United States Department of Agriculture

Forest Service

Southwestern Region

MB-R3-07-19a

February 2014

Appendices for the Final 

Environmental Impact Statement 

for the Kaibab National Forest 

Land and Resource Management 

Plan

Coconino, Yavapai, and Mojave Counties, Arizona

Cover: collage of four images―Kanab Wilderness, Abert squirrel, Ponderosa pine, and aspen.

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Contents

Appendix A. Response to Comments.......................................................................... 327

Content Analysis Process........................................................................................................ 327

Alternatives.............................................................................................................................. 327

General Comments – Revised Plan/EIS .................................................................................. 329

Standards and Guidelines........................................................................................................ 333

Pinyon-juniper Communities................................................................................................... 335

Ponderosa Pine Forests............................................................................................................ 335

Mixed Conifer Forests............................................................................................................. 355

Aspen....................................................................................................................................... 357

Standards and Guidelines for Vegetation Management in All Forested Communities........... 358

Large-scale Disturbance Events in Forest and Woodland Communities ................................ 359

Sagebrush Shrublands ............................................................................................................. 360

Grassland Communities........................................................................................................... 360

Desert Communities................................................................................................................ 361

Wetland/Cienega ..................................................................................................................... 361

Cottonwood-Willow Riparian Forest ...................................................................................... 361

Soils and Watersheds............................................................................................................... 363

Natural and Constructed Waters.............................................................................................. 365

Wildlife.................................................................................................................................... 367

Threatened, Endangered, and Sensitive Species...................................................................... 377

Rare and Narrow Endemic Species......................................................................................... 385

Nonnative Invasive Species..................................................................................................... 386

Wildland Fire Management..................................................................................................... 387

Air Quality............................................................................................................................... 388

Cultural Resources................................................................................................................... 390

Recreation and Scenery ........................................................................................................... 391

Transportation and Forest Access............................................................................................ 394

Livestock Grazing ................................................................................................................... 395

Timber Suitability.................................................................................................................... 402

Forestry and Forest Products................................................................................................... 404

Energy Transmission and Development.................................................................................. 405

Minerals and Mining ............................................................................................................... 406

Arizona Bugbane Botanical Area............................................................................................ 406

Double A Wild and Free Roaming Burro Territory ............................................................... 407

National Scenic, Historic, and Recreation Trails.................................................................... 407

House Rock Wildlife Area ...................................................................................................... 407

Pediocactus Conservation Area............................................................................................... 408

Research Natural Areas........................................................................................................... 408

Economics............................................................................................................................... 409

Monitoring and Adaptive Management.................................................................................. 412

Climate Change ....................................................................................................................... 415

Glossary................................................................................................................................... 417

References............................................................................................................................... 418

Commenter Codes................................................................................................................... 420

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS i
Appendix A. Response to Comments

Appendix B. Methodologies and Analysis Processes................................................. 421

Vegetation, Fuels, and Fire...................................................................................................... 421

Wildlife Habitat Analysis (Based on VDDT).......................................................................... 443

Watersheds, Soils, and Waters ................................................................................................ 449

Nonnative Invasive Plants....................................................................................................... 449

Air Quality............................................................................................................................... 450

Recreation................................................................................................................................ 450

Scenery .................................................................................................................................... 451

Heritage Resources.................................................................................................................. 451

Transportation.......................................................................................................................... 451

Socioeconomic Analysis ......................................................................................................... 452

References............................................................................................................................... 453

Appendix C. Timber Suitability Calculation, Financial Analysis, ASQ, and LTSY

..................................................................................................................................... 455

Calculating Acres of Suitable Timber..................................................................................... 455

Financial Evaluation................................................................................................................ 461

Allowable Sale Quantity and Long-term Sustained Yield ...................................................... 463

References............................................................................................................................... 470

Appendix D. Grazing Suitability and Capability....................................................... 471

References............................................................................................................................... 473

Appendix E. Wilderness Area Evaluation Summary ................................................ 475

Inventory of Potential Wilderness Areas................................................................................. 475

Evaluation of Potential Wilderness Areas............................................................................... 476

Capability Analysis ................................................................................................................. 476

Availability Analysis............................................................................................................... 481

Need Analysis.......................................................................................................................... 486

References............................................................................................................................... 489

Appendix F. Wild and Scenic River Assessment........................................................ 491

Introduction ............................................................................................................................. 491

Land Management Planning.................................................................................................... 491

Determination of Eligibility and Potential Classification........................................................ 492

Determination of Suitability .................................................................................................... 494

Summary of Results ................................................................................................................ 494

References............................................................................................................................... 494

Appendix G. Research Natural Area Evaluation ...................................................... 495

Background.............................................................................................................................. 495

Regional Research Natural Area Inventory............................................................................. 495

Regional Research Natural Area Representativeness Needs Assessment............................... 496

Kaibab National Forest Evaluation for Previously Proposed Research Natural Areas........... 497

References............................................................................................................................... 500

Appendix H. Crosswalk Between Species Habitat Risk/Threats and Plan 

Components ............................................................................................................... 501

ii Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix I. Management Indicator Species Selection .............................................. 535

Introduction ............................................................................................................................. 535

Management Indicator Species Selection Factors................................................................... 535

Management Indicator Species Selection Results and Rationale ............................................ 537

Strategy for Monitoring Management Indicator Species......................................................... 539

Ecological Indicators............................................................................................................... 539

References............................................................................................................................... 544

Appendix J. Use of the “Best Available Science” for Wildlife in the Forest Plan 

Revision Process ........................................................................................................ 549

Introduction ............................................................................................................................. 549

Literature ................................................................................................................................. 549

Databases and Data Management Systems ............................................................................. 549

Contemporary Modeling Tools and Approaches..................................................................... 550

Scientific Conferences, Workshops, and Collaborations ........................................................ 552

Appendix K. Large Tree Retention Classes for Ponderosa Pine.............................. 555

Age Class Descriptions............................................................................................................ 556

References............................................................................................................................... 556

Appendix L. Collaboration and Coordination with Other Planning Efforts.......... 557

Introduction ............................................................................................................................. 557

Collaboration and Public Involvement Effort ......................................................................... 557

Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as 

amended) and the Revised Forest Plan ................................................................... 577

Appendix N. Comments Received from Governmental Entities During the 90-Day 

Public Comment Period............................................................................................ 655

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS iii

Appendix A. Response to Comments

This appendix documents the Kaibab National Forest (NF) responses to substantive comments 

that were received during the 90-day comment period for the Draft Land and Resources 

Management Plan (plan or forest plan) and Environmental Impact Statement (EIS). A notice of 

availability was posted in the Federal Register on April 20, 2012, by the Environmental 

Protection Agency (EPA) for the “Draft Environmental Impact Statement for the Kaibab National 

Forest Land and Resource Management Plan” (DEIS). This initiated the comment period, which 

ended on July 18, 2012. The Forest Service received comment letters or emails from 56 

individuals, organizations, and agencies; these comments were received by email, in person and 

via the U.S. Post Office. Letters from government agencies and tribes are included in appendix N. 

The original comments received on the DEIS are included in the administrative project record, 

which is available at the Kaibab Forest Supervisors office, 800 s. 6th Street, Williams Arizona 

86046. 

Content Analysis Process

The comment content analysis followed a systematic process of reading, coding, and 

summarizing the comments that were submitted. This process ensured that every comment was 

read, analyzed, and considered. The comments that were most helpful were those that were 

unique and specifically related to the plan and analysis in the DEIS. Each commenter was 

assigned a commenter code (see list of commenter codes on the last page of this appendix). Each 

unique comment was numbered sequentially and paraphrased where necessary to focus on issues. 

Comments were then sorted by topic in a spreadsheet and exported into this appendix. Similar 

comments were grouped and nearly identical comments were combined. The interdisciplinary 

team prepared responses for each comment based on its merits, regardless of the source or 

whether expressed by many or by one. This appendix documents the Kaibab NF responses to 

substantive comments, which are addressed as prescribed in 40 CFR 1503.4 in the following 

ways:

Modifying the proposed plan (alternative B) and alternatives;

Developing or analyzing alternatives not given detailed consideration in the DEIS;

Supplementing, improving, or modifying the analysis that the DEIS documented;

Making factual corrections; and/or

Explaining why the comments need no further agency response.

Alternatives 

Comment: The forest should have prepared a more creative and comprehensive set of 

alternatives. (EBR-1) The Forest Service has failed to provide for a full range of reasonable 

alternatives as the desired conditions are the same for all alternatives. (SC-80)

Response: The EIS evaluates a range of reasonable alternatives that were developed to address 

the significant issues raised. The final environmental impact statement (FEIS) chapter 1 describes 

the issues raised, and chapter 2 describes the alternatives developed in response to the significant 

issues. The desired conditions did not vary as they describe a collaboratively developed common 

vision. Alternatives were developed as different means to achieve those desired conditions. The 

issues that drove alternatives C and D resulted in modifications of the proposed action to include 

different guidelines, a new management area with a corresponding desired condition, additional 

recommended wilderness, and either reduced or no acres identified as suitable timber. Most of 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 327
Appendix A. Response to Comments

the comments received about the desired conditions were addressed by modifying the associated 

desired condition language. Examples include adding language to ponderosa pine and dry mixed 

conifer desired conditions that “group sizes may be larger,” to cottonwood-willow that “native 

vegetation dominates,” and that “Soils are free from anthropogenic contaminants that could alter 

ecosystem integrity or affect public health.”

Comment: There should be an alternative based on the existing standards and guidelines in the 

existing forest plan. (CBD-13) 

Response: Alternative A-no action is the alternative containing the standards and guidelines in 

the existing plan. 

Comment: The Forest Service should consider and fully analyze an action alternative that 

responds to changes in global and regional climate. There should be at least one reasonable 

alternative that provides increased protection to plant and animal species that responds to the 

scientific uncertainty regarding climate change impacts to habitat and water availability. (CBD11, CBD-12)

Response: The proposed action and alternatives were developed to address potential changes to 

the environment attributable to climatic change. The action alternatives respond to this issue to 

varying degrees by increasing plant community resilience and addressing uncertainties 

associated with climate change impacts to habitat and water availability. Climate change is 

addressed indirectly throughout the proposed plan with desired conditions in the form of 

functional ecosystems and resilient landscapes. Climate change is addressed directly in 

management approaches and monitoring plan implementation where appropriate. Plan appendix 

D provides a more detailed explanation of the strategy the Kaibab NF is using to address climate 

change. 

Comment: There should have been at least one alternative that maximizes the long-term 

vegetative health through a hands-off conservation strategy and restrictive management 

standards. (EBR-39)

Response: Chapter 2 describes an alternative that uses a hands-off approach to vegetation 

management that was considered, but not analyzed in detail because it did not meet the purpose 

and need. Current conditions in the ponderosa pine and frequent-fire mixed conifer forests have 

accumulations of live and dead woody material that can lead to uncharacteristic and undesirable 

fire effects. With a “hands-off” approach, fire and other natural disturbances are the only 

available mechanisms for making progress toward desired conditions. Under current conditions, 

when natural ignitions occur, they typically either burn at low intensity and do not do enough to 

lift crowns, open up tree density, and reduce fuel accumulations; or they burn with high intensity, 

resulting in the loss of ecosystem diversity, structure, and processes. All of the action alternatives 

seek to provide for long-term vegetative health. Alternative D has no lands identified for timber 

production, which responds to the desire for a hands-off approach for maintaining the desired 

conditions after necessary mechanical treatments are implemented. Alternative D also has a more 

restrictive tree retention guideline, and additional recommended wilderness areas which would 

reduce both the intensity and extent of the mechanical treatments that are implemented. 

Comment: In addition to the recommended potential wilderness additions in alternatives C and 

D, we also urge the Kaibab National Forest to establish Red Point Inventoried Roadless Area 

(IRA) (7,136 acres) as a potential wilderness. (SC-111, WILD-29)

328 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: The Red Point IRA was assessed during the Potential Wilderness Evaluation and the 

rational for why it was not included in an alternative analyzed in detail was documented in the 

Potential Wilderness Evaluation report. In response to this comment and one received during 

scoping, an “alternative considered, but not analyzed in detail” was added to the FEIS. Chapter 

2 now includes an alternative that contains the remaining two IRAs that were not previously 

addressed in the alternatives section. Red Point did not meet the criteria to be recommended for 

wilderness designation due to low capability scores for naturalness, special features and values, 

and manageability. The lower scores were in part due to extensive burning during the Warm Fire 

of 2006. As a result, the area has management needs to improve its progress toward the desired 

conditions that would be more difficult and expensive without mechanical means. As an 

inventoried roadless area, Red Point will continue to be managed for its roadless character and 

would likely be more capable of providing wilderness values in the future with fewer weeds and 

forest structure that better resembles the desired conditions. A description of the potential 

wilderness area analysis process and results for each area is found in the Kaibab National Forest 

Potential Wilderness Area Report.

General Comments – Revised Plan/EIS

Comment: A historical synthesis including the administrative history of each forest district would 

benefit the Forest Service’s long-term planning process to let future managers and the interested 

publics know about the historic individuals and the issues considered in each plan revision. (LS13, WILD-4)

Response: Historical information was used to: identify baseline conditions and trends in the 

Analysis of the Management Situation (AMS), provide context in the background and 

management approach sections of the plan, and inform the EIS existing conditions and 

cumulative effects analysis. As we implement the plan, we will continue to build upon, synthesize, 

and use historical information. While there would be benefits to compiling the suggested historic 

synthesis, it is beyond the scope of the plan revision process. 

Comment: The DEIS affected environment section should disclose important ecological, 

economic, and historic information, including how management under the old plan succeeded or 

failed. (EBR-22)

Response: The management needs for change documented in the Analysis of the Management 

Situation/Comprehensive Evaluation Report (AMS/CER) identified conditions and trends that 

indicated a need for change in management under the old plan. These needs for change served as 

the focus for the proposed action development. The effects analysis documented in chapter 3 of 

the EIS discloses the effects and effectiveness of the no-action alternative, which is continued 

management under the 1988 plan, as amended. 

Comment: For a variety of reasons, the Kaibab NF has been unable to implement the current 

plan (alternative A). This situation is unsustainable and puts our public lands and future 

generations at risk. (JK-3)

Response: The Kaibab NF has been implementing the original 1988 forest plan, as amended, 

over the last 15 plus years. Project proposals made during this time period were developed 

following plan guidance with the intent of moving the Kaibab NF toward plan-specified goals. 

Many of these proposals have been implemented or are in the process of being implemented. 

Achieving plan-specified goals for the Kaibab NF has not moved forward as rapidly as desired 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 329
Appendix A. Response to Comments

due to a variety of factors that have delayed project development and implementation. This has 

led to conflict and delays related to conflict resolution. The revised plan clarifies sections that 

have led to confusion over plan interpretation and provides direction for sustainable land 

management for future generations.

Comment: The plan should provide more clear direction to assist practitioners to navigate the 

plan. (AGFD-1) When references are made to other law, regulation or policy, they should more 

clearly describe how they would be implemented in the context of the plan. (DOI-18)

Response: Chapter 1 of the draft plan contained guidance for navigating the plan and an 

explanation about the relationship of the plan to law, regulation, and policy. Portions of chapter 1 

explained how to use the plan, but they were scattered throughout different sections where they 

were also a logical fit. For the final plan, a “Plan Implementation” header was added and the 

sections that addressed navigating, interpreting, and implementing the plan was consolidated. 

Additional information was added to chapter 1 to better clarify how to use the plan and how to 

apply the desired conditions at different scales. Chapter 1 of the plan has also been updated to 

clarify that the Kaibab NF is managed in accordance with law, regulation, and policy, but that the 

plan direction does not reiterate them. Certain laws, regulation, or policy are referenced in the 

management direction for specific resources. For example, plan guidelines for threatened, 

endangered, and sensitive species include “Project activities and special uses occurring within 

federally listed species habitat should integrate habitat management objectives and species 

protection measures from approved recovery plans.” Therefore, in this case, the objectives and 

protection measures contained in current species recovery plans have the same force and effect as 

if they were duplicated in the plan. They are referenced and not duplicated verbatim to avoid 

having to revise the forest plan whenever a recovery plan is updated. 

Comment: Given the high spatial overlap of the Kaibab Plan and the 4FRI Project, we 

encourage the KNF to crosswalk its plan with that of 4FRI. (AGFD-55)

Response: A crosswalk was done with the 4FRI for plan consistency, and the 4FRI proposed 

action is consistent with revised forest plan. Because 4FRI is a project implementing the plan, the 

crosswalk is in the 4FRI administrative record, not in the plan administrative record. 

Comment: Under Wilderness and Recommended Wilderness sections of the revised plan, we are 

concerned about the ability to adequately manage wildlife as habitat becomes more restricted and 

fragmented. Sometimes a more proactive approach to wildlife management is needed. The 

Department has experienced restrictions resulting from wilderness designation, including project 

delays and increased costs. If not properly implemented, additional wilderness designations could 

further inhibit the ability to perform necessary management activities. (AGFD-42)

Response: The revised plan is based on restoration of the different vegetation groups to reflect 

historic conditions. Managing forest guided by historical conditions also restores the 

evolutionary environment, enhancing the capacity of organism’s ecosystems to adapt to stressors 

(Reynolds et al. 2013) and should provide for the habitat components required by native species 

at the level in which they evolved with (Kalies et al. 2012; Kalies and Rosenstock 2013). The 

proposed restoration activities should help maintain and restore habitat that has been fragmented 

and would maintain wildlife habitat at historic levels in the long-term. The potential 

management needs were considered in the availability portion of the wilderness evaluation 

330 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

process. Site-specific information and input from stakeholders, including AGFD was used to 

evaluate the relative trade-offs of the wilderness recommendations.

Comment: Active forest restoration activities that reduce the risk of unnaturally severe fire are 

urgently needed in some existing wilderness areas. We encourage the plan to consider taking a 

strategic, experimental approach that allows for mechanical treatment of the heaviest fuel loads to 

achieve restoration objectives in wilderness. (AGFD-43)

Response: The Wilderness Act prohibits the use of mechanized equipment in designated 

wilderness. The plan cannot make recommendations that are in conflict with the Wilderness Act. 

While the plan does not specifically address fuel reduction in wilderness, the Forest’s Fire 

Management Plan does. It allows for the use of prescribed and wildfire to reduce unnatural 

accumulation of fuels.

Comment: We think you should strike the word "breeding" from the Grand Canyon Game 

Preserve DC. This area is important for game animals in all seasons and especially for mule deer 

in the winter. (AGFD-45)

Response: We agree. The word “breeding” has been removed. 

Comment: The proposed plan makes promises and targets to do various restoration work, as did 

the old plan, but few have been met. This should be acknowledged to show how empty these 

promises can be. (EBR-18)

Response: Objectives and monitoring in the plan were developed to be realistic given budget, 

capacity, and weather constraints. There is acknowledgment in the introduction to chapter 3 of 

the EIS stating that the objectives were developed with the assumption that budgets would be 

similar to the last 5 years. If this is not the case, it is expected that actual accomplishments would 

be lower. 

Comment: Please explain how travel management, the 4FRI, and FSH relate to the plan. (RE-4)

Response: The forest plan provides strategic guidance for project design and development that is 

consistent with the Forest Service Handbook and Manual direction that the Kaibab NF is already 

required to follow. Travel management and the Four Forest Restoration Initiative (4FRI) are 

large projects that implement plan direction and are to be consistent with the plan. 

Comment: Management for forest conditions for North Kaibab is needed to ensure compliance 

with potential designation of that district within the proposed Grand Canyon Headwaters National 

Monument. (LS-25)

Response: Establishment of the proposed Grand Canyon Headwaters National Monument is not 

foreseeable, and therefore, not within the scope of the forest plan revision process. Should it 

become established, necessary compliance and adjustments to the forest plan would be completed 

at that time. 

Comment: Garland Prairie supports some of the highest fawn: doe ratios for pronghorn 

anywhere in the state of Arizona. We recommend the KNF include mention of this value in the 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 331
Appendix A. Response to Comments

Management Area discussion, and specifically encourage a pronghorn-friendly boundary fence in 

the Objectives. (AGFD-48)

Response: The statement “it is known to support some of the highest fawn to doe ratios for 

pronghorn anywhere in the state of Arizona” has been added to the management approach 

section. We did not develop objectives for this area because it would be redundant with the 

objectives in the revised plan which states “Modify fences and/or install crossings to facilitate 

pronghorn movement on 50 miles of fence within 10 years of plan approval” and the guideline 

“Pronghorn fence crossings should be installed along known movement corridors.”

Comment: The proposed plan and DEIS represent movement by Forest Service away from 

integrated resource management. (RE-3)

Response: While the plan and EIS are organized resource-by-resource and use-by-use, the 

development of the plan and FEIS used an interdisciplinary process, considering input from a 

wide range of stakeholders and resource specialists with the intent of developing system-based 

interdisciplinary guidance to balance sustainability, use, and capacity. Where appropriate, the 

plan contains crosswalks to other relevant resource or use sections. The result is a plan and EIS 

that are better integrated, and easier to navigate than the previous plan.

Comment: The EIS should establish criteria for active and passive restoration of forest 

vegetation accounting for the “future range of variability.” (CBD-68)

Response: The plan provides the desired conditions and objectives, but does not prescribe how 

criteria should be established or implementation should be accomplished. Those types of 

decisions are typically made at the project level. 

Comment: We request clarifying language to distinguish between the CWPP (which covers all of 

the Williams District (326,000 acres) and the WUI areas that buffer specific features. As it reads, 

there could be misinterpretation that the Desired Condition is to manage the entire CWPP toward 

the lower end of basal area. In addition, it would be helpful to estimate the acreage of WUI 

designation and to reiterate the size of buffers and feature types buffered by WUI treatments. 

(AGFD-47)

Response: Within the WUI introduction it is already stated that: “For the purposes of this plan, 

the WUI area is refined to a buffer around WUI values to focus more intensive treatments where 

they will have the most impact for fire protection, and includes the following lands: Half-mile 

buffer around all private lands; Half-mile buffer around administrative sites, fee use cabins, fire 

lookouts, developed campgrounds, day use picnic areas, and facilities managed under special use 

permits; Half-mile buffer around at-risk communication sites”.

Comment: In the third bullet under the Kaibab Plateau Parkway desired conditions, we 

recommend adding "and to facilitate animal movement". (AGFD-46)

Response: We agree and have added the recommended language.

332 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Standards and Guidelines

Comment: The National Forest Management Act (NFMA) regulations require the Forest Service 

to prepare a regional guide to provide each region to “provide standards and guides for addressing 

major issues and management concerns that need to be addressed at the regional level.” (CBD34)

Response: There is no longer a regional guide for the Southwestern Region. This was withdrawn 

as required by the 2000 Planning Rule at 219.35(e). 

Comment: The proposed plan would repeal virtually all the standards and guidelines and replace 

them with nonbinding desired conditions and guidelines, which the Forest Service may disregard 

in project design and implementation at its discretion. (CBD-1)

Response: To provide greater transparency about the disposition of each of the standards and 

guidelines from the current plan, we added a new appendix to the FEIS (appendix M) that shows 

how the key standards and guidelines from the original plan (as amended) compare with the final 

plan.

We added a short section to chapter 1 of the revised plan that provides some background about 

plan development and explains the following:(1) many of the standards and guidelines that were 

“repealed” duplicated law, regulation, or policy, which the Kaibab NF is required to follow along 

with the forest plan direction; and (2) where appropriate, standards and guidelines were either 

retained or reframed in the form of desired conditions or objectives. Even with many of the 

standards and guidelines removed or reframed for these reasons, the revised plan still contains 

over 180 guidelines and 20 standards.

Chapter 1 of the revised plan explains that desired conditions and guidelines are not 

discretionary; projects must either maintain or move toward desired conditions. Guidelines are 

technical criteria or constraints that provide sideboards to keep projects and activities moving 

toward the desired conditions. A guideline only allows departure from its terms when the original 

intent of the guideline is met. When there is deviation from a guideline, the decision document 

must specify the deviation and the rationale for how the project meets its original intent. If it 

does not meet the original intent, a plan amendment is required. 

Comment: Repealing environmental standards in the forest plan will result in reduced 

environmental standards at the site-specific level resulting in direct, indirect, and cumulative 

effects that should be disclosed in the EIS. (CBD-25) The EIS does not examine how 

management will change or acknowledge important differences between the proposed plan and 

the existing plan. (EBR-14) The EIS should include a discussion about how well the first forest 

plan worked. (RE-1)

Response: The plan and the action alternatives provide for equal or increased environmental 

protection over that of the current plan through a combination of desired conditions, objectives, 

standards, and guidelines. We added appendix M to the FEIS that shows how the key standards 

and guidelines from the original plan (as amended) compare with the final plan. Many of the 

components were retained, some were modified, and some that were not within management 

control or that were already addressed by law, regulation, or policy were not carried forward. 

The AMS analyzed and disclosed the effectiveness of the current plan, and the FEIS evaluates and 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 333
Appendix A. Response to Comments

discloses the direct, indirect, and cumulative effects of all alternatives including alternative A (no 

action/current plan). Comparisons among alternatives are discussed throughout the FEIS.

Comment: The plan should not have discarded the water quality standards or standards for the 

Mexican spotted owl. (EBR-11)

Response: The revised plan provides management direction for water quality in the Natural and 

Constructed Waters, Soils and Watershed, and Potable Water sections of the plan. The Mexican 

spotted owl is addressed in the plan section for threatened, endangered, and sensitive species. 

Some of the 1988 plan (as amended) standards for water quality and Mexican spotted owls were 

not retained because there is existing law, regulation, and policy guidance for these resources 

outside the plan that the Kaibab NF is already required to follow. The effects of the revised plan 

and the 1988 plan (as amended) on these resources are disclosed in the respective sections of the 

FEIS. In the revised plan, appendix B lists other law, policy, and regulation and appendix M 

shows how the key standards and guidelines from the original plan (as amended) compare with 

the final plan.

Comment: The guidelines all contain the word “should” which does not afford any protection at 

all because the Forest Service can decline to follow them whenever the agency doesn't want to. If 

a project does not include such a measure, is it in violation of the plan? (EBR-8)

Response: Plan language follows the Forest Service’s technical guidance for writing guidelines, 

which specifies using the word “should.” Guidelines are not discretionary. A guideline only 

allows for departure from its terms when the intent of the guideline is met. Deviation from a 

guideline must be specified in the decision document with the supporting rationale. When 

deviation from a guideline does not meet the original intent of the guideline, a plan amendment is 

required.

Comment: The 1988 plan should have been used as a building block for the revised plan. For 

example, there was a standard that there should be 200 snags per acre, three age classes of woody 

riparian species along stream banks, and 90 percent shrub cover along stream banks. (EBR-2)

Response: The original plan was used as a building block for the revised plan. Many of the 

original plan components were retained, some were modified, and some that were not within 

management control or that were already addressed by law, regulation, or policy were not carried 

forward. Point of correction: the original plan said there should be 200 snags per 100 acres, not 

per acre. When the plan was revised in 1996, the snag guidance in forest-wide directions for 

ponderosa pine habitat was modified to be two snags per acre. 

In the revised plan, the snag requirements were reframed as desired conditions at the mid-scale, 

and are very similar to the original 1988 plan and the original plan as amended, which is 1 to 2 

snags per acre when averaged over 100 acres in ponderosa pine. The shrub and age classes in 

riparian areas were either not attainable due to upstream diversions off the Kaibab NF or not 

representative of the riparian systems that occur on the Kaibab NF. We added appendix M to the 

FEIS to show how the key standards and guidelines from the original plan (as amended) compare 

with the final plan.

334 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Pinyon-juniper Communities

Comment: There should be language that allows for management of pinyon juniper communities 

toward a condition that may be considered outside of historic conditions (typically more open), 

and therefore, outside of the desired conditions as written. (AGFD-27)

Response: The desired condition for canopy cover in the pinyon-juniper potential natural 

vegetation type (PNVT) now specifies “at the mid-scale.” This additional language better reflects 

that variation is desirable, and that would likely have occurred under the natural disturbance 

regime. The language modification will better support management in pinyon-juniper that 

reduces tree density and creates fine-scale openings to improve wildlife habitat. The desired 

conditions for pinyon-juniper communities were developed to reflect the historic range of 

variation. The desired conditions include a mix of seral stages. The desire to manage for a 

somewhat balanced mix of seral stages on the landscape permits management for open 

conditions where appropriate, which would include some areas at the fine scale being more open 

(canopy cover less than the defined 10 percent).

Comment: The desired condition for understory plant cover in pinyon-juniper communities and 

pinyon-juniper grasslands should also mention that they also support wildlife. (AGFD-2)

Response: We responded to this comment by modifying these desired conditions (several places) 

to better represent the important habitat that pinyon-juniper communities provide for wildlife.

Comment: The plan should include a guideline in pinyon-juniper communities that states 

"Vegetation treatments and livestock utilization levels should favor the development of 

understory diversity in areas where it has the potential to grow”. (AGFD-4)

Response: This suggestion was not incorporated because it would be redundant. The concern is 

already addressed through the vegetation desired conditions combined with the guidelines that 

state “Vegetation management should favor the development of native understory species in 

areas where they have the potential to establish and grow,” “livestock management should favor 

the development of native cool season grasses and forbs,” and “annual operating instructions for 

livestock grazing permittees should ensure livestock numbers are balanced with capacity and 

address any relevant resource concerns (e.g., forage production, weeds, fawning habitat, soils, 

etc.).” 

Ponderosa Pine Forests

Comment: Reconstructed historic reference conditions should be used as general guides, rather 

than rigid restoration prescriptions. Restoration is not a single event, but a process that occurs 

over time. (SC-86)

Response: Agreed. Plan components lay out the framework for restoration, rather than providing 

rigid prescriptions to restore specific reference conditions in specific locations. The revised plan 

was developed to leave room for specifics to be determined on a site-specific basis using a variety 

of information sources, including but not limited to reference conditions. Often a single project 

can only make progress toward, but not fully achieve the desired conditions. Follow-up activities 

are often needed to achieve and maintain desired conditions over time.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 335
Appendix A. Response to Comments

Comment: A process-centered approach emphasizing the use of naturally adapted fire 

disturbance should be used rather than a structural approach that tries to replicate the spatial 

patterns of old growth that may have existed at a particular point in history. (CBD-41)

Response: Structure and function of old growth are not independent of one another and both are 

addressed in the plan. Desired conditions for the vegetation types that restoration objectives were 

developed for specify both structural and process-based components articulating the desired fire 

regime and other aspects of ecosystem function. The management approach for ponderosa pine 

and frequent-fire mixed conifer forests specifies that “fire-only treatments may be appropriate for 

some areas with open canopies and low fuel loads, but mechanical fuel reduction is needed in 

many areas before fire can be safely reintroduced.” This recognizes that under current conditions, 

a process-centered approach may result in the loss of critical ecosystem components that would 

have been resilient under historic conditions as well as the dynamic nature of uneven-aged forest 

ecosystems where old-growth habitat may shift on the landscape over time.

Comment: Desired vegetation structure and composition patterns based solely on the historic 

ranges of variability may not be appropriate. Desired conditions concepts should be updated to a 

“future range of variability” that accounts for inevitable climate change. The EIS should assess 

departure from the fire regime from more than just one narrowly defined historic condition. 

(CBD-21, CBD-22)

Response: Historic conditions and climate change were only some of the considerations in 

determining the desired conditions. Natural ranges of variability are considered a “best” 

estimate of a resilient and functioning ecosystem because they reflect the evolutionary and 

historical ecology of forests. Natural ranges of variability are thereby a powerful template for 

improving the resiliency of frequent-fire forests. By restoring resiliency, current frequent-fire 

forests will be better able to adapt with changed climates and environments. Additionally, the 

effects of climate change are uncertain, and the historic range of variability is not. Desired 

conditions reflect both restoration and adaptation in restoring and maintaining resilience in 

forest ecosystems. For more information, refer to “Desired Conditions for Use in Forest Planning 

in the Southwestern Region: Development and Science Basis Updated August 2013,” which 

describes the process and science backing the development of the Regional Planning Desired 

Conditions.

Climate change is addressed throughout the revised plan; indirectly through desired conditions in 

the form of functional ecosystems and resilient landscapes, and directly in management 

approaches and the monitoring plan, where appropriate. EIS appendix D provides a more 

detailed explanation of the strategy the Kaibab NF is using to address climate change.

Comment: Relying on evidences as an absolute basis for determining residual tree density targets 

is likely to underestimate the natural variability of forest structure. (SC-5)

Response: Pre-Euro-American tree evidences are not exclusively used to determine target tree 

densities, but are useful to inform about historical conditions prior to the time when cessation of 

natural frequent fires occurred. This has led to conflict and delays related to conflict resolution. 

Evidences may be used to inform what the lower part of this range might be for any particular 

site, but many other factors play a role in determining what the actual residual stocking for an 

area could be. Other resource needs (wildlife, visuals, soils, fuels, etc.) and issues were 

considered in developing this range.

336 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Local research has shown that biological evidences are fairly robust indicators of the naturally 

variable forest structure that was historically present, with the reliability of field-based 

reconstruction techniques falling within 10 percent (e.g., Moore et al. 2004). See Vegetation, 

Fuels, and Fire Specialist Report.

Comment: The PNVT concept assumes that plant community succession is a unidirectional 

process leading to a steady-state condition, an arbitrarily selected successional trajectory assumed 

to develop without disturbance. (CBD-28)

Response: The PNVTs assume a range of structure, composition, and dynamics characteristic to 

the ecosystem, including successional patterns in the natural disturbance processes are intact. 

There is no assumption of a unidirectional process. This is reflected in the Vegetation Dynamics 

Development Tool (VDDT) model, which is a state and transition model that shows probabilistic 

and not deterministic transitions for succession. PNVTs are used primarily as a descriptor of a 

vegetation community, and do not imply management toward a vegetative end-state. The desired 

conditions describe the range of conditions that are desired for each PNVT. 

Comment: The DEIS states that “With thinning from below, it takes longer to achieve a multistoried state, if it is ever achieved” without explaining why this is the case. (SC-92)

Response: By definition, multistoried (uneven aged) stands have at least three age classes of 

trees. When there is a limitation on the trees that are available to be cut, the only way to meet 

desired densities (to increase growing space and reduce competition) is to remove the smaller size 

classes. When the smallest size classes are removed over time, it results in less age diversity in the 

stand. This clarification has been added to the FEIS.

Comment: The DEIS (p. 299) notes that, “the vegetation characteristics of our large, open states 

today do not exactly correspond to the vegetation characteristics of the large, open states in 

reference conditions; but for the purpose of this analysis, this was the assumption.” Please 

provide further explanation. (SC-100)

Response: The statement that was included in Appendix B describes the methodology used to 

evaluate the potential outcomes of various strategies. It acknowledges that historic conditions 

are similar but do not exactly correspond to States J and K as described in the VVDT model. The 

model states have a select group of variables including broad classes for dominant tree sizes, 

canopy under or over 30%, and whether they are single or multistoried. As a result, they cannot 

fully reflect the variability found in the reference conditions. This clarification has been added to 

the FEIS.

Comment: Even though the draft plan says that reference conditions should only be used as a 

guide, the modeling of the effects analysis has very specific target conditions. (SC-3)

Response: We selected conditions for modeling the effects to vegetation based on the midpoint of 

the desired range. Plan language accurately reflects the Kaibab NF’s management approach 

regarding reference conditions. The vegetation modeling is not intended to reflect every treatment 

possibility, but to give insight into the average probable outcomes and provide a relative basis for 

comparing alternatives. We added clarification to appendix B of the FEIS to ensure this is clear. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 337
Appendix A. Response to Comments

Comment: VDDT and PNVT analyses would be more compelling if they had been subjected to 

unbiased peer review. Please state the level of review, accountability, and accuracy of these 

analyses. (LS-12, WILD-2)

Response: We used the VDDT model to assist in evaluating the relative differences among 

alternatives; it is not presumed to be a predictive model. All steps in the process were developed 

using the best available information. ESSA Technologies is the environmental consulting 

company that developed the model; information on ESSA Technologies and the VDDT modeling 

application can be found on their website: http://essa.com/tools/vddt//. A review of this website, 

including the “Reports and Publications” section, demonstrates that this landscape modeling 

framework is state-of-the-art and has been used widely in the United States and Canada.

Use of the VDDT model in support of revising forest plans in the USFS Southwest Region, 

including the Kaibab NF, has been thoroughly documented in several white papers that are 

included in the analysis records. Three are published and peer-reviewed, including one refereed 

journal. See Weisz, R., J. Triepke, and R. Truman. 2009. Evaluating the ecological sustainability 

a ponderosa pine ecosystem on the Kaibab Plateau in Northern Arizona. Fire Ecology 5(1): 

100−114. Additionally there have been two papers published in Conference proceedings (Weisz et 

al. 2011 and Weisz et al. 2009). 

The state and transitions inputs into the model used for the Kaibab Forest Plan analysis were 

built using peer-reviewed literature and the best available science. Inputs for probability of 

occurrence under current management came from rates of treatment and known disturbances. 

The vegetation data on the distribution of states came from the mid-scale data provided by the 

Southwestern Regional Office following a nationally consistent process. The indices developed 

for comparing alternatives relate to specific desired conditions. Appendix B in the EIS articulates 

each component of the modeling to provide increased transparency. See appendix B for more 

detail about the assumptions and process of the VDDT modeling and vegetation analysis.

Comment: The draft plan and DEIS are silent on impacts of removing the standards related to 

canopy and old growth densities. This management shift would allow a significant change in 

forest structure to occur and the effects should be assessed. (SC-93)

Response: The EIS analyzes the current plan (alternative A – no action) and compares it to the 

revised plan and alternatives. It focuses on the outcomes of the alternatives rather than the 

presence or absence of plan components written in a specific way. The canopy cover and 

densities called for in the 1988 plan (as amended) left the landscape at greater risk of stand 

replacing fire and were not open enough to support desired understory diversity. These 

differential changes in anticipated forest structure are discussed throughout the EIS.

Comment: We support a broader range of target basal areas, groups, and sizes; and less extreme 

openings. The Forest Service preferred alternative would create an extremely open condition at 

all spatial scales, with a cookie cutter approach to the percentage of openings that is incompatible 

with desired conditions of variable group sizes, including larger groups. (SC-97) The high end of 

the basal area should be extended to prevent a cookie cutter, 40- to 60-square feet per acre basal 

area result at the fine-scale. (SC-18b)

Response: The basal area range for ponderosa pine at the mid-scale is 20 to 80 square feet per 

acre, which is supported by science. The mid-scale describes conditions when averaged over 

100 to 1,000 acres. Fine-scale units (less than 10 acres) would be expected to have greater 

338 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

variability, not less. At the fine scale, the desired condition for ponderosa pine and frequent-fire 

mixed conifer is that “density is variable,” and there are no limits to basal area at the fine scale, 

greater variability is not only acceptable, but desired. The desired basal area was specified at the 

mid-scale to allow for greater variability at the fine scale, not less.

Comment: More specific information regarding the post-treatment stand structure needs to be 

included to determine the possible impacts of the proposed action on site-specific post-treatment 

canopy densities and, basal areas, and diameters. (SC-6)

Response: This level of site-specific detail is not appropriate for the plan. The plan lays the broad 

framework for stand structure in the form of desired conditions. Projects implementing the plan 

would provide the specific information about post-treatment stand structure based on the existing 

conditions and the objectives of the specific proposed project. 

Comment: All scales of the desired conditions should contain target ranges for the same 

structural attributes, such as basal area, structural stages, opening sizes, percentage of opening or 

any other parameters used in the effects analysis. (SC-17) 

Response: Not all variables are appropriate at all scales, because at the fine scale, a lot of 

variation is expected and desired. Some less common components may not be present at the finer 

scales, but are desired within the landscape. See chapter 1 Plan Implementation section for 

additional discussion. 

Comment: The desired conditions at the mid-scale state that basal area will generally range 

from 20 to 80 square feet per acre with openings typically ranging from 10 to 70 percent. Are the 

opening percentages per acre or on a larger scale? (SC-18a)

Response: It is per acre, when averaged across the mid-scale. The mid-scale desired conditions 

“have descriptions that would be averaged across areas of 100- to 1,000-acre units. Additional 

detail can be found in chapter 1 of the plan in the Plan Concepts section. 

Comment: The desired conditions for the ponderosa pine and mixed conifer vegetation types 

should include language that larger groups are possible particularly on northerly aspects or on 

highly productive sites. (AGFD-7) Larger group sizes with a broader range of maximum group 

sizes should be provided. (SC-11) Without a broader range of group sizes, the less than an acre 

average will become a “maximum” management constraint. (SC-12)

Response: We modified the language to indicate that it is desirable for larger tree groups to 

occur by adding “... but may be larger, such as on north-facing slopes.” The desired conditions 

do support even-aged stands (mid-scale units) to occur as a minor component of the landscape. If 

the intent was for the typical group size to be a maximum management constraint, the statement 

would have been in the form of a standard or guideline, not a desired condition. 

Comment: The draft plan states, “Crowns of trees within the mid-aged to old groups are 

interlocking or nearly interlocking and consist of approximately 2 to 40 trees.” Given the group 

definition, is this per acre, or per group? (SC-13)

Response: It is per group, as stated in the plan. 

Comment: The desired conditions should specify a range of acres for the size of forest openings. 

(AGFD-6)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 339
Appendix A. Response to Comments

Response: We added language to the plan stating that “regeneration openings occur as a mosaic 

and are similar in size to nearby groups.” This articulates that management-created regeneration 

openings should be a size similar to nearby groups, as they are intended to create replacement 

groups, which are typically less than one acre in size. 

Comment: The maximum size of openings is not defined except for those pertaining to large 

uneven-aged stands. (SC-34)

Response: The standard that specifies the maximum size of openings for even-aged management 

comes from national direction (NFMA, 36 CFR, FSH, etc.). This type of even-aged management 

(clearcutting) is infrequently used on the Kaibab NF. However, it may be used when it is the 

optimum method for making progress toward the desired conditions, such as where there are 

undesirable levels of dwarf mistletoe, other severe damage, or a desire to regenerate aspen in 

specific locations.

Comment: Creating regeneration openings may be the equivalent to creating even-aged tree 

groups over time, which is counter to what is known about historic patterns of regeneration in 

southwestern forests (see White 1985). (AGFD-18)

Response: Other literature indicates reference conditions in ponderosa pine that include evenaged groups (Cooper 1960) and a mixture of both even- and uneven-aged groups (Reynolds et al. 

2013). The desired condition described within the revised plan at the fine scale does not exclude 

uneven-aged groups. It states that “Trees within groups are of similar or variable ages....” The 

commenter assumes that the creation of regeneration openings will lead to even-aged groups over 

time. This is not completely true. Older reserve trees can still be retained in regeneration 

openings that will provide uneven-aged structure with groups. Regeneration openings will not 

always completely regenerate to pine all at once. Pine that fills in openings around and within 

groups at a later time will also provide some age and size diversity within tree groups. The 

revised plan does allow for maintaining and developing uneven-aged tree groups

We added clarification to the Management Approach section for vegetation management to 

specify when even-aged prescriptions are appropriate. Depending on the initial conditions, evenaged treatments are sometime the most efficient and effective pathway toward uneven-aged 

conditions across the mid- and landscape scales. As the historic fire interval is reintroduced, 

heterogeneity at the fine scale will increase over time. 

Comment: The draft plan and DEIS do not adequately define openings and discuss the 

relationship between openings and regeneration cuts. (SC-8)

Response: We added definitions for “regeneration openings” and “interspaces” to the glossary.

Comment: Openings that were created by the logging should not be openings to be maintained 

over time. The impacts of existing management created openings should be considered when 

proposing the creation of new openings. This should apply to all spatial scales. (SC-10)

Response: The plan desired conditions and guidelines would maintain the general spatial pattern 

of historical openings. The “potential,” not the “existing” vegetation conditions that determine 

the desired conditions following site-specific analysis using historical evidences and soil 

characteristics would be used as a guide. As a result, management-created openings would not 

typically be expected to regenerate and develop into new forest structural stages over time. 

340 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: The desired conditions for openings state that the openings are variably shaped, but 

do not provide a range of potential sizes or a maximum size. However, the Vegetation 

Development Dynamics Tool (VDDT) model contains targets for basal area as they relate to 

canopy and openings that differentiate open and closed conditions. (SC-14)

Response: VDDT is not spatially explicit and does not model opening size, but it does contain 

three descriptive density classes: openings, open forest states, and closed forest states. In VDDT 

modeling (EIS, appendix B), openings have canopy cover less than 10 percent, “open” states 

have canopy cover between 10 and 30 percent, and “closed” states have canopy cover greater 

than 30 percent.

There are two types of openings: regeneration openings and interspaces, both of which are 

defined in the glossary. In response to this comment, we added a statement to the fine-scale 

ponderosa pine and frequent-fire mixed conifer desired conditions that “Regeneration openings 

occur as a mosaic and are similar in size to nearby groups.” This relates to the existing desired 

condition statement that tree groups “typically occur in areas less than one acre.” Between draft 

and final, the term “openings” was replaced by the word “interspaces” to differentiate the two 

types. The term “regeneration openings” was added to the glossary. 

Mid-scale desired conditions place practical constraints upon the size of openings that are not 

explicit because the desired conditions contain minimum mid-scale densities (20 square feet per 

acre of basal area in ponderosa pine, 30 square feet per acre of basal area in frequent-fire mixed 

conifer), require a range of basal areas (up to 80 square feet per acre in ponderosa pine, up to 

100 square feet per acre in frequent-fire mixed conifer), and specify the Kaibab NF is generally 

uneven-aged. To meet these desired conditions, openings would be limited in both size and extent.

Comment: The models used in the effects analysis looked at movement of opening sizes and 

locations over time. We assume there are data available regarding a range of opening sizes which 

could inform the desired condition. (SC-15)

Response: The VDDT model is not spatially explicit, but it assumes a shifting mosaic of 

conditions over time as the result of various disturbances. The assumptions about opening sizes 

were derived from a combination of studies on historic natural disturbances (fire, insects, 

disease, etc.) and the sizes of openings created from different management prescriptions. 

Comment: The guidelines only mention regeneration openings in relationship to being 

adequately stocked as opposed to discussing how these relate to the percentage of openings in the 

desired condition. Does the Forest Service anticipate the need to achieve stocking levels with 

planting? (SC-35)

Response: Regeneration openings are intended to become future groups. These areas are 

typically less than one acre in size with enough seed-producing trees nearby to achieve adequate 

stocking with natural regeneration. The only objective in the plan for planting trees is for areas 

that burn with uncharacteristic fire and lack adequate seed sources. No other tree planting is 

anticipated, although a project could propose planting to meet a specific need. 

Comment: Shade provided by closed canopy shields the ground from direct solar radiation, 

reduces ground temperature and horizontal wind speed, and increases ambient relative humidity 

and fuel moisture compared to open stands. (CBD-38)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 341
Appendix A. Response to Comments

Response: We acknowledge that there are benefits to shading and maintaining moister 

microclimates at the fine scale, However, in the fire-adapted ecosystems of the Southwest, high 

tree densities associated with closed-canopy conditions can lead to competition-related stress, 

decrease forest diversity by reducing development of other vegetative species in the understory, 

and support active crown fire that is outside the historic range of variability. Closed-canopy 

cover conditions can also lead to diminished snowpack through interception and sublimation.

The revised forest plan allows greater interspaces between groups of trees. This greater distance 

between groups of trees decreases the likelihood of wildland fires being able to move for large 

distances through the forest canopy and consuming large areas of trees within the forest canopy. 

Wider forest openings increase the chances that wildland fires will move primarily along the 

forest floor. Surface fires are much less destructive to the forest canopy and the associated forest 

ecosystem. The revised plan also calls for maintaining groups of trees so that while there is an 

increase in openings around groups of trees there is also a large portion of the forest where 

denser tree conditions exist. These higher density areas will provide the many desirable attributes 

associated with a higher density of trees (interlocking crowns, wildlife cover, shading, moister 

microsites, etc.). The revised plan thus allows for protecting and retaining the forest while still 

maintaining the desirable structural attributes associated with trees of higher densities. The 

revised plan also will develop a forest with much more diverse vegetative and structural 

conditions than a forest with a closed canopy would allow.

Comment: What are the expected sizes of tree groups and expected canopy cover with a 10 to 

20 percent increase in the 20 to 80 square feet per acre basal area range of the general forest 

structure as described in the desired conditions for ponderosa pine at the mid-scale? (SC-76)

Response: The draft plan states that the expected group sizes would vary depending on site 

conditions but “typically occur in areas less than one acre.” Language was added to this desired 

condition statement in the revised plan to acknowledge that group sizes “may be larger, such as 

on north-facing slopes.”

The expected canopy cover would depend on scale and arrangement. At the fine scale (an area 

10 acres or less), canopy could range from very open to very dense (i.e., 10 to 95 percent). At the 

mid-scale (100 to 1,000 acres), canopy would be expected to be higher in an area with larger, 

lower density groups than another area with the same basal area containing small, dense groups. 

This variability is one of the reasons that percent canopy cover was considered a poor metric for 

describing desired conditions in the proposed plan. 

Comment: We disagree that canopy should only be measured at the group level. (SC-9) 

Measuring canopy only at the group scale allows the Forest Service to meet the guidelines on 

paper while failing to meet them on the ground. (SC-75) The plan and DEIS should disclose how 

canopy will be measured and at what spatial scale these measurements will occur. (SC-7) Forest 

Service staff from the regional office previously stated that the canopy requirements in the 

Management Recommendation for the Northern Goshawk (MRNG) RM-217 relating to VSS 4, 5, 

and 6 apply to the group level. Since the discussions were about the MRNG, is it correct to 

assume that this opinion will apply to the larger Kaibab National Forest planning area? (SC-72)

Response: The plan and its alternatives do not specify how canopy should be measured. Only 

alternative A (no action) has canopy cover guidelines. If no action is the selected alternative, 

current management direction would continue and canopy cover guidelines would only apply to 

342 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

groups of VSS 4, 5, and 6, regardless of the areal extent evaluated. Under the action alternatives, 

VSS is not used, and therefore, the canopy cover guidelines do not apply. Instead, the desired 

conditions provide direction consistent with the MRNG.

Comment: The guidelines in alternatives C and D call for maintaining trees established after 

1890, but the caps as currently written would cut mature yellow-barked trees that are smaller than 

16 inches. (SC-33)

Response: The guideline in alternatives C and D only refers to approximate age and not 

diameter. 

Comment: Given the extreme rarity of large trees and the overabundance of small trees, the 

harvest of trees larger than 16 inches diameter at breast height (d.b.h.) cannot be justified on 

ecological grounds. Therefore, an upper limit of 16 inches d.b.h. is necessary to preserve the large 

tree structure critical to wildlife habitat, forest health, and general aesthetics. (CBD-71)

Response: It is not true that an upper tree removal limit of 16 inches d.b.h. is needed to preserve 

large tree structure. Large tree structure can be maintained over time without this arbitrary 

diameter limit (Triepke et al. 2011). The revised plan provides for the large tree structure critical 

to wildlife habitat, forest health, and general aesthetics through desired conditions and vegetation 

management guidelines: “projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across broad age and diameter 

classes at the mid-scale. As such, the largest and oldest trees are usually retained” and 

“prescriptions should generally not remove: large, old ponderosa pine trees with reddish-yellow, 

wide platy bark, flattened tops, with moderate to full crowns and large drooping or gnarled 

limbs” (e.g., Thomson’s age class 4, Dunning’s tree class 5 and/or Keen’s Tree Class 4, A and B). 

The presettlement tree guideline of alternatives C and D was modeled as a 16-inch maximum (as 

a proxy because the model was not sensitive to age). The modeled effects of a 16-inch diameter 

cap demonstrated an increase in stand-replacing fire, resulting in a net loss of large and old tree 

structure critical to wildlife habitat and forest health. 

Comment: We question the need for removal of presettlement trees in this situation as large 

stands of old growth trees may be important local sources of biodiversity when compared to the 

larger landscape that is generally deficient of presettlement trees. (AGFD-15)

Response: The plan guidelines apply to the entire forest for all projects. Cutting presettlement

trees may be necessary in some areas to achieve the desired density and reduce the potential of 

total loss due to uncharacteristic fire: to address local insect, disease, or public safety issues; and 

to move the forest toward uneven-aged conditions desired by the revised plan. It would actually 

be a fairly rare circumstance where presettlement trees would be removed under the revised plan 

as the plan contains direction to retain most of these trees. Before taking any action on the 

ground, site-specific planning would be used to address the specific needs of the area and may 

establish more restrictive guidance. The desired conditions were developed to reflect the historic 

conditions. Peer-reviewed reconstructed conditions for southwestern ponderosa pine and 

frequent-fire mixed conifer indicate that old-growth structure was not historically found in large 

contiguous areas, but rather at finer scales across the landscape. Two guidelines in the proposed 

plan provide guidance for retaining older trees, one specific to old tree structure (e.g., Thomson’s 

age class 4, Dunning’s tree class 5 and/or Keen’s Tree Class 4, A and B), and one that would 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 343
Appendix A. Response to Comments

“retain at least historic frequencies of trees by species across broad age and diameter classes at 

the mid-scale. As such, the largest and oldest trees are usually retained.”

Not all areas on the Kaibab NF show a deficit in presettlement trees. On the North Kaibab 

Ranger District, there are more trees over 20 inches in diameter than there were historically, 

many of which were established before Euro-American settlements. 

Comment: The DEIS acknowledges that old growth trees do not exist as they did historically 

(page 299), but the guidelines in the draft plan do not discuss means for making up deficits. (SC30)

Response: The guidelines do address retaining “at least historic frequencies of trees by species 

across broad age and diameter classes at the mid-scale. As such, the largest and oldest trees are 

usually retained.” These guidelines, along with a suite of desired conditions (old growth, unevenaged conditions, mature trees interlocking crowns, etc.), would direct for the restoration and 

maintenance of old growth making up deficits where they occur.

Comment: The EIS should provide a spatially based discussion of the extent, distribution, and 

structural qualities of old growth as well as a scaled analysis of its current status and projected 

future structure, composition extent and distribution. (CBD-16, CBD-39)

Response: The EIS analyzes the ability of the alternatives to achieve and maintain the old-growth 

desired conditions and species habitat, but a detailed analysis of existing old growth is not 

required. For other purposes, the Kaibab NF does conduct analyses using a variety of sources of 

vegetation structural data that inform and consider the existing spatial extent, distribution, and 

structural qualities of old growth at different scales when comparing existing conditions to 

desired conditions during plan implementation and project design. 

Comment: All old growth that meets the standards and guidelines in the current plan should be 

deferred and there should be standards and guidelines to designate old growth habitat at the site, 

watershed, and ecosystem scales. (CBD-40)

Response: The desired conditions were developed to provide for a flow of old-growth conditions 

and function over time at the fine, mid, and landscape scale. The desired conditions provide for 

spatial shifting or transition of old growth on the landscape over time, consistent with historic 

conditions. 

Comment: Standards and guidelines should specifically address the problem of fragmentation of 

old growth caused by past even-aged timber management and road construction, and apply 

spatially explicit direction showing that old growth systems will be sustained over time. (CBD42)

Response: The plan lays out desired conditions and guidelines that provide general direction for 

possible management, regardless of an area’s history. Where existing conditions differ from 

desired conditions, there is a need for change. Finer, more spatially explicit direction is 

determined at the project level. The revised plan does specify that it is a desired condition to have 

old growth throughout the landscape, but that its location shifts over time as a result of 

succession and disturbance in ponderosa pine and frequent-fire mixed conifer, where a high 

degree of age-class interspersion (fragmentation) is natural, and therefore desired. For mesic 

344 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

mixed conifer/spruce-fir, the plan has a desired condition at the landscape scale that old growth 

occurs over large areas as stands or forests.

The fragmentation concept is not applicable for frequent fire forests in the Southwest. The 

fragmentation concept is applicable to infrequent-fire forest ecosystems where large blocks of 

even-aged old growth develops and persists over long periods of time (e.g., coastal Douglas-fir or 

high-elevation spruce-fir), based on the ecology of these forests. In southwestern frequent-fire 

forests, old growth is naturally fragmented, and occurs as tree groups, clumps, individual trees, 

and occasional patches in an uneven-aged forest landscape. 

Comment: The plan should contain standards and guidelines for maintaining and developing a 

well-defined block of old growth in each project-level assessment area. (CBD-43)

Response: The revised plan provides for goshawk nest areas, which are typically well-defined 

tree groups that meet the definition of old growth. Additionally, the revised plan has a guideline 

that is intended to provide for old growth consistent with its historical occurrence: “Projects in 

forested communities that change stand structure should generally retain at least historic 

frequencies of trees by species across broad age and diameter classes at the mid-scale. As such, 

the largest and oldest trees are usually retained.”

Comment: Due to climate uncertainties, the removal of large, mature or old growth trees may 

constitute an irretrievable commitment of resources. (CBD-60)

Response: While the plan would allow the removal of large, mature, and old trees, the vegetation 

analysis demonstrates that the plan would result in a net gain of large trees over time, and more 

than any other alternative. Therefore, the plan would not result in an irreversible or irretrievable 

commitment of resources. Moreover, managing for restored forest conditions that are similar to 

natural conditions will restore resiliency and the evolutionary environment of these forests, 

providing the best opportunity for these forests to persist and adapt to future climates (Reynolds 

and others 2013).

Comment: The draft plan states, “Old growth occurs throughout the landscape, generally in 

small areas as individual old growth components, or as clumps of old growth.” The Forest 

Service seems to have determined that old growth only occurs on a small scale. (SC-21)

Response: Research has demonstrated an inverse relationship between fire frequency and oldgrowth contiguity. In the ponderosa pine and frequent-fire ecosystems of Kaibab NF, local 

research has shown that old growth did not occur in large contiguous areas, but rather as finescale components of the uneven-aged system (Reynolds et al. 2013). There is no scientific basis to 

support managing for contiguous old-growth conditions at larger scales for these vegetation 

types on the Kaibab NF. 

Comment: The 1996 plan contained minimum structural attributes to provide old growth. The 

DEIS should have displayed how much of the Kaibab meets the current landscape scale old 

growth requirements and assess the impacts of removing those standards. (SC-22)

Response: While the revised plan does not provide “minimum structural attributes,” it does 

contain management direction for old growth through the desired conditions and guidelines. It 

describes old growth and old-growth components for all forest and woodland vegetation types, 

which all projects must either maintain or make progress toward. Additionally, the vegetation 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 345
Appendix A. Response to Comments

management guidelines provide direction not to remove structural components associated with 

old growth including “Large, old ponderosa pine trees, mature trees with large dwarf mistletoeinduced witches’ brooms, large snags, partial snags, and trees (greater than 18 inches d.b.h.) with 

broken tops, cavities, sloughing bark, and lightning scars.” The guidelines also state that the 

project “should generally retain at least historic frequencies of trees by species across broad age 

and diameter classes at the mid-scale. As such, the largest and oldest trees are usually retained.”

Tables 5 and 6 of the EIS show that the current percentage of the landscape in “State K” 

(described as open, multistoried, and dominated by trees greater than 20 inches d.b.h.) is 

2 percent in ponderosa pine and 0.5 percent in frequent-fire mixed conifer. These tables also show 

the anticipated changes over time as modeled under each of the alternatives including the 

original 1988 plan (as amended).

Comment: To preserve the greatest biological diversity, all old growth trees regardless of size, 

and the larger diameter trees that would become the next generation of old growth should be 

retained. (SC-23)

Response: While the Kaibab NF does seek to preserve biodiversity and provide for old-growth 

structure and components over time, we do not believe that a guideline to retain all presettlement 

trees is sustainable for all areas forestwide. Projects may include such design features, where 

needed, to achieve and maintain the plan desired conditions and increase resiliency over time. 

Comment: None of the action alternatives contain retention guidelines that would retain old 

growth trees. At least one of the alternatives should contain a retention guideline similar to the 

Four Forest Restoration Initiative that has only a few exceptions. (SC-25, SC-84, AGFD-16a) 

Response: All of the action alternatives contain guidance for retaining “old growth” trees. 

Guidance not to remove large or old trees can be found in the “Guidelines for Vegetation 

Management in All Forested Communities” in the plan. The guidelines provide direction to leave 

logs, snags, and large, old trees. It states that the projects “should generally retain at least 

historic frequencies of trees by species across broad age and diameter classes at the mid-scale. As 

such, the largest and oldest trees are usually retained.” Appendix C in the plan specifies the 

structural characteristics associated with mature and over-mature trees that are addressed in the 

revised plan’s tree retention guideline. Alternatives C and D contain a guideline that would not 

cut trees with physical characteristics indicating they were established prior to 1890. These 

alternative retention guidelines were evaluated and compared in the EIS.

Comment: The old growth tree retention in the plan should be consistent with the Four Forest 

Restoration Initiative. (SC-84)

Response: The revised plan guidelines provide direction that sets outer bounds and are intended 

to be broader than what might be needed for site-specific projects. This allows for flexibility for 

projects to be more restrictive, when needed, to effectively make progress toward the desired 

conditions. Because 4FRI is a project that fits within the bounds of the plan guidance, 4FRI is 

consistent with the plan. 

Comment: The tree retention guideline should include Thomson Age-class 3 (intermediatemature), which includes trees approximately 150 years and older. (AGFD-16b)

346 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: In areas where there is a deficit of mature and intermediate-mature trees, Thomson 

Age-class 3 trees would typically be retained. This is provided for with the vegetation guideline 

that would “retain trees by species across broad age and diameter classes.” Retaining all 

Thomson Age-class 3 trees on all projects could leave some areas more susceptible to fire, 

insects, and drought, and could impede achievement of desired uneven-aged forest conditions in 

many locations. 

Comment: We support a diversity of structural stages across the landscape with the intent of 

providing for old growth over time; however, the creation of regeneration openings is often used 

as an excuse to log old growth and large diameter trees. The EIS should specify the percentage of 

regeneration acres to occur and how these impact forest canopy. (SC-31)

Response: The EIS did not calculate a percentage of possible regeneration cuts that would occur, 

but it does assume that the plan would be implemented. The revised plan says that mechanical 

thinning would be conducted on up to 19,000 acres per year in ponderosa pine and 2,100 acres of 

the frequent-fire mixed conifer areas per year, and that there would be a relatively even 

distribution of size classes. The EIS modeled mechanical treatments on suitable timberlands. 

Assuming about a 30-year cutting cycle and a balance of age and size classes, including older 

trees (180 years of age and greater it would be desirable for up to approximately one-sixth of the 

treed areas to be in young tree, grass, forb, shrub state (regeneration areas with low canopy 

cover). Group selection cuts for the purpose of regeneration would occur where needed following 

site specific analysis to move toward desired conditions in areas where the youngest size classes 

are underrepresented. 

Comment: The DEIS states that the protection of existing old growth and management that 

provides for future old growth were two of the significant issues that drove the development of 

the alternatives, but none of the alternatives as currently written appear to meet this need. The 

DEIS states that both alternatives C and D were developed to address this issue because the 

prescriptions call for cutting a significant number of old growth trees. (SC-83)

Response: Alternatives C and D have a guideline that would not cut trees with physical 

characteristics typical of those established prior to 1890. This tree retention guideline was 

developed to respond to specific comments made by the commenter. The VDDT state and 

transition model used a 16-inch-diameter cap to represent trees established prior to 1890 and 

display the relative differences among alternatives over the long term. Under alternatives C and 

D, the guideline would be implemented as described, based on structural characteristics typical 

of presettlement trees, regardless of size. There are no prescriptions in the plan; prescriptions are 

developed at the project level following site-specific planning in accordance with the National 

Environmental Policy Act (NEPA). The plan does not call for cutting any “old growth” trees, but 

it would allow it doing so was within the plan guidelines and would make progress toward the 

desired conditions.

Comment: The DEIS states that alternative C was developed in response to the issue that “the 

proposed plan does not adequately protect existing and provide for future old growth.” 

Alternative C would change the draft plan definition of old growth and management guidelines 

based on age and structural characteristics, but the DEIS narrows the definition to trees generally 

larger than 16 inches d.b.h. Old growth should be described as a function of age not size. (SC-85)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 347
Appendix A. Response to Comments

Response: Old growth is a function of age and not size. The 16-inch d.b.h. used in the vegetation 

analysis (VDDT modeling) was a surrogate for age.. The rational for this surrogate is described 

in appendix B in the EIS section “Calibrating the PPG Model for the Kaibab NF.”

Comment: The DEIS states that alternative B has a large old tree retention guideline because 

“...these types of trees are less abundant than in reference conditions and can take more than a 

century to replace if removed.” We agree with a retention approach and the statement of scarcity. 

However, elsewhere in the document it is asserted that there has been an increase in all diameter 

classes over the last 100 years. (SC-94)

Response: Both statements are true. Historic cutting, particularly in the southern Kaibab NF, has 

resulted in fewer of the very large old trees on the landscape (e.g., greater than 30 inches). The 

first statement refers to the trees specified in the tree guideline that are currently less abundant 

than reference conditions (see appendix C of the plan or appendix K of the FEIS. The second 

statement refers to the VSS diameter classes, where the largest class is greater than 24 inches. All 

VSS size classes have seen an increase in frequency over the last 100 years. We clarified these 

statements in the FEIS.

Comment: The DEIS states that State K, best represents the desired condition in the preferred 

alternative and is described as, “Very large trees, open, multistory; 10-30% canopy closure; 20+” 

diameter class.” It is unclear what scale the desired canopy closure is achieved. (SC-95)

Response: The VDDT model and supporting data are “mid-scale.” This is described in appendix 

B of the EIS.

Comment: The alternative comparison has also been oddly constrained by the single entry before 

lands are removed from the suitable timber base contained in alternatives C and D. Alternatives C 

and D appear to have a single entry to achieve the conditions targeted in the desired conditions. 

While we understand the financial constraints the Forest Service is operating under this approach 

is not based on ecosystem needs, but economic needs. (SC-89, SC-81) Alternative C specifies that 

in the Kaibab Squirrel National Natural Landmark, mechanical thinning would be used to restore 

the desired structure and that it would then be removed from the suitable timber base, but the 

alternative description lacks specific information regarding restoration goals and the number of 

entries required to achieve those goals. (SC-87)

Response: Specific needs vary by location. Some areas may require one entry (e.g., dense areas 

currently containing all of the desired components) and others would require a minimum of two 

entries (e.g., in currently even-aged areas to achieve multiple age classes). As a result, the 

specific strategies, prescriptions, and number of needed entries to achieve desired conditions are 

determined through site-specific analysis and project-level planning. The scope of the plan 

decision is focused on the broader guidance that sets out desired conditions, objectives, 

standards, and guidelines.

Comment: The introduction states that the specific location, design, and extent of any activities 

are generally not known and the analysis only covers the potential for an effect to occur. While no 

site-specific proposal has been made, the models used specific target basal areas, openings and

group sizes to predict percent openings based on the interspersion of clumps of trees and 

openings; the abundance of understory production, and associated potential fire behavior. (SC-90)

348 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: The conditions for the effects analysis and modeling were selected based on the 

midpoint of the desired range. The plan language accurately reflects the Kaibab NF’s 

management approach regarding reference conditions. The vegetation modeling is not intended to 

reflect every treatment possibility, but to give insight into the average probable outcomes and 

provide a relative basis for comparing alternatives. 

Comment: Alternatives C and D are said to compare unfavorably with the preferred alternative 

because of the guideline to retain all presettlement trees established prior to 1890. These 

alternatives tie what we advocated for as retaining trees established in a natural fire regime into a 

diameter cap, which would not necessarily represent the historic forest structure. (SC-96)

Response: The 16-inch d.b.h. used in the vegetation analysis (VDDT modeling) was a surrogate 

for age; therefore a diameter cap was used for modeling purposes to represent trees established 

prior to 1890. Age and diameter are correlated. It is a reasonable representation, given that the 

modeling results are used to reflect the relative difference among alternatives, not exact 

outcomes. The EIS analysis describes some of the effects expected under alternatives C and D, 

regardless of the modeling limitations. These include an increased risk of uncharacteristic fires 

and reduced amount of understory production due to the guideline that would result in leaving 

higher tree densities and a lower “interspersion” of age classes due to thinning from below that 

would be needed to reduce fire risk while retaining presettlement trees. 

Comment: The Vegetation Dynamics Development Tool (VDDT) model was used to evaluate 

changes and trends in forest structure, with State K representing the large, open, multistoried state 

in the mid-scale desired conditions. Given the data that exist and the capacity of the model, the 

effects analysis should be extended to the fine spatial scale. The fact that the plan is a 

programmatic document does not remove the obligation to display that desired conditions at the 

fine spatial scale can be met. (SC-91) While the VDDT model displays the DFC (State K) midscale structural attributes, the evaluation criteria all related back to fine-scale attributes. (SC-16)

Response: VDDT modeling results are all at the mid-scale, and aggregated to the landscape 

scale. The results represented by VDDT are an aggregation of fine-scale attributes to produce a 

mid/landscape-scale projection. The effects analysis for vegetation interpolated the mid-scale 

outputs to describe the anticipated fine-scale conditions using expert opinion based on the 

prescriptions modeled and their ability to create certain desired fine-scale conditions (clumps and 

groups, interspaces, regeneration, etc.).

Comment: The DEIS states (page 301) “Alternatives C and D have a guideline that would not 

cut trees that were established prior to 1890. Due to model and data limitations (data and models 

do not have an age variable); this guideline was modeled as a 16 inch maximum diameter limit or 

diameter cap.” As a result, we are left to assume that modeling limitations were the issue? (SC98).

Response: The 16-inch d.b.h. used in the vegetation analysis (VDDT modeling) was a surrogate 

for age. The results were used for describing the relative comparison among alternatives only. 

Comment: The DEIS cites a document detailing the model development process called, “VDDT 

Analysis Process of the Kaibab National Forest” (Higgins 2011), but this document cannot be 

found on the Kaibab National Forest website or the Region 3 website. (SC-99)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 349
Appendix A. Response to Comments

Response: The document “VDDT Analysis Process of the Kaibab National Forest” (Higgins 

2011) was a preliminary process paper and was later edited for increased readability. This was 

included in appendix B in its entirety. The content was on the website, but was in the DEIS 

appendix B at http://fs.usda.gov/goto/kaibab/plan_revision It was not posted as a stand-alone 

document. We have corrected this reference in the FEIS.

Comment: A structure-oriented approach can result in the aggressive removal of too many trees 

during the initial entry, which may seriously constrain ecosystem response and management 

options. (SC-4)

Response: A structure-oriented approach is necessary to achieve the desired functional processes 

including natural disturbances and nutrient cycling. Equally of concern is removing too few trees, 

which would leave them at risk to stand-replacing wildfire and insect and disease epidemics.

Comment: Prescribed burning is a risk reduction management tool that can be used to mitigate 

the undesirable effects of wildfires. Emissions from prescribed burning are typically much lower 

than those stemming from unplanned wildfires. Therefor the Forest Service should consider and 

disclose the benefits and potential liabilities of using prescribed fire at broad spatial scales. 

(CBD-55)

Response: Emissions from prescribed fires and wildfires is discussed in the Air Quality section 

of the EIS. A comparison is made by looking at how well management activities under each 

alternative, including prescribed burning, reduce the likelihood of high-severity, high emissions 

producing fires. The potential effects that would result from implementing the action alternatives, 

which includes using prescribed fire to restore the natural fire regime, reduce fuel loads, increase

nutrient cycling, protect wildlife habitat, is discussed extensively in the Vegetation and Fire 

section of the EIS.

Comment: The forest should prioritize active fuel management where relatively little resource 

investment may facilitate ecosystem fire resilience, including low-productivity sites and relatively 

open stands dominated by large trees. (CBD-74)

Response: The revised plan does not set priorities, although it does discuss priorities in the 

management approach sections, specifically the management approach in the fire management 

section of the plan states “Examples of such areas are steep rugged terrain where the high cost 

and hazards preclude mechanical treatment, or in remote areas of the forest where the distance to 

high values does not justify the expenditure of limited funds and work capacity. Fire can be 

successfully used in these areas to treat NFS lands at the landscape scale and at a minimal cost. 

Objectives allowing for higher fire intensities and higher levels of mortality may be needed in

these areas to achieve the structural change that will not occur through other means.”

Comment: The plan and EIS should separate objectives for “Acres Treated” for by prescribed 

fire and naturally ignited wildfires. (KCC-2) 

Response: The objectives for acres treated with fire were established based on the ecological 

need to restore fire adapted ecosystems. The capacity of the Forest to implement prescribed burns 

varies yearly due to climatological conditions, budget restraints, and other limitations, and is 

unlikely to consistently occur at a rate that would meet the ecological need. To treat enough 

acres annually to approach the historic fire regime, lightning caused wildfires will need to be 

350 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

managed to perform their natural role in the ecosystem. Combining prescribed fire and wildfire in 

the objectives for ponderosa pine and mixed conifer underlines that it is not the ignition source, 

be it drip torch or lightning, that matters in restoring fire adapted ecosystems, but rather the 

broad treatment with fire across the landscape. 

Comment: As modeled in the DEIS “ingrowth” over the planning horizon will exceed “harvest”. 

This will make it difficult to restore historic fire adapted forested ecosystems during this century. 

(KCC-3)

Response: The mechanical thinning objectives were set based on the anticipated capacity during 

the plan period. While additional capacity would move the forest more quickly towards restored 

conditions, modeling shows that the projected capacity still makes progress toward the desired 

conditions. Additionally, some mortality and volume loss is expected that is not accounted for in 

the harvest when fire is combined with mechanical harvests. 

Comment: The draft plan indicates that it proposes to thin 11,000 - 19,000 acres per year on the 

NKRD. Considering the Forest Service’s present "capacity”, which is limited by appeals and 

budget, one wonders whether this can be accomplished. (KCC-5)

Response: The objective applies to the entire Kaibab NF, not just the North Kaibab. While we 

hope to significantly increase acres treated on the North Kaibab, a lot of the acres treated would 

likely be accomplished on the Williams and Tusayan Districts through the Four Forest 

Restoration Initiative. Objectives are based on levels that we believe are achievable given current 

budgets and capacity. 

Comment: The objectives for prescribed and naturally ignited fire should be consistent with the 

fire return interval for forest and woodland types. The current objectives are less than half of what 

they should be. (MK-1)

Response: We are aware that the objectives in the plan would not attain the historic fire return 

interval across the Kaibab NF in the “plan period,” which is the next 10 to 15 years. The 

objectives were set at a level that is possible to accomplish given the current high-risk state of the 

Kaibab NF, capacity to do the work, and public tolerances for smoke. As the forest structure and 

fuel loading approach the desired conditions, the fire return interval will also be closer to the 

desired (historic) condition, fire interval, but this may not happen for many years beyond the plan 

period. 

Comment: The plan should not implement widespread, high-severity treatments in the absence 

of a formal peer review process. A variety of treatments are needed to spread the risk because a 

one-size-fits-all approach to forest management is inappropriate. (WILD-1)

Response: The planned restoration treatments modeled in the action alternatives are not 

considered “high-severity” in the peer-reviewed literature. For modeling purposes, one or two 

thinning or regeneration prescriptions were included and each may be applied with highly 

variable intensities that would be determined at the project level. The desired conditions for 

ponderosa pine and frequent-fire mixed conifer forest include wide variation on both fine-scale 

and mid-scale densities (Desired Conditions in Forest Resources section, chapter 2 of the plan). 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 351
Appendix A. Response to Comments

Comment: The forest should develop forest management standards and guidelines calling for the 

analysis of spatial dimensions of fuel treatments.(CBD-73)

Response: The plan contains guidelines stating that “The location and layout of vegetation 

management activities should effectively disconnect large expanses of continuous predicted active 

crown fire” and “vegetation management prescriptions should provide for sufficient canopy 

breaks to limit crown fire spread between groups, allow for the redevelopment and maintenance 

of a robust understory, and mimic the spatial arrangement of the reference conditions.” This 

would necessarily call for the analysis of spatial arrangement during project design and be 

analyzed as part of the effects analysis for fuel treatment and restoration projects. Additionally, 

several questions in the forestwide monitoring plan also help to ensure effectiveness of these 

guidelines. Specifying the need for analysis would reiterate existing policy required by NEPA. 

Comment: Actively thinning small trees and intermediate-sized trees would retain most of the 

carbon pool levels, reduce potential wildfire emissions, and favor the development of large fire 

resistant trees which would better stabilize carbon stocks. (CBD-61)

Response: While mechanical treatments typically focus on thinning the small and intermediatesized trees to restore the desired uneven-aged desired conditions, over time it can reduce the 

representation of the desired younger age cohorts. Plan solutions to address carbon stocks 

include a combination of protecting the large trees from wildfire, opening up canopies to increase 

growth and sequestration rates, and encouraging a wood products industry that produces durable 

goods that store carbon over the long term. Huang et al. (2013) found that carbon storage 

increased in above-ground and below-ground residual live trees over time under thinning and 

prescribed burning treatments. Additionally, they showed that carbon stored in live trees over one 

century at all the five study sites was higher for two prescribed burning scenarios (prescribed fire 

every 10 years and prescribed fire every 20 years) compared with no treatments under two 

wildfire scenarios (wildfire return interval of 50 years versus wildfire return interval of 100 

years). Hurteau and North (2009) suggest that a low-density forest, dominated by large, fireresistant pines, may be a desired stand structure for stabilizing tree-based C stocks in wildfireprone forests.

Comment: Not only should vegetative characteristics fall within the desired range, but there 

should be full representation of conditions along the desired spectrum. (AGFD-14)

Response: This was the intent, but to make it more clear, we added language to chapter 1 stating 

“Where desired conditions specify a range, the full spectrum of values within that range is 

desirable, although the desired distribution may vary depending on the resource.”

Comment: At a minimum, the forest should clearly outline when and why management would 

deviate from the “should generally” retain recommendation. (AGFD-17)

Response: This comment refers to this guideline for vegetation management in all forested 

communities:

“Projects in forested communities that change stand structure should generally 

retain at least historic frequencies of trees by species across broad age and 

diameter classes at the mid-scale. As such, the largest and oldest trees are 

usually retained.”

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Appendix A. Response to Comments

Interdisciplinary and leadership teams discussed striking the word “generally” from this 

guideline. If exceptions are made, the deviation would need to be specified in the decision 

documents. Although the intent is to retain these components when possible, a few exceptions 

would likely be needed in most projects to meet logistical and safety requirements and in some 

cases to facilitate moving existing forest conditions towards desired conditions. 

Comment: The guidelines say that projects should retain historic frequencies of tree species, 

across broad age and diameter classes, but stops short by stating that the old trees to be retained 

should be large. (SC-29)

Response: In addition to the guideline referenced above that states that “ the largest and oldest 

trees are usually retained,” there is also a guideline that specifies “treatment prescriptions 

should generally not remove: Large, old ponderosa pine trees with reddish-yellow, wide platy 

bark, flattened tops, with moderate to full crowns and large drooping or gnarled limbs” (e.g., 

Thomson’s age class 4, Dunning’s tree class 5 and/or Keen’s tree class 4, A and B [appendix C]).

Comment: The desired conditions should ensure that all tree species are being retained. (AGFD11)

Response: The plan contains a guideline that addresses this concern. It states “Projects in 

forested communities that change stand structure should generally retain at least historic 

frequencies of trees by species across broad age and diameter classes at the mid-scale.” This 

guideline specified to “retain historic frequencies by species.” The desired conditions provide 

more specific guidance by PNVT. There are some PNVTs, such as cottonwood-willow riparian, 

where there are nonnative tree species such as Russian olive and tamarisk that should NOT be 

retained. 

Comment: Some concern that the costs of creating even-aged conditions outweigh the benefits 

for wildlife. (AGFD-8)

Response: Chapter 1 of the plan states, “These desired conditions are integrated and are 

intended to reflect not only healthy ecological systems, but also the social and economic 

considerations needed for long-term sustainability.” The desired conditions for most of the 

Kaibab NF are uneven-aged. Decisions about where even-aged forest structure may be desirable 

to create or retain are project-level decisions.

Comment: The plan should manage for Gambel oak, not only where it occurred historically, but 

also where it may grow within its natural range on the Williams Ranger District. (DOI-2)

Response: The desired conditions were developed to reflect conditions within the natural range of 

variability. Oak is recognized in the plan as an important and dynamic habitat component and 

there is no plan direction that would prevent an expansion within its natural range. However, oak 

species occur within specific biophysical site conditions (plant associations). It would be 

inappropriate to manage for oaks where biophysical conditions are not conducive and where they 

did not historically occur. Consistent with the concepts of ecological sustainability and 

restoration, there is no desire for oak to occur in areas where it did not occur historically.

Comment: Tree-form Gambel oak occurs, but in the area, not just as snags or partial snags. 

Therefore, we recommend modifying the desired condition to include the desire for larger, treeform oaks. (DOI-3)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 353
Appendix A. Response to Comments

Response: The words “tree-form oaks” was added to the ponderosa pine desired conditions and 

to the guideline for wildland fire management. 

Comment: The vegetation management guidelines in the plan should include provisions for 

retaining large oaks. (AGFD-19)

Response: We concur. In response to this comment, we modified the guideline to add “Gambel 

oak greater than 8 inches diameter at root collar” to the list of trees that should generally not be 

removed.

Comment: The Forest Service should not drop the standards related to goshawk nest areas, postfledgling family areas (PFA), and foraging areas. The structural requirements in the MRNG 

related to nest areas, PFAs, and foraging areas are described in terms of stand structures that 

occur across 30 acres for nest areas, 420 acres for PFAs, and 5,400 acres for foraging areas. 

Additional desired conditions for each forest type are also described in terms of stand 

characteristics. The draft plan and DEIS appear to have dropped this approach in favor of creating 

small groups surrounded by a high percentage of openings. (SC-73) The draft plan omits 

standards and most guidelines for management of ponderosa pine and its structural attributes 

contributing to nesting, fledging, and foraging habitat of the northern goshawk, retaining a few 

guidelines that says that they “should” consider. (CBD-49)

Response: The revised plan does incorporate provisions of the “Management Recommendations 

for the Northern Goshawk” (RM-217) but not its exact language. There are guidelines for 

establishing nest areas and PFAs, and limiting human disturbance during the breeding season. 

The vegetation management guidelines also include provisions for retaining large, old ponderosa 

pine trees, mature trees with large dwarf mistletoe induced witches’ broom, large snags, partial 

snags, and trees (>18 inches d.b.h.) with broken tops, cavities, and Gambel oaks greater than 8 

inches d.r.c. They also state that: projects “should generally retain at least historic frequencies of 

trees by species across broad age and diameter classes at the mid-scale. As such, the largest and 

oldest trees are usually retained.” The desired conditions state that: “The mosaic of tree groups 

generally comprises an uneven-aged forest with all age classes and structural stages present.” 

“Tree groups are made up of clumps of various age classes and size classes that typically occur 

in areas less than one acre, but may be larger, such as on north-facing slopes.” “Crowns of trees 

within the mid-aged to old groups are interlocking or nearly interlocking and consist of 

approximately 2 to 40 trees per group.” “Forest conditions in some areas contain 10 to 20 

percent higher basal area in mid-aged to old tree groups than in the general forest (e.g., goshawk 

post-fledging family areas, nesting/roosting habitat, drainages, and steep north-facing slopes). 

They state that “goshawk nest areas are multi-aged forests dominated by large trees with 

interlocking crowns and are generally denser than the surrounding forest.” The desired 

conditions also describe numbers and sizes of key habitat components such as snags and logs for 

each PNVT. These and other plan components were developed to meet vegetation descriptions 

within the MRNG and provide for viability of the northern goshawk and its prey (see: Desired 

Conditions for Use in Forest Planning in the Southwestern Region: Development and Science 

Basis Updated: August 2013). 

Some of the more prescriptive provisions of the original forest plan (as amended) including 

canopy cover and vegetation structural stage (VSS) distribution were not retained for several 

reasons. The guidelines in the original forest plan (as amended) provided guidance intended to 

establish and maintain uneven-aged conditions over time. However, some literal interpretations 

354 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

of the guidelines left some areas much denser than desired and did not provide for adequate 

interspace between groups. This was in part due to the fact that the original plan as amended was 

vague regarding the scale at which canopy cover and VSS would be measured. 

Interspaces contribute to a wide range of other desired conditions including increased water 

availability, reduced competition, reduced potential for stand replacing fire, increased understory 

vigor and diversity, increased snowpack, and food and habitat for small mammals. The guidelines 

for canopy cover and vegetation structural stage (VSS) also proved to be difficult to measure and 

implement consistently. The prescribed distribution of VSS classes in the original plan (as 

amended) was developed to provide for uneven-aged conditions over time through recruitment 

and growth. The current plan also provides for uneven aged condition over time, but better 

reflects natural variation that occurs following periodic regeneration events typical of 

southwestern forest ecosystems. 

Comment: The effects analysis should disclose the differences in estimated canopy cover 

between the current management and the proposed plan. (SC-77)

Response: The EIS does not disclose the differences in estimated canopy cover between the 

revised plan and the original plan (as amended) because the methodologies for measuring 

canopy cover result in wide variation. To provide this analysis and disclosure, it would first be 

necessary to specify the scale, whether the metric was for total land area or across groups of 

mature trees, and methodology (vertical projection on a line transect, remote imagery, FVS, 

densitometer, etc.) Additionally, due to the spatial nature of canopy cover measurements; there is 

no reliable methodology for modeling forest canopy cover under differing plan alternatives. 

For these reasons, the revised forest plan generally uses basal area to describe the desired 

condition for tree density rather than canopy cover. The original plan contained language that 

addressed average percent canopy cover to specify tree density for goshawk habitat. The original 

plan was vague as to precisely how canopy cover would be measured and at what scale canopy 

cover would be measured. This lack of clarity led to misunderstandings of the recommended 

means for measuring canopy cover. The methodology for measuring basal area is more 

consistent than canopy cover. It is also more easily determined on the ground during project 

implementation. Basal area is more easily understood by a greater number of people so that 

there is a better understanding of what the plan is attempting to achieve. The revised plan also 

more clearly defines the scale that desired basal areas are applied to. Desired conditions for tree 

densities expressed as basal areas in the revised forest plan provide for goshawk habitat needs 

and would sustain goshawk population viability (Reynolds et al, 2013). It was not necessary to 

relate tree densities directly to canopy cover in the revised forest plan.

Mixed Conifer Forests

Comment: It appears the intention of the plan is to manage most mixed conifer forest on the 

Kaibab NF in a more open, ponderosa pine-dominated condition. (DOI-5)

Response: Historically, most of the mixed conifer on the Kaibab NF was more open and 

contained at least a plurality of ponderosa pine. The desired conditions of the frequent-fire mixed 

conifer PNVT are within its natural range of variability and more consistent with frequent-fire 

disturbance regimes. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 355
Appendix A. Response to Comments

Comment: The desired conditions should support smaller openings and larger tree groups within 

mixed conifer to accommodate the habitat requirements of species dependent on denser 

conditions. (AGFD-10)

Response: While disturbances like root rot and wind throw, did historically create small openings 

in mixed conifer, the historic fire regimes more typically resulted in groups and openings being 

similar in size. Species that evolved with these systems should be accommodated by providing 

habitat within its historical range of variability. If there are situations where are specific 

concerns, the desired conditions are broad enough to permit larger tree groups in project design 

to meet site-specific objectives.

Comment: The draft plan acknowledges the lack of agreement on treatment intensity and 

approaches for frequent-fire mixed conifer, and plans to use experimental design features and 

monitoring to accelerate learning and adaptive management, but adaptive management is not a 

substitute for creating a science-based panel from outside of the agency to address the issues of 

restoration in mixed conifer and spruce-fir. Before moving forward with treatments in mixed 

conifer, the Forest Service should create a science panel with broad representation from outside 

the agency to address the research needs of the agency. (SC-26, SC-32)

Response: The plan desired conditions, objectives, and guidelines were based on research and 

management experience in the Southwest, including recent research on the Kaibab Plateau, that 

describe historic conditions and trends and restoration approaches for both mixed conifer and 

spruce-fir forests. We formulated regionally consistent desired conditions with consideration of 

this research and experience. 

The Kaibab NF did host collaborative workshops with a variety of experts and stakeholders to 

develop plan components for mixed conifer. Based upon this process and a lack of agreement 

about the optimal treatment intensity and design, a guideline was developed to use an adaptive 

experimental approach to increase learning and build trust. This was described in the 

management approach sections for frequent-fire mixed conifer and mesic mixed conifer/spruce-fir 

in the plan. Creating a science panel to address research needs of the agency is outside the scope 

of the plan decision, but could be explored during plan implementation.

Comment: The plan should provide more information regarding how mesic mixed conifer forest 

will be maintained. (DOI-4)

Response: There are no objectives for mesic mixed conifer, and therefore, no “planned” 

activities. Should a project be proposed to address needs for change in a particular area, it would 

be developed to move toward the desired conditions within the standards and guidelines for 

vegetation management articulated in the plan. The proposed activities would be planned to 

address the site-specific needs.

Comment: The reference in the draft plan and EIS to cork-bark fir on the North Kaibab Ranger 

District is an error on the North Kaibab Ranger District in the wet mixed conifer. It should be 

subalpine fir. (KCC -6)

Response: We agree that subalpine fir is the more accurate term. This change is reflected in the 

final plan.

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Aspen

Comment: The plan and DEIS should include more detail about the historical acres of aspen as 

well as some indication about the amount of aspen needed for long-term sustainability. (RE-18)

Response: Objectives and guidelines have been established to address concerns over aspen 

decline on the Williams and Tusayan Ranger Districts. The available research and data suggest 

aspen is stable to increasing on the North Kaibab Ranger District, declining on the Williams 

Ranger District, and minimal on the Tusayan Ranger District with no historic references. The 

available research for aspen on the Kaibab NF does not include historical acreage, although 

historical descriptions indicate it was not known to occur in large contiguous patches anywhere 

on the forest. Condition rather than amount is a better indicator of long-term sustainability of 

aspen.

Comment: As written, the desired condition for aspen that states “coniferous species comprise 

less than 10 percent of the overstory” would support logging of the remaining ponderosa pine in 

the old seed cuts on the North Kaibab Ranger District where aspen has regenerated along logging 

roads and skid trails. (SC-28)

Response: In response to this comment, we adjusted the desired condition to specify that the 

desire is that coniferous species do not shade and out-compete with aspen on the Williams and 

Tusayan Ranger Districts where it is of concern. The desired condition now reads “Within aspen 

stands, coniferous species comprise less than 10 percent of the overstory on the Tusayan and 

Williams Districts.” It also makes clear that there is not a desire to reduce the coniferous 

overstory on the North Kaibab Ranger District where past management activities have resulted in 

aspen occupying areas they may not have historically. 

Comment: In the comparison of alternatives table in the DEIS chapter 2, there should be a row 

for aspen management for the Williams and Tusayan districts. (LS-20)

Response: There was a row for aspen management in table 1 of the EIS, but we added language 

to clarify that the objectives were developed for the Williams and Tusayan Ranger Districts, 

where aspen decline is a concern. 

Comment: The list of potential aspen treatment options should be expanded to include fire, 

coppice treatments, jackstrawing, and ripping, and planting. (AGFD-13, WILD-6)

Response: In response to this comment, we expanded the management approach for aspen: 

“Other strategies to promote aspen such as jackstrawing, fire, coppice treatments, ripping, 

planting, public education, and improving the forage and browse in the surrounding area to 

diffuse browse pressure on aspen may be used.”

Comment: Browsing on aspen is not limited to elk, suggest that the word “elk” be replaced with 

changed to “wild ungulate” and “livestock grazing.” (AGFD-12)

Response: We adjusted the wording to read “ungulate.”

Comment: The plan should not allow grazing by domestic livestock in areas with aspen and 

wetlands. (RE-19, SC-58)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 357
Appendix A. Response to Comments

Response: Many aspen and wetland areas have already been fenced to exclude livestock, and 

more will be protected and restored through implementation of the objectives that would fence or 

restore aspen, springs, and wetlands at specified levels. Areas with site-specific resource concerns 

are prioritized. Additionally, a guideline for newly constructed waters says they should be located 

in areas that would reduce ungulate impacts to aspen and wetlands. By using these strategies, the 

Kaibab NF should be able to protect these important resources while providing for continued 

livestock grazing. 

Comment: The guidelines indicate that the plan will not do anything to protect aspen until 

grazing NEPA is done which could be more than 10 years away. (EBR-36)

Response: This statement is inaccurate. The objectives for aspen are independent of the livestock 

grazing guidelines. Aspen protection and restoration has been and will continue to be addressed 

as a stand-alone need. Where there are site-specific concerns related to livestock grazing, they 

may be addressed in the annual operating instructions and throughout the season. 

Standards and Guidelines for Vegetation 

Management in All Forested Communities

Comment: The standards and guidelines do not assure meeting the minimum management 

requirements (EBR-6). The 1982 planning regulations include mandatory “management 

requirements” including limits on the maximum size of management created openings and stream 

side buffers. If any of these standards are eliminated or changed, they must be fully analyzed in 

the EIS. (CBD-44)

Response: The Standards for Vegetation Management in All Forested Communities states the 

“maximum size opening that may be created in one harvest operation for the purpose of creating 

an even-aged stand shall not exceed 40 acres except when it is following a large-scale 

disturbance event such as a stand-replacing fire, wind storm, or insect or disease outbreak.” This 

is unchanged from the current plan.

There are no standards for “streamside” buffers because the only perennial streams on the 

Kaibab NF are within the Saddle Mountain and Kanab Creek Wildernesses, which have desired 

conditions that maintain wilderness values, have no suitable timber, and do not allow motorized 

or mechanized equipment, and Forest Service Handbook and Manual direction that provide 

higher levels of protection. 

The minimum management requirements specified in the 1982 planning regulations were 

addressed by the proposed plan and alternatives. Key minimum management requirements are in 

the vegetation management standards and guidelines, and some are addressed in the form of 

desired conditions. The EIS analyzes these alternatives.

Comment: The Forest Service should resolutely prohibit seeding with any species or stock other 

than those that are known to occur within 50 miles of the forest. (LS-15, WILD-16) “Genetically 

local sources” of seed can be difficult to procure. Consider the use of native seed sources from a 

regionally adapted area if local sources are not available. (AGFD-20) If seeding of understory 

vegetation is planned, will the Forest Service use native species? (SC-36)

Response: While it is preferred to obtain seed from more local sources, it is often not available. 

There are currently too few seed sources within 50 miles of the Kaibab NF to meet the 

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revegetation needs. We modified this guideline slightly to address the primary concern. It now 

reads “Seed and plants used for revegetation should originate from the same PNVT and general 

ecoregion (i.e., southern Colorado Plateau) as the project area.”

Comment: There should be guidelines in other vegetation types for minimizing the spread of 

cheatgrass similar to those written for sagebrush. (AGFD-5) The plan should include direction for 

minimizing spread and new infestations of cheatgrass. (AGFD-24)

Response: The guideline was originally listed in vegetation management for sagebrush 

communities as, “In areas with moderate to high risk of cheatgrass invasion, fire should be 

excluded if adequate treatments are not available or if they are cost prohibitive.” In response to 

this comment, it was moved to the Wildland Fire section of the plan, and it now applies 

forestwide. It now reads, “Evaluate the risk of cheatgrass invasion. When there is a moderate to 

high risk of cheatgrass invasion, mitigation measures should be developed. If adequate treatments 

are not available, or if they are cost-prohibitive, objectives to minimize the burned area should be 

developed.” An additional guideline under nonnative invasive species specifies that “all grounddisturbing projects should assess the risk of noxious weed invasion and incorporate measures to 

minimize the potential for the spread of noxious and invasive species.”

Large-scale Disturbance Events in Forest and 

Woodland Communities

Comment: Areas affected by severe fire should be managed for natural recovery, not economic 

production. (CBD-9)

Response: Plan guidelines for large-scale disturbance events primarily focus on restoring the 

land to meet desired conditions in the plan. The desired conditions are integrated and are 

intended to reflect healthy ecological systems as well as social and economic considerations as 

described in chapter 1 of the plan. The desired conditions for forest and woodland communities 

would not change after large-scale disturbances, including severe fire. Guidelines were developed 

to assist in attaining desired conditions in areas affected by large-scale disturbance, should a 

site-specific proposal be made following the disturbance.

Comment: The EIS for plan revision must not equate post-fire logging with ecological 

restoration. (CBD-72)

Response: We agree that salvage logging does not equate with ecological restoration; however, 

the FEIS vegetation and soil and watershed sections discuss that it can be a tool for achieving 

certain restoration objectives and desired conditions.

Comment: Salvage logging should not be used unless it can be proven that it will not inhibit 

natural recovery or regeneration, increase nonnative invasive species, and/or increase soil 

compaction or erosion. (AGFD-21) 

Response: Salvage logging is an appropriate tool under certain circumstances. Site-specific 

decisions would specify the appropriate management response following large-scale disturbances 

after we evaluate the risks and benefits of any proposed activities including salvage logging. 

Comment: Planting trees in mixed conifer areas should not be done in areas that may have had a 

fire regime that included some naturally occurring stand-replacing fire. (AGFD-22)

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Response: In most cases, this is already true as the desire is to manage similar to the historic or 

natural fire regime. However, the Kaibab NF reserves the flexibility to plant trees to accelerate 

achieving tree cover where it is lost due to uncharacteristic fire and distant seed sources. 

Comment: When planting trees, the resulting structure should mimic historic conditions, i.e., 

plantings should be arranged to achieve a heterogeneous structure, or later be thinned to a more 

natural forest structure. (AGFD-23)

Response: Agreed. Because projects are to be consistent with the desired conditions in the plan, 

project-level design for planting would incorporate design features to reflect the fine-scale 

heterogeneous desired conditions.

Sagebrush Shrublands

Comment: The plan says sagebrush provides important habitat, but the guideline says that 

sagebrush must be severely degraded before any steps are taken. (EBR-16)

Response: We deleted the word “severely.” The guideline now reads “Where sagebrush 

communities are severely degraded, water should be strategically placed to improve animal 

distribution and reduce grazing impacts.”

Grassland Communities

Comment: The plan states that part of its strategy for restoring grasslands is to make a map of 

where they used to occur. It is unacceptable not to already have a map about an issue that is 

identified as a priority need for change. (EBR-25)

Response: The Kaibab NF has Terrestrial Ecosystem Survey (TES) maps that show the grassland 

PNVT, and historic maps for many areas. From these, we have a good understanding of the 

approximate locations and extent of historic grasslands. However, delineations are needed for 

project-specific designs that take into account evidences of presettlement trees and soils at a finer 

scale.

Comment: Desired Conditions for Colorado Plateau/Great Basin grasslands and semi-desert 

grasslands should include native plant dominance. (SC-40)

Response: The desire for native plant dominance is already specified in the Desired Conditions 

for All Grasslands section where it states “Vegetation is dominated by herbaceous plants 

composed of a mix of native grasses and forbs.” This desired condition applies, but is not 

repeated in each of the grassland types. 

Comment: The plan should include a guideline that states “Where historically occurring, 

grassland patches should be maintained by removing encroaching juniper.” (AGFD-3)

Response: This concern had already been addressed with an objective rather than a guideline. 

Needed management actions are addressed with objectives; guidelines are the sideboards to those 

actions. Because the desired conditions for the vegetation communities are identified by their 

PNVT, the grassland desired conditions apply when an area falls within the grassland PNVT 

(historically grassland) regardless of whether the area is currently encroached with trees. The 

objectives for grasslands would remove trees to restore 5,000 to 10,000 acres of historic 

grasslands annually.

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Desert Communities

Comment: In the desert communities’ desired conditions, the plan language should be changed 

from “Domestic livestock are absent.” to say, “Domestic livestock and nonnative ungulates are 

absent.” (SC-42)

Response: This guideline states “domestic livestock are absent, except for recreation and 

administrative packing and riding animals.” This guideline was intended to reflect the fact that 

the desert communities (which all occur in the Kanab Creek Wilderness) were identified as 

unsuitable for grazing following site-specific analysis. We did not include “non-native ungulates 

are absent” because there are times when it is desirable to have ungulate pack animals in the 

wilderness.

Comment: “Native ungulates free from disease and domestic livestock are absent” seems out of

place within a vegetation community discussion. (AGFD-25)

Response: We added language to the plan to be more explicit that the concern is related to the 

potential for the spread of disease between bighorn sheep and domestic sheep and goats. We split 

the desired condition into two statements which now read “native ungulates are free from 

disease” and “livestock are absent, except for recreation and administrative packing animals.” 

Additionally, we added a guideline to the livestock grazing section: “grazing of domestic sheep 

and goats should not be authorized on the Tusayan and North Kaibab Ranger Districts due to the 

proximity of bighorn sheep in the Grand Canyon and Kanab Creek to prevent the spread of 

disease between domestic and wild populations.” 

Wetland/Cienega

Comment: Desired conditions for wetlands/cienegas should indicate that they be dominated by 

“native” plants. (SC-43a)

Response: The word “native” was added to the desired condition. It now reads “Native plant and 

animal species that require wetland habitats...”

Comment: Desired conditions for wetlands/cienegas should indicate that nonnative ungulates are 

absent. (SC-43b)

Response: Many wetlands are already fenced to exclude livestock and there are objectives to 

protect and restore six additional acres within five years of plan approval. While there is a 

desired condition for wetland habitats to be healthy within the constraints of the particular 

wetland community, there is not a desire to exclude all nonnative ungulates. As a result, the 

suggestion that the desired condition state “nonnative species are absent” was not incorporated. 

Cottonwood-Willow Riparian Forest

Comment: The cottonwood-willow riparian section should say “dominated by deciduous 

species,” not “predominantly composed of deciduous species.” (SC-44)

Response: The statement referenced is in the introduction section, which describes the vegetation 

type and existing condition, not the desired condition. The suggested language was not 

incorporated because it would not be accurate. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 361
Appendix A. Response to Comments

Comment: In the description for cottonwood-willow riparian forest it says “This vegetation type 

is found adjacent to surface water, such as streams and springs” it should also say “and in places 

where shallow ground water is consistently available.” (SC-45)

Response: We added the suggested language to the description of the vegetation type.

Comment: The desired condition Cottonwood-Willow Riparian Forest the statement “Vegetation 

is characterized by willow and other herbaceous understory species. Snag and gallery tree 

components comprise 55 percent mid-aged to mature cottonwood and willow trees, 25 percent 

younger trees and 20 percent in grass, shrubs, suckers, seedlings, and tree sprouts,” should also 

include “forbs.” (SC-46)

Response: We added the word “forbs” to the desired condition statement.

Comment: The Plan should have maintained the standard that "three age-classes of woody 

debris be maintained along streambanks. (EBR-3)

Response: Standards are intended to put sideboards on activities. On the Kaibab NF, the only 

streams are within designated wilderness. The wilderness designation puts significant limitations 

on vegetation management activities that affect woody debris levels. In the revised plan, this 

standard has been addressed more appropriately through desired conditions “Stream channel 

stability and aquatic habitats retain their inherent resilience to disturbances and climate 

fluctuations. Stream channel morphology reflects changes in the hydrological balance, runoff, 

and sediment supply appropriate to the landscape setting,” and “the necessary physical and 

biological components, including cover, forage, water, microclimate, and nesting/breeding 

habitat, provide habitat for a diverse community of plant and wildlife species.

Comment: The desired condition that states “When nonnative vegetation is present ...” should 

not be a desired condition. It is understood that the forest is likely referring to tamarisk here, but it 

currently reads as if “nonnative” vegetation is a goal. The desired conditions for cottonwoodwillow riparian forest (draft plan p. 37) should state that the area is “Dominated by native 

vegetation.” (AGFD-26, SC-47)

Response: “Native vegetation dominates” was added to the desired condition, so it now reads 

“Native vegetation dominates, but when nonnative vegetation is present, the spatial and 

structural composition contributes to overall faunal diversity.”

Comment: The desired conditions for cottonwood-willow riparian forest (draft plan p. 37) should 

add the desired condition “Soils and water are free from pollution that derives from mining 

activities.” (SC-49)

Response: To address this concern, we added a desired condition to the revised plan in the soil 

section that states “Soils are free from anthropogenic contaminants that could alter ecosystem 

integrity or affect public health.”

Comment: The Desired Conditions for Cottonwood-Willow Riparian Forest (Draft Plan p. 37) 

should change from “Grazing from domestic ungulates is minimal or absent.” to “Grazing from 

domestic and nonnative ungulates is absent.” (SC-48)

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Response: This suggestion was not incorporated because all of the cottonwood-willow riparian 

forest vegetation type on the Kaibab NF is in the Kanab Creek Wilderness where horses and pack 

animals are allowed for recreational and administrative use. This area is identified in the plan as 

“unsuitable for livestock grazing” and is not part of a grazing allotment. Therefore, the word 

“minimal” is appropriate.

Comment: The management approach for cottonwood-willow riparian forest should add “Cap or 

move exposed mine waste and mine tailings that could be scattered during flood events.” (SC-50)

Response: There are no known mine waste sites on-forest or nearby that are likely to be scattered 

during flood events. Should a concern arise, it could be addressed with a site-specific proposal.

Soils and Watersheds

Comment: There is nothing in the plan to support the assertion that “Watershed conditions have 

been generally static over the last 20 years.” (SC-59)

Response: The statement about watershed conditions being generally stable comes from the sitespecific analysis and monitoring that has occurred over the past 20 years. Supporting 

documentation can be found in the project record at the Kaibab NF Supervisor’s office, and in the 

ecological sustainability report on the Kaibab NF website: 

http://fs.usda.gov/goto/kaibab/plan_revision.

Comment: There should be standards to protect soil productivity, prohibit vandalism of natural 

springs, and set limits to damage that livestock grazing may cause. (EBR-9)

Response: The plan does not include standards to address these concerns because they are 

already addressed by plan guidelines or existing law, regulation, or policy. There are guidelines 

in the Soil and Watershed section of the plan, and National Best Management Practices to protect 

soil productivity. Vandalism of springs is intentional resource damage, which is illegal and 

already addressed by the Code of Federal Regulations (CFRs). The livestock grazing guidelines 

address grazing-related resource concerns through the annual operating instructions to minimize 

and mitigate adverse effects. Guidelines in the plan are not discretionary.

Comment: The Affected Environment section of the DEIS should address the impaired and 

unsatisfactory soils in the grazing allotments. (EBR-30)

Response: The affected environment section of the Soils and Watershed Specialist Report 

discussed the impaired and unsatisfactory soils on the Kaibab NF, but it was not included in the 

more condensed version that was published in the DEIS. We have added an excerpt containing 

the key points to the soils affected environment section of the FEIS. 

Comment: On page 159 there is an enticing hint that the Forest Service intends to consider the 

impacts to biological crusts, but then reveals that it knows essentially nothing except that 

reducing livestock grazing, which it is not going to do, would help. This too needs to be honestly 

addressed and revealed. (EBR-27)

Response: The greatest risk to biological soil crusts is trampling from ungulates. The revised 

plan section for livestock grazing has a guideline that, “annual operating instructions 

should...address any relevant resource concerns.” In addition, there is a soils desired condition 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 363
Appendix A. Response to Comments

that states “biological soil crusts (mosses, lichens, algae, liverworts) are stable or increasing in 

semidesert grasslands, desert, pinyon-juniper, and sagebrush communities.” Therefore, if 

authorized grazing is not achieving or maintaining the desired conditions, management 

adjustments would be implemented. The soils and watershed section of the EIS and the 

supporting specialist report state that for all action alternatives “It is estimated that improved 

cattle management on the Kaibab NF that is currently being implemented will benefit biological 

crusts.”

The Kaibab NF does have limited information related to the presence and extent of 

cryptogrammic crusts in the House Rock Valley area of the North Kaibab Ranger District and the 

northwestern portion of the Tusayan Ranger District near the boundary with Grand Canyon 

National Park. The Kaibab NF is cooperating with Dr. Matthew Bowker, Assistant Professor of 

Forest Soils and Ecosystem Ecology at the School of Forestry, Northern Arizona University. Dr. 

Bowker’s study is aimed at gaining information necessary for developing biological crust mosses 

as restoration materials.

Comment: The Forest Service should develop stronger relationships with adjacent land 

managers. Negotiations with the towns of Kanab and Fredonia, as well as the Utah Division of 

Water Resources, are needed to ensure or restore Kanab Creek stream flow quantity, and to limit 

groundwater depletion and water pollution. Negotiation with the towns of Tusayan and Williams 

are needed to ensure groundwater sustainability on those two districts. (LS-9, WILD-23)

Response: We agree that stronger relationships and coordination with adjacent land managers, 

other agencies, and the towns of Kanab, Fredonia, Tusayan, and Williams would provide 

opportunities for improved adaptive management of natural resources, including groundwater 

resources on the Kaibab NF. The benefits and strategies of partnering are discussed in the 

management approach sections of the plan; however, this is beyond the scope of the plan 

decision.

Comment: It should be noted that several of the 28 natural lakes on the North Kaibab are 

apparently spring fed. Bear and Deer Lakes, for example, retained water on the driest years (2000 

and 2002), and likely are fed by groundwater. (LS-17, WILD-24)

Response: The Soils and Watershed Specialist Report and FEIS have been revised to reflect the 

importance of spring ecosystems as sources of surface water in natural lakes on the North Kaibab 

Ranger District. 

Comment: Some proposed activities may require Arizona Department of Environmental Quality 

(ADEQ) water quality permits or approval. (ADEQ-1)

Response: The Kaibab NF will obtain the necessary water quality permits or approvals from 

ADEQ for any activities requiring such permits or approvals prior to project implementation.

Comment: The forest plan should have standards for litter (dead vegetation that forms ground 

cover). (RE-15)

Response: Desired litter levels vary widely across the Kaibab NF depending on soil type, 

microclimate, vegetation type, etc. As a result, litter was addressed directly through desired 

conditions rather than as a standard, which only provides sideboards. The Kaibab NF uses these 

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factors along with the TES to determine appropriate litter levels for project planning and decision 

making. 

Comment: Why was the former standard to correct unsatisfactory conditions not retained? (EBR13)

Response: The revised plan does contain direction for correcting unsatisfactory soil conditions. 

Because forest plans cannot compel activities, it was not articulated as a mandate. Instead, the 

revised plan lays out a strategic framework that specifies desired conditions (desired outcomes), 

objectives (activities to achieve those objectives), and standards and guidelines, which are used 

to apply constraints on activities and uses. In the revised plan, the intent of the former standard is 

addressed through the soils desired conditions, the livestock grazing guidelines, and vegetation 

objectives for implementing mechanical thinning and fire treatments. 

Comment: Active forest management in key watersheds and riparian reserves should be 

preceded by and informed by watershed analysis. (CBD-64)

Response: Agreed. This concern was already addressed. An analysis was conducted in 2010 

through the Watershed Condition Framework, which is a national process for improving 

watershed conditions across the nation. This identified priority watersheds for restoration.

Comment: Roads contribute more sediment to streams than any other land management activity. 

Roaded and logged watersheds also feature significantly higher channel bed substrate 

embeddedness than do undeveloped watersheds. Therefore, the Forest Service should consider an 

alternative that prohibits new road construction and required road density in each fifth code 

watershed to less than 2 miles per square mile to prevent catastrophic increases in channel 

sediment. (CBD-66)

Response: An alternative was considered, but not analyzed in detail that included a road density 

standard. It was not analyzed in detail because no issues were raised that would support such an 

alternative. The Forest Service recently conducted site-specific planning covering all three ranger 

districts, which closed hundreds of miles of unneeded roads. These decisions considered a range 

of criteria including potential resource impacts, access needs, as well as public input and 

alternative views, rather than using an arbitrary road density target. The plan does provide for 

the protection and management of healthy and sustainable soils and watersheds, which are the 

primary resource concerns associated with forest roads. If undesirable resource conditions 

resulted from open roads, they could be addressed through site-specific evaluation and analysis.

Natural and Constructed Waters

Comment: The EIS should provide an analysis of ecological conditions of rivers, perennial and 

intermittent streams, wetlands and other aquatic resources. (CBD-15a)

Response: The EIS water resources section specifically addresses streams, lakes, wetlands, and 

springs. Additionally, water resources were evaluated in the CER/AMS that served as a basis for 

identifying the needs for change in the plan. These in-depth reports can be found on the Kaibab 

NF’s plan revision website at http://fs.usda.gov/goto/kaibab/plan_revision.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 365
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Comment: The Forest Service should have standards and guidelines to restore aquatic and 

riparian habitats. This is prudent and necessary given the perilous state of native fish populations 

and other aquatic organisms such as the Chiricahua leopard frog. (CBD-62)

Response: The plan contains desired conditions, objectives, and guidelines for protecting and 

restoring aquatic habitats in the Wetland/Cienega and Natural Waters sections. Point of 

information: the Kaibab NF has no populations of Chiricahua leopard frogs or native fish. 

Comment: The plan says it will protect natural waters, but there are no standards and few 

guidelines for springs, wetlands, and riparian areas to protect these areas. (EBR-17)

Response: The plan contains guidance for the protection and restoration of natural waters in the 

desired conditions, objectives, and guidelines for natural waters. These plan components were 

based on comments received about the proposed action and input from subject matter experts. 

The development of plan content for springs and wetlands was a collaborative and iterative 

process involving experts and interested parties. No issues were raised that were not addressed by 

the action alternatives.

Comment: The objectives for spring and wetland protection should be more aggressive to protect 

a minimum of 8 springs per year and at least 75 acres of wetlands per year. (RE-20)

Response: These objectives were based on levels of implementation within the capacity of the 

Kaibab NF. There is nothing to prevent the Kaibab NF from exceeding the objective if resources 

are available.

Comment: The DEIS states that 167 springs occur on the forest. As many springs in the Kanab 

Creek have yet to be mapped, this phrase should read that the forest contains 167 known springs. 

(LS-10)

Response: We adjusted the language in the FEIS and Soils and Watershed Specialist Report to 

reflect that the locations and conditions of springs are for known springs only and that there are 

likely numerous springs yet to be discovered or inventoried on the Kaibab NF.

Comment: The plan should require that diversions of water that recharge wetlands must be 

assessed within 5 years and actions taken to eliminate their effects. (RE-21)

Response: The plan does not include compulsory language as its implementation is subject to 

fluctuating budgets and changing capacity. Additionally, any “actions to eliminate effects” must 

be consistent with valid existing rights. The current water diversions on the Kaibab NF are 

associated with water rights that are outside of the plan revision decision. The plan does, 

however, include desired conditions and objectives for restoring wetlands. Restoring wetlands 

was identified as a priority need for change, and wetlands have been and will continue to be 

evaluated and restored within the capacity of the Kaibab NF.

Comment: Part of your management strategy for protecting springs is to “do an inventory.” The 

inventory should be done first, and then you should write the standards and guidelines to protect 

the springs. (EBR-26)

Response: Resource plan components stipulating the need to conduct resource inventories are 

outside the scope of the plan. However, an extensive spring inventory and comments and review 

on the plan components for springs were recently conducted through an agreement with the 

366 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
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Museum of Northern Arizona Springs Stewardship Institute. This inventory is already providing 

information that will improve springs through additional NEPA analysis work (i.e., Kane Ranch 

Allotments Environmental Assessment).

Comment: There should be an objective for protecting/restoring Kanab Creek. (LS-21)

Response: We identified objectives for the highest priority activities that are within the Kaibab 

NF’s anticipated budget over the next 10 to 15 years. Restoring Kanab Creek and the associated 

cottonwood-willow riparian vegetation communities is recognized as an important restoration 

need; however, given the Kaibab NF’s current capacity and the anticipated restoration needs of 

Kanab Creek, no specific objectives were developed. The priority needs for change and desired 

conditions in the plan would support restoration efforts as resources become available. The 

management approach specifies building capacity to do this work through partnerships. 

Comment: The DEIS states that Kanab Creek has been dewatered and that flooding disturbance 

has been eliminated. Kanab Creek remains perennial within Kaibab National Forest, as it is fed 

by several springs (e.g., Mountain Sheep Spring) that emerge in the middle reaches. (LS-8)

Response: Agreed. We modified the FEIS to reflect the perennial flow of Kanab Creek and the 

important role that spring ecosystems have in contributing to the base flow of Kanab Creek.

Additionally, language has been added to reflect that the flooding regime caused by highintensity, short-duration monsoon storms also contributes to the base flow. 

Comment: The management approach for natural waters should remove the text “desired 

nonnative plants, aquatic, and wildlife species.” (SC-54)

Response: We modified this statement, which is in the desired conditions section. The new 

language still includes “desired nonnative wildlife,” but it has been reorganized to make it 

apparent that the primary emphasis is on native species. We also added a footnote under desired 

conditions to define desired nonnative species.

Wildlife

Comment: The draft plan contains no mention of the requirement to maintain viable populations 

of fish and wildlife species. (CBD-26)

Response: The Wildlife Specialist Report describes the legal requirements to maintain viable 

populations in the introduction section of the report. Further, the plan developed specific 

components to meet the viability requirement of the NFMA and in the planning rule (36 CFR, part 

219.19). There is no requirement for the plan to restate the viability requirement of the CFR.

Comment: It is difficult to determine from the information provided what species are present on 

the Kaibab, how they were selected for risk analysis, and how the desired conditions and design 

criteria presented in the plan may affect vertebrate species or their habitats. (CBD-27)

Response: The proposed plan and EIS do not individually address all species on the Kaibab NF. 

However, a species database was developed for the plan revision effort and contains information 

on all known species likely to occur on the Kaibab NF. A coarse filter was applied to those 

species whose needs would be accounted for through desired conditions of the broad vegetation 

types. A second, fine filter was applied to those species with more specific and fine-scale habitat 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 367
Appendix A. Response to Comments

needs that could be impacted by forest management activities; plan components (e.g., standards 

and guidelines) were added as necessary. The species that went through the fine filter resulted in 

the “forest planning species” list. The forest planning species list was developed collaboratively 

by the Kaibab NF, local stakeholders and species area experts, and by consulting with scientific 

databases such as NatureServe and BISON-M, The Arizona State Wildlife Action Plan (AGFD 

2012), the Regional Forester’s Sensitive Species list, the U.S. Fish and Wildlife Service (USFWS) 

threatened, endangered list, and the Museum of Northern Arizona. The process for the coarse and 

fine-scale process for this selection is discussed in the Species Diversity Report and the Wildlife 

Specialist Report, which is available on the Kaibab NF website at 

http://fs.usda.gov/goto/kaibab/plan_revision. Appendix H of the EIS contains a crosswalk 

between species habitat risk or threats and plan components that will reduce or eliminate the 

risks. 

Comment: Our native fish are in great peril. Nonnative fish should be removed to improve native 

fish viability. (SC-53)

Response: There are no objectives to remove nonnative fish because they are not an issue of the 

Kaibab NF. A population of “nonnative” but “threatened” Apache trout was introduced to North 

Canyon Creek in the Saddle Mountain Wilderness, which has no other fish. The plan contains the 

desired condition that “a reproducing population of Apache trout is maintained in North Canyon 

Creek.” The only other nonnative fish on the Kaibab NF are stocked sport fish in man-made lakes 

that do not contain native fish.

Comment: The EIS should provide an analysis of population and habitat trends of threatened, 

endangered, proposed, sensitive, and management indicator species. (CBD-14) 

Response: Where relevant to the specific effects analysis, population and trend information is 

summarized in the existing conditions descriptions in the EIS sections that address threatened, 

endangered, and sensitive species and management indicator species, respectively. More detailed 

information can be found in the Kaibab NF Management Indicator Species (MIS) Report (2010), 

Wildlife Specialist Report, Species Diversity Report, and the CER/AMS, all of which are available 

on the Kaibab NF website at http://fs.usda.gov/goto/kaibab/plan_revision.

Comment: The Department recommends including a DC or guideline for MIS species 

specifically in the Plan in the wildlife section. (AGFD-29)

Response: MIS do not convey a special status; they are selected to assess the effects of 

management and to help evaluate differences among plan alternatives. The desired conditions for 

wildlife habitat and species viability are the same for MIS as the other native wildlife species in 

the plan. Based on the analysis done for the EIS, the revised plan (alternative B) would provide 

improved habitat conditions for all MIS species. No additional guidelines were needed to protect 

and maintain viability of these species.

Comment: There should be MIS for all ecological types, including riparian and aspen. (EBR-4, 

EBR-40) 

Response: MIS are selected to help assess the effects of management, and to compare 

alternatives. There is no legal requirement to select MIS for all ecological types. Aspen and 

368 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

natural waters were, however, selected as ecological indicators to be monitored under the 

monitoring plan. Ecological indicators differ from MIS in that there is not a specific species 

population trend that is indicative of management, but rather a suite of parameters that are 

assessed. See appendix I of the EIS for details about the decision process for selecting MIS and 

ecological indicators, and how riparian and aspen systems will be monitored. 

Comment: The plan lacks an adequate representation of MIS for several categories: the Kaibab 

NF must choose MIS that represent the following categories “where appropriate: Endangered and 

threatened plant and animal species identified on State and Federal lists for the planning area; 

species with special habitat needs that may be influenced significantly by planned management 

programs; species commonly hunted, fished, or trapped; non-game species of special interest; and 

additional plant or animal species selected because their population changes are believed to 

indicate the effects of management activities on other species of selected major biological 

communities or on water quality.” (NFMA 1982 219.19) The selection of three songbirds and one 

mammal cannot be construed to span this suite of categories, and the Kaibab NF does not 

sufficiently justify why they have not chosen more MIS. (SC-2, SC-102)

Response: The three songbirds and one mammal were selected to evaluate management effects in 

ponderosa pine, mixed conifer, and grassland habitat. These vegetation types are included under 

three of the four priority needs for change and have explicit restoration objectives. The 1982 Rule 

Provisions at section 219.19(a)(1) direct that the categories mentioned above shall be considered 

(though not necessarily included) for MIS status. MIS are selected to help assess the effects of 

management and to compare planning alternatives. It is recommended that an adequate but 

limited number of species be selected to reflect the major management issues and which can serve 

as effective metrics for monitoring the forest plan. The proposed species will help the Kaibab NF 

assess management effectiveness in those vegetation types, as described under the MIS analysis 

section of the EIS (table 18). The proposed species also allowed the Kaibab NF to assess the 

differing effects among alternatives. Also see appendix I of the EIS, Management Indicator 

Species Selection, for a detailed account of what species were or were not selected and why. 

Comment: The Kaibab did not select an MIS for stream habitats, even though that habitat 

contains an endangered species and the Kaibab forest plan (p. 40) acknowledges “Streams, 

springs, groundwater, and other natural waters are centers of high biological diversity in arid 

landscapes, and the ecological health of these resources is important for forest ecosystem 

sustainability.” (SC-103)

Response: There is no requirement to select MIS for all ecological types. MIS are selected to help 

assess the effects of management and to compare planning alternatives. It is recommended that 

an adequate but limited number of species be selected as MIS to reflect the major management 

issues. 

The Kaibab NF’s only flowing perennial stream, North Canyon Creek, occurs on the North 

Kaibab Ranger District within the Saddle Mountain Wilderness. The wilderness management 

designation limits the amount and type of management activities that could be applied to this 

area. Because there is no difference among the action alternatives for wilderness management, an 

MIS would not be necessary for comparing planning alternatives. Rather than select an MIS with 

an area of inference restricted to the Kaibab NF’s one flowing perennial stream, natural waters 

(which include streams) will be assessed by monitoring a suite of ecological parameters that are 

found under the monitoring plan for natural waters and soils and watersheds. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 369
Appendix A. Response to Comments

Beyond monitoring, the revised plan identifies desired conditions, objectives, and guidelines that 

will help to ensure habitat integrity is maintained in the Kaibab NF’s stream habitat as well as for 

all of its natural waters. These plan components can be found in appendix H of the EIS and under 

the Natural Waters, Wilderness, Vegetation Management in all Forested Communities, Large 

Scale Disturbances in Forested and Woodland Communities, and Threatened, Endangered and 

Sensitive Species sections of the plan.

Comment: Due to the importance of small mammals to the northern goshawk and Mexican 

spotted owl, the forest should include small mammals as MIS including, but not limited to 

squirrels, gophers, mice, and prairie dogs. (RE-9) The northern goshawk and Kaibab squirrel do 

not have the protection and status they had in the previous plan (LS-3). The Forest Service should 

retain the tassel-eared squirrel as a management indicator species, tassel-eared squirrels are an 

indicator of interlocking canopies. (WILD-7) The Forest Service should retain the tassel-eared 

squirrel as an MIS because they are highly associated with interlocking ponderosa pine canopies 

and are sensitive to management practices. (SC-106a) 

Response: MIS do not convey a special status; they are selected to assess the effects of 

management and to help evaluate differences among plan alternatives. Small mammals were not 

selected as MIS because they have a tremendous amount of interannual variation in their 

population levels, making it difficult to reliably estimate trends and relate those trends to 

management effects. The Kaibab NF continues to manage for healthy robust populations of 

tassel-eared squirrels and northern goshawk through the desired conditions and guidelines in the 

plan. The northern goshawk continues to be a Forest Service sensitive species and would be 

analyzed at the project level to help maintain viability of the species. The Kaibab squirrel (tasseleared squirrel subspecies) has additional protection under the National Natural Landmark 

section of the plan. Finally, we believe the best indicator for interlocking canopies are the 

canopies themselves, which are addressed though the monitoring plan. See appendix I of the EIS,

Management Indicator Species Selection, for a detailed account of what species were or were not 

selected and why. 

Comment: The existing standards and guidelines and best management practices, even if fully 

funded, are inadequate to meet statutory and regulatory requirements to provide for viable fish 

and wildlife populations that depend on aquatic habitats. (CBD-65)

Response: We developed plan content for aquatic habitats to meet the statutory and regulatory 

requirements and to address the issues that were raised during scoping and collaborative 

processes. Fish and wildlife populations that depend on aquatic habitat are provided for in the 

plan under the desired conditions, standards, and guidelines for wetland cienegas, cottonwoodwillow riparian, natural and constructed waters, soils and watersheds, wildlife, threatened, 

endangered, and sensitive species. The viability analyses showed that those species depending on 

aquatic habitats would be provided for.

Comment: The use of PNVT as a proxy for viability is subject to significant scientific 

uncertainty and the habitat-proxy approach to managing target species has rarely been tested in 

any context. (CBD-29, CBD-30). The factual presentation of the habitat-proxy approach lacks 

basic information about what species exist, what their habitat requirements are, or how 

management might affect their recovery or viability. (CBD-33)

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Appendix A. Response to Comments

Response: The coarse filter, fine filter concept for conserving biological diversity is a welldeveloped concept in scientific literature that incorporates biological and conservation science 

advances of the past three decades (Noss 1987, Haufler et al. 1996, Iverson, 2001, Shulte et al. 

2006, Zenner et al. 2010). The coarse filter, fine filter approach does not assume that PNVTs are 

a proxy for viability, nor is the viability analysis process a habitat proxy. The coarse filter looks at 

the plan components that provide for the ecosystem needs of the species. Species at risk are 

assessed against these coarse filter plan components, and where those approaches fail to provide 

a high likelihood of maintaining ecological conditions to support viable populations, fine filter 

(species-specific) plan components or strategies must be developed. The list of 68 forest planning 

species analyzed, their habitat requirements, and potential management effects on recovery or 

viability, or both are discussed in the species viability section of the EIS.

Comment: Isolated pockets of large trees would not meet the needs of canopy dependent species. 

(SC-20)

Response: The fine-scale desired conditions provide for mature trees with interlocking crowns 

consistent with the historic reference conditions, not isolated pockets. These conditions provide 

for those species that naturally occurred and evolved in these systems, see Desired Conditions for 

Use in Forest Planning in the Southwestern Region: Development and Science Basis Updated: 

August 2013.

There are many species with different canopy-related habitat needs, life history strategies, and 

behavioral adaptations. The list of 69 forest planning species includes canopy-dependent wildlife 

species such as birds, reptiles, amphibians), and small mammals. The forest plan addresses 

canopy-dependent wildlife species needs through the following wildlife desired condition: 

“Species with specific habitat needs (e.g., snags, logs, large trees, interlocking canopy, and 

cavities) are provided for.” 

Additional plan components that will provide for canopy-dependent species can be found in 

appendix H of the EIS under multilayered canopy, interlocking canopy, and old growth. The 

species viability analysis in the EIS also addresses the needs of species associated with canopy 

cover; see discussion for federally listed and sensitive species of the FEIS, and in the 

management indicator species analyses for Grace’s warbler, western bluebird, and ruby-crowned 

kinglet.

Comment: If structural stages and the associated canopy densities are measured at the group 

level, then species with contiguous canopy requirements will lose habitat. (SC-74)

Response: The plan does not specify how canopy cover is measured. Species with shade and 

closed-canopy needs were addressed through the coarse filter, /fine filter process used to develop 

plan components. The viability analysis in the FEIS assures canopy-dependent species needs are 

met (see appendix H for list of canopy-dependent species and associated plan components that 

mitigate potential management risk). 

Comment: Tassel-eared squirrels should be monitored to increase our knowledge of the state of 

this species, rather than assume a resilience that has not been demonstrated. (SC-106b)

Response: We do not have a monitoring question in the plan to specifically monitor tassel-eared 

squirrels. Monitoring plan questions try to address those key habitat components likely to affect 

numerous species, and to assess movement (progress) toward desired conditions. Monitoring plan 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 371
Appendix A. Response to Comments

questions were developed to address those areas of greatest concern, and for which the Kaibab 

NF could collect adequate monitoring data within existing funding levels. 

Comment: Table B-20 of the DEIS indicates that that the amount of pine oak habitat would 

increase under the proposed action, but there is no indication of where this would come from. 

(DOI-23)

Response: The amount of a PNVT does not change, but the VDDT states correlate to quality 

habitat. As the vegetation objectives are implemented over time, the amount of quality habitat is 

expected to increase. This is articulated in appendix B of the EIS in the wildlife section. 

Comment: The current plan has quantified standards for snags, but the proposed plan only says 

some snags “should be retained.” This change should be analyzed in the EIS. (EBR-15)

Response: Snags were analyzed as a habitat element in the wildlife viability section of the EIS. 

Rather than standards which specify snag levels, the proposed plan identifies snag levels as 

desired conditions under many of the vegetation types. For example, the Vegetation Midscale 

Desired Condition for Ponderosa Pine specifies: “snags 18 inches d.b.h. or greater average 1 to 

2 snags per acre, and in frequent fire mixed conifer they “average 3 per acre.” Snags and green 

snags of variable size and form are common.” The monitoring plan then identifies the following 

question to ensure that the appropriate snag levels are maintained for those vegetation types: 

“Are snags, coarse woody debris, downed logs and large old trees at desired levels at the 

midscale (100 to 1,000 per acre average)?” The guideline “snags should be retained” was 

modified in the revised plan under Vegetation Management in All Forested Communities and now 

states that project design and treatment prescriptions should generally “not remove” snags. 

Comment: The DEIS (p. 105) asserts that according to the VDDT modeling, in 15 years under 

alternative B, goshawk habitat would increase by 48,673 acres and frequent-fire mixed conifer 

would increase by 5,350 acres, but does not specify what structural characteristics it is managing 

for that would achieve this difference. (SC-79)

Response: The EIS used the VDDT model to help determine how nesting and roosting habitat, 

could change over time with each alternative. The VDDT states do correlate to quality habitat 

and structural characteristics, as specified in appendix B (table B-14) of the EIS under the 

wildlife section. For goshawks, the structural characteristics of the VDDT states correspond to 

include large trees in multistory stands with both open and closed canopy. This equates to acres 

of nesting, and roosting habitat. 

Comment: The plan fails to adequately protect the remaining old growth ponderosa pines and 

mixed-conifer and virtually ensures the further decline of species such as the northern goshawk. 

(SC-1)

Response: The needs of the northern goshawk were addressed in the regionally consistent desired 

conditions and guidelines (see Desired Conditions for Use in Forest Planning in the 

Southwestern Region: Development and Science Basis Updated: August 2013). The viability 

analysis in the EIS assessed the risk to the northern goshawk and its habitat. The plan desired 

conditions provides for old-growth ponderosa pine and mixed conifer forest structural stages as a 

component of the uneven-aged forest, similar to historic natural conditions at all scales. In 

addition, the guidelines under threatened, endangered, and sensitive species reinforce retention 

management of known goshawk nesting areas for quality nesting habitat attributes.

372 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: Canopy cover maintained at the clump and group scales has the potential to reduce 

the amount of forest cover at the stand scale that is needed for goshawk nesting and fledging 

habitat. (CBD-50) The Forest Service should not drop the standards related to goshawk nest 

areas, PFAs and foraging areas. Removing standards will ensure that the goshawk becomes more 

rare and uncommon. (SC-70)

Response: The needs for the goshawk were considered and provided for at all three scales of the 

vegetation desired conditions in ponderosa pine and mix conifer stands (Reynolds et al. 2013.)

Alternative A would maintain the standards and guidelines of the current plan. The action 

alternatives reformat a number of standards and guidelines in the current plan into desired 

conditions in a way that removes difficulties that have become apparent with implementing the 

current standards and guidelines. Application of stand-scale canopy cover measures conflicts 

with management for uneven-aged stand conditions, and is inconsistent with current science 

relative to the ecology of these forests. Managing for stand-scale closed-canopy forest conditions 

is also inconsistent with the habitat needs of other wildlife species, some of which are primary 

components of the goshawk food web. Beside the Reynolds et al. (2013) GTR, how goshawk 

habitat components are provided for under the revised plan is reflected in appendix M. There are 

desired conditions and guidelines in the Threatened, Endangered and Sensitive Species section of 

the revised plan that directly address nesting and PFAs for the goshawk. A viability risk 

assessment by alternative was carried out in the EIS for several habitat components important to 

the goshawk and viability was assured. Alternative A has the highest risk. Overall, the greatest 

risk to goshawk habitat identified in the EIS was loss of habitat due to uncharacteristic fire.

Comment: More science is needed to determine which management practices actually benefit the 

goshawk. (SC-105a) 

Response: There is no NEPA or CEQ requirement that decisions must wait for more research and 

data. We used the best available science related to goshawk habitat to develop the plan 

components (see Desired Conditions for Use in Forest Planning in the Southwestern Region: 

Development and Science Basis Updated: August 2013). The desired conditions focus on 

managing for forest vegetation conditions that reflect the local evolutionary environment of the 

goshawk and its food web. Assessing specific effects of management practices on the goshawk is a 

research question and is outside the scope of the plan and EIS. However, research on goshawks 

continues to occur outside the planning process and, in time, this information can be 

incorporated into management practices. The Kaibab NF is committed to integrating best science 

into its management decisions.

Comment: The DEIS states that conservation of wildlife in a changing environment was "not 

easily implemented under the current plan, but fails to explain why. (CBD-36)

Response: The DEIS stated in Environmental Consequences for Wildlife Species Viability: 

Alternative A – Current Plan, Current Management (No Action) the following: “The current plan 

has very prescriptive (restrictive) standards and guidelines that make it difficult to apply adaptive 

management based on our understanding about management effects on ecosystems and wildlife. 

Adaptive management will be essential to effectively manage for climate change and invasive 

species in changing and uncertain conditions.” In response to this comment, clarification was 

added that “As a result the action alternatives include a monitoring plan designed to better 

inform the effects and effectiveness of management and progress towards desired conditions.” In 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 373
Appendix A. Response to Comments

the DEIS, the next paragraph goes on to further explain that “Climate change has the potential to 

affect all wildlife species, and influences the likelihood of large-scale disturbance (e.g., fire, bark 

beetle outbreaks) across the landscape. The original forest plan (alternative A) does not recognize 

climate change, and offers limited guidance associated with management activities (e.g., salvage 

logging) related to such disturbance events.” 

Comment: Goshawks should be closely monitored to determine what its population trajectories 

are and its condition should be used to assess forest conditions. (SC-105b)

Response: Although goshawks are not specifically called out in the monitoring plan, forest 

conditions for the goshawk are assessed in the monitoring matrix (table 5) of the revised plan. 

The monitoring questions for ponderosa pine and frequent-fire mixed conifer assess desired 

conditions in the plan, which should benefit goshawk and the necessary forest conditions. The 

relevant monitoring questions are: “How many acres of the Kaibab NF are in an uneven-aged 

open state, at the mid-scale (above 100 acres)?” and “What is the total area within the desired 

range for basal area and openings?” 

While not directed by the plan, the Forest Service does monitor goshawks at different spatial 

scales. Region 3 is currently monitoring the goshawk populations across the Colorado Plateau. 

Surveys are completed about every 5 years. Additionally, the Kaibab NF has baseline occupancy 

(presence/absence) data (Dickson et al. 2013.).We intend to re-measure on a regular interval, 

which will allow us to determine changes in habitat use over time and infer projects’ effects and 

other environmental influences. Results from some of this work are available on the Kaibab NF 

website: http://fs.usda.gov/goto/kaibab/plan_revision. See “Best Use of Science” link.

Comment: We suggest incorporating additional research models and findings relevant to 

goshawk management. (WILD-10)

Response: The proposed plan and the regionally consistent desired conditions were developed 

using a variety of existing peer-reviewed research and findings (see appendix J of the EIS, and 

the Desired Condition White Paper; Desired Conditions for Use in Forest Planning in the 

Southwestern region: Development and Science Basis Updated: August 2013). The Kaibab NF is 

committed to integrating best science into its management decisions.

Comment: Tassel-eared squirrels need patches of old or mature ponderosa pine trees. (WILD-8a)

Response: This need is addressed through the desired conditions for ponderosa pine in the plan. 

There is a fine-scale desired condition that states “Crowns of trees within the mid-aged to old 

groups are interlocking or nearly interlocking and consist of approximately 2 to 40 trees per 

group.” The mid-scale desired conditions provide for a distribution of mature and old trees 

through the desired condition that says “all age classes and structural stages are present.”

Comment: The Kaibab squirrel is not “readily adaptable to a wide variety of habitats” as asserted 

in the DEIS (appendix I). In fact, the Kaibab squirrel is considered to be vulnerable to extirpation 

or extinction globally, nationally, and statewide by NatureServe (2001). (WILD-8b)

Response: The statement “readily adaptable to a wide variety of habitats” refers to the cottontail 

rabbit, which is immediately below Abert’s squirrel (tassel-eared squirrel) in table I-2 in appendix 

I. Kaibab squirrels (tassel-eared squirrel subspecies) are found throughout their habitat on the 

374 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Kaibab NF. The NatureServe ranking of S3 is due to the limited range and distribution of this 

endemic species. 

Comment: We recommend that hunting of tassel-eared squirrels not be allowed. (WILD-9) For 

pronghorn, there should be a desired condition for achieving at least 40 fawns per 100 does as a 

goal to expand the existing populations. (RE-11)

Response: Arizona Game and Fish is the lead agency responsible for managing wildlife 

populations, and for making decisions about hunting and hunted species in Arizona. The Forest 

Service does not set goals for game species populations. This is outside the scope of the plan 

decision.

Comment: Please include a guideline which recommends moving fences back from roadways to 

facilitate pronghorn crossing. (AGFD-30)

Response: While we recognize the value for fence setbacks for pronghorn antelope, we did not 

include the suggested guideline. Decisions to relocate fences needs to be made at the project-level 

because there are many conditions that need to be evaluated such as easements, rights-of-way, 

and effects to permittees. 

Comment: Spatial and temporal connectivity within and between watersheds is necessary for 

maintaining aquatic and ecosystem function. Connections among basins must allow for 

movement between refugia. (CBD-63)

Response: While it is desirable for there to be wildlife connectivity and human-caused habitat 

fragmentation to be minimized, in some cases (springs) aquatic function is better protected by 

maintaining its isolation (L. Stevens, pers. comm.). As a result, no additional plan components 

were developed to address this concern. 

Comment: The EIS should provide an analysis of the implications for the viability and recovery 

of aquatic associated fish and wildlife species, particularly fish and amphibians. (CBD-24)

Response: The wildlife section of the EIS contains a viability analysis for at-risk aquatic species 

including the northern leopard frog, spikedace, loach minnow, and Apache trout. Additional 

supporting information about aquatic resources can be found in the spring assessment database 

and species database in the project record.

Comment: In the guidelines for wildlife management, please include the Department's State 

Wildlife Action Plan Species of Greatest Conservation Need in bullet 2. (AGFD-28) 

Response: As a general note, due to format changes between draft and final, the comment now 

refers to bullet 2 in guidelines for threatened, endangered and sensitive species. The plan 

includes language about working with AGFD to achieve management goals and objectives 

specified in Arizona’s State Wildlife Action Plan in the wildlife management approach section. 

The management approach section is the most appropriate part of the forest plan for 

acknowledging how we will be working with partners. 

Comment: Bison hybrids and Rocky Mountain elk are both nonnative and their continued 

presence could take a heavy toll on forest resources. Management direction is needed for these 

species to minimize their impacts. Coordination is needed with neighboring Federal land 

managers (i.e., Grand Canyon National Park) to ensure that these nonnative wildlife species do 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 375
Appendix A. Response to Comments

not harm forest resources, or those on adjacent Federal lands. Bison (cattalo) should be addressed 

as an invasive species. They do not naturally occur on the Kaibab; they are probably multiplying 

rapidly and should be eliminated. (GR-1)

Response: The following guideline was added to the plan to minimize the impacts from bison: 

“the bison should be managed so that the herd is concentrated within the House Rock Wildlife 

Area. Active management should be used to minimize impacts from bison to sensitive resources, 

particularly outside the House Rock Wildlife Area.” The following desired condition was modified 

to further address this concern: “The bison herd size is in balance with ecological conditions in 

the House Rock Wildlife Area.” Specifically for bison, the following language has also been 

added to the plan management approach: “Efforts to achieve the desired conditions will likely be 

implemented in phases with an initial emphasis on reducing the herd size and excluding them 

from Grand Canyon National Park. Strategies may include hunting and trapping, fencing, and 

herding.” Point of clarification: The IUCN/SSC Bison Specialist Group has documented that the 

Kaibab NF is within the historic range of bison and that they are considered native to this area 

(Potter et al. 2010). While history of the herd that was re-introduced to the Grand Canyon 

Preserve in 1906 has shown the introduction of cattle genes to the herd, the AGFD has 

determined that this is a wildlife herd, and therefore, is treated as such. Most bison herds within 

the United States outside of conservation herds have a certain level of cattle genes present. Bison 

on the Kaibab NF are considered native wildlife. 

Plan direction that would minimize the impacts from elk can be found in the plan under Aspen 

and Constructed Waters. For example, the plan contains an objective to fence 200 acres of aspen 

on the Williams and Tusayan Ranger Districts within 10 years of plan approval, and a desired 

condition that constructed waters do not concentrate ungulate activity in aspen stands.

As mentioned in the aspen sections of the plan, the Kaibab NF is committed to working with its 

partners to find achievable management strategies that balance the needs of the ecosystem with 

desired nonnative species such as elk. 

Comment: The plan should have direction that would prevent the further introduction of 

nonnative species by the AGFD. (GR-2)

Response: We evaluate species introduction proposals on a case-by-case basis according to 

Forest Service policy. If the AGFD should recommend introducing a species, we would follow the 

Forest Service policy to evaluate the potential effects and relative trade-offs before making a 

decision. This is outside the scope of the forest plan decision.

Comment: Please clarify what is meant by “selected nonnative species.” (SC-51)

Response: We changed the natural waters desired condition from “select nonnative species” to 

“desired nonnative species” and added a footnote to clarify that desired nonnatives are those 

with high social or economic value. On the Kaibab NF, there are some desired nonnative species 

such as Apache trout and Rocky Mountain elk. While some people have called bison a nonnative 

species, current research shows that the Kaibab NF is within the historic range of the bison and 

they were native to this area (Potter et al. 2010).

Comment: The dwarf shrew and spotted skippering are essentially written off in the DEIS (p. 

87). (LS-2, WILD-13)

376 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: Little is known about these species. The Kaibab NF supports efforts and works with 

partners to increase knowledge about these species. Until more information is available, the plan 

accommodates these species by providing overall habitat and incorporating design features to 

provide for them as recommended in the Kaibab NF’s rare and endemic guidebook. 

Comment: The plan does not address extirpated species such as the grey wolf and pileated 

woodpecker (LS-1, WILD12). The forest plan should consider reintroduction of extirpated 

species, thereby enabling the first steps in the reintroduction process (SC-109).

Response: The reintroduction of extirpated species is outside the scope of the plan decision. This 

is described in the introduction to the plan’s wildlife section, which states “the Kaibab NF is 

primarily responsible for providing habitat to maintain species diversity on the forest....” “The 

AGFD and the U.S. Fish and Wildlife Service are the lead agencies responsible for managing 

wildlife populations in Arizona.” The plan would, however, support such an effort if and when the 

AGFD or USFWS initiated a reintroduction effort. The Wildlife Management Approach section of 

the plan states that “the Forest Service cooperates with State, Federal, and nongovernmental 

organizations to reestablish naturally occurring species.” The plan also has a desired condition 

that “native species occur throughout their potential natural range.” 

Comment: The plan contains an objective to modify and or install pronghorn crossings on 

50 miles of fence in a 10-year period (5 miles per year). How many miles of fence need to be 

maintained? Is this enough? (SC-38)

Response: Many of the fences in priority habitat (e.g. fawning areas and migration corridors) 

have already been modified. We will continue to focus on areas where there is greatest need. The 

objective was not based on the total need, but what we believe we have the capacity to 

accomplish over the next 10 years. 

Threatened, Endangered, and Sensitive Species 

Comment: The Forest Service fails to explain why it seeks to repeal standards for wildlife habitat 

management. (CBD-35) The DEIS fails to disclose the negative effects to listed and sensitive 

species that would result from the removal of binding standards for wildlife. (CBD-37)

Response: The viability analysis in the EIS assesses the habitat needs for the 69 forest planning 

species, which includes listed and sensitive species. This analysis demonstrated that the preferred 

alternative had the least viability risk of all alternatives, including the current plan.

Each standard and guideline from the original plan (as amended) was evaluated, and those that 

were not needed were not retained. Standards or guidelines were not retained if they were already 

addressed by law, regulation, or policy, outside the management control of the Forest Service, or 

were restrictive or prescriptive guidelines and not based on the best available science. The EIS 

appendix M further describes how existing standards and guidelines for wildlife habitat 

management were incorporated into the revised plan. 

Most of the standards and guidelines that have the potential to benefit wildlife in the current plan 

are also found in the action alternatives in the form of desired conditions, guidelines, or 

management approaches. For example, specific guidance from approved recovery plans is not 

repeated verbatim in the plan, but is instead incorporated by reference under the guidelines for 

threatened, endangered, and sensitive species, which state “project activities and special uses 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 377
Appendix A. Response to Comments

occurring within federally listed species habitat should integrate habitat management objectives 

and species protection measures from approved recovery plans.” This approach will help keep the 

plan current and in line with the best available science. Additional direction for wildlife also 

resides with many of the vegetation types where those species live, or with activities that might 

affect them. For example, guidance for certain listed and sensitive species can be found under the 

desired conditions for ponderosa pine and frequent-fire mixed conifer, and there are numerous 

guidelines under vegetation management in all forested communities. See the introduction 

chapter of the revised plan for a discussion on plan components and how standards and 

guidelines differ and the Wildlife Species Viability: Effects Common to All Action Alternatives 

section of the EIS for further discussion of the effects of the action alternatives on wildlife species 

viability. 

Comment: The Forest Service should avoid grouping threatened, endangered, sensitive, and 

indicator species with more common species because species with more restrictive ranges are less 

likely to be protected by management of habitat at taxonomic scales than widespread species. 

(CBD-31, CBD-32)

Response: The coarse filter analysis did group more and less common species, but by threat to 

habitat not by range. The fine filter analysis further identified specific threats within those 

habitats. By using this approach, we were able to identify and develop additional plan 

components where needed to provide for viability. This process is described in detail in the 

Species Diversity Report (2008) and in the Wildlife Specialist Report. The EIS does analyze 

threatened, endangered, and sensitive species separately for each alternative and the MIS are 

discussed in their own section. 

Comment: Page 70 of the DEIS should either delete the vegetation types from this table or be 

more specific about the aspects of habitat that are important. (DOI-17)

Response: The vegetation types were listed in table 11 of the Species Viability wildlife section to 

show how much potential habitat each species occupies. This table provides a baseline for 

potential and occupied habitat, and is fundamental to the subsequent analyses. This table was set 

up to show the primary habitat types important for each species; it was not intended to provide 

specific aspects of habitat. 

Comment: Even if the guidelines in the revised plan were required, the direction would not 

ensure viability of the goshawk or its 14 prey species. (CBD-51)

Response: The plan does not rely on guidelines alone to ensure viability for the goshawk and its 

prey. In addition to the guidelines, viability is provided through the vegetation desired conditions 

and objectives. The FEIS analyzed the revised plan and alternatives and determined that the 

revised plan has the greatest ability to provide for the goshawk over time and provides for the 

goshawk viability from forest management activities. None of the 14 prey species where shown to 

have viability issues resulting from implementation of the revised plan. The intent of guidelines 

must be followed or a plan amendment is needed. Objectives are concise projections of 

measurable, time specific intended outcomes. Objectives have been established for the work 

considered most important to address the needs for change and achieve desired conditions. 

Projects are required to maintain or move toward desired conditions and to be consistent with the 

plan over the long term. Collectively, these plan components provide for viability of the goshawk 

and its prey.

378 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: Designation of protected and restricted areas and implementation of the standards and 

guidelines in the 1996 Record of Decision is the minimum required to support a no jeopardy call 

on the revised plan. (CBD-46)

Response: The no jeopardy call for the 1996 Record of Decision was based on the original forest 

plan, as amended. The USFWS has reviewed the revised plan and issued a new biological opinion 

(September10, 2013) that reflects the provisions in the revised forest plan, the revised recovery 

plan for the Mexican spotted owl (FWS 2012), and new information that has become available 

during the past 15 years. A no jeopardy call was issued in the new biological opinion.

Comment: We recommend designing any timber harvest, thinning, or fire treatments in the 

watershed(s) supporting North Canyon Creek in a manner that enhances and protects Apache 

trout habitat. In the watersheds that include and drain into North Canyon Creek, we recommend 

designing fire treatments in a manner that will result in low intensity surface fire with minimal 

torching. (DOI-8)

Response: No plan components were developed to direct timber harvest or thinning activities in 

the North Canyon watershed because most of this area is within the Saddle Mountain Wilderness, 

which would not support timber harvests or mechanical thinning activities. Any planned activities 

in the area that may affect the Apache Trout would be coordinated with the USFWS. Additionally, 

there is a wildfire management standard that states “Managers will use a decision support 

process to guide and document wildfire management decisions.” Additionally, there is a guideline 

that protection objectives should be developed “if current or anticipated fire behavior and fire 

effects exceed the desired fire behavior and effects.” The designing of any treatment that affects 

North Canyon would be at the project level.

Comment: To ensure the viability of California condors, the Forest Service should consider an 

alternative to require the use of lead-free ammunition. Lead shot is not only the primary killer of 

California condors in Arizona; it also harms a suite of raptors and other scavengers and is harmful 

to humans who consume contaminated meat. The Forest Service should use its authority to 

protect all species in the forest by banning lead ammunition. (SC-107, TS-2)

Response: While we acknowledge the harmful effects of lead to condors and other raptors, 

banning lead ammunition would require following the rule-making procedures established in 

5 U.S.C. 553. Rulemaking requires additional analysis and documentation for compliance with 

the National Environmental Policy Act, which is outside the scope of the plan revision decision 

and analysis.

Comment: The agency is in violation of the endangered species act by failing to regulate use of 

lead ammunition by hunters on the Kaibab National Forest and the Draft Plan would similarly 

violate the ESA prohibition on unlawful take of the species. (CBD-59)

Response: The regional forester has the authority to prohibit actions on the forest for the 

purposes of protection of endangered species per 36 CFR 261.70. However, such a prohibition 

would require following the rule making procedures established in 5 U.S.C. 553. Rulemaking is 

outside the scope of the plan revision EIS analysis. Further, additional protections for the condor 

are not needed for the purposes of the forest plan. Under all plan alternatives, the viability of the 

California condor from forest management activities is maintained, as documented in the viability 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 379
Appendix A. Response to Comments

analysis in chapter 3. The Kaibab NF did consult with the USFWS on the plan, and no take was 

issued for the condor. 

Comment: Due primarily to issues from exposure to lead ammunition, the condor population is 

currently maintained through release of captive-bred birds, and is not likely to become selfsustaining unless further lead reduction efforts are taken but the DEIS identified the viability risk 

as “low.” (DOI-11)

Response: As noted in the FEIS discussion for the Species Viability Analysis, the viability ratings 

are based only on the habitat elements and the potential to be affected by Forest Service 

management action (or inaction).. Other factors that could affect species are not included (e.g., 

disturbance during the breeding season). The FEIS states that there is a moderate viability risk to 

the condor within the habitat element rocky outcropping, caves and cliffs. This ranking is based 

on the combination of forest ranking for the condor and rating of the likelihood that habitat 

would be a limiting factor. The EIS was clarified to state that while cumulatively there is a 

negative effect to the Southwest population from lead shot, the Kaibab NF management activities 

would not adversely affect the viability of the species. The EIS recognizes that all species listed as 

endangered have an inherent viability risk. 

Comment: The DEIS should clarify that the California condor is a federally listed species under 

the Endangered Species Act, and only for purposes of section 7 consultation within the 10 (j) 

population area are they treated as proposed. (DOI-20)

Response: We added language to the FEIS to ensure that this is clear. 

Comment: The Kaibab has the authority to prohibit the use of lead ammunition and should do so 

to prevent this risk to condor viability. (WILD-18, TS-1)

Response: The regional forester has the authority to prohibit actions on the Kaibab NF for the 

purpose of protecting endangered species per 36 CFR 261.70. However, such a prohibition would 

require following the rule-making procedures established in 5 U.S.C. 553. Rulemaking would 

require additional analysis and documentation for compliance with the National Environmental 

Policy Act, and is outside the scope of the plan revision EIS analysis.

Comment: The EIS minimizes the threat to condor viability and states that it does not regulate 

hunting, it “only provides access to hunting,” but the Forest Service issues commercial big game 

permits that do not require non-lead ammunition. (WILD-19)

Response: The Forest Service does not issue commercial big game permits; it issues permits to 

State-licensed outfitter-guide businesses to provide assistance to hunters. Permitted guides are 

hired to track game, maintain camp, and to provide other support services, but they do not direct 

or control the hunting activities of their customers. As a result, hunting regulation is not within 

the Forest Service’s authority. Permitted guides are required to encourage their clients to use 

non-lead ammunition or pack out gut piles.

Comment: The plan would remove standards and guidelines that limit the development of utility 

corridors in condor habitat. (CBD-3)

380 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: There are standards and guidelines that limit the development of utility corridors in 

the plan (See appendix M). The only standards that were removed reiterated guidance found in 

Forest Service handbooks and manuals. 

Comment: The DEIS should specify that the first successful condor nesting attempt occurred in 

2011, an unsuccessful attempt occurred in 2010. (DOI-22)

Response: We adjusted wording in the FEIS to reflect this. 

Comment: If forest management practices or other activities managed by the Kaibab NF may 

affect habitat for the spikedace or loach minnow, a description of these activities and potential 

effects should be disclosed. (DOI-19)

Response: The nearest populations of loach minnow and spikedace are 12 miles from the Kaibab 

NF boundary. The potential for off-forest effects to these species from management activities is 

low. The greatest risk to these species from Kaibab NF lands is large-scale, uncharacteristic, 

high-severity fire and the associated downstream effects. The potential effects were discussed in 

the DEIS. The FEIS will provide greater clarification and detail.

Comment: Mixed conifer will continue to have issues due to U.S. Fish and Wildlife Service’s 

preoccupation with critical habitat designations for nonexistent populations of Mexican spotted 

owls on the North Kaibab Ranger District. (KCC -6)

Response: The Kaibab NF will continue to work closely with the USFWS to provide quality 

habitat for the Mexican spotted owl. We believe there is flexibility to provide both for the Mexican 

spotted owl and to restore desired conditions. 

Comment: The plan and DEIS should recommend restating that following the Mexican Spotted 

Owl Recovery Plan is an objective for each alternative. (DOI-14)

Response: The guideline “project activities and special uses occurring within federally listed 

species habitat should integrate habitat management objectives and species protection measures 

from approved recovery plans” is common to all action alternatives and applies to all approved 

recovery plans. There is no need to restate it for each species and alternative. Additionally, the 

management approach sections of the vegetation types that support Mexican spotted owl habitat 

specifically reference the Mexican Spotted Owl Recovery Plan. 

Comment: All guidelines in the plan can be changed in project-level decision for any reason, this 

would allow the agency to design projects unencumbered by binding direction that would prevent 

adverse effects to the spotted owl and its critical habitat. (CBD-48)

Response: This assertion is not true. All projects and activities must meet the intent of plan 

guidelines, or plan amendments are required. Further, the plan, the biological opinion for the 

plan, recovery plans, and project specific consultations, all provide protections for T&E species. 

The plan contains a guideline that “project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and species protection 

measures from approved recovery plans.” The Kaibab NF also follows the terms and conditions 

in the biological opinion for the forest plan. Additionally, the Kaibab NF consults with USFWS 

to minimize potential adverse effects on all projects that may affect the MSO and its habitat. .

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 381
Appendix A. Response to Comments

Comment: It is unclear how the draft plan desired conditions would provide for nesting and 

roosting habitat for Mexican spotted owls. (DOI-1)

Response: We added language to the fine-scale desired conditions to better align with the 

language in the Mexican Spotted Owl Recovery Plan that “where Gambel oak comprises more 

than 10 percent of the basal area, it is not uncommon for canopy cover to be greater than 

40 percent,” and that in frequent-fire mixed conifer forest, canopy cover may be very closed at 

the fine scale. 

Comment: The DEIS and plan should discuss how protection of Mexican spotted owl protected 

activity centers (PACs) will be balanced with this experimental approach. (SC-27)

Response: The experimental approach specified in the guideline for vegetation management 

activities in mixed conifer is consistent with the direction in the revised recovery plan (FWS 2012) 

that supports adaptive learning. The specifics of implementation would consider site-specific 

information and would involve the USFWS in developing project design criteria and associated 

monitoring related to Mexican spotted owl PACs. 

Comment: The draft plan proposes no affirmative survey requirement for Mexican spotted owls 

and as a result would only protect known PACs. (CBD-47)

Response: While the plan does not directly have a survey requirement for Mexican spotted owls, 

the plan contains a guideline that states “project activities and special uses occurring within 

federally listed species habitat should integrate habitat management objectives and species 

protection measures from approved recovery plans.” The revised recovery plan (2012) specifies 

that surveys should be done prior to activities that may alter potential owl habitat. The 

reasonable and prudent measures in the biological opinion call for survey, and the forest consults 

with the USFWS on all Federal actions that may affect the Mexican spotted owl or its critical 

habitat. The revised recovery plan for the Mexican spotted owl details a new sampling framework 

that is at a scale that is biologically meaningful for the owl. This necessarily crosses large 

landscapes and land jurisdictions and is stratified by ecological management units. Implementing 

this survey design is beyond the scope of the plan and EIS. However, the Forest Service will be 

meeting with the USFWS and other land management agencies to discuss strategies for 

implementing this new sampling framework. The surveys should yield data on population and 

habitat trends. The Kaibab NF is part of this bigger sampling framework and design, which must 

be integrated consistently by all parties if the results are to yield statistically sound data which 

can be applied toward down listing of the species. 

Comment: The plan eliminated standards and guidelines related to the Mexican spotted owl, and 

replaced them with a reference to the recovery plan. The recovery plan is not enforceable in sitespecific project implementation and will not ensure species viability or avoid jeopardy. (CBD-45) 

If consultation for the Mexican spotted owl is deferred to site-specific proposed actions or if the 

revised plan fails to implement the recovery plan (as opposed to just referencing it) the Mexican 

spotted owl and its habitat may be jeopardized. (CBD-58)

Response: The Kaibab NF follows the intent of Mexican Spotted Owl Recovery Plan and the 

provisions in the Endangered Species Act. The revised forest plan does not reiterate law, 

regulation, or policy, but instead points to it. This enables the plan to remain current by 

incorporating higher level policy by reference. Additionally, the Kaibab NF consults with the 

USFWS on the forest plan as well as on site-specific projects that may affect the Mexican spotted 

382 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

owl or its habitat. Project design and site-specific mitigation measures are developed to provide 

for the owl to prevent jeopardy.

Comment: The similarity of desired conditions between ponderosa pine and dry mixed conifer 

could lead to type conversion of mixed conifer over time. There should be language that specifies 

post-treatment conditions should not be dominated by ponderosa pine. (AGFD-9) There needs to 

be more clarification about how meeting the objectives for reduced tree density and increased 

openness would be applied so that they do not degrade or create a type conversion in Mexican 

spotted owl habitat. The DEIS should describe whether and how type conversions would occur 

and the effects of such conversions on listed species. (DOI-15, DOI-24)

Response: By definition, the frequent-fire mixed conifer type historically had a plurality of, but 

was not dominated by ponderosa pine. The guideline to “retain at least historic frequencies of 

trees by species across broad age and diameter classes” is intended to make progress toward the 

desired conditions for each forest type and prevent type conversion. The Kaibab NF does not 

consider restoration toward the historic condition where ponderosa pine has a plurality a “type 

conversion.” The species composition objective for frequent fire forest types is to manage for a 

plurality of species that are fire-resistant, consistent with the desire to restore essential ecosystem 

processes such as frequent surface fire. Managing for a plurality of species that are not fire 

resistant would maintain or develop unsustainable conditions that are inconsistent with natural 

processes.”

Comment: Condors are also a federally listed endangered species; the Forest Service also has a 

responsibility under the Endangered Species Act to promote recovery of this species. (SC-108) 

We recommend including more specific guidelines for management and protection of Mexican 

spotted owls and other listed species on the Kaibab NF, under the “Guidelines of Wildlife 

Management” and within desired condition objectives, in order to incorporate section 7(a)(1) 

recovery responsibilities. (DOI-7)

Response: The plan meets the section 7(a)(1) responsibilities by providing for key habitat 

components and guidance for activities that affect all listed species including the condor and 

Mexican spotted owl. These provisions are integrated throughout the plan in the form of desired 

conditions, objectives, and guidelines. In addition to providing for quality habitat, the plan 

emphasizes educational outreach, which is an important medium for communicating the benefits 

of good stewardship practices to the public and can be a major instrument through which longterm conservation change may be achieved. These long-term conservation activities should help 

promote recovery of the condor. In response to this comment and to continue the promotion of 

reducing the effect of lead on the condor, the recreation desired condition for public education 

was supplemented to better reflect the Kaibab NF’s 7 (a)(1)responsibilities. It now reads “Visitors 

have access to information that enriches their recreation experiences and contributes to an 

understanding of their role in public land stewardship. “Leave No Trace,” “Tread Lightly,” fire 

prevention, wildlife awareness (e.g., lead reduction, Bear Aware, Animal Inn, etc.), and 

archaeological resource protection principles are promoted and practiced by the visiting public.” 

The words “wildlife awareness (e.g., lead reduction)” are bolded to highlight the language that 

what was added to the desired condition to help meet the 7(a)(1) responsibilities.

Comment: Recommend that Mexican spotted owl habitat (pine-oak and mixed conifer), as 

defined in the Mexican Spotted Owl Recovery Plan, be identified. (DOI-12)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 383
Appendix A. Response to Comments

Response: We added language to the introduction of the ponderosa pine PNVT to better highlight 

the pine-oak subtype. It now reads “The ponderosa pine forest vegetation community includes two 

subtypes: ponderosa pine-bunchgrass and ponderosa pine-Gambel oak. Higher densities of 

Gambel oak (Quercus gambelii) are often correlated with higher species richness, and the 

Gambel oak subtype provides critical nesting and foraging resources for many northern Arizona 

birds, including Mexican spotted owls.” Additionally, desired conditions were added for 

ponderosa pine and frequent-fire mixed confer to clarify that at the fine scale, higher densities 

and canopy cover may be desired. 

Comment: Pages 66−68 of the DEIS should address important MSO habitat element categories 

including large trees, tree density, large logs, hardwoods, canopy cover, species composition, and 

residual plant cover. (DOI-16)

Response: The habitat elements, including snags and large logs (course woody debris section), 

specified on pages 66 to 68 are for a variety of species that were not necessarily captured in the 

course filter analysis). We added language to the FEIS to ensure it is clear that the plan provides 

for other key Mexican spotted owl habitat features.

Comment: By removing the standards and guidelines in the proposed plan related to the 

Mexican spotted owl, the Forest Service is returning to an era of unlimited management 

discretion that would not avoid jeopardy or maintain the viability of sensitive animal population. 

(CBD-2)

Response: The plan and alternatives were developed to address viability for all species including 

threatened and endangered species. The threatened, endangered, and sensitive species guideline 

that incorporates by reference the habitat management objectives and species protection 

measures from approved recovery plans will keep the plan guidance current with all recovery 

plans. The Kaibab NF consults with the USFWS to avoid jeopardy and to provide for critical 

habitat for listed species at both the plan and project levels. No projects can be implemented in 

threatened and endangered species habitats without site-specific consultation with USFWS to 

address site-specific habitat needs and project mitigations needed to ensure viability. The USFWS 

has prepared a biological opinion for the plan FEIS. The EIS discusses the plan components that 

help maintain sensitive wildlife species. Appendix H crosswalks the different threats to wildlife 

species, including listed and sensitive species, with the plan components that reduce or eliminate 

the threats. 

Comment: The mid-scale desired condition that provides for 10 to 20 percent higher basal area 

in goshawk PFAs is not adequate to provide for the structural attributes required by the goshawk. 

(SC-19)

Response: The desired conditions were developed to provide habitat for all associated native 

species by specifying desired conditions within the natural range of variability. Native species 

evolved with and are adapted to these conditions (see Desired Conditions for Use in Forest 

Planning in the Southwestern Region: Development and Science Basis Updated: August 2013). 

Habitat structural attributes for goshawks were analyzed in the Species Viability Specialist 

Report and are discussed in the EIS under “effects common to all action alternatives,” and 

“environmental consequences.” See the wildlife section in appendix B for information on how 

vegetation structural states used in the vegetation analyses correspond to goshawk PFA needs 

(tables B-14 and B-19 through B-20).

384 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: The DEIS analysis for risk to species viability for the proposed plan (alternative B) 

shows low risk for the goshawk because the analysis compares it to the achievement of the 

desired basal area, group sizes and openings, not the habitat needs outlined in the MRNG. (SC78)

Response: Part of the goshawk low viability risk rating for all habitat elements, other than 

frequent-fire mixed conifer, which had a moderate rating, is based on the different habitat 

elements meeting the desired conditions shown in the plan over a 50-year time period. The 

desired conditions for ponderosa pine and mixed conifer were developed to meet vegetation 

descriptions within the MRNG (see Desired Conditions for Use in Forest Planning in the 

Southwestern Region: Development and Science Basis Updated: August 2013). The other factor 

that determines viability risk rating is the species forest ranking. Goshawks were given a forest 

rank of F3, as a conservative estimate of abundance, even though existing research on 

productivity (20+ years) on the North Kaibab Ranger District has demonstrated the species has 

saturated its habitat and is maintaining its population levels (Reynolds and Joy 2006). 

Additionally, preliminary results for recent goshawk surveys on the Williams and Tusayan Ranger 

Districts indicate high occupancy rates.

Comment: The goshawk is not likely to thrive in forests that do not have high canopy closure 

and lifted crowns. (WILD-11)

Response: The desired conditions were developed to provide for the goshawk and its prey. The 

viability analysis in the EIS specifically assesses the viability risk and assures the continued 

viability of the northern goshawk and its habitat. The plan desired conditions for threatened, 

endangered, and sensitive species specify that “Goshawk nest areas are multi-aged forests 

dominated by large trees with interlocking crowns and are generally denser than the surrounding 

forest.” The fine-scale desired conditions for ponderosa pine state “Crowns of trees within the 

mid-aged to old groups are interlocking or nearly interlocking and consist of approximately 2 to 

40 trees per group.” These conditions lead to lifted crowns. The desired conditions also provide 

for a close interspersion of all forest structural stages (grass/forb/shrub, young forest, mid-aged 

forest, mature forest) that provide habitats for species critical to the food web of the goshawk 

(rabbits, ground squirrels, tree squirrels, etc.). Habitat requirements for the goshawk are not 

uniform throughout its home range; while areas of mature trees with high canopy closure are 

considered to be quality nesting/roosting habitat, it will not maintain a diversity of prey species. A 

high degree of interspersion of forest densities and structures is necessary to provide for all of the 

components of the goshawk’s habitat and its prey species.

Rare and Narrow Endemic Species

Comment: Prior to giving up conservation of a rare species, the issues should be elevated to the 

regional level where a detailed inquiry of restoration options can be pursued. (LS-4)

Response: The Kaibab NF has not “given up” conservation of any rare species. The revised plan 

provides for habitat and protection of rare species through multiple plan components and 

resource areas including threatened, endangered, and sensitive species and natural waters. In 

addition, rare species are directly addressed through their own section titled “Rare and Narrow 

Endemic Species” through desired conditions: “Habitat and refugia are present for narrow 

endemics or species with restricted distributions and/or declining populations, location and 

conditions of rare and narrow endemic species are known.” and through the following guideline: 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 385
Appendix A. Response to Comments

“Project design should incorporate measures to protect and provide for rare and narrow endemic 

species where they are likely to occur. If there are additional management needs or gaps in the 

plan needed to provide for species viability, they may be addressed on a project-specific basis 

until the plan (programmatic) can be revised. 

Comment: The plan should provide guidance on how the forest intends to continue basic 

biological inventories particularly related to determining the occurrence, status, and habitat 

requirements of rare species. (LS-5, WILD-14)

Response: The monitoring plan addresses the key monitoring needs that may be affected by forest 

management. Budgets and capacity limit what can be committed over the long term. In addition 

to the resource-specific surveys contained in the monitoring plan (song birds, aspen, Mexican 

spotted owl, Arizona Bugbane, and pediocactus), the Kaibab NF has funded and will likely 

continue to fund additional surveys through partnerships with other agencies, academic 

institutions, and non-governmental organizations. 

Comment: How are you going to protect plants with viability risk and other rare plant or 

populations that have not yet been found on your forest? (SN-1)

Response: The viability requirement of the 1982 Planning Rule only requires the Kaibab NF to 

provide for species known to occur on the forest. An overarching goal of the forest plan is to 

restore the functionality of ecosystems that are departed and to maintain forest structure and 

function. This should provide the habitat required of rare plants that would have naturally 

evolved with those systems. If a new rare plant is discovered, species viability will be assessed at 

the project level until the plan (programmatic) can be amended or revised, if needed.

Comment: The guideline for rare and endemic species to incorporate measures to provide for 

rare and endemic species “where they occur” does not meet the requirements to provide for all 

native species. (EBR-12)

Response: We modified this guideline to read “Project design should incorporate measures to 

protect and provide for rare and narrow endemic species where they are likely to occur.” This 

addresses the commenter’s concern by ensuring consideration not just where there are known 

populations, but also where there is habitat within their known range.

Nonnative Invasive Species

Comment: The EIS should provide a spatially based discussion of the extent and distribution of 

noxious weeds and weed spread. (CBD-17)

Response: The Kaibab NF maintains spatial data about noxious weed locations in the corporate 

database (NRIS). Relevant information and discussion regarding the alternatives were included in 

the noxious weeds section of the EIS. 

Comment: Please add that nonnative aquatics directly and adversely affect other native species, 

through predation and habitat partitioning, and not just ecosystem function. (AGFD-31) In the 

first bullet, please add "or impact native wildlife" and "eliminated when practicable". (AGFD32a) Add language that at the implementation level could facilitate native fish restoration 

(AGFD-32b). 

386 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: In the non-native invasive introduction, the impacts of non-native aquatic species are 

now in their own paragraph and the following sentence was added. “They can out compete native 

animal species, alter food web interactions, and impact native vegetation.” The first bullet in the 

desired condition now reads “Invasive species are contained and/or controlled so that they do not 

disrupt the structure or function of ecosystems or impact native wildlife.” The suggestion to add 

“eliminated when practicable” addresses management rather than an outcome and therefor does 

not meet the criteria for a desired condition. The suggestion to add a desired condition in the 

non-native section to facilitate native fish restoration was not included because there are no 

native fish found on the Kaibab NF. 

Comment: The plan should consider nonnative invasive animals using the same process it 

addresses nonnative plants. (KBPI-3)

Response: This process for considering nonnatives was originally applied to plants, but was later 

expanded to include nonnative animals. Initially, there were a couple places where the language 

failed to reflect the expansion. This has been corrected.

Comment: The DEIS should qualify its endorsement of connectivity, as it is often the isolation of 

some habitat types, such as springs, that protects them from invasion of nonnative species, such 

as crayfish, bullfrogs, and nonnative fish. (LS-11, WILD-20)

Response: Connectivity connects adjacent habitat and promotes healthy movement of animals 

between foraging and wintering grounds, as well as genetic flow between populations. An 

animal’s ability to move between optimal habitats is important in evaluating how well it responds 

to such disturbances overtime, however connectivity is not always desirable because it can 

facilitate the invasion of non-native species. This concern is now reflected in the nonnative 

invasive management approach section of the plan. 

Comment: The Forest Service should contribute to research toward the control of cheatgrass. 

(LS-16, WILD-17)

Response: Addressing the need for “research” is outside the scope of the plan and plan process. 

However, the Kaibab NF does contribute to research for controlling cheatgrass. The Kaibab NF 

has been working on different science-based methods for controlling cheatgrass since 2007. In 

February 2012, a memorandum of agreement was developed among the Kaibab National Forest, 

the BLM, Grand Canyon Trust, AGFD, University of Arizona, USGS, and Northern Arizona 

University to establish a “Research Ranch.” One of the primary focuses of the group is 

cheatgrass control. Research projects are being evaluated for how to reduce the spread of 

cheatgrass and additional measures of controlling cheatgrass. 

Wildland Fire Management

Comment: The EIS should provide an analysis of suppressing unplanned ignition. (CBD-20)

Response: While the plan provides some guidance for managing unplanned ignitions, fire 

suppression is an emergency response and is outside the scope of the forest plan decision. 

Comment: The standard that the Forest Service will suppress wildfires at the lowest cost and 

with the fewest negative consequences is not possible because you cannot maximize three 

variables that are at odds with each other. (EBR-7)

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Appendix A. Response to Comments

Response: This standard was included in the revised plan to reflect the 2001 Federal Wildland 

Fire Management Policy that “Firefighter and public safety is the first priority in every fire 

management activity.” And the 2009 Guidance for the Implementation of the Federal Wildland 

Fire Management Policy, which lists nine guidelines, including, “initial action on human-caused 

wildfire will be to suppress the fire at the lowest cost with the fewest negative consequences with 

respect to firefighter and public safety.” This plan standard does not imply that cost, firefighter 

safety, and public safety can all be “maximized” on every incident, but rather that a balance must 

be found between safety and cost, with priority given to firefighter and public safety. 

Comment: It seems that all the fire management strategies have been formulated from a 

standpoint of what to do after an ignition unwanted and/or “unplanned” human caused ignitions. 

There should be guidance to support preventing ignitions before they occur. (BB-1)

Response: In response to this comment, the recreation desired condition was expanded to include 

fire prevention. It now reads “Visitors have access to information that enriches their recreation 

experiences and contributes to an understanding of their role in public land stewardship. “Leave 

No Trace,” “Tread Lightly,” fire prevention, wildlife awareness (e.g. lead reduction, Bear Aware, 

Animal Inn, etc.), and archaeological resource protection principles are promoted and practiced 

by the visiting public. Also included in the Wildland Fire Management Approach is the following 

statement ““Fire prevention is an integral part of the fire management program. The goal of the 

fire prevention program is to educate the public to reduce the number of potentially harmful 

human caused fires; the prevention program also works with project managers to develop 

practices and protocols that are less likely to result in ignitions from management activities and 

recreational use.”

Air Quality

Comment: The unintended and unacceptable consequences of alternative D would result in never 

ending costs of prescribed burning and smoke in the Grand Canyon during tourist season. It is not 

implementable because the public would stop the process. (JK-4)

Response: The air quality section of the EIS, explains that all alternatives are expected to achieve 

the desired conditions for air quality: “Air quality meets or surpasses State and Federal ambient 

air quality standards” and “Management activities on the Kaibab NF do not adversely impact 

Class I airshed visibility as established in the Clean Air Act.”

This is because the number of acres burned with prescribed fire is expected to be the same under 

all alternatives due to legal, climatological, social, and logistical limits on the number of acres 

that can be burned per year. The reasons for this are more fully explored in the assumptions 

section of the Air Quality Specialist Report (USDA Forest Service KNF 2012a). 

Comment: The Plan indicates that smoke is the only air quality issue that provokes public outcry 

(Draft Plan p. 48- 49). Public meetings related to the 20-year mineral withdrawal of public lands 

surrounding Grand Canyon drew large turnouts, many with concerns about air quality, dust, and 

particulate contamination, indicating a lack of public tolerance for the risks from contaminated 

dust at uranium mine sites. (SC-56)

Response: Because the statement about smoke being the only air quality issue that provokes 

public outcry it is not entirely accurate, we have removed it from the revised plan. Contaminated 

388 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
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dust was raised as an issue at public meetings for the uranium withdrawal, although it was not 

brought up at forest plan public meetings. The FEIS now discusses the potential for radioactive 

elements to be released from prescribed burns.

Comment: The coal-burning power plants in northern Arizona result in the air quality in and 

around Grand Canyon National Park often being poor. The Kaibab NF needs to take care so that 

actions within the Forest don’t exacerbate the air quality problem. (SC-55)

Response: For the past ten years, 70% or more days were rated in the Good category by the EPA 

Air Quality Index. Good is the best rating, where air pollution poses little risk to human health. 

Less than 1% of days per year rated in the Unhealthy for Sensitive Groups category, and no days 

were rated Unhealthy, Very Unhealthy or Hazardous (US EPA 2010). 

The plan contains the following desired conditions to ensure projects and activities do not 

contribute to poor air quality: “air quality meets all State and Federal ambient air quality 

standards,” and “management activities on the Kaibab National Forest do not adversely impact 

Class I airshed visibility as established in the Clean Air Act.

Additionally, the plan contains two guidelines to address this concern: “Project design for 

prescribed burns and strategies for managing wildfires should incorporate as many emission 

reduction techniques as feasible, subject to economic, technical, and safety criteria, and land 

management objectives.” and “Decision documents, which define the objectives and document 

line officer approval of the strategies chosen for wildfires, should identify smoke sensitive 

receptors, and identify appropriate objectives and courses of action to minimize and mitigate 

impacts to those receptors.

Comment: The impacts of fugitive dust should be more thoroughly considered in the 

Transportation section of the DEIS. (LS-23)

Response: Effects from fugitive dust are discussed in the air quality section of the EIS, not in the 

transportation section. The air quality section of the EIS indicates that the Kaibab NF and 

surrounding lands are all classified as being in attainment (meaning “in compliance”) for all 

criteria pollutants of the National Ambient Air Quality Standards. This includes compliance for 

the small-diameter particulate matter (PM10 and PM2.5) that is largely responsible for visibility 

impacts to Class I airsheds. Particulate levels as measured by the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) network are generally low, but episodic events do 

occur (BLM 2011). Heavy equipment used during project implementation has the potential to 

create localized impacts from fugitive dust. With high wind events, this fugitive dust has the 

potential to be carried for several kilometers. Mitigation measures developed for site-specific 

projects can reduce these localized particulate matter emissions, such as reducing travel speeds 

on unpaved surfaces and ceasing work activities during periods of high winds.

Comment: Burning the forest will release radionuclides stored in its soils and vegetation and 

expose citizens to increased radiological doses. (DH-1)

Response: The DEIS did not address the potential effects of prescribed burning to release 

radionuclides. In response to this comment, further research was done, and the findings are 

included in the Air Quality Specialist Report (KNF 2012a) and in the air quality section of the 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 389
Appendix A. Response to Comments

FEIS. Findings indicate that while radionuclides are released during prescribed fire activities, 

the levels are very low and below thresholds that produce a risk to human health.

Cultural Resources

Comment: The Forest Service should cite the United Nations Declaration on the Rights of 

Indigenous Peoples in the Decision and incorporate its policies and procedures. (HOPI-5)

Response: The declaration had not been published when the draft plan was released. It doesn’t 

actually contain policy and procedures, but it does lay out goal statements that are well reflected 

by the plan components in the cultural resources, traditional cultural properties, and traditional 

uses sections. In response to this comment, the declaration is now listed in the plan appendix B 

relevant laws, regulation, and policy, “other” section.

Comment: There should be discussion of the management of sacred sites and ethnographic 

resources that are not necessarily archaeological, a traditional cultural property (TCP), or a 

traditional use area. (KBPI-4)

Response: We added discussion to the management approach for traditional cultural use to 

reflect this comment. The section now states: “The Kaibab NF recognizes that there are important 

tribal sacred sites, ethnographic resources and traditional use areas that may not meet the 

definition of a historic property. The Kaibab NF will work to protect these resources using 

existing authorities in collaboration with federally recognized tribes.”

Comment: We think that heritage resources and TCPs should have been identified as a priority 

needs for change. (HOPI-1)

Response: The four priority needs for change were identified in the AMS by considering key 

issues related to ecological and socio-economic sustainability where the conditions and trends 

indicated the greatest need for a change. Although they did not emerge as a priority need for 

change, heritage resources and TCPs were given full attention during plan development. Through 

collaborative meetings with area tribes, we developed sections of the plan to address cultural 

resources, TCPs, traditional and cultural uses, and the Red Butte Management Area. 

Additionally, we incorporated tribal comments into plan components for a wide variety of 

resources and uses throughout the plan including springs, caves, pinyon-juniper communities, 

recreation, forest products, and mineral and mining activities. See Heritage Specialist Report for 

details.

Comment: TCPs should also be protected from mining activity, not just sites listed on the 

National Register of Historic Places and State highways. (SC-64)

Response: The revised plan contains desired conditions and guidelines to preserve and protect 

TCPs from impacts related to various uses; however the Forest Service does not have the 

discretionary authority to prevent mining of locatable minerals on public domain lands as 

prescribed by the 1872 Mining Law (as amended). 

Comment: Mineral withdrawal authorities should be used to proactively protect sacred sites. 

(HOPI-4)

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Response: The Bureau of Land Management is the agency responsible for mineral withdrawals. 

Therefore, mineral withdrawals are outside the scope of the plan revision decision.

Comment: The guideline “The purposeful excavation of human remains for educational 

purposes, such as research or field schools, should not be permitted” should be a standard. (EBR10)

Response: We concur. The Kaibab NF has had a policy of prohibiting the purposeful excavation 

of human remains for educational purposes such as research or field schools since 1989, as 

articulated in its memorandum of understanding with the Havasupai Tribe, Hopi Tribe, Hualapai 

Tribe, and Kaibab Band of Paiute Indians. This policy was originally framed as a guideline in the 

draft plan, but has been reworded to reflect that it is a standard. 

Comment: The objective of 100 acres of non-project survey is so low; it would take many, many 

years to complete the heritage survey needed to protect cultural resources. The objective for nonproject related cultural resource survey acreage should be increased to better identify and protect 

sites. (KBPI-1, HOPI-2)

Response: We increased the acreage in this objective in the final plan from 100 to 200 acres per 

year in response to these comments and national guidance. In addition to non-project-related 

survey, the Kaibab NF completes an average of 5,000 and 10,000 acres of project-related survey 

each year. Non-project surveys typically entail higher costs per acre due to higher densities of 

archaeological sites in areas of high archaeological interest. The Kaibab NF will continue to 

conduct the maximum amount of non-project survey each year contingent on resources and 

funding.

Comment: Depending on the size and impact of the surface use and occupancy, the “foreground” 

may not be enough. Is this strictly to hide the activity from the public or is it about protecting the 

site/resource? (SC-63)

Response: This comment refers to the standard for mineral and mining activities that “surface 

use and occupancy is restricted to the foreground of heritage sites nominated or listed on the 

National Register of Historic Places.” This standard was originally developed to reduce the 

visual impacts in the immediate foreground of specific areas identified in the 1988 Forest Plan as 

amended. This standard provides plan direction for specific visually sensitive areas. The 

forestwide and management area direction in the plan address resource protection such as those 

related to soils and watershed, recreation, and scenery which provides direction for managing 

scenery and varying distances within the greater viewshed. 

Comment: The plan should replace the words “Kaibab-Paiute” with “Kaibab Band of Paiute 

Indians” to be more accurate and specific. (KBPI-2)

Response: We corrected the wording and the plan and EIS now reflect the more accurate name as 

“Kaibab Band of Paiute Indians.”

Recreation and Scenery

Comment: The EIS should explore and disclose ongoing and expected impacts of climate change 

on winter recreation use and cold-water fishing. (CBD-23)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 391
Appendix A. Response to Comments

Response: Climate change is addressed as an integrated part of the EIS, rather than as a standalone set of desired conditions and effects. The EIS and plan emphasize managing for resistance 

and resilience in forest and grassland ecosystems, which will help protect the recreational 

opportunities available in these ecosystems. The potential effects of climate change on outdoor 

recreation were included in the development of the Forest’s Climate Change Approach (appendix 

D). 

Comment: Efforts should be made to protect viewsheds beyond “the immediate foreground (0 to 

300 feet) in the Desired Conditions for National Scenic and Recreation Trails. The distance 

considered within the view shed should depend on topography, not a straight line distance. (SC68)

Response: The forestwide direction for scenery (as mapped using the Scenery Management 

System) provides complimentary direction for viewsheds beyond the immediate foreground of the

National Scenic and Recreation Trails 

Comment: While we are glad to see that snowmaking will not be allowed at the Elk Ridge Ski 

Area on Bill Williams Mountain, this may not be the only place where snowmaking would be 

requested. (SC-57)

Response: Snowmaking at the Elk Ridge Ski Area was previously evaluated and determined to be 

inconsistent with multiple desired conditions associated with Bill Williams Mountain. As a result, 

guidance was developed specifically for the Bill Williams Management Area. The issue of 

snowmaking in general was not determined to be inconsistent with the plan and would need to be 

addressed on a site-by-site analysis basis due to varying conditions and issues that could arise 

with each proposal. 

Comment: The plan should specifically address the Great Western Trail Route and include 

language acknowledging and preserving this recreation opportunity as well as recognition for the 

need to maintain signage identifying its presence and alignment. (AQ-1)

Response: We agree. In response the following desired condition was added to the plan: “The 

Great Western Trail route can be driven boundary to boundary through each of the districts 

where it occurs. Signage helps to identify and highlight the route.”

Comment: The plan should include provisions for a designated system of backcountry airstrips 

that provide opportunities for recreation aviation including access to internal trailheads. (RAF-1)

Response: The plan would not preclude the establishment of backcountry airstrips; however, any 

proposal would need to go through site-specific analysis.

Comment: Backcountry airstrips could be established on existing closed roads or abandoned 

airstrips, or grassland parks. (RAF-2)

Response: The plan does not preclude the establishment of backcountry airstrips. However, the 

establishment of such areas would require site-specific analysis and decision.

Comment: The plan should allow aircraft in semiprimitive nonmotorized areas due to their 

ability to provide low impact access. (RAF-5)

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Response: Motorized uses are prohibited in areas designated as semiprimitive nonmotorized, 

regardless of impacts.

Comment: The Management Approach that addresses air traffic in the vicinity of Red Butte 

should include language that "Educational brochures distributed by the Arizona pilots association 

will broadcast awareness of this sensitive area, and when tribal events are taking place, APA 

assistance in generating a NOTAM (Notice to Airmen) will route aircraft away from the area.” 

(RAF-6)

Response: The suggested language was not included verbatim because it is too specific in nature, 

but language was added to the management approach section for Red Butte to capture the intent 

of the comment. The management approach for Red Butte now includes the statement: "The Forest 

Service does not have the authority to regulate air traffic (flights), so it is important that the 

Kaibab NF work closely with and educate potential operators about the impacts. When 

temporary closures are in place for traditional or ceremonial use, a request for air operators to 

avoid the area may be made.”

Comment: Recreation aviation should not be considered a special use, but just another legitimate 

method of access. (RAF-9)

Response: While the activity of recreational flying is not a special use, landing requires 

infrastructure and/or accommodation to ensure public safety and resource protection. Such 

infrastructure requires a special use authorization under the policy provided in Forest Service 

Handbook 2709.11. 

Comment: The plan should include a bullet that “Backcountry airstrips are constructed of natural 

material and allowed to return to natural vegetation, and they should be minimally marked 

consistent with safety requirements.” (RAF-4)

Response: The recreation section in the plan already contains guidelines for constructed features 

in the backcountry that already addresses these concerns. The construction and/or maintenance 

of airstrips on the Kaibab NF would require a special use authorization. Should the Kaibab NF 

receive and accept a proposal, a site-specific environmental analysis would be required. If 

approved for authorization, any stipulations or requirements resulting from the analysis would be 

included in the subsequent permit and operating plan.

Comment: The glossary should contain a definition of back country airstrips. (RAF-8) 

Response: The term “back country airstrips” does not appear in the plan, and as such is 

inappropriate to appear the glossary. 

Comment: If there are no appropriate locations for backcountry airstrips, please describe what 

criteria were used and what sites were considered in making this determination? (RAF-11)

Response: The Kaibab NF planning process did not conduct site-specific evaluations for 

backcountry airstrips. The plan would not preclude the establishment of backcountry airstrips, 

but we have no areas that are known to be appropriate for accommodating recreational fly-in 

activities. The determination of the appropriateness of particular locations for backcountry 

airstrips are site-specific in nature and would only be made following an analysis of trade-offs 

and resource impacts.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 393
Appendix A. Response to Comments

Comment: With proper procedures to alleviate potential conflicts with motorized vehicles on the 

ground, open roads may serve a dual role as a backcountry airstrip. (RAF-10)

Response: The plan does not preclude the approval of an open road for use as a backcountry 

airstrip. This is outside the scope of the plan revision process.

Comment: The word “airstrips” should be added to the desired condition statement “Forest 

roads, bridges, and trails provide safe, legal and reasonable access for recreation opportunities.” 

(RAF-3)

Response: Currently there are no airstrips on the Kaibab NF that can provide safe and legal 

access, and it has yet to be determined if there are any locations that might be appropriate in the 

future. This determination can only be made through site-specific analysis. Should an airstrip 

become established in the future, an adjustment could be made to this desired condition 

statement.

Transportation and Forest Access

Comment: The EIS should provide an analysis of the transportation network and its impact on 

physical chemical, and biological forest properties and processes. (CBD-18)

Response: The transportation network recently underwent a site-specific analysis on each of the 

districts as part of the travel management planning process. The plan and EIS are programmatic 

in nature and do not repeat or revisit previous site-specific analysis and decisions. Additionally, 

the EIS analysis is focused on differences among alternatives and potential changes from 

baseline. There was no difference among alternatives with regard to transportation. 

Comment: Forest projects and activities that have the potential to impact the ADOT Right of 

Way on SR 67, SR 64, I-40, HWY 180, and/or HWY 89A should: (1) mitigate sediment, 

vegetation or debris causing track-out (mud) from vehicles; (2) limit the amount of disturbance to 

existing ground cover vegetation to limit erosion in drainages hydraulically connected to the 

storm water conveyances; and (3) implement storm water conveyance BMPs (straw wattles, 

hydroseeding, check dams, etc.) to control sediment in storm water runoff. (ADOT-1)

Response: Activities on these specific roads are outside the scope of the plan revision decision. 

These concerns are addressed through the use of best management practices (BMPs) and other 

activity design elements, which are incorporated into project-level planning and implementation 

in accordance with the memorandum of understanding among the Arizona Department of 

Transportation, the Federal Highway Administration, Arizona Division, and the USDA, Forest 

Service, Southwestern Region Regarding the Construction, Operation, and Maintenance of 

Highways in Arizona Crossing National Forest System Lands. 

Comment: Road closure through wetlands and meadows also should be more thoroughly 

evaluated. (LS-24)

Response: While the plan provides guidance for locating new and temporary roads, site-specific 

road closures are outside the scope of the plan revision decision. All roads on the Kaibab NF 

have gone through recent site-specific planning under the Travel Management Rule.

394 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Livestock Grazing

Comment: The 1982 planning regulations state that suitable and capable lands “shall be 

identified” and that their trend “shall be determined.” This document fails to do this. (EBR-31)

Response: Capability to produce forage for grazing animals was determined for the original 

forest plan (USDA Forest Service KNF 1988). Most landscape-scale conditions that influence 

capability have not changed significantly since the initial evaluation. However, the data and 

analysis tools used in the initial determination were not as accurate or precise as what is 

available today. For this revised plan, capability was revisited using the corporate GIS data. 

Table 2 of the revised plan displays the results of the recent capability analysis. The area capable 

for livestock grazing has about 12 percent fewer acres than the original forest plan. More detail 

about the process and the rationale behind these calculations are documented in the white paper 

“Grazing Capability Calculations for the Kaibab NF” filed in the project record. 

The current forest plan analysis met the regulations for identifying suitable and capable lands 

and trend. Subsequent NEPA analysis for each of the allotments was used to determine trend 

information. The decisions for those analyses were reviewed for areas where livestock grazing 

was not authorized. Site-specific NEPA identified three large contiguous areas that were not 

authorized for grazing following environmental review: the Kanab Creek allotment, Jump-up 

Pasture of the Central Winter allotment, and the Bill Williams Mountain portion of the Hat 

allotment. In the revised plan and other action alternatives, these areas are identified as not 

suitable for livestock grazing. A summary of this analysis is included in the EIS appendix D, 

Grazing Suitability and Capability.

A suitable determination indicates that grazing is compatible with the desired conditions for the 

relevant portion of the plan area. It is guidance for project and activity decision making, and is 

not a commitment or a final decision. It does not mean that grazing will or will not occur in a 

particular area. The final decision to authorize livestock grazing and the determination for how 

lands are managed (including those that have been identified as not capable of producing 

forage), is made at the project or allotment level. The decision to authorize grazing and under 

what conditions is made following environmental review (NEPA) where site-specific conditions 

can be assessed and addressed through project design. 

Comment: The 1982 planning regulations state that those lands “in less than satisfactory 

condition shall be identified and appropriate action planned for their restoration.” This document 

does not meet those requirements. (EBR-32)

Response: Less than satisfactory soil conditions have been identified in the Terrestrial Ecosystem 

Survey data. A majority of the unsatisfactory soils on the Kaibab NF occur on steep slopes or in 

dense pinyon-juniper vegetation that is not typically grazed. The plan lays out desired conditions, 

objectives and guidelines for protecting and restoring soils and watersheds. Restoration of these 

lands would be accomplished through plan objectives such as thinning, fire, and noxious weed 

treatments and implemented through site specific analysis and project-level planning. Priority 

areas were identified in the Watershed Condition Framework. The grazing management 

guidelines in the revised plan state that “annual operating instructions for livestock grazing 

permittees should ensure livestock numbers are balanced with capacity and address any relevant 

resource concerns (e.g., forage production, weeds, fawning habitat, soils, etc.). As a result, if 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 395
Appendix A. Response to Comments

grazing was contributing to the unsatisfactory soils, the grazing management would be adjusted 

through the annual operating instructions. 

Comment: The negative effects of livestock grazing are only superficially addressed in the DEIS. 

The removal of forage as well as disruption of nesting cover can have effects on large and small 

mammals. (WILD-25)

Response: Ongoing grazing effects to wildlife were not specifically called out in the DEIS 

analysis because grazing did not emerge as an issue or high risk factor. Livestock grazing is 

managed through adaptive management and adjustments are made continuously, as resource 

concerns are identified. To provide protection for wildlife, a guideline states “Annual operating 

instructions for livestock grazing permittees should ensure livestock numbers are balanced with 

capacity and address any relevant resource concerns (e.g., forage production, soils, weeds, 

fawning habitat, and other wildlife needs).” This guideline is in addition to livestock grazing 

manual and handbook policy and direction. See appendix H of the EIS for for those species which 

could likely be affected by grazing, (e.g.grassland, meadow, and shrub-dependent species, and 

species needing interconnected habitat), and the plan components that mitigate that risk. 

Comment: The plan should develop alternative ways of grazing to meet the 1982 rule 

requirements. (EBR-34)

Response: We developed alternatives only in response to issues raised. No specific issues were 

raised related to grazing that were not already addressed by the proposed action. We did add 

language to clarify the role of monitoring, adaptive management, and the annual operating 

instructions in the revised plan and action alternatives. 

Comment: The Forest Service should have developed alternatives to address grazing issues such 

as cool season grasses, aspen, riparian systems, water developments, capability/ suitability, and 

the amount of unsatisfactory soils as well as how monitoring has been implemented and what it 

has shown.(EBR-37)

Response: The revised plan contains components to address cool season grasses (livestock 

grazing), aspen, wetland/cienegas, natural and constructed waters, soils and watershed, and 

capability/suitability. Under the action alternatives, there is a desired condition that livestock use 

is consistent with other desired conditions and that annual operating instructions should 

“address any relevant resource concerns.” Under all alternatives, grazing can be reduced or 

adjusted in response to any site-specific resources conditions within any grazing allotment. No 

grazing-related resource issues were raised that could not be addressed with the adaptive 

management strategy included in the revised plan and alternatives. (See livestock grazing section 

of the revised plan and DEIS/FEIS). 

Most range-related monitoring is site-specific and conducted at the project level; however, the 

forestwide monitoring plan does help to ensure effectiveness of grazing management, see 

monitoring questions for soils and watersheds, aspen, natural waters, and livestock grazing. 

Comment: Guidelines for restoring grasslands should include removing grazing in areas where 

native herbaceous cover and seeds sources are sparse. (SC-37)

Response: There is no need for a guideline specific to restricting grazing in grassland restoration 

areas where native herbaceous cover and seeds sources are sparse, because the livestock grazing 

396 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

guidelines in the plan specify that the annual operating instructions should address any relevant 

resource concerns. As such, they would address areas where there is a restoration need for 

understory vegetation establishment. The AMS/CER need for change specified that the primary 

need for grassland restoration is to remove encroaching trees and modify fences for pronghorn 

passage. Removal of trees in encroached grasslands will increase understory. 

Comment: The EIS should provide an analysis of livestock grazing along with the direct, 

indirect, and cumulative impacts. (CBD-19)

Response: The EIS does analyze livestock grazing. Direct, indirect, and cumulative effects on the 

grazing resources can be found in chapter 3 of the FEIS in the Livestock grazing section. Effects 

on other resources from grazing are assessed in their respective sections (e.g. soils, wildlife, etc.). 

Comment: As an identified issue, reduced livestock grazing should have been given a more 

thorough evaluation. (EBR-24)

Response: The Kaibab NF considered a reduced grazing alternative, but did not analyze in detail 

(see chapter 2 of the EIS) because under all of the alternatives the livestock grazing program has 

multiple mechanisms to evaluate, review, and adapt management as needed to effectively protect 

resources and respond to changing conditions. No plan-level changes to the grazing program 

were identified during scoping, only general statements about grazing impacts to watersheds, 

streams, and grasslands. Any site-specific concerns may be addressed on a site-specific basis. 

Comment: Aspen stands and wetland areas should be protected from livestock grazing. (SC-58)

Response: The Livestock Grazing section of the plan provides guidelines for wetlands and aspen. 

We have evaluated wetland and aspen effects from livestock grazing in our livestock grazing 

NEPA analysis since 1992. Where livestock are having long-term effects on these areas, livestock 

exclosures, pasture deferrals, and special utilization limits are being used to reduce these 

impacts. Future evaluations of these areas will further determine livestock impacts and additional 

adjustments will be made, if necessary. The revised plan objectives would restore at least 6 acres 

of wetlands within 5 years of plan approval. The new forestwide monitoring plan includes 

questions that will also help identify any potentially negative impacts from livestock in aspen and 

wetland areas.

Comment: Natural waters should be protected from livestock and nonnative ungulate grazing. 

(SC-52)

Response: The plan components do contain direction for protecting natural waters from livestock 

and non-native ungulate grazing. They include desired conditions for healthy sustainable 

conditions, objectives to “protect and/or restore at least 10 individual springs within 5 years of 

plan approval,” “restore native vegetation and natural water flow patterns on at least 6 acres of 

wetlands within 5 years of plan approval, and “ guidelines that “mitigation measures such as 

deferment and fencing (full or partial) should be implemented as needed to minimize potential 

livestock effects (to natural waters)”, and “annual operating instructions for livestock grazing 

permittees should ensure livestock numbers are balanced with capacity and address any relevant 

resource concerns (e.g., forage production, weeds, fawning habitat, soils, etc.).”

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 397
Appendix A. Response to Comments

Comment: The plan needs to calculate suitability and capability for livestock grazing in a 

scientifically justifiable manner. (EBR-33)

Response: The current forest plan analysis meets the regulations for identifying suitable and 

capable lands and trend. Subsequent NEPA analysis for each of the allotments was used to 

determine trend information. The decisions for those analyses were reviewed for areas where 

livestock grazing was not authorized. Site-specific NEPA identified three large contiguous areas 

that were not authorized for grazing following environmental review: the Kanab Creek allotment, 

Jump-up Pasture of the Central Winter allotment, and the Bill Williams Mountain portion of the 

Hat allotment. In the revised plan and other action alternatives, these areas are identified as not 

suitable for livestock grazing. A summary of this analysis is included in the EIS appendix D, 

Grazing Suitability and Capability.

Capability to produce forage for grazing animals was determined for the original forest plan 

(USDA Forest Service KNF 1988). Most landscape-scale conditions that influence capability 

have not changed significantly since the initial evaluation. However, the data and analysis tools 

used in the initial determination were not as accurate or precise as what is available today. For 

this revised plan, capability was revisited using the corporate GIS data. Table 2 of the revised 

plan displays the results of the recent capability analysis. The area capable for livestock grazing 

has about 12 percent fewer acres than the original forest plan. More detail about the process and 

the rationale behind these calculations are documented in the white paper “Grazing Capability 

Calculations for the Kaibab NF” filed in the project record. 

Suitability is the appropriateness of applying certain resource management practices to a 

particular area of land in consideration of the relevant social, economic, and ecological factors. 

Areas within the plan area are not suitable if livestock grazing would be incompatible with the 

desired conditions or result in substantial and permanent impairment of the land. Determinations 

of suitability consider available science, but are necessarily qualitative analysis. Capability is a 

course filter analysis based on physical characteristics such as soils, slope, and landform. 

Capability is the potential for an area to produce at least 100 pounds of forage per acre, per year. 

It does not indicate the amount of forage produced, but rather the potential for forage to be 

produced. Actual production is dependent on precipitation. 

A suitable determination indicates that grazing is compatible with the desired conditions for the 

relevant portion of the plan area. It is guidance for project and activity decision making, and is 

not a commitment or a final decision. It does not mean that grazing will or will not occur in a 

particular area. The final decision to authorize livestock grazing and the determination for how 

lands are managed (including those that have been identified as not capable of producing 

forage), is made at the project or allotment level. The decision to authorize grazing and under 

what conditions is made following environmental review (NEPA) where site-specific conditions 

can be assessed and addressed through project design.

Comment: The DEIS needs to reveal where water is piped off-site to grazing structures, what 

their condition is, and include standards so this no longer happens. (EBR-35)

Response: The DEIS summarizes the existing conditions of natural waters, but does not provide 

detailed site-specific information. Detailed information on the condition, including modifications, 

of most of the waters (springs) on the Kaibab NF can be found in the project record in a report: 

398 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Ecohydrology of Springs on the Kaibab National Forest to Support Planning (Stevens and 

Ledbetter 2012) 

While there are no standards for preventing water from being piped off of natural waters, there 

are objectives in the plan for restoring springs and wetlands, desired conditions for healthy 

functioning natural waters and guidelines that state “spring source areas should be preferentially 

protected,” “water rights for springs should be secured where there are no existing water rights 

or claims,” and the impacts of management activities on springs, streams, and wetlands should 

be evaluated and minimized.” These desired conditions and guidelines for natural waters would 

not support new modifications that pipe water away from sources, as they would not be consistent 

with the plan direction. 

Comment: Cattle grazing guidelines should be developed to prevent the degradation of reservoir 

banks impacts and important sport fisheries, like those that can be seen at White Horse Lake. 

(AGFD-37)

Response: All sport fishing lakes on the Kaibab NF, including White Horse Lake, are already 

excluded from livestock grazing. Therefore, grazing guidelines for these areas are not needed. We 

are unaware of any impacts to the banks of lakes with sport fisheries except those associated with 

trampling from recreationists.

Comment: The plan should authorize the voluntary permanent retirement of grazing allotments 

by permittees for conservation purposes. (RE-21, WILD-26a, SC-110)

Response: The authority to permanently retire an allotment from grazing is retained by the Forest 

Service and is not held by the permittee. When the Forest Service retires an area from grazing, it 

is typically based on site-specific resource concerns. All of the allotments within the Kaibab NF 

receive annual inspections. Since 1992, all allotments have been analyzed for livestock grazing 

effects through project-level grazing authorization, and as a result, some areas have been 

permanently retired from grazing. This comment is outside the scope of forest plan revision.

Comment: Please add a DC in the grazing section that indicates that grazing duration and 

intensity occurs "at levels that do not conflict with, damage, or otherwise harm valued resources 

including wildlife. (AGFD-33)

Response: This desired condition would be redundant with other direction already included in the 

revised plan. Prevention of harm/damage applies to all activities and resources, not just grazing 

and wildlife.

Comment: We recommend that "concentrated use of montane meadows" be avoided. If options 

elsewhere were limited, we could support light use if adequate rotation occurred, and grazing. 

(AGFD-34)

Response: The full grazing guideline on use of montane meadows is as follows: “The 

concentrated use of montane meadows for livestock grazing should be minimized when soils are 

saturated to reduce grassland impacts. When no other options are available, use should be 

rotated annually.” It is not promoting a concentrated use of the meadows; rather it is stating that 

it should be at a level that prevents grassland impacts. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 399
Appendix A. Response to Comments

Comment: The Department supports utilization decisions that are made on an allotment-byallotment ecological basis, rather than a forest wide decision of 30/40 percent (AGFD-36)

Response: The conservative use levels referenced in the Livestock Grazing Management 

Approach says “in general, the Kaibab NF continues to keep grazing at conservative use levels 

(30 to 40 percent). This grazing intensity, based on percent use of forage by weight, should 

provide for plant integrity, density, diversity, and regeneration over time.” This statement does 

not preclude a different use level following site-specific analysis. 

Comment: There is nothing in the plan to support the assertion that conservative use levels (30 to 

40 percent) will provide for plant integrity, density, diversity, and regeneration over time. (RE-22)

Response: The conservative livestock use level of 30 to 40 percent, which includes native wildlife 

ungulate use, has been evaluated in all the range allotments on the Kaibab NF since 1992. This 

use level leaves 60 to 70 percent of the plants for ground cover, soils, fire spread, hiding cover, 

and forage for other animals and insects. Grazing research supports this level of grazing. 

Conservative utilization leaves residual cover for wildlife and soils, and provides for long-term 

health of the grazed plants (Smith et al. 2005). 

Comment: There should be opportunities for participation and more transparency in the Annual 

Operating Instruction decisions process. This would be particularly helpful for decisions such as 

range readiness after a disturbance event. (AGFD-35) 

Response: There are opportunities for transparency and participation in the annual operating 

instruction process and decisions; however, it is outside the scope of the plan decision. 

Comment: The AGFD Statewide Pronghorn Plan (April 2006) recommends a smooth bottom 

wire greater than or equal to 20 inches above the ground, but the plan says 18 inches. (RE-12)

Response: While the Kaibab NF works closely with the AGFD to meet the needs of pronghorn 

antelope, the AGFD does not set forest policy. The livestock grazing guideline in the plan says 

that “new construction and reconstruction of fences should have a barbless bottom wire that is at 

least 18 inches high. Where needed, the bottom wire may be higher and goat bars are sometimes 

installed to facilitate pronghorn passage, particularly in areas that pronghorn are known to use. 

Fences are designed to keep livestock within a pasture or allotment. When the bottom wire is at 

least 18 inches, there are many places where the fence is 20 inches above the ground due to 

uneven ground conditions.

Comment: The forest plan should use the word “must” with regard to pronghorn friendly fences 

so that the needed modifications actually happen. (RE-13)

Response: In the DEIS and FEIS under “Assumptions” on the first page of chapter 3, it states 

that the “plan provides a programmatic framework that guides site-specific actions, but does not 

authorize, fund or carry out any project activities.” As a result, it does not does not require

actions. The ability to carry out objectives is contingent upon the Kaibab NF’s capacity. 

Pronghorn fence modifications are done in priority areas as resources and budget allow. Many 

fences in areas of known pronghorn usage (high priority areas) have already been modified

Comment: The Forest Service should allow grazing allotment holders to substitute pronghorn for 

cattle in order to address the current population decline. (LS-18, WILD-26b)

400 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: The plan addresses livestock grazing. Livestock grazing allotments on the Kaibab NF 

are not grazed at levels that limit pronghorn populations. Grazing utilization is set for all 

allotments at the conservative level of 30 to 40 percent, leaving at least 60 percent of the forage. 

The NEPA analysis process for each allotment since 1992 has analyzed the effects of livestock 

grazing on pronghorn. Each year, livestock numbers are set in each allotment so livestock 

numbers are matched with annual forage production.

Comment: The plan and DEIS should provide details explaining how the Kaibab NF will provide 

for quality antelope habitat (hiding cover and high quality food resources) and also provide forage 

for nonnative cows and elk. (RE-10)

Response: The plan contains desired conditions for all grasslands including “in pronghorn 

habitat, understory vegetation provides cover for fawning...” and “understory composition is 

within the natural range of variability and contains diverse native herbaceous plant species that 

provide nutrition for pronghorn and other species....” In addition, a desired condition under all 

pinyon-juniper communities states “...the configuration of vegetation and openings provides 

foraging and browsing opportunities for wildlife, and enough sighting distance and hiding cover 

for pronghorn to escape predators.” The plan contains a guideline for the annual operating

instructions for grazing permittees to balance use with capacity and address any relevant 

resource concerns, including wildlife habitat. Use levels are set individually for each allotment, 

but are typically 30 to 40 percent to provide for a suite of desired conditions including wildlife 

habitat, forage, and watershed health. 

Comment: Forage reserves need greater flexibility than the two stated purposes. Wording in the 

guideline should be written with more flexibility to address other potential needs including those 

associated with wolf expansion. (CM-1)

Response: We adjusted the language in the guideline so that it replaces the words “range 

management in times of drought” with “in response to other range management needs.” The 

guideline now reads “As grazing permits are waived back to the Kaibab National Forest, they 

should be evaluated for conversion to forage reserves to improve flexibility for restoring fireadapted ecosystems and in response to other range management needs.”

Comment: The forest should provide the scientific justification for use by nonnative herbivores 

on any Map Unit where the erosion rates are 100 percent and greater of natural. (RE-14a) The 

forest should provide the scientific justification for the use or grazing by nonnative herbivores on 

any map unit where the current litter is less than or equal to 50 percent and the erosion rates are 

equal to or greater than 100 percent of natural. (RE-14b)

Response: The forest plan is not the place to provide scientific justification for livestock use. 

Livestock evaluations are made during allotment analysis in the NEPA process. In addition, the 

TES documents on-the-ground conditions as observed during the field mapping phase of the 

project (i.e., 1979 to 1986). The TES is therefore a somewhat dated and static document with 

regard to the definition of “current conditions.” Soils and watershed conditions are assessed and 

data are collected as part of NEPA analyses for grazing allotment renewals. These data are used 

to support determinations of grazing capacity, utilization, and stocking levels.

Comment: The plan should have a requirement that there is a quantitative and qualitative 

analysis prior to issuing the annual operating instructions showing that there is adequate open 

water for grazing animals and wildlife. (RE-16)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 401
Appendix A. Response to Comments

Response: Guidelines in the Livestock Grazing section of the plan state that the annual operating 

instructions should address “any relevant resource concerns.” While adequate water is one of the 

resources considered, the plan is programmatic in nature and does not specify every aspect of 

day-to-day management. The annual operating instructions are prepared based on the current 

conditions and short-term outlook for forage and water. Adjustments are made throughout the 

season based on actual conditions. 

Comment: The DEIS states that a majority of grazing lands “show an improvement.” What is the 

basis for this statement? (EBR-29)

Response: All allotments within the Kaibab NF were recently analyzed for livestock grazing 

effects since 1992, along with annual inspections. This summary was prepared from these 

allotment-specific analyses and added to the FEIS appendix D, Grazing Suitability and 

Capability.

Comment: The plan should include a drought policy that is proactive and science-based rather 

than subjective based on professional opinion. (RE-17)

Response: The revised plan does not include a drought policy; however, it does address climate 

change in a proactive and integrated way (See appendix D of the revised plan). The Kaibab NF 

“drought policy” is a three-forest policy with the Coconino and Prescott National Forests and is 

outside the scope of the plan decision. 

Comment: The plan should include a set of defensible standards to prevent an overbearing 

industry representative or permittee from insisting that grazing is good for the landscape. (EBR41a)

Response: The Livestock Grazing section of the EIS provides guidelines for livestock grazing. 

Permittees must follow the terms of their permits. Livestock grazing and special use permits are 

prepared to be consistent with the desired conditions in the plan, which was developed 

collaboratively. The Kaibab NF follows the NEPA process in project-level planning for grazing 

authorization, and all individuals have equal standing and opportunity to comment on projects 

and raise issues about the potential effects.

Timber Suitability

Comment: The Forest Service must ensure that timber will only be harvested from National 

Forest System lands where “(i) soil, slope, or other watershed conditions will not be irreversibly 

damaged....” (CBD-5) Timber suitability determinations “shall...be embodied in appropriate 

written material, including maps, and other descriptive documents reflecting proposed and 

possible actions, including the planned timber sale program and the proportion of probable 

methods of timber harvest within the unit necessary to fulfill the plan” (1604(f)(2)). (CBD-4)

Response: The timber suitability analysis for the plan and alternatives was conducted following 

the guidance in the 1982 Planning Rule provisions. The timber suitability process determinations 

and maps are documented in chapter 4 of the revised plan and appendix C of the EIS. Of the 

forested National Forest System lands administered by the Kaibab, the lands identified with a 

potential for irreversible resource damage were identified as unsuitable for all action 

alternatives. The list of proposed and possible actions including mechanical thinning objectives 

and probable management prescriptions are listed in appendix A of the revised plan.

402 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: The Forest Service should consider and analyze lands with high erosion hazard, steep 

slopes, within one tree height of perennial or intermittent streams, unroaded areas, critical habitat, 

areas occupied by threatened, endangered, sensitive, or endemic species, and MIS sensitive 

species conservation areas in the determination of suitable and unsuitable lands for sustained 

yield timber production: (1) High or severe soil erosion hazard identified by Terrestrial 

Ecosystem Survey; (2) slopes steeper than 30 percent; (3) lands within one site-potential tree 

height of perennial or intermittent streams or wetlands; (4) contiguous areas larger than 

1,000 acres without roads in all vegetation types; (5) occupied and/or critical habitat of threatened 

or endangered species or species proposed for listing; (6) designated conservation areas for 

sensitive or management indicator species; (7) occupied locations of endemic species; and 

(8) lands directly impacted by high-severity fire effects to vegetation or soil. (CBD-8)

Response: The suitability determination for the plan and action alternatives excluded areas with 

high erosion hazard and steep slopes, as well as wilderness areas (withdrawn), which contain the 

only perennial streams. Additionally, timber suitability was evaluated for each of the alternatives 

to determine “areas where management prescriptions could not be met.” This resulted in 

alternatives with varying acres of suitable timber. 

The identification of an area as suitable for a particular use or uses is guidance for project and 

activity decision making, and is not a commitment or a final decision and does not mean that a 

particular use will or will not occur in the area. When projects are proposed under plan 

implementation, the appropriateness of timber harvest would evaluate and address site-specific 

resource concerns such as the presence of intermittent streams or wetlands, roadless areas, lands 

directly impacted by high-severity fire effects, and habitat for species that are threatened, 

endangered, proposed, rare, endemic, management indicator, or otherwise of concern.

Comment: Lands designated as suitable for timber production will be managed with the 

assumption that sustained biomass production and harvest for economic purposes is a primary 

objective whether or not it is compatible with other goals such as wildlife habitat or restoration of 

fire-adapted ecosystems. (CBD-7a)

Response: This is not true. Timber harvests do not take precedence over other goals (desired 

conditions) in the revised plan. There is a guideline in the revised plan and action alternatives 

requiring that timber harvests are carried out “in a manner consistent with maintaining or 

making progress toward the desired conditions in this plan.” This ensures they are compatible 

with other goals such as wildlife habitat, watershed conditions, and the restoration of fireadapted ecosystems. “Land Suitable for Timber Production” does not imply that management 

will be focused on maximizing timber yields, only that periodic harvests are expected to occur as 

a tool for meeting and maintaining desired land conditions. 

Comment: Appendix B states that the VDDT model assumes a regulated stand condition in areas 

“Suitable” for timber production. “Although not explicit in the model, it is also assumed that an 

effort would be made to regulate stands so that they are uneven-aged and have a generally 

balanced representation of age classes.” The desired conditions only generally mention 

maintaining age classes over time. What is the definition of a generally balanced representation of 

age classes? (SC-101)

Response: A generally balanced representation of age classes would include approximate 

representation (by percent of area within each stand) of at least three broad age classes: 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 403
Appendix A. Response to Comments

regeneration or young, mid-aged, and mature. In the revised plan, this is provided for in the 

guideline that states “Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across broad age and diameter 

classes at the mid-scale. As such, the largest and oldest trees are usually retained.” 

Comment: Three hundred thousand acres of the conifer forests have been identified as not 

suitable for timber production; this could put these forests at risk. (JK-1)

Response: Areas “not suitable for timber production” may still receive harvests to achieve the 

project-level desired conditions, but they are not managed with the intent of mechanical entry on 

a regular interval that would contribute to the sustained yield of timber over time or maintaining 

an approximate balance of tree age classes. The guideline in the Forestry and Forest Products 

section of the revised plan states that “on lands classified as not suited for timber production, 

timber harvesting should only be used for making progress toward desired conditions (for all 

resources and uses) or for salvage, sanitation, public health, or safety.”

Comment: Table 1 (page 19) of the DEIS shows the outputs related to timber harvest for 

alternative D as zero. This is confusing because the language in the alternative descriptions that 

states, “Mechanical thinning would be used initially to restore the desired forest structure.” (SC88) The DEIS shows that the mechanical thinning acres for ponderosa pine and frequent-fire 

mixed conifer are the same under all alternatives, but does not explain why the outputs in terms of 

allowable sale quantity (ASQ) and long-term sustained yield (LTSY) are different. (SC-82)

Response: We added a footnote to table 1 in the EIS, explaining that ASQ and LTSY are only 

calculated from lands classified as suitable for timber production. Also, LTSY is a concept that 

implies an average yield in perpetuity from regular cutting cycles or rotations. One treatment 

provides one-time yield of products, but not LTSY.

Forestry and Forest Products

Comment: There are only three sawmills left within log haul distance of the North Kaibab, all of 

which are at risk of loss if the preferred alternative is not implemented soon. These mills help to 

achieve the desired conditions on the ground. If we don't act soon, Mother Nature will destroy the 

timber stands and associated flora and fauna. (JK-2)

Response: The desired conditions for forestry and forest products states that a “ sustainable 

supply of wood is available to support a wood harvesting and utilization industry of a size and 

diversity that can effectively and efficiently restore and maintain the desired conditions for 

ponderosa pine and frequent-fire mixed conifer communities. Large projects are currently being 

prepared on the North Kaibab Ranger District under the existing forest plan that will yield wood 

products available for public contracting and purchase. This will continue under the revised 

forest plan.

Comment: The proposed planning area is adjacent to several forest-dependent communities that 

stand to gain significant financial benefits from the direct and indirect effects from natural 

resource management, through employment and local business sustainability. (KCC-1)

Response: We recognize the Kaibab NF’s roles and contributions it makes to local communities. 

With implementation of the Kaibab NF restoration objectives in the proposed plan, income and 

employment are expected to increase substantially. See EIS tables 53, 54, and 55. 

404 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: How do the guidelines for firewood gathering link with the desired future conditions 

for major vegetation community types? The guidelines do not have size (or location) restrictions 

for dead and downed firewood gathering. (SC-60)

Response: Personal and commercial fuelwood is to be consistent with the desired conditions for 

the particular area. All fuelwood gathering that receives site-specific NEPA analysis is managed 

through permits, which can be tailored as needed to meet any site-specific resource concerns. 

Comment: Firewood removal should be excluded from PACs, PFAs, and the Kaibab Squirrel 

Area. (SC-61)

Response: There already are guidelines that limit disturbing activities near PACs and PFAs and 

desired conditions to provide for key habitat components. Under Threatened, Endangered, and 

Sensitive species, guidelines state that “project activities and special uses occurring within 

federally listed species habitat should integrate habitat management objectives and species 

protection measures from approved recovery plan; Project activities and special uses should be 

designed and implemented to maintain refugia and critical life cycle needs of Forest Service 

Sensitive Species..” The Kaibab Squirrel National Natural Landmark (NNL) designation is not a 

land withdrawal and does not direct or prohibit any activity. The needs for the NNL are addressed 

in the forestwide direction for the ponderosa pine vegetation type. There has been no evidence 

that legal firewood removal has adversely affected Kaibab squirrel habitat.

Comment: The term “moulding” instead of “molding” should be used to refer to the wood 

product used for decorative purposes. (PR-1)

Response: We changed the spelling of this word in response to this comment. 

Energy Transmission and Development

Comment: The Kaibab should aim for consistency with Coconino County’s guidelines when 

considering new energy projects. (SC-62)

Response: The Forest Service has agency-specific guidance in law, regulation, and policies 

established at the national level. When considering new energy projects, the Kaibab NF seeks 

consistency with the county guidelines (Coconino, Yavapai, and Mohave), but if there are 

conflicts with Federal laws, regulations or policy, Federal guidance takes precedence. We added 

language to the plan in the management approach section for energy transmission and 

development to work with the counties to ensure consistency where practicable. 

Comment: The plan should refer to the recommendations by the Avian Powerline Interaction 

Committee for new and retrofitted powerlines (DOI-21). Add standards from the Avian Power 

Line Interaction Committee (APLIC) standards for any above ground transmission lines (AGFD39). Add a DC that makes reference to energy development that is in balance with other 

resources being managed such as wildlife. (AGFD-40)

Response: The management approach section of the plan now states “work closely with the 

AGFD and Federal agencies to incorporate the Avian Power line Interaction Committee 

recommendations for new and retrofitted power lines”. The suggestions to include the standards 

from the APLIC were not incorporated into the revised plan. The APLIC is a tool used during the 

analysis of any new proposed power line and mitigation would be done at a project level. Adding 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 405
Appendix A. Response to Comments

this desired condition to balance with other resources would be redundant because there is 

already the following desire condition: “Energy transmission and development on the Kaibab 

National Forest meets the legal mandates to facilitate the transmission and development of 

energy resources in a manner that minimizes adverse impacts and does not detract from meeting 

other desired conditions applicable to the area.”

Comment: We would like the plan to have a guideline that makes direct reference to working 

with USFWS and AGFD for reducing impacts to wildlife from energy development. The forest 

should indicate to developers at the Plan level that it is essential to work with wildlife agencies 

early in the process. (AGFD-41)

Response: This suggestion was not incorporated due to it not meeting the requirements for a 

guideline. However, in the wildlife section for management approach for wildlife it references the 

need to work with USFWS and AGFD along with other federal, state and non-government groups 

on the management of wildlife species. 

Minerals and Mining

Comment: The recent Canyon Mine decision is not consistent with the desired conditions and 

guidelines in the proposed plan (HOPI-3)

Response: The Canyon Mine decision was consistent with the forest plan that was in place at the 

time of the decision. Decisions must be consistent with the plan in place at the time they are 

signed, and as a rule, are not revisited.

Comment: The plan should include a set of defensible standards to prevent an overbearing 

industry representative or permittee from insisting that mining is good for the landscape. (EBR41b)

Response: The plan contains standards and guidelines aimed at minimizing adverse impacts from 

mineral extraction and mining activities on sensitive forest resources. Most of the guidance for 

mining is governed by law, regulation, and policy, which are outside of the scope of the forest 

plan. The Kaibab NF follows the NEPA process in permitting new mineral extraction and mining 

activities, and all individuals have equal standing and opportunity to comment on projects and 

raise issues about the potential effects of mineral extraction and mining activities. 

Arizona Bugbane Botanical Area

Comment: The revised plan should fully incorporate and integrate the May 1995 Arizona 

bugbane (Cimicifuga arizonica) Conservation Assessment and Strategy into the “Guidelines for 

the Arizona Bugbane Botanical Area.” (DOI-10)

Response: We reviewed the conservation agreement to ensure that the plan-level strategies were 

addressed. The plan does contain desired conditions and guidelines that reflect the guidance in 

the agreement. One guideline was added that had previously only been implied that “Wildfires in 

the Botanical Area should be suppressed when high severity fire is anticipated and it is safe to do 

so.” Additionally, the plan references the conservation agreement between the Fish and Wildlife 

Service and Forest Service for the Arizona bugbane in appendix B under other law, regulation, 

and policies.

406 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Double A Wild and Free Roaming 

Burro Territory

Comment: The number of burros maintained in the Double-A Wild Burro Territory should be 

modified to account for that fact that fertility treatments increase lifespan of equines (Turner and 

Kirkpatrick 2002). (SC-65)

Response: The plan guidance for the Double A Wild Burro Area states that a “biologically sound 

and genetically viable burro population is in balance with native wildlife, permitted livestock, and 

other resource values” and that “population control measures should be implemented to maintain 

genetic diversity and desired resource conditions in the area.” The potential lifespan of burros is 

a consideration that would be relevant to project planning and potential management activities 

achieving the desired condition, but is outside the scope of the forest plan decision.

Comment: All wild horse and burro populations near Grand Canyon National Park should be 

carefully monitored to be sure that animals are not travelling toward the park. (SC-66)

Response: The Double A Burro Territory is approximately 50 miles from Grand Canyon National 

Park. We have no information indicating that these burros travel anywhere near the park 

boundary. If it is necessary to monitor these populations, it might be done to support day-to-day 

management, but it is not within the scope of the plan because it is not responsive to and does not 

directly address any plan components. 

Comment: We would like to see an objective to reduce the burro population in the Double A 

Wild Burro Area below the permitted number by a specified time. (AGFD-44)

Response: The Forest Service coordinates management of the Wild Horse and Burro program 

with the Bureau of Land Management including maintaining the desired burro herd size. The plan 

established objectives for only the greatest resource needs and considered the anticipated budget 

and capacity for the plan period.

National Scenic, Historic, and 

Recreation Trails

Comment: In the National Recreation Trail section of the plan there is an error, “National Scenic 

Trail” should be changed to “National Recreation Trail.” (SC-67)

Response: We agree and have made the correction.

House Rock Wildlife Area

Comment: Bison hybrids should be confined to the Buffalo Ranch MA to protect 

montane/subalpine grasslands and the semi-desert grasslands outside of the Buffalo Ranch MA. 

(SC-39, SC-41) Bison hybrids and Rocky Mountain elk are both nonnative and their continued 

presence could take a heavy toll on forest resources. Management direction is needed for these 

species to minimize their impacts. Coordination is needed with neighboring Federal land 

managers (i.e., Grand Canyon National Park) to ensure that these nonnative wildlife species do 

not harm forest resources, or those on adjacent Federal lands. (LS-19, WILD-15)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 407
Appendix A. Response to Comments

Response: Point of information: The “Buffalo Ranch Management Area” is now called the 

“House Rock Wildlife Area.” It has been referred to as the House Rock Wildlife Area for several 

years, but the forest plan language had not been updated to reflect it. The Kaibab NF recognizes 

that there are resource concerns associated with bison outside the House Rock Wildlife Area. The 

proposed plan contains two guidelines that address this concern: “The bison herd should be 

managed to be concentrated within the House Rock Wildlife Area,” and “Active management 

should be used to minimize impacts from bison to sensitive resources, particularly outside the 

House Rock Wildlife Area.” Currently, there are bison on the Kaibab Plateau and in Grand 

Canyon National Park. We clarified this concern by adding language to the management 

approach for the area which now states “Coordination and cooperation between the Kaibab NF, 

AGFD, Grand Canyon National Park, and researchers will be needed to identify workable 

solutions for managing the bison which are now spending much of their time on the remote 

forested points of the Kaibab Plateau. Efforts to achieve the desired conditions will likely be 

phased with the initial emphasis to reduce the herd size and to exclude them from Grand Canyon 

National Park. Strategies may include intensive hunting and trapping, fencing, and herding.”

Comment: The buffalo desired condition should be revised for accuracy. The MOU for bison 

management does not specify a maximum herd size. Similarly, the guidelines state that bison 

"should be confined' to the area identified in MOU, but the MOU does not define an area to 

which the bison must be confined. (AGFD-49)

Response: We agree and the corrections have been made. The desired condition now reads “The 

bison herd size is in balance with ecological conditions in the House Rock Wildlife MA.” The 

guideline now reads “The bison should be managed so that the herd is concentrated within the 

House Rock Wildlife MA.” Note: the management area name was changed from the “Buffalo 

Ranch Management Area” to the “House Rock Wildlife Management Area” in the final revised 

plan. 

Pediocactus Conservation Area

Comment: The revised plan should fully incorporate and integrate the October 1996 Paradine 

Plains Cactus (Pediocactus paradinei B.W. Benson) Conservation Assessment and Strategy into 

the “Guidelines for the Pediocactus Conservation Area.” (DOI-9)

Response: The conservation agreement for the Paradine plains cactus is currently being updated 

and we anticipate that the agreement may be updated again during the life of the plan. As a 

result, the plan references the conservation agreement rather than incorporating and integrating 

its components. 

Comment: The Kaibab Plains Cactus Conservation Area should only allow low-intensity surface 

fires, or fires be suppressed if conditions lead to higher intensity fire. (DOI-13)

Response: We added a guideline to the plan stating that “Wildfires in the Pediocactus 

Conservation Area should be suppressed when high-severity fire is anticipated and it is safe with 

respect to firefighter safety.”

Research Natural Areas

Comment: There should be research natural areas designated for each of the major habitat types 

on the forest, as well as selected natural ponds/lakes, springs, and caves. (LS-22, WILD-27)

408 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Response: Research natural areas (RNA) are a type of special area within the National Forest 

System (NFS), designated for their unique or special characteristics with the intent that they be 

designated for the purposes of research and establishing reference sites. They are established and 

managed jointly by the Kaibab NF and the Forest Service (Rocky Mountain) Research Station. 

Guidance for selecting and establishing RNAs within the NFS primarily comes from Forest 

Service Manual direction (FSM 1920 and FSM 1950). The NFS objective is to have an effective 

ecological distribution of RNAs across major climate gradients and biophysical settings 

(potential natural vegetation types or PNVTs). In identifying RNAs, we considered the distribution 

of existing RNAs within the region (inside and outside the agency), specifically looking for 

underrepresented vegetation types where there was little evidence of major human disturbance. 

There is no intent for RNA representation for each major habitat type on an individual forest. We 

evaluated two areas for RNA potential and neither met the conditions appropriate for

establishment. If, in the future, the Kaibab NF or forest research station identifies an area that 

meets the RNA intent and criteria, it may be evaluated and recommended at that time. A full 

description of the Kaibab NF RNA analysis can be found in appendix G of the EIS.

Comment: It is unclear why Garland Prairie does not qualify as a Research Natural Area. (LS14-WILD-28)

Response: Garland Prairie was evaluated but not recommended as a potential RNA because 

(1) the montane grassland PNVT is not an underrepresented vegetation type, (2) it does not

contain sensitive species or unique ecological features, (3) its proximity to I-40 and the railroad 

interrupts the potential for natural processes (fire) from playing their natural role, and (4) it is 

currently encroached by trees and contains nonnative invasive plants that would benefit from 

treatment. Documentation of the RNA evaluation process can be found in appendix G of the EIS. 

The Kaibab NF does recognize the importance of the Garland Prairie Management Area as a 

reference site and its value for research.

Comment: North Canyon hosts a remarkable array of unique species and should be the subject 

of intensive inventory and considered as a candidate for Research Natural Area (RNA) status. 

(LS-6)

Response: While we agree that North Canyon contains unique species and has high biological 

values, it was not considered as a RNA for two primary reasons: 1)Mixed conifer vegetation is 

already well represented in the system of RNAs and need was the first filter used in the RNA 

evaluation process; 2) North Canyon is in the Saddle Mountain wilderness where it will already 

be managed to maintain its pristine condition. 

Economics

Comment: The DEIS did not discuss the benefits and costs of alternate strategies. (EBR-5)

Response: The EIS discussed the costs and benefits of the alternate strategies (alternatives) that 

were proposed or developed in response to issues raised. This analysis can be found in the 

Economics section of the EIS in Chapter 3. 

Comment: The DEIS should discuss and look at different ways of meeting or maximizing net 

public benefit as required by NFMA. (EBR-38, CBD-1)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 409
Appendix A. Response to Comments

Response: Section 219.1 − Purpose and principles - (a) states that the plans shall provide for 

multiple use and sustained yield of goods and services from the National Forest System in a way 

that maximizes long-term net benefits in an environmentally sound manner. Section 219.3 defines 

net public benefits as: “An expression used to signify the overall long-term value to the nation of 

all outputs and positive effects (benefits) less all associated inputs and negative effects (costs) 

whether they can be quantitatively valued or not. Net public benefits are measured by quantitative 

and qualitative criteria, rather than a single measure or index such as Present Net Value (PNV).” 

We developed alternative ways to maximize net public benefit in response to comments received 

and alternatives evaluated in the EIS.

Costs and revenues, by program area (including range, wildlife, watershed, and recreation) 

appear in tables 56 and 57 in the FEIS. The PNVs, by program area and alternative, are shown in 

table 58. Alternative B is the most financially efficient based on PNV . The identification of the 

alternative that comes nearest to maximizing net public benefits is determined by the deciding 

official in the record of decision based on all effects including PNV, multiple uses, environmental 

and social factors that are displayed in the EIS.

Comment: The economic analysis should provide detailed information about the contributions, 

values, and revenue generated from different recreation activities as well as the costs associated 

with administering such activities. (RE-6)

Response: Information on the contribution to income and employment from the Kaibab NF 

recreation program was factored into the IMPLAN1 economic analysis and is displayed in table 

51 of the EIS. The costs, revenues, and PNV associated with the recreation program appear in 

tables 56 through 58. The costs for all program areas, including recreation, exceed revenues 

(dollars) received.

Comment: The economic section should provide an honest assessment of returns to the treasury 

and costs to the public about livestock grazing. (EBR-23)

Response: The cost and revenues by program area are reported in the economic section of the 

plan. Detailed analysis of the grazing program was not provided because there was no difference 

between alternatives with respect to grazing. 

Comment: Timber suitability designations must apply a cost-benefit analysis and "stratify" 

national forest lands by allowable timber management intensity (1604 (k). (CBD-6)

Response: Table 59 in the EIS displays a benefit-cost analysis by various forest resources and by 

alternative. Table 59 presents present net value (PNV) by program area and alternative. PNV is 

the difference between program revenues (benefits) and program expenditures (costs) over a 10-

year period, using a 4 percent discount rate. All alternatives result in a negative PNV. Alternative 

A is the least negative, while alternative D has the highest negative PNV. The differences in PNV 

for the alternatives are a function of the presettlement tree in guideline in alternatives C and D as 

1 IMPLAN (IMpact analysis for PLANing, Minnesota IMPLAN Group, Inc.) is a regional economic impact analysis 

system that uses county level, input-output data to determine the extent to which these activities (such as livestock 

grazing) contribute to the local economy. Input-output analysis is an economist’s tool that traces linkages among the 

structural parts of an economy and calculates the employment, income, and output effects resulting from a direct 

impact on the economy.

410 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

 
Appendix A. Response to Comments

well as differing acres of suitable timberland. The process for identifying suitable timberland 

classifies types of unsuitable lands (withdrawn/wilderness, non-forested, irreversible resources 

damage, etc.), but does not have differing levels of allowable timber management intensity. The 

amount and intensity of timber harvest depends on the needs to achieve or maintain desired 

conditions and is made following site specific analysis. 

Comment: The economic analysis should provide detailed information about the consumptive 

and non-consumptive wildlife opportunities. (RE-5)

Response: Information regarding recreation opportunities (including those related to wildlife) is 

found in the Recreation section of the EIS. The economic analysis (efficiency and impact analysis)

includes those activities associated with wildlife. See EIS tables 51, 56, 57, and 58.

Comment: The FEIS should provide more detailed analysis about the costs and effects of grazing 

by nonnative ungulates on the limited forage and water for wildlife, soils, species composition, 

plant vigor, natural fire, and aspen so that the public may provide meaningful input into Forest 

Service decisions affecting this private-commercial use and competition for limited resources and 

the deciding official can consider the financial costs verses impacts to native species and 

ecosystems to determine the highest and best use of forest resources. (RE-7)

Response: When the Kaibab NF gathers utilization information on the amount of forage 

consumed by grazing, it does not distinguish between livestock and wildlife. It is not possible to 

determine how much is grazed by which species. The financial costs and revenues associated with 

livestock grazing on the Kaibab NF are part of the range, watershed, and wildlife program. 

Activities conducted under this program often are designed to improve range and watershed 

condition for both livestock and wildlife simultaneously. 

Comment: There are errors in acreage on table 53 that carry over to table 55. This 

underestimates the socio-economic benefits and outputs. (KCC-4)

Response: We agree and have made the corrections in the FEIS.

Comment: The short-term financial benefits of timber harvest fails to offset the long-term costs 

of loss of soil productivity, compaction, exposure, erosion, reduced habitat quality, etc. These 

effects should be analyzed in a cost-benefit analysis. (CBD-7b)

Response: Table 58 displays revenues by alternative. Table 59 displays present net value (PNV) 

by alternative, which is a cost benefit or financial efficiency comparison. PNV is the difference 

between program revenues (benefits, and program expenditures (costs). These tables do not apply 

monetary values to positive and negative environmental effects of the alternatives. Chapter 3 of 

the EIS discloses the positive and negative short- and long-term effects of mechanical harvesting 

for the specified affected resource areas including the approximate costs. The selected alternative 

focuses on restoration of ecosystem resiliency, in ways that enhance protection of watersheds, 

soils, habitat and other resources. Implementation of the preferred alternative will not result in 

long term loss of soil productivity or habitat quality. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 411
Appendix A. Response to Comments

Monitoring and Adaptive 

Management

Comment: The EIS for plan revision is an appropriate vehicle for proposing monitoring 

protocols that can be reliably implemented to support restoration-focused adaptive management. 

(CBD-70)

Response: We agree that forest plan monitoring provides the mechanism to enable and support 

restoration-focused adaptive management. Chapter 5 of the plan identifies the monitoring 

questions to be answered; however, the protocols and methodologies for answering those 

questions are not specified in the plan, but in a supporting monitoring and implementation guide. 

This is to ensure the plan is flexible and responsive to new information, emerging issues, and 

recommended changes to protocols without requiring a plan amendment. See the plan, chapter 5, 

Monitoring and Evaluation introduction section. 

Comment: The monitoring plan can only be judged based on how well the last one worked. In 

many, many cases planned monitoring never occurred. (EBR-19)

Response: Forest plan monitoring occurs on an annual basis and is reported in the annual 

monitoring reports, which may be found on the Kaibab NF website at 

http://fs.usda.gov/goto/kaibab/plan_revision. Not all monitoring items are required every year, 

and some of the monitoring items identified in the original forest plan were never appropriately 

funded and did not inform achievement of plan components.

Comment: Neither the proposed plan nor the current one has any consequences if monitoring 

does not get completed. It is arbitrary and capricious to rely on monitoring to drive future actions 

when it does not always occur. (EBR-20, EBR-21) How will the Forest Service ensure that 

monitoring and enforcement are maintained given limited funding and resources? (SC-69)

Response: There are legal requirements for conducting a wide range of resource-related 

monitoring. However, the monitoring plan is based on the Kaibab NF’s intent based on an 

assumption of recent and relatively stable budgets. Within that context, the Kaibab NF is 

committed to integrating monitoring with its management decisions as discussed in chapter 5 of 

the plan. By focusing on effectiveness monitoring and movement toward desired conditions, the 

Kaibab NF will be better able to assess future actions. If funding is significantly decreased, it is 

expected that both monitoring and implementation would be less than what is planned. Allocation 

of monitoring funds is outside the scope of the plan and EIS. 

Some monitoring requirements and consequences vary by resource area, and are often driven by 

other law, regulation, and policy, and regulation, which is outside the scope of the plan and EIS. 

If funding for monitoring is lower than in recent years, the monitoring plan may need to be 

adaptively adjusted to reflect the new funding levels.

Comment: The plan states that a more prescriptive monitoring implementation guide will be 

developed later. This needs to be developed first and revealed to the public. (EBR-28)

Response: The relevant monitoring questions are specified in the plan, but the specific 

procedures, methods, and analysis are necessarily developed and maintained outside the plan so 

that they may be adjusted as necessary to reflect current science and analysis. A draft monitoring 

implementation guide for some of the monitoring plan questions (e.g., rapid plots) is available on 

412 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

the Kaibab NF planning website at http://fs.usda.gov/goto/kaibab/plan_revision). This 

implementation guide was developed collaboratively using the best available science, and will be 

refined and evaluated over time as it is implemented.

Comment: The forest should build a large-scale ecosystem conceptual model. Such models have 

been developed for other forests and ecosystems throughout the West, and provide essential 

information about data gaps, climate-related changes in productivity, and ecological linkages that 

may greatly help improve monitoring and adaptive management. (LS-7, WILD-3)

Response: While a specific large-scale conceptual model was not built for this plan revision, we 

used a comprehensive and integrated approach. We recognize the value of such models and invite 

the commenter and others to help build such a model that would serve to guide future 

management and plan implementation over time; however, this is outside the scope of the plan 

decision.

Comment: Given that ecosystem management based on natural disturbance regimes will always 

be somewhat uncertain, conservation biologists urge use of the precautionary principle. As a 

result, restoration should target areas most likely to benefit from active intervention and be 

confined to small spatial scales and accompanied by monitoring and evaluation sufficient to 

inform adaptive management. (CBD-69)

Response: There is strong scientific support for restoring ponderosa pine ecosystems in the 

Southwest, and the effects are well known. The risks of loss associated by doing nothing often 

outweigh the potential short-term adverse effects of thinning and burning. While there is a lot of 

variation as mixed conifer vegetation ranges from the warmer/drier sites to cool moist sites and 

there are fewer peer-reviewed studies for restoration of mixed conifer compared to ponderosa 

pine, the effects are not unknown. In recognition that there is a level of uncertainty, the revised 

plan does exercise the precautionary principle as demonstrated by the guideline that “vegetation 

management activities in mixed conifer forests should incorporate experimental design features 

and monitoring to accelerate learning and adaptive management.” The relevant spatial scale and 

size of a project depends on the objectives and questions asked; there is no one-size fits all 

answer. These site-specific questions must be determined at the project level and are outside the 

scope of the plan and EIS.

Additionally, there are, however, several monitoring questions in chapter 5 of the plan responsive 

to proposed forest restoration efforts at the forestwide level that were developed to evaluate the 

effects and effectiveness of treatments, facilitate learning, and help to enable adaptive 

management.

Comment: Periodic assessments of wilderness areas are needed to ensure that valued species and 

habitats remain sustainable, and that such areas are not subject to nonnative species invasions.

(LS-26)

Response: The plan does contain objectives for monitoring for trails and campsites in wilderness 

and for noxious weeds. Additional wilderness and weed monitoring outside the forest plan 

monitoring is conducted as funding and resources are available. 

Comment: There is currently a monitoring question “does habitat configuration provide 

functional connectivity for pronghorn?” We recommend also considering a corollary for closed 

habitat conditions such as black bear or grey fox. (AGFD-33)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 413
Appendix A. Response to Comments

Response: We added language to the desired condition statement to ensure it is clear that 

functional connectivity is desired for closed-canopy species as well. A corollary question was not 

added to the monitoring plan because questions were developed to be within the capacity of the 

existing budget. Evaluating functional connectivity for pronghorn is a higher priority because it 

directly relates to a priority need for change and pronghorn is also a management indicator 

species.

Additionally, the rapid plot and remotely sensed forest structural data collected to address other 

monitoring questions will be used to answer questions for species with closed-canopy needs.

Comment: The monitoring plan matrix asks the question 'how many acres of the forest is in an 

uneven aged open state at the midscale (above 100 acres)? While presettlement evidence suggests 

that this would be the dominant condition at the midscale, we know that patches of forest in an 

uneven aged "closed" state existed at the fine scale and perhaps in some small proportion at the 

midscale because wildlife that depend on those conditions are still present today. We suggest 

adding a monitoring question that addresses and tracks this issue (AGFD-53) 

Response: The monitoring plan focused on those questions that were most important to answer to 

determine the effectiveness and or need for change in management (e.g. reducing the threat from 

uncharacteristic wildfire) across the forest. The question 'how many acres of the forest is in an 

uneven aged open state at the midscale (above 100 acres)?” informs achievement of specific midscale desired conditions (the mosaic of tree groups generally comprises an uneven-aged forest 

with all age classes and structural stages present). The fine scale desired conditions include wide 

ranges and variability between groups. If specific questions related to specific wildlife species 

arise, and there is a need to further characterize the amount and arrangement of the open and 

closed patches at the fine scale it could be done at the project level using stand exam and or rapid 

plot data. Rapid plots are designed to capture data at the fine to mid-scale. A complete 

description of the rapid plots and associated monitoring questions and sampling methodology 

can be found in the “Rapid Plot Monitoring and Statistical Guide”. While not part of the forest 

wide monitoring plan, this document was developed to help with its implementation. It can be 

found on the Kaibab NF website: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5438937.pdf

Comment: We would like to see greater emphasis on oak and specific monitoring objectives to 

address oak separately from general ponderosa pine forest. (AGFD-50)

Response: While there are no monitoring questions in the plan specific to oak, the rapid plot 

protocol mentioned in the preceding response (which is more detailed and not in the plan) does 

collect data that would inform the plan desired conditions for oak which acknowledges its 

importance for wildlife.

Comment: We recommend separating the two vegetation (ponderosa pine and frequent fire 

mixed conifer) types in terms of monitoring questions, metrics, and methods to assess progress 

toward desired conditions in each type. (AGFD-51)

Response: The questions for ponderosa pine and frequent fire mixed conifer are only combined 

because the questions are relevant to both resource areas. Each vegetation type would be 

assessed separately because they have differing desired conditions. 

414 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: Consistent with our recommendation to consider the full range of aspen treatment 

methods, we suggest including additional monitoring metrics and objectives that relate to other 

treatment methods. (AGFD- 52)

Response: The monitoring plan questions for aspen are limited to achievement of desired 

conditions and objectives in the plan. Questions related to treatment effectiveness are projectlevel or research in nature.

Comment: Consistent with our recommendation to consider the full range of aspen treatment 

methods, we suggest including additional monitoring metrics and objectives that relate to other 

treatment methods. (AGFD-14)

Response: We agree this is an important consideration to include in project design, particularly if 

some of the goals are to evaluate experimental treatments and effects on aspen recruitment. 

However, these additional monitoring metrics, treatment methods, and objectives will be 

considered at the project level, and are outside the scope of the plan and EIS.

As described in chapter 5 of the plan, the monitoring plan is adaptive in nature, and additional 

plan-level monitoring metrics or questions may be deleted, added, and or modified over time as 

our understanding about forest management evolves. 

Comment: Chapter 5, table 5 of the draft plan includes the monitoring question “Are Mexican 

spotted owls present in PACs?” We recommend also asking the question “Do Mexican spotted 

owls occupy potential nest/roost habitat?” (DOI-6)

Response: The Kaibab NF monitoring plan commits to monitor and report on PAC occupancy at 

regular intervals. The Kaibab NF did not include this question because it does not consistently 

have the resources to broadly monitor potential nest and roost habitat on regular intervals. Nest 

and roost habitat and occupancy monitoring is typically conducted where it is potentially affected 

by project actions as agreed upon during the consultation process with the USFWS. 

Comment: The Forest Service should monitor aquatic macroinvertebrates in areas that might be 

at risk from uranium contamination. This is especially important since hikers frequent Kanab 

Creek and several use water from the creek or nearby springs for drinking and bathing. (SC-104)

Response: Water quality and spring inventories and monitoring have been and will continue to be 

conducted on the Kaibab NF. Determining the biological pathways for uranium contamination is 

a research question that would need to be refined, tested, and validated. This is outside the scope 

of the plan and EIS.

Comment: The monitoring plan should include registration boxes at back country airstrips to 

track the numbers, frequency of use, and seasonal statistics. (RAF-7)

Response: There are currently no back country airstrips on the Kaibab NF, and therefore no need 

to monitor use. 

Climate Change

Comment: The Forest Service should recognize and disclose changes in climate and the 

implications for natural resource availability and multiple-use for current and future generations. 

(CBD-10)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 415
Appendix A. Response to Comments

Response: The revised plan for the Kaibab NF does address changes in climate and the 

implications on land management planning. See appendix D of the plan for a summary of the 

Kaibab NF’s approach to climate change for plan revision. Climate change is addressed directly 

in the revised plan in the management approaches and the monitoring plan where appropriate. 

Climate change is addressed indirectly throughout the plan through desired conditions that 

represent elements of functional ecosystems and resilient landscapes. 

Comment: The EIS must assess and disclose the potential contribution of managing multiple 

uses and activities that may contribute to or compound changes to climate systems including but 

not limited to groundwater extraction, surface water diversions and withdrawals, road use and 

construction, livestock grazing, fire and fuels management, mining, logging, and invasive species 

spread. (CBD-52)

Response: Multiple use and other activities are consistent with desired conditions for other plan 

resource areas and were considered in the effects analyses. Further, the plan components were 

developed to account for climate change such as resilience and adaptability (plan appendix D). 

Therefore the plan components assessed and disclosed in the FEIS account for climate change 

effects in the respective resource areas. Climate change is discussed throughout the EIS. See the 

Species Viability, Watersheds and Soils, Water Resources, Livestock Grazing, and Vegetation and 

Fire Sections for additional discussion.

Comment: Forest management can help mitigate global warming by helping to avoid emissions 

and by helping our forests grow. The EIS should consider and disclose the potential 

environmental consequences associated with continued commercial harvests. (CBD-53)

Response: Additional analysis has been added to the FEIS that discloses the potential 

environmental effects and compares alternatives with respect to carbon storage and 

sequestration. The analysis indicates that the plan (proposed action) is most effective at 

sequestering and storing carbon because it reduces the risk of uncharacteristic stand-replacing 

fire and reduces competition, which increases tree growth and carbon sequestration. Additionally, 

perennial grasses sequester more carbon when they receive more light, which more than offsets 

the soil carbon loss that occurs when temperatures rise as a result of exposure. Commercial 

harvests that result in creation of durable wood products can store carbon over long timeframes 

(Huang et al. 2013, Hurteau and North 2009). 

Comment: A recent report from the Food and Agriculture Organization of the United Nations 

found that livestock are responsible for eighteen percent of all greenhouse emissions. Livestock 

grazing is widespread on NFS lands and the contribution of grazing to climate change must be 

assessed and disclosed. (CBD-54)

Response: Concentrated animal feeding operations (feedlots which may have 50,000 + head) 

are known to contribute to CO2 emissions because they have high concentrations of decomposing 

manure being stored in large quantities, which releases methane and CO2 into the atmosphere. 

Grazing on the Kaibab NF is very distributed and the number of livestock on forest at any given 

time is minimal. Additionally, manures are not composted. They are dispersed, and when , they

decompose, they contribute to soil organic carbon and are available as soil nutrients for plants 

for uptake and carbon sequestration. This offset, results in total emissions being extremely low 

and was therefore not included in the EIS. Additional documentation was added to the project 

record. 

416 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

Comment: The EIS must address the emerging issue of biomass and how the biomass industry 

could affect the national forest and climate change impacts. (CBD-57)

Response: The plan components were developed considering climate change and climate effects 

(see appendix D of the plan), and these effects were evaluated in the EIS. The plan and EIS 

address biomass utilization indirectly, recognizing that biomass utilization would help accomplish 

the objectives of the plan. The biomass industry and its effects on climate change and national 

forests are outside the scope of the analysis. 

Comment: The EIS must consider any oil and gas development. The ultimate burning of these 

fossil fuels would further increase global warming pollution. (CBD-56)

Response: The plan does not propose any oil and gas development. Although the plan does have 

areas that are considered “available,” there are no oil and gas leases on the Kaibab NF and the 

development potential is very low. As a result, the indirect effect of burning fossil fuels was not 

discussed. See EIS Minerals and Mining Affected Environment section. 

Glossary

Comment: The EIS should explicitly define its use of the terms “sustainable” “appropriate,” 

“restore,” “resilience.” (CBD-67)

Response: The EIS glossary does contain definitions for “sustainability,” “resiliency,” and 

“restoration”. The EIS uses the term “appropriate” consistent with the traditional definition, 

which may be found in any standard dictionary. 

Comment: The draft Kaibab Plan and DEIS should have easy-to-find definitions for the different 

thinning prescriptions referenced (e.g., matrix thinning, all-size free thinning, group selection, 

etc.). (SC-24)

Response: We added these terms to the glossary

Comment: The glossary contains a definition for goshawk foraging areas, but the wildlife desired 

conditions and guidelines do not mention foraging areas or a structural condition to be achieved. 

(SC-71)

Response: We removed the definition for goshawk foraging areas from the glossary because the 

term is not used in the revised plan. The concept of foraging areas also did not appear in the 

amended 1996 plan.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 417
Appendix A. Response to Comments

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forest fuels-reduction treatments. Journal of Environmental Management 130 (2013): 

221-231

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Nature Conservancy (USA). Biol. Conserv. 41:11-37.

Reynolds,, R.T., A.J. Sanchez. Meador, J.A. Youtz, T. Nicolet, M.S. Matonis, P.L. Jackson, D.G. 

DeLorenzo, A.D. Graves. 2013. Restoring the composition and structure in southwestern 

frequent-fire forests: a science-based framework for improving ecosystem resiliency. 

Gen. Tech. Rep. RMRS-GTR-310. Fort Collins, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station. 75 pp.

Shulte, L.A., Mitchell R.J., Hunter, Jr. M.L., 2006. Evaluating the conceptual tools for forest 

biodiversity conservation and their implementation in the US. Forest Ecol Manag 232: 1–

11

Triepke, F. J., B. J. Higgins, R. N. Weisz, J. A. Youtz, and T. Nicolet. 2011. Diameter caps and 

forest restoration —Evaluation of a 16-inch cut limit on achieving desired conditions. 

USDA Forest Service Forestry Report FR-R3-16-3. Southwestern Region, Regional 

Office, Albuquerque, NM. 31 pp.

USDA-Forest Service. 2013. Desired Conditions for Use in Forest Planning in the Southwestern 

Region: Development and Science Basis. Unpublished white paper, Southwestern 

Region, Albuquerque, NM. Updated: August 2013.

Weisz, R., J. Triepke, R. Truman. 2009. Evaluating the ecological sustainability a ponderosa pine 

ecosystem on the Kaibab Plateau in Northern Arizona. Fire Ecology 5(1): 114-128. 

Weisz, R. D. Vandendriesche, M. Moeur, M. Boehning, L. Wadleigh, F.J. Triepke, M. White, C. 

Nelson, J. Palmer, J. Youtz, B.J. Higgins, T. Nicolet, P. Bostwick, D. Mindar, M. Pitts, M. 

Manthei, and W. Robbie. 2011. Calibrating natural and anthropogenic events in state and 

418 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix A. Response to Comments

transition models with FVS: A case study for ponderosa pine forest ecosystems. In draft 

proceedings of the State and Transition Modeling Conference, June 2011, Portland, OR. 

USDA technical report on file. USFS Southwestern Region, Albuquerque, NM.

Weisz, R., F.J. Jack Triepke, D. Vandendriesche, M. Manthei, J. Youtz, J. Simon, and W. Robbie. 

2010. Evaluating the ecological sustainability of a pinyon-juniper grassland ecosystem in 

northern Arizona. In Jain, T.B., R.T. Graham, and J. Sandquist (eds.). Proceedings of the 

2009 National Silviculture

White, A.S. 1985. Presettlement Regeneration Patterns in a Southwestern Ponderosa Pine Stand. 

Ecology 66:589–594. Zenner, E. K., Peck, J. E., Brubaker, K., Gamble, B., Gilbert, C., 

Heggenstaller, D., & Withington, R. 2010. Combining ecological classification systems 

and conservation filters could facilitate the integration of wildlife and forest management. 

Journal of Forestry, 108(6), 296-300.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 419
Appendix A. Response to Comments

Commenter Codes 

Below is the list of agencies, tribes, groups, and individuals who provided substantive comments 

to the DEIS and Draft Revised Forest Plan. The codes and sequential comment number were used 

for tracking between this appendix (A) and the original comment, which can be found in the 

project record. 

ADEQ= Arizona Department of Environmental Quality

ADOT= Arizona Department of Transportation

AGFD= Arizona Game and Fish Dept.

AQ= Anthony Quintile

BB= Bob Blasi

CBD= Center for Biological Diversity

DH= Dorothy Holasek

DOI= Dept. Of Interior-Office of Environmental Policy and Compliance 

EBR= Erik B. Ryberg

EPA= Environmental Protection Agency

FRE= Town of Fredonia

GR= Glenn Rink

HOPI= The Hopi Tribe

JK= Jim Koons

KBPI= Kaibab Band of Paiutes

KCC= Kane County Commissioners

LS= Lawrence Stevens

MK= Mike Kearsley

PR= Patrick Rappold

RAF= Recreation Aviation Foundation 

RE= Rick Erman, Friends of Anderson Mesa

SC= Sierra Club-Grand Canyon Chapter

SN= Sue Nikopol

TS= Tracy Swensen

WILD=Wildlands Council/WildEarth Guardians/GOBW/GRW

420 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies

and Analysis Processes

The methods and analysis process section supplements the methods in the effects analysis for the 

DEIS, chapter 3. This supplemental information provides increased transparency for the 

processes, assumptions, and logic used in what are necessarily complex analysis processes. 

Descriptions of the required analysis for timber suitability, annual sale quantity (ASQ), and longterm sustained yield (LTSY) calculations, livestock grazing capability and suitability, potential 

wilderness area evaluation, wild and scenic river assessment, research natural area assessment, 

are located in appendices C, D, E, F, and G. 

Vegetation, Fuels, and Fire

The vegetation analysis models the potential vegetation conditions resulting from natural 

disturbances and succession in conjunction with proposed management (human disturbances) for 

each of the alternatives. A major portion of this analysis is based upon changes in vegetation state 

as a result of disturbances. Each vegetation state within a potential natural vegetation type 

(PNVT) is a combination of the dominant plant canopy cover class and (for forest and woodland) 

size class and density class. The evaluation focused on ecosystem functions (such as the amount 

of forest providing “old growth”, robust understory or high interspersion of vegetation states) 

associated with the priority needs for change. The analysis served as the basis for several other 

resource assessments including species habitats, soil and watershed condition, air quality, and 

social and economic uses. A number of sources were used to display current conditions. Various 

models were used to predict trends in vegetation and disturbances in response to natural and 

anthropogenic forces by alternative. Alternatives were evaluated by their progress toward priority 

needs for change and associated desired conditions.1

The primary sources for existing vegetation conditions are:

• A PNVT map based primarily upon the soil units from the terrestrial ecosystem survey 

was used to delineate all major vegetation types and compare existing to characteristic 

vegetation. Characteristic vegetation is the vegetation composition and structure that 

would exist under a natural disturbance regime, and considered to be ecologically 

sustainable.

• A “mid-scale” vegetation map, completed in 2008 across the Coconino and Kaibab 

National Forests provided geospatial polygons with characteristics of life form (tree, 

shrub, grass-forb), size class (for trees), and canopy cover class suitable for analysis at a 

scale of approximately 1:100,000.

• Forest inventory and analysis (FIA) plot data were used to calibrate the Vegetation 

Development Dynamics Tool model (VDDT), to estimate relative proportions of evenand uneven-aged conditions on the forest, and to estimate proportions of various 

vegetation types within pinyon-juniper systems.

1 For the potential natural vegetation types modeled with VDDT on the Kaibab NF (ponderosa pine forest and frequentfire mixed conifer) the mid-scale desired condition is assumed to be an open, multi-storied forest, dominated by trees 

20 inches d.b.h., or more. In the models for these two vegetation types, this is referred to as “state K.” This state can 

vary from 10 to 30 percent canopy cover and will have many tree sizes present, though it is dominated by trees 20 

inches d.b.h. and larger. It is expected to contain a myriad of fine-scale states with the sole exception of state N 

(uncharacteristic large openings), provided they average out to an open forest dominated by large trees at the midscale of 100 to 1,000 acres.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 421

 
Appendix B. Methodologies and Analysis Processes

• Field sampled vegetation data gathered on the Kaibab National Forest (NF).

• Mapped areas of stand-replacing fire on the Kaibab NF and other national forests along 

the Mogollon Rim for estimating the probability of occurrence for such events. 

Ecosystems and the plant communities that comprise them are dynamic. Plant communities 

undergo vegetation changes (transitions) over time, both with and without disturbances such as 

fire or management by humans. In the absence of disturbance changes in plant communities also 

occur over time as plants grow and die and, in many cases, new species establish and become 

dominant (plant succession). In order to evaluate vegetation, fire, and fuels trends (the sum of 

many vegetation transitions over time) that are within the scope of the Forest Plan Revision, 

modeling was used. The primary models used are the Vegetation Development Dynamics Tool, 

the Forest Vegetation Simulator, and spreadsheet based models which are each described in more 

detail in the following narratives.

Vegetation Development Dynamics Tool 

The Vegetation Development Dynamics Tool (VDDT), developed by ESSA Technologies (ESSA 

Technologies, LTD 2007) is widely used for modeling vegetation dynamics at landscape scales. 

For forest plan revision purposes in the Southwest Region, this model is applied to PNVT/forest 

plan alternative combinations to provide information that will aid in comparing alternative 

effects. 

VDDT is a “state-and-transition” modeling tool which provides a framework for predicting the 

effects of various disturbances, including management actions that affect vegetation state 

changes. States within a PNVT are defined by a dominant plant or tree cover type and structural 

stage such as seedling/sapling, medium size trees, etc. Table B 1 lists the vegetation states used 

for PNVTs that were modeled with VDDT for the Kaibab Forest Plan analysis. The PNVTs 

modeled and the rationale for modeling only these PNVTs is discussed at the end of this section. 

422 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Table B 1. VDDT state descriptions

State Description

A Grass, forb, shrubland; <10% canopy cover

B Seeding/sapling, open; <10% canopy cover

C Small trees, open; 10-30% canopy cover; 5-10′′ diameter class

D Medium trees, open, single story; 10-30% canopy cover; 10-20′′ diameter class

E Very large trees, open, single story; 10-30% canopy cover; 20+′′ diameter class

F Seeding/sapling, closed; >30% canopy closure; 0-5′′ diameter class

G Small trees, closed; >30% canopy closure; 5-10′′ diameter class

H Medium trees, closed, single story; >30% canopy closure; 10-20” diameter class

I Very large trees, closed, single story; >30% canopy closure; 20+′′ diameter class

J Medium trees, open, multistory; 10-30% canopy closure; 10-20′′ diameter class

K Very large trees, open, multistory; 10-30% canopy closure; 20+′′ diameter class

L Medium trees, closed, multistory; >30% canopy closure; 10-20′′ diameter class

M Very large trees, closed, multistory; >30% canopy closure; 20+" diameter class

N Uncharacteristic state; <10% canopy cover; large openings unlikely to regenerate in a timely fashion

Without disturbance, vegetation moves (transitions) from one state to the next on a time- or 

probability-dependent pathway (plant succession). Many VDDT models use time-dependent 

pathways for succession; however an analysis documented in Weisz et al. (2011) found no single 

predictable successional pathway for southwestern forests. Therefore, several probability-based 

outcomes for plant succession were used instead of time-based outcomes. Natural or humancaused disturbances also affect vegetation transitions. In VDDT, disturbances are defined for each 

state according to:

• type (e.g., wildfire, thinning, insects/diseases, etc.)

• destination state (the outcome of a disturbance)

• probability of occurrence

• relative stand age (in some cases)

Figure B 1 illustrates the vegetation states and transitions in the VDDT model.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 423
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Appendix B. Methodologies and Analysis Process

Figure B 1. VDDT state and transition model for ponderosa pine and frequent fire mixed conifer
Appendix B. Methodologies and Analysis Process

To simulate transitions from one state to another, VDDT breaks the analysis area down into a 

number of equivalent sized cells (also referred to as pixels). Each cell is assigned a specific state 

and age. The percentage of each state within the analysis area is based on the proportion of the 

total number of cells within the analysis area that is found in each state at any point in time. The 

starting point for each model run it set up so that the percentage of cells in each state match the 

current conditions that were determined for each PNVT. For each simulation year VDDT cycles 

through the cells, generates a random number, and determines whether each cell gets a year older 

in the same state, moves to a new successional state, or has a disturbance applied to it that would 

also move the cell to a new state. Probabilities of each of these outcomes happening in the model 

were developed using data related to past, current, and expected actions or events.

Some of these states within a VDDT model are found within the historic range of variability 

(such as large, multi-storied, open-canopied forest), while others are uncharacteristic states that 

occur currently, but did not occur historically (such as very large openings) within the ponderosa 

pine PNVT. Model outputs are the ratios of the various states with the PNVT for the landscape at 

the end of a given time period. 

The U.S. Forest Service Southwestern Region and its national forests have developed VDDT 

models specifically for several forest/woodland PNVTs to be used for forest plan revision in the 

region. The models were informed and calibrated with FIA data from across the region and 

stratified into PNVTs. FIA data were the best available data for making adjustments to the FVS 

and VDDT models. This analysis assumes that these data are representative and valid for 

evaluating attainment of the desired conditions and possible consequences of the plan 

alternatives. 

A set of vegetation management prescriptions and natural disturbances were developed and 

modeled in FVS to predict vegetation state outcomes for each state. In most cases, more than one 

outcome is predicted due to the existing differences between plots within each state. The process 

for developing the model is documented in a white paper by the Southwestern Region, Process 

Overview of Using FVS to Create VDDT Models (Weisz et al. 2011). 

For the Kaibab forest plan revision process, plan objectives that may have significant effects on 

PNVT structure or composition across the forest are proposed only for the ponderosa pine 

forest/bunchgrass (PPG), ponderosa pine forest/Gambel oak (PPO) and frequent fire mixed 

conifer (aka mixed conifer dry, or MCD) models. The PPG and PPO models are very similar so 

the two were evaluated together as “PPF.” The process used to test, adjust and apply the VDDT 

models to the Kaibab NF is discussed in more detail below, under VDDT Analysis Process of the 

Kaibab National Forest.

Forest Vegetation Simulator

The FVS is an individual tree, distance-independent, growth and yield model that has been 

calibrated for specific geographic areas (variants) of the United States (Dixon 2002). FVS can 

simulate a wide range of silvicultural treatments and was used for certain cases outside of the 

VDDT model when more resolution was needed. FVS is more sensitive to management actions 

because it models the fate of individual trees over time, rather than whole states of stand 

averages. This was needed to better evaluate the probable outcomes of specific treatments such as 

tree retention guidelines considered in the FEIS alternatives. Results from FVS were used to 

evaluate how often a treatment would retain or create a multistoried state, whether subsequent 

treatments were feasible with the same guidelines in place and whether the desired conditions 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 425
Appendix B. Methodologies and Analysis Process

could be met or retained over time. FVS has better resolution for quantifying the results of 

specific treatments, which may differ from the stand averages over time. FVS modeling of the 

tree retention guideline was modeled as a maximum diameter and is documented in Diameter 

Caps and Forest Restoration: Evaluation of a 16-inch Cut Limit on Achieving Desired Conditions 

(Triepke et al. 2011).

Spreadsheet-based Models

Various spreadsheet-based models (indices) were used to calculate the relative differences 

between alternatives for similarity to reference conditions, interspersion of states, understory 

production as a function of overstory tree density, and correlations of tree canopy cover to tree 

basal area. These were used for processing the output results from VDDT models.

An important assumption made in the vegetation modeling is that the population and calibration 

of VDDT using FIA plots and FVS modeling of growth and disturbances generally represents the 

response of forested PNVTs well enough to compare the estimated effects of EIS alternatives to 

forested PNVTs in a relative way at the mid-scale.

Goals or desired conditions used to evaluate contributions to sustainability are based on the 

desired conditions in the draft plan. These desired conditions are a combination of: 

• Forest Service Southwestern Region consistent desired conditions, which were developed 

using an interdisciplinary process and various scientific references (USDA Forest Service 

2013). 

• Kaibab NF specific desired conditions that supplement the Region 3 consistent desired 

conditions. The Kaibab also developed desired conditions for non-forested PNVTs not 

addressed in the regionally consistent process.

VDDT Analysis Process of the Kaibab National Forest

The Kaibab NF began with the models presented here by applying them to the combined 

ponderosa pine forest/bunchgrass-ponderosa pine/Gambel oak (aka ponderosa pine forest, or 

PPF) and frequent fire mixed conifer (aka mixed conifer dry, or MCD) models. The forest tested 

some basic model capabilities and adjusted coefficients to reflect the forest’s local history, 

particularly with fire and regeneration following high severity fire. This model provides a base 

comparison of the relative progress plan alternatives are predicted to make toward desired 

conditions; outputs were then supplemented by other information from the spreadsheet-based 

models discussed previously. VDDT was also used for most of the wood production and potential 

values calculations as required under the 1982 Planning Rule procedures. Much of the modeling 

response in VDDT was calibrated using Kaibab NF FIA data inputs and results from FVS runs.

The regional VDDT model (discussed above) has 391 state-transition combinations for both PPF 

and MCD. Multiple disturbance agents acting simultaneously with differing probabilities make it 

difficult to assess which disturbances have the greatest effect. In order to make this assessment,

the model was deconstructed to better understand the relative influence of outcomes from various 

disturbances over time, using a simple sensitivity analysis, discussed below.

Probabilistic Transitions for Plant Succession

VDDT models have the ability to model plant succession transitions from any one state to any 

other state in a specific time period if no other disturbance first intervenes. For example, it might 

426 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Process

be expected that as vegetation in a small-sized state grows, that it would transition into a larger 

state in a predictable fashion. However, there are some complications with the Southwestern 

region models the Kaibab NF tested to validate this expectation.

In the FVS modeling process used to calibrate the VDDT models (documented in Weisz et al. 

2011) several possible outcomes (rather than just one for each state) were identified for most 

model states. This occurred because the FIA plots that served as the source data for FVS, when 

modeled individually, grew into a large variety of states within one year. For example, in PPF, 

medium-sized, closed canopy, single-storied forest (state H in table B 2 and figure B 1), the 

probabilities that it will transition to a larger state in the following year are about 0.6 percent, 

while the probability that it will transition to either a multistoried state (L) or a smaller state (F) 

are about 1.2 percent (the other 98 percent would be expected to remain in the current state, H.) 

To account for these diverse outcomes, transitions from natural growth are modeled as the 

probability of transitions to each of the states. These were entered into the model as probabilistic 

transitions to accommodate more than one outcome. Their labels are “2_x”, where “2” means the 

word “to” and “x” means the destination state.

To check the plant succession outcomes, a test was performed where only the 2_x transitions 

were allowed to operate and all others were not. In one test, the entire PPF model was set to state 

B (perhaps a common condition after a mega-drought, such as one in the 1500s) and run for 300 

years. Another test tried a possible set of historic conditions —50 percent in E and 50 percent in 

K. The results of these and subsequent tests are presented in table B2.

Add I&D Transitions 

Next, we explored the potential outcomes when only the 2_x transitions and endemic 

insect/disease disturbances were allowed to operate and all others were not, beginning with a 

young, open forest. Would the model move to the largest, densest states, as expected? Would open 

large states occur as expected? As above, these were tested to verify the model was “wellbehaved,” or in other words produces model results consistent with what would be expected in a 

natural ecosystem. 

Add Fire Transitions 

Next we explored the potential outcomes when the 2_x transitions, endemic insect/disease 

disturbances, and fires burning under various conditions of weather and fuel moisture, with all 

other disturbances absent, beginning with a young, open forest. Would the model transition to the 

largest, densest states, as expected with low and moderate fire conditions?

Outcomes 

The results of the model runs, presented in the order discussed above, and quantified in table B 2

below, are as follows. These outcomes apply to the scale modeled with VDDT; the mid-scale:

• In 300 years, the model grew 55 percent of the initial small tree (dominated by trees 5 to 

10 inches), open state (10 to 30 percent canopy) into larger (dominated by trees greater 

than 10 inches d.b.h. and canopy greater than 30 percent) (run 1). The model is capable of 

growing small tree states into the denser and larger states.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 427
Appendix B. Methodologies and Analysis Process

• Adding insect and disease disturbances did not result in a detectable change in the 

outcome for larger state development (run 2). Endemic-level disturbances have a very 

small effect upon plant succession.

• Adding nonlethal fire (less than 25 percent top canopy kill) slightly increased the 

attainment of larger open states (run 3). These fires play a role (albeit small) in opening 

up the forest.

• Beginning with only large, open states (representing reference conditions) and nonlethal 

fire resulted in slightly more larger state closed conditions than beginning with all state B 

(run 4). 

◦ It should be noted that the vegetation characteristics of our large, open states today 

may not exactly correspond to the vegetation characteristics of the large, open states 

in reference conditions because there were certainly a wide range of conditions, 

especially at fine scales; but for the purpose of this analysis, we assumed state K (in 

figure B 1) captures reference conditions. Quantitative information from inventories 

and research on the Kaibab NF in ponderosa pine and dry mixed conifer forests

uniformly describe the pre-European settlement condition as an open forest 

dominated by large trees at the mid- or landscape scales (Lang and Stewart1909,

Woolsey 1911, Fulé et al. 2002, Huffman et al. 2001). However, the number of 

stories in the forest is more difficult to describe consistently, and the amount of forest 

that might have been single- or multi-storied using the definition in this model is hard 

to predict.

• Increasing fire intensity from low to moderate burning condition transitions dramatically 

shifted attainment of the larger, denser states to more open states, and also increased 

attainment of the larger open states from smaller states (run 5). These fires play a role in 

opening up the forest.

• Increasing the fire probability for moderate burning conditions to 1 in 5 years (run 7) 

does not make much difference compared to less frequent fire (run 5). Changing initial 

conditions to all state B slightly reduced the development of larger, open states (run 9).

• Using the fire probability of 1 in 5 years (local average) with low burning conditions (run 

8) produced larger states that are comparable to the outcomes in the less frequent, 

moderate burning conditions of run 5. Changing initial conditions to all state B did not 

result in changes to development of larger states (run 10).

• Increasing fire intensity to high burning condition transitions with frequent fire nearly 

prevented attainment of larger states; 9 percent of the landscape attained larger, open 

states while over 60 percent moved to an uncharacteristic state (state N).

These tests show the VDDT models are well-behaved for plant succession, endemic 

insect/disease levels. The fire disturbance outcomes are generally well-behaved, although there 

are some surprises with both moderate and high burning conditions. Adjustments to some fire 

transitions are discussed below.

428 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

FEIS for the Kaibab National Forest Land Management Plan 429

Table B 2. Sensitivity/validation analysis of the ponderosa pine forest/bunchgrass (PPG) model

300 Years with One Iteration

Run No. 1 2 3 4 5 6 7 8 9 10

Test 

2_x 

(growth

) only, 

with all 

in State 

B

Run 

1 + 

I&D

Run 2 + 

Nonlethal 

fire 500-yr 

(0.2 * .01)

Run 3, 

only w/ 

“TNC”

initial 

conditions

Run 4 

except 

only 

moderate 

burn 

cond.

Run 4 

except 

only 

high 

burn 

cond.

Run 6 

except 

moderate 

burn 

cond.

Run 6 

except 

low 

burn 

cond.

Run 8 

except 

all State 

B start

Run 9 

except all 

moderate 

burn 

cond.

State Initial 1 in 500 

yr fire Initial 1 in 500 years fire probability 1 in 5 years fire probability Initial 1 in 5 years fire probability

A 0 0 0 0 7 18 7 2 3 7

B 1.00 1 1 1 0 2 4 3 1 1.00 2 3

C 2 2 2 2 2 2 3 3 3 3

D 1 1 2 1 7 2 8 9 8 8

E 13 13 14 0.50 13 44 6 45 47 43 45

F 5 5 5 5 2 1 3 3 3 3

G 14 14 13 14 4 2 2 3 4 2

H 8 8 7 7 6 1 6 5 7 6

I 11 11 10 8 1 0 1 1 2 1

J 4 3 4 4 4 1 5 3 5 5

K 6 6 6 0.50 7 16 0 14 10 10 14

L 20 20 19 24 5 1 4 10 8 4

M 16 16 16 15 2 0 1 3 3 1

N 0 0 0 0 0 62 0 0 0 0

All 1.00 101 100 99 1.00 100 102 100 102 100 1.00 101 102

m-l open 24 23 26 25 71 9 72 69 66 72

m-l 

closed 55 55 52 54 14 2 12 19 20 12
Appendix B. Methodologies and Analysis Processes

Calibrating and Running the Ponderosa Pine Forest 

(PPF) Model for the Kaibab National Forest

The PPF VDDT model, as delivered by the Southwestern Region, was adjusted to account for 

Kaibab NF-specific information and some uncertainties related to fire and natural regeneration 

success.

Adjusting to Kaibab National Forest Specific 

Information and Uncertainties

Analysis was performed with the VDDT model to evaluate the outcome of thinning prescriptions. 

Given the need to clearly communicate the results, two indices were developed to facilitate the 

comparison of model alternative results. One index assigns a value of “1” to the desired condition 

of “very large tree (dominated by trees greater than 20 inches d.b.h.), open, multistory; with 10 to 

30 percent canopy closure” (state K) and a value of “0” to uncharacteristic departed conditions 

with an uncertain recovery time (state N). In between these bounding values, states were assigned 

values relative to their time to attain the desired condition assuming successful management, such 

as timely disturbances that result in progression from closed to open states and from smaller, 

single-storied to larger, multi-storied states. With successful management, it was assumed that it 

takes 200 years from seedling establishment to attainment of the desired large open, uneven-aged 

state. 

A second index is much more sensitive to stand density, with open forest conditions receiving 

higher index values than denser, more closed canopy, conditions. This index is more sensitive to 

the size of dominant trees. 

The first index is a relative indicator of overall similarity to reference conditions while the second 

index is a relative indicator of the risk of uncharacteristic disturbance, especially stand-replacing 

fire.

Prescriptions commonly used on the Kaibab NF for restoration treatments include group 

selection/matrix thinning and free thinning. Diameter cap treatments, as advocated by some, are 

infrequently used unless restoration objectives can be met with one entry. An initial run of the 

model using free thinning on states G and L and group selection/matrix thinning states H and M 

was compared to a run that used only a group selection/matrix thinning prescription (see runs 11, 

12 and 13 in table B 3). The group selection with matrix thinning prescription made more 

progress toward the desired condition when applied to the larger dense states of H, I, L, and M. 

This prescription was then applied to subsequent runs adding other disturbances. The relative 

attainment of the desired condition went from 0.546 to 0.637 and 0.648, respectively, for runs 12 

and 13. Given this progress toward attainment of the desired condition, these prescriptions were 

retained for modeling the proposed action.

Run 14 added the potential for high-intensity fire. This predictably reduced progress toward the 

desired condition, but the effect was relatively small using the regionally provided values for 

probabilities and outcomes. In the regional models, rather large proportions of the forest 

transition to regeneration states from large open states. However, local historical data and 

research shows that most trees within forests in this condition survived numerous fires, regardless 

of the weather, for centuries. So, for the Kaibab NF implementation of the VDDT models, highintensity fire was not allowed to occur in large, open states. 

430 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

It is also worth noting that there is a labeling misnomer in the models. While the prescription 

names imply fire behavior, they were actually based upon burning conditions (fire weather and 

fuel moisture). The outcomes in the regional models are based upon results from the Fire and 

Fuels Extension within the FVS modeling. It is not clear why the outcomes for large open states 

show so much transition to regeneration (openings) but the experience of local fire experts and 

research contradicts this outcome. This is why the transitions were prevented from occurring in 

large open states within the VDDT model used for the Kaibab NF.

Diameter Cap

Issues raised by some members of the public for protecting existing and providing for future old 

growth call for the retention of presettlement trees. Alternatives C and D have a guideline that 

would not cut trees that were established prior to 1890, which is generally when fire suppression 

and intensive livestock grazing began in Northern Arizona. Due to model and data limitations 

(data and models do not have an age variable) this guideline was modeled as a 16-inch maximum 

diameter limit or diameter cap. Run 15 explores the outcome of using a diameter cap restriction 

compared to run 14 which had no diameter cap. The prescription was changed from a group 

selection/matrix thin, with no diameter cap to a group selection/matrix thin with a 16-inch 

diameter cap. Desired condition attainment of 0.623 was higher than the initial conditions, but 

lower than runs 13 and 14. Table B 3 provides a summary of preliminary alternative evaluations 

used to test the alternative responses within the model under different assumptions.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 431
432 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Appendix B. Methodologies and Analysis Processes

Table B 3. Preliminary alternative evaluations

Run No.: Alt. B - 1 (11) Alt. B - 2 (12) Alt. B - 3 (13) Alt. B - 4 (14) Alt. C - 1 (15)

Test:

Free Thin H,L; GS-thin I,M; 

Mod. Burn fire all. Mid-scale 

initial states.

GS-thin H, I, L, 

M; Mod. Burn 

fire all. Midscale initial 

states.

Same as 13 only 

add stand-replacing 

fire possible in 

dense states (1.0).

Same as 14

Same as 14, except 

substitute d.b.h.-cap Rx for 

GS/matrix thin

State Initial

300 years 

with 1 

simulation

50 years with 10 simulations 250 yrs w/10 

sims

50 yrs w/ 10 

sims

250 yrs w/10 

sims

A 0.09 4 5 5 6 4 5 4

B 0.01 3 3 3 3 3 4 3

C 0.04 3 4 4 4 4 4 3

D 0.08 8 12 7 7 6 12 8

E 0.03 40 35 35 36 42 38 46

F 0.01 3 4 4 4 3 4 3

G 0.08 5 7 7 6 6 6 5

H 0.25 4 5 4 4 3 5 4

I 0.05 0 1 0 0 1 1 1

J 0.07 5 6 7 7 5 5 4

K 0.02 18 13 17 17 19 11 14

L 0.23 3 5 4 4 3 4 3

M 0.02 2 1 2 1 1 1 1

N 0.02 0 0 0 1 0 0 1

All 1.00 98 101 99 100 100 100 100

Note: For additional information on the VDDT and model limitations, see the Vegetation Fuels, and Fire Specialist Report (KNF 2011) appendices.
Appendix B. Methodologies and Analysis Processes

Stand-replacing Fire 

For the initial model runs, The regionally developed models used stand-replacing fire 

probabilities of 0.01 or 0.02 per acre-year (1 year in 100 or 1 year in 200 - the odds of fire 

occurring on any cell); however, based upon recent occurrences of stand-replacing fire on the 

Apache-Sitgreaves, Coconino, and Kaibab NFs and professional opinion about , a stand-replacing 

fire probability of 0.004 per acre-year (1 year in every 250 years) is being used for VDDT 

modeling on all three forests. An adjustment was also made to better represent the stand-replacing 

fire in open states. There is no documented evidence of stand replacing fires occurring on the 

Kaibab NF at the mid scale (100 to 1,000 acres) in the open pre-settlement forest so standreplacing fire was only modeled in closed states in PP for the Kaibab.

A comparison of the known outcomes of the 2006 Warm Fire (KNF 2007) was made to evaluate 

the model outcome probabilities. For purposes of plan and alternative analysis, areas with standreplacing fire greater than 100 acres are considered undesirable. This is because the time to 

achieve the desired conditions can be delayed for an indefinite period due to distance from live 

trees that produce seed without successful artificial regeneration efforts (Haire and McGarigal 

2010, Higgins 2008, Savage and, Mast 2005). In the Warm Fire suppression area (wildfire), about 

60 percent had almost complete overstory mortality. In the ponderosa pine portion, 75 percent of 

the area had complete mortality and 25 percent had high mortality (but less than 100 percent –

although most trees subsequently died). 

The regional model uses a ratio of about 2:1 for states A (characteristic, small openings) to N 

(uncharacteristic, large openings) for stand-replacing and high Rx burning conditions. For 

example, in VDDT model state F, a stand-replacing fire would change 39 percent of it to state A 

and 19 percent of it to state N – about 2:1 for the transitions to states A and N. Based upon the 

Kaibab NF-specific analysis, the ratio of 1:3 for states A to N was used to represent the portion of 

stand-replacing fire that goes to either state A or N in the Kaibab model. Table B 4 displays this 

adjustment. The overall percentage of the beginning (“from”) state does not change; the 

percentages for the resulting (“to”) states were changed but the overall percentage of change was 

kept the same. Outcomes to other states were not changed.

Table B 4. Modification of state A:N outcomes for stand-replacing fire and prescribed 

burn high (regional model Kaibab National Forest-specific adjustment)

↓To \ From→ F G H I L M

A 39 → 14 21 → 8 27 → 10 17 → 6 21 → 8 18 → 7

N 19 → 44 11 → 25 13 → 30 8 → 19 8 → 24 9 → 20

Total 58 33 40 25 32 27

The regionally delivered model had a recovery rate from state N (uncharacteristic large openings) 

to state A (Grass, forb, shrubland; less than 10 percent canopy cover) or state B (Seedling-sapling; 

less than 10 percent canopy cover) of about 9 percent per year, based upon interpretation of 

various sources. On the Kaibab, several field visits to high-intensity burn sites have not shown 

recovery to tree cover without artificial reforestation (planting). Literature on regeneration 

following wildfire events varies. Savage and Mast (2005) showed regeneration in areas near seed 

433
Appendix B. Methodologies and Analysis Processes

sources, some other studies showed somewhat prompt recovery, while other areas had virtually 

no ponderosa pine regeneration. 

Aspen, oak, brush species and/or grasses have occupied all Kaibab NF sites visited with past 

high-intensity burns. Following the 1996 Bridger Fire on the North Kaibab District, the midscale assessment mapped oak brush as tree cover and found 10 to 25 percent tree cover. The 

overall canopy cover is probably in that range, but very little is ponderosa pine, and almost none 

was ponderosa pine regeneration. The highest known natural regeneration frequency following a 

large stand-replacing fire event on the Kaibab NF is after a fire in North Kaibab District’s Saddle 

Mountain Wilderness documented by Haire (2010). In this study, there was a definite line of 

ponderosa pine re-occupancy from the forested edge, with a few interior seedlings that are likely 

from individual surviving pre-fire trees. This is consistent with regeneration patterns observed by 

Savage and Mast (2005) with nearby seed sources. However, even at Saddle Mountain the 

regeneration rates were well below 9 percent per year. Verbal communication with Haire about 

the Saddle Mountain and La Mesa Fires indicates that the best case (observed on La Mesa in New 

Mexico, but not on Saddle Mountain) would be about 9 percent year.

The regional model moves 9 percent per year from state N to K with natural regeneration. The 

Kaibab adjustment uses both 0 percent and 5 percent regeneration of ponderosa pine per year to 

evaluate alternatives. The 5 percent per year is roughly what the Kaibab NF can currently 

accomplish with artificial reforestation in areas suitable for timber production following crown 

fires, and is a modeled objective for the proposed action.

Second Round Analysis

VDDT databases, “kaibab-preside-vddt-2010-11-08.mdb” (for PP [ponderosa pine]) and “mcdpreside-vddt-2010-12-08.mdb” (for MCD [mixed conifer, dry]) contain the model runs for each 

EIS alternative and alternative portion (timber suitable, other and unsuitable) when applicable.3

Both categories of ponderosa pine type, PPG and PPO, were run together for the DEIS analysis 

using the PPG model developed by the region, as adjusted. It is referred to here as the ponderosa 

pine forest (PPF) model.

Adjustments to the regionally developed models are documented above. The following 

assumptions and parameters were applied to the model:

• Stand-replacing fire frequency was modeled at 1 per 250 years. 

• Disturbances with a model frequency of 0 – 0.0001 are not presented, as they are 

negligible to model results; 2_x disturbances are as developed regionally; no changes 

were made for local conditions.

• Natural regeneration was turned off. This only affects transitions from state N to A. 

3 “Timber suitable” areas are those where a regular entry to produce timber is assumed. Although not explicit in the 

model, it is also assumed that an effort would be made to regulate stands so that they are uneven-aged and have a 

generally balanced representation of age classes. “Other” areas are places where trees may be harvested but there is 

no objective to regularly produce forest products. They are still intended to be uneven-aged but may have large gaps 

in age classes. “Unsuitable” areas are those where no mechanical treatment is modeled, because the areas are 

reserved lands (such as wilderness or proposed wilderness), have other management requirements imposed in the 

plan alternative that prohibits tree harvest, or could have irretrievable resource damage if mechanical treatments were 

applied.

434 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

 
Appendix B. Methodologies and Analysis Processes

• Artificial reforestation at current rates (around 5 percent per year) is adequate to keep up 

with creation of state N, should planting occur. If no artificial reforestation, the recovery 

of N to A is likely to be much less than this, and may be effectively zero when 

regeneration to characteristic desired species abundance is considered.

• Runs with no regeneration (natural or planting) were done to evaluate the number of 

acres likely to need planting over time – a cost factor in alternative evaluation and 

discussion.

• Outputs were captured every five years for 250 years, with 10 simulations each time into 

files that could be imported into spreadsheets for further analysis. A thousand cells were 

used. As discussed above, “[t]o simulate transitions from one state to another, VDDT uses 

a fixed number of cells with each cell assigned to a succession state and age. For each 

simulation year VDDT cycles through the cells, generates a random number, and 

determines whether each cell gets a year older in the same state, moves to a new 

successional state, or has a disturbance applied to it that would also move the cell to a 

new state.”

• The output files were imported into and stored in spreadsheets as pivot tables for each 

alternative, with tabs for alternative portions and an activity table used for an 

“interspersion calculation.” Interspersion refers to the juxtaposition of vegetation states; 

high interspersion means there is high diversity of vegetation states in a small area. This 

is an important measure used to evaluate fine-scale desired condition attainment.) The 

naming convention for these spreadsheets is [PP:MCD]_Summary_[A:B:C:D].xlsx. 

• The alternative portions tabs were transferred to tabs in two spreadsheets; either ppkaibab-alternatives-2010-12-16.xlsx (for PP PNVTs) or dmc-kaibab-alternatives-2010-

12-16.xlsx (for MCD). 

Other key model run settings and inputs to the VDDT models are displayed in table B 5. Under 

the heading “Alternative and analysis portion” are sub-headings that identify alternative, 

alternative portion, and some information detail about the alternative portion. For example, “Asfvs” refers to alternative A, timber suitable portion, and that some local FVS modeling was used 

to refine the regional model transitions. “Bo-w-ft” refers to alternative B, “other portion” and that 

free thinning was applied to the initial model prescription. Other details relevant to table B 5 are:

• Alternatives A through D are divided into portions (timber suitable, other and unsuitable) 

and modeled separately.

• Names of portions correspond to the subdirectories where model results are written, and 

are somewhat descriptive of the portion. “FVS” indicates the Kaibab carried out some 

FVS modeling to help calibrate model outcomes over several decades for the prescription 

applied (d.b.h. cap). “W_ft” indicates a free-thinning was added to the initial prescription 

of “GS-matrix thin only” after some time to address some increasing thinning treatment 

needs.

• The “TSD on?” (time since disturbance) is a way to time treatments in VDDT and is used 

here for portions where a “restore with thinning, then use fire only” management is in

place. The model may only mechanically treat a cell one time. For MCD, a problem with 

the TSD switch wasn’t fixable in the time available, so area limits were applied over time 

to transition groups to simulate the TSD effect.

435
Appendix B. Methodologies and Analysis Processes

• Several multipliers are qualified with area or time-area limits. For example, “550+” 

means at least 550 acres per year are treated. “(1020: 0-1k; 21+ 1.5k-2k)” means 0 to 

1,000 acres per year in years 1 through 20 and 1,500 to 2,000 acres per year thereafter.

436 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
FEIS for the Kaibab National Forest Land Management Plan 437

Appendix B. Methodologies and Analysis Processes

Table B 5. VDDT model settings for areas and multipliers by alternative portions

As-fvs Ao Au Bs-w-ft Bo-w-ft Bu Cs-fvs Co-fvs Cu Do-fvs Du

Acres 325,433 144,216 77,431 301,676 167,163 78,241 277,275 186,111 83,694 463,386 83,694

TSD On? Yes No No No No Yes No Yes No

I Plant Seedlings 5.002 0 0 5 0

Stand-Replacing Fire

Insect/Disease

2_x

Natural Regeneration

Acres 37,507 351 89,861 36,410 1,248 90,061 32,237 5,201 90,281 37,438 90,281

TSD On? No Yes No Yes No

I Plant Seedlings 5 0 5 5 (210-310); 0 5 (0 - 1.9k); 0

Stand-Replacing Fire

Insect/Disease

2_x

Natural Regeneration

0

No

VDDT Model settings for the DEIS analysis

ppf.mdb

0.924

2.95

0.4

5

0

0

NC

B Free thin... (MinMax)

D Thin under 16-inch... 

(Min-Max)

E GroupSelect w... 

(Min-Max)

J RX FIRE ONLY L... 

(Min-Max)

K RX FIRE ONLY M... 

(Min-Max)

NC

0.162 

(550+)

0.162 

(550+)

0.318 

(993+)

2.639 (6k - 6k) 2.415 (4k - 

4k) 0 2.425 (10k - 

10k) 0

5.366 (1-20: 13k - 

13k; 21+: 10k - 

5.366 (1-20: 

3k - 5k; 21+: 

 

0

No

2.5

7.5

0

0 5

2.7 (0-1.5k; 

2k-3k) 0 2.7 (0-1k; 1.5k-2k) 0

J RX FIRE ONLY L... 

(Min-Max)

K RX FIRE ONLY M... 

(Min-Max)

0

7.76 (1-

20:0.3k-0.5k) 

21+: 0

B Free thin... (MinMax) 1

5

0 1 (400-400) 0

0 7 (1-20: 1400-

2800; 21+: 1400+)

0

7.76 (1-20:1.8k3.2k) 21-60: 3.88 

(.9k - 1.6k); 61+: 1

0

4.95 (1-

20:1.55k - 

2.15k) 21+: 0

NC

NC

0

1

3

0.4

dmc.mdb

Area &/or Alternative and analysis portion

Multiplier

Data

base

E GroupSelect w... 

(Min-Max) 0.542 7

5 2.5 5 2.5 5 2.5

5

0

D Thin under 16-inch... 

(Min-Max)
Appendix B. Methodologies and Analysis Processes

The following sections describe some design features of the alternatives evaluated and the 

settings and inputs to VDDT models for each of them. Refer back to table B 5 for each 

description. Tables B 6 through B 13 present some parameters used for running the models on 

portions of the alternative. Where “once” is used, a treatment may not reoccur during the model 

run on a cell after it has occurred once. This is used to prevent future mechanical treatments in 

areas where the intent is restore the forest (consistent with any limits in the alternative design 

direction) and then use natural disturbances only (particularly fire) thereafter to manage forest 

structure and composition.

No Action

The current forest plan, as implemented in recent projects, is the modeled “no action” alternative. 

Current (last 5 years) rates and typical prescriptions (or surrogates) are used. 

Ponderosa Pine (PPF)

The Kaibab NF has several thousand acres of historic grasslands invaded by trees, primarily 

ponderosa pine, due to fire absence. These grassland PNVTs are identified as timber suitable in 

the current forest plan and may receive treatments in project areas to reduce trees to historic 

densities (less than 10 percent canopy cover) and patterns. Although these may be reclassified as 

grasslands with a site-specific plan amendment, they are retained in timber suitable for model 

purposes in this alternative. Timber suitable areas are those identified in the current plan. “Other” 

lands are unlikely to receive mechanical treatments in this alternative, so they are treated with fire 

only. “Unsuitable” in the spreadsheets means reserved lands or those where irreversible resource 

damage could occur with mechanical treatments also receive fire-only treatments. 

For timber suitable areas:

• Objectives include some free thinning and d.b.h. cap (where objectives can be met in PP) 

and group selection with matrix thinning, with overall mechanical treatments totaling 

around 2,100 acres per year (last 5 years average), reforestation at 5 percent per year, and 

low to moderate managed fire on about a 20-year return interval.

For “other” and “unsuitable” areas:

• Set no mechanical treatments or planting objectives. Fire return interval is about 20 years, 

currently.

Table B 6. Model parameters for alternative A – PPF runs

Portion Timber Suitable Other Unsuitable

Area (Acres) 325,433 144,216 77,431

Mechanical treatment Yes No No

Reforestation Yes No No

Frequent Fire Mixed Conifer (MCD)

The current forest plan includes many conservation measures specified in the 1995Mexican 

Spotted Owl Recovery Plan. Implementation of the current forest plan’s direction in Mexican 

spotted owl habitat has effectively placed significant limits on the ability of the Forest Service to 

438 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

restore this system, either with thinning or fire, partly because of high basal area retention 

requirements, low diameter caps and the associated costs of economically thinning or safely 

under-burning the forest. Current accomplishments (based on recent history under the current 

plan) are applied to timber suitable areas.

For timber suitable areas:

• Objectives include group selection – matrix thin on 150 acres per year, reforestation at 5 

percent per year. Low to moderate burning condition fire are set to return intervals of 100 

years and 33 years, respectively, for a combined return interval of 25 years.

For “other” and “unsuitable” areas:

• No mechanical treatments or plantings are scheduled. Managed fire is the same as the 

timber suitable area.

Table B 7. Model parameters for alternative A - MCD runs

Portion Timber Suitable Other Unsuitable

Area (Acres) 37,507 351 89,861

Mechanical treatment Yes No No

Reforestation Yes No No

All Action Alternatives (Alternatives B, C and D)

Consistent with recommendations from the Kaibab Forest Health Focus (KNF 2009a) and 

concurrence from the Kaibab leadership team, treatments were initially focused on areas with the 

“biggest bang for the effort” to restore a fire-tolerant state. The filters applied are, in order:

• States where risk of uncharacteristic fire is high (closed-canopy states – F, G, H, I, L, and 

M);

• Places where there is the greatest potential of loss in attaining the desired condition of 

state K (closed-canopy states containing many large, old trees that would take over a 

century to replace and that could attain state K relatively quickly given proper 

management - H, I, L, and M); and,

• States likely to be treated without a high net cost; states H, I, L, M. Conversely, other 

states require relatively higher effort or expense for little gain, so thinning in these other 

states is not initially, planned.

Within the states treated, the large majority of trees that would be thinned are smaller than the 

average trees that dominate the state in all alternatives.

Overall, an attempt was made to have fire occur on all lands on a 10-year return interval, with a 1 

to 3 ratio of low to moderate conditions to reflect recent history. Adjustments were made in the 

unsuitable areas of MCD to reduce the incidence of uncharacteristic fire.

Proposed Action (Alternative B)

This alternative is based on the proposed action description:

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 439
Appendix B. Methodologies and Analysis Processes

• Adopts the upper range of thinning and restoration area objectives identified in the 

Kaibab Forest Health Focus for both PPF and MCD PNVTs.

• Uses group selection with matrix thinning and free thinning for mechanical treatments.

• Uses the tree class retention guidelines for identifying older trees while maintaining 

treatment implementation economy.

Ponderosa Pine (PPF)

For timber suitable areas:

• Objectives for thinning and Group Selection-matrix thin are 14,500 to 15,000 acres per 

year for 20 years and planting 5 percent per year of uncharacteristic fire areas (state N). 

• Prescribed fire and managed wildfire use multipliers of 2.5 for low burning conditions 

and 7.5 for moderate burning conditions; resulting in a combined multiplier of 10, and 

therefore a 10-year fire return interval.

For other areas:

• Objectives for thinning and group selection-matrix thin are 0 to 1,500 acres per year for 

20 years and planting 5 percent per year of uncharacteristic fire areas (state N). 

• Prescribed fire and managed wildfire use multipliers of 2.5 and 7.5 for low and moderate 

burning conditions, respectively.

For unsuitable areas: 

• No mechanical or planting objectives are identified. 

• Prescribed fire and managed wildfire use multipliers of 2.5 and 7.5 for low and moderate 

burning conditions, respectively.

Table B 8. Model parameters for alternative B – PPF runs

Portion Timber Suitable Other Unsuitable

Area (Acres) 301,676 167,163 78,241

Mechanical treatment Yes Once No

Reforestation Yes Once No

Frequent Fire Mixed Conifer (MCD)

Agreement was reached in the Kaibab Forest Health Focus (KNF 2009a) that at least 14,000 acres 

annually may be treated mechanically in dry mixed conifer forest, but the specific types of 

treatment or prescriptions were not identified. A group selection-matrix thin and free thinning 

prescriptions in timber suitable was applied in the proposed action (alternative B) to address the 

minimum need in a decade, assuming an equivalent need will be identified in the second decade 

and future maintenance needs will also occur in a regulated forest. 

For timber suitable acres:

• Objectives for thinning and group selection-matrix thin are 1,400 to 2,800 acres per year 

for 20 years and planting 5 percent per year of state N. 

• Prescribed fire and managed wildfire are assumed at 20-year return intervals for both low 

and moderate burning conditions, respectively, for a combined 10-year return interval.

440 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

For other areas: 

• Only small mechanical treatment or planting objectives are identified due to the limited 

area (1,200 acres.)

For unsuitable acres:

• There are no objectives for mechanical or planting treatments. Overall prescribed fire 

frequency was lowered to account for limitations on burning in highly vulnerable North 

Canyon Creek (stand-replacing fire risk) and the associated Apache trout habitat.

Table B 9. Model parameters for alternative B – MCD runs

Portion Timber Suitable Other Unsuitable

Area (Acres) 36,410 1,248 90,061

Mechanical treatment Yes Yes No

Reforestation Yes Yes No

Alternative C

This alternative modifies the proposed action with these major changes:

• Reclassifies most timber suitable areas on the North Kaibab Ranger District to “other,” 

with a restore and then use fire only prescription.

• Adds several wilderness recommendations that reserve areas from both timber suitable 

and “other” areas (to “unsuitable”).

• Uses a d.b.h. cap instead of a group selection-matrix thin prescription.

Ponderosa Pine (PPF)

For timber suitable areas:

• Objective for thinning is lowered to 6,000 acres per year (60 percent of the lower end of 

the Kaibab Forest Health Focus for PP). 

• Planting and prescribed fire objective multipliers are unchanged from alternative B.

For other areas:

• Objective for thinning is 4,000 acres per year (40 percent of the lower end of the Kaibab 

Forest Health Focus for PP).

• A d.b.h. cap is used (once) on these reduced acres.

• Planting may occur, but never after a thinning has occurred (190 acres per year).

For unsuitable areas:

• Objectives are the same as alternative B.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 441
Appendix B. Methodologies and Analysis Processes

Table B 10. Model parameters for alternative C – PPF runs

Portion Timber Suitable Other Unsuitable

Area (acres) 277,275 186,111 83,694

Mechanical treatment Yes Once No

Reforestation Yes Once or No No

Frequent Fire Mixed Conifer (MCD)

For timber suitable areas:

• Timber suitable area is about 32,000 acres.

• Objective for thinning is 1,800 to 3,200 acres per year for 20 years.

For other areas:

• Area is about 5,200 acres, primarily on the North Kaibab Ranger District in the North 

Kaibab Wildlife Habitat Complex.

• Objective for thinning is 300 to 500 acres per year for 20 years, then ceases, going to fire 

maintenance.

• No objective for planting is modeled due to the small size of the area and the 

unlikelihood of a stand-replacing fire in the 20 years before management becomes fire 

maintenance.

For “unsuitable” areas:

• Area is about 93,000 acres.

• Turn off mechanical treatments and planting.

• Prescribed fire objectives (multipliers) are the same as alternative B.

Table B 11. Model parameters for alternative C – MCD runs

Portion Timber Suitable Other Unsuitable

Area (acres) 32,237 5,201 90,281

Mechanical treatment Yes No No

Reforestation Yes No No

Alternative D

This alternative is based on the alternative C description with these major changes:

• Reclassifies remaining timber suitable areas on the Kaibab NF to “other,” with a d.b.h. 

cap (in effect) and then applies a fire only prescription.

• Adds several wilderness recommendations that reserves area from both timber suitable 

and “other” areas (to “unsuitable”)

• Thinning objectives for timber suitable and other areas in alternative C are combined into 

one objective in other areas for this alternative.

442 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Ponderosa Pine (PPF)

For “other” areas:

• Objective for thinning is 10,000 acres per year; planting and fire objectives (multipliers) 

are the same as alternative C.

Table B 12. Model parameters for alternative D – PPF runs

Portion Timber Suitable Other Unsuitable

Area (acres) 0 463,386 83,694

Mechanical treatment? NA Once No

Reforestation? NA Once or No No

Frequent Fire Mixed Conifer (MCD)

For “other” areas:

• Objective for thinning is 10,000 acres per year for 20 years, then ceases, going to fire 

maintenance.

• Planting may occur but not after a thinning and ceases when management shifts to fire 

maintenance.

For “unsuitable” areas:

• No mechanical treatments or plantings are planned. Managed fire is the same as 

alternative C. 

Table B 13. Model parameters for alternative D – MCD runs

Portion Timber Suitable Other Unsuitable

Area (acres) 0 37,438 90,281

Mechanical treatment NA Once No

Reforestation NA Once or No No

Wildlife Habitat Analysis (Based on VDDT)

The VDDT model analysis process is described in detail above. The existing vegetation 

conditions were stratified into different states, and then the model was used to predict how the 

vegetation states would change over time under each of the alternatives. Because the VDDT 

model uses mid-scale data (1:100,000 map scale), percent canopy cover averages the openings 

and tree cover over the entire mid-scale area. This means that at the fine scale, some areas may 

have lower actual canopy closure and other areas may have higher actual canopy closure than 

what is shown in the state description. This is true for mid-scale data in general because the 

variables are averaged over the areas of 100 to 1,000 acres.

The forest first defined which vegetative states would provide habitat for certain species. The 

habitat types were selected based on the associated PNVT as identified in the species diversity 

report. Table B 14 shows the species and states that were associated to each species habitat. Every 

species is not necessarily associated with every vegetation state (e.g., Kaibab tree squirrel uses a 

broader range of vegetation states than does the Mexican spotted owl).

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 443
Appendix B. Methodologies and Analysis Processes

The current amount of habitat was first determined by selecting vegetation type (i.e., ponderosa 

pine) and then the tab for “initial conditions.” The percentage for each existing state was then 

converted into acres. Next, the predicted amount of the states in 15 years was compared to the 

initial conditions to determine how the vegetation would change under each alternative. This was 

done for each vegetation type by selecting for each alternative the “forestwide totals” tab and then 

using the average percent of acres in each state for each decade to determine percentage amount. 

For example, decade 1.5 results in a percentage for year 15. The percentages were then converted 

to acreages 

For some species, there was a need to include further assumptions: 

The Mexican spotted owl only uses ponderosa pine/Gambel oak habitat on the Williams 

Ranger District within the pine type. However, the VDDT model lumps this habitat type in 

with all ponderosa pine. Based on the GIS layer for the Williams Ranger District there is 

approximately 49,440 acres of the ponderosa pine that is considered to be ponderosa pine/oak 

currently on the district. Therefore to estimate the amount of change in this habitat, the 

selected states in ponderosa pine were multiply by nine percent, which is the percentage of 

pine-oak on the Williams RD of ponderosa pine cover type on the Forest.

The Kaibab tree squirrel is only found in ponderosa pine on the North Kaibab Ranger 

District. Based on the Kaibab National Forest Ecological Sustainability Report (Version 1.01, 

December 19, 2008), the district has approximately 28 percent of the ponderosa pine cover 

type on the forest. Therefore, the states selected for the Kaibab tree squirrel were multiplied 

by 28 percent to estimate the amount of habitat affected on the district.

The Kaibab least chipmunk and Kaibab northern pocket gopher both use mesic mixed conifer 

and spruce-fir habitat on the North Kaibab Ranger District. While there is a small amount of 

mesic mixed conifer found on the Williams Ranger District, almost all of the vegetation type 

is found on the North Kaibab Ranger District. Since there is only a limited amount of habitat 

on the Williams Ranger District, the total acres of mesic mixed conifer was used to determine 

the amount of habitat for these species. 

444 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Table B 14. Species analysis for ponderosa pine and mixed conifer by species, their 

habitat needs and their associated VDDT model states

Species States Comments

Mexican spotted owl K, L, M Is associated with large trees in multistory stands and >40 

percent canopy closure. Uses ponderosa pine/Gambel oak 

and mixed conifer stands.

Goshawk J, K, L, M Is associated with large trees in multistory stands both 

open and closed. Shows nesting, roosting, and postfledgling family habitat acres. Uses ponderosa pine and 

frequent fire mixed conifer stands.

Bald eagle D, E, H, I, J, K, L, M Is associated with large ponderosa pine trees. Will use 

both open and closed stands.

Allen lappet-browed bat D, E, H, I, J, K, L, M Is associated with large trees with loose bark. Will use 

both open and closed stands. Is found in ponderosa pine 

and frequent fire mixed conifer (MCD).

Merriam’s shrew C, D, E, J, K Is associated with open conifer stands. Is found in 

ponderosa pine and frequent fire mixed conifer (MCD)

Kaibab tree squirrel E, H, I, J, K, L, M

Optimum habitat

J, K, L, M

The squirrel will use a variety of stands for foraging 

within ponderosa pine stands. Optimum habitat (nesting 

habitats) is more restricted to large trees with interlocking 

crowns within the groups.

Kaibab least chipmunk C, D, E, J, K Is associated with openings within mesic mixed conifer 

stands.

Kaibab northern pocket 

gopher

C, D, E, J, K Is associated with openings within mesic mixed conifer 

stands. 

Table B 15 compares current existing conditions by vegetation “state” (used in the VDDT model 

runs) for mixed conifer, with conditions expected to occur under implementation of each of the 

alternatives. Table B 16 displays specific species associated with mixed conifer habitat and how 

their existing habitat (as defined by the vegetative states in table B 14) would likely change by 

implementing the proposed alternatives. It combines the relevant vegetation states from table B

15 for each species into one value to compare existing to future habitat for each species by 

alternative. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 445
Appendix B. Methodologies and Analysis Processes

Table B 15. VDDT modeling used for species dependent on mixed conifer habitat, current 

condition and each alternative after 15 years

Mixed Conifer - Total Acres on PNVT= 12,7719 (Acreage Includes Dry and 

Mesic MC:10,700 +20,719)

States Current Current 

Acres Alt. A Alt. A Acres Alt. B Alt. B Acres Alt. C Alt. C Acres Alt. D Alt. D Acres

A 6% 7,804 0% 0 1% 1,660 1% 1,277 1% 1,788

B 1% 1,277 1% 1,277 1% 1,660 1% 1,277 2% 2,554

C 7% 8,429 0% 0 1% 1,660 1% 1,277 1% 1,788

D 1% 1,405 5% 6,386 8% 10,218 6% 7,663 7% 8,940

E 5% 6,322 5% 6,386 8% 10,218 16% 20,435 15% 19,158

F 0.21% 268 17% 21,712 16% 20,435 17% 21,712 17% 21,712

G 8% 10,141 8% 10,218 6% 7,663 7% 8,940 7% 8,940

H 32% 40,806 18% 22,989 12% 15,326 13% 16,603 12% 15,326

I 0.14% 179 4% 5,109 2% 2,682 3% 3,193 2% 2,554

J 0.50% 639 3% 3,832 6% 7,663 3% 3,193 4% 5,109

K 0.50% 639 4% 5,109 11% 14,049 5% 6,386 5% 6,386

L 17% 21,712 15% 19,158 10% 12,772 11% 14,049 10% 12,772

M 10% 12,772 9% 11,495 6% 7,663 6% 7,663 5% 6,386

N 12% 15,326 11% 14,049 11% 14,049 11% 14,049 11% 14,305

Total 100% 127,719 100% 127,719 100% 127,719 100% 127,719 100% 127,719

Table B 16. Total habitat for species dependent on mixed conifer for each alternative

Species States Current Alt. A Alt. B Alt. C Alt. D

Goshawk habitat J, K, L, M 35,761 39,593 42,147 31,291 30,653

MSO habitat (K, L, M) 35,123 35,761 34,484 28,098 25,544

Allen LEB D, E, H, I, J, K, L, M 84,473 80,463 80,591 79,186 76,631

Merriam’s shrew C, D, E, J, K 17,434 21,712 43,808 38,954 41,381

Table B-17 compares current existing conditions by vegetation “state” (used in the VDDT model 

runs) for mesic mixed conifer, with conditions expected to occur under implementation of each of 

the alternatives. Table B 18 displays specific species associated with mesic mixed conifer habitat 

and how their existing habitat (as defined by the vegetative states in Table B-14) would likely 

change by implementing the proposed alternatives. It combines the relevant vegetation states 

from Table B-17 for each species into one value to compare existing to future habitat for each 

species by alternative. Further assumptions as noted above apply to the Kaibab least chipmunk 

and Kaibab northern pocket gopher.

446 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Table B 17. VDDT modeling used for species dependent on mesic mixed conifer habitat, 

current condition, and each alternative after 15 years

Mesic Mixed conifer - total acres on Forest of PNVT = 20,719

States Current Current 

Acres

Alt. 

A

Alt. A 

Acres

Alt. 

B

Alt. B 

Acres

Alt. 

C

Alt. C 

Acres

Alt. 

D

Alt. D 

Acres

A 6% 6,538 0% 0 1% 1,391 1% 1,070 1% 1,498

B 1% 1,070 1% 1,070 1% 1,391 1% 1,070 2% 2,140

C 7% 7,062 0% 0 1% 1,391 1% 1,070 1% 1,498

D 1% 1,177 5% 5,350 8% 8,560 6% 6,420 7% 7,490

E 5% 5,297 5% 5,350 8% 8,560 16% 17,120 15% 16,050

F 0.21% 225 17% 18,190 16% 17,120 17% 18,190 17% 18,190

G 8% 8,496 8% 8,560 6% 6,420 7% 7,490 7% 7,490

H 32% 34,187 18% 19,260 12% 12,840 13% 13,910 12% 12,840

I 0.14% 150 4% 4,280 2% 2,247 3% 2,675 2% 2,140

J 0.50% 535 3% 3,210 6% 6,420 3% 2,675 4% 4,280

K 0.50% 535 4% 4,280 11% 11,770 5% 5,350 5% 5,350

L 17% 18,190 15% 16,050 10% 10,700 11% 11,770 10% 10,700

M 10% 10,700 9% 9,630 6% 6,420 6% 6,420 5% 5,350

N 12% 12,840 11% 11,770 11% 11,770 11% 11,770 11% 11,984

Total 100 107,000 100 107,000 100 107,000 100 107,000 100 107,000

Table B 18. Total habitat for species dependent on mesic mixed conifer for each 

alternative

Species States Current Alt. A Alt. B Alt. C Alt. D

MSO habitat (K, L, M) 5,698 5,801 5,594 4,558 4,144

Kaibab least chipmunk, K. 

N. Pocket gopher (C, D, E, J, K) 2,828 3,522 7,107 6,319 6,713

Table B-19 compares current existing conditions by vegetation “state” (used in the VDDT model 

runs) for ponderosa pine, with conditions expected to occur under implementation of each of the 

alternatives. Table B-20 displays specific species associated with ponderosa pine habitat and how 

their existing habitat (as defined by the vegetative states in Table B-14) would likely change by 

implementing the proposed alternatives. It combines the relevant vegetation states from Table B19 for each species into one value, to compare existing to future habitat by alternative. Further 

assumptions as noted above apply to the Mexican spotted owl and Kaibab squirrel.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 447
Appendix B. Methodologies and Analysis Processes

Table B 19. VDDT modeling used for species-dependent on ponderosa pine habitat, 

current condition, and each alternative after 15 years

Ponderosa Pine - VDDT - total acres on forest = 547,080

States Current Current 

Acres Alt. A Alt. A Acres Alt. B Alt. B Acres Alt. C Alt. C Acres Alt. D Alt. D Acres

A 9% 49,237 4% 21,883 5% 27,354 5% 27,354 5% 27,354

B 1% 4,924 3% 16,412 3% 16,412 3% 16,412 3% 16,412

C 4% 21,883 3% 16,412 4% 21,883 3% 16,412 3% 16,412

D 8% 43,766 10% 54,708 8% 43,766 12% 65,650 14% 76,591

E 3% 16,412 12% 65,650 11% 60,179 14% 76,591 18% 98,474

F 1% 5,4071 4% 21,883 4% 21,883 4% 21,883 4% 21,883

G 8% 43,766 8% 43,766 8% 43,766 7% 38,296 7% 38,296

H 25% 136,770 15% 82,062 10% 54,708 13% 71,120 10% 54,708

I 5% 27,901 3% 16,412 2% 10,942 2% 10,942 2% 10,942

J 7% 38,296 9% 49,237 13% 71,120 10% 54,708 8% 43,766

K 2% 10,942 5% 27,354 14% 76,594 8% 43,766 5% 27,354

L 22% 120,358 18% 98,474 13% 71,120 14% 76,591 17% 93,004

M 3% 16,412 4% 21,883 3% 16,412 3% 16,412 2% 10,942

N 2% 10,942 2% 10,942 2% 10,942 2% 10,942 2% 10,942

Total 100% 547,080 100% 547,080 100% 547,080 100% 547,080 100% 547,080

Table B 20. Total habitat for species-dependent on ponderosa pine habitat for each 

alternative

Species States Current Alt. A Alt. B Alt. C Alt. D

Goshawk habitat J, K, L, M 186,007 196,949 235,244 191,478 175,066

Mexican spotted 

owl habitat 

K, L, M (14% of PP 

meets PP/oak) 13,294 13,294 14,771 12,399 11,817

Allen lappetbrowed bat and 

bald eagle

D, E, H, I, J, K, L, M 410,857 415,781 404,839 415,781 415,781

Merriam’s shrew C, D, E, J, K 131,299 213,361 273,540 257,128 2562,598

Kaibab squirrel

E, H, I, J, K, L, M 

(28% of PP on 

NKRD)

102,785 101,100 101,100 98,037 94,973

Kaibab squirrel 

(optimal) J, K, L, M 52,082 55,146 65,868 53,614 49,018

448 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Watersheds, Soils, and Waters

Analyses used to determine the environmental consequences of implementing the plan 

alternatives on the soil and watershed resources were based on information in the Kaibab 

National Forest’s Terrestrial Ecosystem Survey (USDA Forest Service 1991), the Kaibab National 

Forest Comprehensive Evaluation Report (KNF 2009b), the Kaibab National Forest Supplement 

to the Comprehensive Evaluation Report (KNF 2010), information obtained from other Kaibab 

NF resource specialists, other agency reports, available literature, and input from Kaibab NF

collaborators and cooperators. Geospatial analysis was used to quantitatively and qualitatively 

assess soils and subbasin, watershed, and subwatershed conditions. Analyses were performed 

under the framework provided by the four primary needs for change identified in the plan. The 

Soils, Watersheds, and Waters Specialist Report contains a more detailed description of the 

analysis used for evaluating effects to soils, watersheds, and water resources (KNF 2013a)

Soils information from the terrestrial ecosystem survey (TES; available at 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5138598.pdf) and outputs from the 

Vegetative Dynamics Development Tool (VDDT) were used to determine the effects treatments 

under different plan alternatives would have on soil conditions. VDDT modeling results for each 

potential natural vegetation type (PNVT) were based on the range of acres of proposed treatment 

for each PNVT by alternative. The TES was used to evaluate and adjust land uses to the 

limitations and potentials of natural resources and the environment. Interpretations based upon 

TES incorporate: (1) soil physical and chemical properties; (2) climatic considerations; 

(3) topographic position and slope; (4) vegetation and anthropogenic influences as well as animal 

impacts; (5) productive and successional potentials; and (6) geologic influences. 

Effects to water quality were assessed qualitatively by alternative by comparing projected 

changes to current areas of water quality impairment and by comparing predicted indirect effects 

by major land-disturbing activities (e.g., forest thinning, animal grazing, roads, mining, and 

burning) to desired conditions set by Arizona authority under the Clean Water Act. Effects to 

water yield are discussed qualitatively, based on comparison of current activities to projected 

effects of implementing alternatives. Effects to groundwater availability are discussed 

qualitatively using regional studies and Forest Service policies to generally predict effects to the 

forests. Other watershed evaluation criteria discussed include the condition of streams and 

habitat, aquatic ecosystems, riparian vegetation, roads, soils, fire regime and effect, forest cover, 

rangelands and open areas, terrestrial nonnative invasive species, and forest health related to 

insects and disease. 

Nonnative Invasive Plants

For the purposes of this analysis, current known populations of noxious and invasive species were 

reviewed and incorporated as the affected environment along with discussion of how these 

species respond to management activities. How these populations could be affected by 

management activities and the potential for new infestations were analyzed for each alternative. 

Invasive seed vectors that provide the ability for seed to be moved from one area to another, and 

the level of disturbance generated by each alternative, were the primary evaluation criteria. The 

scale of potential activities and the impact to invasive species were also considered.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 449
Appendix B. Methodologies and Analysis Processes

Air Quality

Comparison of air quality impacts was analyzed using outputs from the Vegetation Dynamics 

Development Tool (VDDT). See the “Vegetation, Fuels and Fire” methodology section above for 

a description of VDDT. For a full discussion of the development, calibrations, and assumptions 

used in the VDDT models for the Kaibab NF, as well as all outputs from the model, refer to the 

Vegetation, Fire and Fuels Specialist Report (KNF 2013b).

VDDT models for ponderosa pine and frequent fire mixed conifer were developed by the Forest 

Service at the regional level to be used specifically to compare alternatives for forest land 

management plans in Region 3. For ponderosa pine and frequent fire (dry) mixed conifer, there 

are 14 states that are each defined by the variables of predominant diameter class, canopy cover, 

single storied versus multistoried, and potential for natural regeneration. States A, B, C, D, E, J, 

K, and N are “open states” in that canopy cover is 30 percent or less. The others 6 states are 

classed as “closed” with greater than 30 percent canopy cover.

This analysis used the running averages of acres of ponderosa pine and frequent fire (dry) mixed 

conifer treated by wildland fire from the objectives for each alternative as a fixed number per year 

to make broad comparisons among alternatives. In reality, the climatological, social, and 

logistical limits cause wide fluctuations in the number of acres treated each year.

Fuel model, fuel loading, and fuel moisture are highly variable over time and space. For making 

broad comparisons between the alternatives of “least,” “more,” and “most” air quality impacts, 

these inputs are greatly simplified. For site-specific projects, fuel loadings are more precisely 

estimated, and emissions are predicted in accordance with Arizona statutes and Arizona 

Department of Environmental Quality regulations.

The analysis did not attempt to predict the actual total emissions that would be produced under 

each alternative. Rather, it aims to present a rationale for which alternatives are likely to produce 

the “least,” “more,” and “most” emissions. It assumes that, over time, there is some degree of 

correlation between total emission production, and total air quality impacts; while impacts are 

measured as the concentration of emissions, not the total amount of emissions, over the course of 

10, 50 or 250 years, the alternative that produces the most emissions is likely to produce the most 

air quality impacts. Though meteorological conditions vary immensely by time of day, and from 

one weather system to the next, over the course of years these varying conditions should have an 

averaging effect over time, allowing a correlation between total emissions and total impacts. 

Recreation

Probable management activities related to alternatives A, B, C and D were used to evaluate or 

predict long- and/or short-term effects on recreation settings. These activities were evaluated in 

relation to their effects on recreation settings, opportunities, and/or experiences. The analysis used 

the running averages of acres of ponderosa pine and frequent fire (dry) mixed conifer treated by 

wildland fire, acres mechanically treated (thinned) and acres identified for potential wilderness 

areas from the objectives for each alternative as fixed numbers per year in order to make broad 

comparisons between alternatives.

450 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix B. Methodologies and Analysis Processes

Scenery

The key indicator used in the analysis to determine how the alternatives would affect scenery is in 

the scenic integrity objectives (SIOs) adopted for each alternative and the level at which various 

management activities are evident or meet an acceptable threshold of dominance. The term 

“scenic integrity objective” refers to the degree of acceptable visual alteration of the landscape 

and is defined as a desired level of scenic excellence based on physical and sociological 

characteristics of an area. Typically, more stringent or very high SIOs are incorporated to protect 

the most highly visible and frequently seen areas that have the greatest variety in vegetation and 

other naturally occurring features. SIOs are rooted in the Scenery Management System (SMS). 

The SIOs applicable to the Kaibab NF revised forest plan are:

Very High: The characteristic landscape is intact, with only minute deviations.

High: The characteristic landscape appears intact. Deviations may be present, but must 

repeat form, line, color, texture, and pattern common to the landscape character so 

completely and at such a scale that they are not evident.

Moderate: The landscape appears slightly altered. Noticeable deviations are visually 

subordinate to the landscape character.

Low: The landscape appears moderately altered. Deviations may be dominant, but are 

shaped to borrow from the natural landform and other visual dominance elements (line, 

form, texture, color), and are subordinate to the characteristic landscape when viewed as 

a background.

Probable management activities related to the alternatives were used to evaluate or predict longand/or short-term effects on scenery. Activities were evaluated in relation to their ability to meet 

or exceed forestwide desired SIOs established in the revised forest plan.

This analysis used the running averages of acres of ponderosa pine and frequent fire (dry) mixed 

conifer treated by wildland fire, acres mechanically treated (thinned), and acres for potential 

wilderness areas from the objectives for each alternative as a fixed number per year in order to 

make broad comparisons between alternatives.

Heritage Resources

Data on Kaibab cultural resources used for this analysis are derived from field data collected over 

several decades. Since the 1960s, archaeologists have conducted over 1,700 intensive pedestrian 

surveys for cultural resources in advance of Federal undertakings under Sections 106 and 110. In 

this manner, approximately 30 percent of the forest has been surveyed for heritage resources and 

over 9,600 archaeological sites have been identified and documented. Spatial data for all of these 

surveys and sites are maintained in the Kaibab Heritage Resource Geodatabase. In addition, the 

Forest Service uses the INFRA database system to maintain descriptive data on each heritage 

property. Such data include site condition, site type, and monitoring information. This analysis 

combines both INFRA and Geodatabase data.

Transportation

Information related to the forest road system was obtained from the Infra Database (I-Web), the 

database of record for the transportation system and facilities, and from the Kaibab Geographic 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 451
Appendix B. Methodologies and Analysis Processes

Information System (GIS). GIS is a spatial tool and is linked to the Infra Database. The data 

include but are not limited to miles of roads, maintenance levels of roads, features of the roads 

(culverts, grade dips, cattleguards, etc.), road management objectives, maintenance items, and 

costs. The data reflect the current motorized transportation system and administrative facilities to 

the best of our available knowledge, how the forests have been managing the motorized 

transportation system and administrative facilities, and how the public has been using the 

motorized transportation system.

Socioeconomic Analysis

The socioeconomic affected environment was described by a number of demographic variables 

including: assessment area population (growth and density), age and gender, education, ethnicity, 

and poverty status. Economic variables included in the description of the affected environment 

included income and (un)employment, economic diversity, and Kaibab NF payments to counties. 

Data were obtained from a variety of published sources including: the University of Arizona, U.S. 

Bureau of Census, U.S. Bureau of Economic Analysis, and the U.S. Bureau of Labor Statistics. 

Additionally, data and information were provided by the Forest Service TEAMS Enterprise Unit 

in a Socioeconomic Resource Report (Eichman and Jaworski 2012)

The potential consequences of alternative management scenarios on the socioeconomic 

environment were evaluated by economic impact analysis and financial efficiency analysis. 

Economic impact analysis estimates the employment and labor income consequences of forest 

management actions. Economic impacts were modeled using IMPLAN5 Professional Version 3.0 

with 2009 data. Economic impacts were presented in terms of employment (jobs) and income 

resulting from the different alternatives.

Financial efficiency analysis was conducted with QuickSilver6 Version 6. Data on program 

revenues were collected from the Final National Forest Statement of Receipts (ASR-13-1). Data 

on program costs were provided by the Kaibab NF budget staff. These figures are based on 

average expenditures over the past 5 fiscal years (FY 2006 to 2010). We cannot predict or assume 

increases or decreases in budget levels, therefore the forest budget data are held constant over the 

10-year period and are applicable to all alternatives. Financial efficiency analysis compares forest 

expenditures and revenues for the expected life (10 to 15 years) of the forest plan.

5 IMPLAN (IMpact analysis for PLANing, Minnesota IMPLAN Group, Inc.), is a regional economic impact analysis 

system that uses county level, input-output data to determine the extent to which these activities (such as livestock 

grazing or timber harvest) contribute to the local economy. Input-output analysis traces linkages among the structural 

parts of an economy.

6 QuickSilver is a program for economic analysis of long-term, on-the-ground resource management projects. It 

provides a consistent benefit/cost framework to determine if one management action costs less or has a better payoff 

than others.

452 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

 
Appendix B. Methodologies and Analysis Processes

References

Dixon, G.E. 2002 (Revised 2009). Essential FVS: a user's guide to the Forest Vegetation 

Simulator. Internal Rep. Fort Collins, CO: USDA Forest Service, Forest Management 

Service Center. 220 pp.

Eichman, H. and D. Jaworski. 2012. Socioeconomic Resource Report. TEAMS Enterprise Unit.

30 pp.

Fulé, P.Z., W.W. Covington, M.M. Moore, T.A. Heinlein, and A.E.M. Waltz. 2002. Natural 

variability in forests of the Grand Canyon, USA. Journal of Biogeography 29:31-47.

Haire, S.L. and K. McGarigal. 2010. Effects of landscape patterns of fire severity on regenerating 

ponderosa pine forests (Pinus ponderosa) in New Mexico and Arizona, USA. Landscape 

Ecology 25:1055−1069.

Higgins, B.J. 2008. A Comparative Analysis of Forest Recovery After Uncharacteristic Fire in 

Ponderosa Pine Forest. Williams, AZ.

Higgins, B.J. 2011. VDDT Analysis Process of the Kaibab National Forest. Williams, AZ: Kaibab 

National Forest.

Huffman, D.W., M.M. Moore, W.W. Covington, J.E. Crouse, and P.Z. Fulé. 2001. Ponderosa 

Pine Forest Reconstruction: Comparisons with Historical Data. USDA Forest Service 

Proceedings RMRS-P-22.

Lang, D.M. and S.S. Stewart. 1909. Reconnaissance of the Kaibab National Forest. USDA Forest 

Service, Kaibab National Forest.

Savage, M. and J.N. Mast. 2005. How resilient are southwestern ponderosa pine forests after 

crown fires? Canadian Journal of Forest Research 35:967–77.

Triepke, F.J., B.J. Higgins, R.N. Weisz, J.A. Youtz, and T. Nicolet. 2011. Diameter Caps and 

Forest Restoration: Evaluation of a 16-inch cut limit on achieving desired conditions. 

USDA, Forest Service Forestry Report, FR-R3-16-3, Southwestern Region, Albuquerque, 

NM. 31 pp.

USDA Forest Service. 1991. Terrestrial ecosystem survey of the Kaibab National Forest. 

Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5138598.pdf.

USDA Forest Service. 2009. Plan Revision: Regional Guidance (Region 3). Available at 

http://www.fs.usda.gov/detail/r3/landmanagement/planning/?cid=stelprdb5177400. 

Accessed 23 May 2013. 

USDA Forest Service, Kaibab National Forest (KNF). 2007. Warm Fire Assessment Post-Fire 

Conditions and Management Considerations. Unpublished Report Kaibab National Forest 

April 2007. 83 pp.

USDA Forest Service, Kaibab National Forest (KNF). 2009a. The Kaibab forest health focus: 

collaborative prioritization of landscapes and restoration treatments on the Kaibab 

National Forest. Williams, AZ: Kaibab National Forest

USDA Forest Service, Kaibab National Forest (KNF). 2009b. Kaibab National Forest 

Comprehensive Evaluation Report. Unpublished report to the USDA Forest Service 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 453
Appendix B. Methodologies and Analysis Processes

Southwestern Regional Office. On file at the Kaibab National Forest Supervisor’s Office, 

Williams, AZ. Available at 

http://prdp2fs.ess.usda.gov/Internet/FSE_DOCUMENTS/fsm91_050073.pdf.

USDA Forest Service, Kaibab National Forest (KNF). 2010. Management indicator species of the 

Kaibab National Forest: An evaluation of population and habitat trends. Prepared by 

Foster, V. S., Nobel, B., Bratland, K., Joos, R. Williams, AZ: Kaibab National Forest. 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5114494.pdf. 

USDA Forest Service, Kaibab National Forest (KNF). 2013a. Kaibab National Forest Soils and 

Watershed Specialist Report for the Forest Plan Revision FEIS. Williams, AZ: Kaibab 

National Forest.

USDA Forest Service, Kaibab National Forest (KNF). 2013b. Kaibab National Forest Air Quality 

Specialist Report for the Forest Plan Revision FEIS. Williams, AZ: Kaibab National 

Forest.

Weisz, R. et al. 2011. White Paper O: Process Overview of Using FVS to Create VDDT Models. 

U.S. Department of Agriculture, Forest Service, Southwestern Region, Regional Office, 

Albuquerque, NM. Interoffice publication. 32 p.

Woolsey, T.S., Jr. 1911. Western yellow pine in Arizona and New Mexico. Bulletin 101. U.S. 

Department of Agriculture, Forest Service. 64 p.

454 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix C. Timber Suitability Calculation, 

Financial Analysis, ASQ, and LTSY

National Forest System (NFS) lands were reserved with the intent of providing goods and 

services to satisfy public needs over the long term. These goods include the production of a 

sustainable supply of forest products. The NFMA requires that NFS lands be classified as to their 

suitability for timber production. Timber production is defined as “the purposeful growing, 

tending, harvesting, and regeneration of regulated crops of trees... for industrial or consumer use” 

(36 CFR 219.3).

Calculating Acres of Suitable Timber 

A multistep GIS analysis was conducted on all NFS lands managed by the Kaibab National Forest 

(NF) to categorize acres of land as suitable and not suitable for timber production. 

The 1982 Planning Rule provisions state that lands within any one of the categories described 

below shall be identified as not suited for timber production:

1. The land is not “forest land.”6

2. Technology is not available to ensure timber production from the land without 

irreversible resource damage to soils productivity or watershed conditions.

3. There is not reasonable assurance that such lands can be adequately restocked.

4. The land has been withdrawn from timber production by an Act of Congress, the 

Secretary of Agriculture, or the Chief of the Forest Service.

The analysis began by removing lands within the Kaibab NF boundary not administered by the 

forest: Equation 1: Finding All NFS Lands

All NFS Lands = Forest boundary – Land not managed by Kaibab NF

where “forest boundary” is the Kaibab NF boundary layer and “land not managed by the Kaibab 

National Forest” includes Camp Navajo and lands of other ownership.

Next, lands not suitable for timber production were isolated based on the four categories outlined 

in the planning rule provisions as well as lands classified as “nonindustrial” (which include lands 

incapable of producing industrial wood or lands producing trees not currently utilized or not 

expected to be utilized for timber production) were included:

Equation 2: Finding Lands Not Suitable for Timber Production 

6 Forest land is defined as “land at least 10 percent occupied by forest trees of any size or formerly having had such tree 

cover and not currently developed for non-forest use” (36 CFR 219.3).

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 455

 
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Not suitable for timber production = Σ

Non-Forested

Withdrawn

Irreversible resource damage

Adequate restocking not assured

Nonindustrial

Timber component codes (Timco), vegetation cover type from the vegetation stands GIS layer, 

and existing wilderness areas were used to classify lands into the categories not suitable for 

timber production (table C 1). Timcos are codes assigned to each stand in the vegetation database 

that identify areas of suitability or non-suitability for timber production and also identify areas of 

management for activities other than timber production. More detailed descriptions of Timco 

codes are contained in the Rocky Mountain Resource Information System User Guide (RMRIS) 

Data Dictionary, Appendix 12 (USDA Forest Service 2002). The Kaibab NF updates the

vegetation database when changes in management or site specific information indicate a change 

to suitability for timber production.

Table C 1. Categories of lands not suitable for timber production and the specific 

attributes used to classify these categories

Not Suitable for Timber 

Production Category Specific Attribute Used to Categorize

Lands of other ownership Timco = 001 and 100 (water) and 200 (non-forest)

Withdrawn lands Timco = 300 (withdrawn by law or pending final action) and 301 (existing 

wilderness areas)

Irreversible resource damage

Timco = 730 (irreversible resource damage-general), 720 (current 

techniques prevent harvesting), 721 (topography limitations), 722 (does not 

meet plan criteria), and 700 (unsuitable timberland) where the cover type 

was ponderosa pine, Douglas-fir, treeland, or white fir.

Adequate restocking not assured Timco = 710 (e.g., naturally open areas due to microclimates, etc.)

Nonindustrial

Timco = 900 (nonindustrial–incapable of producing industrial wood), 901 

(nonindustrial–aspen), 950-963 (suitable woodlands), 970 (unsuitable 

woodlands), and 700 (unsuitable timberland) where the cover type was 

aspen, pinyon-juniper, juniper, oak, and any other hardwoods.

Lands tentatively suitable for timber production were then calculated by subtracting unsuitable 

timber lands (Equation 2) from the “All NFS Lands” layer (Equation 1):

Equation 3: Finding Lands Tentatively Suitable for Timber Production

Tentatively Suitable (TS) = All NFS Lands – Not suitable for timber production

Table C 2 displays the results of these calculations. The categories in table C-1 apply to all 

alternatives, so the tentatively suitable land does not differ by alternative.

456 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 2. Calculation of acres of land tentatively suitable (same for all alternatives) 

Category Acres by Alternative

A B C D

All NFS lands 1,543,265*

 Non-forested (includes nonindustrial) -847,376

 Irreversible resource damage -54,265

 Adequate restocking not assured -21,834

 Withdrawn (219.14(a)(4)) -117,563

 Subtotal: Lands not suitable for timber production 1,041,038

Lands tentatively suitable for timber production (All NFS 

lands minus “not suitable” categories) 502,227

* Acreages of NFS lands may vary slightly over time due to factors such as resurvey, improved mapping technology, 

and updates to corporate GIS layers.

The next stage of the analysis determined areas not appropriate for timber production. These 

include areas that are either not desirable or not feasible to manage for periodic harvests of forest 

products and lands where management prescriptions preclude timber production, where 

management requirements cannot be met, and where harvest would not be cost efficient in 

meeting timber objectives.

Equation 4: Finding Tentatively Suitable Lands Not Appropriate for Timber Production

TS Lands Not Appropriate for Timber 

Production =

Σ Mgmt prescription precludes timber production

Management requirements cannot be met

Not cost efficient in meeting timber objectives

The lands “not appropriate for timber production” vary by alternative. Table C 3 outlines these 

differences.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 457
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 3. Categories of not appropriate for timber production by alternative

Not 

Appropriate 

for Timber 

Production 

Category

Alternative A Alternative B Alternative C Alternative D

Management 

prescriptions 

preclude timber 

production

Timco = 800, 801, 

and 803 

(incompatible with 

multiple-use critical 

wildlife habitat), 

plus 813 (developed 

recreation sites), 

plus any developed 

recreation sites 

currently coded as 

suitable.

Same as 

alternative A, plus 

alternative B 

recommended 

wilderness, plus 

grassland PNVTs 

previously 

classified as 

suitable for 

timber production 

Same as alternative 

B, plus areas within 

the North Kaibab 

Wildlife Habitat 

Complex that were 

previously classified 

as suitable for timber 

production, plus 

recommended 

wilderness under 

alternativess C and D

Management 

prescriptions would 

preclude all lands 

from timber 

production. 

Management 

requirements 

cannot be met

Timco = 820 

(minimum mgmt 

requirements for 

resource protection, 

vegetative 

manipulation, 

silvicultural 

practices, evenaged management, 

riparian areas, soil 

and water, and 

diversity cannot be 

met).

Timco = 820 Timco = 820 N/A

Not cost 

efficient in 

meeting timber 

objectives (see 

further 

explanation 

below)

Timco = 850-880 

(cost efficiency–

low product value, 

road concerns, 

isolated patches, 

high logging costs)

Same as 

Alternative A, 

plus isolated 

polygons under 

160 acres that 

were suitable in 

Alternative A.

Same as Alternative 

B (resulting acres 

differ because of 

areas previously 

removed due to 

management 

prescriptions). 

N/A

Finally, lands suitable for timber production were determined for each alternative as follows:

Equation 5: Finding Lands Suitable for Timber Production

Suitable for Timber Production = Tentatively Suitable – TS Lands Not Appropriate for Timber Production

Calculated acres for each category and alternative are displayed in table C 4.

458 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 4. Calculations for acres not appropriate for timber production by alternative. 

Negative values indicate acres that were removed from the lands tentatively suitable for 

timber production 

Land Category Acres by Alternative

A B C D

Tentatively suitable for timber production 502,227

 Mgmt prescriptions preclude timber production -80,829 -90,782 -249,207 -501,046

 Management requirements cannot be met -20,298 -16,903 -10,944 N/A

 Not cost efficient in meeting timber objectives -141 -13,025 -11,520 N/A

 Subtotal: Not appropriate for timber production -101,268 -120,710 -271,671 -501,046

Total suitable for timber production 400,959 381,517 230,556 0

Many mostly small areas were identified as “not cost efficient” in meeting timber objectives due 

to the excessive costs (e.g., road construction) and low/negative returns that would be associated 

with timber harvesting (preparation/logging costs) and removal (haul costs) in these areas. These 

include small portions of otherwise suitable land with low product value (Timco 850), high road 

construction costs (Timco 860), high logging costs (Timco 880), or areas that exist as isolated 

patches of otherwise commercial timberland (Timco 870). Additionally, under alternatives B and 

C, other isolated patches of timber lands less than 160 acres were removed from the suitable 

timber base.

Cost efficiency is an important consideration in determining timber suitability. For example, road 

construction costs range from $15,000 to $25,000 per mile compared to reconstruction costs for 

existing roads, which range between $5,000 and $8,000 per mile. Once new roads are 

constructed, they must be either maintained at an average cost of $500 to $800 per mile each 

decade or be obliterated and seeded at an estimated cost of $2,000 per mile. In many of these 

areas, harvest volumes are low and harvest preparation and logging costs are excessively high. 

When ground-based mechanical (tractor) logging is not feasible and other harvesting systems 

(e.g., cable/helicopter) are required, logging costs generally increase by 200 to 500 percent. In 

areas that would have very high operating costs, regular entry for purposes of timber production 

is not financially feasible. This is particularly true under the current conditions, where even on 

tractor-operable and currently roaded areas, all prescriptions have negative present net value 

(table C 7). Due to the associated high costs and/or limited returns to harvest-limited commercial 

volume, lands identified as not cost efficient were removed from the suitable timber base. 

Figure C 1 depicts suitable timberlands by each alternative. Alternative D removes all lands on 

the Kaibab NF from the suitable timber base, so this alternative is not mapped.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 459
460 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Appendix C. Timber Suitability Calculation

Figure C 1. Suitable timberlands for each alternative (Note: Alternative D has no suitable timber lands).
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Financial Evaluation

The Planning Rule provisions at Section 219.14(b) also require that forest lands determined 

suitable for timber production “shall be further reviewed and assessed... to determine the costs 

and benefits for a range of management intensities for timber production.” To meet this 

requirement, the Kaibab NF used the financial evaluation spreadsheet from the WO/EMC TIPS 

Web site. The spreadsheet incorporates information regarding harvest volumes, revenues, and 

costs over time to calculate the per acre present net value (PNV) at discount rates of 3, 4, and 7 

percent. The spreadsheet was completed based on the guidelines contained in plan alternatives for

those acres identified as tentatively suitable (see EXCEL spreadsheet FEIS Timber Suitability 

PNV Analysis 2_2013 in the project record).

The management intensities/prescriptions applied in alternatives and analyzed are: free thin all 

sizes to an assumed average target basal area of 50 square feet per acre, group select with matrix 

thin to an assumed average target basal area of 60 square feet per acre, and thin under diameter 

limit 16 inches d.b.h. to an assumed average target basal area of 60 square feet per acre. Data and 

methods used to estimate PNV for each alternative are described below.

Alternative A

The average revenue/ccf was based on actuals for the years 2006 to 2010. These data were 

obtained from USFS Cut and Sold Reports. The average calculated revenue was $6.72/ccf (see 

EXCEL spreadsheet FEIS Timber Suitability PNV Analysis 2_2013 in the project record). The 

estimated per acre harvest volume of 4.77 ccf is based on the volumes produced for acres treated, 

by prescription, by VDDT state (see EXCEL spreadsheets Acre&Vol data Timb Suitability and 

Recalculation of MCD & PP vols NKRD & South Zone in the project record).

Alternative B

The information used to estimate volumes, costs, and revenues for alternative B is based on 

estimates produced for the Four Forest Restoration Initiative (4FRI) project/contract. These data 

are summarized and presented in tables C 5 and C 6. The majority of the timber harvested on the 

South Zone over the next 10 years is expected to be under 4FRI contracts. While the North 

Kaibab Ranger District is not included in the 4FRI contract, the same data are used since the 

prescriptions applied will be the same on the North Kaibab Ranger District (in accordance with 

the forest plan).

Table C 5. Estimated average volume (green tons), by size class, removed under 4FRI 

contract on the Williams Ranger District

Green Ton 

Estimates

Size Class

0-5.9" 6-8.9" 9-11.9" 12+" Tons/Acre

Green tons per acre (goods)

Average 0.00 2.30 4.41 11.92 18.63

Green tons per acre (residue)

Average 0.69 1.53 2.38 4.41 9.01

Green tons per acre (total)

Average 0.69 3.83 6.79 16.33 27.64

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 461
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 6. Estimated costs (residue/biomass) and revenues (goods) for volumes removed 

under the 4FRI contract on the Williams Ranger District

PP 0-5.9" PP 6-8.9" PP 9-11.9" PP 12.0"+ Totals

Total green tons per acre 0.69 3.83 6.79 16.33 27.64

% green ton residue 100% 40% 35% 27%

$ per green ton goods $3.50 $3.50 $3.50 $3.50 

$ per green ton residue ($3.50) ($3.50) ($3.50) ($3.50)

Green ton goods per acre 0.00 2.30 4.41 11.92 18.63

Green ton residue per acre 0.69 1.53 2.38 4.41 9.01

$ per acre for goods $0.00 $8.04 $15.45 $41.72 $65.21 

$ per acre for residue ($2.42) ($5.36) ($8.32) ($15.43) ($31.53)

Total $ to Forest Service per acre ($2.42) $2.68 $7.13 $26.29 $33.68 

Alternative C

In alternative C, the free thin all sizes to an assumed average target basal area of 50 square feet 

per acre and group select with matrix thin to an assumed average target basal area of 60 square 

feet per acre prescriptions are applied only on the South Zone. Volume, cost, and revenue 

estimates for the North Kaibab Ranger District were based on those associated with the thin under 

diameter limit 16 inches to an assumed average target basal area of 60 square feet per acre

prescription. Weighted averages were calculated based on these assumptions. Detailed methods 

and calculations are found in EXCEL spreadsheet FEIS Timber Suitability PNV Analysis 2013 in 

the project record.

Alternative D

Under alternative D, there are no suitable timber lands. The analysis for alternative D is 

completed and presented for regulatory and informational purposes. The only prescription 

analyzed under alternative D was the thin under diameter limit 16 inches to an assumed average 

target basal area of 60 square feet per acre prescription.

Under these cost and revenue assumptions, all estimated net revenues were negative (table C 7). 

The thin under 16 inches diameter to target basal area of 60 square feet per acre produced the 

highest negative values at all discount rates.

462 FEIS for the Kaibab National Forest Land Management Plan
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 7. Per acre present net value (PNV), by alternative

PNV by Discount Rate Alternative 

A

Alternative 

B

Alternative 

C

Alternative 

D

Undiscounted net revenue -$2,916.89 -$1,828.66 -$2,089.24 -$3,280.74

PNV @ 3% - $662.87 - $405.56 - $462.69 - $747.53

PNV @ 4% - $554.67 - $336.80 - $384.99 - $626.72

PNV @ 5% - $423.95 - $252.64 - $290.27 - $481.33

The Planning Rule Provisions at Section 219.14(c) require a consideration of costs and benefits 

for alternative management of the lands as identified in 219.14.b (TABS 2010). Management 

prescriptions (in this case for timber harvest) shall be defined to meet management objectives for 

the various multiple uses including outdoor recreation, timber, watershed, range, wildlife and fish, 

and wilderness. It should be noted that in the revised Forest plan, there are no objectives for 

timber output (thousand board feet (MBF) or hundred cubic feet (CCF). However, there are 

objectives for acres of mechanical treatment to achieve or progress toward desired conditions. 

Unlike the previous forest plan (1987), the revised plan is focused on outcomes, not outputs.

Lands were identified as “suitable for timber production” when the strategy for achieving and 

maintaining the desired conditions and objectives would involve planned, periodic timber 

harvests. Designation of “lands suitable for timber production” does not imply that management 

would be focused on maximizing timber yields, only that periodic harvests are expected to occur 

as a tool for achieving or maintaining desired conditions with a minimum level of regeneration 

(Youtz and Vandendriesche 2011).

The forest objective relative to the mechanical harvest of trees is the number one priority need for 

change: 

• Modify stand structure and density toward reference conditions and restore historic fire 

regimes.

The provisions at Section 219.12(f)(8) state that each alternative shall represent to the extent 

practicable the most cost efficient combination of management prescriptions examined that can 

meet the objectives established in the alternative.

By producing the least negative net revenue, the combination of free thin all sizes to an average 

target basal area of 50 square feet per acre and group select with matrix thin to an average target 

basal area of 60 square feet per acre are the most cost efficient combination of management 

prescriptions (table C 7).

Allowable Sale Quantity and Long-term 

Sustained Yield

The NFMA at Section 13 (limitations on timber removal) and the 1982 Planning Rule Provisions 

at Section 219.16 (timber resource sale schedule) require that timber harvest levels be based on 

the principle of sustained yield. Long-term sustained yield (LTSY) is the uniform wood yield 

from lands being managed for timber production that may be sustained under a specified 

management intensity consistent with multiple-use objectives. Allowable sale quantity (ASQ) is 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 463
Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

the quantity of timber that is planned to be sold from the suitable timberland covered by the forest 

plan for a time period specified by the plan. ASQ is usually expressed on an annual basis as the 

“average annual allowable sale quantity” because it may be exceeded in a given year as long as 

the 10-year average is not exceeded. ASQ and LTSY apply only to those lands that are suitable 

for timber production where there is intent to have regular harvests that produce commercial 

timber products.

These provisions allow for the establishment of an ASQ to depart from (exceed) the projected 

LTSY provided that such planned departure is consistent with and leads to the better attainment of 

multiple-use management objectives. 

The ponderosa pine and dry mixed conifer PNVTs are currently departed from reference 

conditions in terms of density, structure, and susceptibility to unnatural high-severity crown fire. 

In order to make progress toward the desired conditions in the ponderosa pine and frequent fire 

mixed conifer vegetation types, timber harvest levels will need to be significantly higher than the 

estimated LTSY until the desired density and structure is attained. LTSY is roughly equal to 

production or growth that can be sustained over time. LTSY is only applicable once the desired 

structure and density have been achieved.

Tables C 8 through C 13 display ASQ calculations for the ponderosa pine and dry mixed conifer 

PNVTs for the revised plan (alternative B), based on the VDDT analysis described in the 

Vegetation and Fire Specialist Report. The shaded boxes indicate the VDDT states (see appendix 

B) to which each prescription can be applied and from which volumes can be produced. Volumes 

in shaded boxes were the only volumes used to calculate PNV, ASQ, and LTSY.

464 FEIS for the Kaibab National Forest Land Management Plan
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 465

Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

The following is the key to vegetation condition descriptions for VDDT States referenced in tables C-8 through C-13:

C_SMO = small, open I_VCS = very large, closed, single story 

D_MOS = medium, open, single story J_MOM = medium, open, multistory

E_VOS = very large, open, single story K_VOM = very large, open, multistory 

F_SSC = seedling/sapling, closed L_MCM = medium, closed, multistory 

G_SMC = small, closed M_VCM = very large, closed, multistory

H_MCS = medium, closed, single story 

Table C 8. Average yield per acre (CF) in ponderosa pine/grass PNVT by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to target basal area 50 square feet per acre

5 - 9" d.b.h. (CF) for ASQ 

Calcs 5.90 25.48 10.78 31.75 371.44 153.91 25.28 15.10 15.14 154.14 124.16

9+" d.b.h. (CF) for ASQ Calcs 0.00 142.37 353.40 76.43 263.63 534.30 2,374.48 220.55 508.61 805.89 1,700.99

Group selection with matrix thin to 60 square feet per acre

5 - 9" d.b.h. (CF) for ASQ 

Calcs 22.23 0.00 0.00 0.00 140.56 0.90 11.86 4.53 112.15 82.04

9+" d.b.h. (CF) for ASQ Calcs 78.48 260.28 0.00 0.00 523.83 1,442.56 93.62 279.70 771.45 1,293.04

Table C 9. Average annual acres treated in ponderosa pine/grass PNVT by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to 

target BA 50 ft2

/ac 0 0 0 213 662 0 0 0 0 0 0

Group Selection with 

matrix thin to 60 ft2

/ac 0 2022 1366 0 0 4,209 823 0 0 4,201 472

Table C 10. Average annual yield (CF/ac x acres) in ponderosa pine/grass by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to target basal area 50square feet per acre
466 FEIS for the Kaibab National Forest Land Management Plan

Financial Analysis, ASQ, and LTSYAppendix C. Timber Suitability Calculation,

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

5 - 9" d.b.h. (CF) 

for ASQ Calcs 6,755 245,988

9+" d.b.h. (CF) for 

ASQ Calcs 16,260 174,589

Group selection with matrix thin to 60 square feet per acre

5 - 9" d.b.h. (CF) 

for ASQ Calcs 44,936 0 591.608 743 471,132 38,705

9+" d.b.h. (CF) for 

ASQ Calcs 158,675 355,636 2,204,706 1,187,609 3,240,78

7 610,003

Table C 11. Average yield per acre (CF) in dry mixed conifer PNVT by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to target basal area 50 square feet per acre

5 - 9" d.b.h. (CF) for ASQ 

Calcs 0.00 8.75 20.47 36.97 247.57 158.40 0.00 23.09 12.38 142.61 63.39

9+" d.b.h. (CF) for ASQ 

Calcs 2.47 95.74 70.02 409.89 416.73 987.15 2,157.45 220.55 508.61 901.02 1,442.85

Group selection with matrix thin to 60 square feet per acre

5 - 9" d.b.h. (CF) for ASQ 

Calcs 0.00 0.00 129.85 0.00 15.84 0.00 106.55 13.74

9+" d.b.h. (CF) for ASQ 

Calcs 31.38 77.26 748.70 1,530.37 65.96 367.04 658.07 1,008.88
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 467

Appendix C. Timber Suitability Calculation,

Financial Analysis, ASQ, and LTSY

Table C 12. Average annual acres treated in dry mixed conifer PNVT by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to target 

basal area 0 0 0 296 101 0 0 0 0 0 0

Group select with matrix thin 0 0 0 0 0 435 61 0 0 465 394

Table C 13. Average annual yield (CF/ac x acres) in dry mixed conifer by prescription, by applicable VDDT state

Prescription C_SMO D_MOS E_VOS F_SSC G_SMC H_MCS I_VCS J_MOM K_VOM L_MCM M_VCM

Free thin all sizes to target basal area

5 - 9" d.b.h. (CF) for ASQ 

Calcs 10,942 25,004

9+" d.b.h. (CF) for ASQ Calcs 121,327 42,090

Group selection with matrix thin

5 - 9" d.b.h. (CF) for ASQ 

Calcs 56,484 0 49,546 5,415

9+" d.b.h. (CF) for ASQ 

Calcs 325,683 93,535 306,004 397,497

Note: All dry mixed conifer PNVT acres treated and volumes removed come from the North Kaibab Ranger District.
Appendix C. Timber Suitability Calculation, 

Financial Analysis, ASQ, and LTSY

LTSY calculations provided by the Southwestern Region (Youtz and Vandendriesche 2011) were 

used for the Kaibab NF LTSY estimates. Table C 14 displays the ASQ and LTSY for each 

alternative.

Table C 14. Allowable sale quantity and long-term sustained yield, volumes (CCF) by 

alternative

Alternative A* Alternative B Alternative C Alternative

D

Allowable sale quantity 152,300 CCF+ 107,815 CCF 60,970 CCF 0

Long-term sustained yield 216,200 CCF 74,737 CCF 45,148 CCF 0

* Volumes shown for alternative A are from the current forest plan

CCF = hundred cubic feet

Alternative A is the current plan, which had a goal that emphasized timber production primarily 

using even-aged management. Under the previous forest plan (1988), the objective was to 

increase timber yield each decade until it reached the desired long-term sustained yield. The 

timber production level expected in the first 10 years of the current plan was 22.9 million cubic 

feet per year. The highest volume removed on the Kaibab NF for any year in the past 30 years

was 17.25 million cubic feet (1987). The potential volumes identified in the original plan were 

never achieved. Over the past five years, the annual volume sold on the Kaibab NF has ranged 

between 10,000 and 15,000 CCF. The harvest volume levels under alternative A were not 

achieved, and would no longer be desirable because the desired conditions have shifted from 

relatively young even-aged under the old plan to relatively old uneven-aged structure under the 

proposed new plan. 

The suitable timber lands are currently highly departed in terms of density, structure, and 

susceptibility to unnatural high-severity crown fire. As a result, alternatives B and C have an ASQ 

that is higher than the LTSY. This planned departure from the LTSY will be needed for at least 

seven decades to achieve the desired density and structure consistent with other multiple-use 

management objectives.

Under alternative D, there are no lands identified as suitable for timber production. As a result, 

the ASQ and LTSY for alternative D is zero. 

Figure C 2 assumes full capacity to implement mechanical thinning at the rate identified in the 

objectives in the plan. Actual capacity may be limited due to lack of product utilization 

infrastructure, budget, or successful project planning. Although the estimated number of years in 

each phase of departure would vary depending on the actual implementation rates, the pattern is 

expected to remain roughly the same. The total time from plan implementation to achievement of 

the desired density and structure is estimated to be between 70 and 100 years, with a minimum of 

20 years between treatments designed to achieve uneven-aged structure. Note that due to the 

current lack of infrastructure, the volumes during the first period may actually start below the 

ASQ and climb before flattening out at or near the ASQ.

468 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix C. Timber Suitability Calculation, 

Financial Analysis, ASQ, and LTSY

Figure C 2. Pattern of estimated departure between ASQ and LTSY for alternatives B and C

In the first two to three decades, volumes removed are expected to remain relatively stable. 

During this time, the forest would focus mechanical thinning efforts in the areas most at risk of 

loss to crown fires. These are the areas containing the greatest percentage of dense states that are 

dominated by trees in the larger size classes. These states are given higher priority because they 

are at risk of loss from uncharacteristic high-intensity wildfire, and it would take longer to replace 

the larger trees if they are lost (more than 100 years). The uneven-aged dense states dominated by 

large trees could potentially be treated to the desired open, uneven-aged state in one treatment. 

Once the desired density and structure is achieved, the areas would no longer contribute to the 

departure. Following the initial treatments in the even-aged, dense, large tree-dominated sites, the 

desired density would be achieved. However, these areas would not have the desired uneven-age 

class distribution, even with the new age cohort (regeneration) that would be expected following 

the initial treatment. These two-aged areas would be scheduled for a second treatment in phase 

two in order to progress toward or accomplish the desired uneven age condition.

Once all of the suitable areas in the dense large tree states (H, I, L, and M) have had one treatment 

(minimum of 25 years), the volume would drop and stabilize for another one or two decades, 

even though the implementation rate for mechanical restoration would be similar to the first 

period. During this second phase, the original dense even-aged states would receive a second 

treatment establishing new regeneration, and the younger dense states (F and G) would receive 

their first treatments. While implementation rates are expected to be stable, lower yields would 

likely result because the smaller dense states yield about half the volume of the larger states, and 

because the intensity of treatments on the second treatment of the areas in the larger states is 

expected to be lower than the first treatment. With a second treatment establishing a third age 

class, most of these stands would be in the desired uneven-aged open state and would no longer 

contribute to the departure.

In the third phase, the volumes would drop again to just above the LTSY level and then taper off 

to a zero departure, where harvest/ASQ would be equal to LTSY. During this last phase of 

departure, the areas with one or two age classes would receive their final restructuring treatments 

to establish regeneration and reduce density which would release the largest trees (component 

most lacking) so that they may grow more quickly and achieve the desired larger diameters. 

When all suitable timberlands are in the desired open uneven-aged condition, the yield of wood 

produced and harvested would stabilize at the identified LTSY. All treatments thereafter would 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 469
Appendix C. Timber Suitability Calculation, 

Financial Analysis, ASQ, and LTSY

focus on maintaining the desired conditions over time, while yielding a sustainable supply of 

wood in perpetuity.

Note that commercial wood volume may be produced from restoration treatments on non-suitable 

timberlands. On non-suitable timberland (all lands under alternative D), mechanical thinning 

would only be used to achieve the desired stand structure and density that would reduce large 

crown fire potential. Thereafter, the desired density would be maintained with fire. There is no 

long-term sustained yield or allowable sale quantity assigned to non-suitable areas.

References 

USDA Forest Service. 2002. Rocky Mountain Resource Information System (RMRIS) Data 

Dictionary: Appendices and Indices. 

Youtz, J. and D. Vandendriesche 2012. White paper K: LTYSC – Long term sustained yield 

calculations: the R3 FVS process for evaluating the effects of vegetation management 

activities in the forest plan revision process. Albuquerque, NM: Forest Service 

Southwestern Regional Office, Department of Agriculture.

470 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix D. Grazing

Suitability and Capability

The 1982 Planning Rule requires that the suitability of rangelands on NFS lands and their 

capability for producing forage for grazing animals be determined in forest planning. Capability 

is the potential of an area of land to produce resources and supply goods and services. Capability 

depends upon conditions such as climate, slope, landform, soils, and geology. Suitability is the 

appropriateness of applying certain resource management practices to a particular area of land in 

consideration of the relevant social, economic, and ecological factors. Lands within the plan area 

are not suitable if livestock grazing would be incompatible with the desired conditions or result in 

substantial and permanent impairment of the land.

Capability to produce forage for grazing animals was determined for the original forest plan.

Most landscape-scale conditions that influence capability have not changed significantly since the 

initial evaluation. However, the data and analysis tools used in the initial determination were not 

as accurate or precise as what is available today. Capability for this plan was reassessed using the 

corporate GIS data. Table D 1 displays the results of this analysis. The area capable for livestock 

grazing has about 12 percent fewer acres than the original forest plan. More detail about the 

process and rationale behind these calculations are documented in the white paper Grazing 

Capability Calculations for the Kaibab National Forest, which is filed in the project record.

Table D 1. Grazing capability calculations for the Kaibab National Forest 

Grazing Capability Category Acres

Gross area of Kaibab NF 1,600,321*

 Area not administered by the Forest Service (Camp Navajo and private lands) -57,056

 Net Analysis Area 1,543,265

 Slopes greater than 40 percent -165,672

 Severe erosion hazard (terrestrial ecosystem survey) -176,554

 Forage productivity less than 100 lb/ac/yr (based on TES) -87,921

Total “no capability” areas -430,147

Lands tentatively capable for livestock grazing 1,113,118

* Acreages of NFS lands may vary slightly over time due to factors such as resurvey, improved mapping technology, 

and updates to corporate GIS layers.

The original plan identified four management areas as unsuitable for livestock grazing: the 

Arizona Bugbane Botanical Area, Garland Prairie, Franks Lake Geologic/Botanic Area, and 

developed recreation sites. These management areas are still identified as unsuitable, but a 

219-acre adjustment was made to the area managed as developed recreation sites. Two developed 

recreation sites have been closed since the original plan was signed and they are no longer 

managed for recreation: Moqui Lodge and Benham Snowplay Area, 202 and 17 acres, 

respectively. The desired conditions for these areas would no longer preclude livestock grazing. 

As a result, this revised plan shows these areas as suitable. 

Since the original plan was approved, each allotment on the Kaibab NF has received site-specific 

environmental review for the authorization of grazing. The decisions for those analyses were 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 471
Appendix D. Grazing Suitability and Capability

reviewed for areas where livestock grazing was not authorized. Site specific NEPA identified 

three large contiguous areas were not authorized for grazing following environmental review: the 

Kanab Creek allotment, Jump-up pasture of the Central Winter allotment, and the Bill Williams 

Mountain portion of the Hat allotment. In this revised plan, these areas have been identified as not 

suitable for livestock grazing. Table D 2 summarizes portions of the Kaibab NF that are 

unsuitable for livestock grazing.

Table D 2. Areas unsuitable for grazing on the Kaibab National Forest 

Feature Acres Note

Arizona Bugbane Botanical Area 490

Management areas closed to grazing in 

the original forest plan.

Garland Prairie 340

Franks Lake Geologic/Botanic Area 145

Existing Developed Recreation Sites 1,556

Kanab Creek Allotment 39,280 Closed to grazing in site-specific NEPA 

decision in March 2001. Jump-up Pasture, Central Winter Allotment 15,745

Bill Williams Mountain, Hat Allotment 2,500 Closed to grazing in site-specific NEPA 

decision in September 2010.

Total Unsuitable Area 60,056

A suitable determination indicates that grazing is compatible with the desired conditions for the 

relevant portion of the plan area. It is guidance for project and activity decision making, and is 

not a commitment or a final decision. It does not mean that grazing will or will not occur in a 

particular area. The final decision to authorize livestock grazing and the determination for how 

lands are managed (including those that have been identified as not capable of producing forage), 

is made at the project or allotment level. The decision to authorize grazing and under what 

conditions is made following NEPA review at the grazing allotment level, under which sitespecific conditions can be assessed and addressed through project design.

During site-specific NEPA review, the condition and trend of each of the Kaibab NF’s allotments 

was assessed to ensure availability of forage and habitat for all species, including wildlife. A 

summary of these evaluations can be found in the project record. Although direct comparisons of 

these condition and trend analyses is difficult due to differences in methodology and reporting of 

results, range condition generally ranged from very poor to very good, with approximately 75 

percent of allotments receiving ratings of poor or better. The majority of allotments had a trend of 

static to upward.

Range condition is a subjective expression (very poor, poor, fair, good, and excellent) and is 

evaluated relative to a standard that encompasses the composition, density, and vigor of the 

vegetation and the physical characteristics of the soil. Range trend expresses the direction of 

change in range condition over time in response to livestock management and other 

environmental factors. The methods used to evaluate range condition and trend are generally 

considered to be a process for determining condition and trend relative to the land’s ability or 

value for grazing livestock and do not provide information regarding ecological status (Holechek 

et al. 1989). As such, there is not a strong correlation between range condition class and 

472 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix D. Grazing Suitability and Capability

ecological condition; an area could be in a poor or fair condition simply because the area has a 

low value for livestock grazing.

References

Holechek, J.L., R.D. Pieper, and C.H. Herbel. 1989. Range Management Principles and Practices. 

Englewood Cliffs, NJ: Regents/Prentice Hall. 501 pp.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 473

Appendix E. Wilderness

Area Evaluation Summary

The National Forest Management Act (NFMA) requires that all areas meeting minimum criteria 

as wilderness be considered for recommendation for wilderness designation during plan revision. 

Recommended areas are those which are capable of providing wilderness experiences and 

character, are available for recommendation in comparison to other values that exist in the area, 

and respond to the need for additional wilderness in the National Wilderness Preservation System. 

This is a summary of the results of the Potential Wilderness Area Evaluation Report (KNF 2013), 

which can be found on the Kaibab National Forest (NF) Web site at

http://fs.usda.gov/goto/kaibab/plan_revision.

The potential wilderness area (PWA) evaluation identified and inventoried all non-wilderness 

areas within the Kaibab NF that satisfy the definition of wilderness found in the 1964 Wilderness 

Act, which states: 

“A wilderness, in contrast with those areas where man and his own works dominate 

the landscape, is hereby recognized as an area where the earth and its community of 

life are untrammeled by man, where man himself is a visitor who does not remain. An 

area of wilderness is further defined to mean in this chapter an area of 

underdeveloped Federal land retaining its primeval character and influence, without 

permanent improvements or human habitation, which is protected and managed so as 

to preserve its natural conditions and which (1) generally appears to have been 

affected primarily by the forces of nature, with the imprint of man’s work 

substantially unnoticeable; (2) has outstanding opportunities for solitude or a 

primitive and unconfined type of recreation; (3) has at least five thousand acres of 

land or is of sufficient size as to make practicable its preservation and use in an 

unimpaired condition; and (4) may also contain ecological, geological, or other 

features of scientific, educational, scenic, or historical value.”

Forest Service Handbook (FSH) direction (1909.12, Chapter 70) provides a three-step process for 

identifying and evaluating potential wilderness on National Forest System Lands. This process 

includes:

1. An inventory of potential areas;

2. Evaluation of potential areas; and,

3. Determination (by the decision maker for the Kaibab forest plan) if a recommendation 

will be pursued for any potential wilderness areas.

Inventory of Potential Wilderness Areas

In 2007, the Southwestern Region developed a Potential Wilderness Inventory process for use by 

National Forests in the Region. Through this process, the Kaibab NF identified areas that met the 

basic requirements of size, geography or adjacency to existing or recommended wilderness. In 

order for an area to be included in the potential wilderness inventory, it must meet the definition 

in the 1964 Wilderness Act and meet either criteria 1 and 3, or criteria 2 and 3 below. 

1. Areas contain 5,000 acres or more. 

2. Areas contain less than 5,000 acres, but can meet one or more of the following criteria: 

a. Can be preserved due to physical terrain and natural conditions. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 475
Appendix E. Wilderness Area Evaluation Summary

b. Self-contained ecosystems, such as an island, that can be effectively managed as a 

separate unit of the National Wilderness Preservation System. 

c. Contiguous to existing wilderness, primitive areas, Administration-endorsed 

wilderness, or potential wilderness in other Federal ownership, regardless of their 

size. 

3. Areas do not contain forest roads (36 CFR 212.1) or other permanently authorized roads, 

except as permitted in areas east of the 100th meridian (sec. 71.12). 

Areas may qualify for inventory of potential wilderness even though they include the types of 

areas or features listed in FSH 1909.12, Chapter 71.11 (e.g. historic mining, electronic sites, 

fences, water troughs, and corrals), providing their impact is minimal. 

The Kaibab NF used a systematic process to identify areas (polygons) that met the inventory 

criteria. An automated GIS model was developed to identify polygons that met inventory criteria 

1, 2c, and 3. The portion of this analysis determining the presence of roads utilized the most upto-date motor vehicle use map. These polygons were then individually examined for inherent 

model errors such as polygons containing “dead-end” roads. Polygons were reshaped or 

completely removed if they contained dense networks of dead-end roads. When delineating the 

boundaries of areas, efforts were made to facilitate easy on-the-ground identification. During this 

examination the Kaibab NF also determined whether a polygon met inventory criteria 2a and 2b, 

and criteria from FSH 1909.12, Chapter 71. 

The inventory process identified sixteen PWAs that were carried forward to the evaluation phase. 

A full description of the PWA inventory process can be found in Appendix A of this document.

Evaluation of Potential Wilderness Areas 

After the initial inventory was completed, PWAs identified in the inventory were evaluated for 

capability, availability, and need:

1. Capability is an evaluation of the inherent characteristics of the potential area.

2. Availability is an evaluation of the value and need for wilderness compared to value and 

need for other resources or uses. 

3. Need is an evaluation of the regional distribution of wilderness and representation of 

regional landforms and ecosystems. 

Capability Analysis

The sixteen PWAs carried forward from the inventory process were evaluated for their capability. 

Basic wilderness capability characteristics were used to evaluate the initial suitability of a PWA 

for wilderness recommendation regardless of its availability or need as wilderness. Five principle 

wilderness characteristics (based on the Wilderness Act) were analyzed in this step (FSH 1909.2, 

Chapter 70, Section 72.1): 

1. Natural–the degree to which the area is substantially free from the effects of modern 

civilization and generally appears to be affected primarily by forces of nature. 

2. Undeveloped–the degree to which an area is without permanent improvements/human 

habitation. 

476 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

3. Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation–the 

degree to which the area provides a wide range of experiential opportunities for feelings 

of solitude, isolation, and a part of nature free from evidence of humans. 

4. Special Features and Values–the degree to which an area is capable of providing other 

values such as those with ecologic, geologic, scientific, educational, scenic, historic or 

cultural significance. 

5. Manageability–ability to manage the area as wilderness as required by the Wilderness Act 

and how boundaries of the area affect its manageability. 

A rating system was used to assess the wilderness character of each PWA. The specific criteria 

were developed by the Southwestern Regional Office with direction from the Forest Service 

Handbook 1909.12 Chapter 72.1. For each PWA, each criterion was assigned a high, medium, or 

low rating. These were then converted to numerical ratings using the following scale: a high 

rating received 3 points; a medium rating received 2 points; and low ratings received zero points. 

Each of the five wilderness characteristics—naturalness, undeveloped, solitude/primitive 

recreation, special features, and manageability—then received a rating of high, medium, or low 

based on the points given to its constituent criteria. The overall capability rating for a PWA was 

based on the total number of points earned in all five categories.

The rating criteria for capability are described in Table E 1. Table E 2 summarizes the capability 

ratings for the 16 inventoried PWAs on the Kaibab NF. The evaluation relied on professional 

knowledge regarding the unique, site specific conditions of each area being considered. More 

detail about the capability of each PWA is provided in the area-specific PWA evaluation 

summaries in this report. Figures E 1 and E 2 display the potential wilderness areas that were 

evaluated for capability as a part of this analysis.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 477
Appendix E. Wilderness Area Evaluation Summary

Table E 1. Potential wilderness area capability rating criteria

Characteristic Criterion Rating*

Natural

Presence of non-native species

High – Non-native species are not evident

Medium – Non-native species are evident in isolated spots 

Low – Non-native species are common or scattered throughout 

the area

Seeps/springs within the area are 

in free-flowing condition

High – Seeps/springs are considered free-flowing (undeveloped)

Medium – Some seeps/springs have development or other issues 

that affect their free-flowing character. 

Low – Springs/seeps are absent, seasonal or heavily impacted by 

development 

Quality of night sky as affected by 

light pollution 

High – The night sky is clear with little to no interference from 

light pollution

Medium – Some stars are visible and there is moderate 

degradation from light pollution

Low –Few stars are visible at night and the presence of light 

pollution is evident

Area provides elements of 

biological diversity and 

naturalness, including unique 

habitats, TES or rare plants & 

wildlife. 

High – Has critical or unique habitats and diverse ecological 

conditions

Medium – Has a mix of habitats and ecological conditions

Low – Has limited ecological conditions and habitats 

Area contains a variety of natural 

resources, including a variety of 

tree species and structures. 

Intermingled grasslands or 

meadows, numerous recreation 

opportunities, diversity of wildlife 

habitats, and wildlife, etc.

High – Diverse amount of natural resources 

Medium – Mixed amount of natural resources

Low – Limited amount of natural resource diversity

Undeveloped Area is free from human 

disturbance

High – Has only minor improvements and appears free from 

human disturbance

Medium – Has several minor improvements and is mostly free 

from human disturbance

Low – Has major improvement such as a power line or road and 

shows signs of human disturbance

Outstanding 

opportunities 

for solitude or 

primitive and 

unconfined 

recreation

Area provides physically and 

mentally challenging recreation 

opportunities that promote 

adventure and self-reliance

High – Most of the area provides challenging recreation 

opportunities

Medium – Some parts of the area have the potential for 

challenging recreation opportunities

Low – Few parts of the area can provide challenging recreation 

opportunities

Opportunity to experience solitude 

and isolation from human 

activities while recreating in the 

area

High – Significant feeling of being alone or remote from 

civilization

Medium – Feeling of being alone is possible but signs of 

civilization are likely

Low – Little opportunity of feeling alone

Opportunity to engage in primitive 

and unconfined recreation such as 

back-packing, hunting, fishing, 

etc.

High - There are many opportunities for engaging in primitive 

recreation

Medium – There are some opportunities for engaging in 

primitive recreation

Low – There are few to no opportunities to engage in primitive 

recreation 

Degree of primitive ROS settings High – Majority of the area is classified primitive or semiprimitive non-motorized

478 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

Table E 1. Potential wilderness area capability rating criteria

Characteristic Criterion Rating*

Medium – Some of the area is classified primitive or semiprimitive non-motorized

Low – Little to none of the area is classified primitive or semiprimitive non-motorized 

Special 

Features and 

Values

Area contains outstanding or

distinct features like rock 

formations, panoramic views, etc.

High – Many distinct features or few but exceptional features 

Medium – Some distinct features 

Low – One or no distinct features 

Area has potential for scientific 

research, environmental education, 

or historic/cultural opportunities

High – Good potential for two or more types of these 

opportunities

Medium – Potential for one type of opportunity 

Low – Little or no potential for this type of opportunity 

Area contains unique or rare 

species of plants and/or animals

High – Area has several unique or rare plants and/or animals 

Medium – Area has a few unique or rare plants and/or animals 

Low – Area has no known unique or rare plants and/or animals.

Manageability

Ability to manage the area for 

wilderness character, including 

distance and influence from 

outside activities; opportunity to 

access the area; and resource 

conflicts or encumbrances

High – Isolated from areas of activity; controlled or limited 

access; no encumbrances or resource conflicts 

Medium – Somewhat isolated from areas of activity; adequate 

access opportunities; some resource conflicts and/or 

encumbrances 

Low – Areas of activity are nearby; many access opportunities; 

many resource conflicts and/or encumbrances

Area boundaries are recognizable 

and defensible

High – Majority of boundary follows features that can be easily 

found and identified on the ground

Medium – About half of the boundary follows features that can 

be easily found and identified on the ground

Low – Boundary can rarely be located without equipment, such 

as a GPS unit * Each criterion rating was assigned a numeric score: High= 3 points, Medium = 2 points, Low = 0 points

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 479
480 FEIS for the Kaibab National Forest Land Management Plan

Appendix E. Wilderness Area Evaluation Summary

Table E 2. Summary of the Kaibab National Forest potential wilderness area capability ratings

Area Name, Size, PWA 

Numbera

Capability Ratingb

Natural Undeveloped

Outstanding opportunities for 

solitude or primitive, unconfined 

recreation

Special 

features 

and values

Manageability

Overall 

capability 

ratingc

Saddle Mountain Addition: 

1,296 ac PWA 03-07-043

Medium 

(2) High (3) High (3) High (3) High (3) 14 = High

Kanab Creek Additions: 4,710 ac 

PWA 03-07-034

Medium 

(2) High (3) Medium (2) High (3) High (3) 13 = High

Grassy/Quaking Aspen Canyons: 

232 ac, PWA 03-07-099 High (3) High (3) High (3) Medium (2) Medium (2) 13 = High

Sycamore Canyon Addition: 

988 ac PWA 03-07-057

Medium 

(2) High (3) High (3) Medium (2) High (3) 13 = High

Jacks Canyon: 156 ac 

PWA 03-07-999

Medium 

(2) High (3) High (3) High (3) Medium (2) 13 = High

Burro Canyon: 10,735 ac 

PWA 03-07-003

Medium 

(2) High (3) High (3) Medium (2) Medium (2) 12 = Medium

Coconino Rim: 7,750 ac 

PWA 03-07-079

Medium 

(2) Medium (2) Medium (2) Medium (2) Medium (2) 10 = Medium

Seegmiller: 6,168 ac 

PWA 03-07-035

Medium 

(2) Medium (2) Medium (2) Medium (2) Medium (2) 10 = Medium

Willis Canyon: 6,418 ac 

PWA 03-07-002

Medium 

(2) Medium (2) Medium (2) Medium (2) Medium (2) 10 = Medium

South Canyon Point: 5,829 ac 

PWA 03-07-045

Medium 

(2) Medium (2) Medium (2) Medium (2) Medium (2) 10 = Medium

The following PWAs were not carried forward to Availability analysis due to an overall “low” score:

Sitgreaves Mtn: 10,016 ac 

PWA 03-07-073

Medium 

(2) Medium (2) Medium (2) Medium (2) Low (0) 8 = Low

Red Point: 7,385 ac

PWA 03-07-098 Low (0) High (3) Medium (2) Low (0) Low (0) 5 = Low

Big Ridge: 9,373 ac 

PWA 03-07-004 Low (0) High (3) Low (0) Medium (2) Low (0) 5 = Low

Red Butte: 2,682 ac 

PWA 03-07-088 Low (0) Low (0) Low (0) Medium (2) Medium (2) 4 = Low

Paradise Ridge: 10,444 ac 

PWA 03-07-134 Low (0) Low (0) Low (0) Low (0) Medium (2) 2 = Low

NW NKRD: 12,110 ac 

PWA 03-07-018 Low (0) Medium (2) Low (0) Low (0) Low (0) 2 = Low

a The first 5 PWAs are included based on the “contiguous to existing wilderness” criterion. Red Butte & Sitgreaves Mtn. are included because “they can be preserved due to 

physical terrain and/or natural conditions.” The remaining PWAs are included based on the >5,000 acres criterion. b Each criterion rating was assigned a numerical score: High = 3 points, Medium = 2 points, Low = 0 points. 

c

Overall capability rating: 13-15 = High (≥87%); 9-12 = Medium (60-86%); <9 = Low (<60%). Only PWAs with a >60% rating are carried 

forward to availability analysis.
Appendix E. Wilderness Area Evaluation Summary

Availability Analysis

Of the sixteen PWAs evaluated for capability, six were not carried forward into the availability 

and need assessments because they had a low capability rating (below 60%). The remaining ten 

PWAs were considered potentially available for wilderness designation. The availability analysis 

compares the resource tradeoffs and consequences of wilderness designation based on the 

qualitative and quantitative information about current and potential uses, outputs, trends for the 

various resources.

Availability of PWAs was evaluated on nine criteria: recreation, including tourism; information 

on wildlife species, populations, and management needs; water availability and use; livestock 

operations; timber; minerals; cultural resources; authorized and potential land uses; and 

management considerations, including fire, insects and disease, and presence of non-federal 

lands. Surface water is exceedingly uncommon on the Kaibab NF, and it was determined that 

available water within the PWAs only occurred as seeps and springs or developed livestock 

waters. The presence of seeps and springs is addressed in the capability analysis (described 

above), and the presence and use of livestock waters is included in the livestock operations 

question described below. 

The availability rating of the ten remaining PWAs was determined by asking a question related to 

each of the resource categories and scoring based on the resulting availability. As with capability, 

the PWAs were assigned a high, medium, or low rating on each criterion. A high rating was worth 

3 points, a medium rating was worth 2 points low ratings received zero points since the objective 

was to promote areas with outstanding wilderness qualities. More detail about the availability 

rating for each PWA is provided in the area-specific summaries in this report. 

Table E 3 describes the rating criteria for availability. Table E 4 summarizes the availability 

ratings and associated scores for each of the ten PWAs under consideration. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 481
Appendix E. Wilderness Area Evaluation Summary

Table E 3. Potential wilderness area availability rating criteria 

Resource Area Availability Question Rating*

Vegetation 

(Timber)/ Fire 

Management

What have been or will be the 

impacts of 

existing//planned/needed 

management activities on the 

“wilderness character” of the 

PWA (includes timber harvest 

activities, invasive/noxious 

species eradication, and fire)?

High – Minimal or no existing/planned/needed activities

Medium – Some existing/planned/needed activities

Low – Many existing/planned/needed activities

Recreation and 

Tourism

What types of recreation or 

tourism occur in the PWA, and 

do they involve motorized or 

mechanized vehicle use (e.g. 

mountain bikes or ATVs)?

High – Primitive non-motorized/mechanized recreation/tourism 

only

Medium – Semi-primitive non-mechanized/motorized vehicle use

Low – User-created (social) mechanized/motorized vehicle trail 

use

Wildlife and Plants

Would wilderness designation 

result in increased protection 

and viability for federally listed 

or sensitive species within the 

PWA?

High – Federally listed or sensitive species are present and 

wilderness designation would improve protection and viability of 

these species

Medium – Only one federally listed and/or sensitive species are 

present and wilderness designation would improve protection of 

these species

Low – No federally listed or sensitive species are present and/or 

wilderness designation would not improve protection or viability

Livestock 

Operations

Are there active allotments and 

associated improvements 

(including water developments) 

within the PWA that are subject 

to periodic maintenance 

requiring the use of mechanized 

equipment?

High – No active allotments and/or improvements do not require 

maintenance with mechanized equipment

Medium – Active allotment(s) are present but existing 

improvements do not require maintenance with mechanized 

equipment

Low – Active allotments are present and improvements do require 

maintenance with mechanized equipment

Lands and Minerals

Are there patented lands, 

mining claims, surface 

occupancy leases, or abandoned 

mines/quarries with the PWA?

High – None of the above exist

Medium – No patented lands, mining claims, or surface 

occupancy leases exist but some abandoned mines/quarries present

Low – Any of the above (except abandoned mines/quarries) are 

present

Heritage and 

Cultural Resources

Are there prehistoric, historic, 

or ceremonial sites with the 

PWA and are they ever 

accessed using mechanized 

vehicles?

High – High density of sites that do not require mechanized 

vehicle access are present and wilderness designation would 

increase protection of sites

Medium – Low to moderate density of sites that do not require 

mechanized vehicle access are present and wilderness designation 

would increase protection of sites

Low – No to low density of sites are present or sites require 

mechanized vehicle access or wilderness designation would not 

increase protection of sites

*High = 3 points, Medium = 2 points, Low = 0 points 

482 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

FEIS for the Kaibab National Forest Land Management Plan 483

Table E 4. Summary of the Kaibab National Forest potential wilderness area availability ratings

Area Name, Size, PWA 

Numbera

Availability Rating Criteriab

Timber, 

Vegetation, and

Fire Mgmt.

Recreation Wildlife and

Plants

Livestock 

Operations

Lands and

Minerals

Heritage and

Cultural 

Resources

Overall 

Availabilityc

Kanab Creek Additions: 4,710 ac

PWA 03-07-034 High (3) High (3) High (3) High (3) High (3) High (3) High (18)

Saddle Mountain Addition: 1,296 ac

PWA 03-07-043 High (3) Medium (2) Medium (2) High (3) High (3) High (3) High (16)

Sycamore Canyon Addition: 988 ac

PWA 03-07-057 High (3) Medium (2) High (3) High (3) High (3) Medium (2) High (16)

Grassy and Quaking Aspen 

Canyons: 232 ac, PWA 03-07-099 High (3) Medium (2) High (3) High (3) High (3) Medium (2) High (16)

Jacks Canyon: 156 ac

PWA 03-07-999 Medium (2) Medium (2) High (3) High (3) High (3) Medium (2) Medium (15)

Coconino Rim: 7,750 ac 

PWA 03-07-079 Medium (2) Medium (2) Medium (2) Medium (2) Medium (2) High (3) Medium (13)

Seegmiller: 6,168 ac

PWA 03-07-035 Medium (2) Medium (2) Medium (2) Medium (2) High (3) Medium (2) Medium (13)

Burro Canyon: 10,735 ac

PWA 03-07-003 Medium (2) Medium (2) Medium (2) Low (0) High (3) Medium (2) Medium (11)

South Canyon Point: 5,829 ac

PWA 03-07-045 Medium (2) Low (0) Medium (2) Medium (2) High (3) Medium (2) Medium (11)

Willis Canyon: 6,418 ac

PWA 03-07-002 Low (0) Medium (2) Low (0) Low (0) High (3) Medium (2) Low (7)

a The Kanab Creek, Saddle Mountain, Sycamore Canyon, Jacks Canyon, and Grassy/Quaking Aspen Canyons additions are included based on the "contiguous to existing 

wilderness" criterion. The remaining five PWAs are included based on the ≥5,000 acres criterion.

b Each criterion rating was assigned a numerical score: High = 3 points, Medium = 2 points, Low = 0 points. c Overall availability rating: 16-18 = High (≥87%); 11-15 = Medium (60-86%); <11 = Low (<60%).
Appendix E. Wilderness Area Evaluation Summary

Figure E 1. North Kaibab Ranger District existing and potential wilderness areas with 

capability and availability

484 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

Figure E 2. Tusayan and Williams Ranger Districts existing and potential wilderness areas 

with capability and availability 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 485
Appendix E. Wilderness Area Evaluation Summary

Need Analysis

The purpose of the need analysis is to identify the need for additional wilderness based on the 

regional distribution of wilderness and the representation of landforms and ecosystems within 

existing wilderness areas. The need for additional wilderness is determined by analyzing the 

degree to which an individual PWA contributes to the national wilderness system. Need analysis 

was performed only for the ten PWAs that passed the Capability analysis. The need evaluation is 

based on six factors and follows the process identified in FSH 1909.12, Subsection 72.3:

1. The location, size, and type of other wildernesses in the general vicinity and their 

distance from the proposed area. Consider accessibility of areas to population centers and 

user groups. Public demand for wilderness may increase with proximity to growing 

population centers. 

2. Present visitor pressure on other wildernesses, the trends in use, changing patterns of use, 

population expansion factors, and trends and changes in transportation.

3. The extent to which non-wilderness lands on the NFS unit or other Federal lands are 

likely to provide opportunities for unconfined outdoor recreation experiences.

4. The need to provide a refuge for those species that have demonstrated an inability to 

survive in less than primitive surroundings, or the need for a protected area for other 

unique scientific values or phenomena.

5. Within social and biological limits, management may increase the capacity of established 

wildernesses to support human use without unacceptable depreciation of the wilderness 

resource. 

6. An area’s ability to provide for preservation of identifiable landform types and 

ecosystems. Consideration of this factor may include utilization of Edwin A. Hammond’s 

subdivision of landform types and the Bailey-Kuchler ecosystem classification. This 

approach is helpful from the standpoint of rounding out the National Wilderness 

Preservation System and may be further subdivided to suit local, subregional, and 

regional needs.

Table E 5 summarizes the need ratings for the PWAs carried forward from the capability analysis.

486 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

Table E 5. PWA need ratings for each factor

Area Name, Size, PWA 

Number

Need Rating Criteria

Factor 

1

Factor 

2

Factor 

3

Factor 

4

Factor 

5

Factor 

6

Kanab Creek Addition:

4,710 ac, PWA 03-07-034

Low Low Low High Low Medium

Saddle Mountain Addition: 

1,296 ac, PWA 03-07-043

Low Low Low Low Low Medium

Sycamore Canyon Addition: 

988 ac, PWA 03-07-057

Low Low Low Low Low Low

Grassy/Quaking Aspen Canyons:

232 ac, PWA 03-07-099

Low Low Low Low Low Medium

Jacks Canyon: 156 ac

PWA 03-07-999

Low Low Low Low Low Low

Burro Canyon: 10,735 ac, PWA 

03-07-003

Low Low Low Low Low Medium

Coconino Rim: 7,750 ac, PWA 

03-07-079

Medium Low Low Low Low Medium

Seegmiller: 6,168 ac, PWA 03-

07-035

Low Low Low Low Low Low

South Canyon Pt.: 5,829 ac, 

PWA 03-07-045

Low Low Low Low Low Medium

Willis Canyon: 6,418 ac, 

PWA 03-07-002

Low Low Low Low Low Medium

Summary of Results and Leadership Team Discussion

Table E 6 summarizes the capability, availability, and need ratings for the 16 PWAs identified on 

the Kaibab NF as a part of the plan revision process, and lists the plan alternatives that 

recommend each area for wilderness designation. Of these, six were not evaluated for availability 

or need due to low capability ratings. Five PWAs (Kanab Creek Addition, Saddle Mountain 

Addition, Grassy and Quaking Canyons, Jacks Canyon, and Sycamore Canyon Addition) rated 

“high” for capability. With the exception of Jacks Canyon, these PWAs rated “high” for 

availability. All PWAs ranked “low” for need. As a result, considerations were primarily focused 

on capability and availability, with general recognition of the low need.

The leadership team and plan revision team discussed the individual characteristics of each PWA 

and the criteria/factors for capability, availability, and need. After considering the merits of each 

area, there was general support for recommending the areas for wilderness that had at least a 

combined rating of high/medium capability and availability in the proposed action.

The potential additions to Kanab Creek Wilderness would bring the area managed as wilderness 

to the rim, making it more identifiable and, therefore, manageable. The potential addition to 

Saddle Mountain Wilderness would add a unique landform, the “Cockscomb,” into the area 

managed as wilderness. Grassy and Quaking Aspen Canyons are adjacent to proposed wilderness 

in the Grand Canyon National Park and would also bring the area managed as wilderness to the 

rim, improving manageability. These additions also received strong support from Grand Canyon 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 487
Appendix E. Wilderness Area Evaluation Summary

NP. Jacks Canyon extends the boundary of the Sycamore Canyon Wilderness into a side canyon, 

improving its manageability.

Because the Sycamore Canyon Addition is less than 1,000 acres, it was only to be recommended 

by the Kaibab NF for wilderness designation if the adjacent PWA on the Prescott NF (Sycamore 

Canyon Contiguous C) was recommended in the Prescott’s revised forest plan. This portion of the 

Prescott NF was not included in their proposed action, so the Sycamore Canyon Addition is not 

recommended as a PWA under the Kaibab NF’s Alternative B (proposed action).

Table E 6. Capability, availability, and need ratings for Kaibab National Forest potential 

wilderness areas

PWA 

Number Name Acres Capability Availability Need

03-07-034 Kanab Creek Addition 4,710 High High Low

03-07-043 Saddle Mountain Addition 1,296 High High Low

03-07-099 Grassy/ Quaking Aspen Canyons 232 High High Low

03-07-999 Jacks Canyon 156 High Medium Low

03-07-057 Sycamore Canyon Addition 988 High High Low

03-07-003 Burro Canyon 10,735 Medium Medium Low

03-07-079 Coconino Rim 7,750 Medium Medium Low

03-07-035 Seegmiller 6,168 Medium Medium Low

03-07-045 South Canyon Point 5,829 Medium Medium Low

03-07-002 Willis Canyon 6,418 Medium Low Low

Following the discussion of what should be included in the proposed action (Alternative B) to be 

recommended for wilderness, there was discussion about which PWAs should be evaluated in 

detail in the alternatives to the proposed action. During the scoping phase for the plan, comments 

were received on the initial capability and availability evaluations. Some commenters wanted all 

of the inventoried roadless areas and Sitgreaves Mountain to be recommended for wilderness. 

Other comments stated that no new areas should be recommended for wilderness, and others 

supported the recommendation of any capable areas contiguous to the Grand Canyon be proposed 

as wilderness.

Of the five inventoried roadless areas on the Kaibab NF, Big Ridge and Red Point rated low for 

capability. This is due in large part to the effects of the Warm Fire of 2006, which burned these 

areas at generally high severity. These areas were considered but not included in the alternatives 

to be analyzed in detail because of their lower capability and because they would benefit from 

management aimed at improving their ecosystem integrity. Such management would be more 

efficient and effective with the ability to use a variety of tools, including mechanized and 

motorized equipment, and would likely improve these areas’ wilderness capability over the long 

term. Similarly, Sitgreaves Mountain was eliminated from further consideration because of a low 

capability rating and the need for treatments aimed at reducing the risk of uncharacteristic fire. 

Not recommending these or other areas for wilderness designation at this time does not preclude 

their recommendation in the future. All of the remaining PWAs that received at least a medium 

488 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix E. Wilderness Area Evaluation Summary

capability rating were included in the alternatives to the proposed action in an effort to maintain a 

range of alternatives and provide the greatest amount of information for use in the decision. 

Overview of Results

The proposed action recommends four PWAs (Kanab Creek Addition, Saddle Mountain Addition, 

Grassy/Quaking Aspen Canyons, and Jacks Canyon), totaling about 6,394 acres, for wilderness 

designation. These areas are shaded grey in Table E 6.These areas would be managed under the 

“Recommended Wilderness Management Area” in the proposed plan. Alternatives C and D 

recommend the PWAs in the proposed action, plus six additional wilderness areas (totaling about 

37,000 acres): Burro Canyon, Coconino Rim, Seegmiller, South Canyon Point, Sycamore Canyon 

addition, and Willis Canyon. 

References

USDA Forest Service, Kaibab National Forest (KNF). 2013. Kaibab National Forest Potential 

Wilderness Area Evaluation Report. Williams, AZ: Kaibab National Forest.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 489

Appendix F. Wild and

Scenic River Assessment

Introduction

The Wild and Scenic Rivers Act of 1968 (Public Law 90-542),Section 1(b), expresses 

congressional policy for America’s rivers as follows:

“It is hereby declared to be the policy of the United States that certain selected 

rivers of the Nation which, with their environments, possess outstanding 

remarkable scenic, recreational, geologic, fish and wildlife, historic, cultural, or 

other similar values, shall be preserved in free-flowing condition, and that they 

and their immediate environments shall be protected for the benefit and 

enjoyment of present and future generations.”

To accomplish this decree, Congress established a National Wild and Scenic Rivers System and 

prescribed methods and standards by which selected rivers could be added. Rivers or river 

segments are eligible to be considered for inclusion in the National Wild and Scenic Rivers 

System if they are essentially free flowing (without major dams, diversions, or channel 

modifications) and if they possess at least one “outstandingly remarkable” scenic, recreational, 

geologic, fish, wildlife, historic, cultural, or other similar value. These values should be a unique 

or exceptional representation for the area studied, and must be related to the river or its immediate 

environment. For study purposes, the Act requires that the evaluation of a river’s eligibility 

consider, as a minimum, the area within 1⁄4 mile of either side of the high water mark of the river. 

Eligible rivers are evaluated for potential classification and determination of suitability. They s 

are considered for potential “wild,” “scenic,” or “recreational” classification based on the 

condition of the river and adjacent lands as they exist at the time of the study. The suitability 

analysis provides the basis for determining which rivers to recommend as components of the 

National Wild and Scenic Rivers System and considers the appropriateness of congressional 

designation and classification as a wild, scenic or recreational river. Suitable rivers may be 

recommended to Congress by the administration, whereby Congress then decides whether to pass 

a law adding the river to the national system. If designation occurs, a final boundary is established 

and a comprehensive river management plan is developed. 

The Wild and Scenic Rivers Act also provides specific direction in Section 5(d)(1) regarding the 

identification of potential wild and scenic rivers in Federal agency planning processes:

“In all planning for the use and development of water and related land resources, 

consideration shall be given by all Federal agencies involved to potential 

national wild, scenic, and recreational river areas, and all river basin and 

project plan reports submitted to the Congress shall consider and discuss any 

such potentials.” 

Land Management Planning 

The land management planning process shall include a comprehensive evaluation of the potential 

for rivers in an administrative unit to be eligible for inclusion in the national system. Sources for 

identifying the significance of river-related values include the Nationwide Rivers Inventory; state 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 491
Appendix F. Wild and Scenic River Assessment

river assessments; identification by tribal governments, or other Federal, State, or local agencies; 

and the public.

Agency policy related to wild and scenic rivers assessment during the land management planning 

process is defined in the Land Management Planning Handbook (FSH 1909.12, Chapter 80, Wild 

and Scenic River Evaluation). This chapter describes the process for identifying and evaluating 

potential additions to the National Wild and Scenic Rivers System on National Forest System 

lands pursuant to the Wild and Scenic Rivers Act. It requires the land management planning 

process to include a comprehensive evaluation of the potential for rivers to be eligible for 

inclusion in the national system.

Direction is provided in FSH 1909.12, Section 81.2 in regard to the assessment of rivers in forest 

plan revision. The assessment of a river identified as having potential for wild and scenic river 

designation follows a 3-step process:

7. Determination of eligibility.

8. Potential classification (wild, scenic, or recreational).

9. Determination of suitability.

Latitude is provided in FSH 1909.12, Chapter 80 regarding the process used for determination of 

eligibility as well as determination of suitability in land management planning, i.e., completing a 

river study in the revised forest plan to determine which rivers the agency may recommend to 

Congress as additions to the National Wild and Scenic Rivers System. Specifically, FSH 1909.12, 

Section 81.2 states:

“If a systematic inventory of eligible rivers or a comprehensive forest, grassland, 

prairie, or other comparable administrative unitwide suitability study has been 

previously completed and documented, additional assessment and study at time 

of land management plan revision need only be done if changed circumstances 

warrant additional review of eligibility or if the responsible official decides to 

evaluate suitability for one or more eligible rivers in the planning process. 

Otherwise, the process need not be revisited in land management planning.”

Determination of Eligibility and Potential 

Classification

Wild and scenic rivers were not addressed in the 1987 forest plan for the Kaibab NF. However, a 

systematic inventory of eligible rivers was completed in January 1993 by the Forest Service, the 

Arizona Game and Fish Department, and other state and Federal agencies. The 1993 report, 

known as the Preliminary Analysis of Eligibility and Classification for Wild/Scenic/Recreational 

River Designation, included representatives from the Apache-Sitgreaves, Coconino, Coronado, 

Kaibab, Prescott and Tonto National Forests. Resource information for potential wild, scenic, and 

recreational rivers that the Forest Service determined to be potentially eligible for inclusion into 

the National Wild and Scenic Rivers System was compiled in a supplemental report published in 

September 1993 [Resource Information Report – Potential Wild/Scenic/Recreational River 

Designation, National Forests of Arizona (USDA Forest Service 1993)]. This report includes a 

determination of eligibility for Kanab Creek, with a classification of wild. Detailed information in 

the report includes location, descriptions of resources, outstandingly remarkable values, land uses 

and developments and social and economic values. In accord with FSH 1909.12, Section 81.2, 

492 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix F. Wild and Scenic River Assessment

this inventory has been used as the basis for assessing potential wild and scenic rivers eligibility 

in the revision of the Kaibab National Forest Land and Resource Management Plan.

As a result of the 1993 inventory, Kanab Creek was listed as eligible in the Nationwide Rivers 

Inventory. This Inventory, first published by the National Park Service in 1982, is a listing of 

more than 3,400 free-flowing river segments in the United States that are believed to possess one 

or more “outstandingly remarkable” natural or cultural values judged to be of more than local or 

regional significance. Under a 1979 presidential directive and related Council on Environmental 

Quality procedures, all Federal agencies must seek to avoid or mitigate actions that would 

adversely affect one or more Nationwide Rivers Inventory segments. The Nationwide Rivers 

Inventory includes 20 miles of Kanab Creek, located on the Kaibab NF and within a designated 

wilderness (see table F 1). Additional segments of Kanab Creek beyond the southern Kaibab NF

boundary are eligible. This segment includes the reach which flows into the Colorado River 

through lands administered by the National Park Service in Grand Canyon National Park. 

Table F 1. Description of the eligible segment located on the Kaibab National Forest

River County Reach Length 

(miles)

Year 

Listed

Potential 

Classification ORVs Description

Kanab 

Creek 

MohaveCoconino 

Boundary

FS/BLM 

Boundary 

to NPS/FS 

Boundary 

20 1993 Wild S, R, 

W, G

Intermittent, 

isolated reaches 

of perennial 

flow. Riparian 

vegetation. 

Broad canyon.

Source: Nationwide Rivers Inventory at http://www.nps.gov/ncrc/programs/rtca/nri/states/az2.html

ORV = Outstandingly remarkable value (S-Scenery, R-Recreation, W-Wildlife, G-Geology)

As allowed in FSH 1909.12, Section 81.2, this forest plan revision includes supplementary 

assessment of the 1993 inventory in order to determine if there are additional rivers or river 

segments that may be eligible given changed circumstances and/or new information that has 

occurred since the 1993 inventory was completed. The supplementary assessment entails a review 

of the following information as it relates to changed circumstances:

1. Changes in land status or ownership. The acquisition of additional private lands on the 

Kaibab NF could include new rivers or river segments that may not have been addressed 

in the 1993 inventory.

2. Changes related to additional identification of important resource values that may not 

have been identified in the 1993 inventory. New information regarding identification of 

important resource values could be reflected in monitoring and evaluation reports 

conducted on the Kaibab NF since the 1993 inventory.

As a result of the supplementary assessment, there are no changed circumstances or conditions 

necessitating additional consideration of rivers. Kanab Creek will continue to be listed in 

Nationwide Rivers Inventory as eligible for further study.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 493
Appendix F. Wild and Scenic River Assessment

Determination of Suitability

The Kaibab NF has chosen to delay the suitability determination on Kanab Creek until a separate 

study is conducted outside of the forest plan revision process.. As provided in FSH 1909.12, 

Section 83.1, the decision to delay the suitability determination must be accompanied by 

provisions to provide for protection of the river area until a decision is made as to the future use 

of the river.

For interim management of eligible or suitable rivers, the special area recommendation should 

include the desired conditions, objectives, guidelines, and suitability of areas to be used in the 

design of projects and activities consistent with management guidelines of eligible or suitable 

rivers (FSH 1909.12, section 82.51). The segment determined as eligible for Kanab Creek is 

contained within a designated wilderness. The desired conditions, objectives, guidelines, and 

suitability of areas to be used in the design of projects and activities contained within the 

wilderness management area direction are consistent with management guidelines that protect 

Kanab Creek’s eligibility and potential wild classification, therefore no additional direction is 

needed in the revised plan.

Summary of Results

The eligibility process resulted in finding no new rivers or river segments eligible for inclusion in 

the National Wild and Scenic Rivers System. Kanab Creek is considered eligible for further study 

as a wild and scenic river. Interim management of Kanab Creek within a designated wilderness 

will maintain its eligibility as a classified wild river until a suitability study is completed. 

References

USDA Forest Service. 1993. Resource information report: Potential wild/scenic/recreational river 

designation, national forests of Arizona. Albuquerque, NM: Southwestern Region, USDA 

Forest Service. 

494 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix G. Research

Natural Area Evaluation

Background

Research natural areas (RNAs) are a type of special area within the National Forest System 

designated for their unique or special characteristics (FSM 1905 – Definitions). As special areas, 

RNAs must be supported by desired conditions or other plan components developed in the 

revised forest plan. RNAs are physical or biological units in which current natural conditions are 

maintained insofar as possible. These conditions are ordinarily achieved by allowing natural 

physical and biological processes to prevail without human intervention. RNAs are principally 

used for nonmanipulative research, observation, and study (FSM 4063). RNAs are designated to:

“maintain a wide spectrum of high quality representative areas that represent the 

major forms of variability found in forest, shrubland, grassland, alpine, and 

natural situations that have scientific interest and importance that, in 

combination, form a national network of ecological areas for research, 

education, and maintenance of biological diversity” (FSM 4063.02). 

Guidance for the selection and establishment of RNAs within the National Forest System comes 

primarily from the manuals for land and resource management planning and associated 

environmental analyses (FSM 1920 and FSM 1950). RNAs must be large enough to provide 

essentially unmodified conditions within their interiors. Whenever possible, proposed areas 

should show no evidence of major disturbances by humans, such as livestock grazing or timber 

cutting, for the past 50 years. In the selection of representative areas, a pristine condition is the 

goal.

Regional Research Natural Area Inventory

The Southwestern Region developed a process for the evaluation and incorporation of RNAs into 

forest plan revision under the 1982 Planning Rule Provisions (USDA Forest Service 2009). A 

Regionwide coarse-filter assessment of RNA ecological representation was conducted to help 

identify ecosystems and vegetation types that are underrepresented among the Region’s currently 

established RNAs. This provided an inventory of existing and previously proposed RNAs as 

identified in existing forest plans. The inventory identified 18 designated or formally established 

RNAs in the Southwestern Region, and 28 RNAs that were previously proposed (recommended) 

but never formally established.

To assist the coarse filter analysis of RNA representativeness in the region, the RNAs were 

categorized by potential natural vegetation type (PNVT). Four ecological datasets were used to 

help determine how well the established and previously proposed RNAs represent vegetation 

types and ecosystems in the Southwest, including:

• R3 Climate Regime

• The Nature Conservancy (AZ) Priority Conservation Areas

• Ecoregions (Cleland et al. 2007)

• R3 Potential Natural Vegetation (PNVT)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 495
Appendix G. Research Natural Area Evaluation

Regional Research Natural Area 

Representativeness Needs Assessment

Once the regional RNA inventory was completed, it was used to evaluate the need for additional 

RNAs in the region. This process rated the representativeness of existing RNAs within the region 

and identified underrepresented ecosystems. The objective of this effort was to support an 

effective ecological distribution of RNAs across major climate gradients, biophysical settings 

(PNVTs), and to some extent, across important vegetation types within life zones.

The distribution of existing RNAs and other protected lands, inside and outside the agency, were 

compared with the distribution of PNVT classes (general ecosystem types), ecological sections, 

and terrestrial ecological unit inventory (TEUI) climate gradients (Winthers et al. 2005). This 

assessment was conducted under the assumption that any proposed RNAs would be designated 

for the purposes of research and establishing reference sites across all major ecosystem types.

RNA needs were considered according to the distribution of currently-protected lands across 

PNVT classes, ecological sections, and TEUI climate gradients. There currently are 18 designated 

(formally established) RNAs in the Southwestern Region. The RNA Needs Assessment assigned 

representativeness ratings on a scale of 1 to 3. A rating of “1” reflects the least degree of need 

according to those criteria of representativeness used for this assessment (PNVT is well 

represented). A rating of “2” indicates that the PNVT is moderately represented, but additional 

representation across the region may be warranted. A rating of “3” reflects there is very little to no 

representation of a particular PNVT. In this assessment, rating of 2 and 3 are considered 

appropriate for RNA recommendations. Table G 1 displays the need ratings for the PNVTs that 

occur on the Kaibab National Forest (NF).

Table G 1. Potential natural vegetation type (PNVT) on the Kaibab National Forest and their 

research natural area (RNA) needs rating for the Southwestern Region

PNVT Name Need for Additional RNA

Juniper Grassland 3

PJ Sagebrush 1

PJ Woodland (persistent) 2

Ponderosa Pine Forest 2

Mixed Conifer - Frequent Fire 1

Spruce-fir Forest 1

Sagebrush Shrubland 2

Montane/Subalpine Grassland 1

Colorado Plateau/Great Basin Grassland 1

Semidesert Grassland 2

Desert Communities 1

Gambel Oak Shrubland 2

Wetland/Cienega 2

Cottonwood Willow Riparian Forest 2

496 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix G. Research Natural Area Evaluation

Kaibab National Forest Evaluation

for Previously Proposed Research Natural Areas

The original Kaibab forest plan (as amended) proposed Garland Prairie, a 340-acre area on the 

Williams Ranger District, as an RNA. This area is typical of the high-elevation grassland ecotone 

dominated by Arizona fescue and mountain muhly and is classified as the montane grassland 

PNVT. Garland Prairie was never established as a RNA, so it was reevaluated as a candidate for 

establishment under the revised plan. The first step in the evaluation process is to identify 

whether the potential RNA contains PNVTs with a need rating of 2 or 3, and if there are 

outstanding aquatic habitats within the area. Because this area has a need rating of “1” and there 

are no associated aquatic habitats, Garland Prairie does not meet the regional RNA PNVT 

representativeness criteria and is not being recommended for establishment. 

Garland Prairie (Montane Grassland PNVT, Need 

Ranking = 1)

While Garland Prairie does not meet the need criteria for RNA designation, the Kaibab NF

recognizes it has continued value as a reference area because grazing has been excluded since 

1989, and it was considered to be in good condition when it was identified in the original forest 

plan. The area has some invasive species present and also conifer encroachment that would 

benefit from treatments. As a result, the proposed forest plan has retained Garland Prairie as a 

management area and provided plan direction that would protect it from activities that could 

directly or indirectly modify ecologic processes. 

Identification and Evaluation of New Research 

Natural Areas on the Kaibab National Forest

The Kaibab NF solicited public input during several phases of the plan revision process: at the 

initial public meetings, during a topic meeting on special areas, as a question in the initial 

working drafts of the proposed plan, and during the Issues and Alternatives Development 

meeting. At the public meetings held in Williams and Fredonia, Arizona, in August 2009, an RNA 

poster was presented that shared the RNA concept and assessment process. During the meeting, 

there were opportunities to provide oral or written responses to several questions, including one 

specifically for RNAs:

“Are there specific areas that you know of on the forest that might be good examples of the 

underrepresented vegetation types to consider for designation as RNAs? (i.e., ponderosa pine, 

Gambel oak, pinyon-juniper, sagebrush, semidesert grassland, wetlands, cottonwood/willow 

riparian forest)?” 

There were no written or oral responses to this question at either meeting. 

Additionally, the forest solicited input from forest specialists and partners. One area, Lookout 

Canyon, was identified internally by a gap in the forest timber sale data. This suggested that the 

area had not been commercially logged. This was shared as a potential RNA that would be 

evaluated, and it received support from participants during the issues and alternative development 

meeting in July 2010. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 497
Appendix G. Research Natural Area Evaluation

No juniper grasslands (need = 3) were brought forward as potentially good RNAs. Historically 

pinyon-juniper grasslands had relatively low tree cover and typically experienced low-severity 

fires. Disruptions in the fire regime on the Kaibab NF have resulted in the pinyon-juniper 

grasslands being denser than the reference conditions and with an increased risk of standreplacing fire. The juniper grasslands on the forest are generally departed from reference 

conditions and regular livestock grazing occurs in most of the PNVT (KNF 2008).

Lookout Canyon (Ponderosa Pine PNVT, Need Ranking = 2)

Lookout Canyon is located on the North Kaibab Ranger District. This potential RNA area is a 

relatively steep, narrow canyon that runs from southeast to northwest on the northeast side of 

NFS Road 22 between NFS Roads 415 and 425. Elevation varies from approximately 8,000 feet 

to 7,600 feet over one-quarter to one-third of a mile.

A field trip to the area revealed that the northeast-facing slope is primarily mixed conifer. The 

bottom of the canyon is a grassy opening approximately 50 to 100 meters wide. The southwestfacing slope is occupied by dense, single-story ponderosa pine, and does not appear to represent 

the reference condition. Because the northeast-facing slope would be better described as frequent 

fire mixed conifer PNVT (which has a need rating = 1), this potential RNA has a lower need. 

Summary of Results

The Kaibab NF followed the evaluation process and completed the ecological conditions review 

table (see table G 2) for Lookout Canyon. The field trip and documentation revealed that the area 

was a poor representation of the ponderosa pine PNVT. Because no new areas were identified as 

potentially good RNAs and the only previously recommended RNA (Garland Prairie) no longer 

meets the criteria, no RNAs are being recommended during this plan revision effort.

498 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix G. Research Natural Area Evaluation

Table G 2. Review of ecological conditions in Lookout Canyon 

Ecological Conditions Appropriate for RNA 

Establishment

State Reason 

Why the Area 

Meets the 

Criterion

State Reason Why the 

Area Does Not Meet the 

Criterion

Area contributes to a wide spectrum of high-quality 

representative areas that represent the major forms of 

variability found in forest, shrubland, grassland, alpine, 

aquatic habitats, and natural situations of scientific 

interest and importance that in combination form a 

national network of ecological areas for research, 

education, and maintenance of biological diversity. 

RNA represents a specific vegetation type or ecosystem 

as identified by the regional ecological RNA evaluation. 

Mixed conifer w/aspen is 

ranked “1” – least need. No 

aquatic habitats. Does not 

represent a specific vegetation 

type. 

Area contributes or continues to contribute to the 

preservation and maintenance of genetic diversity, 

including threatened, endangered, aquatic systems, and 

sensitive species. 

May contain 

sensitive bat 

species.

No known threatened, 

endangered, or sensitive 

species.

Area serves as a baseline or reference area for the study 

of long-term ecological processes such as disturbance, 

hydrologic processes, climate change, or other 

processes. 

Definitely NOT a reference 

area. Seeded nonnative grass 

species, ponderosa pine 

multistoried and denser than 

reference conditions.

Area serves as a control area for comparing results from 

manipulative research. 

Steep slopes would likely 

prevent manipulative research.

Area boundaries encompass an area large enough to 

provide essentially unmodified conditions within their 

interiors, and to protect the ecological processes, 

features, and/or qualities for which the RNA was 

established.

Narrow, highly modified, 

subject to human presence and 

disturbance. 

Area shows little or no evidence of major disturbances 

by humans. Activities, such as livestock grazing and 

other uses, have not affected the area beyond its ability 

to recover. No evidence of timber cutting in past 50 

years. 

Developed trail and trailhead 

nearby, stumps, two-track road 

up the bottom of the canyon 

with, recent vehicle use 

evident, power line, livestock 

evidence.

Area reflects its original, near pristine condition as 

closely as possible. 

Not Pristine 

The best available, qualified area was chosen. In certain 

geographic regions and in certain community types, it 

may be impossible to find candidate areas that do not 

contain exotic plant or animal life. 

NO

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 499
Appendix G. Research Natural Area Evaluation

References

Cleland, D.T., J.A. Freeouf, J.E. Keys, Jr., G.J. Nowacki, C. Carpenter, and W.H. McNab. 2007.

Ecological subregions – sections and subsections of the conterminous United States: 

Washington, D.C., U.S. Department of Agriculture–Forest Service, General Technical 

Report WO-76, scale 1:3,500,000. Available from 

http://fsgeodata.fs.fed.us/other_resources/ecosubregions.php. Accessed April 25, 2013.

Kaibab National Forest (KNF). 2008. Kaibab National Forest ecological sustainability report. 

Version 1.01.

USDA Forest Service. 2009. Research natural area process for forest plan revision under the 1982 

Planning Rule provisions. Albuquerque, NM: Southwestern Region RNA Work Group.

Winthers, E., D. Fallon, J. Haglund, T. DeMeo, G. Nowacki, D. Tart, M. Ferwerda, G. Robertson, 

A. Gallegos, A. Rorick, D. Cleland, and W. Robbie. 2005. Terrestrial Ecological Unit 

Inventory Technical Guide. Washington, DC: U.S. Department of Agriculture, Forest 

Service, Washington Office, Ecosystem Management Coordination Staff. 245 pp.

500 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 501

Appendix H. Crosswalk Between Species

Habitat Risk/Threats and Plan Components 

This table is a crosswalk that shows how plan components meet species specific habitat needs. More detailed information on individual 

species contained within groups can be found in the “Species Diversity Report,” version 1.2.5. 

DC = Desired Conditions, OBJ = Objectives, ST = Standards, GD = Guidelines

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Tree dependent 

Northern goshawk, 

golden eagle, juniper 

titmouse, ferruginous 

hawk, red-faced 

warbler, evening 

grosbeak, olive-sided 

flycatcher, dusky 

grouse, Grace’s 

warbler, black-throated 

gray warbler, bald 

eagle, Lewis’s 

woodpecker, purple 

martin, red-naped 

sapsucker, Mexican 

spotted owl, gray vireo, 

western skink, Utah 

Mountain kingsnake, 

pale Townsend’s bigeared bat, Allen’s 

lappet-browed bat, 

southwestern myotis , 

Merriam’s shrew

Large trees and 

snags, cavities, 

downed logs, 

woody debris,

mistletoe broom

Logging, 

wildfire, forest 

treatments such 

as prescribed fire 

and thinning, 

firewood 

collection, pile 

burning.

Pinyon-Juniper Communities DC: Pinyon-juniper communities occur as a shifting mosaic 

across the landscape interspersed with openings. Old growth occurs throughout the landscape, 

generally in small areas as individual components, or as clumps. The mature groups of trees 

are structurally diverse, containing large live trees, as well as trees with dead or broken tops, 

gnarls, and burls. Snags, green snags and downed trees greater than 10 inches at root collar 

are present and average 1 to 2 per acre. 

Pinyon-Juniper Shrub Communities DC: The pinyon-juniper sagebrush shrub forest type is 

a mix of trees and shrubs that occur as shifting vegetation states (herbaceous-dominated, 

shrub-dominated, and tree-dominated) in even-aged and uneven-aged patches with a variable 

understory. There is a mix of large and small to mid-size juniper. 

Pinyon-Juniper Woodland DC: Some very old trees (over 300 years old) are present. 

Disturbances rarely affect the composition, structure, and function. Insects, disease and 

mistletoe occur at endemic levels.

Pinyon-Juniper Communities GD: Restoration efforts should emphasize the retention of 

groups of mature trees where they occurred historically. Where pinyon-juniper obligate 

species occur (e.g., gray vireo), project designs should use methods (e.g., selective pruning, 

lop and drop, etc.) that emphasize the retention of key habitat features including snags, and 

partially dead or dying trees, and downed logs.

Ponderosa Pine DC: Fine-scale: Tree groups are made up of clumps of various age classes 

and size classes that typically occur in areas less than one acre, but may be larger, such as on 

north-facing slopes. Large tree form oaks, snags and partial snags with hollow boles or limbs 

are present. Isolated infestations of Southwest dwarf mistletoe may occur, but the degree of 

severity and amount of mortality varies among the infected trees. Witch’s brooms may form 
502 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

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on infected trees, providing habitat and food for wildlife and invertebrate species. Mid-scale:

The ponderosa pine forest vegetation community is characterized by variation in the size and 

number of tree groups depending on elevation, soil type, aspect, and site productivity. The 

mosaic of tree groups generally comprises an uneven-aged forest with all age classes and 

structural stages present. Basal area within forested areas generally ranges from 20 to 80 

square feet per acre, with larger trees (i.e. >18 inches d.b.h.) contributing the greatest percent 

of the total basal area. Snags 18inches d.b.h. or greater average 1 to 2 snags per acre. Snags 

and green snags of various size and forms are common. Downed logs (over 12 inches

diameter at mid-point, and greater than 8 feet long) average 3 logs per acre. Coarse woody 

debris greater than 3 inches in diameter (including downed logs), ranges from 3 to 10 tons per 

acre. Landscape: The ponderosa pine forest vegetation community is a mosaic of forest 

conditions composed of structural stages ranging from young to old trees. Groups of old trees 

are mixed with groups of younger trees. The ponderosa pine forest is composed 

predominantly of vigorous trees, but declining trees are present. Snags, green snags, and 

coarse woody debris are well-distributed throughout the landscape. Old growth occurs 

throughout the landscape, generally in small areas as individual old growth components, or as 

clumps of old growth. Old growth components include old trees, dead trees (snags), downed 

wood (coarse woody debris) and structural diversity. The location of old growth shifts on the 

landscape over time as a result of succession and disturbance (tree growth and mortality). The 

landscape is a functioning ecosystem that contains all its components, processes, and 

conditions associated with endemic levels of disturbances (e.g., fire, dwarf mistletoe, insects, 

diseases, lightning, drought, and wind).

Frequent Fire Mixed Conifer DC: Fine-scale: Trees within groups are of similar or variable 

ages, often containing more than one species. Dwarf mistletoe infections may be present on 

ponderosa pine and Douglas-fir, and rarely on other tree species, but the degree of infection 

severity and rate of mortality varies among infected trees. Witch’s brooms may be present 

with these infestations, providing habitat for wildlife. Mid-scale: The frequent fire mixed 

conifer forest vegetation community is characterized by variation in the size and number of 

tree groups depending on elevation, soil type, aspect, and site productivity. Basal area within 

forested areas generally ranges from 30 to100 square feet per acre, with larger trees 

contributing the greatest percent of the total basal area. The mosaic of tree groups generally 

comprises an uneven-aged forest with all age classes and structural stages. Snags and green 

snags, 18inches d.b.h. or greater average 3 per acre. Downed logs (greater than12 inches

diameter at mid-point and over 8 feet long) average 3 per acre within the forested area of the 

mid-scale. Coarse woody debris, including downed logs, ranges from 5 to 15 tons per acre.

Landscape: At the landscape scale, the frequent fire mixed conifer forest community is a 

mosaic of forest conditions composed of structural stages ranging from young to old trees. 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 503

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

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Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Old growth occurs throughout the landscape, generally in small areas as individual old growth 

components, or as clumps of old growth. Old growth components include old trees, dead trees 

(snags), downed wood (coarse woody debris) and structural diversity. The frequent fire mixed 

conifer forest community is composed predominantly of vigorous trees, but declining trees 

are present and snags, top killed, lightning and fire scarred trees, and coarse woody debris 

(greater than 3-inch diameter) are well-distributed throughout the landscape. The landscape is 

a functioning ecosystem that contains all components, processes, and conditions that result 

from endemic levels of disturbances (e.g., fire, insects, diseases, and wind). Dwarf-mistletoe 

is present and infects ponderosa pine and Douglas-fir, but occurs at endemics levels, which 

allows for the establishment and sustainability of the desired uneven aged forest structure 

over time.

Mesic Mixed Conifer/Spruce-Fir DC: Fine-scale: Trees within groups can be of similar or 

variable species and ages. Dwarf mistletoe infections may be present on Douglas-fir or spruce 

and rarely on other tree species, but the degree of infection severity and amount of mortality 

varies among infected trees. Witch’s brooms may be present with these infestations, 

providing habitat for wildlife. Mid-scale: The number of snags and downed logs (greater than 

12 inches diameter at mid-point, over 8 feet long) and coarse woody debris (over 3-inch

diameter) vary by seral stage. Snags 18 inches or greater at d.b.h. typically range from 1 to 5 

snags per acre, with the lower range associated with early seral stages and the upper range 

associated with late seral stages. Coarse woody debris, including downed logs, varies by seral 

stage, but ranges from 5 to 20 tons per acre for early seral, 20 to 40 tons per acre for mid 

seral, and over 35 tons per acre in late seral areas. Fire and other disturbances maintain 

overall desired tree density, structure, species composition, coarse woody debris, and nutrient 

cycling. Landscape: The vegetation community is a mosaic of structural and seral stages 

ranging from young trees through old and is composed of multiple species. The landscape is 

composed predominantly of vigorous trees, but older declining trees are a component and 

provide for snags, top-killed, lightning- and fire-scarred trees, and coarse woody debris. The 

forest landscape is a functioning ecosystem that contains all its components, processes, and 

conditions that result from endemic levels of disturbances (e.g., insects, diseases, wind, snow, 

and fire), including snags, downed logs, and old trees. Dwarf mistletoe infestations may be 

present in stands that are composed of Douglas-fir or spruce and rarely in other tree species. 

Infestation size, degree of severity, and amount of mortality varies among infested stands. 

Witch’s brooms may be scattered throughout the infestations providing structural diversity in 

the stand and improved foraging and nesting habitat for wildlife species such as small 

mammals (e.g., tree squirrels), and raptors (e.g., goshawks, spotted owls). Old growth 

includes old trees, dead trees (snags), downed wood (coarse woody debris) and structural 
504 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

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Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

diversity.

Aspen (General) DC: Aspen is successfully regenerating and recruiting into older and larger 

size classes. Size classes have a natural distribution, with the greatest number of stems in the 

smallest classes. 

Aspen within Ponderosa Pine and Frequent Fire Mixed Conifer Forests DC: In 

ponderosa pine and frequent fire mixed conifer vegetation types, the size, age and spatial 

extent of aspen stands reflect reference condition.

Aspen within Mesic Mixed Conifer / Spruce-Fir Forests DC: Downed aspen and woody 

debris are scattered across the landscape and provide habitat for a variety of wildlife species 

(e.g., small mammals, reptiles, amphibians, and birds) while contributing to efficient nutrient 

cycling. The size, age, and spatial extent of aspen stands reflect large-scale disturbance 

patterns and processes.

Aspen GD: Aspen trees 10 inches or greater d.b.h. (both live and dead) should be protected 

during project activities, except where they may pose a risk to fences lines or regeneration 

efforts.

Vegetation Management in all Forested Communities GD: Projects in forested 

communities that change stand structure should generally retain at least historic frequencies 

of trees by species across broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. Project design and treatment prescriptions should 

generally not remove: (1) Large, old ponderosa pine trees with reddish yellow wide platy 

bark, flattened tops, with moderate to full crowns and large drooping or knarled limbs (e.g., 

Thompson’s age class 4, Dunning’s tree class 5 and/or Keen’s tree class 4, A and B). (2) 

Mature trees with large mistletoe brooms suitable for wildlife nesting, caching, and denning, 

except where retaining such trees would prevent the desired development of uneven-aged 

conditions over time. (3) Large snags, partial snags and trees (greater than 18 inches d.b.h) 

with broken tops, cavities, sloughing bark, lightning scars over 4 inches wide, and large stick 

nests (over 18 inches in diameter). (4) Gambel oak greater than 8 inches d.r.c. and (5) Known 

bat roost trees. 

Activities Following Large-scale Disturbances GD: Recovery and restoration project 

design should seek to establish a trajectory toward the desired conditions for the affected 

vegetation type. Some snags and coarse woody debris should be retained to provide for 

wildlife habitat, soil stabilization, and other resource benefits. Some clumps of large (18

inches d.b.h.) standing dead trees should be retained. Snag retention should be balanced with 

desired fuel levels over time.

Cottonwood Willow Riparian DC: Snag and gallery tree components comprised 55 percent
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 505

Appendix H. Crosswalk Between Species Habitat 

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Group

Characteristi

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Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

mid-aged to mature cottonwood and willow trees, 25 percent younger trees, and 20 percent in 

grass, shrubs, suckers, seedlings, and tree sprouts. Mature cottonwood and other trees provide 

cavities for cavity-dependent wildlife such as woodpeckers, sapsuckers and secondary cavity 

users. Tall trees provide lookouts and opportunities for nesting raptors. 

Wildlife DC: Species with specific habitat needs such as snags, logs, large trees, interlocking 

canopy, and cavities are provided for. 

GD: Project activities and special uses should be designed and implemented to maintain 

refugia and critical life cycle needs of wildlife, particularly for raptors. Project activities and 

special uses should incorporate recommended measures for golden eagle management such as 

closures to limit human disturbance in the vicinity of golden eagle nests.

Threatened, Endangered, and Sensitive Species GD: Project activities and special uses 

occurring within federally listed species habitat should integrate habitat management 

objectives and species protection measures from approved recovery plans. Project activities 

and special uses should be designed and implemented to maintain refugia and critical life 

cycle needs of Forest Service Sensitive Species.

Personal Fuelwood Collection GD: The following should be permitted for personal use 

fuelwood gathering: (1) Dead and downed ponderosa pine, Douglas-fir and spruce, juniper, 

pinyon pine, Gambel oak, or aspen. (2) Standing dead: (a) Ponderosa pine, Douglas-fir or 

spruce less than 12 inches d.b.h. or less than 15 feet in total height; (b) Juniper without green 

foliage; (c) Pinyon pine less than 12 inches d.r.c. or less than 12 feet in height; (d) Gambel 

oak: less than 8 inches d.r.c.; and (e) Aspen, less than 12 inches d.b.h.

Wildland Fire Management GD: Decision documents for wildland fires should address 

wildlife desired conditions for key habitat features that provide structural diversity such as 

snags, logs, large tree form oaks, and oak thickets. Associated courses of action or 

management practices to address those objectives should also be developed.

Wildland-urban Interface DC: Logs and snags, which often pose fire control problems, 

are present in the wildland-urban interface, but at the lower end of the range given in the 

vegetation community desired conditions. Dead and down fuel load is between 1 and 5 tons

per acre.

Multilayered canopy, 

interlocking canopy 

and old growth

Northern goshawk, 

juniper titmouse, redfaced warbler, evening 

Interlocking 

canopy, old 

growth and 

denser stands.

Logging, fire 

(natural and 

prescribed).

Pinyon Juniper Communities DC: Pinyon-juniper communities occur as a shifting mosaic 

across the landscape interspersed with openings. Old growth occurs throughout the landscape, 

generally in small areas as individual components, or as clumps. The location of old growth 

shifts on the landscape over time as a result of succession and disturbance (tree growth and 

mortality). At the mid-scale and above, canopy cover is at least 10 percent with a mix of 

young and mature groups and clumps of trees. The mature groups of trees are structurally 

diverse, containing large live trees, as well as trees with dead or broken tops, gnarls, and 
506 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

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grosbeak, olive-sided 

flycatcher, dusky 

grouse, black-throated 

gray warbler, pinyon 

jay, Lewis’s 

woodpecker, 

MacGillivray’s 

warbler, green-tailed 

towhee, goldencrowned kinglet, 

Mexican spotted owl, 

Arizona treefrog, 

Abert’s squirrel, 

Kaibab tree squirrel, 

dwarf shrew, red 

squirrel

burls. Some tree groups have 30 to 40 percent canopy cover that provides habitat for nesting, 

bedding, and foraging. 

Pinyon-Juniper Shrub Communities DC: The pinyon-juniper sagebrush shrub forest type is 

a mix of trees and shrubs that occur as shifting vegetation states (herbaceous-dominated, 

shrub-dominated, and tree-dominated) in even-aged and uneven-aged patches with a variable 

understory. 

Pinyon-Juniper Communities GD: Restoration efforts should emphasize the retention of 

groups of mature trees where they occurred historically.

Ponderosa Pine DC: Fine-scale: Crowns of trees within the mid-aged to old groups are 

interlocking or nearly interlocking and consist of approximately 2 to 40 trees per group. 

Where Gambel oak comprises more than 10 percent of the basal area, it is not uncommon for 

canopy cover to be greater than 40 percent. Mid-scale: The ponderosa pine forest vegetation 

community is characterized by variation in the size and number of tree groups depending on 

elevation, soil type, aspect, and site productivity. The mosaic of tree groups generally 

comprises an uneven-aged forest with all age classes and structural stages present. Forest 

conditions in some areas contain 10 to 20 percent higher basal area in mid-aged to old tree 

groups than in the general forest (e.g., goshawk post-fledging family areas, Mexican spotted 

owl nesting/roosting habitat, drainages, and steep north facing slopes). Landscape: The 

ponderosa pine forest vegetation community is a mosaic of forest conditions composed of 

structural stages ranging from young to old trees. The forest is generally uneven-aged and 

open. Groups of old trees are mixed with groups of younger trees. Denser tree conditions 

exist in some locations such as north facing slopes, canyons, and drainage bottoms. Old 

growth occurs throughout the landscape, generally in small areas as individual old growth 

components, or as clumps of old growth. Old growth components include old trees, dead trees 

(snags), downed wood (coarse woody debris) and structural diversity. The location of old 

growth shifts on the landscape over time as a result of succession and disturbance (tree 

growth and mortality). 

Frequent Fire Mixed Conifer DC: Fine-scale: Trees typically occur in irregularly shaped 

groups and are variably-spaced with some tight clumps. Crowns of trees within the mid-aged 

to old groups are interlocking or nearly interlocking. Tree groups are typically greater than 1-

acre size and consist of 2 to 50 trees per group, but are sometimes larger, such as on northfacing slopes. Density is variable, with canopy ranging from very open to very closed. Midscale: The more biologically productive sites contain more trees per group and more groups 

per area. Forest conditions in some areas contain 10 to 20 percent higher basal area in midaged to old tree group than in the general forest; these include goshawk post-fledging family 

areas, Mexican spotted owl nesting/roosting habitat, and north-facing slopes. The mosaic of 

tree groups generally comprises an uneven-aged forest with all age classes and structural 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 507

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Characteristi

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Potential 

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Plan Components Which Address Risks to Species Viability

stages. Landscape: At the landscape scale, the frequent fire mixed conifer forest community 

is a mosaic of forest conditions composed of structural stages ranging from young to old 

trees. Old growth occurs throughout the landscape, generally in small areas as individual old 

growth components, or as clumps of old growth. Old growth components include old trees, 

dead trees (snags), downed wood (coarse woody debris) and structural diversity. The location 

of old growth shifts on the landscape over time as a result of succession and disturbance (tree 

growth and mortality). Forest appearance is variable but generally uneven-aged and open; 

occasional patches of even-aged structure are present. The forest arrangement is in small 

clumps and groups of trees interspersed within variably sized openings of native 

grass/forb/shrub vegetation associations similar to reference conditions. Size, shape, number 

of trees per group, and number of groups per area are variable across the landscape. Denser 

tree conditions exist in some locations such as north facing slopes, canyons, and drainage 

bottoms. 

Mesic Mixed Conifer/Spruce-Fir DC: Fine-scale: Mid-aged and older forests trees are 

typically variably-spaced with crowns interlocking (grouped and clumped trees) or nearly 

interlocking. Trees within groups can be of similar or variable species and ages, contributing 

to vertical and horizontal heterogeneity. Mid-scale: Forest conditions in some areas contain 

higher basal area than the general forest; examples include goshawk post-fledgling family 

areas, Mexican spotted owl nesting/roosting habitat, and north-facing slopes. Density ranges 

from 20 to 250 square feet of basal area per acre, depending upon disturbance and seral stages 

of groups and patches. Landscape: The vegetation community type is a mosaic of structural 

and seral stages ranging from young trees through old and is composed of multiple species. 

The landscape arrangement is an assemblage of variably sized and aged groups and patches of 

trees and other vegetation similar to reference conditions. Old growth generally occurs over 

large areas as stands or forests where old growth is concentrated. Old growth includes old 

trees, dead trees (snags), downed wood (coarse woody debris) and structural diversity. The 

location of old growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). 

Aspen (General) DC: Aspen is successfully regenerating and recruiting into older and larger 

size classes. Size classes have a natural distribution, with the greatest number of stems in the 

smallest classes.

Aspen within Ponderosa Pine and Frequent Fire Mixed Conifer Forests DC: In 

ponderosa pine and frequent fire mixed conifer vegetation types, the size, age and spatial 

extent of aspen stands reflect reference condition.

Vegetation Management in All Forested Communities GD: Projects in forested 

communities that change stand structure should generally retain at least historic frequencies 

of trees by species across broad age and diameter classes at the mid-scale. On suitable 
508 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

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timberlands, projects should retain somewhat higher frequencies of trees across broad 

diameter classes to allow for future tree harvest. Project design should manage for 

replacement structural stages to assure continuous representation of old growth over time. 

Wildlife DC: Habitat is available at the appropriate spatial, temporal, compositional, and 

structural levels such that it provides adequate opportunity for breeding, feeding, nesting, and 

carrying out other critical life cycle needs for a variety of vertebrate and invertebrate species. 

Threatened, Endangered, and Sensitive Species DC: Goshawk nest areas are multi-aged 

forests dominated by large trees with interlocking crowns and are generally denser than the 

surrounding forest.

GD: Project activities and special uses occurring within federally listed species habitat 

should integrate habitat management objectives and species protection measures from 

approved recovery plans. Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest Service sensitive 

species. A minimum of six nest areas (known and replacement) should be located per 

territory. Goshawk nest and replacement nest areas should generally be located in drainages, 

at the base of slopes, and on northerly (NW to NE) aspects. Nest areas should generally be 

25 to 30 acres in size. Goshawk territories (post-fledging family areas) of approximately 

420 acres in size should be designated surrounding the nest areas.

Understory 

dependent

Dusky grouse, redfaced warbler, Nevada 

point-head 

grasshopper, 

Persephone’s darner, 

desert green hairstreak, 

Kaibab Indra 

swallowtail, fourspotted skippering, 

Nokomis fritillary, 

Nokomis fritillary ssp. 

nokomis, pronghorn, 

Navajo Mogollon vole, 

Merriam’s shrew, 

dwarf shrew

Native grasses 

and shrubs/

underbrush.

Pile burning, 

nonnative plant 

invasion.

Pinyon-Juniper Communities DC: Pinyon-juniper communities occur as a shifting mosaic 

across the landscape interspersed with openings. At the mid-scale and above, canopy cover is 

at least 10 percent with a mix of young and mature groups and clumps of trees. Plant litter 

(leaves, needles, etc.) and understory plant cover is present in sufficient quantity to stabilize 

soils, prevent erosion, promotes nutrient cycling, improve water retention, and provide the 

microclimate conditions necessary for pinyon seed germination.

Pinyon-Juniper Grasslands DC: Pinyon-juniper grasslands are generally uneven-aged and 

open in appearance. Trees occur as individuals, but occasionally are in small groups and 

range from young to old. Scattered shrubs and a dense herbaceous understory including native 

grasses, forbs and annuals are present to maintain soil productivity, resist soil erosion and can 

support frequent low-intensity surface fires. Understory composition is within the natural 

range of variability and contains diverse native herbaceous plant species that provide nutrition 

for pronghorn and other species. Depending on soil type and vegetation potential, bare soil 

varies between 10 and 60 percent. Basal vegetation varies between 5 and 50 percent ground 

cover. Organic litter varies between 30 and 50 percent of the ground cover. The relative 

proportion of vegetation canopy cover averages 40 to 60 percent grass, 10 to 30 percent 

forbs, and 5 to 20 percent shrub..

Pinyon-Juniper Shrub DC: The shrub component consists primarily of sagebrush, but oak, 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 509

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cliffrose, and other shrub species may also be present. The understory is dominated by shrubs 

depending on structural stage. The shrub component consists of one or more shrub species, 

which are well-distributed. Litter and rock comprise the greatest percentage of ground cover. 

Grasses and forbs are sparse due to shrub dominance.

Pinyon-Juniper Communities GD: Pinyon-juniper communities should maintain tree 

densities that maximize herbaceous plant growth and wildlife species diversity typical for 

their respective community subtype. Project design for vegetation management activities 

should prioritize treatment areas along known wildlife corridors, in the wildland-urban 

interface, and historic openings.

Ponderosa Pine DC Fine-scale: Trees typically occur in irregularly shaped groups and are 

variably spaced with some tight clumps. The interspaces between groups are variably shaped,

composed of a grass/forb/shrub mix, and may contain individual trees or snags. Organic 

ground cover and herbaceous vegetation provide protection for soil and moisture infiltration, 

and contribute to plant and animal diversity and ecosystem function. Herbaceous vegetation 

reflects the site potential. Mid-scale: Basal area within forested areas generally ranges from 

20 to 80 square feet per acre, with larger trees (i.e. >18 inches d.b.h.) contributing the greatest 

percent of the total basal area. Interspaces with grass/forb/shrub vegetation are variably 

shaped and typically range from 10 to 70 percent, with the more open conditions typically 

occurring on less productive sites. Landscape: The forest is generally uneven-aged and open. 

OBJ: Mechanically thin 11,000 to 19,000 acres annually. Treat an average of 13,000 to 

55,000 acres annually, using a combination of prescribed fire and naturally ignited wildfires.

Frequent Fire Mixed Conifer DC: Fine-scale: Trees typically occur in irregularly shaped

groups and are variably-spaced with some tight clumps. Interspaces between groups are 

variably shaped, are comprised of native grasses-forbs- shrubs mix, and may contain 

individual trees or snags. Organic ground cover and herbaceous vegetation provide protection 

of soil, moisture infiltration, and contribute to plant and animal diversity and to ecosystem 

function. Herbaceous vegetation reflects the site potential. Mid-scale: Basal area within 

forested areas generally ranges from 30 to 100 square feet per acre, with larger trees 

contributing the greatest percent of the total basal area. Openings with native grass, forb, and 

shrub vegetation typically range from 10 to 50 percent of the area. Landscape: The forest 

arrangement is in small clumps and groups of trees interspersed within variably sized 

openings of native grass-forb-shrub vegetation associations similar to reference conditions. 

OBJ: Burn an average of 1,000 to 13,000 acres annually, using prescribed fire and/or 

naturally ignited wildfires. Mechanically thin 1,200 to 2,100 acres annually.

Mesic Mixed Conifer/Spruce-fir DC: Fine-scale: Small openings (gaps) are present as a 

result of past disturbances. Organic ground cover and herbaceous vegetation provide 

protection for soil and moisture infiltration, and contribute to plant diversity and ecosystem 
510 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

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function. Understory vegetation reflects site potential. Mid-scale: Density ranges from 20 to 

250 square feet of basal area per acre, depending upon disturbance and seral stages of groups 

and patches. Grass, forb, and shrub dominated openings created by disturbance may make up 

10 to 100 percent of the mid-scale patches (100 to 1,000 acres). 

Aspen (General) DC: Understory vegetation consists of shrubby or herbaceous species, 

providing forage and cover for wildlife and habitat for invertebrates such as pollinators.

Vegetation Management in All Forested Communities GD: Vegetation management 

prescriptions should provide for sufficient canopy breaks to limit crown fire spread between 

groups, allow for the redevelopment and maintenance of a robust understory, and mimic the 

spatial arrangement of the references conditions. Trees established after 1890 should 

generally not be retained in areas where biophysical conditions would have supported stable 

openings over time. Vegetation management activities should meet or exceed goals for scenic 

beauty (scenic integrity objectives) by creating natural patterns, structure and composition of 

trees, shrubs, grasses and other plants. Vegetation treatments should favor the development of 

native understory species in areas where they have the potential to establish and grow. Seed 

and plants used for revegetation should originate from the same PNVT and general ecoregion 

(i.e., southern Colorado Plateau) as the project area.

Desert Communities DC: Desert communities are characterized by extensive grasses with a 

shrub cover less than 30 percent. Ground cover canopy ranges from 5 to 40 percent. Shrubs 

contribute to native plant diversity and structure.

Cottonwood-Willow Riparian Forest DC: Vegetation is characterized by willow and other 

herbaceous understory species. Snag and gallery tree components comprised 55 percent midaged to mature cottonwood and willow trees, 25 percent younger trees and 20 percent in 

grass, shrubs, suckers, seedlings, and tree sprouts.

Soil DC: Soils provide for diverse native plant species. Vegetative ground cover is welldistributed across the soil surface to promote nutrient cycling and water infiltration.

Wildlife DC: Grasses, forbs, and shrubs provide forage, cover, fawning, and nesting sites. 

Nonnative Invasive Species DC: Invasive species are contained and controlled so that they 

do not disrupt the structure or function of ecosystems. 

GD: All ground-disturbing projects should assess the risk of noxious weed invasion and 

incorporate measures to minimize the potential for the spread of noxious and invasive species. 

New populations are detected early, monitored, and treated as soon as possible. Use of 

pesticides, herbicides, and biocontrol agents should minimize impacts on non-target flora and 

fauna.

Livestock Grazing DC: Livestock use is consistent with other desired conditions.

GD: Livestock management should favor the development of native cool season grasses and 

forbs. Annual operating instructions for livestock grazing permittees should ensure livestock 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 511

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

numbers are balanced with capacity and address any relevant resource concerns (e.g., forage 

production, weeds, fawning habitat, soils, etc.). Post-fire grazing should not be authorized 

until Forest Service range staff confirms range readiness.

Mineral and Mining GD: Restoration and reclamation of surface disturbance associated 

with mineral activities should be implemented to achieve 70 percent of ground cover (as 

compared to nearby undisturbed areas) with permanent native vegetation within three 

growing seasons.

Grassland dependent 

Golden eagle, western 

burrowing owl, 

ferruginous hawk, 

savannah sparrow, 

Arizona black 

rattlesnake, milksnake, 

Great Basin spadefoot, 

Kaibab Indra 

swallowtail, pronghorn, 

Gunnison’s prairie dog, 

House Rock Valley 

chisel-toothed 

kangaroo rat, spotted 

bat, Navajo Mogollon 

vole

Native plant 

composition, 

openness.

Invasive plants, 

conifer/

woodland 

encroachment, 

unmanaged 

grazing.

Pinyon-Juniper Grassland DC: Pinyon-juniper grasslands are generally uneven-aged and 

open in appearance. Trees occur as individuals, but occasionally are in small groups and 

range from young to old. Scattered shrubs and a dense herbaceous understory including native 

grasses, forbs and annuals are present to maintain soil productivity, resist soil erosion and can 

support frequent low-intensity surface fires. Understory composition is within the natural 

range of variability and contains diverse native herbaceous plant species that provide nutrition 

for pronghorn and other species. Depending on soil type and vegetation potential, bare soil 

varies between 10 and 60 percent. Basal vegetation varies between 5 and 50 percent ground 

cover. Organic litter varies between 30 and 50 percent of the ground cover. The relative 

proportion of vegetation canopy cover averages 40 to 60 percent grass, 10 to 30 percent forbs, 

and 5 to 20 percent shrub.

Grasslands DC: Vegetation is composed of a mix of native grasses and forbs. The structure, 

composition, and distribution of vegetation are within the range of natural variability and 

occur in natural patterns of abundance and diversity, which vary depending on soil type and 

microclimate. Disturbance processes are similar to reference conditions and play a primary 

role in the function of the ecosystem. Vegetation height and cover are sufficient to support the 

historic fire return interval. Understory composition is within the natural range of variability 

and contains diverse native herbaceous plant species that provide nutrition for pronghorn and 

other species. Depending on soil type, bare soil varies between 5 and 80 percent. Basal 

vegetation varies between 5 and 60 percent ground cover. Organic litter varies between 30 

and 50 percent of the ground cover. Vegetation composition will average 40 to 60 percent 

grass, and 10 to 30 percent forbs. Understory vegetation reflects the site potential. Tree and 

shrub canopy cover are each less than 10 percent.

OBJ: Reduce tree density to greater than 10 percent on 5,000 to 10,000 acres of historic 

grasslands annually.

GD: In areas where native herbaceous cover is sparse and seed sources are depleted, seeding 

should be considered.

Colorado Plateau/Great Basin Grasslands DC: Vegetation height and canopy cover are 

sufficient to carry fire under low wind conditions to support fire on a 10- to 30-year return 
512 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

interval.

Semidesert Grasslands DC: Vegetation height and canopy cover are sufficient to carry fire 

under low wind conditions to support fire on a 10- to 30-year return interval.

Soil DC: Soils provide for diverse native plant species. Vegetative ground cover is welldistributed across the soil surface to promote nutrient cycling and water infiltration.

Wildlife DC: Grasses, forbs, and shrubs provide forage, cover, fawning, and nesting sites. 

Non-Native Invasive Species DC: Invasive species are contained and controlled so that they 

do not disrupt the structure or function of ecosystems. 

GD: All ground-disturbing projects should assess the risk of noxious weed invasion and 

incorporate measures to minimize the potential for the spread of noxious and invasive species. 

New populations are detected early, tracked, and treated as soon as possible. Use of 

pesticides, herbicides, and biocontrol agents should minimize impacts on non-target flora and 

fauna.

Livestock Grazing DC: Grasses and forbs provide adequate forage for permitted livestock. 

Livestock use is consistent with other desired conditions.

GD: Livestock management should favor the development of native cool season grasses and 

forbs. Annual operating instructions for livestock grazing permittees should ensure livestock 

numbers are balanced with capacity and address any relevant resource concerns (e.g., forage 

production, weeds, fawning habitat, soils, etc.). Post-fire grazing should not be authorized 

until Forest Service range staff confirms range readiness.

Meadow dependent

Golden eagle, 

American peregrine 

falcon, California 

condor, savannah 

sparrow, Kaibab 

variable tiger beetle, 

four-spotted 

skippering, pronghorn, 

Gunnison’s prairie dog, 

spotted bat, greater 

western mastiff bat, 

long- tailed vole, 

Navajo Mogollon vole, 

big free-tailed bat, 

Moist meadows, 

loss of forbs, 

soil substrate.

Erosion, tree 

invasion, 

mechanical 

thinning, fire, 

trampling/soil 

compaction.

Vegetation Management Activities GD: Heavy equipment and log decks should not be 

staged in montane meadows.

Grasslands DC: Vegetation is composed of a mix of native grasses and forbs. The structure, 

composition, and distribution of vegetation are within the range of natural variability and 

occur in natural patterns of abundance, which vary depending on soil type and microclimate. 

Disturbance processes are similar to reference conditions and play a primary role in the 

function of the ecosystem. Vegetation height and cover are sufficient to support the historic 

fire return interval. Understory composition is within the natural range of variability and 

contains diverse native herbaceous plant species that provide nutrition for pronghorn and 

other species. Depending on soil type, bare soil varies between 5 and 80 percent. Basal 

vegetation varies between 5 and 60 percent ground cover. Organic litter varies between 30 

and 50 percent of the ground cover. Vegetation composition will average 40 to 60 percent 

grass, and 10 to 30 percent forbs. Understory vegetation reflects the site potential.Tree and 

shrub canopy cover are each less than 10 percent.

Montane/Subalpine Grasslands DC: Montane meadows and subalpine grassland vegetation 

have high soil productivity and biological diversity. Native species occur in natural patterns 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 513

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

dwarf shrew, Kaibab 

northern pocket gopher

of abundance, composition, and distribution. Vegetation is healthy and at least stable. 

Vegetation and litter is sufficient to maintain and improve water infiltration, nutrient cycling, 

and soil productivity. 

Soil DC: Soils provide for diverse native plant species. Vegetative ground cover is welldistributed across the soil surface to promote nutrient cycling and water infiltration.

Wildlife DC: Grasses, forbs, and shrubs provide forage, cover, fawning, and nesting sites. 

Nonnative Invasive Species DC: Invasive species are contained and controlled so that they 

do not disrupt the structure or function of ecosystems above the fine scale. 

GD: All ground-disturbing projects should assess the risk of noxious weed invasion and 

incorporate measures to minimize the potential for the spread of noxious and invasive species. 

New populations are detected early, tracked, and treated as soon as possible. Use of 

pesticides, herbicides, and biocontrol agents should minimize impacts on non-target flora and 

fauna.

Livestock Grazing DC: Grasses and forbs provide adequate forage for permitted livestock. 

Livestock use is consistent with other desired conditions.

GD: Livestock management should favor the development of native cool season grasses and 

forbs. Annual operating instructions for livestock grazing permittees should ensure livestock 

numbers are balanced with capacity and address any relevant resource concerns (e.g., forage 

production, weeds, fawning habitat, soils, etc.). Post-fire grazing should not be authorized 

until Forest Service range staff confirms range readiness. The concentrated use of montane 

meadows for livestock grazing should be minimized when soils are saturated to reduce 

grassland impacts. When no other options are available, use should be rotated annually.

Transportation GD: Roads should not be located in meadows when they can be located in 

other areas.

Shrubland dependent

Sage sparrow, golden 

eagle, ferruginous 

hawk, sage thrasher, 

green-tailed towhee, 

Brewer’s sparrow, 

Arizona black 

rattlesnake, Utah 

Mountain kingsnake, 

Persephone’s darner, 

desert green hairstreak, 

pronghorn, spotted bat, 

Native shrubsspecies 

composition, 

openings.

Woodland 

invasion/successi

on unmanaged 

grazing

Pinyon-Juniper Shrub DC: The pinyon-juniper sagebrush shrub forest type is a mix of trees 

and shrubs that occur as shifting vegetation states (herbaceous-dominated, shrub-dominated, 

and tree-dominated) in even-aged and uneven-aged patches with a variable understory. There 

is a mix of large and small to mid-size juniper. The shrub component consists primarily of 

sagebrush, but, oak, cliffrose, and other shrub species may also be present. The understory is 

dominated by shrubs depending on structural stage. The shrub component consists of one or 

more shrub species, which are well-distributed. Shrubs typically are in a closed-canopy state 

during the later successional stages. The composition, structure, and function of vegetation 

conditions are resilient to the frequency, extent, and severity of disturbances including 

insects, diseases, fire, and climate variability.

Sagebrush Shrublands DC: The composition, structure, and function of biotic and abiotic 

components of sagebrush shrublands are within or moving toward reference conditions. The 
514 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

bat free-tail bat, desert 

bighorn sheep

majority of sagebrush is in mid-seral or mature states. Enough shrub cover exists to meet the 

needs of a variety of sagebrush-obligate wildlife species. A vigorous, but not necessarily 

dense, understory community of native grasses and forbs are present. Understory vegetation 

reflects the site potential. Single trees or groups of trees cover less than 10 percent of any 

Terrestrial Ecosystem Survey (TES) map unit polygon and less than 5 percent of the 

community. Shrub cover is at least 5 percent, and typically makes up 20 to 50 percent of any 

TES soil unit. Characteristic disturbances play a role in the function of the ecosystem.

GD: Prior to developing project proposals for restoring sagebrush communities, a 

determination should be made of the sagebrush sub-species because the differing sub-species 

indicate different desired reference conditions. Management activities should be designed to 

mimic the historic disturbance. Where sagebrush communities are severely degraded, waters 

should be strategically placed to improve animal distribution and reduce grazing impacts.

Desert Communities DC: Desert communities are characterized by extensive grasses with a 

shrub cover less than 30 percent. Ground cover canopy ranges from 5 to 40 percent. Shrubs 

contribute to the native plant diversity and structure. Plant litter occupies up to 5 percent of 

the soil surface. Density of juniper and other shrubby species is maintained at levels which 

promote natural fire regimes and long fire return intervals. Fire occurrence is low and 

infrequent. Natural disturbance regimes include soil engineers such as arthropods and 

sometimes small mammals. Rocky outcroppings and shrubby plant species provide abundant 

browse and foraging opportunities for mule deer and bighorn sheep. Native ungulates are free 

from disease. Domestic livestock are absent. 

GD: Fire should not be used as a vegetation management tool in desert communities.

Gambel Oak Shrublands DC: The system is dominated by native tall shrubs and hardwood 

trees. Some areas contain many trees with relatively large hollow boles or limbs. Coniferous 

trees are widely scattered and are frequently mature or old. Young Gambel oak thickets and 

sometimes other species comprise a patchy shrub layer. Ground cover is mostly comprised of 

oak litter, with grasses and forbs present. Low intensity fire occurs regularly with intervals of 

over 25 years. Nonnative species are absent or comprise less than 1 percent of the total cover. 

Old stands contain habitat for birds and arboreal nesting or roosting mammals. A variety of 

oak growth forms, sizes, and densities that benefit wildlife species can be found across the 

landscape. 

Wildland Fire Management GD: Decision documents for managing fire should evaluate the 

risk of cheatgrass invasion. When there is a moderate to high risk of cheatgrass invasion (e.g., 

lower elevation areas), mitigation measures should be implemented and/or fire should be 

excluded if adequate treatments are not available or if they are cost prohibitive.

Wilderness Areas GD: Wildfires should be suppressed in the desert communities of the 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 515

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Kanab Creek Wilderness.

Pinyon-juniper 

dependent

Pronghorn, Juniper 

titmouse, blackthroated gray warbler, 

pinyon jay, purple 

martin, gray vireo, 

Arizona black 

rattlesnake, western 

skink, Utah Mountain 

kingsnake, Great Basin 

spadefoot, 

Persephone’s darner, 

desert green hairstreak, 

Kaibab Indra 

swallowtail, big freetail bat

Openness of 

stands, diversity 

of stands.

Erosion, tree 

invasion, 

mechanical 

thinning, fire, 

trampling/soil 

compaction.

Pinyon-Juniper Communities DC: Pinyon-juniper communities occur as a shifting mosaic 

across the landscape interspersed with openings. The configuration of vegetation and 

openings provides foraging and browsing opportunities for wildlife, and enough sighting 

distance and hiding cover for pronghorn to escape predators. Old growth occurs throughout 

the landscape, generally in small areas as individual components, or as clumps. The location 

of old growth shifts on the landscape over time as a result of succession and disturbance (tree 

growth and mortality). At the mid-scale and above, canopy cover is at least 10 percent with a 

mix of young and groups and clumps of trees. The mature groups of trees are structurally 

diverse, containing large live trees, as well as trees with dead or broken tops, gnarls, and 

burls. Snags, green snags and downed trees greater than 10 inches at root collar are present 

and average 1 to 2 per acre. Some clumps have 30 to 40 percent canopy cover that provides 

habitat for nesting, bedding, and foraging. The composition, structure, and function of 

vegetative conditions are resilient to the frequency, extent and severity of disturbances (e.g., 

insects, diseases, and fire) and climate variability. Plant litter (leaves, needles, etc.) and 

understory plant cover contributes to soil stabilization, prevents erosion, promotes nutrient 

cycling, improves water retention, and provides the microclimate conditions necessary for 

pinyon seed germination. Nurse trees provide understory microclimate with improved 

nutrient and soil properties, higher soil moisture, and lower temperatures, and lower light 

levels, which increases the survival of pinyon seedlings under harsh conditions. A robust crop 

of pinyon pine nuts are regularly produced.

Pinyon-Juniper Grasslands DC: Pinyon-juniper grasslands are generally uneven-aged and 

open in appearance. Trees occur as individuals, but occasionally are in small groups and 

range from young to old. Scattered shrubs and a dense herbaceous understory including native 

grasses, forbs and annuals are present to maintain soil productivity, resist soil erosion and can 

support frequent low-intensity surface fires. The composition, structure, and function of 

vegetative conditions are resilient to the frequency, extent, and severity of disturbances 

(including insects, diseases, and fire) and climate variability. Understory composition is 

within the natural range of variability and contains diverse native herbaceous plant species 

that provide nutrition for pronghorn and other species. Depending on soil type and vegetation 

potential, bare soil varies between 10 and 60 percent. Basal vegetation varies between 5 and 

50 percent ground cover. Organic litter varies between 30 and 50 percent of the ground cover. 

The relative proportion of vegetation canopy cover averages 40 to 60 percent grass, 10 to 30 

percent forbs, and 5 to 20 percent shrub.

Pinyon-Juniper Shrub DC: The pinyon-juniper sagebrush shrub forest type is a mix of trees 

and shrubs that occur as shifting vegetation states (herbaceous-dominated, shrub-dominated, 
516 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

and tree-dominated) in even-aged and uneven-aged patches with a variable understory. There 

is a mix of large and small to mid-size juniper. The shrub component consists primarily of 

sagebrush, but, oak, cliffrose, and other shrub species may also be present. The understory is 

dominated by shrubs depending on structural stage. The shrub component consists of one or 

more shrub species, which are well-distributed. Shrubs typically are in a closed-canopy state 

during the later successional stages. Litter and rock comprise the greatest percentage of 

ground cover. Grasses and forbs are sparse due to shrub dominance. The composition, 

structure, and function of vegetation conditions are resilient to the frequency, extent and 

severity of disturbances including insects, diseases, fire, and climate variability. 

Pinyon-Juniper (Persistent) Woodlands DC: Pinyon-juniper woodland (persistent) is 

characterized by even-aged patches of pinyons and junipers that at the landscape level form 

multi-aged woodlands. Tree density and canopy cover are high, shrubs are sparse to 

moderate, and herbaceous cover is low and discontinuous due to soil and other site 

conditions. Some very old trees (over 300 years old) are present. Disturbances rarely affect 

the composition, structure, and function. Insects, disease and mistletoe occur at endemic 

levels. 

Pinyon-Juniper Communities GD: The pinyon-juniper vegetation type (pinyon-juniper 

grassland, shrubland, or woodland) should be determined before developing project 

proposals to ensure the applicable desired conditions are applied. Restoration efforts should 

emphasize the retention of groups of mature trees where they occurred historically. Pinyonjuniper communities should maintain tree densities that maximize herbaceous plant growth 

and wildlife species diversity typical for their respective community subtype. Where 

pinyon-juniper obligate species occur (e.g., gray vireo), project designs should use methods 

(e.g., selective pruning, lop and drop, etc.) that emphasize the retention of key habitat 

features including snags, and partially dead or dying trees, and downed logs. Project design 

for vegetation management activities should prioritize treatment areas along known wildlife 

corridors, in the wildland-urban interface, and in historic openings. Restoration treatments 

in pinyon-juniper should be rotated over time and various successional stages to maximize 

wildlife habitat and diversity.

Riparian dependent 

American peregrine 

falcon, bald eagle, 

migratory birds, 

Arizona toad, Arizona 

treefrog, northern 

Lowering of the 

water table, 

dense thickets 

of shrubby 

vegetation, 

structural 

heterogeneity, 

Dewatering or 

channelization,

invasion by 

nonnative 

species, 

treatments of 

exotic plant 

Wetland/Cienega DC: Wetlands conditions are consistent with their flood regime and flood 

potential. Plant and animal species that require wetland habitats have healthy populations 

within the natural constraints of the particular wetland community. Wetlands infiltrate water, 

recycle nutrients, resist erosion, and function properly.

OBJ: Restore native vegetation and natural water flow patterns on at least 6 acres of wetlands 

within 5 years of plan approval.

Cottonwood Willow Riparian DC: The extent, diversity, and condition of riparian habitat 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 517

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

leopard frog, Great 

Basin spadefoot, 

western red bat

full complement 

of tree age size 

classes, snags, 

streamside 

vegetation, 

species 

(mechanical 

removals, 

herbicides), 

livestock/

grazing, wildfire

contribute to ecological sustainability. Dense shrubbery and high levels of vegetative 

diversity (structural and compositional) and permanent water provide food, cover, and water 

for wildlife, including terrestrial and aquatic invertebrates and vertebrates. Vegetation is 

characterized by willow and other herbaceous understory species. Snag and gallery tree 

components comprise 55 percent mid-aged to mature cottonwood and willow trees, 25

percent younger trees and 20 percent in grass, shrubs, suckers, seedlings, and tree sprouts. 

Vegetation is structurally diverse and provides habitat for high bird species diversity and 

abundance with nesting and foraging opportunities for neotropical migrants birds. Mature 

cottonwood and other trees provide cavities for cavity-dependent wildlife such as 

woodpeckers, sapsuckers and secondary cavity users. Tall trees provide lookouts and 

opportunities for nesting raptors. Water flow regime approximates reference conditions (i.e.,

perennial flows) and flows freely. Sedimentation is minimized. Springtime flooding 

contributes to ecosystem sustainability by optimizing germination conditions for seedlings 

and/or suckering opportunities from the parent plant. When nonnative vegetation is present, 

the spatial and structural composition contributes to overall faunal diversity. Grazing from 

domestic ungulates is minimal or absent. Soil is free from compaction and includes sand and 

gravelly reaches and provides suitable germination sites for desirable plant species. Sandy 

and vegetated terraces provide habitat for reptiles and amphibians. Shallow exposed 

watersides provide drinking and foraging opportunities for wildlife. Fire is limited or absent 

in this system.

Soils and Watersheds GD: Seeds and plants used for revegetation should originate from the 

same PNVT and general ecoregion (i.e., southern Colorado Plateau) as the project area. 

Natural Waters DC: The necessary physical and biological components, including cover, 

forage, water, microclimate, and nesting/breeding habitat, provide habitat for a diverse 

community of plant and wildlife species. Riparian-dependent plant and animal species are 

self-sustaining and occur in natural patterns of abundance and distribution. Native 

macroinvertebrates are appropriately abundant and diverse. Unwanted nonnative species do 

not exert a detectable impact on aquatic and wetland ecosystems. Springs, streams and ponds 

have appropriate plant cover to protect banks and shorelines from excessive erosion.

Non-Native Invasive Species GD: Use of pesticides, herbicides, and biocontrol agents 

should minimize impacts on non-target flora and fauna.

Livestock Grazing GD: Livestock use in and around wetlands should be evaluated on an 

allotment-specific basis. Mitigation measures such as deferment and fencing (full or partial) 

should be implemented as needed to minimize potential livestock effects.

Water dependent Lowering or 

depletion of the 

Wetland 

drainage, spring 

Wetland/Cienega DC: Wetlands conditions are consistent with their flood regime and flood 

potential. Plant and animal species that require wetland habitats have healthy populations 
518 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

(wetlands, 

seeps/springs, waters)

American peregrine 

falcon, bald eagle, 

migratory birds, 

spikedace, Apache 

trout, loach minnow, 

Arizona toad, Arizona 

treefrog, northern 

leopard frog, Great 

Basin spadefoot, 

Kaibab fairy shrimp, 

Nevada point-head 

grasshopper, 

Persephone’s darner, 

hoary skimmer, fourspotted skippering, 

Nokomis fritillary, 

Nokomis fritillary ssp. 

nokomis, pale 

Townsend’s big-eared 

bat, spotted bat, greater 

western mastiff bat, 

Allen’s lappet-browed 

bat, western red bat, 

southwestern myotis, 

water table, 

edge vegetation, 

connectivity/

stopover habitat 

for migrating 

birds.

capping, flood 

scouring, 

overgrazing, 

trampling.

within the natural constraints of the particular wetland community. Wetlands infiltrate water, 

recycle nutrients, resist erosion, and function properly.

OBJ: Restore native vegetation and natural water flow patterns on at least 6 acres of wetlands 

within 5 years of plan approval.

Watershed DC: Vegetation conditions within watersheds contribute to downstream water 

quality and quantity.

Natural Waters DC: Stream channel stability and aquatic habitats retain their inherent 

resilience to disturbances and climate fluctuations. Stream channel morphology reflects 

changes in the hydrological balance, runoff, and sediment supply appropriate to the landscape 

setting. Springs and ponds have the necessary soil, water, and vegetation attributes to be 

healthy and functioning. Water levels, flow patterns, groundwater recharge rates, and 

geochemistry are similar to reference conditions. Within its capability, stream flow and water 

quality is adequate to maintain aquatic habitat and water sources for native and selected 

nonnative wildlife. The necessary physical and biological components, including cover, 

forage, water, microclimate, and nesting/breeding habitat, provide habitat for a diverse 

community of plant and wildlife species. Riparian-dependent plant and animal species are 

self-sustaining and occur in natural patterns of abundance and distribution. Within its 

capability, streamflow and water quality are adequate to maintain aquatic habitat and water 

sources for native and desired nonnative species. Native macroinvertebrates are appropriately 

abundant and diverse. Unwanted nonnative species do not exert a detectable impact on 

aquatic and wetland ecosystems. Native amphibians are free from or minimally impacted by 

nonnative predation and diseases. Springs, streams and ponds have appropriate plant cover to 

protect banks and shorelines from excessive erosion. Hydrophytes and emergent vegetation 

exist in patterns of natural abundance in wetlands and springs in levels that reflect climatic 

conditions. Overhanging vegetation and floating plants such as water lilies exist where they 

naturally occur. Where springs or other natural waters have been modified for livestock 

and/or human consumption, developments are operational. 

OBJ: Protect and/or restore at least 10 individual springs within 5 years of plan approval. 

GD: Access to natural waters should be restricted to designated trails and points of entry to 

mediate erosion and prevent trampling and inadvertent introduction of nonnative and 

undesirable biota and disease. Fences constructed around natural waters should allow bats and 

other desirable wildlife to pass through unharmed. Diversions of water sources that recharge 

wetlands should be assessed and appropriate actions should be identified to mitigate or 

minimize effects. Spring source areas should be preferentially protected. Water rights for 

springs should be secured where there are no existing water rights or claims. The impacts of 

management activities on springs, streams, and wetlands should be evaluated and minimized.

Constructed Waters DC: Drinkers have escape ramps that provide safe access and egress 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 519

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

for wildlife. Constructed waters do not contribute to the spread of chytrid fungus or unwanted 

nonnative species, Reservoirs maintain high quality for parameters such as temperature, 

dissolved oxygen, and water levels within the seasonal range of variable conditions. Desirable 

nonnative fish species provide recreational fishing opportunities in reservoirs and lakes 

consistent with the needs of native species. 

GD: Scholz Lake should not be managed for recreational sport fishing. In riparian aquatic 

areas, current protocols for preventing the spread of chytrid fungus should be followed. If 

new drinkers are necessary, they should be constructed in areas that reduce ungulate impact to 

sensitive vegetation or soils such as riparian, aspen, and wet meadow areas. Drinkers should 

be maintained to provide water during times of scarcity. 

Livestock Grazing GD: Livestock use in and around wetlands should be evaluated on an 

allotment-specific basis. Mitigation measures such as deferment and fencing (full or partial) 

should be implemented as needed to minimize potential livestock effects.

Wilderness DC: A reproducing population of Apache trout is maintained in North Canyon 

Creek.

Frank’s Lake Geologic-Botanic Area GD: Livestock should be excluded from the Frank’s 

Lake Geologic Botanic Area.

Species affected by 

sediments into natural 

waters

Spikedace, Apache 

trout, loach minnow, 

Arizona toad, Arizona 

treefrog, northern 

leopard frog, Kaibab 

fairy shrimp

Loss of habitat 

function, 

increase in 

sediments 

above 

background 

level. 

Erosion, 

unmanaged 

grazing.

Pinyon-Juniper Communities DC: Plant litter (leaves, needles, etc.) and understory plant 

cover contributes to soil stabilization, prevents erosion, promotes nutrient cycling, improves 

water retention, and provides the microclimate conditions necessary for pinyon seed 

germination.

Ponderosa Pine DC: Fine: Organic ground cover and herbaceous vegetation provide 

protection for soil, and moisture infiltration, and contribute to plant and animal diversity and 

to ecosystem function. Herbaceous vegetation reflects the site potential.

Frequent Fire Mixed Conifer DC: Fine: Organic ground cover and herbaceous vegetation 

provide protection for soil, and moisture infiltration, and contribute to plant and animal 

diversity and to ecosystem function. Herbaceous vegetation reflects the site potential.

Mesic Mixed Conifer/Spruce-Fir DC: Fine: Organic ground cover and herbaceous 

vegetation provide protection of soil, moisture infiltration, and contribute to plant and animal 

diversity and to ecosystem function. Understory vegetation reflects the site potential.

Following Large-scale Disturbances GD: Recovery and restoration projects design should 

seek to establish a trajectory toward desired conditions for the affected vegetation type. 

Erosion control should be implemented to protect significant resource values and 

infrastructure such as stream channels, roads, structures, and archeological or historic sites. 

Practices that restore nutrient cycling and stabilize soils (revegetation, mulching, lop and 

scatter, etc.) should be implemented.
520 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Montane/Subalpine Grasslands DC: Montane and subalpine meadow vegetation has high 

soil productivity and biological diversity. Vegetation and litter is sufficient to maintain and 

improve water infiltration, nutrient cycling, and soil productivity. 

Wetland/Cienega DC: Wetlands provide habitat consistent with their flood regime and flood 

potential. Wetlands infiltrate water, recycle nutrients, resist erosion, and function properly.

Soil DC: Vegetative ground cover is well-distributed across the soil surface to promote 

nutrient cycling and water infiltration. Accelerated soil loss is minimal, especially on 

sensitive or highly erodible sites. 

Soils can readily absorb, store, and transmit water vertically and horizontally, accept, hold, 

release nutrients, and resist erosion. Infiltration rates are good in TES soil units that are 

described as well drained and moderately well-drained.

Watershed DC: Vegetation conditions within watersheds contribute to downstream water 

quality and quantity. Surface runoff, sheet, rill, gully erosion and subsequent sedimentation 

into connecting waters downstream is minimal. Flooding maintains normal stream 

characteristics (e.g., water transport, sediment, woody material) and dimensions (e.g., 

bankfull width, depth, slope, sinuosity). Vertical down cutting and embeddedness are absent 

in drainages. Floodplains are functioning and lessen the impacts of floods on human safety, 

health, and welfare. The fuels composition within watersheds does not put the watersheds at 

risk for uncharacteristic disturbance. Water quality meets or exceeds State of Arizona or 

Environmental Protection Agency water quality standards for designated uses. Water quality 

meets critical needs of aquatic species.

Soils and Watershed GD: Projects should include design features to protect and improve 

watershed condition. In disturbed areas, erosion control measures should be implemented to 

improve soil conditions.

Natural Waters DC: Stream channel stability and aquatic habitats retain their inherent 

resilience disturbances and climate fluctuations. Stream channel morphology reflects changes 

in the hydrological balance, runoff and sediment supply appropriate to the landscape setting.

GD: Access to natural waters should be restricted to designated trails and points of entry to 

mediate erosion and prevent trampling and inadvertent introduction of nonnative and 

undesirable biota and disease.

Wildland Fire Management DC: Wildland fire maintains and enhances resources and, as 

nearly as possible, is allowed to function in its natural ecological role. Regular fire entry 

protects social, economic, and ecological values at risk from high-severity disturbance effects. 

Wildland fires burn within the range of intensity and frequency of the historic fire regime of 

the vegetation community. Uncharacteristic high-severity fires rarely occur, and do not burn 

at the landscape scale.

Transportation System OBJ: Obliterate or naturalize 20 miles of non-system roads 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 521

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

(unauthorized, unneeded, and decommissioned) within 10 years of plan approval.

GD: Roads should be decommissioned when no longer needed.

Mineral and Mining Activities GD: Adverse surface impacts should be minimized through 

the appropriate administration of mining and mineral laws and regulations. Soil disturbance 

should be kept to a minimum. Restoration and reclamation of surface disturbance associated 

with mining operations should be implemented to achieve 70 percent of ground cover (as 

compared to nearby undisturbed areas) with permanent native vegetation within 3 growing 

seasons.

Aspen dependent

Red-faced warbler, 

evening grosbeak, 

olive-sided flycatcher, 

dusky grouse, 

MacGillivray’s 

warbler, red-naped 

sapsucker, orangecrowned warbler, 

Kaibab least chipmunk, 

Kaibab northern pocket 

gopher

Regenerating of 

stands, diversity 

in age within 

stands, conifer 

encroachment.

Ungulate

grazing. 

Frequent Fire Mixed Conifer DC: Landscape: Where they occur naturally, groups of aspen 

and all structural stages of oak are present.

Mesic Mixed Conifer/Spruce-Fir DC: Mid-scale: Aspen is occasionally present in large 

patches.

Aspen (General) DC: Aspen stands are characterized by disturbances which may include 

fire, mechanical thinning, insects, pathogens and abiotic factors. Collectively these agents of 

change promote healthy tree regeneration, decadence, and nutrient cycling. These processes 

further contribute to high-quality wildlife habitat and biodiversity. Aspen occurs in natural 

patterns of abundance and distribution at levels similar to or greater than those at time of plan 

approval. Aspen is successfully regenerating and recruiting into older and larger size classes. 

Size classes have a natural distribution, with the greatest number of stems in the smallest 

classes. Fire intervals are similar to reference conditions and maintain aspen. Understory 

vegetation consists of shrubby or herbaceous species, providing forage and cover for wildlife 

and habitat for invertebrates such as pollinators. 

Aspen within Ponderosa Pine and Frequent Fire Mixed Conifer Forest DC: In ponderosa 

pine and frequent fire mixed conifer vegetation types, the size, age and spatial extent of aspen 

stands reflect reference conditions. Coniferous species comprise less than 10 percent of the 

overstory on the Tusayan and Williams Ranger Districts. Isolated aspen stands, diverse in 

vegetation structure and composition, provide wildlife refugia and diversity in an otherwise 

conifer-dominated landscape.

Aspen within Mesic Mixed Conifer /Spruce-Fir Forest DC: Downed aspen and woody 

debris are scattered across the landscape and provide habitat for a variety of wildlife species 

(e.g., small mammals, reptiles, amphibians, and birds) while contributing to efficient nutrient 

cycling. Aspen occurs as a shifting mosaic across its range with new aspen clones 

establishing over time. The size, age, and spatial extent of aspen stands reflect large-scale 

disturbance patterns and processes.

Aspen on Williams and Tusayan Ranger Districts OBJ: Fence 200 acres of aspen within 

10 years of plan approval to exclude ungulates. Reduce conifer encroachment on 800 acres of 
522 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

aspen within 10 years of plan approval.

GD: Small patch clear-cuts (less than 5 acres in size), conifer removal, and wildland fire 

should be used to stimulate aspen sprouting in areas that have or previously had aspen. Aspen 

trees 10 inches or greater d.b.h. (both live and dead) should be protected during project 

activities, except where they may pose a risk to fences or regeneration efforts. Fences should 

be regularly inspected and maintained while aspen recovers. Fences should be removed when 

no longer needed.

Constructed Water DC: Artificial waters do not concentrate ungulate use in aspen stands. 

GD: If new drinkers are necessary, they should be constructed in areas that reduce ungulate 

impact to sensitive vegetation or soils such as riparian, aspen, and wet meadow areas.

Livestock Grazing GD: Livestock use in aspen areas should be authorized at levels that are 

consistent with the desired conditions for aspen regeneration and establishment.

Rock/cave and other 

abiotic dependent

Golden eagle, 

American peregrine 

falcon, California 

condor, Arizona black 

rattlesnake, western 

skink, Utah Mountain 

kingsnake, milksnake, 

Great Basin spadefoot, 

pale Townsend’s bigeared bat, House Rock 

Valley chisel-toothed 

kangaroo rat, spotted 

bat, greater western 

mastiff bat, Allen’s 

lappet-browed bat, 

southwestern myotis, 

big free-tailed bat, 

dwarf shrew, 

Rocks (canyons, 

caves, mines, 

ledges, talus 

slopes, and 

cliffs), 

manmade 

habitat 

(buildings, 

bridges).

Rock collection, 

cliff blasting, 

recreational rock 

climbing/

caving, mining/

mineral 

activities. 

Caves, Karst, and Mines DC: Caves maintain moisture and temperature levels consistent 

with reference conditions. Archeological, geological, and biological features of caves and 

mines are not disturbed by visitors. Caves, karst features, and abandoned mines provide 

quality habitat for bat species. Disease is within natural levels. Mine closures do not 

compromise habitat for species that require specialized niches for roosting and overwintering 

(e.g., bats).

GD: Project design should include protections for subsurface geologic features to minimize 

disruptions to cave microbiology and other aspects of cave ecology. When entering caves or 

mines, decontamination procedures should be followed for preventing the spread of whitenose syndrome (Geomyces destructans). Caves containing endemic species should be 

managed for the protection of that species over other uses. Before closing caves or mines, 

they should be inspected to determine if bats are using these areas. If roost sites are present, 

closure structures should allow bats to continue to use the cave or mine, such as wildlife 

friendly bat gates that meet the most current recommendations.

Cliffs and Rocky Features DC: Cliff ledges provide cover and nesting habitat for wildlife 

such as the American peregrine falcon, California condor, snakes, bats, birds, and small 

mammals. Rocks and rocky areas promote seedling germination and maintain cover for 

vertebrate and invertebrate species. Rock climbing and related recreational activities do not 

disrupt the life processes of rare or threatened species or diminish the function of specialized 

vegetation, such as mosses, lichens, and fleabanes. Rockslides and talus slopes are natural, 

undisturbed features that provide habitat for wildlife such as lizards, snakes, and land snails.

GD: Activities involving heavy machinery or blasting should minimize impacts to habitat 

associated with rocky features and cliffs. Near known active raptor nest sites, temporary 

closures and use restrictions should be implemented for rock climbing and other potentially 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 523

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

disruptive activities. Talus slopes should be surveyed for endemic species prior to authorizing 

quarrying, rock hounding, or construction activities that may alter them.

Transportation GD: Surveys should be conducted to assess wildlife use (bats, birds, etc.) 

and intensity before demolishing and/or modifying structures such as old bridges. If surveys 

determine that wildlife actively use the structures, project design should include efforts to 

minimize impacts.

Developed Recreation Sites GD: Surveys should be conducted to assess bat activity and 

intensity of use before demolishing and/or modifying structures such as old buildings. If 

surveys determine that bats are actively roosting in such structures and no alternate bat roost 

sites exists in the immediate vicinity, project design should include efforts to minimize 

impacts and to provide for alternate roost sites such as bat boxes where feasible.

Species needing 

connected 

habitat/movement 

corridors

Pronghorn, Gunnison’s 

prairie dog, elk, mule

deer, mountain lion

Large 

contiguous 

blocks of 

habitat.

Habitat 

fragmentation.

Pinyon-Juniper Communities DC: Pinyon-juniper communities occur as a shifting mosaic 

across the landscape interspersed with openings. The configuration of vegetation and 

openings provides foraging and browsing opportunities for wildlife, and enough sighting 

distance and hiding cover for pronghorn to escape predators.

GD: Pinyon-juniper communities should maintain tree densities that maximize herbaceous 

plant growth and wildlife species diversity typical for their respective community subtype. 

Project design for vegetation management activities should prioritize treatment areas along 

known wildlife, in the wildland-urban interface, and in historic openings. Restoration 

treatments in pinyon-juniper should be rotated over time and various successional stages to 

maximize wildlife habitat and diversity.

Restoring Grasslands OBJ: Reduce tree density to less than to 10 percent on 5,000 to 

10,000 acres of historic grasslands annually. Modify fences and install crossings to facilitate 

pronghorn movement on 50 miles of fence within 10 years of plan approval.

GD: Pronghorn fence crossings should be installed along known movement corridors.

Wildlife DC: Native wildlife species are distributed throughout their potential natural range. 

Desirable nonnative wildlife are present and in balance with healthy, functioning ecosystems.

Habitat is available at the appropriate spatial, temporal, compositional, and structural levels 

such that it provides adequate opportunity for breeding, feeding, nesting, and carrying out 

other critical life cycle needs for a variety of vertebrate and invertebrate species.

Interconnected habitats allow for movement of wide-ranging species and promote natural 

predator-prey relationships, particularly for strongly interactive species (e.g., mountain lions). 

Habitat configuration and availability allows wildlife populations to adjust their movements 

(e.g., seasonal migration, foraging etc.) in response to climate change and promote genetic 

flow between wildlife populations.

Livestock Grazing DC: Allotment fencing allows for passage of animals prone to movement 
524 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

restrictions such as pronghorn. 

GD: New construction and reconstruction of fences should have a barbless bottom wire and 

be at least 18 inches high.

Transportation and Forest Access DC: Roads allow for safe and healthy wildlife movement 

in areas of human development. Vehicular collisions with animals are rare. 

GD: Roads should be decommissioned when no longer needed.

Lands DC: NFS lands exist in a pattern that promotes efficient management, which consist 

of large contiguous areas that provide efficient and effective resource management and 

wildlife connectivity within and across NFS lands.

Wilderness DC: Wilderness provides opportunities for nonmotorized and non-mechanized 

primitive and unconfined recreation and contiguous wildlife habitat.

Recommended Wilderness DC: The recommended wilderness areas provides nonmotorized and non-mechanized opportunities for primitive and unconfined recreation and 

contiguous wildlife habitat.

Rare endemics/

restricted 

distributions

Arizona black 

rattlesnake, Utah 

Mountain kingsnake, 

Persephone’s darner, 

Kaibab variable tiger 

beetle, Kaibab Indra 

swallowtail, House 

Rock Valley chiseltoothed kangaroo rat, 

Kaibab least chipmunk, 

Kaibab tree squirrel, 

Kaibab northern pocket 

gopher

Rare habitat and 

the species 

itself. Direct 

loss of 

vegetation, 

change in 

species 

composition, 

and microsite 

conditions.

Collecting, 

trampling, 

herbicide 

treatments, 

misidentification 

and accidental 

eradication, pile 

burning, 

unmanaged 

livestock grazing 

and excessive 

wildlife 

herbivory

Wildlife GD: Project activities and special uses should be designed and implemented to 

maintain refugia and critical life cycle needs of wildlife, particularly raptors.

Rare and Narrow Endemics DC: Habitat and refugia are present for narrow endemics or 

species with restricted distributions and/or declining populations. Location and conditions of 

rare and narrow endemic species are known.

GD: Project design should incorporate protective measures to provide for rare and narrow 

endemic species where they are likely to occur. 

Caves, Karst, and Mine GD: Caves containing endemic species should be managed for the 

protection of those species over other uses.

Risk of Large-scale 

Wildfire 

All species

Loss of habitat 

components on 

a large scale. 

Fire behaving 

unnaturally 

within the 

system.

Pinyon-Juniper Communities DC: The composition, structure, and function of vegetative 

conditions are resilient to the frequency, extent and severity of disturbances (including 

insects, diseases, and fire) and climate variability. Fires are typically low severity with a 0- to 

35-year return interval (Fire Regime I).

Pinyon-Juniper Grasslands DC: The composition, structure, and function of vegetative 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 525

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

conditions are resilient to the frequency, extent and severity of disturbances (including 

insects, diseases, and fire) and climate variability. Fires are typically low severity with a 0- to 

35-year return interval (Fire Regime I).

Pinyon-Juniper Shrub DC: The composition, structure, and function of vegetation 

conditions are resilient to the frequency, extent and severity of disturbances including insects, 

diseases, fire, and climate variability. Fires are mixed to high severity and have fire return 

interval of 35 to more than 200 years (Fire Regimes III, with occurrences of stand replacing 

fire at longer intervals).

Pinyon-Juniper (Persistent) Woodlands DC: Disturbances rarely affect the composition, 

structure, and function. Fire disturbance is infrequent and variable due to lack of continuous 

ground cover.

Ponderosa Pine Forest DC: Fine-scale: Fires generally burn as surface fires, but single-tree 

torching and isolated group torching is not uncommon. Mid-scale: Disturbances sustain the 

overall variation in age and structural distribution. Fires primarily burn on the forest floor and 

typically do not spread between tree groups as crown fire. Landscape: The landscape is a 

functioning ecosystem that contains all its components, processes, and conditions associated 

with endemic levels of disturbances (e.g., fire, dwarf mistletoe, insects, diseases, lightning, 

drought, and wind). Grasses and needle cast provide the fine flashy fuels needed to maintain 

the natural fire regime. Fire and other disturbances are sufficient to maintain desired overall 

tree density, structure, species composition, coarse woody debris loads, and nutrient cycling. 

The risk of uncharacteristic high intensity fire and associated loss of key ecosystem 

components is low. Frequent, low-severity fires (Fire Regime I) occur across the entire 

landscape with a return interval of 0 to 35 years. 

OBJ: Mechanically thin 11,000 to 19,000 acres annually. Treat an average of 13,000 to 

55,000 acres annually, using a combination of prescribed fire and naturally ignited wildfires.

Frequent Fire Mixed Conifer DC: Fine-scale: Fires generally burn as surface fires, but 

single tree torching and isolated group torching occasionally occurs. Mid-scale: Fires 

primarily burn on the forest floor and typically do not spread between tree groups as crown 

fire. Landscape: The composition, structure, and function of vegetative conditions are 

resilient to the frequency, extent, severity of disturbances, and to climate variability. The 

landscape is a functioning ecosystem that contains all its components, processes, and 

conditions that result from endemic levels of disturbances (e.g., fire, insects, diseases, and 

wind). Grasses and needle cast provide the fine flashy fuels needed to maintain the natural 

fire regime. Fire and other disturbances are sufficient to maintain desired overall tree density, 

structure, species composition, coarse woody debris, and nutrient cycling. Frequent, low 

severity fires (Fire Regime I) occur across the entire landscape with a return interval of 0 to 

35 years. 
526 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

OBJ: Burn an average of 1,000 to 13,000 acres annually, using prescribed fire and/or 

naturally ignited wildfires. Mechanically thin 1,200 to 2,100 acres annually.

Mesic Mixed Conifer/Spruce-Fir DC: Fine-scale: Due to the presence of ladder fuels, fires 

usually burn either with low intensity, smoldering combustion, or transition rapidly in the 

canopy as passive or active crown fire. Mid-scale: During moister conditions, fires exhibit 

smoldering low-intensity surface fires with single-tree and isolated group torching. Under 

drier conditions, fires exhibit passive to active crown fire behavior with conifer tree mortality 

up to 100 percent across mid-scale patches (100 to 1,000 acres). High-severity fires generally 

do not result in areas of mortality exceeding 1,000 acres. Other smaller disturbances occur 

more frequently. Fire and other disturbances maintain overall desired tree density, structure, 

species composition, coarse woody debris, and nutrient cycling. Fire severity is mixed or 

high, with a fire return interval of 35 to over 200 years (Fire Regimes III, IV, and V). 

Landscape: The forest landscape is a functioning ecosystem that contains all components, 

processes, and conditions that result from endemic levels of disturbances (e.g., insects, 

diseases, wind, snow, and fire), including snags, downed logs, and old trees. The 

composition, structure, and function of vegetative conditions are resilient to the frequency, 

extent and severity of disturbances and climate variability. Mixed-severity fire (Fire Regime 

III) is characteristic at the lower elevations of this type. High-severity fires (Fire Regime IV 

and V) are more common at the higher elevations.

Aspen (General) DC: Fire intervals are similar to reference conditions and maintain aspen.

Vegetation Management in all Forested Communities GD: The location and layout of 

vegetation management activities should effectively disconnect large expanses of continuous 

predicted active crown fire. Vegetation management prescriptions should provide for 

sufficient canopy breaks to limit crown fire spread between groups, allow for the 

redevelopment and maintenance of a robust understory, and mimic the spatial arrangement of 

the references conditions.

Large-scale Disturbance OBJ: To reestablish ponderosa pine in areas with inadequate seed 

source and reduce the time to achieve the desired forest structure: Plant 300 to 700 acres 

annually. 

GD: Recovery and restoration project design should seek to establish a trajectory toward the 

desired conditions for the affected vegetation type. Where conifer seed sources are lost or 

poorly distributed due to high-intensity fire, artificial regeneration (planting, etc.) should be 

implemented to promote the desired forest structure and accelerate the recovery of habitat 

conditions for native wildlife species. Some snags and coarse woody debris should be 

retained to provide for wildlife habitat, soil stabilization, and other resource benefits. Some 

clumps of large (18 inches d.b.h.) standing dead trees should be retained. Project design 

should incorporate measures to protect regeneration and reforestation investments.
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 527

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Sagebrush Shrublands DC: Characteristic disturbances play a role in the function of the 

ecosystem.

GD: Management activities should be designed to mimic the historic disturbance. 

Grasslands DC: Disturbance processes are similar to reference conditions and play a primary 

role in the function of the ecosystem.

Desert Communities DC: Density of juniper and other shrubby species is maintained at 

levels which promote natural fire regimes and long fire return intervals. Fire occurrence is 

low and infrequent. 

GD: Fire should not be used as a vegetation management tool in Desert Communities.

Gambel Oak Shrublands DC: Low intensity fire occurs regularly with intervals of greater 

than 25 years.

Cottonwood-Willow Riparian Forest DC: Fire is limited or absent in this system.

Watersheds DC: The fuels composition within watersheds does not put the watersheds at 

risk for uncharacteristic disturbance.

Livestock Grazing GD: As grazing permits are waived back to the forest, they should be 

evaluated for conversion to forage reserves to improve flexibility for restoring fire-adapted 

ecosystems and range management in times of drought.

Forestry and Forest Products DC: A sustainable supply of wood is available to support a 

wood harvesting and utilization industry of a size and diversity that can effectively and 

efficiently restore and maintain the desired conditions for ponderosa pine and frequent fire 

mixed conifer communities.

Wildland Fire Management DC: Wildland fire maintains, and enhances resources and, as 

nearly as possible, is allowed to function in its natural ecological role. Regular fire entry

protects social, economic, and ecological values at risk from high-severity disturbance effects. 

Wildland fires burn within the range of intensity and frequency of the historic fire regime of 

the vegetation community. Uncharacteristic high-severity fires rarely occur, and do not burn 

at the landscape scale. Wildland fire is understood, both internally and by the public, as a 

necessary natural disturbance process integral to the sustainability of the forest’s fire-adapted 

vegetation communities.

ST: Managers will use a decision support process to guide and document wildfire 

management decisions.

GD: Decision documents for wildland fires that progress past initial attack should include 

interdisciplinary input to assess site specific values at risk and develop project or incident 

objectives and courses of action to enhance or protect those values. Decision documents for 

wildland fires should include objectives to minimize fire-created openings to those within the 

reference range of variability for the vegetation community. Associated courses of action to 

address those objectives should also be developed. Decision documents for wildland fires 
528 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

should address wildlife desired conditions for key habitat features that provide structural 

diversity such as snags, large oaks, and oak thickets. Associated courses of action or 

management practices to address those objectives should also be developed. If current or 

anticipated fire behavior and fire effects exceed the desired fire behavior and effects, 

protection objectives should be developed, or a more conservative prescription window 

produced. Strategies and tactics to mitigate those effects should be implemented on active 

wildland fires.

Wilderness DC: Natural processes are maintained within the wildernesses. Fires function in 

their natural ecological role.

GD: Wildfires should be suppressed in the desert communities of the Kanab Creek 

Wilderness.

Recommended Wilderness DC: Natural processes are maintained within the wildernesses. 

Fires function in their natural ecological role.

GD: Wildfires should be suppressed in the recommended wilderness areas adjacent to Kanab 

Creek in the desert communities PNVT.

Garland Prairie Management Area DC: Lightning fires are able burn naturally within the 

area.

Bill Williams Mountain Management Area OBJ: Implement a project to improve the 

health and sustainability of forested conditions on and surrounding Bill Williams Mountain 

within 5 years of plan approval.

Invasive Species 

Interactions, e.g., but 

not limited to noxious 

weeds, crayfish and 

bullfrogs

Sage sparrow, golden 

eagle, western 

burrowing owl, 

ferruginous hawk, sage 

thrasher, savannah 

sparrow, green-tailed 

towhee, Apache trout, 

Arizona toad, Arizona 

black rattlesnake, 

Arizona treefrog, 

Competition for 

resources (food, 

space, water) 

and/or 

hybridizations 

which can lead 

to direct 

mortality and 

decreases in 

populations 

within the 

planning area, 

loss of native 

species and 

changes in 

vegetation 

Introduction of 

nonnative 

species; loss of 

habitat 

component.

Grasslands DC: Vegetation is dominated by herbaceous plants composed of a mix of native 

grasses and forbs.

Montane/Subalpine Grasslands DC: Native species occur in natural patterns of abundance, 

composition, and distribution. Vegetation is healthy and at least stable.

Gambel Oak Shrublands DC: The system is dominated by native tall shrubs and hardwood 

trees. Non-native species are absent or comprise less than 1 percent of the total cover.

Cottonwood-Willow Riparian Forest DC: When nonnative vegetation is present, the spatial 

and structural composition contributes to overall faunal diversity.

Natural Waters DC: Unwanted nonnative species do not exert a detectable impact on 

aquatic and wetland ecosystems. Native amphibians are free from or minimally impacted by 

nonnative predation and diseases.

GD: Access to natural waters should be restricted to designated trails and points of entry to 

mediate erosion prevent trampling and inadvertent introduction of nonnative and undesirable 

biota and disease.

Constructed Waters DC: Constructed waters do not contribute to the spread of chytrid 

fungus or unwanted nonnative species.
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 529

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

northern leopard frog, 

Great Basin spadefoot, 

pronghorn, Navajo 

Mogollon vole

structure. Nonnative Invasive Species DC: Invasive species are contained and/or controlled so that 

they do not disrupt the structure or function of ecosystems. 

GD: All ground-disturbing projects should assess the risk of noxious weed invasion and 

incorporate measures to minimize the potential for the spread of noxious and invasive species. 

New populations are detected early, monitored, and treated as soon as possible. Treatment 

approaches should use integrated pest management (IPM) practices to treat noxious and 

nonnative invasive species. IPM includes manual, biological, mechanical, and 

herbicide/pesticide treatments. Use of pesticides, herbicides, and biocontrol agents should 

minimize impacts on non-target flora and fauna. 

Wildland Fire Management GD: Decision documents for managing fire should evaluate the 

risk of cheatgrass invasion. When there is a moderate to high risk of cheatgrass invasion (e.g., 

lower elevation areas), mitigation measures should be implemented and/or fire should be 

excluded if adequate treatments are not available or if they are cost prohibitive. 

Wilderness DC: Wilderness areas have minimal to no nonnative, invasive species.

GD: Wildfires should be suppressed in the desert communities of the Kanab Creek 

Wilderness. Nonnative, invasive species should be treated within wilderness in order allow 

natural processes to predominate.

Recommended Wilderness DC: Recommended wilderness areas have few to no nonnative, 

invasive species.

GD: Wildfires should be suppressed in the recommended wilderness areas adjacent to Kanab 

Creek in the desert communities vegetation type. Nonnative, invasive species should be 

treated within recommended wilderness areas in order allow natural processes to 

predominate.

Pediocactus Conservation Area GD: Nonnative invasive weeds should be regularly 

monitored and promptly treated

Poisoning/Pesticide 

Use

Golden eagle, 

California condor, bald 

eagle, pale Townsend’s 

big-eared bat, 

Gunnison’s prairie dog, 

Allen’s lappet-browed 

bat, big free-tailed bat

Unintentional 

poisoning of 

species or 

misuse of 

herbicide or 

pesticide.

Nontarget 

species 

poisoning

Invasive Species GD: Treatment approaches should use integrated pest management (IPM) 

practices to treat noxious and nonnative invasive species. IPM includes manual, biological, 

mechanical, and herbicide/pesticide treatments. Pesticides should be properly labeled and 

stored as per the manufacturer’s recommendations.
530 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Disease 

Arizona toad, Arizona 

treefrog, northern 

leopard frog, pale 

Townsend’s big-eared 

bat, Gunnison’s prairie 

dog, spotted bat, 

greater western mastiff 

bat, Allen’s lappetbrowed bat, 

southwestern myotis, 

big free-tailed bat, 

desert bighorn sheep

Human 

activities that 

result in the 

spread of 

disease through 

infected soil and 

water from one 

occupied site to 

another can kill 

wildlife; 

activities can 

include 

recreation, 

research, and 

fire and grazing 

management.

Loss of 

populations or 

decline in habitat 

effeteness

Desert Communities DC: Native ungulates are free from disease. 

Natural Waters DC: Native amphibians are free from or minimally impacted by nonnative 

predation and diseases.

GD: Access to natural waters should be restricted to designated trails and points of entry to 

mediate erosion, prevent trampling, and prevent inadvertent introduction of nonnative and 

undesirable biota and disease. Activities in and around waters should use decontamination 

procedures to prevent the spread of chytrid fungus

Constructed Waters DC: Constructed waters do not contribute to the spread of chytrid 

fungus or unwanted nonnative species.

GD: Activities in and around waters should use decontamination procedures to prevent the 

spread of chytrid fungus.

Caves, Karst, and Mines DC: Disease is within natural levels.

GD: When entering caves or mines, decontamination procedures should be followed for 

preventing the spread of white-nose syndrome (Geomyces destructans).

Livestock Grazing GD: Grazing of domestic sheep and goats should not be authorized on 

the Tusayan and North Kaibab Ranger Districts due to the proximity of bighorn sheep in 

Grand Canyon and Kanab Creek to prevent the spread of disease between domestic and wild 

populations.

Development 

(facilities, roads, 

fences)

Golden eagle, western 

burrowing owl, 

ferruginous hawk, 

California condor, bald 

eagle, milksnake, 

pronghorn, Gunnison’s 

prairie dog, bats, 

raptors

Human 

structures such 

as fences, 

buildings, and 

bridges, 

electrical power 

lines, 

demolition of 

existing 

structures.

Potential 

removal of 

habitat 

components, 

creating barrier 

to movement.

Restoring Grasslands OBJ: Modify fences and/or install crossings to facilitate pronghorn 

movement on 50 miles of fence within 10 years plan approval.

GD: Pronghorn fence crossings should be installed along known movement corridors.

Natural Waters DC: Where springs or other natural waters have been modified for livestock 

and/or human consumption, developments are operational.

GD: Fences constructed around natural waters should allow bats and other desirable wildlife 

to pass through unharmed. Diversions of water sources that recharge wetlands should be 

assessed and appropriate actions should be identified to mitigate or minimize effects. The 

impacts of management activities on springs, streams, and wetlands should be evaluated and 

minimized.

Constructed Waters DC: Drinkers have escape ramps that provide safe access and egress 

for wildlife. Reservoirs maintain high quality for parameters such as temperature, dissolved 

oxygen, and water levels within the seasonal range of variable conditions. Artificial water

sources do not concentrate ungulate use in aspen stands.

GD: If new drinkers are necessary, they should be constructed in areas that reduce ungulate 

impact to sensitive vegetation or soils such as riparian, aspen, and wet meadow areas. 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 531

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Drinkers should be maintained to provide water during times of scarcity.

Recreation and Scenery DC: Opportunities for off-highway vehicle (OHV) riding and 

driving for pleasure are available on the designated system of NFS roads and motorized trails. 

Recreation Front Country DC: Constructed facilities in front country settings provide for 

user comfort and resource protection. The number and size of constructed facilities is 

appropriate for the use and activities that occur at each site. 

GD: Any new motorized trailheads should be located in front country areas, incorporate or 

convert existing roads, protect open space, and protect natural and cultural resources. 

Livestock Grazing DC: Allotment fencing allows for passage of animals prone to movement 

restrictions such as pronghorn.

GD: New construction and reconstruction of fences should have a barbless bottom wire and 

be at least 18 inches high.

Transportation and Forest Access DC: All designated routes open to wheeled motorized 

vehicles are shown on a motor vehicle use map (MVUM) that is readily available to the 

public. Roads allow for safe and healthy wildlife movement in areas of human development. 

Vehicular collisions with animals are rare.

ST: Motor vehicle use off the designated system of roads, trails, and areas is prohibited, 

except as identified on the MVUMs and as authorized by law, permits, and orders in 

connection with resource management and public safety.

GD: Construction of permanent roads or temporary roads in semi-primitive non-motorized 

areas should be avoided unless required by a valid permitted activity. If authorized, roads 

should be constructed and maintained at the lowest maintenance level needed for the intended 

use. Roads should not be located in meadows when they can be located in other areas. Roads 

should be decommissioned when no longer needed. Surveys should be conducted to assess 

bat activity and intensity of use before demolishing and/or modifying structures such as old 

bridges. If surveys determine that wildlife are actively using structures, project design should 

include efforts to minimize impacts.

Energy Transmission and Development DC: Energy transmission and development on the 

forest meets the legal mandates to facilitate the transmission and development of energy 

resources in a manner that minimizes adverse impacts and does not detract from meeting 

other desired conditions applicable to the area. Joint use of rights-of-way is provided to 

concentrate uses to the extent possible. Energy transmission lines are not visible (usually 

underground) across the landscape. Vegetative conditions and land uses within energy rightsof-way facilitate the operation and maintenance of the associated facilities and infrastructure. 

They may differ from the surrounding PNVT desired conditions in that they generally consist 

of low-growing or non-woody vegetation. 

ST: Major utility corridor development is confined to the area identified and mapped in the 
532 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

West-wide Energy Corridor Programmatic EIS.

GD: Environmental disturbance should be minimized by co-locating pipelines, power lines, 

fiber optic lines, and associated infrastructure. Existing energy corridors should be used to 

their capacity with compatible upgraded power lines, before evaluating new routes. When 

compatible with protection of heritage resources, the use of below-ground utilities should be 

optimized in order to avoid potential conflicts with wildlife, scenery, wildfire, and long-term 

vegetative management.

Frank’s Lake Geologic-Botanic Area DC: There is minimal evidence of human 

disturbance.

Developed Recreation Sites GD: Reconstruction and improvements of private sector 

developed sites should be within site capacity allocations. Surveys should be conducted to 

assess bat activity and intensity of use before demolishing and/or modifying structures such 

as old buildings. If surveys determine that bats are actively roosting in such structures and no 

alternate bat roost sites exists in the immediate vicinity, project design should include efforts 

to minimize impacts and to provide for alternate roost sites such as bat boxes where feasible. 

Developed recreation site vegetation management plans should guide thinning and burning 

activities in the campgrounds.

Bill Williams Mountain Management Area GD: The existing term permit for the Elk Ridge 

Ski Area on Bill Williams Mountain should be restricted to the existing established permit 

area. High-use roads within the municipal watershed should be maintained to prevent erosion 

and sedimentation.

Red Butte Management Area GD: The helipad on Red Butte should only be used for 

administrative purposes.

Pediocactus Conservation Area GD: Motorized access should be restricted.

Disturbance to 

wildlife from 

management activities

Goshawk, golden 

eagle, American 

peregrine falcon, 

California condor, 

raptors

Potential 

disturbance to 

species during 

breeding season

Timber harvest, 

recreation 

activities, fuel 

reduction 

activities, road 

building, mineral 

collections

Wildlife DC: Human-wildlife conflicts are minimal.

Wildlife GD: Potentially disturbing project-related activities should be restricted within 

300 yards of active raptor nest sites between April 1 and August 15.

Threatened, Endangered, and Sensitive Species GD: Potentially disturbing project-related 

activities should be minimized in occupied goshawk nest areas during nesting season of 

March 1 through September 30.

Cliffs and Rocky Features GD: Near known active raptor nest sites, temporary closures and 

use restrictions should be implemented for rock climbing and other potentially disruptive 

activities.

Recreation and Scenery GD: Group uses should be concentrated in front country areas. 

Resource impacts should be reduced in front and backcountry by directing camping to 

existing dispersed campsites. 
Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 533

Appendix H. Crosswalk Between Species Habitat 

Risk/Threats and Plan Components

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Transportation Management ST: Motor vehicle use off the designated system of roads, 

trails, and areas is prohibited, except as identified on the MVUMs and as authorized by law, 

permits, and orders in connection with resource management and public safety.

Wilderness Areas DC: Wilderness provides opportunities for nonmotorized and 

nonmechanized primitive and unconfined recreation and contiguous wildlife habitat. Human 

encounters are only with individuals or small parties, are infrequent, and opportunities for 

solitude are common.

ST: Group size in wilderness is limited to 12 people. Competitive events are not permitted in 

wilderness areas. Establishment geo-caches will not be permitted in wilderness areas.

Frank’s Lake Geologic-Botanic Area GD: Camping within the fenced boundary of Frank’s 

Lake should not be permitted.

Recommended Wilderness Areas DC: Wilderness provides opportunities for 

nonmotorized and nonmechanized primitive and unconfined recreation and contiguous 

wildlife habitat. Human encounters are only with individuals or small parties, are infrequent, 

and opportunities for solitude are common.
534 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS

Risk/Threats and Plan ComponentsAppendix H. Crosswalk Between Species Habitat 

Species or Species 

Group

Characteristi

c at risk

Potential 

Management 

Threats

Plan Components Which Address Risks to Species Viability

Providing additional 

protection for 

federally listed 

species, Region 3 

sensitive species, 

migratory birds, or 

raptors not covered in 

the above categories

Loss of habitat 

components. 

Logging, fuel 

management.

Ponderosa Pine DC: Fine-scale: Where historically occurring, there are oak thickets with 

various diameter stems, and low-growing, shrubby oak. These thickets provide forage, 

cover, and habitat for species that depend on them such as small mammals, foliage nesting 

birds, deer, and elk. Gambel oak mast (acorns) provides food for wildlife species. 

Landscape: Where it naturally occurs, Gambel oak is present with all age classes 

represented. It is reproducing and maintaining or expanding its presence within its natural 

range.

Forestry and Forest Projects GD: Timber harvest activities should be carried out in a 

manner consistent with maintaining or making progress toward the desired conditions in this 

plan.

Mineral and Mining Activities DC: Mineral and mining activities meet the legal mandates 

to facilitate the development of minerals on the forest in a manner that minimizes adverse 

impacts to surface and groundwater resources, and that do not prevent meeting other desired 

conditions applicable to the area.

GD: Surface use should be restricted or prohibited in areas with habitat for threatened, 

endangered, and sensitive plant and animal species, and for heritage resources nominated or 

posted to the National Register. Use and occupancy should be restricted yearlong in areas 

supporting populations of threatened, endangered, and sensitive plant species.

Wild and Free Roaming Burro Territory DC: A biologically sound and genetically 

viable burro population is in balance with native wildlife, permitted livestock, and other 

resource values.

GD: Population control measures should be implemented to maintain genetic diversity and 

desired resource conditions in the area.

Kaibab Squirrel National Natural Landmark DC: The Kaibab Squirrel National Natural 

Landmark provides quality ponderosa pine habitat for the Kaibab squirrel.

Bill Williams Mountain Management Area DC: Bill Williams Mountain provides quality 

habitat for Arizona bugbane, Mexican spotted owls, and culturally important plants.
Appendix I. Management

Indicator Species Selection

Introduction

This appendix outlines the Kaibab National Forest (NF) selection process and final candidates for 

management indicator species (MIS). The current planning rule requires that species shall be 

selected as MIS to estimate the effects of the planning alternatives on wildlife populations. MIS 

are selected because their population changes are believed to indicate the effects of management.

They are used to evaluate alternatives by displaying the effects of the alternatives in terms of 

amount and quality of habitat and corresponding predicted changes to population trends. 

It is recommended that an adequate but limited number of species be selected to reflect the major 

management issues and which can serve as effective metrics for monitoring the forest plan. It is 

not necessary to represent every dominant vegetation type, activity, or management issue. The 

Kaibab NF four priority “needs for change” identified during the Comprehensive Evaluation 

Report, guided the selection process: (1) modify stand structure and density toward reference 

conditions and restore historic fire regimes; (2) regenerate aspen to insure long-term healthy 

aspen populations; (3) restore natural waters and wetlands to insure healthy riparian communities;

and (4) restore historic grasslands by reducing tree encroachment and restoring fire. The “needs 

for change” are the metrics that are used to help determine which MIS should be selected. 

In identifying potential MIS, we considered the 1982 Planning Rule Provisions, 20 years of 

subsequent case law, and regional guidance. We also considered input from other forests, 

stakeholders, scientific literature, local research, and wildlife habitat models developed locally for 

the forest plan revision process. A topic discussion focused on species viability and the MIS 

selection process was also held for the public at the Rocky Mountain Research Station in June 

2010. Participants included representatives from the Arizona Game and Fish Department, U.S. 

Fish and Wildlife Service, Sierra Club, Nature Conservancy, Coconino and Apache-Sitgreaves 

National Forests, and faculty from Northern Arizona University. 

Management Indicator Species Selection Factors

The 1982 Rule Provisions include the following concepts:

• Each forest plan alternative must establish objectives that maintain and improve habitat 

for MIS;

• To estimate the effects of planning alternatives on fish and wildlife populations, certain 

vertebrate and/or invertebrate species shall be selected as MIS;

• These species are to be selected because their population changes are believed to indicate 

the effects of management; and

• Planning alternatives must be evaluated in terms of both amount and quality of habitat 

and of animal population trends of MIS.

There is no legal requirement to select an MIS for every activity, vegetation type, or management 

issue. Rather, MIS should be selected for those areas most likely to be affected by management.

There is a legal requirement, however, to establish plan objectives for the maintenance and 

improvement of habitat for the MIS that have been selected.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 535
Appendix I. Management Indicator Species Selection

The 1982 Rule Provisions at section 219.19(a)(1) direct that several categories of species shall be 

considered (though not necessarily included) for MIS status:

• Endangered and threatened plant and animal species identified on State and Federal lists; 

• Species commonly hunted, fished, or trapped; 

• Nongame species of special interest;

• Species with special habitat needs that may be influenced significantly by planned 

management programs (preferred); and

• Additional plant or animal species selected because their population changes are believed 

to indicate the effects of management activities on other species of selected major 

biological communities or on water quality (no scientific basis for this).

The first three categories must be considered. However, frequently they are not the best choice 

because they are either difficult to survey and/or collect population trend data (e.g., sensitive 

species), they are not directly tied to a habitat type (e.g., forest generalists), or may be affected by 

factors other than forest-level management (e.g., habitat effects on the wintering grounds for 

long-distance migrants).

Species That Make Good Management Indicator 

Species

• Common species with high site fidelity and strong associations with particular habitat 

types and or vegetation structural or compositional attributes;

• Species that demonstrate a strong and/or predictable response to management activities 

against a background of environmental variability;

• Species for which population data is readily available or easy to obtain: the subject of 

existing monitoring programs (e.g., some bird species), species monitored by other 

entities (e.g., State wildlife agency census data), etc.; and/or

• Species with stable or increasing population trends. 

Species That Make Poor Management Indicator 

Species 

• Species for which monitoring protocols do not already exist;

• Species that exhibit variable response to forest management;

• Species that are difficult to detect or survey;

• Rare species or species with high variability of interannual abundance;

• Species with declining population trends; and/or

• Species populations that are influenced by factors outside forest management control.

While there are many species worthy of monitoring, species that cannot be effectively and 

accurately monitored at appropriate spatial and temporal scales with available resources, and/or 

that occupy an area not wholly representative of the planning unit, have limited if any utility for 

relating population level changes to habitat management and the subsequent integration of such 

results into the adaptive management feedback loop. These species are not well served as MIS. 

536 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix I. Management Indicator Species Selection

Federally and State listed endangered and threatened plant and animal species that occur in the 

planning area were considered. However, because of their rarity in terms of population numbers 

and/or limited spatial extent on the forest and/or difficulties in collecting statistically sound data 

within appropriate temporal scales, no threatened or endangered species were found to be 

effective in terms of evaluating differences across management alternatives in the planning area. 

**See Table I 2 for “Species considered but not selected as MIS.”

Management Indicator Species Selection Results 

and Rationale

Based on complimentary lines of evidence, the priority needs for change, proposed action, and 

plan alternatives, the Kaibab NF identified four MIS believed to serve as strong indicators of 

management. These species also represent those vegetation types which have the greatest risk to 

species viability, as discussed in the Wildlife Effects Analysis in chapter 3 of the forest plan

revision FEIS (KNF 2013).

These species meet the recommended criteria and would be relatively cost efficient to monitor 

and analyze. In addition to meeting the requirements for MIS, we believe these species would 

also serve as good “focal species” candidates under the 2012 Planning Rule. Focal species are

defined as “a small subset of species whose status permits inference to the integrity of the larger 

ecological system to which it belongs and provides meaningful information regarding the 

effectiveness of the plan in maintaining or restoring the ecological conditions....” Although this 

analysis was conducted under the 1982 Planning Rule, current policy requires the revised plan be 

compliant with the new (2012) Planning Rule within 4 years. In an effort to streamline this 

process, the plan alternatives were developed proactively and considered many of the key 

components, such as MIS that would also serve as good focal species, outlined under the new 

planning rule. The results of our MIS analysis are summarized below. 

Table I 1. Species proposed for new management indicator species for plan revision

Species What They Indicate Priority Need for Change

Grace’s warbler

(Setophaga graciae)

Clumps of mature ponderosa 

pine/pine-oak forests, yellow pine 

(parklike environments, such as 

reference condition)

Modify stand structure and density toward

reference conditions and restore historic fire 

regimes.

Western bluebird

(Sialia mexicana)

Understory development within 

openings in ponderosa pine stands

Modify stand structure and density toward

reference conditions and restore historic fire 

regimes.

Ruby-crowned 

kinglet

(Regulus calendula)

Mixed conifer (frequent fire) mature 

forest, overstory. 

Modify stand structure and density toward

reference conditions and restore historic fire 

regimes.

Pronghorn

(Antilocapra 

americana)

Grasslands 

Restore historic grasslands by reducing tree 

encroachment and restoring fire.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 537
Appendix I. Management Indicator Species Selection

Need for Change 1: Modify stand structure and density toward

reference conditions and restore historic fire regimes (ponderosa pine).

Grace’s warbler is a neotropical migrant and breeding resident in ponderosa pine forest across all 

three ranger districts on the Kaibab NF (Birek et al. 2010). It is strongly associated with forest 

structure having well-developed canopy and pine-oak forest indicative of the open park-like

conditions found historically in northern Arizona (Szaro and Balda 1986, Stacier and Guzy 2002, 

Saab et al. 2007, Kalies et al. 2010). Occupancy models developed for the forest plan revision 

process further demonstrate the strong association this species has with ponderosa pine-oak 

habitat, including structural variables such as basal area, canopy cover, and density (Dickson et 

al. 2011), likely to be affected by forest treatments. Local research has also demonstrated a strong 

response to fire by this species (Chambers and Kalies 2011). A return to presettlement (defined as 

prior to 1890) conditions should have a positive influence on population trends for this species. 

This species would allow the forest to assess overstory management by assessing its response to 

fuel treatments and fire management goals. Grace’s warbler is a USFWS Species of Conservation 

Concern; there has been stakeholder interest in monitoring this particular species (K. Crumbo 

pers. comm. 2010).

Adequate ground cover—including the presence of fine fuels—is integral to maintaining the kind 

of low-intensity fires characteristic of presettlement conditions. Therefore, it is also necessary to 

evaluate the post-restoration understory response to overstory removal in ponderosa pine forests. 

Western bluebird, a ground-foraging species which depends largely on the understory for capture 

of invertebrate prey, has shown a strong response to burning and thinning in ponderosa pine forest 

(Wightman and Germaine 2006, Hurteau et al. 2008, Guinan et al. 2008, Russell et al. 2009, 

Dickson et al. 2009, Chambers and Kalies 2011). Wightman and Germaine (2006) found that 

western bluebird productivity and nest success were significantly affected by tree density 

(ponderosa pine and gambel oak) and adequate ground cover (grasses, forbs, and bare ground 

combined total of at least 20 percent). Occupancy models have further demonstrated a strong 

relationship of bluebirds with ponderosa pine forest and canopy cover of less than or equal to 35 

percent (Dickson et al. 2011). A resident species, western bluebirds can be found forestwide. 

Need for Change 1: Modify stand structure and density toward

reference conditions and restore historic fire regimes (frequent fire mixed conifer).

Ruby-crowned kinglets are also a year-round resident that occupy mature, well developed mixed 

coniferous forest (Corman-Gervais 2005). This species may be sensitive to forest logging and 

wildfire (Swanson et al. 2008). Occupancy model results developed locally for this species show 

a strong association with mixed conifer forest (Dickson et al. 2011).

Need for Change 4: Restore historic grasslands 

by reducing tree encroachment and restoring fire.

Pronghorn are associated with grasslands and savannahs with scattered shrubs and rolling hills. 

They prefer forbs and grasses as forage, but will eat woody browse when forbs and grasses are 

not available (O’Gara and Yoakum 2004, Brown and Ockenfels 2007). Pronghorn are also 

important for economic and social reasons. Pronghorn should respond positively to increased 

habitat availability as a result of grassland restoration and improved connectivity because they are 

sensitive to crossing hard barriers (e.g., fence lines, I-40). Positive response have been predicted

538 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix I. Management Indicator Species Selection

from implementing the proposed revised plan has already been demonstrated through wildlife 

habitat models developed in collaboration with The Nature Conservancy (Hurteau 2010).

Strategy for Monitoring Management Indicator 

Species

Songbirds are relatively easy to survey because data can be collected on many species at one time 

without additional effort. Forestwide breeding bird surveys have been conducted on the Kaibab 

NF by the forest and Rocky Mountain Bird Observatory since 2005. Survey data are analyzed 

using widely accepted statistical methods. Under the existing sample design, it is possible to 

detect an average annual population change of 3 percent within 15 to 30 years, a change which 

could trigger listing under the Endangered Species Act for some birds. The methodology yields 

robust and statistically sound density estimates for the proposed MIS species, as well as other bird 

species of interest. Existing breeding bird survey data suggest a stable to increasing trend for all 

three bird species across the forest (Birek et al. 2010). This data serve as a solid baseline for 

future analyses and help to evaluate consequences across all planning alternatives. Spatially 

explicit occupancy models developed for these species should further assist with analyses of 

planning alternatives by incorporating information on environmental correlates in a statistically 

valid manner (Dickson et al. 2011).

Further, existing land bird survey methodology also incorporates data collection on fine scale 

vegetation variables at each point count station. These data can be incorporated into species 

habitat models to discern which predictor variables are most tightly linked to each MIS species. 

Forest Service projects hope to concurrently collect data on these same variables to ascertain how 

well projects are meeting the needs of these species over time. Annual monitoring and evaluation 

and reporting on at least a 5-year interval should allow the forest to reasonably assess if any 

management changes are warranted.

The Arizona Game and Fish Department is already monitoring and tracking population trend data 

for pronghorn on the Kaibab NF; the Kaibab NF would use those data to assess population trends 

and relate it to habitat.

Ecological Indicators

While MIS are to be selected to reflect major management issues (needs for change), MIS are not 

always the best approach to evaluate management. We believe that the other two of the needs for 

change—aspen and natural waters—would be better served by “ecological indicators.” Ecological 

indicators are plants or animal species, communities, or special habitats that have a narrow range 

or ecological tolerance that are part of the monitoring plan. They differ from MIS in that there is 

no requirement to estimate population trends, rather a number of different parameters can be 

assessed to evaluate management. 

Need for Change 2: Regenerate aspen to 

insure long-term healthy aspen populations.

Aspen stands are typically moister and richer in flora and fauna than their coniferous 

counterparts, and are an integral component of southwestern forests. In fact, aspen acts as a 

keystone species in the sense that its removal or addition may have significant impacts on 

community composition and structure. Second only to riparian systems in terms of biodiversity, 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 539
Appendix I. Management Indicator Species Selection

loss of aspen represents a loss of diversity in the forest that affects numerous wildlife species, 

plants, and abiotic processes (Campbell and Bartos 2001). Aspen is also important for economic 

and social reasons. The proposed plan details specific objectives for aspen; however, because 

aspen has a declining trend and the primary factors affecting aspen health are outside of Forest 

Service control, aspen was not considered a good MIS. We propose monitoring aspen directly as 

an ecological indicator with questions focused on regeneration, extent, and mortality. 

Monitoring Strategy for Aspen

Fencing and ungulate removal should allow aspen to regenerate and facilitate long-term 

restoration. The forest monitoring plan has a specific question related to aspen regeneration and 

establishment which should provide information on the effectiveness of restoration efforts. The 

Kaibab NF already dedicates some resources to aspen monitoring, primarily on the Williams 

Ranger District, and peer-reviewed protocols for sampling aspen exist (USDA Forest Service 

2004, Jones et al. 2005). Aspen on the North Kaibab Ranger District is abundant enough to be 

tracked through the Forest Service’s existing Forest Inventory and Analysis program 

(http://www.fia.fs.fed.us).

Need for Change 3: Restore natural waters 

and wetlands to insure healthy riparian communities

Natural waters and wetlands emerged as key needs for change in the analysis of the management 

situation because the value of Kaibab NF waters is disproportionately greater than the area they 

represent. As oases across a primarily arid landscape, these features are extremely valuable to 

flora and fauna and provide important recreational, cultural, and economic benefit. 

Springs and wetlands are highly variable depending on available water, elevation, soils, and other 

site factors. There is no single terrestrial or aquatic species common enough or cost-effective 

enough to serve as a good MIS. There are instead a suite of indicators that indicate healthy (water 

quality) or disturbed (nonnative invasive) aquatic ecosystems. 

For example, riparian obligate plant species have a narrow range of ecological tolerance; in 

addition, they are resilient with good ability to reflect management consequences (USDI 2001). 

As an ecological indicator, a suite of parameters such as plant and invertebrate diversity—as well 

as healthy soil and water conditions—could be gathered during rapid on-the-ground assessments. 

Also, nonnative species (contraindicants) which cannot be used under MIS guidelines can be used 

as an ecological indicator to evaluate the effects of management alternatives. Nonnative species 

respond readily to ground-disturbing events (Ringold et al. 2008). 

Monitoring Strategy for Natural Waters

The Kaibab NF has already conducted two cycles of wetland surveys since 1990, and has baseline 

trend data for this resource. In addition, the forest has entered into an agreement with the Museum 

of Northern Arizona to conduct an inventory and assessment of springs, which will be managed in 

a user-friendly database. This inventory would provide a baseline for future survey work, 

monitoring, and trend analysis. Improved spring and wetland habitat should be visible over time 

as the new plan is implemented and the effects of ground disturbance by humans and/or ungulates 

are abated. Additionally the forest monitoring plan contains questions related to the functional 

condition of lakes and wetlands and the restoration effectiveness of springs and wetlands. 

540 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix I. Management Indicator Species Selection

Table I 2. Species considered but not selected as management indicator species

Species or 

Group Taxa Habitata

Need for 

Changeb

T & E

Existing 

MIS

Otherc

Screening Rationale

Mexican 

spotted owl

(Strix 

occidentalis 

lucida)

Bird Late-seral 

mixed conifer 

and spruce-fir, 

canyons

1 X X Species is not well distributed in the 

planning area. Limited to seven 

protected activity centers on the 

Williams Ranger District. Difficult to 

assess population trends and relate to 

habitat changes and assess differences 

between management alternatives.

Apache trout

(Oncorhynchus 

apache)

Fish Water 3 X Species is not well distributed in the 

planning area. Limited to one perennial 

stream (North Canyon Creek) on the 

North Kaibab Ranger District. 

California 

condor

(Gynmogyps 

californianus)

Bird Open areas 

for foraging, 

cliffs and 

rocky areas 

for nesting.

NA X X Species not directly tied to any one 

habitat type or priority need for change. 

Availability of rocks/cliffs and carrion 

more of a factor. Experimental (10j) 

population.

Northern 

goshawk

(Accipiter 

gentilis)

Bird Late-seral 

ponderosa 

pine

1 X X Difficult to effectively assess 

population trends. Population 

fluctuations may be more closely tied to 

variable weather conditions and the 

interrelated response by the species’ 

mammalian prey base. Habitat 

generalist.

Pygmy nuthatch

(Sitia pygmaea)

Bird Late-seral 

ponderosa 

pine, snags

1 X X Fairly ubiquitous and not as closely tied 

to forest structure as Grace’s warbler. 

Snags will be monitored directly in 

revised LMP monitoring plan.

Hairy woodpecker

(Picoides 

villosus)

Bird Snags (pine, 

mixed conifer, 

spruce-fir)

1 X Ubiquitous species, responds to 

disturbance and subsequent insect 

irruptions and availability of snags. 

Snags will be monitored directly in 

revised LMP monitoring plan.

Northern flicker

(Colaptes 

auratus)

Bird Openings, 

savanna, 

snags, and 

woody debris.

1 X Not tied closely enough to habitat type. 

Some suggestion that the species seems 

to be on the decline; however, reasons 

are unknown and some may not be 

related at all to forest management (e.g., 

pesticides).

Mountain 

chickadee

(Poecile 

gambeli)

Bird Mature forest 

in mixed 

conifer and 

ponderosa 

pine, snags.

1 X Response to forest treatments has been 

variable, not a clear pattern in the 

literature.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 541
Appendix I. Management Indicator Species Selection

Table I 2. Species considered but not selected as management indicator species

Species or 

Group Taxa Habitata

Need for 

Changeb

T & E

Existing 

MIS

Otherc

Screening Rationale

Olive-sided 

flycatcher

(Contopus 

cooperi)

Bird Mixed conifer 

and spruce-fir 

forest, snags 

and woody 

debris.

1 X Long-distance migrant. Dichotomy 

exists between favorable response to 

forest treatments and overall population 

decline that could be linked to other 

factors such as deforestation on the 

wintering grounds.

Vesper sparrow

(Pooecetes 

gramineus)

Bird Grasslands, 

sagebrush 

shrublands

4 X Existing population trend data for this 

species is lacking.

Gray vireo

(Vireo vicinior)

Bird Pinyonjuniper 

communities, 

4 X Existing population trend data on the 

Kaibab NF for this species is lacking. 

No differences between alternatives or 

objectives developed for pinyonjuniper.

Pinyon jay

(Gymnorhinus 

cyanocephalus)

Bird Pinyonjuniper 

communities

NA X No differences between alternatives or 

objectives developed for pinyonjuniper.

Virginia’s 

warbler

(Oreothlypis 

virginiae)

Bird Pine-oak and 

pinyonjuniper, 

understory

1 X Lack density estimates for baseline or 

trend. Management concern on 

wintering grounds in Mexico a possible 

confounding factor. 

Black-throated 

gray warbler

(Dendroica 

nigrescens)

Bird Pinyonjuniper and 

pine-oak 

forest.

1 X Habitat generalist, not tied closely 

enough to habitat variables of interest to 

be an MIS. Existing density trends for 

the forest are in pinyon-juniper and 

there is no alternative for this habitat. 

Information on habitat-related 

population changes lacking at both local

and regional scales.

Brown creeper

(Certhia 

americana)

Bird Snags, old 

growth.

1 X Lack current density estimates for 

species on forest. Snags will be 

measured directly in new LMP.

Mogollon vole

(Microtus 

mexicanus)

Mammal Meadows, 

openings.

1, 3, 

4

X Current population trends for Arizona

are inconclusive but suggest a decline. 

Lack conclusive baseline for the 

analyses. Small mammals subject to 

natural cyclic fluctuations in the short 

term which might not have anything to 

do with management.

Abert’s squirrel

(Sciurus aberti)

Mammal Early seral 

ponderosa 

pine, canopy.

1 X X Difficult to monitor and estimate 

population trends. Wide interannual 

variations in population estimates 

which are a normal function of species 

life history make it difficult to assess 

management effects. 

542 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix I. Management Indicator Species Selection

Table I 2. Species considered but not selected as management indicator species

Species or 

Group Taxa Habitata

Need for 

Changeb

T & E

Existing 

MIS

Otherc

Screening Rationale

Cottontail rabbit

(Sylvilagus 

floridanus)

Mammal Ponderosa 

pine 

(openings, 

understory).

1 X Species is readily adaptable to a wide 

variety of habitats; may not be sensitive 

enough to assess specific management 

actions. Hunting pressure can further 

confound response. 

Mountain lion

(Puma 

concolor)

Mammal Varies widely. 

Includes 

canyons and 

rocky areas 

with dense 

understory.

1, 2,

3, 4

X Not tied to any one habitat type or 

priority need for change. More an 

indicator of habitat connectivity/

fragmentation which is not a plan 

alternative. Difficult and costly to 

monitor.

Elk

(Cervis 

elaphus)

Mammal Early-seral 

ponderosa 

pine, mixed 

conifer, 

spruce-fir.

1, 2,

3, 4

X X Hunted species with high 

socioeconomic value and needs habitat 

connectivity; also considered a threat to 

aspen health. Population is stable and 

well distributed. Affected more by 

habitat connectivity and available 

forage than any one particular habitat 

type. Population trends reflect hunt 

success, not management effects on 

population.

Mule deer

(Odocoileus 

hemionus)

Mammal Early-seral 

aspen and 

pinyonjuniper.

1, 2,

3, 4

X X Species is demonstrably widespread 

and secure. Affected more by habitat 

connectivity (winter/summer range) and 

available forage. Population trends 

reflect hunt success, not management 

effects on population.

Western chorus 

frog (Pseudacris 

triseriata), 

northern

leopard frog

(Rana pipiens), 

red-spotted toad

(Bufo 

punctatus),

wood-house 

toad canyon 

tree frog (Hyla 

arenicolor)

Herp Wet moist 

ground, water, 

emergent 

vegetation.

3 X Difficult to assess population trends, 

species likely localized to specific sites 

and not well distributed throughout 

planning area. Better as an ecological 

indicator. Lack existing baseline trend 

data.

Butterflies Invert Understory 

herbaceous 

cover.

1, 2,

3, 4

X Response varies by species, no one 

species can be singled out. Lack 

existing trend data. Better as an 

ecological indicator.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 543
Appendix I. Management Indicator Species Selection

Table I 2. Species considered but not selected as management indicator species

Species or 

Group Taxa Habitata

Need for 

Changeb

T & E

Existing 

MIS

Otherc

Screening Rationale

Beetles Invert Understory 

and overstory 

health.

1 X Response varies by species, no one 

species can be singled out. Lack 

existing trend data. Sorting and 

identification can be laborious and 

requires taxonomic expertise. Better as 

an ecological indicator.

Cheatgrass

(Bromus 

tectorum), 

Russian olive

(Elaeagnus 

angustifolia), 

leafy spurge

(Euphorbia 

esula), salt 

cedar (Tamarix 

ramosissima)

Plants Invasive 

response to 

disturbance

1, 2,

3, 4

X Contraindicants, not appropriate as 

MIS. Better as an ecological indicator.

a For existing MIS this includes habitat they represent in the current forest plan b Priority needs for change under the proposed plan: 1) Restore Fire Adapted Ecosystems 2) Protect and regenerate 

aspen 3) Restore natural waters and wetlands 4) Restore historic grasslands

c Additional species of interest brought up internally and/or externally

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548 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix J. Use of the

“Best Available Science” for Wildlife 

in the Forest Plan Revision Process

Introduction

Wildlife biologists consulted with a variety of resources during the Kaibab National (NF) forest 

plan revision process. From development of the initial forest planning species list to writing plan 

components, monitoring approaches, and analyzing the effects of forest planning alternatives on 

species viability, the “Best Available Science” was consulted and used to ensure wildlife species 

would be afforded the best protection possible under the proposed action. Although not an 

exhaustive list, some of the more prominent sources are described in detail below.

Literature 

The Forest Service maintains access to two separate but associated online libraries. The National 

Agricultural Library is one of four national libraries of the United States. It houses one of the 

world’s largest and most accessible agricultural information collections and serves as the nexus 

for a national network of state land grant and U.S. Department of Agriculture field libraries: 

http://www.nal.usda.gov/. Within this context, the National Forest Service Library provides 

information services, access to e-journals and bibliographic databases, current literature alerting 

services, and a full range of document delivery and interlibrary loan services to Forest Service 

employees: http://www.fs.fed.us/library/.

Using these resources, Forest Service biologists consulted with premier journals during all phases 

of the plan revision process, namely the development of fine-scale plan components for wildlife 

species, summarizing the effects analyses for species viability, and development of the proposed 

management indicator species list. Top journals referenced included: Science, Nature, Ecology, 

Forest Science, Ecological Restoration, Biological Conservation, Journal of Wildlife

Management, Conservation Biology, Frontiers in Ecology and the Environment, the Condor, and 

the Birds of North America online, among others. These journals support the wildlife analyses by 

providing timely and relevant results, peer-reviewed data on emerging trends, and high impact 

articles and conference proceedings.

Wildlife biologists also consulted with lesser known documents including non-published “gray 

literature” such as technical reports, white papers, internal reports, theses, systematic reviews, and 

meta-analyses. Many of these documents are maintained through the Rocky Mountain Research 

Station library and locally based academic institutions, including the Forestry Department and 

Ecological Restoration Institute at Northern Arizona University.

Databases and Data Management Systems

NatureServe, a nonprofit conservation organization whose mission is to provide the scientific 

basis for effective conservation action was consulted largely during development of the “forest 

planning species” list. This list provided the foundation for the forest’s viability analysis and 

helped to focus plan components as needed. 

NatureServe and its network of natural heritage programs are the leading source for information 

about rare and endangered species and threatened ecosystems. NatureServe represents an 

international network of biological inventories—known as natural heritage programs or 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 549
Appendix J. Use of the “Best Available Science” for Wildlife in

the Forest Plan Revision Process

conservation data centers—operating in all 50 U.S. states, Canada, Latin America, and the 

Caribbean. Detailed information is collected and managed on plants, animals, and ecosystems. 

Information products, data management tools, and conservation services are also developed to 

help meet local, national, and global conservation needs. The objective scientific information 

about species and ecosystems developed by NatureServe is used by all sectors of society—

conservation groups, government agencies, corporations, academia, and the public—to make 

informed decisions about managing our natural resources. More information on NatureServe can 

be found here: http://www.natureserve.org/.

Additionally, databases and species lists managed by the U.S. Fish and Wildlife Service and the 

Arizona Game and Fish Department were consulted regarding threatened, endangered, and 

sensitive species as well as other local species of concern (e.g., narrow endemics and/or species 

likely to be affected by local processes). 

The Heritage Database Management System (HDMS) managed by the Arizona Game and Fish 

Department, is part of a global network of more than 80 natural heritage programs and 

conservation data centers. HDMS information allows managers, stakeholders, and decision 

makers to make prudent decisions weighing future development, economic growth, and 

environmental integrity by identifying elements of concern in Arizona. The system consolidates 

information about wildlife species distribution and status throughout the State. This includes, but 

is not limited to, plants and animals with special status at the Federal, tribal, or State level, or 

specific habitat(s) necessary for their survival. Information included in the HDMS comes from 

published and unpublished reports, data collected by cooperating agencies, museum and 

herbarium collections, the scientific and academic communities, and many other sources, 

generally opportunistic in nature. Data managed under the HDMS is site-specific in nature, and 

appropriate for project level planning. As such, these data help Forest Service biologists develop 

forest planning guidelines. In addition to HDMS species, biologists also considered species listed 

under the State Wildlife Action Plan (SWAP) for helping to develop desired conditions and 

guidelines. SWAP species consist of species of greatest concern (SGCN) or species of economic 

and recreation importance (SERI). The SWAP also developed range maps for these species using 

wildlife models that broadly represent where a species habitat exists, and where the species itself 

may occur. Although all features of the SWAP mapping tools are not currently available to the 

public, Forest Service biologists obtained draft species list from Arizona Game and Fish

biologists for reference during the plan revision process.

More information on these species lists and planning tools can be found here: 

http://www.azgfd.gov/w_c/edits/species_concern.shtml, http://www.azgfd.gov/w_c/cwcs.shtml, 

http://www.fws.gov/southwest/

Contemporary Modeling Tools and Approaches

In collaboration with local researchers and scientists, Kaibab NF biologists developed and used 

several wildlife-related habitat models to help assess the suitability of proposed management 

indicator species and to set a “baseline” for future monitoring. Further, these tools provide the 

forest with an empirically based platform for assessing wildlife habitat and species population 

change over time under each planning alternative, and provide a basis for refining future 

management. 

550 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix J. Use of the “Best Available Science” for Wildlife in

the Forest Plan Revision Process

The models, described in more detail below, incorporate the most current vegetation structural 

data based on remotely sensed and plot level data, with population data on density, occupancy, 

and/or movement patterns for select wildlife species. 

• Vegetation Dynamic Development Tool (VDDT): The Vegetation Dynamics 

Development Tool (VDDT) is a Windows-based computer tool which provides a state 

and transition landscape modeling framework for examining the role of various 

disturbance agents and management actions in vegetation change. It allows users to 

create and test descriptions of vegetation dynamics, simulating them at the landscape 

level. Projecting changes in vegetation structure and composition over time is an 

important part of landscape level analyses, and VDDT model runs were foundational to 

the Kaibab NF plan revision process. Vegetation may change for a variety of reasons, 

such as human activity, fires, insects, pathogens, mammals, weather, or growth and 

competition. The interaction of these factors is complex and the combined effects are 

difficult to predict over long periods. VDDT provides a common platform for specialists 

from different disciplines (e.g., fire ecology, silviculture, wildlife biology) to collectively 

define the roles of various processes and agents of change on landscape level vegetation 

dynamics. The model runs allowed specialists from different resource areas on the 

planning team to evaluate how the on-the-ground changes to vegetation likely to occur 

from implementation of the different planning alternatives might affect their resource 

area. Specifically, wildlife biologists used VDDT model runs to assess availability of 

habitat for certain species of interest (e.g., threatened and endangered species, forest 

planning species, management indicator species and other species of concern) under the 

different planning alternatives.

• Ripley’s K: The Ripley’s K spatial test is a tool that can be used to quantify the spatial 

arrangement of trees across the landscape. As treatments include more structural 

heterogeneity at various scales, this statistical test should help the forest achieve desired 

conditions by allowing the Kaibab NF to verify if the forest structure outlined in the 

thinning prescription was achieved on-the-ground (i.e., are prescriptions implemented as 

planned?). To examine tree aggregation patterns, a quantitative assessment of the 

resulting structure retained after thinning treatments was compared to historic range of 

variability by using the Ripley’s K function. This function statistically analyzes spatial 

patterns between pairs of points and tests the degree to which the remaining trees were 

spatially aggregated to determine whether or not treatments result in an evenly spaced, 

random, or aggregated (clumpy) forest structure. This helps to inform what changes need 

to be made in future forest treatments to meet objectives for restoring historic forest 

structure on the forest. This information could be used for a variety of wildlife species 

over time.

• PatchMorph: Vegetation structural characteristics and composition are frequently used 

to define wildlife habitat needs. A few of the metrics used to examine wildlife habitat 

include spatial heterogeneity, structural diversity, and vegetation temporal dynamics. 

Variation in these metrics across the landscape, in patches of optimal, suboptimal, and 

deficient habitat, are what allows species to coexist and be sustainable over time. A patch 

delineation algorithm called PatchMorph (Evan Girvetz; http://arcscripts.esri.com) was 

used to characterize functionally connected habitat for two focal species (Abert’s squirrel 

and pronghorn) likely to be affected by increased rates of forest restoration treatments in 

ponderosa pine and grassland habitat types. The PatchMorph algorithm allows for the use 

of natural history characteristics specific to the focal species of interest to inform the 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 551
Appendix J. Use of the “Best Available Science” for Wildlife in

the Forest Plan Revision Process

threshold values for habitat suitability, habitat gaps, and habitat spurs on the landscape. 

This tool helped Kaibab NF wildlife biologists to assess how effectively focal species are 

moving across the landscape under the current forest plan, and how those patterns might 

change under the planning alternatives. These tools could be applied to additional species 

in the future, depending on management needs.

• Occupancy and Population Trend Models: Spatially explicit occupancy modeling 

techniques were used in a monitoring context to estimate the current state (e.g., 

proportion of area occupied) of select management indicator species (Grace’s warbler, 

western bluebird, and ruby-crowned kinglet) and provide information on trends. These 

methods allow managers to make inferences about the effects of habitat change (both 

natural and human-caused) as it relates to population change over time. Occupancy 

models were developed to: (1) evaluate the suitability of the three management indicator 

species; (2) establish baseline trend estimates for future management indicator species

monitoring and analyses; and (3) incorporate adaptive management into the Kaibab NF

monitoring process and subsequent management decisions. An information theoretic 

approach was used to find the “best fit” model for each species. The models also provide 

a basis for adaptive management. As projects are implemented, post-treatment data can 

be collected on forest structural variables to assess how well management prescriptions 

meet the needs of these species over time. More information on wildlife habitat modeling

tools for management can be found at http://www.cefns.nau.edu/seses/llecb/

• The Arizona Game and Fish Department began a new process for determining population 

trends for pronghorn in 2010. Trends are determined using population models based on 

inputs on harvest, male-female ratios, and young-female ratios, estimated mean mortality 

rates, and estimated starting populations. The best model is estimated by changing 

mortality rates of the starting population so that the predicted male-female ratios from the 

models for each year match those that are based on surveys. These data were referenced 

for estimates of pronghorn during the management indicator species analysis process and 

set a baseline for future trend monitoring.

• Finally, managing wildlife and wildlife habitat under an uncertain climate was expressly 

considered during evaluation of the different planning alternatives, and for developing 

plan components and/or management approaches. Biologists referenced the literature, as 

well as innovative tools such as a System for Assessing Vulnerability of Species (SAVS), 

a decision support tool for assessing wildlife vulnerability to climate change during 

project level planning. For more information on this application, see:

http://www.fs.fed.us/rm/grassland-shrubland-desert/products/species-vulnerability/

Scientific Conferences, Workshops, and 

Collaborations

Forest Service biologists and planners attended and made contributions to several scientific 

conferences and workshops during the forest plan revision process including:

• Flagstaff Climate Change Adaptation Workshop

• 2010 Society of American Foresters Conference

• National Workshop on Climate and Forests: Planning Tools and Perspectives on 

Adaptation and Mitigation Options.

552 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix J. Use of the “Best Available Science” for Wildlife in

the Forest Plan Revision Process

• The 11th Biennial Conference of Research on the Colorado Plateau: “Cultural and 

Natural Resource Management on the Colorado Plateau: Science and Management at the 

Landscape Scale”

• Society for Conservation Biology North American Conference for Conservation Biology. 

Bridging the Gap: Connecting People, Nature and Climate. Oakland, CA.

• The 12th Biennial Conference of Science and Management on the Colorado Plateau: 

“Effects of Rapid Climatic, Social, and Technological Changes on the Colorado Plateau”

The Kaibab NF sponsored two locally based workshops related to monitoring and the wildlife 

viability and management indicator selection process. Ecologists and biologists from other 

Federal agencies, nonprofit organizations, and academia were among the attendees representing a 

wide range of expertise in the fields of forestry, fire, restoration, wildlife, and spatial ecology, 

among others. Recommendations from these collaborations were integrated into various aspects 

of the draft forest plan and/or wildlife viability analysis. Kaibab NF wildlife biologists also 

engaged in several locally held “collaborwriting” sessions focused on group and public 

involvement. Plan content was developed in conjunction with this process which involved a 

variety of “expert” representatives from local stakeholder groups, academia, and other agencies.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 553

Appendix K. Large Tree Retention Classes

for Ponderosa Pine

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 555
Appendix K. Large Tree Retention Classes for Ponderosa Pine

Age Class Descriptions

Dunning (1928) Age Class 5: Overmature; usually largest trees in stand; bark light yellow with 

wide, long and smooth plates; tops flat with terminals rarely discernible; nearly all branches are 

drooping, gnarled, and crooked.

Keen (1943) Age Class 4: Overmature; making no further height growth; diameter growth very 

slow; bark light yellow, uniform for entire bole (except in extreme top), with wide, long and 

smooth plates and often shallow fissures; tops usually flat or occasionally rounded or irregular; 

branches large, heavy, and often gnarled or crooked and mostly drooping except in extreme top.

Thomson (1940) Age Class 4: Mature-overmature; trees usually large; bark reddish-brown to 

yellow with wide, long and smooth plates; tops usually flat and making no further height growth; 

branches mostly large and drooping, gnarled or crooked.

References

Dunning, D. 1928. A tree classification for the selection forests of the Sierra Nevada. Journal of 

Agricultural Research 36(9): 755–771.

Keen, F.P. 1943. Ponderosa pine tree classes redefined. Journal of Forestry 41(4): 249–253.

Thomson, W.G. 1940. A growth rate classification of Southwestern ponderosa pine. Journal of 

Forestry 38(7): 547–553.

556 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and

Coordination with Other Planning Efforts

Introduction

This appendix summarizes the collaboration and coordination efforts for the Kaibab National 

Forest (NF) plan revision. It describes how the Kaibab NF engaged with the public, stakeholders, 

tribes, and other agencies throughout this effort. The first section of the document, Collaboration 

and Public Involvement Effort, provides information on meetings, workshops, and process used 

for sharing information and obtaining input. The second section of this document, Coordination 

with Other Public Planning Effort, briefly displays the planning and land use policies on adjacent 

and overlapping lands and how the Kaibab NF took that guidance into consideration.

Collaboration and Public Involvement Effort

Recognizing that our partners and publics have valuable ideas, knowledge, opinions, and needs 

that can inform and improve management of the Kaibab NF, the planning team developed a 

public involvement plan designed to provide opportunities for meaningful dialogue and 

collaboration throughout the plan revision process. Synopses of the key collaborative processes 

are listed below.

2006 Public Meetings 

Public involvement for the Kaibab NF plan revision began in the fall of 2006 under the direction 

of the 2005 Planning Rule with two sets of public meetings held in the surrounding communities 

(Williams, Flagstaff, North Kaibab, and Tusayan). Meetings jointly hosted with the Coconino 

National Forest were also held in Phoenix. The first set of meetings provided an overview of the 

plan revision process, and included facilitated small group sessions that focused on 

likes/vision/desired conditions and dislikes/needs for changes. The second set of meetings 

reported back on the content from the first set of meetings and then followed up with more 

specific questions to drill down to gain additional detail and insight.

2006 Agency Meetings

In November 2006, the Coconino and Kaibab NFs held a multiagency plan revision meeting. This 

was attended by the National Park Service, Arizona State Parks, Coconino County, Yavapai 

County, Fish and Wildlife Service, Arizona State Forestry, Arizona Game and Fish Department, 

city of Flagstaff, city of Sedona, and Babbitt Ranches. This meeting reviewed the public comment 

process to date and asked for information from each agency that would be helpful in the plan 

revision effort. The majority of participants asked to stay informed via agency briefings.

2007 Working Group Meetings

In an effort to obtain more targeted public participation related to evaluating sustainability and 

identifying management needs for change, working group meetings were held on species 

diversity, ecosystem diversity, social and economic sustainability, and special areas. All working 

group meetings were advertised and open to the public. Input received during the working group 

meetings was used to prepare the “Ecological Sustainability Report,” “Social and Economic 

Sustainability Report,” and “Comprehensive Evaluation Report.” These reports are all available 

on the Kaibab NF Web site at: http://fs.usda.gov/goto/kaibab/plan_revision.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 557
Appendix L. Collaboration and Coordination with Other Planning Efforts

In March of 2007, the 2005 Planning Rule was enjoined. While the forest was able to work 

internally on specific products, public meetings were put on hold until direction was provided 

about how forests were to continue with forest planning. The Southwestern Region decided to 

move forward in a “rule neutral” manner. 

In January 2008, the Coconino and Kaibab NFs held a multiagency and public meeting to share 

how the forests intended to go forward in forest plan revision in a planning rule neutral manner. 

Public input was sought on the products to date, and how the forest should move into finalizing 

the first phase of revision. In the fall of 2008, a new planning rule was in place (2008 Rule) and 

the Kaibab NF, adjusted its planning process to ensure conformance.

In accordance with the 2008 Planning Rule, a notice of initiation to revise the Kaibab forest plan

was published in the Federal Register and Arizona Daily Sun in April of 2009. Concurrently, the 

comprehensive evaluation report (CER) was made available to the public online and hard copy. 

The CER specified the management needs for change that would serve to focus the plan revision

effort. The notice of intent initiated another round of public meetings as well as several efforts 

specifically designed to develop content for the plan and alternatives. 

2009 Kaibab National Forest Health Focus 

The Kaibab NF sponsored a series of science-based, collaborative meetings to prioritize treatment 

areas and provide guidance for forest restoration treatments for use in revising the Kaibab forest 

plan and guide future landscape level forest restoration efforts. The forest formed a partnership 

with Northern Arizona University’s Lab of Landscape Ecology and Conservation Biology to host 

a collaborative forum on forest health supported by spatial modeling and analysis. The effort 

drew from, and expanded upon, previous collaborative assessments and analysis including the 

Western Mogollon Plateau Landscape Assessment, the Statewide Strategy for Restoring Arizona’s

Forests, and the Analysis of Small-diameter Wood Supply for Northern Arizona. The effort 

produced a series of recommendations used to develop desired conditions, objectives, and 

guidelines in the initial working draft plan. A detailed report can be accessed at

http://fs.usda.gov/goto/kaibab/plan_rev_docs.

Following publication of the CER, but prior to the public meetings that were scheduled to follow, 

the 2008 Planning Rule was enjoined. A Federal District Court order issued in June 2009 

reinstated the 2000 Planning Rule, which included transition provisions to revise plans under the 

earlier 1982 Rule (section 219.35). In an effort to maintain momentum and capitalize on the 

collaborative efforts and analysis to date, the Kaibab NF decided to continue with the plan 

revision effort under the provisions of the 1982 Rule.

2009 Public Meetings 

Public meetings were held in Fredonia and Williams to share the needs for change and solicit 

input on possible wilderness, research natural areas, and wild and scenic river recommendations. 

Due to recent legal actions and subsequent changes to the plan revision process, the intent to 

proceed under the 82 Rule Provisions and its differing requirements were also a topic of 

discussion. 

558 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

2009-2010 “Collaborwriting” Workshops

The Kaibab NF hosted five workshops for developing specific plan content for aspen, grasslands, 

springs, mixed conifer, and recreation. The workshops used a groupware tool called 

“collaborwriting” which served like an electronic flipchart onto which everyone could view and 

type comments at the same time. Facilitated follow up enabled exploring themes, seeking detail, 

and gaining clarification. This tool allowed for: (1) a lot of content to be captured in a short time;

(2) the exact words and intent to be preserved; (3) the meeting content to be immediately 

available as it did not need to be transcribed; and (4) quieter participants to have an opportunity to 

express themselves and prevented more vocal participants from monopolizing. 

In conjunction with the collaborwriting workshops, an online component shared the workshop 

content. The intent was to validate and build on the workshop content, but there was limited 

participation and it did not yield additional content. A final collaborwriting session was held 

following the comment period on the draft plan to address issues and develop alternatives. 

Due to the complexity and also public interest in wildlife issues and monitoring/adaptive 

management, two additional workshops were held. Both of these workshops had participants 

from Arizona Game and Fish Department, U.S. Fish and Wildlife Service, environmental groups, 

academia, and other agency personnel. 

2012 Draft plan and DEIS Roll-Out

Following publication of the NOA (Notice of Availability) in the Federal Register on April 20, 

2012 announcing the availability of the DEIS and proposed plan, the planning team hosted public 

meetings in Williams and Fredonia, AZ. Presentations were given to the Williams City Council, 

Tusayan Town Council, Fredonia Town Council, Southwest Utah Planning Authorities Council, 

Cameron and Bodaway-Gap Navajo Chapters, livestock grazing permittees, and the Williams 

Rotary Club. Work sessions were held with the Grand Canyon National Park staff and the Kane 

County (UT) Commissioners to go over the plan and DEIS contents and discuss concerns. 

Meetings were also held with the Arizona Game and Fish Department, U.S. Fish and Wildlife 

Service, Kaibab Band of Paiute Indians, and Hopi Tribe to discuss comments. 

Coordination with State, Federal and Local 

Governments 

Coordination with State, Federal, and local governments occurred throughout the planning 

process. A majority of the coordination that resulted in substantive plan language was around 

topics of mutual interests such as wildlife management, potential wilderness areas, and managing 

across agency boundaries. More formal presentations and briefings were held with State, local 

and Federal elected officials including the city of Williams, town of Fredonia, town of Tusayan, 

Coconino County Board of Supervisors, and congressional representatives. The briefings and 

presentations focused on issues and key topics such as continued economic uses, access, and 

protections.

Tribal Meetings

Due to the level of use of the forest by tribal members and the unique interests of area tribes, the 

Kaibab NF conducted extensive tribal consultation and scoping of tribal communities throughout 

the forest plan revision process. This consultation process reflects a long-standing commitment 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 559
Appendix L. Collaboration and Coordination with Other Planning Efforts

by the Kaibab NF to share the stewardship of public lands with area tribes. Throughout the plan 

revision process, tribal consultation was conducted at the government-to-government level with 

concerned tribes according to established memoranda of understanding and pertinent laws and 

regulations. Additionally, the forest scoped tribal communities and individual tribal members that 

use the forest. These efforts were made to assure that affected tribal publics were given the 

opportunity to participate in the planning process as required by the National Environmental 

Policy Act and other laws and regulations. In more than 30 face-to-face meetings, a wide range of 

concerns were raised related to almost every aspect of land management. The primary tribal 

concerns were about increased development on the forest, extractive undertakings such as 

uranium mining, and continued access to ceremonial sites and forest products for traditional and 

cultural purposes. 

In August 2007, the Kaibab NF hosted the first of what has since been an annual intertribal 

meeting. . The first meeting was held specifically to discuss the forest plan revision and uranium 

mining. Subsequent meetings have continued to have forest planning as an agenda item; however 

the scope has become broader, and recently involved other agencies as well. The meetings have 

been attended by representatives of the Havasupai Tribe, Hopi Tribe, Hualapai Tribe Kaibab Band 

of Paiute Indians, Navajo Nation, Yavapai-Prescott Indian Tribe, Yavapai-Apache Nation, Zuni, 

and Tonto Apache Tribe.

Additionally, there were meetings and phone calls with various stakeholders upon request and as 

needed to discuss and clarify comments received and to provide information.

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

6/8/2006 Meeting with Governor’s Oversight Council on Forest Health Flagstaff, AZ

6/22/2006 Hopi Tribe and Hopi Cultural Resource Advisory Team (CRAT) Kykotsmovi, AZ

7/6/2006 Kaibab Paiute Band of Indians Tribal Council Pipe Springs, AZ

9/19/2006 1st round – public meeting Williams, AZ

9/20/2006 1st round – public meeting Flagstaff, AZ

9/21/2006 1st round – public meeting Kanab, UT

9/22/2006 1st round – public meeting Tusayan, AZ

10/7/2006 1st round – public meeting Phoenix, AZ

10/12/2006 2nd round – public meeting Kanab, UT

10/18/2006 2nd round – public meeting Williams, AZ

10/19/2006 2nd round – public meeting Flagstaff, AZ

10/20/2006 2nd round – public meeting Tusayan, AZ

11/17/2006 Phoenix area Government meeting (joint w/Coconino) Phoenix, AZ

560 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

11/18/2006 2nd round – public meeting (joint w/Coconino) Phoenix, AZ

12/17/2006 Cameron Chapter Meeting of Western Navajo Cameron, AZ

12/18/2006 Navajo Forestry Department Fort Defiance, AZ

01/31/2007 Navajo Nation (joint meeting with Coconino National Forest) Window Rock, AZ

02/05/2007 Havasupai Tribal Council Tusayan, AZ

02/15/2007 Bodaway/Gap Chapter of Western Navajo Gap, AZ

02/21/2007 Hopi Tribe Kykotsmovi, AZ

03/11/2007 Coppermine Chapter of Western Navajo Agency Red Mesa, AZ

05/30/2007 Navajo Nation Window Rock, AZ

07/11/2007 Havasupai Tribe Conference Call

08/07/2007 Multitribal Meeting Williams, AZ

11/19/2007 Navajo Nation Window Rock, AZ

12/18/2007 Field trip to Chuska Mountains w/Navajo Forestry Navajo, AZ

12/19/2007 Hopi Natural Resources Kykotsmovi, AZ

01/12/2008 Joint Meeting w/Coconino Multistakeholder Flagstaff, AZ

01/28/2008 Kaibab Paiute Tribe Fredonia, AZ

02/14/2008 Navajo Nation Flagstaff, AZ

02/19/2008 Yavapai-Prescott Indian Tribe Williams, AZ

02/20/2008 Hopi Tribe Kykotsmovi, AZ

03/04/2008 Hualapai Tribal Chair and Staff Peach Springs, AZ

03/18/2008 Havasupai Tribal Council Tusayan, AZ

03/19/2008 Kaibab Paiute Tribe Pipe Springs, AZ

04/22/2008 G&F Coordination Meeting Flagstaff, AZ

05/01/2008 Bat Meeting at Arizona Game and Fish Flagstaff, AZ

7/15/2008 Attend Navajo Natural Resources Conference Flagstaff, AZ

09/02/2008 First Multitribe meeting Williams, AZ

09/03/2008 Hopi Tribe, Kaibab Band of Paiute, Hualapai Tribe, Navajo Nation Williams, AZ

11/05/2008 Attend Arizona Department of Transportation Statewide 

Transportation Meeting Flagstaff, AZ

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 561
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

01/21/2009 Forest Health Focus – Meeting1 Flagstaff, AZ

02/18/2009 Forest Health Focus – Meeting 2 Flagstaff, AZ

04/28/2009 Forest Health Focus – Meeting 3 Flagstaff, AZ

06/2/2009 Forest Health Focus – Meeting 4 Flagstaff, AZ

08/26/2009 Public Meeting – Rollout of Comprehensive Evaluation Report Williams, AZ

08/27/2009 Public Meeting – Rollout of Comprehensive Evaluation Report Fredonia, AZ

09/03/2009 Triforest Leadership Meeting; Presentation to RF Williams, AZ

09/28/2009 Multitribe Meeting Williams, AZ

12/14/2009 Collaborwriting Workshop: Grasslands Flagstaff, AZ

12/17/2009 Collaborwriting Workshops: Aspen and Springs Flagstaff, AZ

01/19/2010 Collaborwriting Workshop: Recreation Flagstaff, AZ

02/02/2010 Mixed Conifer Topic Meeting Flagstaff, AZ

03/02/2010 USFWS Meeting Flagstaff, AZ

03/04/2010 Pueblo of Zuni Zuni, NM

03/10/2010 Hualapai Tribe Peach Springs, AZ

03/12/2010 Navajo Nation Window Rock, AZ

03/26/2010 Hopi Tribe (Hopi Vice Chairman and Other Hopi Staff) Kykotsmovi, AZ

04/01/2010 Arizona Game and Fish Department Coordination Meeting Flagstaff, AZ

04/06/2010 Havasupai-FPR Briefing for Council Havasue, AZ

05/13/2010 Fredonia Public Meeting Fredonia, AZ

06/07/2010 Kaibab-Paiute Community Meeting Pipe Springs, AZ

06/15/2010 Wildlife Issues and Analysis Topic Meeting Flagstaff, AZ

06/16/2010 Meeting with Arizona Coalition of Conservation Groups Flagstaff, AZ

07/15/2010 Meet w/Wildlands Council Flagstaff, AZ

7/29/2010 Collaborwriting Workshop: Issues and Alternatives Meeting Flagstaff, AZ

8/3/2010 Meet w/Andi Rodgers (Arizona Game and Fish Department) Flagstaff, AZ

8/24/2010 Monitoring and Adaptive Management Workshop Williams, AZ

9/2/2010 Meet w/Alicyn Gitlin Sierra Club Flagstaff, AZ

9/15/2010 Intertribal Meeting Williams, AZ

09/21/2010 Attend Sierra Club “Meet and Greet” Flagstaff, AZ

562 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

10/22/2010 Call with Wildlands Council (Kim Crumbo) re: Alternatives Conference Call

10/27/2010 Attend Society of American Foresters, present poster on 

collaborwriting Albuquerque, NM

11/21/2010 Conference Call with Sierra Club to Discuss Alternatives Conference Call 

01/13/2011 Meet w/Sierra Club Flagstaff, AZ

02/15/2011 Yavapai-Prescott Indian Tribe Prescott, AZ

02/16/2011 Hualapai Tribe Peach Springs, AZ

02/23/2011 Pueblo of Zuni Zuni, NM

02/24/2011 Meet w/ Fish and Wildlife Service Flagstaff, AZ

02/24/2011 Navajo Nation Window Rock, AZ

03/01/2011 Presentation to Williams Fire Advisory Council (WFAC) Williams, AZ

03/9/2011 Havasupai Tribe Flagstaff, AZ

03/14/2011 Presentation at Sierra Club Meeting Flagstaff, AZ

03/23/2011 Hopi Tribe Kykotsmovi, AZ

04/6/2011 Arizona Game and Fish Coordination Flagstaff, AZ

04/26/2011 Coordination Meeting with Fish and Wildlife Service Flagstaff, AZ

06/02/2011 Meet Arizona Game and Fish Department, discuss Viability/ MIS Flagstaff, AZ

09/13/2011 Participate in Tribal Climate Change Workshop Flagstaff, AZ

09/21/2011 Tusayan Town Council Tusayan, AZ

09/22/2011 City of Williams Council Williams, AZ

09/27/2011 Fredonia Town Council Fredonia, AZ

10/05/2011 Briefing with Congressman Gosar’s Staff Washington, DC

100/6/2011 Briefing with Senator Kyl’s Staff Washington, DC

10/07/2011 Briefing with Senator McCain’s Staff Washington, DC

10/24/2011 Kaibab Forest Plan Related Posters/presentations Biennial 

Conference Flagstaff, AZ

10/25/2011 Wildlands Council/Sierra Club (K. Crumbo, L. Nemeth, A. Gitlin) Flagstaff, AZ

10/26/2011 Monitoring Workshop 4FRI Science & Monitoring group Flagstaff, AZ

11/8/2011 Presentation to Southern Utah Planning Authorities Council Kanab, UT

12/14/2011 Meet with County Supervisors Matt Ryan, Carl Taylor, Lena Fowler. Flagstaff, AZ

01/19/2012 N. Arizona Chapter-Society of American Foresters, presentation Flagstaff, AZ

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 563
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

03/26/2012 Attended round table discussion with Coconino NF and Rocky 

Mountain Reseach Station. Flagstaff, AZ

04/04/2012 Annual coordination meeting with Arizona Game and Fish/U.S. Fish 

and Wildlife Service –presentation Q&A Flagstaff, AZ

04/12/2012 Annual Range Permittee meeting-presentation Q&A Williams, AZ

04/26/2012 City of Williams Council Meeting presentation Q&A Willaims, AZ

05/02/2012 Briefing for Deputy Undersecretary of Agriculture, Butch Blazer Tusayan, AZ

05/07/2012 Kanab County Commisioners, Working group meeting Kanab, UT

05/07/2012 Public Meeting Fredonia, AZ

05/09/2012 Intertribal Meeting Pipe Springs, AZ 

06/16/2012 Public Meeting Williams AZ

05/20/2012 Cameron Chapter Meeting, Navajo Nation Cameron, AZ

05/31/2012 Williams Rotary Club, presentation, Q&A Williams, AZ

06/06/2012 Tusayan Town Council Meeting, presentation Q&A Tusayan, AZ

06/12/2012 Fredonia Town Council Meeting, presentation Q&A Fredonia, AZ

06/28/2012 Monitoring Workshop Flagstaff, AZ

07/1020/12 Meeting with Grand Canyon National Park staff Flagstaff, AZ

07/10/2012 Meeting with Sierra Club Chapter (to answer questions). Flagstaff, AZ

09/06/2012 Council Meeting, Kaibab Band of Paiute Pipe Springs, AZ

09/19/2013 Consultation Meeting with Hopi Tribe Kykotsmovi, AZ

10/11/2012 Atttended Greater Grand Canyon Landscape Assessment 

Collaborative Meeting Flagstaff, AZ

12/21/2012 Meeting/ Soltice potluck, Hopi Tribe Kykotsmovi, AZ

04/05/2013 Northern Arizona Forest Policy class presentation Flagstaff, AZ

04/15/2013 Forest plan update for Zuni and Hopi tribal elders Kane Ranch, AZ

06/17/2013 Atttend Greater Grand Canyon Landscape Assessment Collaborative 

Technical Worksession Flagstaff, AZ

08/21/2013 Deputy Undersecretary of Agriculture Butch Blazer, briefing Washington, DC

08/21/2013 Meet with Senator Flake’s Staff Washington, DC

08/22/2013 Meet with Senator McCain’s Staff Washington, DC

08/22/203 Meet with Congresswoman Kirkpatrick’s staff. Washington, DC

564 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 1. Listing of key collaboration and public involvement meetings and 

discussions

Date Meeting Location

0827/2013 Undersecretary of Agriculture’s Brief Chief of Staff Washington, DC

Information Made Available to the 

Public on the Forest Plan Revision Web Site

Under the 2008 Planning Rule, three reports were prepared and released to the public: the 

Economic and Social Sustainability Assessment was released in August of 2008; the Ecological 

Sustainability Report was released in December 2008, and the Comprehensive Evaluation Report

was released in April of 2009. These reports were made available at public meetings, on the 

Kaibab NF Web site, and by request. A notice of initiation was published in the Federal Register 

in April of 2009 announcing the availability of these reports, as well as the forest’s intent to revise 

its forest plan based on identified needs for change. 

To meet the requirements of the 1982 Planning Rule Provisions, an analysis of the management 

situation was prepared. Availability of the analysis of the management situation and the initial 

working draft plan was published in the Federal Register with a notice of intent on April 24, 

2010. 

Over a year and a half period, four iterations of the Kaibab working draft forest plan were posted 

to the Web site. While the official comment period was in the 2 months following release of the 

initial working draft plan, comments were received throughout the process that were used to 

modify and refine language in the working draft for the proposed plan and alternatives. 

Following the Notice of Availability published to the Federal Register, The Draft Plan and DEIS 

were posted to the Kaibab website. Additionally, information was posted about how to comment, 

plan development, collaboration, and how we used the best available science, wilderness and wild 

and scenic river assessments, and specialist reports. 

Coordination with Other Planning Efforts 

Provisions of the 1982 Planning Rule state that the responsible line officer shall review the 

planning and land use policies of other Federal agencies, State and local agencies and 

governments, and American Indian tribes. In preparing the Kaibab forest plan, the planning team 

reviewed the objectives expressed and evaluated the interrelationships. For the most part, the 

proposed Kaibab forest plan compliments these other planning efforts. These plans, assessments, 

and strategies were considered in the development of plan components to ensure as much 

alignment as was practicable. Management approach sections of the plan articulate identified 

issues and opportunities for coordinating with various partners across administrative boundaries, 

particularly State, local, tribal, and Federal agencies. The primary concordances are in managing 

for safe and healthy vegetation conditions, protection of air and water quality, providing for 

quality core wildlife habitats with connectivity, and maintenance of high scenic values. Cross 

boundary issues include managing for wide ranging species and wildfire across agency 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 565
Appendix L. Collaboration and Coordination with Other Planning Efforts

boundaries, and working together to improve efficiency. While there were some differences 

related to the differing missions, no conflicts requiring alternative development were identified. 

Coordination has also been ongoing with the 4 Forest Restoration Initiative. The primary focus 

areas for coordination included topics about plan consistency, monitoring and adaptive 

management, where there is a high degree of overlap.

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

State

Arizona Forest 

Resource 

Strategy (2010)

Arizona 

State 

Forestry 

Division

This strategy: (1) outlines long-term coordinated approaches for addressing 

forest resource issues and opportunities in priority landscapes; (2) describes 

how the State proposes to invest Federal funding and other resources to 

address State, regional, and national forest management priorities;

(3) identifies key partners and stakeholders for future program, agency, and 

partner coordination; (4) incorporates existing statewide plans including the 

State Wildlife Action Plan (SWAP) and community wildfire protection plans 

(CWPP); and (5) discusses the resources necessary for implementation. The 

goals include: (1) people and communities receive maximum benefits from 

forests and trees with minimized negative impacts to trees and forests; 

(2) resilient and diverse forest ecosystem structures, processes, and functions 

with progress toward landscape scale outcomes, restoration of unhealthy 

ecosystems, and enhanced sustainability with negative impacts; (3) improved 

water quality and quantity from forested watersheds, improved health and 

resiliency of forested aquatic systems (riparian areas, springs, and wet 

meadows); (4) increased public understanding of the importance of forests to 

Arizona’s water quality and improved air quality; (5) wildland ecosystems 

where appropriate fire regimes maintain health and resiliency of natural 

vegetation, “Fire Adapted Communities” that provide shared stakeholder 

responsibility for healthy landscapes and wildfire prepared communities, 

enhanced wildland fire management capacity in Arizona, and an Arizona 

public and government leadership that is well informed about wildland fire, 

management, science, and prevention issues; (6) realized long-term economic 

potential of sustainable forest products and bioenergy (while achieving 

ecosystem health goals), protection of areas with economic development 

potential related to ecosystem services, community recognition of the 

economic importance to protecting healthy natural systems; (7) increased 

resilience of ecosystems to climate change, reduced rate of future climate 

change through maximized carbon sequestration in Arizona forests and trees, 

broad public and community understanding of climate change science–

Arizona’s variable climate and current and future impacts; and (8) improved 

communication between all land management agencies, indigenous tribes, and 

other cultural groups about varying perspectives and beliefs related to forests, 

trees, and other natural resources, effective collaboration mechanisms for 

sharing of information about resources, priorities, policies, and management 

strategies between tribes and nontribal organizations.

566 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Governor’s 

Forest Health 

Council 

Statewide 

Strategy for 

Restoring 

Arizona’s 

Forests (2007

[Draft]).

Governor’s 

Forest 

Health 

Oversight 

Council

This document describes approaches for achieving long-term ecosystem 

restoration, fire risk reduction around communities, natural fire management in 

wildlands, and the development of appropriate restoration related economic 

opportunities. Based on sound ecological and social science, the statewide 

strategy incorporates valuable insights and techniques from the successful and 

innovative efforts already underway in Arizona. The primary purpose of the 

statewide strategy is to foster the implementation of a comprehensive, 

systematic effort to restore the ecological integrity of Arizona’s forests and 

woodlands, while at the same time describing how rural communities can 

benefit from their aesthetic, ecological, and economic resources without 

compromising forest health and public safety.

The State 

Long-Range 

Trans-portation 

Plan (2011)

Arizona 

Dept. of 

Transportation

(ADOT)

ADOT’s long-range plan identifies the following goals and objectives: 

Improve Mobility and Accessibility, Link Transportation and Land Use, 

Support Economic Development, Promote Natural, Cultural, and 

Environmental Resources, and Strengthen Partnerships. Key areas of 

concordance include safety, wildlife corridors, and collaborative approaches.

Statewide 

Comprehensive Outdoor 

Recreation 

Plan (SCORP) 

(2012 [Draft])

Arizona 

State Parks

The primary purpose of the SCORP is to: (1) establish outdoor recreation 

priorities for Arizona that will help outdoor recreation and natural resource 

managers at all levels of government, the State legislature, and the executive 

branch make decisions about the State’s outdoor recreation sites, programs and 

infrastructure; (2) set evaluation criteria to allocate the Federal Land and Water 

Conservation Fund and local, regional and State Parks Heritage Fund grants 

consistent with the State’s outdoor recreation priorities identified in this plan; 

(3) provide outdoor recreation managers with guidance and information to use 

for more specific recreation planning and budgeting; (4) encourage a better, 

highly integrated outdoor recreation system throughout Arizona that balances 

recreation and protection of natural and cultural resources; and (5) strengthen 

the awareness of the connections between outdoor recreation with health 

benefits and a thriving economy.

Seven priority issues were identified, each with specific goals and strategies. 

These issues are: (1) secure sustainable funding; (2) improve collaborative 

planning and partnerships; (3) respond to the needs of special populations and 

changing demographics; (4) resolve conflicts; (5) secure access to public; (6) 

protect Arizona’s natural and cultural resources; and (7) communicate with 

and educate the public.

Arizona Bat 

Conservation 

Strategic Plan

(2003)

Arizona 

Game and 

Fish Dept.

Delineates specific areas of concern for management, research, inventory and 

monitoring, and education that should be addressed in Arizona by land 

managers, wildlife managers, and scientists. Provides consistency for bat 

conservation throughout the State.

Arizona 

Partners in 

Flight Bird 

Conservation 

Plan (1999)

Arizona 

Game and 

Fish Dept.

Identifies priority bird species and habitats, and establishes objectives for bird 

populations and habitats in Arizona. Focuses on microhabitat requirements of 

priority species, and also identifies landscape scale requirements. Conservation 

actions are recommended, and partnerships are identified to accomplish the 

objectives.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 567
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Arizona’s 

Wildlife 

Linkages 

Assessment 

(2006)

Arizona 

Game and 

Fish Dept.

Helps to inform planners and engineers by providing suggestions for the 

incorporation of linkage zones into their management planning to address 

wildlife connectivity in the planning process. Helps to integrate considerations 

for wildlife connectivity into regional planning and projects early in the 

process, and provides increased opportunities to conserve wildlife movement.

The Coconino 

County 

Wildlife 

Connectivity

Assessment: 

Report on 

Stakeholder 

input (2011)

Arizona 

Game and 

Fish Dept.

This report provides background information on the importance and benefits of 

conserving wildlife linkages for both people and wildlife in Coconino County, 

and describes the methods used in a series of stakeholder driven workshops. It 

includes a series of maps that depict the general locations of wildlife linkages 

and potential barriers to wildlife movement. The maps are followed by tables 

of descriptive information about the habitat areas each linkage connects, the 

species each linkage serves, and known threats and potential conservation

opportunities associated with each linkage and barrier.

State Wildlife 

Action Plan 

(2012)

Arizona 

Game and 

Fish Dept.

The SWAP provides a framework for helping to set the State’s wildlife 

conservation priorities. SWAP species consist of species of greatest concern 

(SGCN) or species of economic and recreation importance (SERI). 

HabiMapTM Arizona, a component of the SWAP, provides a visual 

representation of the Species and Habitat Conservation Guide, which includes 

more than 300 layers of wildlife data and other information to identify the 

conservation potential at a statewide level.

Arizona 

Statewide 

Proghorn 

Management 

Plan (2011)

Arizona 

Game and 

Fish Dept.

The objectives of this plan are to (1) identify all occupied or potential 

pronghorn habitat. Manage pronghorn populations under a herd unit or 

management unit basis; whichever best facilitates achievement of management 

objectives; (2) survey pronghorn populations using a standardized survey 

protocol that produces survey-generated population estimates. Estimate current 

populations within each pronghorn management area using population 

modeling in conjunction with surveygenerated population estimates; (3) use 

habitat and issue assessment to identify major issues and opportunities relative 

to pronghorn herd or management unit populations; (4) use the Guidelines for 

the 2012–2013 and 2013–2014 Hunting Seasons to direct annual hunt 

recommendations; (5) recommend management objectives and identify 

specific strategies for each pronghorn herd-management unit to address 

priority issues and opportunities; and (6) report on completed management 

actions.

Arizona 

National Forest 

Cave and Karst 

Management 

Plan (2013 

draft)

Central 

Arizona 

Grotto

The purpose of this guide is to summarize Cave Management procedures used 

on the Arizona National Forest. Cave resources are both fragile and nonrenewable and special considerations are required to provide resource protection 

and recreational opportunities.

568 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

County

Coconino 

County 

Comprehensive Plan. 

(2003) 

Coconino 

County, 

Arizona

Improve forest health and promote the restoration of forest ecosystems. 

Manage recreational uses in a manner that minimizes impacts to communities 

and the environment. Concentrate development in designated growth areas 

while preserving open space and landscapes.

Encourage residents of neighborhoods in wildland-urban interface areas to 

participate in forest planning, management, and restoration efforts. Coordinate 

planning and maintenance of recreational opportunities that minimize adverse 

impacts to natural systems and residential areas. Assist other agencies with the 

planning and development of designated OHV routes and educational 

information that addresses the needs and impacts of OHV uses.

Coconino County supports Federal acquisition through exchange or purchase 

of private inholdings surrounded by national forest or BLM lands that are 

important habitat areas, that contain environmentally sensitive lands, or that 

would reduce fragmentation.

Yavapai 

County 

General Plan 

(2003). 

Yavapai 

County, 

Arizona

Sustain Yavapai County’s rural character. Preserve open lands and the 

county’s attractive image. Maintain open space between communities, 

encourage continued ranching and livestock grazing, coordinate with land 

agencies sale/exchange proposals to recognize existing zoning and recreational 

opportunities, maintain clear air. Protect scenic views and mountain vistas.

Enhance parks and recreational opportunities. Preserve existing trails for 

differentiated uses. Identify sites of scenic interest and practice visual 

conservation. Protect natural water resources. Maintain waterflow, ecosystems. 

Strive to reserve desirable public lands for recreation, open space, protection of 

wildlife habitats, and buffering residential areas. Connect open spaces with 

wildlife corridors and pronghorn grassland habitats, protect wildlife habitats, 

protect riparian areas, watercourses, and associated flood plains.

Yavapai 

County Comprehensive Plan 

(2012)

Yavapai 

County, 

Arizona

Revises the Yavapai County General Plan (2003). “The guiding vision for the 

Yavapai County Comprehensive Plan is to provide a flexible and adaptable 

approach to managing growth while respecting the values of our past, to 

achieve our common goals, and to plan for a future that enhances our high 

quality of life while protecting a permanently sustainable natural environment.

Our vision is to protect the unique quality of life characteristics within each of 

Yavapai County’s diverse communities, to preserve our Western rural and 

ranching traditions, and to responsibly manage the process of urbanizing 

communities, when desired, through sensible planned growth and the 

sustainable use of finite resources. This vision is a reflection of the shared 

desire to protect and enhance rural character; small town friendliness; 

abundant natural open spaces, public lands, and scenic vistas; and to ensure the 

compatibility between rural and urbanizing areas. To best serve a diverse 

population, our vision is to be flexible and adaptable to the wide variety of 

needs within the County’s distinct regions.”

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 569
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Kane County 

Resource 

Management 

Plan (2011)

Kane 

County, 

Utah

The major provisions in the resource management plan that guide Federal 

resource management coordination with State and local governments are: 

(1) preserve traditional multiple use/sustained yield management processes; 

(2) do not employ management prescriptions that parallel, duplicate, or 

resemble wilderness management without congressional designation of 

wilderness areas; (3) coordinate inventories for wilderness characteristics with 

state and local governments; (4) achieve and maintain highest reasonably 

sustainable levels of energy, hard rock (including nuclear) resources; 

(5) achieve and maintain highest reasonably sustainable levels of livestock 

grazing; (6) achieve and maintain highest reasonably sustainable levels of 

watersheds; (7) preserve traditional access for recreational opportunities; 

(8) recognize and incorporate county transportation plans for motorized access; 

(9) protect and preserve cultural resources in cooperation with the State 

Historic Preservation Office; (10) preserve rights of access to private property; 

(11) recognize and incorporate State School and Institutional Trust Lands 

Administration fiduciary agreement provisions when planning for uses near 

trust lands; (12) oppose the designation of areas of critical environmental 

concern (ACECs) except in well documented special cases; (13) coordinate 

visual resource management provisions with State and local governments. 

Class I and II VRM designations are generally not compatible with state and 

local plans; and (14) include a comprehensive socioeconomic analysis in all 

decision documents. Note: This plan was signed in November 2011, following 

development of the draft plan and DEIS. 

Mohave 

County 

General Plan 

(Draft)

Mohave 

County

Key natural resource goals include: (1) maintain and improve air quality; 

(2) preserve the quantity and quality of water resources in perpetuity; 

(3) hillside protection; (4) wetland protection; (5) habitat preservation; 

(6) minimizing excessive noise; and (7) preserve, protect and enhance scenic 

routes and vistas that characterize the rural beauty of Mohave County. 

Local

Tusayan Area 

Plan (adopted 

April 7, 1995 

and amended 

May 5, 1997)

Coconino 

County, 

Arizona

Most of the goals for the Tusayan plan are focused on infrastructure to support 

the vision statement as a gateway to Grand Canyon National Park. Natural 

resource goals include: (1) quality of all surface waters and groundwaters shall 

be protected to preserve or improve existing qualit; (2) every effort shall be 

made to preserve or improve air quality; (3) every effort shall be made to 

minimize the amount of outdoor lighting in order to preserve the dark night 

sky without jeopardizing reasonable utility, safety, and security concerns; 

(4) the community shall make every attempt to protect and improve the 

aesthetic and audio quality of the environment and to prevent negative impacts 

on property values and quality of life; and (5) the community, including public 

agencies, shall protect and preserve native vegetation and wildlife habitat 

areas, and shall especially seek to protect unique natural areas and rare 

endangered plant and animal species.

570 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

City of 

Williams 

General Plan 

(2003)

City of 

Williams

Goals: Continued respect for the natural environment, balanced economy, 

affordable housing, spaciousness for outdoor recreation, and support business 

diversity and the hospitality industry attractions.

Objectives: (1) develop pathway systems tied to Forest Service trails; 

(2) protect water availability and quality; (3) maintain the integrity of the golf 

course and other recreation areas; and (4) mitigate negative impacts to the 

city’s land, air, and water resources

Strategies include: (1) use scenic easements and buffering techniques to retain 

picturesque, spacious character; (2) cooperate with Coconino County and the 

Forest Service to prevent the degradation of the forests, waters, and other 

natural assets; and (3) evaluate development suitability and consider protective 

measures for habitat wildlife corridors and natural vegetation.

Greater 

Williams Area 

Community 

Wildfire 

Protection Plan

(WACWPP)

(2005)

Multiparty The WACWPP contains the following strategic goals: (1) create the greater 

Williams area community base map, define the wildland-urban interface at 

risk, and perform a risk analysis to identify priority areas for treatment on 

Federal, State, and private lands; (2) offer a wide range of treatment options 

for use on Federal, State, and private lands; (3) educate the public in firewise 

treatments around their homes as well as ways to reduce structural ignitability 

through fuels treatment, defensible space, and use of fire resistant building 

materials; (4) educate the public in hazardous fuels treatments needed in the 

wildland urban-interface to not only protect lives and infrastructure, but also to 

protect the ecosystems that are so valuable in the Williams area; (5) improve 

fire prevention and suppression efforts; (6) reduce hazardous forest fuels; 

(7) promote community involvement in the CWPP process and fuels 

treatments; (8) provide options for the city and fire districts to reduce structure 

ignitability; and (9) encourage development of small wood processing 

businesses to aid in funding the necessary fuels treatments as well as promote 

economic development in the area.

The Code of 

the Town of 

Fredonia

Town of 

Fredonia

Focus of the Fredonia Town Code is on providing town infrastructure and 

services. Fredonia’s niche is as the gateway to Grand Canyon National Park’s 

North Rim. Much of the business growth in Fredonia centers around the 

provision of services for the community.

Tusayan 

Community 

Wildfire

Protection Plan

(TCWPP)

(2005)

Multiparty The goals of the TCWPP are to: promote community involvement in the 

TCWPP process, improve fire prevention and suppression, reduce hazardous 

forest fuels, restore forest health, educate the public in firewise treatments 

around their homes and businesses to reduce structural ignitability in the 

TCWPP area, recommend measures to create a more wildfire defensible 

community, and support HFRA, Title II- Biomass, Section 201-203.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 571
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Community 

Wildfire 

Protection Plan 

for the

Flagstaff and 

Surrounding 

Communities 

in the 

Coconino and 

Kaibab 

National 

Forests (2005)

Multiparty To protect Flagstaff, surrounding communities, and associated values and 

infrastructure from catastrophic wildfire through: (a) an educated and involved 

public; (b) implementation of forest treatment projects designed to reduce 

wildfire threat and improve long-term forest health, in a progressive and 

prioritized manner; and (c) utilization of Firewise building techniques and 

principles. 

Tribal

Hopi 

Woodland 

Management 

Plan (2006)

The Hopi 

Tribe

The Hopi Woodland Management Plan is an integrated resource management 

plan for the almost 200,000 acres of pinyon-juniper woodlands on the Hopi 

Reservation. The primary objective: protection of woodland spiritual and 

cultural values, while providing tribal members with the opportunity to harvest 

subsistence amounts of firewood and fencing material. Other objectives 

include protection and provision of traditionally used resources; wildlife 

habitat; watersheds; threatened, endangered, and culturally sensitive species;

prevention of noxious weed invasion; protection and restoration of riparian 

areas; and promoting pinyon nut harvest. 

Navajo Nation 

Forestry Plan 

(2001)

Navajo 

Nation 

Forestry 

Departmen

t

The Navajo Nation Forestry Department manages about 600,000 acres of 

ponderosa pine and mixed conifer forest and about 4.8 million acres of pinyonjuniper woodlands and provides for the protection and management of the 

Navajo Nation’s forest and woodland resources in a manner that benefits the 

Navajo Nation and all tribal members.

Hualapai Fire 

Management 

Plan (2002) 

and Watershed 

Management 

Plan (2006)

Hualapai 

Tribe 

Departmen

t of Natural 

Resources

The overall goal of the Haulapai Department of Natural Resources is to 

produce long-term, sustainable, balanced, multiple use of natural resources 

under the direction of the Hualapai Tribal Council.

The fire management plan includes goals to: (1) protect human safety and 

property while managing timber and range resources sustainably; (2) maintain 

adequate air and water quality; and (3) reduce the likelihood of catastrophic 

fire. The 2006 Watershed Management Plan includes identification of 

nonpoint source pollution sources and associated mitigation actions to improve 

water quality in the Colorado River and within the Truxton Wash and Upper 

Gila watersheds. The tribe is actively managing endangered native fish and an 

active elk hunting program.

572 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Federal 

Recovery Plan 

for the 

Mexican 

Spotted Owl 

(2012)

U.S. Fish 

and 

Wildlife 

Service

Provides general guidance for activities in the Mexican spotted owl recovery 

unit which helps to maintain consistency with other agency planning efforts. 

Recovery Plan 

for the 

California 

Condor (1996)

U.S. Fish 

and 

Wildlife 

Service

Provides general guidance for activities in the California Condor 10(j) 

Experimental Range which helps to maintain consistency with other agency 

planning efforts.

Recovery Plan 

for the Apache 

Trout (2009)

U.S. Fish 

and 

Wildlife 

Service

Provides general guidance for activities in Apache trout habitat which helps to 

maintain consistency with other agency planning efforts.

U.S. Fish and 

Wildlife 

Service Draft 

Land-Based 

Wind Energy 

Guidelines

Recommendations on 

measures to 

avoid, 

minimize, and 

compensate for 

effects to fish, 

wildlife, and 

their habitats

U.S. Fish 

and 

Wildlife 

Service

Addresses risks to fish and wildlife resources. These draft guidelines, when 

used in concert with the appropriate regulatory tools, will be the best practical 

approach for conservation of species of “Federal trust responsibility.” These 

draft guidelines are intended to: (1) promote compliance with relevant wildlife 

laws and statutes; (2) encourage scientifically rigorous survey, “monitoring,”

assessment, and research designs proportionate to the “risk” to “affected 

species;” (3) produce potentially comparable data across the Nation; (4) avoid, 

minimize, and/or compensate for potential adverse effects on fish, wildlife, and 

their habitats; and (5) improve the ability to predict and resolve effects locally, 

regionally, and nationally.

A National 

Plan for 

Assisting 

States, Federal 

Agencies, and 

Tribes in 

Managing 

White-Nose 

Syndrome in 

Bats (2011)

U.S. Fish 

and 

Wildlife 

Service

This plan provides a coordinated national management strategy for 

investigating the cause of white-nose syndrome and finding a means to prevent 

the spread of the disease. 

General Land 

Management 

Plan for the 

Grand Canyon 

National Park

(1995)

Grand 

Canyon

National 

Park

Focuses on desired conditions, monitoring, and adaptive management with 

mutually common goals of promoting native vegetative communities and 

ecological processes. These goals should help to provide healthy habitat for 

wildlife and sustainable, resilient ecosystems over the greater landscape.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 573
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

North Rim 

Development 

Plan for the 

Grand Canyon 

National Park

Grand 

Canyon 

National 

Park

The North Rim Development Plan outlines a number of enhancements in 

visitor services, structure utilization, employee housing, and 

vehicular/pedestrian circulation for the North Rim Unit of Grand Canyon 

National Park. 

The North Rim Development Plan also includes the mitigation measures 

outlined in the FONSI and Programmatic Agreement developed as part of the 

NEPA and NHPA compliance completed for the plan and an estimate of the 

implementation costs for all plan components. The appendix includes an 

analysis of visitation and transportation, recommendations for employee 

housing, and a more detailed breakdown of building rehabilitation needs and 

costs.

Fire 

Management 

Plan for Grand 

Canyon 

National Park 

(2012)

Grand 

Canyon 

National

Park

Specifies a mixed fire treatment program. Defines new fire management units 

which include suppression, wildland fire use, and prescribed fires and nonfire 

treatments with additional options of mechanical and manual hazard fuel 

treatment techniques. The focus is on restoring and maintaining park 

ecosystems with prescribed and wildland fire-use fire and reducing hazard 

fuels in wildland-urban interface areas using prescribed fire and nonfire 

treatments.

BLM-Arizona 

Strip Resource 

Management 

Plan (2008)

BLM Focuses on desired conditions, monitoring, and adaptive management with 

mutually common goals of promoting native vegetative communities and 

ecological processes. These goals should help to provide healthy habitat for 

wildlife and sustainable, resilient ecosystems over the greater landscape.

Coconino, 

Prescott, and 

ApacheSitgreaves 

National 

Forests draft 

land 

management 

plans (in 

revision)

USDA 

Forest 

Service

Forest planning efforts based upon the same regional vegetative desired 

conditions, standards, and guidelines, and similar objectives for ponderosa 

pine and mixed conifer as the Kaibab NF. The cumulative restoration activities 

from the action alternatives from these plans could have a landscape level 

effect on modifying stand structure to reduce the risk of stand-replacing fire in 

these vegetation types, while promoting resiliency with regard to climate 

change. 

Four Forest 

Restoration 

Project

(4FRI)

Coconino, 

Kaibab, 

ApacheSitgreaves, 

and Tonto 

National 

Forests

A large-scale planning effort in the adjacent vicinity focused on improving 

resiliency in fire-adapted ecosystems. If implemented, the 4FRI could treat up 

to 55,000 acres annually across the Kaibab NF and adjacent NFS lands. The 

cumulative effect of this process could have widespread beneficial outcomes in 

restoration across the forest including decreased susceptibility to large 

disturbances (e.g., uncharacteristic wildfire and insect outbreaks) and increased 

water yields from winter snowfall through the creation of interspaces. The 

scale of this project is such that these changes could have a meaningful impact 

on wildlife habitat by improving adaptability of ponderosa pine type to a 

changing climate and providing for it well into the future.

574 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix L. Collaboration and Coordination with Other Planning Efforts

Table L 2. Planning and land use policies of State, local, tribal governments and other 

Federal agencies in the greater landscape

Planning 

Document Agency Description

Camp Navajo 

Integrated 

Resource 

Management 

Plan (INRMP)

Departmen

t of 

Defense

The INRMP provides information on the management of natural resources on 

Camp Navajo. It describes the setting, defines land management units, and the 

manner that they will be managed to sustain ecological functions and ensure 

that Camp Navajo can support present and future training and testing 

requirements while maintaining, improving, and enhancing ecosystem 

integrity. Goals include: (1) protect sensitive and other nongame species; 

(2) provide sustained military training and outdoor recreation opportunities: 

(3) preserve desert washes and native vegetation, protection of special areas, 

water and wildlife management, wildfire prevention, and pest management; 

and (4) making lands available to the public for educational or recreational use 

of natural and cultural resources.

Strategies include: implementation of an ecosystem management philosophy, 

implementation of the full Integrated Training Area Management Program, 

use of the Land Rehabilitation and Maintenance component of Integrated 

Training Area Management to plan rehabilitation projects for damaged areas, a 

study to determine methods for managing and restoring old growth forests, 

planning and implementing thinning, and prescribed burning. 

Memorandum 

of 

Understanding 

(MOU)

California 

Condor

Multiparty Establishes a general framework for cooperation and participation among all 

cooperators to promote the recovery of the California condor. The MOU 

applies to the Southwest California condor reintroduction program and 

designated nonessential experimental population.

National Best 

Management 

Practices for 

Water Quality 

Management 

on National 

Forest System 

Lands (2012)

USDA 

Forest 

Service

“This technical guide is the first volume of guidance for the Forest Service, 

U.S. Department of Agriculture, National Best Management Practices (BMP) 

Program. The National BMP Program was developed to improve agency 

performance and accountability in managing water quality consistent with the 

Federal Clean Water Act (CWA) and State water quality programs. Current 

Forest Service policy directs compliance with required CWA permits and State 

regulations and requires the use of BMPs to control nonpoint source pollution 

to meet applicable water quality standards and other CWA requirements.”

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 575

Appendix M. Crosswalk Between Key Direction from the 1988 Forest 

Plan (as amended) and the Revised Forest Plan

The intent of this appendix is to provide greater transparency on how existing plan direction (e.g. standards and guidelines) was incorporated into 

the revised plan. The following table is not an exhaustive account of all plan direction, but rather highlights those issues that drove the plan revision 

process (e.g. priority needs for change) and or were critical to Appendix A (response to comments). The revised plan is strategic in nature, as such; 

many of the standards and guidelines in the current plan were reframed as desired conditions or guidelines in the revised plan. In other instances, 

existing plan guidance was modified or removed because it reiterated other law, regulation, or policy.

KEY

Plan Components

DC: Desired Conditions, OBJ: Objective, ST: Standard, GD: Guideline, MA: Management Area, EMA: Ecosystem Management Area.

Vegetation

PP: Ponderosa pine, MC: Mixed conifer, DBH: Diameter at Breast Height, DRC: Diameter at Root Collar, BA: Basal Area

Wildlife

ESA: Endangered Species Act, MBTA: Migratory Bird Treaty Act, MSO RP: Mexican spotted Owl Recovery Plan, FWS: Fish and Wildlife 

Service. TES: Threatened, Endangered, and Sensitive Species, MIS: Management Indicator Species, NOGO: Northern Goshawk, PAC: Protected 

Activity Center, MRNG: Management Recommendations for Northern Goshawk (GTR-217), AGFD: Arizona Game and Fish Department, NNL: 

National Natural Landmark

Other 

FSM: Forest Service Manual, FSH: Forest Service Handbook, BMP: Best Management Practice, MOU: Memorandum of Understanding, SDWA: 

Safe Drinking Water Act, 1988 Land Management Plan (as amended): 1988 plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Facilities Management Direction for EMA 4:

Maintain Kendrick Mountain lookout 

tower to present state. Prevent 

expansion of lookout tower and 

electronic facilities. Service and 

maintain facilities by primitive means.

GD for Wilderness Area: The fire lookout on Kendrick Mountain should 

be supplied and maintained using non-motorized equipment and nonmechanized transport.

FSM 7310 Under the 1988 plan this was 

rather vague direction, neither a 

ST nor GD.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 577
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Facilities Potable Water Management for 

EMA 21: Monitor potable water 

systems in accordance with Safe 

Drinking Water Act.

DC for Potable Water: Potable water systems are safe for human 

consumption.

SWDA Under the 1988 plan this was 

rather vague direction, neither a 

ST nor GD. Redundant with other 

law.

Fire Treatment of Natural Fuels for 

EMA 4: Use fire with both prescribed 

fire and wildland fire use to break up 

unnaturally large areas of continuous 

fuel and create a more natural 

"mosaic" of fuelbeds. Target stand 

size is 50 to 150 acres.

PP and Frequent Fire MC DCs mid-scale: Fires burn primarily on the 

forest floor and typically do not spread between tree groups as crown fire. 

OBJ for Ponderosa Pine: Treat an average of 13,000 to 55,000 acres 

annually, using a combination of prescribed fire and naturally ignited 

wildfires. OBJ for Frequent Fire MC: Burn an average of 1,000 to 13,000 

acres annually, using prescribed fire and/or naturally ignited wildfires. GD 

for Vegetation Management: The location and layout of vegetation 

management activities should effectively disconnect large expanses of 

continuous predicted active crown fire. 

Federal 

Wildland 

Fire Policy 

(2001), 

ESA

Under the 1988 plan, the 

direction was rather vague, 

neither a ST nor GD. However, 

the terms and conditions in the 

Biological Opinion for the 

Environmental Assessment of a 

Wildland Fire Use Program within 

the Kaibab NF did not allow 

management of wildfires for 

resource benefits in the mixed 

conifer types on the NKRD, and 

set prescriptive limits within MSO

habitat on the Williams District.

Revised as DCs OBJs, GDs in 

the new plan.

Fire GDs for Fire Protection in EMAs, 2, 

10, 13: Fires from unplanned natural 

ignitions may exceed these size limits 

when burning within a predetermined 

prescription approved area and 

declared a prescribed fire wildland 

fire use action.

MA in Wildland Fire Management: In areas moderately to highly 

departed from desired conditions, somewhat higher fire intensities and the 

associated fire effects may be acceptable or even desirable at the fine 

scale to move fire behavior toward desired conditions. Multiple small areas 

of high mortality are preferred over a single large, high-severity event.

Guidance 

for the 

Implementa

tion of 

Federal 

Wildland 

Fire 

Manageme

nt Policy, 

2009

Covered under other direction.

578 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Fire/

Wildlife

Fire Management Planning and 

Analyses for EMA 19: Protect the 

aquatic habitat in North Canyon. The 

maximum size objective for any fire 

within a two mile radius of North 

Canyon Spring is 5 acres. Initial 

Attack Fire Suppression: Use 

appropriate suppression methods to

control all wildfires within a 2-mile 

radius of

North Canyon Spring. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

DCs for Wilderness: A reproducing population of Apache trout is 

maintained in North Canyon Creek. 

STs for Wildfire Management: Managers will use a decision support 

process to guide and document wildfire management decisions. 

GDs for Wildfire Management: Decision documents, which define the 

objectives and document line officer approval of the strategies chosen for 

wildfires that progress past initial attack, should include interdisciplinary 

input to assess site-specific values at risk and develop incident objectives 

and courses of action to enhance or protect those values. At a minimum, 

the interdisciplinary team should: “Develop objectives and courses of 

action to address the desired conditions for wildlife habitat and key habitat 

features such as snags, logs, large tree-form oaks, and oak thickets."

ESA In the 1988 plan, it is unclear 

what kind of management 

direction this is, not specifically 

labeled as ST or GD. Some of 

this direction is redundant with 

other law and policy. Reframed 

as explicit STs, GDs, and DCs in 

new plan.

Fire GDs for Fire Protection: Fires which 

exceed or are expected to exceed 

the size objective are considered 

escaped and appropriate response is 

determined by an escaped fire 

situation analysis (EFSA). The EFSA 

will consider at least the following: 

Ignition source of the fire (lightning or 

person-caused). 2. If lightning 

caused, the appropriateness of the 

predicted burn with respect to the 

objectives of fire management in 

wilderness. 3. Resource 

management emphasis and 

protection objectives of threatened 

management area. 4. Suppression 

costs commensurate with resources 

protected. 5. Effects of suppression 

tactics on wilderness values, air 

quality, aesthetics, soil, and 

watershed. 6. Social acceptance of 

acreage burned. 7. Current 

availability of suppression resources. 

8. Safety of personnel.

ST for Wildland Fire Management: Initial action on human-caused 

wildfires will be to suppress the fire at the lowest cost with the fewest 

negative consequences with respect to firefighter and public safety. 

Managers will use a decision support process to guide and document 

wildfire management decisions.

Federal 

Wildland 

Fire Policy, 

2001, 

Guidance 

for the 

Implementa

tion of 

Federal 

Wildland 

Fire 

Manageme

nt Policy, 

2009

Direction was elevated to a 

standard in the revised plan and 

reflects more current fire decision 

policy.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 579
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Standards for EMAs 1, 3, 8, 9, 

12&16: Provide for the following snag 

and other tree objectives: 1. 

Regionally consistent Standards and 

Guidelines apply for snag 

management in ponderosa pine, 

mixed conifer and spruce-fir cover 

types. 2. Pinyon-juniper type: not less 

than 100 snags et al., 9 inches and 

larger DRC and 12 feet in height, per 

100 acres over 65 percent of the 

forested area. 

GDs Vegetation Management in all Forested Communities : Project 

design and treatment prescriptions should generally not remove: Large, 

old ponderosa pine trees with reddish-yellow, wide platy bark, flattened 

tops, with moderate to full crowns and large drooping or gnarled limbs 

(e.g. Thomson’s age class 4, Dunning’s tree class 5 and/or Keen’s Tree 

Class 4, A and B [appendix C]). Mature trees with large dwarf mistletoe 

induced witches’ brooms suitable for wildlife nesting, caching, and 

denning, except where retaining such trees would prevent the desired 

development of uneven-aged conditions over time. Large snags, partial 

snags, and trees (>18 inches dbh.) with broken tops, cavities, sloughing 

bark, lightning scars >4 inches wide, and large stick nests (>18 inches in 

diameter). DCs for Ponderosa Pine (Mid-scale): Snags 18 inches 

diameter at breast height (d.b.h.) or greater average 1 to 2 snags per acre. 

Snags and green snags of various sizes and forms are common. (Landscape-scale: The ponderosa pine forest is composed predominantly of 

vigorous trees, but declining trees are present. Snags, green snags, and 

coarse woody debris occur across the landscape. DCs for Frequent Fire 

MC (Mid-scale): Snags and green snags 18 inches d.b.h. or greater 

average three per acre. Downed logs (greater than 12 inches diameter at 

mid-point and greater than 8 feet long) average three per acre within the 

forested area of mid-scale units. Coarse woody debris, including downed 

logs, ranges from 5 to 15 tons per acre.(Land-scape scale): The frequent 

fire mixed conifer forest community is composed predominantly of 

vigorous trees, but declining trees (e.g. snags, top killed, lightning and fire 

scarred trees) and coarse woody debris (greater than 3 inches diameter) 

are present and well distributed throughout the landscape. Mesic 

MC/Spruce Fir (Mid-scale): The number of snags and downed logs 

(greater than 12 inches diameter at mid-point, over 8 feet long) and coarse 

woody debris (greater than 3 inches diameter) vary by seral stage. Snags 

18 inches or greater d.b.h. typically range from one to five snags per acre, 

with the lower range associated with early seral stages and the upper 

range associated with late seral stages. (Land-scape scale): The 

landscape is composed predominantly of vigorous trees, but older 

declining trees (e.g. snags and top killed, lightning-, and fire-scarred 

trees), as well as coarse woody debris, are present.

DCs for All Pinyon-juniper Communities: The mature groups of trees 

are structurally diverse, containing large live trees, as well as trees with 

dead or broken tops, gnarls, and burls. Snags, green snags, and downed 

trees > 10′′ at root collar are present and average 1 to 2 per acre. Some 

Confusing as written in the 1988 

plan, a standard that references 

both STs and GDs, the majority 

of snag direction is actually GDs. 

Direction has been reframed as 

forest-wide GDs and DCs for 

respective vegetation types. 

More information on snag 

densities has become available 

since the 1988 plan was signed, 

but still snag dynamics are poorly 

understood and reflect wide 

ranges in spatial and temporal 

variability across the different 

vegetation types. 

580 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

tree groups have 30 to 40 percent canopy cover that provides habitat for 

nesting, bedding, and foraging. GDs for Pinyon-juniper: Where pinyonjuniper obligate species occur (e.g. gray vireo), project design should use 

methods (e.g. selective pruning, lop and drop etc.) that emphasize the 

retention of key habitat features including snags, and partially dead or 

dying trees, and downed logs. 

Forestry/

Wildlife

GDs for non-structural habitat 

improvements for EMAs 

1,3,8,9,12,16 a. Manage Gambel oak 

for increased hard mast production, 

cavities, and deciduous foliage 

volume to promote and enhance 

wildlife habitat. 

GDs for Vegetation Management in all Forested Communities: Project 

design and treatment prescriptions should generally not remove: Gambel 

oak >8 inches, diameter at root collar. PP DCs fine scale: Large tree form 

oaks, snags, and partial snags with hollow boles or limbs are present. 

Mid-scale: Stands are dominated by ponderosa pine, but other native 

hardwood and conifer species occur. Landscape scale: Where it naturally 

occurs, Gambel oak is present with all structure classes represented. It is 

reproducing and maintaining or expanding its presence on suitable sites 

across the landscape. 

GDs were modified to be more 

explicit and extended forest wide. 

DCs provide aspirational direction 

for GDs.

Forestry/

Wildlife

GD for Range non-structural 

improvement for EMAs 1, 

3,8,9,12,16 Opening is not larger 

than 40 acres excepting that in 

primary pronghorn antelope range. 

DCs for All Pinyon-juniper communities: Pinyon-juniper communities 

occur as a shifting mosaic interspersed with openings across the 

landscape. The configuration of vegetation and openings provides 

foraging and browsing opportunities for wildlife, and enough sighting 

distance and hiding cover for pronghorn to escape predators. 

ST for Vegetation Management in all Forested Communities: The 

maximum size opening that may be created in one harvest operation for 

the purpose of creating an even-aged stand shall not exceed 40 acres 

except when it is following a large-scale disturbance event such as a 

stand replacing fire, wind storm, or insect or disease outbreak.

Direction replaced by forest wide 

DCs for pinyon-juniper 

communities and ST on 

maximum opening size.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 581
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

GD for EMAs 1, 3, 8, 9, 12&13:

Pronghorn antelope habitat: a. In key 

antelope ranges, maintain existing 

openings and create additional 

openings as provided for in Wildlife 

Non-structural Habitat Improvement 

[HB]. Provide for high forb 

composition (25 percent). a. In 

antelope range, remove all net wire 

fences; in the interim, modify every 

one-half mile of such fence to 

facilitate movement. 

DCs for Wildlife: Grasses, forbs, and shrubs provide forage, cover, 

fawning, and nesting sites. Interconnected forest and grassland habitats 

allow for movement of wide ranging species and promote natural predatorprey relationships, particularly for strongly interactive species (e.g., 

mountain lions). Habitat configuration and availability allow wildlife 

populations to adjust their movements (e.g., seasonal migration, foraging, 

etc.) in response to climate change and promote genetic flow between 

wildlife populations. Human-wildlife conflicts are minimal. Hunting, fishing 

and other wildlife based recreation opportunities exist, but do not 

compromise species populations or habitat. DCs for All Grasslands:

Vegetation is dominated by herbaceous plants composed of a mix of 

native grasses and forbs. In pronghorn habitat, understory vegetation 

provides cover for fawning. Vegetation composition is within the natural 

range of variability and contains diverse native herbaceous plant species 

that provide nutrition for pronghorn and other species. Depending on soil 

type, bare soil varies between 5 and 80 percent. Basal vegetation varies 

between 5 and 60 percent ground cover. Organic litter varies between 30 

and 50 percent of the ground cover. Vegetation composition will average 

40 to 60 percent grass, and 10 to 30 percent forbs. OBJs for Restoring 

Grasslands: To restore the extent and quality of grasslands and 

grassland habitat: Reduce tree density to less than 10 percent on 5,000 to 

10,000 acres of historic grasslands annually. Modify fences and/or install 

crossings to facilitate pronghorn movement on 50 miles of fence within 10 

years of plan approval. GDs: Pronghorn fence crossings should be 

installed along known movement corridors. In areas where native 

herbaceous cover is sparse and seed sources are depleted, seeding 

should be considered. DCs for Livestock Grazing: Allotment fencing 

allows for passage of animals susceptible to movement restrictions such 

as pronghorn. GDs: Livestock management should favor the 

development of native cool season grasses and forbs. New construction 

and reconstruction of fences should have a barbless bottom wire that is at 

least 18 inches high.

Revised plan actually has more 

GDs and plan guidance for 

pronghorn, a species which has 

been retained as an MIS. Most 

net wire on the forest has been 

removed since the 1988 plan was 

signed and new GDs better 

reflect BMPs for fence

construction. 

582 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

GD for EMAs 1, 3 8, 9, 12&13, Red 

squirrel habitat: a. Manage for at 

least 40 percent of potential habitat 

capability for red squirrels in 

assessment areas as determined by 

the Forest Habitat Capability Model. 

As needed to meet habitat capability, 

protect red squirrel primary caches at 

a density of one cache per two acres. 

Retain all trees within a 26-foot onehalf chain radius from the cache 

(1/20 acre mixed-conifer only). This 

does not apply to regeneration areas. 

DCs for Wildlife: Habitat is available at the appropriate spatial, temporal, 

compositional, and structural levels such that it provides adequate 

opportunity for breeding, feeding, nesting, and carrying out other critical 

life cycle needs for a variety of vertebrate and invertebrate species. 

Species with specific habitat needs (e.g. snags, logs, large trees, 

interlocking canopy, and cavities) are provided for. GDs for Wildlife 

Management: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of wildlife, 

particularly for raptors. Management Approach for Wildlife: The Kaibab 

NF strives to create and maintain natural communities and habitats in the 

amounts, arrangements, and conditions capable of supporting viable 

populations of existing native and desired nonnative plant, aquatic, and 

wildlife species within the planning area while contributing to broader 

landscape-scale initiatives where appropriate......The Kaibab NF 

references current literature and the best available science when making 

site specific decisions relevant to project planning. This is done in an 

interdisciplinary context with input from other resource specialists.

Overly prescriptive at the Forest 

plan level; project /site specific. 

Squirrels are not being carried 

forward as an MIS; hunted 

species. Viability for red squirrels 

was provided through the coursefilter analysis and vegetation 

components. No additional finefilter components were necessary 

at the plan level.

Forestry/

Wildlife

Wildlife Habitat ST for EMAs 1, 3, 

8, 9, 12,16: Snags and cavity, cull 

and damaged trees: Select larger 

trees for retention from the following 

categories in sequence: a. Existing 

snags and dying trees. b. Living trees 

with cavities. c. Trees with dead tops, 

spike tops, and damaged tops. d. 

Living cull and damaged trees. e. 

Living diseased trees, excepting 

mistletoe infected trees, not 

accounted for in 1 through 4 above. f. 

Living healthy trees. g. Avoid 

retention of mistletoe infected trees. 

Intensively manage emphasis areas 

(forest opening edges, water 

sources) to meet snag et al. 

objectives.

GDs for Vegetation Management in All Forested Communities:

Project design and treatment prescriptions should generally not remove: 

Mature trees with large dwarf mistletoe induced witches’ brooms suitable 

for wildlife nesting, caching, and denning, except where retaining such 

trees would prevent the desired development of uneven-aged conditions 

over time. Large snags, partial snags, and trees (>18 inches d.b.h.) with 

broken tops, cavities, sloughing bark, lightning scars >4 inches wide, and 

large stick nests (>18 inches in diameter). Also see DCs for Ponderosa 

Pine, Frequent Fire Mixed Conifer and Mesic Mixed Conifer for 

description of snags to be retained.

 

Revised as forest wide GDs and 

DCs.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 583
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Wildlife Habitat ST 1, 3, 8, 9, 12, 16: 

Raptor habitat except goshawk and 

MSO. Bald eagle: a. Provide a 10-

chain uncut buffer zone around 

existing and potential bald eagle 

winter roosts. b. Identify and protect 

foraging perches and potential roost

sites. 

GDs for Wildlife: Project activities and special uses should be designed 

and implemented to maintain refugia and critical life cycle needs of 

wildlife, particularly for raptors. Potentially disturbing project-related 

activities should be restricted within 300 yards of active raptor nest sites 

between April 1 and August 15. GDs for TES: Activities occurring near 

areas used by bald eagles should follow recommendations identified in the 

National Bald Eagle Management Guidelines and Arizona Conservation 

Assessment and Strategy for the Bald Eagle. Management Approach 

Wildlife: The Kaibab NF references current literature and the best 

available science when making site specific decisions relevant to project 

planning. This is done in an interdisciplinary context with input from other 

resource specialists. For example; the wildlife guideline specifying 

disturbance buffers around raptor nests is intended as a minimum buffer. 

Some raptor species (e.g., osprey) are more adapted to disturbance and 

are likely to tolerate a buffer of just 300 yards during the breeding season 

while other, less tolerant species (e.g. peregrine falcons (Falco 

peregrinus)) may require buffers of up to a 1⁄2 mile. Wildlife biologists work 

with other IDT resource specialists to identify and define the appropriate 

site specific buffers (within the context of plan guidance) for other raptors 

on a case-by-case basis.

MBTA, Bald 

and Gold 

Eagle 

Protection 

Act, FSM 

2670.32

Bald eagles have been delisted 

since the 1988 plan was signed. 

They are still a sensitive species 

and are protected through other 

mandates in addition to the forest 

plan. STs were revised as GDs.

584 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Wildlife Habitat ST 1, 3, 8, 9, 12, 16:

Raptor habitat except northern 

goshawk and Mexican spotted owl. 

Retain raptor nest tree-groups and a 

non-activity buffer around raptor nest 

sites as follows: Cooper's hawk: 7-

chain buffer zone around the nest, 

Sharp-shinned hawk: 6-chain buffer 

zone around the nest. Osprey: 

Provide an 8-chain uncut buffer area 

around existing (occupied or 

unoccupied) nests. Restrict logging 

activities within 20 chains of active 

nest sites between April 1 and 

August 15. Provide, for every ten 

surface acres of water, not less than 

five acres of mature and overmature 

trees with not less than four snags, 

with heights, equal to, or greater 

than, the surrounding trees, and not 

less than 20 inches in DBH, per acre, 

for potential osprey nesting sites. 

Provide uneven-aged and, or 

irregular-aged stand conditions within 

a 10-chain zone around aquatic 

areas with five or more surface-acres 

of water. Provide artificial nesting 

platforms as needed for habitat 

improvement. Prohibit road 

construction in roost areas and buffer 

zones. Others: 3-chain buffer zone

around the nest. 

GDs for Wildlife: Project activities and special uses should be designed 

and implemented to maintain refugia and critical life cycle needs of 

wildlife, particularly for raptors. Potentially disturbing project-related 

activities should be restricted within 300 yards of active raptor nest sites 

between April 1 and August 15. Management Approach Wildlife: The 

Kaibab NF references current literature and the best available science 

when making site specific decisions relevant to project planning. This is 

done in an interdisciplinary context with input from other resource 

specialists. For example; the wildlife guideline specifying disturbance 

buffers around raptor nests is intended as a minimum buffer. Some raptor 

species (e.g., osprey) are more adapted to disturbance and are likely to 

tolerate a buffer of just 300 yards during the breeding season while other, 

less tolerant species (e.g. peregrine falcons (Falco peregrinus)) may 

require buffers of up to a 1⁄2 mile. Wildlife biologists work with other IDT 

resource specialists to identify and define the appropriate site specific 

buffers (within the context of plan guidance) for other raptors on a caseby-case basis.

MBTA, 

Executive 

Order 

13186

As written are overly prescriptive 

at the plan level. Specifications 

may vary by project and site. STs 

revised as GDs.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 585
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Wildlife Habitat STs for EMAs 1, 

3,8,9,12,16. Peregrine falcon habitat. 

a. Prohibit activities which disturb 

nesting birds between March 15 and 

August 15. If birds arrive in their 

territories before March 15, suspend 

disturbing activities immediately. 

Extend this period if the birds are 

strongly attached to the nest site after 

August 15. b. Take all reasonable 

precautions, consistent with policies 

regarding jeopardy to human life and 

property, during fire suppression, 

search and rescue, or other 

emergency operations from March 15 

through August 15 to protect 

peregrine nesting sites and their 

confidentiality.

GDs for Wildlife: Project activities and special uses should be designed 

and implemented to maintain refugia and critical life cycle needs of 

wildlife, particularly for raptors. Potentially disturbing project-related 

activities should be restricted within 300 yards of active raptor nest sites 

between April 1 and August 15. GD for TES: Project activities and special 

uses should be designed and implemented to maintain refugia and critical 

life cycle needs of Forest Service Sensitive Species. Management 

Approach Wildlife: The Kaibab NF references current literature and the 

best available science when making site specific decisions relevant to 

project planning. This is done in an interdisciplinary context with input from 

other resource specialists. For example; the wildlife guideline specifying 

disturbance buffers around raptor nests is intended as a minimum buffer. 

Some raptor species (e.g., osprey) are more adapted to disturbance and 

are likely to tolerate a buffer of just 300 yards during the breeding season 

while other, less tolerant species (e.g. peregrine falcons (Falco 

peregrinus)) may require buffers of up to a 1⁄2 mile. Wildlife biologists work 

with other IDT resource specialists to identify and define the appropriate 

site specific buffers (within the context of plan guidance) for other raptors 

on a case-by-case basis.

FSM 2670, 

MBTA, 

Executive 

Order 

13186

This species has since been 

federally delisted and is currently 

a regionally sensitive species. 

Protected through other law, 

policy, and direction, but did 

revise STs as GDs. Forest wide 

GDs for raptors and TES species

should provide protection at the 

project level.

Forestry/

Wildlife

Wildlife Habitat ST for EMAs 1, 

3,8,9,12,16. Personal-use fuelwood 

standards. Pinyon Pine: a. Any dead 

and down tree b. any standing dead 

tree less than 12 DRC (10"DBH) c. 

Any standing dead tree less than 12 

feet in height. Personal-use fuelwood 

standards. Gambel oak: a. Any dead 

and down tree. b. Any standing dead 

tree less than 8 inches in DBH. 

Juniper: a. Any dead and down tree. 

b. Any standing dead tree without 

green foliage). c. Any standing dead 

tree less than 15 feet in total height. 

Quaking aspen: a. Any dead and 

down tree. a. Any standing dead tree 

less than 12 inches in DBH. 

GDs for Fuelwood Collection: The following should be permitted for 

personal use firewood gathering: Dead and downed ponderosa pine, 

Douglas-fir, white fir, spruce, juniper, pinyon pine, Gambel oak, and 

aspen; Standing dead: Ponderosa pine, Douglas-fir, white fir, or spruce 

less than 12 inches DBH or less than 15 feet in total height; Juniper 

without green foliage ; Pinyon pine less than 12 inches diameter at DRC

or less than 12 feet in height; Gambel oak less than 8 inches DRC; Aspen 

less than 12 inches DBH, Live trees specifically designated by the Forest 

Service. 

Modified as forest wide GDs for 

fuelwood collection. Additional 

restrictions within plan guidance 

may be defined through the 

special use permit process.

586 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Wildlife Habitat STs for EMAs 1, 

3,8,9,12,16. Turkey habitat: a. Leave 

not less than four turkey roost-tree 

groups per section in turkey winter 

range b. Leave not less than two 

turkey roost-tree groups per section 

in turkey summer range. c. 

Emphasize turkey winter habitat in 

areas within 40 chains of pine 

stringers (pine stringers are defined 

as non-contiguous, linear 

communities of predominately 

ponderosa pine, up to 40 chains in 

width, that extend into pinyon-juniper 

woodland). d. Provide not less than 

10 acres of untreated slash for 

nesting habitat within one-half mile of 

water. Consider slope, canopy, 

distribution and distance to water in 

the selection of treatment areas. e. 

Restrict activities in nesting areas 

from April 15 to July 1. 

DCs for Wildlife: Native wildlife species are distributed throughout their 

potential natural range. Desirable nonnative wildlife species are present 

and in balance with healthy, functioning ecosystems. Habitat is available 

at the appropriate spatial, temporal, compositional, and structural levels 

such that it provides adequate opportunity for breeding, feeding, nesting, 

and carrying out other critical life cycle needs for a variety of vertebrate 

and invertebrate species. Species with specific habitat needs (e.g. snags, 

logs, large trees, interlocking canopy, and cavities) are provided for. 

Grasses, forbs, and shrubs provide forage, cover, fawning, and nesting 

sites. Human-wildlife conflicts are minimal. Hunting, fishing and other 

wildlife based recreation opportunities exist, but do not compromise 

species populations or habitat. GDs for Wildlife: Project activities and 

special uses should be designed and implemented to maintain refugia and 

critical life cycle needs of wildlife, particularly for raptors. GDs for 

Vegetation Management in all Forested Communities: Project design 

and treatment prescriptions should generally not remove: Large, old 

ponderosa pine trees with reddish-yellow, wide platy bark, flattened tops, 

with moderate to full crowns and large drooping or gnarled limbs (e.g. 

Thomson’s age class 4, Dunning’s tree class 5 and/or Keen’s Tree Class 

4, A and B [appendix C]). Management Approach Wildlife: The Kaibab 

NF strives to create and maintain natural communities and habitats in the 

amounts, arrangements, and conditions capable of supporting viable 

populations of existing native and desired nonnative plant, aquatic, and 

wildlife species within the planning area while contributing to broader 

landscape-scale initiatives where appropriate. This is accomplished in an 

integrative fashion by working closely with range, fire, timber, and other 

resource areas to coordinate and maximize activities for wildlife benefit. 

Cooperation with State and federal wildlife management agencies also 

helps to minimize conflicting wildlife resource issues related to hunted, 

fished, and trapped species.

Specific habitat needs will be 

determined at the project level. 

Turkeys not being carried forward 

as an MIS. Turkeys are provided 

for through the course filter 

wildlife viability analyses by 

providing healthy vegetation 

conditions and structural 

diversity. No additional fine filter 

habitat needs were identified as 

plan components. 

Forestry/

Wildlife

Wildlife Habitat ST for EMAs 1, 

3,8,9,12,16. Tassel-eared squirrel 

habitat: a. Manage for at least 40 

percent of potential habitat capability 

for tassel-eared squirrels in 

assessment areas as determined by 

the Forest Habitat Capability Model. 

To maintain habitat capability, retain 

one nest tree group per five acres. 

DC for Wildlife: Native wildlife species are distributed throughout their 

potential natural range. Desirable nonnative wildlife species are present 

and in balance with healthy, functioning ecosystems. Habitat is available 

at the appropriate spatial, temporal, compositional, and structural levels 

such that it provides adequate opportunity for breeding, feeding, nesting, 

and carrying out other critical life cycle needs for a variety of vertebrate 

and invertebrate species. Species with specific habitat needs (e.g. snags, 

logs, large trees, interlocking canopy, and cavities) are provided for. 

Grasses, forbs, and shrubs provide forage, cover, fawning, and nesting 

Tassel-eared squirrel not retained 

as an MIS, models outdated by 

new science and methods. Overly 

prescriptive at the plan level, site 

specific direction. Viability 

provided for through course filter 

analyses (vegetation) no 

additional fine scale habitat 

components were identified for 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 587
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Retain all trees within a 26-foot onehalf chain radius from the nest (1/20 

acre ponderosa pine only). This does 

not apply in regeneration areas. 

sites. Human-wildlife conflicts are minimal. Hunting, fishing and other 

wildlife based recreation opportunities exist, but do not compromise 

species populations or habitat. DC Ponderosa Pine (Fine-scale): Trees 

typically occur in irregularly shaped groups and are variably spaced with 

some tight clumps. Trees within groups are of similar or variable ages and 

may contain species other than ponderosa pine. Tree groups are made up 

of clumps of various age classes and size classes that typically occur in 

areas less than one acre, but may be larger, such as on north-facing 

slopes. Crowns of trees within the mid-aged to old groups are interlocking 

or nearly interlocking and consist of approximately 2 to 40 trees per group. 

Isolated infestations of Southwestern dwarf mistletoe may occur, but the 

degree of severity and amount of mortality varies among the infected 

trees. Witches’ brooms may form on infected trees, providing habitat and 

food for wildlife and invertebrate species. (Mid-scale): Forest conditions 

in some areas contain 10 to 20 percent higher basal area in mid-aged to 

old tree groups than in the general forest (e.g., goshawk post-fledging 

family areas, nesting/roosting habitat, drainages, and steep north-facing 

slopes). DCs Frequent Fire MC (Fine-scale): Dwarf mistletoe infections 

may be present on ponderosa pine and Douglas-fir, and rarely on other 

tree species, but the degree of infection severity and rate of mortality 

varies among infected trees. Witches’ brooms may be present with these 

infestations, providing habitat for wildlife. (Mid-scale): Forest conditions in 

some areas contain 10 to 20 percent higher basal area in mid-aged to old 

tree groups than in the general forest; these include goshawk postfledging family areas (PFAs), Mexican spotted owl nesting/roosting 

habitat, and north-facing slopes. DCs for The Kaibab Squirrel NNL: The 

Kaibab Squirrel NNL provides quality ponderosa pine habitat for the 

Kaibab squirrel. GDs for Vegetation Management in all Forested 

Communities: Mature trees with large dwarf mistletoe induced witches’ 

brooms suitable for wildlife nesting, caching, and denning, except where 

retaining such trees would prevent the desired development of unevenaged conditions over time. 

this species beyond the NNL 

designation for the Kaibab 

squirrel (tassel-eared squirrel 

sub-species)..

588 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

Wildlife Non-structural Habitat 

Improvement GDs EMAs 1, 3, 8, 9, 

12, 16: Gambel oak: Retain all 

standing oak trees eight inches and 

larger at DBH. Quaking aspen: Treat 

aspen using special cutting methods. 

Optimum size of the treatment area is 

four acres although in some 

situations larger areas (10 acres+) 

can be treated. Prohibit grazing of 

improvement areas for not less than 

one growing season immediately 

following treatment. Remove 

coniferous understory during 

treatment. Alligator juniper: Retain 

live, large alligator juniper for wildlife 

habitat where it occurs with 

ponderosa pine.

DCs for Wildlife: Habitat is available at the appropriate spatial, temporal, 

compositional, and structural levels such that it provides adequate 

opportunity for breeding, feeding, nesting, and carrying out other critical 

life cycle needs for a variety of vertebrate and invertebrate species. 

Species with specific habitat needs (e.g. snags, logs, large trees, 

interlocking canopy, and cavities) are provided for. GDs for Vegetation 

Management in all Forested Communities: Gambel oak >8 inches, 

diameter at root collar. GDs for Livestock grazing: Livestock use in 

aspen areas should be authorized at levels that are consistent with the 

desired conditions for aspen regeneration and establishment. 

Management Approach for Wildlife: The Kaibab NF references current 

literature and the best available science when making site specific 

decisions relevant to project planning. This is done in an interdisciplinary 

context with input from other resource specialists. Also see DCs, OBJs, 

and GDs for Aspen.

Revised as forest wide guidance.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 589
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Range/ 

Wildlife

Wildlife Non-structural Habitat 

Improvement GDs for EMAs 1, 

3,8,9,12,16. Created openings in 

pinyon-juniper woodland: Exclude 

livestock from seeded areas for not 

less than two growing seasons 

immediately following treatment. The 

maximum sight distance within the 

opening is 15 chains excepting in 

primary pronghorn antelope range. 

The minimum distance between any 

two openings is 10 chains

DCs for all Pinyon-juniper Communities: Pinyon-juniper communities 

occur as a shifting mosaic interspersed with openings across the 

landscape. The configuration of vegetation and openings provides 

foraging and browsing opportunities for wildlife, and enough sighting 

distance and hiding cover for pronghorn to escape predators. DCs for 

Wildlife: Interconnected forest and grassland habitats allow for movement 

of wide ranging species and promote natural predator-prey relationships, 

particularly for strongly interactive species (e.g., mountain lions). Habitat 

configuration and availability allow wildlife populations to adjust their 

movements (e.g., seasonal migration, foraging, etc.) in response to 

climate change and promote genetic flow between wildlife populations. 

DCs for Livestock Grazing: Livestock use is consistent with other

desired conditions. GDs for Livestock Grazing: Annual operating 

instructions for livestock grazing permittees should ensure livestock 

numbers are balanced with capacity and address any relevant resource 

concerns (e.g., forage production, weeds, fawning habitat, soils, etc.). 

Wildlife Management Approach Management Approach: The Kaibab 

NF strives to create and maintain natural communities and habitats in the 

amounts, arrangements, and conditions capable of supporting viable 

populations of existing native and desired nonnative plant, aquatic, and 

wildlife species within the planning area while contributing to broader 

landscape-scale initiatives where appropriate. This is accomplished in an 

integrative fashion by working closely with range, fire, timber, and other 

resource areas to coordinate and maximize activities for wildlife benefit. 

Cooperation with State and federal wildlife management agencies also 

helps to minimize conflicting wildlife resource issues related to hunted, 

fished, and trapped species.

Overly prescriptive at the plan 

level. Sight distance will vary 

based on topography and 

vegetation, structural diversity 

and composition. Revised as 

forest wide guidance.

590 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry/

Wildlife

GD for Non-structural habitat 

improvement EMAs 1, 3, 8, 9, 12, 

and 16: Gambel oak: Consider age 

class distribution in project planning.

DCs Ponderosa Pine (fine-scale): Where historically occurring, Gambel 

oak thickets with various diameter stems and low growing, shrubby oak 

are present. These thickets provide forage, cover, and habitat for species 

that depend on them such as small mammals, foliage nesting birds, deer, 

and elk. Gambel oak mast (acorns) provides food for wildlife species. 

Large tree form oaks, snags, and partial snags with hollow boles or limbs 

are present. (Land-scape): Where it naturally occurs, Gambel oak is 

present with all structure classes represented. It is reproducing and 

maintaining or expanding its presence within its natural range. DCs 

Gambel Oak Shrublands: The system is dominated by native tall shrubs 

and hardwood trees. Some areas contain many trees with relatively large 

hollow boles or limbs. Coniferous trees are widely scattered and are 

frequently mature or old. Young Gambel oak thickets and sometimes other 

species comprise a patchy shrub layer. Old stands contain habitat for 

birds and arboreal nesting or roosting mammals. A variety of oak growth 

forms, sizes, and densities that benefit wildlife species can be found 

across the landscape. GDs for Vegetation Management in all Forested 

Communities: Projects in forested communities that change stand 

structure should generally retain at least historic frequencies of trees by 

species across broad age and diameter classes at the mid-scale. As 

such, the largest and oldest trees are usually retained. Project design and 

treatment prescriptions should generally not remove: Gambel oak >8 

inches, DRC.

Revised as forest wide direction. 

There is actually more direction in 

the revised plan for oak.

Forestry Intermediate Harvest Conifer GDs 

in EMAs 1, 3, 8, 9, 12 & 16: Harvests 

within the ecotone between 

woodlands and ponderosa pine 

habitat types will not be initiated 

unless there is reasonable assurance 

that regeneration of ponderosa pine 

will occur within five years following a 

regeneration harvest. The selection 

regeneration methods will be the 

preferred method of regenerating 

stands within this ecotone.

National 

Forest 

Manageme

nt Act 

(NFMA) of 

1976, Sec. 

4, FSM 

2470.3

Already addressed by existing 

law, regulation or policy.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 591
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Forestry Conifer Stand GDs for EMAs 

1,3,8,9,12,16: To provide for future 

snags requirements as specified in 

Wildlife Surveys, Planning, 

Prescriptions, Monitoring, Coop, and 

Administration, 3.a. (1) and (2), retain 

at least 400 live trees, 14 inches DBH 

and larger, per 100 acres, on 65 

percent of the treatment acres in 

ponderosa pine stands; and at least 

600 live trees , 14 inches DBH and 

larger, per 100 acres, on 65 percent 

of the treatment acres in mixed 

conifer stands. Select larger trees for 

retention from the following 

categories in sequence: (a) Living 

trees with cavities. (b) Trees with 

dead tops, spike tops, and damaged 

tops. (c) Living cull and damaged 

trees. (d) Living diseased trees, 

excepting mistletoe infected trees, 

not accounted for in a through c 

above. (e) Living healthy trees. (f) 

Avoid retention of mistletoe infected 

trees. 

GDs for Vegetation Management in All Forested Communities:

Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across 

broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. On suitable timberlands, projects 

should retain somewhat higher frequencies of trees across broad diameter 

classes to allow for future tree harvest. Project design should manage for 

replacement structural stages to assure continuous representation of old 

growth over time. Project design and treatment prescriptions should 

generally not remove: Large, old ponderosa pine trees with reddishyellow, wide platy bark, flattened tops, with moderate to full crowns and 

large drooping or gnarled limbs (e.g. Thomson’s age class 4, Dunning’s 

tree class 5 and/or Keen’s Tree Class 4, A and B [appendix C]). Mature 

trees with large dwarf mistletoe induced witches’ brooms suitable for 

wildlife nesting, caching, and denning, except where retaining such trees 

would prevent the desired development of uneven-aged conditions over 

time. Large snags, partial snags, and trees (>18 inches d.b.h.) with broken 

tops, cavities, sloughing bark, lightning scars >4 inches wide, and large 

stick nests (>18 inches in diameter). Gambel oak >8 inches, diameter at 

root collar. Known bat roost trees. DC Frequent Fire Mixed Conifer (Midscale): The mosaic of tree groups generally comprises an uneven-aged 

forest with all age classes and structural stages. Occasionally small 

patches (generally less than 50 acres) of even-aged forest structure are 

present. Disturbances sustain the overall variation in age and structural 

distribution. Management Approach Wildlife: The Kaibab NF strives to 

create and maintain natural communities and habitats in the amounts, 

arrangements, and conditions capable of supporting viable populations of 

existing native and desired nonnative plant, aquatic, and wildlife species 

within the planning area while contributing to broader landscape-scale 

initiatives where appropriate. This is accomplished in an integrative 

fashion by working closely with range, fire, timber, and other resource 

areas to coordinate and maximize activities for wildlife benefit. 

FSM 2600 

(2620.3, , 

2621.4) 

Overly prescriptive at the plan 

level. silviculturalists work with 

biologists on interdisciplinary 

teams to determine retention of 

key habitat elements at the site 

specific /project level.

592 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GD for NOGO Habitat: 

Emphasize maintenance and 

restoration of healthy riparian 

ecosystems through conformance 

with forest plan riparian standards 

and guidelines. Management 

strategies should restore degraded 

riparian areas to good condition as

soon as possible. Damage to 

riparian vegetation, stream banks, 

and channels should be prevented.

OBJ Natural Waters: Protect and/or restore at least 10 individual springs 

within 5 years of plan approval. OBJ Wetlands/Cienegas: Restore native 

vegetation and natural water flow patterns on at least 6 acres of wetlands 

within 5 years of plan approval. GDs for Natural Waters: Access to 

natural waters should be restricted to designated trails and points of entry 

to mediate erosion and prevent trampling and inadvertent introduction of 

nonnative and undesirable biota and disease. DCs Natural Waters: 

Stream channel stability and aquatic habitats retain their inherent 

resilience to disturbances and climate fluctuations. Stream channel 

morphology reflects changes in the hydrological balance, runoff, and 

sediment supply appropriate to the landscape setting. Springs and ponds 

have the necessary soil, water, and vegetation attributes to be healthy and 

functioning. Water levels, flow patterns, groundwater recharge rates, and 

geochemistry are similar to reference conditions. Springs, streams, and 

ponds have appropriate plant cover to protect banks and shorelines from 

excessive erosion. The necessary physical and biological components, 

including cover, forage, water, microclimate, and nesting/breeding habitat, 

provide habitat for a diverse community of plant and wildlife species. DCs 

Wetlands/Cienegas: Wetland conditions are consistent with their flood 

regime and flood potential. Wetlands infiltrate water, recycle nutrients, 

resist erosion, and function properly. DCs for Cottonwood-willow 

Riparian Forest: The extent, diversity, and condition of riparian habitat 

contribute to ecological sustainability. Dense shrubbery and high levels of 

vegetative diversity (structural and compositional) and permanent water 

provide food, cover, and water for wildlife, including terrestrial and aquatic 

invertebrates and vertebrates. Water flow regime approximates reference 

conditions (i.e., perennial flows) and flows freely. Sedimentation is 

minimized. Springtime flooding contributes to ecosystem sustainability by 

optimizing germination conditions for seedlings and/or suckering 

opportunities from the parent plant.

The revised plan actually has 

more direction and restoration 

objectives for natural waters. 

Streams are in Wilderness areas 

which preclude mechanized 

activities and alterations that 

would affect their wilderness

character.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 593
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide ST for NOGO Habitat:

Manage for uneven-age stand 

conditions for live trees and retain 

live reserve trees, snags, downed 

logs, and woody debris levels 

throughout woodland, ponderosa 

pine, mixed conifer and spruce-fir 

forest cover types. Manage for old 

age trees such that as much old 

forest structure as possible is 

sustained over time across the 

landscape. Sustain a mosaic of 

vegetation densities (overstory and 

understory), age classes and species 

composition across the landscape. 

Provide foods and cover for goshawk 

prey. 

GDs under Vegetation Management for all Forested Communities: 

Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across 

broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. Project design should manage for 

replacement structural stages to assure continuous representation of old 

growth over time. Project design and treatment prescriptions should 

generally not remove: Large, old ponderosa pine trees with reddishyellow, wide platy bark, flattened tops, with moderate to full crowns and 

large drooping or gnarled limbs (e.g. Thomson’s age class 4, Dunning’s 

tree class 5 and/or Keen’s Tree Class 4, A and B [appendix C]). Mature 

trees with large dwarf mistletoe induced witches’ brooms suitable for 

wildlife nesting, caching, and denning, except where retaining such trees 

would prevent the desired development of uneven-aged conditions over 

time. Large snags, partial snags, and trees (>18 inches DBH) with broken 

tops, cavities, sloughing bark, lightning scars >4 inches wide, and large 

stick nests (>18 inches in diameter). Gambel oak >8 inches, DRC. Also 

see all DCs for Ponderosa pine and Frequent Fire Mixed Conifer.

Reframed as forest wide GDs 

and DCs for major vegetation 

types are. New direction is 

consistent with MRNG and 

provides for healthy sustainable 

goshawk habitat.

594 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide ST for NOGO Habitat:

Manage the ground surface layer to 

maintain satisfactory soil conditions 

i.e. to minimize soil compaction; and 

to maintain hydrologic and nutrient 

cycles. 

GDs for Soils and Watershed Management: Projects should incorporate 

the national best management practices for water quality management 

and include design features to protect and improve watershed condition. 

In disturbed areas, erosion control measures should be implemented to 

improve soil conditions. DCs for Soils and Watersheds: Soils provide 

for diverse native plant species. Vegetative ground cover is well 

distributed across the soil surface to promote nutrient cycling and water 

infiltration. DC for Pinyon Juniper Communities: Plant litter (leaves, 

needles, etc.) and understory plant cover contributes to soil stabilization, 

prevents erosion, promotes nutrient cycling, improves water retention, 

provides cover and forage for small mammals, and conditions necessary 

for pinyon seed germination. DC for Ponderosa Pine (Fine-scale): 

Organic ground cover and herbaceous vegetation provide protection for 

soil and moisture infiltration, and contribute to plant and animal diversity 

and ecosystem function. Herbaceous vegetation reflects the site potential. 

DC for Frequent Fire Mixed Conifer (Fine-scale): Organic ground cover 

and herbaceous vegetation provide protection for soil and moisture 

infiltration, and contribute to plant and animal diversity and ecosystem 

function. Herbaceous vegetation reflects the site potential. DC for Mesic 

Mixed Conifer/Spruce Fir (Fine-scale): Organic ground cover and 

herbaceous vegetation provide protection for soil and moisture infiltration, 

and contribute to plant diversity and ecosystem function. Understory 

vegetation reflects site potential. DC for Aspen: Understory vegetation 

consists of shrubby or herbaceous species, providing forage and cover for 

wildlife and habitat for invertebrates such as pollinators. DC for Aspen in 

Mesic MC/Spruce Fir: Downed aspen and woody debris are scattered 

across the landscape and provide habitat for a variety of wildlife species 

(e.g., small mammals, reptiles, amphibians, and birds) while contributing 

to efficient nutrient cycling. GDs for Vegetation Management for all 

Forested Communities: Vegetation management should favor the 

development of native understory species in areas where they have the 

potential to establish and grow. 

FSM 

2509.18; 

FSH 

2509.22

Reframed as GDs and more 

explicit DCs for major vegetation 

types on the forest. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 595
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk GDs for Home Range 

Establishment: Establish a minimum 

of three nest areas and three 

replacement nest areas per Postfledgling family area. The nest areas 

and replacement nest areas should 

be approximately 30 acres in size. A 

minimum total of 180 acres of nest 

areas should be identified within each 

post-fledgling family area. 

GDs for TES: A minimum of six goshawk nest areas (known and 

replacement) should be located per territory. Nest and replacement nest 

areas should generally be located in drainages, at the base of slopes, and 

on northerly (NW to NE) aspects. Nest areas should generally be 25 to 30 

acres in size. Goshawk PFAs (post-fledging family areas) of approximately 

420 acres in size should be designated surrounding the nest sites.

Retained as a guideline with 

slightly different wording based 

on current scientific information.

Goshawk Forest wide GD outside PFA's:

General: The distribution of 

vegetation structural stages for 

ponderosa pine, mixed conifer and 

spruce-fir forests is 10% 

grass/forb/shrub (VSS1), 10% 

seedling-sapling (VSS2), 20% young 

forest (VSS 3), 20% mid-aged forest 

(VSS4), 20% mature forest (VSS 5), 

20% old forest (VSS6). NOTE: The 

specified percentages are a guide 

and actual percentages are expected 

to vary + or - up to 3%. 

GDs for Vegetation Management in all Forested Communities: 

Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across 

broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. Also see DCs for Ponderosa Pine 

and Frequent Fire Mixed Conifer.

DCs for vegetation types are 

consistent with MRNG and 

provide for sustainable goshawk 

habitat, prescriptive provisions 

not retained. See Desired 

Conditions for Use in Forest 

Planning in the Southwestern 

Region: Development and 

Science 

Basis (RMRS-GTR-310)

596 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs outside PFAs:

Spruce-fir: Canopy cover for midaged forest (VSS 4) should average 

1/3 60% and 2/3 40%, mature forest 

(VSS 5) should average 60+%, and 

old forest (VSS 6) should average 

60+%. Maximum opening size is 1 

acre with a maximum width of 125 

feet. Provide two groups of reserve 

trees per acre with six trees per 

group when opening size exceeds 

0.5. Leave at least 3 snags, 5 

downed logs, and 10-15 tons of 

woody debris per acre (including the 

downed logs). 

DCs for Mesic Mixed Conifer/Spruce Fire (Fine-scale): Mid-aged and 

older trees are typically variably spaced with crowns interlocking (grouped 

and clumped trees) or nearly interlocking. Trees within groups can be of 

similar or variable species and ages, contributing to vertical and horizontal 

heterogeneity. Small openings (gaps) are present as a result of past 

disturbances. (Mid-scale): The size and number of groups and patches 

vary depending on disturbance, elevation, soil type, aspect, and site 

productivity. Patch sizes vary, but are frequently hundreds of acres; 

groups and patches of tens of acres or less are relatively common. Forest 

conditions in some areas contain higher basal area than the general 

Forest; examples include goshawk post-family fledgling areas, Mexican 

spotted owl nesting and roosting habitat, and north-facing slopes. A 

mosaic of primarily even-aged groups and patches, which vary in size, 

species composition, and age is present. Aspen is occasionally present in 

large patches. Density ranges from 20 to 250 square feet of basal area 

per acre, depending upon disturbance and seral stages of groups and 

patches. The number of snags and downed logs (greater than 12 inches 

diameter at mid-point, over 8 feet long) and coarse woody debris (greater 

than 3 inches diameter) vary by seral stage. Snags 18 inches or greater 

DBH typically range from one to five snags per acre, with the lower range 

associated with early seral stages and the upper range associated with 

late seral stages. Coarse woody debris, including downed logs, vary by 

seral stage, with averages ranging from 5 to 20 tons per acre for early 

seral stages; 20 to 40 tons per acre for mid-seral stages; and 35 tons per 

acre or greater for late seral stages. (Landscape scale): The vegetation 

community is a mosaic of structural and seral stages ranging from young 

trees through old and is composed of multiple species. The landscape 

arrangement is an assemblage of variably sized and aged groups and 

patches of trees and other vegetation similar to reference conditions. The 

landscape is composed predominantly of vigorous trees, but older 

declining trees (e.g. snags and top killed, lightning-, and fire-scarred 

trees), as well as coarse woody debris, are present. Old growth generally 

occurs over large areas as stands or forests. Old growth includes old 

trees, snags, coarse woody debris, and structural diversity. The location of 

old growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). Also see GDs for Vegetation 

Management in all Forested Communities.

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat, prescriptive 

provisions not retained. See 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis 

(USDA 2013)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 597
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs outside PFAs: 

Mixed Conifer: Canopy cover for midaged forest (VSS 4) should average 

1/3 60+% and 2/3 40+%, mature 

forest (VSS 5) should average 50+%, 

and old forest (VSS 6) should 

average 60+%. Maximum opening 

size is up to 4 acres with a maximum 

width of up to 200 feet. Retain one 

group of reserve trees per acre of 3-5 

trees per group for openings greater 

than 1 acre in size. Leave at least 3 

snags, 5 downed logs, and 10-15 

tons of woody debris per acre, 

(including the downed logs). 

DCs Frequent Fire Mixed Conifer (Fine-scale): Trees typically occur in 

irregularly shaped groups and are variably spaced with some tight clumps. 

Trees within groups are of similar or variable ages, often containing more 

than one species. Crowns of trees within mid-aged and old groups are 

interlocking or nearly interlocking. Tree groups are typically less than 1 

acre size and consist of 2 to 50 trees per group, but are sometimes larger, 

such as on north facing slopes. Regeneration openings occur as a mosaic 

and are similar in size to nearby groups. Interspaces between groups are 

variably shaped, are comprised of a native grass-forb-shrub mix, and may 

contain individual trees or snags. (Mid-scale): The frequent fire mixed 

conifer forest vegetation community is characterized by variation in the 

size and number of tree groups depending on elevation, soil type, aspect, 

and site productivity. Forest appearance is variable, but generally unevenaged and open; occasional patches of even-aged structure are present. 

The more biologically productive sites contain more trees per group and 

more groups per area. Basal area within forested areas generally ranges 

from 30 to 100 square feet per acre, with larger trees contributing the 

greatest percent of the total basal area. Forest conditions in some areas 

contain 10 to 20 percent higher basal area in mid-aged to old tree groups 

than in the general forest; these include goshawk post-fledging family 

areas, Mexican spotted owl nesting/roosting habitat, and north-facing 

slopes. Interspaces with native grass, forb, and shrub vegetation typically 

range from 10 to 50 percent of the area. The mosaic of tree groups 

generally comprises an uneven-aged forest with all age classes and 

structural stages. Occasionally small patches (generally less than 50 

acres) of even-aged forest structure are present. Snags and green snags 

18 inches d.b.h. or greater average three per acre. Downed logs (greater 

than 12 inches diameter at mid-point and greater than 8 feet long) average 

three per acre within the forested area of mid-scale units. Coarse woody 

debris, including downed logs, ranges from 5 to 15 tons per acre. 

(Landscape-scale): At the landscape scale, the frequent fire mixed 

conifer forest community is a mosaic of forest conditions composed of 

structural stages ranging from young to old trees. Old growth occurs 

throughout the landscape, generally in small areas as individual old 

growth components, or as clumps of old growth. Old growth components 

include old trees, snags, coarse woody debris, and structural diversity. 

The location of old growth shifts on the landscape over time as a result of 

succession and disturbance (tree growth and mortality). Forest 

appearance is variable but generally uneven-aged and open; occasional 

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat, prescriptive 

provisions not retained. See 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis. 

598 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

patches of even-aged structure are present. The forest arrangement is in 

small clumps and groups of trees interspersed within variably sized 

openings of native grass-forb-shrub vegetation associations similar to 

reference conditions. Size, shape, number of trees per group, and number 

of groups per area are variable across the landscape. The frequent fire 

mixed conifer forest community is composed predominantly of vigorous 

trees, but declining trees (e.g. snags, top killed, lightning and fire scarred 

trees) and coarse woody debris (greater than 3 inches diameter) are 

present and well distributed throughout the landscape. Also see GDs for 

Vegetation Management in all Forested Communities and DCs for 

mesic MC/Spruce fir in the previous row. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 599
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forestwide GDs outside PFAs.

Ponderosa Pine: Canopy Cover for 

mid-aged forest (VSS 4) should 

average 40+%, mature forest (VSS 

5) should average 40+%, and old 

forest (VSS 6) should average 40+%. 

Opening size is up to 4 acres with a 

maximum width of up to 200 feet. 

One group of reserve trees, 3-5 trees 

per group, will be left if the opening is 

greater than an acre in size. Leave 

at least 2 snags per acre, 3 downed 

logs per acre, and 5-7 tons of woody 

debris per acre, (including the 

downed logs).

DCs for Ponderosa Pine (Fine-scale): Crowns of trees within the midaged to old groups are interlocking or nearly interlocking and consist of 

approximately 2 to 40 trees per group. The interspaces between groups 

are variably shaped, are comprised of a native grass/forb/shrub mix, and 

may contain individual trees or snags. Regeneration openings occur as a 

mosaic and are similar in size to nearby groups. Where Gambel oak 

comprises more than 10 percent of the basal area, it is not uncommon for

canopy cover to be greater than 40 percent. (Mid-scale): Forest 

conditions in some areas contain 10 to 20 percent higher basal area in 

mid-aged to old tree groups than in the general forest (e.g., goshawk postfledging family areas, Mexican spotted owl nesting/roosting habit. Snags 

18 inches DBH or greater average 1 to 2 snags per acre. Snags and 

green snags of various sizes and forms are common. Downed logs 

(greater than 12 inches diameter at mid-point and greater than 8 feet long) 

average 3 logs per acre. Coarse woody debris greater than 3 inches in 

diameter (including downed logs), ranges from 3 to 10 tons per acre. 

(Landscape-scale): The ponderosa pine forest vegetation community is a 

mosaic of forest conditions composed of structural stages ranging from 

young to old trees. The forest is generally uneven-aged and open. Groups 

of old trees are mixed with groups of younger trees. Occasional areas of 

even-aged structure are present. Denser tree conditions exist in some 

locations such as north-facing slopes, canyons, and drainage bottoms. 

The ponderosa pine forest is composed predominantly of vigorous trees, 

but declining trees are present. Snags, green snags, and coarse woody 

debris occur across the landscape. Old growth occurs throughout the 

landscape, generally in small areas as individual old growth components, 

or as clumps of old growth. Old growth components include old trees, 

snags, coarse woody debris, and structural diversity. The location of old 

growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality).

Revised as DCs

Goshawk Forest wide GD for Home Range 

Establishment: Post-fledgling family 

areas (PFA) will be approximately 

600 acres in size. Post-fledgling 

family areas will include the nest sites 

and consist of the habitat most likely 

to be used by the fledglings during 

their early development. 

Guidelines under TES: Goshawk PFAs (post-fledging family areas) of 

approximately 420 acres in size should be designated surrounding the 

nest sites. A minimum of six goshawk nest areas (known and 

replacement) should be located per territory. Nest and replacement nest 

areas should generally be located in drainages, at the base of slopes, and 

on northerly (NW to NE) aspects. Nest areas should generally be 25 to 30 

acres in size.

Language has been revised, but 

still a GD. This still equates to 

600 acres (420 plus the 6 nest 

areas) of PFA. 

600 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs within PFAs 

General: Provide for a healthy 

sustainable forest environment for 

the post-fledgling family needs of 

goshawks. The principle difference 

between within the post-fledgling 

family area and outside the postfledgling family area is the higher 

canopy cover within the post-fledgling 

family area and smaller opening size 

within the post-fledgling family area. 

Vegetative Structural Stage 

distribution and structural conditions 

are the same within and outside the 

post-fledgling family area. 

DC under TES: Threatened, endangered, and sensitive species have 

quality habitat, stable or increasing populations, and are at low risk for 

extirpation. Goshawk nest areas are multi-aged forests dominated by 

large trees with interlocking crowns and are generally denser than the 

surrounding forest. GDs for TES: Project activities and special uses 

should be designed and implemented to maintain refugia and critical life 

cycle needs of Forest Service Sensitive Species. Goshawk PFAs (postfledging family areas) of approximately 420 acres in size should be 

designated surrounding the nest sites.

Existing guideline more of a 

definition. Exists as both a DC 

and GD in the revised plan.

Goshawk Forest wide GDs within Nesting 

Areas General: Provide unique 

nesting habitat conditions for 

goshawks. Important features include 

trees of mature to old age with high 

canopy cover. 

DC for TES: Goshawk nest areas are multi-aged forests dominated by 

large trees with interlocking crowns and are generally denser than the 

surrounding forest. GDs for TES: Project activities and special uses 

should be designed and implemented to maintain refugia and critical life 

cycle needs of Forest Service Sensitive Species. DCs for Mesic Mixed 

Conifer/Spruce Fire (Fine-scale): Mid-aged and older trees are typically 

variably spaced with crowns interlocking (grouped and clumped trees) or 

nearly interlocking. Trees within groups can be of similar or variable 

species and ages, contributing to vertical and horizontal heterogeneity. 

Small openings (gaps) are present as a result of past disturbances. DCs 

Frequent Fire Mixed Conifer (Fine-scale): Trees typically occur in 

irregularly shaped groups and are variably spaced with some tight clumps. 

Trees within groups are of similar or variable ages, often containing more 

than one species. Crowns of trees within mid-aged and old groups are 

interlocking or nearly interlocking. DCs Ponderosa Pine (Fine-scale):

Trees typically occur in irregularly shaped groups and are variably spaced 

with some tight clumps. Trees within groups are of similar or variable ages 

and may contain species other than ponderosa pine. 

Existing guideline more of a 

definition. Exists as both a DC 

and GD in the revised plan

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 601
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs within PFAs:

Spruce-fir: Canopy Cover for midaged forest (VSS 4) should average 

60+% and for mature (VSS 5) and 

old forest (VSS 6) should average 

70+%. 

DCs Mesic Mixed Conifer/Spruce Fir (Mid-scale): Forest conditions in 

some areas contain higher basal area than the general Forest; examples 

include goshawk post-family fledgling areas, Mexican spotted owl nesting 

and roosting habitat, and north-facing slopes. Also see GDs for 

Vegetation Management in all Forested Communities.

Overly prescriptive at the plan 

level and guidance not retained. 

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat. Also see 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis 

(RMRS-GTR-310)

Goshawk Forest wide GDs within PFAs 

Mixed Conifer: Canopy Cover for 

mid-aged (VSS 4) to old forest (VSS 

6) should average 60+%. 

DCs Frequent Fire Mixed Conifer (Mid-scale): Forest conditions in 

some areas contain 10 to 20 percent higher basal area in mid-aged to old 

tree groups than in the general forest; these include goshawk postfledging family areas, Mexican spotted owl nesting/roosting habitat, and 

north-facing slopes. Mesic Mixed Conifer/Spruce Fir: Forest conditions 

in some areas contain higher basal area than the general Forest; 

examples include goshawk post-family fledgling areas, Mexican spotted 

owl nesting and roosting habitat, and north-facing slopes. Also see GDs 

for Vegetation Management in all Forested Communities.

Overly prescriptive at the plan 

level and guidance not retained. 

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat. Also see 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis.

Goshawk Forest wide GDs within PFAs:

Ponderosa Pine: Canopy Cover for 

mid-aged forest (VSS 4) should 

average 1/3 60+% and 2/3 50+%. 

Mature (VSS 5) and old forest (VSS 

6) should average 50+%. 

DCs for Ponderosa Pine (Mid-scale): Forest conditions in some areas 

contain 10 to 20 percent higher basal area in mid-aged to old tree groups 

than in the general forest (e.g., goshawk post-fledging family areas, 

Mexican spotted owl nesting/roosting habitat, drainages, and steep northfacing slopes). Also see GDs for Vegetation Management in all 

Forested Communities.

Overly prescriptive at the plan 

level and guidance not retained. 

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat. Also see 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis. 

602 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs within PFAs. 

Woodland: Maintain existing canopy 

cover levels. 

DCs for all Pinyon-juniper communities: At the mid-scale and above, 

canopy cover is at least 10 percent with a mix of young and mature groups 

and clumps of trees. Some tree groups have 30 to 40 percent canopy 

cover that provides habitat for nesting, bedding, and foraging. Also see 

GDs for Vegetation Management in all Forested Communities. 

No distinction for canopy cover 

for goshawk PFAs/nesting areas 

from the rest of the DCs. DCs for 

major vegetation types are 

consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat. Also see 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis.

Goshawk Forest wide GDs within PFAs.

Spruce-fir, Mixed Conifer and 

Ponderosa Pine Cover Types: The 

nesting area contains only mature to 

old forest (VSS 5 & 6) having a 

canopy cover (measured vertically) 

between 50-70% with mid-aged VSS 

6 trees 200-300 years old. Nonuniform spacing of trees and 

clumsiness is desirable.

See above mid-scale DCs for Ponderosa Pine, Frequent Fire MC and 

Mesic MC/Spruce Fir. Also see GDs for Vegetation Management in all 

Forested Communities.

Overly prescriptive at the plan 

level and guidance not retained. 

DCs for major vegetation types 

are consistent with MRNG and 

provide for healthy sustainable 

goshawk habitat. Also see 

Desired Conditions for Use in 

Forest Planning in the 

Southwestern Region: 

Development and Science Basis.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 603
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs within nesting 

areas: The structure of the 

vegetation within nest areas is 

associated with the forest type, and 

tree age, size, and density, and the 

developmental history of the stand. 

Table 5 of RM-217 presents 

attributes required for goshawks on 

locations with "low" and "high" site 

productivity. 

DCs for TES: Goshawk nest areas are multi-aged forests dominated by 

large trees with interlocking crowns and are generally denser than the 

surrounding forest. DCs for Ponderosa Pine (Mid-scale): The 

ponderosa pine forest vegetation community is characterized by variation 

in the size and number of tree groups depending on elevation, soil type, 

aspect, and site productivity. The mosaic of tree groups generally 

comprises an uneven-aged forest with all age classes and structural 

stages present. Stands are dominated by ponderosa pine, but other native 

hardwood and conifer species occur. The more biologically productive 

sites contain more trees per group and more groups per area. DCs for

Frequent Fire Mixed-conifer (Mid-scale): The frequent fire mixed conifer 

forest vegetation community is characterized by variation in the size and 

number of tree groups depending on elevation, soil type, aspect, and site 

productivity. Forest appearance is variable, but generally uneven-aged 

and open; occasional patches of even-aged structure are present. The 

more biologically productive sites contain more trees per group and more 

groups per area. Basal area within forested areas generally ranges from 

30 to 100 square feet per acre, with larger trees contributing the greatest 

percent of the total basal area. DCs for Mesic Mixed conifer/Spruce fir 

(Mid-scale): The size and number of groups and patches vary depending 

on disturbance, elevation, soil type, aspect, and site productivity. Patch 

sizes vary, but are frequently hundreds of acres; groups and patches of 

tens of acres or less are relatively common. 

This direction now captured 

through multiple DCs.

Goshawk Forest wide GDs within nesting 

areas. Woodland: Maintain existing 

canopy cover levels. 

DCs for TES: Goshawk nest areas are multi-aged forests dominated by 

large trees with interlocking crowns and are generally denser than the 

surrounding forest. DCs for all Pinyon-juniper communities: At the midscale and above, canopy cover is at least 10 percent with a mix of young 

and mature groups and clumps of trees. Some tree groups have 30 to 40 

percent canopy cover that provides habitat for nesting, bedding, and 

foraging.

No distinction for canopy cover 

for goshawk PFAs/nesting areas 

from the rest of the DCs for this 

vegetation type (limits 

redundancy).DCs for major 

vegetation types are consistent 

with MRNG and provide for 

healthy sustainable goshawk 

habitat. Also see Desired 

Conditions for Use in Forest 

Planning in the Southwestern 

Region: Development and 

Science Basis.

604 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs outside PFAs. 

Woodland: Manage for uneven age 

conditions to sustain a mosaic of 

vegetation densities (overstory and 

understory), age classes, and 

species composition well distributed 

across the landscape. Provide for 

reserve trees, snags, and down 

woody debris.

GDs for all Pinyon-juniper communities: Restoration treatments in 

pinyon-juniper should be rotated over time and various successional 

stages to maximize wildlife habitat and diversity. DCs for Pinyon-juniper 

Woodlands: Pinyon-juniper woodland (persistent) is characterized by 

even-aged patches of pinyons and junipers that at the landscape level 

form uneven-aged woodlands. Tree density and canopy cover are high, 

shrubs are sparse to moderate, and herbaceous cover is low and 

discontinuous due to soil and other site conditions. DCs for all Pinyon 

Juniper Communities: Pinyon-juniper communities occur as a shifting 

mosaic interspersed with openings across the landscape. The 

configuration of vegetation and openings provides foraging and browsing 

opportunities for wildlife, and enough sighting distance and hiding cover 

for pronghorn to escape predators. Old growth occurs throughout the 

landscape, generally in small areas as individual components, or as 

clumps. The location of old growth shifts on the landscape over time as a 

result of succession and disturbance (tree growth and mortality). The 

mature groups of trees are structurally diverse, containing large live trees, 

as well as trees with dead or broken tops, gnarls, and burls. Snags, green 

snags, and downed trees > 10′′ at DRC are present and average 1 to 2 

per acre. 

Revised as a GD under pinyon 

juniper.

Goshawk Forest wide GDs outside PFAs. 

Canopy Cover: Canopy cover 

guidelines apply only to mid-aged to 

old forest structural stages (VSS 4, 

VSS 5, and VSS 6) and not to 

grass/forb/shrub to young forest 

structural stages (VSS 1, VSS 2, and 

VSS 3).

DCs for Ponderosa pine: Crowns of trees within the mid-aged to old 

groups are interlocking or nearly interlocking and consist of approximately 

2 to 40 trees per group. Ponderosa pine forest vegetation community is a 

mosaic of forest conditions composed of structural stages ranging from 

young to old trees. The forest is generally uneven-aged and open. Groups 

of old trees are mixed with groups of younger trees. Occasional areas of 

even-aged structure are present. Denser tree conditions exist in some 

locations such as north-facing slopes, canyons, and drainage bottoms.

Revised plan does not have VSS 

classes or canopy cover 

guidelines. DCs are consistent 

with MRNG.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 605
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs outside PFAs. 

Snags are 18" or larger DBH and 30 

feet or larger in height, downed logs 

are 12 inches in diameter and at least 

8 feet long, woody debris is 3 inches 

or larger on the forest floor, canopy 

cover is measured with vertical crown 

projection on average across the 

landscape. 

Mid-scale DCs Frequent Fire Mixed conifer: Snags and green snags 18 

inches DBH or greater average three per acre. Downed logs (greater than 

12 inches diameter at mid-point and greater than 8 feet long) average 

three per acre within the forested area of mid-scale units. Coarse woody 

debris, including downed logs, ranges from 5 to 15 tons per acre. Midscale DCs Mesic Mixed Conifer/Spruce Fir: The number of snags and 

downed logs (greater than 12 inches diameter at mid-point, over 8 feet 

long) and coarse woody debris (greater than 3 inches diameter) vary by 

seral stage. Snags 18 inches or greater DBH typically range from one to 

five snags per acre, with the lower range associated with early seral 

stages and the upper range associated with late seral stages. Coarse 

woody debris, including downed logs, vary by seral stage, with averages 

ranging from 5 to 20 tons per acre for early seral stages; 20 to 40 tons per 

acre for mid-seral stages; and 35 tons per acre or greater for late seral 

stages. Mid-scale DCs for Ponderosa Pine: Snags 18 inches DBH or 

greater average 1 to 2 snags per acre. Snags and green snags of various 

sizes and forms are common. Downed logs (greater than 12 inches 

diameter at mid-point and greater than 8 feet long) average 3 logs per 

acre. Coarse woody debris greater than 3 inches in diameter (including 

downed logs), ranges from 3 to 10 tons per acre.

Revised plan definitions are now 

embedded in the DCs for 

individual forest communities. 

CWD and snags are in glossary. 

Goshawk Forest wide GDs human 

disturbance. The breeding season 

extends from March 1 through 

September 30. 

GDs for TES: Potentially disturbing project-related activities should be 

minimized in occupied goshawk nest areas during nesting season of 

March 1 through September 30. 

Retained as a guideline in the 

revised plan with revised wording.

606 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Management in goshawk habitat 

(Neither ST or GD). Applicability: 

The northern goshawk standards and 

guidelines apply to the forest and 

woodland communities described

below that are outside of Mexican 

spotted owl protected and restricted 

areas. Within Mexican spotted owl 

protected and restricted areas, the 

Mexican spotted owl standards and 

guidelines take precedence over the 

northern goshawk standards and 

guidelines. One or the other set of 

standards and guidelines apply to all 

forest and woodland communities but 

the Mexican spotted owl standards 

always take precedence in areas of 

overlap.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA, FSM 

2670.31

The revised MSO recovery plan 

(FWS 2012) for MSO will be 

used. ESA (law) has the highest 

authority. FSM policy also directs 

that T&E guidance is the top 

priority. It is not clear if the 1988

plan direction was intended to be

a ST or GD. 

Goshawk ST under Management for 

goshawk habitat. Establish, and 

delineate on a map, a post-fledgling 

family area that includes six nesting 

areas per pair of nesting goshawks 

for known nest sites, old nest sites, 

areas where historical data indicates 

goshawks have nested there in the 

past, and where goshawks have 

been repeatedly sighted over a two 

year or greater time period but no 

nest sites have been located.

GDs for TES: A minimum of six goshawk nest areas (known and 

replacement) should be located per territory. Nest and replacement nest 

areas should generally be located in drainages, at the base of slopes, and 

on northerly (NW to NE) aspects. Nest areas should generally be 25 to 30 

acres in size. Goshawk PFAs (post-fledging family areas) of approximately 

420 acres in size should be designated surrounding the nest sites.

Retained as a GD.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 607
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide ST under Management 

for goshawk habitat. Survey the 

management analysis area prior to 

habitat modifying activities including 

a 1/2 mile beyond the boundary.

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Potentially disturbing project-related activities 

should be minimized in occupied goshawk nest areas during nesting 

season of March 1 through September 30. Wildlife Management 

Approach: The Kaibab NF references current literature and the best 

available science when making site specific decisions relevant to project 

planning. This is done in an interdisciplinary context with input from other 

resource specialists. 

This is overly prescriptive at the 

forest plan level. Goshawk survey 

methods have evolved since the 

last plan was signed and new 

literature on goshawk ecology 

and behavior has been published. 

Survey needs will be determined 

on a project and site specific 

basis following established 

protocols as per the most recent 

scientific literature. Refer to GTRWO-71. 

Goshawk Forest wide GDs for goshawk 

inventories. For areas where 

complete inventories cannot be done, 

use aerial photographs to locate 

vegetative structural stages (VSS) 4-

6 within the project area and 

inventory just those sites for goshawk 

nest areas using R3 inventory 

protocol. All un-inventoried areas 

(VSS 1-3) will be managed to postfledgling family area (PFA) 

specifications while in that stage. If, 

while using this inventory option, 

evidence suggests goshawks are 

present (such as finding plucking 

perches or molted goshawk feathers) 

conduct a complete inventory as 

outlined above. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

This is overly prescriptive at the 

forest plan level and uses 

outdated language, the new 

forest plan does not reference 

VSS classes. Goshawk survey 

methods have evolved since the 

last plan was signed and new 

literature on goshawk ecology 

and behavior has been published. 

Survey needs will be determined 

on a project and site specific 

basis following established 

protocols as per the most recent 

scientific literature. Refer to Gen. 

Tech. Rep. WO-71. 

608 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs for goshawk 

inventories. If forests have 

goshawks commonly nesting in 

stands classified as VSS 1-3, use the 

complete inventory methods for those 

areas. There may be situations 

where an area is classified as a VSS 

3, based on the predominant VSS 

class, but in actuality a combination 

of VSS 4 & 5 predominate the area. 

For those situations, use the 

complete inventory methods. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists.

Outdated language. The new 

forest plan does not reference 

VSS classes. Overly prescriptive 

at the plan level. Survey needs 

will be determined on a project 

and site specific basis following 

recent advances in science

Goshawk Forest wide ST for goshawk 

habitats. Limit human activity in 

nesting areas during the breeding 

season. 

GDs for TES: Potentially disturbing project-related activities should be 

minimized in occupied goshawk nest areas during nesting season of 

March 1 through September 30. 

Retained as a guideline with 

revised language.

Goshawk Forest wide GD for goshawk 

habitats. Refer to USDA Forest 

Service General Technical Report 

RM-217 entitled "Management 

Recommendations for the Northern 

Goshawk in the Southwestern United 

States" for scientific information on 

goshawk ecology and management 

which provide the basis for the 

management guidelines. 

Supplemental information on 

goshawk ecology and management 

may be found in "The Northern 

Goshawk: Ecology and 

Management" published by the 

Cooper Ornithological Society as 

Studies in Avian Biology No. 16. In 

woodland forest cover types, use 

empirical data to determine desired 

habitat conditions. 

Wildlife Management Approach: The Kaibab NF references current 

literature and the best available science when making site specific 

decisions relevant to project planning. This is done in an interdisciplinary 

context with input from other resource specialists. 

Overly prescriptive as a plan level 

guideline, really more of a 

management approach. 

Information about goshawk needs 

continues to evolve as new 

science become available. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 609
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GD for goshawk 

habitats. Use the R3 survey protocol 

to get complete coverage of the 

management analysis area (Kennedy 

and Stahlecker 1993, as modified by 

Joy, Reynolds, and Leslie 1994.) 

Management analysis areas should 

be entire ecosystem management 

areas if possible. Complete at least 

one year of survey, but two years of 

survey should be done to verify 

questionable sightings, unconfirmed 

nest sites, etc. If nesting goshawks 

are found during the first year of 

inventory, a second year of inventory 

is not needed in that territory.

Wildlife Management Approach: The Kaibab NF references current 

literature and the best available science when making site specific 

decisions relevant to project planning. This is done in an interdisciplinary 

context with input from other resource specialists. 

Overly prescriptive at the plan 

level, really more of a 

management approach. Survey 

needs will be determined on a 

project and site specific basis 

following the most recently 

established protocols and 

scientific literature. Region 3 has 

updated survey guidance (GTRWO-71.

Goshawk Forest wide GD at the 

management scale. Distribution of 

habitat structures (tree size and age 

classes, tree groups of different 

densities, snags, dead and down 

woody material, etc.) should be 

evaluated at the ecosystem 

management area level, at the midscale such as drainage, and at the 

small scale of site. 

Monitoring Plan Questions: 01 Ponderosa Pine and Frequent Fire 

Mixed Conifer: Are snags, coarse woody debris, downed logs and large 

old trees at desired levels at the midscale (100-1,000 acre average)? 07 

Ponderosa Pine and Frequent Fire Mixed Conifer: How many acres of 

the Kaibab NF is in an uneven aged open state, at the midscale (above 

100 acres)? 09 Ponderosa Pine and Frequent Fire Mixed Conifer: Is 

the stand density within a range that will allow for a robust understory? 11 

Ponderosa Pine and Frequent Fire Mixed Conifer: What is the total 

area within the desired range for basal area and openings? 

This is redundant guidance. This 

direction is built into the new plan 

as DCs and GDs under the 

relevant vegetation types at the 

landscape, mid and fine scales 

(see above). It is also covered 

under the monitoring plan.

Goshawk Forest wide GDs for goshawk 

home range. Manage for nest 

replacement sites to attain sufficient 

quality and size to replace the three 

suitable nest sites. 

GDs for TES: A minimum of six goshawk nest areas (known and 

replacement) should be located per territory. Nest and replacement nest 

areas should generally be located in drainages, at the base of slopes, and 

on northerly (NW to NE) aspects. Nest areas should generally be 25 to 30 

acres in size. 

Redundant guidance. Address 

above under nest areas.

Goshawk Forest wide GDs for goshawk 

home range. Nest site selection will 

be based first on using active nest 

sites followed by the most recently 

used historical nest areas. When 

possible, all historical nest areas 

should be maintained. 

Wildlife Management Approach: The Kaibab NF references current 

literature and the best available science when making site specific 

decisions relevant to project planning. This is done in an interdisciplinary 

context with input from other resource specialists

Overly prescriptive. Will vary by 

site and project. 

610 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs outside PFAs. 

The distribution of VSS, tree density, 

and tree age are a product of site 

quality in the ecosystem 

management area. Use site quality 

to guide in the distribution of VSS, 

tree density and tree ages. Use site 

quality to identify and manage 

dispersal PFA and nest habitat at 2 -

2.5 mile spacing across the 

landscape. 

PP Landscape-scale DC: The ponderosa pine forest vegetation 

community is a mosaic of forest conditions composed of structural stages 

ranging from young to old trees. The forest is generally uneven-aged and 

open. Groups of old trees are mixed with groups of younger trees. 

Occasional areas of even-aged structure are present. Denser tree 

conditions exist in some locations such as north-facing slopes, canyons, 

and drainage bottoms. Old growth occurs throughout the landscape, 

generally in small areas as individual old growth components, or as 

clumps of old growth. Old growth components include old trees, snags, 

coarse woody debris, and structural diversity. The location of old growth 

shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). Frequent fire MC Landscapescale DC. At the landscape scale, the frequent fire mixed conifer forest 

community is a mosaic of forest conditions composed of structural stages 

ranging from young to old trees. Old growth occurs throughout the 

landscape, generally in small areas as individual old growth components, 

or as clumps of old growth. Old growth components include old trees, 

snags, coarse woody debris, and structural diversity. The location of old 

growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). Wildlife Management Approach: 

The Kaibab NF references current literature and the best available science 

when making site specific decisions relevant to project planning. This is 

done in an interdisciplinary context with input from other resource 

specialists

This is redundant with guidance 

for nesting areas (already coved 

above under the different 

vegetation types) and overly 

prescriptive. It uses outdated 

language. The new plan does not 

reference VSS classes. Actual 

treatments prescriptions will vary 

by site and project but the 

landscape DCs would provide for 

habitat requirements including 

nesting across the landscape. 

Only goshawks truly know where 

they will nest.

Goshawk Forest wide GDs outside PFAs.

The order of preferred treatment for 

woody debris is: 1) prescribed 

burning, 2) lopping & scattering, 3) 

hand piling or machine grapple piling, 

4) dozer piling.

GDS for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists

Overly prescriptive as a plan level 

guideline. Appropriate methods 

will vary depending on the 

project, site conditions and 

available equipment.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 611
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs within nesting 

areas. Preferred treatments to 

maintain the desired structure are to 

thin from below with non-uniform 

spacing and use of handtools and fire 

to reduce fuel loads. Lopping and 

scattering of thinning debris is 

preferred if prescribed fire cannot be 

used. Piling of debris should be 

limited. When necessary, hand piling 

should be used to minimize 

compaction within piles and to 

minimize displacement and 

destruction of the forest floor and the 

herbaceous layer. Do not grapple or 

Dozer pile debris. Manage road 

densities at the lowest level possible 

to minimize disturbance in the nest 

area. Use small, permanent skid 

trails in lieu of roads for timber 

harvesting. 

GDs for TES: Potentially disturbing project-related activities should be 

minimized in occupied goshawk nest areas during nesting season of 

March 1 through September 30. Wildlife Management Approach: The 

Kaibab NF references current literature and the best available science 

when making site specific decisions relevant to project planning. This is 

done in an interdisciplinary context with input from other resource 

specialists. DCs for Vegetation Management in all Forested 

Communities: Vegetation management activities in mixed conifer forests 

should incorporate experimental design features and monitoring to 

accelerate learning and adaptive management. DCs for Wildland Fire 

Management: Develop objectives and courses of action to address the 

desired conditions for wildlife habitat and key habitat features such as 

snags, logs, large tree-form oaks, and oak thickets. Management 

Approach Ponderosa Pine: Tools for creating desired stand conditions 

and openings include a variety of treatments and uneven-aged cutting 

methods such as matrix thinning, all-size free thinning, single tree 

selection, group selection, sanitation and salvage, limited even-aged 

regeneration cutting, thinning, and managed fire Also see Management 

Approach sections for Ponderosa Pine and Frequent Fire Mixed Conifer.

Overly prescriptive as a plan level 

guideline. In the new plan, 

treatment methods will reflect 

current science and methods and 

be adaptive as information about 

forest level management and 

associated effects changes over 

time.

Goshawk Forest wide GDs within nesting 

areas. Limit dozer use for piling or 

scattering of logging debris so that 

the forest floor and herbaceous layer 

is not displaced or destroyed. 

GDs for Vegetation Management in all Forested Communities:

Vegetation management prescriptions should provide for sufficient canopy 

breaks to limit crown fire spread between groups, allow for the 

redevelopment and maintenance of a robust understory, and mimic the 

spatial arrangement of the reference conditions. Vegetation management 

should favor the development of native understory species in areas where 

they have the potential to establish and grow. DCs for Ponderosa Pine 

and Frequent Fire Mixed Conifer (Fine-scale): Organic ground cover 

and herbaceous vegetation provide protection for soil and moisture 

infiltration, and contribute to plant and animal diversity and ecosystem 

function. Herbaceous vegetation reflects the site potential. DCs for Soils 

and Watersheds: Soils provide for diverse native plant species. 

Vegetative ground cover is well distributed across the soil surface to 

promote nutrient cycling and water infiltration. 

Overly prescriptive at the plan 

level. Appropriate methods will 

meet DCs and GDs for the 

vegetation communities and soil 

types.

612 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs for human 

disturbance. Limit human activities 

in or near nest sites and postfledgling family areas during the 

breeding season so that goshawk 

reproductive success is not affected 

by human activities. 

GDs for TES: Potentially disturbing project-related activities should be 

minimized in occupied goshawk nest areas during nesting season of 

March 1 through September 30. Project activities and special uses should 

be designed and implemented to maintain refugia and critical life cycle 

needs of Forest Service Sensitive Species. 

Redundant guidance, mentioned 

in 3 different places within 

goshawk section of 1988 plan, 

mentioned as both a ST and a 

GD. Has been replaced by 2 

unique but complementary 

guidelines in the TES section of 

the revised plan. 

Goshawk Forest wide GDs for human

disturbance. Low intensity ground 

fires are allowed at any time in all 

forested cover types, but high 

intensity crown fires are not 

acceptable in the post-fledgling family 

area or nest areas. Avoid burning 

the entire home range of a goshawk 

pair in a single year. For fires 

planned in the occupied nest area, a 

fire management plan should be 

prepared. The fire management plan 

should minimize the risk of goshawk 

abandonment while low intensity 

ground fire burns in the nesting area. 

Prescribed fire within nesting areas 

should be planned to move with 

prevailing winds away from the nest 

tree to minimize smoke and risk of 

crown fire developing and driving the 

adults off or consuming the nest tree. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildland Fire Management DC: Wildland 

fires burn within the range of intensity and frequency of the historic fire 

regime of the vegetation community. Uncharacteristic high-severity fires 

rarely occur, and do not burn at the landscape scale. Develop objectives 

and courses of action to address the desired conditions for wildlife habitat 

and key habitat features such as snags, logs, large tree-form oaks, and 

oak thickets. ST: Managers will use a decision support process to guide 

and document wildfire management decisions. GDs: Decision documents, 

which define the objectives and document line officer approval of the 

strategies chosen for wildfires that progress past initial attack, should 

include interdisciplinary input to assess site-specific values at risk and 

develop incident objectives and courses of action to enhance or protect 

those values. At a minimum, the interdisciplinary team should: Identify 

smoke sensitive receptors, and identify appropriate objectives and 

courses of action to minimize and mitigate impacts to those receptors. 

Develop objectives and courses of action to address the desired 

conditions for wildlife habitat and key habitat features such as snags, logs, 

large tree-form oaks, and oak thickets. If current or anticipated fire 

behavior and fire effects exceed the desired fire behavior and effects, 

protection objectives should be developed for wildfires, or a more 

conservative prescription window should be produced for prescribed 

burns. Strategies and tactics to mitigate those effects should be 

implemented on active wildland fires.

FSM 

5140.3, 

Interagency 

Prescribed 

Fire 

Planning 

and 

Implementa

tion Guide 

(incorporate

d by 

reference). 

Guidance 

for the 

Implementa

tion of 

Federal 

Wildland 

Fire 

Manageme

nt Policy, 

2009 

Portions of this are overly 

prescriptive at the plan level and 

redundant with other direction. 

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 613
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide GDs for Ground 

Surface Layer. Manage road 

densities at the lowest level possible. 

Where timber harvesting has been 

prescribed to achieve desired forest 

condition, use small, skid trails in lieu 

of roads. 

DCs for Transportation and Forest Access: Forest roads, bridges, and 

trails provide safe, legal, and reasonable access for recreation 

opportunities and resource management. Resource impacts from roads 

and trails are balanced with the benefits of having the road or trail 

available for use. OBJ: Obliterate or naturalize 20 miles of nonsystem 

roads (unauthorized, decommissioned, etc.) within 10 years of plan 

approval. GDs: Construction of permanent roads or temporary roads in 

semiprimitive nonmotorized areas should be avoided unless required by a 

valid permitted activity. If authorized, roads should be constructed and 

maintained at the lowest maintenance level needed for the intended use. 

Roads should be decommissioned when no longer needed. Roads allow 

for safe and healthy wildlife movement in areas of human development.

The revised plan has more 

direction in the form of DCs, 

OBJs, and GDs than the existing 

plan.

Goshawk Forest wide GDs for Ground 

Surface Layer. Piling of debris 

should be limited. When necessary, 

hand or grapple piling should be used 

to minimize soil compaction within 

piles and to minimize forest floor and 

herbaceous layer displacement and 

destruction.

GDs for Soils and Watershed Management: Projects should incorporate 

the national best management practices for water quality management 

and include design features to protect and improve watershed condition. 

Wildlife Management Approach: The Kaibab NF references current 

literature and the best available science when making site specific 

decisions relevant to project planning. This is done in an interdisciplinary 

context with input from other resource specialists. 

Overly prescriptive. Addressed 

through DCs and GDs for 

Vegetation communities, soils

and watersheds above.

Goshawk GDs for timber in EMAs 2, 10, 13. 

In northern goshawk existing nest 

areas, the nesting area may be 

thinned from below removing 

suppressed and intermediate trees, 

using prescribed fire or hand 

operated tools. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

Management Approach Ponderosa Pine: Tools for creating desired 

stand conditions and openings include a variety of treatments and unevenaged cutting methods such as matrix thinning, all-size free thinning, single 

tree selection, group selection, sanitation and salvage, limited even-aged 

regeneration cutting, thinning, and managed fire.

Overly prescriptive, will vary 

depending on project, site 

conditions and current 

science/available methods

614 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk GDs for timber in EMAs 2,10, 13. In 

northern goshawk replacement nest 

areas, tree-groups may be thinned 

from below; removing, in order: (1) 

mistletoe infected, (2) suppressed, 

(3) intermediate, and (4) codominant 

individuals. Promote varied, irregular 

spacing between trees. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

Management Approach Ponderosa Pine: Tools for creating desired 

stand conditions and openings include a variety of treatments and unevenaged cutting methods such as matrix thinning, all-size free thinning, single 

tree selection, group selection, sanitation and salvage, limited even-aged 

regeneration cutting, thinning, and managed fire.

Overly prescriptive, will vary 

depending on project, site 

conditions and current 

science/available methods

Goshawk GDs for timber in EMAs 2, 10, 13 In 

northern goshawk PFAs, preferred 

method for treating woody debris is, 

in order, prescribed burning fire use, 

lopping and scattering, hand piling, 

machine grapple piling, and lastly, 

crawler tractor piling. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

Overly prescriptive, will vary 

depending on project, site 

conditions and current 

science/available methods

Goshawk GDs for timber in EMAs 2,10, 13. In 

northern goshawk replacement 

nesting areas, preferred method for 

treating woody debris is prescribed 

burning fire use, next, lopping and 

scattering, and last, hand piling. 

Avoid slash piling with crawler tractor. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

Overly prescriptive, will vary 

depending on project, site 

conditions and current 

science/available methods

Goshawk GDs for timber in EMAs 2,10, 13. In 

northern goshawk suitable nesting 

areas, preferred method for treating 

woody debris is prescribed burning 

fire use, next lopping and scattering, 

and lastly, hand piling. 

DCs for TES: Project activities and special uses should be designed and 

implemented to maintain refugia and critical life cycle needs of Forest 

Service Sensitive Species. Wildlife Management Approach: The Kaibab 

NF references current literature and the best available science when 

making site specific decisions relevant to project planning. This is done in 

an interdisciplinary context with input from other resource specialists. 

Overly prescriptive, will vary 

depending on project, site 

conditions and current 

science/available methods

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 615
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Goshawk Forest wide ST for goshawk. When 

activities conducted in conformance 

with these standards and guidelines 

may adversely affect other 

threatened, endangered, or sensitive 

species or may conflict with other 

established recovery plans or 

conservation agreements; consult 

with US Fish and Wildlife Service to 

resolve the conflict. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Wildlife 

Management Approach: The Kaibab NF works with the USFWS and 

other partners to develop conservation measures (e.g. public education to 

reduce human impacts) to prevent listing and to aid to in the recovery and 

delisting of federally listed species. For 10(j) species, such as the 

California condor, this applies inside and outside the designated 

experimental range.

ESA; 2670 ESA (law) requires consultation 

with USFWS for any activity that 

may affect any listed or proposed 

species. Redundant of law, 

regulation, and policy.

Goshawk Forest wide ST for goshawk. Within 

the ranges of the Kaibab pincushion 

cactus, Pediocactus paradinei, and 

the Arizona leatherflower, Clematis 

hirsutissima arizonica, management 

activities needed for the conservation 

of these two species that may conflict 

with northern goshawk standards and 

guidelines will be exempt from the 

conflicting northern goshawk 

standards and guidelines until 

conservation strategies or recovery 

plans (if listed) are developed for the 

two species. 

Pediocactus Conservation area Management Approach: Pediocactus

paradinei is managed under a conservation assessment and strategy 

developed by the Forest Service, BLM, and USFWS (USDA et al. 1997). 

This document represents the desire to achieve self-sustaining 

populations of Pediocactus paradinei. 

2670 There is a Pediocactus 

Conservation Strategy and 

Assessment (1997) now in place 

and it is currently being updated. 

Arizona leather flower was 

removed as a candidate species. 

Both species are sensitive 

species. 

616 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Lands Realty Management Direction for 

EMA 1. Provide for efficient 

management of realty resources that 

responds to needs for special land 

uses, rights-of-way, adjustments to 

land ownership, and property corner 

and boundary establishment and 

maintenance. Provide timely 

evaluation, administration, and 

termination of special land uses. 

Minimize the amount of land 

allocated to electronic sites and utility 

corridors consistent with appropriate 

accommodation for these public 

services that can be met only on 

National Forest System lands. 

Acquire lands and interests in lands 

to provide consolidated land 

ownership, public and administrative 

access to National Forest Lands, and 

efficient resource management. 

Identify property corners and 

boundaries to protect National Forest 

landownership by detecting and 

resolving unauthorized land 

occupancy and trespass. Administer 

the Small Tracts Act to resolve 

trespass and improve and 

consolidate National Forest 

landownership.[ 49-51]

DCs for Lands: NFS lands exist in a pattern that promotes efficient 

management, which consists of large contiguous areas that provide 

efficient and effective resource management and wildlife connectivity 

within and across NFS lands. Lands identified for disposal and acquisition 

are displayed on the land adjustment map. DCs for Special Uses:

Special use permits support and contribute to the Kaibab National Forest 

and district niches. Permanent structures associated with special uses are 

concentrated on existing sites or designated corridors, minimizing the 

number of acres encumbered by special use authorizations.

FSM 5470,

FSM 7150 

FSH 5509, 

FSH 2709

It is unclear in the 1988 plan what 

type of direction this is. It is

neither ST nor GD.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 617
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Lands Guidelines for Realty Operations 

and Improvements in EMAs 2, 10, 

13: On lands designated as base-inexchange: a. Limit capital 

investments in range structural or 

non-structural improvements, 

recreation improvements, 

administrative improvements, or 

timber stand improvements, etc, to 

those that can be amortized during 

the anticipated period of continued 

government ownership. b. Design 

heritage practices, such as timber 

sales, to protect or enhance real 

estate values by modifying marking 

prescriptions to retain a component 

of mature trees, ensuring timely 

disposal of activity slash and in 

designing location of permanent 

roads. c. Avoid, where possible, the 

authorization of encumbering special 

uses that detrimentally effect real 

estate values and, where possible, 

locate those that must be 

accommodated in a manner to 

minimize impacts to the value of real 

estate. [39-46]

FSM 5402, 

5403.1, 

5450.2 

This direction in the 1988 plan is 

covered by current policy and 

regulations and not carried 

forward in the revised plan 

Lands Realty Management Direction for 

EMA 8: Administer the Small Tracts 

Act to resolve trespass and improve 

and consolidate National Forest land 

ownership. [56-57]

Small 

Tracts Act 

It is unclear if this is a ST or GD 

under the 1988 plan. This is 

direction is covered by the law 

and not carried forward in the 

revised plan.

Lands Management Direction for right-ofway grants for roads and trails 

EMA 6: Issue only right-of-way 

grants that contribute to the 

management goals of the area.

FSM 

2730.3 

It is unclear if this is a ST or GD 

under the 1988 plan. This 

direction is covered by current 

policy and regulations and not 

carried forward in the revised 

plan

618 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Lands Management Direction for right-ofway grants for roads and trails 

EMA 7: Issue only right-of-way 

grants that contribute to the 

management goals of the area.

FSM 

2730.3 

It is unclear if this is a ST or GD 

under the 1988 plan. This 

direction is covered by current 

policy and regulations and not 

carried forward in the revised 

plan

Minerals GDs for Minerals EMAs 2, 10, 13.

Impose the following operating 

constraints on locatable mineral 

prospecting and exploration activities 

to maintain wildlife habitat 

components and visual and special 

resource objectives: a. Restrict 

surface use and occupancy yearlong 

in foreground of heritage resource 

sites with National Register status.

STs for Mining and Minerals: Surface use and occupancy is restricted 

within foreground of heritage resource sites nominated or listed on the 

National Register of Historic Places. Construction of oil and gas well 

surface facilities within foreground of heritage resource sites with National 

Register status and in the visible foreground of State highways is 

prohibited. GDs: Surface use should be restricted or prohibited in areas 

with habitat for threatened, endangered, and sensitive plant and animal 

species, and for heritage resources nominated or listed on the National 

Register of Historic Places. Use and occupancy should be restricted 

yearlong in areas supporting populations of threatened, endangered, and 

sensitive plant species.

GDs in existing plan elevated to 

STs in new plan.

MSO Forest wide GDs for MSO. The 

activity center is defined as the nest 

site. In the absence of a known nest, 

the activity center should be defined 

as a roost grove commonly used 

during breeding. In the absence of a 

known nest or roost, the activity 

center should be defined as the best 

nest/roost habitat. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA This is a definition, not a GD. Not 

in revised plan glossary but see 

revised MSO recovery plan for 

most current working definition 

(FWS 2012)

MSO Forest wide ST for MSO. Other 

forest and woodland types include all 

ponderosa pine, spruce-fir, 

woodland, and aspen forests outside 

protected and restricted areas. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See most current MSO RP (FWS 

2012)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 619
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide ST for MSO. Protected 

areas include delineated protected 

activity centers; mixed conifer and 

pine-oak forests with slopes greater 

than 40% where timber harvest has 

not occurred in the last 20 years; and 

reserved lands which include 

wilderness, research natural areas, 

wild and scenic rivers, and 

congressionally recognized 

wilderness study areas. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See most current MSO RP (FWS 

2012) for current definition of 

protected habitat.

MSO Forest wide ST for MSO. Restricted 

areas include all mixed-conifer, pineoak, and riparian forests outside of 

protected areas. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See most current MSO RP (FWS 

2012)

MSO Forest wide ST for MSO. Survey all 

potential spotted owl areas including 

protected, restricted, and other forest 

and woodland types within an 

analysis area plus the area 1/2 mile 

beyond the perimeter of the proposed 

treatment area. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See most current MSO RP 

Survey Protocol (Appendix D in 

the revised RP, FWS 2012)

620 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Management direction for MSO. As 

the foregoing example shows, the 

guidelines are the detailed 

information about implementation of 

the standards. While standards and 

guidelines both specify the 

management bounds and 

constraints, the standards contain no 

discretionary elements and the 

guidelines may occasionally contain 

discretionary elements. For example 

one of the Mexican spotted owl 

guidelines is "The Protected Activity 

Center should enclose the best 

possible owl habitat...". The terms 

"should" and "best" imply some 

discretion on the part of the person 

implementing the guideline. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA Descriptive information, not 

necessary in forest plan. Is not 

neither ST nor GD. See MSO RP 

(FWS 2012).

MSO Management direction for MSO. 

Submit protected activity center maps 

and descriptions to the recovery unit 

working group for comment as soon 

as possible after completion of 

surveys.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA Revised MSO RP updated with 

most current procedures (FWS 

2012) Is not neither ST nor GD.

MSO Forest wide ST for MSO. Provide 

three levels of habitat management -

protected, restricted, and other forest 

and woodland types to achieve a 

diversity of habitat conditions across 

the landscape.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA This language is outdated and 

inconsistent with revised MSO 

RP (FWS 2012).

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 621
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide ST for MSO. Establish 

a protected activity center at all 

Mexican spotted owl sites located 

during surveys and all management 

territories established since 1989. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine Pine-oak forests are managed as Mexican 

spotted owl (Strix occidentalis lucida) habitat as discussed under the 

approved revised Recovery Plan for the Mexican Spotted Owl (2012). The 

Kaibab NF works closely with the U.S. Fish and Wildlife Service (USFWS) 

to address the habitat needs of the Mexican spotted owl by minimizing 

disturbance and providing nest/roost habitat, which includes managing for 

areas of closed canopy and desired levels of key structural elements such 

as large old trees, snags, and downed woody debris. Management 

Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir: Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA This language is outdated and 

unclearly written. There have 

been no more management 

territories established since 1989, 

only PACs.

MSO Forest wide ST for MSO. Allow no 

timber harvest except for fire risk 

abatement in mixed conifer and pineoak forests on slopes greater than 

40%where timber harvest has not 

occurred in the last 20 years.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA This language is outdated and 

inconsistent with revised MSO 

RP (FWS 2012).

622 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide STs for MSO. Allow no 

timber harvest except for fuelwood 

and fire risk abatement in established 

protected activity centers. For 

protected activity centers destroyed 

by fire, windstorm, or other natural 

disaster, salvage timber harvest or 

declassification may be allowed after 

evaluation on a case-by-case basis in 

consultation with US Fish and Wildlife 

Service. Limit human activity in 

protected activity centers during the 

breeding season. In protected and 

restricted areas, when activities 

conducted in conformance with these 

standards and guidelines may 

adversely affect other threatened, 

endangered, or sensitive species or 

may conflict with other established 

recovery plans or conservation 

agreements; consult with US Fish 

and Wildlife Service to resolve the 

conflict. Monitor changes in owl 

populations and habitat needed for 

de-listing.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine. Pine-oak forests are managed as Mexican 

spotted owl (Strix occidentalis lucida) habitat as discussed under the 

approved revised Recovery Plan for the Mexican Spotted Owl (2012). The 

Kaibab NF works closely with the U.S. Fish and Wildlife Service (USFWS) 

to address the habitat needs of the Mexican spotted owl by minimizing 

disturbance and providing nest/roost habitat, which includes managing for 

areas of closed canopy and desired levels of key structural elements such 

as large old trees, snags, and downed woody debris. Management 

Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir: Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA , FSM 

2670.31

This language is outdated and 

inconsistent with revised MSO 

RP (FWS 2012). ESA (law) 

requires consultation with 

USFWS for any activity that may 

affect any listed or proposed 

species. Redundant of law, 

regulation, and policy

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 623
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO. Breeding 

season is March 1 to August 31. 

Conduct surveys following Region 3 

survey protocol.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine Pine-oak forests are managed as Mexican 

spotted owl (Strix occidentalis lucida) habitat as discussed under the 

approved revised Recovery Plan for the Mexican Spotted Owl (2012). The 

Kaibab NF works closely with the U.S. Fish and Wildlife Service (USFWS) 

to address the habitat needs of the Mexican spotted owl by minimizing 

disturbance and providing nest/roost habitat, which includes managing for 

areas of closed canopy and desired levels of key structural elements such 

as large old trees, snags, and downed woody debris. Management 

Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir: Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA See revised MSO RP (FWS 

2012)

MSO Forest wide GD for MSO in PACs. 

Delineate an area of not less than 

600 acres around the activity center 

using boundaries of known habitat 

polygons and/or topographic 

features. Written justification for 

boundary delineation should be 

provided.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine Pine-oak forests are managed as Mexican 

spotted owl (Strix occidentalis lucida) habitat as discussed under the 

approved revised Recovery Plan for the Mexican Spotted Owl (2012). The 

Kaibab NF works closely with the U.S. Fish and Wildlife Service (USFWS) 

to address the habitat needs of the Mexican spotted owl by minimizing 

disturbance and providing nest/roost habitat, which includes managing for 

areas of closed canopy and desired levels of key structural elements such 

as large old trees, snags, and downed woody debris. Management 

Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir: Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA See revised MSO RP (FWS 

2012)

624 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in PACs. 

Generally allow continuation of the 

level of recreation activities that was 

occurring prior to listing. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine: Pine-oak forests are managed as Mexican 

spotted owl (Strix occidentalis lucida) habitat as discussed under the 

approved revised Recovery Plan for the Mexican Spotted Owl (2012). The 

Kaibab NF works closely with the U.S. Fish and Wildlife Service (USFWS) 

to address the habitat needs of the Mexican spotted owl by minimizing 

disturbance and providing nest/roost habitat, which includes managing for 

areas of closed canopy and desired levels of key structural elements such 

as large old trees, snags, and downed woody debris. Management 

Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir: Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA Existing GD reads more as a 

Management Approach. 

MSO Forest wide GD for MSO in PACs. 

Protected Activity Center boundaries 

should not overlap.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

See revised MSO RP (FWS 

2012)

MSO Forest wide GD for MSO in PACs. 

Require bird guides to apply for and 

obtain a special use permit. A 

condition of the permit shall be that 

they obtain a sub-permit under the 

U.S. Fish and Wildlife Service Master 

endangered species permit. The 

permit should stipulate the sites, 

dates, number of visits and maximum 

group size permissible. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See revised MSO RP (FWS 

2012)

MSO Forest wide GD for MSO in PACs.

Road or trail building in protected 

activity centers should be avoided but 

maybe permitted on a case-by-case 

basis for pressing management 

reasons.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

See revised MSO RP (FWS 

2012)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 625
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in PACs. 

Harvest fuelwood when it can be 

done in such a way that effects on 

the owl are minimized. Manage 

within the following limitations to 

minimize effects on the owl: Harvest 

conifers less than 9 inches in 

diameter only within those protected 

activity centers treated to abate fire 

risk as described below. Designate a 

100 acre "no treatment" area around 

the known nest site of each selected 

protected activity center. Habitat in 

the no treatment area should be as 

similar as possible in structure and 

composition as that found in the 

activity center. Retain key forest 

species such as oak. Retain key 

habitat components such as snags 

and large downed logs. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management 

Approach Ponderosa Pine: Illegal wood cutting is probably the biggest 

threat to oak, as it reduces both the amount and quality of oak habitat. 

Enforcement, education, and site-specific planning will be necessary to 

ensure quality oak habitat over the long term. Firewood collection 

opportunities are managed so site-specific planning and permits may 

specify the amount and size of oak that can be collected in areas where 

live and dead woody oak habitat components are limited. GDs for 

Personal Firewood Collection: The following should be permitted for 

personal use firewood gathering: Dead and downed ponderosa pine, 

Douglas-fir, white fir, spruce, juniper, pinyon pine, Gambel oak, and 

aspen. Standing dead: Ponderosa pine, Douglas-fir, white fir, or spruce 

less than 12 inches d.b.h. or less than 15 feet in total height Juniper 

without green foliage, Pinyon pine less than 12 inches diameter at root 

collar (d.r.c.) or less than 12 feet in height, Gambel oak less than 8 inches 

d.r.c., Aspen less than 12 inches d.b.h. Live trees specifically designated 

by the Forest Service.

ESA Part of this language is outdated 

and inconsistent with revised 

MSO RP (FWS 2012).

MSO Forest wide GD for MSO in PACs.

No seasonal restrictions apply. Treat 

fuel accumulations to abate fire risk. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA See revised MSO RP (FWS 

2012)

MSO Forest wide GD for MSO in PACs.

Pre and post treatment monitoring 

should occur within all steep slopes 

treated for fire risk abatement. (See 

monitoring guidelines)

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA Revised RP had new monitoring 

requirements.

MSO Forest wide GD for MSO in PACs. 

Pre- and post-treatment monitoring 

should be conducted in all protected 

activity centers treated for fire risk 

abatement. (See monitoring 

guidelines)

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA Revised RP had new monitoring 

requirements.

626 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in PACs. 

Reserved Lands (Wilderness, 

Research Natural Areas, Wild and 

Scenic Rivers, and Congressionally 

Recognized Wilderness Study 

Areas). Allow prescribed fire where 

appropriate.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans.

ESA These areas no longer protected 

habitat in revised MSO RP.

MSO Forest wide GD for MSO in PACs.

Retain woody debris larger than 12 

inches in diameter, snags, clumps of 

broad-leafed woody vegetation, and 

hardwood tress larger than 10 inches 

in diameter at the root collar. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. DC 

Ponderosa Pine (Mid-scale): Downed logs (greater than 12 inches 

diameter at mid-point and greater than 8 feet long) average 3 logs per 

acre. Coarse woody debris greater than 3 inches in diameter (including 

downed logs), ranges from 3 to 10 tons per acre. (Land-scape scale):

Old growth occurs throughout the landscape, generally in small areas as 

individual old growth components, or as clumps of old growth. Old growth 

components include old trees, snags, coarse woody debris, and structural 

diversity. DC Mixed Conifer (Fine-scale): Snags and green snags 18 

inches d.b.h. or greater average three per acre. Downed logs (greater 

than 12 inches diameter at mid-point and greater than 8 feet long) average 

three per acre within the forested area of mid-scale units. Coarse woody 

debris, including downed logs, ranges from 5 to 15 tons per acre. 

(Landscape-scale): Old growth occurs throughout the landscape, 

generally in small areas as individual old growth components, or as 

clumps of old growth. Old growth components include old trees, snags, 

coarse woody debris, and structural diversity. DC Mesic Mixed 

Conifer/Spruce Fir (Mid-scale): The number of snags and downed logs 

(greater than 12 inches diameter at mid-point, over 8 feet long) and coarse 

woody debris (greater than 3 inches diameter) vary by seral stage. Snags 

18 inches or greater d.b.h. typically range from one to five snags per acre, 

with the lower range associated with early seral stages and the upper 

range associated with late seral stages. Coarse woody debris, including 

downed logs, vary by seral stage, with averages ranging from 5 to 20 tons 

per acre for early seral stages; 20 to 40 tons per acre for mid-seral stages; 

and 35 tons per acre or greater for late seral stages. (Landscape-scale):

Old growth generally occurs over large areas as stands or forests. Old 

growth includes old trees, snags, coarse woody debris, and structural 

diversity. 

ESA Revised as forest wide guidance 

for relevant vegetation types. 

Consistent with MSO RP.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 627
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in PACs. 

Select and treat additional protected 

activity centers in 10% increments if 

monitoring of the initial sample shows 

there were no negative impacts or 

there were negative impacts which 

can be mitigated by modifying 

treatment methods.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Revised RP had new monitoring 

requirements.

MSO Forest wide GD for MSO in PACs.

Select for treatment 10% of the 

protected activity centers where nest 

sites are known in each recovery unit 

having high fire risk conditions. 

Also select another 10% of the 

protected activity centers where nest 

sites are known as a paired sample 

to serve as control areas.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Revised RP had new monitoring 

requirements.

MSO Forest wide GD for MSO in 

Protective Habitat. Steep Slopes 

(Mixed conifer and pine-oak forests 

outside protected activity centers with 

slopes greater than 40% that have 

not been logged within the past 20 

years)

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Inconsistent with revised MSO 

RP direction

MSO Forest wide GD for MSO in PACs.

Treat fuel accumulations to abate fire 

risk.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. OBJ for 

Ponderosa Pine: To make progress toward the desired conditions and 

reduce the potential for active crown fire in ponderosa pine communities at 

a rate that would maintain the desired conditions over time: Mechanically 

thin 11,000 to 19,000 acres annually. 

Treat an average of 13,000 to 55,000 acres annually, using a combination 

of prescribed fire and naturally ignited wildfires. OBJ. Vegetation 

Management in Frequent Fire MC: To reduce the potential for active 

crown fire and restore frequent fire mixed conifer communities: 

Burn an average of 1,000 to 13,000 acres annually, using prescribed fire 

and/or naturally ignited wildfires. Mechanically thin 1,200 to 2,100 acres 

annually.

ESA See revised MSO RP (FWS 

2012)

628 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in PACs.

Use combinations of thinning trees 

less than 9 inches in diameter, 

mechanical fuel treatment and 

prescribed fire to abate fire risk in the 

remainder of the selected protected 

activity center outside the 100 acre 

"no treatment" area.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Inconsistent with revised MSO 

RP direction

MSO Forest wide GD for MSO in PACs. 

Use light prescribed burns in nonselected protected activity centers on 

a case-by-case basis. Burning 

should avoid a 100 acre "no 

treatment" area around the activity 

center. Large woody debris, snags, 

clumps of broad-leafed woody 

vegetation should be retained and 

hardwood trees larger than 10 inches 

diameter at the root collar.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Inconsistent with revised MSO 

RP direction

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 629
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO Forest wide GD for MSO in 

Restricted Areas. Attempt to mimic 

natural disturbance patterns by 

incorporating natural variation, such 

as irregular tree spacing and various 

patch sizes, into management 

prescriptions. Maintain all species of 

native trees in the landscape 

including early seral species. Allow 

natural canopy gap processes to 

occur, thus producing horizontal 

variation in stand structure. 

Emphasize uneven-aged 

management systems. However, 

both even-aged and uneven-aged 

systems may be used where 

appropriate to provide variation in 

existing stand structure and species 

diversity. Existing stand conditions 

will determine which system is 

appropriate.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. GDs for 

Vegetation Management in all Forested Communities: Projects in 

forested communities that change stand structure should generally retain 

at least historic frequencies of trees by species across broad age and 

diameter classes at the mid-scale. As such, the largest and oldest trees 

are usually retained. Project design should manage for replacement 

structural stages to assure continuous representation of old growth over 

time. Even aged silvicultural practices may be used as a strategy for 

achieving the desired conditions over the long term, such as bringing 

dwarf mistletoe infection levels to within a sustainable range, or old tree 

retention. Management Approach: On the Kaibab NF, the predominate 

vegetation management strategies are uneven-aged management 

systems. This is because vegetation management objectives were only 

developed for the ponderosa pine and frequent fire vegetation types, both 

of which have uneven aged desired conditions. Even aged management 

prescriptions are, however, used as a strategy for achieving the desired 

uneven-aged conditions over the long term. Even-aged prescriptions are 

appropriate when they would increase or maintain a trajectory toward 

desired conditions such as to regenerate aspen or when mistletoe 

infections are moderate to severe and the ability of the area to achieve the 

desired conditions would be significantly impaired. Also see DCs for 

Ponderosa Pine, Frequent Fire MC, and Mesic MC/Spruce Fir.

ESA Restricted is not a designation 

with revised MSO RP.

See revised MSO RP (FWS 

2012)

630 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Restricted (MC, Pine 

oak, and Riparian) Manage to 

ensure a sustained level of owl 

nest/roost habitat well distributed 

across the landscape. Create 

replacement owl nest/roost habitat 

where appropriate while providing a 

diversity of stand conditions across 

the landscape to ensure habitat for a 

diversity of prey species.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. DC 

Ponderosa Pine (Mid-scale): Forest conditions in some areas contain 10 

to 20 percent higher basal area in mid-aged to old tree groups than in the 

general forest (e.g., goshawk post-fledging family areas, Mexican spotted 

owl nesting/roosting habitat, drainages, and steep north-facing slopes). 

DC Frequent Fire MC (Mid-scale): Forest conditions in some areas 

contain 10 to 20 percent higher basal area in mid-aged to old tree groups 

than in the general forest; these include goshawk post-fledging family 

areas, Mexican spotted owl nesting/roosting habitat, and north-facing 

slopes. Interspaces with native grass, forb, and shrub vegetation typically 

range from 10 to 50 percent of the area. DC Mesic MC/Spruce Fir (Midscale): Forest conditions in some areas contain higher basal area than 

the general Forest; examples include goshawk post-family fledgling areas, 

Mexican spotted owl nesting and roosting habitat, and north-facing slopes. 

Management Approach Ponderosa Pine: Pine-oak forests are managed 

as Mexican spotted owl (Strix occidentalis lucida) habitat as discussed 

under the approved revised Recovery Plan for the Mexican Spotted Owl 

(2012). The Kaibab NF works closely with the U.S. Fish and Wildlife 

Service (USFWS) to address the habitat needs of the Mexican spotted owl 

by minimizing disturbance and providing nest/roost habitat, which includes 

managing for areas of closed canopy and desired levels of key structural 

elements such as large old trees, snags, and downed woody debris. 

Management Approach Frequent Fire Mixed Conifer and Mesic Mixed 

Conifer/Spruce Fir : Forest is managed as Mexican spotted owl habitat 

under the approved “Mexican Spotted Owl Recovery Plan, First Revision” 

(USFWS 2012). The Kaibab NF works closely with the USFWS to address 

the habitat needs of Mexican spotted owls by minimizing disturbance, 

providing for some areas of denser forest, and managing for desired levels 

of key structural elements (e.g., large old trees and snags, downed woody 

debris) important for nesting, foraging, and dispersal. 

ESA Restricted is not a designation 

with MSO RP.

See revised MSO RP (FWS 

2012)

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 631
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Restricted 

(Nest/Roost). The following table 

displays the minimum percentage of 

restricted area which should be 

managed to have nest/roost 

characteristics. The minimum mixed 

conifer restricted area includes 10% 

at 170 basal area and an additional 

15% of area at 150 basal area. The 

variables are for stand averages, are 

minimum threshold values and must 

be met simultaneously. In project 

design, no stands simultaneously 

meeting or exceeding the minimum 

threshold values should be reduced 

below the threshold values unless a 

district-wide or larger landscape 

analysis of restricted areas shows 

that there is a surplus of restricted 

area acres simultaneously meeting 

the threshold values. Management 

should be designed to create 

minimum threshold conditions on 

project areas where there is a deficit 

of stands simultaneously meeting 

minimum threshold conditions unless 

the district-wide or larger landscape 

analysis shows there is a surplus. 

Table 13. Minimum Percentage of 

Restricted Area Managed for 

Nest/Roost Characteristics

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Restricted is not a designation in 

revised MSO RP, See tables C1-

C2 in revised MSO RP for current 

allocations.

MSO GDs for MSO Restricted (MC, Pine 

oak, and Riparian). Encourage 

prescribed and prescribed natural 

wildland fire use to reduce hazardous 

fuel accumulation. Thinning from 

below may be desirable or necessary 

before burning to reduce ladder fuels 

and the risk of crown fire.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Restricted is not a designation in 

revised MSO RP, See tables C1-

C2 in MSO RP for current 

allocations.

632 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Restricted (MC, Pine 

oak, and Riparian). Extend rotation 

ages for even-aged stands to greater 

than 200 years. Silvicultural 

prescriptions should explicitly state 

when vegetative manipulation will 

cease until rotation age is reached.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Restricted is not a designation in 

revised MSO RP, See tables C1-

C2 in MSO RP for current 

allocations.

MSO GDs for MSO Restricted (MC, Pine 

oak, and Riparian).In pine-oak 

forests, retain existing large oaks and 

promote growth of additional large 

oaks. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. GDs 

Vegetation Management in all Forested Communities: Project design 

and treatment prescriptions should generally not remove: Gambel oak >8 

inches, diameter at root collar. DC Ponderosa Pine (Fine-scale): Where 

historically occurring, Gambel oak thickets with various diameter stems 

and low growing, shrubby oak are present. These thickets provide forage, 

cover, and habitat for species that depend on them such as small 

mammals, foliage nesting birds, deer, and elk. Gambel oak mast (acorns) 

provides food for wildlife species. Large tree form oaks, snags, and partial 

snags with hollow boles or limbs are present. Where Gambel oak 

comprises more than 10 percent of the basal area, it is not uncommon for 

canopy cover to be greater than 40 percent. 

Restricted is not a designation in 

revised MSO RP, See tables C1-

C2 in MSO RP for current 

allocations.

MSO GDs for MSO Restricted (MC, Pine 

oak, and Riparian).Retain 

substantive amounts of key habitat 

components: Snags 18 inches in 

diameter and larger down logs over 

12 inches midpoint diameter 

hardwoods for retention, recruitment, 

and replacement of large hardwoods. 

Save all trees greater than 24 inches 

dbh. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. GDs 

Vegetation Management in all Forested Communities: Projects in 

forested communities that change stand structure should generally retain 

at least historic frequencies of trees by species across broad age and 

diameter classes at the mid-scale. As such, the largest and oldest trees 

are usually retained. Project design should manage for replacement 

structural stages to assure continuous representation of old growth over 

time. Project design and treatment prescriptions should generally not 

remove: Large, old ponderosa pine trees with reddish-yellow, wide platy 

bark, flattened tops, with moderate to full crowns and large drooping or 

gnarled limbs (e.g. Thomson’s age class 4, Dunning’s tree class 5 and/or 

Keen’s Tree Class 4, A and B [appendix C]). Large snags, partial snags, 

and trees (>18 inches d.b.h.) with broken tops cavities, sloughing bark, 

lightning scars >4 inches wide, and large stick nests (>18 inches in 

diameter). Gambel oak >8 inches, diameter at root collar. PP DCs midscale: Snags 18 in diameter at d.b.h. or greater average 1 to 2 snags per 

All the language is not consistent 

with the revised MSO RP. See

revised MSO RP, See tables C1-

C2 in MSO RP for current 

allocations.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 633
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

acre. Snags and green snags of various sizes and forms are common. 

Downed logs (> 12 in diameter at mid-point, over 8 ft long) average 3 logs 

per acre within the forested area of the landscape. Coarse woody debris > 

3 inches in diameter (including downed logs), ranges from 3 to 10 tons per 

acre. Frequent Fire MC DCs mid-scale: Snags and green snags, 18 in 

d.b.h. or greater average 3 per acre. Downed logs (> 12 in diameter at 

mid-point, over 8 ft long) average three per acre within the forested area of 

mid-scale units. Coarse woody debris, including downed logs, ranges from 

5 to 15 tons per acre. PP and Frequent Fire MC DCs landscape scale: 

Old growth occurs throughout the landscape, generally in small areas as 

individual old growth components, or as clumps of old growth. Old growth 

components include old trees, dead trees (snags), downed wood (coarse 

woody debris), and structural diversity. The location of old growth shifts on 

the landscape over time as a result of succession and disturbance (tree 

growth and mortality). Mesic MC DC mid-scale: The number of snags 

and downed logs (> 12 in diameter at mid-point, over 8 ft long) and coarse 

woody debris (> 3 inches diameter) vary by seral stage. Snags 18 in or 

greater at d.b.h. typically range from 1 to 5 snags per acre, with the lower 

range associated with early seral stages and the upper range associated 

with late seral stages. Coarse woody debris, including downed logs, vary 

by seral stage, with averages ranging from 5 to 20 tons per acre for early 

seral stages; 20 to 40 tons per acre for mid-seral stages; and 35 tons per 

acre or greater for late seral stages. Also see Management Approach 

sections under Ponderosa Pine, Frequent Fire Mixed Conifer, and 

Mesic Mixed Conifer/Spruce Fir.

634 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO in Riparian Areas. 

Emphasize maintenance and 

restoration of healthy riparian 

ecosystems through conformance 

with forest plan riparian standards 

and guidelines. Management 

strategies should move degraded 

riparian vegetation toward good 

condition as soon as possible. 

Damage to riparian vegetation, 

stream banks, and channels should 

be prevented. 

Reframed as an OBJ under Natural Waters: Protect and/or restore at 

least 10 individual springs within 5 years of plan approval. DCs Natural 

Waters: Stream channel stability and aquatic habitats retain their inherent 

resilience to disturbances and climate fluctuations. Stream channel 

morphology reflects changes in the hydrological balance, runoff, and 

sediment supply appropriate to the landscape setting. Springs and ponds 

have the necessary soil, water, and vegetation attributes to be healthy and 

functioning. Water levels, flow patterns, groundwater recharge rates, and 

geochemistry are similar to reference conditions. Springs, streams, and 

ponds have appropriate plant cover to protect banks and shorelines from 

excessive erosion. The necessary physical and biological components, 

including cover, forage, water, microclimate, and nesting/breeding habitat, 

provide habitat for a diverse community of plant and wildlife species. DCs 

Wetlands/Cienegas: Wetland conditions are consistent with their flood 

regime and flood potential. Wetlands infiltrate water, recycle nutrients, 

resist erosion, and function properly. OBJ: Restore native vegetation and 

natural water flow patterns on at least 6 acres of wetlands within 5 years 

of plan approval. DCs for Cottonwood-willow Riparian Forest: The 

extent, diversity, and condition of riparian habitat contribute to ecological 

sustainability. Dense shrubbery and high levels of vegetative diversity 

(structural and compositional) and permanent water provide food, cover, 

and water for wildlife, including terrestrial and aquatic invertebrates and 

vertebrates. 

Water flow regime approximates reference conditions (i.e., perennial 

flows) and flows freely. Sedimentation is minimized. Springtime flooding 

contributes to ecosystem sustainability by optimizing germination 

conditions for seedlings and/or suckering opportunities from the parent 

plant.

Much of this guidance is 

redundant with riparian direction. 

Also see comments for riparian 

habitat in goshawk habitat above.

MSO GDs for MSO Old growth. Except 

where otherwise noted, implement 

forest plan old growth standards and 

guidelines to maintain and promote 

development of owl habitat.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA Redundant with old growth 

direction.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 635
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Other Forest and 

Woodland. Apply ecosystem 

approaches to manage for landscape 

diversity mimicking natural 

disturbance patterns, incorporating 

natural variation in stand conditions 

and retaining special features such 

as snags and large trees, utilizing 

appropriate fires, and retention of 

existing old growth in accordance 

with forest plan old-growth standards 

and guidelines. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. DC 

Ponderosa Pine (Land-scape scale): Old growth occurs throughout the 

landscape, generally in small areas as individual old growth components, 

or as clumps of old growth. Old growth components include old trees, 

snags, coarse woody debris, and structural diversity. The location of old 

growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). DC for all Pinyon-Juniper 

Communities: Pinyon-juniper communities occur as a shifting mosaic 

interspersed with openings across the landscape. The configuration of 

vegetation and openings provides foraging and browsing opportunities for 

wildlife, and enough sighting distance and hiding cover for pronghorn to 

escape predators. Old growth occurs throughout the landscape, generally 

in small areas as individual components, or as clumps. The location of old 

growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). The mature groups of trees are 

structurally diverse, containing large live trees, as well as trees with dead 

or broken tops, gnarls, and burls. Snags, green snags, and downed trees 

> 10′′ at root collar are present and average 1 to 2 per acre. Some tree 

groups have 30 to 40 percent canopy cover that provides habitat for 

nesting, bedding, and foraging.

ESA Revised as DCs.

MSO GDs for MSO Livestock Grazing. 

Implement forest plan forage 

utilization standards and guidelines to 

maintain owl prey availability, 

maintain potential for beneficial fire 

while inhibiting potential destructive 

fire, maintain and restore riparian 

ecosystems, and promote 

development of owl habitat. Strive to 

attain good to excellent range 

conditions.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. DCs for 

Livestock Grazing: Livestock use is consistent with other desired 

conditions.

ESA Now done through site-specific 

range NEPA on allotments and 

annual operating instructions. 

636 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Monitoring.

Monitoring and evaluation should be 

collaboratively planned and 

coordinated with involvement from 

each national forest, USFWS 

Ecological Services Field Office, 

USFWS Regional Office, USFS 

Regional Office, Rocky Mountain 

Research Station, recovery team, 

and recovery unit working groups. 

Population monitoring should be a 

collaborative effort with participation 

of all appropriate resource agencies. 

Habitat monitoring of gross habitat 

changes should be a collaborative 

effort of all appropriate resource 

agencies. Habitat monitoring of 

treatment effects (pre and post 

treatment) should be done by the 

agency conducting the treatment. 

Prepare an annual monitoring and 

evaluation report covering all levels 

of monitoring done in the previous 

year. The annual report should be 

forwarded to the Regional Forester 

with copies provided to the recovery 

unit working groups, USFWS 

Ecological Services field offices, and 

the USFWS Regional Office.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Management

Approach for TES: The Kaibab NF maintains strong partnerships 

between the State, other federal agencies, academia, and nongovernment 

organizations to provide for TES species. Emphasis is placed on the 

protection and replacement of key habitats that contain threatened, 

endangered, and/or sensitive species of plants and animals. The Kaibab 

NF works with the USFWS and other partners to develop conservation 

measures (e.g. public education to reduce human impacts) to prevent 

listing and to aid to in the recovery and delisting of federally listed species. 

For 10(j) species, such as the California condor, this applies inside and 

outside the designated experimental range.

ESA As written, this direction reads 

more as a management 

approach. MSO RP (2012) 

highlights strategies for 

monitoring and collaboration.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 637
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Monitoring 

Rangewide. Track gross changes in 

acres of owl habitat resulting from 

natural and human caused 

disturbances. Acreage changes in 

vegetation composition, structure, 

and density should be tracked, 

evaluated, and reported. Remote 

sensing techniques should provide 

an adequate level of accuracy. In 

protected and restricted areas where 

silvicultural or fire abatement 

treatments are planned, monitor 

treated stands pre and post treatment 

to determine changes and 

trajectories in fuel levels; snag basal 

areas; live tree basal areas; volume 

of down logs over 12 inches in 

diameter; and basal area of 

hardwood trees over 10 inches in 

diameter at the root crown.

Relevant Monitoring Plan Questions: 01 Ponderosa Pine and 

Frequent Fire Mixed Conifer: Are snags, coarse woody debris, downed 

logs and large old trees at desired levels at the midscale (100-1,000 acre 

average)? 07 Ponderosa Pine and Frequent Fire Mixed Conifer: How 

many acres of the Kaibab NF is in an uneven aged open state, at the 

midscale (above 100 acres)? 15 Fire Adapted Ecosystems How many 

acres were burned with desired and undesired fire behavior and effects? 

16 Fire Adapted Ecosystems How many acres were treated with 

mechanical thinning by PNVT? GDs for TES: Project activities and 

special uses occurring within federally listed species habitat should 

integrate habitat management objectives and species protection measures 

from approved recovery plans. 

ESA Has been modified from a GD to 

monitoring questions to better 

reflect effectiveness monitoring of 

the revised forest plan and to 

support the revised MSO RP 

(FWS 2012).

638 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

MSO GDs for MSO Monitoring Upper 

Gila RUs. Assist the recovery team 

and recovery unit working group to 

establish sampling units consisting of 

19 to 39 square mile quadrats 

randomly allocated to habitat strata. 

Quadrats should be defined based on 

ecological boundaries such as ridge 

lines and watersheds. Quadrat 

boundaries should not traverse owl 

territories. Twenty percent of the 

quadrats will be replaced each year 

at random. Using the sample 

quadrats, monitor the number of 

territorial individuals and pairs per 

quadrat; reproduction; apparent 

survival; recruitment; and age 

structure. Track population density 

both per quadrat and habitat stratum.

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. 

ESA This is outdated. The Recovery 

team has determined this 

sampling strategy to be 

unfeasible and it has been 

replaced with new monitoring 

design. The revised MSO RP 

speaks to new approaches for 

monitoring and evaluation.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 639
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Old 

Growth

Forest wide ST for Old Growth. 

Until the forest plan is revised, 

allocate no less than 20 percent of 

each forested ecosystem 

management area to old growth as 

depicted in the table below. In the 

long term, manage old growth in 

patterns that provide for a flow of 

functions and interactions at multiple 

scales across the landscape through 

time. Allocations will consist of 

landscape percentages meeting old 

growth conditions and not specific 

acres. 

GDs for Vegetation Management in all Forested Communities:

Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across 

broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. Project design should manage for 

replacement structural stages to assure continuous representation of old 

growth over time. DC Ponderosa Pine and Frequent Fire Mixed Conifer 

(Landscape scale): Old growth occurs throughout the landscape, 

generally in small areas as individual old growth components, or as 

clumps of old growth. Old growth components include old trees, snags, 

coarse woody debris, and structural diversity. The location of old growth 

shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). DCs Mesic Mixed 

Conifer/Spruce Fir: Old growth generally occurs over large areas as 

stands or forests. Old growth includes old trees, snags, coarse woody 

debris, and structural diversity. The location of old growth shifts on the 

landscape over time as a result of succession and disturbance (tree 

growth and mortality). DCs All Pinyon-juniper Communities: Old growth 

occurs throughout the landscape, generally in small areas as individual 

components, or as clumps. The location of old growth shifts on the

landscape over time as a result of succession and disturbance (tree 

growth and mortality). 

Percentage allocations overly 

prescriptive and outdated as per 

revised forest plan. This is now 

captured by DCs. EMAs are no 

longer a relevant designation 

under the revised plan. Under the 

new plan, the forest is managed 

through a more holistic approach.

Old 

Growth

Forest wide GD for Old Growth.

Strive to create or sustain as much 

old growth compositional, structural, 

and functional flow as possible over 

time at multiple-area scales. Seek to 

develop or retain old growth function 

on at least 20 percent of the naturally 

forested area by forest type in any 

landscape. 

GDs for Vegetation Management in all Forested Communities:

Projects in forested communities that change stand structure should 

generally retain at least historic frequencies of trees by species across 

broad age and diameter classes at the mid-scale. As such, the largest 

and oldest trees are usually retained. Project design should manage for 

replacement structural stages to assure continuous representation of old 

growth over time

Reiterates similar MSO and 

goshawk direction in the 1988 

plan.

640 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Old 

Growth

Forest wide GD for Old Growth. 

Use quantitative models at the 

appropriate scales when considering 

the importance of various factors. 

These models may include, but are 

not limited to: Forest Vegetation 

Simulator, BEHAVE, and FARSITE. 

Forested sites should meet or exceed 

the structural attributes to be 

considered old growth in the five 

primary forest cover types in the 

southwest as depicted in the 

following table. Table 15. Old Growth 

Habitat Characteristics

Relevant Monitoring Plan Questions: 01 Ponderosa Pine and Frequent 

Fire Mixed Conifer: Are snags, coarse woody debris, downed logs and 

large old trees at desired levels at the midscale (100-1,000 acre average)? 

Prescriptive and outdated. See 

glossary for description of 

southwestern old growth. 

Attributes now captured by DCs 

and guidelines. Will be monitored 

through relevant monitoring plan 

questions. Specialists determine 

best methods to use at the 

project level.

Old 

Growth

Forest wide GD for Old Growth. All 

analyses should be at multiple scales 

- one scale above and one scale 

below the ecosystem management 

areas. The amount of old growth can 

be provided and maintained will be 

evaluated at the ecosystem 

management area level and be 

based on forest type, site capability, 

and disturbance regimes. 

See the DC for the Vegetation Communities Types and the 

introduction section that discusses scale.

Prescriptive. Project specialists 

determine scales of analyses 

keeping Forest-wide DCs in mind. 

The DCs in the revised forest 

plan are designed to account for 

scale (fine, mid, and landscape).

Old 

Growth

Forest wide GD for Old Growth. 

Consider the effects of spatial 

arrangement on old growth function, 

from groups to landscapes, including 

de facto allocations to old growth 

such as goshawk nest sites, Mexican 

spotted owl protected activity centers, 

sites protected for species behavior 

associated with old growth, 

wilderness, research natural areas, 

and other forest structures managed 

for old growth function. 

DC Ponderosa Pine (Mid-scale): The ponderosa pine forest vegetation 

community is characterized by variation in the size and number of tree 

groups depending on elevation, soil type, aspect, and site productivity. 

The mosaic of tree groups generally comprises an uneven-aged forest 

with all age classes and structural stages present. Stands are dominated 

by ponderosa pine, but other native hardwood and conifer species occur. 

The more biologically productive sites contain more trees per group and 

more groups per area. Forest conditions in some areas contain 10 to 20 

percent higher basal area in mid-aged to old tree groups than in the 

general forest (e.g., goshawk post-fledging family areas, Mexican spotted 

owl nesting/roosting habitat, drainages, and steep north-facing slopes). 

(Land-scape): Old growth occurs throughout the landscape, generally in 

small areas as individual old growth components, or as clumps of old 

growth. Old growth components include old trees, snags, coarse woody 

debris, and structural diversity. The location of old growth shifts on the 

Redundant with much of the 

goshawk and MSO direction in 

the 1988 plan.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 641
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

landscape over time as a result of succession and disturbance (tree 

growth and mortality). DC Frequent Fire Mixed Conifer (Mid-scale):

Forest conditions in some areas contain 10 to 20 percent higher basal 

area in mid-aged to old tree groups than in the general forest; these 

include goshawk post-fledging family areas, Mexican spotted owl 

nesting/roosting habitat, and north-facing slopes. Interspaces with native 

grass, forb, and shrub vegetation typically range from 10 to 50 percent of 

the area. (Landscape scale): Old growth occurs throughout the 

landscape, generally in small areas as individual old growth components, 

or as clumps of old growth. Old growth components include old trees, 

snags, coarse woody debris, and structural diversity. The location of old 

growth shifts on the landscape over time as a result of succession and 

disturbance (tree growth and mortality). Mesic MC/Spruce Fire (Midscale) Forest conditions in some areas contain higher basal area than the 

general Forest; examples include goshawk post-family fledgling areas, 

Mexican spotted owl nesting and roosting habitat, and north-facing slopes. 

(Landscape scale): Old growth generally occurs over large areas as 

stands or forests. Old growth includes old trees, snags, coarse woody 

debris, and structural diversity. The location of old growth shifts on the 

landscape over time as a result of succession and disturbance (tree 

growth and mortality). DC Pinyon-juniper Communities: Old growth 

occurs throughout the landscape, generally in small areas as individual 

components, or as clumps. The location of old growth shifts on the 

landscape over time as a result of succession and disturbance (tree 

growth and mortality). GDs for Vegetation Management all Forested 

Communities: Projects in forested communities that change stand 

structure should generally retain at least historic frequencies of trees by 

species across broad age and diameter classes at the mid-scale. As 

such, the largest and oldest trees are usually retained. Project design 

should manage for replacement structural stages to assure continuous 

representation of old growth over time. Project design and treatment 

prescriptions should generally not remove: Large, old ponderosa pine 

trees with reddish-yellow, wide platy bark, flattened tops, with moderate to 

full crowns and large drooping or gnarled limbs (e.g. Thomson’s age class 

4, Dunning’s tree class 5 and/or Keen’s Tree Class 4, A and B [appendix 

C]). Large snags, partial snags, and trees (>18 inches d.b.h.) with broken 

tops, cavities, sloughing bark, lightning scars >4 inches wide, and large 

stick nests (>18 inches in diameter). 

642 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Old 

Growth

Forest wide GD for Old Growth. In 

allocating old growth and making 

decisions about old growth 

management, use appropriate 

information about the relative risks to 

sustaining old growth function at the 

appropriate scales, due to natural 

and human-caused events. 

See the DC for the Vegetation Communities Types, management 

approach for the vegetation communities, and the introduction 

section that discusses scale.

Range Forest wide ST for Grazing. Forage 

use by grazing ungulates will be 

maintained at or above a condition 

which assures recovery and 

continued existence of threatened 

and endangered species. 

DC for TES: Threatened, endangered, and sensitive species have quality 

habitat, stable or increasing populations, and are at low risk for extirpation. 

GDs: Project activities and special uses occurring within federally listed 

species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Livestock 

grazing DC: Grasses and forbs provide adequate forage for permitted 

livestock consistent with other desired conditions. Monitoring Plan 

Question 46 Livestock Grazing: Are livestock numbers balanced with 

forage capacity on each allotment? 

Replaced by several DCs and 

GDs. See revised MSO RP 

(USDA 2012)

Range Forest wide GDs for Grazing.

Identify key ungulate forage 

monitoring areas. These key areas 

will normally be 1/4 to 1 mile from 

water, located on productive soils on 

level to intermediate slopes, and be 

readily accessible for grazing. Size 

of the key forage monitoring areas 

could be 20 to 500 acres. In some 

situations such as high mountain 

meadows with perennial streams, key 

areas may be closer than 1/4 mile 

from water and less than 20 acres. 

Within key forage monitoring areas, 

select appropriate key species to 

monitor average allowable use.

DC Livestock Grazing: Grasses and forbs provide adequate forage for 

permitted livestock consistent with other desired conditions. GDs for 

Livestock Grazing: Annual operating instructions for livestock grazing 

permittees should ensure livestock numbers are balanced with capacity 

and address any relevant resource concerns (e.g., forage production, 

weeds, fawning habitat, soils, etc.). Livestock use in and around wetlands 

should be evaluated on an allotment specific basis. Mitigation measures 

such as deferment and fencing (full or partial) should be implemented as 

needed to minimize potential livestock effects. Monitoring Plan Question 

46 Livestock Grazing: Are livestock numbers balanced with forage 

capacity on each allotment? 

FSH 2209 

14.40

Allotment management Plans 

would address forage monitoring

(through NEPA process) on site 

specific basis

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 643
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Range GDs for Rangeland Improvements 

in EMAs 2, 10, 13. In pronghorn 

antelope range, remove net wire 

fences; in the interim, modify every 

one-half mile of such fence to 

facilitate movement.

DCs for Livestock Grazing: Allotment fencing allows for passage of 

animals susceptible to movement restrictions such as pronghorn. OBJ 

Modify fences and/or install crossings to facilitate pronghorn movement on 

50 miles of fence within 10 years of plan approval. GDs: New construction 

and reconstruction of fences should have a barbless bottom wire that is at 

least 18 inches high. Monitoring Plan Question 21 Grasslands: How 

many miles of fence were modified for pronghorn? 

Revised as forest wide guidance. 

Redundant with structural 

improvement direction for 

pronghorn above.

Recreation GDs for Recreation and 

Improvements EMAs 2, 10, 13.

Formulate and implement control 

measures where and when the 

following damage occurs: a. Soil 

compaction. b. Loss of vegetative 

cover. c. Tree damage and mortality. 

d. Deterioration of water quality. 

GDs for Soils and Watersheds: Projects should incorporate the national 

best management practices for water quality management and include 

design features to protect and improve watershed condition. In disturbed 

areas, erosion control measures should be implemented to improve soil 

conditions. Seeds and plants used for revegetation should originate from 

the same PNVT and general ecoregion (i.e. southern Colorado Plateau) 

as the project area.

FSM 

2509.18; 

FSH 

2509.22

Language for the GD was 

updated in the revised plan.

Soil and 

Water

Forest wide GOALS for Riparian: 

Woody riparian communities and 

riparian communities dominated by 

shrub and herbaceous species shall 

be in satisfactory or better condition.

DC Cottonwood Willow Riparian: The extent, diversity, and condition of 

riparian habitat contribute to ecological sustainability. Dense shrubbery 

and high levels of vegetative diversity (structural and compositional) and 

permanent water provide food, cover, and water for wildlife, including 

terrestrial and aquatic invertebrates and vertebrates. Management 

Approach: Program managers work with public affairs to communicate 

the ecological significance of these systems to the broader public and to 

garner support for restoration activities, which may facilitate increasing 

water into these systems. Increased capacity and broad support may be 

gained through partnerships. Work with various stakeholders, including 

the Kaibab Band of Paiute Tribe to restore cottonwood-willow riparian 

vegetation communities.

FSM 

2202.1; 

2522; 2526

Neither ST nor GD under 1988

plan. Translates into a DC for the 

revised plan.

Soil and 

Water

Forest wide GOALS for Riparian:

Inventory all riparian areas (collect 

data regarding location, size, 

classification and condition of the 

riparian).

DC for Natural Waters: The location and status of springs and water 

resources are known, organized, and available. GDs: Forest springs 

information should be maintained in a database that facilitates long-term 

archiving, easy data entry, and comparison with monitoring results.

FSM 

2511.1; 

2526.02; 

2526.03; 

2527; 

2532.03

Neither ST nor GD under 1988 

plan. Translates into a DC for the 

revised plan.

644 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Soil and 

Water

Forest wide GOAL for Soils, Water, 

Air Quality: Rehabilitate nonproductive lands on a planned basis 

to eliminate unsatisfactory watershed 

condition by 2020. 

DCs for Watersheds: Vegetation conditions within watersheds contribute 

to downstream water quality and quantity. Surface runoff, sheet, rill, and

gully erosion, and subsequent sedimentation into connecting waters 

downstream is minimal.

The fuels composition within watersheds does not put the watersheds at 

risk for uncharacteristic disturbance. GDs for Soils and Watershed 

Management: Projects should incorporate the national best management 

practices for water quality management and include design features to 

protect and improve watershed condition. OBJ for Ponderosa Pine: 

Mechanically thin 11,000 to 19,000 acres annually. Treat an average of 

13,000 to 55,000 acres annually, using a combination of prescribed fire 

and naturally ignited wildfires. OBJ for Frequent Fire Mixed Conifer:

Burn an average of 1,000 to 13,000 acres annually, using prescribed fire 

and/or naturally ignited wildfires. Mechanically thin 1,200 to 2,100 acres 

annually. 

FSM 

2510.2; 

2522.1; 

2532.03; 

2526.03

Neither ST nor GD under 1988 

plan. Translates into a DC for the 

revised plan.

Soil and 

Water

Monitoring Plan for Soils, Water, 

Air Quality. Expected Future 

Condition: Improved watershed 

conditions through reduction in the 

amount of watershed in 

unsatisfactory condition. 

DCs Watersheds: Vegetation conditions within watersheds contribute to 

downstream water quality and quantity. Surface runoff, sheet, rill, and 

gully erosion, and subsequent sedimentation into connecting waters 

downstream is minimal. Flooding maintains normal stream characteristics 

(e.g., water transport, sediment, woody material) and dimensions (e.g., 

bankfull width, depth, slope, and sinuosity). Vertical down cutting and 

embeddedness are absent in drainages. Flood plains are functioning and 

lessen the impacts of floods on human safety, health, and welfare. The 

fuels composition within watersheds does not put the watersheds at risk 

for uncharacteristic disturbance. Water quality meets or surpasses State 

of Arizona or Environmental Protection Agency water quality standards for 

designated uses. Water quality meets critical needs of aquatic species. 

Monitoring Plan: Natural and Constructed Waters: Are there any water 

bodies not meeting Arizona water quality standards?

FSM 

2510.2 

(1),(3); 

2522.1; 

2525.03

Neither ST nor GD in 1988 plan. 

Translates into a DC for the 

revised plan.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 645
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Soil and 

Water

Management Direction for Soil and 

Water in EMAs 1, 3,8,9,12,16.

Provide soil and water resource 

integration and coordination in land 

and resource management planning. 

Soils and Watersheds Management Approach: On the Kaibab NF, the 

highest risk to watersheds is uncharacteristic wildfire. Projects that reduce 

this risk and restore the natural vegetative and fuels composition also 

restore watersheds. Projects that reduce this risk and restore the natural 

vegetative and fuels composition also restore watersheds. As a result, the 

Kaibab NF uses an integrated management approach to make progress 

toward the soil and watershed desired conditions. Objectives to address 

these needs are found in the “Major Vegetation Community Types,” 

“Nonnative Invasive Species,” and “Natural Waters” sections of this plan.

With these and other activities, the Kaibab NF generally employs best 

management practices before, during, and after activities to reduce or 

eliminate adverse effects.

FSM 

2510.6; 

2511.02,.03

; 2522.3

Revised plan is inherently 

integrated with other resource 

areas. This is neither a ST nor 

GD in the 1988 plan. Revised as 

a management approach.

Soil and 

Water

GDs for Structural Habitat 

Improvement in EMAs 1, 

3,8,9,12,16. Install structures to 

promote recharge of wet meadows 

and riparian areas.

Wetlands/Cienegas OBJ: Restore native vegetation and natural water 

flow patterns on at least 6 acres of wetlands within 5 years of plan 

approval. Natural Waters OBJ: Protect and/or restore at least 10 

individual springs within 5 years of plan approval.

FSM

2522.12 

Prescriptive as written, 

restoration might not necessarily 

involve structures. Will vary by 

project/site.

Soil and 

Water

Goals for Soil, Water, and Air 

Quality. Maintain soil productivity 

and watershed condition. .... 

Maintain a high quality sustained 

water yield for Forest users and 

others. Identify and protect wetlands 

and floodplains.

Natural Waters DC: Water levels, flow patterns, groundwater recharge 

rates, and geochemistry are similar to reference conditions. Watershed 

DC: Water quality meets or exceeds State of Arizona or Environmental 

Protection Agency water quality standards for designated uses. Water 

quality meets critical needs of aquatic species. Monitoring Plan: Are 

there any water bodies not meeting Arizona water quality standards? 

Constructed Waters DC: Reservoirs maintain high water quality for 

parameters such as temperature, pH, and dissolved oxygen, and water 

levels are within the seasonal range of variable conditions. Monitoring 

Plan: What is the functional condition of the lakes and wetlands on the 

Kaibab NF? Soil DC: Soils can readily absorb, store, and transmit water 

vertically; accept, hold, and release nutrients; and resist erosion. 

Monitoring Plan: Are the effects of forest management resulting in 

changes to the productivity of soils (e.g. evidence of platy structures, 

pedestalling of vegetation or rock, rills)? 

FSM 

2510.2; 

2522.1 

Neither ST nor GD in 1988 plan. 

Revised as DCs

646 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Soil and 

Water

Management Direction for Soils 

and Water in EMAs 1, 3,8,9,12,16.

Formulate and execute land 

treatment measures to (1) close, 

revegetate, and thereby obliterate, 

system roads not needed for 

resource actions and (2) establish 

ground-cover improvements in 

degraded, unsatisfactory watersheds 

to return them to satisfactory 

condition. Provide for the long-term 

maintenance of vegetative groundcover improvements. Maintain soil 

and water inventory and information 

systems. 

OBJ Transportation: Obliterate or naturalize 20 miles of nonsystem 

roads (unauthorized, decommissioned, etc.) within 10 years of plan 

approval. Grade surfaces and clean culverts and ditches on 100 miles of 

open National Forest System roads each year. GD for Transportation: 

Roads should be decommissioned when no longer needed.

FSM 2511; 

2522.1, .2 ; 

2509.22

Not a ST or GD in 1988 plan. 

New plan has specific objectives 

for road treatments and 

rehabilitation. Included in FSH 

2509.22 (Soil and Water 

Conservation Handbook). Also, 

BMPs are found in FS-990a –

National Best Management 

Practices for Water Quality 

Management on National Forest 

System Lands.

Special 

Uses

GOAL for Lands: Minimize the 

number of electronic sites and utility 

corridors consistent with appropriate 

public services that require the use of 

Forest lands. ]

GDs for Communication and Electronic Sites, The number of 

communication and electronic sites should be the minimal that is 

consistent with appropriate public services that require the use of Forest 

lands. Environmental disturbance should be minimized by co-locating 

communication and electronic sites.

DC for Energy Transmission and Development: Energy transmission 

and development on the Kaibab NF meets the legal mandates to facilitate 

the transmission and development of energy resources in a manner that 

minimizes adverse impacts and does not detract from meeting other 

desired conditions applicable to the area. Energy corridors provide a 

reliable supply of energy essential to meet local, regional, and national 

economic demands. Joint use of rights-of-way is provided to concentrate 

uses to the extent possible. SD for Energy Transmission: Major utility 

corridor development is confined to the area identified and mapped in the 

“West-wide Energy Corridor Programmatic EIS (USDOE and BLM 2008).”

FSM 2726,

FSM 2728,

FSH 2709

Neither ST nor GD in 1988 plan. 

Revised as SD and GDs in the 

revised plan.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 647
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Special 

Uses

GDs for Realty Operations in 

EMAs 2,10,13, 1,3,8,9,12,16. Allow 

expansion of existing major utility 

corridors and clearing of new 

corridors (refer to Corridor Map for 

location of major utility corridors). 

Attempt to avoid the following areas:

a.NZ: Areas with pristine, primitive or 

semi-primitive recreation opportunity 

spectrum classifications. b. Areas 

with high heritage resource values. c. 

Important wildlife habitat areas d.NZ: 

Visually sensitive areas. e. ORV 

closure areas. f. Lands classified as 

suitable timberland.

DCs for Energy Transmission and Development: Energy transmission 

and development on the Kaibab NF meets the legal mandates to facilitate 

the transmission and development of energy resources in a manner that 

minimizes adverse impacts and does not detract from meeting other 

desired conditions applicable to the area. Joint use of rights-of-way is 

provided to concentrate uses to the extent possible. Energy transmission 

lines are not visible (usually underground) across the landscape. SD for 

Energy Transmission: Major utility corridor development is confined to 

the area identified and mapped in the “West-wide Energy Corridor 

Programmatic EIS (USDOE and BLM 2008).” GD for Energy 

Transmission and Development: Environmental disturbance should be 

minimized by co-locating pipelines, power lines, fiber optic lines, and 

associated infrastructure. Existing energy corridors should be used to their 

capacity with compatible upgraded power lines, before evaluating new 

routes. When compatible with protection of heritage resources, the use of 

below-ground utilities should be optimized in order to avoid potential 

conflicts with wildlife, scenery, wildfire, and long-term vegetative 

management.

FSM 2726 Reframed in the revised plan as 

DC, SD and GDs. 

Vegetation GDs for Air and Watershed 

Resource Operations and 

Improvements in EMAs 

1,2,3,8,9,10,11,12,13,16,20: Maintain 

not less than three age classes of 

woody riparian species with ten 

percent of the woody plant cover in 

sprouts, suckers, seedlings, and 

saplings. Maintain not less than 90 

percent of the potential shrub cover 

in riparian areas. Maintain not less 

than 90 percent of total linear 

streambank in stable condition.

DC under Cottonwood-willow Riparian Forest: The extent, diversity, 

and condition of riparian habitat contribute to ecological sustainability. 

Dense shrubbery and high levels of vegetative diversity (structural and 

compositional) and permanent water provide food, cover, and water for 

wildlife, including terrestrial and aquatic invertebrates and vertebrates. 

Vegetation is characterized by willow and other herbaceous understory 

species. Snag and gallery tree components comprise 55 percent mid-aged 

to mature cottonwood and willow trees, 25 percent younger trees and 20 

percent in grass, forbs, shrubs, suckers, seedlings, and tree sprouts. DCs 

for Natural Waters: Stream channel stability and aquatic habitats retain 

their inherent resilience to disturbances and climate fluctuations. Stream 

channel morphology reflects changes in the hydrological balance, runoff, 

and sediment supply appropriate to the landscape setting. Springs and 

ponds have the necessary soil, water, and vegetation attributes to be 

healthy and functioning. Water levels, flow patterns, groundwater recharge 

rates, and geochemistry are similar to reference conditions. Springs, 

streams, and ponds have appropriate plant cover to protect banks and 

shorelines from excessive erosion. GDs The impacts of management 

activities on springs, streams, and wetlands should be evaluated and 

minimized.

1988 plan direction unrealistic 

given water rights issues and 

upstream diversions.

648 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Vegetation Riparian Vegetation ST for EMAs 

1, 3,8,9,12,16. Maintain not less than 

90 percent of the potential stream 

shading from May to September 

along all perennial cold or cool water 

streams. Provide shade with tree and 

other vegetational cover. 

DCs Natural Waters: Stream channel stability and aquatic habitats retain 

their inherent resilience to disturbances and climate fluctuations. Stream 

channel morphology reflects changes in the hydrological balance, runoff, 

and sediment supply appropriate to the landscape setting. Springs and 

ponds have the necessary soil, water, and vegetation attributes to be 

healthy and functioning. Water levels, flow patterns, groundwater recharge 

rates, and geochemistry are similar to reference conditions. Springs, 

streams, and ponds have appropriate plant cover to protect banks and 

shorelines from excessive erosion.

ESA Reframed as a DC and ESA 

provides regulatory framework for 

Apache trout habitat.

Wildlife 

and Fish

Goals for Fish and Wildlife:

Cooperate with the Arizona Game 

and Fish Department to achieve 

management goals and objectives 

specified in the Arizona Wildlife and 

Fisheries Comprehensive Plan, and 

in carrying out the cooperative 

agreement for the management of 

the Grand Canyon National Game 

Preserve. Support the Arizona Game 

and Fish Department in meeting its 

objectives for the state. 

Management Approach Wildlife: The Kaibab NF continues to support 

the AGFD in various capacities directed toward managing wildlife, fish, 

and habitat. Areas for potential collaboration include (but are not limited 

to) achieving management goals and objectives specified in Arizona’s 

State Wildlife Action Plan (SWAP), carrying out memoranda of 

understanding (MOUs) and the cooperative agreement for management of 

the Grand Canyon National Game Preserve, and management of 

recreation fisheries.

Descriptive information, not 

necessary in forest plan as a DC, 

ST, or GD.

Wildlife 

and Fish

GDs for Wildlife and Fish 

Improvements in EMAs 2, 10, 13. In 

other coniferous forest timberland: a. 

Encourage and promote oak and 

aspen. b. Encourage diversity of 

plant species in the overstory, 

understory, and ground cover. c. 

Turkey summer and winter home 

ranges. (1) Provide not less than four 

roost-tree groups per 640 acres in 

winter range. (2) Provide not less 

than two roost-tree groups per 640 

acres in summer range. d. Provide 

one permanent water source per 640 

acres. 

DCs for Wildlife: Native wildlife species are distributed throughout their 

potential natural range. Desirable nonnative wildlife species are present 

and in balance with healthy, functioning ecosystems. Habitat is available 

at the appropriate spatial, temporal, compositional, and structural levels 

such that it provides adequate opportunity for breeding, feeding, nesting, 

and carrying out other critical life cycle needs for a variety of vertebrate 

and invertebrate species. Species with specific habitat needs (e.g. snags, 

logs, large trees, interlocking canopy, and cavities) are provided for. Also 

see DCs for Ponderosa pine aspen and Gambel oak

Specific habitat needs will be 

determined at project level. 

Turkeys not being carried forward 

as an MIS. Turkeys provided for 

through the course filter wildlife 

viability analyses by providing 

healthy vegetation conditions and 

structural diversity. No additional 

fine filter habitat needs were 

identified as plan components.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 649
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Wildlife 

and Fish

STs for Wildlife Surveys, Project 

Planning in EMAs 1,3,8,9,12,16 : 1) 

FORAGE: Give priority to areas in 

need of additional forage for elk and 

mule deer when scheduling pinyonjuniper fuelwood special cutting for 

wildlife habitat non-structural 

improvement. Treatments are usually 

done in areas removed from 

disturbance to maximize habitat 

effectiveness.

DCs for Pinyon-juniper: Pinyon-juniper communities occur as a shifting 

mosaic interspersed with openings across the landscape. The 

configuration of vegetation and openings provides foraging and browsing 

opportunities for wildlife, and enough sighting distance and hiding cover 

for pronghorn to escape predators. There are opportunities for collecting 

forest products (firewood, pinyon nuts, posts, and poles, etc.) in a manner 

consistent with other desired conditions. GDS: Pinyon-juniper 

communities should maintain tree densities that maximize herbaceous 

plant growth and wildlife species diversity typical for their respective 

community subtype. Project design for vegetation management activities 

should prioritize treatment areas along known wildlife corridors, in the 

wildland-urban interface, and in historic openings. Restoration treatments 

in pinyon-juniper should be rotated over time and various successional 

stages to maximize wildlife habitat and diversity.

The forest works through an 

MOU with AGFD to provide site 

specific habitat needs for game 

species. Site specific fuelwood 

also handled through special use 

permit process.

Wildlife 

and Fish

STs Wildlife Surveys, Project 

Planning in EMAs 1,3,8,9,12,16 : 1) 

FORAGE: Design projects to achieve 

the following habitat standards: 

Provide forage cover ratios of 40:60 

to 60:40. in areas where TES species 

habitat requirements do not conflict. 

In areas of conflict, new winter 

grazing use by livestock will be 

allowed when such use does not 

adversely affect wildlife objectives. 

Allocate forage to (a) maximize 

habitat capability for threatened and 

endangered species and (b) provide 

habitat capability for indicator and 

harvest species in the range 

specified in the State Comprehensive 

Wildlife Plan.

DCs for wildlife: Habitat is available at the appropriate spatial, temporal, 

compositional, and structural levels such that it provides adequate 

opportunity for breeding, feeding, nesting, and carrying out other critical 

life cycle needs for a variety of vertebrate and invertebrate species. 

Species with specific habitat needs (e.g. snags, logs, large trees, 

interlocking canopy, and cavities) are provided for. Grasses, forbs, and 

shrubs provide forage, cover, fawning, and nesting sites. GDs for TES:

Project activities and special uses occurring within federally listed species 

habitat should integrate habitat management objectives and species 

protection measures from approved recovery plans. Project activities and 

special uses should be designed and implemented to maintain refugia and 

critical life cycle needs of Forest Service Sensitive Species. DCs for 

Livestock: Livestock use is consistent with other desired condition. GDs 

for Livestock Grazing: Annual operating instructions for livestock grazing 

permittees should ensure livestock numbers are balanced with capacity 

and address any relevant resource concerns (e.g., forage production, 

weeds, fawning habitat, soils, etc.). 

ESA Allotment management Plans and 

Annual Operating Instructions 

would address forage and 

utilization (through NEPA 

process) on site specific basis.

650 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Wildlife 

and Fish

STs for Wildlife Surveys, Project 

Planning in EMAs: 1, 3,8,9,12,16 2) 

COVER: Provide for at least 40 

percent cover where TES species 

habitat requirements do not conflict. 

Emphasize cover in travelways, 

bedding areas, reproductive areas, 

and areas adjacent to water sources 

and openings. Cover areas will be at 

least 10 chains in width. Provide for 

hiding and thermal cover in fawning 

and calving areas. Restrict logging 

activities from May 15 to July 1 for elk 

and from June 15 to August 10 for 

mule deer. Provide for not less than 

10 percent thermal cover in 

assessment areas. Emphasize 

thermal cover management in 

travelways, reproductive areas, and 

bedding areas. Provide for not less 

than 10 percent hiding cover in 

assessment areas. Emphasize hiding 

cover adjacent to water sources and 

openings, along travelways, and in 

pine stringers. Hiding cover shall not 

be less than 10 chains in width. 

DCs for wildlife: Habitat is available at the appropriate spatial, temporal, 

compositional, and structural levels such that it provides adequate 

opportunity for breeding, feeding, nesting, and carrying out other critical 

life cycle needs for a variety of vertebrate and invertebrate species. 

Species with specific habitat needs (e.g. snags, logs, large trees, 

interlocking canopy, and cavities) are provided for. Grasses, forbs, and 

shrubs provide forage, cover, fawning, and nesting sites. Interconnected 

forest and grassland habitats allow for movement of wide ranging species 

and promote natural predator-prey relationships, particularly for strongly 

interactive species (e.g., mountain lions). Habitat configuration and 

availability allow wildlife populations to adjust their movements (e.g., 

seasonal migration, foraging, etc.) in response to climate change and 

promote genetic flow between wildlife populations. GDs for TES: Project 

activities and special uses occurring within federally listed species habitat 

should integrate habitat management objectives and species protection 

measures from approved recovery plans. Project activities and special 

uses should be designed and implemented to maintain refugia and critical 

life cycle needs of Forest Service Sensitive Species. 

Overly prescriptive at the forest 

plan level as written. Site specific 

analyses will further develop 

design criteria. The forest works 

through and MOU with AGFD to 

address project level concerns 

and design criteria for these 

wildlife species.

Wildlife 

and Fish

GDs structural habitat 

improvement in EMAs: 1, 3, 8, 9, 

12, And 16: Prevent livestock access 

to 70 percent of the shoreline of the 

stock tanks that have stable water 

levels with the capacity to grow 

emergent aquatic vegetation. In 

addition, fence up to five acres and 

seed to low height cover species.

DCs for Constructed Waters: Reservoirs maintain high water quality for 

parameters such as temperature, pH, and dissolved oxygen, and water 

levels are within the seasonal range of variable conditions. GDs 

Livestock Grazing: Annual operating instructions for livestock grazing 

permittees should ensure livestock numbers are balanced with capacity 

and address any relevant resource concerns (e.g., forage production, 

weeds, fawning habitat, soils, etc.). 

Allotment management Plans and 

Annual Operating Instructions 

would address forage and 

utilization, and relevant stock tank 

issues (through NEPA process) 

on site specific basis

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 651
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Wildlife 

and Fish

GD Structural habitat improvement 

for EMAs 1, 3, 8, 9, 12, 16: Provide 

for one permanent water source per 

square mile. 

GDs Constructed Waters: If new waters are constructed, they should be 

located in areas that would reduce ungulate impact to sensitive vegetation 

or soils such as riparian, aspen, and wet meadow areas. Drinkers should 

be maintained to provide water during times of scarcity. DCs: Artificial 

waters do not concentrate ungulate use in aspen stands. Management 

Approach: Work with the Arizona Game and Fish Department, grazing 

permittees, and sporting groups to manage constructed waters. Improve 

understanding of whether and how drinkers, tanks, and other constructed 

water features influence wildlife distribution and movement. 

Site specific analyses will further 

develop design criteria. The 

forest works through and MOU 

with AGFD to address project 

level concerns and design 

criteria.

Wildlife 

and Fish

GDs Wildlife non-structural habitat 

improvement for EMAs 1, 3, 8, 9, 

12, 16: Quaking Aspen: c. Prohibit 

grazing of improvement areas for not 

less than one growing season 

immediately following treatment.

GDs for Livestock Grazing: Livestock use in aspen areas should be 

authorized at levels that are consistent with the desired conditions for 

aspen regeneration and establishment. DCs for Aspen: Aspen occurs in 

natural patterns of abundance and distribution at levels similar to or 

greater than those at time of plan approval. Aspen is successfully 

regenerating and recruiting into older and larger size classes. Size classes 

have a natural distribution, with the greatest number of stems in the 

smallest classes. GDs for Aspen: Fences should be regularly inspected 

and maintained while aspen recovers. Fences should be removed when 

no longer needed.

Site specific. Will address aspen 

concerns on a case by case 

basis. If stand is treated, aspen 

will be protected from any and all 

grazing. Aspen identified as a 

priority need for change during 

the revision process.

Wildlife 

and Fish

STs for EMAs 2, 10, 13: Formulate 

and portray, describe, or quantify 

management objectives and desired 

conditions for the landscape. In 

landscapes that involve habitat for 

threatened, endangered, or sensitive 

plant or animal species, formulate 

management objectives and desired 

conditions for each designated 

management territory. Formulate, 

design, and implement resource 

operations or improvements that 

contribute to the achievement or 

maintenance of these management 

objectives and desired conditions. 

GDs for TES: Project activities and special uses occurring within federally 

listed species habitat should integrate habitat management objectives and 

species protection measures from approved recovery plans. Project 

activities and special uses should be designed and implemented to 

maintain refugia and critical life cycle needs of Forest Service Sensitive 

Species. Management Approach: The Kaibab NF maintains strong 

partnerships between the State, other federal agencies, academia, and 

nongovernment organizations to provide for TES species. Emphasis is 

placed on the protection and replacement of key habitats that contain 

threatened, endangered, and/or sensitive species of plants and animals. 

The Kaibab NF works with the USFWS and other partners to develop 

conservation measures (e.g. public education to reduce human impacts) 

to prevent listing and to aid to in the recovery and delisting of federally 

listed species. For 10(j) species, such as the California condor, this 

applies inside and outside the designated experimental range.

ESA Work with FWS to fulfill Section 7 

(a1) of the Act. Revised LMP has 

specific objectives and DCs 

which projects will include in site 

specific NEPA.

652 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Wildlife 

and Fish

STs for EMA 19: Survey and 

evaluate assessment areas to 

achieve following habitat standards: 

1. Re-distribute Apache trout 

upstream in North Canyon Creek 

when appropriate. b. Monitor aquatic 

macroinvertebrates biannually. 

Maintain a minimum Biotic Condition 

Index of 80. c. Consider the 

establishment of other populations of 

this species at suitable introduction 

sites to promote and secure the 

genetic integrity and viability of this 

species.

DCs for Wilderness: A reproducing population of Apache trout is 

maintained in North Canyon Creek. DCs for Natural Waters: Riparian 

dependent plant and animal species are self-sustaining and occur in 

natural patterns of abundance and distribution. Within its capability, 

stream flow and water quality are adequate to maintain aquatic habitat 

and water sources for native and desired nonnative species. Native 

macroinvertebrates are appropriately abundant and diverse. DCs for 

Watersheds: Water quality meets or surpasses State of Arizona or 

Environmental Protection Agency water quality standards for designated 

uses. Water quality meets critical needs of aquatic species. 

ESA Current plan overly prescriptive 

and redundant with law. 

Conservation actions for the trout 

fall under ESA and the forest will 

work with partners to achieve 

7(a1) conservation needs for that 

species. Aquatic macro inverts no 

longer a MIS. Water quality 

addressed through revised plan 

DCs.

Wildlife 

and Fish

STs for EMA 19: Survey and 

evaluate assessment areas to 

achieve following habitat standards: 

2. Peregrine falcon habitat. a. 

Prohibit activities which disturb 

nesting birds between March 15 and 

August 15. Extend this period if the 

birds are strongly attached to the 

nest site after August 15.

GDs for Wildlife Management: Project activities and special uses should 

be designed and implemented to maintain refugia and critical life cycle 

needs of wildlife, particularly for raptors. Potentially disturbing projectrelated activities should be restricted within 300 yards of active raptor nest 

sites between April 1 and August 15. Management Approach Wildlife: 

The Kaibab NF references current literature and the best available science 

when making site specific decisions relevant to project planning. This is 

done in an interdisciplinary context with input from other resource 

specialists. For example; the wildlife guideline specifying disturbance 

buffers around raptor nests is intended as a minimum buffer. Some raptor 

species (e.g., osprey) are more adapted to disturbance and are likely to 

tolerate a buffer of just 300 yards during the breeding season while other, 

less tolerant species (e.g. peregrine falcons (Falco peregrinus)) may 

require buffers of up to a 1⁄2 mile. Wildlife biologists work with other IDT 

resource specialists to identify and define the appropriate site specific 

buffers (within the context of plan guidance) for other raptors on a caseby-case basis. 

No longer endangered species, 

but still regionally sensitive. 

Revised as a GD. Will work with 

partners and the State to meet 

delisting goals. Site specific 

design criteria decided at the 

project level.

Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS 653
Appendix M. Crosswalk Between Key Direction from the 1988 Forest Plan (as amended) and the Revised Forest Plan

Resource 1988 Plan Content New Plan Direction (and or retained/modified direction) Other Law, 

Policy, 

Regulation

Rationale for Deleting or 

Modifying 1988 Plan Direction

Wildlife 

and Fish

STs for EMA 19: Survey and 

evaluate assessment areas to 

achieve following habitat standards:

Riparian Vegetarian. a. Inventory all 

riparian areas; collect data regarding 

location, size, classification and 

condition of the riparian. b. Maintain 

not less than three age classes of 

woody riparian species, with ten 

percent of the woody plant cover in 

sprouts, suckers seedlings, and 

saplings. c. Maintain not less than 90 

percent of the potential shrub cover 

in riparian areas.

DC under Cottonwood-willow Riparian Forest: The extent, diversity, 

and condition of riparian habitat contribute to ecological sustainability. 

Dense shrubbery and high levels of vegetative diversity (structural and 

compositional) and permanent water provide food, cover, and water for 

wildlife, including terrestrial and aquatic invertebrates and vertebrates. 

Vegetation is characterized by willow and other herbaceous understory 

species. Snag and gallery tree components comprise 55 percent mid-aged 

to mature cottonwood and willow trees, 25 percent younger trees and 20 

percent in grass, forbs, shrubs, suckers, seedlings, and tree sprouts. DCs 

for Natural Waters: Stream channel stability and aquatic habitats retain 

their inherent resilience to disturbances and climate fluctuations. Stream 

channel morphology reflects changes in the hydrological balance, runoff, 

and sediment supply appropriate to the landscape setting. Springs and 

ponds have the necessary soil, water, and vegetation attributes to be 

healthy and functioning. Springs, streams, and ponds have appropriate 

plant cover to protect banks and shorelines from excessive erosion. The 

location and status of springs and water resources are known, organized, 

and available. OBJs: Protect and/or restore at least 10 individual springs 

within 5 years of plan approval. GDs for Activities in and around 

Natural Waters: The impacts of management activities on springs, 

streams, and wetlands should be evaluated and minimized.

Redundant with previous 

direction for other EMAs. Current 

plan direction not entirely realistic 

given water rights issues and 

upstream diversions.

654 Appendices for the Kaibab National Forest Land and Resource Management Plan FEIS
Appendix N. Comments Received from 

Governmental Entities During the 90-Day 

Public Comment Period

The following Federal, State, county, and tribal agencies submitted comments during the DEIS 

comment period. 

• Arizona Department of Environmental Quality

• Arizona Department of Transportation

• Arizona Game and Fish Department

• The Hopi Tribe

• Kaibab Band of Paiute Indians

• Kane County, Utah

• U.S. Department of Interior, Office of Environmental Policy and Compliance

• U.S. Environmental Protection Agency 

This appendix provides copies of these comment letters

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