IMBA's Comments On The Draft EIS And Proposed Rule For Roadless Areas Conservation - 2000

July 13, 2000

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

Dear Forest Service,

The International Mountain Bicycling Association generally supports the Forest Service Roadless Area Conservation Initiative because we oppose road construction in the inventoried roadless lands of national forests. However, because the various Prohibition alternatives differ only in the amount of logging they allow, and IMBA does not have a policy regarding logging, we don't have a position on which one of the Prohibition alternatives should be adopted. We do not support the No Action Alternative. IMBA supports the Roadless Initiative because it will protect natural, undisturbed areas and bicycling opportunities.

The Draft Environmental Impact Statement confirms our contention that Roadless Areas provide optimum primitive and semi-primitive dispersed recreation opportunities. Roads are typically built in national forests to support logging, mining and other industrial activities, or to access inholdings. These activities degrade the wild nature of forest land, and thus degrade the quality of mountain bicycling experiences. To some extent, this discourages visitation and hurts tourism. The DEIS notes (page 3-122) that the demand for primitive and semi-primitive types of recreation is increasing, while the supply is diminishing. Action Alternatives Two through Four will maintain a higher level of supply of lands suitable for such recreation.

Regarding the procedures to consider and possibly protect unroaded lands of 1,000 to 5,000 acres, we support Procedural Alternative D, rather than the Forest Service preferred Alternative B. The preferred alternative would not protect any of the smaller, unroaded lands until forest plans are completed for each forest. Because many of the forests of the West Coast are not due for revision until late in this decade, considerable amounts of unroaded land could be developed, further diminishing the supply of a vital resource. Alternative D would bridge the gap by considering unroaded values on a project-by-project basis until a forest plan is completed.

IMBA is concerned about the exceptions to the road building prohibition, which would allow 368 miles of non-timber related road construction and reconstruction in the next five years. This represents more than half of the non-timber road miles that would be built under the No Action Alternative, and is one fourth of the total miles that would be built under the No Action Alternative. The DEIS poorly explains this continued road building program and offers no detail as to where or why is might be necessary. IMBA would prefer to see the exceptions narrowed as much as is legally possible.

Thank you for your consideration of these comments.

Sincerely,

Gary Sprung
IMBA Communications Director