Re: Re: IMPORTANT TRAIL ISSUE: Forest Service public rulemaking process

["Duncan Fletcher" <dfletche@gte.net>]

This proposal could have some benefits. How many trails are now gone because
they have been converted to roads? But the potential in the language of one
of the proposed options could be damaging. I have included at the bottom of
this post my comments to the Forest Service on this proposal. I will also be
sending a copy to my Congressman and Senators.

I encourage all of you to do the same. Not in opposition to the proposal,
but in favor of language that will benefit recreational use of the
backcountry. My sense is also that this is one that we can be successful
with.

Duncan Fletcher
dfletche@gte.net


----- Original Message -----
From: Duncan Fletcher <dfletche@gte.net>
To: <roadless/wo_caet-slc@fs.fed.us>
Sent: Sunday, December 19, 1999 9:37 PM
Subject: Roadless Area Initiative


> Some concerns:
> The following is from the perspective of a recreation forest user.
Primarily
> horseback (but I also backpack), but I don't want to create user fights.
> While I would love to have the Forests to myself, I don't wish to pursue a
> selfish agenda - and I hope the US Forest Service will screen those
selfish
> agendas from its decisions. Including those selfish agendas disguised as
> Environmental Concerns that frequently have little bearing on the ultimate
> health of the forest. A mud puddle on the trail is not of much
significance
> in overall forest health, even though folks don't like to walk through it.
>
> I am a member of Backcountry Horsemen of Washington. That organization has
> not take a position on this issue, but I think my concerns will represent
> the concerns of most horseback users. There are definite benefits, but the
> devil is in the details.
>
> PART 1 OF THE PROPOSAL
> Possible alternatives to be considered in the draft environmental impact
> statement for part one may include:
> 1  Prohibiting new road construction and reconstruction projects in the
> remaining unroaded portions of inventoried roadless areas;
> 2  Prohibiting new road construction and reconstruction projects and
> commercial timber harvest in the remaining unroaded portions of
inventoried
> roadless areas;
> 3  Prohibiting the implementation of all activities, subject to valid
> existing rights, that do not contribute to maintaining or enhancing the
> ecological values of roadless areas in remaining unroaded portions of
> inventoried roadless areas; and
> 4  Making no change in current policy (No action alternative).
>
> Number 3 is rather sweeping language that could be interpreted to exclude
> all human activity within the boundaries of the Roadless Areas. Indeed, it
> would be hard to make a case that any recreational activity actually
> contributes, maintains, or enhances ecological values. That is not to
imply
> that most recreational activity does any significant harm, but neither
would
> I suggest that it enhances. The valid existing rights could easily be
> interpreted to include only contractual rights which would exclude most
> individual recreational activities. Any language about restrictions should
> require that a clear case based on sound scientific evidence that the
> activity is causing significant damage (and more than a minor contribution
> to similar damage caused by natural forces and wildlife) to the specific
> overall roadless area that cannot mitigated by better trail design, etc.
> before any activity is prohibited.
>
> Number 4 continues the existing problems for recreation in which trails
are
> frequently turn into roads.
>
> The language is confusing. What is an unroaded portion of an inventoried
> roadless area. The pink sheet of definitions dated 11/22/99 specifically
> states in the definition of an unroaded area that unroaded areas do not
> overlap designated roadless areas. I assume a designated roadless area is
> the same as a roadless area or inventoried roadless area. In the Q & A,
the
> term roadless states no classified or unauthorized roads. I assume that
> there are a number of authorized but unclassified roads.
>
> There is some concern that there may be roads that while unclassified in
FS
> documents have been used long term for recreational access. These need to
be
> dealt with at the local forest service level, not dictated from
Washington,
> DC on a one size fits all basis.
>
> PART 2 OF THE PROPOSAL
> With regard to part two:
> 1  National procedures and criteria that address how land managers at the
> forest plan level should manage activities, other than those addressed in
> part one, in inventoried roadless areas;
> 2  National procedures and criteria that address how land managers at the
> forest plan level should manage uninventoried roadless areas so as to
> protect their unroaded characteristics and benefits. Possible alternatives
> include:
> a.  Protecting unroaded areas based on their ecological characteristics;
> b.  Protecting existing unroaded National Forest System lands that are at
> least 1,000 acres in size and contiguous to unroaded areas of 5,000 acres
or
> more on all other Federal lands;
> c.  Protecting existing unroaded areas of at least 1,000 acres;
> 1  No change in current policy (No action alternative).
>
> Again the devil is in the details. I have reservations about the ability
of
> Washington to set criteria (as opposed to procedures which is fine)
> addressing managing activities to the various and different NF in the US.
> Criteria (for both 1 and 2 above) should largely be left to local forest
> plans. The one criteria that makes universal sense is, again, that before
> any activity is restricted, it should be based on sound scientific
evidence
> that the activity is causing significant damage (and more than a minor
> contribution to similar damage caused by natural forces and wildlife) to
the
> specific overall roadless (unroaded) area to which it applies and that
> cannot be mitigated by better trail design, etc.
>
> The size of the roadless areas is probably best left to local forest
plans,
> although from a selfish perspective of a recreation trail user, the
> prohibition of any new roads that might overlay existing trails is to my
> benefit.
>
> The following comments apply to both parts one and part two.
>
> 1.  That any abandonment or restrictions in existing (classified or
> unclassified) roads or travelways could be at the expense of legitimate
> recreational activity. Let me use as an example the closing of a short
> stretch of dead end road that connects 2 trails. Closing that short
stretch
> and extending the trailhead would make much sense. But that stretch of
road
> provides additional trail head parking. Without expanding the parking, the
> access to all of the trailheads has been reduced.
>
> 2.  A similar concern would be parking at informal camping areas that
could
> be beyond whatever buffer is established along existing roads - i.e. the
> delineation of the roadless (unroaded) area. That buffer needs to take
this
> into account.
>
> Finally, the time frame to respond to this is way to short. The
> contradictory definitions don't help. I have not had the opportunity to
> bounce this of other users. Therefore, these concerns may well be
> incomplete. Informational meetings held several days before the comment
> deadline suggest that comments are not particularly welcome and the final
> decision is already in - I hope that is not the case.
>
>
> Duncan Fletcher
> PO Box 344
> Gold Bar, WA 98251
> dfletche@gte.net
>


Duncan Fletcher
dfletche@gte.net


----- Original Message -----
From: Dyane Smith <sunibey@sisqtel.net>
To: <Zaronica@aol.com>
Cc: Ridecamp <Ridecamp@endurance.net>
Sent: Sunday, December 19, 1999 9:28 PM
Subject: RC: Re: IMPORTANT TRAIL ISSUE: Forest Service public rulemaking
process


>
> ----- Original Message -----
> From: <Zaronica@aol.com>
> To: <ridecamp@endurance.net>; <LOVELLBAGS@aol.com>
> Sent: Sunday, December 19, 1999 8:08 PM
> Subject: RC: Sunday's Headlines!
> > > Clinton, before leaving office Jan. 20, 2001, has pledged to change
the
> > management of millions of acres of public lands, largely in the West.
We
> have been discussing Trails and this represents 40 to 60
> > million acres of trails that could potentially be closed to any type of
> > competitive event be it CTR or     Endurance.
>
> The Forest Service is conducting a national scoping process to evaluate
> public comment on several proposed rule changes.  These rules concern a
plan
> to limit new roads in areas which have previously been designated
> "roadless".  To quote an 11/10/99 "Notice of intent to prepare an
> environmental impact statement", "This proposed rule is designed primarily
> to better manage the existing national forest road system.  It would also
> establish new procedural requirements to help managers make more informed
> decisions concerning entry into roadless areas."
>
> The deadline for public comment is TOMORROW.  If anyone is interested, I
> would encourage them to visit the website set up by the Forest Service to
> address this issue and also for anyone interested to write and ask for
more
> time for public comment.  The fact that the period for comment has
occurred
> during Thanksgiving and Christmas has caught a lot of groups unprepared to
> offer substantive response.  The roadless area rule website is:
> http://roadless.fs.fed.us.
>
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