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ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National Forest13. Roadless AreasWe hereby incorporate all that was written in our appeal comments for the Hoosier LRMP on roadless areas and wilderness.In the entire FEIS for the German Ridge Project, we have one line referring to roadless areas: From German Ridge FEIS, Page 83: “There is no Inventoried Roadless Area, or portion thereof, in the German Ridge Project area.” The Forest Service has changed the wording of the FSH to disqualify areas from roadless. Only areas previously inventoried on the Hoosier [i.e., the Roadless Area Review and Evaluation (RARE II) areas] were considered for coverage under the rule. Additional areas were not considered for coverage under the rule. The Forest Service needs to prepare a DSEIS to consider all potential areas, including German Ridge. The Hoosier FEIS Appendix Page 63 states: “After reviewing public comments submitted from the workshop and completing an internal review, no areas on the Hoosier National Forest qualified as a roadless area. This includes Mogan Ridge, which previously qualified as an Inventoried Roadless Area.” Mogan Ridge is close to German Ridge, and is being considered for a commercial logging project. By excluding what should have been rightly included in the inventoried roadless area, the German Ridge analysis is then skewed. What effects would “treatments’ on German Ridge have on a roadless area nearby? How would this have changed the cumulative effects analysis? So, all the previously inventoried areas are no longer part of the Roadless Inventory. Under the new Roadless Rule this prevents the governor from petitioning to protect these areas as Roadless Areas. If the new rule is thrown out (which it should be), this also removes the rule’s protection for the areas. The DEIS for the Hoosier LRMP did not disclose this was being done. More importantly, the FEIS fails to disclose the environmental impacts of removing this protections or even disclose the implications of removing the areas from the inventory. Likewise, the FEIS fails to disclose the implications of not including these areas. Another problem is the Forest Service is not distinguishing between Wilderness and Roadless. Even if the Forest Service properly eliminated the areas from consideration for Wilderness recommendations, whether or not they should be a roadless area under the roadless rule is an entirely different question. The Forest Service used the section of the Forest Service Handbook on which areas should receive a Wilderness evaluation to eliminate all the roadless areas identified under the Roadless FEIS. This Roadless Rule was not even proposed when the FSH guidance the Forest Service used was adopted. In fact, the FSH specifically states, “This chapter describes the process for identifying and evaluating potential wilderness in the National Forest System.” FSH ' 1909.12 Thus, using this guidance to eliminate areas from roadless consideration is arbitrary and capricious. Roadless Areas and Wilderness Areas are not the same. They serve different purposes. Thus, before eliminating areas from the rule, the Forest Service needs to consider the values and purposes of Roadless Areas. The Roadless Rule FEIS’s purpose and need lists many purposes of roadless areas that are not the same purposes as Wilderness: “These same areas also provide people with unique recreation opportunities. When activities such as hiking, camping, hunting, wildlife viewing, and cross-country skiing take place in areas with roads, the experience will include more interactions with people, more sights and sounds of development, and more restrictions. Recreation in inventoried roadless areas produces experiences that are usually difficult to replicate in roaded areas. The Forest Service is the single largest provider of outdoor recreation opportunities in the United States, and the demand for most recreation activities is growing (Cordell and others 1999b). However, the land available for outdoor recreation (dispersed recreation in particular) is dwindling, and will continue to decline as development encroaches upon available open space. Between 1992 and 1997, nearly 16 million acres of non-Federal forest, cropland, and open space were converted to urban and other uses. This is twice the rate of the previous 10 years in the United States (Natural Resource Conservation Service, NRI Inventory, 1982-1997).” The Forest Service’s decision to eliminate these areas from the roadless inventory did not address or consider a single value roadless lands are supposed to provide. For example, there was no discussion of how well these areas provided clean water. Therefore, the decision to delist these areas under the roadless rule was arbitrary and capricious as it was not based on a consideration of the relevant factors. We believe the onus should be on the Forest Service to explain to the public WHY the German Ridge Project Area and Mogan Ridge area (which used to be part of the roadless inventory) was not considered a roadless area. Why wasn’t it considered? What does the Forest Service consider a road? Is there a perverse incentive to build more roads in this area so that they can no longer be designated roadless? Click here for Part 14. The Size of ClearcutsProtect Our Woods
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