Alternative 3 in Roadless DEIS: A Middle Path?

Here’s a link to the DEIS Basically, it  fixes maps, and takes out WUI.

Removing about ½ million acres of non-National Forest System lands from the national inventoried roadless area maps9. The Roadless Rule applies only to National Forest System lands (see also Potentially Affected Environment).

Curious about that? the footnote says:

There are 44.7 million acres of IRAs managed under 2001 Roadless Rule. Review of the geospatial data found that 44.3 million acres of these are on National Forest System lands, meaning about 0.4 million acres of lands have had land ownership change since the 2001 Roadless Rule or there may be vertical integration problems (mapping errors) between the inventoried roadless data and official land ownership boundary data.

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• Removing about 4 million acres of Congressionally designated areas, which have more restrictive and more permanent mandates than the Roadless Rule (see also Potentially Affected Environment).

Conceivably both of the above shouldn’t have been in there anyway.

• Removing 17.9 million acres which include 5.1 million acres within the wildland-urban interface and 6.3 million acres of roaded roadless and 4.7 million acres that are both within the wildland-urban interface and within 0.5 miles of existing roads. The remaining acreage was removed as the small, isolated areas did not meet previous mapping criteria.

“Roaded roadless” was just an artifact of the mapping process used in 2001; that’s why there are clauses about “substantially altered” acres being included.

♦ Roaded inventoried roadless areas were defined as the area within 0.5 miles (either side) of existing roads.
♦ WUI based on the Healthy Forests Restoration Act’s (HFRA) definition, which includes the areas identified in an existing Community Wildfire Protection Plans or, where a Plan is not in effect, the extent of at-risk communities and up to a 1.5-mi buffer around the communities and areas around evacuation routes for at-risk communities. The mapping process resulted in some small fragments of former IRAs remaining. Under this alternative, USDA would apply past criteria for designating IRAs and the western US (west of the 100th meridian) and Alaska, only retaining areas that are greater than 5,000 acres or share a border with Wilderness or recommended Wilderness. East of the 100th meridian inventoried roadless areas of any size were retained.

We had many lengthy discussions about WUI definitions and size of buffers (not sure we talked about evacuation routes specifically) during the Colorado process. You have to pick something and the choices were some kind of mapping, or using HFRA definitions. Certainly there are advantages to HFRA definitions.  It might encourage communities to update theirs, although I’m not sure CWPPs are all equally worthy. But the fact is it’s enshrined in legislation, so there’s that.

Footnote 11, for those of you less familiar…

WILDLAND-URBAN INTERFACE.—”The term ‘‘wildland urban interface’’ means—(A) an area within or adjacent to an at-risk community that is identified in recommendations to the Secretary in a community wildfire protection plan; or (B) in the case of any area for which a community wildfire protection plan is not in effect—(i) anarea extending 1⁄2-mile from the boundary of an at-risk community; (ii) an area within 11⁄2 miles of the boundary of an at-risk community, including any land that—(I) has a sustained steep slope that creates the potential for wildfire behavior endangering the at-risk community; (II) has a geographic feature that aids in creating an effective fire break, such as a road or ridge top; or (III) is in condition class 3, as documented by the Secretary in the project-specific environmental analysis; and (iii) an area that is adjacent to an evacuation route for an at-risk community that the Secretary determines, in cooperation with the at-risk community, requires hazardous fuel reduction to provide safer evacuation from the at-risk community”. (Healthy Forests Restoration Action of 2003; 16 U.S.C. 6511 (16)

I heard different things about processes for boundary modifications in the 2001 Rule, one is that you could do it (i.e., there is a formal process) but no one does, and the other you can’t do it. Maybe someone here knows more.  It seems important.

Here’s what Alternative 3 does:

This alternative also includes provisions to make modifications and administrative corrections to inventoried roadless area boundaries, responding to comments about issues with inaccurate national mapping. The following procedures are included in this alternative allow site-specific boundary modifications or corrections:
a. Modifications to boundaries. Responsible officials, working with local government, Tribes, and interested parties, may propose boundary modification to the Chief. Modifications and additions approved by the Chief will be reflected in the set of maps maintained at the national headquarters office of the Forest Service. Modifications of inventoried roadless area boundaries may be made to correspond with geographic features, land management plan management areas, or for other reasons. A boundary modification is not required to perform work done under an exception pursuant to §§ 294.12(b) or 294.13(b). Public notice with a minimum 30-day comment period will be provided for any proposed boundary modifications.
b. Administrative corrections to boundaries. The Chief of the Forest Service may issue administrative corrections. Administrative corrections to the maps of any inventoried roadless area are adjustments to correct clerical errors, to conform with new statutory or regulatory requirements, or to correspond with changes based on improvements in mapping technology.

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There are some issues that we had in Colorado that alternative 3 doesn’t touch.. bringing in equipment to fix dams, roads to help manage vegetation along powerlines, and other relatively small issues that could be helped by restricting access on the roads.   But I think this alternative, for the most part, has the greatest potential.