8/2/2006 - ADBSS Comments on Roadless Rule

ARIZONA DESERT BIGHORN SHEEP SOCIETY

P.O. Box 21705

Mesa, Arizona 85277

854-8950 ·(480) 854-8966-fax

www.adbss.org

July 15, 2006

The Honorable Janet Napolitano                               

Governor of Arizona

1700 West Washington

Phoenix, AZ 85007

Re: USFS Roadless Rule

Dear Ms. Napolitano,

The Arizona Desert Bighorn Sheep Society (ADBSS) wishes to express to you our concerns relative to the USFS Roadless Rule. As currently presented we cannot support the rule or the resulting special land allocation.  There are far too many potential pitfalls in this type of broad special land allocation to allow wholesale acceptance without specific provisions ensuring that wildlife management, wildlife conservation, responsible natural resource management and reasonable public access will be maintained. 

The ADBSS would support the rule if your office were to petition the Department of Agriculture to successfully secure the following provisions with any Inventoried Roadless Area (IRA) land allocation in the state of Arizona:

1.  That no additional layers of bureaucracy or added administrative burdens be presented with any roadless area land allocation that could result in obstacles to sound wildlife and natural resource management.  The USFS is already hampered with a plethora of conflicting mandates and policies that currently present significant obstacles to natural resource management and wildlife conservation activities and it makes little sense to blindly add to this burden. Consequently we would suggest that your petition contain specific wording allowing these activities to continue as they do today without any additional administrative processes or encumbrances.

  • Under this category is a particular concern that the roadless area land allocation could present an obstacle to managing vegetation encroachment and invasive brush in lower elevation habitats. What we need is more sensible management of these lands and more aggressive use of fire to return these habitats to a more natural condition. Efforts to improve habitat should not be limited to T&E species but instead should also include benefits for all wildlife including wild game. Commercial logging is not an issue on the vast majority of the roadless lands inventoried in Arizona, especially those in the southern and central parts of the state. Excessive fuel buildup and vegetation encroachment are significant problems throughout the state and mitigation efforts for the benefit of all wildlife should not be complicated by this land allocation.
  • Continued access to construct, maintain and refurbish wildlife waters including livestock tanks.  Objections to vehicular use is often the mechanism used by active management opponents to thwart wildlife water activities.
  • Administrative access to conduct population monitoring and wildlife related research. Every year complications arising from restrictions on vehicle use and the timeliness and expense of helicopter transport negatively impacts wildlife research and monitoring, i.e., retrieval of wildlife collars, ground and aerial surveys, etc.

2.  That all existing roads currently contained within any roadless area are to remain open.  Public access to our public lands is already an ongoing struggle, especially in southern Arizona, and we should not embrace anything short of at least maintaining the current status quo. In addition your petition should clarify the definition of what constitutes a road so that future inventories and travel management decisions are not biased and do not result in errant closures.

3.  That provisions be provided in the roadless area land allocation that would allow the construction of new roads wherever the closure of existing roads and routes on adjacent private, state or federal lands might be presented.  The Heritage program has been very successful in providing access to public lands when confronted with obstinate private property owners or changes in the status of adjacent public lands. We would not like to see any IRA become an obstacle to this program and its goal of providing reasonable public access to our public lands. 

Unless these provisions are clearly articulated in your petition and secured in the text of the resulting roadless area land allocation a great disservice will have been served upon sportsmen and the wildlife conservation programs we all enjoy.  Please do not trust any verbal assurances that these concerns will be allowed in subsequent tiered planning processes. Our experience has shown that these concerns need to be clearly addressed at the land allocation resource level and not deferred to a later time when memories fade, staff or administrations change or funding is less available.

Thank you for your careful consideration of this Roadless Rule. We trust you will work towards ensuring that these public lands and the natural resources they contain will be managed appropriately for all to enjoy.

Sincerely,

Jerry Guevin

President

xc        Duane Shroufe, Director, Arizona Game and Fish Department

            Mike Burris, President, Wildlife Conservation Council

            Mary Jo Miller, President, Arizona Wildlife Federation

            Pete Cimellaro, Executive Director, Arizona Sportsmen for Wildlife

            Bill Geer, Theodore Roosevelt Conservation Partnership