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January/February 2002. Volume 7 # 0

The Quarterly Newsletter of Wildlands Center for Preventing Roads

Inside… Down the Road…. Page 2 ORV Monitoring in Montana. Page 3-5 Depaving the Way: A Tale of Two Roads, by Bethanie Walder. Page 6-7 Policy Primer: The “Existing Routes Exception.” Page 8-9 Odes to Roads: The Landscape of Desire, by Greg Gordon. Page 10-11 Biblio Notes: Evaluation Of Wildlife Crossing Structures, by Maureen Hartmann. Page 12-14 New Resources. Page 14 Regional Reports & Updates. Page 15 Legal Notes: The Forest Service and Categorical Exclusions, by Jim Bensman. Page 16-17 Activist Spotlight: Brian Scherf, Page 17 Around the Office. Page 18 Resources & Membership. Page 18-19

Mount Cowan, in the Absaroka-Beartooth Wilderness. A trail just to the east of this peak is often used illegally by motorcycles trying to cut through the wilderness. — Phil Knight Photo.

Check out our website at: www.wildlandscpr.org

Off-Road Vehicle Monitoring in Montana Many groups in Montana were out in the field this summer documenting ORV and user created route damage from escalating ORV use and abuse and ground-truthing the effects of the new Forest Service Tri-State OffHighway Vehicle Plan (Montana, North Dakota, South Dakota). Here are their summaries.

— See article on page 3 —

A Look Down the Road… Whether it’s roadless protection or new “restoration” plans (more realistically known as salvage sales), the Bush Administration is doing its best to circumvent the public process and existing environmental laws. In mid-December, the Forest Service took yet another hatchet to what minimal protection for roadless areas still remained. Forest Service Chief Dale Bosworth issued a directive that effectively circumvents the National Forest System Transportation Policy protections for roadless areas. With this Bosworth directive, the Bush Administration and its players may nullify the effort by the previous administration to protect roadless areas. But there is one thing Bush doesn’t seem to want to acknowledge: Those efforts were not undertaken because Clinton was such a big fan of roadless areas, but because the American public wants roadless areas protected. Bush, Secretary of Agriculture Ann Veneman and Bosworth can undercut these policies all they want, but that won’t stop the American public from speaking up and speaking out to protect our public lands. And sooner or later, Bush is going to have to pay attention to the American people. In this issue of the Road-RIPorter, we provide you with some new and helpful information to use to ensure that your government is following it’s own laws. To continue the theme of public process gone awry, our “Legal Notes” section includes a thorough explanation of the Categorical Exclusion (CE) process and an update on the status of a current case challenging the abuse of CEs. The newsletter opens, however, with a cooperative article that highlights the multi-tiered monitoring and documentation efforts going on in Montana. The importance of these monitoring efforts are made clear through our new “Policy Primer” section. In it, we highlight the extremely insidious practice of allowing off-road vehicle use to continue on existing, unauthorized routes. Much of the Montana monitoring was designed to collect just this type of information. (And though this issue does have two features about Montana in it, do not fret, we continue to be an organization with a national perspective and we will continue to cover articles from all over the country. Nonetheless, it had been a long time since we promoted the excellent work of the folks in our own backyard.)

Wildlands C Center for P Preventing R Roads Main Office P.O. Box 7516 Missoula, MT 59807 (406) 543-9551 [email protected] www.wildlandscpr.org Colorado Office — Jacob Smith 2260 Baseline Rd., Suite 205 Boulder, CO 80302 (303) 247-0998 [email protected] Wildlands Center for Preventing Roads works to protect and restore wildland ecosystems by preventing and removing roads and limiting motorized recreation. We are a national clearinghouse and network, providing citizens with tools and strategies to fight road construction, deter motorized recreation, and promote road removal and revegetation. Director Bethanie Walder Development Director Tom Petersen

The remainder of the newsletter centers on a different theme — sprawl and mitigation. DePaving the Way looks at some of the biodiversity costs of sprawl, and provides a curious comparison of the drastically different planning/mitigation efforts used during the expansion of a road in western Montana. The mitigation theme also appears in both the Odes to Roads essay by Greg Gordon and the excellent Bibliography Notes about mitigation structures by Maureen Hartmann. And finally, to bring things full circle, Mike Anderson from the Wilderness Society provided us with an informative analysis of the Bosworth directive mentioned above.

Natural Trails & Waters Coalition Grassroots Coordinator Lisa Philipps

So read on, enjoy, learn something, and please, keep in touch with us about our newsletter and features or topics you’d like to see in future.

Program Associate Jennifer Barry

ORV Policy Coordinator Jacob Smith, Nicky Phear Roads Policy Coordinator Marnie Criley

Newsletter Dan Funsch & Jim Coefield

Editors’ Note As you’ve probably noticed, The Road-RIPorter has taken on a bit of a facelift! After around 5 years of the same old format, we’ve decided to start making some changes: some subtle, and some not so subtle. In this issue, we’ve moved to a slightly heavier paper, so as to prevent so much bleed-through, but it’s still 100% postconsumer waste and is process chlorine free. We’ve changed the look of the front cover somewhat, and look for further changes in the format and presentation in upcoming issues! We’ve also added a few new sections: the Policy Primer, where Wildlands CPR staff provide info about some of the finer points surrounding road and ORV policies; and the Activist Spotlight, where the RIPorter highlights the work of an individual who excels at fighting the hard battles out there. And last, but not least, we’ll be moving to a quarterly format after this issue — our final bimonthly Road-RIPorter. But don’t worry, each issue will consist of 24 pages of hard-hitting material to fill your road-fighting desires. We’ll also be adding more diverse material, but more on that in the next issue. So we hope you all enjoy the changes, and as always, please let us know how we’re doing — a little constructive criticism, or a few kudos now and then are always welcome! — Jim & Dan.

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Interns & Volunteers Benjamin Hart, Maureen Hartmann, Emily Yeomans, Roiann Matt, Erich Zimmerman, Brian Crawford, Amy Barry Board of Directors Katie Alvord, Karen Wood DiBari, Sidney Maddock, Rod Mondt, Greg Munther, Cara Nelson, Mary O'Brien, Ted Zukoski Advisory Committee Jasper Carlton, Dave Foreman, Keith Hammer, Timothy Hermach, Marion Hourdequin, Kraig Klungness, Lorin Lindner, Andy Mahler, Robert McConnell, Stephanie Mills, Reed Noss, Michael Soulé, Dan Stotter, Steve Trombulak, Louisa Willcox, Bill Willers, Howie Wolke © 2002 Wildlands CPR

The Road-RIPorter January/February 2002

Off-Road Vehicle Monitoring in Montana Quite a few years ago, the US Forest Service and the Bureau of Land Management got together in Montana, North Dakota and South Dakota to talk about off-road vehicle (ORV) management. They did so, partially, at the request of the BLM resource advisory committees who were frustrated by the spread of weeds from ORVs. The BLM and Forest Service eventually decided to undertake a joint planning process that would change ORV management on 27 million acres of land in the three states. They called this the tri-state OHV plan. Because the BLM and Forest Service had different levels of knowledge about their ORV route systems, they devised a solution that would apply to all the lands, even if some were already at a higher level of management. Finally, they decided that they would allow ORV use to continue on any routes that existed on the ground, but all other cross-country ORV use would be prohibited. (See “Policy Primer” p. 8-9 for a complete explanation of this item.) But then the BLM became engaged in a national ORV effort and they pulled out of the tri-states plan. So when the Forest Service went ahead with the plan, which affects 17 million acres of land in the area, activists decided it was time to get more people on the ground conducting ORV inventories. Though the tri-states plan affects almost all the National Forest lands in the region, other factors also influenced the scope and direction of this summer’s Montana field inventories. These issues ranged from the impacts of ORVs on grizzly bears to the illegal incursion of ORVs in wilderness, to ORV trespass in roadless areas and wilderness study areas protected under the Montana Wilderness Study Area Act. All told, it was a big summer of data collection in Montana, and activists in the region are still coordinating the results of the summer surveys and determining the best possible way to utilize the data. Please read on, in their words, about this summer's monitoring efforts…

to existing roads and trails. The Code of Federal Regulations also has very strong language regarding use of and monitoring of ATVs — were it only enforced.

Data Gathering and Monitoring We have developed and refined techniques for field monitoring, and have a standardized set of forms and codes for recording photographs, GPS points, trail and road numbers, types and severity of damage, and habitat types. This information is being entered into a comprehensive database.

All is not Lost Many strategies aimed at battling destructive motorized recreation are coming together on the Gallatin. They include field surveys and documentation, training volunteers, collecting evidence, refining field monitoring, litigating over impacts

— continued on next page —

The Wild Trails Campaign Documenting the Damage By Phil Knight, Native Forest Network In May the Native Forest Network, in conjunction with Sierra Club Grizzly Bear Ecosystems Project, launched the Wild Trails Campaign to document the damage caused by motorized recreation on the Gallatin National Forest in southwest Montana. The burgeoning popularity of dirt bikes, ATVs and snowmobiles is wreaking havoc on public forests, especially in otherwise wild roadless areas. We found trash (most of which we packed out), bullet shells and shot-up targets, rutted meadows, and trampled, overused campsites. We found abandoned cars, trucks and trailers. We found evidence of illegal motor vehicle use in several locations, including the Absaroka-Beartooth Wilderness. We almost never saw Forest Service people out there checking things out, talking to users, cleaning up messes or packing out trash. It’s a free for all. Recent agreements by the Forest Service give us considerable leverage in limiting motorized travel. The Forest Service has agreed to manage off-trail travel in occupied grizzly bear habitat. In addition, wheeled motorized use is now restricted

The Road-RIPorter January/February 2002

Great Burn Roadless Area. Photo courtesy of the Great Burn Study Group.

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on grizzly bears and Wilderness Study Areas, coordinating environmental groups, reaching out to the public, and pressuring the Forest Service to deal with this growing menace. We are working to secure restrictions in the areas where the worst abuse is occurring. This winter and spring, when the snow piles deep in the remote backcountry, we will be out there on skis and snowshoes, and in airplanes, watching for and recording evidence of lawbreaking by snowmobilers who illegally ride their machines in designated wilderness and other closed areas.

Damage Photos Available Online Please visit http://grizzly.sierraclub.org/wildtrails.htm to see photos of some of the worst examples of public lands abuse we found this summer. You can also download copies of our documentation forms. Start your own monitoring project to document the damage! Join us next season as we expand our efforts to stop the abuse of our fragile public lands by motorized wreckreation. Contact me at [email protected] to get involved.

The Great Burn Citizen Monitoring of ORVs By Bob Clark, Great Burn Study Group The Great Burn Proposed Wilderness is a vast expanse of wild country along the Montana/Idaho border in the northern Bitterroot Mountains. This primeval landscape burned heavily in the Great Fire of 1910, leaving charred snags, grassy slopes, and expanses of sub-alpine tundra-like meadows. High cirques, impressive stands of mountain hemlock, and dozens of clear lakes adorn the high country. Elevations within this 300,000 acre roadless area range from 3200' to 7900' providing critical year-round habitat for a variety of species listed as threatened, endangered, or sensitive. Unfortunately, and to the great concern and dismay of conservationists and some land managers, motorized use has sharply increased in this area (since the early 1990s). Responding to this situation, two local grassroots organizations — the Great Burn Study Group and Friends of the Clearwater — developed and implemented the 2001 Trail Monitoring Project. This project gathered information on offroad vehicle (ORV) and other recreational uses in the Great Burn, including impacts to natural resources and potential user conflicts. Carried out by more than 35 dedicated volunteers, who logged hundreds of hours on more than 15 field outings, with financial assistance from the Natural Trails and Waters Coalition, the project was truly an inspirational effort. The project has yielded hundreds of photos, reports, and summaries outlining the types and level of motorized recreation, user conflicts, illegal activity, resource damage, usercreated trails, conditions at trailheads and backcountry campsites, proper signage, and vandalism. Some of the more significant observations include:

miles inside the roadless area, was severely damaged by up to 60 ORVs per weekend. The Forest Service allowed a halfmile section of the State-Line Trail #736 to remain open to these machines even though the State-Line Trail is designated off-limits to ORVs in Forest Plans. * Numerous cases of unsigned or improperly signed trailheads and vandalism to existing restriction signs. * Heavily impacted outfitter camps complete with roughly built furniture, latrines, and lodging structures, hitching poles nailed to trees, large corrals built with sapling poles and/or strung with electric fencing wire, and tarps and other equipment stored in the woods. These sites covered large areas devoid of vegetation. ORV management in the Great Burn is a complicated mix of open and closed trails resulting from differing management philosophies of the Lolo and Clearwater National Forests (the Lolo NF portion is closed to all motorized use, while 75% of the Clearwater’s trails are open in proposed wilderness). Significantly, the project discovered that motorized use is occurring virtually everywhere in the Great Burn, regardless of restriction, terrain, or distance. For more information about the Great Burn, to obtain copies of the Project Report or to get involved in this ongoing project, contact: Great Burn Study Group 1434 Jackson Street Missoula, MT 59802 or call 406-721-6438

* Evidence of illegal motorcycle use on several trails at remote locations within proposed Wilderness. Volunteers also encountered two motorcyclists deep in the backcountry on the State-Line trail (restricted) in the Cache Saddle area. * The conversion of Fish Lake, just off the Bitterroot crest on the Idaho side, into an ORV playground. Sadly, the Forest Service itself did the “converting.” Forest Service developments at the lake include three port-a-potties, two docks, and ORV parking areas. This beautiful subalpine lake, six Motorcycle track in the Great Burn Proposed Wilderness Area. Photo courtesy of the Great Burn Study Group.

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The Road-RIPorter January/February 2002

Predator Conservation Alliance Field Monitoring By Shawn Regnerus, Predator Conservation Alliance PCA’s summer monitoring focused on road and off-road vehicle impacts in grizzly bear habitat, not just in MT, but in ID, WA, and WY. After completing the road inventory in the Selkirk grizzly bear recovery zones in WA, and ID, our field crew went south to the Targhee NF in WY to survey user-created roads and ORV trails. The Targhee has a long history of heavy motorized use that has hampered the recovery of grizzlies on the western edge of Yellowstone, but with its last forest plan the Targhee committed to close roads and restrict motorized use to “designated” routes. Our field crew looked at two areas to ensure that the Forest Service is living up to its promises. Finally, our field crew went into the backcountry north of Yellowstone to document user-created routes on the Gallatin. Aaron Schuerr, one of our field workers who inventoried Rock Creek for ATV routes, was amazed by the user created routes he found. “I thought I might find a few scattered ATV tracks but instead I found that the user created trails were prominent, well established ruts that were more visible than the official trail.” Shuerr returned a month later to complete the work and found that “even though the ATV riders had already created obvious trials, they still didn’t follow them. Everywhere there was a difficult spot in the trail there were numerous muddy detours around it. The amount of damage even a few ATVs could do was amazing.” All of the trails our field crew found in Rock Creek are inside grizzly bear core habitat, which the Gallatin is required to protect from all wheeled vehicles under the settlement terms of PCA’s recent lawsuit. For more information contact Shawn Regnerus at 406587-3389 or [email protected].

Data Gathering Benjamin used data forms to record critical information about each road. He recorded the date, location by global positioning, initial road width, presence of exotic invasive plants, severity of erosion and other details. He took photographs and kept a photo log to keep track of information. Benjamin attempted to show both the average conditions of each road and the most damaged areas. Two questions were of primary concern: 1. What is the condition of existing roads in the Pryors? 2. Are roads being illegally created in the Pryors?

User Created Routes The topography and vegetation in the Pryors welcome user created routes: the sub-alpine meadows and sage dominated desert offer little protection from off-road vehicles. Routes have been created by individuals accessing mining claims and by cattle ranchers checking on their stock; after these routes are created they become part of the everincreasing network of recreational ATV routes.

Erosion All of the roads inventoried in the Pryors were rated at their most eroded spots on a scale from 0 to 4. Of the 122.507 miles of roads surveyed, Benjamin didn’t observe any that didn’t have level 2 erosion (which includes water channeled down the roadbed) at some point or another. Many of these roads have become nothing more than a playground to challenge four wheel drive vehicles.

ORV Use ORVs have left their mark on the fragile Pryors. Benjamin estimates that over half of the user created routes were made for and by ATVs. They have caused significant erosion on both user created and legal roads. ATVs leave a distinct track, which over time has changed many roads from a double to a wider, triple track.

Road Widening

The Pryors

One of the largest threats posed by roads in the Pryors is road widening. Sub-alpine roads quickly reach erosion levels that make them too challenging to drive on. Individuals begin driving outside of the ruts, creating new ruts. Over time roads in the Pryors have gone from a few feet to dozens of feet wide. Wildlands CPR is still in the process of analyzing Benjamin’s data and checking his mapping against the Forest Service’s. For more information on this project contact Marnie Criley in the Wildlands CPR office.

Monitoring Roads and User-Created Routes By Marnie Criley and Benjamin A. Hart In the summer of 2001 Benjamin A. Hart, an intern with Wildlands CPR, conducted a systematic survey of roads in the Pryor Mountains, located in south central Montana within the Custer National Forest. The Pryors are one of the most complex and interesting areas in Montana; all of the ecosystem types from Great Basin desert and sub-alpine forest exist within them. The reasons we chose to survey this area are twofold: 1) The Custer National Forest is in the process of ground truthing all their transportation structures and we wanted to check the accuracy of their mapping. 2) A couple of years ago the Custer classified nearly 2000 miles of unclassified routes without going through a NEPA process. Wildlands CPR wanted to check the on-the-ground status of roads and see what type of roads they classified.

The Road-RIPorter January/February 2002

Pryor Mountains road washout. Photo by Benjamin A. Hart.

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A Tale of Two Roads By Bethanie Walder

“Before any design concepts for the road were conceived, it was essential to get a better understanding of the land, what makes it unique, and how the Salish and Kootenai people relate to the land. The design of the reconstructed highway is premised on the idea that the road is a visitor and that it should respond to and be respectful of the land and the Spirit of the Place”

A small snake at the Lee Metcalf National Wildlife Refuge. The Metcalf parallels Highway 93 for several miles in the Bitterroot Valley, and is home to a diverse array of wildlife. File photo.

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W

hen a new road invades a native ecosystem, like the southern California foothills, or the Big Bend of northwest ern Florida, or rural West Virginia, it brings development, death and destruction. The development of houses, shopping malls, banks, schools and post offices means the death of plants and animals that had taken refuge in that natural place, and the destruction of wild character. This is more commonly known as sprawl. Sprawl, after all, is about urban, suburban and rural areas. It’s not about wildlands and it’s not about nature. Or is it? Undeveloped lands, whether private or public, protected or not, provide important and often critical habitat for native plants and animals. But protecting habitat from sprawl is difficult, partly because of the scarcity of legal opportunities to limit development on private lands. This article looks first at some of the impacts of sprawl, and then at the stark contrast between the redevelopment plans for one road in two different areas. Sprawl, whether for resource extraction or new housing, doesn’t happen without roads, and it doesn’t depend on new road construction. Sprawl is often fueled by paving an existing dirt road, or by widening or lengthening an existing rural road, increasing the ease of access and hence, the desirability of traveling to and fro. And with increased access comes exploitation and degradation. This degradation is happening on a grand scale: two to twenty percent of the species loss in the lower 48 states is caused by habitat conversion to urban, suburban or agricultural development (Biodiversity Project: Getting On Message About Sprawl). Poster species like grizzly bears and wolves may rely on protected federal lands, but only ten percent of all threatened species live on such lands (ibid). Before white settlers populated the west, these species lived everywhere, from the plains to the mountains. It was sprawling development, and white settlers’ refusal to share their land with wild predators, that lead to the extirpation of grizzlies and wolves from most of their native habitat. And the roads continue to roll through what little remains, impacting species far less photogenic than wolves and grizzlies. Western Montana provides a tale of two roads: Highway 93 north and south of Missoula. This road travels the length of Montana from the Canadian to the Idaho border west of the rocky mountain divide. It separates the Mission Mountain Wilderness from the Mission valley, and bisects the Bitterroot valley, separating the Selway Bitterroot Wilderness from the Sapphire Range. It’s already a significant barrier to wildlife movement and has been slated for upgrading (widening) for years. The US Federal Highway Administration (FHA) and the Montana Department of Transportation (MDOT) have conducted studies, fought citizen lawsuits, and negotiated with the Confederated Salish and Kootenai Tribes over road reconstruction. But the outcomes north and south of Missoula are as different as fire and water.

The Road-RIPorter January/February 2002

Highway 93 North - The Missions The Salish and Kootenai Tribes recognized that if Highway 93 was reconstructed as planned, to an undivided four to five lane highway, it would destroy the remaining rural character of the reservation and dramatically increase habitat fragmentation. After difficult negotiations with the FHA and MDOT, the Tribes succeeded in forming a committee to consider highway redesign in a more culturally and environmentally sensitive manner. According to the Memorandum of Agreement (MOA) signed by all three parties in late December 2000: “Before any design concepts for the road were conceived, it was essential to get a better understanding of the land, what makes it unique, and how the Salish and Kootenai people relate to the land. The design of the reconstructed highway is premised on the idea that the road is a visitor and that it should respond to and be respectful of the land and the Spirit of the Place” (MOA, US 93 Evaro to Polson, 12-20-2000). These are incredible words for a highway development document; the language refers to the road as a visitor, and directs that the road respond to the place, not the other way around. The result is a redesign incorporating two lane, three lane and four lane segments depending on terrain and traffic, in addition to dozens of wildlife crossing structures. The MOA also explains the impacts the existing highway is having on a migratory bird wetland, and it offers options for re-aligning the highway to remove the worst part of the road from the Ninepipe National Wildlife Refuge. While the redesign of HWY 93 north is a success story, it will still be a bigger, faster highway, and it will still fragment critical wildlife habitat (see Bibliography Notes this issue re: mitigation). But by foregoing a standard 5 lane construction for the project’s 53 miles, the upgraded road will not increase sprawl or habitat fragmentation as much as the original design would have. The catalyst for this change was the fact that the agencies were forced to negotiate with the Tribes for right-of-way access. They had no such mighty foe along HWY 93 south through the Bitterroot, just concerned citizens who don’t want to see their rural communities turned into even larger bedroom towns for Missoula.

The indiscriminate widening of HWY 93 south will forever change the character of the Bitterroot Valley. The discriminate widening of HWY 93 north will forever change the Mission Valley. While most wildlife were long ago driven out of the valleys and into the mountains to avoid people, these valleys still provide important habitat for many species. And this is where conservation and sprawl activism again connect. Up in the Mission valley, the Tribal government now must follow through to ensure that developments on adjacent land are at least as sympathetic to the land, wildlife and cultural heritage of the area as the redesigned road. They have the power to do so. In the Bitterroot Valley, communities have eschewed zoning for years, and with the widening of HWY 93 are now faced with new developments that many community members don’t want. They must quickly enact regulations to control and manage growth. Clearly, sprawl affects not just the private lands where it occurs, but the adjacent private and public lands that provide important habitat for wildlife. Unfortunately however, it seems that until we run out of space, we are not willing to conserve it. Sprawl is just one obvious symptom of that problem. Roads provide access for increased and rampant development, and people have to come together to fight both roads and development. While these battles may be difficult, they can be won. Sprawl can be combated through federal laws (e.g. endangered species act), economic incentives (e.g. conservation easements), and through fighting roads. But without coordinating anti sprawl and conservation efforts, much of the hard work of both groups will be for naught and efforts to conserve public land habitat will fall far short of our goals to protect wildlife and wild places.

Highway 93 South — The Bitterroots The Highway 93 Citizens Coalition for Responsible Planning formed in the early 90’s when MDOT first proposed widening the road. This coalition promoted a “Super Two” road plan similar to that now approved on the Flathead reservation: they proposed a mile-by-mile design, with frequent passing lanes and opportunities to enhance wildlife migration (Highway 93 fact sheet). They offered comments within the public process, and appealed MDOT’s final decision to construct a five lane undivided highway. When they lost, they joined with Friends of the Bitterroot, a conservation organization, and sued to force consideration of the Super Two. However, without the negotiating power of the Tribes they lost. To date, eight of the 34 miles to be rebuilt have already been widened to five lanes with no wildlife crossing structures and no other significant wildlife or habitat mitigation. New housing developments are already under construction in anticipation of the road expansion.

The Road-RIPorter January/February 2002

The Mission Mountains loom over the Mission Valley, providing habitat for old-growth forests, grizzlies, and wolves. This side of the Missions is a Tribal Wilderness Area with a designated buffer zone along its perimeter that controls development. In places, it is only a few miles away from Highway 93. Photo by Jim Coefield.

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Wildlands CPR Policy Primer The Policy Primer is a new column in the Road-RIPorter, designed to highlight the ins & outs of a specific road or ORV policy. If you have a policy you’d like us to investigate, let us know!

“Unfortunately, as is often the case, the devil is in the details.”

The “Existing Routes Exception” An update on a new Forest Service paradigm for ORV management By Jacob Smith

The Forest Service is slowly conceding that cross-country motorized travel is inappropriate. While this is a significant step toward appropriate management of off-road vehicles on Forest Service lands, the agency’s implementation of this new management approach is deeply flawed. This primer outlines our off-road vehicle management goals, describes this new Forest Service approach and its flaws, and discusses some implications for public lands activists.

Appropriate Off-Road Vehicle Management In December of 1999, more than 100 organizations joined a formal petition requesting that the Forest Service adopt a suite of management rules aimed at ensuring responsible and prudent management of off-road vehicles. The petition, authored by Wildlands CPR and The Wilderness Society, requested five specific management changes: * The Forest Service must demonstrate that a proposed motorized route will not cause adverse impacts before designating the route. * The designation of motorized vehicle routes, construction of new routes, upgrading of existing routes, and other projects related to off-road vehicle recreation must be fully analyzed under the National Environmental Policy Act. * Off-road vehicle use shall be prohibited in roadless and other sensitive areas. * Off-road vehicle use is only permitted on routes designated and posted as open for this purpose. Cross country travel shall be prohibited. * Off-road vehicle use shall be prohibited unless adequate monitoring and enforcement of the use and impacts are fully funded and implemented.

the Forest Service just announced the closure to dirt bikes of a long-contested route technically off-limits to vehicles but never managed as such. These gains reflect our commitment to eliminating cross country motorized vehicle travel on public lands. Recent Forest Service decisions suggest that the agency is slowly conceding that cross-country motorized travel is inappropriate. For instance, recent travel management decisions on the Medicine Bow National Forest in Wyoming and the Gunnison National Forest in Colorado included, as central provisions, a prohibition on cross-country travel. The January 2001 decision by the Forest Service to ban cross country travel on nine National Forests in Montana and the Dakotas, known as the Tri-States OHV Management Plan, is an even more dramatic example. Unfortunately, as is often the case, the devil is in the details. Most of these decisions involve three components. First, they formally prohibit cross country travel. This is good. Second, they commit to a process for inventorying all of the existing non-system routes (those routes that have been created through use or for long-forgotten purposes and have never been planned for, analyzed, or formally adopted into the travel system). As these routes are inventoried, the Forest Service will then make a site-specific management decision for each. This is a mixed bag, as I explain below. Third, as an ostensibly interim management measure, they allow continued motorized use of those routes that existed as of a specific date (usually near the date of the decision). In other words, while the Forest Service is clearly moving toward a ban on cross-country travel, in each of these instances motorized vehicle use will be permitted on previously existing or established routes until the agency gets around to analyzing all of those routes for their appropriateness and legality. The result, typically, is a so-called “ban” on cross-country travel that is largely a ban in name only. This is bad.

We argued, given the numerous laws and regulations that pertain to off-road vehicle management, and the large body of scientific evidence about the environmental impacts of offroad vehicle use, that these five requests were required in order to manage off-road vehicle use legally and responsibly.

Banning Cross-Country Motorized Travel In the time since we submitted our petition, the conservation community has made noteworthy gains (and suffered some setbacks as well). For example, conservation groups in Montana forced the Forest Service to remove an illegally created snowmobile route, and successfully assisted the Forest Service in defending a decision to prohibit off-road vehicles in a Wilderness Study Area. In August, activists in California successfully pushed the Forest Service to eliminate off-road vehicle access to a fragile botanical area. In western Colorado,

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This is a good example of a cross-country route that has been widened by unregulated off-road vehicles. Photo by Benjamin A. Hart.

The Road-RIPorter January/February 2002

The Flaws of the “Existing Routes Exception” While we greatly appreciate the general direction toward a cross-country travel ban, the flaws in this “interim” approach are severe: * Motorized vehicle use of routes not planned and designated in accordance with the National Forest Management Act, Executive Orders 11644 and 11989, the National Environmental Policy Act, other applicable statutes and all the implementing regulations for these laws is illegal and, furthermore, represents poor land stewardship. * Permitting the continued use of user-created and other unplanned routes rewards decades of destructive and often illegal motorized vehicle travel. * The political challenges associated with closing any given area or cross-country route to motorized travel will only increase over time. The more established the use, the more difficult it will be to eliminate later regardless of environmental and other impacts. This dynamic is especially pronounced if the Forest Service informally sanctioned such use (e.g., by officially permitting its continuation, even if on an interim basis, through travel management planning). The end result will almost certainly incorporate much of this existing system. * Without a clear and nondiscretionary endpoint to the transition period, this type of approach will be interim in name only. If a given National Forest unit ever completes its inventory and evaluation process, and this is by no means assured, it will require many years if not decades. * Responsible off-road vehicle users, which may constitute a large percentage of those who ride the vehicles, will generally have a very difficult time determining if use of any given route is legal or not. * Enforcing an “existing routes” policy will be extremely difficult, as motorized recreationists will usually be able to claim, credibly, that they believed a given route was legal for motorized use. Thus, irresponsible off-road vehicle riders will largely be able to ignore the ostensible prohibition on cross-country travel. This problem is exacerbated by the critical gaps in law enforcement funding and capacity. The result is that motorized use is likely to continue in largely the fashion it occurred before the new policy was adopted.

The Bitter Pill Although it may be simple for activists to determine if an interim management policy is appropriate (it almost certainly is NOT appropriate), there is a more difficult challenge. Forest Service decisions to ban cross country travel with an “existing routes” grandfather clause are frequently structured such that challenges to the sweeping existing routes exception will result in a reversion back to whatever abysmal travel plan existed before the new decision. For example, the Forest Service adopted a Travel Management Plan with this “existing routes” provision on the Uncompaghre National Forest in western Colorado. The Forest Service tried to persuade the conservation coalition to drop the appeal, arguing that our administrative appeal would result in a temporary withdrawal of the decision (while the appeal was decided), which meant that management reverted to the previous “anything goes” policy. In other words, the Forest Service argued that if we didn’t accept this compromise, with all its warts, and appealed or litigated the decision, the resulting environmental impacts would be worse than if we had left it alone. We not only filed the appeal but won it as well, which meant that the “anything goes” approach remains in effect while the agency completes another travel plan. Although we agreed with the Forest Service that there

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might be a short-term increase in environmental damage if the agency withdrew its decision because of the appeal, we believed that the long-term implications clearly outweighed these concerns. For all of the same reasons we object to this approach in the first place, we believe the long term impacts of “existing routes” policies are severe enough to warrant aggressive political, administrative, and legal challenges to their use, even at the risk of Forest Service reliance on older, “anything goes” type management while these challenges are resolved. Although it is possible that such a compromise might make sense under unusual circumstances, in every example we’ve evaluated we believed that the long-term importance of appealing far outweighed the potential shortterm costs of walking away.

Implications for Activists It is important to recognize that these new challenges represent progress on the motorized recreation front. The Forest Service is, by all appearances, conceding that crosscountry motorized travel is inappropriate. That said, the flaws of the “existing routes” approach are so severe that we are generally better off challenging this approach than living with the so-called compromise. There are at least several implications for conservation activists. First, challenging these policies will require thorough and credible field data documenting the existence of illegal routes, use of those routes, and the environmental damage caused by off-road vehicle use. While we should aggressively challenge these sorts of travel management planning decisions, as well as any inappropriate off-road vehicle use of Forest Service lands, we must do so thoughtfully. In every instance, we must be certain to carefully build our case that inappropriate off-road vehicle use has real impacts to the environment and to other users. Simply arguing that the Forest Service is violating the letter of the law, without demonstrating that the impacts of such violations are substantive, will not persuade a judge who doesn’t know or care about off-road vehicle issues. Second, conservation activists should aggressively clarify to the Forest Service that they have both the authority and duty to eliminate off-road vehicle use that is unplanned or causing environmental damage (or both). Even where agency decision-makers are sympathetic, they are often reluctant to close routes or make strong travel decisions for fear of losing subsequent administrative appeals and litigation. To date, the agency’s authority to close such routes has been largely affirmed by the courts; our task is to communicate this to the Forest Service. Finally, the fact that banning cross-country travel is increasingly a part of the agency’s management paradigm is extremely encouraging. We are gaining ground and need to continue to push hard until off-road vehicles are managed appropriately.

Along these lines, conservationists should push hard for cross-country travel bans, strongly support National Forests that have such bans, and aggressively challenge Forest Service decisions that only give lip service to this critical goal of prohibiting crosscountry motorized travel. 9

Odes to Roads

The Landscape of Desire

“…our purpose isn’t to pass through an area as quickly as possible, but rather to come to know a place, to linger and saunter as Thoreau would have us do. ‘For every walk is a sort of crusade,’ he wrote…”

An excerpt, by Greg Gordon To the west of Green River, Utah juts the San Rafael Reef, a shark tooth ridge of upended sandstone. Not an actual marine reef, but so christened by the early pioneers because this 2000 foot high pleat proved a significant impediment to east-west travel. Most of the desert beyond remained inaccessible until the construction of Interstate 70. Begun in 1970, this stretch of Interstate took 20 years to complete. The highway slices right through the San Rafael Reef, revealing successive layers of geologic history. Deposited horizontally, they are now tilted on end, so that one drives through the entire Jurassic period in a few minutes. A dirt road off a dirt road leads to Muddy Creek, the only reliable source of water in the southern half of the vast and seldom visited San Rafael Desert. It looks more like an irrigation ditch loaded with cow manure than a creek. Composed of grey Mancos Shale, the Coal Cliffs loom above us. A cold wind whips the cumulus clouds across the sky like a time release film. Through the low clouds we can see snow in the highlands of the Fishlake Plateau. As we step out of the van after the long ride, everyone replaces their shorts with pants and long underwear and quickly throws fleece over their T-shirts. I pull out the maps and show my students we are headed clear through the San Rafael Desert, from I-70 to the tiny town of Hanksville. A person could easily hike through this county in less than half the time, but our purpose isn’t to pass through an area as quickly as possible, but rather to come to know a place, to linger and saunter as Thoreau would have us do. “For every walk is a sort of crusade,” he wrote. “We should go forth on the shortest walk, perchance, in the spirit of adventure, never to return, prepared to send back our embalmed hearts only as relics to our desolate kingdoms.” “It’s a big chunk of country, nearly all roadless. I’ve never been here before; should be interesting,” I say, closing the map case. We shoulder our heavy packs and navigate through failed attempts at alfalfa fields. We aim toward the Interstate, sighting our course along Muddy Creek. We trudge slowly in a perpendicular line, unwavering as a missile, so as to intercept the four-lane Interstate. We wonder if anyone notices a line of backpackers threading their way through a maze of barbed wire, old tires and car parts to the highway, passing beneath it and heading south into a landscape as desolate as the moon. We could have parked on the other side of I-70 and begun our hike farther downstream, but I wanted us to walk under

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the highway, having spent so much of our lives traveling over it. This ribbon of asphalt superimposed over the landscape defines our movement telling us which places are important and which are not. It gets us from here to there with little concern as to what lies between. We build our highways with near total disregard toward the land and its inhabitants. I also wanted to experience how animals move through the landscape. Driving along I-70 from Grand Junction, Colorado, to Moab, Utah, I was overwhelmed by the hundreds of ground squirrel carcasses littering the pavement. Are we simply oblivious of the lives of animals in our rush across the desert? Why right here on this one stretch of highway? The Humane Society estimates more than one million animals are killed every day on U.S. highways. This includes not only large and small mammals such as deer, bear, raccoons, hares and rodents, but also reptiles, amphibians, birds, and an untold number of invertebrates. Over half a million deer alone are killed every year by traffic. Roadkill is the leading cause of mortality for most large mammals and several endangered species, such as desert tortoise, Houston toad, brown pelican, ocelot, northern long-eared bat (whose only known breeding location is bisected by the Transcanada Highway), American crocodile, and key deer (of which 80% of all known deaths are attributed to traffic). Highways also act as wildlife mortality sinks. For example, snakes are attracted to the road to sunbathe and are flattened as a result; ravens and jays and other scavengers come to feed off the carcasses and are in turn killed themselves. From salamanders to grizzlies, highways prove to be impermeable barriers to some wildlife movements, preventing amphibians from reaching their breeding grounds and bears from finding mates. Roads can also dissect habitat. I-70, for example, severs the San Rafael bighorn sheep population in half. As traffic flow increases in speed and volume, the highway becomes like a solid wall of speeding metal, resulting in decreased gene flow between isolated populations. Furthermore, a decreased ability to re-colonize results in a drop in overall ecological resilience. If populations remain isolated long enough they become susceptible to disease and inbreeding. Extinction results. Many animals avoid highways altogether. Elk spurn areas up to half a mile from a road. Small mammals find many roads too wide to cross. A study of a four-lane highway in the Mojave Desert discovered that rodents hardly ever crossed the road. This is particularly portentous to the Colorado Plateau, which is home to more than thirty species of rodents. Thus

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highways are a double jeopardy for wildlife, for not only do they fragment the available habitat into smaller islands, they simultaneously kill off the remaining populations. Muddy Creek flows unhindered beneath the Interstate. If an animal sensed this passageway, it could safely move from one side to the other. Riparian corridors like this serve as valuable wildlife habitat; indeed 80% of deer kill zones are associated with major drainages. If properly designed, the creek could serve as a wildlife underpass, an idea now being incorporated into highways from Florida (which has installed underpasses for crocodiles and panthers) to Canada (which has installed overpasses for larger mammals such as elk). The Texas highway department is considering a plan that installs tunnels under the highway for the endangered Houston toad. Near Park City, Utah, fenced right-of-ways funnel deer to painted cross walks that have reduced mortality 40%. However, these mitigation measures are expensive and the results mixed. In Florida, deer and raccoons frequently use the underpasses but black bears do not. In Canada, elk, deer and coyotes use the overpasses, but grizzlies and wolves may not. As we hike, I think about Simon Ortiz’ poem. For our brothers: Blue Jay, Gold Finch, Flicker, Squirrel, who perished lately in this most unnecessary war, saw them lying off the side of a state road in southwest Colorado.

before the damming of the Colorado, Harold Ickes, FDR’s Secretary of Interior, proposed the world’s largest preserve, a 4.5 million-acre national monument that would reach from Lee’s Ferry in Arizona west to Kanab, Utah, north to Green River and east to Moab. Only one dirt road crossed this region, the most remote in the contiguous U.S. However, FDR’s Federal Reserve Chairman, Marriner Eccles, was from Utah and was vehemently opposed to the monument. The idea was shelved as the bombing of Pearl Harbor shifted attention elsewhere. Even earlier, Bob Marshall, co-founder of the Wilderness Society, identified two million acres of roadless land in the San Rafael alone in 1935. While I-70 now sliced it in half, I wondered how much remained. Although Interstates and dams have shredded and fragmented one of our last remaining wildernesses, could we still thread together a patchwork traveling by foot across this remote region? Is it still possible to set off into the unknown for weeks, simply following a creek? Would we find the soul of the Colorado Plateau here, damaged but still intact? Would we find our own? We pass an abandoned mine and a road bed scarred into the desert crust. This is a place where you damn the land and hope to get rich quick and get the hell out, an area so desolate

They all loved life. And suddenly, it just stopped for them. Abruptly, the sudden sound of a speeding machine, and that was it. I don’t have to ask who killed you. I know, and I am angry and sorry and wonder what I shall do. This, for now, is as much as I can do, knowing your names, telling about you. Squirrel. Flicker. Gold Finch. Blue Jay. Our brothers. This particular highway also defines some sort of boundary in my own mind. Although much of the Colorado Plateau lies north of I-70, for me the area between I-70 and the Arizona line embodies Utah’s redrock wilderness. I-70 represents civilization and I had always looked to the south — Canyonlands, Zion, the Escalante — as the real wilderness. By starting north of the Interstate and walking beneath it I wanted to defy the validity of that line. I also hoped that this would somehow frame the students’ concept of wilderness on an experiential level. Does anything significant change when we pass under the Interstate? We are hardly in the land of Oz, but nothing civilized lies between us and the tiny town of Hanksville, 85 river miles downstream: no pavement, no houses, nothing but a couple of dirt roads, a muddy creek to follow and over half million acres of wilderness. At Hanksville, Muddy Creek joins the Fremont River and creates the Dirty Devil River. After a short re-supply, we would follow the Dirty Devil its entire length, another 85 river miles to where it converges with the Colorado River beneath the surface of Lake Powell. I-70 to Lake Powell. Icons of the modernization of the West? The Interstate serves as a transportation corridor, emblematic of speed, efficiency, globalization, carrying lettuce from California to the Midwest, orange juice from Florida to San Francisco, and no doubt cocaine from L.A. to Denver. Lake Powell was created by a massive dam across the Colorado River, 120 miles long; the “lake” flooded what was once the very heart of the Colorado Plateau — Glen Canyon. But what lies between I-70 and Lake Powell? Twenty years

The Road-RIPorter January/February 2002

Photo by Marcel Huijser.

that it has never seen a permanent settlement. Scour the earth for uranium (or magnesium as in the case of this mine), or coal or oil and gas, or fill it with cows, scrape every available source off and then fill in the gaps with toxic waste. This unlovely land has been consigned to satisfy the motorized recreation needs of off-road vehicles. We take everything it has to offer and leave feeling not quite satiated. This is a grey streaked country, always too cold and windy or searingly hot. This is a land of salt bush flats and little to no water. What water exists is foul, laced with heavy metals, salt and giardia (as we later discovered). These barren bentonite hills, mysterious enough on their own, seem inhabited by ghosts of a different kind — the specters of greed and desire. The Wilderness Act defines wilderness as an “untrammeled” area. Most misinterpret this as “untrampled.” Untrammeled refers to a trammel line, which is what fishermen use to surround a school of fish with nets. Thus untrammeled would pertain to an area whose boundaries are flexible and porous, not surrounded by civilization. I wondered to what degree I-70 and Lake Powell act as ecological trammel lines for the San Rafael/Dirty Devil region. Could they also act as psychological trammels reining in our own wildness? — This essay is taken from the forthcoming book about the Colorado Plateau, The Landscape of Desire by Greg Gordon.

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Bibliography Notes Bibliography Notes summarizes and highlights some of the scientific literature in our 6,000 citation bibliography on the ecological effects of roads. We offer bibliographic searches to help activists access important biological research relevant to roads. We keep copies of most articles cited in Bibliography Notes in our office library.

An Evaluation Of Wildlife Crossing Structures Their Use And Effectiveness — By Maureen Hartmann

The study of road impacts upon wildlife has ignited in the last decade, but only in the past few years have efforts begun to mitigate these impacts. Engineers and biologists are now working jointly to design operative wildlife underpasses and overpasses that will temper the effect roads have upon wildlife. Effective crossing structures will help to reconnect areas of viable habitat that have become isolated due to road construction. This is an arduous task if you consider the wide-ranging species in the world, their diverse biological needs and habitat requirements.

Photo by Marcel Huijser.

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Forest Service graphic.

In the last decade, wildlife crossing structures ranging from amphibian tunnels to large carnivore open span bridges have been built to combat roadkill and road avoidance. With the passage of a new federal highway bill in the U.S. Congress, the Transportation Equity Act (TEA-21), federal support is available for wildlife crossing structures on both new and existing roads in the United States. The European Union passed a similar measure, COST-341. Both initiatives have heightened the concern for sustainable transportation systems and incorporation of mitigation structures into road plans (Gloyne and Clevenger, 2001). Only limited information exists on the efficacy of those structures that are just now gaining nationwide and global support. Biologists and engineers are on a learning curve, and future studies are needed to determine what attributes will make these structures most effective for the greatest number of species. Although the need for more research is apparent, preliminary studies from Europe, Canada, and the United States have provided some insight concerning significant features/issues that should be considered when building wildlife crossing structures. Wildlife crossing structures come in many sizes and shapes; their features ultimately depending upon the ecological and behavioral needs of the diverse species that inhabit an area. Each species has different needs, therefore, when designing these structures it is virtually impossible to accommodate all species in an area. A more generalized approach should be taken to make highways permeable for as many species as possible. “Today highway planners and land mangers can ill afford the naïve luxury of single-species mitigation structures. Species do not function in isolation but are components of ecological systems that inherently fall into the category of organized complexity. Therefore, any singlespecies mitigation structure is likely to have cascading effects, some positive and some negative, on non-target species also. If a mitigation structure is to succeed, a multi-species approach is needed to evaluate the efficacy of such mitigation on non-target species as well” (Clevenger and Waltho 2000). Various attributes of crossing structures such as light, noise, substrate, natural cover, dimensions, and placement will determine usage by different species. Most studies indicate that the larger the underpass/overpass, the better suited it will be to accommodate a wide range of species (Reed 1981, De Santo and Smith 1993, and Jackson and Curtice 1998). Natural vegetation near the opening will give both large and small species the security of their preferred environment (Rodriguez et al. 1996, Hunt et al. 1992, Clevenger et al. 2001a). Vegetation can serve as a funneling system, guiding animals to the openings, thus helping to motivate them to use the crossing structure (Yanes et al. 1995).

The Road-RIPorter January/February 2002

Proper placement of the crossing structure is likely the most important feature in determining success (Jackson and Curtice 1998, Rodriguez et al. 1996, Land and Lotz 1996, Singer et al. 1985). Most studies indicate that placing the crossing structure near traditional migration routes will increase effectiveness. Methods to determine proper placement are track count surveys, monitoring trails with infrared cameras, GIS modeling to determine likely travel corridors, roadkill data, and radio tracking collared animals (Scheick and Jones). In addition, some biologists recommend that crossing structures be placed away from human disturbance areas; human activity has been negatively correlated with underpass/ overpass use. Underpasses and overpasses will be more effective if they are accompanied by fencing on both sides of a road. Fences were primarily erected to reduce roadkill, however, without a crossing structure, fencing further reduces a road’s permeability. Most studies indicate that fencing should be about eight feet tall (Groot Bruinderink and Hazelbrook 1996, Sipes and Neff 2001). Fencing should be built around the crossing structure to guide (funnel) animals to the passageway, thus preventing them from circumventing the system (Jackson and Curtice 1998).

Photo by Marcel Huijser.

Are These Structures Effective? Crossing structures are slowly being incorporated into the road plans of transportation agencies around the globe, however, very little research has been done on their true effectiveness. “This is a field of applied ecology still very much in its infancy,” says Parks Canada researcher Tony Clevenger (Wilkinson 2000). Clevenger also adds that virtually nothing is known about the relative effectiveness of overpasses and underpasses, or between the different types of underpasses being tested (Clevenger 1998). We can infer what features are most important based on the studies that have been conducted so far, but no study has been able to accurately estimate how many animal crossings would have occurred if a given structure was not there. Knowledge of the abundance and distribution of populations is essential in developing criteria to measure crossing effectiveness (Clevenger 1999). To try and obtain expected

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crossing rates, movement patterns, population densities, and life history requirements, years of study are needed. “Answering some of the complex ecological questions around roads and long-lived wildlife like bears may require research timeframes of up to 10-15 years” (Whyte Museum 2000). Even then, biologists will need to take into consideration that a low crossing rate may be due to a natural fluctuation/decline in wildlife populations. Low crossing rates may also be attributed to the time it takes certain species to adapt to and use a crossing structure. Although more studies are needed to determine effectiveness, the crossing structures and fencing erected in areas such as Banff National Park, Glacier National Park, Florida and Europe have dramatically decreased roadkill and have allowed for numerous wildlife passages. In some cases the carnage on roads has decreased as much as 97%, and wildlife ranging from salamanders to large grizzly bears and panthers are passing through the structures to reach vital habitat.

Conclusion Wildlife crossing structures have had some great successes. They have been useful in decreasing roadkill, and have been successful in enhancing landscape connectivity. The dearth of information on their effectiveness makes further studies essential if biologists and engineers are expected to make the crossings even better for a diverse array of wildlife (Clevenger 1998). Regardless of how much data is collected, there will never be one perfect structure to suit all species’ needs (Clevenger and Hardy pers. comm.). Therefore, “our first choice would always be to not build a road through wildlife habitat” (Lavendel 2000). For already existing roads, wildlife passages should be added thoughtfully with all species considerations in mind. The following list provides some salient recommendations to consider when developing or monitoring wildlife crossing structures: * Take a multi-species approach rather than a single-species focus, remembering that species do not function in isolation but are components of ecological systems; * Know the biology of the species in the area, their distribution, abundance, and ecological and behavioral needs; * Place the structures at known migration routes, away from human disturbance. This can be determined by roadkill data, infrared cameras, GIS modeling, and track-count surveys; * Make the passages wide to accommodate a larger number of species; * Try to build structures to allow for natural lighting and low noise levels; * Have a clear view to the other side; * Use fencing designed to reduce wildlife intrusions; * Conduct intensive monitoring before and after constructing the wildlife passages via track count surveys, radio-collaring, mark-recapture studies, etc., and; * Share the results! It is imperative that biologists and engineers share their findings and ideas concerning crossing structure effectiveness. Events such as the International Conference on Wildlife Ecology and Transportation have become integral to this process. Ideally, the knowledge gained from these meetings will lead to the design of improved crossing structures that will more effectively connect the habitats of a diversity of wildlife. — Maureen Hartmann is a graduate student in Environmental Studies at the University of Montana.

— Citations on next page — 13

Literature Cited Clevenger, A.P. 1998. Permeability of the Trans-Canada Highway to wildlife in Banff National Park: Importance of crossing structures and factors influencing their effectiveness. Pp.109119. In G.L. Evink, P.A. Garrett, D. Zeigler, and J. Berry, eds. Proceedings of the International Conference on Wildlife Ecology and Transportation. Feb. 10-12, 1998 Fort Myers, FL. FL DOT FL-ER 69-98. Clevenger, A.P. and Nigel Waltho. 2000. Factors influencing the effectiveness of wildlife underpasses in Banff National Park, Alberta, Canada. Conservation Biology. 14(1): 47-56. DeSanto, R.S. and D.G. Smith. 1993. Environmental auditing: An introduction to issues of habitat fragmentation relative to transportation corridors with special reference to high-speed rail (HSR). Environmental Management. 17(1): 111-114. Gloyne, C.C. and A.P. Clevenger. 2001. Cougar (puma concolor) use of wildlife crossing structures on the Trans Canada highway in Banff National Park, Alberta. Wildlife Biology. 7(2): 117-124. Groot Bruinderink, G.W.T.A. and E. Hazelbrook. 1996. Ungulate traffic collisions in europe. Conservation Biology. 10(4):10591067. Hunt, A., H.J. Dickens, and R.J. Whelan. 1987. Movement of mammals through tunnels under railway lines. Australian Zoologist. 24(2) 89-93. Jackson, S.D. and G.R. Curtice. 1998. Toward a practical strategy for mitigating highway impacts on wildlife. Pp. 17-22 in G.L. Evink, P.A. Garrett, D. Zeigler, and J. Berry, eds. Proceedings of the International Conference on Wildlife Ecology and Transportation. Feb. 10-12, 1998 Fort Myers, FL. FL DOT FLER 69-98. Land, D. and M. Lotz. 1996. Wildlife crossing designs and use by florida panthers and other wildlife in southwest Florida. In G.L. Evink, P.A. Garrett, D. Zeigler, and J. Berry, eds. Proceedings of the International Conf. on Wildlife Ecology and Transportation. June, 1996. Tallahassee, FL. FL DOT FL-ER 58-96. Lavendel, Brian. 2000. Putting the breaks on roadkill. Animals. 133(6):20-23. Mansergh, I.M., and Scotts, D.J. 1989. Habitat continuity and social organization of the mountain pygmy-possum restored by tunnel. Journal of Wildlife Management. 53(3):701-707. Rodriguez, A., G. Crema, and M. Delibes. 1996. Use of nonwildlife passages across a high speed railway by terrestrial vertebrates. Journal of Applied Ecology. 33:1527-1540. Reed, Dale. 1981. Mule deer behavior at a highway underpass exit. Journal of Wildlife Management. 45(2):542-543. Savage, Candace. 2000. A highway runs through it. Canadian Geographic. 120(5): 35-42. Scheick, B.K. and M.D. Jones. Locating wildlife underpasses prior to expansion of highway 64 in North Carolina. North Carolina Wildlife Resources Commission, Plymouth and Bridgeton, North Carolina. www.myflorida.com/emo/sched/locate.pdf. Servheen, C. 2001. U.S. Fish and Wildlife Service Grizzly Bear Recovery Coordinator. Personal Communication Nov, 2001. Singer, F.J., W.L. Langlitz, and E.C. Samuelson. 1985. Design and construction of highway underpasses used by mountain goats. Transportation Research Record. 1016:6-10. Sipes, J.L. and J. Neff. 2001. Fencing, wildlife crossings, and roads: separating animals and vehicles. Landscape Architecture. 91(6):24-27. Whyte Museum. 2000. Mitigation: Reducing the Impacts of Roads and Railways on Bears. http://www.whyte.org/bears/ mitigate.html. Wilkinson, Todd. Making the road safe — for elk, bears, and wolves. The Christian Science Monitor. 12/09/00. http:// www.csmonitor.com/durable/2000/12/19/text/p3sl.html. Yanes, M., J.M. Velasco, and F. Suarez. 1995. Permeability of roads and railways to vertebrates: The importance of culverts. Biological Conservation. 71:217-222.

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New Resources Wildlands CPR interns produced a series of excellent reports last fall. They ranged from the effectiveness of highway mitigation practices (see page 12-14) to the ecological effects of oil and gas drilling and seismic exploration. The Road-RIPorter will feature many of them in the future. These reports will be posted on our website, and you also can contact our office to receive copies of them. Many thanks to the graduate students who completed these reports for us!

Ecological Effects of Seismic Testing By Erich W. Zimmermann This report includes an incredibly clear and concise explanation of the seismic exploration, from a description of the seismic receiving and source lines to the enormous vibrasise trucks used. It also provides a detailed explanation of the profound amount of ground disturbance caused by seismic exploration.

Coal Bed Methane: One Way Road to Environmental Degradation A study of road-related impacts during development By Brian Crawford Brian looked at existing coal bed methane developments to analyze the number of miles of linear disturbance that are created through a typical project. Brian also included a short comparison to conventional gas extraction.

The Impact of Roads on Neotropical Migratory Songbirds By Roiann Matt Roian's paper summarizes the current research on the impacts that roads have on neotropical migratory songbirds in North America. She presents a detailed discussion of the main impacts: nest predation; parasitism; and habitat decline. Finally, Roian recommends several ways to minimize these impacts if road obliteration isn't an option.

Impacts of Helicopter Recreation By Emily Yeomans Emily's report is an assessment of the impacts of helicopter recreation on wildlife. It provides a survey of the scientific literature on helicopter impacts and recommendations regarding their management.

Field Guide to Road Closures By Amy Barry The new "Field Guide to Road Closures" surveys the techniques used to close routes, from the installation of road closure signs to complete road obliteration, assessing the strengths and weakness of each.

Wildlife Crossing Structures Evaluating their Use and Effectiveness — By Maureen Hartmann Maureen's report provides a detailed and compelling look at the benefits and limitations of highway mitigation structures for wildlife connectivity. She has summarized the available research, presented several case studies and included information about the research questions that remain to be answered.

The Road-RIPorter January/February 2002

Regional Reports & Updates Forest Service Interim Directives on Roadless Area Management by Mike Anderson The Wilderness Society analyzed the Forest Service’s latest interim directives on roadless area management. This latest directive affects the National Forest System Road Management Strategy (Transportation Policy). The directive takes all language within the Transportation Policy that protects roadless areas (this part of the Transportation Policy is enjoined due to lawsuits) and removes it. The interim directives — issued as an amendment to the Forest Service Manual — went into effect on December 14, 2001 and will continue for 18 months. A 60 day public comment period ends on February 19th.

Summary The new Forest Service directives significantly reduce administrative protection for national forest roadless areas. Specifically, the directives: 1. eliminate the requirement that there must be a “compelling need” for road construction in roadless areas; 2. eliminate the requirement to prepare an environmental impact statement prior to building roads in roadless areas; 3. eliminate any special protection for uninventoried roadless areas greater than 1,000 acres that are adjacent to inventoried roadless areas or wilderness areas, and; 4. create a new loophole for logging old-growth forests in roadless areas. The directives essentially allow logging and road building in roadless areas, subject to the approval of the Forest Service Chief or Regional Foresters. However, that approval requirement only lasts until local forest managers complete an amorphous “roads analysis” and update their forest plans. Logging projects in national forests that revised their plans prior to July 2001, such as the Tongass National Forest, are exempt from Chief-level review. The directives continue the policy of ultimately turning over all roadless area management decisions to the local forest planning process, which has favored logging and other development in roadless areas.

Analysis The new directives consolidate interim management direction for inventoried roadless areas (IRAs) into one section (the forest planning section) of the Forest Service Manual, and they entirely delete the roadless area section of the Transportation Policy. These changes have several negative effects on roadless area protection. First, the Transportation Policy stated that any road construction or reconstruction in IRAs may only be authorized if the Regional Foresters determine a “compelling need” for a road (FSM 7712.16b(1)(a)). The new directives eliminate that requirement. Consequently, the standard for road building in roadless areas will be reduced to the same as that in any other area — i.e. the Forest Service must determine only that the road would serve a “documented need” (FSM 7712.12b). Second, the Transportation Policy required the Regional Foresters to prepare and approve an environmental impact statement (EIS) prior to approving road building in IRAs (FSM 7712.16b(1)(c)). The new interim directives give the Forest Service discretion to determine whether or not an EIS is required (FSM 1925.04b(3)). Another section of the Forest Service directive requires an EIS only if an action would “substantially alter the undeveloped character of an inventoried roadless area” (Forest Service Handbook 1909.15,

The Road-RIPorter January/February 2002

chap.20.6(3)). Consequently, Forest Service managers could now elect to build roads in a roadless area without preparing an EIS if they determine that the roadless area would not be substantially altered. Third, by rescinding the roadless area section of the Transportation Policy, the new interim directives remove any form of protection for uninventoried roadless areas. As noted above, the special procedural requirements of the Transportation Policy applied equally to IRAs and to uninventoried roadless areas located adjacent to IRAs and wilderness areas. These “contiguous unroaded areas” often provide important wildlife corridors or other ecological values. Since the new interim directives only require Chief-level review of roadbuilding projects in IRAs, the Forest Service apparently has decided that the contiguous unroaded areas warrant no special protection of any kind. Fourth, the new directives apparently create a loophole for logging old-growth forests in roadless areas. The Roadless Rule generally prohibited commercial logging in IRAs, but included exceptions for logging that “is incidental to the implementation of a management activity not otherwise prohibited by this subpart” (36 CFR 294.13(b)(2)). The interim directives greatly broaden this exception by allowing logging “incidental to the implementation of a management activity and not otherwise prohibited under the land and resource management plan” (FSM 1925.04a(2)(b). This latter exception is far broader than the one in the Roadless Rule, since local management plans often allow unlimited logging in IRAs. In addition, the new interim directives would leave in place Chief Bosworth’s policy of allowing all roadless area decisions ultimately to be made through local forest planning. The new interim directives require approval from the Chief for road building and logging activities in IRAs, with some exceptions. However, the Chief’s approval is no longer required once a national forest completes a forest-scale roads analysis (for road-building activities) and a forest plan revision (for logging activities). — Mike Anderson is a senior resource analyst for The Wilderness Society.

Send Comments by February 19, 2002 USFS CAT Attention: Road Policy P.O. Box 221150 Salt Lake City, UT, 84122 via email to: [email protected] or via fax: 801-517-1021, to USFS CAT, Attn: Road Policy

Talking Points: * Please demand that the USFS cease any attempts to undermine protections on our National Forest roadless areas as provided by the Roadless Area Conservation Rule and the Transportation Policy adopted last January. * Urge the Forest Service and Administration to not renege on their promise to uphold protections for roadless areas. * Our National Forests currently contain over 383,000 miles of classified roads and the maintenance backlog now exceeds $8 billion dollars. The Forest Service should eliminate roads not build new ones. * These directives continue the Forest Service policy of turning over all roadless area management decisions to the local forest planning process, which has favored logging and other development of roadless areas. This marks a return to the same failed management policy that created the need for the Roadless Area Conservation Rule in the first place.

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The Forest Service and Categorical Exclusions A Primer and Update on Current Litigation — By Jim Bensman A Categorical Exclusion (CE) can be a citizen’s nightmare. The Forest Service loves to use CEs to avoid public participation and make it easier for them to violate the law. This article will help you understand CEs and how to deal with them.

What is a CE? The National Environmental Policy Act (NEPA) provides three ways for agencies to document their decisions. An Environmental Impact Statement (EIS) is a full-fledged analysis, and of the three ways, it requires the most analysis and public participation. The second way is called an Environmental Assessment (EA). An EA is basically a mini EIS. The third way is a CE. CEs can be used for “actions which do not individually or cumulatively have a significant effect on the human environment and which have been found to have no such effect in procedures adopted by a Federal agency in implementation of these regulations and for which, therefore, neither an environmental assessment nor an environmental impact statement is required.” 40 CFR § 1508.4. When a CE is used, the least amount of analysis and public participation is provided. CEs are supposed to be only used for projects that have no potential for significant impacts (i.e., cutting the grass at a Ranger Station). When the Forest Service uses an EA or EIS, they have to consider the impacts of the project. The Forest Service’s NEPA regulations include a list of categories of actions that “do not individually or cumulatively have a significant effect” on the environment. See 1909.15 FSH § 30. One example of a categorically excludable category of actions is: Repair and maintenance of administrative sites. Examples include but are not limited to: a. Mowing lawns at a District office. b. Replacing a roof or storage shed. c. Painting a building. 1909.15 FSH § 31.1b (b)(3). When the Forest Service established these categories, they made a determination that every project in that category does not have the potential for significant effects unless there are “extraordinary circumstances.” Therefore, unless there are extraordinary circumstances present, the Forest Service does not have to analyze the effects of any project in the category. To properly use a CE, the Forest Service must determine the project is in the category and there are no extraordinary circumstances present. If these conditions are met, the action can be CE’d from any more thorough NEPA process.

How do you challenge the use of a CE? The first way to challenge the use of a CE is to argue it is not in the category. The Forest Service will often try to use a CE for projects that do not fall within the categories set forth in their regulations. It is important to remember that the examples listed in the regulations are not the only items in the category. Make sure you properly identify the category (i.e., “repair and maintenance of administrative sites”). Then you

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can argue that the action was not in the category. You can argue the project does not fit the plain language of the category. You can also use the drafting history (i.e., Federal Register Notices) of the CE regulations. They have information about the intent of the Forest Service. The citation for the first notice is 56 FR 19718; (April 29, 1991). The final notice is at 57 FR 43180 (September 18, 1992 ). The second way to challenge the use of a CE is to argue that an extraordinary circumstance is present. The Forest Service NEPA Regulations at 1909.15 FSH § 30.3(2) state: “2. Extraordinary circumstances include, but are not limited to, the presence of the following: a. Steep slopes or highly erosive soils. b. Threatened and endangered species or their critical habitat. c. Flood plains, wetlands, or municipal watersheds. d. Congressionally designated areas, such as wilderness, wilderness study areas, or National Recreation Areas. e. Inventoried roadless areas. f. Research Natural Areas. g. Native American religious or cultural sites, archaeological sites, or historic properties or areas.” If any of these extraordinary circumstances are present, the Forest Service cannot legally use a CE. They must prepare either an EA or EIS. Following the law gets in the Forest Service’s way so they have come up with an illegal way to get around this requirement. Instead of preparing an EA or EIS when extraordinary circumstances are present, the Forest Service will often prepare an internal analysis and then claim there will be no significant effects to the extraordinary circumstance and then use a CE. This is illegal and we have proven it in court. The best case is the Court of Appeals ruling in our lawsuit over a project on the Shawnee National Forest: Rhodes v. Johnson, 153 F.3d 785 (C.A.7(Ill.)1998). Another relevant case is Bensman v. United States Forest Service, 984 F.Supp. 1242, 1250 (W.D.Mo. (1997). There are two more cases that have also ruled that this practice is illegal: Washington Trails Association v. United States Forest Service, 935 F. Supp. 1117 (W.D. Wash. 1996); and High Sierra Hikers Ass’n v. Powell, 150 F.Supp.2d 1023, 1044 (N.D. Cal. 2001). The Forest Service recently issued a proposal to change their regulations to get around all these court rulings. 66 FR 48412. We contend that this proposal is illegal and that we will challenge the agency if they adopt it. We even have memos from their own attorneys telling them that what they are proposing is illegal.

What about comments and appeals? When the Forest Service proposed to eliminate appeals of their projects, Congress responded by passing the Appeals Reform Act. 16 USC § 1600NOTE. The law required the Forest Service to provide a comment and appeals process for “projects and activities implementing” Forest Plans. Despite this Congressional action, the Forest Service did not provide a comment and appeals process for projects approved with CEs Heartwood and other groups filed a Petition for Rulemaking arguing that the Appeal Reform Act requires the Forest Service to provide a 30 day comment period and appeals for projects approved with a CE. The Forest Service

The Road-RIPorter January/February 2002

denied our petition. Heartwood then sued the Forest Service. We settled the lawsuit and the Forest Service agreed to immediately start providing comments and appeals for many projects including many ORV projects. They also agreed to start rulemaking to make additional projects subject to appeal. After we settled our lawsuit with the Forest Service, the Blue Ribbon Coalition sought to intervene and to vacate the settlement. The judge issued an absurd ruling that completely ignored all the guidance from the 7th Circuit. He let them intervene and vacated the settlement. We appealed to the 7th Circuit, just had oral arguments on the case and hope to prevail. While the regulations do not currently require a 30 day comment period, they still must conduct scoping for projects that are categorically excluded. 1909.15 FSH § 30.3(3). Scoping is an initial step in the NEPA process allowing interested citizens to identify issues that the Forest Service should address. It is also the time when you should argue that the proposal is not in the category and/or that extraordinary circumstances are present. Since projects approved with a CE are not subject to appeal, the Forest Service can implement the project as soon as the decision is made. Your only recourse is to file a lawsuit. But you have to act quickly. To prevent you from suing, the Forest Service will often issue a CE for an ORV race, rally or similar project on the day that project is to be implemented. You may not find out about the decision until after the project is already carried out. To avoid this, you must be vigilant about conveying your interest in such projects to the relevant Forest Service staff, you must be vigilant in monitoring NEPA project schedules (issued by every Ranger District) and advertisements for the activities you are concerned about. While it can be difficult to stop a categorically excluded project, if the use of the CE is inappropriate you should try, and you should document the impacts of the project so that you are in a stronger position to require a full environmental analysis and public participation process if the proposal reappears in the following year. If you need a copy of the Federal Register Notices, Forest Service NEPA Regulations, or the cases I mention go to http://webpages.charter.net/ jbensman1/. Our comments on the recent FS proposal are also there. — Jim Bensman is Forest Watch coordinator for Heartwood. Reach him at [email protected].

Activist Spotlight The Activist Spotlight shares the stories of some of the incredible activists we work with, both as a tribute to them and to highlight successful strategies and lessons learned. Please email your nomination for the Activist Spotlight to [email protected]. Activist Spotlight honors the outstanding work of Florida Biodiversity Project volunteer Brian Scherf. Brian has been defending Florida’s imperiled wildlands since 1968, when the construction of State Road 84 sliced through the heart of Florida’s Everglades. That’s over 30 years of dedication! In 1993 Brian united with other activists to form the Florida Biodiversity Project (FBP). FBP, a member of the Natural Trails and Waters Coalition, works proactively to preserve and restore Florida’s native ecosystems. FBP utilizes a variety of tactics to compel agencies to follow environmental laws, pushing them to Photo courtesy of the Florida Biodiversity Project. include the best scientific data in their decision making. In 1995 Brian helped FBP file suit against the National Park Service (NPS) for ORV damage in Big Cypress National Preserve, home to an exceptional number of endangered species (including the Florida panther) and rich in biodiversity. The subsequent settlement agreement forced the NPS to prepare an ORV Management Plan/Supplemental EIS. The Plan disclosed a disturbing fact: the Preserve has over 23,000 miles of mainly user-created ORV trails — nearly enough to encircle the earth! Last January, FBP, Wildlands CPR, and a number of other groups formed a coalition of defendant intervenors to defend the ORV Management Plan against a lawsuit filed by pro-ORV organizations. In the words of Jacob Smith, ORV Policy Coordinator for Wildlands CPR, “Brian has worked tirelessly to protect Big Cypress. Without his deep commitment to saving this priceless ecosystem, it would have been destroyed by irresponsible off-road vehicle use long ago.” Brian is working to have U.S. Hwy 41 and I-75 elevated where they cross the Everglades to allow for safe wildlife passage under the roads, and he’s fighting the expansion of U.S. Hwy 1 in the Florida Keys. Brian keeps road and ORV issues germane by attending local meetings, monitoring field impacts, and traveling to Washington D.C. to press his congressional delegation for action. Brian’s hard work pays off. Attorney Amy Atwood with Meyer and Glitzenstein, says: “Brian is incredibly passionate and dedicated when it comes to his work on environmental issues. He accomplishes most of his work during his own time, works tirelessly to produce famously long and detailed comment letters to agencies, attends public meetings, and is tenacious about following through on his FOIA requests. Brian is so persistent that he is no match for those who seek to continue to degrade Florida’s amazing biodiversity and natural resources.” In addition to a hefty schedule of volunteer work, Brian also holds a full-time job as a travel counselor with the American Automobile Association, working oneon-one with AAA members to help them plan their travel routes. Many AAA members travel to National Parks or across natural areas by car, and to Brian, this presents a perfect opportunity to educate them about the ecological condition of these areas. Brian notes that on US or regional maps it is easy to contrast the dense spider web network of roads with the relatively tiny area of preserves. Most AAA members are unaware of road impacts and Brian is not shy when it comes to engaging people in conversation about these issues. Often, he will even suggest ways they can take action themselves. Thanks Brian for your hard work making Florida’s natural world a better place. Contact Brian at [email protected]

The Road-RIPorter January/February 2002

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Around the Office… Thanks Wildlands CPR would like to thank the following foundations for their generous grants: Patagonia — Dillon Outlet; and thePage Foundation And thanks to all the others who responded so generously to our “Give Thanks” appeal, including: * Hi Fidelity Investment Charitable Gift Fund * Bank of America Charitable Fund (anonymously)

Newsletter Distributors We would like to thank the following Wildlands CPR members for distributing The Road-RIPorter in their hometowns: Andrew Laird, Stockbride, Michigan; Larry Glass, Eureka, California; Scott Silver, Bend, Oregon; Howie Wolke, Conner, Montana; Catherine Landis, Syracuse, New York; Howard Wilshire, Sebastopol, California; John Noyes, Kalispell, Montana; and Mary Hindelang, PhD. Chassell, MI. Thank you all! If you are interested in doing the same, email Jen Barry at [email protected] or call our office at 406-543-9551. We’d send you about 15 copies— more or less is fine—for distribution, and offer you a complimentary membership for your efforts.

Welcome Wildlands CPR welcomes two new activists to our staff: Nicky Phear and Lisa Philipps. Lisa comes to us from Colorado, where she was working on off-road vehicle issues. She is taking over as the Grassroots Coordinator for the Natural Trails and Waters Coalition. Lisa has done extensive field monitoring and worked for Colorado Wild before joining us at Wildlands CPR & Natural Trails. Her breadth of experience is refreshing and we’re sure she’ll keep you well-informed, while keeping us on our toes. Much to our chagrin, Jacob Smith has decided to move in a new activist direction. Starting in January, he began splitting his position with Nicky, and he will be working on protecting native grasslands through the Center for Native Ecosystems during the other half of his time. Fortunately, he’s made the transition as painless as possible by giving us a year to adjust to life after Jacob. During that year, Jacob will continue working out of the Colorado office, and Nicky will be working on off-road vehicle issues in our main office in Montana. Nicky brings a diverse background of outdoor education leadership and activism. Most recently she completed a stint as the acting Executive Director of the Alliance for the Wild Rockies. We couldn’t be happier to have two such terrific people join our staff, and we’re sure you’ll find them as resourceful and helpful as their predecessors and co-workers. Welcome aboard Nicky and Lisa!

New Office After nearly five years of our beloved — if a bit decrepid — grain elevator, and nearly seven years sharing space with Missoula’s Ecology Center, Wildlands CPR is moving to a new office space in downtown Missoula. We’ve tried to maintain some continuity by finding another funky space, but it certainly has a different feel to it than our current digs. We’ll miss the EcoCenter, but we’ve really outgrown our space there. Moving does have significant added costs, so if you’d like to make an extra donation, we’d sure appreciate it!

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Resources Printed Materials Road-Ripper's Handbook ($20.00, $30 non-members) — A comprehensive activist manual that includes the five Guides listed below, plus The Ecological Effects of Roads, Gathering Information with the Freedom of Information Act, and more! Road-Ripper's Guide to the National Forests ($5, $8 non-members) — By Keith Hammer. How-to procedures for getting roads closed and revegetated, descriptions of environmental laws, road density standards & Forest Service road policies. Road-Ripper's Guide to the National Parks ($5, $8 non-members) — By David Bahr & Aron Yarmo. Provides background on the National Park System and its use of roads, and outlines how activists can get involved in NPS planning. Road-Ripper's Guide to the BLM ($5, $8 non-members) — By Dan Stotter. Provides an overview of road-related land and resource laws, and detailed discussions for participating in BLM decision-making processes. Road-Ripper's Guide to Off-Road Vehicles ($5, $8 non-members) — By Dan Wright. A comprehensive guide to reducing the use and abuse of ORVs on public lands. Includes an extensive bibliography. Road-Ripper’s Guide to Wildland Road Removal ($5, $8 nonmembers) — By Scott Bagley. Provides technical information on road construction and removal, where and why roads fail, and how you can effectively assess road removal projects. Trails of Destruction ($10) — By Friends of the Earth and Wildlands CPR, written by Erich Pica and Jacob Smith. This report explains the ecological impacts of ORVs, federal funding for motorized recreation on public lands, and the ORV industry’s role in pushing the ORV agenda.

Online Resources Visit our Web Site at http://www.WildlandsCPR.org You’ll find educational materials, back issues of The RoadRIPorter (including all our bibliography, legal and field notes), and current action alerts. Also at the site, we’ve got a link to an ORV Information Site with an interactive map-based database on each National Forest’s ORV Policy.

Now available on our site: Ecological Impacts of Roads: A Bibliographic Database (Updated Jan. 2001) — Contains approx. 6,000 citations — including scientific literature on erosion, fragmentation, sedimentation, pollution, effects on wildlife, aquatic and hydrological effects, and other information on the impacts of roads. Environmental Impacts of Motorized Recreation: A Bibliography This is a 5000 citation bibliography of scientific studies, government reports, and related documents on the environmental impacts of motorized recreation. The documents cited here include scientific studies on a wide variety of adverse impacts, including: soil erosion and soil compaction, sedimentation, pollution, wildlife disturbance, habitat fragmentation and degradation, and others. Subscribe to our online list-serves. Check the boxes on the member form and receive Skid Marks and/or our Activist Alerts over email.

The Road-RIPorter January/February 2002

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