Roadless Comment Deadline Nov. 15

Land Rights Network
American Land Rights Association
PO Box 400 - Battle Ground, WA 98604
Phone: 360-687-3087 - Fax: 360-687-2973
E-mail: alra@landrights.org or alra@governance.net 
Web Address: http://www.landrights.org
Legislative Office: 507 Seward Square SE - Washington, DC 20003

November 15th Roadless Comment Deadline


The Deadline was extended to Midnight, Monday, November 15th.

This is likely your last chance to get a fair Forest Service Roadless
Policy.

Help overturn the Clinton Roadless Rule with one that supports you and
local communities.

Send your Comments to the Forest Service Now!  We've made it easy.

Support The Administration's effort to protect access to your forests.

Support private property owners, hunters, fishermen, ranchers, miners,
foresters, explorationists, campers, rock hounds, off-highway vehicle
users and the general public who likes to go exploring on the ever
decreasing network of roads within the National Forests. 

Over one million acres of private land are held hostage inside the
Clinton Roadless Areas.

>>>>>There is a legal concept called "laches" or "sleeping on your
rights" that says that if you want to preserve your future legal rights,
you must be a participant in the process.  Your comment now will do
that.

The greens think they can walk over you in the comment period.

Your enemies are doing all they can to target your use of the forests.

Don't let it happen. 

You must deluge the Forest Service with comments supporting the new Bush
Administration Roadless Rule.

We've made it easy for you. 


*****Here's what you need to do now:

-----A.  Fill out and fax, e-mail or mail to the Forest Service the
Comment Questionnaire below.  The appropriate addresses are included on
the document.

-----B.  Download a formatted version of the Comment Questionnaire by
going to www.landrights.org.  Fill it out and fax or mail it to the
Forest Service. 

-----C.  Make copies of the Comment Questionnaire below or the formatted
version at www.landrights.org  to hand out to your friends, employees
and allies.  

-----D.  If you work in a plant, make copies to hand out to everyone.
Have someone take responsibility to make sure that each employee, vendor
or supplier  gets a copy and fills them out.  They should be free to say
whatever they feel is appropriate in the answers area. 

Do not assume someone else is going to do this.  It is up to you.
Strike a peaceful blow for freedom and access to our forests.


You may also get a complete copy of the Forest Service new Roadless Rule
Federal Register Notice at www.landrights.org





****E-mail, Fax or US Mail Postmark Deadline is Midnight,  Monday,
November 15th


Roadless Alert -- Roadless Area Management Comment Questionnaire


To All Multiple-Use and Private Property Allies:    


URGENT ACTION REQUIRED        &nbs p;  
                  
The U.S. Forest Service needs to hear from you today on roadless area
management!  It is very important to you that you send comments.    In
law, it is called "laches" or sleeping on your rights.  If you fail to
comment on these proposed Forest Service Roadless Regulations, you could
lose some future legal  rights.

Background -

The new roadless regulations proposed by the Bush Administration in July
provide an improved approach to managing the millions of roadless acres
in the U.S.  The earlier roadless rule, issued in the closing days of
the Clinton Administration, was deeply flawed: boundaries were
inaccurate; access to state, county, and private in-holdings was
significantly restricted; local forest planning was ignored; and
management activities to address forest health were curtailed.
                                       
The newly proposed rule goes a long way to fixing many of these flaws,
primarily by bringing state, county, and local input back into the
process of managing national forest land, without the federal government
ceding final oversight of the land.  It gives Governors an opportunity
to work with the U.S.  Forest Service to establish management
requirements for National Forest System inventoried roadless areas
within their States.
                           
Your comments on the proposed roadless rule are critical to ensuring
local input to management of roadless areas on our national forests.
Please help by filling out and e-mailing or faxing back to the Forest
Service the Comment Questionnaire below.

Please note that multiple-use and private property advocates AGREE with
all the statements below but you do not have to.  Please circle whether
you AGREE,  DISAGREE,  OR  HAVE  NO  OPINIION on each statement. 

Please note that the comment deadline is now Monday, November 15th.

Below the statements there is a place for you to write in any personal
comments you may have.   

You make the comment questionnaire far more valuable with your personal
comments.  

Thank you.







Content Analysis Team, USDA - Forest Service, Attention: 
Roadless State Petitions,
P.O. Box 221090,
Salt Lake City, Utah  84122. 

Fax to:  (801) 517-1014. 

E-mail: statepetitionroadless@fs.fed.us



Dear Chief Bosworth:      

RE: Proposed Rulemaking - Special Areas; State Petitions for Inventoried

             Roadless Area Management, 69 Fed. Reg. 42636 (July 16, 2004)

On July 16, 2004, the Forest Service proposed a new roadless area
regulation that is intended to replace the 2001 rule.  I support the
proposal, but have a number of suggestions for consideration in the
final regulation. The following contains my section specific comments
and recommendations in order of priority:

-----1.  I support the Forest Service's efforts to fix the fatal flaws
in the 2001 Roadless Area Conservation Rule.  This rule is the product
of a deeply flawed NEPA process, which was conducted without adequate or
accurate information about the affected areas, and is contrary to the
agency's legal authority.

AGREE DISAGREE NO OPINION

-----2.  The process that created the 2001 Roadless Area Conservation
Rule ignored substantive concerns raised by the public and by local,
State, and Federal elected officials.

AGREE DISAGREE NO OPINION

-----3.  The proposed regulation in Section 294.11would retain the
definition of "inventoried roadless areas" contained in the January 2001
Roadless Rule.  This regulation defines these areas as identified on the
maps in the Final Environmental Impact Statement and "any subsequent
update or revision of those maps."  However, neither the 2001 regulation
nor the proposed revision provides any mechanism to accomplish these
subsequent updates or revisions. 

   Inventoried roadless areas, and the maps depicting them, were
developed by the Forest Service under the auspices of the Wilderness Act
during the 1970's, well over 20 years.  Their purpose was to identify
areas that met the minimum requirements for consideration as
"wilderness" by Congress and 

I recommend that the final regulations require every national forest to
conduct a boundary review within 18 months of the effective date.  This
review would be conducted either as part of the process to address a
Governor's petition or as a separate action if no petition were filed. 

AGREE DISAGREE NO OPINION

-----4.  In Section 294 .15, state-specific rulemaking, the final rule
must ensure consideration of local concerns by complying with the forest
management laws.  I believe it is vitally important to manage roadless
areas through the applicable forest management plan, as required by the
national forest management laws.  Compliance with these laws will also
ensure that local conditions are considered and local concerns are
addressed.  However, section 294.15 merely prescribes a rulemaking to
address a Governor's petition that has been accepted by the Secretary.
Neither the proposed regulation nor the preamble ever explains or
requires how this rulemaking would be coordinated with the applicable
forest management plan.  Thus, the proposal seems to suffer from the
same fatal flaw as the January 2001 Roadless Law - no compliance with
the national forest management laws and no consideration of local
issues.

Accordingly, I urge the Forest Service to incorporate into the final
regulations a requirement that if a Governor's petition would change the
management of any roadless area from that set out in the applicable
forest plan, that plan must be amended or revised before the rulemaking
comes into effect.

AGREE DISAGREE NO OPINION

-----5.  Under Section 294.12, state petitions, I support the
opportunity for a Governor of a State to petition the Secretary to
promulgate regulations establishing management requirements for all or
any portion of inventoried roadless areas in their state.  As noted
above however, we believe that the actual decision regarding management
of these areas must be finalized through an amendment or revision of the
applicable forest plan.  In regards to the proposed time period of 18
months for Governors to develop a petition, we believe that 18 months is
sufficient, given the recommendations immediately below.

I request that the final rule provide guidance to Governors in this
section of the regulation regarding the process by which Governor's may
develop their petition.  We recommend that the final rule provide
guidance to Governors that before submitting a petition they should:

1)-----------seek professional assistance from their State Forester,
2)-----------consider current and future wildfire risk conditions,
3)-----------review the management decisions for the roadless areas set
out in applicable forest plans,
4)-----------consider needs for access to state and private lands,
5)-----------carefully look at each individual roadless area and
consider local conditions of these areas,
6)-----------adjust boundaries to excluded already roaded areas,
7)-----------consult with local counties and town officials,
8)-----------consider social and economic impacts of their proposals,
9)-----------document the gain or loss in access to national forests by
their proposal.

The preamble indicates that the agency will consider if any additional
consultation will be needed with State and local governments prior to
adopting the rule.  We highly recommend that such consultation take
place in order to develop the guidance suggested above for the final
rule. 

AGREE DISAGREE NO OPINION

-----6.  The preamble to the rule states that the Secretary is
considering the establishment of a national advisory committee to
provide consultation on the implementation of the State-specific
rulemaking process, review petitions, and provide advice on appropriate
NEPA documentation and the decision of the Secretary regarding the
petition.  I am concerned about the make up of this committee as well as
the scope of their responsibilities.  I do not believe that this
committee is essential to the proposed process and could become a
barrier to resolving not just the disposition of the inventoried
roadless areas.  No advisory committee should be established in the
final rule because it is likely to be politically influenced and
scientifically compromised. 

AGREE DISAGREE NO OPINION

-----7.  In conclusion, I support the proposed rule in general, but as
noted above, request that the agency consider a number of changes and
additions to a final rule in order to assure that the rule is legally
sufficient and capable of being implemented by the Forest Service,
Governor's and others involved in the proposed processes. 

It is vitally important that the old, flawed boundaries of inventoried
roadless areas be replaced with land allocations and management
requirements that reflect accurate conditions on the ground and
decisions reflected in forest plans.  The forest health crisis on
federal lands requires that on-the-ground managers have forest plans
that guide projects and programs to restore and maintain forest health
and provide for appropriate multiple uses of the national forests.

AGREE DISAGREE NO OPINION


XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
Your personal comments here will make this document more valuable.  It
is very important to put your personal views in this section.  Add
additional pages if necessary. 















XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
To validate your comments please fill in completely (PRINT or TYPE) and
be sure to sign.

Signature:

Name:

Address:

Town:

State: 

Zip:

Phone: 

Fax:

E-mail

Do not fail to send this comment questionnaire even if it is late.
They are often counted late. 

Don't forget.  You may read and download the complete new Bush
Administration Roadless Rule proposal at www.landrights.org. 

*****You may also download a fully formatted pdf file of the Comment
Questionnaire.

Make copies and hand them out to your friends.  This is a big deal and
worth the effort.  Don't let the Clinton land grabbers win at this late
date.


Mail, Fax or E-mail Deadline for comments-Monday, November 15th.

Lets compete with the greens.  If you want to preserve access to your
forests, now is the time.  The Forest Service must receive as many
comments as possible.





Please forward this message to your entire mailing list.  This is a
critical issue. 
Remember- the deadline is Midnight, Monday, November 15th.

"The only thing necessary for evil to triumph is for good men to do
nothing." --Edmund Burke (1729-97)