Rulemaking:

Notice of intent to prepare an environmental impact statement on National Forest System roadless areas, Federal Register, October 19, 1999, pages 56306-56407.

Stated Purpose:

As the first step in a process "to propose the protection of remaining roadless areas within the National Forest System, the agency requests comments "on the scope of the analysis that should be conducted, [and] on the identification of alternatives to the proposal. . ."

Summary of RSP Comment:

Historically, much of the debate over national forest management has been caused by blanket policies that may have made sense in some, but not all, forests. The Forest Service's fire suppression policy was one such blanket policy. The agency's massive switch from selection cutting in the 1940s and 1950s to clearcutting in the 1960s and 1970s was another such policy.

A blanket roadless area policy, as envisioned in the Forest Service's notice of intent to prepare an environmental impact statement (EIS), is liable to create as much ecological havoc as the fire suppression and clearcutting policies. Moreover, such a blanket policy may be the wrong direction to go if the real problem is a set of incentives that reward forest managers for overbuilding roads and losing money on timber sales.

The Forest Service's EIS on roadless areas should consider the following questions:

• Will a prohibition on roads increase the cost of or prevent ecological restoration, fire prevention, fire suppression, or any other important task on of any of the roadless lands?
• Will a prohibition on commercial timber cutting prevent or increase the cost of restoring and managing any of the roadless areas?
• Will a prohibition on other activities prevent or increase the cost of restoring and managing any of the roadless areas?
• Can the environmental objectives of a roadless area policy be equaled or exceeded at a lower cost by changing the incentives that influence the extent and type of road construction, timber sale design, and other forest practices?

The environmental impact statement should also include alternatives that focus on