United States 

Department of

Agriculture

Forest 

Service

Southwestern

Region

MB-R3-05-5

November 2011

Record of Decision and 

Finding of Nonsignificant 

Forest Plan Amendment 

for the Pinaleño 

Ecosystem Restoration 

Project

Coronado National Forest, Graham

County, Arizona
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Pinaleño Ecosystem Restoration Project, Coronado National Forest 1

Record of Decision and 

Finding of Nonsignificant Amendment

Introduction

The Pinaleño Ecosystem Restoration Project is designed to improve forest health and improve or 

protect red squirrel habitat. It also includes administrative actions to incorporate amendments to 

the “Coronado National Forest Land and Resource Management Plan” (referred to as the “forest 

plan”), which will allow on-the-ground treatments to be implemented. An environmental impact 

statement (EIS) was developed to analyze the potential effects of the Pinaleño Ecosystem 

Restoration Project. Three alternatives were considered and analyzed. The EIS was finalized in 

March of 2010 and made available to the public on April 28, 2010, on the Coronado National 

Forest Web site. This record of decision documents the alternative I have selected and the 

rationale for my decision.

Background of the Project

The Pinaleño Ecosystem Restoration Project area is approximately 5,754 acres located in Graham 

County, in Townships 8 and 9 South, Ranges 23 and 24 East (figure 1). The project area is in the 

Pinaleño Ecosystem Management Area and contains lands that fall within Management Area 2 

(dispersed recreation, mixed-conifer), Management Area 2a (wilderness values, enhanced 

wildlife), and Management Area 8 (research) of the Coronado forest plan. The forest plan states 

that management for the Mount Graham red squirrel (Tamiasciurus hudsonicus grahamensis) is a 

primary objective. This direction is reinforced in the “Record of Decision for Amendment of 

Forest Plans, Arizona and New Mexico” (USDA Forest Service 1996).

The project area lies within the Pinaleño Mountains, a massive mountain range of over 300 

square miles. Rising from the surrounding semidesert grasslands to the forest’s only subalpine 

forest, the mountain range includes the highest cross section of ecological communities found in 

the Southwest. It is home to numerous endemic or rare wildlife and plant species including the 

endangered Mount Graham red squirrel and the threatened Mexican spotted owl (Strix 

occidentalis lucida). 

Its highest point, 10,720-foot Mount Graham (known by local tribes as Dził Nchaa Si’an), has 

been formally recognized, along with the entire Pinaleño Ecosystem Management Area, as a 

traditional cultural property important to the Western Apache and has been determined eligible for 

listing on the National Register of Historic Places. Many other residents of southeastern Arizona 

also consider Mount Graham a special place, often retreating to the mountain for relief from 

summer heat. Because of this, the Forest Service has principally managed the mountain for its 

recreational and scenic values. 

Active fire suppression and other factors in the Pinaleño Mountains over the past 100 years have 

drastically reduced the role of natural fire, causing the forests there to become dense and filled 

with dead and down trees. These conditions have led to a high potential for severe wildfires. In 

1996 and 2004, large wildfires burned with active crown-consuming fire, which reduced red 

squirrel population numbers directly by killing some of them, and indirectly by burning through 

their habitat. 
Record of Decision and Finding of Nonsignificant Amendment

2 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Figure 1. Location of the Pinaleño Ecosystem Restoration Project
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 3

Progressive insect infestations, beginning in 1996, began defoliating and killing trees in the 

spruce-fir and mixed-conifer forests. The dead and dying trees resulting from these outbreaks has 

resulted in increased wildfire potential and a further decline in the red squirrel population through 

habitat loss and decreased cone crops. Census estimates of the red squirrel population dropped 

dramatically in the late 1990s, and have not recovered to pre-insect infestation levels since. 

Viability of the subspecies is of paramount concern. The moist mixed-conifer forest is now the 

primary remaining habitat for the red squirrel. Fires and insect infestation effects have heightened 

the current concern for protecting remaining red squirrel habitat, and raised the need for restoring 

degraded habitat.

In response to these conditions, the Forest Service has worked closely with the Arizona Game and 

Fish Department and the U.S. Fish and Wildlife Service in an interdisciplinary team of resource 

professionals to develop the Pinaleño Ecosystem Restoration Project.

My Decision 

This record of decision documents my decision and rationale for the selection of Alternative 2 but 

with modifications as described on the next page. It also documents my finding that the proposed 

amendments to the forest plan are not significant (see finding on page 15 of this document). 

Alternative 2 is described in the FEIS between pages 17 and 32. My decision includes the 

associated transportation system, the design features and mitigation measures (FEIS, appendix A), 

forest plan amendments (FEIS chapter 2, p. 36), and monitoring (FEIS, appendix B) as described 

in the FEIS. My conclusion is based on a thorough review of the final environmental impact 

statement, public comments, and the project record. I considered relevant scientific information, 

public concerns and opposing viewpoints, incomplete or unavailable information, scientific 

uncertainty, and risk. 

On a landscape scale, the project works toward the goal of reducing the risk of and increasing the 

resistance to wide-scale disturbance events from wildfire, insects, and disease. However, this 

project is primarily designed to protect and improve the long-term sustainability of the habitat for 

the endangered Mount Graham red squirrel. This project will be accomplished over a 10-year 

period, following an implementation schedule that will prioritize treatments to most directly 

protect occupied red squirrel habitat and provide for quick monitoring feedback on potential 

effects to Mount Graham red squirrels and their habitat. 

As directed by the Coronado forest plan, project design prioritized the policy requirements of an 

endangered endemic subspecies, the Mount Graham red squirrel, over those of a wider ranging 

threatened subspecies, the Mexican spotted owl, and prioritized both over the policy requirements 

of the northern goshawk (Accipiter gentilis), a Forest Service sensitive species, and the policy 

requirements of old growth forests. Two strategies were developed to reduce potential fire 

behavior and to initiate a restoration process for improving forest resilience to bark beetle 

disturbance. Both would lessen threats to habitat while insuring only low levels of potentially 

harmful direct impacts to the two listed species, balancing long-term benefits with short-term 

impacts. The selected strategy, Alternative 2, closely adheres to the recovery plan for the Mount 

Graham red squirrel and the best available science concerning the squirrel. 

A second action alternative, Alternative 3, attempted to strictly apply the Mexican spotted owl 

standards and guidelines while also attempting to meet needs of the Mount Graham red squirrel.
Record of Decision and Finding of Nonsignificant Amendment

4 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Red squirrels and spotted owls require similar old growth conditions as part of their habitat 

requirements; however, there were inherent conflicts in Alternative 3 treatment priorities. See 

page 11 for a detailed explanation.

In selecting and modifying Alternative 2, I carefully reviewed disclosures in chapter 3 of the FEIS 

regarding how well the alternative will achieve our objectives. Notable conclusions include:

• Alternative 2 will treat the most acres (2,641) with the overlap of activities (such as 

thinning, prescribed fire, and other fuel reduction treatments) providing the most reduced 

potential for stand-replacing wildfire (FEIS, p. 46), which is the primary threat to the 

Mount Graham red squirrel. 

• Alternative 2 will increase the amount of area that supports surface fire rather than active 

and passive crown fires with flame lengths that exceed those that can be fought with 

direct attack (FEIS, p. 108). 

• Alternative 2 will thin trees under a forest restoration prescription across the most 

acreage (1,722 acres), applying variable density thinning, thinning from below, and group 

selection treatments. Compared to the other alternatives, this alternative will produce the 

largest and most long-standing effects reducing insect and disease susceptibility and 

increasing tree growth and vigor, while retaining greater structural diversity and 

providing for long-term sustainability of the ecosystem (FEIS, p. 73).

• Alternative 2 will treat additional acres (849 acres) under an important wildlife treatment 

prescription by applying variable density thinning, thinning from below, and group 

selection treatments to only the smaller diameter trees and snags (maximum 9-inchdiameter limit), and retain higher overstory stocking levels (more trees per acre) within 

forest stands within the most important wildlife areas including Mexican spotted owl core 

areas (166 acres).

• Effects to existing and potential Mount Graham red squirrel habitat are similar in both 

Alternatives 2 and 3. However, Alternative 2 will increase tree growth and vigor to a 

greater extent on the most acreage resulting in moving more stands closer to old-growth 

characteristics preferred by the Mount Graham red squirrel, producing larger and more 

frequent cone crops, and creating the potential to provide more habitat to the species over 

the long term (FEIS pp. 101-107). 

• The application of prescribed fire, lop and scatter, pile and burning, mastication and 

small-diameter thinning, will maintain or enhance fire-dependent ecosystems (2,641 

acres). 

Modification of Alternative 2

Modifications Resulting from Inventoried Roadless Area Direction

Upon completion of the FEIS, the forest recognized that a 308-acre portion of the treatments in 

Alternative 2 were located within the Pinaleno Inventoried Roadless Area. Although this is only 

0.23 percent of the roadless area acres, and treatment within this area either met or could be 

modified to meet our inventoried roadless area guidelines, the forest failed to inform the public of 

the status of this land through the NEPA scoping process. Because of this failure, I have elected to 

drop these acres from the proposal. The inventoried roadless area treatment units dropped from 

the project are listed in appendix A.
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 5

Project Modifications Resulting from the 

Endangered Species Act (Section 7) Consultation Process

During the Endangered Species Act Section 7 consultation process with the U.S. Fish and 

Wildlife Service (USFWS), treatment modifications and additional design features were 

developed in order to reduce the level of incidental take issued by the USFWS. These 

modifications are all related to Mexican spotted owl conservation. Changes were made to the 

project that will reduce potential impacts to six of the Mexican spotted owl protected activity 

centers in the project area. 

In some cases, our changes involved small modifications to treatment unit boundaries to 

completely avoid entry into a protected activity center. In other protected activity centers, we 

dropped some units near core nesting or roosting sites from the project. I have also decided to 

defer a decision at this time on an entire implementation subdivision, Clark Peak, because of 

potential impacts to two protected activity centers. The forest may reinitiate consultation at a later 

time on this unit after initial monitoring results are reviewed.

An additional projectwide design feature was added that restricts all project treatment actions to 

the nonbreeding season of the Mexican spotted owl. Only monitoring and project preparation 

activities will occur between March 1 and August 31 each year. 

Changes to Alternative 2 are listed in appendix B and summarized below. A final project map is 

attached at the end of this document.

• Moonshine protected activity center – 3.5 acres of treatments were dropped in the 

Grant Creek implementation unit removing all potential impacts to this protected activity 

center.

• Riggs Lake and Nuttall protected activity centers – 602 acres in the Clark Peak 

implementation unit and 42 acres in the Lefthand implementation unit were deferred or 

removed, removing all impacts to these protected activity centers; this also will reduce 

impacts to the Chesley and Lefthand protected activity centers.

• Chesley protected activity center – an additional 11.5 acres of treatments were dropped 

that were too close to core nesting and roosting areas, no treatments will now occur south 

of Swift Trail within this protected activity center. 

• Webb Peak protected activity center – 109.1 acres were removed from treatment in the 

Columbine implementation unit that were too close to core nesting and roosting areas; no 

treatments will now occur south of Swift Trail within this protected activity center.

• Grant Vista protected activity center – 44.5 acres were removed from treatments in the 

Bible Camp and Columbine implementation units, reducing potential impacts to this 

protected activity center.

In total, 644 acres of treatments have been deferred from a decision at this time and an additional 

168.6 acres of treatments have been removed from the project.
Record of Decision and Finding of Nonsignificant Amendment

6 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Responsiveness of Alternative 2 to the Purpose and Need 

As with many areas on the Coronado National Forest, changes in forest dynamics have occurred 

within the Pinaleño Ecosystem Restoration Project planning area during the past 100 years. 

Although fire exclusion has been a primary factor in these changes, other management practices 

have contributed as well. As a result, forest density has increased and species composition has 

changed with the forest becoming more at risk and less resistant to wildfire, insect, and disease 

problems. 

As stated in the FEIS on page 5, the purpose and need for this project is to initiate forest 

restoration efforts within the project area using guidelines provided in the “Mount Graham Red 

Squirrel Recovery Plan” and as allowed by the forest plan; initiate the restoration of ecological 

processes for wildlife habitat improvement purposes; restore and maintain fire-dependent 

ecosystems; and improve the resiliency of overstory trees to insect and disease impacts promoting 

a healthier forest condition as directed by the Coronado forest plan as amended. The treatments 

will protect and promote late-successional forest conditions, reduce susceptibility to insect and 

disease outbreaks, and reduce fuel loading within the Pinaleño planning area. 

The Pinaleño Mountains have experienced high-intensity wildfires, such as the Clark Peak Fire in 

1996 and Nuttall-Gibson Complex Wildfire in 2004, and insect infestations since the 1990s 

affecting over 40,000 acres of upper montane forests. The goal of this proposed project is to move 

toward a more stable forest ecosystem by creating conditions that are resilient and resistant to 

uncharacteristic disturbance. At present, any fire under current forest conditions is likely to result 

in an uncharacteristic loss of forested habitat. Recent large-scale fires in other areas of the 

Coronado National Forest this year have demonstrated the severity of risks these ecosystems face. 

I would like to treat this area so that it is in a condition where a naturally ignited wildfire would

be able to burn more similar to historical conditions, and can be managed with improved 

firefighter and public safety. 

Alternative 2 provides proactive management of the forest and will result in a substantially 

reduced risk of tree mortality from wildfire and bark beetles in high-density stands. In dense 

stands, two factors that greatly influence forest health are the reduction of tree species that attract 

bark beetles and an increase in individual tree vigor, both of which allow for better defense from 

attack. There is considerable evidence that lower density stands of seral species are more likely to 

have less mortality and exhibit greater resiliency following wildfire or bark beetle attack than 

higher density stands. By addressing tree stocking levels and species composition in stands that 

are dominated by more desirable species, Alternative 2 will promote increased growth rates, 

increased resistance to insects and disease, and greater resiliency in the event of disturbance. 

Alternative 2 will reduce the amount of understory trees and shrubs that are also contributing to 

the risk of uncharacteristically severe fire behavior. Thinning small trees, treating or removing 

slash, and applying prescribed fire to the stands will substantially improve the ability of the forest 

to withstand a wildfire should one start in the planning area or enter from adjacent areas.

Responsiveness of Alternative 2 to the Significant Issues 

In response to public comments we received during analysis, the interdisciplinary team identified 

five key issues. These issues were then used to develop Alternative 2, the proposed action: 
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 7

Significant Issue 1: The proposed project’s silvicultural 

prescriptions are not consistent with silvicultural guidelines 

of the “Mexican Spotted Owl Recovery Plan.”

Because some members of the public feel these types of treatments will not be consistent with the 

“Mexican Spotted Owl Recovery Plan” and the Mexican spotted owl standards and guidelines in 

the forest plan under the 1986 regionwide amendment, they expressed a desire to have an 

alternative that closely follows this guidance (Alternative 3). 

Even though Alternative 2 does not strictly follow the guidelines for forest management as 

established by the “Mexican Spotted Owl Recovery Plan,” it is consistent with the forest plan as 

amended under the 1986 regionwide amendment, which prioritizes actions related to management 

of the Mount Graham red squirrel over those of Mexican spotted owl (chapter 2, p. 44). 

Therefore, a forest plan admendment was not required for treatment prescriptions designed for the 

protection of Mount Graham red squirrel habitat even when those prescriptions did not follow 

Mexican spotted owl standards and guidelines.

Due to high tree stocking levels and forest fuels buildup in the project area, these stands are 

highly susceptible to mortality from disturbances that would adversely impact both the red 

squirrel and Mexican spotted owl. Both Alternatives 2 and 3 are similar in effects. Both are likely 

to adversely affect the threatened Mexican spotted owl but will not jeopardize the species. 

Adverse effects are limited in scope; neither alternative will reduce the amount of habitat meeting 

or exceeding Mexican spotted owl nesting and roosting threshold conditions, and neither is 

expected to affect viability of the species. Adverse effects are outweighed by expected long-term 

protection and stabilization of the species habitat.

Treatments conducted in the selected alternative provide better resilience to disturbance than 

Alternative 3 by reducing the stand density more. Alternative 2 treats more acres and better 

reduces the canopy fuels continuity, which reduces the risk of crown fire. These benefits will 

favor conditions that support a greater proportion of surface fires rather than crown fires. In areas 

and conditions where fire must be suppressed, Alternative 2 will reduce the occurrence of highintensity fire, which has flame lengths that exceed those that can be fought with direct attack. 

This reduces the need for the use of aerial retardant applications and indirect attack strategies. 

In addition, treatments prescribed under the selected alternative will result in greater diversity in 

forest structure than those developed for Alternative 3, the Mexican spotted owl alternative. 

Prescriptions in Alternative 3 would result in more open understory canopies, which would lead 

to reduced hiding cover for Mount Graham red squirrel and greater vulnerability of the squirrel to 

avian predators.

Significant Issue 2: The proposed project doesn’t treat enough 

areas of the Pinaleño Mountains or use enough prescribed fire to fully 

meet the ecosystem restoration purpose and need of the project.

Alternative 2 addresses this issue better than the other alternatives. Vegetation treatments consist 

of live tree thinning, removing standing and down dead trees, and a variety of fuels treatments on 

2,641 acres. The purpose and need states that this project initiates forest restoration to protect key 

ecosystem components. This project is only part of a long-term management strategy for the 

entire Pinaleño Ecosystem Management Area, with the ultimate goal of returning fire to a more 

natural role throughout the mountain range. Current fuel loading and stand conditions are such 
Record of Decision and Finding of Nonsignificant Amendment

8 Pinaleño Ecosystem Restoration Project, Coronado National Forest

that significant use of fire as a primary management tool cannot yet be contemplated, due to 

unacceptable risk associated with additional loss of Mount Graham red squirrel habitat.

Significant Issue 3: The proposed project may have negative 

effects to wildlife including the Mount Graham red squirrel, 

the Mexican spotted owl, and northern goshawk.

Both Alternatives 2 and 3 resulted in a “may affect/likely to adversely affect” determination for 

the Mount Graham red squirrel, Mexican spotted owl, and Mexican spotted owl critical habitat, 

but neither are likely to jeopardize the existence of the species. These adverse effects are limited 

in scope, are not expected to affect viability of the species, and are outweighed by expected longterm protection and stabilization of the habitat for the Mount Graham red squirrel. This resulted 

in the “may affect/is not likely to adversely affect” determination for critical habitat for the Mount 

Graham red squirrel. The U.S. Fish and Wildlife Service concurs with our determination 

(“Biological Opinion: Pinaleño Ecosystem Restoration Project,” 22410-2005-F-0651, August 5, 

2011).

Many, if not all, of the habitat conditions for the Mount Graham red squirrel exceed those for the 

Mexican spotted owl in terms of forest density and structure. By prioritizing our restoration 

efforts on the Mount Graham red squirrel, habitat change impacts on the Mexican spotted owl 

will be minimized. Long-term benefits such as improved forest health and reduced fire severity 

will also be essential to the continued viability of Mexican spotted owls within this mountain 

range. The interdisciplinary team continually balanced the potential for short-term impacts to red 

squirrel and spotted owl with long-term sustainability of their habitat. Mitigation measures were 

designed to limit any potential impacts, such as seasonal operation restrictions and snag and log 

retention (FEIS, appendix A). Monitoring measures were also developed to measure impacts to 

habitat and direct impacts to the species (FEIS, appendix B).

Management for northern goshawk is a lower priority than for the Mount Graham red squirrel or 

Mexican spotted owl as directed by the forest plan under amendment 8, (June 1996, “Regional 

Mexican Spotted Owl, Northern Goshawk and Old Growth Amendment”). Northern goshawk 

standards and guidelines apply to the forest and woodland communities that are outside of 

Mexican spotted owl protected and restricted areas. The entire project area falls within either 

protected or restricted Mexican spotted owl habitat. In addition, the FEIS showed that the two 

action alternatives posed little impact to this species and would create major benefits to old 

growth resilience.

Alternative 2 provides prescriptions that may improve habitat conditions for goshawk, but still 

remains more conservative than those provided in goshawk management standards and 

guidelines. Some disturbance of birds is likely to occur as a result of human presence and noise; 

however, historical monitoring of nesting birds in this mountain range have indicated that nests 

have not been abandoned despite large-scale wildfires (i.e., Clark Peak Fire of 1996 and Nuttall 

Complex of 2004) or mid-scale thinning projects. This monitoring effort will continue under this 

project. This alternative is not likely to result in a trend toward Federal listing or loss of viability 

of the species.
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 9

Significant Issue 4: The proposed 

project will negatively affect air quality.

Implementation of Alternative 2 will carefully follow Arizona’s smoke management regulations 

and restrictions to maintain air quality in populated areas and Class I airsheds, in cooperation with 

the Environmental Protection Agency (EPA), Arizona Department of Environmental Quality 

(ADEQ), and local agencies (FEIS p. 135). 

There will be a direct, short-term impact on air quality within the project area. Management 

activities proposed will likely cause direct short-term impacts from dust. Specifically, these 

activities involve chipping and masticating of live and dead vegetation, loading and processing 

activities at landing sites, and truck transportation of material. These activities are not anticipated 

to result in significant impacts to regional air quality because of the transitory nature of fugitive 

dust.

In addition, activities planned would generate short-term impacts from smoke resulting from 

prescribed understory burning and hand pile burning. The largest unit planned for burning under 

these alternatives is approximately 200 acres in size. Modeled particulate matter (PM2.5) 

concentrations are projected to be below the Federal ambient 24-hour standard; therefore, the 

national ambiaent air quality standards for public health established by the EPA for PM2.5 would 

not be violated (FEIS, p. 137).

Receptors located within or near the project analysis area such as campgrounds, the Arizona Bible 

Camp, and the astrophysical site may experience higher concentrations of PM2.5 during the course 

of burning as indicated above and, depending on air movement, may be impacted by inversions in 

the evenings. The closest Class 1 airshed (Galiuro Wilderness) lies to the west. Modeling shows 

there would be no significant impacts to this or any other Class 1 airshed resulting from this 

project (FEIS, p. 137). 

The effects from smoke are not likely to have cumulative effects with other activities in the 

airshed given the oversight by the ADEQ that allows for good smoke dispersion. Daily regulation 

of the amount of burning is managed to reduce impacts and negative effects of smoke. The 

prescribed burning in this project would compete with other burning in the airshed on any given 

day. The Coronado is responsible for establishing burn priorities within the forest, and the ADEQ 

is responsible for managing all the burning on a given day within the State. If air quality exceeds 

thresholds, the activities will be delayed until they are not exceeded (FEIS, pp. 138-139).

Significant Issue 5: The proposed project 

will decrease old growth in the analysis area.

One of the six goals listed for the purpose and need (FEIS chapter 1, p. 5) is the protection and 

promotion of old-growth (late-successional) forest conditions. For the moist mixed-conifer, which 

dominates the project area, this is primarily the groves of large old Douglas-fir trees. These 

groves are considered a “keystone” element of the southwestern mixed-conifer ecosystems. Latesuccessional conditions should not be confused with late-seral trees. Old growth in this forest 

type developed with moderate levels of disturbance, primarily frequent low-severity and less 

frequent mixed-severity wildfires. The late-seral species, primarily white fir in this forest type, 

are those that develop and come to dominate the forest without this natural disturbance. Reasons 

Douglas-fir is so valuable in the Pinaleño Mountains as an ecological keystone component 

include its long lifespan (700 years and longer growing to become the largest trees on the 
Record of Decision and Finding of Nonsignificant Amendment

10 Pinaleño Ecosystem Restoration Project, Coronado National Forest

landscape), and its great durability after dying as a snag and down log, providing an essential 

component of Mount Graham red squirrel habitat. Contrast that with white fir, which seldom lives 

longer than 200 years, never reaching the size of older Douglas-firs, and once dead, decays 

rapidly. Treatments under Alternative 2 are focused on improving the resilience of the remaining 

large Douglas-fir groves by removing the competing understory white fir. 

Our classification of stands as old growth indicates that 83 percent of the forested area within the 

project area currently meets the forest plan old growth criteria. Neither action alternative 

measurably reduces this proportion of old growth (FEIS, table 30, p. 77) due to the fact that the 

treatment prescription criteria developed to meet the Mount Graham red squirrel needs surpasses 

the criteria of the old growth standards and guidelines across all parameters. Because of this, the 

selected alternative will not reduce the amount of mixed-conifer old growth at any of the three 

scales of measure required by the forest plan; including the project, the Pinaleño Ecosystem 

Management Area, or at a multiple ecosystem management area level.

I believe that Alternative 2 is the best alternative for sustaining old-growth forest conditions 

because it will increase the resiliency of the largest and most valuable trees to insect infestations 

by reducing competition with smaller competing understory trees. It will also decrease the 

amount of ladder fuels and the continuity of canopy fuels, thus reducing the likelihood of both 

passive and active crown fires, allowing for the eventual reintroduction of fire back into the 

system.

Alternatives Considered

In addition to Alternative 2, two other alternatives were analyzed in detail. They include 

Alternative 1, the no action alternative, and Alternative 3, which featured a Mexican spotted owl 

emphasis. Additional alternatives include those considered in the FEIS and “dropped from 

detailed consideration” (FEIS, pp. 45-46). 

Alternative 1 (No Action) 

The no action alternative would allow current processes to continue, along with associated risks 

and benefits, in the Pinaleño planning area. This alternative serves as a baseline for comparison of 

the effects of all other alternatives. Under Alternative 1, current management plans would 

continue to guide management. There would be no change in the level of ongoing management 

activities within the project area. All custodial activities such as road maintenance, law 

enforcement, and response to emergencies, including wildfire, would continue. 

Our analysis shows that it is likely that insect and disease levels would continue to increase 

causing increased tree mortality and fuel accumulations. No progress would be made toward the 

restoration of ecological processes that include the reintroduction of low-intensity prescribed fire. 

Stands would remain at risk to severe stand-replacing crown fire threatening the Mount Graham 

red squirrel and other important wildlife habitat and forest ecosystems. Also, the sustainability of 

current old growth stands is in jeopardy because of the risk of losing large tree structure to 

wildfire and insects. This alternative was not selected because it does not meet the stated purpose 

and need, and allowing the current conditions to exist is not acceptable.
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 11

Alternative 3 - Mexican Spotted Owl Emphasis

Alternative 3 attempted to strictly apply the Mexican spotted owl standards and guidelines while 

also attempting to meet needs of the Mount Graham red squirrel. Both species require similar oldgrowth conditions as part of their habitat requirements; however, this alternative would have 

created inherent conflicts in priorities including the following: 

1. The timing of treatments within Mexican spotted owl protected activity centers under 

Alternative 3 restricted the preferred sequence of treatments that focused primarily on the 

Mount Graham red squirrel;

2. There would have been an inability to treat Mexican spotted owl core areas adjacent to 

Mount Graham red squirrel habitat and midden protection zones;

3. There would have been a lower capability to develop complex forest structure (diverse 

both horizontally and vertically) under the spotted owl prescriptions, due to restrictions 

on only removing smaller diameter trees (this would open the understory canopy more 

and expose the Mount Graham red squirrel to greater pressure from avian predators); and 

4. There would have been less benefit to the residual large Douglas-fir groves, a key Mount 

Graham red squirrel habitat component in the moist mixed-conifer habitat, since removal 

of the more shade-tolerant competing white fir would be limited to smaller trees. The 

more homogenous forest structure would also leave the area more vulnerable to crownreplacing wildfire.

Environmentally Preferable Alternative 

Under the National Environmental Policy Act, the Agency is required to identify the 

environmentally preferable alternative (40 CFR 1505.2(b)). This is interpreted to mean the 

alternative that would cause the least damage to the biological and physical components of the 

environment, and which bests protects, preserves, and enhances, historic, cultural, and natural 

resources (Council on Environmental Quality, Forty Most Asked Question Concerning CEQ’s 

National Environmental Policy Act Regulations, 46 Federal Register 18026). 

In the short term, it could be argued that Alternative 1 would best meet the definition of 

“environmentally preferable” because it would not alter the existing biological and physical 

environment and, thus, would not result in any short-term impacts to vegetation, water, wildlife or 

social values. In addition, it does not have any of the impacts associated with building of 

temporary roads or of the increased traffic associated with treatments. However, Alternative 1 

does not address the pressing environmental issues identified in the EIS, such as the need to 

protect and restore the habitat of the Mount Graham red squirrel. Further, taking no action would 

likely lead to undesirable and unintended consequences because the environmental conditions of 

the area would continue to trend away from desired watershed, wildlife habitat, and fuel loading 

conditions. 

Of the six goals listed in the purpose and need for action (FEIS chapter 1, p. 5), two are for 

ecosystem restoration, two are for protecting large overstory trees or enhancing old growth forests 

and one is for reducing the risk of stand-replacing wildfires. I consider all of these actions to be 

enhancing the environment. The only other project goal is to provide for the protection of our 

firefighters.
Record of Decision and Finding of Nonsignificant Amendment

12 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Both action alternatives focus on the long term as it relates to reducing risk of a wide-scale 

disturbance event that could remove large blocks of forest, threatening the remaining habitat of 

the Mount Graham red squirrel and other old-growth-dependent species. Alternative 2 as 

modified will reduce this risk to a greater extent than Alternative 3, and it will leave a more 

structurally diverse and resilient forest landscape, furthering our restoration goals to a greater 

extent. Alternative 2 also provides a better strategy to encourage the return of the natural fire 

cycle, increase the resiliency of mixed-conifer stands including those with old growth 

characteristics, and protect and restore the habitat of the Mount Graham red squirrel. 

Removal of forest products, if any, are a byproduct of these efforts and a means to improve 

operational efficiency and mitigate the impacts of pile burning and prescribed broadcast burning 

but are not a direct objective of the project. The project will be implemented regardless of 

whatever opportunities might or might not occur from stewardship contracts or agreements. 

These are only methods of reaching our goals and objectives. The impacts of temporary road 

building and transportation of equipment and woody biomass will be spread out over a 10-year 

implementation period, and the impacts of these activities will be monitored and mitigated (FEIS, 

appendix F).

Therefore, I have determined that the environmentally preferable alternative is Alternative 2 as 

modified for balancing both the short-term impacts and long-term benefits. This was the task 

assigned to the interdisciplinary team and I believe that they have accomplished this charge.

Public Involvement 

The Forest Service has provided stakeholders the opportunity to be involved in the planning 

process. In 2004, a letter was sent to local user and interest groups, cabin owners, and the 

forestwide NEPA mailing list asking for input regarding the “Mount Graham Sky Island 

Demonstration Project.” Based on responses from this mailing, a biological working group made 

up of conservation organizations, agency personnel from the Arizona Game and Fish Department, 

USDI Fish and Wildlife Service, Forest Service, and university scientists was developed. They 

provided insights and shared their scientific knowledge on historical fire regimes and potential 

strategies to initiate restoration of the forested ecosystems, and how best to protect the habitat of 

the endangered Mount Graham red squirrel. In May 2005, draft proposals were distributed and 

sent to the public. Public meetings were held to discuss and develop potential alternatives. In 

September 2005, tribal coordination began regarding the specific proposals being discussed. In 

October 2005, field trips were held to discuss potential treatments with the public and to receive 

input regarding those treatments. In January 2006, the Coronado redrafted a proposed action 

substantively to emphasize protection of currently occupied Mount Graham red squirrel habitat, 

while restoring declining mixed-conifer stands and improving forest stand health in potential 

Mount Graham red squirrel habitat.

A notice of intent (NOI) was published in the Federal Register on August 3, 2007, indicating our 

intent to prepare and consider an environmental impact statement, which would examine the 

potential impact to the Mount Graham red squirrel and Mexican spotted owl in much more detail. 

From this notice, responses were received from 12 individuals or organizations with a range of 

issues and concerns. Using the comments from the public and other agencies (see “Issues” 

section), the interdisciplinary team developed a list of issues and alternatives to the proposal. 
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 13

A 45-day comment period for the Pinaleño Ecosystem Restoration DEIS was provided for 

interested and affected publics, including appropriate local, State, and Federal Government 

agencies, and tribes. This period started on June 20, 2009, following the publication of a notice of 

availability in the Federal Register on June 19, 2009. The official public comment period ended 

on August 4, 2009. During this period, the Forest Service received comments from different 

sectors of the public, with a range of concerns and questions. All comments were reviewed and 

substantive comments were considered during comment analysis. Some comments resulted in 

further clarification or analysis within the FEIS. I have reviewed and considered the comments as 

part of the decisionmaking process. The response to substantive comments is included in the 

FEIS in appendix I. The complete comment record is kept within the Pinaleño Ecosystem 

Restoration Project public record and is available for review at the Safford Ranger District, 

Safford, Arizona.

Consultation with 

Government Agencies and Tribes 

Consultation with many Federal and State agencies is required and was completed during the 

DEIS comment period. A list of agencies consulted is found in chapter 4 of the FEIS. Most 

notably, the Arizona Game and Fish Department and U.S. Fish and Wildlife Service played key 

roles in the project; both agencies provided a wildlife biologist to assist the interdisciplinary team.

Both agencies also provided other wildlife biologists who participated in many of the 

interdisciplinary meetings and field trips and provided input to the project. We also held an 

interagency briefing with the line officers and their staff prior to the release of the DEIS to 

discuss the project, our restoration strategy, and to provide me their perspective on the best course 

of action. Integral to this was how the project would help meet the recovery needs of the Mount 

Graham red squirrel, fulfill forest management recommendations of the “Mount Graham Red 

Squirrel Recovery Plan” and how these efforts fit into the ongoing efforts to update and revise the 

recovery plan. 

Consultation with tribal entities on a government-to-government basis in reference to activities 

related to potential disturbance of cultural heritage resources, including archaeological sites, 

sacred sites, gathering areas, springs and any other areas of interest to tribal nations, is mandated 

under various executive orders, policies, statutes, and case law. Federal land managing agencies 

including the Forest Service are authorized to consult with American Indian tribes not only under 

mandated law but also under the U.S. Government’s trust responsibility to tribal nations.

The Western Apache, which include the San Carlos, White Mountain, Tonto and Yavapai-Apache 

Nations, maintain deep and significant cultural, spiritual, social, physical, and holy ties to the 

Pinaleño Mountains, known in the Western Apache language as Dził Nchaa Si’an. Other 

American Indian tribes including the Chiricahua Apache, Four Southern Tribes (the Ak Chin 

Indian Community, Tohono O’odham Nation, Salt River Pima Maricopa Indian Community, and 

Gila River Indian Community), Hopi Tribe, and Pueblo of Zuni also are recognized as 

stakeholders with interest and association to the Pinaleño Mountains. However, Dził Nchaa Si’an

has been determined eligible for, and is in the process of being nominated to the National Register 

of Historic Places as a Western Apache traditional cultural property. The San Carlos and White 

Mountain Apache Tribes are often deferred to and considered the lead tribal entities with regard 

to activities and projects associated with the Pinaleño Mountains.
Record of Decision and Finding of Nonsignificant Amendment

14 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Various consultation meetings were conducted with representatives of both the San Carlos and 

White Mountain Apache Tribes concerning the Pinaleño Ecosystem Restoration Project. 

Mitigation recommendations and project concerns from both San Carlos and White Mountain 

Apache consultants were identified and integrated into the environmental impact statement. The 

Western Apache continue to oppose the Mount Graham International Observatory as incompatible 

with the spiritual values of Dził Nchaa Si’an and is central to most of my discussions with the 

Western Apache tribes. I recognize that even though consultation continues to occur concerning 

various projects having the potential to affect Dził Nchaa Si’an, the Western Apache will continue 

to fervently and adamantly oppose the Mount Graham International Observatory. However, 

implementations of Alternative 2 will likely benefit Pinaleño cultural heritage resources over the 

long term, by beginning to restore the ecosystem to pre-1870 conditions as recommended by the 

White Mountain Apache Tribe. Implementation of the project will be completed with respect 

toward the values inherent in Dził Nchaa Si’an and in compliance with applicable cultural 

heritage resource legislation.

Consultation occurred with the Arizona State Historic Preservation Office and a finding of “no 

adverse effect” was made for this project. See page 17 for more information.

Consistency with Other Laws and Regulations

After consideration of the discussion of environmental consequences (FEIS, chapter 3), I have 

determined that Alternative 2 as modified is consistent with other laws and regulations as outlined 

in the FEIS. Detailed discussions of laws and regulations are provided in the FEIS, chapter 3, pp. 

57 to 198, and within the appendices. 

The National Forest Management Act (NFMA)

Consistency with the Forest Plan and Other NFMA Requirements

The National Forest Management Act requires projects to comply with forest plan direction. The 

“Coronado National Forest Land and Resource Management Plan” (forest plan) establishes 

management direction for the Coronado National Forest. This management direction is achieved 

through the establishment of forest plan goals and objectives, standards and guidelines, and 

management area goals and accompanying standards and guidelines. Projects and activity 

decisions must demonstrate and explicitly document consistency and compliance with forest plan 

forestwide standards, management area standards, and monitoring plan requirements.

The selected alternative is consistent with the “Coronado National Forest Land and Resource 

Management Plan Final Environmental Impact Statement,” “Record of Decision,” and the 

accompanying “Land and Resource Management Plan,” as amended dated June 11, 2005 (FEIS 

chapter 2, pp. 5-7). 

I also find the selected alternative to be consistent with other requirements of the National Forest 

Management Act implementing regulations, specifically: 

Forest Vegetation: All of the project area is considered unsuitable for timber management; 

however, the Forest Plan allows for vegetation management where necessary that consists of 

sanitation salvage operations, maintenance and improvement of wildlife habitat, and control 

of insect and disease outbreaks. In Management Area 2A, the forest plan specifies “outbreaks 

of insects or disease will be controlled using integrated pest management concepts when there 
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 15

is a significant danger to the vegetation needed to sustain habitat for the Mount Graham red 

squirrel and astronomical research activities” (forest plan, p. 54-5). It is consistent with 36 

CFR 219.27(c)(1). 

Cultural Resources: The selected activities comply with forest plan direction for cultural 

resources (FEIS, p. 183).

Old Growth: The selected activities will not reduce the proportion of the area classified as 

old growth. 

The activities included in this decision are consistent with all forest plan standards for old growth 

(forest plan, p. 23). The definitions of old growth were used in the validation and analysis process 

of old growth in this project.

Finding of Nonsignificant Amendment

Under the National Forest Management Act (NFMA, 16 USC 1604(f)(4), forest land and resource

management plans (forest plans) may “be amended in any manner whatsoever after final adoption 

and after public notice.” Federal regulations at 36 CFR 219.14 allow the Forest Service to use the 

provisions of the planning regulations in effect before November 9, 2000, in order to amend 

forest plans. These regulations state that the responsible official shall (1) determine whether 

proposed changes to a land management plan are significant or not significant in accordance with 

the requirements of sections 1926.51, (2) document the determination of whether the change is 

significant or not significant in a decision document, and (3) provide appropriate public 

notification of the decision prior to implementing the changes.

The Forest Service Land and Resource Management Planning Manual (Forest Service Manual 

1926.51) provides a framework for consideration listing instances when a proposed change to a 

forest plan is not significant or significant. An amendment is not significant when it involves:

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term 

land and resource management;

2. Adjustments of management area boundaries or management prescriptions resulting from 

further onsite analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management;

3. Minor changes in standards and guidelines; or

4. Opportunities for additional projects or activities that will contribute to achievement of 

the management prescription.

As stated in the FEIS, we need to amend our forest plan to allow activities integral to the 

proposed Pinaleño Ecosystem Restoration Project (FEIS pp. 36-37). Specifically, the forest plan 

would be amended to allow (1) regulated Christmas tree removal and public firewood gathering 

associated with treatment prescriptions and (2) exceptions to the visual quality objectives. These 

amendments would apply only within the project area and over the lifespan of the project. As part 

of this proposal, management area specific standards and guidelines in the forest plan would be 

amended to reflect changes in direction.
Record of Decision and Finding of Nonsignificant Amendment

16 Pinaleño Ecosystem Restoration Project, Coronado National Forest

I have evaluated the proposed changes to management direction and concluded that they do not 

constitute significant amendments to the Coronado forest plan for the reasons described below:

1. Actions that do not significantly alter the multiple-use goals and objectives for longterm land and resource management.

The proposed amendments to the forest plan do not alter any of the multiple-use goals 

and objectives for long-term land and resource management. The amendments propose 

temporary, site-specific changes in management direction to allow forest restoration 

activities. The results of the proposed amendments will be consistent with long-term 

current goals and objectives.

2. Adjustments of management area boundaries or management prescriptions 

resulting from further onsite analysis when the adjustments do not cause significant 

changes in the multiple-use goals and objectives for long-term land and resource 

management.

There are no adjustments to management area boundaries and the adjustments to 

prescriptions in the proposed amendments do not alter the long-term multiple-use goals 

and objectives for the land and resource management plan.

3. Minor changes in standards and guidelines.

The proposed amendments to the forest plan make minor changes to standards and 

guidelines to allow activities associated with the Pinaleño Ecosystem Restoration Project 

that are temporary (over the life of the project) and site specific (within the project area).

4. Opportunities for additional projects or activities that will contribute to 

achievement of the management prescription.

The proposed amendments adjust standards and guidelines to allow land managers to 

work toward recovering habitat for the Mount Graham red squirrel, restoring ecosystem 

processes, improving forest health, reducing the risk of stand-replacing crown fire, 

protecting old growth forest conditions, and improving firefighter safety.

The current forest plan is nearing the end of the first planning period and is undergoing 

revision. The proposed management direction will be in place until efforts to revise the forest 

plan are complete, thereby supporting my determination that the proposed changes do not 

constitute a significant amendment of the forest plan.

Finding

On the basis of the information summarized above, it is my determination that this is not a 

significant amendment to the Coronado forest plan.

National Environmental Policy Act (NEPA)

NEPA establishes the format and content requirements of environmental analysis and 

documentation as well as requirements for public involvement and disclosure. The entire process 

of preparing this environmental impact statement was undertaken to comply with NEPA.
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 17

The Preservation of American Antiquities Act of 

June 1906 and the National Historic Preservation 

Act: The Arizona State Historic Preservation Office

Consultation occurred with the Arizona State Historic Preservation Office (SHPO). A finding of 

“no adverse effect” was made for this project. This finding was based on the knowledge that 

although cultural resource sites may be impacted by the proposed undertaking, site avoidance and 

project design criteria will provide protection of eligible site characteristics. The probability that 

certain eligible sites may be impacted during project activities leads to this finding of effect as 

described in 36 CFR 800.5 (b) and 36 CFR 800.16(i) (Federal Register Vol. 65, No. 239; Tuesday, 

December 12, 2000; pages 77730 and 77738). The SHPO concurred with this finding on May 5, 

2008.

American Indian Religious Freedom Act of 1978

This act provides for the maintenance of “access to sites ... freedom to worship through 

ceremonials and traditional rites.” This decision allows for continued access and does not abridge 

any rights to continue “worship.”

Executive Order 13007 - Indian Sacred Sites

This order indicates that Federal land management agencies “shall, to the extent practicable, 

permitted by law, and not clearly inconsistent with essential agency functions, (1) accommodate 

access to and ceremonial use of Indian sacred sites by Indian religious practitioners and (2) avoid 

adversely affecting the physical integrity of such sacred sites.” This order is based on a 

“government-to-government” relationship between agencies and tribal government. There have 

been ongoing government-to-government consultations on this project under section 106 of 

NHPA. Access to sacred sites and their physical integrity has been maintained with this project 

(see “Consultation with Government Agencies and Tribes” section above).

The Endangered Species Act and 

Regional Forester’s Sensitive Species 

Details regarding actual species found within the Pinaleño Ecosystem Restoration Project area 

and potential effects of proposed activities on those species and their habitat are discussed in the 

“Wildlife” section in chapter 3 of the FEIS. The Endangered Species Act requires protection of all 

species listed as threatened or endangered by Federal regulating agencies. Biological assessments 

were prepared to document the possible effects of the proposed activities to endangered, 

threatened, and sensitive plant and wildlife species within the project area. Appropriate 

coordination, conferencing, and consultation with the U.S. Fish and Wildlife Service have been 

completed as directed under Section 7 of the act (see previous section of this document titled 

“Consultation with Government Agencies and Tribes”). 

We have determined that implementation of all of the proposed activities will result in a “may 

affect/likely to adversely affect” determination for the Mount Graham red squirrel and for the 

Mexican spotted owl and owl critial habitat. The biological opinion issued by the U.S. Fish and 

Wildlife Service after consultation concludes that implementation of the project will contribute to 

the likelihood of the survival and recovery of the Mount Graham red squirrel throughout its range

(“Biological Opinion: Pinaleño Ecosystem Restoration Project,” 22410-2005-F-0651, August 5, 
Record of Decision and Finding of Nonsignificant Amendment

18 Pinaleño Ecosystem Restoration Project, Coronado National Forest

2011). The biological opinion also concludes that the project is neither likely to jeopardize the 

continued existence of the spotted owl, nor result in destruction or adverse modification of 

spotted owl critical habitat. In their opinion, the project will ultimately improve forest health and 

reduce the likelihood of high-severity wildfire, the primary threat to spotted owl habitat in the 

Pinaleño Mountains. The U.S. Fish and Wildlife Service also concurred with our determination of 

“may affect/not likely to adversely affect” for red squirrel critical habitat, Apache trout 

(Oncorhynchus apache), and Gila trout (O. gilae).

The remaining threatened and endangered species have determinations of “no effect” and 

sensitive species have determinations of “no impact” or “may impact individuals of the species, 

but not likely to result in a Federal trend toward listing the species.” During formal consultation, 

the Forest Service and U.S. Fish and Wildlife Service share information about the proposed 

project and the species likely to be affected. Modifications were made to the proposed action 

specifically to reduce potential impacts on the Mexican spotted owl. These changes are listed in 

appendix B and were summarized in the “Decision” section above.

As part of their biological opinion, the U.S. Fish and Wildlife Service issued an Incidental Take 

Statement to the Coronado National Forest. “Incidental take” is defined as take that is incidental 

to, and not for the purpose of, carrying out an otherwise lawful activity. Anticipated incidental 

take for the Mount Graham red squirrel could result in up to a 15 percent decline in the 

abundance of Mount Graham red squirrels within treated areas during project implementation 

(through year 15). This take could be in the form of loss of occupied nests with litters, 

competition with Abert’s squirrels, increases in predation, and loss due to roadkill. Incidental take 

for this project will not exceed the incidental take as described in the Coronado forest plan

biological opinion as measured through abandonment and/or physical alteration of middens.

Because all middens are buffered or within midden protection zones, no physical alteration of 

middens will occur as a result of this project; therefore, no individual middens are likely to be 

directly affected by the proposed action. This will be verified by monitoring sweeps of adjacent 

midden protections zones prior to and after treatments. These midden sweeps will be used to 

quantify take relevant to allotted take for this project and the forest plan incidental take statement.

Hair-tube monitoring will provide the data needed to detect changes in abundance of Mount 

Graham red squirrel and Abert’s squirrel, and will be compared to mountainwide population 

trends to determine if these changes reflect effects of the proposed action, or are due to largescale habitat changes across the range of Mount Graham red squirrel. The U.S. Fish and Wildlife 

Service determined that this level of anticipated take is not likely to jeopardize the continued 

existence of the species. They also issued reasonable and prudent measures and terms and 

conditions that are nondiscretionary actions the Forest Service must follow to minimize incidental 

take. These are listed in appendix B of this document. 

In addition, the U.S. Fish and Wildlife Service biological opinion issued an Incidental Take 

Statement to the Coronado National Forest for Mexican spotted owl using anticipated impacts to 

the integrity of protected activity centers to quantify incidental take thresholds for the spotted 

owl. Incidental take can be anticipated as the harm and harassment of birds to such a degree that 

the birds are considered lost as viable members of the population and thus “taken.” The project 

action will result in an incidental take of six pairs (four harm and harass, two harass) and 

associated juvenile owls associated with six protected activity centers over the life of the project 

due to the effects of chronic or long-term disturbance within and/or immediately adjacent to 

protected activity centers, habitat degradation, and within four protected activity centers, core 
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 19

habitat alteration. The U.S. Fish and Wildlife Service determined that this level of anticipated 

incidental take is not likely to jeopardize continued existence of the species. They also issued 

reasonable and prudent measures and terms and conditions that are nondiscretionary actions the 

Forest Service must follow to minimize incidental take. These are listed in appendix B of this 

document. 

Review requirements: If, during the course of the action, the level of incidental take is exceeded

for either of these two species, such incidental take would represent new information requiring 

review of the reasonable and prudent measures provided, the Coronado National Forest shall 

immediately notify the U.S. Fish and Wildlife Service and request reinitiation of consultation, 

pursuant to 50 CFR 402.16a. Furthermore, the forest will immediately provide an explanation of 

the causes of the taking and review with the Arizona Ecological Services Office the need for 

possible modification of the reasonable and prudent measures.

The Clean Water Act, 1982 and 303(d) 

This act is the basis for the Intergovernmental Agreement between the Arizona Department of 

Environmental Quality (ADEQ) and Forest Service for the control of nonpoint source pollution 

and maintenance of clean water (ADEQ Contract No. HH-1037). This is accomplished through 

planning, application, and monitoring of best management practices, which are recognized as the 

primary means to control nonpoint source pollution on National Forest System lands. The 

proposed actions incorporate project design features that would ensure compliance with these 

regulations (FEIS appendix A).

Civil Rights and Environmental Justice 

Executive Order 12898 requires Federal agencies to identify and address any disproportionately 

high and adverse human health or environmental effects on minority and low income populations.

I have determined that there would be no discernable impacts from the selected alternative in the 

effects on Native Americans, women, other minorities, or the Civil Rights of any American 

citizen (see “Social Considerations” section of the FEIS).

Project Implementation 

Implementation of treatments would likely begin in fall of 2012. I have reviewed the Pinaleño 

Ecosystem Restoration Project FEIS and associated appendices. I believe there is adequate 

information within these documents to provide a reasoned choice of action. I am fully aware of 

the possible adverse environmental effects that cannot be avoided, and the irreversible and 

irretrievable commitment of resources associated with the selected alternative. I have determined 

that these risks will be outweighed by the benefits of protecting the Mount Graham red squirrel 

populations and their habitat, and reducing fuel loading and stand densities that will sustain the

forested ecosystem in the long term. Implementing the selected alternative will cause no 

unacceptable cumulative impact to any resource. The FEIS adequately documents how 

compliance with these requirements is achieved (FEIS, chapter 3).

Procedure for Change During Implementation 

Minor changes may be needed during implementation to better meet onsite resource management 

and protection objectives. 
Record of Decision and Finding of Nonsignificant Amendment

20 Pinaleño Ecosystem Restoration Project, Coronado National Forest

In determining whether and what kind of further NEPA action is required, I will consider the 

criteria to supplement an existing environmental impact statement in 40 CFR 1502.9(c) and FSH 

1909.15, sec. 18, and in particular, determine whether the proposed change is a substantial change 

to the intent of the selected alternative as planned and already approved, and whether the change 

is relevant to environmental concerns. Connected or interrelated proposed changes regarding 

particular areas or specific activities will be considered together in making this determination. 

The cumulative impacts of these changes will also be considered. 

The intent of field verification prior to my decision was to confirm inventory data and to 

determine the feasibility and general design and location of a road or unit, not to locate the final 

boundaries or road locations. Minor adjustments to unit boundaries may be needed during final 

layout for resource protection, to improve logging system efficiency, and to better meet the intent 

of my decision. Many of these minor changes will not present sufficient potential impacts to 

require any specific documentation or action to comply with applicable laws.

Appeal Rights 

This decision is subject to administrative review (appeal) pursuant to 36 CFR Part 215. The 

appeal must be filed (regular mail, fax, email, hand delivery, or express delivery) with the appeal 

deciding officer at: USDA Forest Service, Southwestern Region, Appeal Deciding Officer, 333 

Broadway Blvd., SE, Albuquerque, NM 87102. Facsimiles may be received at (505) 842-3173.

Emails may be electronically received at: appeals-southwestern-regional-office@fs.fed.us The 

office business hours for those submitting hand delivered appeals are: 8:00 a.m. to 4:30 p.m.

Monday through Friday, excluding holidays. Electronic appeals must be submitted in a format 

such as an email message, plain text (.txt), rich text format (.rtf), or Word (.doc) to the email 

address listed above. In cases where no identifiable name is attached to an electronic message, a 

verification of identity will be required. A scanned signature is one way to provide verification. 

All appeals, including attachments, must be filed within 45 days from the publication date of this 

notice in the Arizona Daily Star, the newspaper of record. Attachments received after the 45-day 

appeal period will not be considered. The publication date in the Arizona Daily Star is the 

exclusive means for calculating the time to file an appeal. Those wishing to appeal this decision

should not rely upon dates or timeframe information provided by any other source.

If an appeal is received on this project, there may be informal resolution meetings and/or 

conference calls between the responsible official and appellant. These discussions would take 

place within 15 days after the closing date for filing an appeal. All such meetings are open to the 

public.

If no appeals are filed within the 45-day time period, implementation of the decision may occur 

on, but not before, 5 business days from the close of the appeal filing period. When appeals are 

filed, implementation may occur on, but not before, the 15th business day following the date of 

the last appeal disposition.
Record of Decision and Finding of Nonsignificant Amendment

Pinaleño Ecosystem Restoration Project, Coronado National Forest 21

Contact Persons 

For additional information concerning this decision or the Forest Service appeal process contact:

Ms. Andrea Wargo Campbell, Forest NEPA Coordinator

Coronado National Forest

Supervisor’s Office

300 West Congress Street

Tucson, AZ 85701

Phone: (520) 388-8352

Email: awcampbell@fs.fed.us

For information concerning the record of decision or the final environmental impact statement 

contact:

Mr. Craig Wilcox, Forest Silviculturist

Coronado National Forest 

711 S. 14th Ave., Suite D

Safford, AZ 85546

Phone: (928) 348-1961

Email: cpwilcox@fs.fed.us

Responsible Official Signature

October 31, 2011

JIM UPCHURCH Date

Forest Supervisor, Coronado National Forest

Pinaleño Ecosystem Restoration Project, Coronado National Forest 23

Appendix A - Treatments Dropped 

from Consideration Due to 

Inventoried Roadless Area Status

The following table lists the Pinaleño Ecosystem Restoration Project treatment units, treatment 

prescriptions, and acres that fall within a designated inventoried roadless area. 

Table 1. Pinaleño Ecosystem Restoration Project FEIS proposed action (Alternative 2) 

treatments by unit within designated inventoried roadless area

Unit 

No.

Silviculture 

Treatment

Fuels 

Treatment

Removal 

Method

Treatment 

Area

Treatment 

Subdivision Acres

18 No Treatment Lop and scatter; 

underburn

No 

Removal

Forest 

restorationmodified 

treatment area

Shannon 15.2

21 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

underburn

No 

Removal

Important 

wildlife areageneral Rx

Shannon 23.9

26 No Treatment Lop and scatter; 

underburn

No 

Removal

Forest 

restorationmodified 

treatment area

Shannon 52.5

79 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter No 

Removal

Important 

wildlife areageneral Rx

Cunningham 2.4

496 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter No 

Removal

Important 

wildlife areageneral Rx

Cunningham 20.9

498 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter No 

Removal

Important 

wildlife areageneral Rx

Cunningham 10.2

187 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; thin 

live <9 in. d.b.h.

Masticate; hand 

cut, pile, and 

burn steep 

slopes; followup 

underburn

No 

Removal

Important 

wildlife areamodified 

treatment area

Ash Creek 9.1

201 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; thin 

live <9 in. d.b.h.

Lop and scatter; 

hand cut, pile, 

and burn; 

followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

skyline

Important 

wildlife areamodified 

treatment area

Ash Creek 4.7
Appendix A – Treatments Dropped from Consideration 

Due to Inventoried Roadless Area Status

24 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Table 1. Pinaleño Ecosystem Restoration Project FEIS proposed action (Alternative 2) 

treatments by unit within designated inventoried roadless area

Unit 

No.

Silviculture 

Treatment

Fuels 

Treatment

Removal 

Method

Treatment 

Area

Treatment 

Subdivision Acres

185 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; general 

Rx <18 in d.b.h.

Lop and scatter; 

hand cut, pile, 

and burn; 

followup 

underburn

No 

Removal

Forest 

restorationmodified 

treatment area

Webb Peak 4.5

205 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; thin 

live <9 in. d.b.h.

Masticate; hand 

cut, pile, and 

burn steep 

slopes; followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

skyline

Forest 

restorationmodified 

treatment area

Webb Peak 10.1

172 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; general 

Rx <18 in d.b.h.

Masticate; hand 

cut, pile, and 

burn steep 

slopes; followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

groundbased 

equipment

Forest 

restorationmodified 

treatment area

Webb Peak 2.6

194 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; general 

Rx <18 in d.b.h.

Masticate; hand 

cut, pile, and 

burn steep 

slopes; followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

groundbased 

equipment

Forest 

restorationmodified 

treatment area

Webb Peak 4.9

532 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; general 

Rx <18 in d.b.h.

Masticate; hand 

cut, pile, and 

burn steep 

slopes; followup 

underburn

Whole-tree 

yard; hand 

cut; remove 

by skyline

Forest 

restorationmodified 

treatment area

Webb Peak 8.6

432 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

hand cut, pile, 

and burn

No 

Removal

Important 

wildlife areageneral Rx

Webb Peak 40.7

395 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

hand cut, pile, 

and burn

No 

Removal

Important 

wildlife areageneral Rx

Webb Peak 17.1

230 No Treatment Underburn No 

Removal

Non-forest 

prescribed 

burn

Lefthand 5.4
Appendix A – Treatments Dropped from Consideration 

Due to Inventoried Roadless Area Status

Pinaleño Ecosystem Restoration Project, Coronado National Forest 25

Table 1. Pinaleño Ecosystem Restoration Project FEIS proposed action (Alternative 2) 

treatments by unit within designated inventoried roadless area

Unit 

No.

Silviculture 

Treatment

Fuels 

Treatment

Removal 

Method

Treatment 

Area

Treatment 

Subdivision Acres

521 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

underburn

No 

Removal

Important 

wildlife areageneral Rx

Lefthand 16.0

522 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

underburn

No 

Removal

Important 

wildlife areageneral Rx

Lefthand 8.0

460 Thin trees <9 in. 

d.b.h.; MSO 

restricted (170 BA)

Lop and scatter; 

hand cut, pile, 

and burn

No 

Removal

Important 

wildlife areageneral Rx

Clark Peak 11.6

461 Thin trees <18 in. 

d.b.h.; MSO 

restricted (150 BA)

Lop and scatter; 

hand cut, pile, 

and burn

Whole-tree 

yard; hand 

cut; remove 

by skyline

Forest 

restorationgeneral Rx

Clark Peak 1.7

235 Thin trees <18 in. 

d.b.h.; MSO 

restricted (150 BA)

Lop and scatter; 

hand cut, pile, 

and burn

Whole-tree 

yard; hand 

cut; remove 

by skyline

Forest 

restorationgeneral Rx

Clark Peak 10.3

458 Thin trees <18 in. 

d.b.h.; MSO 

restricted (150 BA)

Lop and scatter; 

hand cut, pile, 

and burn

Whole-tree 

yard; hand 

cut; remove 

by skyline

Forest 

restorationgeneral Rx

Clark Peak 19.3

242 Thin trees <18 in. 

d.b.h.; MSO 

restricted (150 BA)

Lop and scatter; 

hand cut, pile, 

and burn; 

followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

groundbased 

equipment

Forest 

restorationgeneral Rx

Clark Peak 5.9

243 Reduce mortality in 

snag pockets (0.25-

1.25 acre group size) 

up to 18 in. d.b.h. to 

6 snags/acre; no live 

tree thinning

Lop and scatter; 

hand cut, pile, 

and burn; 

followup 

underburn

Whole-tree 

yard; 

machine or 

hand cut; 

remove by 

groundbased 

equipment

Forest 

restorationmodified 

treatment area

Clark Peak 4.4

Total Treatment unit acres

in inventoried 

roadless area

307.7

Pinaleño Ecosystem Restoration Project, Coronado National Forest 27

Appendix B - Project Modifications 

Resulting from Section 7 Consultation 

Process with the Fish and Wildlife Service

During the Section 7 consultation process, modifications resulted to the Pinaleno Ecosystem 

Restoration Project proposed treatments and design features in order to reduce the incidental take 

under the Endangered Species Act. These modifications are intended to reduce potential impacts 

to the Mexican spotted owl. A map of the revised project follows at the end of this appendix.

Modification of Proposed Action

Projectwide Design Feature added – Treatments will not occur during MSO breeding season.

Only monitoring and project preparation will occur between March 1st and August 31st. This 

design feature listed below will be incorporated into the project. 

Treatments in Mexican Spotted Owl Protected 

Activity Centers (PAC) Modified to Preclude Incidental Take

1. Moonshine PAC – PAC acres removed from project

Implementation Subdivision Treatment 

Unit

Acres 

Removed Removals from Project

Grant Creek 69 0.4 Boundary change remove PAC Acres

Grant Creek 509 3.1 Boundary change remove PAC Acres

2. Riggs Lake PAC – Defer decision to treat all units in Clark Peak Implementation Subdivision 

for 5 years including portions inside of the Riggs Lake PAC, reinitiation of consultation may 

occur after that time.

Implementation 

Subdivision

Treatment 

Unit

Acres 

Deferred Deferrals/Removals

Clark Peak 124 19.6 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 125 3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 129 16.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 134 10.6 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 142 3.8 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 145 16.7 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 152 17.3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 156 9.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 159 19.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 170 6 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 171 15.3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 176 20.8 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 189 50.3 Deferred, may reinitiate consultation with FWS after year 5
Appendix B – Project Modifications Resulting from 

Section 7 Consultation Process with the Fish and Wildlife Service

28 Pinaleño Ecosystem Restoration Project, Coronado National Forest

Implementation 

Subdivision

Treatment 

Unit

Acres 

Deferred Deferrals/Removals

Clark Peak 192 5.1 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 197 24 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 200 28.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 209 7.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 213 3.7 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 218 9.9 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 222 45.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 223 0.8 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 226 10.4 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 231 5.3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 232 18.2 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 233 37 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 234 2.8 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 235 10.3 Removed from treatment, in IRA

Clark Peak 236 5.7 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 237 16.9 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 238 8.1 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 239 13.2 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 242 5.9 Removed from treatment, in IRA

Clark Peak 243 4.4 Removed from treatment, in IRA

Clark Peak 458 19.3 Removed from treatment, in IRA

Clark Peak 459 5.5 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 460 11.6 Removed from treatment, in IRA

Clark Peak 461 1.7 Removed from treatment, in IRA

Clark Peak 462 24.3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 464 33.3 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 533 34.5 Deferred, may reinitiate consultation with FWS after year 5

Lefthand 165 8.3 Deferred, may reinitiate consultation with FWS after year 5

Lefthand 450 11.3 Deferred, may reinitiate consultation with FWS after year 5

Lefthand 451 11.4 Deferred, may reinitiate consultation with FWS after year 5

Lefthand 453 6.8 Deferred, may reinitiate consultation with FWS after year 5

Lefthand 454 3.9 Deferred, may reinitiate consultation with FWS after year 5
Appendix B – Project Modifications Resulting from 

Section 7 Consultation Process with the Fish and Wildlife Service

Pinaleño Ecosystem Restoration Project, Coronado National Forest 29

3. Chesley PAC – Drop portion of treatments that were inside the core, other treatments only 

occur outside the breeding season, deferred Clark Peak Implementation Subdivision units (acres 

reported in previous table) 

Implementation 

Subdivision

Treatment 

Unit

Acres 

Removed Removal from Project

Lefthand 445 1.8 Removed from treatment

Lefthand 447 9.7 Removed from treatment

Implementation 

Subdivision

Treatment 

Unit Deferrals

Clark Peak 145 Deferred, may reinitiate consultation with FWS after year 5

Clark Peak 533 Deferred, may reinitiate consultation with FWS after year 5

4. Webb Peak PAC – Remove treatments that are south of Swift Trail, removing all treatments 

in the core, all remaining treatments will occur outside the breeding season, topography will aid 

in directing smoke away from cores.

Implementation 

Subdivision

Treatment 

Unit

Acres 

Removed Removals from Project

Columbine 92 10.4 Removed from treatment

Columbine 93 14.3 Removed from treatment

Columbine 95 2.7 Removed from treatment

Columbine 105 14.0 Remove PAC portion only from treatment

Columbine 380 13.8 Removed from treatment

Columbine 382 2.3 Removed from treatment

Columbine 471 11.8 Removed from treatment

Columbine 473 5.5 Removed from treatment

Columbine 475 7.2 Removed from treatment

Columbine 477 16.5 Removed from treatment

Columbine 479 2.0 Removed from treatment

Columbine 483 4.2 Removed from treatment 

Columbine 529 0.6 Remove PAC portion only from treatment

Columbine 530 3.8 Removed from treatment 
Appendix B – Project Modifications Resulting from 

Section 7 Consultation Process with the Fish and Wildlife Service

30 Pinaleño Ecosystem Restoration Project, Coronado National Forest

5. Grant Vista PAC – Remove all of the important wildlife area silviculture treatment units from 

PAC, other treatments will occur outside the breeding season, small acreage most are fuel 

treatments only, topographic features help redirect smoke away from the core.

Implementation 

Subdivision

Treatment 

Unit

Acres 

Removed Removals from Project

Bible Camp 403 1.3 Removed core acres from unit

Columbine 80 14.3 Removed unit from treatment

Columbine 82 10.1 Removed unit from treatment

Columbine 91 6.0 Removed unit from treatment

Columbine 368 4.5 Removed unit from treatment

Columbine 375 8.3 Removed unit from treatment

Reasonable and Prudent Measures and 

Terms and Conditions – Mount Graham Red Squirrel

The following reasonable and prudent measures, with their accompanying terms and conditions, 

are necessary and appropriate to minimize incidental take of Mount Graham red squirrel 

(MGRS):

1. Any MGRS nest trees that are found in important wildlife areas and forest restoration 

areas shall be bufferred. 

a. Should MGRS nest trees be discovered during pre-implementation, sweeps of 

treatment blocks shall be provided a no-treatment buffer similar to one that would be 

created around a newly discovered midden. In important wildlife areas, a 92-foot 

radius buffer, and in forest restoration areas, a 200-foot radius buffer shall be 

established around MGRS nest trees.

2. You shall submit annual reports documenting project implementation; results, effects, and 

incidental take to the FWS and review committee for the life of the project.

a. Reporting of monitoring results and complete records of all incidental take that 

occurs during the life of the project will be included in the Forest Service’s 

Endangered Species Act (act) report submitted annually to the FWS. If appropriate, a 

separate report containing this information may be submitted to the review 

committee.

b. Should the FWS or a member of the review committee determine further discussion 

is required based on the results included in any annual report, the forest shall convene 

a meeting accordingly.

Conservation Recommendations

Section 7(a)(1) of the act directs Federal agencies to utilize their authorities to further the 

purposes of the act by carrying out conservation programs for the benefit of endangered and 

threatened species. These conservation recommendations from the U.S. Fish and Wildlife Service 

are discretionary agency activities to minimize or avoid adverse effects of a proposed action on 

listed species or critical habitat, to help implement recovery plans, or to develop information.
Appendix B – Project Modifications Resulting from 

Section 7 Consultation Process with the Fish and Wildlife Service

Pinaleño Ecosystem Restoration Project, Coronado National Forest 31

The FWS recommended continued assistance of the forest in implementation of the MGRS 

recovery plan and its revisions, including providing funding for carrying out key recovery actions

under our authorities.

The FWS also recommended acquistion of LiDAR (Light Detection and Ranging) data of the 

project area after the proposed action is complete to fully assess the changes in basal area, forest 

structure, and other key habitat components important to Mount Graham red squirrels when 

compared to LiDAR data that the forest acquired in 2008.

Reasonable and Prudent Measures 

with Terms and Conditions – Mexican Spotted Owl

The following reasonable and prudent measure and the associated term and condition is necessary 

and appropriate to minimize take of MSO:

1. Annual reports shall be submitted documenting project implementation, results, effects, 

and incidental take to the FWS for the life of the project.

a. Reporting of monitoring results, progress in implementing the project as proposed, 

and complete records of all incidental take detected during the life of the project will 

be tracked yearly and included in the Forest Service’s Endangered Species Act report 

submitted annually to the FWS (both the Tucson suboffice and the Mexican spotted 

owl lead in the Flagstaff suboffice). In regard to incidental take, the following shall 

be monitored and reported: (1) the length of time of disturbance within or 

immediately adjacent to each PAC, (2) the extent of treatment occurring within PACs 

and cores, and (3) numbers of MSO injured, killed, or otherwise incidentally taken as 

a result of the proposed action, where such a determination can be made. 

Conservation Recommendations

Section 7(a)(1) of the act directs Federal agencies to utilize their authorities to further the 

purposes of the act by carrying out conservation programs for the benefit of endangered and 

threatened species. These conservation recommendations from the U.S. Fish and Wildlife Service 

are discretionary agency activities to minimize or avoid adverse effects of a proposed action on 

listed species or critical habitat, to help implement recovery plans, or to develop information.

The FWS recommended continued assistance of the Forest to improve prescribed burning 

techniques and determine means by which more key habitat components/physical and biological 

features of spotted owl habitat may be retained following fuels reduction treatments.

The FWS also recommended aquistion of LiDAR data of the project area after the proposed 

action is complete to fully assess the changes (when compared to LiDAR data acquired in 2008) 

in key habitat components/physical and biological feature of MSO habitat.

Appendix B – Project Modifications Resulting from 

Section 7 Consultation Process with the Fish and Wildlife Service

Pinaleño Ecosystem Restoration Project, Coronado National Forest 33