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The Road RIPoRTeR
spring equinox 2012. Volume 17 no. 1
TakIng sTock of Travel PlannIng
By 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, by
Bethanie Walder. Pages 8-9
Biblio Notes: The Value of Wildlife Crossing Structures, by
Liz Fairbank. Pages 10-14
Wildlands CPR 2011 Annual Report. Pages 15-18
Policy Primer: Forest Planning, by Sarah Peters and Adam
Rissien. 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 Offce. Page 29
Membership Info. Page 30
Wildlands CPR photos.
2012 Wildlands CPR
Wildlands CPR revives and protects wild places by
promoting watershed restoration that improves
sh and wildlife habitat, provides clean water, and
enhances community economies. We focus on
reclaiming ecologically damaging, unneeded roads
and stopping off-road vehicle abuse on public lands.
P.O. Box 7516
Missoula, MT 59807
(406) 543-9551
Bethanie Walder
Development Director
Thomas R. Petersen
Science Program Director
Adam Switalski
Legal Liaison/Staff Attorney
Sarah Peters
Policy Specialist
Adam Rissien
Field Coordinator
Marlies Wierenga
Program Associate
Grace Brogan
Journal Editor
Dan Funsch
Board of Directors
Susan Jane Brown, Dave Heller,
Marion Hourdequin, Crystal Mario, Kathi Nickel,
Brett Paben, Jack Tuholske
By Bethanie Walder
funny thing happened as we were preparing this issue of the Road-RIPorter, and we now nd
ourselves in the midst of a controversy involving federal ofcials and the off-road vehicle com-
munity. It began to erupt when the Senate Energy and Natural Resource Committee recently
held an oversight hearing on the Forest Services budget request for Fiscal Year 2013. About an hour
into that hearing, Senator Barasso (R-WY) questioned Forest Service Chief Tom Tidwell about the
2011 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 Service
and Federal Highways Administration.
Senator Barasso was concerned about the Best Management Practices (BMPs) included in the reports
appendices, because those BMPs were written by Wildlands CPR. He said that it undermined the
credibility of the Forest Service to publish them. Chief Tidwell defended the BMPs, but shortly there-
after, seven off-road vehicle organizations sent a letter to USDA Secretary Tom Vilsack opposing the
publication of the report for a variety of reasons including the BMPs, and the use of inammatory
and derogatory language.
Thats when things got really interesting, because we found out that the Comprehensive Framework
was no longer available online. Its unclear when the report was actually pulled, and if that happened
before or after the Senate Oversight Hearing and/or the submission of the opposition letter to Sec-
retary Vilsack. What is clear, however, is that a group of off-road vehicle organizations discovered
that our Best Management Practices had been adapted for use in this report and they werent very
Their letter to the Secretary (ccd to the heads of the Forest Service, Park Service and FHWA) referred
to Wildlands CPR as a radical and extreme group, and claimed that the BMPs were not scienti-
cally-based and therefore unjustied for inclusion in the Comprehensive Framework.
Indeed, the Comprehensive Framework excerpted sections of our full report Best Management Prac-
tices for Off Road Vehicle Use on Forestlands, co-authored with Wild Utah Project. We developed
these BMPs with a rigorous review of the research and best available science on off-road vehicle im-
pacts, and included that information in the full version of the BMPs. In addition, our ORV BMPs were
recently published in the peer-reviewed Journal of Conservation Planning.
We have since sent our own letter to the same parties addressed by the off-road vehicle organiza-
tions. Our letter defends the BMPs and specically requests that the full Comprehensive Framework
be posted back online and made available to the public again as soon as possible. It turns out that
the Comprehensive Framework was printed in late 2011. As far as we know, the report is still avail-
able in print form, but not in electronic format. This entire controversy is humorous, in a way, since
the Comprehensive Framework is actually a guide to constructing off-road vehicle trails in a sustain-
able 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 consent
to 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.
continued on next page
By Josh Hicks, The Wilderness Society
In late 1999 Wildlands CPR and The Wilderness Society,
joined by more than 100 other conservation and recreation
organizations, submitted a rule-making petition to the Forest
Service asking them to overhaul their regulations for dirt
bikes, ATVs and other off-road vehicles (ORVs). That peti-
tion was an important catalyst for the Forest Services 2005
national Travel Management Rule (the Rule), requiring all
national forests to limit ORVs to designated routes. When
the Rule was published, it marked the beginning of the end
of cross-country travel, the free-for-all, anything goes man-
agement paradigm where ORVs drive wherever they want.
The promulgation of the Rule kick-started hundreds of local
travel management planning processes on forests and dis-
tricts across the country processes that would determine
which routes would be open for motorized travel and which
would be closed.
Since the 2005 rule was published, hundreds of travel planning processes have come and gone, with some
still 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, thereby
bringing new protection to tens of millions of acres. At this point in time, the Forest Service has declined to add
thousands of miles of unauthorized, user-created routes to the system, far outweighing the smaller number of
such 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 difcult truths. One of
these 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 small
task. Furthermore, the Forest Service still has about 373,000 miles of system roads enough to travel from the
earth to the moon and halfway back. Theyve told us to expect that the overall system may actually grow as the
remaining nal decisions come out.
Outcomes Vary Widely
Lets 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 forests
to conduct travel analysis as the rst step in travel planning. And while the travel analysis step has delayed the
travel planning timeline in the southwest, it has led to better decisions and considerably smaller road systems
than in other regions. For example, the Mountainair Ranger District on the Cibola NF in New Mexico proposed
to reduce its road system from 471 miles to 178 miles, a 62% reduction, in the revised draft plan. Their Envi-
One of the benets of travel planning is the restriction of cross-country travel from
nearly all national forest lands. Photo by Dan Funsch.
continued on next page
ronmental Assessment used a route density calculation (as opposed to
road density) that takes into consideration all trails as well as roads. This
route density assessment offers a more accurate account of the impacts
that the transportation system is having on forest resources. Under the
proposed 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 much
less ecologically impacting to wildlife. Numerous peer-reviewed studies
nd that road densities above 1 mi/mi
are problematic for many differ-
ent species of wildlife.
At the other end of the spectrum is California. For years we unsuccessfully
urged the Regional Forester and Forest Supervisors across the state to use
the travel planning process to streamline the road system. Countless let-
ters, meetings, and phone calls from conservation and recreation groups
across the state as well as letters from members of Congress did not sway
the Forest Service to change their approach. The regional ofce refused
to conduct travel analysis as part of travel planning, opting instead to use
the travel planning process primarily to add routes to the motorized trans-
portation system. As such, forests across California have increased their
transportation system by more than 800 miles. The travel plan decision
for the Stanislaus NF, located on the western slope of the Sierra Nevada
mountain range, was one of the worst in the state. The Wilderness So-
ciety (TWS) and Central Sierra Environmental Resource Center (CSERC)
worked together to submit extensive evidence of environmentally prob-
lematic 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 closed to
the public and, in so doing, approved a massive network
of roads and trails for ORV use. Even with a $96 million
backlog in road maintenance, the Stanislaus increased
the mileage of open system routes by an additional 158
miles, bringing the total to 2,437 miles. Of particular con-
cern is the fact that the travel management plan adds sig-
nicant mileage of user-created ORV routes into inappro-
priate places like pristine roadless areas, wild and scenic
river corridors, and rare and sensitive species habitat,
such as for the California spotted owl, northern goshawk,
Pacic sher and western pond turtle. CSERC and TWS
have led a lawsuit and we are currently awaiting for the
court to issue its decision.
While this isnt an isolated example, it also isnt the norm.
Travel planning in most other regions falls somewhere be-
tween the Southwest and California examples with the
result largely focused on maintaining the massive motor-
ized system footprint without making substantive changes
to either add or reduce miles.
The Forest Service still has plenty of work to do to
identify roads that are ripe for reclamation.
Wildlands CPR photo.
Setting aside dedicated off-road use areas can help to avoid user conicts and
damage to sensitive areas. Photo by Sarah Peters.
continued on next page
Where do we go from here?
Most of the remaining travel planning processes will nish by the end of 2012; however, our work
wont be done even after all of the formal requirements of the Rule have been met and all units have
published their Motor Vehicle Use Maps (MVUMs). There are still numerous avenues through which
activist engagement will be important.
First, travel planning will always be happening somewhere. A handful of slow moving units, like the
Malheur NF in Oregon, will likely still be trying to comply with the Rule into 2013. In addition, the
agency 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 (like
the Sawtooth National Forests in Idaho) based on challenges from either side. Finally, ORV clubs will
continue to press the agency to provide more riding opportunities or to seek access to routes that were
not designated in the rst round of travel planning. Conservation Northwest, for example, recently won
protections for the Colville NF in Washington by deecting a proposal by the Forest Service to add
user-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 reects any changes to the system
that occurred since the map was last published. It will be important for activists to watchdog annual
MVUM revisions to ensure that routes are not added to the system without rst undergoing analysis in
accordance with the National Environmental Policy Act. Conservationists are litigating this very issue
on the Pike-San Isabel NF in Colorado.
A third opportunity for engagement is assisting the Forest Service with implementing the route and
area decisions made during travel planning. Implementation activities include trailhead maintenance,
installing signs and gates, reclaiming routes not designated for public motorized use, and constructing
motorized trails. There is more work to do than the Forest Service has funding to accomplish. It will be
important to engage with the Forest Service both to help prioritize work that is most important to your
organization 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.
The Forest Service does not have the resources to manage,
or even adequately monitor, the massive motorized systems
it designated through travel planning. Citizen monitoring
that identies where problems are occurring (e.g., erosion,
newly blazed user-created routes, user-conicts) and how
the problems are evolving over time will be important. This
data can be used to convince the agency to revisit designa-
tions made during travel planning. If the agency ignores
you, it may be possible to use the data youve collected to
le a petition for emergency closure.
Forests across the country will soon embark on a new
type of transportation system analysis (unless your forest is
one of the few exceptions where travel analysis is mostly
complete) to assess their entire road system, whereas the
process that is just now concluding focused on motorized
recreation designations (for more details about the interre-
lationship of this process, see The ABCs of Travel Planning;
RIPorter 12.4). The new process entails an inter-disciplinary
analysis wherein forests evaluate the environmental risk
and social value of each road in the system. Based on this
analysis, forests will make recommendations about which
roads to keep and which to reclaim or store for future use.
The process is supposed to conclude by September 30,
2015. One important way for activists to engage in this
road assessment is to offer site-specic information to the
agency that demonstrates a routes high environmental
risks and/or low social value. This information could result
in the agency recommending the route be reclaimed.
In most cases, forests did not address winter use as a part
of travel planning. When the Forest Service does take on
winter planning, it will offer an opportunity to protect the
natural quiet from snowmobiles.
Since the Rule was published, the conservation, recreation
and even hunting/angling communities have collectively
engaged in a tremendous number of travel planning pro-
cesses across the country. Weve had both successes and
setbacks throughout, and weve been fairly effective argu-
ing against the addition of a high number of user-created
routes to the formal system. Some forests have also reduced
the total number of system roads open to motorized use.
Activists will continue to have opportunities both to improve
quiet recreation by advocating for better management of
ORVs, and to right-size the road system to improve water
quality and reconnect habitat well into the future. It will be
crucial for the conservation community to be present and
engaged in these efforts.
Josh Hicks is a Planning Specialist for The Wilderness
Societys National Forest Action Center in Denver, Colo-
Once reclaimed, forest roads can provide secure habitat for wildlife. A remote,
motion-activated camera caught these elk using a reclaimed road on the
Clearwater National Forest, ID. Wildlands CPR photo.
See the case study of Mt Hoods travel plan
on the following page
Activists will need to stay engaged to ensure positive travel
planning outcomes. Photo by Dan Funsch.
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 sh 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 eldwork, generated letters to the editor, guest
columns and news articles, and hosted town meetings. The TWS National Forest Action Center
and Wildlands CPR provided campaign, policy, GIS, nancial, 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 dened zones. The result: cleaner water and healthier habitat,
and a better balance between motorized and non-motorized
Photo courtesy of Bark.
Photo courtesy of Bark.
By Bethanie Walder
continued on next page
ince 2007, Wildlands CPR has been advocating for increased funding for
watershed restoration on Forest Service lands through the Legacy Roads
and Trails Remediation Program and associated efforts. Now a new funding
approach offers a potential opportunity to increase funding for this work, but it
is not without its risks. Over the past few years, the Forest Service has been irt-
ing with a new Integrated Resource Restoration (IRR) idea: instead of funding
individual line items, the Forest Service will merge several different funds into one
large restoration funding bucket. IRR was rst proposed in the Presidents budget
a few years ago, but Congress wasnt so keen on it and so it wasnt adopted.
Last 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 the
Now heres the risky part. Usually, when a pilot is tested, it is also evaluated
to understand what worked and what didnt, however, the February release of
the Presidents budget for 2013 proposed skipping this evaluation and adopt-
ing IRR wholesale across all Forest Service lands. This would mean no evalu-
ation of the challenges and opportunities presented by implementing the pilot,
and no opportunity for adapting the proposal to address the lessons learned.

While increasing Forest Service restoration funding is a goal we share with the
agency, it has to be done right. What if IRR doesnt work? And whats the point of
a pilot if you dont take time to assess it before adopting it wholesale?
The agency is promoting IRR because they think it will work better than the current
system. The rationale: pooled funding will be more efcient and the agency can
accomplish more with the same amount of money. We can support this in theory,
but we want to see if its true on the ground. Unfortunately, in the FY12 pilot
regions, the agency isnt just trying to accomplish more with the same amount of
money, theyre actually trying to accomplish more with less funding because
their overall funding went down. This makes the pilot a little challenging to test.
Perhaps most signicantly to Wildlands CPR, we have serious concerns about the
intersection of Legacy Roads and Trails funding and IRR. In the FY12 pilot regions,
all Legacy Roads and Trails money was pooled into the IRR, becoming part of
that big bucket of money along with sh and wildlife funds, vegetation and wa-
tersheds funds, timber funds and fuels/re hazard reduction funds. Our concern
is that once an individual fund is pooled into the IRR, that individual fund ceases
to exist, and what used to be dedicated funding can be used for any activity
within the IRR. The pooled Legacy Roads and Trails funds can be used for timber
harvests, but so too can pooled timber funds be used
for road decommissioning. In the pilot regions, there-
fore, Legacy Roads and Trails money has effectively
disappeared this year. But the road problems that led
to its creation have not.
We are very concerned that under IRR, roads might
fail to garner the attention they so desperately need
from within the agency, as staff work to achieve the
many competing mandates set out for them. For ex-
ample, Forest Service staff have regularly told us that
Legacy Roads and Trails funding works because the
money is dedicated exclusively to xing road prob-
lems problems that were often overlooked until this
new program was created. Some staff are worried
that roads might fall back to the bottom of the list
once the funding is pooled.
Wildlife use of reclaimed roads has been documented.
Wildlands CPR photo.
DePaving the Way, contd
The agency is trying to address this and other stake-
holder concerns by setting targets for accomplish-
ments in the pilot regions. Theyve adopted ve spe-
cic performance measures related to the IRR pilot:
Number of watersheds moved to an im-
proved condition class
Acres treated annually to sustain or restore
watershed function and resilience
Volume of timber sold
Miles of road decommissioned
Miles of stream habitat restored or en-
We are generally positive about these performance
measures. They illustrate that the Forest Service is start-
ing to reframe the concept of restoration and that they
are looking at restoration from a broader perspec-
tive than just silvicultural management. Were most
pleased, of course, that road decommissioning is one
of their performance measures, and like to think that
our persistent engagement is one of the reasons they
included this target. In addition, a signicant portion
of the stream habitat restored measure could come
from xing culverts and restoring aquatic passage
another signicant road issue. As a matter of fact,
the performance measures could actually be an im-
provement over the independent Legacy Roads and
Trails line item, because that line item never included
specic targets for road decommissioning (though for
the years we have assessed, it seems that about a
third of the funds were used for decommissioning).

But shortcomings remain. Most problematic: timber
volume sold is one of the target performance mea-
sures. Though we recognize a legitimate need to ad-
dress re/fuels and unnaturally dense forests in some
places through ecologically sensitive logging, we do
not think that timber volume sold is an appropriate
performance measure for a restoration initiative. The
timber targets could create a perverse incentive to
promote timber sales that are not restorative. We
are also concerned that acres treated for watershed
function could become a euphemism for additional
timber harvest that may not be ecologically justiable
from a restoration perspective. The acres treated
measure needs to be rened and improved to ad-
dress a broad range of restoration needs and con-
This brings us back to the concept of evaluation the Forest Service needs to
assess the pilot ideally for a full three years. This can help us understand how
concerned we should be about our favorite program, Legacy Roads and Trails,
which would be swallowed up if the IRR is adopted across the board. This will
help other stakeholders understand if their concerns are being met, and it will
provide the agency an opportunity to improve the pilot based on the results of
the assessments.
Our goal is not just to sustain Legacy Roads and Trails, but to ensure that the work
for which it was created is prioritized and accomplished. The Forest Service esti-
mates a multi-billion dollar road maintenance problem that is damaging sheries
habitat and municipal drinking supplies. In the state of Washington, for example,
it will cost a minimum of $300 million to bring Forest Service roads up to mini-
mum Clean Water Act standards. While road work makes sense as a part of an
integrated restoration approach, the problem is so enormous that it has justiably
received its own dedicated funding for the past ve years, and that funding has
only been a drop in the bucket. The Legacy Roads and Trails program goals have
not yet been met, and its unclear whether or not IRR will be the right mechanism
for meeting these goals over the long-term.
We appreciate this attempt to improve restoration outcomes and to create orga-
nizational efciencies by creating a pooled fund, and were looking forward to
working with the pilot regions to identify additional performance measures and
to fully evaluate the effectiveness of the program. However, in the meantime, we
hope the Forest Service takes a step back, consistent with this pilot approach,
to ensure that IRR is well-vetted and amended as needed as a result of lessons
learned. Well be very curious to learn whether IRR increases, or decreases, the
agencys capacity to address road issues, and well press to ensure this informa-
tion, specically tied to Legacy Roads and Trails performance, is included in the
public and private reports developed on IRR.
Reseeding with native vegetation on a Colorado road restoration
project. Photo by Vicky Burton, US Forest Service.
Bibliography Notes summarizes and highlights some of the scientic literature
in our 20,000 citation bibliography on the physical and ecological effects of
roads and off-road vehicles. We offer bibliographic searches to help activists
access important biological research relevant to roads.
By Liz Fairbank
continued on next page
s the number of roads and their trafc volumes continue to increase, mitiga-
tion measures are becoming increasingly important to minimize the risks
to both humans and wildlife populations. One type of mitigation measure
is the use of wildlife crossing structures that allow wildlife to cross either over or
under roadways without coming into contact with trafc. The goals of building
these crossing structures are to reduce the risks associated with wildlife-vehicle
interactions, and to provide connectivity between habitat patches (Cramer and
Bissonette 2005; Bond et al. 2008). There are many factors that inuence the ef-
fectiveness of crossing structures, including their placement, frequency, and struc-
tural attributes. In this article, I review the current state of scientic knowledge on
the effectiveness of crossing structures.
Types of Structures
There are several types of crossing structures that are used in highway mitigation,
each with different levels of effectiveness and cost. Most fundamentally, these
structures are either designed to allow animals to travel below the highway (un-
derpasses) or over the highway (overpasses). The use of fencing in combination
with crossing structures can help to guide and funnel wildlife towards crossing
structures, increasing their use and keeping animals out of the roadway (Gagnon
et al. 2005; Glista et al. 2009). Several studies have reported that crossing struc-
tures and fencing/barrier walls together have reduced road mortality by >80%
(Dodd et al. 2004; Dodd et al. 2007; Huijser et al. 2011).
Wildlife underpasses are the most common and least costly mitigation option.
They are typically not fauna-specic structures, and have the potential to be used
by a wide variety of species (Mata et al. 2008). These structures can range
greatly in size, anywhere from small pipe culverts (0.3-2m in diameter), to large
underpasses crossing under road bridges (Glista et al. 2009). They are typi-
cally constructed of concrete, smooth steel, or corrugated metal (Glista et al.
2009). Large underpasses provide crossing opportunities for the greatest number
of species, although small animals often show preference for small underpasses,
presumably for security from predation (McDonald and St. Clair 2004; Glista et
al. 2009).
The dimensions of an underpass or culvert play an
integral role in their use by certain species. Under-
passes with high relative openness (short length,
tall, and wide) are preferred by ungulates, as well
as large carnivores, particularly grizzly bears and
wolves (Clevenger and Waltho 2000 and 2005; Ng
et al., 2004; Grilo et al. 2008; Glista et al. 2009).
Other carnivores, such as black bears, coyotes, bob-
cats, and cougars have been found to also use, and
possibly prefer, smaller and more constricted under-
passes and culverts (Ng et al. 2004; Clevenger and
Waltho 2005).
Crossing structures can be sized to accommo-
date many different species groups, including
amphibians. Photo Marcel Huijser.
The vegetation approaching and around underpass
entryway can affect crossing structure attractiveness
and usage differentially by species type. For exam-
ple, natural vegetation at underpass openings is ben-
ecial for use by small to mid-sized mammals, but
can deter ungulates if it restricts their vision (Glista et
al. 2009). Visibility to the opening at the other side
of the underpass is an important factor in underpass
use, particularly by ungulates (Cramer and Bissonette
2005; Rosell et al. 1997 [as cited in Glista et al.
As existing culverts and underpasses were often
originally constructed for drainage purposes and
may sometimes have standing water in them, modify-
ing them with shelves or raised walkways has been
found to be an effective way to ensure their use even
when inundated with water (Foresman 2003; Bru-
din III 2003; Cramer et al. 2005; Bond and Jones
Overpasses provide wildlife with a wide bridge-like
structure, connecting habitat on either side of a trans-
portation corridor. Overpasses can range greatly in
width from only a few meters to over 200m on each
end (they are sometimes hourglass shaped), and are
typically planted with natural vegetation including
grass, shrubs, and trees to appear as a continuation
of surrounding habitat (Glista et al. 2009, Corlatti et
al. 2009). Wider overpasses are more effective than
narrower structures, particularly for large mammals,
and some studies suggest that structures should be
>60m in width (Evink 2002 [as cited in Corlatti et
al. 2009]).
Wildlife overpasses can accommodate a wider va-
riety of species than underpasses and are generally
the preferred crossing structure of deer, elk, and oth-
er ungulates (Glista et al. 2009). Other advantages
of overpasses are that they are less conned, quieter,
and maintain ambient environmental conditions such
as moisture, temperature, and light (Jackson and
Grifn 2000 [as quoted in Glista et al. 2009]). The
drawback of overpasses is that they are typically the
most expensive mitigation option because of their
large size and high construction costs (Glista et al.
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 other
ungulates. A wildlife/nonmotorized transportation dual-use overpass. Photo
Marcel Huijser.
Without crossing structures in place, wildlife face direct mortality risks on a
daily basis. Photo Marcel Huijser.
continued on next page
Biblio Notes, contd
Factors That Inuence Crossing Structure Effectiveness
Suitable habitat on both sides of the road is a necessary condition
for all wildlife to cross, and areas with the highest quality habitat
will often have the highest rates of crossing (Barnum 2003). Ng
et al. (2004:504) agree, stating that regardless of other factors
a crossing structure will be of little value as a wildlife corridor if
it does not connect suitable habitat. This may be the most impor-
tant factor for species with narrow habitat preferences, whereas
species with broad habitat preferences (such as deer, elk and
coyotes) may be more affected by other factors (Barnum 2003).
Distance to cover is another feature that will differentially affect
crossing structure use by various species based on their habitat
preferences. Deer and elk tend to prefer crossings in open areas
away from forest cover, especially during the winter (Clevenger
and Waltho 2005; Barnum et al. 2007). Moose have been found
to prefer crossing in mixed cover types, where there is both for-
age and moderate cover (Barnum et al. 2007). Several studies
found that, with the exclusion of red fox, the carnivores studied
(including cougars, grizzly bears, black bears, coyotes, bobcats,
gray fox, badger, genet, sher, short and long tailed weasels, mongoose, stone
marten and American marten) crossed most often in areas within or near more
dense forest cover (Clevenger and Waltho 2005; Barnum et al. 2007; Grilo et
al. 2008).
Drainage systems are known to be used as travel routes for wildlife and often
contain a higher diversity of species, as they are also home to riparian species
not present in surrounding upland areas (Clevenger and Waltho 2000; Puky et
al. 2007). Carnivores in particular have a higher tendency to use crossing struc-
tures near drainage systems (although distance to forest cover remains a more
signicant factor) (Clevenger and Waltho 2000; Clevenger and Waltho 2005;
Grilo et al. 2008). Conversely, in narrow valleys, ungulates were found to avoid
underpasses near drainages, probably due to an increase in perceived predation
risk rather than landscape attributes (Clevenger and Waltho 2000).
The proximity of crossing structures to human population centers and human ac-
tivities/use is shown to negatively affect their use by most wildlife, particularly
large carnivores and other large mammals (Clevenger and Waltho 2000; Ng et
al. 2004; Grilo et al. 2008). Thus restricting human use of crossing structures,
especially at night, is essential in ensuring effective use by wildlife (Clevenger and
Waltho 2000; Cramer and Bissonette 2005; Grilo et al. 2008).
Another important factor to take into consideration in the placement of crossing
structures is the spatial and home range dynamics of the target species. This is
especially essential for small mammals and less mobile species including reptiles
and 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 frequen-
cy that is appropriate for the distance that species
generally travel. As it may be nancially impossible
to place structures with the frequency needed to pro-
vide full habitat permeability, and because wildlife-
vehicle collisions tend to be clustered or restricted to
crossing hotspots, appropriately spaced mitigation
measures should be prioritized within these areas
to yield the greatest increase in connectivity and de-
crease in wildlife-vehicle interactions (Bissonette and
Adair 2008).
With an increasing understanding of the importance
of restoring wildlife connectivity, mitigating highway
fragmentation has come to the forefront of road ecol-
ogy. Wildlife crossing structures have been shown
to be effective at increasing permeability and reduc-
ing wildlife-vehicle collisions, but a number of factors
can inuence their success. By ensuring that highway
planners choose the right type of structure and place
them in the most appropriate places, we can build a
sustainable highway system where both wildlife and
humans can thrive.
Liz Fairbank is a University of Montana Environ-
mental Studies graduate student.
Fences or other structures used to funnel wildlife towards crossings can increase
the effectiveness of crossing structures. Photo Marcel Huijser.
Biblio Notes, contd
continued on next page
Barnum, S.A. 2003. Identifying the best locations to provide safe
highway crossing opportunities for wildlife. In 2003 Proceed-
ings of the International Conference on Ecology and Trans-
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Barnum, S., K. Rinehart, and M. Elbroch. 2007. Habitat, highway
features, and animal-vehicle collision locations as indicators
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Leroy Irwin, Debra Nelson, and K.P. McDermott. Raleigh, NC:
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State University, 2007. 511-518.
Bissonette, J.A., and W. Adair. 2008. Restoring habitat perme-
ability to roaded landscapes with isometrically-scaled wildlife
crossings. Biological Conservation 141:482-488.
Bond, A.R., and D.N. Jones. 2008. Temporal trends in use of
fauna-friendly underpasses and overpasses. Wildlife Research
Brudin III, C.O. 2003. Wildlife use of existing culverts and bridges
in north central Pennsylvania. In 2003 Proceedings of the In-
ternational Conference on Ecology and Transportation, edited
by C. Leroy Irwin, Paul Garrett, and K.P. McDermott. Raleigh,
NC: Center for Transportation and the Environment, North
Carolina State University, 2003. 344-352.
Clevenger, A.P. and N. Waltho. 2000. Factors inuencing the
effectiveness of wildlife underpasses in Banff National Park,
Alberta, Canada. Conservation Biology, 14(1), 47-56.
Clevenger, A.P. and N. Waltho. 2005. Performance indices
to identify attributes of highway crossing structures facilitat-
ing movement of large mammals. Biological Conservation
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wildlife overpasses to provide connectivity and prevent genetic
isolation. Conservation Biology 23:548-556.
Cramer, P.C. and J.A. Bissonette. 2005. Wildlife crossings in North
America: The state of the science and practice. In Proceed-
ings of the 2005 International Conference on Ecology and
Transportation, edited by C. Leroy Irwin, Paul Garrett, and K.P.
McDermott. Raleigh, NC: Center for Transportation and the
Environment, North Carolina State University, 2006. 442-
Dodd, C.K., W.J. Barichivich, and L.L. Smith. 2004. Effectiveness
of a barrier wall and culverts in reducing wildlife mortality on
a heavily traveled highway in Florida. Biological Conservation
Dodd, N.L., J.W. Gagnon, S. Boe, and R.E. Schweinsburg. 2007.
Role of fencing in promoting underpass use and highway
permeability. In Proceedings of the 2007 International Confer-
ence on Ecology and Transportation, edited by C. Leroy Irwin,
Debra Nelson, and K.P. McDermott. Raleigh, NC: Center
for Transportation and the Environment, North Carolina State
University, 2007.
Foresman, K. R., 2003. Small mammal use of modied culverts
on the Lolo south project of western Montana an update. In
2003 Proceedings of the International Conference on Ecology
and Transportation, edited by C. Leroy Irwin, Paul Garrett,
and K.P. McDermott. Raleigh, NC: Center for Transportation
and the Environment, North Carolina State University, 2003.
Gagnon, J. 2005. Use of video surveillance to assess wildlife
behavior and use of wildlife underpasses in Arizona. In
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and Transportation, edited by C. Leroy Irwin, Paul Garrett,
and K.P. McDermott. Raleigh, NC: Center for Transportation
and the Environment, North Carolina State University, 2006.
Glista, D.J., T.L. DeVault, and J.A. DeWoody. 2009. A review of
mitigation measures for reducing wildlife mortality on road-
ways. Landscape and Urban Planning 91:1-7.
Grilo, C., J.A. Bissonette, and M. Santos-Reis. 2008. Response
of carnivores to existing highway culverts and underpasses:
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Conservation 17:16851699.
Huijser, M. P., P. McGowen, J. Fuller, A. Hardy, A. Kociolek, A.P.
Clevenger, D. Smith, and R. Ament. 2008. Wildlife-vehicle
Collision Reduction Study. Report to Congress. U.S. Depart-
ment of Transportation, Federal Highway Administration,
Washington D.C., USA. 232 pp.
Properly designed crossing structures make travel safe for wildlife and humans
alike. Photo Marcel Huijser.
References, contd
Huijser, M. P., T.D.H. Allen, and W. Camel. 2010. US 93 Post-
Construction Wildlife-Vehicle Collision And Wildlife Crossing
Monitoring and Research on the Flathead Indian Reserva-
tion between Evaro and Polson, Montana: Annual Report
2010. Western Transportation Institute College of Engineering
Montana State University, Bozeman, Montana, USA. 33pp.
Kaye, D. R. J., K.M. Walsh, and C. C. Ross. 2005. Spotted turtle
use of a culvert under relocated Route 44 in Carver, Massa-
chusetts. In Proceedings of the 2005 International Conference
on Ecology and Transportation, edited by C. Leroy Irwin, Paul
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sity, 2006. 426-432.
Mata, C., I. Hervas, J. Herranz, F. Suarez, and J.E. Malo. 2008.
Are motorway wildlife passages worth building? Vertebrate
use of road-crossing structures on a Spanish motorway. Journal
of Environmental Management 88:407-415.
McDonald, W. and C. St. Clair. 2004. Elements that promote
highway crossing structure use by small mammals in Banff
National Park. Journal of Applied Ecology 41:82-93.
National Cooperative Highway Research Program: Bissonette, J.A.,
and P.C. Cramer. 2008. Wildlife and Roads: A Resource
for Mitigating the Effects of Roads on Wildlife Using Wildlife
Crossings such as Overpasses, Underpasses, and Cross-
walks. ht t p://www.wi l dl i f si on-
gui de/ m
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2004. Use of highway undercrossings by wildlife in southern
California. Biological Conservation 115:499-507.
Puky, M., J. Farkas, and M.T. Ronkay. 2007. Use of existing mitiga-
tion measures by amphibians, reptiles, and small to medium-
size mammals in Hungary: crossing structures can function
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Sawaya, M.A. and A.P. Clevenger. 2009. Using non-invasive ge-
netic sampling methods to assess the value of wildlife crossings
for black and grizzly bear populations in Banff National Park,
Alberta, Canada. In Proceedings of the 2009 International
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USDOT: Federal Highway Administration, Ofce of Highway Policy
Information. 2011. Our Nations Highways: 2011. http://
The threat posed by vehicle-wildlife interactions, and the consequences of
failing to address it. Photos Marcel Huijser.
continued on next page
hough it wasnt an ofcial 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 Program
As noted in our annual report last year, the Forest
Service adopted a plan in November 2010 to iden-
tify an ecologically and scally sustainable road
system by September 30, 2015. This rightsizing
initiative was an extraordinary policy victory for us
in 2010, and it along with a related process (the
agencys Watershed Condition Framework), and the
Legacy Roads and Trails Remediation Initiative
became the basis of our 2011 policy agenda. We
partnered with The Wilderness Society to develop
tools for activists to engage with the Forest Service on
rightsizing, and we worked with grassroots groups
throughout the country to coordinate meetings with
regional ofces and individual forests regarding their
rightsizing plans.
A restored Doe Creek, Clearwater National
Forest. Photo by Katherine Court.
Organizational development and stafng
We got image conscious in 2011, working with a fantastic local graph-
ic designer to update our logo and website, and incorporating the new
graphic themes into all of our written and electronic communications. We
also up-scaled our ofce, moving to a much more user-friendly and well-lit
space, just one block from our former digs.
From a nancial perspective, we further diversied 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 more
important element of our annual fundraising. In addition, we completely
revamped our annual gifts campaign, resulting in signicantly more unre-
stricted income. It couldnt have gone better we surpassed our $40,000
campaign goal and we had 40% more individual donors participate! Our
2012 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 Legacy
Roads and Trails Campaign. Through her work with Wildlands CPR she
also led the Washington Watershed Restoration Initiative (WWRI) a co-
alition of conservation organizations, state agencies and tribes working to
advance Legacy Roads and Trails and other rightsizing objectives in the
state. Sue brought inspiring ideas to Wildlands CPR, helping us achieve
extraordinary things. Upon her departure, we recongured her position
to focus more on the on-the-ground implementation of the Forest Service
initiative to identify an optimum road system that is both ecologically and
scally sustainable. In October, we hired Marlies Wierenga as our WA/
OR Field Coordinator to oversee this and to run the WWRI. Since Marlies
is based in Portland, OR, we now have two satellite ofces in OR (Sarah
Peters, our Legal Liaison/Staff Attorney, is in Eugene) and we no longer
have an ofce in WA, though Marlies will be working closely with our
WA partners.
Perhaps our biggest victory of the year was protect-
ing the Legacy Roads and Trails Remediation Pro-
gram from the Congressional budget cutting frenzy
in early 2011. In the end, Congress spared the pro-
gram, but they did cut funding in half, from $90 mil-
lion to $45 million. They proposed further cuts for
FY12, but fortunately it remained stable at $45 mil-
lion. Our work to educate decision-makers and build
support for Legacy Roads and Trails ranged from co-
ordinating support letters from diverse stakeholders
in western states, to holding an excellent media eld
tour in MT, to developing a host of investigative and
highly-informative fact sheets and reports about the
successes of the Legacy Roads and Trails program at
improving water quality and providing green jobs.
As part of the FY12 federal budget, a new policy
threat and/or opportunity emerged, as Congress
agreed to let the Forest Service pilot a new Inte-
grated Resource Restoration (IRR) budgetary ap-
proach in three FS regions. We worked on this is-
sue throughout the year and it will be a signicant
priority for 2012. We also regularly met with Forest
Service leadership in Washington DC to understand
and help promote their new Watershed Condition
Framework (WCF), culminating in a request to the
agency to host a webinar for grassroots activists to
learn more about the WCF. More than 50 partici-
pants attended the webinar.
We also became integrally involved in a time-sen-
sitive campaign to ensure that logging roads will
continue to be regulated under the Clean Water Act.
Wildlands CPR staff worked closely with the lead
plaintiffs and attorneys in the NEDC v. Brown case,
as well as numerous other Pacic Northwest and na-
tional conservation organizations, after the timber industry pushed to overturn this
decision by amending the Clean Water Act. When the federal budget passed in
December, the effort to amend the CWA was put on hold for one year, so we will
engage on this as needed in 2012.
We also entered into our second year of monitoring to assess the effectiveness of
Legacy Roads and Trails projects in MT and northern ID. We partnered with other
grassroots groups on ve different national forests to assess wildlife and vegeta-
tive response to road reclamation treatments. The highlight of the summer: captur-
ing our rst images of a grizzly bear using a reclaimed road. And this wasnt just
any griz, but a sow with cubs on the Gallatin National Forest in MT.
But the science/monitoring highlight of the year, however, was publication of two
new road reclamation studies in peer-reviewed journals. Our Science Program
Director Adam Switalski works with former board member and University of Mon-
tana Assistant Professor Cara Nelson and several others on a variety of road
reclamation-based research. U of MT graduate student Ashley Grant was the
primary author on the rst paper, which included Adam, Cara and Forest Service
researcher S. Rinehart as coauthors: Restoration of native plant communities after
road decommissioning: effect of seed mix composition and density on vegetation
establishment. Restoration Ecology 19:160-169. The second paper is based on
ve years of road reclamation monitoring on the Clearwater National Forest in
Idaho: Efcacy of road removal for restoring wildlife habitat: Black bear in the
Northern Rocky Mountains, USA. Biological Conservation 144 (2011): 2666-
2673. This research provided the methodology for our current Legacy Roads and
Trails monitoring program in MT.
continued on next page
Wildlands CPRs restoration eld trips brought together scientists, land
managers, and members of the media to experience rst-hand the
benets of road reclamation. Wildlands CPR photo.
Removed road bed in OBrien Creek, Lolo NF, Montana.
Photo by Adam Switalski.
Transportation Program
It was incredibly satisfying to see one of our long-term goals nally become re-
ality in 2011. Working in close partnership with The Wilderness Society and
grassroots organizations throughout the west, our tenacious focus on Forest Ser-
vice off-road vehicle travel planning paid off. With more and more district and
national forest travel planning decisions issued it became clear that unrestricted
cross-country travel on national forest lands will become a thing of the past in all
but a small number of dedicated play areas. Instead, off-road vehicles will be
allowed only on designated roads and motorized routes. This is a major change
from ve years ago, when the Forest Service really got started with this planning
process, and it shows how important it is to engage with the agency over the
long-term. The overall results of travel planning have been mixed, however, and
some national forests have taken a balanced approach by adding some user-
created unauthorized routes while specically closing others. We expect the For-
est Service to nalize nearly all decisions by the end of 2012, though a handful
of outliers will likely remain.
We know from experience that administrative deci-
sions must be followed up with legal oversight, and
our Legal Liaison Sarah Peters stayed very busy
helping grassroots activists develop appeals of prob-
lematic travel plans. She also provided technical as-
sistance to several organizations litigating against
others, including The Wilderness Society and Idaho
Conservation Leagues successful challenge of the
Salmon-Challis National Forest (ID) Travel Plan. The
court overturned that plan in an important decision
that, among other things, upheld the off-road vehicle
Executive Orders (issued by Presidents Nixon and
Carter). Unfortunately, we also lost an off-road vehi-
cle management case on the Custer National Forest
(MT) where we partnered with the Pryors Coalition.
Sarah worked with our lawyers at the Western Envi-
ronmental Law Center, and we have now appealed
that decision to the Ninth Circuit Court of Appeals.
In addition to working with lawyers and activists
across the nation, Sarahs been engaging in her
home state of Oregon, becoming more active in trav-
el planning and related processes on the Umpqua,
Fremont-Winema, Siuslaw and Rogue-River Siskiyou
National Forests. Shes been playing a key role in
project level work on the Fremont-Winema, for ex-
ample, including working with the Forest Service to
begin Phase II of travel planning, which will both
designate different routes for motorized use and de-
commission those no longer needed.
Back here in the northern Rockies, Adam Rissien
continued to watchdog travel planning on the Bea-
verhead-Deerlodge and Bitterroot National Forests
in MT. While the Beaverhead-Deerlodge is early in
the process, the Bitterroot is nearly nished. They
postponed their nal decision several times, though
we expect their process to be completed in 2012.
Adam and Sarah also partnered to develop a guide
for grassroots activists to engage with the Forest Ser-
vice as they update their travel planning maps. These
Motor Vehicle Use Maps, or MVUMs, are one of
the most important products stemming from travel
planning. Sarah and Adam distributed their guide
to several hundred grassroots groups throughout the
continued on next page
At left, trail ruts caused by off-road ve-
hicle use. Through the travel planning
process, off-road impacts are being
contained and mitigated. Photo by
Erin Switalski.
Below, an off-roader rides in a desig-
nated off-road play area.
Photo courtesy of Bureau of Land
There may be no better measure of Wildlands CPRs esteem than when federal land managers borrow
our work. In July 2011, the Forest Service, Park Service and Federal Highway Administration nalized
a new off-road vehicle guidance document: A Comprehensive Framework for Off-Highway Vehicle
Trail Management. This new national guide to improving off-highway vehicle management includes
an abbreviated version of the off-road vehicle Best Management Practices that Wildlands CPR devel-
oped with the Wild Utah Project (WUP) in 2008. Inclusion of these science-based BMPs is a great step
forward towards improving public land management of off-road vehicle recreation over the long-term.
Adam Switalski and his co-author from WUP, Allison Jones, also abbreviated the BMPs for publication
in a peer-reviewed journal. The Journal of Conservation Planning accepted and published the BMPs
in early 2012.
Primary Support
We couldnt accomplish all this without the support of our members, donors, and foundations. Wild-
lands CPR would like to thank the following foundations for their generous support in 2011: 444S,
Bullitt, Cinnabar, Firedoll, Harder, High Stakes, Jubitz, Lazar, Maki, Mountaineers, National Forest
Foundation, New-Land, Norcross, and Page Foundations, and the Yellowstone to Yukon Conservation
Initiative. Wed also like to thank the many individuals who contributed to our work independently,
and/or through a state or federal workplace giving campaign.
Total expenses: $419,785
Admin & Fundraising
Contributions &
Total income: $368,084
Wildlands CPRs expenses exceeded our income, but this is largely due to the fact that
our scal year (the calendar year) never exactly matches up with our grant income.
By Adam Rissien and Sarah Peters
continued on next page
The Forest Service manages 155 national forests and 20 national grass-
lands covering 193 million acres across the country. Each one adheres to
a specic Land Management Resource Plan, otherwise known as a forest
plan. These forest plans direct a wide variety of activities such as timber
production, livestock grazing, and recreational uses, all while ensuring
clean drinking water, sustainable sheries and viable wildlife populations.
A large percentage of these forest plans are also drastically overdue for
The National Forest Management Act of 1976 (NFMA) requires the For-
est Service to issue specic regulations directing what forest plans should
contain. On February 14th, 2011 the Forest Service issued new draft
planning regulations citing the need for rules that reect current science
and are more responsive to issues such as the challenges of climate
change; the need for forest restoration and conservation, watershed pro-
tection, and wildlife conservation; and the sustainable use of public lands
to support vibrant communities.

The new rules also seek to streamline

the 1982 regulations and allow more latitude for local interpretation. On
January 26, 2012, the Forest Service released the nal regulations, which
could go into effect at anytime. The 1982 NFMA regulations, under which
current forest plans were developed, contain specic requirements to en-
sure the laws mandates are met, but they have long been under attack
due, in part, to the success of organizations that use them to hold the
agency accountable with regards to its management actions. Unlike ob-
jectives and guidelines, Forest Plan standards are not discretionary and
courts have repeatedly ruled against the agency for failure to adequately
follow them.
Unfortunately, the new regulations continue the trend away from requiring
strong standards to maintain viable wildlife populations, protect riparian
areas or provide clear road management direction.
Still, the 2012 regulations are an improvement from past attempts to revise
the planning regulations, and include direction that all new and revised
plans must be supported by an environmental impact statement, as well
as a requirement for broad-scale monitoring that looks beyond the forest
level. The nal rule also directs agency ofcials to use the best available
science, which is a major improvement over the initial draft rule. The new
rule also includes recognition that ecosystem services are part of the agen-
1 National Forest System Land Management Planning Draft Programmatic Envi-
ronmental Impact Statement Ch. 1, p. 7.
Wildlands CPR le photo.
cys multiple use mandate, which is a signicant addition
that the 1982 rules did not include. However, even with
these and other improvements the nal regulations could
certainly have been stronger, and will likely face litigation
threats from all sides of the management debate.
Policy Primer, contd
continued on next page
Summary of Key Problems
One concern we have with these new regulations is the amount of discretion provided to
individual forests with regards to restoring and protecting water quality, wildlife habitat
and diversity, and other forest resources. Whereas the 1982 regulations provided clear
standards, the new ones greatly increase the agencys discretion, through requiring either
standards or guidelines, leaving more opportunity for lax environmental protections.
The following is by no means a comprehensive listing of our issues with the regulations, but
serves 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 option
between the two is problematic since guidelines are legally less enforceable
than standards, thereby potentially weakening any protections if they rely on
guidelines alone.
No requirements to protect watersheds and only an option to maintain or
restore 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
Requires standards or guidelines for sustainable recreation, which directs a
balance of ecological, economic and social factors, but lacks clear direction
as 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 mandates
for 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 allow
for 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 road
washout on the Helena NF.
Below, a llslope failure on the Nez Perce NF.
Photos by Adam Switalski.
Policy Primer, contd
continued on next page
Final Planning Rule (as of January 25, 2012)
Standards v. Guidelines
Required plan components include standards and guidelines. Standards are manda-
tory components that must be specically followed to help achieve or maintain the
desired condition. Guidelines allow for variation from their specic language, so long
as the intent of the guideline is met. ( 219.15(d)(3)). 219.15(d) addresses the
steps a forest must take to determine consistency.
Each approval document for a project or activity must describe how the project or
activity is consistent with applicable plan components. With regard to standards, the
project or activity must comply with applicable standards. 219.15(d)(2). For guide-
lines, 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 out
the intent of the applicable guidelines. 219.15(d)(3). It is difcult to conceive how the
intent of the guideline would be met without the action being designed to comply
with the guideline. This denition provides a large amount of discretion for forests and
could end up leading to a large amount of litigation.
Standards are much more powerful than guidelines, and using the conjunctive or
rather than and means that most forest plans will lean more heavily towards includ-
ing guidelines over standards, and thus potentially weaken the protections offered
in previous forest plans. The new rule directs that forest plans include standards or
guidelines to maintain or restore air, soil and water, but does not require they be
protected. Therefore forest plans may not contain specic standards to protect water
quality and could simply rely on guidelines to satisfy the regulations. Additionally it is
unclear how or when the agency will maintain or restore ecosystem components. We
discuss these aws further as they apply to riparian areas, soils and watersheds under
the sustainability section.
Riparian Areas
The nal rule requires plans to maintain or restore the ecological
integrity of riparian areas in the plan area, including plan compo-
nents to maintain or restore structure, function, composition, and con-
nectivity. This is actually weaker language than the draft rule, which
included direction to maintain, protect or restore the ecological
integrity of riparian areas The omission of protect is concern-
ing. Fortunately the new rule requires that Plan components must
ensure that no management practices causing detrimental changes
in water temperature or chemical composition, blockages of water
courses, or deposits of sediment that seriously and adversely affect
water conditions or sh habitat shall be permitted within the riparian
management zones or the site-specic delineated riparian areas.
219.8(a)(3)(ii)(B). This is a signicant improvement over the draft
rule and closely mirrors the 1982 regulation, and the Forest Service
deserves credit for making this change. Even with this improvement
Installing erosion control to protect a riparian area. Photo by Wendy
R. Magwire, US Forest Service.
Standards OR guidelines? Or standards AND
guidelines? There is a BIG difference. Photo
courtesy of Bureau of Land Management.
Policy Primer, contd
though, the new rule omits size requirements for riparian areas, leaving
that to the supervisors discretion with only vague direction that special
attention be given to areas within 100 feet of perennial streams and
lakes. 219.8(a)(3)(ii). Obviously this offers more exibility for supervi-
sors, and could even result in the protection of areas larger than the 100
feet minimum in the old rules, but there is no guarantee.
Another major ambiguity in this portion of the rule is around plan compo-
nents, as previously mentioned. A forest supervisor could potentially use
any combination of plan components to maintain or restore riparian areas
and do so in a manner that precludes any accountability. This exemplies
a larger trend found throughout the regulations; namely no clear mandates
for restoration or for specic standards, combined with the wide discretion
given to forest supervisors.
We see this again in the case of soils and soil productivity. The 1982
regulations mandate the conservation of soils, including their protection,
which is to be guided by technical handbooks that show specic ways to
avoid or mitigate damage and maintain or enhance soil productivity. 36
CFR 219.27(f) (1982). In order to meet this requirement, forest regions
developed soil productivity standards.
In contrast, the nal regulation states that plans only must contain components to maintain or restore
Soils 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 that
the rule has no denition for guidance and while it may include issuing technical handbooks, it is
doubtful that the agency will issue specic formal directives to maintain or enhance soil productivity.
While subtle, these changes further weaken the old regulations.
continued on next page
Roads & Watersheds
In regard to road management and watershed integrity,
the nal regulation contains absolutely no requirements
for managing the road system. The 1982 regulations also
lacked strong language regarding this issue, directing, that
all roads are planned and designed to re-establish vegeta-
tive cover on the disturbed area within a reasonable pe-
riod of time, not to exceed 10 years after the termination
of a contract, lease or permit, unless the road is determined
necessary as a permanent addition to the National Forest
Transportation System. 36 CFR 219.27(a)(11) (1982). This
comes directly from the NFMA and while it certainly could
be stronger, its exclusion from the nal regulation is surpris-
ing. Instead, the regulation directs that forest plans, must
include plan components, including standards or guidelines,
to maintain or restore the ecological integrity of terrestrial
and aquatic ecosystems and watersheds in the plan area,
including plan components to maintain or restore structure,
function, 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 CPR
(1). However, the overall language is weak, and though the nal rule
requires the forest supervisor to include either standards or guidelines,
wide discretion remains in how those will be implemented and whether
they will be binding on future forest actions. Additionally, by omitting
any mention of roads in the discussion of watershed integrity, there is
no reminder that specic requirements for their removal or mitigation of
their impacts should be included in forest plans.
The only direct mention of roads in the new planning regulations is as
one of the examples of ecological conditions. The denition by itself
makes sense that roads are an impact on ecological conditions. But,
the references to ecological conditions elsewhere in the regulation seem
to assume that they are more positive in nature, while this denition
seems to be just a summation of the existing condition. This could have
been improved by making a distinction between existing ecological con-
dition and desired ecological condition, but the Forest Service chose
not to travel that particular route, and this is one more reason why the
distinction between restore and maintain and when those should be ap-
plied is so important.
Policy Primer, contd
The regulations lack specic language to prevent recreation use from
damaging the environment. Photo by Wendy R. Magwire, US Forest
The ambiguous regulations are likely to provide no safeguards for quiet
recreation. Photo by Dan Funsch.
Sustainable Recreation
The nal planning rule includes the concept of sustainable
recreation, which it denes as the set of recreation settings
and opportunities on the National Forest System that is eco-
logically, economically, and socially sustainable for present
and future generations. 219.19. Furthermore, the proposed
rule explains 219.10(b)(1) the plan must include plan com-
ponents, including standards or guidelines, to provide for: (i)
Sustainable recreation; including recreation settings, opportu-
nities, access; and scenic character....
While this certainly is a laudable vision, the reality is that
oftentimes social, scal and ecological sustainability can only
be achieved at the expense of one another, and there is no
specic direction to prevent recreational impacts from harm-
ing the environment or from conicting with other uses.
However, recreational activities must still comply with regula-
tions and executive orders, and site-specic analysis must be
completed to ensure such compliance. This is an improvement
from the current planning regulations that are ambiguous on
this point, especially in relation to over-snow vehicle travel.
While there were many improvements between the draft and
nal regulations, the nal regulations remain long on vision,
short on specics, weak on denitive protection and they give
individual forest supervisors too much discretion in deciding
what plan components should be included.
continued on next page
By Thomas R. Petersen, Development Director
ou think youve got a stellar March Madness team going for you? Maybe, but Wildlands CPRs
Oregon Team Sarah Peters, our Staff Attorney/Legal Liaison based in Eugene, and Marlies
Wierenga, 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 always
high prole (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.
arah, 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 conservation
groups with ling 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 signicant legal decisions recently that attest to her ability to weave in
and 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-
Program Updates, contd
ho. While Wildlands CPR wasnt a plaintiff in the Salmon-Challis
case, Sarahs strategic support helped the plaintiffs in their success-
ful effort to secure a result in the courts ruling that the agency must
follow the plain language of the off-road vehicle Executive Orders
by minimizing the impacts of off-road vehicles on natural resources
and other users.
And just last month, Sarahs assistance paid off in another im-
portant decision on an Idaho forest. On the Sawtooth Minidoka
Ranger District travel plan the court ruled that the Forest Service
failed to provide enough analysis to justify its decision to move
forward with the Minidoka travel plan, which added 94 routes to
an already bloated system and left 630 miles of user created routes
The decision reaches the following conclusions with regards to
ORV management on National Forest lands:
Afrmed the nding in the Salmon-Challis NF decision
(above) that the Executive Orders are enforceable;
Found that the Forest Service failed to comply with
Forest Plan standards by failing to design and imple-
ment mitigation measures and failing to address water
quality impacts from user created routes; and
Found that the NEPA analysis was inadequate on a
number of levels and did not support the Finding of
No Signicant Impact in the decision; in particular,
the judge ruled that the agency cannot ignore user-
created routes simply because they were already there
or rely on the presumption that cross country travel im-
proves the situation to such an extent that site specic
analysis is not necessary.
arlies backcourt actions are equally impressive. When Wild-
lands CPRs Restoration Coordinator Sue Gunn retired, the
Washington Watershed Restoration Initiative (WWRI) a solid
team of 16 diverse conservation groups including Washington
States Department of Ecology, Trout Unlimited, and the Upper Co-
lumbia United Tribes was left without a leader. Marlies, who
joined Wildlands CPR last October, stepped in to re-invigorate the
WWRI, which had been such a successful component of Wildlands
CPRs Legacy Roads and Trails work.
For example, in January Marlies facilitated a meeting of the full
WWRI in Olympia, WA where they worked as a team to estab-
lish draft goals for 2012 including continued Legacy Roads and
Trails advocacy work, engaging in rightsizing, and building sup-
port through additional partners. Marlies has been improving the
WWRIs communication pieces, including a Legacy Roads and
Trails accomplishments table (that will be used as an insert to the
Forest Service Legacy Roads and Trails accomplishment report),
revisions to the WWRI website, and the development of a talking
points guide for WWRI members.
Marlies is also our point person with Region 6 of the Forest Service
(Oregon and Washington) where so much of the restoration work
of Legacy Roads and Trails is playing out on the ground. Marlies
meets with staff there regularly, and in early January participated
in a eld trip on the Siuslaw National Forest along with Sarah
and Forest Service engineers to view road projects completed
via Legacy Roads and Trails, plus a proposed road thats scheduled
for reclamation later this year.
Marlies is also pulling together other networks, and building rela-
tionships and discussing opportunities where increased collabora-
tion a strong point of Wildlands CPRs could provide more
tangible results. For example, shes met with Washington and Or-
egon state agencies including the Oregon Department of Environ-
mental Quality and the Oregon Watershed Enhancement Board,
and Washingtons Department of Ecology, as well as a number of
NGOs including Oregon Wild, Trout Unlimited and the Gifford
Pinchot Task Force.
So while both Sarah and Marlies worked their magic in the back-
court, the result has been a winning season for Wildlands CPR,
with, for example, the Forest Service using Legacy Roads and Trails
funds to reclaim 1,172 miles of roads in 2011 alone. (Back in the
day, we were lucky to have the Forest Service remove 100 miles
of roads per year.)
With that kind of record we think well be a shoo-in for the Big
Dance for years to come.
Little Blitzen waterfall, Steens mountain,
OR. Photo courtesy of Bureau of Land
continued on next page
By William Laurance
e live in an era of unprecedented road and highway
expansion an era in which many of the worlds last
tropical wildernesses, from the Amazon to Borneo to the
Congo Basin, have been penetrated by roads. This surge in road
building is being driven not only by national plans for infrastructure
expansion, but by industrial timber, oil, gas, and mineral projects
in the tropics.

Few areas are unaffected. Brazil is currently building 7,500 kilo-
meters of new paved highways that crisscross the Amazon basin.
Three major new highways are cutting across the towering Andes
mountains, providing a direct link for timber and agricultural ex-
ports from the Amazon to resource-hungry Pacic Rim nations, such
as China. And in the Congo basin, a recent satellite study found a
burgeoning network of more than 50,000 kilometers of new log-
ging roads. These are but a small sample of the vast number of new
tropical roads, which inevitably open up previously intact tropical
forests to a host of extractive and economic activities.

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

Despite their environmental costs, the economic incentives to drive
roads into tropical wilderness are strong. Governments view roads
as a cost-effective means to promote economic development and
access natural resources. Local communities in remote areas of-
ten demand new roads to improve access to markets and medi-
cal services. And geopolitically, new roads can be used to help
secure resource-rich frontier regions. India, for instance, is currently
constructing and upgrading roads to tighten its hold on Arunachal
Pradesh 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,

Of course, roads are not just an environmental worry in the tropics. In
forested areas of western North America, one of the best predictors of
wildre frequency is the density of roads. In Siberia, road expansion
is promoting a sharp increase in logging and forest res. And new
roads in the Arctic could potentially alter epic mammal migrations.

But no other region can match the tropics for the sheer scale and
pace of road expansion and the degree of environmental change
roads bring. Road building has a range of direct impacts on rainfor-
est ecology. In wet tropical environments, the cut-and-ll operations
associated with road construction can impede streams, increase
forest ooding, and drastically increase soil erosion. Roads also
discharge chemical and nutrient pollutants into local waterways
and provide avenues of invasion for many disturbance-loving ex-
otic species.

A satellite view of deforestation associated with roads in the
Brazilian Amazon. Photo courtesy of NASA.
Odes to Roads, contd
Roads that cut through rainforests can also create barriers for sensi-
tive wildlife, many of which are ecological specialists. Studies have
shown that even narrow (30 meter-wide), unpaved roads drastical-
ly reduce or halt local movements for scores of forest bird species.
Many of these species prefer deep, dark forest interiors; they have
large, light-sensitive eyes and avoid the vicinity of road verges,
where conditions are much brighter, hotter, and drier. A variety
of other tropical species including certain insects, amphibians,
reptiles, bats, and small and large mammals have been shown
to be similarly leery of roads and other clearings.

And by bringing nave rainforest wildlife into close proximity with
fast-moving vehicles, roads can also promote heavy animal mor-
tality. For some creatures, especially those with low reproductive
rates, roads could potentially become death zones that help propel
the species toward local extinction.

Although the direct effects of roads are serious, they pale in com-
parison to the indirect impacts. In tropical frontier regions, new
roads often open up a Pandoras box of unplanned environmental
maladies, including illegal land colonization, res, hunting, gold
mining, and forest clearing. The best thing you could do for the
Amazon, said the respected Brazilian scientist Eneas Salati, is to
bomb all the roads.

In Brazilian Amazonia, my colleagues and I have done studies
showing that around 95 percent of all deforestation occurs with-
in 50 kilometers of highways or roads. Human-lit res increase
dramatically near Amazonian roads, even within many protected
areas. In Suriname, most illegal gold mining occurs near roads,
whereas in tropical Africa we have found hunting to be so intense
near roads that it strongly affects the abundance and behavior of
forest elephants, buffalo, duikers, primates, and other exploited
species. Roads can sharply increase trade in bushmeat and wildlife
products; one study found that eight killed mammals were trans-
ported per hour along a single road in Sulawesi, Indonesia.
Paved highways are especially dangerous to forests. They provide
year-round access to forest resources and reduce transportation
costs, causing larger-scale impacts on forests and wildlife than do
unpaved roads, which tend to become impassable in the wet sea-
son. The proposed routes of new highways often attract swarms of
land speculators who rush in to buy up cheap forest land, which
they then sell to the highest bidder.

Perhaps the most damaging aspect of paved highways is that they
spawn networks of secondary roads, which spread further environ-
mental destruction. For instance, the 2,000-kilometer-long Belem-
Braslia highway, completed in the early 1970s, has today evolved
into a spider web of secondary roads and a 400-kilometer-wide
swath of forest destruction across the eastern Brazilian Amazon. As
my colleagues and I showed in a 2001 study published in Science,
large expanses of the Amazonian forest could be fragmented by
the advance of new highways and roads in Brazil. According to
our models, by the year 2020, rates of forest destruction would
rise by up to 500,000 hectares per year, and the area of forest
that remained in large, unfragmented tracts exceeding 100,000
square kilometers would decline by 36 percent.

Can the environmental impacts of tropical roads be minimized? In
theory, the answer is Yes, partially. Frequent culverts can reduce
the effects on streams and hydrology. Impacts on animal move-
ments can be reduced by keeping road clearings narrow enough
so that canopy cover is maintained overhead, providing a way for
arboreal species to cross. In high-priority areas, such as certain
national parks, rope-bridges are being used to facilitate road cross-
ings of monkeys and possums. For small ground-dwelling species,
culverts beneath roads can allow road-crossing movements, and
even large animals such as Asian elephants will use highway un-
derpasses that are designed to be wildlife-friendly.

Measures also exist to limit the devastating indirect impacts of
roads, such as illegal land colonization and forest clearing. One
of the most vital steps is to legally establish parks or reserves along
road routes in advance of road construction. Such reserves often
substantially reduce forest incursions, though they rarely halt them
continued on next page
New roads facilitate the clearing of land for agriculture. Photo
by Felipe Menegas.
Odes to Roads, contd
entirely. Another promising idea is to promote railroads rather than
highways in tropical wilderness regions. Because railroads stop
only at xed locations, the spatial patterns of forest exploitation
and movement of forest products can be more easily controlled and
monitored than with roads.
In practice, however, limiting the environmental impacts of roads in
developing nations is expensive and risky. Tropical nations rarely
have the institutional capacity, human capital, or nancial resourc-
es to adequately manage development in their remote frontier re-
gions, frequently leading to a resource grab revolving around
illegal trade and outright theft of natural resources, which is greatly
facilitated by road expansion.

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

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

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

How can this be achieved? First, we need to sensitize political de-
cision-makers, economists, infrastructure planners, and the general
public about the myriad environmental costs of road expansion,
especially into intact forests. The biggest road projects are often
being supported by international lenders such as the Asian, Afri-
can, and Inter-American development banks and by foreign aid
doled out by China, the U.S., and the European Union. Educating
such decision-makers needs to be done both generally and on a
project-by-project basis.

When I was president of the Association for Tropical Biology and
Conservation, one of my key goals was to use the organizations
scientic expertise and credibility to combat some of the most en-
vironmentally risky plans for frontier road expansion. We were
especially active in critiquing plans to punch new roads into the
cores of national parks, such as Yasun in Ecuador, Kerinci Seblat
in Indonesia, and the Serengeti in Tanzania.

Another key priority should be better frontier law enforcement and
forest monitoring, given that much road building in tropical nations
is illegal or unplanned. Special attention should be focused on the
more-aggressive timber, oil, gas, and mineral corporations, many
of which are known to engage in bribery and collusion in their ef-
forts to gain unbridled access to forest resources.
There is also a dire need to improve environmental impact assess-
ments (EIAs) for planned roads. In Brazil, for instance, EIAs for
several major Amazonian highways focused only on a narrow strip
along the road route itself, while completely ignoring the devastat-
ing indirect effects of roads. Similarly, EIAs for major development
projects, such as large mines and hydroelectric dams, often ignore
the impacts of road proliferation that such projects inevitably pro-

Finally, given that tropical deforestation is a massive source of green-
house gas emissions, international carbon-trading funds should be
used to better plan and mitigate road projects, to establish new
protected areas in advance of road construction, and to halt the
most ill-advised road projects altogether. In the end, the easiest and
most cost-effective way to limit the manifold pressures from roads
may be simply not to open Pandoras box in the rst place.

William Laurance is Distinguished Research Professor and an
Australian Laureate at James Cook University in Queensland, Aus-
tralia. He is also the Prince Bernhard Chair in International Nature
Conservation at Utrecht University, Netherlands.
Lavra and Lavrinha diamond mines in Guinda, Diamantina,
Brazil. Photo by Ricardo Scholz.
As mentioned in the last RIPorter, longtime Program
Associate Cathrine Walters decided to try out some
new adventures and left Wildlands CPR in February.
We are very pleased to welcome her replacement,
Grace Brogan. Grace is currently splitting her time
between Wildlands CPR and completing her Masters
in Environmental Studies at the University of Mon-
tana. Grace has worked for several different environ-
mental and social service nonprots in the Midwest
and here in Montana, including interning with our
ofce colleagues at the Community Food and Ag-
riculture Coalition. Shes got writing, photography,
pottery and numerous other artistic endeavors in her
background and were looking forward to taking
advantage of her photography and writing skills at
Wildlands CPR. Grace will be working specically to
expand our social media and overall web presence
and shes already started. Welcome Grace, were so
happy to have you on board!
Wildlands CPR recently entered into a ve-year challenge cost-share agreement
with the Lolo National Forest to inventory roads in different priority project areas
on the forest. We partnered with the Lolo on similar work in 2009 and 2010, so
were very pleased to have a longer-term agreement in place. The project will run
for six months a year and it requires a car for a signicant portion of the work.
Since weve signed a multi-year agreement with the agency, it meant it was time
for us to purchase a car. We owe a very big thank you to the Kendall Auto Group
and their local dealer, Kendall Four Seasons in Missoula, for helping us out with
our car purchase. Kendall donated one-third of the cost of a certied used Subaru
Forester. We picked it up in February and staff will be using it for local travel
needs until the eld season begins on April 30. If you live in Missoula well be
having a party at our ofce during First Friday gallery night on May 4, to thank
our partners Kendall and the Lolo, and to further explain the project.
Thanks so much to everyone who sent in year-end donations to help us meet our
2011 fundraising goals. We couldnt have done it without you, and well be us-
ing your contributions for our on-the-ground work! Wed also like to thank those
of you who participated in our winter e-membership drive. Im pleased to report
that we met our goal!
Finally, a big thank you to the following foundations for their recent support of
Wildlands CPR: Musicians United for Sustaining the Environment, Patagonia and
Temper of the Times Foundation.
Photo by Dan Funsch.
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Spring in Joshua Tree National Park.
Photo by Dan Funsch.