John T. Nicoles, Chair
Northern California Society of American Foresters
732 Santa Ray Avenue
Oakland, CA 94610
(510) 834 8953
(510) 465 5444 (FAX)
jnicoles@jps.net

November 29, 1999

USDA Forest Service-CAET
Attention: Roadless Area Notice of Intent
P.O. Box 221090
Salt Lake City, UT 84122

Dear Project Team Leader:

This letter responds to the Notice of Intent published in the Federal Register on October 19, 1999, pages 56306 and 56307 (FR Doc. 99-273000). Based on the alternative actions described therein, the Northern California Society of American Foresters (NorCal SAF) endorses the no action alternative. Our strong preference, however, would be for the USDA Forest Service to reverse its decision to embark on the ill-conceived and ill-advised proposed roadless area analysis.

As participants in the seven-year-old ongoing process to address the habitat needs of California spotted owls and related issues in the Sierra Nevada, NorCal SAF is keenly aware of the major problems inherent in attempts to use programmatic applications of the National Environmental Policy Act (NEPA) to resolve complex forest planning issues. By encompassing a nationwide study area and attempting to usurp the purview of the Congress in establishing wilderness areas, the costs entailed in the proposed use of NEPA will in all likelihood exceed the combined costs to prepare the California Spotted Owl (CASPO) environmental documents and conduct the Sierra Nevada Conservation Framework (SNCF).

Although the SNCF process has been costly and cumbersome, it has resulted in a significant, yet fragile, level of trust among key stakeholders including natural resource users, environmentalists, resource professionals, and Forest Service staff. This trust is based on many hard-fought compromises concerning management of some of the very areas to be addressed by the proposed action. By unilaterally reallocating several million affected acres to some undefined class of “protection”, the proposed Washington-based, top-down action will seriously undermine the accomplishments of the local stakeholders and the trust they share. Based on the many lessons apparent from similar recent conflicts throughout the West, the Washington Office of the Forest Service should acknowledge that, while these lands are national forests, decisions determining their fate must be locally-based. To presume otherwise is imperious folly.

The most pressing resource management problem in California national forests is the need to reduce fuel loads and risks of catastrophic wildfires. Roadless area boundaries are not respected by wildfires, yet roads are perhaps the most important asset at the firefighter’s disposal. In the past few months, more than $70 million was spent with only limited success attempting to suppress the Megram Complex in northwestern California. This amount represents a large share of the annual budget for managing the national forests in Region 5. The fact that much of the burned area is roadless did not appreciably affect the need to contain this fire complex, but it did significantly limit opportunities to contain it. For there to be any hope of avoiding similar catastrophes in the future, the Forest Service’s commitment to an aggressive program of fuel treatment in California must be substantially increased, and the need for new roads to implement this program must be carefully considered. If the proposed “protection” of roadless areas in any way limits implementation of fuel treatments on these lands, the public will have been cruelly deceived by the use of this term.

All California lands addressed by the proposed action have been designated for various management emphases through exhaustive land and resource management planning. We recognize that some of the roadless areas designated for intensive management in national forest plans adopted several years ago are unlikely to have roads constructed in them in the foreseeable future, and their management emphasis may eventually need to be revised to reflect changed conditions. All such national forest plans, however, are scheduled to be updated within the next decade. Considering the constraints on new road construction imposed by overlapping environmental laws and regulations, not to mention preservationist opposition, there is virtually no chance that significant road construction will occur in these areas under the current plans. The proposed action is unnecessary and would greatly undermine the normal national forest planning process.

In our February 1998 comment on the temporary suspension of road construction in roadless areas, we decried the disingenuous linkage of roadless area and road system management policies. Using the Forest Service’s poor record for road maintenance to justify unilateral reallocation of roadless areas to the proposed “protection” designation is an insult to professional resource managers. Resource managers know that forest roads built to modern construction standards are not to be compared to legacy roads with regard to the water-quality hazards they pose. Moreover, the amount of new road construction in California national forests has been negligible throughout the 1990s.

Please do not repeat the Forest Service’s recurring mistake of presuming that the NEPA process offers a quick fix to complex land-use issues. We cannot afford to abandon the vast resources at stake for years on end while the agency’s analysts churn out their volumes and its leaders avoid making decisions.

Sincerely,

John T. Nicoles, Chair
Northern California Society of American Foresters

About the Society

The Society of American Foresters, with about 18,000 members, is the national organization that represents all segments of the forestry profession in the United States. It includes public and private practitioners, researchers, administrators, educators, and forestry students. The Society was established in 1900 by Gifford Pinchot and six other pioneer foresters.

The mission of the Society of American Foresters is to advance the science, education, technology, and practice of forestry; to enhance the competency of its members; to establish professional excellence; and to use the knowledge, skills, and conservation ethic of the profession to ensure the continued health and use of forest ecosystems and the present and future availability of forest resources to benefit society.

The Society is the accreditation authority for professional forestry education in the United States.The Society publishes the Journal of Forestry; the quarterlies Forest Science, Southern Journal ofApplied Forestry, Northern Journal of Applied Forestry, and Western Journal of AppliedForestry; The Forestry Source and the annual Proceedings of the Society of American Foresters national convention.