September 2, 2003

Public Interest Comment on the Application of the Roadless Rule to the Tongass and the Chugach National Forests

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Advanced Notice of Proposed Rulemaking soliciting comments on whether the Tongass and the Chugach National Forests should be permanently exempted from the roadless rule and Notice of Proposed Rulemaking to exempt the Tongass National Forest from the roadless rule until the USDA promulgates a revised final roadless rule.

Stated Purpose:

To solicit comments on the applicability of the roadless rule to the Tongass and the Chugach National Forests and to solicit comments on exempting the Tongass from the roadless rule until the roadless rule is finalized.

Summary of RSP Comment:

The Forest Service is correct to evaluate the appropriateness of a blanket ban on roads in the Tongass and Chugach National Forests.

Forest Service officials, both in Washington D.C. and in the various regional and district offices face some difficult management challenges. Millions of acres of forestlands are not healthy, and forest managers will need to work hard to improve forest ecosystem health. Furthermore, decisions about forest management have a large impact on the communities in and near forests. Identifying management plans that maximize environmental, social, and economic benefits will require in-depth, forest specific analyses.

The documents and analyses used to support the 2001 roadless rule provided little evidence that the rule would actually improve the ecological health of the Tongass or the Chugach. They did not appear to recognize that roads are sometimes necessary to maintain forest health. Instead of a blanket ban, the Forest Service should permit (and even encourage) low-impact, temporary roads (that would be closed and restored to a natural condition after use) to manage forest health and conduct ecosystem restoration activities. Such alternatives were not considered in the Forest Service proposals but would likely prove better at protecting the ecosystems of the Tongass and Chugach.

For these reasons, the roadless rule should not be applied to the Tongass or the Chugach and the Chugach should be exempted from the rule until the Forest Service promulgates a revised final rule. This will give the Forest Service the opportunity to examine not only the environmental impacts of different plans on these forests, but the impacts on the communities in and around them.