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Roadless comments due now. Last chance!

Did Clinton really want the Roadless policy to be implemented? If so, why did he wait so long to do it? Regardless, we get to do it all over again. Bush has decreed that the record 1.6 million comments the first time around did not qualify as sufficient public participation, and has asked that the following skewed 10 questions be put out for public comment - with the goal of amending the roadless rules. Here are the questions:
Roadless comments due now.

Did Clinton really want the Roadless policy to be implemented? If so, why did he wait so long to do it? Regardless, we get to do it all over again. Bush has decreed that the record 1.6 million comments the first time around did not qualify as sufficient public participation, and has asked that the following skewed questions be put out for public comment - with the goal of amending the roadless rules. Here are the questions:


- Informed Decisonmaking. What is the appropriate role of local forest planning as required by NFMA in evaluating protection and management of inventoried roadless areas?
- Working Together. What is the best way for the Forest Service to work with the variety of States, tribes, local communities, other organizations, and individuals in a collaborative manner to ensure that concerns about roadless values are heard and addressed through a fair and open process?
- Protecting Forests. How should inventoried roadless areas be managed to provide for healthy forests, including protection from severe wildfires and the buildup of hazardous fuels as well as to provide for the detection and prevention of insect and disease outbreaks?
- Protecting Communities, Homes, and Property. How should communities and private property near inventoried roadless areas be protected from the risks associated with natural events, such as major wildfires that may occur on adjacent federal lands?
- Protecting Access to Property. What is the best way to implement the laws that ensure States, tribes, organizations, and private citizens have reasonable access to property they own within inventoried roadless areas?
- Describing Values. What are the characteristics, environmental values, social and economic considerations, and other factors the Forest Service should consider as it evaluates inventoried roadless areas?
- Describing Activities. Are there specific activities that should be expressly prohibited or expressly allowed for inventoried roadless areas through Forest Plan revisions or amendments?
- Designating Areas. Should inventoried roadless areas selected for future roadless protection through the local forest plan revision process be proposed to Congress for wilderness designation, or should they be maintained under a specific designation for roadless area management under the forest plan?
- Competing Values and Limited Resources. How can the Forest Service work effectively with individuals and groups with strongly competing views, values, and beliefs in evaluating and managing public lands and resources, recognizing that the agency can not meet all of the desires of all of the parties?
- Other Concerns. What other concerns, comments, or interests relating to the protection and management of inventoried roadless areas are important?

For more details see:
 http://www.onrc.org/alerts/107.usfsannounce.html


Feel free to respond to the questions, or just make the following comments:
- It is complete 100% bullshit politics that we should have to respond to such skewed questions when so many people commented in favor of full protection of our roadless areas the first time around.
- The roadless policy rule, as originally passed, should be kept as is.
- No timber harvest in roadless areas.
- No road building in roadless areas.
- All national forests should be included within the rule, including the Tongass, with no phase-in periods.

Send comments to:
USDA-Forest Service -- CAT
Attention: Roadless ANPR Comments,
P.O. Box 221090,
Salt Lake City, Utah, 84122;

via email to:  roadless_anpr@fs.fed.us;

or via facsimile to: 1-801-296-4090, Attention: Roadless ANPR Comments.

Sample answers to bullshit survey 26.Aug.2001 17:36

pissed

All comments, including names and addresses when provided, are placed in the record and are available for public inspection and copying at Salt Lake City, Utah. Include as much place specific information as possible in your comments. Chief Bosworth said that these kinds of comments will receive additional weight by the agency.

_SAMPLE LETTER to Dale Bosworth, U.S. Forest Service Chief

Dear Mr. Bosworth, I am writing to insist that you maintain strong roadless area protections in National Forests, as they are currently formulated. Following are my comments to your recent scoping questions:
1. Informed Decisionmaking. What is the appropriate role of local forest planning as required by NFMA in evaluating protection and management of inventoried roadless areas? Local forest planning has clearly failed to provide adequate protection of roadless areas, having resulted in the destruction of 2.8 million acres of roadless areas over the past 20 years. Under current forest plans, about 60 percent of the remaining roadless areas are available for road construction, logging, and other commodity development. Only a uniform national rule can protect roadless areas permanently. Roadless areas are a finite resource in worldwide decline. Policy decisions affecting roadless areas affect all Americans, thus the national level is the appropriate level to manage for clean air, clean water, and continued existence of roadless areas.
2. Working Together. What is the best way for the Forest Service to work with the variety of States, tribes, local communities, other organizations, and individuals in a collaborative manner to ensure that concerns about roadless values are heard and addressed through a fair and open process? The Roadless Area Conservation Rule was developed through the most extensive public involvement in the history of federal rulemaking, with more than 600 public hearings nationwide. More than 1.6 million Americans submitted official comments, 95% of which supported strongest possible protections for remaining roadless areas. States, tribes, communities, and the general public had ample opportunity to review and comment on the proposal. This question erroneously assumes the previous process was unfair and closed. The process used by the Clinton administration should be used, and its policy outcomes implemented. In other words, we have already answered these questions and are waiting for the Bush administration to act.
3. Protecting Forests. How should inventoried roadless areas be managed to provide for healthy forests, including protection from severe wildfires and the buildup of hazardous fuels as well as to provide for the detection and prevention of insect and disease outbreaks? The Roadless Area Conservation Rule already provides exceptions that allow road building and logging when needed to address concerns of wildfires and forest health. According to the Forest Service, less than 2% of the inventoried roadless areas are at combined risk of insects, disease, and fire. Wildfires are much more likely to start in areas with roads, due to increased public access. Research indicates ecosystem health declines as road densities increase. This question reflects a poor understanding of forest ecology. Wildfires, disease outbreaks, and insect infestations are part of the forest health cycle. The best way to maintain healthy roadless areas is to keep them roadless.
4. Protecting Communities, Homes, and Property. How should communities and private property near inventoried roadless areas be protected from the risks associated with natural events, such as major wildfires that may occur on adjacent federal lands? Roadless areas are a backstop against catastrophic wildfire events. Unroaded, uncut forests have retained their larger, fire-resistant trees, while areas growing back from clearcuts are often comprised of unnaturally thick stands of smaller trees that burn easily. Roaded forests face a higher risk of catastrophic fire, as waste from timber operations acts as tinder for flames, and road access brings more people who unintentionally ignite forest fires. The risks from natural events cannot be eliminated, only reduced. Wild fires are important in maintaining the natural ecological function of roadless forests, and should be left to burn in most instances. Those wishing to live near roadless wilderness areas should bear the cost of fire- proofing their structures.
5. Protecting Access to Property. What is the best way to implement the laws that ensure States, tribes, organizations, and private citizens have reasonable access to property they own within inventoried roadless areas? Access to property is already ensured in the present rule. The Roadless Area Conservation Rule has no effect on access to state and private land inholdings. Roadless areas are no different from any other national forest lands regarding inholder access. The Bush administration should not be perpetuating the myth that the current Rule denies access to property inholdings.
6. Describing Values. What are the characteristics, environmental values, social and economic considerations, and other factors the Forest Service should consider as it evaluates inventoried roadless areas? There are tremendous environmental, social, and cultural values associated with roadless areas. These include:
(1) scientific value - they provide the only meaningful baseline against which forest management can be evaluated;
(2) wildness value - humans can not create wildness. Wildness helps us understand ourselves as part of something larger and grander.
(3) conservation value - roadless areas act like Noah's ark, ensuring all species are provided for. Scientists do not know how to ensure long-term ecosystem sustainability, and advise that we "keep all the parts" as they study the problem;
(4) spiritual value - our great religious figures, like Jesus, had to spend time in the wilderness before beginning their ministry.
(5) cultural value - wilderness is an American idea and one of our greatest exports. Vast roadless areas built the national character, influenced our expansionist history, and our writers like Cooper, Emerson, Thoreau, and Leopold. The continued loss of roadless areas breaks our links with our history and our sense of identity as Americans.
(6) replacement value - roadless areas are finite. They can be eliminated in as little as a summer, but require decades-to-centuries to be recreated. Because they are vulnerable and important, they need protection;
(7) future value - roadless areas represent a legacy we can leave for our children so that they can decide how to manage them. If we eliminate roadless areas now, we foreclose that option.
(8) freedom value - in his novel 1984, George Orwell's totalitarian dictator "Big Brother" made the elimination of wilderness his top priority. Wilderness was a place where thought could not be monitored or controlled, and therefore represented a threat to the regime.
Roadless areas: -Provide sources of clean drinking water; -Protect water quality for fishing and swimming; -Function as biological strongholds for rare wildlife; -Provide large, relatively undisturbed landscapes important for protecting the web of life; -Present opportunities for stepping outside of the hustle and bustle of daily life and returning to nature; -Serve as barriers against the spread of weeds and pests into pristine areas; -Offer opportunities for scientific study and research; -Provide open space and unspoiled vistas; -Preserve areas needed for traditional Native American religious and cultural observances; - and generally maintain local and regional ecosystem sustainability. The commodity values in roadless areas are not significant. Roadless areas provide less than two-tenths of one percent of the nation's timber supply, and commercial logging of roadless areas would require large taxpayer subsidies. Similarly, roadless areas in the Rocky Mountains contain only four-tenths of one percent of the nation's oil resources and six-tenths of one percent of U.S. gas resources. The real economic value of national forests comes from recreation and environmental quality of life, which the Roadless Area Conservation Rule carefully preserves. Approximately 85 percent of the revenue generated from America's national forests comes from recreational activities, more than five times the amount generated by logging.
7. Describing Activities. Are there specific activities that should be expressly prohibited or expressly allowed for inventoried roadless areas through Forest Plan revisions or amendments? Commercial logging, mining, oil drilling, ORV use, and pack animals should be banned in all roadless areas. Scientific study, hunting, fishing, hiking, camping, and firewood collection are compatible uses. "Land swaps" disposing of roadless areas must be prohibited. Allowing forest plans to make additional exceptions for specific activities would completely undermine the Rule, setting the stage for a return to the incremental destruction of roadless areas that the Rule was intended to stop. Roadless areas should receive additional protection through the forest planning process, especially from destructive off-road vehicle use and hard-rock mining.
8. Designating Areas. Should inventoried roadless areas selected for future roadless protection through the local forest plan revision process be proposed to Congress for wilderness designation, or should they be maintained under a specific designation for roadless area management under the forest plan? Both should be pursued. This is not an either/or issue, and no changes in the Roadless Area Conservation Rule are needed to address it. By law, forest plans must evaluate the wilderness potential of all roadless areas and make recommendations for wilderness designation by Congress. The Rule allows the wilderness recommendation process to continue. Forest plans also designate roadless areas for continued roadless management, regardless of whether they are recommended for wilderness. The Rule ensures that roadless areas will, at a minimum, be protected from road construction and commercial logging.
9. Competing Values and Limited Resources. How can the Forest Service work effectively with individuals and groups with strongly competing views, values, and beliefs in evaluating and managing public lands and resources, recognizing that the agency can not meet all of the desires of all of the parties? The Roadless Rule represents a balanced approach to managing National Forests. The majority of land in the National Forests is already open to logging, mining, and drilling, while just 18 percent is designated wilderness. The Rule will protect the remaining 31 percent of the National Forests that are roadless areas as a natural legacy for future generations. The Roadless Area Conservation Rule enjoys the overwhelming support of the American people. While some people disagree with the Rule, the Bush administration needs to respect the expressed views of the vast majority, who have made it abundantly clear that they want protection for all roadless areas.
10. Other Concerns. What other concerns, comments, or interests relating to the protection and management of inventoried roadless areas are important? This questionnaire is highly biased and unnecessary. The American people have spoken, and the Roadless Area Conservation Rule should be retained and implemented as is. The Bush administration needs to do all that it can to ensure protection of America's remaining roadless areas. In particular, the Forest Service should stop preparing timber sales in the Tongass National Forest that are in violation of the Roadless Area Conservation Rule. The administration should also stop undermining the legality of the Rule and begin mounting a vigorous defense against the lawsuits challenging the Rule. In addition, the Administration should call off its efforts to weaken the environmental safeguards and public participation opportunities in the forest planning regulations. The existence of the last uniquely American forest landscapes is at stake. I urge the Forest Service to immediately implement the long overdue Roadless Area Conservation Rule.
Sincerely,
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** This Alert was compiled with information from the Heritage Forests Campaign, American Lands and many others. See Forests.org's "United States of America Forest Conservation News & Information, Most Recent" news archive - the most comprehensive source of information on American Forest Conservation on the Internet - at < http://forests.org/america/> for more information. You may also use Forests.org's unique Forest Conservation Portal search engine to find additional news and information: < http://forests.org/america/> for more information. You may also use Forests.org's unique Forest Conservation Portal search engine to find additional news and information: < link to forests.org Forests.org works to end deforestation, preserve old-growth forests, conserve all forests, maintain climatic systems and commence the age of ecological restoration. Copyright 2001, Forests.org, Inc.

How to comment ONLINE 26.Aug.2001 17:38

helper

FOREST CONSERVATION NEWS TODAY Bush Administration Moves to Weaken Roadless Forest Protections Only Two More Weeks for Public to Make Comments!! Take Action Now! ***********************************************
Lend your support to protection of America's Last Roadless Forests by submitting your comments to the U.S. Forest Service online

By Forests.org, Inc August 25, 2001 TAKE ACTION:

< http://forests.org/emailaction/bushroad.htm>

Forest Service Employees comments 26.Aug.2001 17:45

AFSEE supporter

THE FSEEE E-ACTIVIST
Electronic Journal Helping You Influence National Forest Policy
Volume 5, No. 3
August 24, 2001
<><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><>

============================================================
Roadless Area Conservation Rule in Jeopardy
Public Comment Needed by September 10, 2001
============================================================

The Roadless Area Conservation Rule was finalized and approved on January 12, 2001 during the last days of the Clinton administration. One of the most important forest conservation initiatives in the past 100 years, the new rule was designed to protect 58.5 million acres of our national forests from logging and road construction. Predictably, the Bush Administration postponed its implementation, substantially failed to defend it in court, and later announced that it may revise or amend it. On July 3, the Forest Service asked for a new round of public comment on the Roadless Area Conservation Rule. The comment period ends September 10.

Many people expect the Bush administration to significantly undermine the Roadless Area Conservation Rule by allowing greater flexibility in decision making at the local level and exemptions for significant portions of the national forest system, such as Alaska's Tongass National Forest. The possibility exists that the new administration may even decide to overturn the rule altogether. On the other hand, it's also possible that the Bush administration won't tinker with the Roadless Area Conservation Rule if the message from you and me is that we like the rule as is and don't want any changes.

1.6 Million Comments and Counting

The Roadless Area Conservation Rule was created with monumental public involvement and extensive planning. Nevertheless, given the newest request for public comment, the Bush administration apparently believes that 6oo public meetings and 1.6 million public comments during a three-year public planning process were inadequate and not reflective of the desires of the American public. The rule received tremendous public scrutiny and was no last minute decision, yet the Bush administration is now asking you and me for more input.

Once again, we must stand up, voice our opinions, and do what we can to safeguard America's last wild national forests. There's no better time than right now to let the Bush administration know that the vast majority of Americans really do want our wild and roadless forests protected from the bulldozer and chainsaw.

Pressing Questions

The Forest Service is asking for public response by September 10 to ten questions. Your comments should address at least some of the ten questions. For your convenience, the questions and FSEEE's official response to the Forest Service are included below. We encourage you to make your comments as personal as you can. Tell the Forest Service why you think the last wild forests should be protected. Talk about specific wild and roadless forests that you especially appreciate and enjoy. You may also borrow from FSEEE's comments if you wish.

Be sure to include the following:

- Ask that your comments be accepted in response to the "Roadless Area Conservation advance notice of proposed rulemaking."

- Tell the Chief of the Forest Service Dale Bosworth to protect all of our nation's roadless areas from commercial logging, road building and mining.

- Tell Chief Bosworth that you respectfully request that no exemptions or exclusions be created to undermine or weaken the Roadless Area Conservation Rule.

Where to Send Comments

All comments sent by mail must be postmarked by September 10, 2001. All emails and faxes must also be dated on or before September 10.

Via email:  roadless_anpr@fs.fed.us

By mail: USDA-Forest Service-CAT
Attn: Roadless ANPR Comments
P.O. Box 221090
Salt Lake City, Utah 84122

Or by FAX: 1-(801)-296-4090
Attn: Roadless ANPR Comments

Let's make sure that the Roadless Area Conservation Rule is put into effect and not cast aside by the Bush administration. Encourage co-workers, friends, and family to send comment letters. Please also mail copies of your comments to your local congressional representative and U.S. Senators. For names and addresses of your representatives/senators are, use the links provided below.

Links

To find U.S. Senators:
www.senate.gov/contacting/index_by_state.cfm

To find Representatives:
www.house.gov/house/MemberWWW.html

To view the entire Federal Register advance notice of proposed rulemaking:
www.roadless.fs.fed.us/documents/anpr.html

FSEEE's Response to the 10 Questions

Informed Decisonmaking. What is the appropriate role of local forest planning as required by NFMA in evaluating protection and management of inventoried roadless areas?

NFMA provides that plans may "be amended in any manner whatsoever after final adoption after public notice . . ." Thus, a national rule setting forth standards for the protection of roadless areas that has the effect of amending local forest plans is fully consistent with NFMA's procedures. Just as local forest planning must incorporate the effect of other national-level decisions, e.g., congressional wilderness designation, Forest Service Manual and Handbook directives, and national monument designation, so, too, local planning has to accommodate national level policy decisions regarding road building and protection of roadless areas. Unless national circumstances change, e.g., road maintenance backlog is eliminated and social preferences for protecting backcounty wildlands are reversed, local forest planning is not the appropriate venue to revisit national roadless policies.

On the other hand, local forest planning can more precisely determine roadless area boundaries and develop site-specific resource prescriptions within the constraints of national roadless area policy.

Working Together. What is the best way for the Forest Service to work with the variety of States, tribes, local communities, other organizations, and individuals in a collaborative manner to ensure that concerns about roadless values are heard and addressed through a fair and open process?

It is incumbent upon the Forest Service to match the public involvement process to the scope of the issues. Where issues of national import, such as the conservation of wild areas, are on the table, the public involvement process must be national and open to all citizens. Where the issues are primarily of local concern, such as the availability of firewood, then the public involvement process is best targeted to local interests.

The roadless rule's promulgation clearly satisfied any rational test for sufficient opportunity for public involvement. The roadless rule garnered more comment than any other Forest Service decision in history. The combination of over 600 local public meetings combined with national media exposure ensured that anyone with an interest in roadless area protection would have an opportunity to learn about the Forest Service's proposal and comment upon it. That over one million people chose to do so is testimony to the outreach effort.

The interest groups who now object to the adequacy of the public comment process share one thing in common - they don't like the outcome so they are crying foul about the process. However, if the situation were reversed (as it soon may be!), those same interests won't be heard objecting to the inadequacy of a much less involved public process so long as they get the results they want.

Protecting Forests. How should inventoried roadless areas be managed to provide for healthy forests, including protection from severe wildfires and the buildup of hazardous fuels as well as to provide for the detection and prevention of insect and disease outbreaks?

Roadless areas have prospered without roads for millenia. There is no evidence that roads are necessary to ensure their continued health. The Forest Service does almost all of its insect and disease surveys aerially; thus roads are quite unnecessary for that purpose. So-called "severe" wildfires are generally quite natural stand-replacing fire events that have been occurring in our forests for thousands of years. Forest types in most roadless areas have not been adversely affected by fire suppression during the last fifty years. These forests do not burn frequently and when they do burn usually do so in stand-replacing fires. Thus there is no ecological justification for road construction or silvicultural activities in these forest types.

Protecting Communities, Homes, and Property. How should communities and private property near inventoried roadless areas be protected from the risks associated with natural events, such as major wildfires that may occur on adjacent federal lands?

The Forest Service, working in concert with other fire fighting organizations, should first determine where such communities and property exist. Without such an inventory it is difficult to determine appropriate strategies and attendant costs. However, as a general rule, Forest Service research has shown that private residences and communities only gain protection from wildfires (whether emanating from roadless areas or otherwise) by managing the immediate vegetation within several hundred feet of structures. Community-threatening fires can occur regardless of the silvicultural practices employed. In other words, thinning and brush removal does nothing to stop a stand-replacing fire once it gets going. Whether that fire ends up burning private structures depends upon the fuels management immediately adjacent to the structure. The Forest Service and others also need to sort out questions of who ought to be protecting structures and areas immediately adjacent to them, and who ought to pay for such protection.

Protecting Access to Property. What is the best way to implement the laws that ensure States, tribes, organizations, and private citizens have reasonable access to property they own within inventoried roadless areas?

The roadless rule guarantees the right of access under existing law. Just follow it.

Describing Values. What are the characteristics, environmental values, social and economic considerations, and other factors the Forest Service should consider as it evaluates inventoried roadless areas?

The Forest Service should not evaluate roadless areas separate from its regular, on-going natural resource inventories and assessments. The time to consider the unique characteristics of a roadless area in decisionmaking is when the Forest Service proposes an action that may affect a roadless area. Until that time, any evaluation of roadless areas is purely academic and of no utility to land managers or the public.

Describing Activities. Are there specific activities that should be expressly prohibited or expressly allowed for inventoried roadless areas through Forest Plan revisions or amendments?

Forest plans should address those activities not already regulated by the existing roadless rule. These include off-road vehicle and other recreational uses, wildfire for resource benefits, prescribed burning, wildlife habitat improvement, noxious weed control, and the like. Roadbuilding and timber harvesting are sufficiently addressed by the existing rule.

Designating Areas. Should inventoried roadless areas selected for future roadless protection through the local forest plan revision process be proposed to Congress for wilderness designation, or should they be maintained under a specific designation for roadless area management under the forest plan?

The plan revision process is not the appropriate venue to decide issues of national policy, such as the disposition of America's last unprotected wilderness frontier. Forest planning has failed miserably in every effort to resolve issues of regional or national significance; it is even questionable whether forest planning could be called a success for issues of only local interest.

Competing Values and Limited Resources. How can the Forest Service work effectively with individuals and groups with strongly competing views, values, and beliefs in evaluating and managing public lands and resources, recognizing that the agency can not meet all of the desires of all of the parties?

The Forest Service must better understand political, management, and leadership issues of working "effectively with individuals and groups with strongly competing views, values and beliefs." There is little evidence that that agency has given much thought to these complexities, hence most agency engagement tends away from collaboration and engagement and toward older forms of command and control behavior - often thinly camouflaged with language hinting at collaboration and positive interaction in search of public interest. The Forest Service must also put aside its own vested self-interest if it is to have any chance at working effectively with all parties.

===============================================

Reminder: If you are a government employee, please remember that your response to this and other E-Activists should be done on your own time, not on government time or using government equipment.

As always, please pass this action alert on to your friends and colleagues. Thank you very much!

==============================================
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Another Sample Letter 30.Aug.2001 20:51

waluta

USDA Forest Service
Atention: Roadless ANPR Comments
P.O. Box 221090
Salt Lake City, Utah 84122

To whom it may concern:

I am writing to protest the abrogation of 1.6 million comments pertaining to the Roadless Policy. How many people do you need before you get the picture? To throw out the roadless policy is to say that there is no democratic procedure that affects the Forest Service.

Further, to frame the "new questions" in such a skewed manner is to make the intent of this process transparent to those who support the roadless policy. It fosters disdain for the process, and further erodes democratic participation.

The roadless policy rule, as originally formulated and implemented by President Clinton should be kept as is. There should be no timber harvest in roadless areas. To harvest timber in the face of global warming is collective suicide. There should be no road building in roadless areas. All national forest should be included within the rule, including the Tongoss, with no phase-in periods.

Please stop this farce immediately. You are losing face as a credible institution.

Sincerely,