AMERICAN FEDERATION OF MINERALOGICAL SOCIETIES

         Volume 54, Number 8
            September, 2001

 LOUD & CLEAR

by George Loud, AFMS Conservation & Legislation Chair

You have probably noticed that we have a new gang in the Executive Branch of our Federal government. The nomination of Gale Norton for Secretary of Interior provoked a considerable amount of controversy with the multiple use advocates including the Blue Ribbon Coalition expressing support and various environmental groups including the Sierra Club opposing the nomination. The League of Conservation Voters placed a large ad in the Washington Post which had the heading Gale Norton is so far on the fringe... she's off the page. Given the extent of the opposition to her nomination, her confirmation by the Senate was surprisingly easy. Perhaps she can thank John Ashcroft for taking the heat from critics of the new administration. So, with the new gang in place where are we headed? The initial actions of the Bush administration, insofar as they impact on issues dear to the hearts of rockhounds, are so far without effect although several initiatives are pending which may well help in our efforts to cling to our rights to collect on public lands.

Clinton Monument Designations

Invoking statutory authority allegedly found in the Antiquities Act of 1906, President Clinton established 19 National Monuments covering more than five million acres and expanded three others. The Clinton administration used both National Monument designation and the rule making process (see below) to protect federal lands in a manner circumventing Congress and the Wilderness Act. Jon Spunaugle, President of ALAA, has documented numerous mineral collecting locations falling within the National Monuments established by the Clinton administration. On February 20, 2001, Interior Secretary Gale Norton stated that the Bush administration is not seeking to overturn any of President Bill Clinton's designations of federal land as National Monuments. The extent to which commercial and recreational activities, which had been allowed in these areas, will be permitted to continue under monument designation creates a number of questions for which we do not yet have answers.

U.S. Forest Service Final Rule Roadless Area Conservation (36 CFR Part 294)

The final so-called Roadless Area rule was published in the January 12, 2001 issue of the Federal Register. The path between the announcement of the Forest service Roads Initiative and the final rule took a number of unexpected turns. The Clinton administration initially projected that 40 million acres would be affected by the proposed roadless initiative. In a Senate hearing November 2, 1999, top Department of Agriculture officials could not agree among themselves on the number of National Forest acres that would be subject to the proposed new policy. Guesstimates varied from 50.2 million acres to 62 million acres. In the end, 58.5 million acres are affected. This 58.5 million acres of newly created defacto wilderness dwarfs the approximately 35 million acres of public lands designated as wilderness by Congress pursuant to the 1964 Wilderness Act. The statutory mechanism for wilderness designation provided by the 1964 Wilderness Act reserves to Congress alone power to designate public lands as wilderness. The Clinton administration's end runs around the statutory mechanism, through monument designations and the roadless policy rule-making, if allowed to stand, leave the 1964 Wilderness Act all but meaningless. Secretary of Interior Bruce Babbitt on at least one occasion told Congress that either Congress protects the lands the administration wanted protected or they would do it their way.

According to an article in the April 26, 2001 issue of the Washington Post, The [Bush] White House has instructed the Justice Department to research ways to scuttle a Clinton administration regulation protecting 60 million acres of National Forest from logging and road building. The final rule for 36 CFR Part 294 Roadless Area Conservation prohibits logging within the areas in the 58.5 million acres classified as inventoried roadless areas. That rule has been challenged by the states of Idaho, Utah and Alaska as well as the Boise Cascade Corporation in a suit currently pending in the U.S. District Court in Boise, Idaho. The Bush administration has been required to file a brief declaring whether or not it will support this new rule. By the time you read this, we will know the gist of the administration brief in that case.

In its short life the Bush administration has taken some heavy hits on environmental issues and currently seems to be looking for policy initiatives to help it shake the onus of the anti environmental label. Please e-mail and fax President George W. Bush at:

Facsimile: (202) 456-2461
e-mail: President@whitehouse.gov

This is a tough one. Environmentalism seems to have replaced God, motherhood and apple pie in this country. My sense is that it will be extremely difficult for the Bush administration to reverse the Clinton Forest Service road rules. A Washington Post editorial of May 2, 2001 headed Keep the Roadless Rule lauded the policy goals of the new rules in protecting wildlife habitat and watershed quality. Certainly the concept of preserving the wild state of lands currently deserving that description has a certain amount of appeal. However, the editorialists generally fail to recognize that there are both pros and cons. The cons include:

1. The new rules diminish recreational opportunities, including rockhounding.

2. The new rules will have a severe economic impact on states and counties where the land in question represents a significant portion of their jurisdiction and tax base.

3. The new rules have a severe potential impact on the economy of the nation as a whole. As reported in an April 4, 2001 of the House Subcommittee on Forest, Forest Health Energy and Mineral Resources, an analysis performed by Advanced Resources International, Inc., under contract to the Department of Energy, showed that an estimated 11.3 trillion cubic feet of natural gas is technically recoverable in the 58.5 million acres affected by the Roadless Rule. All of us who heat our homes with natural gas have seen our utility bills skyrocket this past winter. We cannot have our cake and eat it too.

4. Last but not least, the end does not justify the means. The use of the rule-making process and monument designation to by-pass Congress and the 1964 Wilderness Act smacks of arrogance.

In an op-ed column published in the April 28, 2001 Washington Post, Mike Dombeck, former Chief of the U.S. Forest Service, wrote a piece defending The Roadless Rule as a balanced solution to a decades-old controversy. He writes:

"The Forest Service policy would not block any existing access to National Forests for recreation, fire suppression, timber harvest or any other use. Nor would it close a single mile of existing road."

Huh? What about the prohibition against reconstruction of roads in the new 36 CFR Part 294 prohibition against road reconstruction. In the aforementioned U.S. District Court case pending in Idaho a court ruling noted that officials in the California Chasta-Trinity National Forest had to drop plans to reconstruct and maintain old jeep trails that provide access to the lower McCloud River. More to the point, what about new rule 36 CFR Part 212 which is also a part of the so called Forest Service roads initiative. The final rule, which became effective January 12, 2001 and was that date published in the Federal Register, adds a new paragraph (b) to 36 CFR 212.5. Subparagraph (2) provides:

Identification of unneeded roads. Responsible officials must review the road system on each National Forest and grassland and identify the roads on lands under Forest Service jurisdiction that are no longer needed to meet Forest Service Resource Management objectives and that, therefore, should be decommissioned or considered for other uses, such as for trails. Decommissioning roads involves restoring roads to a more natural state. Activities used to decommission a road include, but are not limited to, the following: reestablishing former drainage patterns, stabilizing slopes, restoring vegetation, blocking the entrance to the road... [the list goes on and on].

In explaining the Background of the new rule, the Federal Register notice of January 12, 2001 states that one of the primary purposes of the new rules is to aggressively decommission roads that are determined, through forest planning, implementation of the National Environmental Policy Act, and other analyses, to be damaging to the environment, or to be no longer necessary for achieving resource management objectives. The language quoted above from new rule 36 CFR Part 212 probably poses more of a clear and present danger to rockhounding than does the new so called Roadless Rule 36 CFR Part 294.

Suspension of The New Final Rules Governing Hard Rock Mining Published In the Federal Register November 21, 2000

Another Bush administration initiative which might benefit our hobby is the proposal to suspend and amend the final rules published November 21, 2000. Mineral collectors more knowledgeable than myself with regard to mining regulations have expressed the view that the new rules published November 21, 2000 and which became effective January 20, 2001 would greatly curtail or even eliminate specimen mining. My understanding is that the bonding requirement poses a major problem for small miners. Comments may be submitted to the BLM as follows:

Mail:         Director, Bureau of Land Management
                Administrative Record, Room 401 LS
                1849 C Street, N.W.
                Washington, D.C. 20240

e-mail: <WOComment@blm.gov>
                (Include Attn: AD22")

Deer Hill Reopened

At the Rochester Mineralogical Symposium I was fortunate to meet Woody Thompson of the Maine Geological Survey who informed me that the collecting sites in the While National Forest portion of Deer Hill (East side) had been reopened to collecting on a fee basis. The fee is reported to be $3.00 per day per collector and purportedly covers the cost of policing the area and maintaining the trails. This represents a resolution of the issue far preferable to the alternative of closure to collecting. Credit is undoubtedly due to those collectors who took the time to write the U.S. Forest Service supervision urging that the collecting site be reopened. Deer Hill in Maine and Moat Mountain in New Hampshire were stops on an EFMLS collecting tour several years ago in which I participated. This is my answer to my fellow mineral collectors here in the East who suggest that all of these land use issues have no impact on us.

Log On

If you have a computer with a modem you can readily review the rule changes discussed above.

1. Log on to <www.gpo.gov>

2. Scroll down to Access to Government Information Products and thereunder, subindented under Quick Links, click on Federal Register;

3. Now on the Federal Register home page, click on the Browse feature near the top of the page and which has a red arrow New pointing to it;

4. Scroll down to Browse Back Issues of the Federal Register Table of Contents after which are enumerated the different years. To review the final hard rock mining regulations published November 21, 2000, click on the year 2000 following Browse Back Issues of the Federal Register Table of Contents which will bring up the heading Contents Pages: 2000", scroll down to November 21, 2000 and click on that date. That will give you a Table of Contents for the Federal Register issue of November 21, 2000. Then scroll down to the listings for Land Management Bureau and click on the TEXT for the final mining regulations.

5. If you wish to review the final rules 36 CFR Part 294 or 36 CFR Part 212, go back to the line Browse Back Issues of the Federal Register Table of Contents and click on the year 2001. Then scroll down to January 12, 2001, click on and you will bring up the Table of Contents for the Federal Register issue of that date. Scroll down to Forest Service and thereunder you will find both the text for Roadless Area Conservation (36 CFR Part 294) and Forest Transportation System Administration (36 CFR Part 212).

6. To review the proposal to suspend the new mining regulations click on the date March 23, 2001 and then scroll down to listings for Land Management Bureau and click on the TEXT.
 



AMERICAN FEDERATION OF MINERALOGICAL SOCIETIES         Volume 54, Number 9
SERVING SEVEN REGIONAL FEDERATIONS                                     October, 2001

LOUD & CLEAR

by George Loud, Conservation & Legislation Chair

The Roadless Battle Continues

Access to 59 million acres of public land (in National Forests), i.e., the so-called "Inventoried Roadless Areas", remains a political football. We laymen can only wonder at the use of the word "roadless" by bureaucrats to describe land areas which are the subject of so much debate as to how to manage roads therein. The controversy continues on two fronts.

On the judicial front, on May 10, 2001 the Idaho District Court granted a Preliminary Injunction which prohibits the U.S. Forest Service from implementing "all aspects of the Roadless Area Conservation Rule" as well as the section of the November 2000 Forest Planning Rule that addresses the inventory and evaluation of roadless areas during the Forest Plan Revision Process. The "green" groups who are interveners in the suit have appealed that Preliminary Injunction to the 9th Circuit Court of Appeals. The Bush administration declined to participate in the appeal. Oral argument on the appeal is set for the middle of October 2001. I believe that the trial on the merits of the case is on hold pending resolution of the appeal.

On the regulatory front, the chief of the Forest Service has issued Interim Directives Nos. 2400-2001-3 and 7710-2001-2 on July 27, 2001. Comments on these directives must be submitted in writing by October 22, 2001 and should be sent to:

Content Analysis Team
Forest Service, USDA
Attn: Roadless Interim Directives
P.O. Box 221150
Salt Lake City, UT 84122
via e-mail to: roadless_id@fs.fed.us
or via facsimile to: 801 296 4088

By Interim Directive No. 7710-2001-2, the chief of the Forest Service has reserved himself "The authority to approve or disapprove road construction or reconstruction in inventoried roadless areas, except..." My understanding is that this reservation of authority to the chief of the Forest Service would extend to any act decommissioning a road in the so-called "roadless areas", although I do not find decommissioning to be explicitly mentioned in the directive. If true, if the decommissioning of a road must now be approved by the chief of the Forest Service, this might ameliorate the problem encountered all too often in recent years by field collectors who find access to a site blocked by closure of a road for no apparent reason.

Please write and give your input. My understanding is that comments received today run heavily in favor of locking-up these lands by shutting off access to everyone, including rockhounds and others who use public lands for benign purposes. Again, the deadline for comment is October 22, 2001.
 



AMERICAN FEDERATION OF MINERALOGICAL SOCIETIES         Volume 53, Number 6
SERVING SEVEN REGIONAL FEDERATIONS                                              May, 2000
 

Wither the Sierra Club

John Muir is famous as the founder of the Sierra Club and as a promoter of the creation of new national parks in the early 20th century. In his book Stake Your Claim! The Tale of America's Enduring Mining Laws, Charles Wallace Miller, Jr. describes Muir as a pragmatist who admired miners and "endorsed mining if it had no serious conflict with other values."

An article in the March 15, 2000 issue of the Wall Street Journal describes a "rift" between the "old guard" of the Sierra Club which believes that its interest is best served by a pragmatism that makes compromises with industry and government and "a radical group" which advocates the banning of all commercial logging in national forests and the draining of Lake Powell.

Columnist George Weigel recently reported that the Sierra Club is a cosponsor of the "See Change" initiative which would change the status of the Vatican at the United Nations from one of "permanent observer" to one of a "non-governmental organization." Mr. Weigel asked the rhetorical question "But what on earth (no pun intended) is the Sierra Club's interest in the holy see's U.N. status? Good question.

Congratulations to the California Federation

Through the efforts of Jim Strain, Isabella Burns and others, the BLM recently dedicated a geode collecting area in the Wiley Well District as a "Rockhound Educational and Recreational Area." This designation by the BLM comes after a successful negotiation culminating with a "Memorandum of Understanding" signed by both representatives of the BLM and the CFMS, under which both parties agree to cooperate to facilitate use of the area by the general public, to ensure compliance with BLM rules and to engage in periodic clean-ups. Hopefully, this agreement will serve as a blueprint for other collecting sites in California and other states.

While on the subject of California collecting, I must pass along a request from Isabella Burns that we write our representatives regarding HR3676, the "Santa Rosa and San Jacinto Mountains National Monument Act of 2000." The new national monument is in the Palm Springs, California area and would include sites where large garnets and tourmaline are found. Isabella asks that we write to request amendment of the bill to specifically sanction mineral and rock collecting for recreational or educational purposes within the area to be encompassed by the proposed new national monument.

George Loud
9709 Layminster Lane
Vienna, VA 22182
 
 




AMERICAN FEDERATION OF MINERALOGICAL SOCIETIES         Volume 53, Number 7
SERVING SEVEN REGIONAL FEDERATIONS                                              June, 2000

The Handwriting is on the Wall
by Dan Lingelbach, AFMS President

I don't know where the above expression came from but I think it conveys the situation existing with the "invitation" by the Forest Service for comments on their proposed changes to 36 CFR parts 212,261, and 295 in the March 3 issue of the Federal Register. The Forest Service is going to close some existing accesses to the public lands they manage. George Loud has already brought this to your attention in a previous message. If you read the 16 or so pages in that notice a couple things stand out. One is there is a fundamental change in that there will a shift from "development of a transportation system" to "maintenance of needed roads and the decommissioning of unneeded roads". The other is that they are redefining the usual definition of roads. In their original notice of intention issued several months ago to propose these changes in the CFR, they used terms for areas as being "roaded, roadless and unroaded" in conjunction with "inventoried and uninventoried". This time they used classified and unclassified. When words are used in usual or different ways one gets suspicious of their intentions and I sent a comment to them to that effect.

In the March 3 notice they did do a better job of defining their terms and at least we now know they propose to define a road as "A motor vehicle travelway over 50 inches wide, unless classified and managed as a trail. A road maybe classified or unclassified." You'll have to get a copy of the March 3 notice to find out how classified and unclassified roads are defined, as my message will get way too long if I include them and what goes with it.

Anyway, how do you respond to the notice of the proposed changes to the 36 CFR? Following is how I responded to this "invitation" to comment. Instead of getting into the details of the effects, I tried to stress that rockhounding is a bona fide recreational activity, that access by motor vehicle is needed to get to certain areas and that our clubs are willing to work with the local managers to maintain access to collecting areas. Also, we are not anti-environmentalists.

You'll notice that this response was my personal feeling and not an official position of the AFMS, but hopefully this expresses the sentiment of our members. I would be pleased to learn of your feelings of this approach. I know this is longer than I usually have but maybe I'll have a short one sometime to make up for this one.

April 27, 2000

USFS CAET
Attn: Roads
P.O. Box 221090
Salt Lake City, UT 84122

Greetings:

This communication is in regard to the Forest Service Notices of Overview of Proposal, Proposed Rule Making, Administrative Policy and Proposed Forest Service Manual Revisions published in the March 3rd issue of the Federal Register.

As President of the American Federation of Mineralogical Societies, Inc., (AFMS) an organization of some 55,000 card carrying rockhounds (and many more who elect to remain anonymous) I believe I express the sentiment of the members by saying that our main concern regarding the proposed changes to 36 CPR parts 212,261 and 295 is access to areas to surface collect rocks on public land managed by the Forest Service. I suspect those who do not belong to a rock club are younger people with children who have other scheduled activities but who enjoy being able to pick up rocks when they visit public lands for that and other recreational activities.

Unfortunately, many of the card carrying rock hounds are older and unable to hike miles from the roads to look for and possibly surface collect rocks. Therefore, the decommissioning of existing unclassified roads is of great concern to us, as rockhounds. Surface collecting of rocks should be as much a recreational activity as say, hiking, horseback riding, snowmobiling, skiing etc. Since rocks of interest to rockhounds exist in only certain locations, access by high clearance vehicles is likely a requirement.

For years rockhounds have been attracted to certain areas on public lands because they contain specimens with interesting features. To maintain access to some of these areas on public lands, "Memorandums of Understanding" have been developed between a managing agency and an organized mineralogical society. One notable example of this has been the Hauser Beds "Rockhound Education and Recreational Area" an agreement between the BLM and the California Federation of Mineralogical Societies which is a member of the American Federation of Mineralogical Societies, Inc. Therefore, whatever regulations are developed for managing a Forest Service transportation system should have provisions allowing the Forest Supervisor or District Rangers to work with an organized mineralogical society to develop agreements to maintain access to certain areas previously used by rockhounds to surface collect.

I would like to emphasize that surface collecting of rocks is a bona fide recreational activity and with some restrictions would have a minimal environmental impact on the area. Organized mineralogical societies are willing to work with any managing agency to work out an acceptable agreement to both parties, as we are probably as concerned about our environment as many other environmental groups. Our feeling is that public lands should be managed to the greatest benefit to the greatest number of people and a livable environment is definitely a benefit. However, access to certain areas of public land is one key to providing this greatest benefit.

Respectfully,
 

Dan Lingelbach
AFMS President
1116 S. Gray
Stillwater, OK 74074




AMERICAN FEDERATION OF MINERALOGICAL SOCIETIES
         Volume 53, Number 3
         February, 2000

Loud & Clear
from George Loud, Conservation & Legislation Chair

Wilderness - Too Much of a Good Thing?

My brother is currently building his dream home in the San Juan Mountains of Colorado on a property bordering the Rio Grande River. A Federal wilderness area on the opposite side of the river gives him a great view from one side of his home. Understandably, my brother is quite pleased to have a wilderness area in his front yard because he need not worry that future development there will destroy his view and/or the rural ambience of his location. My brother and I both regard some amount of wilderness designation as "good" but recognize that it comes with a price, i.e., loss of some forms of recreational opportunities, not the least of which is rockhounding, and loss of revenue to the state and county jurisdictions in which the wilderness area is located. While we might disagree on how much is "too much", at least we can agree on the principle that it is theoretically possible to have too much wilderness. Of course, the problem we all encounter in discussing the issue is that we are unable to define that amount or extent where the good thing becomes "too much" However, I have recently seen some anecdotal evidence that we are at or near the point of "too much."

One item of anecdotal evidence appeared as an article on page 1 of the Wall Street Journal issue of December 14, 1999 entitled "Tough Cuts - Rural School Districts Get a Taxing Primer in Politics of Timber". The article was subtitled "As National Forest Logging is Curbed, They See Share of Revenue Fall Steeply." No state or country government has the power to tax the federal government, which presents a problem particularly acute in a number of the Western states where the federal government owns 50% or more of the land within the boundaries of many jurisdictions. Because the tax base for the state and county governments may be severely limited by the presence of federally owned lands, as compensation, a 1908 federal law still in effect gives school districts and county road departments one-quarter of the revenue generated by National Forest lands within their boundaries. Historically, about 90% of the National Forest revenue has come from logging. Because logging is not permitted in wilderness areas, as the area covered by wilderness designation increases, such revenues decrease. The situation has been made worse under the current administration by severely curtailing the amount of logging permitted in the non-wilderness of our National Forests. Understandably, many legislators from the Western states oppose federal initiatives to purchase yet more land and thereby further erode the tax base of the jurisdictions which they represent.

Another item of anecdotal evidence came to me in the form of a telephone call from an attorney with a State's Attorney Office in a Midwestern state. He was preparing to file suit in Federal Court on behalf of a county, against the Federal government, to prevent closure of certain roads which historically had been maintained by the county. I attempted to assist him by sending him copies of various materials from my files relating to the current laws relating to the so-called R.S. 2477 Rights-of-Way. The aggrieved county which he represents has seen the Federal Government purchase a considerable amount of land within its boundaries and then proceed to close many of the roads traversing those lands, including several which had been maintained by the county. The purchase of private lands and creation of de facto wilderness areas by the Executive Branch of our Federal Government is quite different from the preservation of preexisting wilderness areas by act of Congress.

A King of England was forced to sign a Magna Carta in part to address the grievance that commoners were not allowed to hunt in the King's forest. If present trends continue we common rockhounds, likewise, will not be allowed to hunt in the National Forests.

Mineral Collecting in a Wilderness Area ?

I recall reading an article in a hobbyist magazine wherein the author stated that, without exception, mineral collecting is prohibited on wilderness designated public lands. In a paper presented at the October 1995 "Rockhound Workshop" sponsored by the Oklahoma Geological Survey, John Nichols, Forest Geologist for the Ouachita National Forest (Arkansas) wrote: "Areas on National Forests that generally are not available to the mineral collector include wildernesses and designated 'wild' portions of rivers that Congress has determined will be very selectively managed."

I believe that statements such as those referred to above are erroneous. Jon Spunaugle, President of ALAA in his letter to Congress of April 13, 1997 regarding a joint committee hearing on wilderness correctly summarized the situation as follows:

Acceptable collecting activity differs from wilderness to wilderness. The variance is from outright prohibition of any collecting, even for scientific and educational purposes, to a tolerance of surface collecting with hand-tools which does not disturb the wilderness character of the land.

To the best of my knowledge, the only wilderness area wherein all mineral collecting is outright prohibited is in the Sawtooth Mountain Wilderness Area of Idaho. The legality of such a prohibition is suspect in view of the wording of The Wilderness Act of 1964, 16 USC 1131, §4(d)(2), which states:

Nothing in this Act shall prevent within National Forest Wilderness Areas any activity, including prospecting, for the purpose of gathering information about mineral or other resources, if such activity is carried on in a manner compatible with the preservation of the wilderness environment.

Thus, the Wilderness Act seems to create a "right" to "prospect" in National Forest Wilderness Areas. Of course, the affected agencies have the responsibility for rule making to establish rules enabling the statutory law. The "right" to "prospect" is subject to such regulation and is certainly not unlimited. While prospecting can clearly be regulated consistent with the statutory law, a statutory right cannot be regulated out of existence. A tenet of administrative law is that an agency cannot, through the rule-making process, contravene statutory law. To the best of my knowledge, the prohibition against all mineral collecting in the Sawtooth Wilderness Area has never been challenged in court, although a reasonable case might be made for such a challenge.

Several years ago when I was looking into the issue, I questioned a number of congressional staffers regarding the right to prospect embodied in the Wilderness Act. Even though these staffers were supposedly knowledgeable with regard to land use law, they were ignorant of the prospecting provision of the Wilderness Act. I encountered the same problem in my 1995 contacts with the Offices of the BLM in Phoenix, Arizona. In the latter instance the advice that I received was that mineral collecting is entirely prohibited in wilderness areas, that is, until I worked my way up the chain of command to a person in higher management who acknowledged that mineral collecting is not prohibited in wilderness areas 'although not encouraged.'. Ignorance of both the statutory law and the relevant agency rules at the field level is a major problem facing collectors on all public lands.

Does the foregoing amount to a "distinction without a difference"? Assuming you wish to explore an old mining site in a wilderness area, you must walk in. In some areas horseback riding would be permitted. The ever-growing likelihood is that, after you hike in, you will find that the old mine site has been reclaimed. Even if you locate the old mine site and it is not reclaimed, you must then walk out carrying your specimens. At this point a vision comes to mind - a vision from many years ago of my daughter and her fellow 'Indian Princesses' returning from an old mine site on a long trail, each 'Indian Princess' being carried by her Father because the weight of the rocks in her pockets would otherwise pull her pants down. Unless you have your Father or a horse to carry you, you probably don't attach much value to any right to collect in a Wilderness Area.

The Clinton Roadless Initiative - Creation of De Facto Wilderness

On October 13, 1999 President Clinton announced an initiative to protect 40 to 60 million acres of 'roadless' areas within the National Forest system. In launching this initiative, the U.S. Forest Service published a 'Notice of Intent' (NOI) October 9, 1999 in the Federal Register, which publication opened a window for comment (now closed) and set in motion the process of collecting public comment supposedly for the purpose of receiving guidance in the drafting of proposed rules to effect the Presidential Directive. When enacted in 1964 the Wilderness Act initially established 9 million acres of wilderness area. Today, approximately 107 million acres are federally protected by wilderness designation. This latest roadless initiative would make an additional 40-60 million acres de facto wilderness. Of course, 'roadless' need not actually mean 'roadless'. What constitutes a 'road' is subject to bureaucratic interpretation. In any event, once an area is designated 'roadless' we can expect that any preexisting trail or road in that area will be closed.

Once the proposed rules have been drafted they should be published in the Federal Register and a new window of opportunity for comment will be opened. Stay tuned.
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