Date:
July 2, 2002


Dr. Bruce Means
Coastal Plains Institute and Land Conservancy
1313 Milton Street
Tallahassee, FL 32303

Dear Dr. Means:

  Thank you for your correspondence expressing concern over ongoing road maintenance projects in the Apalachicola National Forest. LL Wallace Road (FDR 322), the road that seems to be your major concern, was one of six-forest development roads in southern Leon County Florida with maintenance planned during the months June through September of this year.

  We have taken a closer look at these road maintenance projects following your correspondence pointing out sensitive biological concerns in the Munson Sandhill geological formations of the Apalachicola National Forest. Although, you did not express concern about the remaining five roads scheduled for maintenance, these roads are located in the same or similar forest area and any decisions made as a result of your comments will affect future maintenance of these roads as well.

  LL Wallace road was constructed some sixty plus years ago. It is pretty obvious the road was not professionally designed and laid out. This road was originally a two-tract dirt road providing low volume recreation traffic and timber management access. There were private residences located along both the east and west ends of the road but they probably only used these short sections for access to their residence from the main highway.

  As demand for a more adequate access road grew, maintenance along the road became a necessity. Today the LL Wallace road serves some thirty residences (37) and provides access for forest management. This road also serves as access for the public services necessary with residential occupancy such as: mail, delivery services, utilities, school buses, fire, law enforcement, medical, and telephone. These are some of the factors considered in the early planning stages of looking at the proposed road maintenance project.

  Road maintenance is considered a routine part of forest management. We perform maintenance on approximately 300 miles of roads under the supervision of our engineering staff. This type of activity has been recognized by our management direction as an action that can be categorically excluded from formal environmental documentation if there are no extraordinary circumstances present during our initial staff review. This is the case with the LL Wallace Road. The project work was categorically excluded and no public scoping was done. Our staff review of the proposed action determined the appropriate action to accomplish the maintenance needs on the selected roads.

  A cooperative road maintenance agreement exists between Leon County and the U.S. Forest Service to maintain forest owned and county maintained roads. Under this agreement the county is responsible for maintenance and has jurisdiction on the road for that purpose. A list of the proposed roads needing maintenance along with the proposed actions was presented to the Forest Service by Leon County.

  The county proposed application of a soil stabilization process on roads to reduce maintenance cost while providing an all weather driving surface. The process involved applying fill material (clay) and mixing it with a chemical commonly known as ‘lignin’ treatment. This treatment would be applied on all six of the roads identified.

  In addition to the soil stabilization process, the county also proposed the use of an open-graded cold mix (OGCM) asphalt surfacing material on selected sections of certain roads. These were the sections accessing private property with higher traffic volumes. Our response to the proposed action was positive but with stipulations directing the type and extent of the work to be performed on each of the roads.

  On LL Wallace road our direction was that no ditching, digging or other soil movement was to take place on the three (3) mile section of the road that is totally on national forest land. Only grading and the application of the soil stabilization treatment were to be performed. This stipulation was for the protection of potential heritage resource sites along the edges of the road. There was a five hundred (500) foot section of road (national forest land) on the east end that was included in the one mile section accessing private residents that would involve ditching and road bank reconstruction. This section (one mile) would involve the OGCM surfacing. Since this section involved mostly private property we concurred with the County proposal for this section.

  After work began on LL Wallace road, we discovered that the crew working on the road had created some lead off ditches and other soil movement. The county was very cooperative in stopping the work. This was about the same time that you pointed out the activity addressing your concerns. The county immediately responded to the mistake and applied erosion control structures at all of the critical points along the road.

  We have prepared a map showing critical points along the road that will respond to the erosion/sedimentation concerns pointed out in your letter. Our biologist is currently reviewing the project and will perform an assessment of the action. Our Archeologist has determined that the current condition does not warrant additional surveys if no other soil movement occurs outside the existing roadbed. Our engineering staff has evaluated the current erosion control structures and determined that they will be effective in assuring no soil movement into the sensitive areas. We reviewed information provided by the U.S. Forest Service Technology Center regarding the use of ‘lignosulfonates’ as a dust abatement and soil stabilization treatment and find nothing that causes us alarm in use of this substance. I will make this information available and would welcome your continued research efforts and cooperation as we continue to evaluate this maintenance process.

  At this point we are not prepared to leave the road in its present condition. The clay material in its present state is not stable. We have considered the following alternatives and consequences:

  Remove the clay. We believe this would cause more damage than good. It would further entrench the roadbed. Possible additional erosion problem are likely to occur.
  Mix the clay with the existing sand. Compaction would only be temporary. Soil movement would continue.
  Apply the stabilization treatment. Compaction would be more long term. Minimal soil movement would occur.
  Apply OGCM to the entire Road. Increased traffic and traffic speed. Not consistent with the forest management objectives. Reduce erosion potential.
  After taking all this into account, we are proceeding with the county’s proposal to apply the soil stabilization treatment. Runoff control structures along the road will be maintained for a period of one year and at road maintenance intervals following.

  I share your concern for the sensitivity of the Munson Sand Hills. As we go about trying to balance access demands with ecological concerns, we need input from all involved. Please work with Acting District Ranger Glenn Coleman on any additional questions or concerns you might have. Thank you again for your support and interest in National Forest lands management over the years. We look forward to working with you on this and other projects.

Sincerely,

/s/ Denise Rains

for

MARSHA KEARNEY

Forest Supervisor

cc: Ryan Means

Kenneth Krysko

Dale Jackson

Margaret Gunzburger

Matthew J. Aresco

Bruce Ritchie