COHVCO's public comment letter regarding the Colorado Roadless Rule proposal is attached.
COHVCO would strongly encourage everyone to comment as there are groups trying to remove all access to roadless areas, despite the fact dispersed motorized is a valid use of a roadless area. Comments are due by July 14, 2011.
E-mail address for sending in your comments is COComments@fsroadless.org
Colorado Roadless Rule/EIS
P.O. Box 1919
Sacramento, CA 95812
I am contacting you to voice my support for the 57,600 acre reduction in designated Roadless areas provided by Alternative 2 of the proposed Colorado Roadless Rule. I am vigorously opposed to Alternative 4 of the proposal. I also support the continued management of dispersed motorized recreation in Roadless Areas under the Travel Management Planning process. Motorized recreationalists utilize these areas for the dispersed recreational experience they are designed to provide, a fact often lost in the application of the roadless rule.
While I support Alternative 2, I do not support the theory of upper tier area included in this proposal, as often the Roadless Rule is a source of confusion and frustration for the users of the forests. An additional level of roadless area designation will not help this situation. The upper tier area theory will make the frustration and confusion experienced by forest users worse. In addition to increasing frustration, the upper tier theory simply makes no sense in terms of providing flexibility to managers to address local fire prevention concerns. Alternative 4 simply makes no sense from this perspective as it provides an upper tier area.
I believe the increased flexibility provided by the Colorado Roadless Rule proposal is superior to the existing Roadless Rule. Given the exceptionally high fuel loads present as a result of the pine beetle epidemic, it is critical that forest managers have the full range of possible options to address the most cost effective way to reduce the risk of forest fires to mountain communities and homes. The EIS goes to great lengths to address the need for flexibility in dealing with fuels issues on the forests. The theory of upper tier area directly conflicts with this analysis as significant numbers of local communities will be directly limited in their ability to address fire prevention as a result of upper tier designations within a short distance of the community.
I am also opposed to the negative economic impact that will result from the upper tier theory in the new Roadless Rule which will result in a negative impact to the Colorado economy in excess of $100 million dollars. Given the poor state of the Colorado economy for the foreseeable future and the mandate of the Multiple Use Sustained Yield Act requirement of balancing economic interests with all other interests, I don't think this required balance has been achieved after the inclusion of the upper tier areas.
I also have concerns regarding the proposed 107,300 acre increase in roadless areas on the Pike/San Isabel Forest and the 22,300 acres increase on the San Juan Forest. These expansions of roadless areas are directly in conflict with the stated need for flexibility in fire management that is discussed at length in the EIS. Clearly an areas designation as roadless will reduce the tools available to managers to deal with fire mitigation issues.
(please remember to include your address )