To:
USDA-Forest Service CAT
ATTN: Roadless ANPR Comments
P.O.B. 221090
Salt Lake City, UT 84122

Date: September 10, 2001

Please accept the following scoping comments from the Western Fire Ecology Center in response to the Roadless Area Conservation advance notice of proposed rulemaking. In brief, we wish to see all of our nation’s roadless areas permanently protected from commercial logging under any guise (e.g. timber sales or "stewardship" logging), roadbuilding, mining, grazing, and aggressive firefighting. We request that no exemptions or exclusions be created to undermine or weaken the Roadless Area Conservation Rule (RACR) approved by the Clinton Administration (e.g. logging or roadbuilding for "forest health restoration" or "fire hazard reduction" activities). On the contrary, we desire to see the RACR strengthened to eliminate any and all loopholes permitting intensive management and/or commodity resource extraction in roadless areas.

Below we provide some general comments on the scientific basis for protecting roadless areas from intensive management and commodity extraction activities, followed by specific answers addressing the ten questions posed by the CAT. Most of our comments focus on fire/fuels management issues.

SCIENTIFIC BASIS FOR ROADLESS AREA PROTECTION

Over the last five years, Congress has spent over $57 million on scientific assessments for the Sierra Nevada Ecosystem Project (SNEP) and the Interior Columbia Basin Ecosystem Management Project (ICBEMP) . Both of these studies concluded that commercial logging was the primary reason for increased wildfire intensity and severity. Moreover, these studies revealed that no matter what logging system was used (e.g. thinning, salvaging, or clearcutting), watersheds that were roaded and logged experienced more rapid rates of fire spread, higher fire intensities, and greater fire severity than unlogged, roadless watersheds. Conversely, the SNEP and ICBEMP studies also revealed that roadless watersheds have the highest levels of ecological integrity and the greatest resiliency to wildland fires-precisely because they have experienced less road-building, less logging, and less-efficient firefighting. Claims that roadless areas are more prone to so-called "catastrophic wildfires" because they are unroaded/unlogged are simply ignoring the Forest Service’s own scientific research, and in our opinion, these unfounded claims are merely propaganda intended to serve the short-term economic interests of resource extraction industries, not the nation’s long-term interests in ecological integrity and sustainable economies.

The superb articles published in the Forest Service’s own Fire Management Today (Spring 2001, Volume 61, Number 2) documents that the best available science supports strong protection for roadless areas. For example, the article by DellaSala and Frost (2001) summarizes the findings of the scientific literature:

1) Timber management activities often increase fuel loads and reduce a forest’s resilience to fire.
2) Areas without roads have been less influenced by fire suppression than intensively managed lands.
3) Widespread road access associated with intensively managed lands raises the risk of human-caused ignitions.

These comments were made available to the USFS during the original RACR public comment process, so this should not be new information to the CAT. The evidence is fairly clear: roading, logging, grazing, mining, and firefighting are the sources of, not the solutions to, most "forest health" problems in America’s wildlands.

Question #1: What is the appropriate role of local forest planning as required by NFMA in evaluating protection and management of inventoried roadless areas?

The role of local Forests is NOT to determine "if" roadless areas should be protected, but how they should be protected. The reason the public demanded a national rule to conserve roadless areas was because local Forest Service officials were unwilling or unable to do this themselves. Once the national RACR is reaffirmed, this should provide the framework for local forest planning to determine the best means and methods for fully implementing the rule. For example, local Forests should determine which roads may need to be blocked, decommissioned, and/or obliterated. Also, boundaries for roadless areas can be located to include previously uninventoried and unroaded areas for protection.

Question #2: 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?

We believe that the RACR was developed through a fair and open process. The RACR generated more public comments than any other USFS decision in history, and every citizen had multiple opportunities to learn about the issues and voice their opinions. The Bush Administration’s effort to undermine or reverse the RACR is not motivated by legal, social, or ecological concerns, but rather, by political concerns to allow unfettered access to public lands by private/corporate economic interests that contributed heavily to the Bush presidential campaign. We are very concerned that political manipulation will make this current effort to re-examine the RACR an unfair and closed-door process, and we feel that the USFS will pay a heavy price for the Administration’s cynical and opportunist attempt to thwart majority public opinion.

As a reminder, National Forests are owned by all U.S. citizens, and are held in trust for current and future generations. The opinions of local residents should not have any more or any less value than the opinions of citizens living long distances away from a given roadless area. In general, though, public input processes should conform to the scope of the management issues under review. Thus, where the issues are broad and long-term, for example, conservation of an endangered species or destruction of its habitat through resource extraction and other industrial development, then public involvement must be national in scope and open to all citizens. Where the issues are relatively narrow and short-term, for example, the routine maintenance of trails or availability of firewood, then public involvement can be more local and targeted to citizens living in closer proximity to a given roadless area.

Question #3: 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 survived and thrived for millenia without roads, logging, and/or intensive management. The majority of the best available scientific literature, including the agencies own research conducted in the SNEP and ICBEMP studies, reveals that roadless areas have the highest ecological integrity precisely because they have experienced less road-building, commercial logging, livestock grazing, and less effective fire suppression. On the other hand, areas with highest levels of road densities managed for commercial timber extraction and livestock grazing have the lowest ecological integrity--and the highest probability for severe wildfire events. Since the Forest Service has been dominated for most of its history by an industrial-agricultural paradigm that equates the concept of "management" with some kind of resource extraction or destructive development, we feel that roadless areas would best be protected from USFS management, not by management.

In terms of the goal of protecting roadless areas from severe fires, logging roads have a paradoxical effect: they are places where wildfires can be contained, but are also places where wildfires are often ignited. A significant portion of human-caused wildfires are, in fact, ignited alongside roads, and as a general rule, increased road access results in increased risk of human-caused wildfires. Thus, while to some extent roads may help to suppress wildfires, roads can also hinder the agency’s efforts to prevent wildfires. The link between arson fires and logging roads is particularly strong, and arson is the most difficult kind of human-caused wildfire to prevent. Unfortunately, forest arsonists are rarely captured or convicted, and the vast network of logging roads carved into the National Forests has greatly increased the burden on fire prevention and law enforcement patrols. The net effect is less protection of wildlands from severe fires due to the increase in number and frequency of human-caused ignitions, often during extreme fire danger situations.

In terms of fuels management, logging roads break up continuous fuel beds with wide swaths of non-combustible dirt and gravel; however, highly flammable vegetation (e.g. grass, brush, conifer saplings) often grows in the exposed, disturbed sites alongside roads. This accounts for many wildfires being easily ignited by the exhaust or cigarette butts tossed from passing motorists. More significantly, most National Forest roads travel through and to logged areas. Commercial logging produces large amounts of flammable dead surface fuels (e.g. "slash" and "cull" logs), followed by revegetation from grass and brush, or replanting with young conifer saplings. The best available scientific research has demonstrated that wildfires tend to spread more rapidly, with higher intensity and greater severity, when they burn through roaded and logged landscapes compared to unlogged roadless areas. Fires entering plantation zones and other intensively managed areas are prone to sudden "blow ups," creating major conflagrations such as occurred on the 1994 Tyee Fire in Washington State.

As noted above, logging roads are typically high risk/high hazard areas since they are sites of frequent human ignitions and dense flammable fuels. However, it is acknowledged that roads can, at times, help fire suppression efforts because they provide the cheapest, safest means of transporting large numbers of firefighters (although traffic accidents are a major source of serious injuries and fatalities on wildfires). Roads also provide access for heavy equipment such as bulldozers, water trucks, and fire engines. Roads also provide a ready-made fireline for backfire/burnout operations which, ironically, can increase the total amount of burned acreage. Indirect attack strategies automatically sacrifice acreage to the wildfire, especially if large backfires are ignited; thus, another paradox: wildfires often increase in size in the act of trying to contain and control them.

The USFS created standing crews of smokejumpers, hotshots, helitacks, and helirappellers for the purpose of initial and extended attack fire suppression in roadless areas. The speed, mobility, and versatility of aerial-based fire suppression forces are making them more attractive to fire managers. While it can cost thousands of tax dollars to purchase and maintain a fire engine, it can only be used efficiently by a small crew (approximately 3-5 workers) and its use is largely restricted to a single District on a single Forest. The same amount of money invested in aircraft and associated crews and equipment can be mobilized to protect whole Regions or can be dispatched nationally or internationally depending on the need, and can be more easily shared among other federal, state, and local fire protection agencies. Consequently, given modern technology and the huge number of helicopters and fixed-wing aircraft available for fire suppression duty, roads are not necessary in order to suppress fires.

Another paradox: applying effective fire suppression /exclusion results in an increase in fuel hazards and potential fire severity, and a decrease in biological diversity and ecological integrity. The forests most in need of vegetation and fuels treatments to reduce fire hazards, insect and disease outbreaks, and restore biological diversity are not roadless areas, but rather, areas that have already been roaded and logged. Building roads allegedly for the purpose of "forest health restoration" or "fire hazard reduction" only makes sense if mechanical thinning treatments are being proposed. However, the use of mechanical thinning as a tool for fire hazard reduction is highly controversial, scientifically unsubstantiated, and fundamentally experimental in nature. Unfortunately, it appears that mechanical thinning is becoming yet another euphemism for industrial-scale commercial logging—one of the prime management activities that degrade ecosystems and cause forest health/fire hazard problems.

In some instances, it has been demonstrated that commercial thinning treatments intended to reduce fire hazard have actually had the opposite effect. Although gross tonnage of fuels may have been reduced, there has been a net increase in hazardous fine fuels accumulating on the surface and available for burning—primarily logging debris or "slash." Also, changes in microclimate from tree removal serves to increase solar radiation and wind penetration, which in turn increases site flammability following thinning treatments. DellaSala and Frost document the best available science that determines that even when they are carefully conducted, mechanical thinning treatments can result in numerous adverse environmental impacts, including:

Soil damage through increased erosion, compaction, and loss of duff/litter layer (Harvey et al. 1994, Meurisse & Geist 1994).

Increased tree mortality of residual/retained trees due to pathogens and mechanical damage to boles and roots (Hagle & Schmitz 1993, Filip 1994).

Increased sediment and siltation that is harmful to fish habitat and other aquatic species (Beschta 1978, Grant & Wolff 1991).

Increased levels of fine fuels and short-term fire hazard (Fahnestock 1968, Weatherspoon 1996, Wilson & Dell 1971, Huff et al. 1995).

Dependence on roads, which result in numerous long-term adverse effects (Henjum et al. 1994, Megahan et al. 1994).

Reduced habitat quality for sensitive, rare, threatened and endangered species associated with cool, moist microsites or closed canopy forests (FEMAT 1993, Thomas et al. 1993).

Given the potential for serious adverse impacts from mechanical thinning treatments in addition to the adverse effects of roads, such treatments should be restricted to previously roaded areas that are also the sites most degraded and in need of restoration. It just makes no sense to build roads to facilitate road-dependent fuels treatments in the name of "conservation," "restoration," or "protection."

The most effective fuels treatment that would both protect roadless areas from future severe fires, insect and disease outbreaks while at the same time it restores areas altered by past fire exclusion would be a program of prescribed burning and wildland fire use. Fire reintroduction has been the longstanding call among scientists, ecologists, and conservationists. It is the most ecologically beneficial and least economically costly management treatment to manage roadless areas. It is fully in accordance with the letter and spirit of the National Fire Plan, the USFS Cohesive Strategy, the 1995 Federal Wildland Fire Management Policy, and the 2001 Review and Update of the Federal Wildland Fire Management Policy. In most cases on most roadless areas, careful fire management planning can devise the prescriptions necessary to apply both prescribed and wildland fire use for all needed fuels treatments. In contrast to road-dependent mechanical thinning treatments, roads are unnecessary for prescribed burning or wildland fire use. The economics of fire-based fuels management would thus be even more attractive since the costs of constructing and maintaining roads are moot. To burn or not to burn is really not an issue dependent on more research or policy reform—it is mainly a matter of Forest Service managers harnessing the will to make the right decisions regarding wildland fire use and prescribed burning.

Question #4: 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 challenge of protecting homes, communities, and private property from severe wildland fires is one of the most critical issues facing fire managers today; yet, this is one of the easiest issues to solve, too. The best available science on home ignitability factors reveals that the most effective and efficient means of fireproofing homes is to design and construct homes with non-flammable or low-flammable materials, and to manage the vegetation immediately surrounding structures. This zone of vegetation management extends only a couple hundred feet around structures, not hundreds or thousands of feet away. Reducing fuels on lands outside of this area is both ineffective and inefficient in protecting homes, according to Forest Service research. In all but the rarest cases, most of the land needing fuels management for the purpose of home protection is privately owned, and is not located in publicly-owned roadless areas. Hence, protection of homes and private property is largely the right and responsibility of private citizens. It should not be a burden placed upon the public at large to degrade public assets in order to protect private property—especially when such measures will not work.

The best way to protect homes is to educate homeowners and communities about the risks of building in fire-prone locations with flammable materials, and failing to manage their own flammable vegetation. Once homes and communities are effectively fireproofed, then the potential threat of damage from wildland fire is qualitatively reduced, and the opportunities to apply prescribed fire or monitor wildland fire in areas adjacent to communities is qualitatively increased. Unfortunately, agency decisionmakers and elected officials seem determined to use the threat of burning homes more as an opportunistic scare tactic to convince the public on the "need" for more road-construction, commercial logging, livestock grazing, and fire suppression.

Question #5: 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?

It is not clear whether or not the alleged lack of access to private in-holdings is a problem of such a scale that it should warrant a massive rehaul of the RACR. It is our understanding that the RACR guarantees the right of access to private property under existing laws. Consequently, there needs to be no changes in the RACR based on this issue.

Question #6: 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 USFS should evaluate roadless areas for the prime characteristics and environmental values of ecological integrity, biological diversity, and habitat quality. The social and economic considerations should include recreational opportunity, sources of clean water and air, and unique quality of "wildness." Most of these above values do not have monetary or market values that are easy to define or attribute. Given the longstanding institutional biases of the USFS towards commodity resource extraction, we insist that the special non-market social and economic values of roadless areas be given extra emphasis in the analysis, and that the environmental values of roadless areas be given primacy in any comparison of values. This is fully in accordance with the majority public opinion who desire to see roadless areas permanently protected for both current and future generations, not plundered for the short-term private profits of a few.

Question #7: Are there specific activities that should be expressly prohibited or expressly allowed for inventoried roadless areas through Forest Plan revisions or amendments?

Forest Plan revisions and amendments should address the issues that were not adequately addressed in the RACR. The list of activities that should be allowed in roadless areas include: wilderness designation; wildland fire use for resource benefits; landscape-scale prescribed burning; invasive weeds control; and roadless area expansion through road obliteration. The list of activities that should be prohibited in roadless areas include: off-road vehicle use, mechanized fire suppression (e.g. bulldozers); timber extraction under any guise (i.e. eliminate the loophole for logging alleged as "fuels reduction"), and other forms of intensive management.

Question #8: Should inventoried roadless areas selected for future roadless protection through the local Forest Plan Revision be proposed to Congress for wilderness designation, or should they be maintained under a specific designation for roadless area management under the Forest Plan?

In general, local Forests have failed miserably to designate enough wilderness areas through the development of Forest Plans, Amendments, and Revisions. It has mainly been through Congressional action that existing wilderness areas have been designated. It is desireable for most roadless areas to become officially designated wilderness areas, but it is doubtful that local agency managers will have the wisdom or willpower to take such action on their own. By default, we argue for the greatest amount of protection from intensive management and development in all roadless areas so that they will effectively be managed like wilderness until they can be formally designated as wilderness.

Question #9: 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 agency must first begin by recognizing its own vested interests in certain kinds of organizational systems, management structures, and management methods. The agency is not a neutral arbiter amongst competing interests, but rather, has its own interests that are too often allied with private industrial users at the expense of all other citizens, interests and values. To date, despite glowing rhetoric about the need for greater collaboration and partnerships in planning and decision-making, the agency’s actions betray a continued interest in asserting technocratic power and control over the land and people. The RACR is not the proper venue for managers to relearn how to "care for the land and serve people." The problems of Forest Service management extends far beyond the roadless area issue. We recommend that as a first step all Forest Service employees should read Dr. Paul Hirt’s excellent critique of Forest Service management, "A Conspiracy of Optimism."

Question #10: Are there any additional comments?

We would like to make some site-specific recommendations for an inventoried roadless area that we have tried to the past ten years to get protected due to their high fire ecology research and educational values: the Cornpatch Inventoried Roadless Area located on the Willamette National Forest. Local citizens, scientists, and conservationists from across the nation have written literally thousands of letters to the Forest Service urging permanent protection of the Cornpatch and its designation as the nation’s first Fire Process Research Natural Area, but to no avail. Instead, the Willamette has tried to propose several "salvage" clearcut timber sales and old-growth "green" clearcut timber sales within the roadless area and proposed RNA. It has been only through national directives such as the Glickman directive during the Salvage Logging Rider, and the RACR, that the Cornpatch has been spared destruction by local Forest managers. In a sense, the case of the Willamette’s inability to provide protection to the Cornpatch Inventoried Roadless Area is an excellent example of the need for a national rule on roadless area conservation. Only a national rule will force the hands of local managers who continually defy the will of the citizenry and make decisions diametrically opposed to the best available science and highest conservationist ethics. We urge that the Cornpatch Inventoried Roadless Area be specifically mentioned as a candidate for permanent protection under the RACR.

CONCLUSION

In sum, we view this whole exercise of revisiting the RACR to be an illegitimate waste of taxpayer resources. The American people have already clearly stated their views in over 1.6 million letters and 600 public hearings. We believe that the critics of the original RACR were less concerned about the mechanics of the public process than they were with the outcome of the rule-making process. We are confident that the courts will eventually declare that the rule-making process was fully legal and legitimate. However, if the RACR is changed in significant ways that eliminates or undermines the original protections for roadless areas, this may yield the Bush Administration a short-term political benefit (i.e. it may pay back some personal debts to corporate donors who funded the Bush presidential campaign), but it will come at the long-term cost of further eroding the credibility and integrity of the USFS in the eyes of the American people. We urge responsible employees in the Forest Service not to aid and abet the Bush Administration’s blatantly opportunistic attempt to ignore the best available science and majority public opinion which together have long argued for strong protection for roadless areas. We urge that the RACR be reaffirmed and even strengthened to eliminate all opportunities for road-building, commercial logging, livestock grazing, or mining under any excuse or rationale, and provide permanent protection from future intensive management or resource extraction.

Sincerely,


Timothy Ingalsbee, Ph.D.
Director, Western Fire Ecology Center