USDA FOREST SERVICE
ROAD MANAGEMENT POLICY OF JANUARY 2001

Finding of No Significant Impact

Background

In January 2001, the U.S. Forest Service issued a final Environmental Assessment for the National Forest System Road Management Strategy (EA).  In this EA, the Forest Service examined the potential environmental impacts associated with the road policy (the “no- action” alternative) in effect prior to January 2001, the road management strategy as originally proposed in March 2000, and the final preferred road management strategy.  These impacts included potential adverse and beneficial impacts to access and public safety; fire, insect, and disease management; timber harvesting and mineral resource development; recreational and non-recreational land uses; fish and wildlife; wilderness values; watershed and air; and social and economic effects.

Previous Preferred Alternative.  On the basis of the EA, the Forest Service issued a finding of no significant impact on January 12, 2001 (66 FR 3219; January 12, 2001) that adopted the preferred alternative identified in the EA.  Specifically, the Forest Service adopted an administrative policy that would:  

•	Develop a comprehensive inventory of classified and unclassified roads that are important to the management and use of the National Forest System (NFS);

•	Give priority to decommissioning unneeded roads and reconstructing and maintaining the most heavily used roads rather than to constructing new roads;

•	Add roads to the transportation system only where supported by a science-based roads analysis; 

•	Make future decisions regarding proposed road construction, reconstruction, and decommissioning at the local level using a science-based roads analysis process that considers environmental and transportation needs and effects at multiple scales; and

•	Provide analysis guidance for construction of roads and reconstruction of existing roads within roadless areas until a roads analysis had been conducted and the results integrated into the applicable forest plan, consistent with a final Roadless Area Conservation Rule.

Under the January 2001 preferred alternative, each Forest System unit had to complete a forest-scale road analysis within two years of the effective date of the policy and an extension of this deadline could only be made by the Chief of the Forest Service.  The findings of a forest-scale roads analysis would be incorporated into the forest plan, either through amendment, revision or a determination that a revision was not necessary.  Further, any future project, ecosystem assessment, or forest plan amendment or revision must be informed by a roads analysis at an appropriate scale.  However, to avoid costly disruption, any project decision, ecosystem assessment, or forest plan revision published within six months of the effective date of the policy (i.e., July 12, 2001) did not require a roads analysis.

Until a comprehensive road inventory and forest-scale road analysis was completed and incorporated as appropriate into a forest plan (through a forest plan amendment or revision or the Forest Supervisor has made a written determination that the forest plan did not require amendment or revision to reflect the findings of the roads analysis), there would be a period during which decisions on reconstruction and construction of roads in inventoried roadless areas and unroaded areas contiguous to inventoried roadless areas required a demonstration of a compelling need and could be made only after completion of an environmental impact statement (EIS) approved by the Regional Forester. 

Compelling need was defined to include critical resource restoration and protection; road realignment needed to prevent resource damage by an existing road that is deemed essential for public or private access, or public health and safety, and where such damage cannot be corrected by maintenance; access needed to carry out a statute or treaty or pursuant to reserved or outstanding rights including access to locatable and leasable minerals; and restoration of wildlife habitat.  To the extent consistent with the Tongass National Forest Land and Resource Management Plan and all applicable laws, the Regional Forester for Region 10 had the specific authority to determine that a compelling need exists to provide for the multiple-use and sustained-yield of all renewable resources of the Tongass National Forest, including seeking to meet market demand for timber.

However, the procedures required during the interim requirements period (demonstration of a compelling need and completion of an EIS) did not apply to a proposal to construct or reconstruct a road in an inventoried roadless or contiguous unroaded area if the road were needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property; if the road was needed to conduct a response action under the Comprehensive Environmental Response, Compensation, and Liability Act or to conduct a natural resource restoration action; or if road construction was needed in conjunction with the issuance, continuance, extension, or renewal of a mineral lease on lands that were under lease by the Secretary of the Interior at the time the final Roadless Area Conservation Rule was issued.

Revisions of Preferred Alternative.  Upon adoption of the administrative policy and accompanying road management rule (66 FR 3206; January 12, 2001), the Forest Service began implementation training on the use of the science-based roads analysis process mandated by the revised policy and incorporated into the Forest Service Manual.  Further, in late January 2001, the Secretary of Agriculture began a review of the Roadless Area Conservation rule (also adopted on January 12, 2001) and directed the Chief of the Forest Service to undertake a review of the recently adopted road management policy.

In the course of the training and following the review of the road management policy, it became apparent that several modifications to the policy were needed.  The agency first issued an Interim Directive for Forest Service Manual 7710 on May 31, 2001, that extended the deadline by which roads analyses must inform road management decisions by six months, to January 12, 2002, and delegated to Regional Foresters the authority to approve on a case-by-case basis the deadline for a forest to complete a forest-scale roads analysis (Interim Directive 7700-2001-2).  The review also indicated that the following changes were necessary:

•	Remove contiguous unroaded areas from the interim requirements period provision because of the difficulty in identifying and mapping these areas and because existing forest plans identify inventoried roadless areas but do not identify contiguous unroaded areas.

•	Remove the requirement to prepare an EIS to consider proposed road construction and reconstruction in inventoried roadless areas because a blanket requirement for an EIS would result in needless expenditures of agency resources where only minor surface disturbances would occur.

•	Remove the interim requirements from Chapter 7710 of the Forest Service Manual dealing with transportation analyses, and relocate the remaining requirements to Chapter 1920 dealing with land and resource management planning.

•	Clarify the local responsible official’s discretion and flexibility to conduct roads analyses and provide examples of circumstances where roads analyses may not be necessary would be added.

It should also be noted that the Chief of the Forest Service issued two other Interim Directives emphasizing the importance of managing and protecting inventoried roadless areas as an important component of the National Forest System and reserved the authority to make all decisions regarding road construction and timber harvesting in inventoried roadless areas (Interim Directives 7710-2001-2 and 2400-2001-3, July 27, 2001).

Environmental Impacts.  The Forest Service does not believe that the proposed modifications to the road management policy affect the anticipated environmental impacts described in the January final EA.  Overall, under the January road management strategy, the Forest Service expected that more miles of roads would be decommissioned and reconstructed than under the “no-action” alternative and that fewer miles of roads would be constructed than under the “no-action” alternative.  Under the proposed Interim Directive to Forest Service Manual 7710, more miles of roads could be constructed or reconstructed in unroaded areas contiguous to inventoried roadless areas than expected under the final road management strategy, but still less than the miles of roads that would be constructed or reconstructed under the no action alternative.  Thus, the impacts of the modified road management policy would fall between the impacts described in the January EA for the “no-action” alternative and those described for the final road management strategy.  

Implementation of the final road management strategy as modified by the proposed Interim Directive would still result in additional protection of watersheds and air resources; wildlife; fish; and threatened, endangered, and sensitive species.  It would also reduce access to some forest resources and the economic and social values associated with those resources.  Because the impacts of the final road management strategy as modified by the proposed Interim Directive would fall within the impacts described in the final Road Management Strategy EA, there is no need to modify or reissue that document prior to making a decision on whether to issue the Interim Directive.

Reasons for Finding of No Significant Impact

In consideration of the analysis documented in the January EA and the reasons below, implementation of the final road management strategy as now to be modified would not constitute a major federal action that would significantly affect the quality of the human environment.  Therefore, an EIS will not be prepared.  This determination is based on the following reasons:

1.	The adoption of this modified road management policy will impose no on-the-ground effects and will not authorize any ground-disturbing activities.  Implementation of the modified policy will occur at the forest level, with appropriate NEPA analysis and documentation and public involvement undertaken at that time.

2.	The Forest Service has thoroughly evaluated both the beneficial and adverse effects (40 CFR 1508.27(b)(1)) and found them to be without significant impact.  The cumulative economic effects of the modified road management policy will be less than those estimated for the preferred alternative/final road management strategy in the January Road Management Strategy EA.  As stated in that EA, the impacts of the preferred alternative/final road management strategy are expected to be minor (see Appendix E) and are primarily related to a decrease in timber harvesting.  

3.	The Forest Service estimated that the eventual implementation of the preferred alternative/final road management strategy on all National Forests could result in an annual decrease in timber harvesting by as much as 170 million board feet, a decrease of 5 percent from current levels if no roads were constructed in any inventoried roadless or contiguous unroaded areas for the purpose of serving timber harvests.  This represents a value of approximately $23 million.  A decrease of this magnitude could result in a loss of approximately 1,039 jobs nationwide.  However, in the January EA, it was pointed out that this level of impact was highly unlikely. The modified road management policy would remove contiguous unroaded areas from the interim requirements, and thus it will be even more unlikely that these levels of impacts would be reached. 

4.	The environmental effects of implementing the modified road management policy on some resources such as wildlife; fish; threatened, endangered, or sensitive species; watershed; and air quality will be beneficial.  While the impacts of the modified policy on fire suppression and recreation will be both beneficial and adverse, the overall impact will be beneficial.  However, these beneficial impacts will not be significant due to their limited intensity.

5.	The modified road management policy will not significantly affect public health or safety (40 CFR 1508.27(b)(2)).  The modified policy does not authorize any ground-disturbing activities or direct changes to the environmental status quo.  Instead, the modified policy provides programmatic direction to be applied locally on the National Forests.  Revisions to forest plans and project-specific decisions will be made at the forest level, with appropriate NEPA analysis and documentation and public involvement undertaken at that time.  In addition, specific provisions for protecting public safety or to ensure access provided by statute or provided pursuant to reserved or outstanding rights have been provided (see Access and Public Safety).

6.	The modified road management policy will not significantly affect any unique characteristics of the geographic area (40 CFR 1508.27(b)(3)).  Similarly, it will not adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or cause loss or damage to objects listed in or eligible for listing in the National Register of Historic Places (40 CFR 1508.27(b)(8)).  
 
The EA includes a description of the impacts of the preferred alternative/final road management strategy on cultural resources (see Recreation, Heritage, and Wilderness Resources).  Neither the preferred alternative/final road management strategy nor the modified road management policy will alter the environmental protection afforded to sites of cultural or historic value that are protected under the Preservation of American Antiquities Act of 1906 or the Archeological Resources Protection Act of 1979.  Because the modified road management policy does not commit resources that would alter the unique characteristics of geographical areas, it is not significant.

7.	The modified road management policy will not involve effects to the quality of the human environment that are likely to be highly controversial (40 CFR 1508.27(b)(4)).  “Controversial” in this context refers to scientific controversy regarding the identification or extent of potential environmental impacts.  Public comments expressing disagreement with the EA pertained primarily to the level of economic effects from reduced timber harvest.  While there is no scientific controversy over the level of economic effects described in the EA or the methodology used for the cost-benefit analysis (see Appendix E), there is considerable public controversy over whether those effects are acceptable.  The cost-benefit analysis, performed using accepted economic principles and analysis tools, found that the national economic effects from reduced timber harvesting are minor.  Other environmental effects are without significant disagreement or scientific controversy.  The impacts of the modified road management strategy fall within the impacts described in the Road Management Strategy EA.  Controversy over the decision is not responsive to the significance criteria that would lead to the preparation of an environmental impact statement.  The analysis and results are not highly controversial.

8.  	The modified road management policy will not impose highly uncertain risks or involve unique or unknown risks (40 CFR 1508.27(b)(5)).  The best available information provided the basis for assessing the environmental consequences in the January EA.  The new action to modify the road management policy does not constitute any irreversible commitment of resources that are unique or any unknown risks.

9.	The modified road management policy will not establish a precedent for future actions with significant effects and does not represent a decision in principle about a future consideration (40 CFR 1508.27(b)(6)).  This action does not lead to any specific changes in forest plans or require any further inventory or analysis of wilderness or roadless area management.  

10.	The modified road management policy is not related to other actions with individually insignificant but cumulative significant impacts (40 CFR 1508.27(b)(7)).  The January EA disclosed the potential cumulative effects of the preferred alternative/final road management strategy with other ongoing and completed Forest Service activities and initiatives (see Cumulative Effects).  Although these initiatives had similar components such as road management in roadless areas, they are not connected actions.  The impacts of the modified road management policy will be less than those described for the preferred alternative/final road management strategy.  Based on this analysis, the Forest Service concludes that the effects will not be significant.  

11.	The modified road management policy will not adversely affect threatened or endangered species or habitats that have been determined to be critical under the Endangered Species Act (40 CFR 1508.27(b)(9)).  The Forest Service consulted with the U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS) in accordance with established requirements with regard to the January 2001 policy.  The EA reflected the results of these consultations (see Consultation section and Appendix H).  Since the agency’s modification of the road management policy retains the requirements for standards for rigorous analysis and consideration of threatened and endangered species, there are no changes that would affect the conclusions of USFWS and NMFS.  Site-specific projects undertaken to further the modified road management policy will be preceded by biological evaluations to review the potential effects to threatened, endangered, or sensitive species.

12.	The modified road management policy does not threaten to violate federal, state, or local laws or requirements imposed for the protection of the environment (40 CFR 1508.27(b)(10)).  In addition, adoption and implementation of the modified road management policy will not significantly affect the following elements specified in statutes, regulations, or Executive Orders regarding the human environment:  air quality; cultural resources; farm lands (prime or unique); floodplains; American Indian religious concerns; threatened, endangered, or sensitive species; hazardous or solid wastes; water quality; wild and scenic rivers; and wilderness.  The modified road management policy ensures access provided by statute or pursuant to reserved or outstanding rights (see Environmental Consequences).

Determination

On the basis of the information and analysis in the final Environmental Assessment for the National Forest System Road Management Strategy and all other information available, as summarized above, it is my determination that adoption of the modified road management policy would not constitute a major federal action that would significantly affect the quality of the human environment.  Therefore, an EIS is unnecessary.

/s/ Sally D. Collins for						10/09/01
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DALE N. BOSWORTH                                                                            Date
Chief, USDA Forest Service

Supporting record is available at: 
U.S. Forest Service
Engineering 
Rosslyn Plaza, Bldg. C
1601 N. Kent Street
Arlington, VA  22209