July 17, 2000

Public Interest Comment on the Forest Service Roadless Area Proposal

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Roadless Area Conservation Draft Environmental Impact Statement 

Stated Purpose:

"Provide appropriate long-term protection for most or all . . . currently inventoried 'roadless' areas, and to determine whether such protection is warranted for any smaller 'roadless' areas not yet inventoried."

Summary of RSP Comment:

The draft environmental impact statement for roadless area conservation is deficient in several respects. It fails to show that a blanket, nationwide prescription is needed for roadless lands. It provides little data and what data it does provide indicate that a blanket, no-roads rule will cost more than it will benefit in at least some roadless areas. And it fails to consider important alternatives, including alternatives built around incentives rather than proscriptions and alternatives that would allow temporary, low-impact roads in roadless areas when needed for forest health or ecosystem restoration.

Reflecting these deficiencies, the proposed rule will impose unnecessary economic and environmental costs on the national forests. The economic cost will be high because a ban on roads will increase the cost of improving forest health or restoring ecosystems in some roadless areas. The environmental cost will be high because, without such improvements, many roadless area ecosystems will continue to deteriorate and may even suffer unnaturally catastrophic fires and other ecological problems.

The roadless area rulemaking makes no attempt to identify the source of past mistakes, which include poor incentives on the part of local forest managers. A roadless area rule is not the best way to prevent future errors. Instead, what is needed is a major reform of the Forest Service?s budgetary process. Such a reform would improve management and reduce environmental and economic costs on both roadless and roaded lands.

Short of such a major reform, the Forest Service should consider an alternative that would ban permanent roads but allow temporary, low-impact roads in certain areas for forest health or ecosystem restoration. This would eliminate most of the objections to the proposed rule while retaining most, if not all, of the benefits.