Here is what I came up with, I’d be interested in what everyone thinks., so I can add or take out stuff before I submit. Feel free to use anything in yours.
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I worked directly, hands-on with the Colorado Roadless Rule for over six years, through Democrat and Republican State and Federal Administrations, and so the following comments are the voice of experience:
- It makes sense to have a public process to change the Rule rather than remove it. What happened in Alaska? The next Administration just put it back. For the good of the public, the employees, and the taxpayers, it makes sense to come to a stable solution. That would require a public and transparent process. We can assume it would be litigated but that’s OK. Colorado and Idaho were litigated. Also I would argue for sticking to a timeframe, and not letting it get away from you in pursuit of agreements that might never happen.
- Any other alternatives should be based on specific needs for change.
- The first step should be to fix all the maps in a common-sense way. For example, in Colorado we found areas could be mapped to the nearest road or ridgetop, making any management easier.
- The second step is removing roaded areas from the roadless inventory. The 2001 Rule handled this by calling them “substantially altered” and having different requirements within the Rule. Just take them out. In Colorado we found “real unroaded” acres we could add back in. This also works and could be part of negotiation.
- The third step would be a forest- by- forest identification of the need for change, including a public process for comments. The WO could develop a template to collect the information such that all the forest would have to do is prepare a forest specific presentation and provide the link to post comments. It would be cool if the comments could be linked to a map, such that people could also look at the map and see what comments are associated with it.
- The fourth step would be for OGC and DOJ attorneys to do a “need for change” highlighting parts of the 2001, Colorado and Idaho that have led to legal difficulties, and provide recommendations for clarifications.
- The fifth step would be to round up the national groups – I have mixed feelings about a FACA committee to give advice about general fixes for things like mechanical fuel treatments and other topics that make sense to be approached nationally. Perhaps it would be better for an NGO to convene a series of meetings with a workgroup of diverse interests, with tentative recommendations and opportunity for public comment on their recommendations at each stage. The problem with FACA committees is that by size, they can’t include the diversity of perspectives of stakeholder groups. For example, if there’s one FACA position for outfitters, it seems likely that holders of jeep or OHV permits might think differently than whitewater permittees. I’ll also add that some members of the RACNAC, (the previous Roadless Area FACA committee) did not live up to our expectations for contributing to the discussion.
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For TSW Readers: Folks were chosen for the RACNAC for political reasons, like maybe they represented important groups, I guess. At the Salt Lake RACNAC meeting, the Colorado folks were sitting behind one member of the RACNAC who was looking at photos of his dog on his laptop and clearly not paying attention to the presentation. But on the positive side, at another meeting in DC, an NGO person spoke who knew not very much, and had apparently been briefed on the plane as to what to say. FS people had to be polite, but other RACNAC people could and did make the point “we don’t need to be lectured, thank you!” The leadership of RACNAC was outstanding- Ray Vaughan and Dale Harris- but good policy shouldn’t depend on a few key people with relational superpowers, IMHO.
If you’re not familiar with that part of history, this is from a RACNAC meeting on Idaho, note the temp road recommendation, also how small the RACNAC was.
I always thought the preamble to the 2001 Roadless Rule was a good starting place to affirm that many of us can agree to why unroaded areas are desirable. Perhaps your comments could to do the same? Point out that people can agree to some amount of the landscape be unroaded?
I think there were eight different topic areas in the preamble that people could rally around (for example – many communities in Utah have their municipal water source on National Forest land…developing such an unroaded area with roads would raise the risk of water quality for human consumption).
Thanks, Tony! I remember helping write an old growth letter for an NGO.. they got a call from another NGO saying we didn’t say enough nice things about old growth. So I had to write more stuff about “we love old growth values.” So I probably need to start with that..
I understand the municipal water source issues.. also in Colorado one of the issues was that we had dams that needed roads for maintenance, but unless there was an “immanent threat” of collapse, 2001 wouldn’t let them build a road to bring equipment in. In fact, we have an exception for “water conveyance structures:” in Colorado as well. That’s why I think the need for change needs to be focused on the local level. It depends on what the road is for, and what the environmental and safety and water supply issues are on that piece of ground.
I agree…local considerations are typically best for difficult land management decisions. However, when the topic is larger in scale than just the local consideration, this is when decision-making becomes complicated – addressing the larger scale topic while also attempting to respect the local nuances to that topic. Policy will never be able to account for all these local nuances, which is why critical thinking is a vital component to a decisionmaker’s effectiveness.
I agree, that’s why I think that “at least two scales” to look at the problem is important. Also having a process to go through when the general doesn’t fit the specific (corrections or changes). Idaho and Colorado both tackled fuel treatments differently and maybe there is value to a more general approach for the other states.
Sharon said:
“For the good of the public, the employees, and the taxpayers, it makes sense to come to a stable solution.”
Previous efforts to get rid of the roadless rule have failed. If the present effort is to succeed, it will be important for USDA to address, either in the draft EIS or some other publicly available document, how the present effort will avoid the previously encountered legal and political pitfalls. Otherwise, the public might reasonably conclude that this rescission effort is nothing more than a performative gesture. I agree that a better path toward achieving a sustainable solution would be to mend the rule rather than end it, and that the Colorado process is worth examining as a potential way forward.
Sharon, [you don’t have to post this if you think it disrespectful, dis-honest or will create discord in the ranks, just delete this part if you do post – although I can back everything up or I wouldn’t have sent to a federal agency]
I think your ideas and expertise on the subject of roadless, especially as relates to your work on the CO state rule, in moving forward, will be an asset to any comments provided in the aftermath of the current proposed rescission of the 2001 rule. Lay people such as myself can understand what you (and others on this site) are writing about.
Personally however, I am not a proponent of tweaking the 2001 rule. Deja vu! I base that on the majority of comments rec’d by USFS, to date, that mirror some of the exact smoke brought forth with “overwhelming public support” of the 1990’s media drive during the promulgation of the 2001 rule to begin with, to again retain the 2001 rule. Deja vu! Let’s confuse the publics like me one more time.
Originally my comment was going to be specific to, https://www.regulations.gov/document/FS-2025-0001-0001 and, contextually as it is worded. But, after being bombarded with “form” comments when we were attempting to find something like you would write (we checked out over 8000 as of 12SEP and found none), my mindset changed.
This documented pre-decisional history, https://www.regulations.gov/document/FS-2025-0001-0001/comment?filter=mfb-bdq7-d4rr , will likely add a bit of fuel to the ongoing fires as far as our (UT-CO-WY) local commenters experienced in R-2 and 4 during the promulgation of all the rules in the late 1990’s through early 2000’s, and the pre-decisional occurrences that took place beforehand. Thousands of pages of FOIA back then were a waste of everyone’s time and funds and hopefully won’t be necessary this second time around.
Cordially,
Randy, we with the Colorado Rule were faced with the same “overwhelming” form letter public support for not doing it.. for seven years. And I agree that the Federal Register comments should be easier to search. For one comment period I actually downloaded all of them and tried to filter out all form letters, but I wasn’t technically astute enough. Also thanks for sharing your comment letter. For people who remember, there are still bad memories of how the 2001 was done. Maybe you saw Rick Cables’ op-ed in the Grand Junction Sentinel?
Thank you Sharon, I had not seen the op-ed as it took some time rounding up all the FOIAs we had stashed for my comment that back-up Mr. Cables’ writing.
Rick Cables had the utmost respect of most every group and local government I worked with due his horse-sense. We felt sorry for the predicaments he had to mediate under arbitrary management protocols after roadless.
Especially appreciated was his presentation and paper as concerns the headwaters of the Colorado River System years ago; something that should be recalled as far as discussing landscape scale planning efforts by any proponent of tweaking the 2001 rule since the Upper States are in such a quandary today.
Before RF Cables entered R-2 we were requesting all the mapping as was suggested by Jim Lyons, whose request was shot down by certain FS administrators prior to the NOI OCT 1999 because the WO had “shaky data”.
Cheers,
Keep up the good works.