United States 

Department of

Agriculture

Forest 

Service

Southwestern

Region

Cibola 

National 

Forest and 

National 

Grasslands

May 2011

Forest Products Specialist 

Report

Kiowa, Rita Blanca, Black Kettle 

and McClellan Creek National 

Grasslands Plan Revision

Environmental Impact Statement 

Analysis

Submitted by: __/s/

Forestry Program Manager

Cibola National Forest and National Grasslands

_Ian Fox________________________

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Executive Summary

Alternative A (No Action) would continue activities as they are currently being managed. 

This alternative gives very little direction in management of forest products other than, 

“Current plan directs that areas should be evaluated for their suitability for firewood 

gathering and that firewood gathering would not be allowed in designated RNAs.” This 

Alternative would continue to provide forest products to the public but with no emphasis 

or clear direction that would develop projects for the purpose of providing for forest 

products.

Alternative B emphasizes the direction for what is currently being implemented at the 

project level through proposed actions and prescriptions. This Alternative provides more 

concise direction on when forest products would be generated from projects with an 

emphasis on forest products as by-product of treatments that move the ecosystems 

towards desired conditions. Alternative B direction states, “Grasslands would provide 

firewood, fuelwood and wildlings when consistent with meeting desired conditions. 

Individual firewood permits for personal use would be limited to the amounts typically 

needed for domestic household use in a year’s time if firewood is limited. Firewood and 

other personal use forest products would be offered free when fee permits are not 

practical. Managers recognize the right of Tribes to collect forest products for noncommercial traditional and cultural purposes. Forest Products plan components are not 

applicable to wilderness.” 

Alternative C is the same as A and B, except this alternative would recommend 

Wilderness Area in a portion of what is now the Mills Canyon Inventoried Roadless 

Area. However, this alternative would not differ in environmental consequences from A 

or B due to the fact that presently forest products are not gathered from the Mills Canyon 

Inventoried Roadless Area.

Overview of the Affected Environment

A small portion of the grasslands contains pinyon pine and juniper (pinyon-juniper) woodlands on 

the western half of the Kiowa NG and mixed-hardwood woodlands encroaching on the BK NG. 

Over the past 60 to 80 years, dependence on wood products has declined as lifestyles shifted from 

subsistence to ranching. There is a relatively low demand by rural residents for posts, poles, and 

firewood, and for vigas and latillas that are occasionally used as home building materials.

The supply of firewood on the grasslands is dependent on the amount of wood that has been 

thinned by grassland employees or contractors. On the KRB, cut down trees are left at thinning 

sites for the public to remove. This is a cost-effective way to meet ecological objectives.

The Kiowa NG provides just over 100 cords per year for sale. Market value has been about $100 

per cord, yielding revenues of about $10,000 per year. Demand is not expected to greatly 

increase, as the human population near the pinyon-juniper woodlands is low and declining.

Even though the supply of available wood on the Kiowa NG has fluctuated between 200 and 600 

acres during the period from 1998 to 2005, it has been adequate to meet the demand for wood 

from this remote area. It is projected that the supply will continue to adequately meet firewood 
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demand in this area as thinning is expected to continue in order to meet ecological objectives. 

Currently, about 500 to 900 acres of pinyon-juniper that are overstocked and encroaching onto the 

shortgrass prairie are thinned annually.

The BK NG has designated areas where the public may remove undesirable mixed hardwood 

trees for firewood. Although supply far outweighs demand, this activity helps to restore the native 

grassland ecosystem while providing a wood product. Average volume in mixed hardwood stands 

that are no longer needed as windbreaks or have escaped the original footprints of shelterbelts or 

windbreaks is about 941 cubic feet per acre (7.35 cords per acre). Some of the tree rows planted 

to Osage orange after the Dust Bowl have also been or are currently being harvested for posts. 

Even though employment income associated with woodcutting activities is negligible, it provides 

a resource that is important to individuals who rely on the cheap availability of these products to 

subsist. The gathering of wood products has not shown to be in conflict with other uses on the 

grasslands, and demand for this activity is not projected to increase or decrease significantly in 

the future.

Summary of Environmental Consequences

Environmental consequences incurred in providing forest products would include potential 

impacts to soils from the gathering of products, for example, user created roads, soil compaction, 

disturbance of established ground vegetation and disturbance of established wildlife feature such 

as nest or burrows. Common to all alternatives, theses consequences would be mitigated through 

the following methods 1) administration of permits and contracts, 2) limiting of forest product 

gathering during seasonal wet periods and 3) limiting gathering during wildlife breeding and 

foraging periods. 

Also common to all alternatives. Pinyon-juniper forest products would be available to the public.

Under alternatives B and C. invasive tree forest products would be available on 1,000 to 2,000 

acres on the BK NG. Forest product availability would be limited in the pinyon-juniper 

vegetation type on the KRB NGs from April 15 to July 31.

Under alternative C, removal of some forest products could be prohibited in the potential 

wilderness area, even by non-motorized, non-mechanical methods.

Specialist Report

Introduction

This report discloses and evaluates the potential environmental consequences on the Forest 

Products resource that may result with the adoption of a revised land management plan. It 

examines, in detail, three different alternatives for revising the management direction from the 

1985 Cibola National Forest Land Management Plan (only that which is relevant to the National 

Grasslands).
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Relevant Laws, Regulations, and Policy that Apply 

National Environmental Policy Act of 1969

National Forest Management Act of 1976

Tribal Consultation on Section 8105 of the Food, Conservation and Energy Act of 2008

36 CFR part 223, 261 Sale and Disposal of National Forest System Timber; Special Forest 

Products and Forest Botanical Products

Forest Service Handbook 2409.18 Timber Sale Preparation 

Forest Service Handbook 2409.19 Renewable Resources

Forest Service Handbook 2409.15 Timber Sale Administration

Forest Service Handbook 1909.15 National Environmental Policy Act

36 CFR 223.1 Authority to Sell Timber

36 CFR 223.2 Disposal of Timber for Administrative Use

36 CFR 223.5 Scope of Free Use Granted to Individuals

36 CFR 223.6 Cutting and removal of Timber in Free-use Areas

36 CFR 223.7 Permission for Free Use of Timber outside Free-use Areas

36 CFR 223.8 Delegations of Authority to Approve Free-use by Individuals

Forest Service Manual 2431

Forest Service Manual 2463

Forest Service Manual 2467

Forest Service Manual 2462

16 U.S.C 2104 Note Stewardship Contracts and Agreements

Methodology and Analysis Process

The plan components (ie., objectives, suitability, guidelines, standards, and monitoring elements) 

and management approaches of other resource areas were evaluated against the desired conditions 

for Forest Products to determine if achieving the desired conditions was affected positively, 

negatively, or not at all.
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Conversations were had at various times between myself, the Black Kettle District Staff and 

Supervisor Office personnel discussing the existing condition where black locust and eatern red 

cedar are encroaching on the grassland areas.

I have made several site visits to Mills Canyon over the past 2.5 years to assess the existing 

condition, especially in pinion juniper areas located on the rim of the canyon.

Assumptions

In the analysis for this resource, the following assumptions have been made:

• The land management plan provides a programmatic framework for future site-specific 

actions.

• Land management plans do not have direct effects. They do not authorize or mandate any 

site-specific projects or activities (including ground-disturbing actions).

• Land management plans may have implications, or environmental consequences, of 

managing the forests under a programmatic framework.

• The plan decisions (desired conditions, objectives, standards, guidelines, management 

areas, monitoring) will be followed when planning or implementing site-specific projects 

and activities.

• Law, policy, and regulations will be followed when planning or implementing sitespecific projects and activities.

• Monitoring will occur and the land management plan will be amended, as needed.

• We will be funded similar to past budget levels (past 5 years).

• The planning timeframe is 15 years; other timeframes may be analyzed depending on the 

resource (usually a discussion of anticipated trends into the future).

Revision Topics Addressed in this Analysis

Existing laws, regulations, and policies provide the legal direction for the management and 

disposal of forest products. The desired condition for forest products in this revision is to 

continue to provide for them where they are by-products of projects that are meeting other desired 

conditions of the plan, such as removing non-native tree species or where thinning pinion juniper 

improves wildlife habitat and/or improves watershed conditions. Unless existing laws, 

regulations and policies that grant the Forest Service the authority to dispose of forest products 

drastically change, then the desired condition would be met as described in Alternative B and C.

Summary of Alternatives

1) Alternative A allows for the disposal of forest products through sales or freeuse but gives little direction of where or for what purpose other than areas 
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should be evaluated for their suitability for firewood gathering and that 

firewood gathering would not be allowed in designated RNAs.

2) Alternative B would provide direction for the disposal of forest products 

through sales or free-use and would give clear direction on when and how 

disposal would occur. Grasslands would provide firewood, fuelwood and 

wildlings when consistent with meeting desired conditions. Individual

firewood permits for personal use would be limited to the amounts typically 

needed for domestic household use (typically about 12 cords) in a year’s time 

if firewood is limited. Firewood and other personal use forest products would 

be offered free when fee permits are not practical. Managers would recognize 

the right of Tribes to collect forest products for non-commercial traditional 

and cultural purposes. 

3) Alternative C would be similar to Alternative B except C would recommend a 

Canadian River Wilderness Area. The recommended Wilderness Area would 

have no direct impact on the desired conditions to provide for forest products 

because the proposed wilderness area is a current Inventoried Roadless Area 

where product removal does not occur due to restrictions on tree cutting and 

removal within an IRA without the Secretary of Agriculture’s approval.

Description of Affected Environment (Existing Condition)

A small portion of the Grasslands contains “forested” areas consisting of piñon pine and juniper 

(piñon-juniper) woodlands on the western half of the Kiowa National Grassland and black locust 

woodlands encroaching on the mixed grass prairie of Black Kettle National Grassland.. Over the 

past 60 to 80 years, the level of dependence on wood products has declined as lifestyles shifted 

from subsistence to an agricultural ranching lifestyle. There is a relatively low demand by rural 

residents for posts, poles and firewood, and for vigas and latillas that are occasionally used as 

home-building materials. 

The supply of firewood on the Grasslands is dependant on the amount of wood that has been 

thinned by Grassland employees. Employees leave the cut-down trees at thinning sites for the 

public to remove. This is a cost-effective way to meet ecological objectives.

The Kiowa National Grassland provides an average of 10-30 cords per year for (free) personal 

use and just over 100 cords per year for sale. Market value has been approximately $100/cord, 

yielding revenues of approximately $10,000/year (USDA Forest Service 2005b). Demand is not 

expected to greatly increase as populations near the piñon-juniper woodlands are quite low and 

continuing to decline. 

Even though the supply of available wood on the Kiowa National Grassland has fluctuated 

between 200 and 600 acres during the period 1998-2005., it has been adequate to meet the 

demand for wood from this remote area. It is projected that the supply will continue to adequately 

meet firewood demand in this area as thinning is expected to continue in order to meet ecological 

objectives. Stands of piñon-juniper that are overstocked and encroaching onto the shortgrass 
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prairie are being treated using thinning and prescribed burning. Currently, the level of treatment is 

approximately 500-900 acres of thinning a year

On the Black Kettle National Grasslands, there are designated areas where the public may remove 

black locust trees for firewood. Although supply far outweighs demand, providing for this activity 

helps reduce the prevalence of this invasive tree to restore the native grassland ecosystem while 

providing a wood product. Average volume in black locust stands that no longer are needed as 

windbreaks or have escaped the original footprints of shelterbelts or windbreaks is estimated at 

approximately 941 cubic feet peracre (7.35 cords per acre). It is estimated that up to 1,000 acres 

of black locust trees would be masticated for chips or harvested for fire wood or posts or other 

products for each of the next two 10-year time periods and 500 acres in the third time period. 

Some of the tree rows planted to Osage orange after the Dust Bowl have also been or are 

currently being harvested for posts. 

Even though employment income associated with wood cutting activities is negligible (UNMBBER 2005), it provides a resource that is important to individuals who rely on the cheap 

availability of these products to subsist. The gathering of wood products has not shown to be in 

conflict with other uses on the Grasslands and demand for this activity is not projected to increase 

or decrease significantly in the future.

Environmental Consequences

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Because the land management 

plan does not authorize or mandate any site-specific activities or ground-disturbing actions there 

can be no direct effects. However, there may be implications, or longer term environmental 

consequences, of managing the forests under this programmatic framework. 

Environmental consequences incurred in providing forest products would include potential 

impacts to soils from the gathering of products, for example, user created roads, soil compaction, 

disturbance of established ground vegetation and disturbance of established wildlife feature such 

as nest or burrows. Common to all alternatives, theses consequences would be mitigated through 

the following methods 1) administration of permits and contracts, 2) limiting of forest product 

gathering during seasonal wet periods and 3) limiting gathering during wildlife breeding and 

foraging periods. 

Also common to all alternatives. Pinyon-juniper forest products would be available to the public.

Under alternatives B and C. invasive tree forest products would be available on 1,000 to 2,000 

acres on the BK NG. Forest product availability would be limited in the pinyon-juniper 

vegetation type on the KRB NGs from April 15 to July 31.

Under alternative C, removal of some forest products could be prohibited in the potential 

wilderness area, even by non-motorized, non-mechanical methods.

Cumulative Environmental Consequences

There are no known cumulative environmental consequences regarding special forest products.
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Unavoidable Adverse Impacts

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Before any ground-disturbing 

actions take place, they must be authorized in a subsequent environmental analysis. Therefore 

none of the alternatives cause unavoidable adverse impacts.

Irreversible and Irretrievable Commitment of Resources 

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Because the land management 

plan does not authorize or mandate any ground-disturbing actions, none of the alternatives cause 

an irreversible or irretrievable commitment of resources.

Adaptive Management

All alternatives assume the use of adaptive management principles. Forest Service decisions are 

made as part of an on-going process, including planning, implementing projects, and monitoring 

and evaluation. The land management plan identifies a monitoring program. Monitoring the 

results of actions will provide a flow of information that may indicate the need to change a course 

of action or the land management plan. Scientific findings and the needs of society may also 

indicate the need to adapt resource management to new information. The Forest Supervisor 

annually evaluates the monitoring information displayed in the evaluation reports through a 

management review and determines if any changes are needed in management actions or the plan 

itself. In general, annual evaluations of the monitoring information consider the following 

questions:

• What are the effects of resource management activities on the productivity of the land?

• To what degree are resource management activities maintaining or making progress 

toward the desired conditions and objectives for the plan?

• What changes are needed to account for unanticipated changes in conditions?

In addition to annual monitoring and evaluation, the Forest Supervisor reviews the conditions on 

the land covered by the plan at least every 5 years to determine whether conditions or demands of 

the public have changed significantly. The forest plan is ordinarily revised on a 10-year cycle and 

the Forest Supervisor may amend the plan at any time. 

Consistency with Law, Regulation, and Policy

All alternatives are designed to guide the Kiowa, Rita Blanca, Black Kettle and McClellan Creek 

National Grasslands’ management activities in meeting federal law, regulations, and policy.
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Other Planning Efforts

There are no potential conflicts between the proposed action and objectives of federal, regional, 

state forest assessments or state wildlife action plans, local or tribal land use plans.

List of Preparers

Ian Fox, Forestry Program Manager, Cibola National Forest. 

Bachelor Degree of Science in Forestry “Resource Management”, University of 

Tennessee 1998. 

I began my career with Forest Service in 1999 as a seasonal timber marker and cruiser for 

1999 and 2000 field seasons. I also worked for the Colorado State Forest Service in the 

winter of 1999 writing a Land Management Plan for parcel of State Land. In 2001 I 

became a Forester for the Florida Division of Forestry on Goethe State Forest

specializing in timber sale preparation, timber sale administration, reforestation and 

prescribe burning. In 2002 I became a Forester on the Prescott National Forest in 

Arizona specializing in timber sale and mechanical restoration contracts, timber sale 

cruise designs, program management duties and budget. In 2008 I moved to the Cibola 

National Forest in New Mexico as the Collaborative Restoration Program Coordinator 

specializing in administering grants and agreements related to fuel reduction and 

restoration activities. In 2009 I was promoted on the Cibola National Forest to the 

Forestry Program Manager specializing in supervision of the forestry organization, 

program management and budget.