Apply suspensions to sensitive wildlife areas. Forest Service Manual 2670 provides direction pursuant to implementing section 7 of the Endangered Species Act (ESA). Forest Service policy is to implement objectives and actions to contribute to the recovery of listed species. Direction also is provided regarding consultation under ESA to ensure that Forest Service actions do not jeopardize the existence of any species or destroy or adversely modify critical species habitat designated under ESA. Forest Service policy is to ensure that species do not become threatened or endangered because of Forest Service action and to maintain viable populations as defined in National Forest Management Act (NFMA) regulations. The Forest Service prepares biological evaluations to determine an action's potential effect on sensitive species. Regional Foresters have the responsibility to identify sensitive species. An interim approach to protecting selected 1,000-acre areas would be inconsistent with, and not as biologically effective as, the continued emphasis on developing conservation strategies, assessments, and agreements. Developing conservation strategies, assessments, and agreements, on-going in every Forest Service region, contributes to species viability and mitigates the need to list species as threatened or endangered under ESA.

Apply proposed temporary suspension retroactively to road construction projects under contract. The Forest Service honors contracts and permits and believes that resources are best devoted to proactive policy development rather than extended debate over existing contract modifications. Environmental impacts from past activities will be addressed in the comprehensive revision of the long-term transportation policy.

Suspend all road construction on all NFS lands. Although suspending all road construction would be environmentally beneficial, such action would broadly extend the geographic scope of the proposal. This proposal is to preserve the resource options of unroaded areas from potentially adverse effects associated with permanent and temporary road construction and reconstruction while adopting a revised road management policy.

Make proposed temporary suspension permanent or indefinite. This action would extend the temporal scope of the proposed temporary suspension, which is to provide a safeguard while a long-term transportation system policy is developed. The question of permanent suspension of road construction is most appropriately left to the Agency's long-term transportation system policy under development.

Exempt significant forest plan amendments. Only one significant forest plan amendment was identified; the Winema National Forest proposed forest plan amendment for the Pelican Butte Ski Project scheduled for completion in fiscal year 1999. This forest plan amendment is already exempt as a part of the NWFP.

The estimated road miles for permanent and temporary road construction and reconstruction on all NFS lands (roaded and unroaded) used in this EA are for purposes of this analysis only. These estimates were not developed as a part of the formal processes used for budget planning, site-specific NEPA analysis, and on-the-ground project scheduling. They represent a one-time survey of field units of all possible road miles for an 18-month period. Adjustments have been made to the field data based on road projects over the 3-year period reflected in the fiscal year 1999 Presidential Budget.

The primary factor in estimating the effects of permanent and temporary road construction and reconstruction is the number of miles rather than the number of projects. Projects vary considerably in size and type and have been referred to in terms out outputs (e.g., volume of timber). The action suspends roads not projects. A direct relationship exists between permanent and temporary road construction and reconstruction miles and resource effects.

Although the mileage estimates are the most accurate information on permanent and temporary road construction and reconstruction on all NFS lands, they are constantly changing. Many of the estimated road miles will be altered or abandoned during planning and site-specific NEPA analysis, others will be delayed by appeals, litigation, and needed environmental information, some will be completed, and others will be added within the 18-month period. The 18-month period does not assume a start or end date. The estimates cannot be used, with precision or certainty, regarding effects on any specific national forest. The effects are characterized at national, regional, and sub-regional levels.

The estimates used in the EA should not be used to calculate revenues lost as cited under the provisions of P.L. 105-174, Section 3006, 1998 Supplemental Appropriations and Rescissions Act. When the final interim rule is published, specific implementation direction will be established to evaluate projects and determine the extent of the compensation needed for lost revenue.

Certain types of projects, such as special use permits and lands and minerals activities, are affected largely by forces outside the Forest Service. Private parties may propose new uses of NFS lands that are then considered by the Forest Service. Under all alternatives, each road project would be evaluated on a case-by-case basis to determine whether the proposed temporary suspension applies or if the project qualifies under an exemption. Table 4 and Figure 1 show the permanent and temporary road construction and reconstruction miles suspended, on NFS lands by natural resource purpose and alternative, during the proposed temporary suspension.

The following assumptions were made to estimate the effects of the alternatives.

Duration of effects. Although the proposed temporary suspension would last for a maximum of 18 months, some effects may last longer. Specifically, social and economic effects from suspended projects would occur over periods that may exceed the 18-month period. For example, timber from a suspended timber sale is assumed not to be harvested in 1 year, rather the volume is dispersed over 3 years (but the suspension period remains 18-months). This accurately reflects how timber sales usually progress when providing market and extends the economic effects over multiple years rather than one. When such assumptions are used in the analysis, they are discussed.

Projects may proceed without road construction. The analysis of effects assumes that planned projects involving road construction or reconstruction in unroaded areas of NFS lands would be suspended. However, once the final interim rule is effective, each unit will be required to evaluate all potentially affected projects (under the provisions of P.L. 105-174, Section 3006, 1998 Supplemental Appropriations and Rescissions Act) to determine if it can be implemented without the road work. For example, oil drilling in a unroaded area could be accomplished by transporting equipment by helicopter. In addition, some projects may involve unroaded areas of NFS lands subject to suspension and roaded areas not subject to suspension; this is common for timber sales that involve relatively large areas. In these situations, suspending the unroaded portion may require suspending the entire project if the roaded portion cannot proceed on its own. For discussion of timber sales in this analysis, a range of miles is provided with the lower value being the portion of the project within the unroaded area subject to suspension and the higher value being the entire project. Once the final interim rule is effective, each unit will evaluate any split projects to determine if the portion that is unaffected by the suspension can proceed.

Road reconstruction in unroaded areas of NFS lands. Depending on the road type, it is possible for road reconstruction to occur during the proposed temporary suspension. For example, when an unclassified road (Glossary) exists in an unroaded area or in a roadless area (Glossary) reconstruction could proceed. However, usually road reconstruction is for unclassified roads that require betterment, restoration, or realignment to alleviate a resource concern.

Under current management, permanent and temporary road construction and reconstruction is estimated to be 8,948 miles on all NFS lands and 534 miles in unroaded areas of NFS lands during the 18-month suspension period. Figure 2 shows the permanent and temporary road construction and reconstruction miles by Forest Service region that would be suspended under alternatives 2 through 6 on unroaded NFS lands. Figure 3 compares, by alternative, the permanent and temporary road construction and reconstruction miles that are estimated and that would be suspended on all NFS lands during the proposed temporary suspension. Figure 4 compares, by alternative, the permanent and temporary road construction and reconstruction miles that would be suspended on unroaded NFS lands during the proposed temporary suspension.

The following discussion addresses estimated permanent and temporary road construction and reconstruction miles in unroaded areas of NFS lands. Estimates are for an 18-month period and are for miles constructed or reconstructed, not acreage affected by projects. All existing contracts, permits, other instruments of authorization, and MOUs existing as of the effective date of the final interim rule would be exempt from the proposed temporary suspension. In addition, activities often associated with roads that can be accomplished without road construction (e.g., timber harvest by helicopter or from existing roads) would be unaffected. Routine maintenance of existing roads would be unaffected by all alternatives.

Alternative 2 - RARE II with exemptions. This alternative would temporarily suspend an estimated 207 miles of construction and reconstruction in unroaded portions of inventoried RARE II areas and areas inventoried in forest plans that lie one-quarter mile of more beyond any classified road. This involves an estimated 72 miles (35% of the total miles for alternative 2) of road construction, 69 miles (33% of the total miles for alternative 2) of reconstruction, and 66 miles (32% of the total miles for alternative 2) of temporary road construction. The most miles affected under this alternative would be in Region 8 (37% of the total miles for alternative 2), Region 4 (20% of the total miles for alternative 2), and Region 1 (18% of the total miles for alternative 2). The majority of estimated permanent and temporary road construction and reconstruction miles temporarily suspended under this alternative are for forest management (timber) purposes.

Alternative 3 - Proposed action. This alternative would temporarily suspend an estimated 243 miles of permanent and temporary road construction and reconstruction. This involves an estimated 78 miles (32% of the total miles for alternative 3) of road construction, 75 miles (31% of the total miles for alternative 3) of reconstruction, and 90 miles (37% of the total miles for alternative 3) of temporary road construction. The most miles affected under this alternative would be in Region 8 (31% of the total miles for alternative 3), Region 4 (17% of the total miles for alternative 3), and Region 1 (16% of the total miles for alternative 3). The majority of permanent and temporary road construction and reconstruction miles temporarily suspended under this alternative are for forest management (timber) purposes.

Alternative 4 - Broadest safeguards. This alternative would temporarily suspend an estimated 461 miles permanent and temporary road construction and reconstruction. This involves an estimated 213 miles (46% of the total miles for alternative 4) of road construction, 92 miles (20% of the total miles for alternative 4) of reconstruction, and 155 miles (34% of the total miles for alternative 4) of temporary road construction. The most miles affected under this alternative would be in Region 10 (35% of the total miles for alternative 4), Region 8 (20% of the total miles for alternative 4), and Region 4 (10% of the total miles for alternative). The majority of estimated permanent and temporary road construction and reconstruction miles temporarily suspended under this alternative are for forest management (timber) purposes.

Alternative 5 - RARE II without exemptions. This alternative would temporarily suspend an estimated 401 miles of permanent and temporary road construction and reconstruction. This involves an estimated 201 miles (50% of the total miles for alternative 5) of road construction, 75 miles (19% of the total miles for alternative 5) of reconstruction, and 125 miles (31% of the total miles for alternative 5) of temporary road construction. The most miles affected under this alternative would be in Region 10 (40% of the total miles for alternative 5), Region 8 (23% of the total miles for alternative 5), and Region 4 (10% of the total miles for alternative 5). The majority of estimated permanent and temporary road construction and reconstruction miles temporarily suspended under this alternative are for forest management (timber) purposes.

Alternative 6 - Preferred alternative. This alternative would temporarily suspend an estimated 262 miles of permanent and temporary road construction and reconstruction. This involves an estimated 81 miles (31% of the total miles for alternative 6) of road construction, 78 miles (30% of the total miles for alternative 6) of reconstruction, and 102 miles (39% of the total miles for alternative 6) of temporary road construction. The most miles affected under this alternative would be in Region 8 (33% of the total miles for alternative 6), Region 4 (17% of the total miles for alternative 6) and Region 1 (16% of the total miles for alternative 6). The majority of estimated permanent and temporary road construction and reconstruction miles temporarily suspended under this alternative are for forest management (timber) purposes.

Figure 5 shows the permanent and temporary road construction and reconstruction miles that are estimated under alternative 1 on all NFS lands. Figure 1z shows permanent and temporary road construction and reconstruction miles on unroaded NFS lands suspended under alternatives 2 through 6 by natural resource purpose.

Public safety would be unaffected under any of the alternatives. For new general access the effect of the proposed temporary suspension would be negligible under all alternatives. In addition, the differences between alternatives are minimal.

Access is the opportunity to enter NFS lands for personal and reasonable use of other lands and rights within the NFS lands. The National Forest Transportation System, approximately 373,000 miles of roads, includes 23% arterial or collector roads, that serve all users and 57% local roads, that are typically passable by high-clearance vehicles. Access to the remaining 20% of these roads is restricted by gates or other methods. An estimated average of 1.7 million vehicles per day use the National Forest Transportation System. Additionally, 15,000 commercial vehicles associated with timber harvesting and the development of other resources use the system daily. An estimated 9,000 Forest Service vehicles drive system roads daily to accomplish a variety of administrative tasks such as fire suppression, contract administration, resource projects, and law enforcement. Where the primary purpose identified for road construction and reconstruction is for access, the action will probably involve repair of NFS roads damaged by flooding in 1997 and 1998.

Permanent and temporary road construction and reconstruction on all NFS lands for general access during the proposed temporary suspension is an estimated 859 miles of road reconstruction, 19 miles of road construction, and less than a mile of temporary road construction. Permanent and temporary road construction and reconstruction miles on all NFS lands for public safety during the proposed temporary suspension is an estimated 36 miles of road reconstruction, 7 miles of road construction, and less than a mile of temporary road construction (table 5).

The effects of the alternatives on general access range from no impact under alternative 1 to less than 1% of access miles suspended under alternative 4 on all NFS lands during the 18-month temporary suspension period. An exemption applies to public safety under all alternatives, therefore, it would be unaffected.

Alternative 1 - Current management. Under this alternative, permanent and temporary road construction and reconstruction for the primary purpose of general access is estimated to be 7 miles in unroaded areas of NFS lands. No miles were identified specifically for the primary purpose of public safety in unroaded areas during the 18-month suspension period. General access provided by permanent and temporary road construction and reconstruction in unroaded areas of NFS lands would be unaffected under this alternative.

Alternatives 2, 3, and 6. Less than 1% of the estimated road construction and reconstruction identified for the primary purpose of general access would be suspended under these alternatives on unroaded areas of NFS during the 18-month suspension period. No temporary road construction would be suspended. There would be no effect on general public safety due to the exemption applied under all alternatives.

Alternative 4 and 5. Less than 1% of the estimated road construction and reconstruction identified for the primary purpose of general access would be suspended under these alternatives on unroaded areas of NFS during the 18-month suspension period. No temporary road construction would be suspended. These alternatives differ from alternatives 2, 3, and 6 by suspending of 1 additional mile of road reconstruction. The effect of the proposed temporary suspension on general access would be negligible at Forest Service regional and national levels. There would be no effect on general public safety due to the exemption applied under all alternatives.

Approximately 40 million acres of all NFS lands are at abnormally high risk of catastrophic fire, disease, and insect outbreaks. In 1997, the Forest Service treated 286,000 acres by commercial thinning and salvage using timber sales. Under current management, many acres will likely burn or be subject to insect attack before they can be treated. The Forest Service plans to treat approximately 514,000 acres in 1998 and 1999. A maximum of 15,000 acres have been estimated for treatment in unroaded areas of NFS lands during the 18-month suspension period, which is 3% of the need on all NFS lands. There is a greater need for treatment than can be accomplished across NFS lands each year. Any reduction of forest health projects in unroaded areas of NFS lands would likely be balanced by increased forest health projects in roaded areas.

Some of the projects that would be affected by the proposed temporary suspension are intended to improve forest health. These include thinning, salvage, or regeneration to restore forests affected by fire suppression to less fire prone conditions. Without such treatments, the risk of catastrophic wildfire and local insect and disease epidemics could be high for some areas.

Roads provide access for fire suppression forces and equipment and for human-caused fire. Road development often increases the risk of human-caused fires by increasing exposure of fuels to human activities. Human-caused fires occur frequently in areas served by roads; however, these fires are sometimes more easily suppressed because of the road access. With an existing road system estimated at 373,000 miles, a variation of a few hundred miles would not have an appreciable effect on initial suppression effectiveness due to alternative firefighting strategies. In addition, because prescribed burns (fires ignited by management actions to meet specific objectives) rarely involve road construction or reconstruction, they would be unaffected by the proposed temporary suspension. Initial suppression strategies for fire suppression depend on the presence or absence of roads. The use of aerially delivered fire fighters into unroaded areas of NFS lands is often as effective as conventional fire truck suppression in roaded areas.

Federal fire policy recognizes the benefits of landscape-scale wildland fire including prescribed fire. Prescribed fire is independent of roads as alternatives exist that are often more effective and less costly; for example, natural features and short-term fire break construction. The marginal benefit of new road construction and its ancillary increased human exposure is insignificant when viewed in light of alternative suppression strategies.

In 1997, more than 1 million acres of hazardous fuels were treated. In 1998, 1.2 million acres will be treated. This effort is estimated to increase to an average of 3 million acres per year on a continuous, rotational basis. All these acres can be treated without roads. The physical conditions that predispose forests to catastrophic fire, such as overly dense stocking, large continuous amounts of volatile fuels, and severe fire weather, greatly exceed the impact of the roads system.

At the local level, the short-term risk of insect epidemics is highest in the South, while the risk of catastrophic fire is highest in the Intermountain West and California. Conifer forests of Idaho, Colorado, eastern Oregon, and the Sierra Nevadas often juxtapose severe fire risk with residential development in the wildland/urban interface. Across the Coastal Plain and Piedmont, southern pine beetle populations are building to epidemic levels, but the Talladega National Forest in Alabama is particularly affected by the southern pine beetle.

Alternative 1 - Current management. Under this alternative, temporary road construction for fire suppression is estimated to be 6 miles in unroaded areas of NFS lands during 18-month suspension period. There are no permanent road construction and reconstruction miles estimated because forest health treatments in unroaded areas of NFS lands may be offset by treating roaded areas. The proposed temporary suspension would not appreciably affect the health of NFS forests from a national perspective.

Alternative 2 through 6. Homes are being built in wildlands. This is called the wildland/urban interface. Priorities for forest health and fire treatments tend to be in interface areas, which tend to be more roaded. Nationwide, there are more opportunities for forest health and fire treatment than there are funds available. The suspension of permanent and temporary construction and reconstruction on forest health and fire treatment in unroaded areas by alternatives 2 through 6 would likely cause the work to be accomplished in unroaded areas to shift to roaded areas. There would be a slight disruption in the forest health and fire treatment programs as work is redirected from unroaded areas to roaded areas.

Where fuel loading is high under alternatives 2 through 5, in unroaded areas of NFS lands scheduled for salvage logging or fuel treatment, suspension of permanent and temporary road construction and reconstruction for these projects could increase the risk of catastrophic wildfire in some areas in the absence of alternative protection strategies. Prescribed burning rarely involves road construction or reconstruction. Local units have fire suppression strategies and technology that provide appropriate and timely protection for unroaded, high-risk areas allowing a small increment of increased risk. Therefore, there are protection strategies available that minimize the risks.

Fire risk in the Intermountain West and in the increased insect risk in the Coastal Plain, Piedmont and Alabama along with localized impacts are mitigated under an alternative 6 exemption in unroaded areas within NFS where there is a need to address an imminent threat of flood, fire, or other catastrophic event that, without intervention would cause the loss of life or property.

The risk of untreated beetle activity is also increased where there is spread to adjoining private land resulting in loss of valuable timber, wildlife habitat, and forest cover. The FS conducts insect and disease surveys throughout the country. By using the insect and disease survey under the preferred alternative exemption to address an imminent threat of flood, fire, or other catastrophic event; specific areas could be identified for treatment that without intervention would cause the loss of life or property.

Timber sales are used to achieve vegetation management objectives. These objectives include providing a sustainable yield of forest products to meet the nation's demands, and restoring, improving, and maintaining forest ecosystem health. Timber sales are often used as a least-cost method to manage vegetation for improving wildlife habitats, reducing fuels that may increase fire risk, recovering value from natural disasters, combating insect and disease infestations, and improving tree growth. Table 6 shows the national trends in the NFS timber program.

Roads are generally required for timber harvest. Some timber sales can be harvested using helicopters or cable-yarding systems from existing roads. Use of these methods depends on the value of the timber being removed, the terrain, and the distance to an existing road. Each timber sale contract specifies the yarding method and any permanent and temporary road construction and reconstruction required. Timber purchasers may be required to complete needed road reconstruction to ensure public safety and to protect the environment from logging traffic. Roads that the Forest Service has determined are needed for future multiple-use management are constructed to meet road specifications and retained for future use after the timber sale. Temporary roads are constructed only for the duration of the timber sale. Even though a sale may require helicopter logging, some road reconstruction may be needed and temporary road construction may be required.

Public comments about the timber sale program focused on delays in the amount of timber offered for sale and the resulting effect on jobs, income, payments-to-states, timber supply, imports, and other economic considerations (Economics and Appendix D).

United States wood consumption would be unaffected by the proposed temporary suspension. The reduction in timber sale offerings because of the proposed temporary suspension would eventually result in a minor reduction in national forest timber harvest. The effect of this reduction would depend on the local relationship between national forest timber sales and local supply and demand. There would be ample opportunity to substitute timber from other ownerships to replace most of the reduction in national forest timber sales in the eastern United States. In the West, substitution opportunity is limited, any volume that could not be substituted from other United States ownerships could probably be met by Canadian imports. The reduction in national forest timber volume sold from more than 11 billion board feet in 1987 to 3.4 billion board feet in 1996 was offset by an increase in Canadian imports and private-land harvesting. Since 1991, softwood lumber imports from Canada have increased from 10.5 billion board feet to 17.8 billion board feet, and United States softwood consumption of Canadian imports has increased from 27% to 36%. The impact is small without a marked change in total number of imports from Canada; therefore, the effect to the Canadian environment is insignificant.

The Forest Service estimates the amount of timber to be offered for sale at a given budget level each fiscal year. A timber sale generally requires several years of preparation from identification of the need until final sale offering. During this time, the sale must meet all legal requirements including those mandated by NFMA and NEPA.

The timber volume affected by the various alternatives is based on the annual estimate of capability, considering budget constraints, and on the stage of the timber sale preparation process. Each national forest has an estimate of the allowable sale quantity that establishes a ceiling on the timber harvest for that forest. However, forests frequently do not achieve the allowable sale quantity because of budget limitations and conditions that have occurred since their allowable sale quantities were determined. In addition, estimated volumes are based on timber sales currently in the planning phase; therefore, there is no guarantee that the estimated volume for sale would be the actual volume for sale. Appeals and litigation can also cause delays in timber sale offerings. These factors were considered when estimating the potential suspension in timber volume offered for sale under the various alternatives. The volume estimates are based on estimated sales for an 18-month period, but these sales are not actually scheduled.

Table 7. Low and high range of timber volumes offered for sale, by alternative, that would be suspended during the proposed temporary suspension of permanent and temporary road construction and reconstruction in unroaded areas of the National Forest System land.

^a Values in million board feet.
^b Values in miles.

Alternative 1 - Current management. Under this alternative, 375 MMBF of timber would be offered for sale requiring 46 miles of reconstruction, 183 miles of construction, and 136 miles of temporary road construction in unroaded areas of NFS lands during the 18-month suspension period. This alternative represents a timber sale program for a typical 18-month period. Based on the estimated fiscal year 1998 timber sale program and the fiscal year 1999 budget request, 5.44 billion board feet of timber would be offered for sale during a typical 18-month period. Approximately 3,654 miles of road reconstruction, 649 miles of road construction, and 1,652 miles of temporary road construction would be required to harvest this volume on all NFS lands during the 18-month suspension period.

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