Public Comment: Letter to Chief Dombeck - Withdraw the Roadless Rule

The Forest Service is accepting public comments until July 17, 2000 on the Roadless Area Conservation Draft Environmental Impact Statement.

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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. Sincerely,

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