Open letter to Gov. Kempthorne by Robert Krumm, former federal land manager, regarding roadless management in Idaho
Dear Governor Kempthorne,
I attended the Valley County Commissioner's public meeting in McCall regarding roadless area management, and I have strong objections to the Valley County public comment process as outlined at the meeting.
I worked as a federal land manager throughout the West, Alaska and Washington, D.C., for over 30 years. I've had considerable experience in federal land and resource planning, environmental statements and public involvement in natural resource decision-making. Based on this experience, I was shocked at the complexity of the comment process. In my opinion, the volume and complexity of the process negates the value of requesting public input.
The county-designed comment form alone is very difficult to understand, even for citizens that attended the public meeting. For example, the county form asks to name the "Management Unit" a person is commenting on. However, Forest Service maps passed out at the meeting identify "Inventoried Roadless Areas" not "Management Units." It was necessary to log on to the Payette National Forest Web site to find out what a "Management Unit" is, its name and where they are located in the forest. This was very confusing and time consuming for me, despite having spent a career doing similar work.
At the McCall meeting, we were told that a citizen must fill out a separate form for every "Unit" to be commented on (a formidable task). However, I was told by a person who attended the Cascade meeting that if their comments are the same for several "units," they can be combined on one form. I surmise that even the county officials are confused--or are making up the rules as the process develops.
It is critical that this confusion be cleared up, because county officials made it very clear that the form must be filled out precisely and correctly and the comments must be specific not generalized. Otherwise, they said, the comments would be ignored.
Another problem: How do citizens who weren't at the meetings or live in a different county or in another state submit comments and be assured their comments are considered by the county commissioners? In fact, the process implies that only locals have the right or the capability to submit meaningful comments. If this is the case, the process to be used in Valley County is seriously flawed and possibly illegal. All Americans have a stake in the management of our national forests and, if they desire, all have a right to comment on the management of the public's land.
I am suspicious that the intent of the Valley County designers of the process was to skew the procedures so that commercial users' opinions would outweigh comments from ordinary citizens. The more difficult the comment process, the less chance that general public comments will be forthcoming.
Anyone who has a long acquaintance with the national forests in Valley County will remember the devastating soil blowouts in the 1960s along the South Fork of the Salmon River. The siltation damage to the river and the salmon spawning gravels are still very obvious after 35 or 40 years. It was caused by careless logging and inadequate logging roads. Anyone who can ignore what happened on the South Fork while deciding how to manage roadless areas is not thinking straight about the consequences to the environment or the economy.
In Appendix C of the Final Environmental Impact Statement covering National Forest Plans in Region 4, Forest Service planners prepared an analysis called, "Consequences of Wilderness or Non-Wilderness Recommendations." The analysis was done in components, soil and water, wildlife, fish, plants, etc. The consequences of development in non-wilderness units were similar in each case. Development would adversely affect soil by increasing erosion, water quality by sedimentation, fish evolution and habitat would be interrupted and the plant world's natural ecological succession could be disrupted. The more development (or use by motorized vehicles), the greater the adverse consequences.
The list goes on, but one thing is evident--if roadless areas are developed (and damaged by vehicles), there is a very real chance that we will experience other shameful episodes comparable to the South Fork disaster. It takes very, very little disturbance to mess up the granitic soils of the Idaho Batholith. Idaho's pristine watersheds, our premier asset, depend on all of us to keep this fact foremost in our minds and actions.
Please, Governor, leave Idaho's remaining roadless areas roadless. They are an irreplaceable treasure and add immense value to Idaho's economy.
--Robert C. Krumm,