United States Department of Agriculture

Draft Record of Decision

for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests

Coconino County, Arizona

Forest Service Southwestern Region MB-R3-04-23 November 2014
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Printed on recycled paper – November 2014
Draft Record of Decision for the 

Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 

Coconino County, Arizona 

Lead Agency: U.S. Forest Service

Cooperating Agencies: Arizona Game and Fish Department 

Responsible Officials: M. Earl Stewart

Coconino National Forest 

Forest Supervisor

1824 South Thompson Street 

Flagstaff, AZ 86001

Michael R. Williams 

Kaibab National Forest 

Forest Supervisor

800 South Sixth Street 

Williams, AZ 86046

For Information Contact: Annette Fredette, Project Team Leader

1824 South Thompson Street 

Flagstaff, AZ 86001 

(928) 226-4684 
List of Acronyms

4FRI Four-Forest Restoration Initiative

ADEQ Arizona Department of Environmental Quality 

AGFD Arizona Game and Fish Department 

BA Basal area

BMP Best management practice

CFLRA Collaborative Forest Landscape Restoration Act

CFR Code of Federal Regulations 

d.b.h. Diameter at breast height

DEIS Draft environmental impact statement

dPFA Dispersal post-fledging area

EIS Environmental impact statement

EPA Environmental Protection Agency

EIS Environmental impact statement

FEIS Final Environmental Impact Statement

FSM Forest Service Manual

FWS United States Fish and Wildlife Service

HUC Hydrologic unit code 

LOPFA Landscapes outside post-fledging family area

LTIP Large tree implementation plan

LTRS Large tree retention strategy

MSO Mexican spotted owl

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NHPA National Historic Preservation Act

NRV Natural Range of Variability

PAC Protected activity center

PFA Northern goshawk post-fledging family area

RU Restoration unit

SDI Stand density index 

SHPO State Historic Preservation Office

TMDL total maximum daily load

USDA United States Department of Agriculture

USDI United States Department of the Interior

VSS Vegetation structural stages
Contents

Contents ............................................................................................................................................ i

Introduction ...................................................................................................................................... 1

Background ...................................................................................................................................... 1

Public Involvement .......................................................................................................................... 1

Tribal Consultation .......................................................................................................................... 3

Purpose and Need ............................................................................................................................ 4

Issues Addressed .............................................................................................................................. 5

Issue 1: Prescribed Fire Emissions .............................................................................................. 5

Issue 2: Conservation of Large Trees .......................................................................................... 5

Issue 3: Post-treatment Canopy Cover and Landscape Openness ............................................... 6

Issue 4: Increased Restoration and Research ............................................................................... 6

Procedural Concerns ........................................................................................................................ 6

Range of Alternatives and Comparison of Alternatives .............................................................. 6

Significant Forest Plan Amendments .......................................................................................... 7

Alternatives Considered But Eliminated From Detailed Study ...................................................... 8

Limit Mechanical Treatments to 8 Inches D.B.H. ....................................................................... 8

Use Prescribed Fire as the Sole Treatment Method ..................................................................... 9

Eliminate the Use of Prescribed Fire ........................................................................................... 9

Incorporate the Original Large Tree Retention Strategy (LTRS) .............................................. 10

Limit Mechanical Treatments to 16 Inches D.B.H. as a Means to Preserve Large Trees ......... 10

Evidence-Based Full Restoration Alternative ........................................................................... 10

Alternatives Considered in Detail .................................................................................................. 11

Alternative A – No Action......................................................................................................... 11

Alternative B – Proposed Action ............................................................................................... 11

Alternative C – Selected Alternative ......................................................................................... 11

Alternative D ............................................................................................................................. 11

Alternative E .............................................................................................................................. 12

Decision ......................................................................................................................................... 12

Rationale for Our Decision ........................................................................................................ 18

Consideration of Unavoidable Adverse Effects ........................................................................ 30

Uncertainty and Risk for Mexican Spotted Owl ........................................................................ 31

Environmentally Preferable Alternative .................................................................................... 31

Unavailable Information ............................................................................................................ 32

Compatibility with Goals of Other Local, State and Federal, Governments ............................. 32

Findings Required by Other Laws and Authorities ................................................................... 32

Implementation .......................................................................................................................... 43

Monitoring ................................................................................................................................. 43

Effective Date ............................................................................................................................ 43

Contact ....................................................................................................................................... 43

Responsible Official Signatures ..................................................................................................... 44

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests i 
Figure 1. Four-Forest Restoration Initiative (4FRI) project area

ii Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Introduction 

This is the draft record of decision for the Four-Forest Restoration Initiative on the Coconino and 

Kaibab National Forests (figure 1). An environmental impact statement was developed to analyze 

the potential effects of the project. The final environmental impact statement (FEIS) for this 

project has been prepared pursuant to the requirements of the National Environmental Policy Act 

(NEPA, 40 CFR 1500-1508), the National Forest Management Act and its implementing 

regulations, the Coconino National Forest Plan, as amended (USDA Forest Service 1987) and the 

revised Kaibab National Forest Land and Resource Management Plan (USDA Forest Service 

2014). The decision presented in this document addresses activities proposed on lands 

administered by the Forest Service for which Federal decisions are required. On March 11, 2011, 

the Arizona Game and Fish Department (AGFD) was designated a cooperating agency. 

The FEIS documents the analysis of environmental effects associated with a suite of restoration 

treatments on approximately 586,110 acres of National Forest System lands. The project would 

be implemented over a 10-year period or until objectives are met. The area affected by this 

decision includes approximately 355,707 acres on the Flagstaff, Mogollon, and Red Rock Ranger 

Districts of the Coconino NF and approximately 230,402 acres on the Williams and Tusayan 

Ranger Districts of the Kaibab NF.

This decision documents the analysis of five alternatives including a “no action” alternative. It 

presents our decision along with the rationale and alternatives considered in reaching the 

decision.

Background 

This decision is a result of several years of planning and collaboration among interested parties, 

groups and organizations, and Federal, State and local government agencies. In 2010, 

stakeholders developed a comprehensive landscape restoration strategy for the national forests 

that documented existing conditions, potential treatment areas, and desired post-treatment 

conditions (4FRI Stakeholders 2010). In 2011, the stakeholders developed a Large Tree Retention 

and Old Growth Protection Strategy (4FRI Stakeholders 2011). The Forest Service used the 

stakeholder’s Landscape Restoration Strategy to inform the purpose and need and proposed 

action for this project. The large tree and old growth strategy was used to develop alternatives and 

the implementation plan. This project received Collaborative Forest Landscape Restoration Act 

(CFLRA) funding. The CFLRA supports landscape restoration on National Forest System lands.

Public Involvement

The 4FRI Project has been published in the Coconino and Kaibab NFs’ Schedule of Proposed 

Actions since January of 2011. The notice of intent to prepare an environmental impact statement 

was published in the Federal Register on January 25, 2011 (76 FR 4279–4281). A draft proposed 

action was sent to the project mailing list (paper copies and electronic mail), consisting of 1,331 

individuals, local governments, State governments, Federal and State agencies, and organizations 

that encompassed both national forests. Fifty-four (54) scoping responses (emails and letters) 

were received through May 5, 2011. A scoping report that included a summary of the scoping 

process was posted on the 4FRI website on June 29, 2011. On March 11, 2011, the Arizona Game 

and Fish Department (AGFD) was designated a cooperating agency. The agency provided a 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 1 
Draft Record of Decision

habitat specialist to serve as an interdisciplinary team member and to assist with the wildlife 

analysis.

From January to June, 2011, seven public meetings were held for the purposes of receiving 

comments that would be used to develop a revised proposed action. On average, 

meeting/workshop attendance ranged from 10 to 20 participants. Details on all meetings can be 

found in the project record. 

A revised proposed action was sent to a refined mailing list (based on scoping responses) of 213 

parties (169 electronic mail and 44 paper copy recipients), and a second 14-day informal scoping 

period began with the publication of a second revised notice of intent in the Federal Register on 

August 19, 2011 (76 FR 51936–51938). Not counting duplicates, 42 scoping responses (emails 

and letters) were addressed in content analysis (for the revised proposed action).

In the fall of 2011, meetings were held with commenters to clarify comments received on the 

revised proposed action. This included hosting meetings to discuss comments on large trees on 

October 14, 2011 and on canopy cover (in relation to forest plan goshawk guidelines) on 

December 15, 2011 (Coconino NF Supervisor’s Office). 

In 2012, monthly public meetings were hosted from March through July to discuss the status of 

the environmental analysis. Draft (working) documents were shared at the public meetings and 

made available on the 4FRI website at http://www.fs.usda.gov/main/4fri/planning. Documents 

posted included: issues, alternatives, draft forest plan amendments, cumulative effects, the 

scoping report (August 2011 scoping period), and version 5 of the modified Large Tree Retention 

Implementation Strategy (alternative C). Only a sampling of the public involvement effort is 

included here. See the project record for complete documentation. The project has been 

continuously posted on the Coconino and Kaibab NFs Schedule of Proposed Actions since 

January of 2011 and public involvement and analysis-related documents have been posted on the 

project’s website since January, 2011. 

Four issues including issue 1: prescribed fire emissions, issue 2: conservation of large trees, 

issue 3: post-treatment canopy cover and landscape openness; and issue 4: increased research and 

restoration focused the analysis or drove alternative development. The team also identified other 

comments and concerns. Many of these concerns were considered and incorporated in the draft 

environmental impact statement (DEIS) as design features, mitigations, and best management 

practices (DEIS, appendix C). Many comments resulted in the development of the 

implementation plan (DEIS, appendix D) and the monitoring and adaptive management plan 

(DEIS, appendix E). See chapter 1 of the FEIS for information on how other public concerns and 

recommendations were addressed. 

On February 26, 2013, a preview of the DEIS was posted on the project’s website at 

http://www.fs.usda.gov/main/4fri/planning, and interested parties were notified via email, phone 

call, or letter. On March 29, 2013 a notice of availability was published in the Federal Register 

(78 FR 19261). The notice of availability began a 60-day public comment period. 

Documentation of the formal DEIS comment process is contained in the project record. A legal 

notice announcing the availability of the DEIS for review and comment was published in the 

Arizona Daily Sun on April 4, 2013 and posted on the project’s website. 

Comments on the DEIS were provided by individuals; tribal governments; Federal, State, and 

local agencies; organized interest groups; and businesses. Approximately 213 letters and emails 

2 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
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were received on the DEIS. About 1,000 individual comments were received. All comments were 

made available on the project’s web-based public reading room (https://cara.ecosystemmanagement.org/Public/ReadingRoom?project=34857). 

The Forest Service analyzed comments to identify issues that required further or updated analysis 

and to identify analyses that required further clarification. Issues 1 to 4 were edited to reflect 

public comments on the DEIS related to canopy cover, post-treatment openness and the 

conservation of old and large trees. Two procedural concerns were added to the FEIS as a result 

of public comments. In summary, the FEIS responded to four issues, two procedural concerns, 

and evaluated five alternatives. Alternatives include the no action alternative (alternative A) 

required by regulations, the proposed action (alternative B), and three alternatives (alternatives C, 

D, and E) to provide sharp contrast and comparison to the proposed action. 

Appendix I of the FEIS contains comment letters received from government agencies in their 

entirety in accordance with Forest Service Handbook 1909.15. Per 40 CFR 1503.4, summarized 

responses to comments received on the draft EIS are included in this appendix. They have been 

organized by topic. The complete comment analysis and response document is located in the 

project record and is available on the project’s website.1

 

Tribal Consultation 

The following tribes and tribal chapters who have historic ties and an interest in the Coconino and 

Kaibab National Forests were consulted and include: Hopi, Kaibab Band of Paiute Indians, Navajo

Nation including Coppermine, Coalmine, Naness, Lechee, Leupp, Bodaway, Cameron, Tuba City, 

Dilkon and Tolani Lake Chapters, San Juan Southern Paiute, White Mountain Apache, YavapaiApache Nation, San Carlos Apache, Hualapai, Yavapai- Prescott Indian Tribe, Havasupai, Tonto 

Apache, Pueblo of Zuni, Pueblo of Acoma, and Fort McDowell Yavapai Nation. 

Consultation began September 10, 2009 with the Kaibab NF forest supervisor sending an 

invitation to seven federally recognized tribes to discuss 4FRI and other national forest projects. 

On January 27, 2011, the Forest Service sent a letter to tribes and tribal chapters providing 

information and seeking involvement and comments. Two written scoping responses were 

received. The White Mountain Apache responded on February 17, 2011 and indicated no concern 

with the project. A response from the Havasupai Tribe on March 7, 2011 asked for additional 

information on what the expected outcome of the proposals would be. The Hopi Tribe provided 

comments on treatments and the heritage survey strategy on March 21, 2011. On August 22, 

2011, a second scoping letter was sent to the tribes. The tribes responded and provided additional 

input and voiced concerns during consultation meetings including: 

• Traditional cultural properties are at risk to catastrophic fire. 

• Springs and plant collection areas are at risk to catastrophic fire.

• Overstocked stands are reducing the sunlight available for cultural and medicinal plants.

• Springs that are important to tribal ceremonies are drying up. 

• A lack of low-intensity fire is reducing regeneration of plant collection areas.

• Smoke may affect some tribal communities.

• Tribes need access to sites for ceremonies and traditional gathering.

• Preservation of cultural resources.

1 http://www.fs.usda.gov/main/4fri/planning

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 3 

 
Draft Record of Decision

One written comment was received from the Hopi Tribe in response to the DEIS (see appendix I 

of the FEIS). Since consultation began in 2011, continuous updates on the project have been 

provided to tribes. The “Tribal Relations” section in chapter 3 of the FEIS and the tribal relations 

specialist report provides complete consultation documentation. 

Tribes that did not participate in tribal consultation continued to receive information via email 

and hand-delivered mail. Information will continue to be shared unless a tribe asks specifically to 

not be informed.

Purpose and Need

The purpose of this project is to reestablish and restore forest structure and pattern, forest health, 

and vegetation composition and diversity. There is a need to increase forest resiliency and 

sustainability, protect soil productivity, and improve soil and watershed function. Resiliency 

increases the ability of the ponderosa pine forest to survive natural disturbances such as fire, 

insect and disease, and climate change (FSM 2020.5). This action is needed because:

• Over 50 percent of the ponderosa pine is even-aged and lacks age-class diversity. The singleage forest structure has reduced the health of the ponderosa pine forest. Large, old ponderosa 

pine trees are rare across the landscape. The remaining old pines are at risk of dying from the 

increased overcrowding of trees (stand density-related mortality) and the potential for severe 

fire effects.

• In contrast to having a ponderosa pine ecosystem consisting of groups of trees mixed with 

interspaces, approximately 74 percent of the ponderosa pine forest type within the project 

area is departed from historical reference conditions. Non-forested openings have been 

invaded by ponderosa pine since fire exclusion and this has changed the natural (and desired) 

spatial pattern. 

• The dense, single-age forest structure combined with the lack of nonforested openings has 

affected function related to the presence of grass, forbs, and shrubs (vegetation composition 

and diversity). There is reduced understory productivity and function throughout the forest 

and within grasslands and meadows where trees have grown in. Ephemeral stream function 

has been affected by reduced ground cover, the presence of noxious weeds, increased 

numbers of trees, and the lack of fire. Spring function has been affected by drought, the lack 

of fire, and closed forest canopies, which increase evapotranspiration. 

• The existing forest structure is in poor forest health. This has affected resiliency, or the ability 

of ponderosa pine to withstand natural disturbances including fire, insects and disease, and 

changing climatic conditions, such as drought. About 191,000 acres (38 percent) are at risk 

from crown fire. Additional acres, primarily within or next to Mexican spotted owl habitat are 

at risk from high-intensity surface fire that can result in high-severity effects.

• Approximately 72 percent of the ponderosa pine in the project area has a high hazard rating 

for bark beetle. About 34 percent of the ponderosa pine is moderately to heavily infected with 

dwarf mistletoe (see silviculture report). The current deficiency in resiliency is attributed to 

closed forest conditions and the associated buildup of forest fuels.

4 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Issues Addressed

The final environmental impact statement responded to four issues and evaluated five 

alternatives: the no action alternative (alternative A) required by the regulations, the proposed 

action (alternative B), and three alternatives (alternatives C, D, and E) to provide sharp contrast 

and comparison to the proposed action. 

Two procedural concerns related to the range of alternatives and plan amendments were added to 

chapter 1 to highlight concerns raised by the public. Public concerns that are routine disclosures 

(see chapter 3) were not considered to be key issues. For example, consultation with the U.S. Fish 

and Wildlife Service on endangered species is a requirement. Therefore, comments that stated 

consultation needed to occur were not considered an issue. Many public comments submitted 

during the scoping period suggested alternatives that were either considered in detail or 

eliminated from detailed analysis (see chapter 2). 

Some comments were determined to be outside the scope of this analysis for one or more of the 

following reasons: they did not reflect a cause-and-effect relationship supported by scientific 

evidence; they were not relevant to the decision to be made; they were outside the Forest 

Service’s authority; or they were already decided by law, regulation, or policy. The issues raised 

in these comments were dismissed from further consideration. Appendix I of the FEIS provides a 

summary of comments (organized by topic) received on the DEIS. 

Each specialist analyzed: (1) issues raised by the public (next section), (2) how the proposed 

alternatives address the purpose and need, (3) topics required by law, regulation or policy, and, 

(4) additional resource topics and concerns they felt were important for their resource (see 

specialist reports).

Issue 1: Prescribed Fire Emissions

This issue relates to the emissions from prescribed fire activities and the impact on air and water 

quality, public health, quality of life, and the economy of northern Arizona. In response to 

comments on the DEIS, emissions include, but are not limited to, radionuclide particles and 

mercury.

An alternative that would eliminate all prescribed fire was considered but eliminated from 

detailed study as it did not adequately meet the purpose and need for restoring the fire-adapted 

southwestern ponderosa pine ecosystem. Alternatives B, C, and E propose using prescribed fire 

across the entire project area and alternative C adds acres on which prescribed fire would be used 

to restore additional acres of grasslands. Alternative D was developed to respond to the 

emissions/smoke issue by decreasing the acres proposed for prescribed fire by 69 percent (when 

compared to alternative B). This equates to removing fire on about 404, 889 acres. All action 

alternatives include design criteria aimed at reducing impacts to air quality (as practicable) and 

increasing coordination efforts amongst neighboring forests. 

Issue 2: Conservation of Large Trees

This issue focuses on the conservation of large trees and the inclusion into the action alternatives 

of a strategy produced by the 4FRI stakeholders, the “Old Growth Protection and Large Tree 

Retention Strategy”2 (also referred to as the “Large Tree Retention Strategy” or the “Old Tree 

2 4FRI Stakeholders 2011

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 5 

 
Draft Record of Decision

Retention Strategy”). Large post-settlement trees, as defined by a socio-political process, are 

those greater than 16 inches d.b.h. 

Commenters stated alternatives B (proposed action alternative) and D do not incorporate the 

Large Tree Retention Strategy. Alternative C and E respond to this issue by incorporating key 

components of the strategy and focusing on ecological desired conditions. In response, an 

implementation plan that is integral to all action alternatives was developed. The plan identifies 

ecological conditions where large, post-settlement trees may be removed to move toward or meet 

desired conditions. The intent of the Large Tree Retention Strategy has been incorporated into 

alternative C and E’s design criteria, the monitoring and adaptive management plan, and the 

project implementation plan. All resource reports have analyzed and disclosed how the modified 

Large Tree Retention Strategy (the Large Tree Implementation Plan) has been addressed in the 

environmental consequences section of the FEIS. 

Issue 3: Post-treatment Canopy Cover and Landscape Openness

This issue focuses on retaining closed canopy conditions for species including, but not limited to, 

goshawk and Mexican spotted owl. Commenters stated measuring canopy cover in goshawk 

habitat at the group level would not meet forest plan stand-scale canopy requirements. 

Commenters stated a reduction in canopy and large tree densities have never been analyzed under 

the National Environmental Policy Act and National Forest Management Act and could have 

deleterious effects to goshawk, its prey species, and those wildlife species that are dependent on 

that cover. Because natural openings would no longer be included within the vegetation structural 

stage (VSS) classification, it would result in significantly more lands being in an open condition 

or outside of the VSS 4 to 6 classifications. This could substantially increase the logging of 

mature and old trees and negatively affect wildlife, including goshawk and its prey species.

Alternatives B through E are designed to provide closed canopy conditions and comply with the 

forest plans. The vegetation analysis addresses the interrelationship between canopy cover and 

old and large trees. To address post-treatment openness and canopy cover, a nonsignificant forest 

plan amendment for the Coconino NF was developed for alternatives B, C, and D. Alternative E 

does not propose a forest plan amendment. 

Issue 4: Increased Restoration and Research

This issue focuses on recommendations to increase the acres and type of restoration treatments. 

Commenters recommended including additional acres of grassland restoration. The U.S. Fish and 

Wildlife Service recommended increasing prescribed fire and mechanical treatments within 

Mexican spotted owl habitat (to improve the quality of the habitat and be in alignment with the 

revised Mexican Spotted Owl Recovery Plan (USDI FWS 2012)). Commenters recommended 

including a paired watershed study and small mammal research to evaluate the impact of 

landscape-scale restoration. Alternative C was developed to respond to this issue. 

Procedural Concerns 

Range of Alternatives and Comparison of Alternatives

This procedural concern was raised in comments to the DEIS. There is a concern that the action 

alternatives proposed in the DEIS were virtually identical except for the variation in acreages. 

Some commenters stated there is no (action) alternative where a plan amendment would not take 

6 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

place. Commenters stated it is not possible to understand the environmental effects and tradeoffs 

for resources that result from the amendments themselves. 

Alternative E may address this concern. In alternative E, no forest plan amendment would occur 

and treatments would comply with the current Coconino NF forest plan. In summary, the FEIS 

includes 11 alternatives including no action, 4 action alternatives, and 6 alternatives that were 

considered but eliminated from detailed study. 

Significant Forest Plan Amendments

This procedural concern is based on comments on the DEIS. Commenters stated the plan 

amendments are significant because they may bring about changes that may have an important 

effect on the entire land management plan (or affect land and resources throughout a large portion 

of the planning area) see FSM 1926.52 (Jan. 31, 2006). Some commenters stated the plan 

amendments are significant because the two national forests are including identical plan 

amendments in similar projects. 

In the FEIS, the analysis has been updated to clarify methodology and data used for the 

significance evaluation. Alternative E, which proposes no forest plan amendments, provides a 

point of comparison to alternatives B, C and D which do include plan amendments. 

In the DEIS, three forest plan amendments were proposed for the Kaibab NF. The forest plan was 

revised in 2014. As a result, all forest plan amendments were removed in the FEIS. No forest plan 

amendments are needed on the Kaibab NF because the proposed actions are consistent with forest 

plan objectives, desired conditions, and standards and guidelines (see FEIS chapter 2, “Forest 

Plan Consistency”). 

Three nonsignificant amendments for the Coconino NF were evaluated in the FEIS. The 

amendments are authorized by the Forest Service Planning Rule (36 CFR 219). Section 

219.17(b)(3) of the Rule provides the transition language that allows this project to propose 

amendments to the Coconino NF forest plan using the provisions of the 1982 Planning Rule. The 

significance of each amendment was evaluated in accordance with Forest Service Manual (FSM)

1926.51 and FSM 1926.52. 

The purpose of amendment 1 is to bring the selected alternative in alignment with the revised 

Mexican Spotted Owl Recovery Plan and defer monitoring to the U.S. Fish and Wildlife Service 

biological opinion that is specific to this project. Amendment 2 clarifies existing direction related 

to managing canopy cover and interspace in the forest plan. The purpose of amendment 2 is to 

bring the project into alignment with the best available science (Reynolds et al. 2013) that 

provides desired conditions for restoring fire-adapted ponderosa pine in the Southwest. 

Amendment 3 resolves a forest plan error related to the management of heritage resources and is 

specific to this project. See page 15 of this document for more information about each 

amendment. The detailed significance analysis for each amendment is located in appendix B of 

the FEIS.

No amendment alters multiple-use forest plan goals and objectives, adjusts management area 

boundaries or management prescriptions. The changes in standards and guidelines are considered 

to be minor because they reflect the latest, best available science (Reynolds et al. 2013). The 

amendments bring the alternatives into alignment with the revised Mexican Spotted Owl 

Recovery Plan, although the degree of alignment varies by alternative. No amendment would 

alter the long-term relationship between levels of multiple-use goods and services originally 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 7 
Draft Record of Decision

projected for the Coconino NF. These outputs were specific to a planning period ranging from 10 

to 15 years (as identified in 1987). 

• Amendment 1: In alternative C the amendment would affect 6,906 acres or 18 percent of 

Mexican spotted owl protected activity center habitat on the Coconino NF.

• Amendment 2 is a clarification amendment. The canopy cover portion of the amendment 

would generally affect 137,242 acres (15 percent) of all goshawk habitat on the Coconino NF. 

Managing 28,653 acres of ponderosa pine for an open reference condition would affect 

approximately 3 percent of all suitable goshawk habitats on the Coconino NF. 

• Amendment 3 is specific to the 355,707 acres of proposed treatments in this project. In 

alternative C this would affect about 20 percent of the Coconino NF (which totals 1,821,495 

acres).

For these reasons, the amendments would not result in an important effect to the entire land 

management planning area. Each amendment is a specific, one-time variance for this restoration 

project. The best available science for management in southwestern forests (Reynolds et al. 

2013), and the Coconino NF forest plan revision process are affecting ongoing and future 

analyses. The plan amendments that are specific to this project do not impose direction on 

ongoing or future analyses. 

Some commenters stated the plan amendments are significant because the two national forests are 

including identical plan amendments in similar vegetation projects and therefore, are providing 

direction that must be followed by other projects. The list of vegetation projects that were 

included in comments on the DEIS were reviewed. Overall, the forest plan amendments that have 

been proposed in other vegetation projects reflect the ongoing Coconino NF forest plan revision 

process, using the best available scientific information (Reynolds et al. 2013), and they are 

compliant with the revised Mexican Spotted Owl Recovery Plan (USDI FWS 2012). A complete 

analysis of other proposed forest plan amendments by project is located in the project record. 

Six alternatives were considered but eliminated from detailed study for reasons described in depth 

in chapter 2 of the FEIS and summarized in this decision: 

Alternatives Considered 

But Eliminated From Detailed Study

The FEIS included six alternatives that were considered but eliminated from detailed study. These 

are summarized in the following pages. All alternatives were evaluated to determine how well the 

proposal would accomplish the purpose and need for action. Further details can be found in 

chapter 2 of the FEIS.

Limit Mechanical Treatments to 8 Inches D.B.H. 

This alternative was based on the assertion that crown fire can be effectively addressed with 

mechanical treatments that do not cut trees larger than 8 inches d.b.h. Small diameter mechanical 

tree cutting would be used to establish tree groups, nonforested openings (interspaces), and move 

toward a balance of tree age and size classes. Prescribed fire would be used to reduce litter and 

other surface fuels, stimulate herbaceous understory vegetation, prepare sites for natural 

ponderosa pine regeneration, and maintain interspaces. 

8 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

This alternative would partially address Issue 2, conservation of large trees, since mechanical 

treatments would be curtailed at 8 inches d.b.h. It would not achieve restoration desired 

conditions. It would resolve Issue 3, post-treatment canopy cover and landscape openness, since 

only small-diameter trees would be removed. However, approximately 73 percent of the 507,839 

acres of ponderosa pine within the project area would not move toward forest structure and 

pattern desired conditions. Of all the even-aged stands, 47 percent (VSS 4), 8 percent (VSS 5), 

and 1 percent (VSS 6) would remain even-aged. There would be 0 percent movement toward 

desired conditions in uneven-aged VSS 4 through VSS 6 stands. For these reasons, this 

alternative was considered but eliminated from detailed study.

Use Prescribed Fire as the Sole Treatment Method

In response to public comments and recommendations received during scoping, an alternative 

which only uses prescribed fire to move toward restoration desired conditions was considered. 

The recommendations are based on the assertion that the current high-intensity fire rotation in 

southwestern forests is 625 years and/or that the forests should be predominantly managed as 

self-regulating through the use of natural processes such as fire.

This alternative was considered but eliminated from detailed study because: (1) the potential for 

uncharacteristically severe fire effects would remain high and there would be no improvement in 

terms of resiliency in and around Mexican spotted owl protected activity centers; (2) treatment on 

192,819 acres or 33 percent of the treatment area would likely be deferred in order to avoid a 

further reduction in pre-settlement trees; (3) movement toward having a sustainable forest 

structure with age and size class diversity would not be met as there would be continued 

overrepresentation in the VSS 3 and 4 age classes and continued underrepresentation in the VSS 5 

and VSS 6 age classes; (4) forest structure and pattern and overall function would not be restored 

on 11,230 acres of grasslands (equates to 9,435 acres of grassland in VSS 3+) and 45,142 acres 

of historic mollic-integrade savanna (equates to 42,009 acres in VSS 3+) ; and (5) movement 

toward the desired condition of restoring the historic pattern within the pine-sage mosaic would 

not be achieved in areas where treatment was deferred.

Eliminate the Use of Prescribed Fire

Some public comments recommended eliminating all prescribed fire to remove project nuisance 

smoke and its resulting emissions. Recommendations include using livestock (cattle, goats) in 

lieu of prescribed fire to reduce fuels. This alternative assumes that approximately 90 percent of 

all treatment-related slash (biomass) would be moved offsite and considers grazing and a variety 

of mechanical treatment methods to reduce fuels.

Without the ability to use prescribed fire it is estimated the project area would begin to move 

away from forest structure and pattern and resiliency desired conditions within 10 years of the 

mechanical treatment. The use of alternative fuels treatment methods in lieu of prescribed fire 

could provide reductions in some surface fuels but would not meet the ecological need of a fireadapted landscape. In the case of grazing, the level that would be needed to maintain the project 

area without fire would exceed forest plan allowable thresholds. Using grazing as a surrogate for 

prescribed fire would be contrary to the purpose and need which is designed to increase 

vegetation composition and diversity, and move toward improved soil productivity and watershed 

function. For these reasons it was considered but eliminated from detailed study. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 9 
Draft Record of Decision

Incorporate the Original Large Tree Retention Strategy (LTRS)

Comments recommended incorporating the LTRS as written by the 4FRI stakeholders. It was 

determined that incorporating and implementing the original LTRS would not meet various 

elements of the purpose and need. A modified version of the original strategy, the Large Tree 

Implementation Plan (LTIP), was included in alternatives C and E. The “background” section in 

the FEIS summarizes how the original LTRS was modified. Table 15 in the DEIS (and FEIS) 

displays a few excerpts from the original LTRS, the location of the excerpts in the LTRS, a 

crosswalk to the modified LTIP, and rationale why the original language was not accepted as 

written. For these reasons it was considered but eliminated from detailed study. 

Limit Mechanical Treatments to 16 Inches D.B.H. as a Means to 

Preserve Large Trees

This alternative originated over the impression that there are relatively few large trees remaining 

on the landscape and that the removal of large trees is a return to commercially-focused forest 

management. An alternative limiting mechanical harvest to trees less than 16 inches d.b.h. was 

not analyzed in detail for two reasons: 

1. The 4FRI collaborative group developed and submitted to the Forest Service for 

consideration a large tree retention strategy (LTRS). The LTRS identifies situations where 

removing post-settlement trees larger than 16 inches d.b.h. would be ecologically beneficial. 

Key components from the 4FRI stakeholder strategy have been incorporated into alternative 

C’s implementation plan.

2. Land managers and researchers throughout the Southwest have concerns that such a policy is 

unsustainable, and that constraining restoration treatments to trees 16 inches d.b.h. and 

smaller would limit achievement and maintenance of desired conditions for long-term forest 

structure, composition, and forest dynamics unique to the open tree canopy/multistoried 

conditions in the frequent fire forests of Arizona and New Mexico. 

Evidence-Based Full Restoration Alternative

This alternative was considered as a result of comments on the DEIS. Commenters stated the 

DEIS did not include an evidence-based, full-restoration alternative, which looks at the outcomes 

and impacts of applying science-based ecological restoration on this landscape. Science that 

supports ecological restoration includes (but is not limited to) Woolsey (1911), Cooper (1960), 

White (1985), Pearson (1950), Covington et a1. (1997), and Abella and Denton (2009). 

This alternative would meet the objective of increasing forest resiliency and sustainability. It 

would address Issue 4. However, the full restoration alternative would compromise closed and 

moderately-closed forest structure in Mexican spotted owl and goshawk habitat. The alternative 

would remove much of the closed canopy (bridge) habitat for wildlife (appendix G) thereby 

removing refugia for closed canopy-dependent species. Desired conditions and forest plan 

direction specific to vegetation composition and diversity in Gambel oak, Mexican spotted owl

and goshawk habitat would not be achieved (see FEIS chapter 1). The desired condition of a 

having moderate-to-closed canopy conditions widely distributed on the landscape would not be 

achieved. There would be insufficient moderate-to-closed conditions that would provide habitat 

connectivity. For these reasons, the alternative was considered but eliminated from detailed study. 

For additional details, see the project record.

10 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Alternatives Considered in Detail

The FEIS displayed the effects of five alternatives (FEIS, chapter 2). 

Alternative A – No Action

Alternative A is the no action alternative as required by 40 CFR 1502.14(c). There would be no 

changes in current management and the forest plans would continue to be implemented. 

Approximately 166,897 acres of current and ongoing vegetation treatments and 195,076 acres of 

prescribed fire projects would continue to be implemented within and next to the project area. 

Approximately 43,041 acres of vegetation treatments and 58,714 acres of prescribed fire and 

maintenance burning would be implemented next to the project area by the Coconino and Kaibab 

NFs in the foreseeable future (within 5 years). Activities such as road maintenance, recreation, 

firewood gathering and authorized livestock grazing would continue. Activities that have been 

authorized in separate decisions such as the control of non-native invasive plants and 

implementation of travel management would continue. Alternative A is the point of reference for 

assessing alternatives B through E.

Alternative B – Proposed Action 

Alternative B is the proposed action. It incorporates comments and recommendations received 

during eight months of collaboration with individuals, agencies, and organizations. This 

alternative would mechanically treat 384,966 acres of vegetation and use prescribed fire on 

583,330 acres. It incorporates comments and recommendations received during eight months of 

collaboration with individuals, agencies, and organizations. It proposes mechanically treating 

trees up to 16 inches in diameter (d.b.h.) in 18 Mexican spotted owl protected activity centers and 

includes low-severity prescribed fire within 70 Mexican spotted owl protected activity centers, 

excluding 54 core areas. Three non-significant forest plan amendments on the Coconino NF 

would be required. No forest plan amendments are proposed on the Kaibab NF. See chapter 2 of 

the FEIS for additional details. 

Alternative C – Selected Alternative

Alternative C is the selected alternative. This alternative would mechanically treat 431,049 acres of 

vegetation and use prescribed fire on 586,110 acres. It responds to Issue 2 (conservation of large 

trees), and Issue 4 (increased restoration and research). It adds acres of grassland treatments on 

the Kaibab NF and incorporates wildlife and paired watershed research on both national forests. It 

proposes to mechanically treat trees up to 17.9 inches d.b.h. in 18 Mexican spotted owl protected 

activity centers and includes low-severity prescribed fire within 70 Mexican spotted owl protected 

activity centers, including 54 core areas. Key components of the stakeholder-created Large Tree

Retention Strategy are incorporated into the alternative’s implementation plan. Three nonsignificant forest plan amendments on the Coconino NF would be required. No forest plan 

amendments are proposed on the Kaibab NF. See chapter 2 of the FEIS for additional details. 

Alternative D

This alternative would mechanically treat 384,966 acres of vegetation and use prescribed fire on 

178,441 acres. This alternative was developed in response to Issue 1 (prescribed fire emissions). It

decreases the acres that would receive prescribed fire by 69 percent (when compared to 

alternative B, the proposed action). This equates to removing fire on about 404,889 acres. It 

proposes mechanically treating trees up to 16 inches d.b.h. in 18 Mexican spotted owl protected 

activity centers, but the protected activity centers would not be treated with prescribed fire. Three 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 11
Draft Record of Decision

non-significant forest plan amendments on the Coconino NF would be required. No forest plan 

amendments are proposed on the Kaibab NF. See chapter 2 of the FEIS for additional details. 

Alternative E

Alternative E was developed in response to comments on the DEIS. This alternative would 

mechanically treat 403,218 acres of vegetation and use prescribed fire on 581,020 acres. 

Alternative E responds to Issue 3 (post-treatment landscape openness and canopy cover), and may 

resolve concerns the public had related to the range of alternatives and forest plan amendments. It 

is similar to alternative C in that it adds acres of grassland treatments on the Kaibab NF and 

incorporates a paired watershed study and small mammal research. It proposes to mechanically 

treat trees up to 9 inches d.b.h. in 18 Mexican spotted owl protected activity centers and includes 

low-severity prescribed fire within 70 Mexican spotted owl protected activity centers, excluding 

54 core areas. Key components of the stakeholder-created Large Tree Retention Strategy are 

incorporated into the alternative’s implementation plan. No forest plan amendments are proposed 

on either forest. See chapter 2 of the FEIS for additional details. 

Actions Common to Alternatives B, C, D, and E

• Alternatives B through E propose additional actions including restoring springs and 

ephemeral channels, constructing protective fencing in select aspen stands, constructing (and 

decommissioning) temporary roads, reconstructing and improving roads, relocating a 

minimal number of road miles, and decommissioning existing roads and unauthorized routes 

(FEIS, table 1).

• On those acres proposed for prescribed fire, two fires would be conducted over the 10-year 

period. 

• Design features, best management practices (BMPs), and mitigation to be used as part of 

alternatives B through E are located in volume 2, appendix C of the FEIS. 

• All action alternatives include adaptive management actions that would be taken as needed to 

restore springs, ephemeral channels, and naturalize decommissioned and unauthorized roads 

(FEIS, table 16). Temporary roads would be decommissioned by the purchaser/contractor 

immediately after use using adaptive management actions (FEIS, chapter 2) and BMPs for 

the rehabilitation of ground-disturbed sites (FEIS, appendix C).

All these alternatives incorporate into each alternative’s design features key components of the 

Old Tree Retention Strategy (FEIS volume 2, appendix C), the implementation plan (FEIS 

volume 2, appendix D), and the adaptive management, biophysical and socioeconomic 

monitoring plan (FEIS volume 2, appendix E). The Forest Service worked collaboratively with 

stakeholders to develop the final monitoring and adaptive management and implementation plan. 

Appendix E also includes the Mexican spotted owl and Arizona bugbane monitoring plan as 

approved (through formal consultation) by the U.S. Fish and Wildlife Service. 

Decision 

Based on our review of the environmental analysis disclosed in the Four-Forest Restoration 

Initiative Coconino and Kaibab National Forests FEIS, forest plans, the project record, and in 

consideration of public comments received on the draft environmental impact statement, we have 

decided to implement alternative C (the “selected alternative”). One change to this alternative will 

be how approximately 3,300 acres of grasslands, savannas, and meadows are proposed for 

12 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

savanna treatments. These acres will instead be treated as described in alternative E, as analyzed 

in the FEIS (see the project record for additional information). 

In the selected alternative, the Coconino and Kaibab NFs will conduct restoration activities on 

approximately 586,110 acres over a period of 10 years or until objectives are met. On average, 

45,000 acres of vegetation will be mechanically treated annually. On average, 40,000 to 60,000 

acres of prescribed fire will be implemented annually across the Forests (within the treatment 

area). Up to two prescribed fires3

 will be conducted on all acres proposed for treatment over the 

10-year period. Table 1 displays treatment types and acres. Restoration activities will:

• Mechanically cut trees on approximately 430,261 acres. This includes: (1) mechanically 

treating trees up to 17.9 inches d.b.h. within 18 Mexican spotted owl protected activity 

centers, and (2) using low-severity prescribed fire within 70 Mexican spotted owl protected 

activity centers (including 54 core areas). 

• Apply prescribed fire on approximately 430,261 acres where mechanical treatment occurs. 

• Use prescribed fire only (no mechanical treatment) on approximately 155,849 acres.

• Construct approximately 520 miles of temporary roads for haul access and decommission the 

roads when treatments are complete (no new permanent roads will be constructed). 

• Reconstruct up to 40 miles of existing, open roads for resource and safety concerns (no new 

permanent roads will be constructed). Of these miles, approximately 30 miles will be 

improved to allow for haul (primarily widening corners to improve turn radiuses) and about 

10 miles of road would be relocated out of stream bottoms. Relocated roads will include 

rehabilitation of the moved road segment. 

• Decommission 726 miles of existing system and unauthorized roads on the Coconino NF. 

• Decommission 134 miles of unauthorized roads on the Kaibab NF. 

• Restore 74 springs and construct up to 4 miles of protective fencing. 

• Restore 39 miles of ephemeral channels.

• Construct up to 82 miles of protective (aspen) fencing. 

• Construct up to 12 flumes and 12 weather stations and associated instrumentation (up to 3 

total acres of soil disturbance) to support the paired watershed study research.

• Allocate and manage as old growth 40 percent of ponderosa pine and 77 percent of pinyonjuniper woodland on the Coconino NF 

• Manage and develop uneven-aged stands with a representation of old growth components 

across most of the project area on the Kaibab NF.

3 A single prescribed fire may include burning piles and a follow-up broadcast burn. Prescribed fire would be 

implemented as indicated by monitoring data to augment wildfire acres, with the expectation that desired conditions 

would require a fire return interval of about 10 years.

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 13

 
Draft Record of Decision

Table 1. Selected Alternative mechanical and prescribed fire treatment description and acres

Treatment Type Treatment Description/Objective Acres

Aspen Mechanical treatment that removes post-settlement 

conifers within 100 feet of aspen clone; stimulates 

suckering. Accompanied by prescribed fire.

1,227

Prescribed Fire Only Prescribed fire would be applied exclusively to move 

treated areas towards desired vegetation conditions.

155,849

AZ Game & Fish Research Mechanical treatment designed to create groups of 

various sizes ranging from 1 to 15 acres in size. 

Accompanied by prescribed fire.

4,837

Grassland Restoration Mechanical treatment that removes encroaching postsettlement conifers and manages for up to 90 percent of 

the treatment area as grass/forb/shrub using presettlement tree evidence as guidance. Accompanied by 

prescribed fire.

11,230

Grassland Mechanical Mechanical treatment in grassland vegetation types. 

Accompanied by prescribed fire.

48,161

Intermediate Thin (IT) 10 

(10 to 25% interspace)

IT 25 

25 to 40% interspace)

IT 40 

(40 to 55% interspace)

Mechanical treatment that thins tree groups and 

establishes interspace adjacent to tree groups to an 

average of 70 to 90 square feet of basal area and 

manages for improved tree vigor and growth by retaining 

the best growing dominant and co-dominant trees with 

the least amount of mistletoe; Interspace would occupy 

10 to 55 percent of the treatment area, respectively. 

Accompanied by prescribed fire.

7,565

11,871

38,642

Mexican spotted owl (MSO) 

Threshold

Same as MSO Target (below) 1,892

MSO Target Intermediate thinning designed to improve forest health, 

reduce fire risk, and meet forest density, structure, and 

species composition requirements. Accompanied by 

prescribed fire.

6,495

MSO Restricted Uneven-aged mechanical treatment designed to develop 

uneven-aged structure, irregular tree spacing, a mosaic of 

interspaces and tree groups of varying sizes. 

Accompanied by prescribed fire.

62,785

MSO PAC Mechanical treatment designed to increase tree vigor and 

health and create canopy gaps to reduce fire risk. 

Accompanied by prescribed fire.

10,284

MSO PAC Grassland 

Mechanical

Mechanical treatment designed to reestablish the historic 

meadow edge as defined by the current forest structure of 

young trees encroaching around the meadow edge; 

Retain large trees with long-lived characteristics. 

Accompanied by prescribed fire.

35

Pine-sage Mechanical treatment that restores pre-settlement tree 

density and pattern using pre-settlement tree evidence as 

guidance. Accompanied by prescribed fire.

5,261

Savanna 

(70 to 90% interspace)

Mechanical treatment that restores presettlement tree 

density and pattern, and manages for a range of 70 to 90 

percent of the treatment area as interspace (grass/forb) 

between tree groups or individual trees using presettlement tree evidence as guidance. Treatment would 

be accompanied by prescribed fire.

41,839

14 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Treatment Type Treatment Description/Objective Acres

Stand Improvement (SI) 10

(10 to 25% interspace)

SI 25 

(25 to 40% interspace)

SI 40 

(40 to 55% interspace)

Mechanical treatment that establishes tree groups and 

interspace adjacent to tree groups and manages for 

improved tree vigor and growth by retaining the best 

growing dominant and co-dominant trees within each 

group; Interspace would occupy 10 to 55 percent of the 

treatment area, respectively. Treatments would be 

accompanied by prescribed fire.

1,914

6,618

12,270

Uneven-aged (UEA) 10

(10 to 25% interspace)

Uneven-aged mechanical treatment designed to develop 

uneven-aged structure, and a mosaic of interspaces and 

tree groups of varying sizes. Interspace would occupy 10 

to 25 percent of the treatment area. Accompanied by 

prescribed fire.

17,865

UEA 25

(25 to 40% interspace)

Uneven-aged mechanical treatment designed to develop 

uneven-aged structure, and a mosaic of interspaces and 

tree groups of varying sizes. Interspace would occupy 25 

to 40 percent of the treatment area. Accompanied by 

prescribed fire.

38,492

UEA 40 

(40 to 55% interspace)

Uneven-aged mechanical treatment designed to develop 

uneven-aged structure, and a mosaic of interspaces and 

tree groups of varying sizes. Interspace would occupy 40 

to 55 percent of the treatment area. Accompanied by 

prescribed fire.

98,219

Wildland Urban Interface 

Pinyon-juniper

Mechanical treatment around the community of Tusayan 

designed to reduce fire risk and meet Community 

Wildfire Protection Plan objectives. Accompanied by 

prescribed fire. 

535

Wildland-urban Interface

(55 to 70% interspace)

Uneven-aged mechanical treatment designed to develop 

uneven-aged structure, and a mosaic of interspaces and 

tree groups of varying sizes. Interspace would occupy 55 

to 70 percent of the treatment area. Accompanied by 

prescribed fire.

2,224

Paired Watershed Study 2,300 acres of control watersheds and infrastructure (50 

ft. high towers with no guy lines, snow pillows, 12 

flumes and 12 weather stations and associated 

instrumentation) to evaluate how restoration affects 

water yield and carbon. No fire treatments for 5 to 7 

years in control watersheds. 

Up to 3

No forest plan amendments will be needed on the Kaibab NF. The proposed actions are consistent 

with forest plan objectives, desired conditions, and standards and guidelines (FEIS, chapter 2, 

Forest Plan Consistency). Three nonsignificant forest plan amendments will be required on the 

Coconino NF to implement the selected alternative. 

Amendment 1: The purpose of amendment 1 is to bring the selected alternative in alignment 

with the revised Mexican spotted owl Recovery Plan and defer monitoring to the U.S. Fish and 

Wildlife Service biological opinion that is specific to this project.

Amendment 1 will allow mechanical treatments up to 17.9 inches d.b.h. to improve habitat 

structure (nesting and roosting habitat) in 18 Mexican spotted owl protected activity centers 

(PACs). These PACs will be managed for a minimum basal area of 110. Low-intensity prescribed 

fire will be allowed within 54 Mexican spotted owl PAC core areas. The amendment removes 

language that limits PAC treatments in the recovery unit to 10 percent increments, and the 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 15
Draft Record of Decision

selection of an equal number of untreated PACs as controls. Language referencing pre- and posttreatment population and habitat monitoring will be removed. The language noted above has been 

removed because it is direction from the former (1995) Mexican Spotted Owl Recovery Plan and 

is not consistent with the 2012 revised Recovery Plan. Monitoring requirements from the U.S. 

Fish and Wildlife Service biological opinion that is specific to this project is in appendix E of the 

FEIS. Definitions of target and threshold habitat will be added, and approximately 6,299 acres of 

restricted target and threshold habitat will be managed for a minimum range of 110 to 150 basal 

area for the purposes of being in alignment with the revised Mexican Spotted Owl Recovery Plan 

(USDI FWS 2012), and to improve Mexican spotted owl habitat. 

Amendment 2 clarifies existing Coconino NF forest plan direction related to managing canopy 

cover and interspace. The purpose of the amendment is to bring the project into alignment with 

the best available science (Reynolds et al. 2013) that provides desired conditions for restoring 

fire-adapted ponderosa pine in the Southwest. The forest plan directs projects to measure “vertical 

crown projection on average across the landscape” (see Coconino National Forest plan, page 65-

9). Whereas the forest plan clearly provides direction for meeting minimum canopy cover 

percentages in vegetation structural stage (VSS) 4 to 6, the plans lack explicit language for 

measuring canopy cover. Although the forest plan provides direction and desired conditions for 

the vegetation structural stages, the forest plan does not describe the relationship between nonforested areas (interspace) and natural openings across the landscape. 

Amendment 2 will add the desired percentage of interspace within uneven-aged stands to 

facilitate restoration in goshawk habitat (excluding nest areas), add the interspace distance 

between tree groups, add language clarifying where canopy cover is and is not measured, allow 

28,653 acres to be managed for an open reference condition, and add a definition to the forest 

plan glossary for the terms interspaces, open reference condition, and stands. 

An exception to this amendment applies to about 38,260 acres of goshawk habitat. In response to 

feedback and comments received on treating less aggressively and leaving more large trees, 

canopy cover will be measured at the stand level on about 38,260 acres of goshawk habitat where 

there is a preponderance of VSS 4, 5 and 6. Because the existing plan is silent on measurement of 

canopy cover, these acres can be managed in this manner under the existing forest plan.

Amendment 3 resolves a forest plan error related to the management of heritage resources and is 

specific to this project. Amendment 3 will remove the cultural resource standard that requires 

achieving a “no effect” determination and will add the words “or no adverse effect” to the 

remaining standard. In effect, management will strive to achieve a “no effect” or “no adverse 

effect” determination.

As the deciding official for the Coconino National Forest, I, M. Earl Stewart, have decided to 

amend the Coconino NF forest plan as described above and in appendix B of the FEIS. The 

amendments update the forest plan with best available science related to the composition, 

structure, landscape pattern and characteristic natural disturbances in ponderosa pine in 

southwestern forests (Reynolds et al. 2013). 

We have decided that appendices A through E are integral to the selected alternative. They will be 

edited to only reflect the selected alternative (as needed) and posted to the project website with 

the final ROD and FEIS. The content of the appendices include the following: 

16 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Appendix A: Map Packet 

Appendix B: Coconino NF Forest Plan Amendments (described above). 

Appendix C: Design Features, Mitigation Measures and Best Management Practices. All 

project design features, mitigation measures, and best management practices that apply to this 

decision are included in appendix C of this draft decision. These features are intended to avoid, 

minimize, reduce, and eliminate project impacts. 

Appendix D: Implementation Plan. The process described in this appendix describes the 

linkage from the FEIS to the project-specific work without the need for additional NEPA 

analysis (above and beyond this environmental analysis). It must be considered in conjunction 

with appendix B, which provides the design criteria, best management practices, and mitigation 

measures. The implementation plan is comprised of several checklists including the Annual 

Implementation Checklist; Planned Acres by Treatment Type and Restoration Unit (RU); 

compliance evaluation with the National Environmental Policy Act, National Forest 

Management Act, Endangered Species Act, and Collaborative Forest Landscape Restoration 

Act; and Supporting Documentation. The implementation plan includes several sections 

designed to guide project implementation: 

Section A includes existing forest plan management direction, desired conditions, and 

treatment specific silvicultural design. It is designed to be used by the project 

silviculturist and implementation team.

Section B is a decision matrix to be used by the project silviculturist and implementation 

team to facilitate establishing tree groups, interspace, and regeneration openings as 

appropriate for each individual treatment.

Section C provides old tree descriptions, illustrations, and guidance used to implement 

the old tree implementation plan.

Section D includes guidance and the “Modified Large Tree Implementation Plan.” The 

guidance is designed to be reviewed by the project’s silviculturist during the development 

of prescriptions and during implementation. 

Section E describes the relationship between treatment intensity, tree group density, and 

overall average density. It includes density management and stocking guidelines. It is 

designed to be used by the project silviculturist (in the design of prescriptions) and 

implementation team.

Appendix E: Four-Forest Initiative Adaptive Management, Biophysical and 

Socioeconomic Monitoring Plan. We considered input from the 4FRI stakeholders and public 

comments when developing this monitoring and adaptive management plan, with the intent of 

integrating it into this draft decision and implementing it within the entire 4FRI project. 

Appendix E also includes the monitoring plan for Mexican spotted owl, Arizona bugbane, and 

the adaptive management plan for roads, springs and ephemeral channels. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 17
Draft Record of Decision

Rationale for Our Decision

Our decision is based on compliance with law, regulation and policy, consultation with 

cooperating and regulatory agencies, consultation with interested tribes, and review of the project 

record. We have thoroughly examined relevant scientific information and acknowledge

incomplete or unavailable information (such as mercury in prescribed fire emissions), scientific 

uncertainty, and risk (to species such as the Mexican spotted owl). We have considered input from 

stakeholders, groups, and individuals (including opposing views) and summarized their 

comments (by topic) in the FEIS, appendix I, “Response to Comments on the Draft 

Environmental Impact Statement.” Complete, individual responses are located in the project 

record. 

We believe the selected alternative best meets the purpose and need of the project by identifying a 

combination of restoration treatments that will put almost 600,000 acres on a trajectory toward 

increased resiliency and sustainability. The key difference in the selected alternative when 

compared to the other alternatives is the ability to restore ecosystem function on over 50,000 

acres of encroached and historic grasslands and ponderosa pine to create an open reference 

condition. The selected alternative treats Mexican spotted owl habitat in alignment with the 

revised 2012 Mexican Spotted Owl Recovery Plan. In this analysis, all ponderosa pine is 

managed as habitat for either Mexican spotted owl or goshawk and their prey species. With the 

exception of specific Mexican spotted owl habitat types (nest cores, protected activity centers, 

and forested recovery habitat managed as nest/roost habitat), the selected alternative moves the 

landscape towards the natural range of variability for ponderosa pine on all sites where 

mechanical and prescribed fire treatments will occur. The selected alternative incorporates old 

tree and large young tree direction that will guide implementation. This decision authorizes two 

important research studies that will inform future restoration projects. We expect these studies to 

yield valuable information on how small mammals and water storage can be affected by 

landscape-scale treatments. 

Throughout this analysis, the issue of conserving large trees has been recognized. A Large And 

Old Tree Implementation Plan was developed (FEIS, appendix D) that will conserve these 

features on the landscape. This decision responds to feedback and comments received on treating 

less aggressively and leaving more large trees, and modifies how canopy cover is measured on 

about 38,260 acres where there is a preponderance of VSS 4, 5 and 6.4 Treatment design criteria 

include managing residual stand structure at the upper end of the natural range of variation by 

varying the intensity of treatments in these stands. This modification remains consistent with the 

implementation plan that displays the need for heterogeneity in group sizes and treatment 

intensity (FEIS, appendix D) and is consistent with the desired conditions to retain large trees 

currently underrepresented on the landscape (FEIS, chapter 2).

The decision to treat approximately 38,260 acres less intensively is based upon clarified 

comments from stakeholders concerning large tree retention, the heterogeneity of group sizes, and 

canopy cover. The process of assessing options and analyzing comments took approximately 

seven months, due to the difficulty in finding the balance between various treatment options that

supply additional canopy cover and set the stands on a trajectory toward forest resiliency, in 

addition to retaining forest canopy cover and additional larger diameter trees. The acres 

considered for less intensive treatments were reduced, following data review and on-the-ground 

assessments, to those areas outside of the wildland-urban interface (one-half-mile buffer on 

private land; see project record).

4 mid-age, mature and old forest vegetation structural stages

18 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 

 
Draft Record of Decision

Public comments and dialogue on the modified treatment strategy originally included topics such 

as the implications of temporary road construction, road placement, treatment type, treatment 

intensity, treatment locations, and overall treatment acreage. Dialogue with stakeholders clarified 

that the principal issue was the retention of canopy cover for goshawk habitat and the retention of 

more large-diameter trees, especially in areas where human populations and infrastructure were 

less likely to be harmed or damaged by high-severity fire. Although the original area of concern 

spanned more than 74,000 acres, geographic data review and on-site assessments led to a 

reduction of this area to approximately 38,620 acres. The method used to determine the resultant 

38,260 acres is described in the project record.

This decision includes changes to the selected alternative’s treatment of about 3,300 acres of 

grasslands, savannas, and meadows, also in response to public comment. These acres were 

proposed and analyzed for savanna treatments in alternative C, managed for 70 to 90 percent 

interspace with mechanical treatments and prescribed fire. These acres will instead be treated as 

proposed and analyzed in alternative E, with mechanical treatments designed to preserve VSS 4, 

5, and 6 trees and to maintain 70 to 90 square feet of basal area, and using prescribed fire. This 

change affects approximately 1 percent of acres that will be mechanically treated in this project 

and is consistent with the implementation plan (FEIS, appendix D) and the desired conditions to 

retain large trees that are currently underrepresented on the landscape (FEIS, chapter 1). These 

stands will still move toward the desired conditions for savanna, particularly with the use of 

prescribed fire, but at a slower pace than originally proposed. Changing the treatments in these 

stands will result in:

• An increase in stand density, an increase in canopy cover, a reduction in grass/forb response 

around groups, movement from a very open structure to an open or moderately closed

structure, and an increase in group size. 

• Leaving more closed canopy conditions on these 3,300 acres, which will increase the 

potential for future crown fire on approximately 100 acres. 

• No likely increase in old growth, as existing design features call for retaining all 

presettlement trees (FEIS, appendix C and D). Moving these acres of savanna habitat towards 

desired conditions rather than attaining pre-settlement conditions could affect individual 

species in these stands, but would not make a difference to wildlife populations at the 

landscape scale.

How Well the Selected Alternative Responds to

Issues, Concerns and the Project Purpose and Need

Prescribed Fire Emissions (Issue 1): This issue relates to the emissions from prescribed fire 

activities and the impact on air and water quality, public health, quality of life, and the economy 

of northern Arizona.

In response to the concern over emissions from prescribed fire, alternative D was developed. 

Alternative D decreased the acres that would receive prescribed fire by 69 percent or 404,889 

acres when compared to alternative B, the proposed action (FEIS, chapter 2). An alternative that 

would eliminate all prescribed fire was considered but eliminated from detailed study as it would

not adequately meet the purpose and need for restoring the fire-adapted southwestern ponderosa 

pine ecosystem (FEIS, chapter 2). 

In response to comments on the DEIS, discussion on potential emissions was expanded to include 

radionuclide particles and mercury. Emission experts at the Environmental Protection Agency 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 19
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(EPA, Region 9), the Forest Service liaison to the Arizona Department of Environmental Quality 

(ADEQ), and the Agency’s Washington Office were contacted to consider the best available 

information (see fire ecology report and project record). 

Communication with the EPA subject matter experts and studies that address radioactive isotope 

emissions (Schollnberger et al. 2002) indicate that radioactive isotopes and other undesirable 

chemicals will be present in wildfire emissions. Some are naturally occurring chemicals that have 

always been present at some level in wildfire smoke and some have resulted from the weapons 

testing that occurred in the mid-20th century. At the level of exposure the public is subjected to, 

radionuclides do not pose as great a risk from wildfire. Radioactive material that may be carried 

in the smoke plume carries a risk of human health concerns of less than 1 chance in 10 million 

(NMED 2002, Graham 2012a) and the greatest health risk is from breathing high concentrations 

of particulate matter in the smoke.

After reviewing available literature and consulting with subject matter experts on the potential for 

mercury emissions from prescribed fire, we have concluded there is incomplete and unavailable 

information relevant to determining reasonably foreseeable adverse impacts to the human 

environment as directed by CEQ Sec. 1502.22 (b). (See FEIS, air quality analysis).

The water quality analysis evaluated the potential for mercury to affect the Lake Mary watershed. 

The Lake Mary total maximum daily load (TMDL) indicates the major source of mercury in the 

Lake Mary Region is atmospheric deposition, with some mercury originating from natural 

geologic materials (primarily from volcanic activity). The analysis concludes that best 

management practices (see FEIS appendix B, fire ecology, soil and water and transportation 

design criteria) will minimize or mitigate potential for mercury to be mobilized in sediment and 

delivered to water bodies (see water quality and riparian areas report).

From a quality of life perspective, smoke emissions will be inevitable, whether from prescribed 

burns that will result from this decision or from wildfire. The air quality analysis finds the 

selected alternative will result in the least emissions (approximately 31,000 pounds per acre) 

when compared to the no action alternative where emissions from wildfire would approach 

80,000 pounds per acre. Once treatments are complete, the emissions from wildfire are projected 

to be slightly greater than 50,000 pounds per acre, a significant reduction when compared to the 

no treatment scenario (FEIS chapter 3, “Air Quality” section). 

Although emissions will occur as a result of this decision, the degree (intensity and duration) of 

emissions will be variable. The selected alternative includes design features and ADEQ emission 

reduction techniques (FEIS, Appendix B, FE3, FE8, FE9 and FE15) to minimize adverse effects 

to quality of life in nearby communities. We will work with ADEQ to ensure that smoke impacts 

to human health are avoided or minimized to the degree possible. 

Alternative A does not respond to the purpose and need or resolve this issue (see previous 

discussion). Although alternatives B and E would reduce prescribed fire emissions, it comes at an 

unacceptable tradeoff. The alternatives do not maximize the restoration of historic grasslands and 

pine with an open reference condition. Alternative D would partially address the issue and reduce 

prescribed fire emissions but it does not meet the objective of returning fire to the fire-adapted 

ponderosa pine ecosystem. Approximately 69 percent of the project area would not receive 

prescribed fire benefits that are necessary to increase resiliency, function and sustainability in 

ponderosa pine. 

20 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
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Issue 1 remains unresolved in that a segment of the public does not support the use of prescribed 

fire.

Conservation of Large Trees (Issue 2): This issue focuses on the conservation of large trees and 

the inclusion of the large tree retention strategy (LTRS), which was developed by the 4FRI 

stakeholders (4FRI stakeholders 2011). 

We carefully considered comments received on the DEIS and developed additional guidance in 

the FEIS to document how restoration activities will emphasize large tree retention and meet 

desired conditions. In response to comments on the DEIS, the purpose and need was revised to 

include a large tree section (FEIS, chapter 1). The large tree section discloses that large trees 

(VSS 5 and 6) are currently underrepresented within the project area and the desired condition is 

to balance community, wildlife, and forest restoration into treatment design. 

The selected alternative includes a Large Tree Implementation Plan (FEIS, appendix D). Overall, 

the selected alternative will increase large tree size classes. The silvicultural analysis indicates 

Mexican spotted owl habitat will meet or exceed desired minimums in trees in the 18- to 24-inch 

size classes by 2020 (FEIS chapter 3, “Vegetation” section). In the mechanically treated PACs, 

trees greater than 24 inches d.b.h. will show consistent improvement (FEIS chapter 3, Mexican 

spotted owl analysis). Because treatments in the mechanically treated PACs are site-specific and 

target the release of big trees from competition with young trees, the ability to retain existing 

large trees through time will also increase (FEIS, chapter 3 and wildlife report). In the short term, 

Mexican spotted owl restricted-other habitat trees greater than 24 inches d.b.h. would be well 

represented. In target/threshold habitat, this size class would continue to be underrepresented. By 

2050 this size class will exceed the desired minimum in Mexican spotted owl restricted other 

habitat (FEIS chapter 3, “Vegetation” section).

The goshawk analysis (FEIS chapter 3, vegetation) indicates the largest size classes (VSS 6) will 

still be underrepresented in all goshawk habitats. There will be good representation of VSS 5 in 

all landscapes outside of post-fledging family area (LOPFA) habitats but VSS 5 will be underrepresented in post-family fledging areas (PFAs). The silvicultural analysis concludes the project 

has been designed to manage for old age trees in order to have and sustain as much large tree and 

old forest structure as possible across the landscape. 

We acknowledge that while some large trees may be removed to accomplish ecological objectives 

or public safety objectives around communities, there is a need to retain as many large trees 

(larger than 16 inches d.b.h.) as possible. The FEIS and this decision acknowledge that large trees 

(VSS 5 and VSS 6) are underrepresented within the project area. The FEIS (chapter 1) 

acknowledges the need to recognize the rarity and ecological and socio-political importance of 

large trees in the Southwest. This decision includes a process (FEIS, appendix D) that addresses 

large tree retention during project implementation. The implementation plan provides guidance 

on how to conserve and promote large (young) trees in order to increase age classes that are 

underrepresented (while moving towards the desired condition of having uneven-aged forest 

conditions). 

In addition, the implementation plan (FEIS, appendix D) now emphasizes that when outside of 

the wildland-urban interface, restoration treatments in goshawk habitat (approximately 38,260 

acres) will focus on the removal of small-diameter trees and will emphasize retaining large trees 

where applicable to move toward deficit stand structure. This will be accomplished by placing an 

emphasis on creating regeneration openings and interspace in areas where smaller VSS 3 and 

VSS 4 trees dominate. The placement of tree groups to be retained will focus on areas where the 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 21
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largest trees are already aggregated. These groups will generally range between 0.25 and 1 acre in 

size. This will result in stands being composed of groups of larger trees intermixed with relatively 

small openings. In stands with a preponderance of large young trees the treatment intensity will 

be managed to the lower end of the available spectrum. Management in these stands still 

recognizes the need to create regeneration openings to be able to promote uneven-aged stand 

conditions. 

The selected alternative also recognizes that, within the savanna treatment acres, there are some 

stands that contain a preponderance of large, young trees. On the 3,300 acres where this occurs, 

we have decided to use the treatments proposed in alternative E that will retain large trees and not 

implement savanna treatments on these acres. 

Alternative A was not selected because it does not respond to the purpose and need. Without 

increasing resiliency and function, moving into the larger tree classes, and, protecting those larger 

tree classes would not be possible. In the 18 Mexican spotted owl PACS that are mechanically 

treated, alternatives B, D, and E would move toward desired conditions in the larger tree size 

classes, but not to the degree as the selected alternative (see wildlife report, table 136). In 

addition, in alternative D only 18 of 70 PACs would have habitat improvements and only 2 

percent of protected habitat would see a reduction of surface fuels as a result of prescribed fire in 

protected (steep slope) habitat. The risk to nesting and roosting habitat (including large trees) 

would remain high given the limited changes in fire behavior within protected habitat and outside 

Mexican spotted owl habitat. In alternative E, although PAC treatments would be site-specific to 

target the release of big trees from competition with young trees, the inability to treat trees 9 to 18 

inches d.b.h. would limit treatment effectiveness. Therefore, no response would be evident in 

trees greater than 24 inches d.b.h. (see wildlife report, “Environmental Consequences” section). 

In goshawk habitat, movement toward desired conditions in the larger tree size classes in 

alternatives B and E would be similar to the selected alternative. However, in goshawk PFA and 

dispersal PFA (dPFA) habitat, alternative E would increase the percent of trees in trees greater 

than 18 inches but not to the degree that the selected alternative will (see FEIS, table 35, evenaged LOPFA VSS 6, 2050). In alternative D there would be slightly less increase in VSS 5 and 6, 

or acres of large trees, due to the continued dense conditions of VSS 3 and 4 size trees occupying 

the majority of the area due to the lack of prescribed burning in alternative D. 

Although this decision provides guidance on how to conserve and promote large, young trees 

during implementation, any cutting of large, young trees is likely to be controversial with those 

people who believe no large, young trees should be cut. 

Post-treatment Canopy Cover and Landscape Openness (Issue 3): This issue focuses on 

retaining closed canopy conditions for species including, but not limited to, goshawk and 

Mexican spotted owl. 

Goshawk: Commenters stated measuring canopy cover in goshawk habitat at the group level 

would not meet forest plan stand-scale canopy requirements. This issue was addressed in the 

selected alternative through treatment design in PFA and dPFAs, and in LOPFA. 

In PFA and dPFA habitat we find that the heterogeneity (percent of openness) of the habitat will 

increase while maintaining interlocking or nearly interlocking tree crowns. Approximately 44 

percent of PFA and dPFA habitat will have closed to moderately closed canopies (FEIS, table 35 

and wildlife report, table 161). In goshawk LOPFA, 26 percent of the habitat will have closed to 

moderately closed canopies (FEIS, table 35 and wildlife report, table 161). In all habitats, the 

22 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
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silvicultural analysis (FEIS, chapter 3) found that residual tree group density will meet and 

exceed the canopy cover requirements in VSS 4 to VSS 6 (Coconino NF forest plan) and desired 

conditions (revised Kaibab NF forest plan). 

In PFA/dPFA prey habitat, the selected alternative provides the most increase in the average 

pounds per acre of understory biomass. Biomass increases from the current condition of 58 

average pounds per acre to 113 average pounder per acre aby 2020 (FEIS, table 35). In goshawk 

LOPFA prey habitat, the selected alternative increases understory biomass to 149 average pounds 

per acre by 2020. This will improve cover and food for birds and mammals preyed upon by 

goshawks as well as the invertebrates that are an important food source for goshawk prey. The 

understory response favor conditions conducive to the spread of low severity fire rather than 

crown fire. In all alternatives, understory response decreases as regrowth occurs.

In all goshawk habitat, the primary benefits from the changes in forest structure are that the risks 

of large scale loss of habitat from disturbances such uncharacteristic fire, bark beetles, and 

density-related mortality will be reduced. The selected alternative reduces fire risks, increases 

openness, and decreases risks from insects and diseases over longer periods. The selected 

alternative maintains composition, form, and structure as natural fire occurrences are reintroduced 

(FEIS chapter 3, goshawk analysis). 

Treatments in goshawk habitat will be implemented using stocking guidelines that will maintain 

interlocking or nearly interlocking tree crowns. Tree group density will meet and exceed the 

canopy cover requirements (Coconino NF only) and desired conditions (Kaibab NF). In response 

to questions raised and comments made on the DEIS about treating less aggressively and leaving 

more large trees, canopy cover will be measured at the stand level on about 38,260 acres where 

there is a preponderance of VSS 4, 5 and 6. The environmental analysis (FEIS, chapter 3) 

indicates that this modification will result in movement towards desired conditions. Although 

canopy cover desired conditions and requirements will be met, the retention of adequate canopy 

cover and closed canopies likely remains controversial with those publics who believe the posttreatment condition will be too open. 

There may be some changes to goshawk habitat due to the changes in treatment on about 3,300 

acres of savanna. With the focus on retaining all VSS 4, 5 and 6 (except where public health and 

safety issues exist), these stands will retain components of goshawk habitat but will decrease food 

and cover for many goshawk prey species. These changes will affect about 1 percent of the total 

goshawk habitat being treated in the project area. Overall, these combined effects will not affect 

goshawk populations in the project area (see project record).

Alternative A was not selected because it would not improve habitat quality, resiliency and 

sustainability. In all goshawk habitat, no action results in the habitat being at highest risk of 

increasing densities, increased fire risk, and increased to insect and disease risk. These results are 

contrary to forest structure, forest health, and resiliency and function desired conditions (FEIS, 

chapter 3, goshawk analysis). See the “Conservation of Large Trees” (Issue 2) section on page 5

for the discussion on how the alternatives move towards large tree desired conditions. 

Of all the alternatives besides no action, alternative D provides the least movement towards 

vegetation composition and diversity, resiliency, and sustainability desired conditions. In all 

goshawk PFA/dPFA, this alternative would result in a higher stand density index (SDI) when 

compared to the selected alternative and will approach the “extremely high density” category by 

2050. In goshawk LOPFA, the SDI remains in the “high density” category throughout the short 

term whereas the selected alternative moves to the high end of “moderate density”. This means 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 23
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the habitat, particularly PFA/dPFA, would continue to lack resiliency and sustainability, contrary 

to desired conditions for forest structure, forest health, and resiliency and function (FEIS, table 

35). 

Alternative D also provides the least improvement to understory biomass in goshawk PFA and 

dPFA by 2050 (57 pounds per acre) and degrades it below the current condition (58 pounds per 

acre), contrary to the purpose and need for vegetation composition and diversity. In LOPFA 

habitat, understory biomass by 2050 of 75 pounds per acre is comparable to the other alternatives 

but is still much less than the selected alternative (89 pounds per acre). Alternative D is the only 

action alternative where at least 30 percent of the habitat would return to fire regime condition 

class 3, contrary to the purpose and need (FEIS, table 35). 

Alternative E provides less movement towards vegetation composition and diversity, resiliency, 

and sustainability desired conditions in comparison to the selected alternative. In PFA/dPFA, 

alternative E provides less improvement to understory biomass (forage) in both the short term 

(109 pounds per acre) and long term (66 pounds per acre). In LOPFA, the trend is similar. In 

goshawk LOPFA, the SDI in the selected alternative will decrease to the high end of “moderate 

density” in the short term whereas in alternative E the SDI would remain in the “high density” 

category (FEIS, table 35). 

Although canopy cover desired conditions and requirements will be met, the retention of adequate 

canopy cover and closed canopies likely remains controversial with those people who believe the 

post-treatment condition will be too open. 

Mexican spotted owl: There was a concern that treatments would reduce or remove closed 

canopy conditions and leave Mexican spotted owl habitat too open. This issue was addressed 

through treatment design. In Mexican spotted owl protected habitat, treatments were specifically 

designed to improve habitat while retaining the closed overstory structure. 

The selected alternative best addresses this issue because after treatments, over 90 percent of 

Mexican spotted owl protected habitat canopy will be closed or moderately closed. By 2020 the 

selected alternative will reduce the potential for stand density-related mortality (FEIS, chapter 3, 

vegetation and Mexican spotted owl analyses). Although protected habitat will remain in the 

“extreme high [tree] density” category, the stand density index (SDI max) nearly achieves a “high 

density” ranking. While the change in overstory is limited, site-specific implementation will 

emphasize releasing5

 large old pine and oak trees. Modeling to the year 2050 illustrates an 

increase in tree growth rates for the largest d.b.h. size classes (also see the issue 2 discussion). In 

restricted habitat, current nesting and roosting habitat characteristics will be maintained, and

future nesting and roosting habitat will be developed. There will also be an increase in the quality 

of foraging habitat. 

The Mexican spotted owl analysis found that the selected alternative will best restore and enhance 

prey habitat. This is expected to benefit Mexican spotted owl and their prey in the short and longterm (Kalies et al. 2012, Ganey et al. 2011). After treatment, Mexican spotted owl protected 

habitat will still have the highest surface fuel loading within the project area. This reflects the 

low-intensity nature of the treatments. However, the risk of having crown fire enter PACs will be 

reduced. The fire analysis indicates the potential for crown fire outside of Mexican spotted owl

protected habitat will be less than 10 percent (FEIS, chapter 3, fire ecology analysis). However, if 

a fire starts within the PAC, it may still result in high severity effects (within the PAC). We find 

5 Cutting trees around a tree to reduce competition for water, nutrients and sunlight.

24 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 

 
Draft Record of Decision

that treatments that are part of the selected alternative are most aligned with objectives in the 

revised Mexican Spotted Owl Recovery Plan (USDI FWS 2012). Overall, there is potential for 

short-term adverse effects to owls, primarily from disturbance to individual birds. However, longterm effects of the project should be beneficial to the Mexican spotted owl population by 

enhancing key habitat components for them (especially the improved stand characteristics and 

resiliency in nesting and roosting habitat) and their prey (e.g., canopy gap openings, aspen, 

meadows, springs). The likelihood of maintaining Mexican spotted owl habitat into the future is 

also enhanced by reducing the predicted risks from climate change-induced changes to 

temperature and precipitation patterns and their synergistic effects with insects, disease, and risk 

of high-severity fire (Noble 2014). 

Alternative A was not selected because it would not improve the quality or quantity of Mexican 

spotted owl protected habitat. At the landscape scale, alternative A moves the project area away 

from desired conditions. It would be at highest risk of increased densities, increased fire risk, 

increased insects and diseases, and increased risks to PACs. While alternative B would reduce 

densities, reduce fire risks, increase openness, and decrease risks from insects and diseases over 

longer periods, it is not as aligned with the revised Mexican Spotted Owl Recovery Plan as the 

selected alternative is. Alternative D would move the project towards the desired condition but 

would leave treated areas at higher risks to high severity fire, contrary to the purpose and need. 

Alternative D is the only alternative besides no action where at least 30 percent of the habitat 

would return to fire regime condition class 3, contrary to the purpose and need. In the long term 

(2050), residual basal areas would be excessive (165 basal area). 

In alternative E, without the ability to apply a forest plan amendment, treatment effectiveness 

would be constrained by following direction from the former Mexican Spotted Owl Recovery 

Plan on the Coconino NF and residual basal areas would remain much higher (153 to 172) than 

recommended, resembling no action and its inability to maintain Mexican spotted owl habitat in 

the long term. Alternative E would result in the least increase in trees 24 inches d.b.h. and greater. 

This is contrary to the purpose and need. The lack of mechanical treatments in PACs would 

maintain current conditions in nesting and roosting habitat and result in the loss of large trees and 

habitat heterogeneity. The selected alternative will allow effective treatments to occur in all 

Mexican spotted owl habitats. Habitat diversity benefits include sustaining Gambel oak, recreating meadows, releasing and regenerating aspen, restoring springs, and increasing grass and 

forb cover. Also see the “Conservation of Large Trees (Issue 2) section on page 5 for more 

discussion on how the alternatives move towards large tree desired conditions. 

Resiliency, Function and Sustainability (Purpose and Need, Issue 4, Increased Restoration 

and Research): A primary objective for this project is to increase resiliency, function and 

sustainability in ponderosa pine (FEIS, chapter 1). Issue 4 relates to this topic because 

commenters requested an increase in restoration treatments that would increase resiliency and 

function. 

The question of whether the selected alternative will result in enough movement towards the 

natural range of variability (NRV) was considered throughout the analysis. The selected 

alternative responded to issue 4 by substantially increasing the acres of grassland and savanna 

treatments, increasing the type and acres of treatment in Mexican spotted owl habitat, and 

including small mammal (AGFD treatments) and watershed research. 

In response to comments on the DEIS, an analysis of how each alternative moves towards NRV 

was included in the FEIS. In the selected alternative, forest attributes (e.g., trees per acre, basal 

area) will be within the NRV except for Mexican spotted owl PACs, goshawk nest areas, and 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 25
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Mexican spotted owl target threshold habitats. As the intensity of treatments increase, the habitats 

will be structured most closely to the lower end of the NRV. All basal areas increase as other nonpine components increase in size (i.e., Gambel oak), with one exception. Those treatments 

designed for small mammal research will trend away from the NRV (see silviculture report).

The silvicultural analysis concluded that the 431,049 acres of mechanical treatments and 586,1106

acres of prescribed fire will be more effective than fire alone. Fire is the essential element needed 

to effectively move towards desired conditions in this fire-adapted landscape. At the landscape 

scale, the difference in modeled crown fire potential between alternatives B though E is minimal 

because the vertical and horizontal continuity of canopy fuels is broken up by mechanical 

treatments. Under alternative E, there would likely be greater potential for crown fire than under 

alternative B because, without a Coconino NF forest plan amendment, the forest plan would 

require less interspace and result in more contiguous canopy fuels. 

We find that the selected alternative meets the purpose and need by decreasing the potential for 

crown fire from 38 percent (on about 191,000 acres) to less than 10 percent. Mexican spotted owl 

habitat would continue to have high surface fuel loadings due to the conservative nature of the 

treatments. Overall, the selected alternative meets the objective of increasing resiliency and 

function by returning fire to this fire-adapted landscape (FEIS chapter 3, fire ecology analysis). 

In the selected alternative, we find that soil productivity and watershed function will be 

maintained and improved on 23 percent at-risk and 42 percent impaired watersheds (FEIS, table 

35). Short-term impacts from soil disturbances will range (watershed average) from 2.9 percent 

(lowest in alternative D) to 3.5 percent (highest in the selected alternative). In the selected 

alternative, no individual watershed will have soil disturbance average above 11.5 percent (3.5

percent below the 15 percent soil productivity threshold). Therefore, soil productivity and 

watershed function should be maintained. 

Alternatives B through E would produce similar results for soil productivity, watershed function 

and soil disturbance. However, alternative B and the selected alternative would be expected to 

maintain, improve and protect long-term soil productivity and watershed function better than

alternative D because the vast majority of that alternative does not follow mechanical treatments 

with prescribed fire. Prescribed fire is necessary to maintain soil productivity and watershed 

function processes.

In the selected alternative, soil disturbance includes temporary road construction, 

decommissioning, reconstruction, and improvement or relocation. Temporary road construction 

will create short-term soil disturbance on about 520 miles of road (950 acres). Of these roads, a 

vast majority are located on soils with slight or moderate erosion hazard. About 22 miles of 

temporary road construction (about 40 acres) would occur on severe erosion hazard soils. 

Road decommissioning will create about 1,645 acres of disturbance in the short term and remove 

approximately 860 miles of roads, or about 1,645 acres of road from future disturbance in the 

long-term. About 38 miles (roughly 70 acres) are on severe erosion hazard soils. BMPs (FEIS, 

appendix C) are designed to minimize impacts from decommissioning efforts. After 

decommissioning, there will be a reduction of roads on soils with severe erosion hazard (see soils 

report, “Temporary Road Construction and Decommissioning” section). 

6 Total acres include 431,049 acres of prescribed fire where mechanical treatment occurs and 155,061 acres of 

prescribed-fire only. 

26 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 

 
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Road relocation will occur on just less than 10 miles (about 17 acres of disturbance) of road 

across the project area. Of these miles, about 0.3 miles are severe erosion sites (about .7 acres). 

Road improvements will occur on about 30 miles, and may affect up to 75-150 acres, depending 

on the extent of the road improvement. Vegetation will likely be removed with these activities. 

These activities may occur on about 10-20 acres of soils with severe erosion hazard. Specific 

best management practices (BMPs; see FEIS, appendix C and soils report) will mitigate effects 

on severe erosion sites.

Overall, road decommissioning and temporary road construction results in less than 0.1 percent 

soil disturbance in the treatment area and much less at the 6th HUC watershed scale. 

Implementation of BMPs is expected to mitigate accelerated erosion, and possible elevated 

sediment transport to connected streamcourses to reduce risk to downstream water quality. 

Although the analysis indicates soil productivity and watershed function will be maintained, the 

disturbance related to the development and decommission of temporary roads is likely to be 

remain controversial with some people. 

Overall, we find that the selected alternative moves the project area closest to desired conditions 

in terms of: (1) increasing species composition, (2) increasing groups of trees, (3) maintaining 

scattered individual trees, (4) increasing grass-forb-shrub interspaces, (5) increasing snags, logs, 

and woody debris, (6) increasing variation in the arrangements of these elements in space and 

time, and (7) establishing ecosystem processes, functions, and fire return intervals that are within 

the natural range of variability.

Alternative A would move the project area the farthest away from resiliency, function and 

sustainability desired conditions (see Mexican spotted owl and goshawk analyses). Alternatives 

B, D, and E would not increase Mexican spotted owl and goshawk habitat resiliency to natural 

disturbances to the extent the selected alternative does (see Issue 1-3 discussion on the previous 

pages). 

Because the selected alternative significantly affects fire behavior, forest structure, and forest 

health, we find this project meets objectives and increases resilience to natural disturbances 

associated with climate change in both the short and long term. 

Range of Alternatives and Comparison of Alternatives (Procedural Concern): In response to 

comments received on the DEIS, another alternative that would propose no forest plan 

amendment was analyzed in the FEIS. This increased the number of fully analyzed alternatives to 

five (four action alternatives and the no action alternative), and increased the number of 

alternatives considered but eliminated from detailed study to six. More importantly than the sheer 

number of alternatives is whether unresolved issues were addressed through alternative 

development or environmental analysis. This is consistent with Council for Environmental 

Quality regulations for implementing the National Environmental Policy Act (40 CFR sections 

1501.2(c) and 1502.14 and 36 CFR 220.5(e), 40 CFR section 1502.14.) 

We find that based on the relevant issues raised, reasonable alternatives were developed. We find 

that the rationale for considering but eliminating six alternatives from detailed study is 

documented and is based on meeting the purpose and need (moving towards desired conditions) 

for this landscape-scale restoration project.

Significant Forest Plan Amendments (Procedural Concern): Some commenters stated the 

DEIS (alternatives B through D) failed to support a finding that the plan amendments are 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 27
Draft Record of Decision

nonsignificant. Some commenters stated the public cannot use the data in the analysis to 

determine the acres affected and to understand how these acres are related to other anticipated 

uses. Some commenters stated the proposed amendments are significant because they may bring 

about changes that may have an important effect on the entire land management plan or affect 

land and resources throughout a large portion of the planning area; see FSM 1926.52 (Jan. 31, 

2006). 

The environmental cause-and-effect relationship is the perceived dramatic change in management 

for Mexican spotted owl that may result in harm to the species. On the Coconino NF, the 

amendments authorized (alternatives B, C, and D) mechanical treatments in Mexican spotted owl

PACs that exceed 9 inches d.b.h. and authorize the use of prescribed fire in Mexican spotted owl 

PAC core areas (alternative C). In alternatives B through D, all Mexican spotted owl existing 

monitoring requirements were removed and specific monitoring requirements were deferred to 

the U.S. Fish and Wildlife Service biological opinion. For goshawk, the amendments on the 

Coconino NF authorized managing acres for an open reference condition (up to 90 percent open) 

and clarified how and where canopy cover would be measured. 

Some commenters stated the plan amendments are significant because the Coconino NF is 

including identical plan amendments in similar vegetation projects; therefore, providing direction 

that must be followed by other projects. Some commenters asked for examples of other projects 

with nonsignificant plan amendments. Some commenters suggested wording to improve clarity.

The detailed significance analysis for each amendment is located in appendix B of the FEIS. No 

amendment alters multiple use forest plan goals and objectives, adjusts management area 

boundaries. The changes in standards and guidelines are considered to be minor because they 

reflect the latest, best available science including the revised Mexican Spotted Owl Recovery 

Plan. The amendments do not alter the long-term relationship between levels of multiple-use 

goods and services originally projected for the Coconino NF. These outputs were specific to a 

planning period ranging from 10 to 15 years: 

• Amendment 1: The amendment will affect 6,906 acres or 18 percent of the PAC habitat on 

the Forest. 

• Amendment 2 is clarification amendment. The canopy cover portion of the amendment would 

generally affect 137,242 acres (15 percent) of all goshawk habitat on the Coconino NF. 

Managing 28,653 acres of ponderosa pine for an open reference condition would affect 

approximately 3 percent of all suitable goshawk habitats on the Forest.

• Amendment 3 is specific to the 355,707 acres of proposed treatments in this project. In 

alternative C this would affect about 20 percent of the Coconino NF (which totals 1,821,495 

acres).

For these reasons, the amendments will not result in an important effect to the entire land

management planning area. 

The list of vegetation projects that were included in comments on the DEIS was reviewed. The 

forest plan amendments that have been proposed in other vegetation projects reflect the ongoing 

Coconino NF forest plan revision process, using the best available scientific information 

(Reynolds et al. 2013), and they are compliant with the revised Mexican Spotted Owl Recovery 

Plan (USDI FWS 2012). A complete analysis of other proposed forest plan amendments by 

project is located in the project record. 

28 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
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The amendments are consistent with the nonsignificance criteria found in FSH 1926.51. Each 

amendment is a specific, one-time variance for this restoration project. The best available science 

for management in southwestern forests, the (Coconino NF) forest plan revision process, and 

revised Mexican Spotted Owl Recovery Plan objectives are affecting ongoing and future 

analyses. This decision will not impose direction on ongoing or future analyses. 

Forest Structure and the Conservation of Old (Presettlement) Trees (Purpose and Need): A 

desired condition on the Coconino NF is to allocate old growth sites (current forest plan 

direction). On the Kaibab NF the desired condition is to manage for old growth components. As 

noted above in the discussion on large trees, the selected alternative includes an implementation 

plan designed to move towards the desired condition of uneven-aged forest conditions. Key to 

this is the need to conserve and promote old (presettlement) trees and improve age classes that are 

underrepresented. Early in the analysis process, the stakeholder-developed Old Tree Protection 

Strategy was used to inform the Old Tree Implementation Plan (FEIS, chapter 1). In response to 

comments on the DEIS, we edited the Old Tree Implementation Plan (FEIS, chapter 1) and added 

additional design features related to temporary road development (FEIS, appendix B, design 

feature T12) to clarify the intent to conserve and protect old trees during project implementation. 

The silvicultural analysis concludes that the selected alternative will improve the sustainability of 

the old tree component across the landscape (FEIS, chapter 3, “Vegetation” section). 

Alternative A would not move the project area towards desired conditions. The silvicultural 

analysis found that the sustainability of the large/old tree component across the landscape may be 

impaired by density-related mortality and forest health issues (FEIS, chapter 3, “Vegetation” 

section). Alternatives B through E included design features and mitigation to protect old trees. In 

this regard there is no difference between the selected alternative and alternatives B, D and E.

Forest Health (Purpose and Need): The selected alternative addresses the purpose and need by 

reducing the moderate/high bark beetle hazard rating from 72 percent to 22 percent by 2020. 

Hazard ratings will increase in the long-term due to vegetation regrowth. Dwarf mistletoe 

infection will be reduced as a result of being able to selectively remove lightly infected trees. The 

percent of the area with moderate/high dwarf mistletoe will not decrease because the intent of the 

treatments was not to eradicate mistletoe but to manage it at endemic levels (FEIS, chapter 3, 

“Vegetation” section; chapter 2, table 35). The selected alternative decreases the potential for 

stand density-related mortality although tree density remains high in Mexican spotted owl and 

goshawk habitat (see previous discussion). 

Alternative A would move the project area farther away from forest health desired conditions. It 

increases the potential for stand density-related mortality in all habitats. It increases the potential 

for insect and disease outbreaks. It results in no movement towards improved resiliency, function 

and sustainability in ponderosa pine. The selected alternative best reduces the potential for stand 

density-related mortality in Mexican spotted owl PACs and decreases the potential for crown fire 

in PACs by having two prescribed fire entries in PACS (including core areas). 

Vegetation Composition and Diversity (Purpose and Need): A key component of the purpose 

and need was to improve vegetation composition and diversity. We find the selected alternative 

meets the purpose and need by improving composition and diversity in aspen, large oak (an 

increase of 7 percent in long term), grasslands, pine-oak and pine-sage. In Mexican spotted owl 

habitat, the benefits were more pronounced in restricted versus protected habitat. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 29
Draft Record of Decision

The selected alternative restores over 50,000 acres of historic grasslands and pine with an open 

reference condition. The selected alternative enhances grassland inclusions on 286,543 acres in 

goshawk PFA/dPFA, LOPFA, and Mexican spotted owl pine-oak habitat.

Alternative A does not respond to the purpose and need. Ponderosa pine tree canopy would 

continue to increase, shading out understory herbaceous vegetation and further reducing forage 

production and species diversity. Oak and aspen growth and vigor would continue to be stagnated 

due to competition with pine resulting in lowered resistance to insects and disease and eventual 

mortality. Oak and aspen regeneration ability would continue to be impaired. Pine would continue 

shading out understory sage further reducing the sage component and the historic pattern within 

the pine sage mosaic (see silviculture report, Alternative A-No Action; “Vegetation Diversity and 

Composition” section). 

Alternatives B and D would not restore as many acres of historic grasslands and pine savanna. 

Alternative D would not meet function and resiliency desired conditions. It removes the use of 

fire from over 60 percent of the landscape and results in 30 percent of the landscape returning to a 

fire regime condition class 3. Alternative E restores no acres of historic grassland or pine savanna. 

Socio-economics: Although social and economic impacts from the project were not included in 

the purpose and need, we considered them a key output. No effects are presented under 

alternative A, as these reflect current conditions. The changes in employment and income under 

alternatives B through E reflect an increase in employment and income due to project harvesting 

and processing activities as well as the potential for a temporary reduction of 60 jobs and 

$2 million in labor income due to recreation displacement. Over the 10-year treatment period, the 

selected alternative will save between $156 and $232 million of cost to the taxpayer as a result of 

using stewardship contracts (see socioeconomic report, Summary of Effects; “Avoided Treatment 

Costs” section). 

Consideration of Unavoidable Adverse Effects

Overall, the selected alternative considers the tradeoffs between short-term adverse effects (i.e., 

environmental harm) and long-term benefits. Implementation of the selected alternative will 

result in some unavoidable short-term adverse effects on threatened and endangered species and 

critical habitat, short term adverse effects on candidate species, proposed species and their 

critical habitat, sensitive species (individuals), soils and water quality (short term), air quality 

(short term, during prescribed fire activities), and recreation settings and scenery (short term). 

However, the selected alternative includes design features, mitigation measures, and best 

management practices (FEIS appendix C) that will reduce these adverse effects to the extent 

practicable while still achieving project objectives. 

Our decision considered all comments received during scoping periods, workshops, public 

meetings, field trips, and the formal notice and comment period. The selected alternative

considers the input received from stakeholders throughout the process. We recognize that there is 

a range of public opinion regarding the variety of treatments identified in the selected alternative, 

particularly the use of prescribed fire. However, we have concluded that our decision is an 

informed one that best meets the project’s purpose and need, moves the project area toward 

desired conditions, and considers the environmental consequences(both positive and negative) of 

the selected restoration actions. Monitoring, evaluation and the use of adaptive management 

during implementation will continue to inform us of the effects of this decision.

30 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Uncertainty and Risk for Mexican Spotted Owl 

The practice of prescribed fire has evolved over time and it is commonly used as a tool to reduce 

surface fuels while also maintaining forest structure and wildlife habitat components such as 

snags, logs, and other coarse woody debris. However, prescribed fire is not a precise tool and 

there is inherent uncertainty and so potential risk with fire management. There is also risk and 

uncertainty in not addressing uncharacteristic surface fuel loads in fire-adapted ecosystems.

Randall-Parker and Miller (2002) reported up to one-third of snags and almost half of all logs 

were lost following prescribed burning. This was largely an observational study based on five 

plots. They were experimenting with methodologies and their data collection techniques changed 

during the course of the study. As the authors point out, the results are not statistically sound. 

Therefore it was published in conference proceedings and not in the referred literature. 

Saab et al. (2006) addressed similar concerns, yielding more rigorous results. Although they also 

reported loss of nearly half the logs from prescribed fire, treatments were conducted during 

drought conditions with low fuel moistures. Prescribed fire did successfully remove live ladder 

fuels. However, most of the results were not statistically significant. 

Monitoring data from the Coconino NF has documented loss of key habitat components from 

prescribed fire. Microhabitat monitoring from burns implemented on the Happy Jack Urban 

Interface Project on the Mogollon Rim Ranger District through late 2004 showed an 8 percent 

loss of trees greater than 18 inches d.b.h., a 21 percent loss of snags, a 71 percent loss of logs, and 

a 47 percent loss of Gambel oak trees greater than five inches d.b.h. In addition, prescribed burns 

conducted along Highway 87 and Forest Highway 3 (2005-2006) appear to have had loss of 

canopy cover and basal area. These projects did not include PACs and did not have the list of 

design features developed to minimize loss of key habitat components. Perhaps most important is 

that the projects being compared had a fuels reduction emphasis different from the restoration 

emphasis in the 4FRI. 

Prescribed burning is expected to reduce the risk of future high-severity fire by reducing 

accumulations of fuels and raising canopy base height, both of which can benefit Mexican spotted 

owl habitat in both the short and long term. However, it can also modify or destroy key habitat 

components that comprise Mexican spotted owl habitat. Based upon the sheer number of acres 

proposed for burning each year, and because the intention is to apply prescribed fire to all PACs 

and nest/roost replacement/target-threshold acres, there is a likelihood that more key habitat 

components could be unintentionally lost to fire than modeling indicates. Some degree of 

unintended fire behavior could improve Mexican spotted owl habitat by creating canopy gaps and 

enriching soils. However, impacts to Mexican spotted owl habitat could also create adverse 

effects (see the U.S. Fish and Wildlife Service biological opinion). 

Environmentally Preferable Alternative

We believe alternative C (selected alternative, as modified) is the environmentally preferable 

alternative. Although this alternative treats the most acres to move toward desired conditions, it 

also provides the most long-term benefits for multiple resources. Approximately 586,110 acres of 

ponderosa pine will be on a trajectory towards long-term resiliency and sustainability (see 

discussion in rationale section). While all action alternatives included restorative actions for 

streams, springs, roads and unauthorized routes, only alternative C adequately addresses 

grassland restoration and only alternative C adequately affects the quality and quantity of 

Mexican spotted owl and goshawk habitat (see Rationale for the Decision on page 18). 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 31
Draft Record of Decision

Unavailable Information 

After reviewing available literature and consulting with subject matter experts on the potential for 

mercury emissions from prescribed fire, we have concluded there is incomplete and unavailable 

information relevant to determining reasonably foreseeable adverse impacts to the human 

environment as directed by CEQ Sec. 1502.22 (b). (See FEIS, air quality analysis).

Compatibility with Goals of

Other Local, State and Federal, Governments 

As part of the collaborative effort, the Coconino and Kaibab NFs have engaged other local, State, 

Federal and tribal governments since 2011. At a local governmental level, the project is not in 

conflict with City of Flagstaff, Williams, Tusayan and Sedona goals or plans. The cities have 

received project updates since 2011 (see project record). Community wildfire protection plans for 

Flagstaff, Williams and Tusayan informed the project’s purpose and need for action. Treatments 

were designed to align with community wildfire protection plans objectives. The project aligns

with the goals of Coconino County which seeks to reduce the risk of high-severity fire and protect 

community watersheds. 

Coconino County has expressed support for the project since 2011 (see project record). Since 

2011 the Coconino Natural Resource Conservation District (DEIS CARA 176) and Flagstaff Fire 

Department (DEIS CARA 40) have been stakeholders and have provided comments. Although 

not directly affected by the project, eastern Arizona counties have commented on the project since 

2011. Counties including Navajo, Apache, Graham, Greenlee and Gila commented on the DEIS 

and provided a review of how the project aligns with county goals and plans (DEIS CARA 76, 

89, 158, 163, 164, 158,174, 184). The counties had specific comments and recommendations but 

overall concluded the project was not in conflict with county goals and objectives. 

At the State level, the Arizona Department of Game and Fish was designated as a cooperating 

agency for the project in 2011 and has continued to support the project (DEIS CARA 113). The 

Arizona State Forestry Division has been a stakeholder since 2011 and has provided comments 

and recommendations since scoping (DEIS, CARA 166). 

Federal agencies including the Bureau of Land Management (scoping comment) and the National 

Park Service (DEIS, CARA 118) and neither identified conflicts. Tribal consultation was initiated 

in 2011. No conflicts with tribal plans or goals have been identified (FEIS tribal relations report). 

Findings Required by Other Laws and Authorities

After consideration of the discussion of environmental consequences (FEIS, chapter 3), we have 

determined that the selected alternative is consistent with the Land and Resource Management 

Plan for the Kaibab National Forest, the Coconino National Forest Plan, as amended, and agency 

directives. We have also determined that the selected alternative is consistent with applicable 

Federal laws, Executive Orders, and regulations. The following is not an all-inclusive listing, but 

summarized conformance with the laws and regulations most relevant to this decision. 

National Forest Management Act

The project was reviewed against the direction in the current “Coconino National Forest Plan” 

(forest plan), as amended (USDA 1987), the “Land and Resource Management Plan for the 

Kaibab National Forest” (USDA 2014) and 36 CFR 219.17(b)(3). Consistency evaluations are 

included in each resource report. A consolidated evaluation is located in the project record.

32 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Forest Plan Consistency

Our decision was reviewed for consistency with the direction in the current “Coconino National 

Forest Plan” (forest plan), as amended (USDA FS 1987), the “Land and Resource Management 

Plan for the Kaibab National Forest, as revised” (USDA FS 2014) and 36 CFR 219.17(b)(3). 

Coconino NF

Three nonsignificant amendments for the Coconino NF were evaluated in the FEIS. The proposed 

forest plan amendments are authorized via 36 CFR 219, the Forest Service Planning Rule. Section 

219.17(b)(3) of the Rule provides the transition language that allows this project to propose 

amendments to the Coconino NF forest plan using the provisions of the 1982 Planning Rule. 

Please refer to pages 7 and 15 for detailed information on the amendments. 

No amendment will alter multiple-use forest plan goals and objectives or adjust management area 

boundaries. The changes in standards and guidelines are considered to be minor because they 

reflect the latest, best available science (Reynolds et al. 2013). The amendments bring the 

selected alternative into alignment with the revised Mexican Spotted Owl Recovery Plan. No

amendment will alter the long-term relationship between levels of multiple-use goods and 

services originally projected for the Coconino NF. These outputs were specific to a planning 

period ranging from 10 to 15 years (as identified in 1987). The amendments will not result in an 

important effect to the entire land management planning area. Each amendment is a specific, onetime variance for this restoration project and decision. The best available science for management 

in Southwestern forests (Reynolds et al. 2013), the (Coconino NF) forest plan revision process, is 

affecting ongoing and future analyses. The silviculture analysis documents the project will not 

alter timber suitability. The plan amendments that are specific to this decision will not impose 

direction on ongoing or future analyses. I have also determined that the amendments provide the 

most effective way for achieving the desired ecological conditions described in the forest plan for 

northern goshawk and Mexican spotted owl habitats as well as the purpose and need. 

Kaibab NF 

The revised forest plan for the Kaibab NF became effective in April of 2014. The project’s 

desired conditions were based on the best available science for the restoration of southwestern 

fire-adapted ecosystems (Reynolds et al. 2013). 

The project is consistent with the revised forest plan in that a guideline for threatened, endangered 

and sensitive species directs projects to integrate management objectives and protection measures 

from approved recovery plans (revised KNF forest plan, p. 51). The revised Mexican Spotted 

Owl Recovery Plan (USDI FWS 2012) does not limit tree removal from within protected activity 

centers to a specific d.b.h., nor does it require a specific method for habitat monitoring. Although 

restricted habitat is referred to as “recovery habitat” and “nest/roost habitats” in the 2012 revised 

recovery plan (USDI FWS 2012, pp. 3-4), the project’s desired conditions for nesting and 

roosting habitat is consistent with the revised recovery plan. The revised recovery plan still 

recommends that a percentage (10 to 25 percent) of recovery habitat be managed as nesting and 

roosting habitat (USDI FWS 2012, p. VIII). Designating habitat in the project area with the best 

potential would move toward desired percentages in recovery habitat. Also see appendix D in the 

FEIS (Implementation Plan). 

Forest plan desired conditions for ponderosa pine, a major vegetation type, would be achieved 

because the project (1) at the fine scale provides for managing crowns of trees within the midaged to old groups as interlocking or nearly interlocking (revised Kaibab NF forest plan, p. 17); 

(2) at the mid-scale manages forest conditions in some areas contain 10 to 20 percent higher basal 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 33
Draft Record of Decision

area in mid-aged to old tree groups than in the general forest (e.g. goshawk post-fledging family 

areas (PFAs), Mexican spotted owl nesting/roosting habitat, drainages, and steep north-facing 

slopes) (revised Kaibab NF forest plan p. 18); and, (3) at the landscape scale the ponderosa pine 

forest is a mosaic of conditions composed of structural stages that range from young to old trees. 

The forest is generally uneven-aged and open, and old growth occurs throughout the landscape 

(revised Kaibab NF forest plan, p. 18). Treatment design in ponderosa pine also meets the wildlife 

guideline of having goshawk nest areas that are multi-aged and dominated by large trees with 

interlocking crowns and are generally denser than the surrounding forest (Kaibab NF forest plan, 

p. 51). See appendix D in the FEIS (Implementation Plan), which provides specific treatment 

design for alternatives. 

The project’s use of the term “interspaces” with treatment design is consistent with the forest 

plan’s desired condition at the midscale for interspace (revised Kaibab NF forest plan, p.17). 

Treatments and site-specific analysis indicate interspace would typically range from 10 to 70 

percent and be based on site productivity (see silviculture forest plan consistency evaluations). 

The project is consistent with soil and watershed desired conditions and guidelines of the revised 

Kaibab NF forest plan (pp. 44-46) in that the project is designed to maintain or improve water 

quality and quantity. The project incorporates best management practices and design features that 

would control erosion and protect and improve watershed condition (see appendix C). The project 

would improve stream channel stability and spring function and move water levels and flow rates 

towards reference conditions (see FEIS, chapter 3). The project is consistent with the desired 

conditions for fire behavior (risk) and fire regime in ponderosa pine by promoting the return of 

low-severity fire into the landscape (revised Kaibab NF forest plan, p. 18). The project is 

consistent with narrow and rare endemic species guidelines in that it incorporates measures to 

protect and provide for rare and narrow endemic species where they are likely to occur (revised 

Kaibab NF forest plan, p. 52). The silviculture analysis documents the project will not alter 

timber suitability. 

Findings Related to the National Forest Management Act

I, M. Earl Stewart, find the selected alternative, with the inclusion of the nonsignificant 

amendments to the Coconino National Forest, as amended, is consistent with the goals and 

objectives of the forest plan. This decision complies with the management direction and standards 

and guidelines for all relevant management areas described in the plan. I find that the 

nonsignificant amendments that are part of this decision are consistent with 36 CFR 219, the 

Forest Service Planning Rule. Section 219.17(b)(3) of the Rule provides the transition language 

that allows this project to propose amendments to the Coconino NF forest plan using the 

provisions of the 1982 Planning Rule. The significant of each amendment was evaluated in 

accordance with FSH 1926.51 and FSH 1926.52. Opportunities for public participation and 

notification was provided as required in § 219.4 and § 219.16. 

I, Michael R. Williams, find the selected alternative is consistent with the revised Kaibab 

National Forest Land and Resource Management Plan components including goals, objectives, 

desired conditions, standards, guidelines, and management area guidance. Consistency 

evaluations are included in each resource report. A consolidated evaluation is located in the 

project record.

34 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
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Consultation with the Fish and Wildlife Service

A biological assessment was prepared to evaluate the potential effects of the project on federally 

listed species, and where appropriate, their critical habitat (Noble 2014). The biological 

assessment analyzed the potential effects on federally listed species in the project area and on the 

Coconino and Kaibab NFs include Mexican spotted owl (threatened), California condor 

(experimental population7

), narrow-headed garter snake (threatened), spikedace (endangered), 

loach minnow (endangered) and roundtail chub (candidate). The biological assessment was 

submitted to the U.S. Fish and Wildlife Service on February 14, 2014. 

This analysis found the selected alternative “may affect, but is not likely to adversely affect”, the 

threatened narrow-headed garter snake (Thamnophis rufipunctatus) and its proposed critical 

habitat, spikedace (Meda fulgida) critical habitat, loah minnow (Tiaroga cobitis) critical habitat , 

and the candidate roundtail chub (Gila robusta). The botanical analysis found the selected 

alternative “may impact individuals, but is not likely to cause a trend toward federal listing or loss 

of viability” for the Arizona bugbane (Cimicifuag airzonica), covered under a conservation 

agreement. 

Technical assistance was requested with respect to compliance with the Bald and Golden Eagle 

Protection Act for bald eagles (Haliaseetus leucocephalus) and golden eagles (Aquila chrysaetos). 

The analysis for Mexican spotted owl (Strix occidentalis lucida) and its critical habitat concluded 

there is potential for short-term adverse effects to owls. Long-term effects of the project should be 

beneficial to Mexican spotted owls by enhancing key habitat components for Mexican spotted 

owl and their prey. The selected alternative may effect, and is likely to adversely affect Mexican 

spotted owl and its critical habitat (Noble 2014). 

The biological opinion (AESO/SE 22140-2011-F-0145) for the project was signed on October 20, 

2014 (USDI FWS 2014). The FWS provided technical assistance as requested for bald eagles and 

golden eagles. The U.S. Fish and Wildlife Service concurred with the determinations presented in 

the biological assessment for narrow-headed garter snake and its proposed critical habitat, 

spikedace critical habitat, loach minnow critical habitat, roundtail chub, and Arizona bugbane. 

The U.S. Fish and Wildlife Service found the selected alternative will not jeopardize the 

continued existence of the Mexican spotted owl, and will not destroy or adversely modify its 

designated critical habitat (USDI FWS 2014, page 33). 

Incidental take for Mexican spotted owl (per section 9 of the Endangered Species Act) was 

attributed at the PAC level. The amount of take tiers to (is included within) the amount of take 

anticipated under the 2012 biological opinion for the Coconino NF forest plan and the 2013 

biological opinion for the Kaibab NF Land and Resource Management Plan (USDI FWS 2014, 

pp. 33-36). Nondiscretionary terms and conditions associated with the incidental take were 

included. These terms and conditions can be found in the project record. 

Bald and Golden Eagle Protection Act

All golden and bald eagles, regardless of status, are protected under the Bald and Golden Eagle 

Protection Act. Technical assistance was requested from the FWS to ensure the intent of the Bald 

and Golden Eagle Protection Act was met while implementing the actions associated this 

decision. With design features and mitigation (FEIS, appendix C) this decision will not result in 

7 section (10)(j) of the ESA

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 35

 
Draft Record of Decision

take for either species (Noble 2014). This decision aligns with the direction recommended by the 

U.S. Fish and Wildlife Service including “Conservation Assessment and Strategy for Bald eagles 

in Arizona” (Driscoll et. al. 2006) in conjunction with “Bald Eagle National Guidelines” (USDI

FWS 2007). This decision aligns with the U.S. Fish and Wildlife Service-issued “Interim Golden 

Eagle Technical Guidance: Inventory and Monitoring Protocols and Other Recommendations in 

Support of Golden Eagle Management and Permit Issuance” (Pagel et al. 2010). 

Collaborative Forest Landscape Restoration Act

We find this decision is compliant with the Collaborative Forest Landscape Restoration Act. The 

purpose and need in the FEIS was revised from the DEIS to the FEIS to emphasize the need to 

comply with Omnibus Public Land Management Act criteria for landscape-scale restoration 

(FEIS, chapter 1). The large tree section of the purpose and need discloses that large trees (VSS 5 

and 6) are currently underrepresented within the project area and the desired condition is to 

balance community, wildlife and forest restoration into treatment design. This decision 

acknowledges that while some large trees may be removed to accomplish ecological objectives or 

public safety objectives around communities, there is a need to retain as many large trees (larger 

than 16 inches d.b.h.) as possible. The FEIS and this decision acknowledge the rarity and 

ecological and socio-political importance of large trees in the Southwest. This decision includes a 

process (appendix D) that addresses large tree retention during project implementation. This 

decision is consistent with the Collaborative Forest Landscape Restoration Act direction

regarding the prohibition of building permanent roads. Only temporary roads, as dictated by 

appendix C design features, mitigation measures, and best management practices, will be 

authorized in this project (FEIS, appendix C). 

National Environmental Policy Act (NEPA)

The National Environmental Policy Act requires Federal agencies to consider and disclose the 

effects of proposed actions that significantly affect the quality of the human environment. The 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests FEIS analyzes the 

alternatives and displays the effects in conformance with the Act (40 CFR 1500 to 1508 and FSH 

1909.15). 

Endangered Species Act 

This decision is compliant with the legal requirements set forth under section 7 of the Endangered 

Species Act (16 U.S.C. 1536 (c)).Federally-listed species in the project area and on the Coconino 

and Kaibab NFs include Mexican spotted owl (threatened), California Condor (Experimental 

population (section (10)(j) of the Act), narrow-headed garter snake (threatened), spikedace 

(endangered), loach minnow (endangered) and roundtail chub (candidate). The FEIS discloses 

potential impacts to the federally listed, proposed, and candidate species as displayed below in the 

summary of determination table (table 2). 

There will be no effects to several federally listed species. There will be no direct, indirect or 

cumulative effects to black-footed ferret. The selected alternative will have no measureable 

direct, indirect, or cumulative effects to California condors. Design features have been developed 

to protect condors in the event they are detected during project implementation (FEIS, appendix 

C, W40 to W44). Gila chub, razorback sucker or Colorado pikeminnow were eliminated from 

further analysis because these species does not have occupied habitat in the analysis area.

The analysis (biological assessment) for Mexican spotted owl concluded there is potential for 

short-term adverse effects to owls (also see Uncertainty and Risk for Mexican Spotted Owl 

36 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests
Draft Record of Decision

section on page 31). However, long term effects of the project should be beneficial to Mexican 

spotted owls by enhancing key habitat components for the owl and their prey. The likelihood of 

maintaining Mexican spotted owl habitat into the future is also enhanced by reducing the 

predicted risks from climate change-induced changes to temperature and precipitation patterns 

and their synergistic effects with insects, disease, and risk of high-severity fire (Noble 2014). The 

biological opinion (AESO/SE 22140-2011-F-0145) for the project was signed on October 20, 

2014. The U.S. Fish and Wildlife Service found that the effects of the proposed action and the 

cumulative effects, will not jeopardize the continued existence of the Mexican spotted owl, and 

will not destroy or adversely modify its designated critical habitat (USDI FWS 2014, p. 33).

Narrow-headed garter snake, which occurs on the Coconino NF, was recently listed as a 

threatened species (effective August 7, 2014) and the U.S. Fish and Wildlife Service has 

proposed critical habitat (USDI FWS 2014, 2013, respectively). This analysis considered a recent 

change in condition as a result of wildfire (2014). The selected alternative may affect but is not 

likely to adversely affect the species, nor is it likely to adversely affect the snake’s habitat. 

Considering direct, indirect, and cumulative effects, the selected alternative may affect but is not 

likely to adversely affect proposed narrow-headed garter snake critical habitat (biological 

assessment 2014). The U.S. Fish and Wildlife Service concurred with this determination (USDI 

FWS 2014, p. 46). 

The analysis for spikedace (endangered) and loach minnow (endangered) concludes that these 

species are not currently present. The selected alternative will result in no effect to these species. 

There may be short-term increases in sedimentation and/or ash flow into critical habitat from 

prescribed fire actions. Long-term benefits would result from restored hydrologic function at 

spring sources, reduced potential for severe flooding in restored ephemeral channels, and reduced 

erosion and runoff resulting from properly decommissioned and/or relocated roads. For these 

reasons, the selected alternative may affect but is not likely to adversely affect spikedace or loach 

minnow critical habitat (see aquatics report, “Species Effects” section). The U.S. Fish and 

Wildlife Service concurred with this determination (USDI FWS 2014, p. 47).

The only candidate species that may become federally listed within the life of this project is the 

roundtail chub (Coconino NF). The analysis for the chub concludes that BMPs will mitigate the 

short-term impacts from increases in soil movement and sedimentation as a result of spring and 

stream restoration and road decommissioning. Long-term benefits are the same as described for 

spikedace and loach minnow. The selected alternative may affect but is not likely to adversely 

affect roundtail chub or its habitat (see aquatics report, “Candidate Species” section). The U.S. 

Fish and Wildlife Service concurred with this determination (USDI FWS 2014, p. 47).

The analysis for Arizona bugbane (Forest Service sensitive species with a conservation 

agreement) concludes that the selected alternative may result in a loss of plants and shade but 

effects will be mitigated to protect the shady environment needed by Arizona bugbane. The 

project may impact individuals but is not likely to result in a trend toward federal listing or loss of 

viability. The U.S. Fish and Wildlife Service concurred with this determination (USDI FWS 2014, 

p. 48).

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 37
Draft Record of Decision

Table 2. Effects Determination for Federally-listed and candidate species

Common Name Status Effects Determination

Mexican Spotted Owl (Strix 

occidentalis lucida) and critical habitat

Threatened May Effect and is Likely to Adversely 

Affect Mexican spotted owls and their 

habitat.

May Effect and is Likely to Adversely 

Affect Mexican spotted owl critical 

habitat

California Condor (Gymnogyps 

californianus)

Experimental 

population (section 

(10)(j) of the ESA) 

No measureable direct, indirect or 

cumulative effects

Black-footed Ferret (Mustela nigripes) Endangered No direct, indirect or cumulative 

effects

Narrow-headed Garter Snake 

(Thamnophis rufipunctatus) and 

proposed critical habitat 

Threatened May Affect but is Not Likely to 

Adversely Affect the species, nor is it 

likely to adversely affect the snake’s 

habitat.. 

May Affect but is Not Likely to 

Adversely Affect proposed narrowheaded garter snake critical habitat

Spikedace (Meda fulgida) Endangered May Affect but is Not Likely to 

Adversely Affect” spikedace critical 

habitat

Loach minnow (Tiaroga cobitis) Endangered May Affect but is Not Likely to 

Adversely Affect” loach minnow 

critical habitat

Roundtail chub (Gila robusta) Candidate May Affect but is Not Likely to 

Adversely Affect” roundtail chub or its 

habitat

Arizona bugbane ((Cimicifuga 

arizonica)

Forest Service 

sensitive species with 

a conservation 

agreement, included in 

FWS consultation

May impact individuals but is not 

likely to result in a trend toward federal 

listing or loss of viability.

Forest Service Sensitive Species

Federal law and direction applicable to Forest Service sensitive species are included in the 

National Forest Management Act and the Forest Service Manual (2670). The Regional Forester 

has developed the sensitive species list for plants and animals for which population viability is a 

concern. The most recent list was transmitted to us on September 18, 2013. We prepared a 

biological evaluation on species designated as sensitive by the Regional Forester. 

The selected alternative will have no effect on western burrowing owl (Athene cunicularia 

hypugaea). No burrowing owls have been documented in the project area. However, potential 

nesting habitat does exist and the analysis focuses on owl prey habitat conditions. The selected 

alternative will improve potential future habitat. There will be no effect to Cliff fleabane 

(Erigeron saxatilis). The habitat is on steep canyon walls and is not likely to be affected by 

management actions.

The selected alternative may affect individuals, but will not cause a trend toward federal listing 

for the following sensitive species: northern goshawk (Accipiter gentilis), northern leopard frog 

38 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests
Draft Record of Decision

(Lithobates pipiens), bald eagle (Haliaeetus leucocephalus), American peregrine falcon (Falco 

peregrinus anatum), Navajo Mogollon vole (Microtus mogollonensis Navaho), western red bat 

(Lasiurus blossevillii), Allen’s lappet-browed bat (Euderma maculatum), pale Townsend’s bigeared bat (Corynorhinus townsendii pallescens) and spotted bat (Euderma maculatum) (see 

wildlife report, “Forest Service Sensitive Species” section). 

Plant species include: Arizona bugbane (Cimicifuga arizonica), rusby milkvetch (Astragalus 

rusbyi), Arizona leatherflower (Clematis hirsutissima var. hirsutissima), Flagstaff pennyroyal 

(Hedeoma diffusum), Arizona sneezeweed (Helenium arizonicum), Sunset Crater beardstongue 

(Penstemon clutei), Arizona phlox (Phlox amabilis), Blumer’s dock (Rumex orthoneurus) and 

Bebb’s willow (Salix bebbiana). 

Aquatic species include roundtail chub (Gila robusta), desert sucker (Catostomus clarki), Sonora 

sucker (Catostomus insignis), California floater (Anodonta californiensis) and A Caddisfly 

(Lepidostoma knulli) and A Mayfly (Moribaetis mimbresaurus) (see aquatics report, “Candidate 

Species” and “Forest Service Sensitive Species” section). 

Management Indicator Species 

Effects on management indicator species are disclosed in the FEIS (chapter 3). Since the DEIS 

was made available for comment in 2013, a new forestwide Coconino NF management indicator 

species report was produced and the Kaibab NF developed a new management indicator species 

list as part of the revised (2014) forest plan. 

On the Coconino NF, terrestrial management indicator species within the project area include 

northern goshawk, pygmy nuthatch and wild turkey (late seral ponderosa pine), elk, Abert’s 

squirrel (early seral ponderosa pine), hairy woodpecker (snags in ponderosa pine), red-naped 

sapsucker (late seral aspen and snags in aspen), mule deer (early seral aspen and pinyon juniper), 

juniper titmouse (late seral pinyon juniper and snags in pinyon juniper), and pronghorn (early and 

late seral grasslands). 

Effects to habitat trends range from no change (due to minimal percentage of habitat treated) to a 

stable or increasing change in habitat trend in both the short and long term. The selected 

alternative results in population trends that: do not change due to the minimal acres affected 

(juniper titmouse), change from decreasing to stable (mule deer), or increase in the long term. 

Only Abert’s squirrel may experience a short term disturbance that may cause the population 

trend to decrease before it increases in the long term (see wildlife report, “MIS for the Coconino 

NF” section). 

On the Coconino NF, the potential impacts from the selected alternative would not affect the 

forestwide trends for macroinvertebrate populations or the quality of their habitat. In the long 

term, the selected alternative would maintain or improve the current forestwide trends in riparian 

habitat (stable to improving) and in macroinvertebrate populations (stable) (see aquatics report, 

“Management Indicator Species” section). 

I, M. Earl Stewart, find that the selected alternative is consistent with the standards and guidelines 

pertaining to management indicator species. Additionally, based on the limited effects to any 

management indicator species, the selected alternative does not result in a long-term reduction in 

the number of acres of available habitat for any of the management indicator species, and does 

not contribute towards a negative trend in viability on the Coconino National Forest. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 39
Draft Record of Decision

On the Kaibab NF, management indicator species within the project area include Grace’s 

warbler and the western bluebird for ponderosa pine and pronghorn for grasslands. Effects to 

habitat trends range from stable to increasing in the short term and all habitats show an increasing 

in the long term. Population trends range from stable to increasing both in the short and long term

(see wildlife report, “Management Indicator Species for the Kaibab NF”). I, Michael R. Williams, 

find that the selected alternative is consistent with management indicator species forest plan 

components. The selected alternative does not result in a reduction in the number of acres of 

available habitat for management indicator species, and does not contribute towards a negative 

population or habitat trend on the Kaibab National Forest. 

Migratory Bird Treaty Act and Executive Order 13186

The selected alternative, with the design features, mitigation measures, and best management 

practices described in appendix C of the FEIS provides for adequate conservation measures for 

migratory birds. The migratory bird analysis discloses that thinning and broadcast burning 

operations activities may lead to loss of egg viability or injury or death to nestlings. Overall, 

unintentional take of some individual birds may occur. However, no measurable negative effect to 

any of the bird populations is associated with the selected alternative (FEIS chapter 3, “Migratory 

Birds” section).

National Historic Preservation Act

The National Historic Preservation Act and the NEPA both require that consideration be given to 

the potential effects of Federal undertakings on historic resources (including historic and 

prehistoric cultural resource sites). 

Initial concurrence on a heritage implementation strategy was received from Arizona State 

Historic Preservation Office (AZ SHPO) in accordance with section 106 of the National Historic 

Preservation Act in 2011. Implementation will be phased over several years as allowed by 

appendix J of the Southwestern Region Heritage Programmatic Agreement (for the phasing of 

section 106 compliance evaluations). Appendix J, the heritage strategy, and the project’s section 

106 report methods will be used to achieve a no adverse effect determination for the selected 

alternative.

Individual task orders or specific project areas will be evaluated by a forest heritage staff for 

inventory needs and then surveyed to the appropriate level as defined in the heritage 

(implementation) strategy. A section 106 report will be produced for each project area as they are 

identified. Consultation with the AZ SHPO and tribes will be completed prior to implementing 

each task order. 

The cultural resource analysis (FEIS, chapter 3) concluded potential effects to cultural resources 

will be avoided using the protection measures in the heritage protocol and section 106 clearance 

report, or the adverse effects will be mitigated. 

Per the Programmatic Agreement with AZ SHPO, there will be continued coordination and 

clearances conducted for each action proposed during implementation. Per agreement with 

affected tribes, coordination will occur prior to initiating project-specific task orders to identify 

traditional use areas and, if necessary, develop project-specific mitigation measures to 

accommodate traditional use of the forest. As part of ongoing tribal consultation, we will inform 

tribes on the timing, type, and amount of smoke tribes may experience during implementation. 

We find the selected alternative is in compliance with National Historic Preservation Act. 

40 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

Clean Water Act

Public Law 92-500, as amended in 1977 (Public Law 95-217) and 1987 (Public Law 100-4) (also 

known as the Federal Clean Water Act provides the structure for regulating pollutant discharges to 

waters of the United States. In Arizona, the designated agency for enforcement of the Clean Water 

Act is the Arizona Department of Environmental Quality (ADEQ). 

The selected alternative is expected to result in minor, short term adverse effects to water quality 

in water bodies within and adjacent to mechanical vegetation and grassland restoration treatment 

area. Best Management Practices and soil and water conservation practices will be applied to the 

selected alternative. These resource protection measures will minimize nonpoint source pollution 

as outlined in Memorandum of Understanding between the Arizona Department of Environmental 

Quality and the Forest Service Southwestern Region (ADEQ 2013). These measures will 

minimize or mitigate most adverse effects to water quality or riparian areas at the site-specific or 

localized scale. Based on the water quality and riparian analysis (water quality and riparian areas 

report), we find the selected alternative is consistent with the Clean Water Act. 

Clean Air Act

The FEIS (chapter 3, fire ecology) addresses and discloses impacts from prescribed fire as 

required by the Clean Air Act. Under the selected alternative, air quality impacts will be most 

likely to those portions of the Little Colorado River Airshed east and northeast of Flagstaff; the 

Colorado River Airshed north of Williams and including all of the treatment area in RU 6; and the 

Verde River Airshed. There is a small chance that there could be some impact to the northern 

portions of the Lower Salt River Airshed. In the short term, there will be air quality impacts 

during implementation of the selected alternative. However, National Ambient Air Quality 

Standards (NAAQS) will not be exceeded. In the long term, there will be less fuel and a lower 

emission potential once an area has received one burn. The combination of lower fuel loads and 

larger burn units will allow more acres to be burned without exceeding NAAQS (fire ecology and 

air quality report). We find this decision is compliant with the Clean Air Act. 

Executive Orders 11990 and 11988 - Wetlands and Floodplain Management

The water quality analysis concludes that there will likely be some minor, short-term, localized 

adverse effects to water quality from selected alternative activities. Best management practices 

and soil and water conservation practices (FEIS, appendix C) will minimize or mitigate most 

adverse effects to water quality or riparian areas at the site-specific or localized scale (water 

quality and riparian areas report). In the long term, riparian and wetland function (as evaluated as 

soil erosion above tolerance and areas of high severity fire) are expected to improve. The selected 

alternative protects floodplains and water quality adjacent to wetlands and is consistent with 

executive order direction. 

Executive Order 12898 - Environmental Justice

In response to a comment from the June 2012 NEPA update public meeting, the possibility of 

smoke-related environmental justice consequences in Snowflake, Arizona were evaluated. The 

community does not have a meaningfully greater percentage of minority residents than the state 

and Snowflake has a smaller proportion of individuals living in poverty than either the state or 

nation (U.S. Census Bureau 2010). In addition, the community is geographically distant from the 

project area, and therefore unlikely to experience acute smoke effects. As a result, Snowflake is 

not considered an environmental justice community in this analysis. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 41
Draft Record of Decision

The selected alternative will not reduce employment and income relative to current conditions, 

therefore, no disproportionate adverse economic effects will occur. The mill in Cameron, which is 

on the Navajo Nation, may benefit from increased wood supply from 4FRI. However, any effect 

to the mill is likely to be small. Changes in employment and income associated with the mill are 

more likely to be affected by activities unrelated to 4FRI, such as potential growth in Tuba City. 

Smoke emissions resulting from wildfires and prescribed burns can have health and quality of life 

consequences. Smoke is most likely to affect vulnerable populations, such as children, the elderly, 

and individuals in poor health. Limited communications technology, language barriers, and 

cultural differences may also limit the effectiveness of informing nearby residents of upcoming 

prescribed burns. These conditions would occur in all alternatives evaluated, including the no 

action alternative. Burn plans will be written for implementation of the proposed prescribed fires. 

The burn plans will include modeling to determine the most appropriate conditions under which 

to burn in order to minimize smoke impacts. Traditional and sacred forest uses will continue 

under the selected alternative (see socioeconomic report, Social Consequences; “Environmental 

Justice” section). 

Wild and Scenic Rivers Act 

No designated wild and scenic rivers will be affected by this decision. The Coconino NF revised 

forest plan (as currently written) has identified West Fork of Oak Creek (within Red Rock-Secret 

Mountain Wilderness) as an eligible wild and scenic river. There will be short-term effects 

associated with mechanical treatment and prescribed fire. The areas that overlap the proposed 

wild and scenic river boundary with the project have mitigation measures to protect soil and 

watershed, scenery, and other resources. The activities approved in this decision will help to 

protect potential values of the eligible wild and scenic river from the effects of wildfire (see 

recreation specialist report). 

Inventoried Roadless Areas

The 2001 Roadless Area Final Rule (36 CFR Part 294) established protections for inventoried 

roadless areas. The rule prohibits road construction, reconstruction, and timber harvest except for 

other than stewardship purposes. This decision does not include treatments within inventoried 

roadless areas. 

Permits, Licenses, and

Authorizations Needed to Implement the Decision

• Section 404 of the Clean Water Act outlines the permitting process for dredging or 

discharging fill material into waters of the U.S., including wetlands. Section 401 of the Act 

allows States and tribes to review and approve, set conditions on, or deny Federal permits 

(such as 404 permits) that may result in a discharge to state or tribal waters, including 

wetlands. When required to implement springs, streams, and temporary road construction and 

decommissioning, obtain a 404/401 permit from the U.S. Army Corps of Engineers.

• The Forest Service will coordinate with ADEQ and obtain water quality certification from 

ADEQ as needed prior to project implementation. 

• In accordance with the legal requirements set forth under Section 7 of the Endangered 

Species Act (16 U.S.C. 1536 (c)), formal consultation was conducted with FWS and a 

biological opinion was received on October 20, 2014. The U.S. Fish and Wildlife Service 

found that there would be no jeopardy to any species or adverse modification to any 

42 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 
Draft Record of Decision

designated critical habitat. Coordination will continue with the Fish and Wildlife Service

throughout project implementation as treatments are completed and effects monitored.

• Initial concurrence from Arizona State Historic Preservation Office (AZ SHPO) was received 

in accordance with Section 106 of the National Historic Preservation Act. Per the 

Programmatic Agreement with AZ SHPO, there will be continued coordination and 

clearances conducted for each action proposed during implementation. 

• Per agreement with affected tribes, coordination with federally recognized tribes will occur 

prior to initiating project-specific task orders to identify traditional use areas and, if 

necessary, develop project-specific mitigation measures to accommodate traditional use of the 

forest by tribal members.

• All burning will be coordinated daily with ADEQ. Burning will not take place on any portion 

of the project without prior approval from ADEQ. 

Implementation

The project implementation plan (appendix D) describes the linkage from the FEIS to the project 

specific work without the need for additional NEPA analysis (above and beyond this 

environmental analysis). It must be considered in conjunction with appendix C which provides 

the design criteria, best management practices, and mitigation measures. The implementation plan 

is comprised of several checklists including the Annual Implementation Checklist (FEIS, table 

117), Planned Acres by Treatment Type and Restoration unit (RU) (FEIS, table 118), NEPA, 

NFMA, ESA, CFLR Act Compliance Evaluation (FEIS, table 119), and Supporting 

Documentation (FEIS, table 120). 

The implementation plan includes several sections designed to guide project implementation. See 

page 17 for a description of each section. 

Monitoring

Input from the 4FRI stakeholders and the public was used to develop the monitoring and adaptive 

management plan included in appendix E of the FEIS. Appendix E also includes the monitoring 

plan for Mexican spotted owl, Arizona bugbane, and the adaptive management plan for roads, 

springs and ephemeral channels. 

Effective Date

If no objection is filed, implementation may begin on, but no sooner than the fifth business day 

following the end of the 45-day objection filing period (36 CFR 218.11). If an objection is filed, 

implementation may begin immediately following the date of the final decision.

Contact

For additional information concerning this draft decision and the final environmental impact 

statement, please contact Annette Fredette, Four-Forest Restoration Initiative team leader, by 

telephone at 928-226-4684 or by email at: afredette@fs.fed.us. Additional information is also 

available on the project website at: http://www.fs.usda.gov/main/4fri/planning. 

Four-Forest Restoration Initiative, Coconino and Kaibab National Forests 43
Draft Record of Decision

Responsible Official Signatures 

M. EARL STEWART

Forest Supervisor, Coconino National Forest 

MICHAEL R. WILLIAMS

Forest Supervisor, Kaibab National Forest

44 Four-Forest Restoration Initiative, Coconino and Kaibab National Forests