Wildlands CPR Issues New Report on Forest Service Road Management
Often referred to as “the largest road building entity in the world,” the Forest Service boasts a road system of nearly 380,000 miles that cut across national Forest lands. The agency also acknowledges a minimum of 60,000 miles of additional roads that are not “formally” in their system, but that do exist on the land. Wildland roads degrade clean drinking water; fragment wildlife habitat; create vectors for the spread of non-native, invasive weeds; severely damage fisheries and hunting opportunities; and otherwise impact national forest resources. While some of these roads provide needed access for resource management and others provide recreational access, the agency has far more roads than it needs or can manage.
The result: an oversized, under-maintained, unaffordable, and ecologically destructive road system. It took the agency nearly 100 years to build all these roads (mostly for logging), and it is likely to take just as long to reduce the road system back down to a manageable size.
With such a vast road system, and so much potential for ecological damage, Wildlands CPR set out in 2005 to conduct a formal assessment of the Forest Service road system and its management.
We sent a Freedom of Information Act (FOIA) request to the Forest Service asking for documents relating to the road system and the methods the agency uses to manage and track that system in the 85 western national forests. After nearly two years of litigation and negotiation, the information arrived, and we are now finalizing a report about the agency’s road management strategies and its failure to effectively protect America’s natural resources.
Reviewing all of the FOIA information together paints a picture of a management approach oriented to transportation rather than land and resource management. By focusing administrative protocols on safety and road miles maintained, the Forest Service impedes its own mission, which is “…to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present
and future generations” (US Forest Service 2009). The agency should re-focus on identifying and mitigating the negative effects of the road system. The following sections provide more insight into the key documents we reviewed.
Each forest completes a RAR every year, detailing maintenance and management based on mileage and cost. But RARs do not link tracked actions to on the ground activities, so there is no way to discern environmental benefits or costs. Just prior to publishing our report, we learned of a separate database (that we did not receive) that links road management spending to watershed issues, but apparently that database also fails to document actual road impacts, mitigation or restoration needs. Apparently
in FY 2008 some data from these two databases was combined, but we do not have that information.
The RARs that we reviewed showed significant discrepancies in road accounting from year to year. They also highlighted the limited amount of maintenance the agency is able to accomplish. For example, between the end of FY 2002 and the start of FY 2003 (essentially from one day to the next), 1063 miles of road disappeared in Region 1 (Northern Region). Similarly, between 2002 and 2003, the Intermountain Region (Region 4) lost 1,748 miles, only to add 1,690 miles between the end of 2003 and the start
of 2004. While not all examples were this egregious, the inconsistencies in the RARs are numerous and highlight a lack of knowledge about how many miles of roads the agency has, where they are, and how they are managed.
According to the RARs nationally, the Forest Service had approximately 80,000 miles of roads on its system in 2001. Over the next six years, they decommissioned roughly 4,000 miles while adding about 5,000 miles— so, the 2007 total should be 381,000 miles, yet the 2007 RARs report only 75,000 miles. What happened to the other 6,000 miles? Are they still here? Is the agency managing them?
Perhaps more significantly, passenger vehicle access decreased nearly 5% from 1995 through 2007 – now totaling ~69,000 miles of roads. The Forest Service estimates that about 80% of road use occurs on only 20% of the roads – mostly the passenger vehicle roads. Yet the agency does not have the funding to maintain those roads to standard, so they have been letting passenger roads “degrade” to lower maintenance levels. This theoretically saves money (road maintenance on passenger vehicle roads
costs an average of $5000/mile, while road maintenance on high clearance vehicle roads averages $500/mile), but it also has the potential to increase wildlife, fisheries and clean water impacts, which cost money to mitigate. It also means that if the agency wants to upgrade these roads back to passenger
vehicle standards it will be very expensive, as roads degrade dramatically over time when they are not maintained (see RIPorter v14, #1).
These problems are further complicated by the Forest Service roads database, INFRA. INFRA is an unwieldy, incomplete, problem-plagued database that fails to accurately track the Forest Service road system and its impacts. INFRA focuses on road mileage, road surface types, vehicle types allowed, and maintenance levels, yet it fails to document related resource issues. This provides another example of the agency’s transportation rather than resource management orientation. For example, no INFRA data fields indicate whether a road is in need of maintenance, when it was last physically inspected, or its distance from a water source.
There is no field to link a road to its National Environmental Policy Act (NEPA) analysis, making it nearly impossible to ascertain when, if ever, a road’s environmental impacts were evaluated. Few, if any, protocols exist to assure accuracy, which causes numerous problems such as incomplete and ad hoc tracking of deferred maintenance costs. Without archival data, it’s impossible to understand how management has changed over time. For example, was a passenger vehicle road downgraded to high clearance, or was it always that way. In addition, because there’s no tracking, even “corrections” to the database could, over time, result in significant changes on the ground without any environmental analysis.
INFRA also tracks road maintenance levels, which are subject to change without notice and may not reflect the original design or purpose of a road. For example, maintenance levels have been changed in the past (e.g. switching a road from passenger level travel to high clearance vehicle travel) at least in part, to reduce the fiscal burden of the road maintenance backlog (at least on paper). Finally, INFRA data can be difficult to connect with GIS layers, and when connected sometimes proves to be an inaccurate representation of conditions on the ground (i.e. roads that do not exist in INFRA are mapped in the GIS layer, or vice versa).
Conclusion
As the largest road-builder in the world, the Forest Service has assumed a management style more akin to a transportation agency than a resource management agency. The result: a bloated road system that
is ecologically damaging and fiscally irresponsible. The Forest Service needs to establish a new direction for the 21st century that incorporates road management in an environmental rather than transportation/access framework. By doing so, they can identify and implement a right-sized road system that is both ecologically and economically sustainable over the long-term.
— Sarah Peters is Legal Liaison for Wildlands CPR; Greg Peters is a contract researcher who will also be heading up Wildlands CPR’s Citizen Monitoring program on the Clearwater National Forest this summer.
The result: an oversized, under-maintained, unaffordable, and ecologically destructive road system. It took the agency nearly 100 years to build all these roads (mostly for logging), and it is likely to take just as long to reduce the road system back down to a manageable size.
With such a vast road system, and so much potential for ecological damage, Wildlands CPR set out in 2005 to conduct a formal assessment of the Forest Service road system and its management.
We sent a Freedom of Information Act (FOIA) request to the Forest Service asking for documents relating to the road system and the methods the agency uses to manage and track that system in the 85 western national forests. After nearly two years of litigation and negotiation, the information arrived, and we are now finalizing a report about the agency’s road management strategies and its failure to effectively protect America’s natural resources.
Reviewing all of the FOIA information together paints a picture of a management approach oriented to transportation rather than land and resource management. By focusing administrative protocols on safety and road miles maintained, the Forest Service impedes its own mission, which is “…to sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present
and future generations” (US Forest Service 2009). The agency should re-focus on identifying and mitigating the negative effects of the road system. The following sections provide more insight into the key documents we reviewed.
Road Accomplishment Reports
Each forest completes a RAR every year, detailing maintenance and management based on mileage and cost. But RARs do not link tracked actions to on the ground activities, so there is no way to discern environmental benefits or costs. Just prior to publishing our report, we learned of a separate database (that we did not receive) that links road management spending to watershed issues, but apparently that database also fails to document actual road impacts, mitigation or restoration needs. Apparently
in FY 2008 some data from these two databases was combined, but we do not have that information.
The RARs that we reviewed showed significant discrepancies in road accounting from year to year. They also highlighted the limited amount of maintenance the agency is able to accomplish. For example, between the end of FY 2002 and the start of FY 2003 (essentially from one day to the next), 1063 miles of road disappeared in Region 1 (Northern Region). Similarly, between 2002 and 2003, the Intermountain Region (Region 4) lost 1,748 miles, only to add 1,690 miles between the end of 2003 and the start
of 2004. While not all examples were this egregious, the inconsistencies in the RARs are numerous and highlight a lack of knowledge about how many miles of roads the agency has, where they are, and how they are managed.
According to the RARs nationally, the Forest Service had approximately 80,000 miles of roads on its system in 2001. Over the next six years, they decommissioned roughly 4,000 miles while adding about 5,000 miles— so, the 2007 total should be 381,000 miles, yet the 2007 RARs report only 75,000 miles. What happened to the other 6,000 miles? Are they still here? Is the agency managing them?
Perhaps more significantly, passenger vehicle access decreased nearly 5% from 1995 through 2007 – now totaling ~69,000 miles of roads. The Forest Service estimates that about 80% of road use occurs on only 20% of the roads – mostly the passenger vehicle roads. Yet the agency does not have the funding to maintain those roads to standard, so they have been letting passenger roads “degrade” to lower maintenance levels. This theoretically saves money (road maintenance on passenger vehicle roads
costs an average of $5000/mile, while road maintenance on high clearance vehicle roads averages $500/mile), but it also has the potential to increase wildlife, fisheries and clean water impacts, which cost money to mitigate. It also means that if the agency wants to upgrade these roads back to passenger
vehicle standards it will be very expensive, as roads degrade dramatically over time when they are not maintained (see RIPorter v14, #1).
Roads Rule
In January 2001, the Forest Service adopted a national Roads Rule. The intent was to identify a fiscally and ecologically sustainable minimum road system that meets both resource management and recreational access needs. The agency estimated this minimum system would be between 146,000 – 186,000 miles smaller than the current system, and that it would take 20-40 years to achieve that new equilibrium. However, the agency has repeatedly adopted new directives reducing the requirements for compliance with the 2001 Roads Rule, and postponing, indefinitely, the identification and implementation of a minimum road system. Most forests, for example, have analyzed only their passenger vehicle roads and found that most are needed in the minimum system. By failing to examine their lower-grade roads, they have been unable to identify a minimum system that is meaningfully smaller than the current system. It appeared, with the 2005 adoption of the Travel Management Rule, that the Forest Service would finally begin long-term comprehensive planning for travel management, but that effort was segmented (see Policy Primer, pages 6-7), further postponing the identification and implementation of a minimum system.INFRA
These problems are further complicated by the Forest Service roads database, INFRA. INFRA is an unwieldy, incomplete, problem-plagued database that fails to accurately track the Forest Service road system and its impacts. INFRA focuses on road mileage, road surface types, vehicle types allowed, and maintenance levels, yet it fails to document related resource issues. This provides another example of the agency’s transportation rather than resource management orientation. For example, no INFRA data fields indicate whether a road is in need of maintenance, when it was last physically inspected, or its distance from a water source.
There is no field to link a road to its National Environmental Policy Act (NEPA) analysis, making it nearly impossible to ascertain when, if ever, a road’s environmental impacts were evaluated. Few, if any, protocols exist to assure accuracy, which causes numerous problems such as incomplete and ad hoc tracking of deferred maintenance costs. Without archival data, it’s impossible to understand how management has changed over time. For example, was a passenger vehicle road downgraded to high clearance, or was it always that way. In addition, because there’s no tracking, even “corrections” to the database could, over time, result in significant changes on the ground without any environmental analysis.
INFRA also tracks road maintenance levels, which are subject to change without notice and may not reflect the original design or purpose of a road. For example, maintenance levels have been changed in the past (e.g. switching a road from passenger level travel to high clearance vehicle travel) at least in part, to reduce the fiscal burden of the road maintenance backlog (at least on paper). Finally, INFRA data can be difficult to connect with GIS layers, and when connected sometimes proves to be an inaccurate representation of conditions on the ground (i.e. roads that do not exist in INFRA are mapped in the GIS layer, or vice versa).
Conclusion
As the largest road-builder in the world, the Forest Service has assumed a management style more akin to a transportation agency than a resource management agency. The result: a bloated road system that
is ecologically damaging and fiscally irresponsible. The Forest Service needs to establish a new direction for the 21st century that incorporates road management in an environmental rather than transportation/access framework. By doing so, they can identify and implement a right-sized road system that is both ecologically and economically sustainable over the long-term.
— Sarah Peters is Legal Liaison for Wildlands CPR; Greg Peters is a contract researcher who will also be heading up Wildlands CPR’s Citizen Monitoring program on the Clearwater National Forest this summer.