1.) Considering the perennial lack of funds to conduct necessary road maintenance, as noted in the NOI, the only prudent course of action is for the Forest Service to suspend any further new road building at least until such time as long-term maintenance costs are met for existing roads.

2.) The Forest Service needs to examine in the EIS whether the existing 380,000 miles of system roads is sufficient to meet the current and reasonably foreseeable management needs. In addition, the EIS needs to examine if existing system roads are in excess of management needs. Such an analysis may help determine whether any new roads need to be built, and may help determine whether any roads should be constructed in any roadless area.

3.) The Forest Service should consider preserving under the new rules unroaded areas as small as 250 acres, or smaller if ecological values so merit. Particularly in heavily roaded areas, such "smaller" roadless tracts provide important refugia for wildlife and likely constitute vital links between larger wild, roadless areas across the landscape. Further, any unroaded areas that are contiguous to any Federal or non-Federal roadless areas of 1,000 acres or more should be protected. In this way, the Forest Service can act as a sort of "anchor" for establishing and preserving larger roadless areas across the landscape.

4.) No unroaded National Forest lands should be exempted under the new rules, and certainly not in theTongass National Forest which contains upwards of 20 percent of all National Forest system roadless areas. Further, unroaded Tongass lands contain much of the last remaining untouched wild temperate rainforest areas on the planet. Additionally, and in order to assure the preservation of all its unroaded wild lands, the Tongass should be subject to immediate protections under part one of the proposed rules.

PFP supports the restriction of all management activities in all inventoried roadless areas until such time that a national policy is adopted. Such inventoried roadless areas should not be restricted to RARE II and forest plans, but to all roadless inventories made up to the current date. Restricted activities should include road building, commercial and non-commercial logging, grazing, mining, OHV use, and other environmentally damaging activities. Adoption of such an "interim" policy would best protect vital roadless area resources.

In terms of uninventoried roadless areas, PFP believes the Forest Service should immediately halt all management activities until such time a national policy is adopted. To do otherwise would run contrary to spirit of the President’s October directive in that uninventoried roadless areas will likely yield those same qualities deserving protection and preservation as found in RARE II and other currently inventoried roadless areas on National Forest lands. Uninventoried roadless areas should be protected by requiring project-level planning to analyze whether proposed activities are located in such a roadless area. If so, then planning must stop in those areas until a national policy is adopted.

Vast areas of National Forest lands nationwide are already utilized for one "extractive" purpose or another, resulting in a fragmented landscape plagued by degraded water quality, failing riparian environments, extinct, threatened and endangered wildlife, and biologically simplified forest ecosystems.

Existing Forest Service roadless areas (inventoried and uninventoried) constitute most of the last remaining locations of wild, biologically rich landscapes outside of National Parks and other similarly protected federal lands. They often contain badly needed high quality aquatic and riparian areas, as well as wild landscapes vital to threatened and endangered wildlife. Further, unroaded areas that generally have been minimally impacted by management activities constitute prime areas for "recruitment" of future wild, biologically rich ecosystems. Consequently, the Forest Service should set aside all such areas as part of its national policy on roadless areas, and permanently prohibit all logging (commercial and non-commercial), mining, grazing, road building, OHV use and other environmentally damaging management activities.