The ABC’s of Travel Planning

In 2005, the Forest Service published new regulations in the Federal Register1 (commonly called the Travel Management Rule) for managing the Forest Service Transportation System. The Travel Management Rule, found in the Code of Federal Regulations (36 CFR 212), has three sections: Subpart A, “Administration of the Forest Transportation System”; Subpart B “Designation of Roads, Trails, and Areas for Motor Vehicle Use”; and Subpart C “Use by Over-Snow Vehicles.” This article explains the intersection of these three subparts during the travel planning process.

Subpart A
In 2001, then Forest Service Chief Mike Dombeck signed the “Road Management Strategy Rule and Policy,” commonly known as the “Roads Rule.”2 This rule signaled a new direction for the agency, as its goal was to guide future management of the entire road network. Decisions on road density standards and decommissioning were left to the local level, and each national forest had two years to determine the “minimum road system required to balance access objectives with ecosystem health goals.”3 To meet the deadline the agency looked only at roads for passenger vehicles, called maintenance level 3, 4 or 5 roads. Left out were roads closed to the public and those for high clearance vehicles (maintenance level 1 and 2 respectively) — analysis for these roads was delayed until a project level action triggered review. Unfortunately, most national forests still have not completed a comprehensive review of their entire road system.

Fast forward to 2005, when, with the release of the Travel Management Rule, many forest officials promptly forgot about their obligations under the Roads Rule. While significant changes were made to the old policy, two key requirements remained. The first is that “the responsible official must identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands.”4 In order to identify the minimum road system, the Forest Service must complete a full, science-based roads analysis. The second requires responsible officials to “identify the roads … that are no longer needed to meet forest resource management objectives and that, therefore, should be decommissioned or considered for other uses, such as for trails.”5

These two requirements are essential to any good travel management plan. With a comprehensive review, maintenance level 1 and 2 roads will be examined. Unfortunately, there has been a tendency among land managers to shortcut the review process by only addressing Subpart B of the travel management rule.

Subpart B
Unmanaged motorized recreation was a key threat identified by former Forest Service Chief Dale Bosworth, who instituted the 2005 Travel Management Rule. To address the threat, the rule mandates that forest officials produce a Motor Vehicle Use Map (MVUM) illustrating the specific routes and areas open to summer off-road vehicle use. The MVUM becomes the basis for enforcement, and users must know where travel is legal by referencing the map, not by relying solely on road or trail signs. This establishes a “closed unless open” policy where roads, trails and areas are protected from motorized use unless the map shows otherwise. Forest officials can release an MVUM that simply designates the official road and trail system, or it can propose changes through the travel planning process.6

However, motorized recreation is only one aspect of travel management, and the opportunity to create good transportation and recreation plans is often lost in the mad rush to produce an MVUM — the Subpart A requirement for comprehensive review has been one such casualty. Bosworth tied each national forest’s annual performance review to the publication of an MVUM, and all travel plans must be completed by December 2009.

To guide implementation of the 2005 Travel Management Rule, the agency proposed new directives in its forest manuals and handbooks. One, called “travel analysis,” incorporates the roads analysis (discussed below) and goes a step further by including motorized routes. Release of the final directives is not expected until spring 2008. However, we have already seen at least one forest, the Black Hills National Forest (SD), complete a travel analysis in preparation for travel planning, and expect that other forests will follow suit.

Subpart C
The Travel Management Rule eliminated 36 CFR 295: “Use of Motor Vehicles Off National Forest System Roads,” which had provided authority to manage snowmobile use. To replace it, Subpart C of 36 CFR 212 was created. Unfortunately, while the new rule (mostly) eliminated cross-country travel, it separated its impacts between uses, effectively de-emphasizing damage and disruption caused by snowmobile use. This means that separate winter use plans or existing forest plans will guide snowmobile use. The deadline for completing MVUMs does not apply to motorized winter recreation, so the agency is under no obligation to address over-snow vehicles during travel planning.

Roads Analysis Through Travel Analysis
The roads analysis process as adopted in 2001 was intended to be comprehensive, looking at multiple scales (eco-regional, forest, and project) and evaluating the ecological effects of roads. But that goal was never realized, as analysis was done only at the forest scale, and only for maintenance level 3-5 roads. It can be argued that “travel analysis” now gives the Forest Service a second chance at roads analysis, and activists should try to persuade agency officials to finish what they started when they analyzed their maintenance level 3-5 roads.

In the draft directives, before the agency proposes a travel management action, officials are to conduct travel analysis. We are awaiting the final directives before evaluating them fully, but key points stand out. The proposed Chapter 20 for the Forest Service Handbook [FSH 7709.55 Ch. 20.02(1)(a)] states that one objective is to identify the minimum road system needed and establish a complete inventory of all system roads and trails7. The first step is to “complete an interdisciplinary science-based analysis of road system opportunities.”8 Travel analysis must be based on “a complete and accurate inventory of NFS roads, NFS trails, and designated areas within the area being analyzed.”9 This does not mean that every user-created route on the forest must be mapped, but that the previously authorized travel system must be determined. Travel analysis, similar to roads analysis, should be “broad-scale,” and should inform the decisions made at the Ranger District or administrative level that implement the “minimum road system” and make “travel management decisions.”10

Unfortunately, this weakens a key part of the roads analysis process. The proposed directives removed the requirement that a roads analysis should be based on the “best available” science,11 instead requiring a “science-based” analysis. The proposed directives also de-emphasize the need to remove roads, and instead concentrate on adding to the existing system. This allows more roads to be identified as necessary for a minimum system and for fewer roads (if any) to be identified for decommissioning.

Travel Planning and Subpart A
Unfortunately, many forest officials skip travel analysis, missing an opportunity to evaluate their maintenance level 1 and 2 roads and highlight opportunities for decommissioning. Another problem is that the purpose and need of a travel planning project is sometimes phrased in a manner that narrows its scope to only designating motorized recreational use, avoiding decisions on the minimum roads system.
In order to address these shortcomings, Wildlands CPR recommends the following actions:

• Request that travel planning meet Subpart A obligations, identifying the minimum road system and recommending the removal of unneeded, damaging roads and trails;
• Verify that officials completed a roads analysis that included all roads. If maintenance level 1 and 2 roads were not evaluated, then demand they be assessed through travel analysis;
• Request that officials conduct travel analysis before developing proposed actions, and include a science-based travel analysis at multiple scales;
• Find out the forest’s obligations under their forest plan. Initiating subpart B independent of the minimum road system may conflict with the Forest Plan in regards to (1) environmental and fiscal resource objectives [36 CFR 219.10(a)(b)];
• Remind officials that they must identify the minimum road system as required by Executive Order 11644.

Conclusion
Since the 2005 Travel Management Rule’s release, Forest Service officials have focused almost exclusively on designating summer motorized recreation and effectively ignored their obligations under 36 CFR 212, Subparts A and C. It is necessary to ask each responsible official to conduct travel analysis, as outlined in the draft directives, and to include roads analysis and snowmobiles. Even then, conservationists will need to make sure such analysis considers multiple levels, is science-based and includes all system roads. Finally, even the best analysis is useless if the responsible official artificially narrows the travel planning scope to focus only on designating summer motorized recreation routes. Conservationists need to meet with the Forest Service to request that they conduct a comprehensive travel planning process that includes all recreational uses and identifies the minimum road system, including decommissioning opportunities.

Footnotes
1 Federal Register Vol. 70, No. 216/Wednesday, November 9, 2005.
2 See The Road RIPorter issue 6-2 or visit http://www.wildlandscpr.org/understanding-new-national-forest-system-roa....
3 Federal Register Vol. 66, No. 9/Friday, January 12, 2001.
4 36 CFR 212.5(b)(1).
5 36 CFR 212.5(b)(2).
6 See The Road RIPorter Vol. 10-4 for a full explanation or visit http://www.wildlandscpr.org/long-anticipated-forest-service-orv-rule-fiz...
7 Draft FSH 7709.55.
8 Draft FSM 7712.4(1).
9 Draft FSM 7712.1(4).
10 See Draft FSM 7712.1(2).
11 Draft FSM 7710.3(1).