Roads are a widespread threat to streams, water quality, and wildlife on National Forests

Recently, several counties in eastern Oregon submitted a petition to the Office of the Department of Agriculture asking to have the Malheur and Wallowa-Whitman National Forests exempted from the 2005 Travel Planning Rule. Blue Mountains Biodiversity Project is extremely concerned about the current state of roads on National Forests in eastern Oregon. We strongly believe that the current out-of-control road densities on National Forests urgently need to be reduced in order to minimize harm to streams, water quality, wildlife, and ecosystem integrity. BMBP and Friends of the Clearwater submitted the following letter to the Office of the Department of Agriculture:

On behalf of thousands of supporters, we are writing to emphasize the importance of completing travel planning on the Malheur and Wallowa-Whitman National Forests as required under the 2005 Final Rule for Travel Management; Designated Routes and Areas for Motor Vehicle Use, and to request that travel planning be completed on these forests as soon as possible. Travel planning for the Malheur and Wallowa-Whitman National Forests is essential for protecting public safety, water quality, and forest ecosystems in a fiscally responsible manner. Travel planning under the 2005 Final Rule is long overdue and urgently needed on the Malheur and Wallowa-Whitman National Forests.

We are concerned that the Office of the Secretary of Agriculture may be considering exempting these forests from the 2005 Final Rule for Travel Management; Designated Routes and Areas for Motor Vehicle Use as a result of a petition submitted on March 1^st, 2019 by the Chairs of several Eastern Oregon Counties. Forest Service compliance with the existing mandates to complete travel planning as required by the 2005 Final Rule for Travel Management would benefit public safety and access, as well as protect water quality, forest ecosystems, and native wildlife. The Forest Service has a social and economic responsibility to complete travel planning as directed by the 2005 Final Rule; the agency should not be hindered by delays or exemptions.

The 2005 Final Rule for Travel Management “requires designation of those roads, trails, and areas that are open to motor vehicle use”. The Rule explains that “clear identification of roads, trails, and areas for motor vehicle use on each National Forest will enhance management of National Forest System lands; sustain natural resource values through more effective management of motor vehicle use; enhance opportunities for motorized recreation experiences on National Forest System lands; address needs for access to National Forest System lands; and preserve areas of opportunity on each National Forest for nonmotorized travel and experiences.” [1]

The bloated and sprawling road systems on National Forest lands, including the Malheur and Wallowa-Whitman National Forests, are fiscally burdensome as well as ecologically harmful. In discussing budget shortfalls, the Forest Service notes, for example, that on the Malheur National Forest, “it would take approximately $56 million dollars to bring the entire road system back up to standard, and about $6.2 million per year to keep it that way”. [2] For the Wallowa-Whitman National Forest, it would take approximately $64 million dollars to bring the entire road system back up to standard, and approximately $6.8 million dollars to keep it that way. [3] On Blue Mountains National Forests, which includes the Malheur and Wallowa-Whitman National Forests, the Forest Service states that the “allocated annual road maintenance budget for national forests in the Blue Mountains only provides approximately 20 percent of the required annual maintenance funds needed to adequately maintain the current open road system. The annual shortfall adds to an already substantially deferred maintenance backlog”. [4] Across Oregon and Washington, the USFS manages approximately 90,000 miles of roads. The agency notes that it is “a challenge to maintain all roads to proper safety and environmental standards to increased use, aging infrastructure, and decreasing budgets. Many roads, built between 1950 and 1990, have exceeded their designated lifespan and require costly repairs. Unmaintained roads and infrastructure can impact water quality and wildlife habitat, especially fish-bearing streams. Backlog maintenance projects top $1.2 billion, and funds available for road maintenance are only about 15% of what is needed to fully maintain the current road system.” [5] Clearly, the Forest Service needs to conduct analyses in order to determine how to operate within budgetary constraints and minimize environmental damage. Avoiding measures that seek to remedy these issues is fiscally irresponsible and potentially jeopardizes public safety.

Roads are ubiquitous on National Forest lands. The Malheur National Forest contains 7,033 miles of open roads and 2,637 miles of closed roads, for a total of 9,670 miles of existing inventoried roads. [6] The Wallowa-Whitman has 4,633 miles of open roads and 4,486 miles of closed roads for a total of 9,119 miles of existing roads. [7] One could drive from the northwestern tip of Washington state to the farthest northeastern tip of Maine, down to Miami, Florida, over to San Diego, California, and back up to the northwestern tip of Washington state, and still not have traveled as many road miles as are contained within either the Malheur or the Wallowa-Whitman National Forests. The USFS notes that “of the 90,000 miles of Forest Service roads in Oregon and Washington, about 2/3 of those are currently open and maintained for both public and administrative uses.” The USFS estimates that approximately 12% of the overall road network is “likely not needed”, with many of these unneeded roads already being “closed or stored”, and only about 20% or 2,000 miles being currently open to the public. [8]

Existing roads (in red) shown on the Malheur National Forest (administrative boundary in light green). Data sources and software: FSGeodata Clearinghouse accessed at https://data.fs.usda.gov/geodata/edw/datasets.php; GoogleEarth Pro.

The Malheur and Wallowa-Whitman National Forests currently have existing road densities at levels that are recognized as threats to water quality, fish, and watershed health. [9] [10] [11] [12] [13] [14] The Malheur and the Wallow-Whitman National Forests continue to exceed Forest Plan standards for road density in many watersheds, including those designated for prioritizing the protection of water quality and fish. [15] Existing average road density on the Malheur National Forest is 3.56 miles per square mile. The average open road density averaged across the forest is 2.56 miles per square mile. If Wilderness and Roadless areas are excluded, then the average existing road density is 4.23 miles per square mile and the open road density is 3.05 miles per square mile. [16] Wilderness and Roadless areas occupy a small percentage of these forests, and the excessive road density outside of these areas has serious and ongoing negative ecological consequences for the majority of watersheds on these forests. Wilderness areas, for example, occupy approximately 17.1 percent of the combined area of the Malheur and Wallowa Whitman National Forests, and only four percent of Oregon’s total land area [17].

The bloated road networks on National Forests lands in the region, including the Malheur and Wallowa-Whitman National Forests, threaten the long-term viability of Bull trout, steelhead, and other ESA-listed fish and aquatic species. The Forest Service notes that “[t]he most important road related environmental issue is the effects of roads on aquatic resources in general, and specifically Threatened, Endangered and Sensitive aquatic species (bull trout, mid-Columbia steelhead, and Columbia spotted frog).” [18] High road densities have been correlated with low population levels and declines in bull trout and other aquatic species that rely on clean, cold waters. [19] In addition, current standards may not be sufficiently protective to provide for the recovery of species such as Bull trout. [20] Of particular concern are roads that interact with stream channels. For example, there are approximately 3,300 miles of roads on the Malheur National Forest that are considered riparian roads [21], and are within or directly adjacent to streamside corridors. Such roads are likely to have disproportionately negative effects on water quality and sensitive fish. [22] Sedimentation from roads is known to be one of the largest contributors for degradation to water quality as well as a source of degradation to fish habitat and spawning areas. Roads in disrepair create safety issues and conflicts with protection for natural resources, especially for those such as water quality, aquatic species, and functioning wetland processes. The ongoing violations of road density standards, and the pervasive state of disrepair of many roads on National Forest lands, are also harmful to terrestrial and avian species that are sensitive to forest fragmentation and road-related disturbances.

Responsible Travel Planning on the Malheur and Wallowa-Whitman National Forests is essential for restoring water quality and aquatic ecosystems, and protecting wildlife habitat. Identifying a sustainable road network that operates within budgetary constraints is also key to providing for recreation and public safety. Travel Planning that address long-standing ecological and economic issues is a win-win-win approach: (1) it’s a win for the Forest Service’s budget, closing the gap between large maintenance needs and drastically declining funding through congressional appropriations; (2) it’s a win for wildlife and natural resources because it reduces negative impacts from the forest road system; and (3) it’s a win for the public because removing unneeded roads from the landscape allows the agency to focus its limited resources on the roads we all use, improving public access across the forest and helping ensure roads withstand strong storms.

We urge you to encourage the Malheur and Wallowa-Whitman National Forests to comply with the common-sense requirements promulgated under the 2005 Final Rule for Travel Management; Designated Routes and Areas for Motor Vehicle Use. Thank you for considering our thoughts and request.

Sincerely,

Paula Hood, Co-Director, Blue Mountains Biodiversity Project

Gary McFarlane, Ecosystem Defense Director, Friends of the Clearwater

References:

[1] USDA Forest Service (2005). 36 CFR Parts 212, 251, 261, and 295. Travel Management; Designated Routes and Areas for Motor Vehicle Use. Accessed online at: https://www.fs.fed.us/recreation/programs/ohv/final.pdf

[2] US Forest Service (2015). Malheur National Forest Forest-Wide Travel Analysis. Pg. 28.

[3] US Forest Service (2015). Malheur National Forest Forest-Wide Travel Analysis. Pg. 28.

[4] US Forest Service (2018). Malheur National Forest Land Management Plan. Accessed online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd584606.pdf

[5] US Forest Service. Webpage. Accessed at: https://www.fs.usda.gov/detail/r6/landmanagement/?cid=fseprd485439]

[6] US Forest Service (2015). Malheur National Forest—Roads Analysis—Describing the Situation. Table 9, page 28. Accessed online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_033277.pdf

[7] US Forest Service. Travel Analysis Report. Wallowa-Whitman National Forest. Table 3, page 19. Accessed online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd486098.pdf

[8] US Forest Service (2018). Malheur National Forest Land Management Plan. Accessed online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd584606.pdf

[9] Carnex and Frissell, C. (2009). Aquatic and Other Environmental Impacts of Roads: The Case for Road Density as Indicator of Human Disturbance and Road Density Reduction as Restoration Target; a Concise Review. The Pacific Rivers Council.

[10] Cederholm C., Reid L., Salo E. (1980). Cumulative effects of logging road sediment on salmonid populations in Clearwater River, Jefferson County, Washington. College of Fisheries, University of Seattle, Washington.

[11] Frissell, C.; Carnefix, G. (2007). The Geography of Freshwater Conservation: Roadless Areas and Critical Watersheds for Native Trout. Wild Trout IX symposium.

[12] National Oceanic and Atmospheric Administration (NOAA) 1996. Coastal Salmon Conservation: Working Guidance for Comprehensive Salmon Restoration Initiatives on the Pacific Coast.

[13] Ripley, T., Scrimgeour, G., and Boyce, M. 2005. Bull trout (Salvelinus confluentus) occurrence and abundance influenced by cumulative industrial developments in a Canadian boreal forest watershed. Can. J. Fish. Aquat. Sci. 62:2431–2442.

[14] US Forest Service 2000. Forest Roads: A Synthesis of Scientific Information. United States Department of Agriculture, General Technical Report, Pacific Northwest Research Station.

[15] US Forest Service (2018). Final Environmental Impact Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. Volume 1, Chapter 3, Page 360.

[16] US Forest Service (2018). Final Environmental Impact Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. Volume 1, Chapter 3, Pages 358-360.

[17] US Forest Service (2018). Final Environmental Impact Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. Volume 1, Pages 1 and 224-226.

[18] US Forest Service (2015) Malheur National Forest—Roads Analysis—Executive Summary. Page v.

[19] United States Fish and Wildlife Service (USFWS) (2010). Bull Trout Final Habitat Justification: Rational for Why Habitat is Essential, and Documentation of Occupancy.

[20] United States Fish and Wildlife Service (USFWS) (2010). Bull Trout Final Habitat Justification: Rational for Why Habitat is Essential, and Documentation of Occupancy.

[21] US Forest Service (2018). Final Environmental Impact Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. Volume 1, Chapter 3, Page 359.

[22] US Forest Service (2018). Final Environmental Impact Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. Volume 1,Pages 258-259; 266-267; 358-359