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Published on Wildlands CPR (http://www.wildlandscpr.org)

Understanding the new National Forest System Road Management Strategy

After years of fights over congressional spending on Forest Service road construction, the Forest Service finally began a national transportation policy assessment and revision. On January 28, 1998, in an Advance Notice of Proposed Rulemaking (63 FR 4350), the Forest Service announced its intent to revise regulations concerning management of the National Forest Transportation System. After considering the comments from that notice, the Forest Service split their process to include two separate policy actions, one to address the national forest transportation system, the other to address national forest roadless areas (referred to in this document as "Roadless Policy").

On March 3, 2000, in Part III of the Federal Register, the Forest Service issued an overview notice to provide background information on the need to change the agency's national forest development transportation system, as well as the proposed rule. A 77-day comment period followed, closing on May 17, 2000. While the Forest Service Roadless Policy draft environmental impact statement (DEIS) garnered 1.7 million comments, the Roads Strategy environmental analysis (EA) only received 5,700 comments. Groups and organizations representing forest resource users accounted for 134 responses, while conservation and preservation groups submitted only 97 responses. This policy affects not only the 446,000 miles of classified and unclassified roads, but also the entire National Forest system with the exclusion of Wilderness areas.

The following assessment refers to the Final EA on the National Forest System Road Management Strategy, as well as the Final Rule and Final Policy. The complete text of all three can be downloaded from the Forest Service web site at http://www.fs.fed.us/eng/road_mgt/ [1]. The changes in rules are reflected in Forest Service regulations (36 CFR Parts 212, 261 and 295). The changes in policy are reflected in the Forest Service Manual, Titles 1900 (Planning) and 7700 (Transportation System); these are also available on the Forest Service website at http://www.fs.fed.us/eng/road_mgt/ [2]. Forest Service Chief Mike Dombeck signed the Road Management Strategy Rule and Policy on January 5, 2001. It was published in the Federal Register on January 12, 2001.

According to the Forest Service, the new National Forest System Road Management Strategy proposes an important shift in emphasis from "transportation development" to "managing access within the capability of the land." As the Final EA states, "it would extend the traditional transportation-planning engineering focus on technical and economic analysis to include more complete integration of environmental considerations" (5-6). However, the new strategy merely provides programmatic guidance for future management of the Forest Service's road network; it does not make any on the ground land management decisions. The new strategy does not contain any specifics about how many miles of roads will be decommissioned, nor does is set road density standards or default limits to road construction in certain sensitive areas. These decisions will still be made at the local forest level with input from the Roads Analysis Process, which is a key component of the new strategy (discussed below). Further, the new policy only deals with road issues; trails and motorized recreation are not addressed, with the important exception that the final rule modifies 36 CFR section 212.20 to require that Forest Service trails be identified in the forest transportation atlas (see below - Transportation Atlas).

The overall emphasis of the new strategy is to "balance scientific information, public needs, safety and environmental protection, and funding levels" (Final EA, 2). The focus is on road reconstruction and decommissioning, as opposed to road construction and transportation
development.

BACKGROUND ON FOREST SERVICE ROAD SYSTEM

While the Forest Service has 386,000 miles of (classified) Forest System roads under their jurisdiction, Forest Service lands also contain an additional 137,000 miles of roads within their boundaries, including 54,600 miles of public roads, 22,400 miles of private roads, and 60,000 miles of unclassified, unauthorized roads. This puts the total number of roads fragmenting habitat and damaging watersheds and streams at approximately 523,000 miles within the national forests. The Forest Service is responsible for the 386,000 miles of classified roads and the 60,000 miles of unclassified roads. States, counties, other agencies and private landowners are responsible for the remaining miles.

A couple of definitions will make it more clear how each of these different types of roads are managed, and under whose jurisdiction:

While the distinction between public and administrative roads may seem minimal, it is not. The Forest Service currently has the ability to close any road or trail within its system if that travelway is causing resource damage, if it may impact wildlife, or if there are public safety or health issues. Public roads, however, can only be closed in an emergency to public health and safety. Interestingly, in 1999, with the passage of TEA 21, the Forest Service became a public road authority. As such, the Forest Service is now pushing to convert their main access roads (approximately 77,000 miles of arterial and collector forest development roads) to public roads. By doing this, they can get Federal Highways Administration money to pave and "improve" these roads. Transferring a Forest System road to a public road will likely mean paving the road (thus increasing access and terrestrial impact). It will also mean that the Forest Service can no longer close these roads except in an emergency to public health and safety.

The Forest Service also estimates there are another 60,000 + miles of unclassified routes. The road management strategy will apply only to forest service roads (classified and unclassified). The road strategy does not apply to private, state or local roads that cross National Forest Service lands. However, in a significant departure from past practices, the existence and impact of these private, state and local roads will now be considered in the roads analysis process conducted in any given area.

About 20% (77,000 miles) of classified Forest Service roads are main access roads that serve all users (arterial and collector roads), 57% are local roads typically passable by high-clearance vehicles, and 23% provide intermittent access for administration, protection, and non-highway vehicle use (Cost Benefit Analysis, E3). The Forest Service estimates that between 260,000 miles and 300,000 miles of National Forest System roads will exist after implementation of the road management strategy (Final Environmental Assessment, 105). This is down from a current total of 446,000 miles of classified and unclassified roads. The Forest Service has not made clear if this number includes the 77,000 miles of main access roads that they want to convert to public roads.


COMPONENTS OF THE ROAD MANAGEMENT STRATEGY

The Road Management Strategy directs forest managers to do the following:
It is important to note that with this language the Roads Strategy provides interim protection for road construction in roadless areas, until the Roadless Policy is implemented (see below - inventoried roadless and other unroaded areas). Even while the roadless policy is being delayed, the Forest Service is required to follow some significant guidelines for road construction in roadless areas.

TIMELINE FOR IMPLEMENTATION

Forest Service Chief Mike Dombeck signed the Road Management Strategy Rule and Policy on January 5, 2001. It was published in the Federal Register on January 12, 2001.

Within two years of the effective date of the final road management strategy, each Forest System unit must complete a forest-scale road analysis (Final EA, 4).

Any project decision, ecosystem assessment, or forest plan revision published within six months of the effective date of the final road management strategy would not require a roads analysis [This is so that nearly completed plans don't have to start over]. All such proposals after that time would be the subject of either a roads analysis process or appropriate documentation explaining why information from a higher-level roads analysis (a forest-or watershed-level analysis) was not needed to inform this project-level decision (Final EA, 30). The Forest Service has not yet clarified under what circumstances a decision could be made without roads analysis?

DEFINITIONS UNDER 36 CFR 212.1

Below is a list of all the relevant definitions that were included in the new strategy, with some comments on those definitions. Several definitions were not changed, but they are also included for the sake of consistency.

Ownership/Jurisdiction
Forest development road -- "A road wholly or partially within or adjacent to a National Forest System boundary that the Forest Service has authorized and maintains jurisdiction over and that is necessary for the protection, administration, and use of lands under the agency's jurisdiction." Forest development roads are not public roads (FSM 7705) in the same sense as roads that are under the jurisdiction of public road agencies, such as states or counties...(T)hey are authorized only for the administration and utilization of National Forest System lands.

Road -- "A motor vehicle travelway over 50 inches wide, unless designated and managed as a trail. A road may be classified, unclassified, or temporary." This is a problematic definition because there is no way to differentiate a road from a trail "on the ground" - trails can be over 50 inches as well. Wildlands CPR submitted the following definition as an alternative:

(1) Classified Roads -- "Roads wholly or partially within or adjacent to National Forest System lands that are determined to be needed for long-term motor vehicle access, including State roads, county roads, privately owned roads, National Forest System roads, and other roads
authorized by the Forest Service."
(2) Temporary Roads -- "Roads authorized by contract, permit, lease, other written authorization, or emergency operation not intended to be part of the forest transportation system and not necessary for long-term resource management."
Temporary roads are required to be revegetated within 10 years of completion of their use. Temporary roads can remain active for upwards of 5 years as part of timber sales. Unless the road is classified as a specified short-term road (see FSM 7701.2), there are no design standards for temporary roads other than location, clearing width, and state best management practices (where they exist).
(3) Unclassified Roads -- "Roads on National Forest System lands that are not managed as part of the forest transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle tracks that have not been designated and managed as a trail; and those roads that were once under permit or other authorization and were not decommissioned upon the termination of the authorization."
Wildlands CPR requested that all illegally created unclassified routes mapped as part of the transportation atlas must be closed until site-specific analysis can be completed to determine whether to remove or decommission the travelway, or to open and classify the travelway as a road, motorized route or non-motorized trail. In FSM 7703.2, the Forest Service states that "unclassified roads will be closed and made inaccessible where funding permits unless they are made part of the authorized forest road system as provided for in this policy" (Final Policy, 51). The decision to classify an unclassified road would come through the Roads Analysis process. It is important to note, however, that the final policy does not place a blanket closure on all existing user-created routes.

Service Life
Constant service (long-term road) -- "A long-term facility developed and operated for continuous or annual recurrent service."

Intermittent road -- "A road developed and operated for periodic service and closed for more than one year between periods of use."
The road can be stored for future use by removing culverts and improving drainage so the road causes minimal damage to watershed/ecosystem health until it is reconstructed.

Short-term road -- "A facility developed and operated for a limited period of time which will cease to exist as a transportation facility after the purpose for which it was constructed is completed, and the occupied land is reclaimed and managed for natural resource purposes."

Activities
New Road Construction -- "Activity that results in the addition of forest classified or temporary road miles."

Road decommissioning -- "Activities that result in the stabilization and
restoration of unneeded roads to a more natural state." Activities used to decommission a road include the following: (1) reestablishing former drainage patterns, stabilizing slopes, and restoring vegetation; (2) blocking the entrance to the road, installing water bars, removing
culverts, re-establishing drainage-ways, and removing unstable fills; (3) pulling back road shoulders; (4) scattering slash on the roadbed; (5) complete elimination of the roadbed by restoring natural contours and slopes; and (6) other methods designed to meet the specific conditions associated with the land around the unneeded road.

Road Maintenance -- "Expenditures in the minor restoration and upkeep of a road necessary to retain the road's approved traffic service level."
Replacements of existing structures, such as culverts or bridges is considered maintenance, while increasing culvert size or improving a bridge would be considered "improvement."

Road reconstruction -- "Activity that results in improvement or realignment of an existing classified road as defined below:

Contracts
Specified road -- Roads authorized for a specific resource need (e.g. logging, mining, grazing). This term can be applied to constant, intermittent or short-term roads.

TRANSPORTATION ATLAS FSM 7711

The Forest Service is replacing the Forest Transportation Plan with the Forest Transportation Atlas. The Atlas is "an inventory, description, display, and other associated information for those roads, trails, and airfields that are important to the management and use of National Forest System lands or to the development and use of resources upon which communities within or adjacent to the National Forest depend." Each national forest, national grassland and experimental forest must maintain a transportation atlas, which will be available to the public at administrative headquarters units. The Forest Road Atlas is a key component of the Transportation Atlas and "will include the location of unclassified roads and any management actions taken to change the status of unclassified roads" (Final Policy, 62).

For years, activists around the country have been ground-truthing Forest Service transportation maps - both documenting and inventorying routes that exist on the ground, but don't exist on FS maps, and also documenting the effectiveness of road closures. With this transportation atlas, the Forest Service is finally acknowledging that they need to have their own understanding of what types of travelways are out there on the ground, how that compares to what they planned for, and how that compares to what they actually need. The transportation atlas will be the first ever Forest Service inventory of their full transportation system, including trails, and as such, it will provide a baseline for understanding future changes to the transportation system, in addition to providing an excellent tool for analyzing the density and impacts of roads and trails on the ground. While all routes will be mapped, the Forest Service will distinguish between classified and unclassified routes.

ROADS ANALYSIS PROCESS FSM 7712.1

This is a new process very similar to the watershed analysis process for determining needs and priorities of the Forest Service's road system. "The Responsible Official shall incorporate an interdisciplinary science-based roads analysis into multi-forest, forest-scale, and watershed or area-scale analyses and assessments to inform planners and decisionmakers of road system opportunities, needs, and priorities that support land and resource management objectives." The Roads Analysis process does not replace NEPA in regards to making road management decisions. "Rather, road management decisions must be informed by roads analysis and disclosed in an appropriate NEPA document (FSM 1950 and FSH 1909.15)." Results and findings of the roads analysis process will be used in forest plan amendments and revisions. The Roads Analysis does include opportunities for public involvement.

The Forest Service estimates that the cost for a stand-alone (not part of forest plan revision) roads analysis is $40,000 - $50,000 per forest.

"Pursuant to FSM 7710.41, the Deputy Chief, National Forest Systems, may approve other science-based analysis methods for field use through amendments to this chapter" (Final policy, 66).

The Roads Analysis process should provide a good opportunity for activist involvement in determining the fate of roads on our National Forests. Wildlands CPR is in the process of conducting an in-depth scientific analysis of the Forest Service's proposed Roads Analysis process. We hope to have preliminary results of this analysis by the end of March.

INVENTORIED ROADLESS AND OTHER UNROADED AREAS

"Until a comprehensive road inventory and forest-scale road analysis had been completed and incorporated as appropriate into a forest plan (through a forest plan amendment or revision or the Forest Supervisor made a written determination that the forest plan did not require amendment or revision to reflect the findings of the roads analysis), there would be an interim requirements period during which a demonstration of a compelling need would be required to construct or reconstruct a road in either an inventoried roadless area or in a contiguous unroaded area (as defined by the Final Interim Rule)" (Final EA, 4).

According the Final Policy, the examples of compelling need may include, but are not limited to:
To the extent consistent with the Tongass National Forest Land and Resource Management Plan and all applicable laws, the Regional Forester for Region 10, … has specific authority to determine that a compelling need exists to provide for the multiple-use and sustained-yield of all renewable resources of the Tongass National Forest, including seeking to meet market demand for timber" (77, Final Policy).

Contiguous unroaded areas are defined as 1,000 acres or more that are contiguous to: (1) remaining unroaded portions of RARE II inventoried roadless areas, (2) roadless areas inventoried in land and resource management plans, (3) congressionally designated wilderness areas or federally-administered components of National Wild and Scenic River System classified as Wild, or (4) unroaded areas of 5,000 acres or more on other federal lands (Final EA, 40).

If and when the Roadless Policy goes into effect, it overrides the Road Management Strategy except that the Strategy would still apply to roads that are built under one of the road building exceptions in the Roadless Rule. In the meantime, however, and while Congress debates the fate of the Roadless Policy, road construction in roadless areas can only occur within the above explained sideboards. Road construction, for example, cannot be justified simply on the basis of logging, except in the Tongass National Forest. Further, if Congress overturns the Roadless Policy, the Road Management Strategy will still apply to roadless areas, providing some continued protection from new road construction in roadless areas.

ROADLESS AREA VALUES

The Forest Service dropped the only specific language regarding roadless values in the entire policy - FSM 1922.15 paragraph 28 which stated that the forest planning process must "ensure that management prescriptions protect values associated with unroaded conditions such as unique or important habitat for wildlife, fish and plant species, sources of drinking water, cultural or
historic areas, sources of dispersed recreation, barriers to invasive species, high or unique biological diversity, or research." They dropped this paragraph "in deference to the final Land and Resources Management Planning Final Rule, which addresses protection of roadless values" (Final Policy, 18).

However, the Final EA does make the following statements regarding roadless area values:
  1. The Forest Service states that in response to strong public sentiment, they need to manage their lands "to take into account roadless area values such as scenic quality, solitude, and primitive recreational opportunities" (2). On page 15 they add refugia and habitat connectivity to this list.
  2. The Final EA assumes that the combined effect of implementing the road management strategy, the Roadless Rule and the Planning Rule will lead to a "reduction in road densities and possibly the creation of unroaded areas" (107).
  3. "Land management plan goals, such as reducing road densities for big game or recreation management, eliminating failing roads in riparian areas, or reducing fragmentation of a particular wildlife habitat, may result in road decommissioning projects" (107).
  4. "Eliminating roads to reduce road density and not creating unroaded areas is likely to be the most common decommissioning scenario accounting for perhaps 90% or more of road decommissioning" (107).
  5. "The Agency estimates that unroaded area acres are likely to increase 5% to 10% by the time NFS roads stabilize at 260,000 miles to 300,000 miles nationally" (108).
  6. "The [Land and Resource Management] Planning Rule would require the responsible official, at the time of plan revision, to identify and evaluate the important social and ecological characteristics of unroaded areas and inventoried roadless areas, and make a determination if they should receive any additional protection" (108). It is not clear what this additional protection would be.

ECONOMIC ANALYSIS

The Cost Benefit analysis for the Roads Strategy basically assessed the economic impacts of the potential reduction in timber harvest. The FS used timber harvest numbers for contiguous unroaded areas and inventoried roadless areas (which were already analyzed in the Roadless FEIS). The Final EA states that "the most tangible social and economic cumulative effect is the potential for an incremental decline in timber harvesting resulting from the proposed or final road management strategy" (95).

The Cost Benefit Analysis focuses on jobs lost by reducing road construction (thus reducing timber harvest); it does not assess the benefits of jobs gained through road reconstruction and obliteration. It does state that "increased job opportunities may also be available as a result of increased road decommissioning and reconstruction on all NFS lands" (Cost Benefit Analysis, E15). What it does not acknowledge is that reducing new road construction merely maintains the status quo in those areas where it applies. In other words, to assess an economic cost to maintaining the status quo is disingenuous. It is impossible to know which projects would go through and which projects would not come to fruition, so the economic cost is based on an assumption of future timber sales. There is no economic "cost" to not building new roads, since preventing new road construction is basically a "no-action" approach. What it is really assessing is lost "opportunity costs" for not logging even more land.

In addition, the Cost Benefit Analysis assesses the "costs" of preventing some new road construction, but not the economic benefits of removing some roads. Nor does it account for the benefit of money saved by not building new roads and by not needing to maintain those roads. Nor does it account for the benefit of reduced maintenance costs associated with road removal. The assessment is flawed assessment at its base. Further, the Final EA talks specifically about jobs created for road construction and reconstruction (20 jobs per $1 million expended), but not for road obliteration (Final EA, 68).

Finally, the net benefits discussed are all ecological benefits: "Net benefits through improving water and air quality, wildlife and fish habitat, protection of wilderness areas and passive use values, and reducing the spread of noxious weeds and invasive plants" (E2). The EA includes no discussion of the economic costs of building new roads and all the ecological consequences that can require expensive mitigation, and continued maintenance.

In terms of economic impacts, any and all analysis of the economics of roads needs to include indirect as well as direct costs. Indirect costs might include such components as reconstruction when a road fails in storm events, or damage to public community drinking water systems, or county and state roads located down slope from unmaintained FS roads. Clearly the cost-benefit analysis should be greatly improved and expanded. Conducting a more balanced and illustrative economic analysis of costs and benefits of this policy may help the Forest Service gain public support, instead of public opposition to their Road Strategy.

UNCLASSIFIED ROUTES

The Forest Service will "not maintain unclassified roads except under emergency resource protection circumstances. Unclassified roads will be closed and made inaccessible where funding permits unless they are made part of the authorized forest road system as provided for in this policy" (FSM 7703.2(1)). The Forest Service includes no discussion of closing unclassified routes until site specific analysis is completed. Unclassified routes will be mapped on the transportation atlas and considered for decommissioning or classification under the Roads Analysis Process. Under the new policy, classifying an unclassified route will be treated the same as new road construction, thus triggering NEPA (conversation with Tom Pettigrew, Region 1 Engineering, 1/31/01).

Wildlands CPR advocates that all illegally created unclassified routes must be closed until site-specific analysis (NEPA) can be completed to determine whether to remove or decommission the travelway, or to open and classify the travelway as a motorized route or non-motorized trail. 36 CFR 261.10(a) states that "constructing, placing, or maintaining any kind of road, trail...on National Forest system land or facilities without a special-use authorization, contract, or approved operating plan" is prohibited. In addition, illegally-created unclassified routes should not be allowed to remain open while that site specific analysis takes place since they may be causing "adverse environmental impact" (NEPA 40 CFR 1506.1(a)(1)). Classifying a user created route as a road is no different than constructing a road and must be prohibited in roadless areas in addition to requiring full environmental analysis outside of roadless areas.

DECOMMISSIONING

Roads that pose the greatest risk of causing environmental damage would be given decommissioning priority. The Forest Service expects that this will consist primarily of unclassified roads, but also of unneeded classified roads. However, it is highly likely that the Forest Service will determine that "needed" classified roads are causing or will cause significant environmental damage. Whether or not they are willing to consider removing those roads remains to be seen.

According to the Final EA, "the road management strategy should result in aggressive decommissioning of roads..." (76). It is likely, however, that the majority of those roads will not be those causing the most significant environmental impact. This is one arena in which ground-truthing and local involvement (which are called for throughout this strategy), may be able to encourage more environmentally responsible assessments for road removal.

"The Forest Service estimates that, at a minimum, approximately 2,900 roads would be decommissioned annually under the proposed or final road management strategy" (Final EA, 108). Roads may also be converted to trails. In 1999, the FS decommissioned 2,907 miles of road, but there is no break down as to how many miles of roads received what decommissioning technique. It is possible, even probable, that the majority of those roads were simply gated and taken off the system, without being treated for their ecological effects.

FUNDING

The Forest Service doesn't have a big enough annual budget to deal with its road system - "current funding provides only 20 percent of funds necessary to fully maintain Forest Service roads to intended safety, service, and environmental standards" (Cost Benefit analysis, E8).

"Addressing only immediate threats to health and safety, resource protection, access, and basic operation would require $197 million per year, about double current funding levels" (Cost Benefit analysis E8).

The Forest Service needs an estimated annual road budget of $900 million to: (Final EA, 106)

The Forest Service also is exploring the benefits of converting selected high use roads to public roads to qualify more roads for funding from the Federal Highway Trust Fund (Final Rule, 26). The Forest Service's intent is to convert the approximately 77,000 miles of main access roads to public roads. Some of these roads would then come under the jurisdiction of the Federal Highways Administration with their requirements for straightening and widening roads and increasing road verge widths. Other roads would remain under the Forest Service's jurisdiction. However, once a road became a public road, the Forest Service would lose their authority to close that road except for emergency public health or safety reasons. The significance of this type of wholesale conversion cannot be understated. While paving some dirt roads may reduce overall sedimentation to nearby rivers and streams, larger, smoother roads bring more vehicles at higher speeds, causing increased terrestrial impacts such as roadkill and habitat fragmentation. Road upgrades and improvements for traveling comfort and speed are also likely to lead to increased "development" along the roads, and to continue the trend of promoting "drive-through" recreation on national forest lands.

SPECIFIC LANGUAGE

The Roads Strategy contains some specific information about how they are assessing roads and road impacts, and the overall intent of the policy. Some of the most significant pieces that did not fit into the above categories are listed below.
  1. The FS only views road impacts as a factor of the miles of roads, and whether they are located in inventoried roadless, contiguous unroaded or roaded areas (Final EA, 19). The final rule doesn't factor in their placement on the landscape.
  2. The FS does not maintain data on how forest roads are used (Final EA, 22).
  3. The final road management strategy would exempt the Sierra Nevada Framework from the roads analysis requirement (Final EA, 101). The alternatives in the SNF Project DEIS don't show any decline in NFS road miles.
  4. The final road management strategy would exempt the ICBEMP from the road analysis requirements (Final EA, 101). The ICBEMP DEIS does project declines in road miles.
  5. ANILCA projects are "observed." Wildlands CPR will take a closer look at exactly how the new policy and rule will deal with ANILCA projects.
  6. "The demand for recreation on NFS lands is expected to continue to increase, so managers would increasingly have to make decisions to accommodate additional use without ecological degradation [this plays into the 70,000 miles of roads to upgrade to public roads]. No spatial data exists to demonstrate current patterns of use on NFS lands" (E18). It is important to note that part of that demand is for primitive recreation, which the Forest Service ignores.
  7. "Implementation of road maintenance activities does not require a roads analysis before proceeding; however, roads analysis is a useful management tool to help set maintenance priorities" (Final policy, 68).
  8. "Roads that were important to recreational users would not likely be decommissioned" (Final EA, 57).

CONCLUSION

The Forest Service's new Roads Management Strategy is a step in the right direction for improving transportation management and transportation impacts on wildlands. It includes many opportunities for local citizens to engage in the new planning processes and to voice their concerns and ideas about better transportation management. It provides the Forest Service with an opportunity and obligation to develop baseline data about their transportation system - a responsibility they have avoided for the past 100 years. Wildlands CPR will continue to expand on this analysis of the new Roads Management Strategy as it is implemented. We will also provide a more complete assessment of how citizens and activists can become more engaged in the processes described in the Roads Strategy. For more information, or if you have specific questions about this policy, please feel free to contact our office at the phone or email address listed below.

For more information, contact:
Marnie Criley, Road Policy Coordinator
Wildlands CPR
PO Box 7516
Missoula, MT 59807
406/543-9551
Source URL:
http://www.wildlandscpr.org/understanding-new-national-forest-system-road-management-strategy

Links:
[1] http://www.fs.fed.us/eng/road_mgt/
[2] http://www.fs.fed.us/eng/road_mgt/