The Letter to the Forest Service

Mr. Harv Forsgren September 22, 2007
Regional Forester, Southwestern Region
USDA Forest Service
333 Broadway SE
Albuquerque, New Mexico 87102                                                     

Re: Travel Management Planning and the Roads Policy on the Santa Fe National Forest

Dear Harv:

We are concerned that the current Travel Management Rule planning process on Santa Fe National Forest is being carried out independent of and not in compliance with the prior approved January 12, 2001 Forest Transportation System Management Policy (“Roads Policy”) (Federal Register 66:3206).

The Roads Policy was the agency’s first major management tool since revision of the National Forest Management Act regulations in 1983. It provides forest managers with objectives and procedures needed to change the current overbuilt and under-maintained road system to one that is economically feasible and less damaging to the environment. Under this policy a science-based roads analysis, validated with site-specific data, must precede all management decisions involving roads and motorized trails that function as roads.

In particular, the Roads Policy requires that each Forest Supervisor determine “the minimum road system necessary for safe and efficient travel, administration, utilization and protection of Forest Service lands” (Federal Register 66:3217). This determination requires a science-based roads analysis for all road management decisions that would result in either a change in access (such as current use, traffic patterns and road standards) or adverse environmental effects on soil and water resources, ecological processes or biological communities. A Transportation Atlas must also be prepared and kept current that includes maps and aerial photos, physical attributes and an assessment of road condition to determine if a road is meeting resources management objectives and access needs.

Twenty years ago the Santa Fe National Forest Plan recognized that thousands of miles of unneeded roads were causing unacceptable environmental damage and called for “an aggressive program for closure of unneeded roads” (USDA Forest Service, 1987:91). The Plan required that 1320 miles of road be obliterated by 2007 (USDA Forest Service, 1987:76). However, since 1994 only 266 miles have been decommissioned (USDA Forest Service 2004a:7).

The National Forest Management Act requires that site-specific projects implementing the Forest Plan be consistent with that Plan. 16 U.S.C. § 1604(i). However, the Travel Management Rule planning process is likely to produce results inconsistent with the Santa Fe National Forest Plan.

First, roads scheduled for decommissioning under the Forest Plan, such as poorly maintained logging roads, temporary roads that were never closed and roads that evolved from tracks made by off-road vehicles, are likely to be included in the Motor Vehicle Use Map. Many of these substandard roads are currently open to off-highway vehicle travel.

Second, the Santa Fe National Forest has the highest road density of any National Forest in the Southwestern Region, exceeding the 2.5 miles/square mile density level that characterizes watersheds “not properly functioning” (USDA Forest Service, 2004:21).[1] This road density estimate should be considered “the minimum known road density” because it does not include an estimated 1500 miles of maintenance level 1 and 2 roads and motorized trails that have yet to be inventoried (USDA Forest Service 2004:21). In some cases, proposed Motor Vehicle Use Map road densities exceed Forest Plan standards.[2]

Failure to determine the minimum road network needed to administer the Santa Fe National Forest before addressing the question of motorized use compromises the agency’s ability to meet Forest Plan standards.

The Roads Policy also has the advantage of injecting a note of fiscal realism into Travel Management planning. The Santa Fe National Forest’s current annual road maintenance needs are more than ten times appropriated funds (USDA Forest Service, 2004a:12). As of 2003, nearly $27.5 million was needed just to meet minimum industry standards for safe travel on the existing transportation system. Inadequate funding will likely continue in the foreseeable future. In light of this reality, the Roads Policy provides clear direction and tools to manage, reduce and reconfigure the Santa Fe National Forest’s road system to minimize the agency’s financial liability.

The Santa Fe National Forest prepared a Forest Level Roads Analysis Report in January 2004 as required by the Roads Policy. However, this report analyzed only some higher standard maintenance level 3 and 4 roads; maintenance level 1 and 2 roads (suitable for high clearance vehicles) and 33 miles of maintenance level 3 and 4 roads were deferred to watershed level analysis that will occur at some unspecified future time (USDA Forest Service, 2004a:5).

For roads that were analyzed, the Forest Level Roads Analysis found that over 70 percent are not being managed to the safety and environmental standards for which they were designed (USDA Forest Service, 2004a:5). According to the study, most forest roads analyzed present a high risk for illegal activities and are causing serious degradation to wildlife habitat, watersheds, cultural resources and aiding the spread of invasive plants (USDA Forest Service, 2004a:5). The study also found that road maintenance is routinely deferred resulting in deteriorating road condition and increased repair cost (USDA Forest Service, 2004a:12 and 45).

An additional concern is temporary roads. The National Forest Management Act requires that temporary roads be closed within 10 years of project completion unless determined to be necessary for a minimum road system. 16 U.S.C. 1608(a). However, off-highway vehicle users have turned many temporary roads into unauthorized motorized trails. It is illegal to designate temporary roads for off-highway vehicle travel that should be closed under the National Forest Management Act.

Integrating Travel Management planning with the Roads Policy will take addition time. The Forest Service Washington Office specifically provides procedures to request additional time to accomplish Travel Management Rule objectives. We urge that the Santa Fe National Forest take advantage of this opportunity and request sufficient time and resources to reverse decades of poor road management practices.[3]

Otherwise the agency runs the risk of failing to meet Clean Water Act water quality standards, soil and watershed protection requirements of the National Forest Management Act, the duty to conserve threatened and endangered species listed under the Endangered Species Act and Occupational Health and Safety Act and Americans with Disabilities Act minimum safety standards.

We would like to discuss these substantive concerns at your earliest convenience.

Respectfully submitted,

Santa Fe Watershed Watch

cc: Mr. Daniel Jiron, Forest Supervisor, Santa Fe National Forest
    Senator Jeff Bingaman
    Senator Pete Domenici
    Congressman Tom Udall
    Governor Bill Richardson
    Secretary Joanna Prukop, NM Energy, Minerals and Natural Resources Department
    State Forester Butch Blazer, EMNRD, Forestry Division
    Dr. Bruce Thompson, Director, NM Department of Game and Fish      

References

USDA Forest Service, 1987. Santa Fe National Forest Plan as Amended, Santa Fe National Forest, Santa Fe, NM

USDA Forest Service, 2004a. Santa Fe National Forest, Forest Level Roads Analysis, Santa Fe National Forest, Santa Fe, NM.

USDA Forest Service, 2004. Biological Assessment for the Continued Implementation of the Land and Resource Management Plans for the Eleven National Forests and National Grasslands of the Southwestern Region, April 8, 2004. Southwestern Region, Albuquerque, NM.