Comments on Roadless Area Conservation Proposal

by Sequoia Task Force, Sierra Club

July 13, 2000

USDA Forest Service-CAET
Attn: Roadless Areas Proposed Rule
PO Box 221090
Salt Lake City, Utah 84122

These comments are from the Sequoia Task Force of the Sierra Club regarding the Forest Service Roadless Area Conservation DEIS. The first set of comments are about the proposal in general while the second part of the comments regard Sequoia National Forest in California.

General Comments

The final EIS should immediately prohibit road building in all inventoried Forest Service Roadless Areas. The proposal should also include roadless areas down to at least 1000 acres in size.

Logging should be immediately prohibited in all roadless areas down to 1000 acres in size. Helicopter logging can have as much impact as roads and could permanently alter the natural character of the roadless areas.

Off Road Vehicles should be banned from roadless areas. Unless they are carefully controlled and regulated they can do serious environmental damage in roadless areas. It is a difficult task to monitor and control ORV use. The Forest Service has never had the money or enough staff to adequately deal with the problem. Unless the Forest Service is prepared to impose strict rules and aggressively enforce them the use of ORVs in Roadless Areas should be prohibited.

Prescribed fire should be the primary tool used to reduce excessive fuel loading where it occurs. Logging in the forests of the Sierra Nevada has created some of the worst fire hazards in the area according to the Sierra Nevada Ecosystem Project report. Logging should not be used to reduce fuel hazards. Too often the need to reduce flammable fuels has been used as an excuse to promote more commercial logging.

The natural conditions found in Roadless Areas are the best way to protect watersheds and assure a supply of high quality water. Many communities in the West depend upon watersheds that originate in roadless Areas for a domestic water supply.

Hardrock mining and drilling for oil and gas should not be allowed in Roadless Areas. In addition proposals for other types of developments such as ski areas should be prohibited. In the Sierra Nevada the Forest Service should deny any requests to leave the San Joaquin Ridge Roadless Area out of the proposal. That area has unique environmental attributes and expansion of existing ski areas into the roadless Area should not be allowed.

The Forest Service should make sure that the definition of roads for this proposal includes only roads that have been constructed and are regularly maintained. User established roads that run cross country should not be allowed to disqualify any Forest Service land that would otherwise be included in the proposal. That would encourage the opponents to this proposal to go out and establish such roads just to disqualify areas for consideration.

The Tongass National Forest in Alaska should be included in the proposal. The rain forests of SE Alaska are of world wide significance. The Roadless Areas found there are just as important as those in the lower 48 and should be just as carefully protected as those in the rest of the nation's forests.

Comments regarding Sequoia National Forest

Many of the Roadless Areas in Sequoia National Forest provide habitat for sensitive species of plants and animals. For example Pacific Fishers and California Spotted Owls are found in some of the higher elevation Roadless Areas. The DEIS for the Sierra Nevada Framework recognizes the need to protect these species. The Roadless Areas in the Giant Sequoia National Monument and the Rincon, Woodpecker, and South Sierra Roadless Areas are particularly important. An isolated population of Pacific Fishers is located in Sequoia National Forest. Habitat for Red Legged Frogs is also found in these areas. Rare and unusual plants are also found in some of the Roadless Areas of the Forest. Keeping these areas roadless and free from developments and activities that would alter their natural character provides the best method to assure their survival.

Many of the Sequoia National Forest Roadless Areas are at low elevations with oak-grassland ecosystems. Most of the lower elevation areas of this type in the Sierra are privately owned. This makes these Roadless Areas in the Forest even more important since there are fewer opportunities to protect them than those at higher elevations that are mostly federally owned.

Most of the communities in the southern San Joaquin Valley depend upon run off from the watersheds of the Sierra Nevada for much of their domestic and agricultural water supply. Sequoia National Forest encompasses the watersheds for much of this resource. For example, Bakersfield depends upon the Kern River for much of its water supply and most of the watershed of the Kern River lies within Sequoia National Forest. The water quality of the Kern River is one of the best in California. Maintaining as much of the Forest as possible in a roadless condition is one sure way to assure the quality of the water in the Kern river remains high.

The mapping of inventoried Roadless Areas in Sequoia National Forest was done several years ago and in many cases is not accurate. I know this from personal visits to much of the Forest. The boundaries of the Roadless Areas should be checked for accuracy and be redone where needed. In addition the Roadless Areas down to 1000 acres should be mapped as well and receive the same protection as the inventoried Roadless Areas.

All activities in the Roadless Areas that would alter their natural character should be prohibited. ORVs are a particular problem in Sequoia National Forest. They can disturb sensitive wildlife. They also interfere with other users who are looking for an escape from the noise they introduce in the Roadless Areas of the Forest. This is particularly true near urban areas where people who just have time for a short outing tend to go.

Many of the Roadless Areas in the Forest have excessive fuel loading. We believe that prescribed burning should be the main tool used to reduce the fire hazard and that mechanical manipulation should be kept to a minimum.

Sequoia National Forest does not have an adequate budget to maintain all of the roads they have. It would be ludicrous to build more roads into Roadless Areas when they cannot take care of the roads they already have. They should make every effort to eliminate user made roads and trails since quite often they have been established in areas where they cause resource damage.

The population in central and southern California is already huge and growing at an explosive rate. Sequoia National Forest accommodates ten million visitors per year, mostly from that part of California. As the population continues to grow more and more people will be seeking an escape from the urban environment most of them live in. That kind of experience can be accommodated most efficiently in Roadless Areas. Therefore if we want to plan for the future all of our remaining Roadless Areas in Sequoia National Forest must be protected. We owe it to our children and grandchildren.

Thank you for considering our suggestions and the opportunity to comment.

Joe Fontaine Vice-Chair Sequoia Task Force Sierra Club

cc: Art Gaffrey Supervisor Sequoia National Forest