Incorrect Road Data Presented to Flathead NF Collaborative

Dear Folks and Flathead National Forest and Meridian Institute;

You have presented inaccurate and misleading road data to the Flathead Forest Plan revision collaborative. We ask that you make the following corrections and insure it is brought to the attention of the entire collaborative and other public participants.

We dowloaded the attached document from the Meridian web site and have attached it for your convenience; “Access Information for Desired Condition Discussion.”

1. On page 5, this Access Information states “A total of about 887 miles of road have been decommissioned” since 1995.

This is not true. Some 130 miles of those roads have not yet been decommissioned and the majority of those have languished on the landscape since 1996.

An example is the 72 miles of road never decommissioned though authorized under the 1996 Crane Mountain Salvage timber sale.

This is important because the Access Information continues on page 7 to claim “the amount of decommissioning each year has decreased as the backlog of decommissioning is reduced and the A19 commitments under project level planning have been largely accomplished” – which is also not true.

The above statement does not fairly or accurately explain why the amount of annual road decommissioning has decreased from an average of 43 miles/year from 2006-2010 to just 4 miles in 2013 – when there are some 130 miles of “shovel-ready” road decommissioning NEPA decisions sitting on the shelf collecting dust.

If this is due to a lack of funds, the Access Information should make that clear. Instead, the Access Information essentially states the Flathead is already at the one-yard line, a touchdown is imminent, and all is fine concerning road decommissioning.

The Access Information needs to make clear that the timber sales which authorized the road decommissioning did not raise enough money to pay for the decommissioning, nor has the Flathead secured enough funding elsewhere to accomplish 15% (that’s one out of seven) of the road mileage it has already decided is necessary to adequately protect fish, wildlife and other resources.

2. The remaining section of the Access Information dealing with road maintenance and budgets is equally misleading and remiss:

The Flathead’s 2004 Analysis of the Management Situation clearly indicated the Flathead receives less than one-sixth of the budget needed to maintain its road system to applicable standards for the protection of water quality, fish, wildlife and human safety. See page 4-2 of this 2004 document at: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5432382.pdf

The attached Access Information at 7, however, presents a table that makes it look like a budget of as little as $1.3 million will adequately maintain 99% of passenger car roads and does not adequately summarize the environmental damage that occurs when roads are not maintained up to standards, including closed roads in Maintenance Level 1.

While the Access Information makes it clear that road management budgets continue to decrease, it does not – but must – contain a succinct summary of what budget the Flathead needs to meet all applicable maintenance standards and what budget it can reasonably expect to receive in coming years (as did the 2004 Analysis).

3. Finally, the Access Information does not provide the summary of road maintenance and road decommissioning costs necessary for the public to determine what mix of roads to retain on the Flathead and which to remove – nor does it provide the summary conclusion that it is cheaper to decommission a road than it is to maintain it with the required Best Management Practices. This is a conclusion announced by the Flathead in a 11/16/98 press release and subsequent 11/20/98 Missoulian news article. This conclusion was most recently confirmed in the Flathead’s 2/14/14 proposed Chilly James Restoration Project.

We ask that you make the above corrections to the Access Information and resubmit it to the collaborative with an announcement of the changes that have been made. And let’s be clear we are not suggesting a more complex presentation of the data. We find you must present it in a more accurate and summary manner in order for the public to grasp the relationship between roads, road funding, resource protection, and fiscal reality. As it stands now, the Access Information is incorrect and misleading.

Please respond and indicate what you intend to do about this.

Thank you,

Keith Hammer – Chair
Swan View Coalition