To Forest Supervisor, Regional Forester, and Plan Revision staff:

I used to live a short distance from the Selway-Bitterroot Wilderness and enjoy hiking and nature study in the area.  I recognize the vital importance of the area for maintaining high levels of water quality and high quality habitat for wild animals in the Northern Rockies.  There is no other place like this in all of the Lower 48 states.  The following are my comments on the Plan Revision.

(1) The agency should recommend all roadless areas for wilderness designation.  I have hiked in the Cove Mallard roadless area, Frank Church River of No Return Wilderness, Selway Bitterroot WIlderness, Mallard Larkins roadless area, and Vanderbilt Hill/Meadow Creek/Upper North Fork area.  The roadless areas of the two national forests are some of the finest in the Lower 48 States.  These areas should remain wild.

The agency's proposal falls far short, since it does not even protect any roadless area as non-motorized, non-mechanized backcountry.  

The Forest Service has not recommended the Weitas Creek, Pot Mountain, Fish and Hungery Creeks, Upper North Fork Clearwater, Frank Church - River of No Return (Cove Mallard) addition, or Hells Canyon addition.  The FS has not recommended most Gospel Hump additions as roadless areas even though the agency's own surveys show that the area is, in fact, qualified.  Forest Service proposals for the Mallard Larkins, and Kelly Creek areas do not adequately designate or protect the unroaded areas within these areas (e.g., snowmobile corridors).

(2) Water quality, wildlife habitat, and fish habitat standards should be enforceable and non-discretionary, without loopholes.

There are serious loopholes to the water quality standards for protection measures, including streamside buffers.  Standards should be rigorous and should be met before and after logging.  The proposal does not adequately protect sensitive soils or steep slopes.

No logging should be permitted in old growth.  The proposal unwisely would allow logging in old growth forests, even those set aside for sensitive species.  The current plan only protects 10% of the forest for old growth for wildlife.

The Committee of Scientists report recommends (a) scientific involvement in the selection of focal species, (b) independent scientific review of proposed conservation strategies before plans are published, (c) scientific involvement in designing monitoring protocols and adaptive management.  These recommendations should be adapted in this plan revision.

Species of Concern lists for the Forests omit peregrine falcon, bald eagle, blackbacked woodpecker, black swift, common loon, harlequin duck, wolverine, bog lemming, western toad, ringneck snake and the Threatened grizzly bear.  There is substantial concern about the viability of these species.  Occasional recent occurrences of the grizzly have been noted on both Forests and the large blocks of wild land on the Forests provide important habitat for the grizzly.

(3) Consider alternatives that allow natural processes to create conditions on the Forests, rather than excessive artificial habitat manipulation.

(4) Road density and motor vehicle use should be limited to protect elk.

I recommend that you fully consider the proposal by Friends of the Clearwater for the Clearwater and Nez Perce National Forest plan revision.

Sincerely yours, 
  




Sherman Bamford, CPA
PO Box 3102
Roanoke, VA  24015-1102
(540) 343-6359
bamford2@verizon.net