USFS Roadless state petitions

USFS Roadless Petition

From: "Lance Christie"
Subject: USFS roadless state petitions

September 3, 2004

Content Analysis Team
Attn: Roadless State Petitions
USDA Forest Service
P.O. Box 221090
Salt Lake City, UT 84122


RE: Proposed rule allowing governors of the states to petition to determine which roadless areas on the national forests in a state should or should not receive the protection of the USFS "roadless rule" instituted during the Clinton administration:

I oppose this rule. It abrogates the statuatory responsibilities of the Department of Agriculture's United States Forest Service established in the Forest and Rangeland Renewable Resource Planning Act of 1974, as amended.

In 2000, "Final Rule: National Forest System Land and Resource Management Planning. 47 Federal Register 1217-1220" the recommendations of the USFS Committee of Scientists that "ecological sustainability" be the first priority when producing plans for management of the National Forests and Grasslands was codified. These regulations state that the "first priority for stewardship of the national forests and grasslands is to maintain or restore ecological sustainability."

Six months after this rule was adopted, the Bush Administration determined that the Forest Service was not "sufficiently prepared to implement the new planning rule." The administration suspended the requirement that ecological sustainability be the first multiple use priority in forest management plan revisions while it conducts a rule revision process to define how ecological sustainability would be ascertained in forest planning.

In the meanwhile, conservation biologists have developed ecological system plans for the Sierra Madres in Mexico, the Arizona "Sky Islands" ecoregion, the Grand Canyon ecoregion, the New Mexico Highlands and Southern Rockies ecoregions, and most recently the "Heart of the West" ecological systems plan for the "Yellowstone to Yukon" northern Rockies ecoregion. I am administrator of the High Colorado Plateaus Ecological Systems Plan project which is underway. When complete, we will have a "blueprint," based in sound science, for how to conserve and restore "ecological sustainability" in all the ecoregions of the mountain west from Alaska into Mexico, including all national forests located between the Sierras to the west and the Great Plains to the east. In our current project grant funding proposals, the majority of effort we anticipate is in implementing this blueprint through intensive collaboration with and support of federal, state, and local land-planning entities. We look forward to working with the USFS, and believe we will deliver the means for the USFS to implement the planning rule concerning ecological sustainability at no cost to the U.S. Treasury.

What all prior ecological systems plans have found is that the key to ecological sustainability on the national forests is the preservation or restoration of "core habitat areas" linked by dispersion corridors. For most species, roadlessness is the key to the viability of such core habitat areas and dispersion corridors. I believe this realization was the scientific basis for the imposition of the "roadless rule" by the Clinton administration, since it occurred contemporary with the recommendations of the USFS Committee of Scientists.

The Clinton "roadless rule" needs to be left in place, unaffected, until and unless ecological systems plans reveal that a given roadless area is not a critical core habitat or wildlife linkage. After our "Spine of the Continent" ecological systems plan implementation is well underway, and the various state administrations are informed of and involved in science-based ecological systems planning for the state's natural heritage ("biological capital"), then the governors of western states will be equipped to make collaborative decisions about what lands to leave (or make) roadless in the service of biological integrity, and which lands may be developed with roads for extraction of resources. At this time they are not so equipped, and abandoning federal agency responsibility for ecological integrity to state governor is not legally or ecologically appropriate.

Sincerely yours,
Richard Lance Christie

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