The Forest Service has a nondiscretionary duty to identify the minimum roads system. We are very concerned that no attempt has been made by the agency to identify the minimum road system. This is particularly troubling given the massive road maintenance backlog on National Forests and the extreme impact the road system is having on the hydrological, biological and botanical values of the Forest.
Further, the purpose of Subpart A (of the Travel Management Rule) is for each unit of the National Forest System to determine a minimum road system in order to establish the means for “safe and efficient” travel and it requires the agency to identify and decommission unneeded roads. It is unacceptable for the Forest Service to ignore the regulations and guidance that call for resource protection while preparing documents that will add significant additional road and trail mileage to the Forest Service road system.
Road density is an important indicator of such things as habitat fragmentation, the potential for wildlife harassment, visual quality, recreation opportunities, the cumulative potential for erosion and sedimentation from road surfaces, and cumulative increases in peak flow due to runoff from road surfaces and ditches. Consequently, the proposed Environmental Impact Statements should include a plan to close and decommission unnecessary or damaging roads to reduce road density in these forests.
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