
impact or desires of agency customers.

Read your own words again and make note of them – this entire document, in 
fact the entire agency direction in the last several years, is wholly 
inconsistent with this fact.  If the agency is no longer to be responsive to 
the public it serves it should be dismantled and its management 
responsibilities reassigned to an agency that does respect the public land 
owners and recognizes their desire to responsibly utilize their public lands.

43) Proposed Action Fourth Paragraph “… reduced road construction … could 
enhance scenic quality and dispersed recreational opportunities.”

This statement is wholly false for the vast majority (see p 39) of the public 
who will no longer enjoy access to the “scenic” and “dispersed recreational 
opportunities” that they now enjoy.  This statement may be true to the less 
than 2% who already enjoy the absence of active roadways in the 25% of NFS 
managed public land already designated as Wilderness, but only to that less 
than 2%.  In order to minimize confusion, clarify that the majority of forest 
visitors (greater than 98%) will not enjoy enhanced “...scenic quality and 
dispersed recreational opportunities...”, only a minority of visitors.

44) P50 Economic Effects  “Some economic values …, while others are enhanced 
by limiting access (e.g. primitive non-motorized recreation experiences).”

This statement and example has not been supported in areas where motorized 
access has been severely curtailed.  In most cases the “increase” is not 
measurable, especially when contrasted with the economic impact of a well 
managed area that remains open to motorized recreation.  Check with 
communities (Moab, UT for example) that have actually struggled through a 
shift away from extractive industry (timbering, mining) and toward recreation 
as a major part of their economic base.  Cite actual evidence rather than 
echoing anti access lobby propaganda.

45) P50 Social Effects “…, if roads interfere with a view or permit a level of 
human density that reduces the quality of the view …”

This statement, again, illustrates the need for increased, dispersed, 
motorized recreational opportunities rather than simply concentrating visitors 
into smaller and smaller areas.  It points clearly to needing management that 
satisfies both the public demand and resource protection.  Sadly, this 
document does not attempt to provide any management solutions.

46) P50 Community Capacity First Paragraph “These less tangible values are 
often adversely affected by roads.”

This statement is purely speculative and pejorative, further, it appears to be 
wishful musing by the author in the way it is tacked on to the end of the 
paragraph.  Either remove it entirely or support it with facts.

47) P50 Community Capacity Second Paragraph

Agency trust has been consistently eroded in communities adjacent to highly 
restricted NF areas.  Northern Nevada is but one of the current and ongoing 
examples of the community partnership and trust-building that the agency 
fosters.  Cite some successes to support the notion that the agency is 
interested in partnering with local communities rather than participating in 
rural cleansing.

48)  P53 Proposed Action “…, impacts of road decommissioning … would not be 
expected to have economic or social impacts.”

This contention has not been supported in other areas where access has been 
significantly curtailed. In fact the exact opposite is generally true.  Cite 
evidence that supports the notion that eliminating access has no social or 
economic impact.  Reconcile how on p50 the agency touts an economic benefit 
from reducing road access and three pages later indicates no change.

49) P53 Proposed Action “… decommissioning more miles of roads under the 
proposed action would increase social values.”

Explain how being removed from historic access to neighboring forests 
increases “social values”.  Explain how road decommissioning can both 
“increase social values” and “would not be expected to have economic or social 
impacts.” 

50) P53 Proposed Action “… social values of those who enjoy off-road vehicle 
use could be adversely affected.”

The principle group of agency customers have sacrificial social values?  
Explain why and how the social values of the single largest visitor group on 
NFS managed lands can be so easily dismissed. 

51) P55 Second Paragraph “Limiting road development …” 

This paragraph, rightly, points out the negative impacts to motorized 
recreation, it should go on to reiterate the fact that this is the primary 
activity being enjoyed on NFS lands.  Further, this paragraph, again rightly, 
illustrates the clear bias in this document in favor of non-motorized visitors 
and against the motorized back country recreationist.  This is completely 
unacceptable and it serves only to further undermine both the credibility of 
the agency and its ability to manage public lands without undue influence from 
the anti recreation lobby.

52) P58 Factor 2

Reconcile how rapidly growing demand for roaded recreational access (p7) is 
compatible with “aggressive decommissioning”.

53) P69 Table 10, Proposed Action “Recreation, Heritage,…” Third Bullet

This statement is misleading, motorized opportunity for dispersed recreation 
and scenic quality would not be improved, rather it would be significantly 
curtailed or eliminated.  This distinction should be clearly made since 
driving for pleasure is the “single largest recreational use of NFS lands.” 
(p39)

54) P72 Cumulative Effects Second Paragraph

If the agency has no ability to determine the cumulative effect of the revised 
road management policy, why is this document being developed?  Without some 
expectation of a tangible benefit, it is a waste of tax dollars to pursue this 
proposed alternative.

55) P72 Cumulative Effects Third Paragraph

It is premature to state that physical and biological resources would benefit, 
especially since this statement appears to contradict the previous paragraph.

56) P72 Cumulative Effects Third Paragraph “Adverse recreational and social 
and economic impacts could occur as a result of decreased motorized 
recreational opportunities …” 

Finally!  It is clearly acknowledged that this plan negatively impacts the 
agency’s primary visitor group and those who most rely on NFS managed land for 
their livelihood.  It is unfortunate that earlier sections of this document do 
not acknowledge this fact (p50, Economic Effects; p50 Community Capacity; p53 
Proposed Action; others) and, in fact, many sections contradict this 
acknowledgement.

57) P74 Relationship Between Short-Term Uses and Long-Term Productivity “Road 
decommissioning …, or are unneeded to meet current uses.”

With future motorized recreation expected to increase a conservative 64%, 
shouldn’t this document be forward thinking and, at least, attempt to provide 
for this future demand?

58) P75 Consultation

The agency must acknowledge all contributors by name and affiliation, 
including those considered “external stakeholders” and those participating in 
the focus groups.

59) P75 Consultation

A final EA will not be adequate for a policy change of this magnitude, a 
complete and thorough EIS must be prepared to fully analyze the long-term 
consequences of this proposal. 

60) P75 Consultation

A Finding of No Significant Impact is clearly not appropriate for an 
alternative that could close off at least 77% of current agency managed access 
roads.  The impact would clearly be significant to the public and to rural 
communities near affected public lands.

61) Appendix A Glossary

•	Road – The agency should abandon the Chief’s unique and confusing definition 
of the term “road” and use the more reasonable and universal definition which 
already enjoys widespread acceptance. “Any way, travelway, 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. 

•	Unclassified Road – Travel ways may indeed appear abandoned, to those who do 
not recreate on them, while very much in use. Appearance should not be used as 
a justification to close or decommission valuable recreational resources.

•	Unroaded Area – Not all roads were constructed or maintained for vehicle 
use. This definition is invalid and should be revised to address those 
legitimate roads and rights of way that are protected under RS2477 and other 
statute but that do not fit the “constructed or maintained” criteria.

62) Appendix D Map

No map(s) were provided.

63) Appendix E Page E1 Fifth Paragraph

This resultant positive qualitative net appears to be manufactured to support 
the proposed alternative and further illustrates the extreme prejudice with 
which the agency views recreation in general and motorized recreation in 
particular. With fewer than 2% of agency visitors taking advantage of 20% of 
agency managed designated wilderness, the agency takes credit for improving 
“protection of wilderness areas” and “improvements or maintenance of legal 
more wilderness-type environments.”  Clearly, the agency bias is to direct the 
majority of managed lands into a wilderness-like refuge for a tiny minority of 
users at the expense of every other visitor.  Further, “...access for Public 
Safety …” will certainly be affected as roads are closed and decommissioned as 
well as knowledge base is lost from volunteer groups such as Search and Rescue 
groups due to a lack of access and resultant familiarity.  This statement is 
false and misleading.

64) Appendix E Page E2 Background

Area lost to multiple use due to WSA and other restrictive designation should 
also be included specifically since many (most?) WSAs are managed as de facto 
wilderness.

65) Appendix E Page E2 Background

The number of road miles closed and current road closure trend information 
should be provided and compared to visitor road use trends to illustrate the 
resultant increase in user density that the agency is advocating.  Some 
evaluation of the two trends (closure vs. increasing demand) should be 
presented so that the public can better understand at what point remaining NFS 
managed roaded areas will be overused. 

66) Appendix E Page E3 Second Paragraph “…, recreation road use has increased 
dramatically since 1950 and is expected to continue to increase.”

Reconcile how this proposed alternative of “aggressive decommissioning” (p58) 
meets the agency goal of ensuring “… the transportation system meets current 
and future management objectives and public uses …” (pE1).  It is not clear 
how reducing the transportation system, especially the recreation portion, 
meets increasing demand. 

67) Appendix E Page E7 Access and Public Safety

No mention is made of recreation needs in this section or those following 
despite agency acknowledgement that recreation is rapidly replacing timber and 
other extractive industries as the primary use of NFS managed lands.  Surly, 
some mention of  the impacts to recreational access is justified in a section 
labeled “access”.

68) Appendix E Page E7 Access and Public Safety

This section appears to only address minimal access to preexisting rights, the 
section title would lead one to believe that this section would address the 
entire spectrum of access and include all types and forms of access on all of 
the various land use designations.  To dismiss access and public safety in two 
sentences is inadequate and misleading.

69) Appendix E Page E9 Benefit-Cost Effects

Some effort should be made in this section to reconcile the contradictory 
statements made earlier in the document addressing costs and potential benefit 
effects.  As presented the only meaningful discussion presented relates to 
timbering, no substantive discussion is presented regarding grazing, 
recreation, mining, or any other activity on NFS managed lands.

70) Appendix E Page E11 Employment Effects Third Paragraph

Explain “harvest substitution” as used in this section to reduce the 
employment impacts of reduced timbering.  Include the type of work to be 
substituted and compare salary ranges to those of jobs lost as a result of the 
reduced timbering.

71) Appendix E Page E11 Employment Effects 

Some consideration should be given to the employment effects associated with 
well managed, recreation focused, public lands.  For example, the Paiute ATV 
Trail system in rural Utah has boosted local economies by nearly $17,500,000 
in 1999 alone (FS analysis: “Paiute ATV Trail Economic Outcome”).

72) Appendix E Page E13 Noxious Weeds and Nonnative Invasive Plants

Other infestation pathways should be addressed, or at least acknowledged, and 
compared to road construction/reconstruction impacts.  Care should be taken to 
fully document and explain how relative infestation causes were determined.

73) Appendix E Page E13 Noxious Weeds and Nonnative Invasive Plants

Some comparison between increased infestation and the ability to treat 
infested areas should be presented.  It is implied that there is a net 
increase in infestation from additional access.  Is that , in fact, the case?  
How has that been determined and where are the results presented?  What impact 
does underfunded or unaggressive treatment have in skewing the results?  If 
funding and agency priority dictated aggressive treatment, would there be a 
net decrease in infestation with adequate access?

74) Appendix E Page E14 Noxious Weeds and Nonnative Invasive Plants “… is 
likely to …”

There appears to be no supporting evidence for this claim.  If there is, it 
should be presented, or at least cited, otherwise the agency may believe a 
result likely, but nothing more.

75) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources “Roads 
are necessary for driving for pleasure, the largest recreational use of NFS 
lands.”

Note that all “driving for pleasure” does not occur, nor should it all occur, 
on high quality, well maintained arterials.  There is a great need for 
primitive, low traffic roads for access to primitive recreational 
opportunities for the motorized recreationists.

76) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources “Roads 
are necessary for driving for pleasure, the largest recreational use of NFS 
lands.”

Please explain how the “aggressive decommissioning” (p58) advocated in the 
proposed alternative, which serves to concentrate visitor use, will address 
the agency’s stated objective to “… causes minimum adverse environmental 
impacts.”(p2).  The preferred alternative appears to be contradictory with the 
clearly illustrated and documented public preference for “driving for 
pleasure”.

77) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources 
“Unroaded and roadless areas are …”

These areas already contain many miles of existing, historically used, roads 
that provide “...primitive and semi primitive settings for dispersed 
recreation …” for the motorized FS visitors.  With about 20% of NFS managed 
lands already designated Wilderness and available only to “backpacking and 
hiking”, these remaining primitive areas should remain unaffected to allow 
that same experience to the motorized recreationists.

78) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources “… 
roads within these areas generally have a negative impact on these recreation 
experiences.” 

Existing roads are currently shared by visitors and, generally, are of such 
quality that they are relatively unnoticeable and lightly traveled.  If 
individual recreationists choose not to share these roads with motorized 
visitors seeking a similar back country experience, they should seek out 
designated Wilderness where motorized recreationists are prohibited.

79) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources 
“Increases in user density …, would have negative effects on users seeking a 
wilderness-type experience.” 

The designated Wilderness system exists expressly for those recreationists 
“seeking a wilderness-type experience.”  Currently, about 2% of FS visitors 
appear to be seeking that experience (FY2000 FS budget request) while the 
agency oversees about 20% of it’s managed lands as designated Wilderness. 
Those visitors whose “wilderness-type experience” will suffer “negative 
effects” by sharing with those visitors who must, or who choose, motorized 
recreation should be directed to that designated Wilderness.

80) Appendix E Page E14 Recreation, Heritage, and Wilderness Resources 
“Decommissioning of other roads …”

Off highway vehicle users are a significant portion of the “driving for 
pleasure” visitors.  Decommissioning roads would seriously impact these 
visitors who use roads the agency might, wrongly, consider lightly used due to 
their primitive nature.  These primitive roads are the key access mechanism 
for the OHV visitor’s primitive back country experience.  These roads must 
remain available and largely unreconstructed to retain their unique, historic 
nature, to keep visitor density to a reasonable level, and to provide the 
mechanized visitor the same type of primitive opportunity that designated 
Wilderness provides the backpacker and hiker. 

81) Appendix E Page E17 Conclusions Third and Fourth Paragraph “No difference 
is expected for access…”

As noted above, this comment is not true, motorized access will be seriously 
impacted and other, non-motorized. access will be negatively impacted to a 
lesser degree.  These impacts should be acknowledged throughout the document, 
not only in small, discrete, sections.  It is misleading by the agency to 
acknowledge these impacts in the body of the document and to then minimize or 
disavow those same impacts in the conclusions, which most of the public will 
limit their reading to.

82) Appendix E Page E17 Conclusions Fourth Paragraph “The effects on 
recreation and heritage resources are ambiguous.”

This is not true at all, the effects on recreation are abundantly clear; there 
will be significantly reduced opportunities for all recreationists as access 
is restricted and visitors are concentrated into smaller and smaller areas.  
This will seriously impact the mechanized visitors as virtually all of the 
primitive roads will eventually be decommissioned and with them the 
opportunity for solitude and a primitive back country experience for all but 
the 2% currently utilizing previously designated Wilderness.

83) Appendix E Page E18 Conclusions “The emphasis on decommissioning … 
designing a transportation system …should lead to an overall increase in net 
public benefits.”

This statement is a good indication of just how out of touch the agency is 
with it’s customers and how poorly conceived this document is.  The agency 
acknowledges the need for access, acknowledges the magnitude of “Driving for 
Pleasure” as the number one visitor need, yet refuses to understand the 
importance of meeting that need.  Forest visitors need a variety of road types 
and quality in order to meet the desire for primitive mechanized recreation 
while also affording access to those who do not seek that level of solitude, 
this plan calls for an elimination of the very resource that the solitude 
seeking visitors require.  It is time to quit viewing the road system as 
strictly for transportation and understand that for many (most?) visitors it 
is an integral part of the recreational infrastructure needed for a positive, 
primitive, back country experience.  We would encourage the agency to work 
with these visitors to identify areas needing immediate attention, resolve 
those issues in partnership, and maintain the opportunity for primitive back 
country solitude for all visitors.

84) Appendix E Page E19 Table E1

The net benefits indicated for recreation should be segregated into at least 
motorized/non-motorized to better capture the true impacts and to illustrate 
the visitors most impacted by this proposal.

With the rapid growth in designated Wilderness proposals, the President’s rash 
of unilateral National Monument designations and the “aggressive 
decommissioning” of roads that this alternative advocates, the principle 
visitors to NFS lands will be concentrated into very small, highly sanitized 
areas with little opportunity for any true back country experiences.  This is 
the path the National Park Service appears to be following at many of their 
public land areas and is often employed by commercial parks where all the 
visitors are herded into small enclave and toured through select areas by 
tram.  We believe that, while that approach may have its place, our NFS 
managed lands deserve to be fully experienced and enjoyed by responsible 
recreationists.  
 
We strongly urge that these proposals be withdrawn and completely rewritten.  
They are contrary to congressional intent as set forth in the Roads and Trails 
Act and in the RPA.  Transportation planning should be integrated into the 
land management planning process as clearly contemplated by the Congress.  We 
also urge the agency to use a broader spectrum of advisors in future 
rule-making and to allow greater input into national policy by those district 
staff that must implement the policy, they know their visitors best.

Thank you very much for the opportunity to comment.  Please allow the public 
to fully participate in this process by extending the comment period for an 
additional 180 days so we can provide well thought out and meaningful input to 
this document. I look forward to your response

Sincerely,