After yesterday I found this link to the public comments There were 106 K so perhaps it took a year to analyze them. I don’t know how many were form comments; usually roadless brings out quite a few of those. Which might not be helpful at discerning what the public thinks about reinstatement vs. Alternative 2. I doubt if many of the commenters, at least for the form comments, were even aware of alternative 2.
Here’s one example:
We need to protect our wild spaces more so now than ever. The importance of the Tongas National Forest and the people who call it home can not be understated. Enough of our world is “improved” upon already. We have options other than timber, and other areas to get timber. Preserve at least some of this world as it should be.
In reality, just as with Trump’s choice of removing the Roadless Rule, I think the real reason is that key groups wanted it. Which is fine, of course, but someone had to write a rationale for the rule text. I think some explanations are better than others. So let’s examine them.
(1) Adopting Alternative 1 also takes appropriate consideration of consultation with sovereign Tribal Nations, which uniformly and strongly supported Alternative 1.
That is cool that the Tribes all agreed “uniformly and strongly.”
(2) Although Alternative 2 serves many of the same values as Alternative 1, Alternative 2 would introduce potentially confusing changes both to the location of designated Alaska Roadless Areas and to the management prescriptions associated with certain management categories. Alternative 2 also lacks a history of implementation consistent with the 2001 Roadless Rule and the 2016 Forest Plan, potentially complicating implementation.
Doesn’t any new regulation “introduce potentially confusing changes”.. think 2012 Planning Rule, new oil and gas or grazing regulations? or Monumentizing? Don’t they also “lack a history of implementation”? But sticking to Roadless, how come Coloradans and Idahoans could handle these complexities but the Department thinks Alaskans can’t? Thumbs down on this one.
(3) The minor environmental advantages of Alternative 2 do not outweigh Alternative 1’s other advantages and those environmental benefits could be achieved under Alternative 1 through alternative planning and program mechanisms that provide greater flexibility for achieving program goals.
The Forest Service employs various planning and project-specific efforts to maintain and restore watersheds by strategically focusing investments on watershed improvement projects and conservation practices at the landscape and watershed scales. For example, watersheds have unique characteristics and can best be addressed through Forest Planning and site-specific planning.
This is an interesting argument.. “we don’t need to put this in a reg.. because protections on the other 110 K Unroaded Roadless acres can be handled during.. Forest and site-specific planning. Whoa. I thought. This argument is that watershed protection is best achieved through Forest Planning and site-specific planning. But then why do you need a Roadless Rule at all? This sounds like an argument for “no Rule.” For me, that’s a double thumbs down.
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What about renewable energy?
Now, one of the things that Colorado Roadless limited was “linear construction zones” for building pipelines, powerlines, etc. We had a fascinating time and a court case with the 2001 Rule talking about whether those are “roads” so in the CRR limited them. I think this is a nice wrap-up of what is allowed in roadless areas with regard to energy infrastructure in the response to comments.
As they say:
The 2001 Roadless Rule has and will continue to accommodate access for qualified mining, energy, and community infrastructure needs while also conserving the multiple ecologic, social, cultural, and economic values
supported by roadless areas on the forest….
The Federal Power Act (FPA) grants the Federal Energy Regulatory Commission (FERC) the authority to issue and administer licenses for hydropower projects. For projects located on NFS lands, section 4(e) of the FPA requires FERC to assure the project will not interfere or be inconsistent with the purpose for which the forest reservation was created or acquired. While section 4(e) of the FPA gives the Forest Service the authority to impose mandatory conditions in the FERC license to ensure the adequate protection and use of forest land and resources, these 4(e) conditions cannot usurp FERC’s role in deciding whether to license a hydropower facility. In short, if FERC decides that a road is necessary for facility development, the Forest Service cannot veto the project or road, but rather is limited to imposing reasonable terms and conditions necessary for the adequate protection and utilization of the forest. The 2001 Roadless Rule (at 36 CFR 294.12(b)(3) (2001)) provides that a road may be constructed or reconstructed in an IRA if ‘‘[a] road is needed pursuant to reserved or outstanding rights, or as provided for by statute or treaty.’’ The FPA is one such statute.
The 2001 Roadless Rule also does not prohibit the construction or maintenance of transmission lines. While new temporary or permanent roads are not permitted in IRAs, temporary linear construction zones can be authorized to facilitate the construction of transmission lines, along with other applicable exceptions set forth in the 2001 Roadless Rule. The courts have sustained that interpretation on more than one occasion. The USDA has acknowledged that the restriction on road construction, including the construction of access roads, may pose a challenge for transmission routes that cross IRAs, potentially increasing construction and maintenance costs.
However, based on analysis for previous transmission projects on the Tongass, roaded alternatives are not necessarily less expensive to construct and maintain than those relying on other means of access. Construction and
maintenance costs depend on terrain, distance to communities, and other factors. Helicopter access, temporary construction zones, and/or trails can also be used to provide access and may even be less expensive than the road construction and maintenance costs associated with permanent roads in remote areas. In addition, the rights-of-way granted in section 4407 of Public Law 109–59, as amended, also allows for specified roaded access in the forest for transmission lines and other utility systems.
I’m sure that there is other interesting stuff in the response to comments and other sections, so if you find something please put it in the comments below.
“The minor environmental advantages of Alternative 2 do not outweigh Alternative 1’s other advantages and those environmental benefits could be achieved under Alternative 1 through alternative planning and program mechanisms that provide greater flexibility for achieving program goals.” Or as you put it, “This argument is that watershed protection is best achieved through Forest Planning and site-specific planning.”
This should also mean that Alternative 1 was environmentally preferable. And it would line up with the current agency thinking that mandatory direction in forest plans (i.e. standards) are bad for the environment because they keep the Forest Service from having the “flexibility” to do good things for the environment. (Conveniently ignoring the fact that they also keep it from doing bad things.)
My point was that if you really think that environmental advantages can be achieved solely by forest planning, what is the point of having any acres in Roadless?
“those environmental benefits could be achieved under Alternative 1 through alternative planning and program mechanisms that provide greater flexibility for achieving program goals.”