FLATHEAD
COUNTY ROADLESS RULE TASKFORCE
The
Flathead County commissioners set up this task force to advise them on
roadless management in Flathead County. After a public hearing the
commissioners made a formal request of the governor to include Flathead
County's recommendations in his petition to the USDA Forest Service
under the Bush Roadless Rule
RECOMMENDATIONS TO THE
BOARD OF COUNTY COMMISSIONERS
February
28, 2006
Purpose:
This report documents formation, process, collaboration, and Task
Force Majority recommendations to the Flathead County Board of County
Commissioners. Ultimately
these recommendations, if/when approved, will be forwarded to Governor
Schweitzer and the National Roadless Advisory Board for future
management requirements of inventoried roadless areas in Flathead
County.
History
of Roadless Issue:
Roadless
lands refer to Federal lands meeting minimum standards for
attributes qualifying the area for evaluation for possible
additions to the Nation's Wilderness System. The areas
generally must exhibit little evidence of past management and
development (little or no timber harvest and no system roads) with
a minimum size of 5000 acres or any undeveloped area contiguous
to an existing Wilderness.
The
first mapped inventory of these areas (Roadless Area
Review and Evaluation- RARE I) was begun in 1972 and completed in
1973 mapping 1449 areas totaling over 56 million acres. RARE
I recommended 272 areas totaling 12.3 million acres for wilderness
designation.
In
response to critics of RARE I, a second Roadless Area Review
and Evaluation (RARE II) was begun in June 1977 to correct
inconsistencies in mapping and evaluation of candidate areas. RARE
II inventoried over 62 million acres. The RARE II January 1979
FEIS recommended over 15 million acres of Wilderness, 10.1 million acres
for further study, and 36.15 million acres for multiple use to
Congress. This recommendation was litigated and found by the
courts to violate the National Environmental Policy Act (NEPA)
because the evaluations were too broad and did not adequately address
site-specific attributes of each inventoried area.
In
1983 the National Forest Management Act implementing regulations were
changed to require individual Forest Plans to update the RARE II
inventory, make site-specific evaluations of wilderness values,
feasibility of management as wilderness, proximity to existing
wildernesses, the anticipated long-term changes in plant and animal
diversity, and values forgone and effects on management of adjacent
lands as consequences of wilderness designation. Based on these
evaluations (the third time the roadless inventory was studied), each
Forest Plan made recommendations to Congress for additions to the
Wilderness system and designated multiple-use long-term land uses
for the balance of the inventoried areas.
Most
Forest Plans in Montana were completed in mid to late 1980's and
Congress has not designated any of the Montana Forest Plan
recommendations.
President
Clinton directed the Forest Service to do another nationwide inventory
and evaluation of roadless areas in October of 1999 when many Forest
Plans should have been revised or in the process of being revised.
This fourth nationwide EIS process was similar to the 1979 RARE II
process and resulted in President Clinton issuing the "Roadless
Rule" just before he left office in 2000.
The
Clinton Roadless Rule directed the USFS to manage all inventoried
roadless areas as if they were wilderness (no development or timber
management) and amended all Forest Plans that had made previous
wilderness recommendations or land use designations for inventoried
roadless areas. The rule was litigated by several States.
The Clinton approved 2001 Roadless Rule was found to be
promulgated in an illegal manner, found in violation of the National
Environmental Policy Act, and the1964 Wilderness Act. The US
District Court in Wyoming issued a permanent injunction and set aside
the roadless rule. That decision was appealed in the US Tenth
Circuit Court of Appeals.
In
an attempt to try to resolve the issue and avoid past mistakes, the Bush
Administration issued a new Roadless Rule Process in May of 2005 that
provides for Governors to submit petitions to the US Department of
Agriculture recommending future management requirements for roadless
areas in their State. The
rule encourages public participation and collaboration at local level in
developing State recommendations that must be submitted to USDA,
Washington DC by November 13, 2006.
As a result of the new rule, the Tenth Circuit Court has ruled
the appeal of the Clinton Roadless Rule is mute because the new rule
replaced the Clinton Roadless Rule.
Montana
Governor Brian Schweitzer subsequently met with County Commissioners in
counties with Federal Roadless Areas, and asked them to help secure
public input for management of these areas.
Accordingly,
the Flathead County Board of County Commissioners adopted a resolution
on September 14, 2005 to establish a 12 member Task Force composed of
members who represent a diverse and broad range of stakeholder groups
for the purpose of making recommendations to the Commissioners on future
management of roadless areas within Flathead County.
A public announcement of the task force formation and request for
applicants was sent to media and appeared in local newspapers.
Task Force members appointed in November 2005 are:
Bill Baum-Local Realtor and part time substitute teacher and
research assistant
Richard
Funk-Kila schoolteacher and librarian
Edwin
Fields-Whitefish planning board and former Whitefish City Council
Lisa
Bate-Consulting research biologist
Vic
Workman-Realtor and member Fish Wildlife and Parks Commission.
Ron
Stuber-Retired veterinarian and Back Country Horsemen Board member
Doug
Denmark-Realtor and Flathead Business and Industry Association
Fred
Hodgeboom-Retired forester and President of Montanans For Multiple Use
Robbie
Holman –retired Holman Aviation and outdoor enthusiast
John
Hansen-forester and Montana Logging Association represetative
Chuck
Roady-FH. Stoltze Land and Lumber Co. Land and Resource Manager
Dave
Hadden-Field Representative Montana Wilderness Association
Process: The Task Force appointments were confirmed and recorded with
the first meeting on December 6, 2006.
All meetings are open to the public with meetings scheduled on
the Commissioner’s Agenda.
A time for public comments was provided at meetings.
Several comment letters were submitted to the task force by
members of the public. Members
of the public were present at each meeting.
(See Appendix A for an index of all public comment letters or
other information provided by the public, the Forest Service, and
letters, studies, and written comments of Task Force members).
State
Senators Dan Weinberg and Greg Barcus co-chaired the meetings with
Commissioner Gary Hall representing the Board of Commissioners. It was agreed that Commissioner Hall would not be a voting
member and that the Chair would vote only if the appointed members voted
in a tie. Task Force
members agreed that it would be desirable for a consensus recommendation
to be reached, but due to the polarized nature of the roadless issue and
time constraints it was recognized that consensus is not likely.
Therefore the committee will generally operate under Robert’s
Rule of Order for making motions, discussion, and voting (minutes
available via e-mail, See Appendix A).
The
Board of Commissioners requested the Flathead National Forest support
the Task Force by providing maps, technical information, and advice.
Accordingly the Flathead NF usually had at least two
representatives present. Each
Task Force participant was provided copies of the current Forest Plan
Appendix C ( Appendix B to this document) that contained maps,
descriptions, site-specific resource data, and the analysis and
management area designations for the current Forest Plan.
The Forest Plan is in the process of being revised.
Maps and description of the tentative Preferred Option for the
revision was provided for comparison with the current Forest Plan
designations and the Roadless Inventory boundaries.
The Task Force thanks the Forest Service for their excellent
support.
The
Flathead County Task Force is especially pleased that Governor
Schweitzer and the Flathead County Board of Commissioners made the
commitment of their time and energy to provide a forum for public debate
of the roadless issue.
Collaboration
Results:
After only two meetings of the Task Force it was abundantly clear
that every member believed that a majority of the acreage within most
mapped roadless boundaries would probably never need a road, but many
members could not accept a blanket resolution freezing the existing
roadless boundaries as a line never to be crossed with a road or other
management practices. In addition the task force generally agreed that we
could not possibly address specific road locations, economics,
environmental effects on over 400,000 inventoried acres in the time
available as requested by Governor Schweitzer.
At that time, additional
direction was sought from the Governor’s Office. Hal Harper, the
Governor’s Chief Policy Advisor, indicated Governor Schweitzer’s
desire for “flexibility” and the opportunity to address “Fire
danger, thinning, hazard reduction, changes in uses, changes in local
citizen needs, and forest uses are among the reasons we are asking for
flexibility…” (Appendix A, Hal Harper e-mail)
Roads. Before 1950 there were very few roads in the Flathead
National Forest. In the
1950’s and 1960’s it was accepted that roads were necessary not only
for timber harvest but to benefit wildlife habitat and disperse hunters
and game throughout the Forest. The
roadless inventory boundaries are a relic of where road development had
progressed by 1972 and adjustments that have been made to those original
boundaries by Wilderness Classifications, timber sale projects that were
implemented, and inventory boundary adjustments made as a result of the
various studies. The
majority of the task force believes the existing roadless boundaries are
not logical management boundaries, and that the boundaries on most areas
should be modified or eliminated completely.
Many
highly productive areas were severely burned in 1910 or the hot dry dust
bowl era in the 1920’s and early 1930’s.
Tens of thousands of acres of these burned over areas in USFS
Region 1 did not support timber that was economic to harvest when
roadless areas were inventoried in 1972, so there were few if any roads
in those large tracts. Today
most of those old burn areas (exemplified by the Mt. Hefty area in the
North Fork Flathead) have grown into high value timber stands that are
now in declining health and under insect attack.
The natural succession growth coupled with effective fire
suppression since the 1930’s has produced dense, continuous, unnatural
stands with heavy ground fire fuels and high resistance to fire control.
Over the last 20 years, efforts to treat some of these areas,
even in areas within roadless inventory boundaries designated for timber
production by the current Forest Plan, have been successfully obstructed
by legal challenges just because the treatment was proposed within a
roadless area.
Today
the Flathead National Forest will not even propose salvage of burned
timber by helicopter or any other means within inventoried roadless
areas. We have even
experienced a reluctance of local Forest Service officials to use dozers
to construct firelines in roadless areas, and that has contributed
escaped fire and increased burn areas.
On
the Flathead, timber and road issues generally are significant only in
the lower elevation (below 5000 ft.) fringe areas and narrow fingers and
protrusions formed by qualifying area mapped between existing roaded
areas. The importance of
these areas for future harvests to maintain forest health, fuel
reduction, enhance wildlife habitat, and protect watersheds cannot be
minimized. The area
available for timber management in the current Forest Plan is only about
25% of the Forest and preserving all the existing roadless inventory
areas would reduce that even more.
The
majority of the task force believe that it is poor stewardship of public
resources to make long term decisions to prohibit roads, other
management practices, and other public uses within the roadless
boundaries that were drawn 35 years ago with no consideration
Fire
Hazard. In 2001
catastrophic fire burned about 36,000 acres of Flathead Forest lands,
27,000acres of Glacier Park, and almost 8,000 acres of State and private
land. In 2003 the
Flathead National Forest lost over 300,000 acres, Glacier National Park
had 235,500 acres burned plus several thousand acres of State and
Private lands including 27 private structures.
These fires and their devastating outcomes were predicted by Dr.
Robert Nelson in his article “The Forest Service’s Tinderbox.”
( Appendix A, Nelson 2000).
Most of these fires started and built up to uncontrollable
holocausts in the continuous heavy fuel within roadless and wilderness
areas before descending onto developed areas and destroying private
property. In addition,
these fires destroyed thousands of acres of prime huckleberry habitat
essential to grizzly and black bears.
The soil legacy from decades of litter and organic layer buildup
on soils was destroyed on tens of thousands of acres exposing soils to
mass sheet erosion and polluting streams and Flathead Lake.
Smoke from forest fires has been proven as a significant source
on nutrient enrichment of Flathead Lake as well a nuisance and health
hazard. Particulate levels exceeded EPA recommended levels for
several days in the Flathead Valley in 2003 and resulted in several
warnings for people with respiratory problems to stay indoors.
Some of the continuing health risks are addressed in the World
Health Organization “Health Guidelines for Vegetative Fire Events.”
(WHO 2000). Continuing to
allow the deterioration of the Flathead National Forest may open the
door for violations under Clean Air Act.
People
generally do not understand that the vast forest areas in the Roadless
Inventory are not “natural”. In
the 15 to 20 thousand years since the last retreat of the glacier that
formed Flathead Lake, Native Americans “managed” the forest
ecosystem vegetation and fuel loads with purposeful burning if natural
fire ignitions did not do the job.
Humans worked in partnership with nature to control biomass
buildup, plant succession, and stand mosaics.
The influence of Native Americans was vastly reduced when Indian
populations were decimated to about 90% of normal by the time of Lewis
and Clark’s exploration due to the introduction of European diseases.
The huge fires of the late 1800’s and 1910 may have been
predisposed by a fuel buildup not unlike that which exists today due to
the reduced influence of humans on the landscape.
The
majority of task force members believe it is necessary to reduce fuel
loads and continuity of fuels in roadless areas where necessary by
making economic use of the excess biomass where possible rather than
waiting for costly and hazardous catastrophic fires.
It has been Flathead County’s experience that Roadless Area
Boundaries have been significant obstructions to doing what is necessary
to protect public health, safety and property.
Today,
litigation wary Flathead Forest Officials will not even propose a fuel
reduction project within a roadless boundary in the Mt. Hefty
inventoried roadless area, even though the County Fire Plan shows the
area to be within the Wildland Urban Interface.
The
Majority of Task Force members believe roadless boundaries should not be
a constraint in planning and implementing fuel reduction projects.
Recreation.
The majority of Task Force members believe access for motorized
recreation is just as important or even more important than timber and
roads. We have experienced
an incremental elimination of motorized access both within and outside
inventoried roadless areas over the last 20 years.
One of the most onerous has been the near elimination of
snowmobiling and off road motorized access to the few alpine ridges that
are not classified wilderness or other non-motorized areas.
Only two alpine ridges, the Whitefish Range and the North end of
the Swan Range, are presently available for multiple uses.
These are areas that offer the highest quality recreation
experiences.
A
Montana Wilderness Association lawsuit 15 years after the current Forest
Plan was approved has resulted in closure of about 400,000 additional
acres to snowmobiling, much of this on the alpine ridges where there has
been historic snowmobiling offering the best opportunities for some
enthusiasts. Only a few
designated trails and a few designated play areas are left open to
snowmobiling on the entire Whitefish Range on the Flathead National
Forest. These closures are
proposed to be carried over into the revised Forest Plan by the Forest
Service. A diverse
recreation economy needs more high quality diverse opportunities.
The rapidly growing and aging population has less leisure time
for recreation and they demand more motorized access not less in the
future. Working Flathead
County citizens have the lowest average wage in the Nation and many work
at more than one job in order to raise their total income somewhat
closer to the National average but still well below the national
average. People need to drive to their recreation and then go home.
Few have the time to walk or ski all day to get to a mountain
lake or view. These trends
are also reflected in the fact that only about 1.5 % of the total
recreation visits to the Flathead National Forest are in the Wilderness
areas comprising 50% of the Forest (Hall, Gary E., 2006.)
Wildlife.
The diverse and abundant wildlife resource of Flathead County is
one of our greatest world-class natural resource assets. The majority of task force members believe that active
management of the vegetation to maintain a diverse pattern of vegetative
age classes and cover types is better stewardship for sustained wildlife
production than the boom and bust cycles of catastrophic fires.
Forest cover needs to be maintained in densities that are not
predisposed to insect and disease attack and crown fires. Strategic
patterns need to be maintained that minimize probability of the whole
drainage being burned out at once.
Similarly diverse patterns of vegetation will provide the best
habitat for the most diversity of wildlife species.
Land managers know how to produce more winter forage on known
timbered winter ranges and how to increase huckleberry production in
higher elevation alpine fir and spruce stands.
Roadless inventory boundaries have effectively constrained
implementation of any wildlife habitat improvement practices.
Recent
satellite monitoring of 11 grizzly bears in the Swan Valley that
recorded individual bear locations every hour all summer of 2003
demonstrates that bears actually choose
to live in landscapes with roads and managed forests (Appendix A, Dr.
Chris Servheen Video, 7/19/2005). The
data shows bears avoid the roadless upper slopes of the Swan Front
Roadless area as well as the Bob Marshall and Mission Mountains
Wilderness areas and they even avoided “pristine” USFS sections in
the valley bottom. Instead,
the bears selected and heavily used adjacent and interspersed Plum Creek
Timber Company lands, all of which are densely roaded and harvested
timberlands. The data shows
grizzly bears prefer to use areas that are counted as “adverse” to
bears in Government cumulative effects analysis, and that the “core
security areas” required by the current Forest Plan are not even used
by any of these bears. Additionally, the data shows that the “maximum
road density” and “maximum open road density requirements” of the
US Fish and Wildlife Service and the Forest Plan do not define effective
habitat that bears will use. There
is no actual bear use of the “corridors” so defined by biologists as
critical to ensure that bears can get from the Mission Mountain
Wilderness to the Bob Marshall Wilderness.
The data shows that motorized access does not displace bears from
their habitat. There is
data available that shows that people on foot excite a more intense
alarm and flee response in animals than do motor vehicles.
The
majority of Task Force Members believe that reasonably managed motorized
access does not destroy any of the wildlife resources.
Access controls such as closures during spring breakup or other
adverse ground conditions, intermittent and seasonal closures, winter
range closures and closures of some roads, trails and areas to provide
specific local recreation opportunities, is just good multiple-use
management. Prohibiting
motorized access in large areas, while leaving a relatively small
percentage of the Forest available for multiple-use, is not in the best
public interest.
Timber.
Active management of our forest cover is the only component of
our ecosystem that we can manipulate for the benefit of the ecosystem,
the economy, and for public use and enjoyment.
A managed forest will not only pay for its treatments, fuel
management, road construction and maintenance, but it will generate
revenues to the treasury above costs which are shared with the counties.
A
University of Montana Study evaluated alternative treatments
effectiveness to reduce probability of crown fires (Fiedler, et. al.,
2001. A Strategic
Assessment of Fire Hazard in Montana).
The study used actual USFS timber inventory data, logging and
slash disposal costs, and market value for logs.
The study did not estimate a value for chipable non-sawlog
material or biomass for energy that is becoming more valuable.
Markets for this material would enhance money returns over that
estimated in the study. The
study concluded the most effective treatment on west side forests
produced a fire resistant stand structure that lasted for thirty years
and produced an average return in excess of $1000/acre over costs.
The
lack of implementation of strategic landscape scale treatments
recommended in the study is a major factor in the health and fire hazard
crisis in our National Forests, and the reason why the Healthy Forest
Restoration Act was passed. The
reason that most family owned sawmills in Montana and throughout the
west have been closed is because the Forest Service has reduced timber
sales to an insignificant level over the past 15 years.
Associated economic effects from the lack of federal timber
availability has led to the proposal for federal land sales or for the
taxpayers to fund the Secure Rural Schools Act for payments to counties
to make up for the lack of revenue from the forests, and it accounts for
the fact there is no road maintenance and a lack of road maintenance
funds.
The
majority of Task Force Members believe that active management of the
timber resource must be restored and where necessary extended into
mapped roadless areas. Many
fringe areas can be treated without the construction of permanent roads.
Temporary and winter snow roads are ephemeral and do not
permanently modify the landscape. Modern
forwarders and skyline systems can operate longer distances and on steep
slopes without significant disturbance.
We believe these options can be implemented on a site-specific
basis to achieve public benefits in a lot of the fringe areas inside the
roadless boundaries. We believe recommendations for blanket prohibitions within
existing roadless boundaries are not good stewardship of natural
resources or public assets.
Soil
and Water Resources. The majority of Task Force members believe that our
experience with the 35 years of cumulative effects of roadless area
non-management is evidence that severe damage will ultimately occur to
all the resources that roadless management is alleged to protect.
The roadless areas become reservoirs of insect and disease
infested trees. The optimal
insect breeding habitat exports millions of bugs into managed areas and
private lands. Eventually the high hazard fire fuel area will develop a
major fire and export the catastrophic fire, especially when fanned by a
wind event, destroying everything in its path.
After
a severe fire, trees become established and every year the trees add
organic material to the soil. On the average, a healthy conifer tree may retain 3-5 years
of needles. Each year needles, cones, twigs, and limbs are shed building
up a legacy of organic litter that protects the soil particles from
being dislodged by rain splash energy and from excessive solar radiation
and evaporation of soil moisture. Eventually
a decayed organic soil horizon is formed that provides a large
percentage of soil productivity, especially on our relatively poor
glacial till and alluvial sand and gravel soils.
In a managed forest the decades of organic legacy is
substantially retained. Even
where broadcast prescribed burning is done, it is done under burning
conditions where a lot of the litter layer is retained and nearly all
the organic soil horizon preserved.
Catastrophic fires burning excessive fuel loads under worse case
burning conditions destroy nearly all the litter layer and significant
areas of organic horizon legacy. We experienced these worse case conditions on many thousands
of acres within roadless areas in the past 5 years observing mass sheet
erosion plugging stream floodplains with several inches of silt, and
sending tons and tons of sediment into the North Fork Flathead River and
additional tons of nutrients
from smoke. We have seen
nearly all the old-growth cottonwood and riparian habitat along the
North Fork destroyed. Eighteen
years after the 1988 Redbench fire there is practically no vegetative
recovery in the area formerly occupied by old-growth cottonwood north of
Polebridge, MT.
Summary
and Recommendations: The
majority of the Flathead County Roadless Task Force believes Montana’s
Roadless petition should provide for maximum flexibility for alternative
management practices to be determined at the site-specific analysis
level where all the on-the-ground information on resources, soils and
topography and local public needs are studied in detail.
From our experience in Flathead County we see the roadless
inventory boundaries as significant barriers to implementing multiple
use management in some critical areas needed to care for the
environment, protect public safety and private property.
The Roadless Boundary invites litigation of every site-specific
proposal. After 35
years, we just don’t need any more study or litigation, we need for
those areas to produce some benefits for the public not just costs.
We emphasize the need for the petition to address all long term
management needs, not just immediate road needs.
Below are our recommendations for the Roadless Rule Petition as
specified by 36 CFR 294.14, and we urge the Flathead County Board of
County Commissioners to adopt and forward this recommendation to
Governor Schweitzer as Flathead Counties’ official input.
FLATHEAD
COUNTY MT 2005 ROADLESS RULE PETITION (36 CFR 294.14)
(1)
The location and description of the particular lands for which
this petition is being made are shown on maps and described in the
Flathead National Forest
Appendix C, attached.
(2)
The particular management requirements recommended below are
listed by the Flathead National Forest Appendix C Roadless inventory
number and name:
Benchmark (X1126)
Remain roadless for the present time with boundary adjustments to
exclude the suitable timber-base on the 1986 Forest Plan Map.
Le Beau (01507)
Remain roadless
Coal Ridge (X1127) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Dead Horse Ridge (X1128) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Standard Peak (X1128) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Mt. Hefty (01481) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Tuchuck (01482) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Thompson Seton ( 01483) Manage
for maximum flexibility for wildlife, recreation, timber production,
watershed and remove the roadless designation.
Bear-Marshall-Scapegoat-Swan
(01485)
(Skyland–Grant
Creek-Puzzle Creek Area [also referred to as
Skyland
Road Area]) Remain
Roadless excluding the suitable
timber-base as shown on the 1986 Forest Plan map.
Remaining areas:
Bear-Marshall-Scapegoat-Swan
(01485) ;Mission Additions (01500-0106); Swan River Island (LIFAA)
The
majority of Task Force Members recommends that the roadless boundaries
be modified to exclude all area shown as suitable for timber production
as shown on the 1986 Forest Plan Map, exclude all areas shown by
Flathead County Wildland Urban Interface map, and that the remaining
areas stay Roadless with flexibility for site-specific planning to
decide what management practices and recreation uses can occur within
the roadless lands in response to on-the-ground conditions and public
needs.
(3)
The identification of the circumstances and needs addressed by
the Petition: Flathead County has experienced several catastrophic
fires in the last 5 years that has cost taxpayers hundreds of millions
in firefighting costs and rehabilitation costs.
Flathead County taxpayers share an increased cost due to special
county levies, millions of dollars in lost revenues due to Glacier Park
closures, and decreased tourism revenues, health costs, and loss of
private property including several residences. Most
of the catastrophic fires started in roadless areas that have huge fuel
accumulations that permit the fires to grow to uncontrollable
catastrophic holocausts. Roadless
boundaries have proved to be significant barriers to motorized access
for fire suppression and well as the ability of the Flathead National
Forest to provide adequate motorized recreation access for a rapidly
growing senior population. Existing
roadless boundaries have proven to be effective obstructions (due to
litigation and threat of litigation) to implementing the current Forest
Plan designations for timber production over the last 20 years.
Flathead County has lost 2 family owned sawmills in that period
in large part because of lack of supply of logs from the Flathead
National Forest. The
“existing” roadless boundaries are relics of an inventory that was
initiated in 1972 RARE I and again in 1977 under RARE II.
The
roadless boundaries were drawn without regard to long term manageability
or public needs. With less
than 1.5% of current recreations visitors using existing wilderness that
comprise 50% of the Flathead National Forest, Flathead County needs
roadless areas comprising almost 25% of the Forest to have more
management flexibility for multiple use management than has been
permitted for the past 35 years.
The recommended management requirements in (2) above are
recommended to ensure establishment of a statuary direction to ensure
management flexibility will exist to address these long standing
barriers to protection and management of lands within and adjacent to
the roadless boundaries.
Conserving
Roadless area values: The
Flathead County roadless lands with the highest potential and
manageability for additions to existing wilderness will be maintained as
roadless by the recommended Management requirements in (2) above.
In the areas where continued roadless management does not serve
the needs of Flathead County, the Management requirements recommended
above will permit implementation of scientific practices to improve
conservation of wildlife, water and air quality, soil, timber, and
scenery as well as meet growing recreation needs.
Protecting roadless area values occasionally require the use of
heavy equipment to implement management practices and to fight fires
effectively. Modifying or
eliminated roadless boundaries and establishing statutory mandates to
insure implementation of these practices will result in a core area of
5,000 acres or more with no classified permanent road in every
inventoried area, simply because it is unlikely that there would ever be
a need for a road over the top of an alpine ridge that would bisect the
core. This would allow more
flexibility in meeting public health, safety, and recreation needs
within the current boundaries.
Protecting
Human health and safety: Existing
roadless area inventory boundaries have proved significant obstructions
to meeting public health and
safety due to combined effects of litigation and Forest Service policy
of trying to maintain wilderness values in roadless areas.
Roadless area values are best conserved by maintaining forest
health and protecting the forest with prompt, aggressive wildfire
suppression. Given
the existing fire hazard in roadless areas that have not yet burned, and
the fact that there is high probability of significant wind events in
late August and early September, it is simply too risky to let fires
burn in roadless areas.
Reducing
hazardous fuels: As
explained in Protecting Human Health and Safety above, and described in
the recommendations in (2) above ensure that a Roadless Inventory
boundary will not constrain or obstruct implementation of hazardous fuel
reduction project within the Wildland Urban Interface as defined by the
Flathead Wildland Urban Interface Map.
(Appendix B).
Restoring
essential wildlife habitats: In
the last five years, Flathead County has experienced huge losses of
essential wildlife habitats as a direct result of catastrophic wildfires
originating in and accelerated by unnatural fuel continuity within
roadless areas. Roadless area management policy constraints and
litigation have obstructed fuel reduction projects and fire fighting. As a result, it is even more imperative that roadless
constraints should be relaxed in the unburned portions of the North Fork
Flathead River roadless areas to permit habitat improvement projects
(especially stimulation of huckleberry production for bears as
prescribed by the existing Forest Plan).
Wildlife habitat improvement projects generally involve thinning
the forest canopy with the added benefit of hazardous fuel reduction.
Maintaining
existing facilities: There
are very few structural facilities within the mapped roadless areas.
Flathead County’s experience has been for motorized access to
be incrementally reduced in roadless areas that increases costs of
maintaining trail facilities as well as cabins, lookouts, etc.
The Flathead National Forest has proposed no motorized access
except in case of emergency for Mt. Hefty, Tuchuck, and Thompson Seton
Roadless areas in their Preferred Option for Forest Plan Revision.
Implementation of the recommendations in (2) above will ensure
that roadless boundary constraints will not impede or increase costs.
Providing reasonable access: Roadless boundaries have been a significant obstacle to
reasonable access to public land for Flathead County citizens.
We have experienced an incremental elimination of historic
motorized access both within and outside inventoried roadless areas over
the last 20 years. One of
the most onerous closures has been the near elimination of snowmobiling
and off road motorized access to the few alpine ridges that are not
classified wilderness or other non-motorized areas.
Only two alpine ridges, the Whitefish Range and the North end of
the Swan Range, are even available for multiple uses.
These are areas that
A
Montana Wilderness Association lawsuit 15 years after the current Forest
Plan was approved has resulted in closure of about 370,000 additional
acres to snowmobiling, much of this on the alpine ridges where there has
been historic snowmobiling offering the best opportunities for
enthusiasts. Only a few
designated trails and a few designated play areas are left open to
snowmobiling on the entire Whitefish Range on the Flathead National
Forest. These closures,
many of them site-specific in nature, are proposed to be carried into
the revised Forest Plan by the Forest Service.
A diverse recreation economy needs more high quality diverse
opportunities. The rapidly
growing and aging population in Flathead County has less leisure time
for recreation and they demand more motorized access not less in the
future.
Working
Flathead County citizens are among the lowest average wages in the
Nation and many folks work at more than one job in order to raise their
total income somewhat closer to the National average.
Flathead County workers are still well below the national average
in total wages (Appendix B, Flathead County Natural Resource Policy
/Custom and Culture Document). People
need to drive to their recreation.
Few have the time to walk or ski all day to get to a mountain
lake or view. These trends
are also reflected in the fact that only about 1.5 % of the total
recreation visits to the Flathead National Forest are in the Wilderness
areas comprising 50% of the Forest.
Day trips into the fringes of the wildernesses are becoming the
most common wilderness user (Appendix A, Gary E. Hall letter).
Implementation
of the recommendations in (2) above will ensure that roadless boundary
constraints will permit access needs to be determined on a site-specific
basis as needed to respond to on-the-ground conditions and public
demand.
Technical
corrections to existing maps: The
recommendations in (2) above recommend corrections in the existing maps
that will ensure that roadless boundaries that were drawn with no
consideration of public needs or benefits will be corrected to permit
some public benefits desired in the current Forest Plan to be achieved
in the future.
(4)
Description of
recommended management requirements differences from existing land
management plans and how they comply with applicable laws and
regulations: The
recommendations in (2) above, if implemented, would permit management
recommended in the current Forest Plan to be more effectively and
efficiently implemented by removing the incentive for tax-exempt special
interests
groups to litigate every project proposal that is proposed within the
mapped roadless boundaries. Our
recommendations would permit and even enhance the Agencies’ ability to
comply with existing laws and regulations by removing the requirement to
analyze roadless areas in project proposals.
(5)
Description of how the recommended management requirements
compare to existing State or local land conservation policies and/or
land and resource management plans:
The recommendations in (2) above would enhance the efficiency of
implementing Land and Resource Plans for Montana State Trust lands
managed by the Department of Natural Resources.
When intermingled State Trust lands are adjacent to a roadless
area boundary (e.g. Coal Creek State Forest border the Deadhorse Ridge
roadless area on the southern border, and the Coal Ridge roadless area
on the north). The fact that the adjacent Federal land is in the Roadless
Inventory makes access to State lands very difficult and expensive,
perhaps even impossible for some local areas.
The presence of the roadless boundaries means the Forest Service
will not likely grant a right-of-way through any corner of the mapped
roadless area even if it were the most efficient way to access the area.
Implementation of the recommended management requirements in a
Federal Rule would permit site-specific planning to work out reasonable
access without the constraints of a roadless boundary.
(6)
Descriptions of how the recommended management requirements
would affect the fish and wildlife that utilize the particular lands and
their habitat: Recent
satellite monitoring of 11 grizzly bears in the Swan Valley that
recorded individual bear locations every hour all summer of 2003
demonstrates that bears actually choose to live in landscapes with roads
and managed forests. The data shows bears avoid the roadless upper slopes of the
Swan Front Roadless area as well as the Bob Marshall and Mission
Mountains Wilderness areas and they even avoided “pristine” USFS
sections in the valley bottom. Instead,
the bears selected and heavily used adjacent and interspersed Plum Creek
Timber Company lands, all of which are densely roaded and harvested
timberlands. The data shows grizzly bears prefer to use areas that are
counted as “adverse” to bears in Government cumulative effects
analysis, and that the “core security areas” required by the current
Forest Plan are not even used by any of these bears. Additionally, the
data shows that the “maximum road density” and “maximum open road
density requirements” of the US Fish and Wildlife Service and the
Forest Plan do not define effective habitat that bears will use.
There is no actual bear use of the “corridors” so defined by
biologists as critical to ensure that bears can get from the Mission
Mountain Wilderness to the Bob Marshall Wilderness.
The data shows that motorized access does not displace bears from
their habitat. There is
data available that shows that people on foot excite a more intense
alarm and flee response in animals than do motor vehicles.
Elk herds in the Flathead Valley are at record populations.
The presence of roads, people, and dogs does
not seem to affect their productivity because a rich forage habitat
component is available.
The
recommended management requirements will permit wildlife habitat
improvement projects to be implemented that will increase habitat value
for most species including grizzly bear.
Large areas of dense forest cover with little or no forage
habitat is not good habitat for most wildlife species.
There will be opportunity to implement better protection from
insects, disease, and especially fire without the constraints and
litigation associated with a roadless boundary.
Habitat improvement is even more critical now that so much
huckleberry production and wildlife cover has been destroyed by
catastrophic fire in Flathead County.
(7)
Description of Public involvement in development of this
petition: All meetings
are open to the public with meetings scheduled on the Commissioner’s
Agenda posted at the Commissioner’s office and on the County Website. Time for public comments was provided at task force
meetings. Several comment
letters were submitted for input to the task force by members of the
public (See Appendix A). Members
of the public were present at each meeting.
State Senators Dan Weinberg and Greg Barcus co-chaired the
meetings with Commissioner Gary Hall representing the Board of
Commissioners. Recommendations
of the Task Force will be made available to the public.
A public hearing is part of the process for the Board of
Commissioners consideration of adopting the recommendations as Flathead
County recommendations to the Governor.
(8)
Commitment of Flathead County to participate as a cooperating
agency in any environmental analysis or rulemaking:
In November, 2004, Flathead County requested Cooperating Agency
Status for Flathead National Forest Plan Revision to which no response
has been received (Appendix B, Copy attached).
Flathead County would appreciate Cooperating Agency Status for
additional Rulemaking relative to roadless areas, as well as for the
Forest Plan Revision now underway.
Signed
this 28th day of February, 2006:
Doug
Denmark
Richard
Funk
John
Hansen
Fred
Hodgeboom
Robbie
Holman
Chuck
Roady
Ron
Stuber
