NMFS Urges Stronger Roadless Plan Salmon Protectionsby Barry Espenson
Columbia Basin Bulletin - August 18, 2000
By A proposal to ban road building, but not logging, on 43 million acres of National Forest System land is a step is a step in the right direction, but does not go quite far enough, according to the agency burdened with the task of recovering Columbia Basin salmon and steelhead stocks.
The U.S. Forest Service in May released its proposal for conserving nearly a quarter of the 192 million-acre forest system -- inventoried roadless areas. Those inventoried roadless areas, and other roadless areas, represent "inherent values and characteristics that are becoming scarce in an increasingly developed landscape," according to the draft summary.
Many of those roadless areas provide opportunities for dispersed recreation and sources of public drinking water, as well as potential timber supplies.
The summary also points out that the areas provide important habitat for rare plant and animal species and support the diversity of native species. About 25 percent of the animal species and 15 percent of the plant species either listed or proposed for listing are likely to have habitat within inventoried roadless areas.
The public "rulemaking" process was launched when President Clinton, in October 1999, directed the agency to develop regulations for federal roadless areas. A public scoping process was conducted over the course of the winter with the USFS receiving 365,000 responses. The May release of a draft environmental impact statement and proposed rule triggered a second public comment process, which ended July 17.
Road construction and reconstruction activities would be prohibited in the unroaded portions of the inventoried roadless areas under the agency's preferred alternative. The Forest Service estimates that 1,444 miles of roads would be constructed over the next five years in the roadless areas under current management.
Timber harvest and mining would not be prohibited under the proposal as long as the activities can be carried out without the construction of new roads. The Forest Service estimated that the proposal would reduce harvest in the roadless areas by 0.3 billion-board feet, from the 1.1 billion board feet planned for sale during 2000-2004. The EIS calculates that 480 total timber related jobs, direct and indirect, and $21 million in total timber income, could be lost if the rule is implemented nationwide.
Exploration and development of mining and oil and gas extraction would be hampered, as would recreational development, such as proposed downhill ski areas, in the roadless areas.
Existing roads within those "roadless areas" would be maintained with recreational access and allowed uses unchanged.
The agency is still in the process of counting, reviewing and categorizing the comments for analysis, according to Cindy Chojnacky of the agency's roadless area project office in Washington, D.C. The tally and analysis is expected to be complete by early this fall. Comments and information offered will be weighed as the agency prepares a final EIS and proposed rule, due for completion in December. A record of decision by the secretary of agriculture, or his designee, could be forthcoming in December.
Hearings held in the Northwest, where nearly half of the inventoried roadless areas are located, drew large crowds. Commenters were largely split along two lines -- those worried that the roadless plan would unfairly limit recreational access, timber harvest and mineral exploration and other uses and those that felt the proposal fell short of its goal of protecting a shrinking pot of pristine ecosystems.
One of the few federal agencies to offer official comment was the National Marine Fisheries Service, Chojnacky said. The NMFS, faced with the growing task of guiding listed salmon recovery, offered pointed remarks. The National Oceanic and Atmospheric Administration agency praised the USFS proposal's recognition of the roadless area's value and offered suggestions on how to strengthen the plan.
The proposal's benefits include protections of in-stream and riparian habitats in those areas and in areas downstream that might be affected by erosion and sedimentation resulting from road building and related activities, NMFS said.
"Many of these undeveloped areas now serve as habitat and species strongholds from which species could recolonize recovered habitats," the NMFS wrote. "If roads were built in unroaded areas, there would be short- and long-term habitat degradation that could reduce the survival and recovery of listed and unlisted species."
The NMFS comments faulted the proposal for its failure to include smaller, roadless areas. Both IRAs and uninventoried units, NMFS said, play key roles in the survival of 26 West Coast salmon and steelhead species listed under the Endangered Species Act.
"Lands administered by the USFS throughout the West Coast and inland Northwest offer many of these species the only remaining high quality freshwater habitat thereby buffering these species from sliding closer to extinction," according to comments submitted by NMFS on the EIS. Inventoried areas in Idaho, Montana, Washington and Oregon total 18.5 million acres.
"NOAA remains concerned about other unroaded areas not subject to the prohibitions in this proposal, which may be less than 5,000 acres in size and that were not included in the RARE II inventory," NMFS commented. "Many of these land also provide critical habitat for ESA-listed Pacific salmon."
"As noted in the DEIS, inventoried roadless areas encompass only 2 percent of the land base in the United States. Because of this limited opportunity to provide aquatic resource conservation via IRAs, smaller land units should be evaluated for their potential contribution to the survival and recovery of listed fishes."
The NMFS was also critical of procedural elements in the proposed action that say "local managers would evaluate whether and how to protect roadless characteristics" both in inventoried roadless area and other roadless areas.
"NOAA is concerned that the proposed action inappropriately defers future decision-making relevant to roadless areas to a scale too small (each national forest) to adequately evaluate effects on listed Pacific salmon and their critical habitat…"
"Snake River spring/summer chinook salmon is a case in point. Their freshwater range includes eight national forest s and three regions of the USFS (Regions 1, 4 and 5). Individual national forest LRMPs are not large enough analysis units to analyze effects on this species The multi-regional/multi-national forest analysis unit is needed to ensure effects are adequately considered throughout this species freshwater range."
The NOAA-NMFS comments also faulted a preferred USFS proposal that limits road building and reconstruction in IRAs, but still allow commercial logging, such as through helicopter logging.
"NOAA recommends that the USFS exclude commodity timber harvests in IRAs because they commonly involve even-age management, and, in roadless areas, require the use of large quantities of fuel to service helicopters that can lead to fuel spills," read the NMFS comments.
"The USFS should limit timber harvest in inventoried roadless and unroaded areas to non-commodity activities necessary for stewardship purposes that do not involve harvest in riparian areas, on steep, potentially unstable slopes, even-age management, or have adverse impacts to water quality."
The NMFS communication also stressed that it did not buy arguments made by some that prohibiting road building in IRAs increased the risk of large-scale wildfires.
"NOAA has reviewed the best available scientific information regarding the effects of wildfires on Pacific salmon and their habitat, and has concluded that adverse effects on Pacific salmon and on habitat are not a significant concern from wildfires compared to traditional road building and timber harvest in roadless areas….
"These areas that have received little active management have been subject to similar risks of wildfire as managed landscapes, yet they tend to remain in high quality condition and serve as strongholds for listed Pacific salmon. Even though more recent wildfires have been larger and hotter than fires during past decades, impacts on anadromous fish resources tend to be short lived, not lasting more than a few years.
"Human-induced disturbance can intensify the effects of wildfires, and studies have shown that erosion at a watershed scale is largely more closely linked to timber harvest and road construction."
Roadless Area Conservation Project: http://www.roadless.fs.fed.us
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