CGC #1142

by CGC on May 26, 2012

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                       THE CGC COMMUNICATOR

                             CGC #1142

                      Saturday, May 26, 2012

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                 Robert F. Gonsett, W6VR,  Editor
                 

   Copyright 2012, Communications General® Corporation (CGC)

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 THE ROADLESS QUEST - HOPEFULLY A NON-ISSUE FOR MOST
 COMMUNICATION SITE OPERATORS USING FOREST SERVICE ROADS

 Portions of Forest Service land in southern California
that now contain roads will ultimately have some of their roads
redesignated as "Back Country Non-Motorized" or "Recommended
Wilderness" under a plan now being put forward by the Forest
Service (only Congress can officially designate areas as
Wilderness).

 To what extent this plan will diminish or eliminate access
to established radio communication sites is unknown and must be
evaluated on a case-by-case basis.  Public workshops will be held
at various locations from May 29 to June 5, 2012 and it is
highly recommended that communications site users attend those
meetings, make the public safety aspects of their services known
and follow up by filing written comments in support of continued
and unfettered access to the communications sites -- even if the
changes proposed do not cause concern today.

 The anticipated downgrading or elimination of some roads
is due to an out-of-court settlement between the Center for
Biological Diversity and the United States Department of
Agriculture (which translates to the Forest Service in this case).
Several other entities joined forces in bringing about the
underlying 'roadless lawsuit' including the Wilderness Society
and the State of California (by then Attorney General Edmund G.
Brown Jr.).  The name "Center for Biological Diversity" should
be familiar to our readers.  The Southwest Center for Biological
Diversity is the entity that brought us the anti-perching and
bird diverter mandates, so the push toward roadless areas
should warrant close review.

 We say "roadless" because large sections of Forest Service
land already carry a roadless designation and the plaintiffs
apparently want the word roadless to really mean roadless despite
the clear need for roads in certain situations.  In southern
California forests, existing Inventoried Roadless Areas ("IRAs")
total approximately 1.1 million acres, or about thirty-two percent
of our local National Forest System lands.  So, if you rely on a
road in one of those Inventoried Roadless Areas, the road could
disappear or you could become a "non-motorized hiker" in order
to reach your site -- even if you have heavy equipment to carry.

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 USING SANTIAGO PEAK AS AN EXAMPLE

 Let's look at the Santa Ana Mountains which are home to
Santiago Peak and four other communications sites where the land
is administered by the Forest Service.  Here, Inventoried Roadless
Areas are extensive.  Download the map at the following URL and
find the Santa Ana Mountains at the extreme left side of the map.
Find the green and red areas immediately south of the City of
Corona and you have found the mountain range in question.  The
red areas are the Inventoried Roadless Areas:

 http://tinyurl.com/InventoriedRoadlessExample

 Fortunately, a geographic area classified as an Inventoried
Roadless Area does not necessarily mean that the Forest Service
will eliminate or downgrade all roads therein or restrict your
access thereto.  Let's look at the Forest Service's Proposed
Action plan, version ALT 2, which is the version posted on the
Web (a 14MB file), to find out just what the authorities have
in mind for Santiago Peak and vicinity:

 http://tinyurl.com/TrabucoProposalALT2

 One of our clients has reviewed this map and believes
that the roads he uses to access Santiago will be preserved,
hence there is no problem provided (a) the ALT 2 map is the
one and only proposal and (b) the detailed wording to be
associated with the map does not open the door to allowing
downgraded or destroyed roads tomorrow.

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 WHERE TO FIND BASIC INFORMATION AND WHAT TO DO NEXT

 To find out much more about the Forest Service's plans and
to download other Inventoried Roadless Area and Proposed Action
maps, use this comprehensive resource page with clickable links:

 http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=35130

 Here's what is important.  The Forest Service will be hosting
multiple open house workshops where you can learn about their
proposed actions for specific areas.  We are told that the content
and format of each meeting will be the same and that Forest
Service staff will be available to answer questions about their
proposed actions.  Maps of the proposed changes will be available
for viewing.  The meeting times and locations are available here:

 http://tinyurl.com/RoadlessMeetings

 Note that written comments are due by June 11, 2012.

 Hopefully there will be little or no impact on access to
your communications site/s with the changes now proposed -- but
you will not know without checking the final proposals.  We
believe that attending the Forest Service workshops and filing
written comments in support of continued and unfettered access
to communications sites is very important.

 Do not hesitate to share this news bulletin with your company
management and news departments.  The potential impact of the
changes is not necessarily trivial and is certainly worth
careful review.

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 CGC INVITES A RESPONSE FROM THE FOREST SERVICE

 The CGC Communicator has chosen to focus its story (above)
on road access to communications sites.  This is because land
down-zonings will inevitably lead to road downgrades or de-
commissionings.

 A draft copy of our story was submitted to the Forest
Service for comment.  We were impressed with the immediate
response we received (see below).  However, we were unable to
secure permission to print the author's name or title in time
to meet our press deadline, meaning that the comments should
be regarded as informal.

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 THE FOREST SERVICE RESPONDS TO CGC'S STORY

 "...thank you very much for sharing this draft story....

 "In your lead paragraph, it would be more accurate to say
that the Forest Service is examining the zoning in designated
roadless areas (the IRAs), rather than describing this as a road
designation project.  Although zoning choices will affect the
future management of the roads and the management of the area
around the roads, this planning effort will not study individual
roads or make any decisions to close an individual road.

 "Even with that caveat, the input from the communication site
users is important.  Most communication sites (like Santiago) were
excluded from the IRAs when the boundaries were drawn, but some
sites (like Black Mtn on the Los Padres) are within the designated
IRAs.  When a site was within an IRA, the Forest Service proposed
action maintained the existing zoning around all authorized
communication site facilities.  I agree that each user should
look at their site and provide comments if an area was overlooked.

 "The other point I'd make is that this is the beginning of
the environmental review process, and the next step will be to
identify issues and alternatives.  The analysis will be published
in a Draft Supplemental Environmental Impact Statement sometime
late this year.  There will be a 90 day comment period on the
draft, which is an important point in the process for anyone
interested in the outcome.

 "Thanks for including the link to the project web page -
comments can be filed through the "Comment on Project" link on
the right side of the page."


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