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Kiowa, Rita Blanca, Black Kettle and McClellan 

Creek National Grasslands

CER Supplementary Document

to meet AMS Requirements

January 2010

Introduction

The Kiowa, Rita Blanca, Black Kettle and McClellan Creek National Grasslands (the Grasslands) plan 

revision process conforms to the 1982 Planning Rule provisions, including those for conducting an 

Analysis of the Management Situation (AMS). The AMS procedures require the Grasslands to develop

and/or verify benchmarks for setting the evaluation space for alternatives, analyzing existing conditions 

and trends, making projections of future demand, and identifying public issues and management concerns 

in order to determine the need to change current plan direction. The Grasslands released a 

Comprehensive Evaluation Report (CER) in September 2008, which accomplished many of the above 

requirements prior to enjoinment of the 2008 planning rule in June 2009. Language and concepts specific 

to the enjoined 2008 rule, such as Species of Concern/Species of Interest, that are found within the CER 

will not be carried forward into plan development and National Environmental Policy Act Environmental 

Impact Statement evaluation of the plan; however, concepts that still apply under the 1982 rule

provisions, such as coarse filter/fine filter analyses, will be carried forward. Most of the material 

developed for the 2008 Grasslands CER meets AMS requirements, and there is no need to redo or 

reformat that material. The additional information below supplements the CER to fully conform to the 

remainder of the AMS requirements. It, along with the CER document, provides the basis for 

development of a new Grasslands plan.

Benchmark Analysis

Benchmark analyses are one of the required components of the 1982 Planning Rule provisions pertaining 

to the AMS. Benchmark analyses define the range within which alternatives are to be developed and 

analyzed in an environmental impact statement (EIS) analysis by identifying the maximums and 

minimums that each alternative should fall within. Selection of benchmarks depends primarily on the 

topics to be addressed during new plan development. 

All National Forests and Grasslands in the Southwestern Region developed benchmarks during 

development of their original plans. Benchmarks were established for timber resources, as well as for 

livestock grazing, recreation, wildlife, wilderness, and other key resources. They were evaluated for their 

physical and biological production potential, and monetary benchmarks were run for those resources 

having an established market value.

In the 1985 Final Environmental Impact Statement for the Cibola National Forest Plan (the 1985 Plan), 

the Forest established 14 economic benchmarks to set a minimum and maximum range for outputs for the 

development of alternatives. These benchmarks were developed cumulatively for the mountain districts 
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and the Grasslands. Of these 14, five do not apply to the National Grasslands, six need to be adjusted for 

the smaller geographic extent of the Grasslands alone, and three have been reviewed and deemed 

adequate to set the range of the alternatives that may be developed as part of Grasslands plan revision. 

Benchmarks from the 1985 plan that have been determined to not apply to the National Grasslands are:

• Net Merchantable Timber Volume [Thousand cubic feet (MCF)] – There are no areas suitable for 

timber production on the Grasslands

• Net Sawtimber Value [Thousand Board Feet (MBF)] - There are no areas suitable for timber 

production on the Grasslands

• Long Term Sustained Yield Capacity [MCF] - There are no areas suitable for timber production on 

the Grasslands

• Wilderness Recreation [Thousand Recreation Visitor Days (MRVD)] – Currently, there are no 

designated wilderness areas on the National Grasslands. 

• Water Yield [Acre Feet (ACFT)] – Water yield is more relevant to the mountain districts of the 

Cibola National Forest than the Grasslands because of the steeper topography of the mountain 

districts. Changes in management approach on the Grasslands are not likely to have a measureable 

effect on water yield and therefore, it is not a meaningful way to bound alternatives.

The following benchmarks have been reviewed, validated, and found appropriate to be carried forward 

from the 1985 Plan into the new Grasslands plan, because it is unlikely that an alternative would be 

developed that falls outside of their minimum and maximum values:

• Developed Recreation [MRVD]

• Grazing Capacity – Non-priced Output [Thousand Animal Unit Months (MAUM)]

• Permitted Livestock Use [MAUM]

Benchmarks that need to be modified from Forest-wide values to fit the Grasslands alone are:

• Dispersed Recreation [MRVD] – The minimum level benchmark for dispersed recreation far exceeds 

the number of recreation visitor days on the National Grasslands according to the 2005 National 

Visitor Use Monitoring surveys.1

 Using the data in the survey, it was determined that the average 

duration of visit to the National Grasslands was 46.9 hours, and there were 56,600 visits estimated for 

2005. Of those visits, approximately 50.6% percent were dispersed recreation. Therefore, there were 

approximately 111.9 MRVDs of dispersed recreation on the Grasslands (See calculation). 

(56,600 visits) X (46.9 hours/12 hours) = 221,211.7 Recreation Visitor Days2

(221,211.7 RVDs X 50.6%3

=111,933 RVDs or 111.9 MRVDs

Because there is good evidence that this number is realistic for the number of dispersed recreation 

visits to the Grasslands, it was selected as the minimum benchmark for the Grasslands. It is expected 

that there would be at least 109.3 MRVDs in future years because the year the data was collected had 

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 Even though the upper bound is very high it is not necessary to change it because all the alternatives developed 

will easily fall within it.

2 A recreation visitor day is a visit of 12 hours. So the average visitor to the Grasslands spends 3.9 RVDs but makes 

only one visit.

3 The percent age of visitors who used dispersed recreation sites according to the 2005 NVUM.
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several lengthy fire closures and a fire which burned over one of the most popular recreation sites on 

the Grasslands.

• Wildlife Recreation [MRVD] – Because there is not enough information to adjust this benchmark 

separately from dispersed recreation, it will be folded into the figures for dispersed recreation.

• Soil Loss [Thousand Tons (MTONS)]1 – The minimum level benchmark given for soil loss of 2102.5 

MTONs in the 1985 plan is too high for the Grasslands because it includes all the Cibola National

Forest System lands (1,875,597 acres), of which the National Grasslands are only a portion (262,232 

acres). Although the rate of soil loss implicit in the minimum benchmark is reasonable, the fact that it 

accounts for approximately seven times as many acres as exist on the Grasslands makes it too high to 

be used going forward. The minimum level soil loss benchmark was, therefore, adjusted as a 

proportion of the total acres of the Cibola National Forest to 294 MTONS on average per year (See 

Calculation).

(262,232 acres/1,875,597acres) X 2102.5MTONs = 294.0 MTONs

• Net Products Value, Firewood Sold and Personal Use (free) Firewood [MBF] – These three 

benchmarks in the 1985 Plan are not distinct in terms of outputs on the National Grasslands. The 

Grasslands therefore combined these into one Forest Products benchmark using the more 

contemporary measure of hundreds of cubic feet (CCF). The vegetation types that were included in 

the calculation of these benchmarks were the pinyon-juniper stands on the Kiowa and Rita Blanca 

National Grasslands excluding the Inventoried Roadless Area, and black locust on the Black Kettle 

National Grasslands. These vegetation types are the only ones where harvest of forest products is 

expected to be used as a means of achieving plan goals. 

o The maximum benchmark was calculated assuming that the average stand volume in black 

locust was 9.41 ccf/acre and that at most 1,000 acres would be treated for each of the first two

10-year time periods and 500 acres in the third time period. It was further assumed that most 

of the black locust would be removed over the cumulative 2,500 acres, with a few possible 

exceptions. This calculation resulted in an average annual output of 941 ccf for the first two 

periods and 470.5 ccf for the third period.

(9.41ccf/acre) X (2,000 acres) / 20 years = 941 ccf

(9.41ccf/acre) X (500 acres) / 10 years = 470.5 ccf

o For pinyon-juniper, it was assumed that the average stand volume that would be removed by 

thinning would be 2.01 ccf/acre and that 2,500 acres would be treated every 10 years. This 

calculation resulted in an average annual output of 502.5 ccf.

(2.01 ccf/acre) X (2500 acres) / 10 years = 502.5 ccf

The range of expected alternatives developed during Grasslands plan and EIS development should fall 

within the maximums and minimums established by the below benchmarks (See Table 1). If, in the 

process of alternative development, it is discovered that an alternative falls outside the range of the

benchmarks, then the affected benchmark will need to be re-evaluated and re-established as necessary. 
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Table 1: Benchmarks for Grasslands Plan Revision - Average Annual Output

Time Period/1

Type of Benchmark 2006-2015 2016-2025 2026-2035

Forest Products (CCF)/2 Max 1,443.5 1,443.5 973

Min 0 0 0

Developed Recreation (MRVD) /4 Max 1,702.1 2,042.9 2,249.1

Min 0 0 0

Grazing Capacity (MAUM) – Non-priced Output/4 Max 230.3 236.8 241.0

Min 0 0 0

Permitted Livestock Use (MAUM) /4 Max 214.7 227.3 236.9

Min 0 0 0

Dispersed Recreation (MRVD) /3 Max 939.0 1127.4 1281.1

Min 111.9 111.9 111.9

Soil Loss (MTONS) Max 5,643.4 5,676.8 5,717.2

Min 294 294 294

1) The Time periods shown were established in the 1985 plan and were kept for this analysis.

2) This benchmark combines the original benchmarks of Net Products Value, Firewood Sold and Personal Use (free) Firewood.

3) This benchmark combines the original benchmarks of Dispersed Recreation, Wildlife Recreation and any potential Wilderness 

Recreation that may occur in an alternative when analyzed in an environmental impact statement.

4) These benchmarks are unchanged from our existing Forest Plan.

Projections of Demand 

This is a summary of the projections of demand analysis required under the 1982 Planning Rule 

provisions. Projected future demand for forest resource-use was estimated using existing data and reports

from federal, state, and forest-specific sources. This analysis is primarily a qualitative description of 

possible future resource demands.

Demand for grazing was not analyzed in the 2008 CER, and this analysis is necessary to meet the 

requirements for an AMS. The share of total demand for grazing within the market area (as measured by 

cattle inventory) that could be supported by these levels of permitted use on the Cibola National Forest 

and National Grasslands has ranged from a high of 3.6 percent in 1999 to a low of 1.8 percent occurring 

in 2004, 2006 and 2009. However, this does not consider effects on actual use due to factors such as 

drought, financial limitations on operators and market conditions. In addition, the supply of grazing is 

limited, and other resource considerations may limit grazing use in addition to these factors. While the 

share of total demand provided by the forest and grasslands is small, it may be more important for smaller 

areas within the market area. However, this trend is uncertain given the wide degree of variation in 

permitted use over the relatively short period examined. Despite these changes, the Forest Service’s 2008 

CER comes to the conclusion that there is no indication that there will be a major increase or decrease in 

grazing on the Grasslands over the next 20 years; however, cattle numbers and management strategies are 

expected to continue to fluctuate in response to drought, wildfire, prescribed fire, and other factors that 

change range conditions, such as prairie dog colonies (USDA 2008).
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An analysis of the projected demand for recreation can be found on pp. 21-27 of the Socio-Economic 

Sustainability Evaluation Report for the Kiowa, Rita Blanca, Black Kettle and McClellan Creek National 

Grasslands dated December 4, 2007 (http://www.fs.fed.us/r3/cibola/planrevision/national_grasslands/social.shtml) This analysis has been reviewed and is sufficient to meet the 

requirements for the AMS.

There are no “Lands Suitable for Commercial Timber Production” on the National Grasslands. Since no 

supply exists on these units, it was not necessary to project demand for commercial timber.

MIS

Management Indicator Species (MIS) are species selected during the planning process because their 

population trends may indicate the effects of management activities. MIS are also selected to allow 

evaluation of the differences between alternatives in the revised plan’s EIS. There may be a need to 

change the MIS identified in the 1985 Plan to reflect changes in management direction made during new 

plan development, to aid in the evaluation of alternatives in an environmental impact study, and

ultimately, to evaluate future management activities. 

Oil and Gas

Amendment #12 (August 2008) to the 1985 Cibola National Forest Plan amended the standards for the 

management of Oil and Gas Leasing on the Grasslands. The amendment established areas of No Surface 

Occupancy and Controlled Use across the Grasslands for new leases. Because the 2008 CER was being 

developed at the same time as Amendment #12, these stipulations were not taken into account in the Need 

for Change analysis. A recent review of these stipulations and the associated NEPA documentation 

shows that they do not constitute a need for change to the 1985 Plan and will be carried forward as they 

are into the new Grasslands plan. 

Review of Need for Change

The need to change the Grassland-specific components of the 1985 Plan that were identified in the 2008

CER document were re-evaluated in this supplementary document in light of the above and other

relevant information. Two needs for change that were identified in the previous CER are, based on 

subsequent analysis and evaluation, inappropriate and are thus removed as needs for change in revising 

the 1985 plan. They are:

1) “The revised plan should acknowledge the need to conduct appropriate project-level analysis to 

mitigate site-specific impacts from on-going use of OHV trails at McClellan Creek National 

Grassland.”

2) “The revised plan needs to address how prescribed fires can be managed across jurisdictional 

boundaries to improve ecological conditions and wildlife habitat on and around the National 

Grasslands.”

Item number one was indeed addressed within a Forest and Grasslands-wide context in the 1985 plan and 

is being carried forward in the new Grasslands plan. Item number two is similarly addressed in the 1985 

plan, and direction is being carried forward to the new Grasslands plan.
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With the addition of the need to change MIS and the removal of the two redundant needs discussed 

above, all other needs for change previously identified remain valid. The topics identified to be carried

forward into new plan development also remain valid.