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    InsIde

    Visit us online: wildlandscpr.org

    The Road RIPoRTeR

    spring equinox 2012. Volume 17 no. 1

    TakIng sTock of Travel PlannIngBy Josh Hicks, The Wilderness Society

    A Look Down the Trail, by Bethanie Walder. Page 2

    Taking Stock of Travel Planning, by Josh Hicks. Pages 3-7

    DePaving the Way: Restoration Funding and IRR, byBethanie Walder. Pages 8-9

    Biblio Notes: The Value of Wildlife Crossing Structures, byLiz Fairbank. Pages 10-14

    Wildlands CPR 2011 Annual Report. Pages 15-18

    Policy Primer: Forest Planning, by Sarah Peters and AdamRissien. Pages 19-23

    Get with the Program: Wildlands CPRs Oregon Team.Pages 24-25

    Odes to Roads: Rainforest Roads, by William Laurance.Pages 26-28

    Around the Ofce. Page 29

    Membership Info. Page 30

    Wildlands CPR photos.

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    2012 Wildlands CPR

    Wildlands CPR revives and protects wild placepromoting watershed restoration that impro

    fish and wildlife habitat, provides clean waterenhances community economies. We focus

    reclaiming ecologically damaging, unneeded and stopping off-road vehicle abuse on public

    P.O. Box 7516Missoula, MT 59807

    (406) 543-9551

    www.wildlandscpr.org

    Director

    Bethanie Walder

    Development DirectorThomas R. Petersen

    Science Program DirectAdam Switalski

    Legal Liaison/Staff AttornSarah Peters

    Policy SpecialistAdam Rissien

    Washington/OregonField Coordinator

    Marlies Wierenga

    Program AssociateGrace Brogan

    Journal EditorDan Funsch

    Board of DirectorsSusan Jane Brown, Dave Heller,

    Marion Hourdequin, Crystal Mario, Kathi NiBrett Paben, Jack Tuholske

    ORV BMPS IN THE HOT SEATBy Bethanie Walder

    A LOOK DOWNTHE TRAIL

    Afunny thing happened as we were preparing this issue of the Road-RIPorter, and we now findourselves in the midst of a controversy involving federal officials and the off-road vehicle com-munity. It began to erupt when the Senate Energy and Natural Resource Committee recently

    eld an oversight hearing on the Forest Services budget request for Fiscal Year 2013. About an hournto that hearing, Senator Barasso (R-WY) questioned Forest Service Chief Tom Tidwell about the011 publication of a report, A Comprehensive Framework for Off-Highway Vehicle Trail Manage-

    ment. This report was developed cooperatively between USDA Forest Service, National Park Servicend Federal Highways Administration.

    enator Barasso was concerned about the Best Management Practices (BMPs) included in the reports

    ppendices, because those BMPs were written by Wildlands CPR. He said that it undermined theredibility of the Forest Service to publish them. Chief Tidwell defended the BMPs, but shortly there-fter, seven off-road vehicle organizations sent a letter to USDA Secretary Tom Vilsack opposing theublication of the report for a variety of reasons including the BMPs, and the use of inflammatorynd derogatory language.

    hats when things got really interesting, because we found out that the Comprehensive Frameworkwas no longer available online. Its unclear when the report was actually pulled, and if that happenedefore or after the Senate Oversight Hearing and/or the submission of the opposition letter to Sec-etary Vilsack. What is clear, however, is that a group of off-road vehicle organizations discoveredhat our Best Management Practices had been adapted for use in this report and they werent veryleased.

    heir letter to the Secretary (ccd to the heads of the Forest Service, Park Service and FHWA) referredo Wildlands CPR as a radical and extreme group, and claimed that the BMPs were not scientifi-ally-based and therefore unjustified for inclusion in the Comprehensive Framework.

    ndeed, the Comprehensive Framework excerpted sections of our full report Best Management Prac-ces for Off Road Vehicle Use on Forestlands, co-authored with Wild Utah Project. We developedhese BMPs with a rigorous review of the research and best available science on off-road vehicle im-acts, and included that information in the full version of the BMPs. In addition, our ORV BMPs wereecently published in the peer-reviewedJournal of Conservation Planning.

    We have since sent our own letter to the same parties addressed by the off-road vehicle organiza-ons. Our letter defends the BMPs and specifically requests that the full Comprehensive Frameworke posted back online and made available to the public again as soon as possible. It turns out that

    he Comprehensive Framework was printed in late 2011. As far as we know, the report is still avail-ble in print form, but not in electronic format. This entire controversy is humorous, in a way, since

    he Comprehensive Framework is actually a guide to constructing off-road vehicle trails in a sustain-ble way to ensure the trails will be long-lasting with limited maintenance needs. Its also focused on

    meeting recreational objectives, so we were somewhat surprised to be asked, but happy to consento republishing our BMPs when the Forest Service requested it.

    Well be continuing to engage with the USDA and the Forest Service to come to an effective outcome.Keep an eye on our blog to learn more.

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    continued on next page

    TAKING STOCK OFTRAVEL PLANNING

    By Josh Hicks, The Wilderness Society

    ntroductionn late 1999 Wildlands CPR and The Wilderness Society,oined by more than 100 other conservation and recreationrganizations, submitted a rule-making petition to the Forestervice asking them to overhaul their regulations for dirtikes, ATVs and other off-road vehicles (ORVs). That peti-on was an important catalyst for the Forest Services 2005ational Travel Management Rule (the Rule), requiring allational forests to limit ORVs to designated routes. Whenhe Rule was published, it marked the beginning of the endf cross-country travel, the free-for-all, anything goes man-

    gement paradigm where ORVs drive wherever they want.he promulgation of the Rule kick-started hundreds of localravel management planning processes on forests and dis-ricts across the country processes that would determinewhich routes would be open for motorized travel and whichwould be closed.

    Since the 2005 rule was published, hundreds of travel planning processes have come and gone, with somestill in play. Weve had both successes and setbacks in our advocacy efforts. As a result of the travel planning

    process (with at least 20 decisions still to come), the Forest Service largely ended cross-country travel, therebybringing new protection to tens of millions of acres. At this point in time, the Forest Service has declined to addthousands of miles of unauthorized, user-created routes to the system, far outweighing the smaller number ofsuch routes that they did add as formal system routes as a result of this process.

    Its important, however, that as we celebrate our successes, we take into account some difficult truths. One ofthese truths is that those unauthorized routes not designated during travel planning have not, of course, just dis-appeared. For the most part, theyre still on the ground, still causing damage. Reclaiming these routes is no smalltask. Furthermore, the Forest Service still has about 373,000 miles of system roads enough to travel from theearth to the moon and halfway back. Theyve told us to expect that the overall system may actually grow as theremaining final decisions come out.

    Outcomes Vary WidelyLets move from the national perspective to a regional one and explore two examples to understand the impor-tance of engaging in these processes. The Forest Services Southwestern Region (AZ and NM) directed its foreststo conduct travel analysis as the first step in travel planning. And while the travel analysis step has delayed thetravel planning timeline in the southwest, it has led to better decisions and considerably smaller road systemsthan in other regions. For example, the Mountainair Ranger District on the Cibola NF in New Mexico proposedto reduce its road system from 471 miles to 178 miles, a 62% reduction, in the revised draft plan. Their Envi-

    One of the benefits of travel planning is the restriction of cross-country travel fronearly all national forest lands. Photo by Dan Funsch.

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    TRAVEL PLANNING, contd

    onmental Assessment used a route density calculation (as opposed tooad density) that takes into consideration all trails as well as roads. Thisoute density assessment offers a more accurate account of the impactshat the transportation system is having on forest resources. Under theproposed action, route density would be reduced from 2.45 to 1.18 mi/

    mi. This new action would make the road system on the Cibola muchess ecologically impacting to wildlife. Numerous peer-reviewed studiesnd that road densities above 1 mi/mi2 are problematic for many differ-nt species of wildlife.

    At the other end of the spectrum is California. For years we unsuccessfullyrged the Regional Forester and Forest Supervisors across the state to usehe travel planning process to streamline the road system. Countless let-ers, meetings, and phone calls from conservation and recreation groupscross the state as well as letters from members of Congress did not sway

    he Forest Service to change their approach. The regional office refusedo conduct travel analysis as part of travel planning, opting instead to usehe travel planning process primarily to add routes to the motorized trans-portation system. As such, forests across California have increased theirransportation system by more than 800 miles. The travel plan decisionor the Stanislaus NF, located on the western slope of the Sierra Nevadamountain range, was one of the worst in the state. The Wilderness So-iety (TWS) and Central Sierra Environmental Resource Center (CSERC)

    worked together to submit extensive evidence of environmentally prob-ematic routes that should not be designated for public motorized use.But, in the end, the Stanislaus opened 136 miles of unauthorized off-road

    trails and 67 miles of roads that were previously closthe public and, in so doing, approved a massive net

    of roads and trails for ORV use. Even with a $96 mbacklog in road maintenance, the Stanislaus increthe mileage of open system routes by an additional miles, bringing the total to 2,437 miles. Of particularcern is the fact that the travel management plan addnificant mileage of user-created ORV routes into inappriate places like pristine roadless areas, wild and scriver corridors, and rare and sensitive species hasuch as for the California spotted owl, northern goshPacific fisher and western pond turtle. CSERC and have filed a lawsuit and we are currently awaiting focourt to issue its decision.

    While this isnt an isolated example, it also isnt the nTravel planning in most other regions falls somewhertween the Southwest and California examples witresult largely focused on maintaining the massive mized system footprint without making substantive chato either add or reduce miles.

    The Forest Service still has plenty of work to do toidentify roads that are ripe for reclamation.Wildlands CPR photo.

    Setting aside dedicated off-road use areas can help to avoid user conflicts anddamage to sensitive areas. Photo by Sarah Peters.

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    TRAVEL PLANNING, contd

    continued on next page

    Where do we go from here?Most of the remaining travel planning processes will finish by the end of 2012; however, our workwont be done even after all of the formal requirements of the Rule have been met and all units havepublished their Motor Vehicle Use Maps (MVUMs). There are still numerous avenues through whichactivist engagement will be important.

    First, travel planning will always be happening somewhere. A handful of slow moving units, like theMalheur NF in Oregon, will likely still be trying to comply with the Rule into 2013. In addition, theagency will be conducting some new analyses when Forest Service decisions are successfully ap-pealed (like the San Juan NFs Rico-West Dolores travel plan in Colorado) or overturned in court (likethe Sawtooth National Forests in Idaho) based on challenges from either side. Finally, ORV clubs willcontinue to press the agency to provide more riding opportunities or to seek access to routes that werenot designated in the first round of travel planning. Conservation Northwest, for example, recently wonprotections for the Colville NF in Washington by deflecting a proposal by the Forest Service to adduser-created routes to the system as well as open roads to ORVs that were previously closed.

    Another important opportunity for activist engagement involves the annual publication of the MVUMs.

    Each year, each forest is supposed to publish a new MVUM that reflects any changes to the systemthat occurred since the map was last published. It will be important for activists to watchdog annualMVUM revisions to ensure that routes are not added to the system without first undergoing analysis inaccordance with the National Environmental Policy Act. Conservationists are litigating this very issueon the Pike-San Isabel NF in Colorado.

    A third opportunity for engagement is assisting the Forest Service with implementing the route andarea decisions made during travel planning. Implementation activities include trailhead maintenance,installing signs and gates, reclaiming routes not designated for public motorized use, and constructingmotorized trails. There is more work to do than the Forest Service has funding to accomplish. It will beimportant to engage with the Forest Service both to help prioritize work that is most important to yourorganization and, where possible, to partner with the agency to get the work done.

    Go through the gate and around the corner to a more sustainable transportation system.Wildlands CPR photo.

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    TRAVEL PLANNING, contd

    he Forest Service does not have the resources to manage,r even adequately monitor, the massive motorized systemsdesignated through travel planning. Citizen monitoring

    hat identifies where problems are occurring (e.g., erosion,ewly blazed user-created routes, user-conflicts) and how

    he problems are evolving over time will be important. Thisata can be used to convince the agency to revisit designa-ons made during travel planning. If the agency ignoresou, it may be possible to use the data youve collected tole a petition for emergency closure.

    orests across the country will soon embark on a newype of transportation system analysis (unless your forest isne of the few exceptions where travel analysis is mostlyomplete) to assess their entire road system, whereas therocess that is just now concluding focused on motorizedecreation designations (for more details about the interre-ationship of this process, see The ABCs of Travel Planning;IPorter 12.4). The new process entails an inter-disciplinarynalysis wherein forests evaluate the environmental risknd social value of each road in the system. Based on thisnalysis, forests will make recommendations about whichoads to keep and which to reclaim or store for future use.he process is supposed to conclude by September 30,015. One important way for activists to engage in thisoad assessment is to offer site-specific information to thegency that demonstrates a routes high environmentalsks and/or low social value. This information could result

    n the agency recommending the route be reclaimed.

    n most cases, forests did not address winter use as a partf travel planning. When the Forest Service does take onwinter planning, it will offer an opportunity to protect theatural quiet from snowmobiles.

    ince the Rule was published, the conservation, recreationnd even hunting/angling communities have collectivelyngaged in a tremendous number of travel planning pro-esses across the country. Weve had both successes andetbacks throughout, and weve been fairly effective argu-ng against the addition of a high number of user-createdoutes to the formal system. Some forests have also reducedhe total number of system roads open to motorized use.

    Activists will continue to have opportunities both to improveuiet recreation by advocating for better management of

    ORVs, and to right-size the road system to improve wateruality and reconnect habitat well into the future. It will berucial for the conservation community to be present andngaged in these efforts.

    Josh Hicks is a Planning Specialist for The WildernessSocietys National Forest Action Center in Denver, Colo-ado.

    Once reclaimed, forest roads can provide secure habitat for wildlife. A remotmotion-activated camera caught these elk using a reclaimed road on theClearwater National Forest, ID. Wildlands CPR photo.

    See the case study of Mt Hoods travel planon the following page

    Activists will need to stay engaged to ensure positive travelplanning outcomes. Photo by Dan Funsch.

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    Lessons from Mt

    Hoods Plan

    Located twenty miles east of the city of Portland, Oregon,

    the Mt. Hood National Forest is bounded on the north

    by the Columbia River Gorge and on the south by the

    Olallie Scenic Area, a high basin in the shadow of Mt.

    Jefferson. In between lies more than sixty miles of forested

    mountains, lakes and streams. The forest is habitat for

    several threatened or endangered fish species: Bull Trout,

    Middle Columbia River Steelhead Trout, Lower Columbia

    River Steelhead Trout, Chinook Salmon, Chum Salmon,

    and Coho Salmon, and serves as Portlands drinking water source.

    In 2007, when the Forest Service initiated travel planning, 38% of the acres and 100% of the

    roads in Mt. Hood National Forest were open to ORVs despite the fact that less than 1% of forest

    visitors came to ride ORVs. The Forest Service proposed to create up to nine ORV intensity zones

    in addition to ORV access to all forest roads. Citizens, led by the local conservation group called

    Bark, organized opposition. They conducted fieldwork, generated letters to the editor, guestcolumns and news articles, and hosted town meetings. The TWS National Forest Action Center

    and Wildlands CPR provided campaign, policy, GIS, financial, and legal support.

    As a result, the Forest Service shifted course and signed a decision

    that created four ORV intensity areas and disallowed ORVs on

    forest roads. In a subsequent appeal resolution with Bark, the

    Forest Service removed one of the four ORV areas. The three

    remaining ORV zones are located near the periphery of the forest

    and are not negatively impacting wilderness or important habitat

    areas. This decision is a model that other activists and forests

    should consider. Rather than designating ORV routes throughout

    the entire forest, the Forest Service limited ORV route designations

    to defined zones. The result: cleaner water and healthier habitat,

    and a better balance between motorized and non-motorized

    recreation.

    TRAVEL PLANNING, contd

    Photo courtesy of Bark.

    Photo courtesy of Bark.

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    WILL RESTORATION FUNDING STAND OUT IN A

    CROWD, OR BE LOST IN THE SAUCE?By Bethanie Walder

    continued on next page

    DEPAVINGTHE WAY

    Since 2007, Wildlands CPR has been advocating for increased funding forwatershed restoration on Forest Service lands through the Legacy Roadsand Trails Remediation Program and associated efforts. Now a new funding

    pproach offers a potential opportunity to increase funding for this work, but its not without its risks. Over the past few years, the Forest Service has been flirt-ng with a new Integrated Resource Restoration (IRR) idea: instead of fundingndividual line items, the Forest Service will merge several different funds into one

    arge restoration funding bucket. IRR was first proposed in the Presidents budget few years ago, but Congress wasnt so keen on it and so it wasnt adopted.ast year the Administration made some changes and proposed it again, and

    Congress amended it further and adopted a three-region pilot to test IRR on theround.

    Now heres the risky part. Usually, when a pilot is tested, it is also evaluatedo understand what worked and what didnt, however, the February release ofhe Presidents budget for 2013 proposed skipping this evaluation and adopt-ng IRR wholesale across all Forest Service lands. This would mean no evalu-tion of the challenges and opportunities presented by implementing the pilot,nd no opportunity for adapting the proposal to address the lessons learned.

    While increasing Forest Service restoration funding is a goal we share with thegency, it has to be done right. What if IRR doesnt work? And whats the point of pilot if you dont take time to assess it before adopting it wholesale?

    he agency is promoting IRR because they think it will work better than the currentystem. The rationale: pooled funding will be more efficient and the agency canccomplish more with the same amount of money. We can support this in theory,ut we want to see if its true on the ground. Unfortunately, in the FY12 pilotegions, the agency isnt just trying to accomplish more with the same amount of

    money, theyre actually trying to accomplish more with less funding becauseheir overall funding went down. This makes the pilot a little challenging to test.

    erhaps most significantly to Wildlands CPR, we have serious concerns about thentersection of Legacy Roads and Trails funding and IRR. In the FY12 pilot regions,ll Legacy Roads and Trails money was pooled into the IRR, becoming part of

    hat big bucket of money along with fish and wildlife funds, vegetation and wa-ersheds funds, timber funds and fuels/fire hazard reduction funds. Our concerns that once an individual fund is pooled into the IRR, that individual fund ceaseso exist, and what used to be dedicated funding can be used for any activitywithin the IRR. The pooled Legacy Roads and Trails funds can be used for timber

    harvests, but so too can pooled timber funds be

    for road decommissioning. In the pilot regions, tfore, Legacy Roads and Trails money has effectdisappeared this year. But the road problems thato its creation have not.

    We are very concerned that under IRR, roads mfail to garner the attention they so desperately from within the agency, as staff work to achievemany competing mandates set out for them. Foample, Forest Service staff have regularly told usLegacy Roads and Trails funding works becausmoney is dedicated exclusively to fixing road plems problems that were often overlooked unt

    new program was created. Some staff are wothat roads might fall back to the bottom of thonce the funding is pooled.

    Wildlife use of reclaimed roads has been documented.Wildlands CPR photo.

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    DePaving the Way, contd

    he agency is trying to address this and other stake-older concerns by setting targets for accomplish-

    ments in the pilot regions. Theyve adopted five spe-ific performance measures related to the IRR pilot:

    Number of watersheds moved to an im-proved condition class

    Acres treated annually to sustain or restorewatershed function and resilience

    Volume of timber sold Miles of road decommissioned Miles of stream habitat restored or en-

    hanced

    We are generally positive about these performancemeasures. They illustrate that the Forest Service is start-ng to reframe the concept of restoration and that theyre looking at restoration from a broader perspec-ve than just silvicultural management. Were mostleased, of course, that road decommissioning is onef their performance measures, and like to think thatur persistent engagement is one of the reasons they

    ncluded this target. In addition, a significant portionf the stream habitat restored measure could comerom fixing culverts and restoring aquatic passage nother significant road issue. As a matter of fact,

    he performance measures could actually be an im-rovement over the independent Legacy Roads andrails line item, because that line item never includedpecific targets for road decommissioning (though for

    he years we have assessed, it seems that about ahird of the funds were used for decommissioning).

    ut shortcomings remain. Most problematic: timberolume sold is one of the target performance mea-ures. Though we recognize a legitimate need to ad-ress fire/fuels and unnaturally dense forests in somelaces through ecologically sensitive logging, we doot think that timber volume sold is an appropriateerformance measure for a restoration initiative. Thember targets could create a perverse incentive toromote timber sales that are not restorative. Were also concerned that acres treated for watershed

    unction could become a euphemism for additionalmber harvest that may not be ecologically justifiablerom a restoration perspective. The acres treatedmeasure needs to be refined and improved to ad-ress a broad range of restoration needs and con-erns.

    This brings us back to the concept of evaluation the Forest Service needassess the pilot ideally for a full three years. This can help us understand concerned we should be about our favorite program, Legacy Roads and Twhich would be swallowed up if the IRR is adopted across the board. Thishelp other stakeholders understand if their concerns are being met, and iprovide the agency an opportunity to improve the pilot based on the resuthe assessments.

    Our goal is not just to sustain Legacy Roads and Trails, but to ensure that the wfor which it was created is prioritized and accomplished. The Forest Servicemates a multi-billion dollar road maintenance problem that is damaging fishhabitat and municipal drinking supplies. In the state of Washington, for examit will cost a minimum of $300 million to bring Forest Service roads up to mum Clean Water Act standards. While road work makes sense as a part ointegrated restoration approach, the problem is so enormous that it has justifireceived its own dedicated funding for the past five years, and that fundingonly been a drop in the bucket. The Legacy Roads and Trails program goals not yet been met, and its unclear whether or not IRR will be the right mechafor meeting these goals over the long-term.

    We appreciate this attempt to improve restoration outcomes and to create onizational efficiencies by creating a pooled fund, and were looking forwaworking with the pilot regions to identify additional performance measuresto fully evaluate the effectiveness of the program. However, in the meantimehope the Forest Service takes a step back, consistent with this pilot approto ensure that IRR is well-vetted and amended as needed as a result of leslearned. Well be very curious to learn whether IRR increases, or decreasesagencys capacity to address road issues, and well press to ensure this infotion, specifically tied to Legacy Roads and Trails performance, is included ipublic and private reports developed on IRR.

    Reseeding with native vegetation on a Colorado road restorationproject. Photo by Vicky Burton, US Forest Service.

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    Bibliography Notes summarizes and highlights some of the scientific lin our 20,000 citation bibliography on the physical and ecological effroads and off-road vehicles. We offer bibliographic searches to help a

    access important biological research relevant to roads.THE VALUE OF WILDLIFECROSSING STRUCTURESBy Liz Fairbank

    continued on next page

    BIBLIOGRAPHYNOTES

    Asthe number of roads and their traffic volumes continue to increase, mitiga-tion measures are becoming increasingly important to minimize the risksto both humans and wildlife populations. One type of mitigation measure

    s the use of wildlife crossing structures that allow wildlife to cross either over ornder roadways without coming into contact with traffic. The goals of buildinghese crossing structures are to reduce the risks associated with wildlife-vehiclenteractions, and to provide connectivity between habitat patches (Cramer andissonette 2005; Bond et al. 2008). There are many factors that influence the ef-ectiveness of crossing structures, including their placement, frequency, and struc-ural attributes. In this article, I review the current state of scientific knowledge onhe effectiveness of crossing structures.

    Types of Structureshere are several types of crossing structures that are used in highway mitigation,ach with different levels of effectiveness and cost. Most fundamentally, thesetructures are either designed to allow animals to travel below the highway (un-erpasses) or over the highway (overpasses). The use of fencing in combination

    with crossing structures can help to guide and funnel wildlife towards crossingtructures, increasing their use and keeping animals out of the roadway (Gagnont al. 2005; Glista et al. 2009). Several studies have reported that crossing struc-ures and fencing/barrier walls together have reduced road mortality by >80%Dodd et al. 2004; Dodd et al. 2007; Huijser et al. 2011).

    UnderpassesWildlife underpasses are the most common and least costly mitigation option.hey are typically not fauna-specific structures, and have the potential to be usedy a wide variety of species (Mata et al. 2008). These structures can rangereatly in size, anywhere from small pipe culverts (0.3-2m in diameter), to large

    nderpasses crossing under road bridges (Glista et al. 2009). They are typi-ally constructed of concrete, smooth steel, or corrugated metal (Glista et al.009). Large underpasses provide crossing opportunities for the greatest numberf species, although small animals often show preference for small underpasses,resumably for security from predation (McDonald and St. Clair 2004; Glista etl. 2009).

    The dimensions of an underpass or culvert plaintegral role in their use by certain species. Upasses with high relative openness (short letall, and wide) are preferred by ungulates, as

    as large carnivores, particularly grizzly bears wolves (Clevenger and Waltho 2000 and 2005et al., 2004; Grilo et al. 2008; Glista et al. 20Other carnivores, such as black bears, coyotes, cats, and cougars have been found to also use,possibly prefer, smaller and more constricted upasses and culverts (Ng et al. 2004; ClevengerWaltho 2005).

    Crossing structures can be sized to accommo-date many different species groups, includingamphibians. Photo Marcel Huijser.

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    he vegetation approaching and around underpassntryway can affect crossing structure attractivenessnd usage differentially by species type. For exam-

    le, natural vegetation at underpass openings is ben-ficial for use by small to mid-sized mammals, butan deter ungulates if it restricts their vision (Glista etl. 2009). Visibility to the opening at the other sidef the underpass is an important factor in underpassse, particularly by ungulates (Cramer and Bissonette005; Rosell et al. 1997 [as cited in Glista et al.009]).

    As existing culverts and underpasses were oftenriginally constructed for drainage purposes and

    may sometimes have standing water in them, modify-ng them with shelves or raised walkways has been

    ound to be an effective way to ensure their use evenwhen inundated with water (Foresman 2003; Bru-in III 2003; Cramer et al. 2005; Bond and Jones008).

    OverpassesOverpasses provide wildlife with a wide bridge-liketructure, connecting habitat on either side of a trans-ortation corridor. Overpasses can range greatly in

    width from only a few meters to over 200m on eachnd (they are sometimes hourglass shaped), and areypically planted with natural vegetation including

    rass, shrubs, and trees to appear as a continuationf surrounding habitat (Glista et al. 2009, Corlatti etl. 2009). Wider overpasses are more effective thanarrower structures, particularly for large mammals,nd some studies suggest that structures should be

    >60m in width (Evink 2002 [as cited in Corlatti etl. 2009]).

    Wildlife overpasses can accommodate a wider va-ety of species than underpasses and are generally

    he preferred crossing structure of deer, elk, and oth-r ungulates (Glista et al. 2009). Other advantagesf overpasses are that they are less confined, quieter,

    nd maintain ambient environmental conditions suchs moisture, temperature, and light (Jackson andGriffin 2000 [as quoted in Glista et al. 2009]). Therawback of overpasses is that they are typically the

    most expensive mitigation option because of theirarge size and high construction costs (Glista et al.009).

    Biblio Notes, contd

    Wildlife overpasses can accommodate a wider variety of species than under-passes and are generally the preferred crossing structure of deer, elk, and otherungulates. A wildlife/nonmotorized transportation dual-use overpass. Photo Marcel Huijser.

    Without crossing structures in place, wildlife face direct mortality risks on adaily basis. Photo Marcel Huijser.

    continued on next page

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    Biblio Notes, contd

    Factors That Influence Crossing Structure Effectiveness

    Placementuitable habitat on both sides of the road is a necessary condition

    or all wildlife to cross, and areas with the highest quality habitatwill often have the highest rates of crossing (Barnum 2003). Ngt al. (2004:504) agree, stating that regardless of other factors crossing structure will be of little value as a wildlife corridor ifdoes not connect suitable habitat. This may be the most impor-

    ant factor for species with narrow habitat preferences, whereaspecies with broad habitat preferences (such as deer, elk andoyotes) may be more affected by other factors (Barnum 2003).

    Distance to cover is another feature that will differentially affectrossing structure use by various species based on their habitatreferences. Deer and elk tend to prefer crossings in open areasway from forest cover, especially during the winter (Clevenger

    nd Waltho 2005; Barnum et al. 2007). Moose have been foundo prefer crossing in mixed cover types, where there is both for-ge and moderate cover (Barnum et al. 2007). Several studies

    ound that, with the exclusion of red fox, the carnivores studiedncluding cougars, grizzly bears, black bears, coyotes, bobcats,ray fox, badger, genet, fisher, short and long tailed weasels, mongoose, stone

    marten and American marten) crossed most often in areas within or near moreense forest cover (Clevenger and Waltho 2005; Barnum et al. 2007; Grilo etl. 2008).

    Drainage systems are known to be used as travel routes for wildlife and oftenontain a higher diversity of species, as they are also home to riparian speciesot present in surrounding upland areas (Clevenger and Waltho 2000; Puky etl. 2007). Carnivores in particular have a higher tendency to use crossing struc-

    ures near drainage systems (although distance to forest cover remains a moreignificant factor) (Clevenger and Waltho 2000; Clevenger and Waltho 2005;

    Grilo et al. 2008). Conversely, in narrow valleys, ungulates were found to avoidnderpasses near drainages, probably due to an increase in perceived predationsk rather than landscape attributes (Clevenger and Waltho 2000).

    he proximity of crossing structures to human population centers and human ac-vities/use is shown to negatively affect their use by most wildlife, particularlyarge carnivores and other large mammals (Clevenger and Waltho 2000; Ng etl. 2004; Grilo et al. 2008). Thus restricting human use of crossing structures,specially at night, is essential in ensuring effective use by wildlife (Clevenger and

    Waltho 2000; Cramer and Bissonette 2005; Grilo et al. 2008).

    requencyAnother important factor to take into consideration in the placement of crossingtructures is the spatial and home range dynamics of the target species. This isspecially essential for small mammals and less mobile species including reptilesnd amphibians (McDonald and St. Clair 2004; Bissonette and Adair 2008;

    Glista et al. 2009). This means not only placing structures within appropriate

    proximity to the home range, but also with a freqcy that is appropriate for the distance that spegenerally travel. As it may be financially imposto place structures with the frequency needed tovide full habitat permeability, and because wilvehicle collisions tend to be clustered or restrictecrossing hotspots, appropriately spaced mitigmeasures should be prioritized within these ato yield the greatest increase in connectivity andcrease in wildlife-vehicle interactions (BissonetteAdair 2008).

    ConclusionWith an increasing understanding of the importof restoring wildlife connectivity, mitigating highfragmentation has come to the forefront of road ogy. Wildlife crossing structures have been shto be effective at increasing permeability and reing wildlife-vehicle collisions, but a number of facan influence their success. By ensuring that high

    planners choose the right type of structure and pthem in the most appropriate places, we can busustainable highway system where both wildlifehumans can thrive.

    Liz Fairbank is a University of Montana Envmental Studies graduate student.

    Fences or other structures used to funnel wildlife towards crossings can incthe effectiveness of crossing structures. Photo Marcel Huijser.

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    Biblio Notes, contd

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    REFERENCES

    arnum, S.A. 2003. Identifying the best locations to provide safehighway crossing opportunities for wildlife. In 2003 Proceed-ings of the International Conference on Ecology and Trans-portation, edited by C. Leroy Irwin, Paul Garrett, and K.P.

    McDermott. Raleigh, NC: Center for Transportation and theEnvironment, North Carolina State University, 2003. 246-252.

    arnum, S., K. Rinehart, and M. Elbroch. 2007. Habitat, highwayfeatures, and animal-vehicle collision locations as indicatorsof wildlife crossing. In Proceedings of the 2007 InternationalConference on Ecology and Transportation, edited by C.Leroy Irwin, Debra Nelson, and K.P. McDermott. Raleigh, NC:Center for Transportation and the Environment, North CarolinaState University, 2007. 511-518.

    issonette, J.A., and W. Adair. 2008. Restoring habitat perme-ability to roaded landscapes with isometrically-scaled wildlifecrossings. Biological Conservation 141:482-488.

    ond, A.R., and D.N. Jones. 2008. Temporal trends in use offauna-friendly underpasses and overpasses. Wildlife Research35:103-112.

    rudin III, C.O. 2003. Wildlife use of existing culverts and bridgesin north central Pennsylvania. In 2003 Proceedings of the In-ternational Conference on Ecology and Transportation, editedby C. Leroy Irwin, Paul Garrett, and K.P. McDermott. Raleigh,NC: Center for Transportation and the Environment, NorthCarolina State University, 2003. 344-352.

    Clevenger, A.P. and N. Waltho. 2000. Factors influencing theeffectiveness of wildlife underpasses in Banff National Park,Alberta, Canada. Conservation Biology, 14(1), 47-56.

    Clevenger, A.P. and N. Waltho. 2005. Performance indicesto identify attributes of highway crossing structures facilitat-ing movement of large mammals. Biological Conservation121:453-464.

    Corlatti, L., K. Hacklander, and F. Frey-Roos. 2009. Ability ofwildlife overpasses to provide connectivity and prevent geisolation. Conservation Biology23:548-556.

    Cramer, P.C. and J.A. Bissonette. 2005. Wildlife crossings in N

    America: The state of the science and practice. In Proceedings of the 2005 International Conference on Ecology andTransportation, edited by C. Leroy Irwin, Paul Garrett, andMcDermott. Raleigh, NC: Center for Transportation and thEnvironment, North Carolina State University, 2006. 442447.

    Dodd, C.K., W.J. Barichivich, and L.L. Smith. 2004. Effectivenof a barrier wall and culverts in reducing wildlife mortality a heavily traveled highway in Florida. Biological Conserv118:619-631.

    Dodd, N.L., J.W. Gagnon, S. Boe, and R.E. Schweinsburg. 20Role of fencing in promoting underpass use and highwaypermeability. In Proceedings of the 2007 International Coence on Ecology and Transportation, edited by C. Leroy IrDebra Nelson, and K.P. McDermott. Raleigh, NC: Centerfor Transportation and the Environment, North Carolina StaUniversity, 2007.

    Foresman, K. R., 2003. Small mammal use of modified culvertson the Lolo south project of western Montana an update2003 Proceedings of the International Conference on Ecoand Transportation, edited by C. Leroy Irwin, Paul Garrett,and K.P. McDermott. Raleigh, NC: Center for Transportatiand the Environment, North Carolina State University, 200342343.

    Gagnon, J. 2005. Use of video surveillance to assess wildlife

    behavior and use of wildlife underpasses in Arizona. InProceedings of the 2005 International Conference on Ecoand Transportation, edited by C. Leroy Irwin, Paul Garrett,and K.P. McDermott. Raleigh, NC: Center for Transportatiand the Environment, North Carolina State University, 200534-544.

    Glista, D.J., T.L. DeVault, and J.A. DeWoody. 2009. A review mitigation measures for reducing wildlife mortality on roadways. Landscape and Urban Planning 91:1-7.

    Grilo, C., J.A. Bissonette, and M. Santos-Reis. 2008. Responseof carnivores to existing highway culverts and underpassesImplications for road planning and mitigation. BiodiversityConservation 17:16851699.

    Huijser, M. P., P. McGowen, J. Fuller, A. Hardy, A. Kociolek, A.Clevenger, D. Smith, and R. Ament. 2008. Wildlife-vehicCollision Reduction Study. Report to Congress. U.S. Depament of Transportation, Federal Highway Administration,Washington D.C., USA. 232 pp. http://www.tfhrc.gov/safety/pubs/08034/index.htm

    roperly designed crossing structures make travel safe for wildlife and humanslike. Photo Marcel Huijser.

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    References, contd

    Huijser, M. P., T.D.H. Allen, and W. Camel. 2010. US 93 Post-Construction Wildlife-Vehicle Collision And Wildlife CrossingMonitoring and Research on the Flathead Indian Reserva-tion between Evaro and Polson, Montana: Annual Report2010. Western Transportation Institute College of Engineering

    Montana State University, Bozeman, Montana, USA. 33pp.http://www.mdt.mt.gov/research/projects/env/wildlife_crossing.shtml

    Kaye, D. R. J., K.M. Walsh, and C. C. Ross. 2005. Spotted turtleuse of a culvert under relocated Route 44 in Carver, Massa-chusetts. In Proceedings of the 2005 International Conferenceon Ecology and Transportation, edited by C. Leroy Irwin, PaulGarrett, and K.P. McDermott. Raleigh, NC: Center for Trans-portation and the Environment, North Carolina State Univer-sity, 2006. 426-432.

    Mata, C., I. Hervas, J. Herranz, F. Suarez, and J.E. Malo. 2008.Are motorway wildlife passages worth building? Vertebrateuse of road-crossing structures on a Spanish motorway.Journalof Environmental Management88:407-415.

    McDonald, W. and C. St. Clair. 2004. Elements that promotehighway crossing structure use by small mammals in BanffNational Park.Journal of Applied Ecology41:82-93.

    National Cooperative Highway Research Program: Bissonette, J.A.,and P.C. Cramer. 2008. Wildlife and Roads: A Resourcefor Mitigating the Effects of Roads on Wildlife Using WildlifeCrossings such as Overpasses, Underpasses, and Cross-walks. http://www.wildlifeandroads.org/decision-guide/2_1_6.cfm

    Ng, S.J., J.W. Dole, R.M. Sauvajot, S.P.D. Riley, and T.J. Valon2004. Use of highway undercrossings by wildlife in southCalifornia. Biological Conservation 115:499-507.

    Puky, M., J. Farkas, and M.T. Ronkay. 2007. Use of existing mtion measures by amphibians, reptiles, and small to mediu

    size mammals in Hungary: crossing structures can functionas multiple species-oriented measures. In Proceedings of th2007 International Conference on Ecology and Transportation, edited by C. Leroy Irwin, Debra Nelson, and K.P. Mmott. Raleigh, NC: Center for Transportation and the Envirment, North Carolina State University, 2007. 521-530.

    Sawaya, M.A. and A.P. Clevenger. 2009. Using non-invasive netic sampling methods to assess the value of wildlife crosfor black and grizzly bear populations in Banff National PAlberta, Canada. In Proceedings of the 2009 InternationaConference on Ecology and Transportation, edited by PauWagner, Debra Nelson, and Eugene Murray. Raleigh, NCCenter for Transportation and the Environment, North CaroState University, 2010. 702-715.

    USDOT: Federal Highway Administration, Office of Highway PInformation. 2011. Our Nations Highways: 2011. http:/www.fhwa.dot.gov/policyinformation/pubs/hf/pl11028chapter1.cfm#fig14

    The threat posed by vehicle-wildlife interactions, and the consequences failing to address it. Photos Marcel Huijser.

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    WILDLANDS CPR 2011 ANNUAL REPORT

    continued on next page

    Though it wasnt an official leap year, 2011 certainly leapt by at Wild-lands CPR. Were pleased to present this report outlining our organi-zational health, successes and challenges throughout the year.

    Restoration ProgramAs noted in our annual report last year, the FService adopted a plan in November 2010 to tify an ecologically and fiscally sustainable system by September 30, 2015. This rightsizinitiative was an extraordinary policy victory foin 2010, and it along with a related processagencys Watershed Condition Framework), anLegacy Roads and Trails Remediation Initiativbecame the basis of our 2011 policy agenda.

    partnered with The Wilderness Society to devtools for activists to engage with the Forest Servicrightsizing, and we worked with grassroots grthroughout the country to coordinate meetings regional offices and individual forests regarding rightsizing plans.

    A restored Doe Creek, Clearwater NationalForest. Photo by Katherine Court.

    Organizational development and staffingWe got image conscious in 2011, working with a fantastic local graph-ic designer to update our logo and website, and incorporating the newgraphic themes into all of our written and electronic communications. Wealso up-scaled our office, moving to a much more user-friendly and well-litspace, just one block from our former digs.

    From a financial perspective, we further diversified our fundraising to re-duce the proportion of our funding derived from foundations. For exam-ple, our online giving improved notably in 2011, becoming a much moreimportant element of our annual fundraising. In addition, we completelyrevamped our annual gifts campaign, resulting in significantly more unre-stricted income. It couldnt have gone better we surpassed our $40,000campaign goal and we had 40% more individual donors participate! Our2012 fundraising efforts will build upon these successes.

    Our staff changed a bit in 2011, with our Restoration Campaign Director,Sue Gunn, retiring in June. Sue was the driving force behind our LegacyRoads and Trails Campaign. Through her work with Wildlands CPR shealso led the Washington Watershed Restoration Initiative (WWRI) a co-alition of conservation organizations, state agencies and tribes working toadvance Legacy Roads and Trails and other rightsizing objectives in thestate. Sue brought inspiring ideas to Wildlands CPR, helping us achieveextraordinary things. Upon her departure, we reconfigured her positionto focus more on the on-the-ground implementation of the Forest Serviceinitiative to identify an optimum road system that is both ecologically andfiscally sustainable. In October, we hired Marlies Wierenga as our WA/OR Field Coordinator to oversee this and to run the WWRI. Since Marliesis based in Portland, OR, we now have two satellite offices in OR (Sarah

    Peters, our Legal Liaison/Staff Attorney, is in Eugene) and we no longerhave an office in WA, though Marlies will be working closely with ourWA partners.

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    ANNUAL REPORT, contd

    erhaps our biggest victory of the year was protect-ng the Legacy Roads and Trails Remediation Pro-ram from the Congressional budget cutting frenzy

    n early 2011. In the end, Congress spared the pro-ram, but they did cut funding in half, from $90 mil-

    on to $45 million. They proposed further cuts forY12, but fortunately it remained stable at $45 mil-on. Our work to educate decision-makers and buildupport for Legacy Roads and Trails ranged from co-rdinating support letters from diverse stakeholders

    n western states, to holding an excellent media fieldour in MT, to developing a host of investigative andighly-informative fact sheets and reports about theuccesses of the Legacy Roads and Trails program atmproving water quality and providing green jobs.

    As part of the FY12 federal budget, a new policyhreat and/or opportunity emerged, as Congress

    greed to let the Forest Service pilot a new Inte-rated Resource Restoration (IRR) budgetary ap-roach in three FS regions. We worked on this is-ue throughout the year and it will be a significantriority for 2012. We also regularly met with Forestervice leadership in Washington DC to understandnd help promote their new Watershed Conditionramework (WCF), culminating in a request to thegency to host a webinar for grassroots activists to

    earn more about the WCF. More than 50 partici-ants attended the webinar.

    We also became integrally involved in a time-sen-itive campaign to ensure that logging roads willontinue to be regulated under the Clean Water Act.

    Wildlands CPR staff worked closely with the leadlaintiffs and attorneys in the NEDC v. Brown case,s well as numerous other Pacific Northwest and na-

    tional conservation organizations, after the timber industry pushed to overturdecision by amending the Clean Water Act. When the federal budget passDecember, the effort to amend the CWA was put on hold for one year, so weengage on this as needed in 2012.

    We also entered into our second year of monitoring to assess the effectiveneLegacy Roads and Trails projects in MT and northern ID. We partnered with grassroots groups on five different national forests to assess wildlife and veg

    tive response to road reclamation treatments. The highlight of the summer: caing our first images of a grizzly bear using a reclaimed road. And this wasnany griz, but a sow with cubs on the Gallatin National Forest in MT.

    But the science/monitoring highlight of the year, however, was publication onew road reclamation studies in peer-reviewed journals. Our Science ProgDirector Adam Switalski works with former board member and University of Mtana Assistant Professor Cara Nelson and several others on a variety of reclamation-based research. U of MT graduate student Ashley Grant waprimary author on the first paper, which included Adam, Cara and Forest Seresearcher S. Rinehart as coauthors: Restoration of native plant communitiesroad decommissioning: effect of seed mix composition and density on vegetestablishment. Restoration Ecology19:160-169. The second paper is base

    five years of road reclamation monitoring on the Clearwater National ForeIdaho: Efficacy of road removal for restoring wildlife habitat: Black bear iNorthern Rocky Mountains, USA. Biological Conservation 144 (2011): 22673. This research provided the methodology for our current Legacy RoadsTrails monitoring program in MT.

    continued on next page

    Wildlands CPRs restoration field trips brought together scientists, landmanagers, and members of the media to experience first-hand thebenefits of road reclamation. Wildlands CPR photo.

    Removed road bed in OBrien Creek, Lolo NF, Montana.Photo by Adam Switalski.

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    ANNUAL REPORT, contd

    Transportation Programwas incredibly satisfying to see one of our long-term goals finally become re-lity in 2011. Working in close partnership with The Wilderness Society andrassroots organizations throughout the west, our tenacious focus on Forest Ser-ice off-road vehicle travel planning paid off. With more and more district andational forest travel planning decisions issued it became clear that unrestrictedross-country travel on national forest lands will become a thing of the past in allut a small number of dedicated play areas. Instead, off-road vehicles will bellowed only on designated roads and motorized routes. This is a major change

    rom five years ago, when the Forest Service really got started with this planningrocess, and it shows how important it is to engage with the agency over the

    ong-term. The overall results of travel planning have been mixed, however, andome national forests have taken a balanced approach by adding some user-reated unauthorized routes while specifically closing others. We expect the For-st Service to finalize nearly all decisions by the end of 2012, though a handfulf outliers will likely remain.

    We know from experience that administrative sions must be followed up with legal oversight,our Legal Liaison Sarah Peters stayed very helping grassroots activists develop appeals of plematic travel plans. She also provided technicasistance to several organizations litigating agothers, including The Wilderness Society and IdConservation Leagues successful challenge oSalmon-Challis National Forest (ID) Travel Plancourt overturned that plan in an important decthat, among other things, upheld the off-road veExecutive Orders (issued by Presidents Nixon Carter). Unfortunately, we also lost an off-road cle management case on the Custer National F(MT) where we partnered with the Pryors CoalSarah worked with our lawyers at the Western

    ronmental Law Center, and we have now appethat decision to the Ninth Circuit Court of Appea

    In addition to working with lawyers and actacross the nation, Sarahs been engaging inhome state of Oregon, becoming more active inel planning and related processes on the UmpFremont-Winema, Siuslaw and Rogue-River SiskNational Forests. Shes been playing a key roproject level work on the Fremont-Winema, foample, including working with the Forest Servibegin Phase II of travel planning, which will designate different routes for motorized use and

    commission those no longer needed.

    Back here in the northern Rockies, Adam Riscontinued to watchdog travel planning on the verhead-Deerlodge and Bitterroot National Foin MT. While the Beaverhead-Deerlodge is earthe process, the Bitterroot is nearly finished. postponed their final decision several times, thowe expect their process to be completed in 20Adam and Sarah also partnered to develop a gfor grassroots activists to engage with the Foresvice as they update their travel planning maps. TMotor Vehicle Use Maps, or MVUMs, are on

    the most important products stemming from tplanning. Sarah and Adam distributed their gto several hundred grassroots groups throughoucountry.

    continued on next page

    At left, trail ruts caused by off-road ve-hicle use. Through the travel planningprocess, off-road impacts are beingcontained and mitigated. Photo byErin Switalski.

    Below, an off-roader rides in a desig-

    nated off-road play area.Photo courtesy of Bureau of LandManagement.

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    POLICYPRIMER

    FOREST SERVICE ISSUES FINAL PLANNING

    REGULATIONS...LET THE PLAN REVISIONS BEGINBy Adam Rissien and Sarah Peters

    continued on next page

    Backgroundhe Forest Service manages 155 national forests and 20 national grass-ands covering 193 million acres across the country. Each one adheres to specific Land Management Resource Plan, otherwise known as a forestlan. These forest plans direct a wide variety of activities such as timberroduction, livestock grazing, and recreational uses, all while ensuringlean drinking water, sustainable fisheries and viable wildlife populations.

    A large percentage of these forest plans are also drastically overdue forevision.

    he National Forest Management Act of 1976 (NFMA) requires the For-st Service to issue specific regulations directing what forest plans shouldontain. On February 14th, 2011 the Forest Service issued new draftlanning regulations citing the need for rules that reflect current sciencend are more responsive to issues such as the challenges of climatehange; the need for forest restoration and conservation, watershed pro-ection, and wildlife conservation; and the sustainable use of public landso support vibrant communities. The new rules also seek to streamlinehe 1982 regulations and allow more latitude for local interpretation. Onanuary 26, 2012, the Forest Service released the final regulations, which

    ould go into effect at anytime. The 1982 NFMA regulations, under whichurrent forest plans were developed, contain specific requirements to en-ure the laws mandates are met, but they have long been under attackue, in part, to the success of organizations that use them to hold thegency accountable with regards to its management actions. Unlike ob-

    ectives and guidelines, Forest Plan standards are not discretionary andourts have repeatedly ruled against the agency for failure to adequatelyollow them.

    Unfortunately, the new regulations continue the trend away from requiringtrong standards to maintain viable wildlife populations, protect riparianreas or provide clear road management direction.

    till, the 2012 regulations are an improvement from past attempts to revisehe planning regulations, and include direction that all new and revisedlans must be supported by an environmental impact statement, as wells a requirement for broad-scale monitoring that looks beyond the forest

    evel. The final rule also directs agency officials to use the best availablecience, which is a major improvement over the initial draft rule. The newule also includes recognition that ecosystem services are part of the agen-

    National Forest System Land Management Planning Draft Programmatic Envi-ronmental Impact Statement Ch. 1, p. 7.

    Wildlands CPR file photo.

    cys multiple use mandate, which is a significant addthat the 1982 rules did not include. However, eventhese and other improvements the final regulations ccertainly have been stronger, and will likely face litigathreats from all sides of the management debate.

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    Policy Primer, contd

    continued on next page

    Summary of Key ProblemsOne concern we have with these new regulations is the amount of discretion provided tondividual forests with regards to restoring and protecting water quality, wildlife habitatnd diversity, and other forest resources. Whereas the 1982 regulations provided cleartandards, the new ones greatly increase the agencys discretion, through requiring either

    tandardsor

    guidelines, leaving more opportunity for lax environmental protections.he following is by no means a comprehensive listing of our issues with the regulations, buterves to highlight some of our top concerns:

    The new regulations call for the establishment and protection of riparian ar-eas but they do so by requiring standards or guidelines. Offering the optionbetween the two is problematic since guidelines are legally less enforceablethan standards, thereby potentially weakening any protections if they rely onguidelines alone.

    No requirements to protect watersheds and only an option to maintain orrestore them. 219.8(a)(1); the draft regulations included a protection provi-sion for ecosystem elements.

    Nebulous requirements for forest plan components (desired future conditions,objectives, standards, guidelines and suitability of lands). Weakens protections for soils and requirements for soil productivity when

    compared to the 1982 regulations. 219.8(a)(2)(v) No requirements for road removal or implementation of the minimum road

    system. Requires standards or guidelines for sustainable recreation, which directs a

    balance of ecological, economic and social factors, but lacks clear directionas to how this will be achieved. 219.10(b)(1)(i)

    Climate change is acknowledged in the regulation as a stressor to forest, wa-tershed and wildlife health, but the regulations do not include clear mandatesfor addressing the impacts of climate change.

    Weakens wildlife viability requirements.*

    Limits the public process and opportunities to challenge decisions.*

    * These issues are concerning but space constraints do not allowfor a full discussion in this article of these topics.

    Road restoration on the Arapaho-Roosevelt NF (CO). Photo by Kevin Bayer,US Forest Service.

    When things go wrong with roads....

    Above, a blocked culvert leads to a roadwashout on the Helena NF.

    Below, a fillslope failure on the Nez Perce

    Photos by Adam Switalski.

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    Policy Primer, contd

    continued on next page

    Final Planning Rule (as of January 25, 2012)

    Standards v. Guidelinesequired plan components include standards and guidelines. Standards are manda-

    ory components that must be specifically followed to help achieve or maintain theesired condition. Guidelines allow for variation from their specific language, so longs the intent of the guideline is met. ( 219.15(d)(3)). 219.15(d) addresses theteps a forest must take to determine consistency.

    ach approval document for a project or activity must describe how the project orctivity is consistent with applicable plan components. With regard to standards, theroject or activity must comply with applicable standards. 219.15(d)(2). For guide-nes, a project or activity approval document must show that it is designed to comply

    with applicable guidelines or is designed in a way that is as effective in carrying outhe intent of the applicable guidelines. 219.15(d)(3). It is difficult to conceive how theintent of the guideline would be met without the action being designed to comply

    with the guideline. This definition provides a large amount of discretion for forests and

    ould end up leading to a large amount of litigation.

    tandards are much more powerful than guidelines, and using the conjunctive orather than and means that most forest plans will lean more heavily towards includ-ng guidelines over standards, and thus potentially weaken the protections offeredn previous forest plans. The new rule directs that forest plans include standards oruidelines to maintain or restore air, soil and water, but does not require they berotected. Therefore forest plans may not contain specific standards to protect wateruality and could simply rely on guidelines to satisfy the regulations. Additionally it isnclear how or when the agency will maintain or restore ecosystem components. Weiscuss these flaws further as they apply to riparian areas, soils and watersheds under

    he sustainability section.

    Sustainability

    Riparian Areashe final rule requires plans to maintain or restore the ecologicalntegrity of riparian areas in the plan area, including plan compo-ents to maintain or restore structure, function, composition, and con-ectivity. This is actually weaker language than the draft rule, whichncluded direction to maintain, protector restore the ecologicalntegrity of riparian areas The omission of protect is concern-ng. Fortunately the new rule requires that Plan components mustnsure that no management practices causing detrimental changes

    n water temperature or chemical composition, blockages of waterourses, or deposits of sediment that seriously and adversely affectwater conditions or fish habitat shall be permitted within the riparianmanagement zones or the site-specific delineated riparian areas.19.8(a)(3)(ii)(B). This is a significant improvement over the draftule and closely mirrors the 1982 regulation, and the Forest Serviceeserves credit for making this change. Even with this improvement

    Installing erosion control to protect a riparian area. Photo by WendyR. Magwire, US Forest Service.

    Standards OR guidelines? Or standards ANDguidelines? There is a BIG difference. Photocourtesy of Bureau of Land Management.

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    Policy Primer, contd

    hough, the new rule omits size requirements for riparian areas, leavinghat to the supervisors discretion with only vague direction that specialttention be given to areas within 100 feet of perennial streams and

    akes. 219.8(a)(3)(ii). Obviously this offers more flexibility for supervi-ors, and could even result in the protection of areas larger than the 100

    eet minimum in the old rules, but there is no guarantee.

    Another major ambiguity in this portion of the rule is around plan compo-ents, as previously mentioned. A forest supervisor could potentially useny combination of plan components to maintain or restore riparian areasnd do so in a manner that precludes any accountability. This exemplifies larger trend found throughout the regulations; namely no clear mandates

    or restoration or for specific standards, combined with the wide discretioniven to forest supervisors.

    SoilsWe see this again in the case of soils and soil productivity. The 1982egulations mandate the conservation of soils, including their protection,

    which is to be guided by technical handbooks that show specific ways tovoid or mitigate damage and maintain or enhance soil productivity. 36

    CFR 219.27(f) (1982). In order to meet this requirement, forest regionseveloped soil productivity standards.

    n contrast, the final regulation states that plans only must contain components to maintain or restoreSoils and soil productivity, including guidance to reduce soil erosion and sedimentation. (219.8(a)2)(ii). Most glaring is the omission of any direction to protect soils. Also, it is important to note thathe rule has no definition for guidance and while it may include issuing technical handbooks, it isoubtful that the agency will issue specific formal directives to maintain or enhance soil productivity.

    While subtle, these changes further weaken the old regulations.

    continued on next page

    Roads & Watershedsn regard to road management and watershed integrity,he final regulation contains absolutely no requirementsor managing the road system. The 1982 regulations alsoacked strong language regarding this issue, directing, thatll roads are planned and designed to re-establish vegeta-ve cover on the disturbed area within a reasonable pe-od of time, not to exceed 10 years after the terminationf a contract, lease or permit, unless the road is determinedecessary as a permanent addition to the National Forestransportation System. 36 CFR 219.27(a)(11) (1982). Thisomes directly from the NFMA and while it certainly could

    e stronger, its exclusion from the final regulation is surpris-ng. Instead, the regulation directs that forest plans, mustnclude plan components, including standards or guidelines,o maintain or restore the ecological integrity of terrestrialnd aquatic ecosystems and watersheds in the plan area,

    ncluding plan components to maintain or restore structure,unction, composition, and connectivity 36 CFR 219.8(a)

    Roads have some of their most severe impacts at stream crossings.Photo courtesy of US Forest Service.

    New culvert installment, Olympic National Forest. Wildlands Cphoto.

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    1). However, the overall language is weak, and though the final ruleequires the forest supervisor to include either standards or guidelines,

    wide discretion remains in how those will be implemented and whetherhey will be binding on future forest actions. Additionally, by omittingny mention of roads in the discussion of watershed integrity, there is

    o reminder that specific requirements for their removal or mitigation ofheir impacts should be included in forest plans.

    he only direct mention of roads in the new planning regulations is asne of the examples of ecological conditions. The definition by itself

    makes sense that roads are an impact on ecological conditions. But,he references to ecological conditions elsewhere in the regulation seemo assume that they are more positive in nature, while this definitioneems to be just a summation of the existing condition. This could haveeen improved by making a distinction between existing ecological con-ition and desired ecological condition, but the Forest Service choseot to travel that particular route, and this is one more reason why theistinction between restore and maintain and when those should be ap-lied is so important.

    Policy Primer, contd

    The regulations lack specific language to prevent recreation usedamaging the environment. Photo by Wendy R. Magwire, US Service.

    The ambiguous regulations are likely to provide no safeguards for quietrecreation. Photo by Dan Funsch.

    Sustainable Recreationhe final planning rule includes the concept of sustainableecreation, which it defines as the set of recreation settingsnd opportunities on the National Forest System that is eco-

    ogically, economically, and socially sustainable for presentnd future generations. 219.19. Furthermore, the proposedule explains 219.10(b)(1) the plan must include plan com-onents, including standards or guidelines, to provide for: (i)ustainable recreation; including recreation settings, opportu-ities, access; and scenic character....

    While this certainly is a laudable vision, the reality is thatftentimes social, fiscal and ecological sustainability can onlye achieved at the expense of one another, and there is nopecific direction to prevent recreational impacts from harm-ng the environment or from conflicting with other uses.

    However, recreational activities must still comply with regula-ons and executive orders, and site-specific analysis must beompleted to ensure such compliance. This is an improvementrom the current planning regulations that are ambiguous onhis point, especially in relation to over-snow vehicle travel.

    ConclusionWhile there were many improvements between the draft andnal regulations, the final regulations remain long on vision,hort on specifics, weak on definitive protection and they givendividual forest supervisors too much discretion in decidingwhat plan components should be included.

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    PROGRAM UPDATES, WINTER SOLSTICE 2011

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    GET WITHTHE PROGRAM

    By Thomas R. Petersen, Development Director

    You think youve got a stellar March Madness team going for you? Maybe, but Wildlands CPRsOregon Team Sarah Peters, our Staff Attorney/Legal Liaison based in Eugene, and MarliesWierenga, our Washington/Oregon Field Coordinator based in Portland will give you a run

    for your money. You might want to consider them for your bracket.

    Bear with me while I stay with the basketball analogy for just a bit longer, as I think its fair to equate

    both Sarah and Marlies as outstanding point guards for Wildlands CPR: while their work is not alwayshigh profile (scoring numerous points with whirling slam dunks), their contributions come as play mak-ers, distributors, strategic thinkers and doers that drive a lot of what a team does and how it performs.

    Sarah, for example, spends a majority of her time using legal, administrative and organizing strate-gies to improve travel management planning and implementation. She assists other conservationgroups with filing closure petitions, comments, appeals, and at times direct litigation. Sound wonky?Yeah, well, so are a lot of Xs and Os on a chalkboard, but necessary for your end result scoring.Sarah has scored a couple of significant legal decisions recently that attest to her ability to weave inand out the tangle of legal court room complexities. (sorry)

    For example, last May Sarah assisted in an important win on the Salmon-Challis National Forest in Ida-

    WILDLANDS CPRS OREGON TEAM

    6DUDK 0DUOLHV

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    Program Updates, contd

    o. While Wildlands CPR wasnt a plaintiff in the Salmon-Challisase, Sarahs strategic support helped the plaintiffs in their success-ul effort to secure a result in the courts ruling that the agency mustollow the plain language of the off-road vehicle Executive Ordersy minimizing the impacts of off-road vehicles on natural resources

    nd other users.

    And just last month, Sarahs assistance paid off in another im-ortant decision on an Idaho forest. On the Sawtooth Minidokaanger District travel plan the court ruled that the Forest Serviceailed to provide enough analysis to justify its decision to moveorward with the Minidoka travel plan, which added 94 routes ton already bloated system and left 630 miles of user created routesnaddressed.

    he decision reaches the following conclusions with regards toORV management on National Forest lands:

    Affirmed the finding in the Salmon-Challis NF decision(above) that the Executive Orders are enforceable;

    Found that the Forest Service failed to comply withForest Plan standards by failing to design and imple-ment mitigation measures and failing to address waterquality impacts from user created routes; and

    Found that the NEPA analysis was inadequate on anumber of levels and did not support the Finding ofNo Significant Impact in the decision; in particular,the judge ruled that the agency cannot ignore user-created routes simply because they were already thereor rely on the presumption that cross country travel im-

    proves the situation to such an extent that site specificanalysis is not necessary.

    Marlies backcourt actions are equally impressive. When Wlands CPRs Restoration Coordinator Sue Gunn retiredWashington Watershed Restoration Initiative (WWRI) a team of 16 diverse conservation groups including WashinStates Department of Ecology, Trout Unlimited, and the Uppe

    lumbia United Tribes was left without a leader. Marlies, joined Wildlands CPR last October, stepped in to re-invigoratWWRI, which had been such a successful component of WildlCPRs Legacy Roads and Trails work.

    For example, in January Marlies facilitated a meeting of theWWRI in Olympia, WA where they worked as a team to elish draft goals for 2012 including continued Legacy RoadsTrails advocacy work, engaging in rightsizing, and building port through additional partners. Marlies has been improvingWWRIs communication pieces, including a Legacy Roads Trails accomplishments table (that will be used as an insert toForest Service Legacy Roads and Trails accomplishment reprevisions to the WWRI website, and the development of a tapoints guide for WWRI members.

    Marlies is also our point person with Region 6 of the Forest Se(Oregon and Washington) where so much of the restoration wof Legacy Roads and Trails is playing out on the ground. Mameets with staff there regularly, and in early January participin a field trip on the Siuslaw National Forest along with Sand Forest Service engineers to view road projects compvia Legacy Roads and Trails, plus a proposed road thats schedfor reclamation later this year.

    Marlies is also pulling together other networks, and building tionships and discussing opportunities where increased collabtion a strong point of Wildlands CPRs could provide tangible results. For example, shes met with Washington andegon state agencies including the Oregon Department of Envmental Quality and the Oregon Watershed Enhancement Boand Washingtons Department of Ecology, as well as a numbNGOs including Oregon Wild, Trout Unlimited and the GiPinchot Task Force.

    So while both Sarah and Marlies worked their magic in the bcourt, the result has been a winning season for Wildlands with, for example, the Forest Service using Legacy Roads and T

    funds to reclaim 1,172 miles of roads in 2011 alone. (Back iday, we were lucky to have the Forest Service remove 100 of roads per year.)

    With that kind of record we think well be a shoo-in for theDance for years to come.

    Little Blitzen waterfall, Steens mountain,OR. Photo courtesy of Bureau of LandManagement.

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    ODESTO ROADS

    AS ROADS SPREAD IN RAINFORESTS, THE

    ENVIRONMENTAL TOLL GROWSBy William Laurance

    We live in an era of unprecedented road and highwayexpansion an era in which many of the worlds lasttropical wildernesses, from the Amazon to Borneo to the

    Congo Basin, have been penetrated by roads. This surge in roaduilding is being driven not only by national plans for infrastructurexpansion, but by industrial timber, oil, gas, and mineral projectsn the tropics.

    ew areas are unaffected. Brazil is currently building 7,500 kilo-meters of new paved highways that crisscross the Amazon basin.hree major new highways are cutting across the towering Andes

    mountains, providing a direct link for timber and agricultural ex-orts from the Amazon to resource-hungry Pacific Rim nations, suchs China. And in the Congo basin, a recent satellite study found aurgeoning network of more than 50,000 kilometers of new log-ing roads. These are but a small sample of the vast number of new

    ropical roads, which inevitably open up previously intact tropicalorests to a host of extractive and economic activities.

    Roads, said the eminent ecologist Thomas Lovejoy, are the seedsf tropical forest destruction.

    Despite their environmental costs, the economic incentives to driveoads into tropical wilderness are strong. Governments view roadss a cost-effective means to promote economic development andccess natural resources. Local communities in remote areas of-

    en demand new roads to improve access to markets and medi-al services. And geopolitically, new roads can be used to helpecure resource-rich frontier regions. India, for instance, is currentlyonstructing and upgrading roads to tighten its hold on Arunachalradesh state, over which it and China formerly fought a war.

    From Brazil to Borneo, new roads are being built into tropical

    forests at a dizzying pace, putting previously intact wilderness

    at risk. If we hope to preserve rainforests, a leading researcher

    says, new strategies must be adopted to limit the number of

    roads and reduce their impacts.

    Editors Note: This article is reprinted from Yale Environment 360,

    http://www.e360.yale.edu

    Of course, roads are not just an environmental worry in the tropiforested areas of western North America, one of the best predictowildfire frequency is the density of roads. In Siberia, road expanis promoting a sharp increase in logging and forest fires. Androads in the Arctic could potentially alter epic mammal migrat

    But no other region can match the tropics for the sheer scalepace of road expansion and the degree of environmental charoads bring. Road building has a range of direct impacts on raest ecology. In wet tropical environments, the cut-and-fill opera

    associated with road construction can impede streams, incrforest flooding, and drastically increase soil erosion. Roads discharge chemical and nutrient pollutants into local waterwand provide avenues of invasion for many disturbance-lovingotic species.

    A satellite view of deforestation associated with roads in theBrazilian Amazon. Photo courtesy of NASA.

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    Odes to Roads, contd

    oads that cut through rainforests can also create barriers for sensi-ve wildlife, many of which are ecological specialists. Studies havehown that even narrow (30 meter-wide), unpaved roads drastical-y reduce or halt local movements for scores of forest bird species.Many of these species prefer deep, dark forest interiors; they havearge, light-sensitive eyes and avoid the vicinity of road verges,where conditions are much brighter, hotter, and drier. A varietyf other tropical species including certain insects, amphibians,

    eptiles, bats, and small and large mammals have been showno be similarly leery of roads and other clearings.

    And by bringing nave rainforest wildlife into close proximity withast-moving vehicles, roads can also promote heavy animal mor-ality. For some creatures, especially those with low reproductiveates, roads could potentially become death zones that help propelhe species toward local extinction.

    Although the direct effects of roads are serious, they pale in com-arison to the indirect impacts. In tropical frontier regions, newoads often open up a Pandoras box of unplanned environmental

    maladies, including illegal land colonization, fires, hunting, gold

    mining, and forest clearing. The best thing you could do for theAmazon, said the respected Brazilian scientist Eneas Salati, is toomb all the roads.

    n Brazilian Amazonia, my colleagues and I have done studieshowing that around 95 percent of all deforestation occurs with-n 50 kilometers of highways or roads. Human-lit fires increase

    dramatically near Amazonian roads, even within many proteareas. In Suriname, most illegal gold mining occurs near rowhereas in tropical Africa we have found hunting to be so intnear roads that it strongly affects the abundance and behavioforest elephants, buffalo, duikers, primates, and other expl

    species. Roads can sharply increase trade in bushmeat and wiproducts; one study found that eight killed mammals were tported per hour along a single road in Sulawesi, Indonesia.

    Paved highways are especially dangerous to forests. They pro year-round access to forest resources and reduce transportcosts, causing larger-scale impacts on forests and wildlife thaunpaved roads, which tend to become impassable in the wetson. The proposed routes of new highways often attract swarmland speculators who rush in to buy up cheap forest land, wthey then sell to the highest bidder.Perhaps the most damaging aspect of paved highways is that spawn networks of secondary roads, which spread further envmental destruction. For instance, the 2,000-kilometer-long BeBraslia highway, completed in the early 1970s, has today evointo a spider web of secondary roads and a 400-kilometer-swath of forest destruction across the eastern Brazilian Amazomy colleagues and I showed in a 2001 study published in Scielarge expanses of the Amazonian forest could be fragmentethe advance of new highways and roads in Brazil. Accordinour models, by the year 2020, rates of forest destruction wrise by up to 500,000 hectares per year, and the area of fthat remained in large, unfragmented tracts exceeding 100,square kilometers would decline by 36 percent.

    Can the environmental impacts of tropical roads be minimizetheory, the answer is Yes, partially. Frequent culverts can rethe effects on streams and hydrology. Impacts on animal mments can be reduced by keeping road clearings narrow enoso that canopy cover is maintained overhead, providing a waarboreal species to cross. In high-priority areas, such as cenational parks, rope-bridges are being used to facilitate road cings of monkeys and possums. For small ground-dwelling speculverts beneath roads can allow road-crossing movements, even large animals such as Asian elephants will use highwayderpasses that are designed to be wildlife-friendly.

    Measures also exist to limit the devastating indirect impacroads, such as illegal land colonization and forest clearing. of the most vital steps is to legally establish parks or reserves aroad routes in advance of road construction. Such reserves osubstantially reduce forest incursions, though they rarely halt

    continued on next page

    New roads facilitate the clearing of land for agriculture. Photoby Felipe Menegas.

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    ntirely. Another promising idea is to promote railroads rather thanighways in tropical wilderness regions. Because railroads stopnly at fixed locations, the spatial patterns of forest exploitationnd movement of forest products can be more easily controlled and

    monitored than with roads.

    n practice, however, limiting the environmental impacts of roads ineveloping nations is expensive and risky. Tropical nations rarelyave the institutional capacity, human capital, or financial resourc-s to adequately manage development in their remote frontier re-ions, frequently leading to a resource grab revolving aroundlegal trade and outright theft of natural resources, which is greatlyacilitated by road expansion.

    When it comes to tropical roads, I believe three conclusions arenescapable. First, highways and roads are the single biggest fac-or determining the pattern and pace of tropical forest destruction.New roads that slice deep into intact forest tracts are especiallyevastating.

    econd, among the many human drivers of environmental change,oad building is one of the most readily amenable to policy modi-cation. In practical terms, it is far easier to cancel or relocate aoad project than it is to, say, reduce human overpopulation or haltarmful climate change.

    inally, if we hope to maintain intact tropical forests and their vitalcosystem services and biodiversity, then we simply must get seri-us about tropical roads. And there is only one real solution: care-ully plan and limit frontier road expansion.

    How can this be achieved? First, we need to sensitize political de-ision-makers, economists, infrastructure planners, and the generalublic about the myriad environmental costs of road expansion,specially into intact forests. The biggest road projects are ofteneing supported by international lenders such as the Asian, Afri-an, and Inter-American development banks and by foreign aidoled out by China, the U.S., and the European Union. Educatinguch decision-makers needs to be done both generally and on aroject-by-project basis.

    When I was president of the Association for Tropical Biology andConservation, one of my key goals was to use the organizations

    cientific expertise and credibility to combat some of the most en-ironmentally risky plans for frontier road expansion. We werespecially active in critiquing plans to punch new roads into theores of national parks, such as Yasun in Ecuador, Kerinci Seblatn Indonesia, and the Serengeti in Tanzania.

    Another key priority should be better frontier law enforcementforest monitoring, given that much road building in tropical nais illegal or unplanned. Special attention should be focused omore-aggressive timber, oil, gas, and mineral corporations, mof which are known to engage in bribery and collusion in theforts to gain unbridled access to forest resources.

    There is also a dire need to improve environmental impact asments (EIAs) for planned roads. In Brazil, for instance, EIAseveral major Amazonian highways focused only on a narrowalong the road route itself, while completely ignoring the deva

    ing indirect effects of roads. Similarly, EIAs for major developprojects, such as large mines and hydroelectric dams, often igthe impacts of road proliferation that such projects inevitablymote.Finally, given that tropical deforestation is a massive source of ghouse gas emissions, international carbon-trading funds shoulused to better plan and mitigate road projects, to establish protected areas in advance of road construction, and to hamost ill-advised road projects altogether. In