Response. The National Forest Transportation System infrastructure is vitally important to responsible management of the national forests. The transportation system is essential to many rural communities, and recreational use of classified roads is also important. The Department recognizes the effects of deferred road maintenance and reconstruction that have occurred in recent years. These deferrals are part of the reason the Forest Service is reexamining the role of roads and developing a new long-term transportation system policy. The interim rule is a temporary measure designed to maintain options for management of certain unroaded areas that are ecologically sensitive to help focus on managing the entire National Forest Transportation System. The agency's long-term transportation system policy will ensure that only necessary roads are constructed and that road maintenance and obliteration priorities are established through public involvement and use of other appropriate planning tools. This rule will have no effect on projects designed to obliterate or decommission roads.

Issue 11: Effects on timber supply. Many respondents believe that reduced timber harvest resulting from implementation of the interim rule will be detrimental to forest health and to the communities that depend on commodity extraction. They wrote about the legal mandate that national forests provide timber resources and suggested that the proposed interim rule will force consumers to use more imported timber products.

However, many individuals believe that placing the remaining unroaded areas off-limits to road construction, reconstruction, will not result in timber supply shortages. Instead, these reviewers suggested that the proposed interim rule will have a negligible effect on timber supply because private ownership and other National Forest System lands can meet the nation's needs.

Response. Production of timber volume from the National Forests accounts for less than 5 percent of the total volume of timber produced in the United States. Implementation of the interim rule may reduce timber harvest volume by 170 to 260 million board feet, which is less than 5 percent of the total volume estimated to be offered from National Forest System lands during an 18-month period. The final interim rule's effect on wood products imports, therefore, is expected to be negligible; less than 1 percent of current total wood fiber imports. Varying levels of substitution of timber from non-federal sources is expected across the country, which should prevent any significant national shortfall. The environmental assessment associated with the interim rule found no significant impacts to commodity production or impacts to communities. However, there are a few local communities, primarily in Idaho, where the amount of timber volume offered could be reduced more than 15 percent from levels initially planned.

Issue 12: Subsidies to commercial users. Many respondents said that road construction and reconstruction projects constitute a subsidy to logging companies and that such subsidies should cease. Some suggested that the 18-month suspension should be extended to ensure that additional public funds are not spent on such subsidies. Others wrote that the construction or reconstruction of purchaser-credit roads serves a larger purpose than to subsidize timber interests. They pointed out that roads facilitate public access to recreation resources, increase the agency's ability to administer programs and policies, and aid in preventing or suppressing wildfire.

Response. Road systems are vital to meet the access needs within each national forest. The 18-month suspension should provide adequate time for land managers to study the related issues and develop analytical tools and adopt a revised road management policy to ensure that road construction and reconstruction projects are useful, safe, environmentally sound, and cost efficient. Additionally, the Omnibus Appropriation Act for fiscal year 1999 eliminated purchaser credit. For these reasons, the Department finds no need to extend the interim rule beyond the 18-month period.

Issue 13: Access into or through unroaded areas. Many people were concerned that the proposed interim rule would preclude public access to recreational opportunities and industry access to national forest timber and other commodities; others suggested that it would deny or interfere with rights-of-way and jeopardize public safety.

Those citing reduced recreational opportunities cited the importance of roads in providing off-highway vehicle access to remote, pristine, scenic, or wilderness areas. Some argued that navigating undeveloped roads is a desired recreational activity. They wrote that road closures will lead to an overcrowding of available roads and trails, increased environmental consequences to a smaller land base, and a reduced quality of recreational experiences.

In contrast, many respondents referred to unroaded areas as national treasures that should be considered precious because they offer recreational experiences removed from the presence of machines. They wrote that too many of the remaining unroaded areas have been penetrated, leaving less and less land free of disruptive human activity. They suggested that increased motorized access will ruin important wildlife habitat and plant ecosystems and cause an increase in the occurrence of wildfire, poaching, and dumping.

Many others believe that timber harvest, mining, oil exploration, and other commodity extraction activities would be severely curtailed by the proposed interim rule. They wrote that without roads, resource extraction could not continue or would be significantly reduced, causing economic hardship for industry and small rural communities.

Response. The final interim rule does not alter the use of existing roads for multiple-use purposes nor does it limit activities that do not require the construction or reconstruction of roads in unroaded areas. Road construction or reconstruction in unroaded areas needed for legal rights-of-access will be provided in accordance with provisions of all applicable laws. Additionally, in response to public comment requesting exemptions for impending threat to life and property from flood, fire, insect infestation, or forest disease, paragraph (c)(4) has been revised to permit all such access for flood, fire, and other catastrophic events that, without intervention, would cause the loss of life or property.

Issue 14: Impacts to soil erosion, sedimentation, and fish. Many respondents cited timber harvest and the road construction associated with resource extraction as reasons for soil erosion, stream sedimentation, and declining fish populations. They mentioned poor engineering design, improper road placement, and degradation of existing roads as leading causes of these adverse effects. They consider roads to be harmful sources for sediment deposition in prime trout and salmon habitat. Many suggested that the proposed interim rule should become permanent policy. Generally, these respondents supported road obliteration, decommissioning, and reconstruction to mitigate soil erosion.

By contrast, some expressed a belief that roads and road construction are not the primary cause of soil erosion and that logging and associated activities, such as road obliteration, are the major causes.

Response. Science and history have shown that roads and road construction can have adverse effects on biological diversity, wildlife habitat, noxious weed infestation, soils, and watersheds. Poor engineering design, improper road placement, and the degradation of existing roads are all causes of soil erosion and sedimentation. For many wildlife and fish species, core habitat and genetic isolation are intricately tied to lands within the National Forest System.

Scientific evidence compiled to date suggests that, depending on their geologic setting and topography, roads are a significant source of increased erosion, sedimentation, and declining fish habitat. This evidence was an important consideration in formulating the proposed interim rule, as well as in publishing the advance notice of proposed rulemaking for the National Forest Transportation System. The final interim rule offers an important safeguard for protecting unroaded areas for 18 months or when a revised road management policy is adopted, whichever is sooner. Such policy will help ensure that possible environmental effects, including soil erosion and sedimentation, are more thoroughly evaluated before roads are constructed or reconstructed or decommissioned. For example, analytical tools will provide scientific information to inform the decisionmaker whether road decommissioning will produce additional disturbance or halt continuing disturbance.

Issue 15: Impacts from noxious weeds. Road construction and timber harvest are believed to increase the spread of noxious weeds. Respondents wrote that logging equipment and other motorized equipment introduce seeds into formerly pristine areas along roadbeds and in areas where resources have been extracted. Others expressed concern that noxious weeds on Federal lands will spread to adjacent private and State lands. On the other hand, some respondents suggested that limiting road construction may limit the ability of Federal and county agencies to manage the spread of noxious weeds.

Response. Invasion of noxious weeds was recognized as a problem in the preamble to the ANPR (63 FR 4350) and in the proposed interim rule. The Department believes that the suspensions established in the final interim rule provide a measure of safeguards to protect unroaded areas against invasion by noxious weeds until a revised road management policy for assessing the possible effects of road construction or reconstruction is adopted. Management of noxious weeds on the entire National Forest Transportation System will be made under the long-term transportation policy announced in the ANPR. In addition, the Forest Service has an established noxious weed policy intended to reduce the invasion and dissemination of noxious weeds to and from the national forests (FSH 2080).

Issue 16: Impacts to old-growth. Many respondents wrote that protection and preservation of old-growth ecosystems within unroaded and wilderness areas of the National Forest System is a good reason to implement the proposed interim rule and subsequent management policies. Others distinguished the proposed suspension of road construction and reconstruction from protection of old-growth, noting that insect, disease, and fire events naturally affect changes in the forest environment and make preservation of old-growth ecosystems problematic. In addition, they wrote that the absence of management plans for old-growth forests has created unhealthy stands that are thick with fuels.

Response. Protection of old-growth forests is not an objective of the proposed interim rule. Issues germane to management of old-growth ecosystems are most appropriately addressed in Regional guides, individual forest plans, and during project planning at the local level.

Issue 17: Impacts to wildlife and plants. Some respondents wrote that protection of plants and animals on undisturbed National Forest System lands should be the purpose of the interim rule and also should be incorporated into agency policy. They expressed a belief that survival of most forest species is ensured in unroaded areas and that an absence of motor vehicle noise, trampling of sensitive plants, littering, and excessive hunting would protect plants and animals. Others suggested that the Forest Service should better balance its management focus between mature and early successional species, placing less emphasis on those species dependent on wilderness and unroaded areas. They wrote that early successional forest management contributes to stratification and diversity among the many species that depend on young forests.

Response. The purpose of and need for the interim rule concerns roads and the problems associated with their construction and reconstruction. Issues related to protection and management of wildlife and plants are best addressed through the agency's established planning process, which includes land and resource management plans and project-level decisionmaking. However, the environmental assessment accompanying the final interim rule does evaluate the possible effects of its implementation on wildlife and plant species and concludes that those effects will be minimal.

Issue 18: Impacts on habitat fragmentation and wildlife corridors. Many respondents welcomed the proposed interim rule as a step toward protecting and preserving critical habitat for numerous species. These respondents wrote that protection of relatively undisturbed ecosystems would help maintain sufficient habitat for viable bird, fish, and animal populations and provide wildlife corridors. A few respondents noted that neotropical birds require contiguous forest cover, which occurs in unroaded areas, and that those species depend on such habitat to nest and reproduce. They wrote that large, pristine, and unmanaged areas maintain critical genetic diversity and species viability. Although many favored the proposed interim rule, they felt that the 5,000-acre guideline would exclude important habitat in the Eastern United States where unroaded areas tend to be smaller than those in Western United States. Some respondents disputed the need to mitigate ecosystem fragmentation, and others questioned the validity of analyses that consider home range or expressed doubt that roads are solely to blame for population declines or the demise of certain species.

Response. The maintenance and protection of large blocks of forest land to prevent habitat fragmentation and retain wildlife corridors is a short-term benefit of the interim rule. Long-term management measures to protect corridors and prevent fragmentation are evaluated in land and resource management planning documents and may be considered in the comprehensive revision of the long-term National Forest Transportation System policy announced in the January 28, 1998, ANPR (63 FR 4350).

Issue 19: Impacts on Threatened, Endangered, or Sensitive (TES) species. A number of comments reflected public awareness of TES species requirements. Many mentioned large predators and carnivores, focusing on the need to monitor and preserve grizzly bear and its habitat in the 48 contiguous States, the brown bear in Alaska, and large cats like the cougar and the lynx. Because neotropical birds are particularly susceptible to habitat fragmentation, some respondents wrote that the proposed interim rule would help increase and improve migratory corridors and critical nesting habitat for those species. Sedimentation from roads and fragmented drainages were blamed most often for the decline of trout, salmon, and other important fish populations. Numerous comments reflected a belief that the proposed interim rule recognizes species that have special interest to people and responds to this interest with increased habitat protection.

Response. The final interim rule does provide short-term assurance that unnecessary road construction will be avoided. This ensures that TES species that require habitats associated with unroaded areas are also better protected. Section 7 consultation with the Fish and Wildlife Service and the National Marine Fisheries Service has been completed for this interim rule. Additionally, when new and improved analytical tools are adopted and applied, protection of TES species will be integrated into those requirements.

Issue 20: Disregard for public involvement in planning. Many respondents wrote that the proposed interim rule would interfere with local forest planning where intensive collaboration and tough compromises have resulted in well-balanced management direction. Many expressed anger that a suspension of road construction and reconstruction would disregard their hard work and invalidate current forest plans. They were concerned that the proposed interim rule would undermine the trust and collaboration gained through effective forest planning. Some questioned the legality of ignoring the forest planning process in 36 CFR part 219 by means of a "top-down" administrative action. They asserted that the proposed interim rule ignores recent analyses conducted at the national forest and regional levels and that current plans have adequately assessed the possible effects of road construction and reconstruction.

Response. By providing exemptions for revised forest plans, the proposed interim rule recognizes and validates specific planning that has occurred through collaboration at the local level. The proposed interim rule does not alter or overturn land management prescriptions, guidelines, or standards contained in land and resource management plans; it merely defers some activities that might be implemented during the next 18-month period. The Department believes the integrity of the NFMA forest planning process has been protected and that the interim rule does not affect that process.

Issue 21: Insufficient public involvement. Officials from all levels of government, including Tribal, Federal, State, county, and local expressed concern about a perceived deliberate attempt to circumvent their authority and bypass the ongoing forest planning processes. Many believe that the authority of Congress and the will of the American people are not reflected in the proposed interim rule. They asserted that the proposed interim rule is a misguided attempt to appease special-interest groups at the general public's expense. Questioning the Forest Service's motives, a few respondents asserted that the agency is party to a broad, hidden agenda that would deny public access to public lands.

Response. The purpose of the interim rule was clearly stated in the Federal Register notice of January 28, 1998 (63 FR 4351). Given the widespread public interest in National Forest System management, the Forest Service gave advance notice of the proposal and invited comment. In response to requests from various individuals, organizations, and elected officials, on February 27, 1998, the agency extended the public comment period on the proposed interim rule for an additional 30 days. Additionally, the agency hosted 31 open houses receiving approximately 2,300 persons and 1,800 comments. Further, the agency will provide opportunity for public comment on revising the roads management policy which will replace the interim rule.

Issue 22: Availability of information. Many respondents wrote that the Forest Service inadequately distributed information to the public about its intent and did not provide sufficient time for meaningful public input to the review process. A number of individuals expressed dissatisfaction with local Forest Service officials' ability to answer questions or to provide more information about the proposed interim rule.

Response. The Department acknowledges that information on the proposed interim rule was not made available before publication in the Federal Register on January 28, 1998 (63 FR 4351). Facts used to support the proposed interim rule were published in an Appendix to that announcement (63 FR 4351, Appendix A - Facts About the National Forest Road System). Further information and reports were made available through the Internet. In response to public requests, the comment period was extended 30 days, and a schedule of open houses was announced in the Federal Register on February 27, 1998 (63 FR 9880). As part of that announcement, preliminary effects information was also made available to the public. Local officials were provided with this information to share with local public and special-interest groups. As evidenced by approximately 53,000 responses to the proposed interim rule, the Department believes sufficient public notice and involvement occurred.

Definitions. There was not a definition paragraph in the proposed interim rule.

Comment: Addition of definitions. Many respondents asked that the definitions of roads and roadless areas be included in the final interim rule. Most were concerned that existing unclassified, or "ghost" roads, would be considered as roads and thus eliminate areas where the suspension should apply. Others expressed concern that the trails they use for hiking, biking, and horseback riding would be characterized as roads, and that necessary maintenance and repair would not be done during the interim 18-month period.

Response. Because such definitions are critical to understanding which projects will be subject to suspension, the agency has added a new paragraph (a) Definitions. The terms "roads", "classified roads", "unclassified roads", "unroaded areas", and "RARE II areas" are defined. Definitions for "road construction", "road reconstruction", and "road maintenance" were not added because these terms are already defined in the Forest Service Manual (FSM 7705).

The term "roads" is used in the interim rule as a general term to mean a vehicle travel way over 50 inches wide. A road may be classified or unclassified. "Classified roads" are those that are constructed or maintained for long-term highway vehicle use. Classified roads may be public, private, or forest development. "Unclassified roads" are roads that are not constructed, maintained, or intended for long-term highway use. Unclassified roads include all temporary roads associated with fire suppression, timber harvest, and oil, gas, or mineral activities, as well as travel ways resulting from off-road vehicle use. Unclassified roads, including roads created by repeated public use and often used by off-road vehicles, do not disqualify an area for consideration as unroaded in the final interim rule.

The term "roadless" is used in the final interim rule in conjunction with areas already inventoried that have defined boundaries as established through forest planning, RARE II, or some other agency planning process. The term "unroaded area" is defined in the final interim rule and is used to characterize any area that does not contain classified roads, even if the area was not previously inventoried in RARE II or land and resource management planning.

The final interim rule will not obliterate or prevent the use of existing classified or unclassified roads. However, construction and reconstruction of unclassified roads in certain unroaded areas will be suspended as described in paragraph (b) of the final interim rule. Decisions regarding the management and use of such travel ways will be addressed through land and resource management planning and project-level decisionmaking, which require environmental analysis and public involvement.

Suspensions. Paragraphs (a)(1) - (5) of the proposed interim rule listed five categories of unroaded areas in which road construction or reconstruction would be suspended. First, the proposed interim rule would apply a temporary suspension of road construction and reconstruction in roadless areas of 5,000 or more acres inventoried in RARE II and in other unroaded areas identified in land and resource management plans. Second, the proposal would also suspend road construction and reconstruction in unroaded areas greater than 1,000 acres that are contiguous to congressionally-designated wilderness areas or contiguous to Federally-administered components of the National Wild and Scenic River System that are classified as "Wild". Third, suspensions would apply to all unroaded areas greater than 1,000 acres contiguous to roadless areas of 5,000 acres or more on other Federal lands. In addition, the suspension would apply to two other categories: (1) any National Forest System (NFS) areas of low-density road development or (2) any other NFS area that retains its unroaded characteristics which the Regional Forester subsequently determined have such special and unique ecological characteristics or social values that no road construction should proceed.

Comment: Size and type of areas where suspensions should apply. Many respondents disagreed that the proposed interim rule should apply only to unroaded areas that are 1,000 acres or more, suggesting instead, that no size limit should be imposed. These respondents proposed that the interim rule should apply to all roadless areas, regardless of size. Others stated that road construction and reconstruction should also be suspended in any unroaded area, not just those adjacent to inventoried roadless areas. A few respondents offered minimum size criteria, which ranged from 10 to 500 acres, to 100 square miles. Still others suggested that criteria might appropriately vary by region; for example, Eastern and Southern forests, which have smaller contiguous National Forest System lands than forests in the West, should have a smaller minimum size criterion. Many recommended that the suspension also should provide protection to unroaded areas that have not been inventoried. Some respondents felt that the suspension should apply to roaded portions of inventoried roadless areas that have been roaded since the inventory was done.

Response. The 5,000-acre limit described in RARE II was used as a criterion for wilderness suitability to define areas that could be effectively managed while providing visitors with an opportunity for solitude. This criterion was included in the proposed interim rule to clearly restate the acreage criteria used for RARE II delineations. The intention was not to limit suspensions to areas that are 5,000 acres or larger. Agency officials believe that the 5,000-acre criterion specific to RARE II areas is redundant and confusing and unnecessary. Therefore, paragraph (b) of the final interim rule omits this acreage limit.

The vast majority of all large blocks of roadless areas (5,000 acres or more) were inventoried in RARE II or forest planning. While some large blocks of National Forest System unroaded areas, in excess of 5,000 acres, have been created through land exchanges, purchases, road obliterations and other management actions, it is impractical and unnecessary to commission a new inventory of roadless areas at this time. Such inventories are appropriate at the forest planning level and regional assessment scales within the existing agency planning and decisionmaking framework. Therefore, road construction and reconstruction are not suspended in un-inventoried areas that are not contiguous to inventoried roadless areas.

Areas inventoried as roadless under RARE II or forest planning, but in which roads have since been constructed, no longer have the ecological and social values of roadless areas and, therefore, do not meet the same threshold of concern and need for protection. Therefore, in the final interim rule a one-quarter mile road influence zone has been added as a criterion for determining the remaining areas that will be considered unroaded and subject to suspension of road construction and reconstruction. An influence zone is an area on either side of a road where the effects on ecological process from the road are felt. Recent science suggests that a road influence zone may be as great as 1000 meters, in excess of one-half mile, away from the road. Other studies suggest a zone as small as 100 meters. For purposes of the final interim rule, the one-quarter mile limit was selected as an intermediate measure of road influence. The final interim rule states at paragraph (b)(1) that road construction and reconstruction will be suspended in remaining unroaded portions of RARE II and forest plan inventoried areas that are one-quarter mile or more beyond any classified road.

The suspension is intended to apply to roadless areas already inventoried and identified through the forest planning process (36 CFR part 219). The final interim rule does not call for a new inventory of roadless areas or compromise the local planning processes. It does, however, cover all unroaded portions of roadless areas inventoried in the forest plans, irrespective of size. The intent in establishing the one-quarter mile limit is not to encourage road construction or reconstruction within the one-quarter mile influence zone. However, it is anticipated that there will be no new road construction or reconstruction within the one-quarter mile influence zone.

The proposed interim rule did not contain an explicit provision to suspend road construction or reconstruction in unroaded areas contiguous to RARE II or contiguous to areas inventoried in land and resource management planning. Having considered the comments, this omission has been corrected. The final interim rule includes an explicit provision, at paragraph (b)(2), suspending road construction and reconstruction in unroaded areas greater than 1,000 acres contiguous to RARE II and forest plan roadless inventoried areas. This provision recognizes that these areas provide the same ecological benefits as areas contiguous to wilderness, Wild components of Wild and Scenic Rivers System, or unroaded areas of other Federal ownership. To qualify for suspension, these contiguous areas must have a considerable common boundary, provide an important corridor for wildlife movement, or significantly extend a unique value of the already inventoried roadless area. This condition is added to ensure that contiguous areas enhance ecological values of inventoried roadless areas. Without this condition, irregular shapes might be created that do not, in fact, significantly enhance the ecological values being protected.

Comment: Regional Forester's authority to designate special areas. Most respondents did not want Regional Foresters to have the authority to suspend road construction in areas thought to have unique ecological characteristics or social values. These respondents wrote that such authority would allow Regional Foresters "arbitrarily" to designate land as special or unique and thereby withdraw it from possible timber harvest. Many expressed a concern that, because special or unique attributes could be found on every acre of the National Forest System, unelected officials might eventually put all lands off-limits to natural resource management. Others, citing a need to protect remaining unroaded areas, wrote that Regional Foresters should use their authority under the proposed interim rule to prevent road construction.

Response. Paragraphs (a)(4) and (a)(5) of the proposed interim rule are not retained in the final interim rule because of the concern with how these procedures would be implemented with consistency and fairness. Additionally, further consideration of these paragraphs led to a conclusion that these provisions are unnecessary to accomplish the objectives of the interim rule, since Regional Foresters have authority to limit road construction or reconstruction without the interim rule.

Comment: Additional areas need to be protected. Some respondents asked that the final interim rule identify specific areas in which road construction and reconstruction would be suspended. Many respondents suggested specific areas they wanted to be protected by suspending road construction and reconstruction. These areas included those listed in the Southern Appalachian Area Assessment and other specific areas of special meaning to various respondents.

Response. Areas that have been inventoried through an established planning process with public involvement were considered for suspension under the proposed interim rule. For example, the preamble to the proposed interim rule (63 FR 4352) listed several areas that might warrant protective consideration under the Regional Foresters' authority, such as municipal watersheds that provide drinking water; habitat for listed or proposed threatened and endangered fish, wildlife, or plants; and areas listed in the Southern Appalachian Area Assessment, Social/Cultural/ Economic Technical Report (Report 4 of 5, dated July 1996). In response to these comments, the Department considered adding designated municipal watersheds and threatened and endangered species habitat to areas suspended but decided not to include these areas in the final interim rule because they are protected through existing environmental laws such as the Safe Drinking Water Act, Clean Water Act, and the Endangered Species Act.

Having considered the comments proposing additional unroaded areas that should be subject to the road construction and reconstruction suspension, the Department has decided to add areas listed in Table 5.1 of the Southern Appalachian Area Assessment as specific and unique ecological areas where road construction or reconstruction will be suspended. Those areas are included in current inventories and have been the subject of extensive public discussion, scientific analysis, and collaborative planning and thus merit special consideration before deciding to construct or reconstruct roads in them.

Comment: Scope of suspension. A number of respondents asserted that all road construction should be suspended, arguing that no additional roads are needed to manage the national forests and that the potential risks are more significant in heavily roaded areas than in roadless areas. These reviewers argued that if the purpose of the proposed interim rule is to allow the Forest Service time to develop improved analysis tools, those tools should be applied to all road construction throughout the National Forest System, not just to roads in unroaded areas. Many wrote that, to be equitable, national policy must be truly national in application. A few respondents asked that the final interim rule suspend all "destructive" activities, including grazing, mining, and oil and gas development. They wrote that unroaded areas are priceless because of their biological diversity, wildlife habitats, and spiritual values. Those whose livelihoods would be more directly affected by a suspension of road construction or reconstruction had a different view. They saw the proposed interim rule as a first step towards eliminating multiple-use and sustained-yield management of unroaded areas. Some wrote that the proposed interim rule is ". . . an attempt by special interests to lock up our National Forests to the public."

Response. The Advance Notice of Proposed Rulemaking (ANPR) and the proposed interim rule both addressed the need for a time-out while additional transportation planning tools are developed and a revised road management policy is adopted. Interim action is needed to ensure better roads management and planning, to help managers avoid causing irreversible damage to resources, and to help focus attention on comprehensive management of the entire National Forest Transportation System. This final interim rule is not intended to suspend decisions made more appropriately in the forest planning process. The purpose of the final interim rule is to retain resource options in unroaded areas and to safeguard those areas from the potential adverse effects associated with road construction and reconstruction until a revised road management policy is adopted. The potentially damaging ecological effects of a first entry into a unroaded area is often proportionately greater than the effects of similar construction or reconstruction in an already roaded area. By contrast, suspending all road construction throughout the National Forest System would be extremely disruptive to the ongoing management of lands and resources. Much road reconstruction is specifically designed to reduce environmental problems by relocating roads originally constructed in sensitive riparian areas, to improve road drainage and reduce erosion, and to improve safety and access. Curtailment of all such work would have greater ecological and social consequences than continuing current program activities in roaded areas. Therefore, the suggestion of suspending all road construction has not been adopted.

Comment: Applicability to construction of temporary roads. A number of respondents were concerned that temporary roads would be allowed during the suspension and indicated that the Forest Service should not allow this to happen.

Response. In the short term, temporary roads can create as great a risk of environmental damage as permanent roads. The proposed interim rule recommended temporary suspension of permanent and temporary road construction and reconstruction in unroaded areas of National Forest System land, with certain stated exemptions. This provision is retained in the final interim rule.

Exemptions. Paragraphs (b)(1) - (b)(4) of the proposed interim rule expressly exempted four categories of roadless areas from the temporary suspension of road construction and reconstruction:

1. Roadless areas within national forests that have a signed Record of Decision revising their forest plans and have completed the administrative appeal process as of the effective date of the rule;

2. Roadless areas within national forests that have a signed Record of Decision revising their forest plans on which the administrative appeal process is underway, but not completed as of the effective date of the rule;

3. Roadless areas in Washington, Oregon and California within those portions of national forests encompassed by the Northwest Forest Plan; and

4. Road construction or reconstruction in roadless areas needed for public safety or to ensure access to private lands pursuant to statute or outstanding and reserved rights.

Comment: Elimination of exemptions. Many respondents questioned the need for any exemptions to the interim rule. To support their arguments, they cited perceived instances of poor planning, an intentional exclusion of roadless issues from planning, and a lack of trust in local Forest Service officials. Many wrote about inadequate safeguards for protecting unroaded areas, insufficient scientific justification, and lack of credible forest planning processes. These reviewers said that exempting any national forest or planning area from the suspension will have a negative effect on lands they believe are already over-roaded and degraded.

By contrast, some respondents thanked the Forest Service for honoring the effort of national forest officials and their public partners to complete plan revisions. They felt that areas in which citizens have invested much time and energy to forge agreements and reach compromises should be exempt from the final interim rule. Many wrote that formal land management planning and appeals processes would be undermined by a "top-down national forest plan amendment" to suspend road construction in most roadless areas. A few suggested exempting all national forests that are in any stage of the planning process, and some were concerned that the interim rule would result in decisions that reverse management direction in revised land and resource management plans now under appeal without regard for the hard work of their communities. Respondents expressing this concern most often cited the Tongass Land and Resource Management Plan.

A number of respondents were concerned that a provision in the proposed interim rule to exempt forests of the Pacific Northwest and national forests with revised forest plans might be reversed in the final interim rule. These respondents believe that formal land management planning and appeals processes would be undermined if revised forest plans are not exempt from the temporary suspension of road construction and reconstruction in the final interim rule. This concern was often coupled with a general opinion that the Forest Service is disregarding valid processes for the development of land and resource management plans.

Response. The Department believes strongly that established planning processes should be honored and, therefore, the exemption for revised forest plans has been retained in the final interim rule. However, the most recent available science has not been incorporated into all revised forest plans. Therefore, the final interim rule includes a provision at paragraph (c)(1) that exempts only the most recent forest plan revisions, specifically those that have Records of Decision issued after January 1, 1996. The effect of this cutoff date is that unroaded areas within Virginia's George Washington National Forest are subject to the road construction suspension. The George Washington National Forest is the only forest that would have been exempted under the proposed interim rule but will not be exempted under the final interim rule.

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