Forest Service

Coronado

National Forest

Safford

Ranger District

MB-R3-05-11

September 2014

 United States Department of Agriculture

Final Environmental 

Impact Statement

New Special-Use Permits for Recreation 

Residences on the Safford Ranger 

District 

Coronado National Forest

Graham County, Arizona

For Information Contact:

Rachael Hohl, Forest Environmental Coordinator

Coronado National Forest

300 W. Congress, 6th Floor

Tucson, AZ 85701

(520) 388-8352
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest iii

Final Environmental Impact Statement

New Special-Use Permits for Recreation 

Residences on the Safford Ranger District

Coronado National Forest

Graham County, Arizona

Lead Agency: USDA Forest Service

Responsible Official: Jim Upchurch, Forest Supervisor 

Coronado National Forest 

300 West Congress Street 

Tucson, Arizona, 85701 

For Information Contact: Rachael Hohl, Foerst Environmental Coordinator

Coronado National Forest 

300 W. Congress, 6th Floor

Tucson, Arizona, 85701

(520) 388-8352 

Abstract: The Coronado National Forest proposes to issue new special-use permits to the owners 

of 88 recreation residences on the Safford Ranger District. This administrative action would 

authorize continued occupancy and use of the residences as specified in the terms and conditions 

of individual permits. Approval of the proposed action would result in no change in the use of the 

residences and no authorization for the addition of structures or improvements. The new permits 

would expire 20 years from their most recent expiration date, which was December 31, 2008. 

Interim permits have been in place while this environmental impact statement was being 

prepared.

This environmental impact statement discloses the results of an analysis of potential effects of the 

proposed action and three alternatives on natural and socioeconomic resources. Selection of 

Alternative 1 (no action) would allow the current permits to expire and, in accordance with Forest 

Service policy, new permits would be issued for a 10-year transitional term of continued 

occupancy, after which permit holders would be required to remove structures and improvements. 

Selection of Alternative 2 would authorize the proposed action as described above; it is the 

preferred alternative. Selection of Alternative 3 would authorize new permits for 74 Turkey Flat 

residences; however, it would deny fourteen new permits for residences within the Old 

Columbine tract. Instead, in accordance with Forest Service special-use policy, new permits 

would be issued to Old Columbine permit holders for a 10-year transitional period, after which

owners would be required to remove structures and improvements. Selection of Alternative 4 

would authorize new permits for 14 Old Columbine residences; however, it would deny 74 

permits for Turkey Flat residences. Instead, in accordance with Forest Service special-use policy,

new permits would be issued to Turkey Flat permit holders for a 10-year transitional period, after 

which owners would be required to remove structures and improvements. 
iv FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Summary

Proposed Action

The Forest Service proposes to issue new special-use permits (SUPs) to owners of recreation 

residences on the Safford Ranger District, Coronado National Forest (forest), in Graham County, 

Arizona. This action is consistent with Forest Service policy [Forest Service Manual 2721.23(e)] to 

“continue recreation residence use when it is consistent with the forest plan” and “to work in 

partnership with holders of these permits to maximize public recreational benefits.”

Special-use permits held by owners who seasonally occupy 88 recreation residences on two separate 

tracts on the District expired on December 31, 2008. Interim permits were issued by amendment of 

the SUPs, in accordance with Forest Service Manual 2714. These have been in effect throughout the 

period during which this environmental impact statement (EIS) was in preparation.

Residences are located on two tracts comprising 77 acres in the 198,411-acre Pinaleño Mountains on

the 1.78 million-acre forest. Fourteen residences are located on 25 acres at Old Columbine, and 74

residences are located on 52 acres at Turkey Flat. 

The proposed action itself is administrative in nature. However, because human use of the residences 

has the potential to impact natural resources and because of the presence of the endangered Mt. 

Graham red squirrel and threatened Mexican spotted owl, the forest analyzed direct, indirect, and 

cumulative effects from the continued occupancy and use of the recreation residences over a 20-year 

term. Three alternatives to the proposed action were evaluated: taking no action, issuing new permits 

for Turkey Flat residences only, and issuing new permits for Old Columbine residences only.

Consistency with Forest Plan

As required by the National Forest Management Act, each aspect of the proposed action was

reviewed by the forest planner to determine consistency with forest-wide and management-areaspecific goals, objectives, standards, and guidelines in the Coronado National Forest Land and 

Resource Management Plan (Plan; 1986, as amended). All aspects were found to be consistent with 

the Plan. Therefore, no amendments to the Plan will be necessary prior to new recreation residence 

SUPs being issued.

Potential Impacts

Table 1 in chapter 2 of this EIS summarizes the results of the impacts analysis of each alternative by 

resource. The findings disclose that no action, the proposed action, and two other action alternatives 

would not have significant direct, indirect, and cumulative effects on air quality, soils, water, riparian

vegetation, recreation, visual quality, wild and scenic rivers, socioeconomics, and fire management in 

the area of potential effect. The potential impacts on wildlife and heritage resources are summarized 

below.
Summary

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest v

Wildlife

As required by Section 7 of the Endangered Species Act (ESA) of 1973, the Forest Service completed 

consultation with the U.S. Fish and Wildlife Service (FWS) regarding the potential for the proposed 

action to result in adverse effects on listed and proposed threatened and endangered species and 

designated critical habitat that occur in the project area. On January 24, 2007, formal consultation was 

initiated by letter transmitting a Biological Assessment and Evaluation (BAE) of the proposed 

action1. With regard to the Mt. Graham red squirrel (MGRS), an ESA determination of “may affect, 

likely to adversely affect” was reported. The BAE reported that the proposed action2“may affect, but 

would not likely adversely affect” the Apache trout and the Mexican spotted owl (MSO) and its 

designated critical habitat. 

In a Biological Opinion (BO) issued in response to these determinations, the FWS assigned “take” for 

two (2) Mt. Graham red squirrels (one “harm” and one “harass”), and stated that “...this level of take 

is not likely to result in jeopardy to the species.” The FWS subsequently issued a BO on April 30, 

2012, addressing the effects of the continued implementation of the Forest Plan. In it, the FWS stated

that “under the terms of section 7(b)(4) and section 7(o)(2), taking that is incidental to and not 

intended as part of the agency action is not considered to be prohibited taking under the Act, provided 

that such taking is in compliance with the terms and conditions of this Incidental Take Statement.”

The FWS concurred with Forest Service species and critical habitat determinations in a Biological 

Opinion (BO) dated August 18, 2008. Since 2009, threatened Gila trout have been introduced into 

Ash and Frye Creeks as part of a multi-agency effort to restore native species to the fishery. To 

address potential effects on this listed species, the forest updated its BAE, finding that the proposed 

action "may affect, but would not likely adversely affect" the Gila trout. This updated 

determination was submitted to FWS on December 16, 2010. The Forest Service received 

concurrence in a letter dated May 6, 2011.

Heritage Resources

Impacts to heritage, or cultural, resources were evaluated as required by the National Historic 

Preservation Act (NHPA), Executive Orders 13007 and 13175, and other laws and direction. Section 

106, NHPA, consultation was initiated in March 2006 with the Arizona State Historic Preservation 

Officer (SHPO) and Native American Tribes and Nations having traditional ties to the forest.

In consultation with the SHPO, the Forest Service concluded that because about three-quarters of the 

residences at both Turkey Flat and Columbine have been modified extensively in the last 50 years, 

neither tract is eligible for listing on the National Register of Historic Places. While most of the 88 

recreation residences are more than 50 years old, only 21 of them retain their original character.

With regard to Native American concerns, the entire Pinaleño mountain range comprises the Western 

Apache traditional cultural property (TCP), Dził Nchaa Si’an, which is eligible for listing on the 

National Register of Historic Places (NRHP). Western Apache people believe that Dził Nchaa Si'an, 

(translated as big-seated mountain) has both cultural and religious significance as a source of divine 

power. In consultation with the SHPO, the Forest Service concluded that neither the presence nor 

 

1

Section 7 of the ESA requires consultation with regard to the proposed action only. 
Summary

vi FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

absence of the recreation residences has an adverse effect on the qualities that make Dził Nchaa Si’an 

eligible for the NRHP. The Arizona SHPO concurred with this determination on September 1, 2006.

Nevertheless, from the Western Apache perspective, the presence and continued operation of the Mt. 

Graham International Observatory and other modern developments located within the Dził Nchaa 

Si’an TCP have damaged and continue to adversely impact its spiritual and cultural integrity. The 

Western Apache believe that no action would have a beneficial effect on the TCP because it would 

allow it to return to its natural state. 

Under the authority of the American Indian Religious Freedom Act, the Religious Freedom 

Restoration Act, and Executive Orders 13007 and 13175, the Forest Service conferred with the San 

Carlos Apache Tribe and the White Mountain Apache Tribe to develop a strategy for minimizing the 

effects of the presence and use of the recreation residences on the Western Apache TCP. Mitigation 

measures developed during these discussions will be included in the terms and conditions of each 

permit to minimize adverse effects on the traditional cultural, spiritual, and historical values of Dził 

Nchaa Si’an. These measures are defined in chapter 2 of this EIS.
Summary

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest vii

Acronyms and Symbols

ADEQ Arizona Department of Environmental Quality

ADOT Arizona Department of Transportation

ADWR Arizona Department of Water Resources

AGFD Arizona Game and Fish Department

AICA Arizona-Idaho Conservation Act

AMR Appropriate Management Response

amsl Above Mean Sea Level

APE Area of Potential Effect

BAE Biological Assessment and Evaluation

BMP Best Management Practice

BO Biological Opinion

CAA Clean Air Act

CE Categorical Exclusion

CEQ Council of Environmental Quality

CFR Code of Federal Regulations

CO Carbon Monoxide

DBH Diameter at Breast Height

EA Environmental Assessment

EIS Environmental Impact Statement

EPA Environmental Protection Agency

ESA Endangered Species Act

FMU Fire Management Unit

FMZ Fire Management Analysis Zone

FRCC Fire Regime Condition Class

FS Forest Service

FSH Forest Service Handbook

FSM Forest Service Manual

FSS Forest Service Sensitive Species

FWS Fish and Wildlife Service

GES General Ecosystem Survey

GIS Geographic Information System

LSC Low Sun-Cold (climatic class)

MA Management Area

MGIO Mount Graham International Observatory

MGRS Mount Graham Red Squirrel

MIS Management Indicator Species

MSO Mexican Spotted Owl

NAAQS National Ambient Air Quality Standards 

NEPA National Environment Policy Act

NF National Forest

NFMA National Forest Management Act

NFS National Forest System

NHPA National Historic Preservation Act
Summary

viii FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

NO2 Nitrogen Dioxide

NOA Notice of Availability

NOAA National Oceanic and Atmospheric Administration

NOI Notice of Intent

O&M Operation and Maintenance

O3 Ozone

ORVs Outstandingly Remarkable Values

PAC Protected Activity Center

Pb Lead

PEM Pinaleño Ecosystem Management

PERP Pinaleño Ecosystem Restoration Project

PILT Payments in Lieu of Taxes

PM Particulate Matter

PNV Present Net Value

ROD Record of Decision

ROS Recreational Opportunity Spectrum

RPA Reasonable and Prudent Alternative

SHPO State Historic Preservation Officer

SMS Scenery Management System

SO2 Sulfur Dioxide

SOPA Schedule of Proposed Actions

SRSCS Secure Rural Schools and Community Self-Determination Act

SUP Special Use Permit

TCP Traditional Cultural Property

TES Threatened and Endangered Species

USDA United States Department of Agriculture

USDI United States Department of Interior

VQO Visual Quality Objective

VRMS Visual Resource Management System

WFSA Wildland Fire Situation Analysis

WSR Wild and Scenic River

WUI Wildland Urban Interface
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest ix

Contents

Final Environmental Impact Statement..................................................................................... iii

New Special-Use Permits for Recreation Residences on the Safford Ranger District............ iii

Coronado National Forest Graham County, Arizona ............................................................... iii

Summary ....................................................................................................................................... iv

Acronyms and Symbols.......................................................................................................... vii

Contents......................................................................................................................................... ix

Chapter 1. Introduction ................................................................................................................ 1

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

Purpose of and Need for Action................................................................................................ 2

Proposed Action........................................................................................................................ 2

Forest Plan Direction ................................................................................................................ 3

Decision Framework................................................................................................................. 5

Public Involvement ................................................................................................................... 5

Issues Identified During Scoping.............................................................................................. 7

Document Structure ................................................................................................................ 10

Chapter 2. Alternatives, Including the Proposed Action...........................................................11

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

Alternatives Considered and Dismissed ................................................................................. 13

Mitigation and Related Requirements .................................................................................... 14

Comparison of Alternatives .................................................................................................... 15

Chapter 3. Affected Environment and Environmental Consequences................................... 25

Air Quality .............................................................................................................................. 29

Soils ........................................................................................................................................ 33

Water Resources and Riparian Areas...................................................................................... 39

Recreation ............................................................................................................................... 51

Visual and Aesthetic Resources.............................................................................................. 55

Wild and Scenic Rivers........................................................................................................... 59

Heritage Resources................................................................................................................. 62

Social and Economic Resources............................................................................................. 66

Wildlife Resources.................................................................................................................. 83

Climate Change..................................................................................................................... 162

Unavoidable Adverse Effects................................................................................................ 163

Irreversible and Irretrievable Commitments of Resources ................................................... 164
Contents

x FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Chapter 4. Consultation and Coordination............................................................................. 165

Chapter 5. Literature Cited...................................................................................................... 167

Appendices................................................................................................................................. 177

Appendix A: Examples of Special-Use Permit and Related Operation and Maintenance Plan

..................................................................................................................................................... 179

Appendix B: Heritage Resources Consultation ..................................................................... 199

Appendix C: Endangered Species Act Consultation ............................................................. 201

Appendix D: Comments Received on the Draft EIS ............................................................. 239

Appendix E: Responses to Comments on the Draft EIS....................................................... 257

List of Tables

Table 1. Comparison of Potential Impacts of all Alternatives Evaluated in this Environmental 

Impact Statement. ........................................................................................................... 16

Table 2. Past, Present, and Reasonably Foreseeable Actions Considered in the Cumulative 

Effects Analysis Reported in this EIS............................................................................. 26

Table 3. Descriptive Information about General Ecosystem Survey Units in the Old 

Columbine and Turkey Flat Recreation Residence Tracts.............................................. 33

Table 4. Effects of Historic Logging in the Sub-watersheds of Old Columbine and Turkey 

Flat Recreation Residence Tracts.................................................................................... 37

Table 5. Historic Impacts of Grazing on Soils in the Ash Creek and Jacobson Sub-watersheds.

........................................................................................................................................ 37

Table 6. Acreage of Soils Impacted by Past, Present, and Future Activities in the Ash Creek 

and Jacobson Canyon Sub-watersheds. .......................................................................... 39

Table 7. Annual Water Yield and Use in the Sub-watersheds of the Safford Ranger District 

Recreation Residence Tracts........................................................................................... 41

Table 8. Surface Water Quality Status in Three Streams in the Vicinity of the Safford Ranger 

District Recreation Residence Tracts.............................................................................. 42

Table 9. Characteristics of Riparian Resources at or near Safford Ranger District Recreation 

Residence Tracts. ............................................................................................................ 43

Table 10. Graham County, Arizona, Population by Race and Ethnicity. ................................ 69

Table 11. Dominant Occupations in Graham County and the State of Arizona...................... 70

Table 12. Financial and Economic Present Net Value (PNV) for No Action (20 Year Planning 

Horizon).......................................................................................................................... 74

Table 13. Financial and Economic Present Net Value (PNV) for the Proposed Action (20 Year 

Planning Horizon)........................................................................................................... 76

Table 14. Financial and Economic Present Net Value (PNV) for Issuing Permits for Turkey 

Flat Only (20 Year Planning Horizon). ........................................................................... 79

Table 15. Financial and Economic Present Net Value (PNV) for Issuing Permits for Old 

Columbine Only (20 Year Planning Horizon)................................................................. 81

Table 16. Federally Listed Threatened and Endangered Species Occurrence and Habitat in the 

Area of the Safford Ranger District Recreation Residence Tracts.................................. 86

Table 17. Habitat and occurrence of Forest Service Sensitive Species at recreation residence 

tracts on the Safford Ranger District............................................................................. 109

Table 18. Information on Management Indicator Species on the Coronado National Forest, 

Safford Ranger District................................................................................................. 142
Contents

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest xi

List of Figures

Figure 1. Location of the Coronado National Forest in Southeastern Arizona......................... 3

Figure 2. General Location of Safford Ranger District Recreation Residence Tracts. ............. 4

Figure 3. Relative Locations of Reasonably Foreseeable Actions near the Safford Recreation 

Residence Tracts............................................................................................................. 28

Figure 4. Location of the Class II Upper Gila River Airshed (7) in Arizona.......................... 31

Figure 5. Relative Location of Ash Creek and Jacobson Canyon Sub-watersheds and the Old 

Columbine and Turkey Flat Recreation Residence Tract................................................ 34

Figure 6. Location and Water Quality Category of Three Streams in the Vicinity of the 

Safford Ranger District Recreation Residence Tracts..................................................... 43

Figure 7. Area of Analysis: Riparian Resources on the Old Columbine Recreation Residence 

Tract on the Safford Ranger District............................................................................... 44

Figure 8. Area of Analysis: Riparian Resources on the Turkey Flat Recreation Residence 

Tract on the Safford Ranger District............................................................................... 45

Figure 9. Stream Channels within the Ash Creek and Jacobson Sub-watersheds on the Safford 

Ranger District................................................................................................................ 47

Figure 10. Mt. Graham Red Squirrel Critical Habitat, as Designated in 1990, in Relation to 

Safford Ranger District Recreation Residence Tracts. Source: USDI-FWS, 1990. ........ 89

Figure 11. Population Estimates for the Mt. Graham Red Squirrel Since 1986. .................... 91

Figure 12. Mexican Spotted Owl Critical Habitat on the Safford Ranger District Relative to 

the Recreation Residence Tracts. .................................................................................... 96

Figure 13. Mexican Spotted Owl Protected Activity Centers (Pacs) on the Safford Ranger 

District Relative to Recreation Residence Tracts............................................................ 97

Figure 14. Mexican Spotted Owl Protected Activity Centers (PACs) Relative to the Turkey 

Flat Recreation Residence Tract on the Safford Ranger District .................................... 99

Figure 15. Historic Distribution of Apache and Gila Trout. ................................................. 105

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 1

Chapter 1. Introduction

Background

Individual recreation residences have been built and occupied on public land since the passage of 

the Organic Administration Act of June 4, 18973. The act provided for construction and 

occupancy of residences on Federally-managed land contingent upon an agency’s authorization of 

an annual permit. At the turn of the 20th century, however, most citizens were unwilling to make 

substantial investments in residences without the assurance that their permits would be issued 

annually without renegotiation or difficulty.

In 1915, the Term Permits Act4provided Federal agencies with the authority to provide up to five

acres of Federal land for construction of summer homes and to grant multi-year occupancy 

permits. Permitted, privately owned residences were subsequently allowed to be inherited or sold. 

The Coronado National Forest (Coronado or forest) recreation residence program was established

shortly afterward.

Both the Old Columbine and the Turkey Flat recreation residence tracts on the Safford Ranger 

District in Graham County, Arizona, were established in the 1920s (Angle, 2006). However, 

residents of Pima, Thatcher, and Safford are known to have enjoyed “summering” on Mt. Graham

since the late 1880s (Spoerl, 1988). Cabins were built at Old Columbine before the land became 

part of the Mt. Graham Forest Reserve in 1902 (King, 1915). Recreation residences at Columbine 

were built between 1923 and 1956, although most have been modified within the last 50 years. 

Bertell and Weech (2003:92) noted that Turkey Flat was first developed by William Deal and Joe 

Bassett, who built a log cabin there as part of a plan to grow potatoes. Most of the recreation 

residences at Turkey Flat were built after the Swift Trail (Highway 366) was constructed to 

improve access to the area. Cabins were constructed at Turkey Flat between 1929 and 1966, and 

most have also been remodeled or expanded within the past 50 years.

The Forest Service Recreation Residence Policy established on June 2, 1994, provides direction 

for issuing new term special-use permits (SUPs) for recreation residences (USDA-FS, 1994). A

decision to issue new permits, following expiration of old ones, requires a determination of 

whether or not the future occupation and use of the residences is consistent with the current 

Forest Land and Resource Management Plan (forest plan) and an assessment of potential 

environmental effects of issuing new permits. 

Consistency is evaluated by considering the extent to which continued recreation residence use 

adheres to the standards and guidelines in the forest plan that apply to specific forest management 

areas. It is Forest Service policy [Forest Service Manual (FSM) 2721.23e (1)] that “when 

recreation residence use is consistent with the forest plan, it shall continue.”

In addition, Forest Service Handbook (FSH) 2709.11, chapter 41.23a (2), requires the forest to 

“initiate the analysis and action to issue a new permit 2 years prior to expiration of the current 

term permit.” The handbook further states because “recreation residences have been in place for 

many years, and experience in administering this use has shown that continuing the use does not 

cause significant environmental impacts, issuance of a new permit can be made without further 

environmental documentation [FSH 2709.11, chapter 41.23a (1)].” However, “if the use has not 

been analyzed sufficiently as part of an EA or EIS completed within 5 years of permit expiration, 

 

3 Ch. 2, 30 Stat. 11, as amended; 16 U.S.C. 473–475, 477–482, 551

4

16 U.S.C. 497, as amended; signed on March 4, 1915
Chapter 1. Introduction

2 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

complete the appropriate environmental analysis and documentation [FSH 2709.11, chapter 

41.23a (1)(b)].”

The action of issuing new recreation residence permits when changes are simply administrative in 

nature is one that may, at present, be categorically excluded from further National Environmental 

Policy Act (NEPA) analysis in an environmental assessment (EA) or environmental impact 

statement (EIS) [see 36 CFR 220.6 (e) (15)]. The validity of using a categorical exclusion (CE) is 

contingent upon there being no extraordinary circumstances that may adversely affect specific 

resources listed in 36 CFR 220.6 (1)(b), including species protected under the authority of the 

Endangered Species Act (ESA) and heritage resources protected under the National Historic 

Preservation Act (NHPA).

Despite the fact that the recreation residences have been present for nearly 80 years, there is a 

history of controversy regarding special uses on Mt. Graham. For several decades, population and 

habitat issues associated with the endangered Mt. Graham red squirrel; heritage issues with Mt. 

Graham being considered eligible as a TCP for the Western Apache; and fire management

strategies have been debated in the public forum. Because of this controversy, the Forest Service

determined that the use of a CE would not be sufficient NEPA compliance for this proposed 

action and that preparation of an environmental impact statement (EIS) was necessary.

Purpose of and Need for Action

Special-use permits for 88 recreation residences on the Safford Ranger District of the forest

expired on December 31, 2008. The purpose of the proposed action is to issue new SUPs to those 

parties who hold interim permits that were granted while this EIS was being prepared. The Forest 

Service is taking action to comply with agency policy of continuing recreation residence use

when it is consistent with the forest plan and to work in partnership with permit holders to 

maximize public recreational benefits [FSM 2347.1 (USDA-FS, 2006b) and USDA-FS, 1986, pp. 

9, 41 and 59].

Proposed Action

The Forest Service proposes to issue SUPs for 88 Safford Ranger District recreation residences. 

Each newly issued SUP term would extend 20 years, from January 1, 2009 (the day after the

previous expiration date), through December 31, 2028. Current permit holders would be required 

to abide by all terms and conditions of the new SUPs and an annual Operation and Maintenance 

(O&M) Plan that will be conveyed with each. An example of an annual O&M Plan is provided in 

appendix A. Prior to each SUP being issued, individual recreation residences will be inspected by 

forest staff to confirm that occupancy and use are compliant with the terms and conditions of their 

current permit [FSH 2709.11, 41.23a (3) (USDA-FS, 2005)]. 

There are 14 recreation residences on 25 acres on the Old Columbine tract in protracted Section 

29, unsurveyed Township 8 South, Range 24 East. The Turkey Flat tract has 74 residence lots on 

52 acres in protracted Sections 19 and 20, unsurveyed Township 9 South, Range 25 East. General 

locations of the Coronado NF and the tracts are shown in figures 1 and 2. The layout of 

residences on the tracts is shown in chapter 3, figures 7 and 8.
Chapter 1. Introduction

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 3

Figure 1. Location of the Coronado National Forest in Southeastern Arizona.

The forest comprises 1,780,000 acres of public land, most of which is in southeastern Arizona, 

and a small portion of which is in the Peloncillo Mountains of southwestern New Mexico. 

Elevations on the forest range from 3000 to 10,720 feet above mean sea level (amsl) across 12 

widely scattered mountain ranges or "sky islands" that rise dramatically from the desert floor. The 

Pinaleño Mountains, which comprise 198,411 acres of the Safford Ranger District, are one of the 

most extensive mountain ranges on the Coronado NF. Mount (Mt.) Graham, at an elevation of 

10,720 feet, is the highest peak in southern Arizona.

Forest Plan Direction 

Direction for allocation and management of land for specific uses and activities on the Coronado 

NF, including the recreation residence program, is provided in the current forest plan (USDA-FS 

1986, as amended). Forest-wide standards and guidelines are augmented by standards and 

guidelines that apply to parcels of forest land designated in the forest plan as management areas 

(MAs) (USDA-FS, 1986, pp. 25-46). The Safford recreation residences are located in MAs 3A 

and 3B. Standards and guidelines, both forest-wide and MA-specific, that apply to these MAs are 

referenced in chapter 3 in the text discussion of the affected environment.
Chapter 1. Introduction

4 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Figure 2. General Location of Safford Ranger District Recreation Residence Tracts.

MAs 3A and 3B comprise approximately 4,165 acres and include lands suitable for and capable 

of supporting recreational development. Management of these areas focuses on providing a 

variety of developed recreation opportunities while at the same time mitigating impacts to the 

unique physical, biological, and cultural resources of each area.
Chapter 1. Introduction

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 5

Forest plan standards and guidelines for the Old Columbine and Turkey Flat tracts include the 

following statements (USDA-FS, 1986, p. 59):

 “Recreation residences, with the exception of those on tenure in the Santa Catalina 

Mountains and Madera Canyon, will be maintained unless and until a determination 

has been made that the site involved is needed for a higher priority public purpose.”

 “Prior to the termination, non-renewal or modification of the special use permits for 

the Arizona Bible School Organization Camp and the Columbine Summer Home 

Tract located in the Pinaleño Mountains, the effect of these special use authorizations 

on the Mt. Graham red squirrel and other threatened or endangered species will be 

determined.”

The Forest planner reviewed the proposed action for consistency with forestwide and MAspecific goals, objectives, standards, and guidelines established in the forest plan and found it to 

be acceptable. Thus, no amendments will be necessary prior to new recreation residence SUPs 

being issued.

Decision Framework

The Coronado National Forest Supervisor is the “responsible agency official” who will decide 

whether or not to approve the proposed action or an alternative to the proposed action. As 

required by CEQ regulations at Section 1505.2, the forest supervisor will document the following

information in a Record of Decision (ROD):

1. The decision (alternative selected) and the rationale that supports it;

2. Consistency of the selected alternative with the governing forest plan;

3. Alternatives considered and evaluated in the EIS;

4. Public involvement in the NEPA review;

5. The specific location of the alternative selected; 

6. Mitigation and monitoring factored into the decision and rationale;

7. The environmentally preferred alternative;

8. Findings required by other laws;

9. Administrative review (objection) opportunity; and

10. A date upon which the proposed action may be implemented.

Public Involvement

Notice of the Proposed Action

The proposed action was first announced to the public in July 2005, when the project was listed in 

a Schedule of Proposed Actions (SOPA) on the internet on the forest public website5. Since that 

time, the project has been listed on each quarterly update of the SOPA.

The scope of this NEPA review is based, in part, on input that was provided in written and oral

comments that responded to a Notice of Intent to Prepare an EIS (NOI) that was published by the 

 

5 www.fs.fed.us/r3/coronado
Chapter 1. Introduction

6 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

U.S. Environmental Protection Agency (EPA) in the Federal Register on March 9, 2006 (project 

record, item #5) and concurrently sent to various stakeholders, interested parties, and Native 

American Tribes and Nations; and comments received during two public meetings. The NOI was 

mailed to 154 stakeholders, including the general public, agencies, government officials, and 

various organizations (project record, item #8). On March 24, 2006, a government-to-government 

scoping letter was sent to 31 tribal leaders among 12 Indian Nations with historic ties to southeast 

Arizona (project record, item #7). 

Two public open-houses were held during the scoping period: one in Tucson, Arizona, on March 

27, 2006, which had 27 attendees (project record, item #60) and the other in Safford, Arizona, on 

March 28, 2006, which had 48 attendees (project record, item #64).

Comments Received from the Public

Public comments received during the scoping period were reviewed by a Forest Service 

interdisciplinary team of resource specialists, who are identified in chapter 4; catalogued by 

resource and/or issue; and determined to either be relevant to the impacts analysis or beyond the 

scope of this environmental review6(project record, items #8 through 11; #13 through 59; #61 

through 63; #65 through 167; #172). Each specialist subsequently developed an approach to 

analyze potential impacts related to specific issues.

Ninety-eight (98) parties offered scoping comments in various formats (electronic mail, U.S. 

mail, telephone, person-to-person) during the scoping period. Ninety-three (93) comment letters 

expressed advocacy for the proposed actions, and two letters included requests to be placed on the 

mailing list for the NEPA review.

One comment letter expressed concern for potential adverse impacts to the Mt. Graham red 

squirrel, citing several factors of concern (project record, item #172), which were considered and 

addressed in this EIS by the district wildlife biologist.

Only one comment letter was received from among the Native American Tribes and Nations who 

were contacted (project record, item #68). Former Tribal Chairman of the White Mountain 

Apache Tribe, Dallas Massey, Sr., commented that the continued existence of the recreation 

residences in itself was an adverse effect on the Dził Nchaa Si’an TCP (Massey, 2006). These 

concerns were considered and addressed in this both the draft and final EIS by the forest 

archaeologist, in consultation with the State Historic Preservation Officer (SHPO).

The remaining comment letter expressed opposition to the Forest Service recreation residence 

program, in general, and recommended that all permits for recreation residences be discontinued 

nationwide. This comment was considered to be outside the scope of the review and was not 

addressed in the impacts analysis in chapter 3.

Review of Draft EIS

In accordance with FSH 1909.15, chapters 23.2 and 23.3, the public was offered a 45-day period 

to review a draft of this EIS. A Notice of Availability (NOA) of the draft EIS for public review 

 

6

Those that (1) expressed concern about an issue that had already been decided by law, regulation, Forest 

Plan, or another higher-level decision; (2) were unrelated to the decision to be made; (3) were conjectural 

and not supported by scientific or factual evidence; (4) expressed an opinion of advocacy or opposition; 

or (5) were so general that a meaningful issue could not be discerned.
Chapter 1. Introduction

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 7

was published in the Federal Register on December 5, 2008 (project record, item #184), and 

copies of the draft EIS were distributed to Federal, state and local agencies and other parties who 

offered comments during the scoping period (project record, items #180 through 183; and #185 

through 187). Public comments on the draft EIS (project record, items #189 through 192; and 

#194) were reviewed by Forest Service resource specialists and the responsible official prior to 

the preparation of this Final EIS. Comments are reproduced in their entirety in appendix D of this 

EIS. Forest Service responses to comments on the draft EIS are provided in appendix E.

Review of Final EIS and Record of Decision

The Responsible Official will issue a draft Record of Decision (ROD) concerning the proposed 

action after EPA has published a Notice of Availability (NOA) of the Final EIS in the Federal 

Register. His draft decision will be uploaded to the Forest public website concurrent with 

publication of a Legal Notice of its availability in the Arizona Daily Star newspaper.

The draft ROD is subject to a Forest Service Predecisional Administrative Review Process [36 

CFR 218 (Subparts A and B)], which became effective on March 27, 2013. In accordance with 

218 regulations, a 45-day public review of the draft ROD will be offered. Only those parties who 

submitted comments during public scoping of the NEPA review and those who commented on the 

Draft EIS or otherwise expressed interest in the action are will be eligible to object to the ROD 

(see 36 CFR 218.5). And, each objection must be linked to the original comments that were 

submitted by a specific party (see 36 CFR 218.2). Information on how to comment is provided in 

the 36 CFR 218 regulations.

Final Record of Decision and Implementation of the Proposed Action

The objection process offers interested parties an opportunity to meet with the Reviewing Officer 

and the Responsible Official with the intent of resolving the concerns expressed in the objection 

(see 36 CFR 218.11).

If no objections are filed, a decision may be signed by the Responsible Official and 

implementation of the decision may occur on, but not before, five business days from the close of 

the objection filing period. 

If objections are filed, informal resolution meetings and/or conference calls may be held among 

the Reviewing Officer, Responsible Official, and the objector(s). The Responsible Official may 

not sign a final ROD until the Reviewing Officer has responded in writing to all pending 

objections. The final ROD must be consistent with any instructions issued by the reviewing 

officer (see 36 CFR 218.12). Tthe proposed action may be implemented immediately upon the 

final ROD being signed.

Issues Identified During Scoping

Potential Effects on the Mt. Graham Red Squirrel 

Background

The Mt. Graham red squirrel (MGRS) is one of 25 subspecies of red squirrels in North America. 

Its habitat is conifer forest, especially old growth spruce-fir, Douglas-fir, and mixed conifer. The

only remaining population of MGRS occurs in the upper elevations of the Pinaleño Mountains. 
Chapter 1. Introduction

8 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

The MGRS was thought to have become extinct during the 1950s, but a small population of 

squirrels was "rediscovered" in the 1970s. The species was added to the Federal endangered list 

in 1987 by the U.S. Fish and Wildlife Service (FWS), after the estimated population in 1986 was 

observed to be less than 400.

Decreased MGRS habitat was the direct result of past logging in the Pinaleño Mountains. More 

recent declines have resulted from drought, insect infestation, and catastrophic wildland fire.

The recreation residences at Old Columbine are located within MGRS habitat. They were built 

and used for about 30 years before the MGRS was reported to be extinct. Recreational use of the 

area is limited, and occupancy of the recreation residences has not been directly correlated with 

population decline. However from other perspectives, the continued presence of the residences at 

Old Columbine inhibits the restoration of approximately 25 acres of forest to historic conditions, 

although this acreage is a very small percent of estimated suitable MGRS habitat on Mt. Graham 

(between 17,000 to 27,000 acres).

Human presence at the recreation residences and, in general, all recreation sites on Mt. Graham, 

increases the probability that individual squirrels may be accidentally injured or killed. In 

addition, squirrels are at risk from the effects of catastrophic wildland fire, which continues to 

occur on the mountain because fire suppression in MGRS habitat at Old Columbine and other 

man-made facilities (the wildland-urban interface or WUI). Fire suppression has and will 

continue to be an impediment to the return of a frequent, low-intensity, natural fire cycle to the 

ecosystem.

To address concerns about potential impacts to the MGRS, an alternative to issue new permits at 

Turkey Flat only is evaluated in this EIS along with a no-action alternative, whereby all 

recreation residence SUPs would be terminated after a 10-year transitional period.

Requirements of the Arizona-Idaho Conservation Act Regarding the Mt. Graham

International Observatory

Just over two decades ago, the forest issued a special-use permit to the University of Arizona

(University) authorizing the construction and operation of telescopes and related facilities on Mt. 

Graham (the Mt. Graham International Observatory or MGIO). Prior to the realization of this 

project, the potential decline of the MGRS was already the subject of public interest.

A draft EIS analyzing the effects of proposed telescope construction was released for public 

comment in October 1986 (USDA-FS, 1986b). In 1987, a biological assessment and evaluation 

(BAE) of the potential effects of the University’s preferred alternative on the endangered MGRS 

was submitted by the Forest Service to the FWS to meet the requirements of Section 7 of the 

ESA. During this timeframe, the University modified its preferred alternative, which necessitated 

the preparation of a second BAE and the re-initiation of formal consultation with the FWS.

In July 1988, the FWS issued its biological opinion (BO) on the potential effects of the modified 

preferred alternative, in which it concluded that the MGRS is "extremely vulnerable to 

extinction" and that construction of the telescopes was likely to jeopardize its continued existence 

(USDI-FWS, 1988). As part of the BO, the FWS proposed three "reasonable and prudent 

alternatives” (RPAs) to the proposed action that would allow the project to proceed while 

providing a necessary degree of protection to the red squirrel. RPA 3 recommended that new 

SUPs for the Old Columbine recreation residences not be issued upon their expiration.
Chapter 1. Introduction

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 9

Significant public controversy followed, generated by passage of the Arizona-Idaho Conservation 

Act of 1988 (AICA; project record, item #196), which, among other things, altered the 

requirements of the RPAs in the BO. Section 602 (a) of the AICA mandated that, subject to the 

terms and conditions of RPA 3 of the BO, the requirements of Section 7 of the ESA were to be 

deemed satisfied with regard to the issuance of an SUP for the first three telescopes, necessary 

support facilities, and an access road to the site.

In addition, AICA Section 605(a) altered features of RPA 3 that addressed whether or not new 

SUPs would be issued upon expiration of permits for the Old Columbine tract area and the 

Arizona Bible Camp. In the 1988 BO, RPA 3 recommended that the SUPs not be issued upon 

expiration. AICA stated that the permits "shall continue subject to the terms and conditions of the 

authorizations, for the duration of the term specified in each authorization. Prior to the 

termination, non-renewal or modification of those special use authorizations, a biological study to 

determine the effects of such special uses authorizations upon the Mt. Graham red squirrel and 

other threatened and endangered species would be conducted. The biological study would include 

public involvement and consultation with the US Fish and Wildlife Service.” The language of the

AICA does not mandate that a biological study of effects to the MGRS be completed prior to the 

forest issuing new permits for the residences upon their expiration.

Research and field studies on the red squirrel have been ongoing since the passage of the AICA. 

In 2007, the Safford Ranger District biologist prepared a BAE of potential impacts to the MGRS, 

on which conclusions reported in this EIS are based (see chapter 3). The BAE was submitted to 

FWS on January 24, 2007, as formal Section 7 consultation. The FWS issued its BO on August 

18, 2008 (see appendix C), in which it assigns “take” for two Mt. Graham red squirrels. 

According to the BO, “...this level of take is not likely to result in jeopardy to the species."

Western Apache Traditional Cultural Property, Dził Nchaa Si’an

The recreation residences are located on Mt. Graham, known to Western Apaches as Dził Nchaa 

Si’an (big-seated mountain), a place of long-standing and ongoing historical, cultural, religious 

and spiritual importance. Dził Nchaa Si’an is associated with Western Apache oral history and 

tradition and plays a vital role in Western Apache lifeways and continued tribal well-being. Dził 

Nchaa Si’an is home to mountain spirits, a source of natural resources and traditional medicine 

for ceremonial uses, a place of prayer, and a source of power to Western Apache people. The area 

within the forest boundary has been determined eligible for listing on the National Register of 

Historic Places as a TCP, but the sacred character of the range is even more extensive, 

encompassing all landforms, minerals, plants, and waters associated with or flowing from Dził 

Nchaa Si’an.

The Forest Service has a trust responsibility toward American Indian tribes to the extent 

mandated by legislation and executive orders to (1) consider the effects of projects on historic 

properties, (2) ensure American Indian access to sacred sites, and (3) protect the physical integrity 

of such sites, wherever possible. During the scoping period for the draft EIS, the chairman of the 

White Mountain Apache Tribe commented that the ongoing presence of the residences continues 

the damage to and desecration of the Western Apache sacred mountain. 

Specifically with regard to the recreation residences, individuals, families, and guests are often 

not aware of the mountain’s role in Western Apache history and culture. Any effects that the 

residences have on the natural wildlife, soils, vegetation, and streams are considered by the 
Chapter 1. Introduction

10 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Western Apache as detrimental to the sacred site. Further, the residences have an effect on land 

and fire management, in that Forest Service fire responses have been predicated on the protection 

of private property rather than on the restoration of ecosystem functions or the protection and 

expansion of the habitat of endangered species.

Document Structure

This EIS discloses the direct, indirect, and cumulative environmental impacts that would result 

from implementation of the proposed action and alternatives. It was prepared in accordance with 

the procedural and content requirements established in the CEQ Regulations Implementing the 

Procedural Provisions of NEPA (40 CFR Parts 1500-1508) and in NEPA guidelines contained in 

FSH 1909.15, chapter 20 (see http://www.fs.fed.us/emc/nepa/index.htm). The document is 

organized as follows:

Chapter 1 –Introduction: The chapter includes information on the background of the proposed 

action, the purpose of and need for action, and the agency’s proposal for satisfying that purpose 

and need. This section also details how the Forest Service informed the public of the proposal and 

how the public responded.

Chapter 2 – Alternatives, Including the Proposed Action: This chapter provides a more 

detailed description of the agency’s proposed action, as well as alternatives that also would satisfy 

the purpose of and need for action. The alternatives were developed, in part, based on issues 

raised by the public and other agencies. Mitigation and monitoring is discussed in this chapter, 

and the environmental consequences of implementing each alternative are compared in a 

summary table.

Chapter 3 – Environmental Consequences: This chapter describes baseline conditions of the 

affected environment and the potential effects of implementing the proposed action and 

alternatives. This analysis is organized by resource area. This chapter reports impacts that cannot 

be avoided or mitigated to acceptable levels. This chapter reports those commitments of resources 

that may not be renewed in the short term or that are lost in the long term.

Chapter 4 – Consultation and Coordination: This chapter provides a list of preparers and 

identifies agencies, stakeholder, and others consulted during the EIS analysis.

Chapter 5 - Literature Cited: This section lists references and other citations in the EIS.

Appendices: The appendices provide supplemental information to the analysis presented in the 

EIS.
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 11

Chapter 2. Alternatives, Including the 

Proposed Action

Alternatives Considered in Detail

This chapter describes the proposed action and alternatives and provides a comparison of the 

environmental impacts of the alternatives in a summary table. In addition to a no-action 

alternative, the Forest Service considered three action alternatives that would satisfy the purpose 

of and need for action. These include alternative 2 (the proposed action and preferred alternative, 

whereby new 20-year special-use permits would be issued for 88 recreation residences); 

alternative 3 (to issue new permits for Turkey Flat residences only); and alternative 4 (to issue 

new permits for Old Columbine only).

Alternative 1: No Action 

No action is included as an alternative to the proposed action, in accordance with the 

requirements of Council on Environmental Quality (CEQ) regulations at 40 CFR Part 1502.14(d) 

that apply to an EIS. No action is generally intended to provide a baseline against which the 

impacts of action alternatives may be compared. 

In addition to providing an environmental baseline, the no-action alternative evaluated by this 

NEPA review would deny new SUPs for both recreation residence tracts. As specified in FSM 

2721.23(e)(2)(b), after a decision is made to terminate recreation residence permits, homeowners 

shall be allowed to occupy the residences for 10 years from the date of notification of nonrenewal. For the purpose of the EIS analysis of no action, the Forest Service assumed that all 

recreation residence holders would continue to occupy their residences for the full 10-year permit 

period.

According to the terms and conditions of each 10-year permit, owners will have a reasonable 

timeframe to remove structures and/or improvements and to restore each site to natural 

conditions, at their expense. The process of removal may take up to five years. Thus, all 

structures and improvements on a tract should be gone within 15 years, if the no-action 

alternative is selected for implementation. Before residences are removed, a site-specific NEPA 

review of proposed restoration plans will be completed.

General improvements on recreation residence tracts include small cabins, decks, patios, 

outbuildings, permanent grills, and other stationary improvements; pumps; overhead wiring; 

propane gas tanks; water tanks; and concrete foundations. As part of the removal process, permit 

holders will be required to secure wells with welded steel caps, pump and fill septic tanks and 

vault toilets with dirt, and fill pit toilets with dirt. Pipelines, underground wiring, sewage 

distribution boxes, and drain fields are permitted to remain. Each site and associated use area will 

be contoured to the original landscape and planted with a native seed mix.

After sites are restored, access to the Old Columbine and Turkey Flat tracts will be gated by the 

Forest to prevent future motorized access. Vegetation will be allowed to repopulate the road beds. 

At present, no specific use for the decommissioned tracts is proposed. However, the area would 

continue to be open to visitors for dispersed recreational use, as it is at present.No action is 

included as an alternative to the proposed action, in accordance with the 

Pursuant to the Arizona-Idaho Conservation Act of 1988, P.L. 100-696, Section 605(c), “If ... 

termination, modification or nonrenewal of special use authorizations...are prescribed, the United 
Chapter 2. Alternatives, Including the Proposed Action

12 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

States Forest Service shall, with the cooperation and approval of the holders of these special use 

authorizations, develop a relocation plan for such individuals and entities.” Therefore, 

implementation of Alternative 1 may require the Forest to allow relocation of up to 88 recreation 

residences, which in turn would require the potential development of residence tracts in other 

areas of the Forest. If alternative 1 is selected, a future NEPA review would be required for any

proposed residence relocation.

Alternative 2: Proposed Action

The action proposed by the forest is to issue SUPs for 88 recreation residences on the Safford 

Ranger District for a term of 20 years, beginning on the day following the previous date of 

expiration, which was December 31, 2008. Permit holders will be required to abide by all terms 

and conditions expressed in individual SUPs and in accordance with an annual operation and 

maintenance (O&M) Plan that is conveyed with each. Prior to a new SUP being issued, each 

recreation residence would be inspected by the Forest Service to confirm that the permit holder is 

compliant with the terms and conditions of his/her interim permit [FSH 2709.11, 41.23a (3)].

Alternative 3: Issue Turkey Flat Permits Only

Implementation of Alternative 3 would authorize new SUPs for 74 recreation residences at the 

Turkey Flat tract only. Each new SUP term would extend 20 years, from January 1, 2009, through 

December 31, 2028. Permit holders would be required to abide by all terms and conditions 

expressed in their respective SUPs and an annual O&M plan. Prior to new SUPs being issued, 

each recreation residence would be inspected by the Forest Service to confirm that the permit 

holder is compliant with the terms and conditions of his/her interim permit [FSH 2709.11, 41.23a 

(3)]. If so, a new SUP will be granted.

Implementation of Alternative 3 would deny new permits for 14 recreation residences within the 

Old Columbine tract. Instead, Old Columbine permit holders would be issued an SUP that 

authorizes 10 years of occupancy, after which all improvements would be removed at the expense 

of homeowners [FSM 2721.23a (10)]. Removal activities at Old Columbine would be the same as 

those described for alternative 1 (no action).

Pursuant to the Arizona Idaho Conservation Act of 1988, P.L. 100-696, Section 605(c), “If ... 

termination, modification or nonrenewal of special use authorizations ... are prescribed, the 

United States Forest Service shall, with the cooperation and approval of the holders of these 

special use authorizations, develop a relocation plan for such individuals and entities.” Therefore, 

implementation of this alternative may require relocation of up to 14 Old Columbine residences, 

which in turn would require the potential development of residence tracts in other areas of the 

Forest. If alternative 3 is selected, a future NEPA review would be required for any proposed 

residence relocation.

Alternative 4: Issue Old Columbine Permits Only

Implementation of Alternative 4 would authorize new SUPs for 14 recreation residences at the 

Old Columbine tract only. Each new SUP term would extend 20 years, from January 1, 2009, 

through December 31, 2028. Permit holders would be required to abide by all terms and 

conditions expressed in their respective SUPs and an annual O&M plan. Prior to new permits 

being issued, each recreation residence would be inspected by special-uses program staff to 
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 13

confirm that the permit holder is compliant with the terms and conditions of his/her interim 

permit [FSH 2709.11, 41.23a (3)]. If so, a new SUP will be granted.

Implementation of Alternative 4 would deny new permits for 74 recreation residences within the 

Turkey Flat tract. Instead, Turkey Flat permit holders would be issued an SUP that authorizes 10 

years of occupancy, after which all improvements would be removed at the expense of the 

homeowners [FSM 2721.23a (10)]. Removal activities at Turkey Flat would be the same as those 

described for alternative 1 (no action). 

Pursuant to the Arizona Idaho Conservation Act of 1988, P.L. 100-696, Section 605(c), “If ... 

termination, modification or nonrenewal of special use authorizations ... are prescribed, the 

United States Forest Service shall, with the cooperation and approval of the holders of these 

special use authorizations, develop a relocation plan for such individuals and entities.” Therefore, 

implementation of this alternative may require relocation of up to74 Turkey Flat residences, 

which in turn would require the potential development of residence tracts in other areas of the 

Forest. If alternative 4 is selected, a future NEPA review would be required for any proposed 

residence relocation.

Alternatives Considered and Dismissed

Federal agencies are required by CEQ regulations to rigorously explore and objectively evaluate 

all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that 

were not developed in detail (40 CFR 1502.14). The following alternatives were considered but 

dismissed from detailed consideration in this EIS.

In-Lieu Lots for Permit Holders

A forest may consider offering in-lieu lots, if available, to permit holders who have received 

notice that either their recreation residence permit is being revoked for specific and compelling 

reasons in the public interest or that a new permit will not be issued following expiration of their 

permit because their lot is needed for an alternative public use (FSH 2709.11, 41.23d).

There are no suitable in-lieu lots for recreation residences available on the district. Therefore, this 

is not reasonably foreseeable alternative to the proposed action and was not considered further in 

this EIS.

New Recreation Residence Tract 

The alternative of creating a new tract at a different location on the Safford Ranger District is also 

not reasonably foreseeable. Creation of a new tract would be contrary to Forest Service policy at 

FSM 2347.1 (6), which states, “Do not establish new recreation residence tracts for in-lieu lot 

purposes.”

No New Permits and Immediate Removal of Residences

The forest evaluated the feasibility of proposing an alternative wherein new SUPs would not be 

issued and immediate removal of residences would be required. Such an alternative would 

support the Western Apache preference that the TCP be restored to its natural state as quickly as 

possible. However, this alternative conflicts with agency policy, which requires that at least 10 

years of continued occupancy be authorized after leaseholder notification that the residence is to 
Chapter 2. Alternatives, Including the Proposed Action

14 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

be removed [FSM 2721.23(e)]. Because a near-term change in FSM direction is not reasonable, 

this alternative was dismissed from further consideration in this EIS.

Mitigation and Related Requirements

The Forest Service has a trust responsibility toward American Indian tribes to the extent 

mandated by current laws and regulations. It requires the agency to (1) consider the effects of 

projects on historic properties, (2) ensure American Indian access to sacred sites, and (3) protect 

the physical integrity of historic, sacred, and cultural sites, wherever possible. 

All of the Pinaleño mountain range is within the Western Apache TCP and sacred site, which has 

been determined as eligible for listing on the National Register of Historic Places. From the 

perspective of the Apache, the presence and occupation of the residences affects Dził Nchaa Si’an

in the many ways.

First, the presence of the residences has altered and continues to alter the mountain’s natural fireadapted ecosystem, because the Forest Service’s primary response to wildland fire has been 

suppression, which has been deemed necessary for the protection of private property. 

Also, certain recreational activities of residents do not reflect the degree of respect that is 

warranted by a sacred site. In Apache cosmology, disrespectful actions not only distract from the 

Apaches’ experiences on the mountain, they can also bring harm to the world. If a decision is 

made to implement either the proposed action, alternative 3, or alternative 4, the continued 

existence of the recreation residences would be authorized by new permits, and these effects 

would continue.

Under the authority of the American Indian Religious Freedom Act, the Religious Freedom 

Restoration Act, and Executive Orders 13007 and 13175, Forest Service heritage program staff 

and the Forest Supervisor at the time, Jeanine Derby, conferred with the San Carlos Apache Tribe 

and the White Mountain Apache Tribe to identify measures to help minimize any effects that the 

presence and use of the residences have on the TCP. It was agreed among the parties that an 

operation and maintenance (O&M) plan conveyed with each new SUP will include the mitigation 

measures listed below. Future homeowner compliance with O&M requirements will reduce future 

effects on the TCP that the Apache associate with the presence and continued occupancy of 

recreation residences on Mt. Graham.

During Forest Service consultation with Western Apache leaders, heritage staff learned that the 

Tribes believe that residents have previously not complied with specific mitigation measures in 

their SUPs. Along with restrictions on modifications of residences and the prohibition of certain 

activities listed below, each new SUP will contain specific information intended to raise 

homeowner awareness of the value and significance of the TCP in the culture and history of the 

Western Apache people. This will include acknowledgement of the Forest Service’s general trust 

responsibility toward American Indian tribes (see above). The following items will be 

emphasized in each new SUP:

• Color standards that apply to all cabins, trim, roofs, and other structures 

• Design standards to ensure that improvements integrate well with the natural setting

• Constraints on public access to the residence tracts
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 15

• Fire-prevention measures 

• Domestic animal restrictions, e.g., a requirement that they be kept inside homes or on 

leashes not to exceed 6 feet in length

• Restrictions on human activities that may adversely affect wildlife breeding and foraging

• Notification to homeowners that in the event of a wildland fire, the Forest Service does 

not have a responsibility to protect recreation residences.

Each O&M plan will prohibit the following activities:

• Expanding structures and constructing room additions

• Planting non-native vegetation

• Diverting or retaining stream water flow

• Ground-disturbing activities without case-by-case District Ranger approval 

• Attaching swings, yard lights, signs, electric or other wires, and other materials to 

vegetation in a harmful manner

• Constructing outdoor fire-pits and sports courts

• Outdoor storage of building materials, recreation vehicles, television antennas, sports 

equipment, picnic tables, lawn chairs, etc.

• Driving off-road or parking outside designated parking areas. It is permissible to park up 

to 30 feet off National Forest System roads that access the residences.

• Constructing gates, fences, or walls

• On-site burning or burial of trash

• Creating unreasonable or excessive noise. 

At 36 CFR 261.10 i, 261.10 j, the Forest Service has established general noise guidelines 

for recreation sites and national forests that include quiet hours at developed sites from 

10:00 p.m. to 6:00 a.m.

Finally, recreation residences and associated structures must be compliant with direction provided 

in the most recent (October 2012) “Architectural Guidelines for Recreation Residences on the 

Coronado National Forest” (project record, item # 198). A copy of the guidelines report is 

available at the Safford Ranger District Office and at the Forest Supervisor’s Office in Tucson, 

Arizona

Comparison of Alternatives

Based on the impact analyses reported in chapter 3, table 1 provides a tabular comparison of the 

potential impacts of each alternative to each resource area. 
Chapter 2. Alternatives, Including the Proposed Action

16 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Table 1. Comparison of Potential Impacts of Alternatives for Issuing Special-Use Permits at Safford Ranger District 

Recreation Residences on the Coronado National Forest.

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

WILDLIFE

Mexican 

spotted owl 

(MSO)

Old 

Columbine

Noise and human presence 

would sporadically disturb the

MSO when improvements are 

being dismanteled. Removal will 

not be allowed during MSO 

nesting season. As natural 

succession occurs, the loss of 

open areas on the tracts may 

decrease populations of small 

mammals upon which the MSO 

preys. Eventual regrowth of 

trees (60 to 80 years hence) 

could provide new habitat 

suitable for MSO nesting. 

Removal of residences would 

negate the need for future fire 

suppression, which, in turn, 

would encourage the return of 

the natural fire cycle. With this, 

less intense fires would be 

expected, and old growth 

nesting habitat conserved.

No change from existing 

conditions. Owls would 

continue to be disturbed 

occasionally by human 

presence and activity, but 

populations and habitat 

would not be significantly 

affected.

Retention of the openings 

created by the residences 

would benefit populations 

of small mammals, upon 

which the MSO preys. 

An ESA* determination of 

“may affect, not likely to 

adversely affect” was 

made with regard to the 

potential impacts to the 

MSO at both tracts.

There would be “no effect” 

on designated critical 

habitat.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 17

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

WILDLIFE

Mt. Graham 

red squirrel 

(MGRS)

Old 

Columbine

Removal of an outhouse at Old 

Columbine could directly impact 

one midden. Death or injury of a 

MGRS is possible. It was 

determined that no action “may 

affect,is likely to adversely 

affect”the MGRS. Natural 

succession of trees on Old 

Columbine may provide 25 acres 

of MGRS habitat in the long 

term. With this, increased tree 

density may reduce nutrients 

available for cone production. 

This, in turn, would negatively 

impact the squirrel’s food 

supply. The removal of 

residences at either tract would 

obviate the need for future fire 

suppression, which, in turn, 

would encourage the return of 

the natural fire cycle. With this, 

less intense fires would be 

expected, and MGRS habitat at 

Old Columbine would be 

conserved.

No change from existing 

conditions.

Because of human 

presence at and near an 

active midden, an ESA 

determination of “may 

affect, likely to adversely

affect” was made for Old 

Columbine. A Biological 

Opinion issued by FWS on 

August 18, 2008, assigned a 

“take” of two squirrels and 

reported that this take 

“would not result in 

jeopardy to the species”.

The tract is not within 

designated critical habitat 

for the MGRS.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.
Chapter 2. Alternatives, Including the Proposed Action

18 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

WILDLIFE

Mt. Graham 

red squirrel 

(MGRS)

Turkey Flat The removal of residences at 

Turkey Flat would obviate the 

need for future fire suppression, 

which, in turn, would encourage 

the return of the natural fire 

cycle. With this, less intense 

fires would be expected, and 

MGRS habitat would be 

conserved.

No change from existing 

conditions. An ESA 

determination of “may 

affect, not likely to 

adversely affect” was 

made with regard to 

potential impacts at Turkey 

Flat.

Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

WILDLIFE

Gila trout

Old 

Columbine

Removal of improvements 

would increase erosion and 

runoff from the tracts in the 

short term. Impacts to water 

quality in the sub-watershed 

would be insignificant.

No change from existing 

conditions. An ESA 

determination of “may 

affect, not likely to 

adversely affect” was 

made with regard to the 

potential impacts to the 

Gila trout at Old 

Columbine.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat This species does not occur at 

the Turkey Flat tract.

Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

WILDLIFE

Forest 

Service 

Sensitive 

Species

Old 

Columbine

No trend toward Federal listing 

or loss of viability of any of the 

Forest Service sensitive species 

that occur at or near each tract.

No change from existing 

conditions. No trend 

toward Federal listing or 

loss of viability of any of 

the Forest Service sensitive 

species found at or near 

both tracts.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as for

alternative 2.

Effects would be 

the same as for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 19

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

WILDLIFE

Management 

Indicator 

Species

Old 

Columbine

No significant changes in 

forestwide populations and 

habitat of forest management 

indicator species.

No change from existing 

conditions.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

HERITAGE 

RESOURCES

(Sites on or 

eligible for 

the National 

Register of 

Historic 

Places)

Old 

Columbine

An NHPA* determination of “no 

adverse effect” on historic 

properties was made, per 36 

CFR 800.5 (b).

Removal is the preferred 

alternative of the Western 

Apaches.

Residences existed before 

eligibility of Mt. Graham as 

Traditional Cultural 

Property for National 

Register of Historic Places 

(NRHP). Their continued 

presence would not affect 

the qualities that make the 

it eliglble for NRHP. A NHPA 

determination of “no 

adverse effect on historic 

properties” was made, per 

36 CFR 800.5(b).

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

20 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

HERITAGE 

RESOURCES

(Dził Nchaa 

Si’an, 

Traditional 

Cultural 

Property)

Old 

Columbine 

Removal would enhance the 

sacredness of the mountain by 

fostering the restoration of the 

natural fire regime and wildlife 

habitat, reducing visual 

intrusions, and reducing human 

occupation and potential 

disrespectful behavior.

No change from existing 

conditions: restoration of 

wildlife habitat and natural 

fire regime would be 

delayed, visual and noise 

intrusions would continue.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

AIR 

QUALITY

Old 

Columbine

Short-term, sporadic, localized 

particulate matter (PM-10) 

emissions in fugitive dust from 

residence removal, burning 

debris, and vehicle traffic. 

Attainment of National Ambient 

Air Quality Standards would not 

be compromised.

No change from existing 

conditions.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

SOILS Old 

Columbine

Minimal short-term increase in 

erosion following removal of 

improvements. Use of best 

management practices would 

minimize erosion to insignificant 

levels. Sites would eventually 

return to a more natural slope.

No change in soil productivity.

No change from existing 

conditions. 

Natural bulk density and 

structure of soils would 

remain slightly compacted 

and altered by foot and 

vehicle traffic on the 77 

acres of the two tracts.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as for 

alternative 2.

Effects would be 

the same as or 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 21

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

WATER AND 

RIPARIAN 

RESOURCES

Old 

Columbine

Potential for increased shortterm erosion on 77 acres. Effects 

of sediment runoff in the subwatersheds would be 

discountable given the small 

acreage of the tracts relative to 

the size of the watersheds. Use 

of best management practices 

to minimize erosion would result 

in insignificant stream turbidity 

levels due to runoff. As the 

tracts are replenished with 

vegetation, hydrologic function 

would improve. The riparian 

channel of Ash Creek would 

eventually naturalize.

No change from existing 

conditions. 

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

RECREATION Old 

Columbine

Use of the tracts for developed 

recreation would discontinue. 

Tracts would become disperseduse sites. Minimal increase in 

use of other District recreation 

sites. Recreation Opportunity 

Spectrum setting for Old 

Columbine would change from 

Rural to Roaded Natural.

No change from existing 

conditions.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

22 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

VISUAL AND 

AESTHETIC 

RESOURCES 

Old 

Columbine

Short-term changes in visual 

quality during removal of 

improvements. Visual quality 

objective of “retention” would 

not be affected.

No change from existing 

conditions

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

WILD AND 

SCENIC 

RIVERS 

Old 

Columbine

No change from existing 

conditions.

No change from existing 

conditions.

No change from 

existing 

conditions.

No change from 

exisiting 

conditions.

Turkey Flat

FIRE 

MANAGEMENT

Old 

Columbine

After 10 years, Forest Service 

would realize cost savings 

because fuel thinning near 

structures and fire suppression 

would no longer be needed. As 

native vegetation repopulates 

the tracts, the fire cycle would 

gradually return to more natural 

fire-adapted conditions.

No change from existing 

conditions. Fire 

suppression and fuel 

thinning would continue to 

be necessary around tracts. 

Wildland fire use for 

resource enhancement 

would not be possible.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 23

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

SOCIAL 

AND 

ECONOMIC 

RESOURCES 

Old 

Columbine

Traditional family uses of 

residences, a small positive 

effect on local economies, and

revenues to the forest and 

Graham County would continue

for 10 years. Improvement

removal would cost permit 

holders about $3000. No 

disproportionate impacts on 

low-income or minority

populations.

No change from existing 

conditions. No 

disproportionate impacts

on low income and 

minority populations.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

24 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

RESOURCE RECREATION 

RESIDENCE 

TRACT

ALTERNATIVE 1 – NO ACTION ALTERNATIVE 2 –

PROPOSED ACTION, ISSUE 

PERMITS FOR BOTH 

TRACTS

ALTERNATIVE 3 –

ISSUE TURKEY 

FLAT PERMITS 

ONLY

ALTERNATIVE 4 –

ISSUE OLD 

COLUMBINE 

PERMITS ONLY

CUMULATIVE 

EFFECTS

Old 

Columbine

The removal of residences at 

both tracts would decrease the 

need for future fire suppression 

over 77 acres of the forest, 

which, in turn, would encourage 

the return of the natural fire 

cycle. Future natural fires would 

be less-intense, and wildlife 

habitat would be conserved, 

including MGRS habitat at Old 

Columbine. The mountain would 

be returned to a more natural 

condition, which would begin 

the reversal of numerous effects 

to the Western Apache TCP. 

No change to existing 

cumulative effects in the 

area of effect of both 

tracts.

Effects would be 

the same as those 

identified for 

alternative 1.

Effects would be 

the same as those 

identified for 

alternative 2.

Turkey Flat Effects would be 

the same as those 

identified for 

alternative 2.

Effects would be 

the same as those 

identified for 

alternative 1.

*ESA = Endangered Species Act; NHPA = National Historic Preservation Act
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 25

Chapter 3. Affected Environment and

Environmental Consequences

In this chapter, the physical, biological, social, and economic characteristics of the environment at 

and near the Old Columbine and Turkey Flat recreation residence tracts are described in as much 

detail as possible to define the baseline condition of the area of potential effect (APE), the 

boundaries of which often vary by resource. The legal coordinates of the tracts were given in 

chapter 1, and the layout of the residences is shown in figures 7 and 8.

The baseline description of the environment is followed by an evaluation of the potential for each 

alternative to impact specific resources. Sources of potential impacts are identified, following by 

an assessment of direct, indirect, and cumulative effects.

Each impact assessment includes a description of the approach used to evaluate proposed 

activities; provides references to scientific or other sources of data and information; discusses 

credible opposing views, if any; and discloses incomplete or unavailable information, scientific 

uncertainty, and risk [40 CFR, 1502.9 (b), 1502.22, 1502.24]. Further, the analysis of impacts to 

each resource is based on current, best-available scientific and commercial information to ensure 

the credibility of the discussions [36 CFR 219.36 (a)].

Not all resource impacts are measurable or quantifiable. Where this is the case, a qualitative 

judgment is made regarding the degree of effect on the resource. Guidelines related to 

significance generally fit into two main categories:

 Emissions-based, comprising standards for air and water quality, noise, etc., and

 Environmental-quality based, comprising significance criteria for valued ecosystem 

components or similar attributes, such as biodiversity.

Determining whether or not an effect is significant is dependent upon the degree of an action’s

effect relative to thresholds established as acceptable for each resource. Said another way, for 

each resource, there is a threshold above which a potential impact is considered as significant. For 

example, an impact to air quality may be considered significant if it increases the ambient 

concentration of a specific chemical element or compound above the concentration established by 

a resource management agency, such as the U.S. Environmental Protection Agency (EPA), for the 

protection of human health and safety. Thresholds also provide a tool to predict whether it is 

likely that the impacts identified as potentially significant can be avoided, reduced, or mitigated 

to a less-than-significant level.

Approach to Cumulative Effects Analysis

The CEQ regulations for implementing NEPA define a cumulative impact as “the impact on the 

environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or nonFederal) or person undertakes such other actions (40 CFR 1508.7).” The combined, incremental 

effects of human activity, referred to as cumulative effects, may pose a serious threat to a 

resources or an entire ecosystem. Although an impact may be insignificant by itself, it may 

contribute to cumulative effects that accumulate over time, from one or more sources, and result 

in the degradation of important resources.

Because the spatial (geographic) and temporal (time) characteristics of an APE differ for each 

resource, each cumulative effects analysis that follows includes a definition of the APE. The 
Chapter 3. Affected Environment and Environmental Consequences

26 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Pinaleño Mountains, in general, are the broad area of consideration for the cumulative effects 

analysis reported in this EIS. Past, present and reasonably foreseeable future activities within this 

area are listed in table 2, with corresponding locations shown on figure 3.

Table 2. Past, Present, and Reasonably Foreseeable Actions Considered in the Cumulative 

Effects Analysis Reported in this EIS.

Number 

on Map 

(Figure 

3) Activity

Approximate 

Date

Area 

Affected

1 (not 

shown)

Introduction of Abert’s squirrel 

(Sciurus aberti) 1940s all

2 Timber sales71943 to 1973 7924 acres

3 Arizona Bible Camp (special-use permit) 1966 to present 20 acres

4 Marijilda fire 1989 363 acres

5

Renewal of Mt. Graham International 

Observatory (MGIO) special-use permit 1988 24 acres

6 Graham Complex fire 1993 544 acres

7 Clark Peak fire 1996 4948 acres

8 Nuttall Complex fire 2004 29,698 acres

9

Use of paved roads: Swift Trail (Hwy 366) 

and Stockton Pass Highway 1960 to1980s 37 miles

10 Pinaleño Ecosystem Management (PEM) 

project (fuel reduction: mechanical) 2001 to present 1100 acres

11

Pinaleño Ecosystem Restoration Project 

(PERP) (fuel reduction, habitat 

improvement)

Present to 2022 5800 acres

12 Reconstruction of Heliograph Lookout 2006 to 2007 < 1 acre

13 Trails use and maintenance (41) Ongoing 155 miles

14

Use and maintenance of developed 

campgrounds (Noon Creek, Shannon, 

Hospital Flat, Cunningham, Columbine 

Corrals, Soldier Creek and Riggs)

Ongoing 25.5 acres

15

Use and maintenance of picnic sites and 

trailheads (Stockton Pass, Old Noon Creek, 

Round-the-Mountain, Wet Canyon, Clark 

Peak)

Ongoing 3.5 acres

 

7

Logging was carried out in the mixed conifer and spruce-fir stands from 1946 to 1973.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 27

Number 

on Map 

(Figure 

3) Activity

Approximate 

Date

Area 

Affected

16

Group use areas (Stockton Pass, Upper 

Arcadia, Upper Hospital Flat, Snow Flat, 

Treasure Park, and Twilight)

Ongoing 26.75 acres

17 Columbine Visitor Information Station Ongoing 1 acre

18

Maintenance and use of administrative 

facilities (Noon Creek, Heliograph, Webb 

Peak, West Peak, and Columbine)

Ongoing 7 acres

19 Operation of electronic sites (Heliograph and 

Ladybug) (special-use permits) Ongoing 7 acres

20 Operation of Angle Orchard (special-use 

permit) Ongoing 2 acres

21 Use and maintenance of dam/reservoir 

(special-use permit) Ongoing 13 acres

22

Operation and maintenance of water systems 

associated with Old Columbine and Turkey 

Flat recreation residence tracts

Ongoing 2.1 miles

23 Maintenance and operation of waterlines (six 

special-use permits) Ongoing unknown8

24 Fuel reduction at 5 special-use sites 2007 250 acres

25 Microwave dish installation 2007

Within 24-

acre MGIO 

site

26

Grazing allotments (active) in Ash Creek and 

Jacobson Canyon sub-watersheds 

 White Streak 

 Veach

 Marijilda

Ongoing

1668 acres

487 acres

1046 acres

 

8

Forest Watershed and Program Manager, Bob Lefevre, reported that this information is unavailable

(4/24/08).
Chapter 3. Affected Environment and Environmental Consequences

28 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Figure 3. Relative Locations of Reasonably Foreseeable Actions near the Safford 

Recreation Residence Tracts. Note: Numbers in figure 3 correspond to those activities listed in 

table 2.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 29

Air Quality

The forest plan establishes the following standard and guideline for air resources; it is applicable 

to all areas of the Coronado NF.

“All management practices would be planned so that air quality would meet local, State, and 

Federal standards (USDA-FS, 1986, p. 45-1).”

Affected Environment

To conserve and protect the ambient air quality of the United States, provisions of the Clean Air 

Act (CAA)9required the EPA to establish National Ambient Air Quality Standards (NAAQS) for 

air pollutants that affect human health and welfare. It also directed EPA to establish criteria that 

would protect and maintain clean air in natural areas, such as designated wilderness areas, 

national parks and national forests.

With regard to protecting ambient air quality, NAAQS were established for the following primary 

air pollutants, which have the potential to adversely affect human health when ambient 

concentrations are above certain levels: carbon monoxide (CO), lead (Pb), nitrogen dioxide 

(NO2), ozone (O3), sulfur dioxide (SO2), and particulate matter (PM). Threshold concentrations 

are continually updated by EPA as new scientific information and monitoring technology become 

available. Networks of ambient air pollutant monitoring stations across the U.S. record data that 

characterizes air quality. When non-attainment for one or more pollutant thresholds is evidenced, 

the EPA or individual states implement enforcement actions that remediate violations of NAAQS.

The preservation of air quality in natural areas was addressed by the CAA in its “prevention of 

significant deterioration” regulatons, which apply to the following classes of airshed: a Class I 

airshed has the most restrictive pollution control standards and generally includes National Parks 

and Wilderness areas; Class II generally comprises rural areas and has less restriction than a Class 

I area. The air quality analysis in this EIS focuses on impacts to the Upper Gila River airshed, 

which is a Class II area (see figure 4). Atmospheric pollutants in this airshed typically result from 

wildland fires, prescribed fires, and dust from traffic and other activities on unpaved roads. 

Gasoline engine exhaust emissions and propane combustion are additional sources of pollutants 

in the airshed.

Ambient air quality in the airshed and at the recreation residence tracts is very good because of its 

relative isolation from urban centers and major highways, limited access, extensive vegetation 

groundcover, and the large scale of the analysis area. As of December 5, 2013, the area was in 

attainment for all NAAQS (US-EPA, 2013).

Environmental Consequences

Direct and Indirect Effects

Direct impacts to air quality are those that result from emissions of pollutants from various 

sources to the atmosphere. Point sources of pollutant emissions include chimneys, smokestacks, 

and other structures that provide a discrete release point. Non-point sources result from soil-

 

9

http://www.epa.gov/lawsregs/laws/caa.html, 42 U.S.C. 7401 et seq. (1970)
Chapter 3. Affected Environment and Environmental Consequences

30 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

disturbing activities, such as vehicle travel on a dirt road or ground disturbance by a bulldozer, 

and smoke from a fire that indiscriminately releases pollutants over a broad area rather than a 

single release point.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 31

Figure 4. Location of the Class II Upper Gila River Airshed (7) in Arizona.

The measure of significance of atmospheric releases is based on a comparison of the predicted 

concentration of each pollutant at or beyond a site boundary or within the boundary on public 

roads, to an established standard, such as a NAAQS, and consideration of the potential for the 

expected concentration to adversely affect a sensitive receptor, human and otherwise.
Chapter 3. Affected Environment and Environmental Consequences

32 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Many of the Safford recreation residences have wood-burning fireplaces or stoves, propane 

stoves and heaters, gasoline generators, and unpaved driveways and access roads. The quantity of 

pollutant emissions from these sources is extremely minimal and intermittent and related to the 

season of use of the recreation residences, which is approximately May 1 to mid-October, and the 

duration of occupancy. Occupancy is most often on a few weekends per season and an occasional 

stay of a week or more.

If no action is taken (alternative 1), emissions from recreation residences would cease after the 

10-year closeout permit expires. However, during removal of the residences, local ambient air 

quality may be temporarily affected by smoke from localized burning of combustible materials 

and by dust from increased vehicle travel to and from the tracts. If this occurs, local 

concentrations of particulate matter (PM-10) may increase sporadically for up to a week, 

depending on the quantity and type of material burned and the duration of burning. Changes in 

ambient PM-10 concentrations would be imperceptible. These emissions would in no way 

adversely affect the attainment of NAAQS in the airshed.

Implementation of alternative 2 (proposed action) would not change the ambient air quality at the 

recreation residence tracts or the quality of the airshed. Attainment of NAAQS would not be 

affected.

The effects of implementing alternatives 3 would be the same as either alternative 1 or alternative

2, depending on which residences are removed or retained.

Cumulative Effects: Air Quality

The Upper Gila River airshed (see figure 4) is the focus of this cumulative effects analysis.

Future prescribed fires and randomly occurring wildland fires are the primary source of air

pollutants considered incrementally. Prescribed fires would affect ambient air quality to various 

degrees during the time of burning, depending on the duration of the burn. To minimize and/or 

avoid potential adverse impacts on ambient air quality, the Forest Service plans and implements 

prescribed fires in accordance with the Arizona Department of Environmental Quality (ADEQ) 

State Implementation Plan, which establishes parameters for minimizing smoke emissions and 

dispersal, such as limitations on burning based on air temperature, humidity, wind speed, etc. 

(ADEQ, 2002, 2006).

Exhaust emissions and dust generated by vehicle travel to and from administrative and specialuse facilities in the APE have a negligible impact on ambient air quality in the airshed. Past 

logging operations and past, present, and future grazing generate negligible emissions of 

atmospheric pollutants, including those areas that have been historically overgrazed or logged, 

where wind erosion of soils may occasionally temporarily increase ambient PM emissions.

If no action is taken and improvements are removed, short-term increases of dust and smoke from 

localized burning on the tracts could minimally increase ambient PM concentrations. Planning of 

prescribed fires by the Forest would ensure that these activities would not be undertaken 

concurrently.

Cumulative effects of implementing alternatives 2, 3, and 4 would also be negligible because of 

the short season of use for the residences at both tracts and the planning of prescribed fires so that 

they do not overlap with removal activities. Significant cumulative effects would not be expected.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 33

Soils

The forestwide standard and guideline applicable to the tracts is as follows:

“Through management services, provide information to minimize disturbance and improve 

already disturbed areas. Best Management Practices (BMP) would be used to minimize 

the time of recovery to a satisfactory erosion level, minimize soil productivity loss, 

improve water quality, and minimize channel damage (USDA-FS, 1986, p. 38).”

Affected Environment

For this analysis, potential impacts to soils in two sub-watersheds were evaluated (see figure 5: 

Ash Creek and Jacobson Canyon sub-watersheds). The Old Columbine tract is in the Ash Creek 

sub-watershed, which is approximately 5094 acres in size, and the Turkey Flat tract is within the 

Jacobson Canyon sub-watershed, which covers about 8920 acres. The residence tracts are a very 

small percentage of the total watershed sizes (25 and 52 acres respectively); therefore, the 

potential for soils impacts is very low.

A General Ecosystem Survey (GES) was completed for the National Forests of Arizona and New 

Mexico (Carleton et al, 1991). For the Safford Ranger District, it reports that soils at both tracts 

are within the Low Sun Cold (LSC) climatic class. In this area, most annual precipitation occurs 

between September 30 and April 1. The average annual precipitation in the project area is 

between 30 and 36 inches (Western Regional Climate Center, 2006). Table 3 provides descriptive 

information for each GES unit in the tracts.

The Old Columbine tract is located on gneiss. Soils are deep, very cobbly to extremely cobbly, 

sandy loams with numerous rock outcrops. The elevation of this tract is 9400 feet above mean sea 

level (amsl). Turkey Flat is located on intrusive granitic rock. Soils are shallow to deep, very 

cobbly to extremely cobbly, sandy loams. The elevation of this tract is 7200 feet amsl.

To determine the existing condition of surface soils, pits were excavated on the recreation 

residence tracts10, using the Forest Service Southwestern Region protocol prescribed in FSH 

2509.18. Determinations were made in areas adjacent to recreation residences, in the common 

areas between the residences, in parking areas, in informal paths, and in general forest areas 

outside the tracts.

The surveys indicated that soil texture and depth have not been modified at any of the areas 

examined. However, natural soil bulk density11 was compacted, and soil structure12 was altered

 

10 June 14, 2006; Bob Lefevre, Forester/Watershed and Forestry Program Manager, Coronado NF

11 Soil bulk density is defined as the ratio of the mass of dry solids to the bulk volume of the soil occupied 

by those dry solids. It varies with structural condition of the soil, particularly that related to packing.

12 The arrangement of soil particles into larger particles or clumps. This arrangement modifies the bulk 

density and porosity of the soil.
Chapter 3. Affected Environment and Environmental Consequences

34 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Figure 5. Relative Location of Ash Creek and Jacobson Canyon Sub-watersheds and the 

Old Columbine and Turkey Flat Recreation Residence Tract.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 35

Table 3. Descriptive Information about General Ecosystem Survey Units in the Old 

Columbine and Turkey Flat Recreation Residence Tracts.

Recreation 

Residence 

Tract

GES 

Unit

Average 

Gradient 

%

Surface 

Texture/ 

Modifier

Soil 

Depth

Parent 

Material

Climate 

Class

(see text for 

description)

Erosion 

Hazard

Old 

Columbine 466 0 to 15

Cobbly / 

Sandy 

Loam

Deep Gneiss LSC Slight

Turkey Flat 476 40 to 80

Extremely 

Cobbly / 

Sandy 

Loam

Deep Granite LSC Moderate

(crushed). This damage was found in the areas adjacent to the recreation residences, parking 

areas, and informal paths, primarily as a result of foot and vehicle traffic. The other areas, 

common areas, and the general forest areas did not show damage to soil bulk density or structure.

Changes in soil density and structure likely resulted from the excavation of foundations and 

footings and from pedestrian and vehicle traffic from residence to residence and to nearby forest 

areas and from landscaping. At residences located on a slope, erosion is presently mitigated by 

landscape vegetation, rock and concrete barriers, terraces, and logs or boards. Maintenance of 

access roads and driveways also minimizes erosion on the tracts.

Soil productivity (the capacity of a soil, in its normal environment, to support plant growth) in the 

tracts is typical for the class of soils present. There is no prime or unique farmland present on 

either tract or in the immediate vicinity of the tracts.

Environmental Consequences

Direct and Indirect Effects

In general, impacts to soils are the result of ground-disturbing activities that alter their physical, 

biological, and chemical properties. Activities conducted by recreation residence permit holders 

for the next 20 years of occupancy would continue to affect erosion patterns and potential, which, 

in turn, may locally affect the condition of the sub-watersheds in which the tracts are located.

The threshold of significance for impacts of soils is related to the degree of changes in soil 

density and structure as well as the degree of erosion and runoff that may occur as a result of the 

proposed action. A quantitative measure for these properties was not defined. In lieu of this, the 

significance of impacts is correlated with the potential for a high degree of runoff that will result 

in such degradation of the watershed as to impact the water quality of streams and their use.

Old Columbine Tract

If no action is taken, the natural slope of the area would gradually return after structures are 

removed. Grasses and shrubs would likely reappear on the tract within the first five years. Based 

on post-removal observations at other locations on the Coronado NF (Madera Canyon on the 
Chapter 3. Affected Environment and Environmental Consequences

36 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Nogales Ranger District and Upper Sabino Canyon on the Santa Catalina Ranger District13), 

compaction and altered soil structure (crushed) would likely persist at least 20 years. 

Until vegetation is established sufficiently to stabilize disturbed soils, Best Management Practices 

(BMPs) would be applied by the forest (FSH 2509.22) to minimize resource damage (USDA-FS, 

1990). Overall, the additional increment of erosion in the short term following residence removal 

would not affect long-term soil productivity.

If new permits are issued, no short-term changes in soils would occur. Over the next 20 years, 

natural soil bulk-density and structure would continue to be compacted and altered by foot and 

vehicle traffic. Landscaping and BMPs would continue to minimize soil erosion. There are no 

sources of impact in the tracts that affect long-term soil productivity. This would not change.

If new permits are issued for Turkey Flat only, effects to soils would be the same as those of no 

action. If new permits are issued for Old Columbine only, effects on soils would be the same as 

reported for the proposed action.

Turkey Flat Tract

The direct and indirect effects of no action and the proposed action at Turkey Flat would be the 

same as those described for Old Columbine. If new permits are issued for Turkey Flat only,

effects on soils would be the same as those of the proposed action. If new permits are issued for 

Old Columbine only, effects on soils would be the same as those of no action.

Cumulative Effects: Soils

Cumulative effects on soils were evaluated based on their interrelationship with the condition of 

the two sub-watersheds in which they are located. Watershed condition is established by 

examination of physical and biological characteristics and processes affecting hydrologic and soil 

functions. In 2000, the condition of each sub-watershed was determined by evaluating data and 

information about soil condition, riparian area condition, and water quality [FSM 2521.05 

(USDA-FS, 2004). Using direction in FSM 2521.1, both sub-watersheds were determined to be in 

Class I Condition, or “satisfactory”14.

Past, present and foreseeable future projects or actions that have affected or may, in the future, 

affect the soils and other resources in Ash Creek and Jacobson Canyon sub-watersheds are listed 

in table 2. A detailed characterization of how these projects have impacted soils in the subwatersheds is on file in the soils specialist report in the EIS project record (item # 176). A brief 

summary of the nature and effects of past projects follows.

Logging

From 1880 until 1973, logging was an important activity in the sub-watersheds. Logging in the 

mixed conifer and spruce-fir stands, including clear cuts and selection cuts, began in 1946; from 

1973 until 1986, it continued on a limited basis. Approximately 800 acres were logged in Ash 

Creek sub-watershed and 300 acres in Jacobson Canyon sub-watershed. On June 14, 2006, test 

 

13 Observations by Bob Lefevre, Coronado National Forest, Watershed and Forestry Program Manager, 

June 2006.

14 Observations by Bob Lefevre, Coronado National Forest, Watershed and Forestry Program Manager, 

June 2006.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 37

pits were excavated in selected areas that had been logged to determine soil conditions. 

Compaction and soil structure alteration were detected in historic skid roads. Based on visual 

observations and soil testing, an estimated 30 percent of the logged area has evidence of 

compaction and altered soil structure (see table 4).

Table 4. Effects of Historic Logging in the Sub-watersheds of Old Columbine and Turkey 

Flat Recreation Residence Tracts.

Recreation 

Residence 

Tract

Analysis Area 

(Subwatershed)

Percent of 

Subwatershed 

Occupied by 

Recreation 

Residence 

Tract

Acres 

Logged

Acres with 

Soil 

Compaction 

and Altered 

Soil 

Structure

Percent of 

Subwatershed 

with

Cumulative 

Effects from 

Historic 

Logging

Old 

Columbine 

(25 acres)

Ash Creek

(5,094 acres) less than 0.01 800 240 5

Turkey Flat 

(52 acres)

Jacobson 

Canyon

(8,920 acres)

0.01 300 100 1

Grazing

Past heavy livestock grazing in these two sub-watersheds has decreased the abundance of native 

grasses, increased shrubs in the uplands, and altered soil structure and bulk density. Further, nonnative plant species, predominantly Lehmann lovegrass (Eragrostis lehmanniana), which were 

introduced in the lower elevation uplands in the 1950s and 60s displaced native grasses in most 

areas already disturbed by grazing. In some areas, removal of vegetation by grazing resulted in 

soil loss, which was followed by the invasion of exotic grasses. Table 5 reports the impacts in the 

sub-watersheds to date from grazing.

Table 5. Historic Impacts of Grazing on Soils in the Ash Creek and Jacobson Subwatersheds.

Recreation 

Residence 

Tract

Analysis 

Area (Subwatershed)

Subwatershed 

Occupied by 

Recreation 

Residence 

Tracts

Portion of 

Grazing 

Allotment 

within Subwatershed

Percent of 

Analysis Area 

with Grazing 

Impacts

Old Columbine

(25 acres)

Ash Creek 

(5,094 acres) less than 0.01 1,842 acres 36

Turkey Flat (52 

acres)

Jacobson 

Canyon

(8,920 acres)

0.01 1,534 acres 17
Chapter 3. Affected Environment and Environmental Consequences

38 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Livestock grazing in the highest elevations of the sub-watersheds was discontinued in the 1950s, 

and BMPs (FSH 2509.22) were implemented on the Coronado NF to mitigate grazing effects. A 

general improvement in soil conditions has been observed.

Fire, Fuel Treatments, and Other Uses

Past prescribed and natural fires as well as wildland fire suppression have changed the vegetation 

composition of the sub-watersheds, which, in turn, has increased erosion. About 50 percent of the 

area affected by the 2004 Nuttall Complex fire (4,705 acres) is still experiencing accelerated 

erosion.

Mechanical fuel reduction and forest restoration projects can have both negative and positive 

effects on soils. Unmitigated ground-disturbance by vehicles and heavy equipment increases 

erosion, while the creation of sustainable native plant communities promotes natural soil 

formation and erosion rates.

The Pinaleño Ecosystem Management (PEM) project (table 2, # 10) was completed on 110 acres 

within the sub-watersheds. To date, no measurable effects on soils have been observed based on 

field observations15. Other proposed projects (table 2, #11 and #24) would treat approximately 

848 acres within the sub-watersheds using both prescribed fire and mechanical treatment. Best 

Management Practices will be employed during both projects to minimize adverse effects.

The use of recreational sites, administrative facilities that include crew quarters, communication 

equipment, privately owned communications facilities, organizational camps, astrophysical sites, 

and the roads and trails that access them, affect soils on approximately 40 acres in the subwatersheds. Foot and vehicle traffic cause soil compaction and alter soil structure in these use 

areas, and erosion is increased in disturbed areas.

Cumulative Effects: Soils

If no action is taken, both short-term (zero to five years) and long-term (30 or more years) 

impacts to soils would continue on approximately 10,154 acres (see table 6) where past activities 

have increased erosion, decreased soil bulk density, and altered soil structure. Over time, soil 

conditions would be expected to gradually improve in areas where ground disturbance has 

discontinued and vegetation is growing.

Most past, present, and reasonably foreseeable projects would continue to affect 72 percent 

(10,154 acres) of the two sub-watersheds over time, ranging from about 20 years of continuing 

effects because of wildland fires, to an indeterminate period of time because of continued grazing 

at lower elevations. The soils resource should benefit across the entire analysis area over time 

because of the continued use of BMPs and natural soil formation processes. Watershed condition 

would continue to remain as is (satisfactory), despite continuing impacts from past actions.

If the proposed action is implemented, cumulative effects on soils would include those that 

continue from past actions plus the additional effects of continued occupancy of the 77 acres at

residence tracts (0.01 percent of the two sub-watersheds) (see chapter 3, soils, affected 

environment section). Watershed conditions would not be measurably affected.

 

15 As reported by Bob Lefevre, Forester; Watershed and Forestry Program Manager, Coronado National 

Forest; April 10, 2006; June 21, 2006; October 2, 3, 4 ,5, and 6, 2006; and November 30, 2006.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 39

The cumulative effects of issuing new permits to Turkey Flat only would be the same as those 

described for no action, except that human activities on 52 acres that comprise the Turkey Flat 

tract would continue to contribute effects on the soil resource within 0.01 percent of the Jacobson 

Canyon sub-watershed. The condition of both sub-watersheds would continue to remain 

satisfactory.

The cumulative effects of issuing new permits for Old Columbine only would be the same as 

those described for no action, except that human activities on 25 acres that comprise the Old 

Columbine tract would continue to contribute effects on the soil resource within the Ash Creek 

sub-watershed (less than 0.01 percent). The condition of both sub-watersheds would continue to 

remain satisfactory.

Table 6. Acreage of Soils Impacted by Past, Present, and Future Activities in the Ash Creek 

and Jacobson Canyon Sub-watersheds.

Project or Action Impacted Acres of Soils

Within Sub-watersheds

Graham Complex fire 250

Clark Peak fire 484

Nuttall Complex fire 4705

PEM Project 110

PERP 848

Heliograph Lookout Repair 1

Historic Logging 340

Grazing 3376

Administrative Facilities 15

Recreation Facilities 25

Total 10,154 acres

Water Resources and Riparian Areas 

Forest plan standards and guidelines applicable to water resource management, including riparian 

areas, are as follows:

 “Through management services, provide information to minimize disturbance and 

improve already disturbed areas. Best management practices would be used to 

minimize the time of recovery to a satisfactory erosion level, minimize soil 

productivity loss, improve water quality and minimize channel damage (p. 38-5);”
Chapter 3. Affected Environment and Environmental Consequences

40 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

 “Monitor designated projects according to an approved water quality monitoring plan 

(p. 39-6);”

 “Manage all programs to eliminate or minimize onsite and downstream water 

pollution (p. 73-2);”

 “Manage riparian areas in accordance with legal requirements regarding floodplains, 

wetlands, wild and scenic rivers, and cultural and other resources. Recognize the 

importance and distinct values of riparian areas in forest plans (p. 39-8);” and

 “Manage riparian areas to protect the productivity and diversity of riparian-dependent 

resources by requiring actions within or affecting riparian areas to protect and, where 

applicable, improve dependent resources (FSM 2526). Emphasize protection of soil, 

water, vegetation, and wildlife and fish resources prior to implementing projects 

(FSM 2526) (p. 39-9).”

Affected Environment

Water resources that may be affected by activities in the recreation residence tracts are located 

within the Ash Creek (Old Columbine) and Jacobson Canyon (Turkey Flat) sub-watersheds (see 

figure 5). Potentially affected elements of water resources include water quantity, water quality, 

and riparian resources.

Water Quantity

Water quantity is measured in terms of the peak flow of surface waters and the total annual water 

yield per area. The peak flow of surface waters depends on hydrologic function, which is the 

ability of soil to capture, hold, and release water. There is one surface water flow gauging station 

in the vicinity of the project area, at Frye Creek near Thatcher, Arizona (USGS 09460150). Frye 

Creek watershed is similar to Ash Creek in many ways, and is used here as a surrogate to describe

the flow characteristics and water yield of the Ash Creek sub-watershed. Data from this gauge 

indicate that snowmelt runoff comprises most of Frye Creek’s flow, because the highest monthly 

mean flows are recorded in April and May. Average water yield is 0.51 acre-feet per acre

annually (USDI-GS, 2007).

Total surface water yield is controlled by annual precipitation in areas receiving less than 20 

inches of precipitation per year, and by vegetation type and density in areas where there is more 

than 20 inches of precipitation per year. The average annual precipitation for the Ash Creek and 

Jacobson Canyon sub-watersheds is less than 20 inches. The average annual precipitation in the 

two tracts is between 30 and 36 inches (NOAA, 2007).

The Jacobson Canyon watershed differs from Ash Creek in that it has more woodland and 

grassland vegetation. There are no representative gauging stations in the vicinity. Using a water 

balance model developed for woodland watersheds (Ffolliott, 2000), it is conservatively 

estimated that the Jacobson Canyon watershed yields 0.10 acre-feet/acre annually.

The Old Columbine tract is located in the Ash Creek sub-watershed. Using the Frye Creek 

average of 0.51 acre-feet/acre water production as a surrogate, Ash Creek is capable of producing 

about 2,624 acre-feet of water annually on the Coronado NF.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 41

The Turkey Flat recreation residences are located in the Jacobson Canyon sub-watershed. Using 

the calculated yield of 0.1 acre-feet/acre water production as a guide, Jacobson Canyon is capable 

of producing about 890 acre-feet annually.

Total water consumption in the sub-watersheds, based on known water rights applications and 

existing water rights, is 2061 acre-feet per year or about 59 percent of the total water produced. 

Fish habitat in Ash Creek and an AGFD facility at Cluff Ranch use 97 percent of the total demand

(i.e., 2000 acre-feet16). The 88 recreation residences use 22.15 acre-feet per year or 0.06 percent

of the total, with Old Columbine consuming about 2.85 acre-feet (0.11 percent of the available 

water) [Arizona Department of Water Resources (ADWR, 1985)] and Turkey Flat using about 

19.3 acre-feet (2.16 percent of available water) (ADWR, 1931 and 1938). Table 7 summarizes 

water yield by sub-watershed and use by recreation residences within the sub-watersheds.

Table 7. Annual Water Yield and Use in the Sub-watersheds of the Safford Ranger District

Recreation Residence Tracts.

Recreation 

Residences

SubWatershed

SubWatershed 

Size (acres)

Estimated 

Annual 

Surface Water 

Yield (acrefeet)

Water 

Used

(acrefeet/yr)

Percent of 

Available 

Water 

Used from 

SubWatershed

Old 

Columbine Ash Creek 5,094 2,624 2.85 0.11

Turkey Flat Jacobson 

Canyon 8,920 890 19.30 2.16

Source: ADWR, 1985

Water Quality

The quality of a water resource is based on its chemical, physical and biological characteristics 

relative to the desired conditions for its use. These characteristics, in turn, are affected by 

conditions and activities within the watershed, which may include point and non-point sources17.

Water quality is often affected by erosion of pollutants from the soil surface, which increases 

sediment deposited in surface waters. Turbidity resulting from increased suspended sediments is a 

common degradation of surface water quality. In Ash Creek and Jacobson Canyon subwatersheds, pollutant sources include, but are not limited to, grazing, recreation, roads, septic 

systems, atmospheric deposition, and point source discharges.

The quality of a surface water resource is determined by how well it meets pollutant standards 

established under the authority of the Clean Water Act (33 U.S.C 1251) relative to its desired or 

designated use (e.g., body contact, fish habitat). Based on monitoring of specific pollutants, the 

 

16 An acre-foot is equivalent to one foot of water covering an area of one acre.

17 A point source is any discernible confined and discrete conveyance including. but not limited to, a pipe, 

ditch, channel, or conduit from which pollutants are or may be discharged 

(http://www.fedcenter.gov/resources/facilitytour/wastewater/pointsource).
Chapter 3. Affected Environment and Environmental Consequences

42 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

ADEQ assigns water quality status as one of the following “attaining all uses, attaining some 

uses, inconclusive, not attaining, or impaired”.

No perennial streams within either of the tracts or surrounding area are reported on the “State of 

Arizona 303(d) List and Other Impaired Waters (ADEQ, 2004)”. The status reports for Ash Creek 

downstream from the residence tracts and for nearby Grant Creek and Frye Creek are provided in 

table 8 (ADEQ, 2004). Figure 6 (Water Quality Assessment) illustrates the location of these 

streams relative to the recreation residences. No link has been established between the presence 

and occupancy of the recreation residences as the source of any pollutants to any of these waters. 

Table 8. Surface Water Quality Status in Three Streams in the Vicinity of the Safford 

Ranger District Recreation Residence Tracts.

Surface Water 2004 Assessment 

Status Standards Exceeded

Ash Creek Category 2 – Attaining 

Some Uses

None; results of the analysis of 

cadmium, copper, and zinc were missing.

Frye Creek Category 2 – Attaining 

Some Uses

None; results of analysis of mercury, 

arsenic, chromium, lead, cadmium, 

copper, and zinc were missing. All 

parameters sampled are attaining all 

uses.

Grant Creek Category 3 –

Inconclusive

None exceeded; only two samples were 

analyzed.

Source: ADEQ, 2004

Riparian Resources

Data and information that define riparian vegetation18 and stream channels in the vicinity of the 

recreation residence tracts (see table 9) were derived from on-the-ground observations19, 

Coronado NF Geographic Information System (GIS) database layers, and the forest plan.

Potential direct and indirect effects on riparian resources were evaluated for a specific area 

around the recreation residence tracts (see figures 7 and 8: Riparian Resources, Old Columbine 

and Turkey Flat tracts). The area for which cumulative effects were assessed includes the two 

sub-watersheds: Ash Creek and Jacobson Canyon. 

 

18 The kinds and amounts of vegetation in the riparian areas are different than terrestrial vegetation. These 

differences reflect the influence of free or unbound water from the adjacent watercourse or water body.

19 Observations made by Bob Lefevre, Coronado NF Forester/Watershed and Forestry Program Manager, 

June 14, 2006.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 43

Figure 6. Location and Water Quality Category of Three Streams in the Vicinity of the 

Safford Ranger District Recreation Residence Tracts.
Chapter 3. Affected Environment and Environmental Consequences

44 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Figure 7. Area of Analysis: Riparian Resources on the Old Columbine Recreation 

Residence Tract on the Safford Ranger District.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 45

Figure 8. Area of Analysis: Riparian Resources on the Turkey Flat Recreation Residence 

Tract on the Safford Ranger District.
Chapter 3. Affected Environment and Environmental Consequences

46 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Table 9. Primary Named Watercourses at or near Safford Ranger District Recreation 

Residence Tracts.

Recreation 

Residences Named Drainage

General 

Direction 

of Flow

Proximity of Recreation 

Residence Tract to Channel

Old Columbine Ash Creek Northeast Within the tract

Turkey Flat Twilight Creek Northeast More than 500 feet away from the 

tract

Ash Creek has year-round surface water flow (perennial) and is located within the Old Columbine 

tract. All other surface water channels in the sub-watershed are either outside the APE or have 

intermittent or ephemeral flows (see figure 9: Stream Channels). The recreation residence tracts 

do not include any mapped wetlands or floodplains (National Wetlands Inventory, 1977).

Old Columbine Tract

Vegetation in the Old Columbine tract includes Engelmann spruce (Picea engelmanni), corkbark 

fir (Abies lasiocarpa var. arizonica), Douglas-fir (Pseudotstuga menziesii), aspen (Populus 

tremuloides), and alder (Alnus spp.). Several wetland species of shrubs and forbs are found along 

the creek banks. This area is not mapped as a true riparian type, but the alder, sedges (Carex spp.) 

and hemlock-parsley (Conioselinum spp.) are generally considered as obligate (i.e., almost 

exclusively) riparian plants in this area. Although bare ground is common because of human 

disturbance (foot and vehicle traffic), the channel banks themselves are heavily vegetated. Only at 

road crossings are the banks lacking vegetation. There are a number of log grade-control 

structures in the area and one 4.5-foot-high earthen and rock dam with an overflow pipe in it. 

These structures appear to have no effect on the riparian nature of the area, other than storing a 

small amount of water onsite. No fish have been observed during several field visits to the 

riparian area on the Old Columbine tract20.

Turkey Flat Tract

There are no true riparian species in the Turkey Flat tract.

Vegetation in the Turkey Flat tract includes white fir (Abies concolor), Gambel oak (Quercus 

gambelii), Douglas-fir (Pseudotsuga menziesii), ponderosa pine (Pinus ponderosa), southwestern 

white pine (Pinus strobiformis), and New Mexico locust (Robina neomexicana).

Environmental Consequences

Direct and Indirect Effects

Direct effects to water resources may result from consumptive use of a source of supply and/or 

the introduction of pollutants and subsequent degradation of water quality. Contamination of 

water resources can occur by direct discharge of pollutants as point source effluents or by more 

diffuse (non-point) sources, such as erosion and runoff. Effects are measured by estimating how 

much a water resource may be affected relative to its use, such as a potable supply or habitat.

 

20 Reported by Bob Lefevre over a period of several years through 2006.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 47

Figure 9. Stream Channels within the Ash Creek and Jacobson Sub-watersheds on the 

Safford Ranger District.
Chapter 3. Affected Environment and Environmental Consequences

48 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Depletion of a source of supply or alteration of water quality may adversely impact habitat and 

populations of both terrestrial and aquatic biota.

Where applicable, the significance of impacts on recreational use and habitat may be determined 

by the degree to which changes in water quality will affect the status of use designated by, or 

exceed standards established by, a regulatory agency, or the potential for changes in populations 

of special status species (i.e., threatened and endangered) or their habitat.

Water Resources, Old Columbine and Turkey Flat 

No Action. Removal of the residences would return the tracts to natural slopes, and grasses and 

forbs would be expected to return within five years. Until vegetation is established sufficiently to 

stabilize disturbed soils, Best Management Practices (BMPs; FSH 2509.22) would be applied by 

the forest to minimize resource damage (USDA-FS, 1990). The return of vegetative groundcover 

would gradually improve hydrologic function in the area, resulting in decreased peak runoff. 

Water would no longer be consumed by occupants on the tracts, but this would have a very 

minimal affect on downstream yield.

Runoff is unlikely to introduce sufficient quantities of contaminants to the watershed to 

significantly degrade water quality because there are relatively few sources of waterborne 

pollutants on the tracts. Because of increased vegetative groundcover and decreased foot and 

vehicle traffic soil compaction would decrease. This would improve infiltration of precipitation 

and reduce any current effects of the tracts on water quality in the Ash Creek sub-watershed.

Proposed Action. If the proposed action is implemented, water yield and consumption would 

remain the same (see table 7). There would be no change in peak flow or total annual water yield.

Issue Turkey Flat Only. If this alternative is implemented, the effects on water resources at Old 

Columbine would be the same as those described for no action. The effects at Turkey Flat would 

be the same as those described for the proposed action.

Issue Old Columbine Only. If this alternative is implemented, the effects on water resources at 

Old Columbine would be the same as those described for the proposed action. The effects at 

Turkey Flat would be the same as those described for the no action.

Riparian Resources, Old Columbine and Turkey Flat

No action and removal of the residences would allow the natural channel of Ash Creek to return

on the Old Columbine tract, including the terraces associated with it. Roads, trails and other 

disturbed areas would be populated with native grasses and forbs.

The proposed action would have no effect on existing riparian resources at Old Columbine. If 

only Turkey Flat permits are issued, the effects of no action would result at Old Columbine. If 

only Old Columbine permits are issued, there would be no change in existing riparian resources.

Because there are no riparian resources on the Turkey Flat tract, there would be no impacts.

Past, Present, and Foreseeable Actions in the Watershed

Past, present, and foreseeable future projects or actions that have affected or, in the future, may 

affect the Ash Creek or Jacobson Canyon sub-watersheds and the recreation residence tracts 

include the following activities (see table 2): historic timber and other forest product harvests; 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 49

historic heavy grazing; prescribed and naturally occurring fires, including pile burning as part of 

the PEM project; wildland fire suppression, including effects from the Clark Peak fire and the 

Nuttall Complex fire; forest restoration projects, such as the PERP; fuel reduction treatments, 

including the PEM and actions at sites under SUPs; activities at administrative facilities, 

including the reconstruction of Heliograph Lookout; recreation; AGFD activities at Cluff Ranch ; 

and livestock and irrigation uses.

Logging

Historic harvesting of timber and other forest products in the sub-watersheds were conducted 

prior to the development and application of current BMPs listed in FSH 2509.22. Without 

mitigation, they contributed to the growth of dense tree stands within and near the recreation 

residence tracts by inadvertently preparing seedbeds and allowing light to the forest floor. This, in 

turn, has probably decreased the overall water yield from the watersheds (Ffolliott and Thorud, 

1975) and increased soil loss from erosion and sediment delivery to surface waters.

The effects of past logging on water quality are no longer present or have been masked by other 

forest activities. On both the Turkey Flat and Old Columbine tracts, there is no documentation of 

logging effects on water and riparian resources. Water and riparian resource effects from future 

forest product harvests during or following fuel reduction treatments, wildlife habitat projects, 

and forest restoration projects would be minimized by BMPs.

Grazing

Historic heavy livestock grazing throughout the watersheds around the turn of the 19th century 

and through most of the 20th century decreased vegetation cover in the sub-watersheds and 

altered water yield quantity and timing. This resulted in increased soil erosion and sediment 

delivery to surface water. In addition, heavy concentrations of livestock in the area contributed to 

high concentrations of nitrogen and bacteria (E. coli) in surface waters.

Best Management Practices to mitigate grazing effects have since been implemented on Federal 

lands, with a general improvement in sub-watershed conditions. Livestock grazing is documented 

as currently affecting water quantity only in direct consumption, and continued use of BMPs in 

grazing would maintain those conditions. In addition, livestock grazing in the vicinity of the 

recreation residence tracts was eliminated in the 1950s.

Fire and Fuel Treatments

Prescribed and natural fires and wildland fire suppression have affected water and riparian 

resources in the APE since the establishment of the Coronado NF around 1902. Fires have 

resulted in periodic, short-term effects on water quantity and quality. Studies indicate that the 

effects of fires on water resources’ quantity and quality decline dramatically after 10 years 

(Debano et al., 1998). The Graham Complex fire (1989) no longer affects water quantity or water 

quality. Effects on water quantity from the Clark Peak (1996) and Nuttall Complex fires (2004) 

may continue to the present time, however, no documentation of this has been undertaken. The 

Clark Peak wildland fire occurred over 10 years ago and its effects on water quality are not 

considered in this analysis.

Prescribed burning and low-intensity natural fires help restore natural vegetation communities in 

the sub-watersheds, which, in turn, help maintain healthy water quantity and quality conditions. 

Unfortunately, wildland fire suppression has resulted in increased growth of shrubs and shade-
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50 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

tolerant tree species and decreased grasses in the lower elevations and shade-intolerant tree 

species at higher elevations of the forest. This, in turn, has increased the frequency and 

consequences of large, severe fires. There are no reports on the effect of fire on riparian resources 

at Old Columbine.

Fuel treatments and forest restoration have temporarily affected water and riparian resources by 

disturbing the surface, altering timing of flows and allowing for accelerated erosion. The longterm positive effect they have had is the establishment of sustainable plant communities that 

improve natural processes, including natural water yield, water quality, and riparian development. 

Ongoing fuel treatment and forest restoration projects would be accomplished using BMPs, 

thereby minimizing negative effects and promoting positive effects on water quantity, water 

quality, and riparian resources.

Recreation and Special Uses

Forest Service administrative facilities in the sub-watersheds include lookout towers, crew 

quarters, communications equipment and facilities, and the roads or trails to access them. NonForest Service administrative facilities include privately owned communications facilities, 

organization camps, astrophysical observatories, and the roads and trails that access them, all of 

which exist and operate under SUPs. The effects of these facilities on water consumption are 

limited to minor alterations in flow timing and water consumption by facility users. Water rights 

are held by permitted users for 25.452 acre-feet per years (ADWR Water Rights Database).

The Heliograph Lookout project replaced a burned facility; it will not contribute to cumulative 

effects. The proposed facility at Columbine Work Center would be located outside the cumulative 

affects area if it is placed at the existing Columbine Work Center. Regardless, the use of BMPs in 

the construction and maintenance of such facilities would minimize adverse effects on water and 

riparian resources. Administrative facilities have no effect on the riparian resources within the

Old Columbine tract.

Recreation facilities in the sub-watershed, in addition to the recreation residence tracts, comprise 

developed areas, such as campgrounds; undeveloped (dispersed) camping areas; and off-road 

vehicle use. The most common effects of recreation on water quantity are minor alterations of 

flow timing and consumption by visitors (estimated 0.64 acre-feet per year). In addition, off-road 

vehicle use has resulted in the creations of surface channels, which change runoff patterns and 

timing, and causes accelerated erosion on increasingly larger areas. As this activity increases, 

effects on surface water flows and water quality may be seen.

The most common effects of recreation that affect water quality are increased soil erosion and 

inappropriate disposal of wastes. There is no documentation of either causing significant adverse 

impacts to water quality in the cumulative effects area. Effects on riparian areas may include the 

displacement or removal of riparian vegetation and channel alteration. Riparian resources in the 

area have evolved despite the presence of these recreation activities.

Farming does not occur in the upper portion of the sub-watersheds. However, Angle Orchard in 

the Jacobson Canyon sub-watershed uses water for irrigation. There are no other farming projects 

known to be proposed in the sub-watersheds.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 51

Cumulative Effects: Water and Riparian Resources 

No action would return the tracts to more natural conditions; therefore there would be no 

incremental contribution to adverse cumulative effects on water or riparian resources in the subwatersheds.

With the proposed action, existing water and riparian resource conditions would remain the same. 

Therefore, no cumulative effects with other activities would result.

If permits are issued at Turkey Flat only, water and riparian resources at Old Columbine would 

improve, therefore, there would no cumulative impacts. Existing resource conditions at Turkey 

Flat would remain the same.

If permits are issued at Old Columbine only, impacts at Turkey Flat would improve; therefore, 

there would no cumulative impacts. Existing resource conditions at Old Columbine would remain 

the same.

Recreation 

Affected Environment

The Pinaleño Mountains, especially Mt. Graham, provide a wide variety of year-round recreation 

opportunities in ecosystems that range from desert grasslands to spruce forests. Historic records 

of the use of Mt. Graham and the Pinaleño Mountains indicate that they served as a summer 

retreat for Mormon pioneers and other settlers of the communities near the mountain, such as 

Safford. Many of the existing trails and roads were constructed by these pioneers and, during the 

Great Depression, by the U.S. Civilian Conservation Corps.

Arizona Route 366 (Swift Trail), the main road into the mountains, provides access to both the 

Old Columbine and Turkey Flat tracts. Along this 36-mile road, there are nine developed 

campgrounds with a total of 127 campsites, two developed picnic areas, numerous hiking trails 

and trailheads, a lake, a visitor center, and multiple dispersed recreation sites, some of which are 

popular group use areas (including Treasure Park, Upper Arcadia, Twilight, Snow Flat, and Upper 

Hospital Flat).

The Mt. Graham area is considered a destination recreation area. Outdoor recreation activities 

include hiking, camping, experiencing solitude, climbing, scenic driving, hunting, fishing, 

horseback riding, wildlife viewing, visiting high mountain cienegas, and playing in winter snows. 

There is also one organizational camp for children (Arizona Bible Camp) near the Old Columbine 

area. Most recreation areas and the higher elevation trails and dispersed sites are used mainly 

from May through September. Use is typically much higher on weekends and holidays than 

during the week.

Riggs Flat Campground is full almost every weekend and holiday between Memorial Day and the 

end of September (Culbert, 2006). Most of the other high elevation developed campgrounds 

receive heavy use (i.e., are over half full) on weekends during this season. The exceptions are 

Clark Peak corrals (a 3-unit campground with horse corrals beyond the end of Swift Trail, which 

is rarely at capacity) and Round-the-Mountain Campground (a low elevation campground, which 

is about half full on weekends and holidays year-round). Most developed sites are lightly used on 

weekdays.
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52 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Like most developed sites in the Pinaleños, dispersed sites are primarily used only during the 

summer season (Memorial Day through September) and are lightly used on weekdays. Dispersed 

group sites are typically full 5 to 7 weekends per year, and smaller dispersed sites are always full 

during the 3 summer holiday weekends. Occasionally there are no dispersed sites of any type 

available on weekends.

Field personnel estimate that 65 to 75 percent of visitors stay one or more nights in the mountains 

(Culbert, 2006). Most stay for the weekend, but many stay up to 2 weeks. Riggs Lake gets a 

moderate amount of day use (picnicking and fishing). Winter use in the Pinaleños is relatively 

light, but there is picnicking at the lower elevation sites and snow play in a few areas at higher 

elevations, especially on weekends.

In 2005, the Coronado NF collected a total of $31,700 at seven developed campgrounds and five

group use sites in the Pinaleños (Warren, 2006). Assuming an average of 3.5 people per campsite 

and 50 people per group site, the estimated number of visitors at these sites during 2005 was 

approximately 13,650 people, mostly from May through September.

Recreation Opportunity Spectrum Settings

The Recreation Opportunity Spectrum (ROS) system (USDA-FS, 1986a) is a framework that the 

Forest Service uses to describe recreation settings which range in character from easy access—

highly developed to remote and natural. The majority of the Swift Trail corridor is mapped as 

Roaded Natural, with nodes of Urban (Heliograph Electronic Site and Mt. Graham Astrophysical 

Complex) and Rural (campgrounds) and areas of Semi-primitive Non-motorized and Primitive

along the edges (a Wilderness Study Area). Definitions of the different settings can be found in 

the ROS Book (USDA-FS, 1986a) and the Recreation Opportunity Spectrum on the Coronado 

National Forest (USDA-FS, 2000).

The Old Columbine and Turkey Flat tracts are designated as Rural recreational settings.

Recreational Use Trends

Recreational use is steadily increasing in the Pinaleño Mountains. Field personnel report 

increased use each year, and camping fees collected by the Forest Service reflect this trend. In 

fiscal year (FY) 1993, $17,295 was collected for this area of the Coronado NF. In FY 2003 (10 

years later) collected fees increased to $26,906. And, in 2005 (just 2 years later), $31,700 was 

collected (Hennings, 2006).

Trail use continues to be relatively light, but field personnel report that five years ago, trailheads 

typically had one car parked at them on most weekends; more recently, there are three to four cars 

parked at each.

The Swift Trail is maintained by Arizona Department of Transportation (ADOT). ADOT records 

vehicle travel at specific points along the 27.4 mile route between the State prison located at the 

base of the mountain and the Columbine area at a higher elevation. Average daily traffic counts 

from years 2003, 2004, and 2005 show 60, 90, and 100 vehicles per day respectively, indicating a 

steady increase in traffic. A high proportion of these vehicles are assumed to be transporting 

recreational visitors.

The Pinaleño Mountains have traditionally provided recreation opportunities for local area 

residents. However, the number of visitors from the metropolitan areas of Tucson (130 miles) and 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 53

Phoenix (245 miles) has increased with the growth of these areas, and increases in visitors from 

Albuquerque have been noted. As these urban areas continue to grow, more visitors to the 

Pinaleños are expected.

The population of Safford has been stable; however, upon the recent opening of a new, large 

copper mine in the area, about 700 new jobs were created. A minimal influx of new residents was 

expected. These new residents are potential recreational users of the Pinaleños.

Recreation Residence Tracts

The history of the Old Columbine tract is not well documented, but Forest Service files indicate 

that permits for the current buildings were first issued between 1923 and 1955; most of the 

structures were modified during the last half of the twentieth century. There are currently 14 

recreation residences located in the Columbine tract that are occupied under the terms and

conditions of SUPs. Along with the residences, the permits allow for storage sheds, outdoor 

toilets, and miscellaneous other minor structures. The residence tract sits on 25 acres of NFS land, 

and all the lots in the tract are currently in use.

The first recreation residences at the Turkey Flat tract were permitted in 1929. The Turkey Flat 

tract has 74 permitted recreation residences, and their permits allow for storage sheds, outdoor 

toilets, and miscellaneous other minor structures. This tract sits on 52 acres of NFS land.

Occupancy of the residences varies widely, with some families occupying the residences most of 

the summer and occasional weekends at other times of the year. Many residences are visited only 

on key weekends during the year. Forest Service special uses managers estimate recreation 

residences in Old Columbine tract are used 50 to 60 days per year, and recreation residences in 

Turkey Flat tract are used approximately 30 to 40 days per year.

Environmental Consequences

Direct and Indirect Effects

No Action

If no action is taken, upon the expiration of a 10-year closeout permit, all recreation residences at 

Turkey Flat and Old Columbine would be subject to removal at the expense of the permit holders. 

With the removal of improvements, the category of recreation would change from developed 

recreation to dispersed recreation.

As dispersed recreation sites, these areas would be available to visitors who prefer a nondeveloped experience or who cannot access developed sites because of overcrowding, which 

occurs on several weekends each summer. Access to the tracts would change from motorized to 

non-motorized because the access roads to the tracts would be gated after residences are removed.

From the perspective of the Western Apache, dispersed, non-motorized recreation is preferred to 

maintain and preserve Western Apache TCP.

Those who formerly held SUPs for the residences would be expected to continue to visit the area 

for recreation. Their presence may slightly increase visitor use at developed and dispersed sites, if 

they do not return to either of these tracts to picnic or camp.
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54 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

During the period when facilities are being removed, there would be increased noise and general 

disturbance caused by removal of structural improvements and heavy hauling. This would 

temporarily detract from the quality of the nearby recreation experience for visitors for 

approximately 1 to 3 months. There would be no long-term effects on recreation caused by the 

activities of facility removal.

The ROS setting for both tracts would change from Rural to Roaded Natural. 

Proposed Action

There would be no effects on recreational use of either tract if the proposed action is 

implemented.

Issue Turkey Flat Only

If this alternative is implemented, new SUPs for recreation residences in Turkey Flat would be 

issued, and their occupancy and use would be allowed to continue. There would be no effects on 

recreational use of this tract.

Impacts at Old Columbine would be the same as those reported in chapter 3, recreation, 

environmental consequences section, for no action. Upon removal of the residences, the ROS 

setting for Old Columbine would change from Rural to Roaded Natural.

Issue Old Columbine Only

If this alternative is implemented, new SUPs for recreation residences in Old Columbine would 

be issued, and their occupancy and use would be allowed to continue. There would be no effects 

on recreational use of this tract.

Impacts at Turkey Flat would be the same as those reported in chapter 3, recreation, 

environmental consequences section, for no action. Upon removal of the residences, the ROS 

setting for Turkey Flat would change from Rural to Roaded Natural.

Cumulative Effects: Recreation

Past, present, and reasonably foreseeable future actions that affect recreational use and ROS 

settings in the Pinaleño Mountains include construction of roads, trails, developed recreation 

sites, and administrative sites; wildland fires; fuel treatment projects, including the PEM and 

ongoing PERP; special-use permitted activities, including recreation residences and the Arizona 

Bible Camp, as well as operation of the Mt. Graham astrophysical complex.

Many of these actions have a positive effect on recreation by providing desirable access routes 

and recreational facilities. Wildland fire and fuels treatments often change the recreation setting, 

but they generally improve forest health and benefit recreational use in the long term. The Mt. 

Graham astrophysical complex has had an indirect negative effect on recreational use of the area, 

because approval of its special-use permit was contingent upon the establishment of the Mt. 

Graham Red Squirrel Refugium, an area where recreation use is severely restricted.

Removal of the recreation residences would change the nature of use from developed recreation 

to dispersed recreation. When added to the effects of past, present, and foreseeable future actions, 

the loss of two developed recreation tracts would have a very minimal impact on the overall 

recreation program in the Pinaleño Mountains. Both developed and dispersed recreation 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 55

opportunities would be available at other developed campgrounds, day use areas, multiple 

dispersed sites, and the organization camp; however, occasionally overcrowding may be 

experienced.

Because the proposed action would not change the status quo of the recreational use of the area, 

no cumulative effects would result.

Visual and Aesthetic Resources 

Direction on how to analyze the potential impacts of a proposed action on the visual resources of 

a national forest is given its forest plan and other Forest Service policy. The forest plan standard 

for visual resource management is based on Visual Quality Objective (VQO) maps created under 

the 1974 Visual Resource Management System (VRMS). Since the mid-1990s, national forests 

have been directed to use the Scenery Management System (SMS) (Memoranda from Forest 

Service Washington Office, Code 2380: Reynolds, August 22, 1994; McDougle, March 10, 1997; 

and Furnish, June 11, 2001). SMS mapping of scenic classes, which show the relative importance 

of scenic resources on the Coronado NF, was completed in 2001.

Although on-the-ground maps for the two systems are quite different, the components of both 

systems are similar, and analysis (affected environment, environmental consequences, and 

cumulative effects) for the proposed project yields largely the same results. To be consistent with 

the forest plan, the analysis that follows evaluates impacts using VQOs.

Current direction in the forest plan for Visual Resource Management (USDA-FS, 1986, p. 28) 

includes:

 “Maintain and protect the visual integrity of the landscape,” and

 “Rehabilitate or enhance the existing visual quality in the process of accomplishing 

other resource management practices.”

Both recreation residence tracts lie in MAs 3A and 3B, for which the forest plan guidelines direct 

that Visual Quality Objectives will be met (USDA-FS, 1986, p. 59). Both recreation residence 

tracts are in areas with the VQO of Retention21.

Visual Quality Objectives are based on two components:

 Variety Class: A measure of the visual variety or diversity of landscape character. 

The three variety classes are A (distinctive), B (common), and C (minimal).

 Sensitivity Levels and Distance Zones: Sensitivity levels are a measure of the 

viewer interest in scenic qualities of a landscape. The three levels are 1 (highest), 2 

(average), and 3 (lowest). Distance zones include foreground (up to 1/2 mile), middle

ground (1/2 mile to 5 miles), and background (over 5 miles).

There are no maps of sensitivity levels for the Coronado NF. However, a review of the VQO 

maps indicates that the Swift Trail and the Bible Camp Road (FR 508) were identified as 

Sensitivity Level 1 areas. A project level review of sensitivity levels confirms that these 

designations are appropriate.

 

21 Retention: A VQO which requires that human activities are not evident to the casual forest 

visitor.
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56 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Affected Environment

Visual resources are the natural and human-created features that give a particular landscape its 

character and aesthetic quality. Landscape character is determined by the visual elements of form, 

line, color, and texture. All four elements are present in every landscape; however, they exert 

varying degrees of influence. The region of influence for visual resources includes the geographic 

area from which the recreation residences may be seen.

Area of Potential Effect

Although the project areas are quite well-defined, the boundaries for visual resources are often 

difficult to draw. As people travel through a landscape, they experience a sequence of viewsheds. 

To capture the potential impacts to visual quality of the broader area surrounding the tracts, the 

following analysis considers elements of visual quality in the landscapes beyond each of the 

recreation residence tracts, including the Swift Trail Highway (AZ 366) corridor and the highelevation conifer forests of the Pinaleño Mountains, where most public use occurs and scenery is 

highly valued.

Within the Pinaleño Mountains are a number of developed recreation sites, including public 

campgrounds and picnic areas, an organization camp, trailheads and trails, and the Columbine 

Administrative Area (which includes a visitor center). Additionally, there are many dispersed 

recreation areas with no facilities other than roads, small dirt parking areas, and stone fire rings. 

At present, the greatest detractions to visual quality are the Heliograph electronic site and 

structures that comprise the Mt. Graham astrophysical complex, one of which is a 167-foot tall

boxy white structure that is highly visible from some areas.

Old Columbine Tract

The landscape character in the Old Columbine area is that of a mixed-conifer forest with pockets 

of rocky mountainside topography, grassy meadows, and occasional stands of aspen trees. The 

area is accessed by the Swift Trail (AZ 366), which has been designated a Scenic Parkway by the 

State of Arizona because of its outstanding scenery.

Visual quality in the Old Columbine area is generally good, despite the presence of many dead 

and diseased trees from insect infestation, several thickets of dense vegetation, and some nearby 

burned areas. Most of the recreation residences in the Old Columbine area are generally wellscreened from roads and scenic viewpoints, and other structures (public recreation areas, 

Columbine, etc.) are in character with the setting.

The Old Columbine area is designated as variety class A, distinctive, based on the distinctive 

conifer forest and landform of the areas. The existing VQO for this area is Retention.

Turkey Flat Tract

The landscape character in the Turkey Flat area is that of a ponderosa pine forest with pockets of 

rocky mountainside topography and occasional stands of aspen trees. The area is also accessed by 

the Swift Trail Highway (AZ 366).

Visual quality in the Turkey Flat area is generally good, despite the presence of many dead and 

diseased trees from insect infestation, several thickets of dense vegetation, and nearby burned 

areas. About 20 recreation residences in the Turkey Flat area can be seen from the Swift Trail; the 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 57

others are well-screened from roads and scenic viewpoints, and other developments (public 

recreation areas, Columbine, etc.) are in character with the setting.

The Turkey Flat area is variety class A, distinctive, because of the distinctive conifer forests and 

landform of these areas. The existing Visual Quality Objective for the Turkey Flat area is 

Retention.

Environmental Consequences

Direct and Indirect Effects 

No Action

During the 10 years of continued use until removal, there would be no new direct or indirect 

impacts from the recreation residences.

Temporary impacts on visual quality would result from removal of structural improvements, 

including disturbance of soils, piling of debris, and operation of heavy equipment, which has the 

potential to damage vegetation. Visual quality impacts from removal of structural improvements

would be observable for at least a few months, and effects following removal of improvements 

would likely be evident for 1 to 2 years. Eventually, the landscape would return to a natural forest 

(with the exception of roads and dispersed recreational use), and the tract would continue to meet 

the VQO of Retention.

All Action Alternatives

Visitors come to the Coronado NF for its natural appearing landscapes. To protect visual quality, 

it is important that, whenever possible, human-made structures on the Coronado NF (including 

recreation residences) harmonize with the line, form, colors, and textures of the surrounding 

landscape.

The following excerpt reflects guidance for management of the recreation residence tracts during 

the early 1980s, when VQOs for the Coronado were mapped (USDA-FS, 2006):

“On the Coronado National Forest, as with all other national forests in the region, the visual 

inventory and objective setting came after the summer home residences had been in place 

for many years. Since the summer homes are a recognized part of the Forest Service 

recreation program, it was assumed they would be there for some time.

In the summer home tracts, it was assumed that each owner would first meet the requirements 

of their permit (no additions to the buildings, no accessory buildings, no trash in the 

immediate area, etc.). It was also assumed that it would be the responsibility of each 

district ranger to manage the area with the Visual Quality Objective (VQO) in mind. This 

means using the principles of the VRMS to mitigate visual impacts of any nonconforming structures, seeking to meet the VQO over time (usually retention or partial 

retention). The VQO of retention means that the structure cannot be visually evident. It 

must borrow from the forest visual elements that surround it – in its form, line, color, and 

texture. In general, this means that in forested areas the roof and exterior wall materials 

must be natural appearing and painted in dark muted forest colors with no shiny materials 

or highly reflective surfaces, and the area around the home is the natural forest. Many 

existing homes at the time could meet this objective. The idea was to have the summer 
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58 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

homes that did not conform to the objective and were visually evident to reduce their 

impact over time. This means that when doing routine maintenance such as painting and 

roofing, owners would choose muted forest colors and dull textures, therefore becoming 

less evident.22”

Because the proposed action would simply be a continuation of an existing use, no new direct or 

indirect impacts would result from its implementation. Likewise, if permits are issued for one 

tract and not the other (alternatives 3 and 4), impacts would be negligible, while the impacts of 

removal at either tract would be the same as those identified for the no action alternative.

If the proposed action is implemented, some recreation residences and associated structures may 

need changes over time to make them better blend with the surrounding landscape, and in some 

locations, there are areas with bare ground from vehicle and pedestrian use that needs to be 

corrected. These maintenance items would be addressed by the Coronado NF in individual SUP 

operation and maintenance plans.

Cumulative Effects: Visual and Aesthetic Resources

Cumulative effects are considered for the entire Pinaleño Ecosystem Management Area, since the 

entire mountain range is visible from many locations.

Past, present, and reasonably foreseeable future actions considered in the analysis of cumulative 

effects on visual quality include the following (see table 2): road maintenance; historic timber 

sales and livestock grazing; presence and operation of the Mt. Graham astrophysical complex and 

Heliograph electronic site; developed recreation site use; administrative site use (Columbine, 

Heliograph lookout, etc.), dispersed recreation use; fuel reduction treatments around special-usepermitted facilities; PEM (a forest thinning and fuel reduction project); new permit for the 

Arizona Bible Camp; microwave tower installation at the Mt. Graham International Observatory; 

and PERP (a project that includes tree removal and prescribed burning to reduce fire hazards).

No Action 

The effects of many of the projects identified as contributing to cumulative visual quality on the 

Coronado NF would continue through the 10-year closeout period applicable to the recreation 

residence tracts. Some of these projects have negatively impacted visual quality for many years, 

most notably, the astrophysical complex telescopes that contrast sharply with the landscape. 

Others (such as PEM and PERP) will provide long-term benefits to visual quality by reducing the 

risk of catastrophic wildland fire.

The Arizona Bible Camp is not visible from public viewing locations, and like the recreation 

residences, existed prior to establishment of VQOs. No new impacts are expected from a new 

permit being issued to the Camp. Visual impacts from developed recreation and administrative 

sites, dispersed uses, past timber cutting and livestock grazing, fuel treatments around special-use 

permitted facilities, and from the microwave dish, are and would continue to be, minimal. Roads 

serve as viewing platforms and provide public access into the forest and are generally considered 

visually neutral elements.

 

22 Source: Memorandum to File, Sarah Davis, Forest Landscape Architect, Coronado National 

Forest, May 2006.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 59

The visual quality impacts of no action reported in chapter 3 (visual and aesthetic, environmental 

consequences section) would be negligible. Therefore, when considered incrementally with the 

effects of past, present, and future actions in the area, cumulative effects would be discountable in 

the short term, and positive in the long term, as the site restores to natural forest conditions. The 

VQO of Retention would not change.

All Action Alternatives

Because there would be no new direct or indirect effects from continuation of existing recreation 

residence permits, there would be no cumulative effects on the visual resources.

Wild and Scenic Rivers

The eligibility of a river for the National Wild and Scenic Rivers System (National System) is 

determined by applying the criteria in sections 1(b) and 2(b) of the Wild and Scenic Rivers Act of 

October 2, 1968, (P.L. 90-542, as amended (95-625 1978); (16 U.S.C. 1271-1287, et seq.). 

Eligibility is further described in the United States Department of Agriculture and United States 

Department of the Interior Guidelines for Eligibility, Classification and Management of River 

Areas, dated September 7, 1982 (USDA-USDI Guidelines), and found in the FSH 1909.12, 90. 

To be eligible for inclusion, a river must be free-flowing and, with its adjacent land area, possess 

one or more “outstandingly remarkable” values. The determination of eligibility is an assessment 

that does not require a decision or approval document, although the results of this inventory need 

to be documented as a part of the plan document or plan set of documents.

To the extent the Forest Service is authorized by statute, a responsible official may authorize sitespecific projects and activities on NFS lands within river corridors eligible or suitable for 

National Wild and Scenic River designation only where the project and activities are consistent 

with all of the following (FSH 1909.12 Ch 80; Section 82.5):

 The free-flowing character of the identified river is not modified by the construction 

or development of stream impoundments, diversions, or other water resources 

projects.

 Outstandingly Remarkable Values (ORVs) of the identified river area are protected.

 For all legislatively mandated study rivers, management and development of the 

identified river and its corridor is not modified to the degree that eligibility would be 

compromised or the classification changed to a less restrictive class (such as from 

wild to scenic or scenic to recreational).

 For all Forest Service-identified study rivers, however, they may be managed at the 

recommended rather than inventoried classification when the suitability study and 

recommendation is completed.

Affected Environment

Old Columbine Tract

A 6.2-mile segment of Ash Creek from its headwaters to the diversion for Cluff Ranch was 

determined to be eligible for the National Wild and Scenic Rivers (WSR) System (USDA-FS, 

1993). Ash Creek has historically been a perennial creek with intermittent reaches. The Ash 

Creek drainage has a diversity of vegetation, dropping in elevation from the spruce-fir type to 
Chapter 3. Affected Environment and Environmental Consequences

60 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

desert scrub. The creek descends through small meadows, Engelmann spruce and Douglas-fir, 

alder, oak, sycamore, box-elder, and Arizona walnut. Steep slopes, deep canyons, and waterfalls 

provide outstanding scenic qualities. Expansive views of the Gila Valley may be seen from the 

mid to upper elevations of the creek. Historic features such as remnants of an old sawmill and 

flume operation from the early 1900s are evidence of early Anglo-American occupancy of the 

mountain. This segment of Ash Creek has a potential classification as recreational (FSH 1909.12, 

Chap. 80, Sec. 82.3) and reflects outstandingly remarkable values (ORVs) of scenic, historic, and 

ecological (FSH 1909.12, Chap. 80, Section 82.14).

Several of the recreation residences in the Old Columbine tract are within 1/4 mile of the 

headwaters of Ash Creek. However, all residences in Old Columbine were built at their present 

sites several decades prior to the 1993 determination of eligibility.

Turkey Flat Tract

The Turkey Flat recreation residences are miles away from any of the potential streams and rivers 

on the Coronado NF eligible for National Wild and Scenic River designation. Therefore, Turkey 

Flat will not be discussed further with regard to potential impacts on Wild and Scenic Rivers.

Environmental Consequences

Direct and Indirect Effects

None of the alternatives would affect the eligibility of Ash Creek for the inclusion into the 

National Wild and Scenic Rivers System because its free-flowing condition, ORVs, and 

classification would not be adversely impacted. The discussion below explains the reasons for 

this determination.

Free-Flowing Condition

With implementation of alternative 1, the removal of recreation residences would not involve 

impoundment, diversion, straightening, rip-rapping, or other modification of the waterway within 

the eligible portion of the river and thus would have no effect on the free-flowing condition of 

Ash Creek.

For alternative 2, the recreation residences would remain in place; therefore, there would be no 

effect on the free-flowing condition of Ash Creek.

Removal of the recreation residences at Old Columbine in alternative 3 would have the same 

effect as alternative 1.

Under alternative 4, the recreation residences at Old Columbine would remain in place; therefore, 

this alternative would not affect the free-flowing condition of Ash Creek.

Outstandingly Remarkable Values (Scenic, Historic, and Ecological)

With implementation of alternative 1, at the end of a 10-year closeout permit period, removal of 

the Old Columbine recreation residences would have a minor and temporary effect on the scenic 

ORV at the upper end of the 6.2-mile segment during the period when structures are being 

dismantled and scrap materials are staged onsite.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 61

The historic ORV for Ash Creek was assigned because of the presence of the Mt. Graham sawmill 

and an associated flume for transporting logging products to the Gila Valley ─ vestiges of early 

1900s Anglo-American use of the mountain. The removal of the Old Columbine recreation 

residences would have no effect on the Mt. Graham sawmill and flume. Recreation residences 

were not mentioned in the 1993 eligibility determination as contributing to the historic ORV, even 

though some of them were built as early as the 1920s. Likewise, the Western Apache Dził Nchaa 

Si’an TCP was not identified as contributing to the historic ORV, even though it encompasses the 

entire watershed within the forest boundary. The TCP was determined to be eligible for the 

National Register of Historic Places in 2001 (Spoerl 2001) and could be identified as contributing 

to the historic ORV of Ash Creek in a future revision of the forest plan. Recreation residences 

were not mentioned in the 1993 eligibility determination as contributing to the historic ORV, even 

though some of them were built as early as the 1920s. The removal of the Old Columbine 

recreation residences would have no effect on these historic resources.

If heavy equipment were used in the removal of the recreation residences, there would be soil 

disturbance and the potential for short-term increased soil erosion and sedimentation of Ash 

Creek. However, most of the erosion would be minimized by the requirement that BMPs be 

implemented during removal (FSH 2509.22). There would be no changes in long-term

productivity or irreversible or irretrievable commitments of resources. While there are no water 

quality criteria prescribed by the National Wild and Scenic Rivers Act, there could be a 

temporary, minor, indirect effect on aquatic species in Ash Creek (ecological ORV) because of 

slightly increased turbidity levels.

Implementing alternative 2 would not affect the ORVs of Ash Creek because the Old Columbine 

recreation residences were in place at the time of the 1993 determination of eligibility and 

because this alternative does not change anything on the ground.

Alternative 3, removal of the Old Columbine recreation residences, would have the same effects 

as alternative 1. If alternative 4 is implemented, the recreation residences at Old Columbine 

would remain in place; therefore, the effects would be the same as alternative 2.

Stream Classification

With implementation of alternative 1, the removal of the recreation residences would have no 

adverse effect on the classification (recreational) of the 6.2-mile segment of Ash Creek eligible 

for National Wild and Scenic River designation. If the residences and roads were removed and the 

area returned to a natural appearance, the future classification of this segment may qualify as 

either scenic or wild.

With alternative 2, there would be no on-the-ground changes; therefore, the recreational 

classification would not be affected.

Alternative 3 would have the same effects as alternative 1.

Alternative 4 would have the same effects as alternative 2.

Cumulative Effects: Wild and Scenic Rivers

There would be no cumulative effects on the section of Ash Creek eligible for National Wild and 

Scenic River designation because there are no direct or indirect effects from any of the 

alternatives.
Chapter 3. Affected Environment and Environmental Consequences

62 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Heritage Resources

Regulatory Framework

Historic properties are those that are eligible for or already listed on the National Register of 

Historic Places. Section 106 of National Historic Preservation Act (NHPA) outlines the process 

that Federal agencies follow to assess potential effects on historic properties when an undertaking 

is proposed. The process is codified in 36 CFR Section 800. Specific direction applicable to

Forest Service, Southwestern Region, compliance with 36 CFR 800 is contained in the First 

Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities 

Among New Mexico Historic Preservation Officer and Arizona State Historic Preservation 

Officer and Texas State Historic Preservation Officer and Oklahoma State Historic Preservation 

Officer and the Advisory Council On Historic Preservation and United States Department Of 

Agriculture Forest Service, Southwestern Region (USDA-FS, 2003).

Other laws, regulations, and Forest Service policies also apply to the inventory, protection, 

restoration, and interpretation of heritage resources. These include the National Environmental 

Policy Act, National Forest Management Act, and the Archeological Resources Protection Act. 

Native Indian Nations’ concerns are considered in this section, because the protection of 

American Indian historic properties is linked to the preservation of their heritage. The federal 

government’s responsibilities to consult on a government-to-government basis with American 

Indian tribes and nations is established in the U.S. Constitution, and further mandates clarifying 

the Forest Service responsibilities to Indian tribes and nations are contained in the Native 

American Graves Protection and Repatriation Act, the American Indian Religious Freedom Act, 

the Religious Freedom Restoration Act, and Executive Orders 13007 and 13175.

Affected Environment

The history of human occupation of the Pinaleño Mountains began long before European entry 

into the region. Settlements at the base of the mountains and shrines on the peaks date back at 

least a thousand years, and the mountains are important in the history and traditions of the Four 

Southern Tribes (Tohono O’odham Nation, Ak-Chin Indian Community, Gila River Indian 

Community, and Salt River Pima Maricopa Indian Community), the Hopi Tribe, and the Pueblo 

of Zuni.

The Pinaleño Mountains are also the ancestral and contemporary homeland of the Western 

Apache, who refer to Mt. Graham as Dził Nchaa Si’an. The Apaches resisted Euro-American

encroachment, subjugation and colonization efforts until the second half of the 19th century. The 

Treaty of Guadalupe-Hidalgo was signed in 1848, ending the U.S. war with Mexico and bringing 

California, New Mexico and Arizona north of the Gila River under U.S. control. In subsequent

decades, the Western Apache were forced from their homelands because of federal Indian policy 

and governmental actions. However, Apache people still claim powerful ties to the Pinaleño 

Mountain range and surrounding areas, and Dził Nchaa Si’an has outstanding significance in 

Western Apache spiritual beliefs and practices (Laluk 2008). The mountain is associated with 

Western Apache oral history and plays a role in stories, songs and myths that reflect ties to it, both 

in historic and contemporary traditional cultural activities (Spoerl 2001, 2002a, 2002b).

In 2002, in consultation with the Western Apache tribes, the Arizona State Historic Preservation 

Officer, and the Keeper of the National Register, the Forest Service determined that the entire 

area of the Pinaleño Mountains (Mt. Graham/Dził Nchaa Si’an) within Forest Service boundaries 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 63

(over 198,000 acres) is eligible for listing on the National Register of Historic Places as a Western 

Apache Traditional Cultural Property (TCP) (Spoerl 2002a, 2002b). Dził Nchaa Si’an was 

determined to have sufficient integrity to be eligible for listing despite the existence of the 

recreation residences and other developments on the mountain. However, to the Western Apache, 

modern developments, especially the Mount Graham International Observatory, have had severe 

detrimental effects to their religion and culture.

The name “Mt. Graham” was first applied to the Pinaleños in 1846 when the Army of the West 

under General Stephen Watts Kearny followed the Gila Valley on its way west to California. The 

first documented Euro-American visit to the top of the Pinaleños occurred in 1871, when a survey 

party under George M. Wheeler left a stone monument on the summit (Gillespie 2000). In 1872, 

President U.S. Grant created by Executive Order “the San Carlos Division of the White Mountain 

Reservation.” This reservation included lands within 15 miles of the Gila River from the New 

Mexico boundary to the San Pedro River, and as such reserved the northern part of the Pinaleño 

Mountains, including both Turkey Flat and Columbine. This part of the reservation was returned 

to public domain by executive order later in the 1870s. In 1873, Fort Grant was relocated from 

the San Pedro Valley to its present location south of the Pinaleño Mountains, and much of the 

southern flank of the mountains was designated a military reservation.

Commercial logging of the range began in the last quarter of the nineteenth century, with the 

establishment of settlements in the Gila Valley. Sawmills were constructed in accessible canyons 

on the north side of the range, and the Army cut timber in the Fort Grant vicinity following its 

establishment in 1873. A military hospital was built at Hospital Flat and used during the summer 

months. In 1889 through 1890, the Army established a heliograph signaling station on Heliograph

Peak. However, military use of the range was in decline after 1880, and ceased when Fort Grant 

was abandoned in 1895 (Spoerl 2001).

Residents of Pima, Thatcher, and Safford have spent summers on Mt. Graham since the late 

1880s (Spoerl 1988). Riggs Flat became the headquarters for summer cattle grazing in the early 

1900s, while Chesley Flat was used for growing potatoes. In 1902, the increasing use of the 

mountains was regulated through establishment of the Mt. Graham Forest Reserve, with the 

objective of protecting the water supply and timber reserves. By that time, cabins were already 

present at Old Columbine (King 1915). The land became part of the Crook National Forest in 

1908, and in 1953, it was transferred to the Coronado National Forest (Spoerl 2001).

Both the Old Columbine and the Turkey Flat tracts were established in the 1920s, upon the Forest 

Service’s receipt of applications for summer residences (Angle 2006). The current recreation 

residences at Columbine were built between 1923 and 1956, although most have been modified 

within the last 50 years. Weech et al. (2003:92) note that Turkey Flat was first developed by 

William Deal and Joe Bassett, who built a log cabin there as part of a plan to grow potatoes. Most

of the recreation residences at Turkey Flat were built after the Swift Trail (Highway 366)

improved access to the area. Turkey Flat cabins were first constructed between 1929 and 1966, 

but as at Columbine, most of them have been remodeled or expanded within the last 50 years.

In 2006, in consultation with the Arizona State Historic Preservation Officer (SHPO), the Forest 

Service evaluated the recreation residences for eligibility for listing on the National Register of 

Historic Places (Farrell 2006, 2006a; Farrell et al., 2006). Twenty-one of the residences (five of 

the 14 residences at Old Columbine and 16 of the 74 residences at Turkey Flat) are over 50 years 

old and have been only minimally modified since their original construction. However, none of 
Chapter 3. Affected Environment and Environmental Consequences

64 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

the 88 recreation residences was determined to meet National Register criteria as an individual 

property. In addition, because most of the residences on each tract lack sufficient age and integrity 

to form a National Register “historic district”, none of the cabins was determined to be eligible as

a contributing element of such a district. Therefore, none of the residences on either tract is 

considered a historic property that would require additional consideration under the provisions of 

the National Historic Preservation Act (Farrell 2006a). The Arizona State Historic Preservation 

Officer concurred with this determination on September 21, 2006 (see appendix B).

In March 2006, the forest supervisor wrote to 12 tribes having traditional ties to the land now 

administered by the Coronado to advise them of the proposed residence permitting action and 

invite comments on the scope of this EIS analysis. One reply was received; it was from the White 

Mountain Apache Tribe. The Tribal Chairman at that point in time, Dallas Massey, Sr., stated that 

the continued existence of the recreation residences in itself was an adverse effect on the Dził 

Nchaa Si’an TCP (Massey 2006). This effect is discussed below.

Environmental Consequences

Direct and Indirect Effects

No Action

No action would have “No Adverse Effect” on historic properties, per 36 CFR 800.5(b). The 

continued existence of the recreation residences for a 10-year closeout period, after which the 

structures would be removed, would not alter the characteristics that make the mountain eligible 

for the National Register of Historic Places as a TCP for the Western Apache. According to 

former Chairman Massey (2006), the Western Apache would prefer that the residences be 

removed from Dził Nchaa Si’an, because modern developments such as these impinge upon the 

spiritual values of the TCP.

The negative effects of the residences expressed by former Chairman Massey do not change the 

qualities of the mountain that make Dził Nchaa Si’an eligible for listing on the National Register 

of Historic Places. Nevertheless, the Forest Service recognizes the Western Apache concerns and 

acknowledges them throughout this EIS.

Action Alternatives

All three of the action alternatives would allow the forest to issue SUPs for some or all of the 

recreation residences, so that they could remain for at least 20 years. No expansion in the 

recreation residences, nor any changes in recreation residence use, is proposed.

Massey (2006) expressed the perspective of the White Mountain Apache Tribe that the continued 

existence of the recreation residences contributes to two effects on Dził Nchaa Si’an. First, 

residential use by individuals, families, and guests, who may not understand or respect the 

mountains as sacred sites and historic properties, fosters and facilitates unwarranted damage and 

desecration to the sacred mountain. Second, the residences are likely to continue to have undue 

and inappropriate effects on land and fire management, because of the Forest Service's historic 

response to fires (i.e., an emphasis on suppression) are based on the protection of private property 

rather than on the restoration of ecosystem function or the protection and expansion of 

endangered species habitat.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 65

The negative effects cited by Massey regarding the continued presence of the residences do not 

change the qualities of the mountain that make Dził Nchaa Si’an eligible for listing on the 

National Register of Historic Places. The residences were present before the TCP was determined 

eligible for the National Register in 2002. Consultation with the Arizona State Historic 

Preservation Officer confirmed that each of the action alternatives (alternatives 2, 3 and 4) would 

have “No Adverse Effect” per 36 CFR 800.5(b) on the Dził Nchaa Si’an TCP (Farrell 2006,

2006b).

In addition, other laws and executive orders require the Forest Service to consider the effect of 

the proposed project on the TCP, Dził Nchaa Si’an. The American Indian Religious Freedom Act 

(Public Law 95-341) recognizes that the religious practices of American Indians are an integral 

part of their cultures, tradition and heritage, such practices forming the basis of Indian identity 

and value systems. The Religious Freedom Restoration Act prohibits the government from 

imposing a “substantial burden” on the free exercise of religion. Recent court decisions23 suggest

that to constitute a “substantial burden,” a government action must coerce someone to act

contrary to their religious beliefs under the threat of sanctions, or condition a governmental 

benefit upon conduct that would violate their religious beliefs. Under this definition, the existence 

of the recreation residences would not meet the criteria for substantial burden.

The most relevant direction is Executive Order 13007, Indian Sacred Sites, which directs Federal 

land management agencies, to the extent permitted by law and not clearly inconsistent with 

essential agency functions, to accommodate access to and use of Indian sacred sites, and to avoid 

affecting the physical integrity of such sites wherever possible (FSM 1563.01e5). Sections 3 and 

4 of this Executive Order appear to limit its applicability and authority:

Section 3. Nothing in this order shall be construed to require a taking of vested property 

interests. Nor shall this order be construed to impair enforceable rights to use of Federal 

lands that have been granted to third parties through final agency action. For purposes of 

this order, "agency action" has the same meaning as in the Administrative Procedures Act

(5 U.S.C. 551[13]).

Section 4. This order is intended only to improve the internal management of the executive 

branch and is not intended to, nor does it, create any right, benefit, or trust responsibility, 

substantive or procedural, enforceable at law or equity by any party.

Nevertheless, there are ways in which the Forest Service can reduce the effects of the recreation 

residences on the Western Apache TCP, within existing law and not inconsistent with essential 

agency functions. To this end, the Forest Service consulted with the San Carlos Apache Tribe and 

the White Mountain Apache Tribe to develop mitigation measures to minimize the ongoing 

effects of recreation residences on the traditional cultural, spiritual, and historical values of Dził 

Nchaa Si’an will be included as stipulations in the operating plan that governs each SUP. These 

measures are identified in chapter 2 under Mitigation. 

 

23 Navajo Nation v. U.S. Forest Service., 408 F. Supp. 2d 866, 883-84 (D. Ariz. 2006); Navajo Nation v. U.S. Forest 

Service, D.C. No. CV-05-01824-PGR, August 8, 2008, U.S. Court of Appeals for the Ninth Circuit, en banc appeal 

decision.
Chapter 3. Affected Environment and Environmental Consequences

66 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Cumulative Effects: Heritage Resources

In addition to the recreation residences and other special-use sites (e.g., Heliograph, Ladybug) on 

Mt. Graham, the Western Apache strongly oppose the existence of the Mt Graham International 

Observatory because of its effects on the TCP. In his letter of April 28, 2006, Chairman Massey 

wrote that recreation and institutional permits on sacred mountains cause desecration and damage 

to the Apache culture. To the Western Apache, recreation residences must be considered part of 

the cumulative impacts to Native American cultural and ecological integrity of sacred sites, which 

has most recently been exacerbated by projects such as the Mount Graham International 

Observatory on the Coronado National Forest, expansion of the ski area on the Coconino 

National Forest, and copper mining on the Tonto National Forest.

Social and Economic Resources 

The forest plan, page 9, provides the following mission statement for the management of the 

Coronado NF:

 “Manage the resources of the Coronado National Forest under multiple use and 

sustained yield principles to provide for balanced contributions to the national 

welfare and to the economic and social needs of the people of southeast Arizona 

and southwest New Mexico. Management programs are to be oriented to 

maintain cultural values and a viable rural economy [emphasis added].”

Additionally, the forest plan provided the following standard/guideline:

 “Consider all resource values and social needs in doing land adjustment planning 

(USDA-FS, 1986, p. 40).”

Affected Environment

The Old Columbine and Turkey Flat recreation residence tracts are located within Graham 

County, Arizona. Most current permit holders list a permanent residence address within Graham 

County (USDA-FS, 2006). As discussed in chapter 3, heritage resources section, the entire 

mountain range has great social and cultural importance for the Western Apaches, who live 

mainly in Gila, Navajo, and Apache Counties, as well as Graham County. The economic and 

social activities resulting from the use of these recreation residences are generally concentrated 

within the county. For this reason, the analysis area for direct, indirect, and cumulative effects of 

this project on the social and economic environment focuses on Graham County, Arizona. The 

period of analysis for cumulative effects is 20 years, based on the term of a newly issued 

recreation residence SUP.

The Graham County Comprehensive Plan emphasizes the importance of protecting both the 

natural resources and scenic beauty that are “essential to the economic stability and unique 

character and lifestyles” of the area (University of Arizona, 2006). Graham County is rich in 

natural resources and has a rural culture and economy supported by copper mining, cotton 

farming, and cattle ranching. The Gila River is a vital source of water for approximately 52,000 

acres of arable land in the County, much of which is dedicated to the production of cotton, a 

primary component of the County’s agricultural economy. Mining also plays a major role in the 

economy of Graham County. There are a number of small mines in the area, and the PhelpsDodge Corporation manages a large open pit mine north of Safford. The Mt. Graham 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 67

International Observatory, located within Graham County on the Coronado NF, is the home of the 

Large Binocular Telescope, the world’s most powerful optical telescope.

The permit holders are represented by two recreation residence owner associations. The 

Columbine Recreation Residence Owners Association represents those in the Old Columbine 

tract and the Mt. Graham Recreation Residence Association represents those in the Turkey Flat 

tract. Spring-fed water system permits have been granted to each of the two associations (Angle,

2006c). The associations manage the water systems using volunteers from within their 

membership, represent recreation residence owners in dealings with the Forest Service, 

disseminate information, and encourage appropriate area maintenance and resident behavior 

(Bennett, 2006c).

The primary season of use for the permitted recreation residences is May 1 through October 31. 

Because of weather conditions, the road to the Old Columbine tract is gated from about 

November 15 to April 15 each year. Snow conditions sometimes prevent opening of the gate in 

the spring until the road can be plowed, generally by Memorial Day. The Turkey Flat tract is 

accessible year round (Angle, 2006a; Bennett, 2006d).

Permits allow recreation residence owners to reside in the recreation residences up to 180 days 

per year. Actual use at each recreation residence is generally much less, limited to a few 

weekends and an occasional stay of a week or more. Very little use has been noted during the 

winter months. Permits do not allow owners to rent their recreation residences to third parties. All 

recreation residences are permitted to individuals, generally in middle income ranges. However, a 

growing number of permit holders are professionals in higher income brackets (Bennett, 2006c). 

Sixty percent of recreation residence owners reside within Graham County. All but two owners 

reside within Arizona (USDA-FS, 2006).

As mentioned above, all recreation residences are served by water systems permitted to and 

administered by owners associations. However, in dry years, the springs have run dry, requiring 

permit holders to haul in water (Bennett, 2006d). Approximately 70 percent of recreation 

residences have septic systems, and the remaining 30 percent use pit toilets. Neither tract has 

telephone or electric service; although some recreation residence owners have generators to 

provide electricity (Bennett, 2006b). Cell phone coverage is poor. Heat is provided through the 

use of propane or wood stoves. When in residence, permit holders generally obtain supplies and 

services in Safford, Arizona (Bennett, 2006d).

Most recreation residences are relatively small, and have an average of two bedrooms, kitchen, 

family room, and a bathroom or pit toilet. Some recreation residences have a loft, and most have a 

deck. Most recreation residences are well maintained. Permits require that owners maintain the 

structural integrity and protective coatings of recreation residences and maintain their lots to 

remove debris, including branches, needles, etc. Wood piles must be kept a safe distance from 

structures. Permit holders are required to remove any hazard tree, on or off the lot, which may 

pose a danger to the house or to residents (Bennett, 2006e).

The permit authorizing the occupancy of the residences specifies that a determination not to issue 

a new permit may be made at the end of the 20-year term, and that if a new permit is not issued, 

the permit holder must remove all improvements. This is a risk assumed by the initial permit 

holder in signing the permit and constructing a recreation residence on public lands and is 
Chapter 3. Affected Environment and Environmental Consequences

68 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

assumed by all succeeding owners. An option available to permit holders to mitigate this loss is to 

move their recreation residence to a location off the Coronado NF rather than remove it.

Other permitted or Forest Service owned facilities also present in the area include a church camp 

(Arizona Bible Camp) and numerous developed recreation sites, and the area is also used for 

dispersed recreation and permitted grazing.

Social Environment

Both the Old Columbine and the Turkey Flat tracts were established in the 1920s, when 

applications for permits were first submitted (Angle, 2006). Many of the recreation residences 

have been passed down through generations within the same family. Other recreation residences 

tend to be more frequently bought and sold, in some cases as often as every 2 to 3 years (Bennett 

2006a; Angle, 2006b). For many of the individuals who hold permits, these recreation residences 

are a well-established element of their lifestyle and standard of living, providing a mountain 

“getaway” to be enjoyed each summer. For some families, ownership and use of these recreation 

residences have become a part of family culture and tradition.

For some permittees, the cabins are physical reminders of the past and powerful ties to family, 

community, and cultural history. For these persons, preservation of these sites is important in 

order to safeguard the history they represent and maintain a sense of connection to the past that 

can be communicated and passed on to future generations. Emotional and psychological 

attachments to these sites can be an important contribution to an individual’s or community’s 

sense of place. In a similar but reverse manner, for some Western Apaches the cabins are physical 

reminders of the economic, social, and spiritual losses their own culture has experienced in the 

past 120 or so years. For them, human-made developments are intrusions that disrupt the sacred 

and traditional environment of the mountain.

The White Mountain Apache Tribe and some members of the public have expressed concern that 

NFS land and fire management decisions are unduly influenced by the permitted recreation 

residences and that the protection and enhancement of habitat for the endangered Mt. Graham red 

squirrel is compromised in order to accommodate the needs of permit holders. Additionally, 

concern was expressed that decisions to suppress wildland fire are too heavily influenced by the 

need to protect recreation residence tract improvements rather than realize ecosystem benefits. 

For this reason, it is believed by tribal members and some of the general public that the needs of a 

few citizens are compromising the greater public benefit. By the same token, permit holders have 

a capital investment in their improvements as well as sentimental attachments resulting in a 

strong desire to see that investment protected.

Population

In 2000, the population of Graham County was 33,489, which equates to approximately 7.2 

persons per square mile as compared to 45.2 persons per square mile across the State of Arizona 

as a whole (U.S. Census Bureau, 2000a). The population of the County is expected to grow by 

approximately 35 percent by the year 2030. This rate of growth is much lower than the population 

growth projected for the State, which is expected to double over the same time period (Arizona 

Department of Economic Security, 2006). Table 10 displays the racial and ethnic breakdown of 

the Graham County population, including poverty rates by race or ethnicity.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 69

In 2000, the total number of housing units in Graham County was 11,430, 2.5 percent of which 

were identified as seasonal homes. Overall, the number of total housing units grew by 25.4 

percent since the 1990 census, compared with a growth rate of nearly 32 percent statewide. The 

highest rate of growth within the County occurred in the number of seasonal homes, which 

increased by 35 percent in the same 10-year period. The county rate of growth in the number of 

seasonal homes still falls short of the State average of 46.8 percent. Housing density remains 

rather sparse, with only 2.47 houses per square mile (University of Arizona, 2006).

Economy

The most dominant categories of employment in Graham County are displayed in table 11. The 

relative breakdown is reflective of the State as a whole, but with a somewhat greater proportion 

of jobs in service occupations and the construction, extraction, and maintenance occupations 

(University of Arizona, 2006).

The major employers within Graham County (University of Arizona, 2006) include the following: 

Arizona State Prison, Safford; Bonita Nurseries, Bonita; City of Safford, Safford; Eastern Arizona 

College, Thatcher; Federal Prison, Safford; Impressive Labels, Safford; Mt. Graham Hospital, 

Safford; Safford United School District, Safford; and Wal-Mart, Thatcher.

Annual fees charged by the Forest Service for a recreation residence is 5 percent of the bare land 

appraisal. Lots are appraised every 20 years. Annually, the 5 percent fee is adjusted for inflation. 

The total 2006 annual use fees paid to the treasury by recreation residence owners at Old 

Columbine totaled $8,232, and owners at Turkey Flat paid $45,064 for a total of $53,296.

Table 10. Graham County, Arizona, Population by Race and Ethnicity.

Race/Ethnicity Population Percentage of 

Population

Number Below 

Poverty Level

Percentage of 

Total Below 

Poverty Level

White 22,473 67.1 3,202 16 

Black or African 

American 625 1.0 173 54 

American Indian 

and Alaska 

Native

5,005 14.9 2,276 49 

Asian 188 0.6 16 14 

Native Hawaiian 

and Other 

Pacific Islander

13 0.0 10 33 

Other Race 4,470 13.3 1,029 27 

Two or More 

Races 715 2.1 246 30 

Hispanic24 9,054 27.0 2,218 28 

 

24 Members of all races may be counted as Hispanic, based on their country of origin or ethnicity.
Chapter 3. Affected Environment and Environmental Consequences

70 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Race/Ethnicity Population Percentage of 

Population

Number Below 

Poverty Level

Percentage of 

Total Below 

Poverty Level

Non-Hispanic 24,435 73.0 2,243 13 

Source: U.S. Census Bureau, 2000.

Recreation residences and outbuildings require routine maintenance to remain in compliance with 

the requirements of the SUPs. Maintenance activities that cannot be accomplished by the owners 

are usually performed by a hired contractor. Most services are obtained from businesses located 

in Safford. Additionally, other supplies and services, such as groceries, gasoline, and auto 

maintenance, required by recreation residence owners while in residence at the recreation 

residences, are generally obtained in Safford. No quantifiable data is available on the revenue 

generated by Safford area businesses as a result of these services.

Table 11. Dominant Occupations in Graham County and the State of Arizona.

Occupational Category Graham County Arizona

Management, professional, 

and related occupations

25.9 % 32.7 %

Sales and office occupations 23.5 % 28.5 %

Service occupations 20.8 % 16.2 %

Construction, extraction, and 

maintenance occupations

16.4 % 11.0 %

Production, transportation, 

and material moving 

occupations

11.5 % 10.9 %

Source: U.S. Census Bureau, 2000

Revenues to Graham County

Special-use permits issued for recreation residences within the Old Columbine and Turkey Flat 

tracts allow the use of NFS lands on which the residences sit. The recreation residences 

themselves are private property and are a source of tax revenue to Graham County. County 

records indicate annual tax revenues of $1,002 are collected on the residences within the Old 

Columbine tract and $6,300 are collected from Turkey Flat owners (Graham County Treasurer, 

2006).

Counties receive Federal funds known as payments in-lieu of taxes (PILT) to replace revenue that 

is lost because of the tax-exempt nature of public lands administered by Federal agencies (1976 

Payments in Lieu of Taxes Act). The amount is based on the amount of acreage administered by 

certain Federal agencies, population, a schedule of payments, the Consumer Price Index, other 

Federal payments made in the prior year, and the level of funding allocated by Congress.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 71

In addition to PILT, counties have historically received payments from the Federal 25 Percent 

Fund, which accrues from fees generated by Coronado NF activities, with the exception of certain 

mineral programs, and is based on the number of NFS acres within each county. The 25 Percent 

Fund payments to some counties were affected by the enactment in 2000 of the Secure Rural 

Schools and Community Self-Determination Act (SRSCS)25, which is intended to stabilize annual 

payments to states and counties for 6 years, which began in 2001. The new formula for 

computing annual payments is based on averaging a State’s three highest payments between 1986 

through 1999 to arrive at a compensation allotment or “full payment amount.” Each county had to 

decide whether to continue to receive payments under the 25 Percent Fund or to receive its 

proportionate share of the State’s full payment amount under SRSCS. Graham County elected to 

receive its proportionate share of the State’s full payment amount under SRSCS.

Environmental Consequences

Direct and Indirect Effects – No Action

Social Environment

If no action is taken, permit holders would have continued use of their lots and recreation 

residences for 10 years, after which they would be required to remove all improvements. Many 

permit holders would consider this a loss of an important element of their lifestyle and an adverse 

impact to their standard of living. For families that have held a permit over multiple generations, 

a place that has been a part of family culture and tradition would be lost. While the tradition could 

potentially be continued in another location, some elements specific to the current recreation 

residence’s location, surroundings, and characteristics would be lost.

Many permit holders would experience a feeling of loss when a physical element important to 

their sense of place is removed, potentially reducing their enjoyment of the area. Those who 

experience historical structures as a physical tie to the past would likely feel a strong sense of 

loss. For these individuals, a paper record is likely to be considered a poor substitute. The ability 

to pass this connection on to future generations would be limited to the communication of verbal 

and written histories.

On the other hand, if no action is taken, an important element of the Western Apache social and 

cultural environment would be restored. Removal of the residences would help protect their 

sacred TCP by returning the tracts to a more natural state and fostering a natural fire regime. 

Concerns about disrespectful and inappropriate behavior on the mountain would be reduced. 

Their ability to pass on to future generations the concept of respect for the entire mountain would 

be enhanced. Because Apache history and wisdom is inextricably tied to a sense of “place” 

(Basso 1996), an improvement in their ability to hand down traditional values, morality, history, 

and identity would be realized.

Concerns about the effect that the presence of recreation residences has on NFS land and fire

management decisions would continue for the next 10 years. Following removal of the recreation 

 

25 The SRSCS (PL 106-393) was enacted to provide transitional assistance to rural counties 

affected by the decline in revenue from timber harvests on Federal lands. Traditionally, these 

counties relied on a share of receipts from timber harvests to supplement local funding for 

school systems and roads.
Chapter 3. Affected Environment and Environmental Consequences

72 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

residences, concerns about their perceived effect on habitat for the Mt. Graham red squirrel would 

be eliminated. However, the dispersed recreation use that is anticipated to occur in these sites may 

present new concerns with regard to the squirrel and other natural resources.

With regard to fire management, the Forest Service would have greater flexibility to manage 

wildland fire to enhance ecosystem health and restore the natural fire regime. The presence of 

other permitted facilities in the area such as the Mt Graham International Observatory, Arizona 

Bible Camp, electronic sites, and developed recreation facilities would continue, however, to 

influence the need for fire suppression.

Population

Use of the existing recreation residences is limited to a maximum of 180 days per year. Actual 

use of the recreation residences is often limited to a few weekends and an occasional stay of a 

week or more (Bennett, 2006c). None of the recreation residences are primary residences. 

Although the ability to own a recreation residence within a relatively short driving distance may 

make Graham County more attractive to some recreation residence owners as a location for their 

permanent residence, the removal of the recreation residences would not be expected to have any 

direct or indirect impacts on the local population.

Economy

For the 10-year closeout period, there would be no change in the economic contribution made to 

the local economy because of the existence and use of the 88 recreation residences in the Old 

Columbine and Turkey Flat tracts. Recreation residence owners would continue to obtain services 

and supplies from local businesses.

At the end of 10 years, permit holders would be required to remove all improvements. The 

required removal of each recreation residence may represent the loss of a capital investment for 

the permit holder. Approximately 56 percent of the recreation residences were constructed in the 

late 1920s to the early 1940s. The remaining recreation residences were constructed during the 

1950s, with a few in the 1960s (Graham County Assessor, 2006). Most of these facilities have 

exceeded the original design life and as such would be fully depreciated. However, many have 

been remodeled or updated over the years, effectively extending the original design life. 

Regardless, a residence still in use is of value to its owner and represents a loss if it must be 

demolished. The limited cash value (replacement cost less depreciation) of the residences in these 

two tracts ranges from a low of $1,500 to a high of $38,000 with an overall average of 

approximately $13,500 (Graham County Assessor, 2006).

The cost of removing improvements would be borne by the permit holders. The cost of removal 

of structural improvements is estimated at approximately $3,000 per recreation residence. 

Removal costs would include the deconstruction and removal of all buildings and foundations 

and reshaping of the site to return it to a natural contour. Sites would then be revegetated using a 

native seed mix. The cost of revegetation is estimated at approximately $200 per site and would 

also be borne by the permit holders. The Forest Service would incur expenses to administer the 

restoration of the site. Forest Service costs are estimated at approximately $125 per recreation 

residence.

Following removal of the recreation residences, services, and supplies that had been provided by 

local businesses to permitted recreation residence owners would no longer be needed. A majority 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 73

of recreation residence owners (60 percent) (USDA-FS, 2006) are residents of Graham County 

and it is anticipated that their spending would continue to remain within the county. The business 

of recreation residence owners with primary residences outside the county would be lost. 

However, no measurable effects on local employment or income are anticipated. The removal of 

improvements at the end of 10 years may stimulate a very small amount of short-term

employment revolving around removal of structural improvements and rehabilitation activities.

Forest Service and County Revenues

If no action is taken, Graham County would continue to collect annual property tax revenues of 

approximately $7,500 from recreation residence owners (Graham County Treasurer, 2006) and 

the Forest Service would continue to collect special use permit fees of approximately $53,296 

annually through December 31, 2018 (USDA-FS, 2006c). After this date, all improvements 

would be removed. County property tax revenues would be reduced by approximately $7,500 

(Graham County Treasurer, 2006). Forest Service revenues associated with the Old Columbine 

and Turkey Flat Recreation Residence tracts would cease.

As explained above, counties in which NFS lands are located receive payments from either the 25 

Percent Fund or the SRSCS. Graham County chose to take payment under the SRSCS. Therefore, 

SRSCS payments to Graham County would not change as a result of implementation of 

alternative 1. However, the SRSCS legislation and associated payments terminated in 2006. 

SRSCS was extended and payments funded for 2007, however, Congress has yet to take action to 

extend it beyond 2007. If SRSCS is not extended, payments may be made under the 25 Percent 

Fund Act.

If payments under the 25 Percent Fund are resumed, Graham County would receive 25 percent of 

the receipts collected for the recreation residence SUPs for the next 10 years. This would be 

approximately $13,300 annually in 2006 dollars. After, 10 years, the special use permits would 

expire, and no further funds would be collected, resulting in a reduction in annual 25 Percent 

Fund revenues to the county of approximately $13,300.

The total revenue loss to the county would be approximately $20,600 annually, which represents 

approximately 0.05 percent of the county’s 2006 total budget (Arizona Tax Research Association,

2006). This reduction is not expected to adversely impact county services.

Financial and Economic Present Net Value (PNV)

The measure of Financial and Economic Present Net Value (PNV) has been determined for the 

alternatives addressed in this EIS.

Financial PNV examines revenue and cost implications from the perspective of the Forest 

Service. It could also be said that this is the perspective of the taxpayer. Only those revenues and 

costs that are recorded in financial records are included in this analysis. When considering 

quantitative issues, financial PNV analysis offers a consistent measure in dollars that can be used 

to compare alternatives. This type of analysis does not account for non-market benefits, 

opportunity costs, individual values, or other values, benefits and costs that are not easily 

quantifiable. This is not to imply that such values are not significant or important, but to 

recognize that non-market values are difficult to represent with appropriate dollar figures. The 

values that are not included in this part of the analysis are often at the center of disagreements and 

interest people have in forest resource projects. Therefore, financial PNV should not be viewed as 
Chapter 3. Affected Environment and Environmental Consequences

74 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

a complete answer, but as one tool decisionmakers use to gain information about resources, 

alternatives, and trade-offs between costs and benefits.

Economic PNV examines a broader definition of benefits by considering the value of national 

forest uses that are not captured in the marketplace. In this analysis, costs and benefits to permit 

holders are the primary additions over a financial analysis. Some outcomes, such as biological 

diversity, visual amenities, and some social impacts have no monetary values or costs that have 

been established by USDA or the Forest Service. While some research studies have explored the 

development of such values, these values are considered in a non-monetary fashion by natural 

resource impacts analysis.

Net public benefit is an important concept in the current regulations for carrying forest 

management activities [benefits minus all the associated Forest Service inputs and negative 

effects (costs), whether they can be quantitatively valued or not]. Thus, net public benefits, 

conceptually are the sum of this economic analysis plus the net value of non-priced outputs and 

costs. It is not the result of economic analysis alone. Many relevant factors cannot be quantified 

or expressed in monetary terms. The agency endeavors to maximize net public benefit through 

public participation in the planning process. By seeking public input and designing alternatives 

and mitigation measures to achieve the desired future condition while minimizing adverse effects 

and analyzing effects relative to the issues and concerns, an agency achieves the maximum net 

public benefit. The economic PNV analysis is but one element that must be considered together 

with the impacts to other resources that are evaluated in this EIS.

PNV is defined as the value of discounted benefits (or revenues) minus discounted costs. A PNV 

analysis includes all outputs to which monetary values are assigned. In deriving PNV figures, 

costs are subtracted from benefits to yield a net value. “Future values” (i.e., benefits received in 

the future) are discounted using an appropriate discount rate to obtain a “present value.” The PNV 

of a given alternative is the discounted sum of all benefits minus the sum of all costs associated 

with that alternative. PNV estimates attempt to condense a large amount of information into a 

single value. This value must be used with caution.

Table 12 displays the financial and economic PNV for the no action alternative. All dollars are in 

constant dollars with no allowance for inflation. A 7 percent discount rate was used over a period 

of 20 years, from 2009 through 2028. Revenues are not reduced for payments made to states and 

counties. No action had the lowest financial and economic PNV of the alternatives evaluated in 

this EIS.

Table 12. Financial and Economic Present Net Value (PNV) for No Action (20 Year Planning 

Horizon).

Value Present Value

(Thousands of Dollars)

Forest Service Revenues $400.50

Forest Service Costs -$146.30

Public Benefits $1,244.10

Public Costs -$812.70
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 75

Value Present Value

(Thousands of Dollars)

Financial PNV $254.30

Economic PNV $431.40

Environmental Justice

If the residences are removed, the social and cultural benefits would accrue mainly to the Western 

Apache, because the residences are incompatible with their TCP. Table 10 indicates that almost 

half of the Native Americans within Graham County live below the poverty level, and it is 

assumed that most of these Native Americans are Western Apaches who live on the San Carlos 

Apache reservation.

Direct and Indirect Effects – Proposed Action

Social Environment

Under this alternative, there would be no change to the existing condition. Existing recreation 

residence permits would be issued for a 20-year period. Permit holders would have the continued 

use of their lots and attached recreation residences until December 31, 2028, when the permits 

would again need to be considered for issue. Permit holder lifestyles and standard of living as 

related to the access to and use of these residences would be maintained. For those families who 

have maintained multigenerational traditions tied to a recreation residence, this alternative 

represents the ability to continue a family tradition and maintain family culture.

Permit holders who attach importance to physical reminders of the past would favor this 

alternative most strongly. Sense of place for these individuals would be maintained. Existing 

recreation residences could be preserved for the next generation.

Conversely, issuing 20-year permits for the recreation residences would continue their effects on 

an important element of the Western Apache social and cultural environment. Desecration of the 

Western Apache sacred TCP would continue, as would their concerns about disrespectful and 

inappropriate behavior on the mountain. The Apaches; ability to pass on to future generations the 

concept of respect for the entire mountain would be diminished, and their ability to convey to 

their children traditional values, morality, history, and identity would be reduced.

The presence of recreation residences would continue to be a consideration in the determination 

of current and future management activities including fire prevention and suppression. Permit 

holders would continue to seek assurance that their properties would be protected from the effects 

of catastrophic wildland fire. Restoration of a natural fire regime would be politically difficult. 

The perception of effects resulting from the presence of these recreation residences to Mt. 

Graham red squirrel habitat would continue. Those who favor the removal of residences in favor 

of habitat concerns would remain unsatisfied.

Population

There would be no change from the existing condition under this alternative; therefore there 

would be no effect on the local population.
Chapter 3. Affected Environment and Environmental Consequences

76 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Economy

There would be no change to the economy if the proposed action is implemented. Existing 

contributions to the local economy would be maintained as recreation residence owners would 

continue to obtain services and supplies from local businesses. Permit holders would be required 

to continue the maintenance of improvements as in the past, incurring a similar level of expense.

Forest Service and County Revenues

No change to Graham County or Forest Service revenues would result from the proposed action. 

The county would continue to collect annual property tax revenues of approximately $7,300 from 

recreation residence owners until 2028 (Graham County Treasurer, 2006). Likewise, the Forest 

Service would continue to collect annual special use permit fees of approximately $53,296 for the 

same period (USDA-FS, 2006c).

If the SRSCS is extended, there would be no effect on Federal funds allocated to the county. If 

the SRSCS is not extended, and payment under the 25 Percent Fund Act resume, Graham County 

would receive annual payments of approximately $13,300 from associated permit fees in addition 

to 25 percent of other Forest Service revenues.

Financial and Economic Present Net Value (PNV)

Table 13 displays the financial and economic PNV associated with the issuance of new permits. 

All dollars are in constant dollars with no allowance for inflation. A 7 percent discount rate was 

used over a period of 20 years, from 2009 through 2028. Revenues are not reduced for payments 

made to states and counties. The proposed action would have the highest financial and economic 

PNV of the alternatives evaluated in this EIS.

Table 13. Financial and Economic Present Net Value (PNV) for the Proposed Action (20

Year Planning Horizon).

Value Present Value

(Thousands of Dollars)

Forest Service Revenues $604.10

Forest Service Costs -$212.20

Public Benefits $4,163.70

Public Costs $-$988.60

Financial PNV $2,398.60

Economic PNV $3,175.10

Environmental Justice

The issuance of permits is detrimental to the culture and religion of the Western Apache, because 

the presence of the residences is contrary to protection of the mountain as a TCP. As table 10 

indicates, almost half of the Native Americans within Graham County live below the poverty 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 77

level, and it is assumed that most of these Native Americans are Western Apaches who live on the 

San Carlos Apache reservation.

Direct and Indirect Effects – Issue Turkey Flat Only

Social Environment

Direct and indirect effects related to issuing new term permits for the Turkey Flat recreation 

residence tract would be the same as described for the proposed action. There would be no 

change to the existing condition relative to these permits. The 74 permit holders with residences 

located in the Turkey Flat tract would have the continued use of their lots and associated 

improvements until December 31, 2028, when new permits would be needed. Turkey Flat permit 

holder lifestyles and standards of living related to the access to and use of these recreation 

residences would be maintained.

Fourteen permit holders in the Old Columbine tract would have continued use of their lots for 10 

years, after which they would be required to remove all improvements. These permit holders 

would consider this an adverse effect to their lifestyle and standard of living. Many recreation 

residences in this tract have been handed down through multiple generations within the same 

family. Loss of the permit would adversely affect the family culture and tradition. While the 

tradition could potentially be continued in an alternative location, some elements specific to the 

current recreation residence’s location, surroundings, and characteristics would be lost.

Sense of place for permit holders would be maintained. All recreation residences in the Old 

Columbine tract would be removed in 10 years. Those who value physical reminders of the past 

would perceive the removal of these recreation residences as an adverse effect to their sense of 

place and a loss to future generations.

For the Western Apaches, removal of the Columbine recreation residences would have part of the 

same beneficial effect as the No Action alternative. Issuing permits for the Turkey Flat tract 

residences would have the part of the same detrimental effect as the proposed alternative.

Concerns about the effect that the presence of recreation residences has on National Forest 

System land and fire management decisions would be alleviated somewhat under this alternative. 

Except for no action, this alternative would have the greatest potential to improve to the Mt. 

Graham red squirrel because of the location of the Old Columbine tract relative to these important 

habitat areas (see chapter 3, wildlife section).

The removal of the residences in the Old Columbine tract would reduce some citizens’ concern 

about the effects on fire management decisions. However, permit holders in the Turkey Flat tract 

would continue to favor protection from the effects of catastrophic wildland fire. The residences 

in the Turkey Flat tract and other improvements in the Old Columbine area, such as the Mt. 

Graham International Observatory the Arizona Bible Camp, electronic sites, and numerous Forest 

Service developed recreation facilities, would continue to require consideration when determining 

fire prevention and suppression tactics or other National Forest System land and fire management 

decisions.

Population

No effects on the population are anticipated.
Chapter 3. Affected Environment and Environmental Consequences

78 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Economy

Contributions to the local economy for the 10-year closeout period would remain unchanged from 

the existing condition. After the removal of the 14 recreation residences located in the Old 

Columbine tract, the demand for services and supplies in support of recreation residence permit 

holders would be slightly reduced; however, no measurable effect to employment or income is 

anticipated. Twelve of the Old Columbine permit holders have permanent residences within 

Graham County. The spending of these families would be expected to remain within the county. 

Spending by the remaining two permit holders would be lost from the local economy.

At the end of 10 years, permit holders in the Old Columbine tract would be required to remove all 

improvements. The required removal of each recreation residence may represent the loss of a 

capital investment for the permit holder. Approximately 29 percent of the recreation residences 

were constructed in the late 1920s to the early 1940s. The remaining recreation residences were 

constructed during the 1950s, with a few in the1960s (Graham County Assessor, 2006). Most of 

these facilities have exceeded the original design life and as such would be fully depreciated. 

However, many have been remodeled or updated over the years, effectively extending the original 

design life. Regardless, a residence still in use is of value to its owner and represents a loss if it 

must be demolished. The limited cash value (replacement cost less depreciation) of the residences 

in the Old Columbine tract ranges from a low of $4,700 to a high of $22,000 with an overall 

average of approximately $12,000 (Graham County Assessor, 2006).

The removal of recreation residences at the Old Columbine tract would be a cost borne by the Old 

Columbine permit holders. The cost of removal is estimated at $3,000 per recreation residence. 

Removal would involve the deconstruction and removal of all buildings and foundations and 

reshaping of the site to return it to a natural contour. The 14 sites would then be revegetated with 

a native seed mix at an estimated cost to the permit holders of $200 per site. Forest Service costs 

to administer the removal of improvements are estimated at $125 per site (Bennett, 2006). The 

removal of improvements at these sites may stimulate a small amount of short-term employment 

revolving around removal of structural improvements and rehabilitation activities.

Forest Service and County Revenues

For the 10-year closeout period at Old Columbine, Forest Service and county revenues would 

remain unchanged. At the end of 10 years, Forest Service revenues would decrease to 

approximately $45,000 annually (USDA-FS, 2006c). County property tax revenues would only 

be collected on the recreation residences in the Turkey Flat tract and would be approximately 

$6,300 annually (Graham County Treasurer, 2006).

If the SRSCS is extended, there would be no effect on Federal funds allocated to the county. If 

the SRSCS is not extended, and payment under the 25 Percent Fund Act resume, Graham County 

would receive payments of approximately $11,250 from associated permit fees in addition to 25 

percent of other Forest Service revenues. Total revenue loss to the county would be 

approximately $3,050 annually. No adverse impact to county services would be anticipated.

Financial and Economic Present Net Value (PNV)

Table 14 displays the Financial and economic PNV associated with issuing new permits for 

Turkey Flat only. All dollars are in constant dollars with no allowance for inflation. A 7 percent 

discount rate was used over a period of 20 years, from 2009 through 2028. Revenues are not 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 79

reduced for payments made to states and counties. Alternative 3 had the second highest Financial 

and Economic PNV of the alternatives evaluated in this EIS.

Environmental Justice

Western Apache concerns would be partly addressed by the removal of the recreation residences 

at the Old Columbine tract after 10 years. The number of residences to be removed represents 16 

percent of the residences currently permitted on the mountain. Apache access to the 25 acres of 

the Old Columbine tract would be less inhibited by the presence of private homes. Members of 

the Tribe would continue to have access to the mountain for cultural, religious, and ceremonial 

purposes, including the 25 acres located in Old Columbine.

Table 14. Financial and Economic Present Net Value (PNV) for Issuing Permits for Turkey 

Flat Only (20 Year Planning Horizon).

Value Present Value

(Thousands of Dollars)

Forest Service Revenues $572.70

Forest Service Costs -$201.70

Public Benefits $3,749.10

Public Costs -$962.60

Financial PNV $371.00

Economic PNV $2,786.40

Direct and Indirect Effects – Issue Old Columbine Only

Social Environment

Direct and indirect effects related to issuing 14 new special use permits in the Old Columbine 

recreation residence tract would be the same as described for the proposed action. There would be 

no change to the existing condition relative to these permits. The 14 permit holders with 

residences located in the Old Columbine tract would have the continued use of their lots and 

associated improvements until December 31, 2028, when new permits would be necessary. Old 

Columbine permit holder lifestyles and standards of living related to the access to and use of 

these residences would be maintained. 

Seventy-four permit holders in the Turkey Flat tract would have the continued use of their lots for 

10 years, after which they would be required to remove all improvements. These permit holders 

would consider this an adverse effect to their lifestyle and standard of living. Loss of these 

permits may adversely affect culture and tradition for some families. While the tradition could 

potentially be continued in an alternative location, some elements specific to the current 

recreation residence’s location, surroundings, and characteristics would be lost.

Sense of place for permit holders would be maintained. All recreation residences in the Turkey 

Flat tract would be removed in 10 years. Those who value the residences as physical reminders of 
Chapter 3. Affected Environment and Environmental Consequences

80 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

the past would perceive their removal as an adverse effect to their sense of place and a loss to 

future generations. 

For the Western Apaches, removal of the Turkey Flat recreation residences would have part of the 

same beneficial effect as the No Action alternative. Issuing permits for the Columbine tract 

residences would have the part of the same detrimental effect as the proposed alternative.

Concerns about the effect that the presence of recreation residences has on National Forest 

System land and fire management decisions would be alleviated slightly under this alternative. 

The removal of 74 residences in the Turkey Flat tract would reduce concerns about effects on fire 

management decisions to a limited extent. However, the permit holders in the Old Columbine 

tract would continue to favor protection of their assets from the effects of catastrophic wildland 

fire. The residences in the Old Columbine tract as well as other facilities authorized under the 

forest plan, such as the Mt. Graham International Observatory, the Arizona Bible Camp, 

electronic sites, and numerous Forest Service developed recreation facilities would continue to 

require consideration by the Forest Service when determining fire suppression tactics and land 

management decisions.

Population

No effects on the population are anticipated.

Economy

Contributions to the local economy for the 10-year closeout period would remain unchanged from 

the existing condition. After the removal of the 74 recreation residences located in the Turkey Flat 

tract, the demand for services and supplies in support of recreation residence permit holders 

would be reduced; however, no measurable effect to employment or income is anticipated. Just 

over half of the Turkey Flat permit holders have permanent residences within Graham County. 

The spending of these families would be expected to remain within the county. Spending by the 

remaining permit holders would be lost from the local economy.

At the end of 10 years, permit holders in the Turkey Flat tract would be required to remove all 

improvements. The required removal of each recreation residence may represent the loss of a 

capital investment for the permit holder. Approximately 61 percent of the recreation residences 

were constructed in the late 1920s to the early 1940s. The remaining recreation residences were 

constructed during the 1950s, with a few in the1960s (Graham County Assessor, 2006). Most of 

these facilities have exceeded the original design life and as such would be fully depreciated. 

However, many have been remodeled or updated over the years, effectively extending the original 

design life. Regardless, a residence still in use is of value to its owner and represents a loss if it 

must be demolished. The limited cash value (replacement cost less depreciation) of the residences 

in the Turkey Flat tract ranges from a low of $1,500 to a high of $38,000 with an overall average 

of approximately $13,800 (Graham County Assessor, 2006).

The removal of recreation residences at the Turkey Flat tract would be a cost borne by the Turkey 

Flat permit holders. The cost of removal is estimated at $3,000 per recreation residence. Removal 

would involve the deconstruction and removal of all buildings and foundations and reshaping of 

the site to return it to a natural contour. These 74 sites would then be revegetated with a native 

seed mix at an estimated cost to the permit holders of $200 per site. Forest Service costs to 

administer the removal of improvements are estimated at $125 per site (Bennett, 2006). The 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 81

removal of improvements at these sites may stimulate a small amount of short-term employment 

revolving around removal of structural improvements and rehabilitation activities.

Forest Service and County Revenues

Over the 10-year closeout period, Forest Service and county revenues would remain unchanged. 

At the end of 10 years, Forest Service revenues would decrease to approximately $8,200 annually 

(USDA-FS, 2006c). County property tax revenues would only be collected on the recreation 

residences in the Old Columbine tract and would be approximately $1,000 annually (Graham 

County Treasurer, 2006).

If the SRSCS is extended, there would be no effect on the amount of Federal funds paid to the 

county. If the SRSCS is not extended, and payment under the 25 Percent Fund Act resume, 

Graham County would receive annual payments of approximately $2,050 from associated permit 

fees in addition to 25 percent of other Forest Service revenues. Total revenue loss to the county

would be approximately $17,500 annually, which would represent approximately 0.07 percent of 

the county 2006 budget (Arizona Tax Research Association, 2006). No adverse impact to county

services would be anticipated.

Financial and Economic Present Net Value (PNV)

Table 15 displays the financial and economic PNV for alternative 4. All dollars are in constant 

dollars with no allowance for inflation. A 7 percent discount rate was used over a period of 20 

years (2009 to 2028). Revenues are not reduced for payments made to states and counties. The 

alternative of issuing permits for Old Columbine only had the third highest financial and 

economic PNV of the alternatives evaluated in this EIS.

Environmental Justice

If new permits are issued for Old Columbine only, 74 recreation residences at the Turkey Flat 

tract would be removed after 10 years. Western Apache concerns would be partially addressed by 

the removal of the recreation residences at the Turkey Flat tract after 10 years. The number of 

residences to be removed represents 84 percent of the residences currently permitted on the 

mountain. Members of the Tribe would continue to have access to the mountain for cultural, 

religious, and ceremonial purposes. Access to the 52 acres of the Turkey Flat tract would be 

improved, less inhibited by the presence of private homes.

Table 15. Financial and Economic Present Net Value (PNV) for Issuing Permits for Old 

Columbine Only (20 Year Planning Horizon).

Value Present Value

(Thousands of Dollars)

Forest Service Revenues $432.00

Forest Service Costs -$156.80

Public Benefits $1,658.80

Public Costs -$838.70
Chapter 3. Affected Environment and Environmental Consequences

82 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Value Present Value

(Thousands of Dollars)

Financial PNV $275.20

Economic PNV $820.10

Cumulative Effects: Social and Economic Resources

No Action

For the first 10 years after a decision is made not to renew the recreation residence permits, there 

would be no change from the existing condition; therefore, there would be no cumulative effects

during this period.

Following the removal of the recreation residences, in years 11 through 20, the tracts would 

return to a more natural state, consistent with preservation of the Western Apache TCP. After 

cabin removal, resource management decisions, including those related to fire, would no longer 

be heavily influenced by the presence of recreational residences on NFS lands.

The Forest Service is planning the Pinaleño Ecosystem Restoration Project. Consultation is 

currently underway way with the San Carlos Apache Tribe and the White Mountain Tribe to 

develop Best Management Practices and appropriate treatments to begin the restoration of the 

Coronado NF ecosystem. Implementation of this proposal would contribute to improved habitat 

conditions for the Mt. Graham red squirrel and ecosystem health.

No measurable cumulative effects are expected relative to the population or the economy.

Proposed Action

With the proposed action, there would be no change from the existing condition; therefore, there 

would be no cumulative effects over a 20-year permit period.

In addition to the recreation residences in the Old Columbine and Turkey Flat tracts, the Forest 

Plan direction allows for the presence of numerous other permitted facilities in the area, such as 

the Mt. Graham International Observatory, the Arizona Bible Camp, electronic sites, and 

developed recreation facilities. Some individuals would continue to perceive that these facilities, 

incrementally with the recreation residences, adversely influence fire suppression and other land 

management decisions.

The Forest Service is planning the Pinaleño Ecosystem Restoration Project. Consultation is 

currently underway way with the San Carlos Apache Tribe and the White Mountain Apache Tribe 

to develop BMPs and appropriate treatments to begin the restoration of the Coronado NF

ecosystem. Implementation of this proposal would contribute to improved habitat conditions for 

the Mt. Graham red squirrel and ecosystem health. This project may also help to mitigate 

concerns for some individuals who object to current forest plan land allocations and their impact 

on the ecosystem.

No cumulative effects on the population or the economy are anticipated.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 83

Issue Turkey Flat Only

For the 10-year closeout period at Old Columbine, there would be no change from the existing 

condition; therefore, there would be no cumulative effects over this period.

Following the removal of the recreation residences in the Old Columbine tract, in years 11 

through 20, the perception that Forest Service resource management decisions are influenced by 

the presence of private property on NFS lands would be reduced.

The Forest Service is planning the Pinaleño Ecosystem Restoration Project. Consultation is 

currently underway way with the San Carlos Apache Tribe and the White Mountain Apache Tribe 

to develop BMPs and appropriate treatments to begin the restoration of the Coronado NF

ecosystem. Implementation of this proposal would contribute to improved habitat conditions for 

the Mt. Graham red squirrel and ecosystem health. This project may also help to mitigate 

concerns for some individuals who object to current forest plan land allocations and their impact 

on the ecosystem.

No measurable cumulative effects are expected relative to the population or the economy.

Issue Old Columbine Only 

For the 10-year closeout period, there would be no change from the existing condition at Turkey 

Flat; therefore, there would be no cumulative effects over this period.

Following the removal of the recreation residences in the Turkey Flat tract, in years 11 through 

20, the perception that Forest Service resource management decisions are influenced by the 

presence of private property on NFS lands would be reduced.

The Forest Service is in the process of developing the Pinaleño Ecosystem Restoration Project. 

Consultation is currently underway way with the San Carlos Apache Tribe and the Western

Apache Tribe to develop Best Management Practices and appropriate treatments to begin the 

restoration of the Coronado NF ecosystem. Implementation of this proposal would contribute to 

improved habitat conditions for the Mt. Graham red squirrel and ecosystem health. This project 

may also help to mitigate concerns for some individuals who object to current forest plan land 

allocations and their impact on the ecosystem.

No measurable cumulative effects are expected relative to the population or the economy.

Wildlife Resources 

Criteria that are generally used to evaluate impacts on wildlife and ecosystem sustainability 

include the potential for a reduction in species populations and diversity; depletion or 

fragmentation of plant and animal habitat; loss of threatened, endangered or other special-status 

species; and impairment of ecological integrity, resilience or health, by such causes as disruption 

of food chains and alterations in predator-prey relationships.

Species Evaluated

The following discussion reports the results of an analysis of the potential impacts to wildlife 

populations and habitat at and beyond the recreation residence tracts at Old Columbine and 

Turkey Flat. The analysis focuses on the following species that have a “special-status”:
Chapter 3. Affected Environment and Environmental Consequences

84 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

1. Federally Listed Species: those that are listed under the authority of the Endangered 

Species Act by the U.S. Fish and Wildlife Service (FWS) as threatened and endangered 

(TES), those proposed for listing as such, and areas that are designated by FWS as critical 

habitat in the proposed area of effect. FSM 2670.31 directs each forest to evaluate its

programs and site-specific actions to determine their potential effect on Federally listed 

species, population viability across their ranges, and all occurrences contribute 

significantly to the conservation of the species”. FSM 2670.32 directs that a biological 

evaluation be prepared to determine potential effects on species designated as “sensitive” 

by the Regional Forester. United States Department of Agriculture Regulation 9500-4 

directs the Forest Service to avoid actions that may cause a sensitive species to become 

threatened or endangered (FSM 2670.12).

2. Forest Service Sensitive (FSS) Species: those that are listed by the Regional Forester as 

“sensitive” in Region 3 (USDA 1999)26 for the following reasons: “because there is 

concern for population viability across their range, and all occurrences contribute 

significantly to the conservation of the species”. FSM 2670.32 directs that a biological 

evaluation be prepared to determine potential effects on species designated as “sensitive” 

by the Regional Forester. United States Department of Agriculture Regulation 9500-4 

directs the Forest Service to avoid actions that may cause a sensitive species to become 

threatened or endangered (FSM 2670.12).

3. Management Indicator Species (MIS): these are a select list of species identified by

individual forests as being representative of many other species. As such, they provide a 

basis for forest management based, in part, on the effects on MIS and their habitats. 

National Forest Management Act (NFMA) implementing regulations (36 CFR 219.19) 

and Forest Service Manual (FSM) 2600 guidelines require that forest plans identify 

certain vertebrate and/or invertebrate species as MIS and that these species be monitored 

“in order to assess the effects of management activities on their populations and the 

populations of other species with similar habitat needs which they may represent” (FSM 

2620.5).

Approach to Impacts Analysis

The Safford Ranger District biologist evaluated direct, indirect, and cumulative effects of the 

proposed action on TES, FSS, and MIS and documented conclusions in a Biological Assessment 

and Evaluation (BAE), which is filed in the administrative record of the NEPA review (item

#178). For the analysis, the treatment area was defined as land on which management actions 

would take place, while the cumulative effects analysis area was defined to include all areas 

where indirect effects may occur, not merely those areas in which actions would take place. The 

cumulative effects analysis area, unless otherwise noted, includes state and/or adjacent private 

land. Each determination of effect reported in the BAE represents the overall expected effect of 

the proposed management actions on TES species.

The BAE was compiled using, but not limited to, the following information sources:

 a review of the literature related to the ecology of TES;

 

26 This list was updated in 2007. Regional Forester direction in a memo dated September 7, 2007, 

was that ongoing impacts analyses for which scoping was completed should continue to use the 

1999 list.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 85

 a review of the following documents: Mt. Graham Red Squirrel Recovery Plan, (U.S. 

Fish and Wildlife Service 1993); Mexican Spotted Owl Recovery Plan (U.S. Fish and 

Wildlife Service 1995); Final Designation of Critical Habitat for the Mexican Spotted 

Owl (U.S. Fish and Wildlife Service 2004); and the forest plan (USDA-FS, 1986, as 

amended);

 a review of Coronado National Forest TES, FSS, and MIS species records; and

 field evaluations of habitat conditions in and adjacent to the residence tracts.

Because of the complexity of issues related to Mt. Graham, in particular, threats to the viability of 

the Mt. Graham red squirrel, this impacts analysis is presented as follows: (1) the presence or 

absence of a TES is reported for each area of potential effect; (2) general information is presented 

for each TES; (3) direct and indirect effects on individual TES are reported separately, followed 

by a Section 7, ESA, determination of effect for the area; (4) effects on Forest Service Sensitive 

(FSS) species and Management Indicator Species (MIS) are discussed and evaluated; and (5) 

cumulative effects and determinations are reported.

Endangered Species Act Consultation

Section 7 of the Endangered Species Act (ESA) of 1973 requires Federal agencies to consult with 

the FWS on potential impacts to listed species and habitat before a proposed action is 

implemented. Section 7(a)(2) requires each Federal agency, in consultation with the Secretary, 

Department of the Interior, to ensure that any action it authorizes, funds, or carries out is not 

likely to jeopardize the continued existence of a listed species or result in the destruction or 

adverse modification of designated critical habitat. In fulfilling ESA requirements, each agency 

must use the best scientific and commercial data available. This section of the Act sets out the 

consultation process, which is further implemented by regulation (50 CFR §402).

”Formal” consultation with FWS is mandated if impacts to a species have the potential to be 

significant. As this was the case for the proposed action, the forest initiated formal consultation 

with the FWS on January 24, 2007. At that time, a BAE of potential impacts of the proposed 

action on the Mexican spotted owl (MSO) and its designated habitat; the Apache trout; and the 

Mt. Graham red squirrel (MGRS) was submitted for FWS review (project record, Item #178). A 

Biological Opinion (BO) regarding effects on the Mt. Graham red squirrel, Mexican spotted owl, 

and Apache trout was received from the FWS on August 18, 2008 (project record, item #196). In 

the 2008 BO, the FWS concurred with Forest Service determinations made in the BAE regarding 

effects to the MSO and trout and assigned “take” for the Mt. Graham red squirrel (MGRS). 

An update to the BAE was necessary in 2010 because of the introduction of the threatened Gila 

trout to streams within the area of potential effect of the proposed action. Earlier in 2008, the 

FWS issued guidance for management of Apache trout hybrids, such as those found in Ash, Frye, 

and Marijilda creeks in the Pinaleño Mountains (project record, item #198). The FWS stated that 

hybrid Apache trout "are not considered essential for recovery and therefore consultation is not 

required." The agency noted in this guidance that streams occupied by hybrid trout may be 

renovated and stocked with non-hybrid trout. With this in mind, the Gila Trout Recovery Team 

explored the possibility of introducing listed trout into Pinaleño Mountain streams. The team 

decided that introduction of the Gila trout would be more appropriate than Apache trout, given 

the former’s historic range. Since 2009, threatened Gila trout have been introduced into Ash and 

Frye Creeks. To address potential effects on an additional listed species, the Forest updated the 

BAE, finding that the proposed action "may affect, but would not likely adversely affect" the 
Chapter 3. Affected Environment and Environmental Consequences

86 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Gila trout. This determination was submitted to FWS on December 16, 2010. The Forest Service 

received concurrence in a letter dated May 6, 2011 (project record, item # 196).

The findings of both BAEs are discussed in the following sections. Copies of FWS concurrences

are provided in appendix C.

Federally Listed Threatened and Endangered Species

The project encompasses approximately 25 acres of mixed conifer in the Old Columbine area, 

and about 52 acres in the mixed conifer and pine-oak types in the Turkey Flat area. The mixed 

conifer areas mainly consist of Douglas-fir (Pseudotsuga menziesii), southwestern white pine 

(Pinus strobiformis), and ponderosa pine (Pinus ponderosa). In the Old Columbine area, the 

mixed conifer also includes invasive non-fire-adapted species from higher elevations, such as 

corkbark fir (Abies lasiocarpa var. arizonica) and Engelmann spruce (Picea engelmanii). The 

pine-oak types are dominated by ponderosa pine, mixed with Gambel oak (Quercus gambelii) and 

Emory oak (Quercus emoryi).

Table 16 summarizes Federally listed threatened and endangered species and habitat in the 

vicinity of both recreation residence tracts. Impacts to the jaguar, Mexican gray wolf, and bald 

eagle are not evaluated, because the species are not known to occur within or near either tract. 

Effects on the Apache trout are evaluated for the Old Columbine tract, but not Turkey Flat, 

because there are no streams in the latter tract.

Table 16. Federally Listed Threatened and Endangered Species Occurrence and Habitat in 

the Area of the Safford Ranger District Recreation Residence Tracts.

Species

(ESA* Designation)

Old Columbine Turkey Flat

Mt. Graham red 

squirrel

(Endangered)

Occurs near the analysis area; 

suitable habitat available nearby; 

potential suitable habitat within 

the tract.

Occurs near the analysis 

area; suitable habitat 

available within Upper 

Turkey Flat tract.

Mexican spotted owl

(Threatened)

Occurs within the analysis area; 

suitable habitat available.

Occurs within the 

analysis area; suitable 

habitat available.

Apache trout

(Threatened)

Occurs downstream of the 

analysis area.

Does not occur within the 

analysis area.

Gila trout

(Threatened)

Occurs downstream of the

analysis area.

Does not occur within the 

analysis area.

Jaguar

(Endangered) Does not occur within either analysis area.

Mexican gray wolf

(Endangered) Does not occur within either analysis area.

Bald eagle

(Threatened) Does not occur within either analysis area.

Arizona cliffrose**

(Endangered) Does not occur within either analysis area.

Chiricahua leopard 

frog**

(Threatened)

Does not occur within either analysis area.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 87

Species

(ESA* Designation)

Old Columbine Turkey Flat

Desert pupfish**

(Endangered) Does not occur within either analysis area.

Gila chub**

(Endangered) Does not occur within either analysis area.

Gila topminnow**

(Endangered) Does not occur within either analysis area.

Lesser long-nosed 

bat**

(Endangered)

Does not occur within either analysis area.

Ocelot**

(Endangered) Does not occur within either analysis area.

Loach minnow**

(Threatened) Does not occur within either analysis area.

Razorback sucker**

(Endangered) Does not occur within either analysis area.

Southwest willow 

flycatcher**

(Endangered)

Does not occur within either analysis area.

Spikedace**

(Threatened) Does not occur within either analysis area.

Desert tortoise, 

Sonora population**

(Candidate)

Does not occur within either analysis area.

Headwater chub**

(Candidate) Does not occur within either analysis area.

Northern Mexican 

gartersnake**

(Candidate)

Does not occur within either analysis area.

Roundtail chub**

(Candidate) Does not occur within either analysis area.

Yellow-billed 

cuckoo**

(Candidate)

Does not occur within either analysis area.

*ESA = Endangered Species Act

**These species are listed by Graham County, Arizona, as threatened and endangered. However, none of 

them occur within the project area or near enough to the project area to be impacted by the proposed action. 

The determination for all is "no effect", and no consultation was required.

Affected Environment, Mt Graham Red Squirrel (Tamiasciurus hudsonicus 

grahamensis)

Habitat

The endangered Mt. Graham red squirrel (MGRS) is one of 25 subspecies of red squirrels in 

North America. Its habitat is conifer forest, especially old-growth spruce-fir, Douglas-fir and 

mixed conifer. The only known population is found in the upper elevations of the Pinaleño 

Mountains. The MGRS was thought to have been extinct in the 1950s, but small numbers of 

squirrels were "rediscovered” in these mountains in the 1970s. The squirrel was added to the 
Chapter 3. Affected Environment and Environmental Consequences

88 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Federal endangered species list in 1987 by the FWS, after the estimated population in 1986 was 

observed to be less than 400. Loss of MGRS habitat resulted from past logging, and drought, 

insect infestations, and catastrophic fires have exacerbated the decline in population.27

Recreation residences at Old Columbine are located within MGRS habitat, and their continued 

existence precludes the restoration of natural vegetation that would provide squirrel habitat on 

approximately 77 acres of forest land. In addition, the presence of humans at the recreation 

residences increases the probability that individual squirrels may be accidentally injured or killed.

The MGRS inhabits a narrow selection of habitats, which include high-elevation areas with 

Douglas fir and Engelmann spruce trees, and the transition zone comprised of Douglas fir, 

corkbark fir, Engelmann spruce, southwestern white pine, and ponderosa pine. Current

information on red squirrel habitat on Mt. Graham reports that approximately 11,700 acres of 

coniferous forest are occupied (USDI-FWS, 1992, USDI-FWS, 1999). Recent studies by the 

Arizona Game and Fish Department (AGFD) indicate that approximately 16,680 acres of

“potentially suitable” habitat exists above 7,750 feet elevation (Hatten, 2000). Of occupied 

habitat, approximately 2,700 acres are considered excellent or good quality (USDI-FWS. 1999). 

Hatten (2000) estimated as much as 27,181 acres might be suitable as red squirrel habitat, but 

only a portion of this is occupied.

Approximately 1,900 acres of critical habitat was designated for the MGRS in 1990 (USDI-FWS,

1990; see Figure 10: MGRS Designated Critical Habitat). The areas determined to be critical 

habitat were based upon the fact that, at the time of listing of the species, these areas “contain[ed] 

major concentrations of the Mt. Graham red squirrel, and the habitat necessary to its survival, 

including cover, food sources, nest sites, and midden28 sites (USDI-FWS, 1990).” As such, the 

areas represent the highest elevations (i.e., those above 10,000 feet) in the Pinaleño Mountains, as 

well as slightly lower elevations on north facing slopes, which provide the cooler, moister 

surroundings necessary for successful midden sites. All of the spruce-fir vegetation association is 

included within the boundaries of critical habitat, along with a small portion of the mixed conifer.

The 25-acre tract at Old Columbine comprises 0.2 percent of the 11,700 acres on Mt. Graham

considered to be occupied by the MGRS (USDI-FWS, 1999), or 0.09 percent of the 27,181 acres 

considered to be suitable as MGRS habitat by Hatten (2000). The 52-acre Turkey Flat tract

represents 0.4 percent of the area considered as occupied by the MGRS (USDI-FWS, 1999), or 

0.2 percent of the area considered as suitable for occupancy by Hatten (2000). Neither recreation 

residence tract is located within designated critical habitat for the MGRS

Middens

Mt. Graham red squirrels create middens, which are areas that consist of piles of cone scales in 

which squirrels cache additional cones and other items as an over-wintering food source. Middens 

are typically located in areas with high-canopy closure near food sources (e.g., Douglas fir, 

corkbark fir, and Engelmann spruce trees). Such placement allows specific moisture levels to be 

maintained within the midden, thereby creating prime storage conditions for cones and other food 

items, such as mushrooms, acorns, and bones. The squirrel also prefers to establish middens in 

 

27 http://medusa.as.arizona.edu/graham/envir.html

28 In the animal kingdom, ground burrows, also known as middens, are used mostly for food 

storage.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 89

areas that have large snags or downed logs that provide cover and travel routes (USDI-FWS, 

1993).

All known squirrel midden locations in the vicinity of the recreation residence tracts, both 

historical and present, were considered in this impacts analysis to ensure a conservative analysis, 

i.e., one favoring protection of the species. An AGFD database of all midden locations found 

since 1996 served as the basis for the effects analysis, and all active, inactive, and disappeared 

middens were considered in the analysis.

Figure 10. Mt. Graham Red Squirrel Critical Habitat, as Designated in 1990, in Relation to 

Safford Ranger District Recreation Residence Tracts. Source: USDI-FWS, 1990.
Chapter 3. Affected Environment and Environmental Consequences

90 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Old Columbine tract: Several midden sites have been recorded in the past on the Old Columbine 

tract. According to the most recent information from AGFD, most of these are considered as 

having been “removed” from the database (Personal communication, Tim Snow, AGFD, with 

Anne Casey, Safford Ranger District, April 7, 2006). Classification as “removed” means that 

these middens have decomposed to the point that they no longer have any of the characteristics of 

active middens. That is, there is no mound of cone scales that provide an area for storing cones 

through the winter, no cone scales from recent feeding activities, and no signs the area has been 

used by a red squirrel for more than three survey periods.

Because three historic midden locations in the vicinity of the tract had not been surveyed recently, 

field surveys29 were completed on June 7, 2006. Two of the three middens were found to be 

active, and one had disappeared. Both of the active middens were located outside the residence 

area, with the closest being approximately 15 feet from an outhouse on the west side of the tract.

Turkey Flat tract: The Turkey Flat recreation residence tract lies at the edge of the mixed conifer 

vegetation association and leads downhill to a pine-oak association. The mixed conifer forest is 

generally suitable for middens mountain-wide. However, near this tract, habitat is dry and warm 

because of its aspect and elevation, which makes it less suitable for middens. The pine-oak 

association at Turkey Flat is also in a hot, dry area that is not at all suitable for middens.

Prior to 2008, no middens had been found within the 52-acre Turkey Flat tract. The closest 

midden was located more than 450 feet away from the nearest structure at Turkey Flat (a water 

tank), more than 700 feet from any of the residences, and about 250 feet higher in elevation than 

any of the residences. However, in the summer of 2008, during tree-marking for another project, 

the district biologist discovered an active midden on the Upper Turkey Flat recreation residence 

tract. The FWS was advised of this find (see appendix C) for its consideration in formal ESA 

consultation regarding the MGRS.

Population 

Issues that affect both habitat and population of the MGRS include predation; tree infestation by 

native and exotic insects (Koprowski et al., 2005); direct mortality; the loss of habitat and 

middens as a consequence of catastrophic wildland fire (Koprowski et al., 2006); human 

disturbance; road and trail traffic; use of recreation sites (USDI-FWS, 1992); loss or reduction of 

food sources because of drought; and potential competition with an introduced squirrel (Abert’s 

squirrel, Sciurus aberti) for food and territory (Edelman et al., 2005).

The Arizona Game and Fish Department (AGFD) and the Forest Service have conducted biannual 

population estimates of MGRS since 1986. (See Figure 11, MGRS Population Estimates). The 

spring 2004 MGRS census estimated a range of 284 ( 13) MGRS occupying the Pinaleño 

Mountains before the Nuttall Complex wildland fire.The fall 2004 census, conducted 

approximately 2 months after the Nuttall fire, reported a population estimate of 264 ( 12), 

showing a small decline attributed to direct mortality from the fire. A more notable decline was 

shown in the results of the spring 2005 census, which indicated a population size of 214 ( 12). 

This decline is believed to have resulted from latent indirect effects of the Nuttall fire, such as 

loss of cover, loss of food caches when middens were burned, and mortality of orphaned young 

 

29 Field surveys conducted by Ms. Anne Casey, Safford Ranger District Biologist, and Ms. Thetis 

Gamberg, FWS, Tucson. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 91

(Personal communication, J. Koprowski, University of Arizona,with Mt. Graham Red Squirrel 

Recovery Team, May 8, 2006). A rebound was shown by the fall 2005 census, which estimated 

276 squirrels ( 12). However, the spring 2006 census estimated a population of 199 squirrels (

15), almost a 10 percent decline from the previous spring count. The fall 2006 estimate 

rebounded to a population of 276 squirrels ( 12). In spring of 2007, the population was estimated 

to be 216 ( 12) squirrels, and was followed by another increase in the fall of 2007, when the 

population was estimated to be 299 ( 11) squirrels. In 2008, the spring and fall estimates were 

297 ( 11) and 263 ( 11), respectively. Methods for monitoring changed slightly in 2009, when 

FWS, AGFD, and the Forest Service agreed to switch to fall-only surveys. This change was made 

with the knowledge that signs of activity were more visible during the fall months (i.e., fresh 

digging, cached green cones for winter, etc.). The census results after this change were an 

estimate of 250 ( 11) in 2009, and 214 ( 12) in 2010. The chronology of MGRS estimates of 

population is depicted in figure 13 (AGFD, unpublished data).

Figure 11. Population Estimates for the Mt. Graham Red Squirrel Since 1986.

Environmental Consequences, Mt. Graham Red Squirrel

Direct and Indirect Effects, Alternative 1 – No Action

Old Columbine. Residences and improvements, such as water tanks and gas tanks, would be 

removed from this area in 2018, at the end of the 10-year permit closeout period. Henceforth, the 

natural vegetation would return in a series of successional stages, including a grassy stage, 

leading to a shrub stage, followed by the eventual growth of tree species. The mix of new growth
Chapter 3. Affected Environment and Environmental Consequences

92 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

would likely resemble the vegetation surrounding the recreation residence area, i.e., mostly mixed 

conifer.

Tree densities are quite high throughout the Pinaleño Mountains, and there are signs of densityinduced weaknesses, such as disease and susceptibility to insect infestation (Personal 

communication, Craig Wilcox, Safford Ranger District, Silviculturist, with Anne Casey, Safford 

Ranger District, Biologist, August 8, 2006; see also Gersonde and O’Hara 2005). It has been 

reported that decreased tree density, such as that which exists in the Old Columbine tract, may 

actually increase nutrients available for cone production in surrounding trees (Stoll and Schmid 

1998). Given this observation, it is possible that the increased density of trees that results from 

eventual reforestation at Old Columbine may not benefit the MGRS because it may reduce 

nutrients available to surrounding trees, thereby decreasing cone production and the squirrel’s 

food supply. If residence removal is combined with maintenance of open space on the tract, 

temporary short-term disturbances may be offset by long-term benefits.

Removal of residences would involve the intermittent use of noisy equipment and vehicles, 

ground disturbance, and human presence, all of which would temporarily disturb squirrels but 

would have insignificant or discountable impacts. Because of the proximity of an active midden 

near the outhouse, there is a possibility that removal activities could cause injury or death to a 

squirrel and/or any offspring present. If the outhouse is left standing, the midden would remain 

intact. However, the proximity of access roads and deconstruction of other buildings would 

continue to pose a danger to any foraging squirrel on the tract.

Turkey Flat. Considering the natural warmth and dryness on the Lower Turkey Flat tract, the 

removal of residences would not likely directly or indirectly affect the MGRS. In Upper Turkey 

Flat, the presence of the midden found in 2008 would result in similar impacts as those expected 

for removals in the Columbine area, including noise disturbance and possible injury or death. 

Further, vegetation similar to that which occurs presently would be expected to re-populate this 

tract; suitable habitat could be found in portions of Upper Turkey Flat, but Lower Turkey Flat 

would not be suitable as MGRS habitat.

Cumulative Effects of Alternative 1 on Mt. Graham Red Squirrel

Other developed areas across the mountain include the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. Each of 

these areas is located within a man-made opening in the forest that is maintained by regular 

removal of brush and hazard trees. All sites are within potential habitat for the red squirrel except 

for Ladybug, which is a dry pine-oak vegetation type.

Regular thinning and removal of brush at these additional sites continues to limit cover available 

for the MGRS. Also, removal of snags may decrease available nesting habitat and cache sites. In 

addition, occasional human presence at all sites may affect the squirrel foraging and nesting 

behavior.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural

role in ecological processes. Depending on the size of the trees thinned by these projects, a small 

amount of cover for squirrels would be lost. However, trees remaining in each treated stand 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 93

would receive additional nutrients, which will increase tree growth rates and cone production, 

both of which benefit the squirrel.

If the recreation residences are removed at the two tracts, vegetation at the sites would replenish 

through natural succession, and eventually, new habitat for the squirrel would become available. 

Therefore, the no-action alternative would have no adverse cumulative or additive effect with the 

other uses of the forest that affect squirrel habitat.

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) reduced the amount of MGRS foraging and nesting habitat in areas that burned at high 

intensities. While initial impacts were negative, the restoration of natural ecosystem processes 

will benefit forest health and the MGRS in the long term as cone crops increase in size and the 

forest becomes better adapted to wildland fire.

Wildfire use, large wildfires, and fire suppression are known to alter the composition of overstory

and understory trees that provide cover, nest sites, and food sources, either by fire damage and/or 

vegetation removal/cutting to create fire lines. On the other hand, fire creates a mosaic of 

vegetation seral stages, which releases nutrients to surrounding forested areas. Because fire is a 

randomly occurring event of unpredictable intensity and duration, the additive effects that it 

might have in combination with no action are impossible to quantify. However, in general, the 

damage caused by wildland fire on the two tracts, if unsuppressed, would likely be to reduce 

MGRS habitat by a maximum of 77 acres, or 0.3% of suitable habitat on the mountain. The 

reduction in habitat from creation of firelines would be discountable relative to the suitable 

habitat of 27,181 acres estimated by Hatten (2000).

No Action- Effects Determination, MGRS

Although the occupied area within the Old Columbine tract represents an extremely small portion 

of potential habitat and population of the MGRS, the fact that two squirrel middens and perhaps 

their occupant(s) may be impacted during residence removal at Old Columbine and Upper Turkey 

Flat indicates that no action “may affect, and is likely to adversely affect” the MGRS.

Direct and Indirect Effects, Alternative 2 – Proposed Action

Old Columbine. The MGRS using the active midden near the outhouse may be disturbed by 

human presence at the residences as well as other casual forest users. This midden site is in an 

area of unusually open canopy, and the midden and squirrel could be adversely affected by human 

disturbance because it lies on a slight slope and is easily accessible.

Ongoing research of the MGRS indicates that it has a lifespan of about three years, which allows 

it to breed only once (Personal communication, J. Koprowski, University of Arizona, with Mt. 

Graham Red Squirrel Recovery Team, May 8, 2006). Thus, when continuous use of a midden is 

observed, it does not always indicate that the resident squirrel is acclimated to human presence. 

What may happen when the microclimate is of high quality is that, when one resident is lost, 

another squirrel will use the midden.

Because of human presence near the active midden near the outhouse, the potential exists for 

accidental injury or death of a squirrel.

Turkey Flat. The MGRS in this area could potentially be disturbed by human presence, noise,

and local traffic, but the nearby midden would not be directly impacted. Indirect effects may 
Chapter 3. Affected Environment and Environmental Consequences

94 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

result from the need for fire suppression at the tract, and, therefore, the inability for Forest 

Service fire managers to use natural-ignition fires (i.e., lightning-caused fires) to burn areas that 

are historically adapted to fire. Because of human presence near the active midden near the 

outhouse, the potential exists for accidental injury or death of a squirrel.

Cumulative Effects of Alternative 2 on Mt. Graham Red Squirrel

Other developed areas across the mountain include the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. Each of 

these areas is located within a man-made opening in the forest that is maintained by regular 

removal of brush and hazard trees. All sites are within potential habitat for the red squirrel except 

for Ladybug, which is a dry pine-oak vegetation type.

Regular thinning and removal of brush at these additional sites continues to limit cover available 

for the MGRS. Also, removal of snags may decrease available nesting habitat and cache sites. In 

addition, occasional human presence at all sites may affect the squirrel foraging and nesting 

behavior.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural 

role in ecological processes. Depending on the size of the trees thinned by these projects, a small 

amount of cover for squirrels would be lost. However, trees remaining in each treated stand 

would receive additional nutrients, which will increase tree growth rates and cone production, 

both of which benefit the squirrel.

If the recreation residence permits are issued, the vegetation cover at each tract would remain the 

same. Therefore, the proposed action would have no adverse cumulative or additive effect with 

the other uses of the forest that affect squirrel habitat.

Recent wildland fires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) reduced the amount of MGRS foraging, caching, and nesting habitat in areas that burned 

at high intensities. While initial impacts were negative, the restoration of natural ecosystem 

processes will benefit forest health and the MGRS in the long term as cone crops increase in 

response to nutrient release and the forest becomes better adapted to wildland fire.

Wildfire use, large wildfires, and fire suppression are known to alter the composition of over- and 

understory trees that provide cover, nest sites, and food sources, either by fire damage and/or 

vegetation removal/cutting to create fire lines. On the other hand, fire creates a mosaic of 

vegetation seral stages, which releases nutrients to surrounding forested areas. Because fire is a 

randomly occurring event of unpredictable intensity and duration, the additive effects that it 

might have in combination with the proposed action are impossible to quantify. However, in 

general, the damage caused by wildland fire on the two tracts, if unsuppressed, would likely be to 

reduce MGRS habitat by a maximum of 77 acres, or 0.3% of suitable habitat on the mountain. 

The reduction in habitat from creation of firelines would be discountable relative to the suitable 

habitat of 27,181 acres estimated by Hatten (2000).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 95

Proposed Action- Effects Determination, MGRS

Although the occupied area within the Old Columbine tract represents an extremely small 

percentage of potential habitat and population of the MGRS, the fact that two squirrel midden 

sand perhaps their occupant(s) may be impacted by human presence at and near recreation 

residences at Old Columbine and Upper Turkey Flat supports a finding that the proposed action 

“may affect, and is likely to adversely affect” the MGRS. The FWS agreed with this finding in a 

BO issued August 18, 2008.The BO assigns a “take” of two squirrels, and reports that, “...this 

level of take is not likely to result in jeopardy to the species." 

The FWS issued a BO on April 30, 2012, that addresses the effects of the Coronado’s continued 

implementation of the Forest Plan. In it, the FWS stated that “under the terms of section 7(b)(4) 

and section 7(o)(2), taking that is incidental to and not intended as part of the agency action is not 

considered to be prohibited taking under the Act, provided that such taking is in compliance with 

the terms and conditions of this Incidental Take Statement.” (See appendix C).

Alternative 3 – Renew Turkey Flat Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as reported above 

under alternative 1.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above 

under the text for alternative 2.

Alternative 4 – Renew Old Columbine Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as those reported 

above under alternative 2.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above

under alternative 1. 

Affected Environment, Mexican Spotted Owl (Strix occidentalis lucida)

The Mexican spotted owl (MSO) occurs throughout Arizona and New Mexico, parts of Colorado 

and Utah, and south into Mexico. It is one of three subspecies of spotted owls; the others are the 

northern (S. o. caurina) and the California spotted owl (S. o. occidentalis). The Mexican 

subspecies is geographically isolated from both of the others.

Mexican spotted owls roost during day and hunt at dusk and at night. They breed primarily in 

dense old growth mixed conifer forests, ponderosa pine-Gambel oak forests, and riparian forests 

located on steep slopes, especially in deep, shady ravines (Fletcher and Hollis, 1994). Breeding 

sites have high canopy-closure, high basal area, many snags, and many downed logs. Owls 

usually nest in cavities about 80 feet up coniferous trees; however, they also use scrapes on cliff 

sites or abandoned platform nests. Pairs may not breed yearly. Incubation lasts from 28 to 32 

days. Males feed females and young until young are 2 weeks old. Young fledge in 34 to 36 days 

(Arizona Game and Fish Department, 2001).

Breeding season begins in late February or March, with juveniles fledging between mid-May and 

mid-June (USDI-FWS, 1995). Formal nighttime callback surveys are performed four times per 

year between May 1 and July 31 in each of four Protected Activity Centers (PACs; i.e., 600-acre 

areas identified around nesting areas) in the Pinaleños. If owl presence is confirmed within a 
Chapter 3. Affected Environment and Environmental Consequences

96 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

PAC, daytime surveys are performed to locate owl roosting and nesting sites. Owl nest sites are 

protected within “core areas”, which are composed of 100 acres of the highest-quality owl habitat 

surrounding the nest site.

Multistoried forest with many potential patches is desirable habitat for MSO foraging. Woodrats 

are the most frequently taken prey and provide most biomass. Birds, lagomorphs (rabbits), and 

insects are also frequently taken. In Arizona, range size for single owls averages 1,600 acres and 

combined home ranges occupied by pairs 2,000 acres (Arizona Game and Fish Department, 

2001).

Designated Critical Habitat

Critical habitat for the MSO in the Pinaleños was designated by the FWS in August 2004 (see 

Figure 12: MSO Critical Habitat). Primary habitat constituents for this subspecies include 

sections of spruce-fir forest, mature mixed conifer forest, pine-oak associations, riparian forests, 

and canyon habitats. Each of these include uneven-aged stands, snags and downed logs, canopy 

Figure 12. Mexican Spotted Owl Critical Habitat on the Safford Ranger District Relative to 

the Recreation Residence Tracts.

closure at or above 40 percent, and trees greater than or equal to 12-inch diameter at breast height 

(DBH), which are preferred characteristics for nesting. Owl recovery also depends upon 

maintenance of a diverse mosaic of habitats, including meadows and other open areas, for the 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 97

owls to have foraging grounds and a diverse prey base (USDI-FWS, 2004). Protected activity 

centers (PACs)30 and core areas within PACs (100-acre areas around nesting sites) were 

designated, based on recent protocol survey results (see Figure 13: MSO PACs).

Old Columbine 

The 25-acre Old Columbine tract is not within a PAC and comprises 0.02 percent of the critical 

habitat available for the MSO in the Pinaleño Mountains. In 2005, ESA consultation addressed 

the potential impacts of vegetation thinning on 8 acres at the southern portion of the tract 

(Consultation # AESO/SE 02-21-05-I-0818). The FWS determined that these 8 acres would be 

exempted from critical-habitat status.

Figure 13. Mexican Spotted Owl Protected Activity Centers (Pacs) on the Safford Ranger 

District Relative to Recreation Residence Tracts.

The other 17 acres of the tract, which comprise 0.015 percent of MSO critical habitat, consist of a 

mix of small meadows interspersed with recreation residences and pockets of mixed conifer 

vegetation of varying density. Primary constituent elements of critical MSO habitat exist in the 

northern portion of the tract, including the vegetation association, uneven-aged stand structure, 

high canopy closure, presence of downed logs, and a large number of trees greater than 12 inches 

DBH. Vegetation on the eastern and southeastern portions was treated recently by the removal of 

trees less than 9-inches DBH and pile-burning. Logs and snags over 9-inches DBH were retained. 

Wind-throw and insect infestations have opened the canopy. With regard to primary constituent 

 

30 600-acre areas in which owl nesting and foraging activities are focused
Chapter 3. Affected Environment and Environmental Consequences

98 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

elements, this area supports a few trees greater than 12-inches DBH, but canopy cover is fairly 

low, and there is little downed woody material. The western and southern parts of the tract 

contain a large meadow and several recreation residences that are surrounded by forest, with 

many trees greater than 12-inches DBH, and high canopy closure. There is a small amount of 

downed woody material available in this area.

A water tank at Old Columbine is located approximately 500 feet from the nearest core area in the 

Grant Vista PAC31. This core area has been surveyed eight times in the last 13 years. While 

surveys confirmed the presence of a single adult owl each time, there has never been confirmation 

of a pair or offspring. It is possible this area actually represents lower-quality habitat used by 

satellite animals rather than breeding pairs.

The core area of the Mill Site PAC has been surveyed eight times over the past 13 years, and no 

nest sites were found. However, the Mill Site PAC was occupied by a pair during seven seasons, 

and offspring were confirmed twice.

Ongoing spotted owl surveys may lead to changes in the mapping of core areas for a portion of 

the PACs in the Pinaleños. Should cores be found closer to the cabins than presently known, or 

should PAC boundaries be re-drawn based on more current data, consultation will be re-initiated 

with FWS.

Turkey Flat 

The Turkey Flat tract consists of 52 acres of land, which comprise 0.05 percent of the critical 

habitat available for MSO in the Pinaleño Mountains. In 2005, ESA consultation was completed 

with the FWS (# AESO/SE 02-21-05-I-0818) regarding potential impacts of vegetation thinning 

on MSO critical habitat on about two-thirds of this area (approximately 35 acres). The FWS 

determined that the 35-acre treatment area would be considered exempt from critical-habitat 

status. The remaining 17 acres comprise 0.02 percent of critical habitat available to the MSO on 

the tract.

Two acres of the Turkey Flat tract are designated MSO critical habitat and comprise 0.3 percent 

of the Turkey Flat PACs (see Figure 14: Turkey Flat MSO PACs). They are located around a 

water tank that supplies the recreation residences and include a small (less than 0.5 acre) open 

area that leads to the water tank. The area supports some of the primary constituent elements for 

MSO habitat, including the pine-oak association, uneven-aged stand structure, and canopy cover 

greater than 40 percent. It could be considered foraging habitat for MSO, although the size of

trees in the immediate area (most trees have a DBH less than 10 inches) would likely not provide 

nesting habitat.

The area around the Turkey Flat residences would likely provide good foraging habitat, however, 

nests have not been found there. Better nesting habitat is more likely to occur in the mixed conifer 

areas of the mountain. The Turkey Flat PAC has been surveyed 12 times since 1990 and has been 

considered occupied all but one time that it was surveyed.

The distance from the Turkey Flat tract to the nearest core area is approximately 1,000 feet, and 

the distance from the Turkey Flat water tank to the nearest known nest is 2,470 feet. A trail near 

the Twilight Spring area is more than 600 feet away from the nest.

 

31 Locations of PACs and core areas are not specifically identified to protect owls and nest sites.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 99

Ongoing spotted owl surveys may lead to changes in the mapping of core areas for a portion of 

the PACs in the Pinaleños. Should cores be found closer to the cabins than presently known, or 

should PAC boundaries be re-drawn based on more current data, consultation will be re-initiated 

with FWS.

Environmental Consequences, Mexican Spotted Owl

Alternative 1 – No Action, Direct and Indirect Effects

Old Columbine. During the removal phase, noise from equipment, ground disturbance, and 

human presence would occur intermittently for several months. Although no breeding birds have 

been reported in recent surveys, removal activities would be restricted during MSO breeding 

season.

Figure 14. Mexican Spotted Owl Protected Activity Centers (PACs) Relative to the Turkey 

Flat Recreation Residence Tract on the Safford Ranger District.

Following removal of residences and other improvements, such as water tanks and gas tanks, and 

the closure of access roads, nesting may occur in this area. However, it would take approximately 

60 to 80 years for the forest canopy to close sufficiently to become suitable MSO breeding 

habitat. In the long term, increases in primary constituent elements, such as increased number of 

large trees, accumulation of downed woody material, and increased canopy cover would be 

expected as natural succession occurs.
Chapter 3. Affected Environment and Environmental Consequences

100 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

While a future increase in the number of trees on the tract may provide new roosting sites, it may 

correspondingly decrease the mosaic of small mammal (prey) habitat available. Only a few 

studies have reported the effects of a decrease in forest openings on populations of small 

mammals32. The analysis in this EIS assumes that, if the creation of openings and other diversity 

in wildlife habitat causes an increase in small mammal species diversity and abundance, then the 

reduction in the diversity of wildlife habitats would cause a reduction in diversity and abundance. 

After residences are removed, wildland fire may be used for resource enhancement. Fire would 

help retain a mosaic of small mammal habitat.

Turkey Flat. Lower Turkey Flat is dry and flat, which may account for its open vegetation 

structure. Revegetation may provide additional trees for roosting, although alteration of the 

mosaic of small mammal habitat onsite may adversely affect the prey base of the MSO (Waters 

and Zabel 1998). Again, it should be noted that there is very little research on the effects on small 

mammals that are induced by the removal of forest openings. In the Upper Turkey Flat area, 

revegetation would follow the pattern described above for the Old Columbine site.

Following removal of residences and improvements, nesting may occur in this area. However, it 

would take approximately 60 to 80 years for the forest canopy to close sufficiently to become 

suitable MSO breeding habitat. In the long term, increases in primary constituent elements, such 

as increased number of large trees, accumulation of downed woody material, and increased 

canopy cover would be expected as natural succession occurs. After residences are removed, 

wildland fire may be used for resource enhancement. Fire would help retain a mosaic of MSO 

prey habitat on the tract.

Cumulative Effects

Other developed areas across the mountain include the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. Each of 

these areas is located within a man-made opening in the forest that is maintained by regular 

removal of brush and hazard trees. Regular thinning and removal of brush at these additional sites 

continues to limit cover available for MSO prey species. However, an increase in the mosaic of 

available habitat can also stimulate increased diversity of prey species, which can benefit the 

MSO. Removal of snags may decrease available nesting habitat. Occasional human presence can

also affect the MSO foraging and nesting behavior.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural 

role in ecological processes. NatureServe (2005) has recommended that initial steps for the 

recovery of the MSO subspecies focus on removal of wildfire threats and avoiding even-aged 

stand management practices. Depending on the size of the trees thinned by these projects, a small 

amount of cover for MSO prey species would be lost. However, trees remaining in each stand 

would receive additional nutrients, which will increase tree growth rates and cover, which should 

lead to increased availability and increased quality of MSO habitat in the future.

 

32 Ecke et al. 2002, Fisher and Wilkinson 2005, Tews et al. 2004, Waters and Zabel 1998,Wilcove 

et al. 1986; for a more complete discussion of landscape ecology and community dynamics, see 

Turner et al. 2001 or Garrett and Peles 1999.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 101

If the recreation residence permits are issued, the vegetation cover at each tract would remain the 

same. Therefore, the proposed action would have no adverse cumulative or additive effect with 

the other uses of the forest that affect MSO habitat.

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) reduced the amount of MSO foraging and nesting habitat in areas that burned at high 

intensities. While initial impacts were negative, the restoration of natural ecosystem processes 

will benefit forest health and the MSO in the long term as foraging habitat for its prey increases 

with a mosaic of vegetation associations and seral stages and the forest becomes better adapted to 

wildland fire.

Wildfire use, large wildfires, and fire suppression are known to alter the composition of over- and 

understory trees that provide cover, nest sites, and food sources, either by fire damage and/or 

vegetation removal/cutting to create fire lines. On the other hand, fire stimulates grass, forb, and 

shrub growth and creates a mosaic of vegetation seral stages, which may encourage increased 

diversity of MSO prey species.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the proposed action are impossible to quantify. 

However, in general, the damage caused by wildland fire on the two tracts, if unsuppressed, 

would likely be to reduce MSO habitat by a maximum of 77 acres. Lost habitat from creation of 

firelines would be discountable.

If the recreation residences are removed at the two tracts, vegetation at the sites would replenish 

through natural succession, and eventually, new habitat for the MSO may become available. 

Therefore, the no-action alternative would have no adverse cumulative or additive effect with the 

other uses of the forest that affect MSO habitat.

No Action- Effects Determination, MSO

Based on the above analysis, it was determined that the removal of the recreation residences at 

both Old Columbine and Turkey Flat “may affect, but is not likely to adversely affect” the MSO. 

It is also likely that the removal of recreation residences would benefit MSO habitat in the long 

term.

Alternative 2 – Proposed Action, Direct and Indirect Effects

Old Columbine. If permits are issued, human presence and noise may continue to disturb the 

MSO. Man-made openings (e.g., wood piles, grassy areas, shrubs near the edge of denser forest, 

and closed canopy areas) would continue to enhance the diversity of MSO prey species by 

offering a diversity of habitat. Openings also provide a release of nutrients to nearby trees, which 

may provide additional food sources for prey species.

If permits are issued and the tract continues to be occupied for another 20 years, there would be 

little change is vegetative cover. Therefore, changes in primary constituent elements of MSO 

critical habitat would not be expected.

Turkey Flat. If permits are issued, human presence and noise would continue to disturb the 

MSO. As this tract is fairly open and flat, nest sites are unlikely to be widely available (FWS 

1995). Man-made openings (e.g., wood piles, grassy areas, shrubs near the edge of denser forest, 

and closed canopy areas) would continue to enhance the diversity of MSO prey species by 
Chapter 3. Affected Environment and Environmental Consequences

102 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

offering a diversity of habitat. Openings also provide a release of nutrients to nearby trees, which 

may provide additional food sources for prey species.

No changes in vegetation would take place in the Turkey Flat area under this alternative; as a 

result, no changes in primary constituent elements of critical habitat would be expected.

Occasional increased occupancy of the residences may slightly increase hiking in the general 

area, but there are several natural features that limit the impacts that hiking may have on the MSO 

and its habitat. Because of the steep terrain that surrounds the flat area of the Turkey Flat tract, 

hikers would likely stay on the trail rather than walk in the direction of the documented nest site. 

In addition, because of the heavy cover in the upper portion of Turkey Flat, it is unlikely that 

hikers would notice a nest and be so curious as to approach it and investigate.

Cumulative Effects

Hiking. A concern was raised during the scoping of this NEPA review about the potential 

cumulative effects on nesting MSOs caused by forest users who hike near the residence tracts. 

These concerns may have arisen from research conducted by Swarthout and Steidl (2003), which 

concluded that the cumulative effects of high levels of short-duration recreation hiking near nests 

may be detrimental to MSO. In an earlier research paper, it was recommended a 72-foot buffer be 

established around nests documented along heavily used trails (Swarthout and Steidl 2001).

Because the number of recreation residences would remain the same, there is no expectation that 

total visitors to the tracts would significantly increase in the future. Use is expected within the 

Old Columbine tract a total of 50 - 60 days per year, and 30 - 40 days per year in the Turkey Flat 

tract (See chapter 3, recreation section).

Summer use of the recreation residence areas is generally light; however, residence owners 

occasionally have family gatherings of approximately 50 people, sometimes as frequently as 10 

times between April and November annually. Each gathering typically lasts no more than a day, 

with occasional higher than normal occupancy for a three-day weekend. Most users remain within 

the recreation residence tracts. However, some will hike during these gatherings. More than 90 

percent of those who hike will use existing trails (Personal communication, Sharon Wallace, Zone 

Recreation Specialist, with Anne Casey, Safford Ranger District, July 18, 2007).

A hiking trail from Old Columbine to the Webb Peak area does not lead to a core area. The Ash 

Creek trail from the Old Columbine tract parallels the length of the Mill Site PAC, but remains 

over 250 feet away from the core area, which was determined based on historical sightings and 

aerial photos of vegetation in the PAC. Because of the steepness of this trail, its use in areas over 

one mile from the residences is generally low (less than 20 people per day during the highest 

traffic) (Personal communication, Sharon Wallace, Zone Recreation Specialist, with Anne Casey, 

Safford Ranger District, July 18, 2007). Dense cover in this area makes it unlikely that hikers 

would spot a nest and approach to investigate.

Other Activities. Other developed areas across the mountain include the Arizona Bible Camp, 

the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each of these areas is located within a man-made opening in the forest that is

maintained by regular removal of brush and hazard trees. Regular thinning and removal of brush 

at these additional sites continues to limit cover available for MSO prey species. However, an 

increase in the mosaic of available habitat can also stimulate increased diversity of prey species, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 103

which can benefit the MSO. Removal of snags may decrease available nesting habitat. Occasional 

human presence at all sites may also affect the MSO foraging and nesting behavior.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural 

role in ecological processes. NatureServe (2005) has recommended that initial steps for the 

recovery of the MSO subspecies focus on removal of wildfire threats and avoiding even-aged 

stand management practices. Depending on the size of the trees thinned by these projects, a small 

amount of cover for MSO prey species would be lost. However, trees remaining in each stand 

would receive additional nutrients, which will increase tree growth rates and cover, which should 

lead to increased availability and increased quality of MSO habitat in the future.

If the recreation residence permits are issued, the vegetation cover at each tract would remain the 

same. Therefore, the proposed action would have no adverse cumulative or additive effect with 

the other uses of the forest that affect MSO habitat.

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) reduced the amount of MSO foraging and nesting habitat in areas that burned at high 

intensities. While initial impacts were negative, the restoration of natural ecosystem processes 

will benefit forest health and the MSO in the long term as foraging habitat for its prey increases

with a mosaic of vegetation associations and seral stages and the forest becomes better adapted to 

wildland fire.

Wildfire use, large wildfires, and fire suppression are known to alter the composition of overstory 

and understory trees that provide cover, nest sites, and food sources, either by fire damage and/or 

vegetation removal/cutting to create fire lines. On the other hand, fire stimulates grass, forb, and 

shrub growth and creates a mosaic of vegetation seral stages, which may encourage increased 

diversity of MSO prey species.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the proposed action are impossible to quantify. 

However, in general, the damage caused by wildland fire on the two recreation residence tracts, if 

unsuppressed, would likely be to reduce MSO habitat by a maximum of 77 acres. Lost habitat 

from creation of firelines would be discountable.

Proposed Action-Effects Determination, MSO

Based on the above analysis, it was determined that issuing of the residence permits for both Old 

Columbine and Turkey Flat tracts “may affect, but is not likely to adversely affect” the MSO. 

Renewal of the permits would result in discountable changes in vegetation of the tracts, and 

therefore, would not result in loss of any existing primary constituent elements of critical habitat. 

For this reason, permit renewal would have “no effect” on MSO critical habitat.

Alternative 3-Renew Turkey Flat Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as those reported 

above for alternative 1.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above 

for alternative 2.
Chapter 3. Affected Environment and Environmental Consequences

104 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Alternative 4-Renew Old Columbine Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as those reported 

above for alternative 2.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above 

for alternative 1.

Affected Environment, Apache trout (Oncorhyncus apache)

Earlier in 2008, the FWS issued guidance for management of Apache trout hybrids, such as those 

found in Ash, Frye, and Marijilda creeks in the Pinaleño Mountains (project record, item # 198). 

The FWS stated that hybrid Apache trout "are not considered essential for recovery and therefore 

consultation is not required." The agency noted in this guidance that streams occupied by hybrid 

trout may be renovated and stocked with non-hybrid trout. With this in mind, the Gila Trout 

Recovery Team explored the possibility of introducing listed trout into Pinaleño Mountain 

streams. The team decided that introduction of the Gila trout would be more appropriate than 

Apache trout, given the former’s historic range. Since 2009, Apache trout hybrids have been 

removed from these streams, and threatened Gila trout have been introduced into Ash and Frye 

Creeks (Consultation # AESO/SE 22410-2009-I-0313). Because Apache trout no longer occupy 

any portion of the action area, no further analysis for the Apache trout is deemed necessary.

Affected Environment, Gila trout (Oncorhyncus gilae)

These fish have yellow heads with black spots and a yellowish "cutthroat mark". The opercles are 

dark copper. They have a golden iridescence (sometimes metallic blue) on their backs and along 

their sides above the lateral lines. Their bodies are scattered with numerous dark spots 

(maximum, 30 per cm2), which are larger dorsally, and diminish in size toward the lateral line. A 

pinkish lateral band is present. The lower sides of their bodies are deep yellow, and their 

abdomens grayish white to pinkish orange. Dorsal fins are yellow, with the first three or four rays 

yellowish orange to white, with fine, dense, round or oval spots. The adipose and caudal fin are 

yellow with spots; anal fin is yellow with first five or six rays tipped with white, with the lower 

rays becoming reddish; and pectorals and pelvic fins are yellowish-orange, edged with white 

(Sublette et al. 1990).

Gila trout are found in moderate to high-gradient perennial mountain streams above 1,660 m 

(5,400 ft) elevation (FWS 2003). These streams are often associated with coniferous and mixed 

woodland, montane coniferous forest, and subalpine coniferous forest. These trout spawn in 

spring to early summer. Average growth leads to a size of 7.6-10 cm (3-4 in) in the first year of 

life, with maximum size being about 28-33 cm (11-13 in). They have been known to hybridize 

with non-native salmonids (AGFD 2002).

Gila trout have recently been introduced into two streams in the Pinaleño Mountains: Ash Creek 

and Frye Creek. These mountain streams are tributaries to the Gila River and are considered 

historical habitat for Gila trout and were identified as potential recovery streams in the recovery 

plan (FWS 2003). Source fish for the stockings came from the Mora National Fish Hatchery and 

Technology Center in New Mexico which currently produces Gila trout for recovery populations.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 105

Figure 15. Historic Distribution of Apache and Gila Trout. for the San Francisco 

form/lineage (B) trout. Other forms of Gila trout include the Gila River form (A), Eagle 

Creek (C), and Verde River (D) forms (slightly revised from USFWS 2003, with permission).

Gila trout are found in moderate to high-gradient perennial mountain streams above 1,660 m

(5,400 ft) elevation (FWS 2003). These streams are often associated with coniferous and mixed 

woodland, montane coniferous forest, and subalpine coniferous forest. These trout spawn in 

spring to early summer. Average growth leads to a size of 7.6-10 cm (3-4 in) in the first year of 

life, with maximum size being about 28-33 cm (11-13 in). They have been known to hybridize 

with non-native salmonids (AGFD 2002).

Gila trout have recently been introduced into two streams in the Pinaleño Mountains: Ash Creek 

and Frye Creek. These mountain streams are tributaries to the Gila River and are considered 

historical habitat for Gila trout and were identified as potential recovery streams in the recovery 

plan (FWS 2003). Source fish for the stockings came from the Mora National Fish Hatchery and 

Technology Center in New Mexico which currently produces Gila trout for recovery populations.

The main threats to the recovery of Gila trout are related to changes in habitat quality and 

suitability, hybridization and/or competition with non-native trout, as well as the effects of 

catastrophic wildfires. Changes in habitat quality are considered to be side effects of poor 

management related to grazing and logging practices, while the latter is considered a combined 

effect of poor grazing management and wildfire suppression (FWS 2003). Recent and ongoing 

field surveys by AGFD have indicated that these creeks, in which introductions of Gila trout are 

ongoing, are in excellent condition to provide suitable habitat, spawning habitat, sufficient 

perennial water, and food sources for Gila trout (Personal communication, Anne Casey, Safford 

District Biologist with Jason Kline, AGFD Fisheries Specialist II, 2008).

Environmental Consequences, Gila Trout

Adverse impacts to the Gila trout can occur when copious amounts of runoff degrade water 

quality by introducing sediment and pollutants. Significant concentrations of introduced sediment 

and pollutants may result in direct effects that cause injury or death, and indirect effects on 

aquatic flora and fauna that comprise food sources for the species.
Chapter 3. Affected Environment and Environmental Consequences

106 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Alternative 1 – No Action, Direct and Indirect Effects

Old Columbine

Cabins and the associated improvements, such as water tanks and gas tanks, would be removed 

from this area. The Forest Service would then gate the access roads and allow natural 

revegetation to occur. This species is placed at risk when large amounts of run-off are forced into 

streams. One negative effect is that the demolition phase would involve equipment that creates 

noise disturbance, smaller areas of flying debris, ground disturbance on and near cabin lots, and 

high human presence. Temporary physical results would likely include increased run-off until 

grasses and forbs could become established there, smoke and fumes from mechanized equipment, 

increased compaction of dirt in roads and driveway areas, and the presence of shards of manmade materials (e.g., glass and metals). In this particular area, there are wooded areas 

surrounding the cabin lots that should serve to reduce run-off due to demolition. There is also a 

large grassy patch in the center of the recreation residence tract, which would provide a ready 

source of grass and forb seeds to take hold in disturbed ground, increasing the rate of revegetation 

and minimizing the likelihood of runoff into nearby streams. Again, placement of the Gila trout 

population approximately a mile downstream from cabins would help to minimize the effects of 

this alternative. 

Cumulative Effects

Other developed areas across the mountain include the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. Each of 

these areas is located within a man-made opening in the forest that is maintained by regular 

removal of brush and hazard trees. The Heliograph and Ladybug sites are not within watersheds 

that support Gila trout habitat.

Grasses, shrubs and trees at these sites minimize erosion to the watershed and runoff to streams 

that support the Gila trout. Except for post-fire runoff, there is no evidence that erosion from 

these areas adversely affected the Apache trout in the past or the Gila trout at present. Recent 

wildland fires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex wildfire) 

reduced the amount of vegetation present and generated large quantities of ash that deposited in 

watersheds previously occupied by Apache trout. On the other hand, these fires have created a 

mosaic of vegetation seral stages, which improve watershed conditions in the long term, by 

increasing infiltration of water, decreasing overland erosion, and decreasing sheeting.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural 

role in ecological processes. Restoration of frequent, low-intensity fires will reduce the 

probability of the occurrence of a high-intensity fire and the consequent erosion and runoff it 

generates. This will, in turn, improve the quality of waters occupied by the Gila trout.

If the recreation residences are removed at the two tracts, vegetation at the sites would replenish 

through natural succession. Increased ground cover would reduce the degree of erosion from each 

tract. Best Management Practices would be followed during the removal phase of the project in 

order to prevent immediate erosion events. Therefore, the no-action alternative would have no 

adverse cumulative or additive effect with the other uses of the forest that may affect the Gila 

trout.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 107

No Action-Effects Determination, Gila Trout

The removal of recreation residences at the Old Columbine tract “may affect, but is not likely to 

adversely affect” the Gila trout. There is no habitat for Gila trout at Turkey Flat; therefore, there 

would be “no effect” on the species at this location.

Alternative 2 – Proposed Action, Direct and Indirect Effects

Old Columbine

The cabins would be renewed for a period of 20 years. All cabins and structures would remain in 

place. There is currently some utilization of the water coming from the Columbine Spring to 

provide water to cabins. If the cabins remain in place, this use will continue, but will not be 

allowed to increase without a separate review and approval process through the Forest Service 

special use program. Currently, there is no evidence that the trout are being adversely affected in 

any way by this use, possibly due to their location within Ash Creek, which begins approximately 

1 mile downstream from developed areas and continues down to the lower elevations of the 

mountain. 

Maintaining cabins in the area would not create additional run-off or siltation issues for the 

downstream population of Gila trout. Because no soil would be disturbed by cabins staying in the 

area, water quality and run-off would not be an issue. No new water quality issues would arise. 

Current information does not indicate that there are any current concerns about water quality 

effects in the area; however, it is possible that the dirt roads leading into and around the area may 

create some siltation into Ash Creek. There is no evidence that this caused harm to past 

hybridized Apache trout populations, and no evidence that it is currently causing harm to the Gila 

trout. This is not expected to change in the future.

Cumulative Effects

Other developed areas across the mountain include the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. Each of 

these areas is located within a man-made opening in the forest that is maintained by regular 

removal of brush and hazard trees. The Heliograph and Ladybug sites are not within watersheds 

that support Gila trout habitat.

Grasses, shrubs and trees at these sites minimize erosion to the watershed and runoff to streams 

that support the Gila trout. Except for post-fire runoff, there is no evidence that erosion from 

these areas adversely affected the Apache trout in the past or the Gila trout at present. Recent 

wildland fires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex wildfire) 

reduced the amount of vegetation present and generated large quantities of ash that deposited in 

watersheds previously occupied by Apache trout. On the other hand, these fires have created a 

mosaic of vegetation seral stages, which improve watershed conditions in the long term, by 

increasing infiltration of water, decreasing overland erosion, and decreasing sheeting.

Three vegetation thinning projects (see table 2, #10, 11, 24) are currently in the planning or 

implementation stages within the mountain range. These projects have a combined objective of 

restoring the vegetation component of the forest to a condition wherein fire will play a natural

role in ecological processes. Restoration of frequent, low-intensity fires will reduce the 

probability of the occurrence of a high-intensity fire and the consequent erosion and runoff it 

generates. This will, in turn, improve the quality of waters occupied by the Gila trout.
Chapter 3. Affected Environment and Environmental Consequences

108 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

If the recreation residence permits are issued, the vegetation cover at each tract would remain the 

same. Therefore, the proposed action would have no adverse cumulative or additive effects of the 

other uses of the forest that affect Gila trout habitat.

Proposed Action-Effects Determination, Gila Trout

Issuing new permits for residences on the Old Columbine tract “may affect, but is not likely to 

adversely affect” the Gila trout. There is no habitat for Gila trout at Turkey Flat; therefore, issuing 

the residence permits “may affect, but is not likely to adversely affect” the species.

Alternative 3 – Renew Turkey Flat Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as those reported 

above for alternative 1.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above 

for alternative 2. This alternative would have “no effect” on Gila trout.

Alternative 4 – Renew Old Columbine Only

Old Columbine. Direct, indirect, and cumulative effects would be the same as those reported 

above for alternative 2.

Turkey Flat. Direct, indirect, and cumulative effects would be the same as those reported above 

for alternative 1.This alternative “may affect, but is not likely to adversely affect” the Gila trout.

Forest Service Sensitive Species

Species Evaluated

Populations of each species designated by the Regional Forester as Forest Service sensitive (FSS) 

must be maintained at viable levels in habitats distributed throughout their geographic range on 

National Forest System lands (FSM 2670.22). The population viability of FSS species becomes a 

concern when downward trends in populations or habitat capability are predicted. When the 

Forest Service undertakes or approves an activity on National Forest System lands, the agency 

seeks to avoid or minimize impacts to FSS.

Table 17 lists the status of FSS on the Coronado, based on the FSS species listed by the 

Southwestern Regional Forester in 1999 33. Table text in gray indicates species for which impacts 

are evaluated in this EIS.

 

33 The FSS species list was updated on September 7, 2007. Region 3 issued accompanying 

guidance that “NEPA analyses for projects that have been through the scoping process and 

where issues have been identified are not required to utilize the revised list of sensitive species.” 

Thus, the analysis in this EIS is based on the July 21, 1999, Regional Forester list of FSS 

species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 109

Table 17. Habitat and occurrence of Forest Service Sensitive Species at Recreation 

Residence Tracts on the Safford Ranger District.

Species Name*

Turkey Flat Recreation 

Residence Area

Old Columbine Recreation 

Residence Area

MAMMALS

White-bellied longtailed vole

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Pinaleño pocket 

gopher Not within the analysis area.

Occurs within the analysis 

area; suitable habitat 

available.

Mexican long-tongued 

bat

Likely occurs near the 

analysis area; not likely to 

occur within tracts.

Not within the analysis area.

Allen’s lappet-browed 

bat

Likely occurs within the 

analysis area; suitable 

habitat available.

Occurs within the analysis 

area; suitable habitat 

available.

Pale Townsend’s bigeared bats

Likely occurs within the 

analysis area; suitable 

habitat available.

Not within the analysis area.

White-nosed coati

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Hooded skunk

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

BIRDS

Apache northern 

goshawk Foraging habitat available. Foraging habitat available.

Peregrine falcon Foraging habitat available. Foraging habitat available.

Common black-hawk Not within the analysis area. Not within the analysis area.

Flammulated owl

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Gould’s wild turkey

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

AMPHIBIANS

Lowland leopard frog Not within the analysis area. Not within the analysis area.

INVERTEBRATES

Pinaleño 

monkeygrasshopper Not within the analysis area.

Occurs within the analysis 

area; suitable habitat 

available.

A tiger beetle

(Amblycheila baroni)

Not within the analysis area. Not within the analysis area.

Aryxna giant skipper Not within the analysis area. Not within the analysis area.

Obsolete viceroy Not within the analysis area. Not within the analysis area.
Chapter 3. Affected Environment and Environmental Consequences

110 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Species Name*

Turkey Flat Recreation 

Residence Area

Old Columbine Recreation 

Residence Area

Chiricahua white 

butterfly

Occurs within analysis area; 

suitable habitat available.

Occurs within the analysis 

area; suitable habitat 

available.

Mountain silverspot 

butterfly

Occurs within analysis area; 

suitable habitat available.

Occurs within analysis area; 

suitable habitat available.

A tiger beetle 

(Cicindela purpurea 

cimerrona)

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Clark Peak talussnail Not within the analysis area. Not within the analysis area.

Mimic talussnail

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Pinaleño talussnail Not within the analysis area. Not within the analysis area.

Wet Canyon talussnail Not within the analysis area. Not within the analysis area.

Pinaleño mountainsnail Not within the analysis area. Not within the analysis area.

PLANTS

Chiricahua dock Not within the analysis area. Not within the analysis area.

Chiricahua rock cress

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Goodding’s onion

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Shade violet

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Coppermine milk vetch

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Mock pennyroyal

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Arizona alum root

Occurs within the analysis 

area; suitable habitat 

available.

Not within the analysis area.

Bigelow thoroughwort Not within the analysis area.

Occur within the analysis 

area; suitable habitat 

available.

Arizona giant sedge Not within the analysis area. Not within the analysis area.

Broad leaf ground cherry Not within the analysis area. Not within the analysis area.

Chihuahuan sedge Not within the analysis area. Not within the analysis area.

Chihuahuan stickseed Occurs within the analysis Not within the analysis area.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 111

Species Name*

Turkey Flat Recreation 

Residence Area

Old Columbine Recreation 

Residence Area

area; suitable habitat 

available.

Mexican broomspurge Not within the analysis area. Not within the analysis area.

Superb beardtongue Not within the analysis area. Not within the analysis area.

Pinaleño Jacob's 

ladder Not within the analysis area.

Occurs within the analysis 

area; suitable habitat 

available.

Rusby hawkweed Not within the analysis area.

Occurs within the analysis 

area; suitable habitat 

available.

White-flowered 

cinquefoil

Occurs within the analysis 

area; suitable habitat 

available.

Occurs within the analysis 

area; suitable habitat 

available.

Trans-Pecos Indian 

paintbrush Not within the analysis area. Not within the analysis area.

 *Species listed in bold are those that are known to occur in one or both recreation 

residence tracts.

Environmental Consequences, White-bellied Long-tailed Vole (Microtus 

longicaudus leucophaeus) 

The white-bellied long-tailed vole occupies high-elevation (6000 to 10,500 feet), grassy 

meadows, flats, areas along boggy stream bottoms and roadsides, cienegas34, and openings in 

coniferous forest. It builds runways through thick grass and steep slopes with bunchgrasses to 

provide easy access from its burrows to grassy food supplies, extending them under snow in 

winter. Nests of grass are built within the burrows, and burrow openings (about 2 inches in 

diameter) are found near logs, stumps, and clumps of vegetation (AGFD 2003).

This vole is active during the day and throughout the winter. At times, it is semi-aquatic. Grasses 

and green, succulent vegetation are primary components of its diet. It also eats grass seeds, the 

bark of willows and alders, roots and fungi. Owls (barn, great-horned, long-eared and shorteared), prairie falcons, weasels and martens are its known predators (AGFD 2003).

This subspecies occurs only in the Pinaleño Mountains; the current population appears to be 

stable. This vole is considered common in appropriate habitat (AGFD 2003). It occurs on both 

residence tracts.

No Action

With no action, meadow habitat may be lost as natural succession leads to a thickening of the 

shrub understory and eventual tree growth, the latter of which would increase canopy closure. 

Loss of open areas may make the tracts less suitable as vole habitat. However, there are several 

other meadows in the Pinaleños that provide excellent habitat for this species, including Hospital 

Flat, Chesley Flat, Peters Flat, and an area south of the Columbine administrative site. In addition 

to these established meadows, many smaller meadows and forest openings were created by recent 

 

34 A perennially wet area supported by a spring or other water source, also called "wetland," "marsh," or "swamp."
Chapter 3. Affected Environment and Environmental Consequences

112 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

wildland fires on the district. Given the availability of other vole habitat in the vicinity, the loss of 

less than 77 acres of vole habitat due to natural succession would not result in a trend toward 

Federal listing or loss of viability of the vole.

Proposed Action

If permits are issued for the tracts, onsite vegetation and human presence would remain the same. 

Habitat and population of the vole would not be changed by the proposed action.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by periodic removal of brush and hazard trees. This maintenance makes additional pockets of 

habitat available for these voles. In the long term, these pockets serve to improve the survival rate 

of the subspecies by dispersing its population over a broad area, which, in turn, makes individuals

less susceptible to mortality from large wildland fires or other random events.

Three thinning projects (see table 2 #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Thinning in the vicinity of the Turkey Flat tract may create new pockets of 

habitat for the vole.

Wildland fire and fire suppression can cause localized mortality of voles. On the other hand, 

although fire damages and destroys trees, this damage opens pockets of vole habitat. Wildland 

fire use and wildland fires also encourage regeneration of grasses and other plants that serve as a 

food source for voles.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex 

wildland fire) decreased vole habitat in areas that burned at high intensity. In moderately-burned 

areas, the reintroduction of fire as a natural process may promote more sustainable forest 

conditions and improve vole habitat in the long term.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the two tracts, if 

unsuppressed, could reduce vole habitat by 77 acres.

If the recreation residences are removed at the two tracts, vegetation at the sites would replenish 

through natural succession, and eventually, close existing pockets of vole habitat. Because other 

reasonably foreseeable actions on the mountain would have no adverse impacts to the vole and 

may actually improve vole habitat, the additive effects from no action would be offset. There 

would be no trend toward Federal listing or loss of viability of the species.

If the permits for the recreation residences are issued, the vegetation that comprises vole habitat 

would remain the same. Therefore, cumulative impacts from the proposed action would be 

discountable. There would be no trend toward Federal listing or loss of viability of the species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 113

Environmental Consequences, Pinaleño Pocket Gopher (Thomomys umbrinus 

grahamensis)

This pocket gopher, which inhabits alpine meadows and cienegas within coniferous forests from 

6000 to 10,000 feet in elevation, may occur on the Old Columbine tract. The species is generally 

associated with understory vegetation composed of perennial grasses (Festuca, Bromus) and 

various forbs, such as sneeze-weed (Helenium hoopesii). The overstory or adjacent forest 

includes spruce-fir and mixed conifer forest (Hoffmeister 1956).

No Action

If no action is taken and the Old Columbine residences are removed, the future natural succession 

of vegetation would likely decrease the availability and quality of gopher habitat, unless action is 

taken to conserve the meadow. However, the loss of less than 25 acres of gopher habitat is not 

likely to result in a trend toward Federal listing of the gopher or loss of viability of the species.

Proposed Action

If the proposed action is implemented, no vegetation or ground-disturbing activities would occur, 

and the Old Columbine meadow would continue to exist and provide habitat for this species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by regular removal of brush and hazard trees. Regular removal of brush maintains pockets of 

habitat for the gopher. These pockets may improve the long-term survival of the subspecies by 

dispersing its population over a broad area, which, in turn, would make individual gophers less 

susceptible to mortality from large wildland fires or other random events.

Wildland fire and fire suppression can cause localized mortality of gophers; however, fires also 

damages and destroys trees, which creates new pockets of gopher habitat. Fire also encourages 

regeneration of grasses and other plants that are food sources for gophers.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

likely decreased gopher habitat in areas that burned at high intensity. In moderately-burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest conditions and 

improve gopher habitat in the long term.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the Old Columbine tract, if 

unsuppressed, could reduce gopher habitat by 25 acres.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Removal of trees in the upper Turkey Flat tract may create pockets of new 

habitat for the gopher.
Chapter 3. Affected Environment and Environmental Consequences

114 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

If the recreation residences are removed at Old Columbine, vegetation at the site would replenish 

through natural succession, and eventually, close existing pockets of gopher habitat. Because 

other reasonably foreseeable actions on the mountain would have no adverse impacts to the 

gopher and may actually improve gopher habitat, cumulative impacts with no action would be 

discountable.

If the permits for the recreation residences are issued, the vegetation that comprises gopher 

habitat would remain the same. Therefore, cumulative impacts from the proposed action would be 

discountable.

Environmental Consequences, Mexican Long-tongued Bat (Choeronycteris 

mexicana) 

The Mexican long-tongued bat occupies mesic sites in mixed oak-conifer forest and semi-desert 

grasslands. Preferred roosting sites are rock formations, including mines, caves, and rock shelters; 

however, this species has also been found roosting in eroded clay soils and sinkholes. These bats 

feed mainly on nectar from the flowers of paniculate agave. They may also feed on pollen, 

probably insects, and the fruits of columnar cacti. Activity levels are highest from 1.5 to 3 hours 

after sunset (AGFD 2006). 

Threats to Mexican long-tongued bats include human disturbance, loss of riparian habitat, 

mining, and mine reclamation. Loss of food sources to development, grazing, and fire may also 

affect the species. This species occurs throughout southern California, southern Arizona, 

southwestern New Mexico, northern and central Mexico and the southern tip of Texas. The bats 

in southern Arizona represent the extreme northern edge of this bat’s range. Population trends for 

this bat are unknown (AGFD 2006).

These bats may be found in a broad range of elevations, varying from a low of 2,540 feet to a 

highest recording at 7,320 feet. Most of the locations in which they have been found occur 

between 4,000 and 6,000 feet. However, due to this highest-recorded elevation so closely 

approaching the elevation of the project, and the fact that this location was found along Swift 

Trail, the main road accessing the project, they are still included in this analysis. 

No Action

If the No Action alternative is selected, noise and human activities such as use of bulldozers and 

other heavy equipment used for cabin removals may cause disturbance to these bats in some 

areas, making them less suitable for these subspecies. Losses of food sources due to machinery 

use are expected to be minimal, due to high project elevation, and the preference for bats to use 

rock formations for roosting sites. The No Action alternative is not likely to result in a trend 

toward Federal listing or loss of viability.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Cabins would remain in place, with no changes. Because these bats use rock 

formations for roosting, no change is expected. A continued trend of increasing density of trees 

and other woody species may reduce the amount of habitat for their food resources; however, due 

to the high elevation of this project, loss of agaves will likely be discountable. The areas within 

this project will continue to have high potential for wildfires, which may affect the foraging 

habitat for Mexican long-tongued bats. However, because this bat occurs in several states and 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 115

throughout northern and central Mexico, it is possible that a partial loss of habitat in the high 

elevations of the Pinaleño Mountains would not result in a trend toward Federal listing or loss of 

viability of these subspecies on the Forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by regular removal of brush and hazard trees. Disturbance from brush removal might occur, but 

habitat features needed by these bats would likely remain unchanged, due to the lack of agaves at 

most of these sites.

Wildland fire and fire suppression can cause localized mortality of bats; however, fire also 

damages and destroys trees, which could create openings suitable for agave growth. 

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

mainly stayed in the higher elevations available in the Pinaleños. In moderate- and low-intensity 

burned areas, reintroduction of fire as a natural process may promote more sustainable forest and 

grassland conditions, which could improve overall bat habitat and sustainability in the long term.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. 

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. 

No impacts would result from the action alternative, as these bats would not be found at such high 

elevations. Due to the lack of large rock formations and agaves in the Turkey Flat tract, it is 

unlikely that long-term effects on this species would be noticed.

Environmental Consequences, Allen’s Lappet-browed Bat (Idionycteris phyllotis) 

Allen’s lappet-browed bats occupy a broad range of elevations, varying from a low of 1,320 feet 

to a high of 9,800 feet. Most of the locations in which they have been found occur between 3,500 

and 7,500 feet. Occupied vegetation associations include white fir, ponderosa pine, pinyonjuniper, Mexican woodland, Mojave desertscrub, and riparian areas of sycamores, cottonwoods 

and willows. Roosting has been associated with abandoned mine shafts and caves, and treeroosting has also been detected on the Apache-Sitgreaves and Coconino National Forests. These 

bats feed mainly on soft-bodied insects; recent studies have indicated use of moths, beetles, 

roaches, and flying ants. Activity levels are highest from 1.5 to 3 hours after sunset (AGFD 

2001). 

Threats and seasonal movements for these bats are relatively unknown. Maternity colonies are 

apparently fairly easily disturbed, and such disturbance may result in the abandonment of the 

roost. This species occurs throughout the central highlands of Mexico, to the Colorado River 

Valley of Arizona and the central-western portions of New Mexico. Population trends for this bat 

are unknown (AGFD 2001).
Chapter 3. Affected Environment and Environmental Consequences

116 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

No Action

If the No Action alternative is selected, noise and human activities such as use of bulldozers and 

other heavy equipment for cabin removals may cause disturbance to these bats in some areas, 

making them less suitable for these subspecies. Losses due to cabin removal operations are 

expected to be minimal, due to high project elevation. The proposed action is not likely to result 

in a trend toward Federal listing or loss of viability.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Because they can use rock formations for roosting, no change is expected with a lack 

of treatment. A continued trend of increasing density of trees and other woody species may 

eventually result in tree mortality; however, tree-roosting has been documented for this species, 

and use of snags may be possible as well. Increased canopy closure and density of trees may 

reduce the amount of habitat for their food resources; however, due to their preference of foraging 

over water, a fairly high density of insects would still be expected. The areas within this project, 

including riparian areas, will continue to have high potential for wildfires, which may affect the 

foraging habitat for Allen’s lappet-browed bats. However, because this bat occurs in two states 

and throughout the highlands of Mexico, it is possible that a partial loss of habitat in the Pinaleño 

Mountains would not result in a trend toward Federal listing or loss of viability of these 

subspecies on the Forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by regular removal of brush and hazard trees. Disturbance from brush removal might occur, and 

because lappet-browed bats can utilize trees for roosting, loss of live or hazard trees could remove 

potential roosting sites. However, there is an extremely high density of live trees and snags acroos 

this mountain range, and small-scale removals are unlikely to present a limiting factor for this 

species.

Wildland fire and fire suppression can cause localized mortality of bats. Recent wildland fires on 

the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) mainly stayed in the 

higher elevations available in the Pinaleños. In moderate- and low-intensity burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest and grassland 

conditions, which could improve overall bat habitat and sustainability in the long term. Highintensity burns would likely cause heavy damage to habitat components.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. 

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Each has some potential to removing roosting trees; however, as stated 

above, the density of trees and snags in this range is unlikely to be thinned to the extent that 

roosting sites would become a limiting factor.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 117

Minimal impact would be evident from either alternative, as vegetation removals for cabin 

protection in these areas are minimal and focus mainly on the removal of hazard trees. Removal 

of the cabins could cause some short-term disturbance, but likely would not cause long-term 

impacts.

Environmental Consequences, Pale Townsend’s Big-eared Bat (Corynorhinus 

townsendii pallescens) 

Pale Townsend’s big-eared bats occupy desertscrub, oak woodlands, and coniferous forests. 

Preferred roosting sites are open and airy, as opposed to cracks and crevices. These bats may use 

open ceilings within abandoned buildings, as well as rock formations (e.g., mines, caves, and rock 

shelters) and lava tubes. These bats feed mainly on insects, including moths, flies, bees, wasps, 

and beetles (AGFD 2003). 

Threats to pale Townsend’s big-eared bats include human disturbance, and vandalism of 

maternity and hibernation cave habitat, loss of roost sites due to mine closures, and deforestation 

of foraging habitats. This species occurs throughout Arizona, with all counties represented other 

than Greenlee and Apache counties. On a broader scale, they occur in southern California, 

Arizona, southwestern New Mexico, northwestern Texas, south-central Kansas, western 

Oklahoma, South Dakota, and the central highlands of northern Mexico. Population trends for 

this bat are suspected to be declining due to loss of roost sites in caves and mine shaft closures 

(AGFD 2003).

These bats may be found in a broad range of elevations, varying from a low of 550 feet to a 

highest recording at 8,437 feet. Most of the locations in which they have been found occur above 

3,000 feet (AGFD 2003). 

No Action

If the No Action alternative is selected, noise and human activities such as use of bulldozers and 

other heavy equipment used for cabin removals may cause disturbance to these bats in some 

areas, making them less suitable for these subspecies. The No Action alternative is not likely to 

result in a trend toward Federal listing or loss of viability.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Cabins would remain in place, with no changes. Because these bats use abandoned 

buildings and rock formations for roosting, no change is expected. Insect prey populations are not 

expected to be affected by this project. The areas within this project will continue to have high 

potential for wildfires, which may affect the foraging habitat for Pale Townsend’s big-eared bats.

However, because this bat occurs in several states and throughout northern Mexico, it is possible 

that a partial loss of habitat in the high elevations of the Pinaleño Mountains would not result in a 

trend toward Federal listing or loss of viability of these subspecies on the Forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by regular removal of brush and hazard trees. Disturbance from brush removal might occur, and 
Chapter 3. Affected Environment and Environmental Consequences

118 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

because big-eared bats can utilize trees for roosting, loss of live or hazard trees could remove 

potential roosting sites. However, there is an extremely high density of live trees and snags acroos 

this mountain range, and small-scale removals are unlikely to present a limiting factor for this 

species.

Wildland fire and fire suppression can cause localized mortality of bats. Recent wildland fires on 

the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) mainly stayed in the 

higher elevations available in the Pinaleños. In moderate- and low-intensity burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest and grassland 

conditions, which could improve overall bat habitat and sustainability in the long term. Highintensity burns would likely cause heavy damage to habitat components.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. 

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Each has some potential to removing roosting trees; however, as stated 

above, the density of trees and snags in this range is unlikely to be thinned to the extent that 

roosting sites would become a limiting factor.

Minimal impact would be evident from either alternative, as vegetation removals for cabin 

protection in these areas are minimal and focus mainly on the removal of hazard trees. Removal 

of the cabins could cause some short-term disturbance, but likely would not cause long-term 

impacts.

Environmental Consequences, White-nosed Coati (Nasua narica) 

White-nosed coatis mainly occupy riparian areas in oak and pine forests, occasionally ranging 

into desert areas, as well. They may be found from 1,667 feet up to 9,445 feet in elevation, 

though most sightings at intermediate altitudes. Coatis are both terrestrial and arboreal. They are 

omnivorous, and their diet consists mainly of invertebrates and fruit, though vertebrates and 

carrion are occasionally taken. In the United States, their predators likely include felids and 

raptors. Some intraspecific mortality occurs when adult males kill juveniles (Gompper 1995). 

Coatis are primarily diurnal, and in Arizona, they are thought to use rock dens and ledges. In 

areas where hunting pressure is intense, their activity patterns may alter to become slightly more 

nocturnal (Gompper 1995). 

Threats to coati populations may include human hunting pressure and use of poisons for predator 

control, a practice which led to the protection of coatis in New Mexico. This species occurs in 

southeastern Arizona, southwestern New Mexico, and throughout Mexico. The current 

distribution and breeding status within Texas is uncertain (Gompper 1995). Population trends for 

white-nosed coatis may have reached a peak in Arizona during the 1950s, after which widespread 

disease, possibly canine distemper, led to a drop in population numbers. Since then, an irregular 

increase in numbers has occurred (Kaufman et al. 1976). The species is currently considered 

stable in Arizona, but is listed by the State of Texas as endangered, and listed in New Mexico as 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 119

Imperiled and as a Species of Greatest Conservation Need (Biota Information System of New 

Mexico; http://www.bison-m.org/booklet.aspx?id=050165). 

No Action

If the No Action alternative is selected, noise and human activities such as use of bulldozers and 

other heavy equipment used for cabin removals may cause disturbance to coatis in some areas, 

making them temporarily less suitable for the species. The No Action alternative is not likely to 

result in a trend toward Federal listing or loss of viability.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Cabins would remain in place, with no changes. Because coatis are considered stable 

within Arizona, it is unlikely that this project will affect the overall state of the Arizona 

population. In addition, this project only occurs within the highest elevations of the Pinaleño 

Mountains; as such, there is still a large proportion of the mountain range that can continue to 

support coatis throughout the implementation period. The areas within this project will continue 

to have high potential for wildfires, which may affect the foraging habitat for coatis. Wildfire use 

and wildfires may also serve to encourage regeneration of grasses and other plants that may 

attract more insects, a potential food source for coatis. This alternative would not result in a trend 

toward Federal listing or loss of viability of this species on the Forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 

by regular removal of brush and hazard trees. Disturbance from brush removal might occur, some 

loss of food sources could occur if oak, locust, or raspberry bushes were removed. However, 

these small-scale removals are unlikely to present a limiting factor for this species.

Wildland fire and fire suppression can cause localized mortality of coatis. Recent wildland fires 

on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) mainly stayed in the 

higher elevations available in the Pinaleños. In moderate- and low-intensity burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest and grassland 

conditions, which could improve overall coati habitat and sustainability in the long term. Highintensity burns would likely cause heavy damage to habitat components.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. 

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Each has some potential to removing food sources, cover, and arboreal 

pathways; however, as stated above, the density of trees and snags in this range is unlikely to be 

thinned to the extent that these habitat components would become a limiting factor.
Chapter 3. Affected Environment and Environmental Consequences

120 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Impacts would likely be evident in the form of short-term movements of coatis to other, less 

disturbed areas, which are readily available near the two tracts. Nearby washes and riparian areas 

would provide some respite from noise and other human activities, while also providing rich 

sources of food and cover. Removal of the cabins could cause some short-term disturbance, but 

likely would not cause long-term impacts.

Environmental Consequences, Hooded Skunk (Mephitis macroura milleri) 

Hooded skunks mainly occupy arid lowlands, but they may also be found in deciduous or 

ponderosa forest, forest edges, pastures, rocky canyons, and riparian habitats. They are generally 

found from sea level up to 8,005 feet in elevation, though they have been found in Arizona as 

high as 8,600 feet. They are omnivorous, and their diet consists mainly of insects, fruits, small 

vertebrates and bird eggs. In the southern portions of their range, these skunks are hunted for 

meat or for their fat and scent glands (for use in folk medicines) (Hwang and Larivière 2001).

There is also some potential for these skunks to be taken as non-target mortalities as a result of 

animal damage control activities involving poison baits (Biota Information System of New 

Mexico; http://www.bison-m.org/booklet.aspx?id=050740#quicklinks). 

Hooded skunks are nocturnal, and sleep during the day in rock crevices, burrows, holes, and 

brushy bottoms. This species occurs in southwestern Texas, southwestern New Mexico, and 

southeastern Arizona, throughout Mexico into Guatemala, Honduras, Nicaragua, and into Costa 

Rica (Hwang and Larivière 2001). Populations are considered secure within Arizona (Biota 

Information System of New Mexico; http://www.bison-.org/booklet.aspx?id=050740#quicklinks).

No Action

If the No Action alternative is selected, noise and human activities such as use of bulldozers and 

other heavy equipment used for cabin removals may cause disturbance to skunks in some areas, 

making them temporarily less suitable for the species. Because hooded skunks are considered 

stable within Arizona, and disturbance will be temporary, the No Action alternative may impact 

some individuals of this species, but is not likely to result in a trend toward Federal listing or loss 

of viability.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Cabins would remain in place, with no changes. Because hooded skunks are 

considered stable within Arizona, it is unlikely that this project will affect the overall state of the 

Arizona population. In addition, this project only occurs within the higher elevations of the 

Pinaleño Mountains; as such, there is still a large proportion of the mountain range that can 

continue to support these skunks throughout the implementation period. The areas within this 

project will continue to have high potential for wildfires, which may affect the foraging habitat 

for skunks. Wildfire use and wildfires may also serve to encourage regeneration of grasses and 

other plants that may attract more insects, a potential food source for skunks. This alternative 

would not result in a trend toward Federal listing or loss of viability of this species on the Forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest that is maintained 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 121

by regular removal of brush and hazard trees. Disturbance from brush removal might occur, some 

loss of food sources could occur if oak, locust, or raspberry bushes were removed. However, 

these small-scale removals are unlikely to present a limiting factor for this species.

Wildland fire and fire suppression can cause localized mortality of coatis. Recent wildland fires 

on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) mainly stayed in the 

higher elevations available in the Pinaleños. In moderate- and low-intensity burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest and grassland 

conditions, which could improve overall skunk habitat and sustainability in the long term. Highintensity burns would likely cause heavy damage to habitat components.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. 

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Each has some potential to removing food sources and cover; however, as 

stated above, the density of trees and snags in this range is unlikely to be thinned to the extent that 

these habitat components would become a limiting factor.

Impacts would likely be evident in the form of short-term movements of skunks to other, less 

disturbed areas, which are readily available near the two tracts. Nearby washes and riparian areas 

would provide some respite from noise and other human activities, while also providing rich 

sources of food and cover. Removal of the cabins could cause some short-term disturbance, but 

likely would not cause long-term impacts.

Environmental Consequences, Apache Northern Goshawk (Accipiter gentilis 

apache)

This species is found throughout Arizona, generally in high-elevation, old-growth ponderosa pine 

and mixed-conifer forests, as well as plateaus. It breeds at elevations above 6000 feet, choosing 

Arizona pine and ponderosa pine for nest (eyrie) placement; from one to eight nests are built in 

March and early April. Short-distance foraging flights are taken from the nest to prey upon tree 

squirrel, rock squirrel, cottontail rabbit, band-tailed pigeon, mourning dove, Stellar’s jay, northern 

flicker, and Montezuma (Mearn’s) quail (AGFD 2003). Both tracts may be used for foraging 

throughout the year.

Goshawk populations are reported to have declined nationwide over the past 50 years. In the 

project area, populations are expected to decline slightly because of fire suppression, loss of prey 

habitat, insect and tree disease outbreaks, and loss of nesting habitat resulting from grazing 

(AGFD 2003).

No Action

No action would also, in the short term, result in noise and increased human presence, both of 

which may disturb foraging during removal activities. Goshawk foraging habitat may be lost as 

the tracts naturally revegetate. Natural plant succession would tend toward a thickening of the 

shrub understory and eventual tree growth, which would increase canopy closure and decrease 
Chapter 3. Affected Environment and Environmental Consequences

122 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

habitat for prey species. However, this loss would not likely result in a trend toward Federal 

listing or loss of viability of the species.

Proposed Action

If permits are issued for the tracts, onsite vegetation would remain the same. There would not be 

a trend toward Federal listing or loss of viability of the species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include the activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. This clearing of vegetation may create pockets of 

habitat for small mammals and birds that serve as prey for goshawks (Ecke et al. 2002, Fisher and 

Wilkinson 2005, Tews et al. 2004).

Wildland fire and fire suppression can cause localized mortality of goshawks, particularly when 

there are young in the nest. However, fire also damages and destroys trees, which provides new 

pockets of prey habitat. Wildland fire may also serve to encourage regeneration of grasses and 

other plants that serve as a food source for prey species.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

likely decreased goshawk prey habitat in areas that burned at high intensity. Although the initial 

impacts of fire are negative, it ultimately encourages the reestablishment of a mosaic of 

vegetation associations and seral stages that improve habitat for prey species in the long term.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the two tracts, if 

unsuppressed, could reduce goshawk foraging habitat by 77 acres.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Thinning would create additional areas of habitat for goshawk prey species.

If the recreation residences are removed at both tracts, vegetation at the sites would replenish 

through natural succession, and eventually, close existing pockets of habitat for goshawk prey 

species. Because other reasonably foreseeable actions on the mountain would have no adverse 

impacts to the goshawk and may actually improve habitat for its prey, cumulative impacts from 

no action would be discountable. There would not be a trend toward Federal listing or loss of 

viability of the species.

If the permits for the recreation residences are issued, the vegetation that comprises goshawk prey 

habitat would remain the same. Therefore, cumulative impacts from the proposed action would be 

discountable. There would not be a trend toward Federal listing or loss of viability of the species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 123

Environmental Consequences, Peregrine Falcon (Falco perigrinus anatum)

The peregrine falcon is both a FSS and MIS. Although it was a Federally listed endangered 

species when designated in the forest plan as an MIS, the falcon was delisted in 1999. Populations 

have increased markedly since organochloride (DDT) pesticide use was banned in the United 

States (USDA 2005).

This species requires cliffs or cliff-like areas for nesting and feeds mainly on birds, with a lesser 

diet of mammals, amphibians, and insects (White et al. 2002). Both tracts may be used for 

foraging throughout the year, by wintering or migrating individuals and by individuals from 

nearby (off-tract) active eyries (high nests) during the breeding season. The primary threat to the 

viability of the species is disturbance of nest sites by recreational rock-climbers and other users. 

In addition, ground-disturbing activities and/or other loud noise during the nesting season (March 

1 to July 15) may affect reproductive success (USDA 2005).

No Action

Over the long term, removal of residences would change both the diversity and abundance of 

falcon prey species, because succession would alter species composition and structure on the 

tracts. No action would also, in the short term, result in noise and increased human presence, 

which may disturb foraging during removal activities. However, the loss of a small amount of 

prey habitat and temporary disturbance at the tracts is not likely to result a trend toward Federal 

listing or loss of viability of the peregrine falcon.

Proposed Action

If the proposed action is implemented, no vegetation removal or ground-disturbing activities 

would occur at either tract. Thus, the diversity of prey species habitat would be maintained. No 

additional disturbance is expected in the vicinity of active eyries, therefore, no impacts on nesting 

birds are likely to occur. There would not be a trend toward Federal listing or loss of viability of 

the species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening that is maintained by periodic 

removal of brush and hazard trees. This may create pockets of habitat for small mammals and 

birds that serve as prey for goshawks. Because the falcon uses a wide variety of vegetation types, 

including those modified by humans (White et al. 2002), the openings and human presence are 

not likely to deter its use of the tracts.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages within the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The falcon may temporarily avoid using treatment areas because of human 

presence and noise. Because no activities would be undertaken near eyries, where peregrines are 

most susceptible to disturbance (White et al. 2002), thinning activities would not likely result in 

the abandonment of nests.
Chapter 3. Affected Environment and Environmental Consequences

124 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Wildland fire and fire suppression damage or destroy overstory trees that provide cover. However, 

fires also stimulate grass, forb, and shrub growth and create a mosaic of vegetation seral stages, 

which encourage increased diversity of prey species.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire), 

the Santa Catalina Ranger District (Aspen and Bullock fires), and the Nogales District (Florida 

Fire) likely decreased peregrine foraging habitat in areas that burned at high intensity. Although 

the initial impacts of fire are negative, it ultimately encourages the reestablishment of a mosaic of 

vegetation associations and seral stages that improve habitat for prey species in the long term.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the two tracts, if 

unsuppressed, could reduce foraging habitat by 77 acres.

If the recreation residences are removed at both tracts, vegetation at the sites would replenish 

through natural succession, and eventually, close existing pockets of habitat for prey species. 

Because other reasonably foreseeable actions on the mountain would have no adverse impacts to 

the falcon and may actually improve habitat for its prey, cumulative impacts from no action 

would be discountable. There would not be a trend toward Federal listing or loss of viability of 

the species.

If the permits for the recreation residences are issued, foraging habitat would remain the same. 

Therefore, cumulative impacts from the proposed action would be discountable. There would not 

be a trend toward Federal listing or loss of viability of the species.

Environmental Consequences, Flammulated Owl (Otus flammeolus)

The tiny flammulated owl (its length is 6 inches) is found in arid pine forests, often intermixed 

with oaks, and almost always with a brushy understory. Other tree species where the owl occurs 

include piñon pine, white fir, and, most often, Douglas-fir. The owl has been observed at 

elevations ranging from 5000 to 8000 feet in Arizona, is not usually found in low elevation pineoak or in spruce-fir, and generally inhabits transitional zones and large canyon bottoms (AGFD 

2005). Any pine and oak within the residence tracts is considered potential habitat. The owls 

forage for large insects, moths, and beetles (AGFD 2005).

Population trends for this species are unknown (AGFD 2005). Flammulated owl calls have been 

noted during previous Mexican spotted owl surveys within the project area (USDA-FS, 

unpublished data).

Logging is the primary threat to this species, and it is quite sensitive to insecticides. It is a 

secondary cavity nester, using openings created by primary cavity nesters for breeding (AGFD 

2005).

No Action

If residences are removed, tree species composition on the tracts would change because of natural 

succession. This would likely provide additional owl habitat in the long term. It would not result 

in a trend toward Federal listing or loss of viability of the species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 125

Proposed Action

If the permits for the recreation residences are issued, owl habitat would remain the same. The 

proposed action may result in disturbance to owls during periods of extended human presence, 

but this is not likely to result in a trend toward Federal listing or loss of viability of the species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. Brush removal may remove some of the cover 

available to this species. Also, removal of snags could reduce the amount of nesting habitat 

available. Some human disturbance likely occurs in these areas when residences are being used.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. NatureServe (2005) has recommended that forests be thinned and burned to 

restore historic habitat conditions for this species. Thus, these activities would enhance owl 

habitat in the vicinity of the residence tracts.

Wildland fire and fire suppression may damage or destroy over- and understory trees that provide 

cover. Although the initial impacts of fire are negative, it ultimately encourages the 

reestablishment of a mosaic of vegetation associations and seral stages that improve habitat for

prey species in the long term. Recent wildland fires on the Safford Ranger District (Clark Peak 

Fire and Nuttall Complex Fire) likely decreased foraging and nesting habitat in areas that burned 

at high intensity.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the two tracts, if 

unsuppressed, could reduce foraging habitat by 77 acres.

If the recreation residences are removed at both tracts, vegetation at the sites would replenish 

through natural succession, and eventually, close existing pockets of habitat for prey species. 

Because other reasonably foreseeable actions on the mountain would have no adverse impacts to 

the owl and may actually improve habitat for its prey, cumulative impacts from no action would 

be discountable and would not result in a trend toward Federal listing or loss of viability of the 

species.

If the permits for the recreation residences are issued, foraging habitat would remain the same. 

Therefore, cumulative impacts from the proposed action would be discountable and would not 

result in a trend toward Federal listing or loss of viability of the species.

Environmental Consequences, Gould’s Wild Turkey (Meleagris gallopavo 

mexicana)

Gould’s turkey is listed as both a FSS and MIS. The Pinaleño population was reintroduced in 

2004, followed by an additional release in spring of 2005. The population has improved 

incrementally with the addition of wild-born poults (Personal communication, Anne Casey, 
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126 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Safford District Biologist, with Duane Aubuchon, AGFD, June 15, 2007). AGFD reports recent 

observations of the Pinaleño population in the lower-elevation Grant and Moonshine Creek areas, 

and during the Nuttall fire, they were observed at a higher elevation (507 Road) (AGFD, 

unpublished data).

This species forages on spring forbs and grasses, insects; and the fruits of juniper, Vitis spp. 

(grapes), and manzanita. It commonly roosts in pine, oak, sycamore, and cottonwood. The species 

generally occupies pine, pine-oak, and piñon pine-juniper habitat (Eaton 1992). Sustainability of 

the Pinaleño population is most likely to be influenced by weather/climate changes and nesting 

success in the project area (USDA 2005).

No Action

If residences are removed, vegetation composition on the tracts would change because of natural 

succession. This may provide additional turkey habitat in the long term. It would not result in a 

trend toward Federal listing or loss of viability of the species.

Proposed Action

If permits are issued, vegetation would remain the same on both tracts. This would not have an 

effect on turkey habitat and would not likely to result in a trend toward Federal listing or loss of 

viability of the species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. These sites provide openings that, in many areas, 

encourage the growth of grasses, forbs, and shrubs, including berry bushes and locust trees that 

are a food source for turkeys. Intermittent human presence also occurs in these areas; however, 

Gould’s turkeys are regularly seen in and around these sites.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The Pinaleño Ecosystem Management (PEM) project (# 10) and special-use 

area thinning project (#24) are focused solely on the understory of the forest, i.e., the removal of 

trees up to 9 inches DBH. Because of this, some cover would be lost. On the other hand, cleared 

areas would provide better foraging for seeds and insects. Trees that remain in thinned stands 

would receive additional nutrient release, which increases trees growth rates and mast production. 

Larger trees that remain in thinned stands would provide excellent turkey roosting sites. A few 

large-diameter trees would be removed in the Turkey Flat area, which may stimulate understory 

shrub growth and provide foraging habitat.

Wildland fire and fire suppression can damage or destroy overstory trees that provide cover for 

the turkey. However, fires also stimulate grass, forb, and shrub growth when the canopy is 

opened, providing additional food sources.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire), 

the Santa Catalina Ranger District (Aspen and Bullock fires), and the Nogales District (Florida 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 127

Fire) probably decreased turkey habitat in areas that burned at high intensity. During 

implementation of the Stockton Pass prescribed fire in 2007, turkeys were observed flying in and 

out of burning areas to forage for insects flushed by the fire. Thus, in moderately-burned areas, 

turkeys may have received immediate foraging benefits from the fire.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire on the two tracts, if 

unsuppressed, could reduce habitat by 77 acres. There would not likely be a trend toward Federal 

listing or loss of viability of the species.

If the recreation residences are removed at both tracts, vegetation at the sites would replenish 

through natural succession, ultimately closing areas presently open to foraging. The loss of less 

than 77 acres of open area would be discountable when considered in combination with the 

improvements in habitat resulting from other actions in the area. Thus, there would not be a trend 

toward Federal listing or loss of viability of the species.

If the permits for the recreation residences are issued, habitat at Old Columbine would remain the 

same. Therefore, cumulative impacts from the proposed action would be discountable and would 

not result in a trend toward Federal listing or loss of viability of the species.

Environmental Consequences, Pinaleño Monkey Grasshopper (Eumorsea 

Pinaleño )

Very little is known about this species; only four specimens have been collected on the forest. It is 

believed to occupy the same habitat as the Mt. Graham red squirrel, including old-growth 

Douglas-fir stands (AGFD 2001). It may occur in and around Old Columbine habitat. Population 

trends are unknown (AGFD 2001).

No Action

If the residences are removed, grasshopper habitat would gradually improve as succession returns 

the vegetation on 25 acres of Old Columbine to a natural state.

Proposed Action

If the proposed action is implemented, vegetation on Old Columbine would remain the same. 

Human disturbance would not adversely impact the grasshopper, except for maybe a lucky catch 

by a pet cat. There would not be a trend toward Federal listing or loss of viability of the species.

Cumulative Impacts

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. At present, these openings are not suitable habitat for 

the grasshopper.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 
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128 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

ecological processes. The PEM project (# 10) is focused solely on the understory of the forest, 

i.e., removal of trees up to 9 inches DBH. Because of this, cover for grasshoppers would be lost. 

However, forest structure after treatment would be more resilient to wildland fire, and the longterm result would be a more sustainable habitat. A few larger-diameter trees would be removed in 

the Turkey Flat area, which may create small openings that are unsuitable for these grasshoppers.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

likely decreased grasshopper habitat in areas that burned at high intensity. In moderately-burned 

areas, reintroduction of fire as a natural process may promote more sustainable forest conditions 

and improve the health of occupied habitat.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by wildland fire at Old Columbine, if 

unsuppressed, could reduce grasshopper habitat by 25 acres.

If the recreation residences are removed, vegetation at Old Columbine would replenish through 

natural succession, and suitable grasshopper habitat may return. This would be an additive benefit 

when considered cumulatively with other nearby activities.

If the permits are issued for Old Columbine, vegetation and habitat would remain the same. There 

would be no additive impacts that would result in a trend toward Federal listing or loss of 

viability of the grasshopper.

Environmental Consequences, Chiricahua White Butterfly (Neophasia terlootii)

This butterfly occupies the high-elevation pine forest, usually above 6200 feet. Eggs are laid on 

ponderosa pine and Engelmann spruce, where the larvae eat the leaves. Population trends for this 

species are unknown, but it may occur on both tracts (AGFD 2001).

No Action

If no action is taken, there is a potential benefit to butterfly habitat in the long term as the tracts 

become reforested.

Proposed Action

If the proposed action is implemented, vegetation on the tracts would remain the same. Thus, 

there would be no impact on the butterfly and no trend toward Federal listing or loss of viability 

of the species.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. These openings do not support suitable habitat for the 

butterfly; human disturbance at these sites is intermittent.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 129

ecological processes. The PEM project (# 10) is focused solely on the understory of the forest, 

i.e., removal of trees up to 9 inches DBH. Because of this, cover for butterflies would be lost. 

However, forest structure after treatment would be more resilient to wildland fire, and the longterm result would be more sustainable habitat. A few larger-diameter trees would be removed in 

the Turkey Flat area, which may create openings that are unsuitable for Chiricahua white 

butterflies.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

likely decreased butterfly habitat in areas that burned at high intensity. In moderately-burned 

areas, reintroduction of fire as a natural process may promote more sustainable forest conditions 

and improve the health of occupied habitat. Because fire is a randomly occurring event of 

unpredictable intensity and duration, the additive effects that it might have in combination with 

the no action or the proposed action are impossible to quantify. However, in general, damage 

caused by wildland fire at both tracts, if unsuppressed, could reduce potential butterfly habitat by 

77 acres.

If the recreation residences are removed, vegetation at both tracts would replenish through natural 

succession, and new butterfly habitat may return. This would be an additive benefit when 

considered cumulatively with benefits of other nearby activities.

If the permits are issued for Old Columbine, vegetation and habitat would remain the same. There 

would be no additive impacts that would result in a trend toward Federal listing or loss of 

viability of the butterfly.

Environmental Consequences, Mountain Silverspot Butterfly (Speyeria nokomis 

nitocris)

This subspecies of butterfly occupies alpine meadows (AGFD 2002), and has been found at 

elevations ranging from 5,400 to 8,500 feet (Ferris and Fisher 1971). They may also occupy moist 

meadows, seeps, marshes, and springsides (Butterflies and Moths of North America; 

http://www.butterfliesandmoths.org/species?l=1678). Females likely spend time on the ground, 

laying single eggs at the base of host plants, which are thought to be Viola nephrophylla, the 

northern bog violet (AGFD 2002, Butterflies and Moths of North America; 

http://www.butterfliesandmoths.org/species?l=1678). Adults feed on various species of red 

thistles (Ferris and Fisher 1971).

This subspecies is found in Arizona, New Mexico, and Colorado (AGFD 2002). It is listed by the 

U.S. Fish and Wildlife Service as a Species of Concern (Biota Information System of New 

Mexico; http://www.bison-m.org/booklet.aspx?id=214840#quicklinks). Threats may include the 

draining of moist habitat sites and development (Butterflies and Moths of North America; 

http://www.butterfliesandmoths.org/species?l=1678).

No Action

The no action alternative would call for removal of the cabins, which would likely result in 

succession and encroachment of woody species, thereby decreasing habitat quality for the 

species. While trampling may occur in both of the alternatives, the proposed action and no action 
Chapter 3. Affected Environment and Environmental Consequences

130 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

alternatives are not likely to result in significant population changes, nor a trend toward Federal 

listing or loss of viability of the species.

Proposed Action

If the proposed action is implemented, there is not likely to be a change in the habitat available to 

this species. Cabins would remain in place, and as a result, small openings around the cabins 

would be maintained. While trampling may occur in both of the alternatives, the proposed action 

and no action alternatives are not likely to result in significant population changes, nor a trend 

toward Federal listing or loss of viability of the species.

Cumulative Effects

Developed areas exist across the Mountain, including the Arizona Bible Camp, the astrophysical 

site, Heliograph and Ladybug electronic sites, recreation sites, and administrative sites. These 

areas all occur within small human-caused openings that are maintained by some removal of 

brush and hazard trees. These openings likely represent additional habitat for this subspecies. 

Some human disturbance also occurs in these areas. Wildfire use, large wildfires, and fire 

suppression may lead to removal of overstory trees through burning or removal as part of a 

fireline; these openings can create new patches of habitat for this species.

Three thinning projects (e.g., PERP, PEM and SUP) are currently in the planning or 

implementation stages within this mountain range. The PERP project will remove trees of varying 

diameters in a range up to 18 inches in diameter at breast height (dbh), with some additional 

treatments with prescribed fire and/or pile burning. The PEM project focused solely in the 

understory of the Forest, removing trees up to 9 inches in diameter at breast height (dbh). The 

SUP project will be focused in areas that fall within 300 feet of cabin or electronic sites, and 

focus mainly in the understory of the Forest as well. Some larger trees will also be removed in the 

Turkey Flat recreation residence area. Some areas of each of these treatments may serve as new 

openings to provide habitat for mountain silverspot butterflies. 

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) may have created new pockets of habitat in areas that were burned at high fire 

intensities. In more moderately-burned areas, reintroduction of fire as a natural process may 

create small openings that serve as habitat, and promote more sustainable forest conditions and 

improved health of occupied habitat.

If the recreation residences are removed, vegetation at both tracts would replenish through natural 

succession, and new butterfly habitat may return, particularly if fire was incorporated as a 

maintenance tool in these areas. This would be an additive benefit when considered cumulatively 

with benefits of other nearby activities.

If the permits are issued for Old Columbine, vegetation and habitat would remain the same. There 

would be no additive impacts that would result in a trend toward Federal listing or loss of 

viability of the butterfly.

Environmental Consequences, A Tiger Beetle (Cicindela purpurea cimerrona)

Cincindel purpurea cimerrona occupies high-elevation meadows and grasslands and areas along 

trails. It is highly mobile on the ground surface in open areas and doesn’t fly unless disturbed by 

predators or other animals. It preys on smaller insects. Primary predators of adult beetles include 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 131

insect-eating birds, robberflies, and dragonflies. Some wasps (Tiphiidae) and bee-flies 

(Bombyliidae) also feed on their larvae. However, the beetle’s greatest threat is man, from 

pesticide use and disturbance by off-highway vehicles (AGFD 2001).

Population trends for this species are currently unknown (AGFD 2001). This beetle may occur at 

both tracts.

No Action

The no action alternative would cause ground disturbance during residence removal, and the 

long-term result would be a slight decrease in available habitat as natural succession progresses 

and currently-open areas become forested. However, this is not likely to result in a trend toward 

Federal listing or loss of viability of the tiger beetle.

Proposed Action

Because there are no vegetation or ground disturbing activities in the proposed action, no adverse 

impacts would be expected. The proposed action would likely have a net positive effect, as 

habitat is preserved in the available small openings around the residences.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. These openings represent potential habitat for this 

species.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Because of the small diameter of trees being removed (less than 9 inches 

DBH), there would likely be no impacts to this beetle. Some larger-diameter trees would be 

removed in the Turkey Flat area, which may create openings that are suitable for the tiger beetle.

Wildland fire and fire suppression may damage or destroy over- and understory trees that provide 

the beetle with cover. Although the initial impacts of fire are negative, it ultimately encourages 

the reestablishment of a mosaic of vegetation associations and seral stages that improve habitat in 

the long term.

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) 

likely reduced beetle habitat in areas that burned at high intensity. In moderately-burned areas, 

reintroduction of fire as a natural process may promote more sustainable forest conditions and 

improve the health of occupied habitat. Because fire is a randomly occurring event of 

unpredictable intensity and duration, the additive effects that it might have in combination with 

the no action or the proposed action are impossible to quantify. However, in general, damage 

caused by wildland fire at both tracts, if unsuppressed, could reduce potential beetle habitat by 77 

acres.

If the recreation residences are removed, vegetation at both tracts would replenish through natural 

succession, and new beetle habitat would become available until trees close the canopy. This 
Chapter 3. Affected Environment and Environmental Consequences

132 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

would be an additive benefit when considered cumulatively with benefits of other foreseeable 

activities.

If the permits are issued for Old Columbine, vegetation and habitat would remain the same. There 

would be no additive impacts that would result in a trend toward Federal listing or loss of 

viability of the tiger beetle.

Environmental Consequences, Mimic talussnail (Sonorella imitator)

This species inhabits rockslides from Clark Peak to Marijilda Canyon within the Pinaleño 

Mountains. Vegetation associated with talussnail populations includes oak, pine, and locust trees, 

depending on elevation (AGFD 2003). Habitat for this talussnail may occur at Turkey Flat. This 

species is becoming more common in areas formerly occupied by Pinaleño talussnails (Sonorella 

grahamensis) (AGFD 2003).

Because the no action alternative would not disturb habitat within talus slopes at Turkey Flat, 

activities that result from issuing new permits for the tract or residence removal are not likely to 

adversely impact the snail. Neither the proposed action nor no action would result in a trend 

toward Federal listing or loss of viability of the species.

None of the potential cumulative effects discussed in previous species descriptions is likely to 

occur within or cause adverse impacts to talus slopes. With the exception of wildland fires, there 

are no other cumulative effects to analyze for this species. Wildland fires may ignite duff that has 

built up on top of talus, and the heat from this burning may kill individuals of this species (AGFD 

2003).

Environmental Consequences, Chiricahua Rock Cress (Arabis tricornuta)

This species occupies rocky slopes and open coniferous forest, from 6,000 to 8,840 feet in 

elevation. This species is endemic to southern Arizona, and has been found only in the Santa Rita, 

Chiricahua, Huachuca, and Rincon mountains of southeastern Arizona (AGFD 2006). While the 

plants have not been documented within the Pinaleño Mountains, this plant has very similar 

habitat characteristics to others found in the Turkey Flat area, and spans an elevation gradient and 

vegetation association that is also present within this mountain range; as such, it is being included 

in this analysis, despite a lack of any locality information confirming its presence. 

No Action

Should the no action alternative be implemented, some plants may be trampled by humans and 

vehicles.Implementation of the no action alternative may impact individuals of this species, but is 

not likely to result in a Federal trend toward listing of the species or loss of its viability on the 

Forest.

Proposed Action

The proposed action may maintain more habitat for this species than the no action alternative, by 

contributing incentive to maintain more open forests in the cabin areas in order to prevent cabins 

harm from wildfires. Implementation of the proposed action will not impact this species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 133

Cumulative Effects

Other developed areas exist across the Mountain, including the Arizona Bible Camp, the 

astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and administrative 

sites. These areas all occur within small human-caused openings that are maintained by some 

removal of brush and hazard trees. This species likely inhabits most of these areas, at least around 

the forest edges around developed sites. On occasion, a plant may be stepped on by recreationists, 

but it is unlikely that this occurs with great frequency, as most human use is restricted to 

meadows and already-cleared areas within recreation sites, which likely do not support cinquefoil 

in significant numbers. Wildfire use, large wildfires, and fire suppression may lead to damage to 

individuals of this species; however, the presence of these plants in fire-adapted ecosystems 

suggests that this plant is also likely to be resilient or adapted to fires.

Three thinning projects (e.g., PERP, PEM and SUP) are currently in the planning or

implementation stages within this mountain range. The PERP project will remove trees of varying 

diameters in a range up to 18 inches in diameter at breast height (dbh), with some additional 

treatments with prescribed fire and/or pile burning. The PEM project focuses solely in the 

understory of the Forest, removing trees up to 9 inches in diameter at breast height (dbh). Because 

all PEM work is done by hand, and only small understory trees are removed, it is likely that there 

has been little disturbance to cinquefoil in the area, with the exception of occasional trampling of 

individual plants. The SUP project will be focused in areas that fall within 300 feet of cabin or 

electronic sites, and focus mainly in the understory of the Forest as well. Some larger trees will be 

removed in the Turkey Flat recreation residence area, which may create some small openings that 

are suitable for cinquefoil.

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) may have eliminated some habitat in areas that were burned at high fire intensities. In 

more moderately-burned areas, reintroduction of fire as a natural process may promote new 

openings for this species, more sustainable forest conditions, and improved health of occupied 

habitat. 

Environmental Consequences, Goodding’s Onion (Allium gooddingii) and Shade 

Violet (Viola umbraticola)

These plants usually grow in canyon bottoms at high elevation. Goodding’s onion occurs within 

climax coniferous forests on moist, north-facing slopes, at elevations from 7,000 to 10,600 feet 

(AGFD 1999). Its range is limited to the White Mountains and Santa Catalina Mountains of 

southern Arizona and southern New Mexico. Perspectives about population trends vary from site 

to site, including a suggestion that Santa Catalina populations are stable, possibly decreasing on 

the Apache-Sitgreaves National Forest, and possibly including extirpation of some populations 

(AGFD 1999). Shade violets occur within Ponderosa pine forests (5,200 to 7,5000 feet elevation) 

in Arizona, but may also be found in northern Mexico. Within Arizona, these violets are known 

to occur within the Chiricahua, Huachuca, Santa Rita, and Santa Catalina mountain ranges 

(AGFD 2004).

While neither of these plants has been located within the Pinaleño Mountains, they have very 

similar habitat characteristics to others found in the area, and span elevation gradients and 

vegetation associations that are also present within this mountain range; as such, they are being 

included in this analysis, despite a lack of any locality information confirming their presence. 
Chapter 3. Affected Environment and Environmental Consequences

134 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

No Action

Implementation of the no action alternative may lead to a small number of plants being trampled 

during the summerhome removal process; however, it is unlikely that activities in such small 

areas would impact these species at a forest scale. The no action alternative may impact 

individuals of this species, but is not likely to result in a Federal trend toward listing of the 

species or loss of its viability on the Forest.

Proposed Action

The proposed action will have no effect on the vegetation surrounding the summerhome areas; no 

changes to the area will be made. No impacts to these species would be expected. 

Cumulative Effects

Other developed areas exist across the Mountain, including the Arizona Bible Camp, the 

astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and administrative 

sites. The Bible Camp, Heliograph electronic site, Columbine Administrative site, and 

astrophysical site occur within the elevation range for Goodding’s onion, but considerably higher 

in elevation than shade violets. Ladybug electronic site is on a warm, dry, south-facing slope, and 

as such, is unlikely to support plants of either species. Some of the recreation sites may support 

individual plants. On occasion, a plant may be stepped on by recreationists, but it is unlikely that 

this occurs with great frequency, as most human use is restricted to meadows and already-cleared 

areas within recreation sites, which would not support either species. Wildfire use, large wildfires, 

and fire suppression may lead to damage to individuals; however, the presence of these plants in 

fire-adapted ecosystems suggests that Goodding’s onions and shade violets are also likely to be 

resilient or adapted to fires.

Three thinning projects (e.g., PERP, PEM and SUP) are currently in the planning or 

implementation stages within this mountain range. The PERP project will remove trees of varying 

diameters in a range up to 18 inches in diameter at breast height (dbh), with some additional 

treatments with prescribed fire and/or pile burning. PERP may create some openings that are 

unsuitable for these species. The PEM project focuses solely in the understory of the Forest, 

removing trees up to 9 inches in diameter at breast height (dbh). Because all PEM work is done

by hand, and only small understory trees are removed, it is likely that there has been little 

disturbance to Goodding’s onion or shade violets in the area, with the exception of occasional 

trampling of individual plants. The SUP project will be focused in areas that fall within 300 feet 

of cabin or electronic sites, and focus mainly in the understory of the Forest as well. Some larger 

trees will be removed in the Turkey Flat recreation residence area, which may create some small 

openings that are unsuitable for these plants.

Recent wildfires on the Safford Ranger District (e.g., Clark Peak Fire and Nuttall Complex 

wildfire) may have eliminated some habitat in areas that were burned at high fire intensities, 

particularly the headwaters of several streams. In more moderately-burned areas, reintroduction 

of fire as a natural process may promote more sustainable forest conditions and improved health 

of occupied habitat. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 135

Environmental Consequences, Mock pennyroyal (Hedeoma dentatum), 

Coppermine milk vetch (Astragalus cobrensis var. marguieri), Arizona alum root 

(Heuchera glomerulata)

These three species occupy fairly open areas, trails, and roadsides in oak woodland, oak-pine, and 

pine forest up to approximately 8500 feet in elevation. All tend to be found on north-facing 

slopes. Milk vetch and alum root are found in sandy and rocky soils, while pennyroyal tends to 

prefer sandy loams (AGFD 1999, 2000, 2004). Mock pennyroyal was once described as common 

and widespread within its range, but is now considered uncommon. There is no scientific 

explanation for the decline since the mid-1990s (AGFD 2000). Coppermine milk vetch is also 

considered to be declining (AGFD 1999). Arizona alum root population trends are undocumented 

(AGFD 2004). These species occur at the Turkey Flat tract.

No Action

If no action is taken, activities during residence removal may result in a temporary loss of 

individual plants. However, long-term effects would be positive, as the tract returns to a more 

natural state.

Proposed Action

If permits are issued, there would be a continued intermittent human presence at Turkey Flat, 

which may result in an occasional loss of a plant as vehicles and people travel through the area.

This impact would not likely result in a Federal trend toward listing of the species or loss of its 

viability on the forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include ongoing activities at the Arizona 

Bible Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. These openings represent potential habitat for this 

species. Occasionally, individual plants may be trampled by forest users, but it is unlikely that this 

affects the success of the species as a whole.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Because of the small diameter of trees being removed (less than 9 inches 

DBH), no impacts to these plants are expected. A few larger-diameter trees would be removed at 

Turkey Flat, which may create small openings that are suitable for all three species. Because 

project #10 is being done by hand and only small understory trees are to be removed, little 

disturbance to these species is expected.

Wildland fire and fire suppression may destroy or damage individuals of this species; however, 

the presence of these plants in fire-adapted ecosystems suggests that this plant is also likely to be 

resilient or adapted to fires. Recent wildland fires on the Safford Ranger District (Clark Peak Fire 

and Nuttall Complex Fire) may have destroyed plants and habitat in areas that burned at high 

intensity. In more moderately-burned areas, reintroduction of fire as a natural process may 

promote more sustainable forest conditions and improved health of occupied habitat.
Chapter 3. Affected Environment and Environmental Consequences

136 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at Turkey Flat, if 

unsuppressed, could reduce potential habitat for these plant species by 52 acres.

If the recreation residences are removed, vegetation at Turkey Flat would replenish through 

natural succession, and populations of these species may increase. This would be an additive 

benefit when considered cumulatively with benefits of other foreseeable activities.

If the permits are issued for Turkey Flat, habitat and human disturbance would remain the same. 

There would be no additive impacts that would result in a trend toward Federal listing or loss of 

viability of these plant species.

Environmental Consequences, Rusby hawkweed (Hieracium rusbyi), Bigelow 

thoroughwort (Eupatorium bigelovii)

These two species occupy high-elevation oak-juniper, mixed conifer forest, and aspen-conifer 

areas (8000 to 9500 feet) (AGFD 2004, 2004a). Both have the potential to occur on the Old 

Columbine tract. Bigelow thoroughwort tends to occupy somewhat rockier and wetter areas 

(AGFD 2004) than hawkweed, which is generally found in shady areas (AGFD 2004a). 

Thoroughwort prefers northeast and southwest facing slopes (AGFD 2004). Hawkweed seems to 

be fairly uncommon (AGFD 2004a). Thoroughwort has been documented in at least two sites 

within the Pinaleño Mountains, although population trends are unknown (AGFD 2004).

No Action

If no action is taken, activities during residence removal may result in a temporary loss of 

individual plants. However, long-term effects would be positive, as the Old Columbine tract 

returns to a more natural state.

Proposed Action

If permits are issued, there would be a continued intermittent human presence at Old Columbine 

which may result in an occasional loss of a plant as vehicles and people travel through the area. 

This impact would not likely result in a Federal trend toward listing of the species or loss of its 

viability on the forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. Ladybug electronic site is on a warm, dry, southfacing slope, and as such, is unlikely to support these species. Occasionally, individual plants at 

the other sites may be trampled by forest users. It is unlikely that this occurs with such frequency 

as to affect the viability of these species, because human use occurs primarily in meadows and 

cleared areas within recreation sites, which do not support hawkweed and thoroughwort.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 137

ecological processes. The PEM project (#10) is underway in a higher elevation than these species 

are likely to be found, with the exception of a small treatment area near Shannon Campground. 

Because all work there is being done by hand, and only small understory trees are to be removed, 

it is likely that there has been or will be little disturbance to these species.

Wildland fire and fire suppression may destroy or damage individuals of these species; however, 

the presence of these plants in fire-adapted ecosystems suggests that these species are likely to be 

resilient or adapted to fires. Recent wildland fires on the Safford Ranger District (Clark Peak Fire 

and Nuttall Complex Fire) may have destroyed plants and habitat in areas that burned at high 

intensity. In more moderately-burned areas, reintroduction of fire as a natural process may 

promote more sustainable forest conditions and improved health of occupied habitat.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at Old Columbine, if 

unsuppressed, could reduce potential habitat for these plant species by 25 acres.

If the recreation residences are removed, vegetation at Old Columbine would replenish through 

natural succession, and populations of these species may increase. This would be an additive 

benefit when considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued for Old Columbine, habitat and human disturbance would remain the 

same. There would be no additive impacts with other actions that would result in a trend toward 

Federal listing or loss of viability of these plant species.

Environmental Consequences, White-flowered Cinquefoil (Potentilla albiflora)

This species occupies rocky slopes and open coniferous forest, from 7500 to 9500 feet in 

elevation (Kearney and Peebles 1960). This plant may occur on both tracts.

No Action

If no action is taken, activities during residence removal may result in a temporary loss of 

individual plants. However, long-term effects would be positive, as the tracts return to a more 

natural state.

Proposed Action

If permits are issued, there would be a continued intermittent human presence on the tracts, which 

may result in an occasional loss of a plant as vehicles and people travel through the area. This 

impact would not likely result in a Federal trend toward listing of the species or loss of its 

viability on the forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. This species occurs at most of these sites, primarily in 

the forest edges around developed areas. Occasionally, individual plants may be trampled by 

forest users. It is unlikely that this occurs with such frequency as to affect the viability of the 
Chapter 3. Affected Environment and Environmental Consequences

138 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

species, because human use occurs primarily in meadows and cleared areas within recreation 

sites, which likely do not support cinquefoil in significant numbers.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Because all work for project #10 is being done by hand and only small 

understory trees are to be removed, it is likely that populations of cinquefoil would be affected, 

with the exception of occasional trampling of individual plants. A few larger-diameter trees would 

be removed at Turkey Flat, which may create openings that are suitable for cinquefoil.

Wildland fire and fire suppression may lead to damage to individuals of this species; however, the 

presence of these plants in fire-adapted ecosystems suggests that this plant is also likely to be 

resilient or adapted to fires. Recent wildland fires on the Safford Ranger District (Clark Peak Fire 

and Nuttall Complex Fire) may have destroyed plants and habitat in areas that burned at high 

intensity. In more moderately-burned areas, reintroduction of fire as a natural process may 

promote more sustainable forest conditions and improved health of occupied habitat.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at both tracts, if unsuppressed, 

could reduce potential habitat for this plant species by 77 acres.

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and populations of these species may increase. This would be an additive benefit 

when considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a trend toward Federal listing or loss of 

viability of these plant species.

Environmental Consequences, Pinaleño Jacob’s Ladder (Polemonium flavum)

This plant species inhabits rich, moist soils in coniferous forests between 7500 and 9500 feet 

elevation (Kearney and Peebles 1960) and likely occurs within the Old Columbine tract.

No Action

If no action is taken, activities during residence removal may result in a temporary loss of 

individual plants. However, long-term effects would be positive, as the Old Columbine tract 

returns to a more natural state.

Proposed Action

If permits are issued, there would be a continued intermittent human presence on the Old 

Columbine tract, which may result in an occasional loss of a plant as vehicles and people travel 

through the area. This impact would not likely result in a Federal trend toward listing of the 

species or loss of its viability on the forest.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 139

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. This species likely inhabits most of these sites.

Occasionally, individual plants may be trampled by forest users. It is unlikely that this occurs 

with such frequency as to affect the viability of the species, because human use occurs primarily 

in meadows and cleared areas within recreation sites, which likely do not support Pinaleño 

Jacob’s ladder in significant numbers.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. Because all work for the PEM project (#10) is being done by hand, and only 

small understory trees are to be removed, it is likely that populations of this species would not be

adversely affected, with the exception of occasional trampling of individual plants.

Wildland fire and fire suppression may lead to damage to individuals of this species; however, 

their presence in a fire-adapted ecosystem suggests that this plant is also likely to be resilient or 

adapted to fires. Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall 

Complex Fire) may have destroyed plants and habitat in areas that burned at high intensity. In 

more moderately-burned areas, reintroduction of fire as a natural process may promote more 

sustainable forest conditions and improved health of occupied habitat.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at both tracts, if unsuppressed, 

could reduce potential habitat for this plant species by 25 acres.

If the recreation residences are removed, vegetation at Old Columbine would replenish through 

natural succession, and populations of these species may increase. This would be an additive 

benefit when considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a trend toward Federal listing or loss of 

viability of these plant species.

Environmental Consequences, Chihuahuan Stickseed (Hackelia ursina)

This plant usually grows in shade on moist, north-facing slopes, in oak-pine woodland forest at 

elevations from 5000 to 8000 feet (AGFD 2000). Its range is limited to Arizona and New Mexico 

(Kearney and Peebles 1960). No population trends are documented for this species (AGFD 2000). 

These plants are not common, but could potentially occur within the Turkey Flat tract. At present, 

the tract provides moist pockets of shade that can be used by this species.

No Action

If no action is taken, activities during residence removal may result in a temporary loss of 

individual plants. However, long-term effects would be positive, as the Turkey Flat tract returns 
Chapter 3. Affected Environment and Environmental Consequences

140 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

to a more natural state. If the residences are removed, further pockets of shaded areas may form 

as the area revegetates.

Proposed Action

If permits are issued, there would be a continued intermittent human presence on the Turkey Flat 

tract, which may result in an occasional loss of a plant as vehicles and people travel through the 

area. This impact would not likely result in a Federal trend toward listing of the species or loss of 

its viability on the forest.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. Ladybug electronic site is on a warm, dry, southfacing slope, and as such, is unlikely to support plants of this species. Some recreation sites may 

support individual stickseed plants.

Occasionally, individual plants may be trampled by forest users. It is unlikely that this occurs 

with such frequency as to affect the viability of the species, because human use occurs primarily 

in meadows and cleared areas within recreation sites, which likely do not support stickseed 

populations.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) is ongoing at a higher elevation than this plant is 

likely to be found, with the exception of a small treatment area near Shannon Campground. 

Because all work at Shannon was done by hand and only small understory trees were removed,

there was little disturbance to stickseed in the area. Some larger-diameter trees are to be removed

at Turkey Flat, which may create some small openings that are unsuitable for Chihuahuan 

stickseed.

Wildland fire and fire suppression damage or destroy individuals of this species; however, the 

presence of these plants in fire-adapted ecosystems suggests that it is likely to be resilient or 

adapted to fires. Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall 

Complex Fire) may have destroyed plants and habitat in areas that burned at high intensity. In 

more moderately-burned areas, reintroduction of fire as a natural process may promote more 

sustainable forest conditions and improved health of habitat.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at Turkey Flat, if 

unsuppressed, could reduce potential habitat for this plant species by 52 acres.

If the recreation residences are removed, vegetation at Turkey Flat would replenish through 

natural succession, and populations of the species may increase. This would be an additive benefit 

when considered cumulatively with the impacts of other foreseeable activities.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 141

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a trend toward Federal listing or loss of 

viability of stickseed.

Management Indicator Species

Species Evaluated

The role of management indicator species (MIS) in national forest planning is described in the 

1982 implementing regulations for the National Forest Management Act (NFMA) of 1976. These 

regulations require that certain vertebrate and/or invertebrate species present on a forest be 

identified as MIS and that they be selected because “their population changes are believed to 

indicate the effects of management activities” (36 CFR 219.19(a)(1).

The Forest Service Manual (FSM) defines management indicators as “Plant and animal species, 

communities or special habitats selected for emphasis in planning, and which are monitored 

during forest plan implementation in order to assess the effects of management activities on their 

populations and the populations of other species with similar habitat needs which they may 

represent.” (FSM 2620.5).

The NFMA regulations identify five categories of species that may be considered, where 

appropriate, as management indicator species:

 Endangered and threatened plant and animal species identified on State and Federal 

lists for the area.

 Species with special habitat needs that may be influenced significantly by planned 

management programs.

 Species commonly hunted, fished or trapped

 Nongame species of special interest

 Plant and 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.

Section 219.19(a)(6) requires that “Population trends of the management indicator species will be 

monitored and relationships to habitat changes determined. This monitoring will be done in 

cooperation with State fish and wildlife agencies to the extent practicable.”

Management indicator species and their habitat are monitored to observe trends in resources, 

evaluate management actions, and provide a timely warning of problems or undesirable 

conditions affecting the resource. MIS were selected during the development of the 1986 

Coronado Forest Plan according to their being either threatened and endangered (TES), requiring 

of special habitat needs, or in high public demand. The analysis of impacts to MIS as part of the 

NEPA process contributes to the identification of trends, which may necessitate development of 

mitigation or new alternatives when a proposed action is under consideration.

Table 18 lists the MIS for the Coronado that may occur in the project area and the forest plan 

indicator group(s) to which it (they) belong. The full list of Coronado MIS is available at 
Chapter 3. Affected Environment and Environmental Consequences

142 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

http://www.fs.fed.us/r3/projects/2004-cor-misreport.pdf. An impacts analysis for those species in 

Table 18 follows.

Table 18. Information on Management Indicator Species on the Coronado National Forest,

Safford Ranger District.

Species Coronado Forest Plan 

Indicator Group Presence Within Recreation Tracts

Cavity Nesters 

Sulphur-bellied 

flycatcher 

Cavity nesters, riparian, 

needs diversity, specialinterest, TES 

Occur within analysis area; suitable habitat 

available.

Primary35 and 

Secondary36 Cavity 

Nesters

Cavity nesters Occur within analysis area; suitable habitat 

available.

Riparian Species

Sulphur-bellied 

flycatcher 

Cavity nesters, riparian, 

diversity, special-interest, 

TES 

Occur within analysis area; suitable habitat 

available.

Black bear Riparian, diversity, game Occurs within analysis area; suitable habitat 

available.

Species Needing Diversity

White-tailed deer Diversity, herbaceous 

cover, game

Occurs within analysis area; suitable habitat 

available.

Sulphur-bellied 

flycatcher 

Cavity nesters, riparian, 

diversity, special-interest, 

TES 

Occur within analysis area; suitable habitat 

available.

Black bear Riparian, diversity, game Occurs within analysis area; suitable habitat 

available.

Species Needing Herbaceous Cover

White-tailed deer Diversity, herbaceous 

cover, game

Occurs within analysis area; suitable habitat 

available.

Mearn's quail Herbaceous cover, game, 

special interest

Occur within analysis area; suitable habitat 

available.

 

35 Primary Cavity Nesters: Ladder-backed woodpecker, Arizona woodpecker, northern flicker, 

Gila woodpecker, acorn woodpecker, hairy woodpecker.

36 Secondary Cavity Nesters: American kestrel, elf owl, flammulated owl, whiskered screech owl, 

western screech owl, Northern pygmy-owl, Mexican spotted owl, elegant trogon, eared trogon, 

sulphur-bellied flycatcher, brown-crested flycatcher, ash-throated flycatcher, dusky capped 

flycatcher, Cordilleran flycatcher, violet green swallow, juniper titmouse, bridled titmouse, 

brown creeper, white-breasted nuthatch, red-breasted nuthatch, pygmy nuthatch, house wren, 

Bewick’s wren, eastern bluebird, European starling, Lucy’s warbler.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 143

Species Coronado Forest Plan 

Indicator Group Presence Within Recreation Tracts

Species Needing 

Dense Canopy

None of those listed in the forest plan occur in 

the analysis area.

Game Species

White-tailed deer Diversity, herbaceous 

cover, game

Occurs within analysis area; suitable habitat 

available.

Mearn's quail Herbaceous cover, game, 

special interest

Occur within analysis area; suitable habitat 

available.

Black bear Riparian, diversity, game Occurs within analysis area; suitable habitat 

available.

Special Interest Species

Mearn's quail Herbaceous cover, game, 

special interest

Occur within analysis area; suitable habitat 

available.

Sulphur-bellied 

flycatcher 

Cavity nesters, 

riparian,diversity, specialinterest, TES 

Occur within analysis area; suitable habitat 

available.

Threatened and Endangered Species

Peregrine falcon TES (has since been 

delisted)

Occur within analysis area; suitable habitat 

available.

Sulphur-bellied 

flycatcher 

Cavity nesters, 

riparian,diversity, specialinterest, TES 

Occur within analysis area; suitable habitat 

available.

Apache trout TES Occurs within analysis area; suitable habitat 

available

Twin-spotted 

rattlesnake TES Occurs within analysis area; suitable habitat available.

Mt. Graham red 

squirrel TES Occurs within analysis area; suitable habitat available.

Gould’s turkey TES (reintroduced) Occurs within analysis area; suitable habitat 

available.

Sulphur-bellied Flycatcher (Myiodynastes luteiventris)

This species occupies mid-elevation riparian areas in Arizona, particularly those with sycamore 

(Platanus spp.), oak (Quercus spp.), walnut (Juglans spp.), and Arizona cypress (Cupressus 

arizonica) components (Ligon 1971). In these areas, the sulphur-bellied flycatcher forages for 

insects, generally catching them in flight or picking them off shrubs and trees. Fruit from vines, 

mistletoe, and fruiting trees supplement their diet during non-breeding season (Fitzpatrick 1980).

Nesting generally occurs at elevations between 3640 and 7500 feet (Arizona Breeding Bird Atlas; 

Corman and Wise-Gervais 2005). These flycatchers occupy the forest during breeding season 

only, which extends from June through September (USDA –FS, 2005).
Chapter 3. Affected Environment and Environmental Consequences

144 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Forestwide habitat for this species has not been estimated. The global population of sulphurbellied flycatchers is considered stable, and in Arizona, it is considered common within a 

restricted range (USDA 2005). It is considered to be a common summer resident in the Pinaleños 

(Corman and Wise-Gervais 2005).

The Turkey Flat tract occurs within the range of elevations listed for this species, but it does not 

contain any true riparian zones. Therefore, the use of the tract as foraging habitat by the 

flycatcher is likely to be limited.

The Old Columbine tract lies at the head of the Ash Creek drainage, but it is over 1500 feet above 

the elevation range for nesting by this species. Therefore, the use of the tract as foraging habitat is 

likely minimal.

No Action

If no action is taken, the residence tracts would revegetate naturally, as shrubs and grasses 

replenish areas denuded by structure removal activities. During normal vegetation succession, 

there would be periods of time that shrubs and vines would be available for the flycatcher. In later 

stages of natural succession, there would likely be trees, some of which would support mistletoe, 

which would also provide a food source for this species. During residence removal, foraging 

flycatchers might experience temporary disturbance and would likely avoid the area. Because of 

the mobility of this species and the presence of many riparian areas available in the Pinaleño 

Mountains, the use of the residence tracts for foraging would likely be limited. The magnitude of 

habitat alteration resulting from residence removal would not be expected to change the 

population trajectory on the forest for this species.

Proposed Action

If permits are issued, the status quo would remain with regard to use of the tracts by this 

flycatcher, because site use and available habitat would remain the same.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. Because most of these sites have no riparian areas, 

flycatchers likely make minimal use of them for foraging and/or nesting. The magnitude of 

habitat alteration and human use of these sites would not be expected to change the population 

trajectory on the forest for this species.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) and thinning around special-use sites (#24) are 

ongoing in the understory, where trees up to 9 inches DBH are being removed. Because of the 

small diameter of the trees being removed, it is unlikely that these projects would have a 

measurable effect on flycatcher foraging habitat in this area. A few larger-diameter trees will be 

removed in the Turkey Flat area, which may decrease habitat for these species by a negligible 

increment.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 145

Wildland fire and fire suppression may destroy or damage vegetation and habitat; however, fires 

are known to stimulate insect activity, which may improve flycatcher foraging success. Recent 

wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex Fire) have 

caused temporary losses of riparian habitat. However, nutrient releases from the fires should

stimulate regeneration of trees and other plants that provide habitat and food sources for the 

flycatcher.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire at Old Columbine if 

unsuppressed, could reduce potential foraging habitat for this species by 25 acres. This magnitude 

of habitat alteration would not be expected to change the population trajectory on the forest for 

this species.

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and populations of insect species may increase. This would be an additive benefit 

when considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a change in the population trajectory 

on the forest for this species.

Primary and Secondary Cavity Nesters

Primary and secondary cavity nesters37 potentially occur in all plant communities on both tracts.

In general, these species require large, older-age-class trees and snags to provide a suitable 

substrate for cavities. Most of the Pinaleño Mountains are heavily wooded; thus, available 

cavities are probably not limited, particularly because of recent fires (Clark Peak Fire, 1996, and 

Nuttall Complex Fire, 2004) and insect activity (starting in the mid-1990s and ongoing). North 

American Breeding Bird Survey data for 1980 through 1999 indicate a significant downward 

trend for the Gila woodpecker and American kestrel. For all other primary or secondary cavity 

nesters, trends are reported as either not significant, or no data were available (USDI-GS, 2000).

Woody upland vegetation that is widespread on the mountain is expected to continue to mature. 

Large-diameter trees are readily available, and there is a high production of snags, providing 

potential cavity nest sites as trees grow.

No Action

If no action is taken and residences are removed at either or both tracts, the sites would revegetate 

naturally, which would eventually provide up to 77 acres of additional wooded habitat. Over 

100,000 acres of woody vegetation is currently available for these species. The additional acreage 

ultimately available after 50 plus years would be less than 1 percent of existing habitat, a very 

small but beneficial effect.

Population trends for cavity nesters vary: they show declines for northern flickers and American 

kestrels, statistically insignificant declines for ash-throated flycatchers and Bewick’s wrens, stable 

 

37 Primary cavity nesters are those species that excavate and nest in cavities, whereas secondary 

cavity nesters use cavities excavated by primary cavity nesters.
Chapter 3. Affected Environment and Environmental Consequences

146 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

trends for elegant trogons and sulphur-bellied flycatchers, and statistically insignificant increases 

for ladder-backed woodpeckers (USDA-FS, 2005). Given the small size of the project area 

relative to available habitat forestwide and the continued availability of large numbers of snags in 

the Pinaleño Mountains, the magnitude of habitat alteration resulting from residence removal 

would not be expected to change the population trajectory on the forest for this species.

Proposed Action

If permits are issued, the status quo would remain with regard to use of the tracts by primary and 

secondary cavity nesters, because site use and available habitat would remain the same.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Each is located within a man-made opening in the forest maintained by 

periodic removal of brush and hazard trees. Removal of hazard trees, which includes some snags 

that might be used by cavity-nesting species, may have localized impacts on primary cavity 

nesters. However, because of the widespread availability of snags and forestwide tree mortality 

and infestations of native and non-native insects, the small increment of loss would be not 

contribute significantly to cumulative effects.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) and thinning around special use sites (#24) are 

ongoing in the understory, where trees up to 9 inches DBH are being removed. Because of the 

small size of trees being removed, it is unlikely that these projects would have a measurable 

effect on primary and secondary cavity nester foraging and nesting habitat on the forest. A few 

larger-diameter trees are planned to be removed in the Turkey Flat area, which may decrease 

habitat for these species by a negligible increment.

Wildland fire and fire suppression may destroy or damage vegetation and habitat; however, fires 

are known to stimulate insect activity, which may benefit foraging success. Recent fires on the 

Santa Catalina Ranger District (Aspen and Bullock fires) and the Nogales District (Florida Fire) 

have increased the forestwide availability of snags for use by these species.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire on these tracts, if 

unsuppressed, could reduce potential foraging and nesting habitat for these species by 77 acres. 

This increment of habitat alteration would not be expected to change the population trajectory on 

the forest for these species.

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and wooded habitat would eventually increase. This would be an additive benefit 

when considered cumulatively with the impacts of other foreseeable activities.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 147

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a change in the population trajectory 

on the forest for these species.

Black Bear (Ursus americanus)

The black bear is a wide-ranging habitat generalist that prefers areas of dense cover and high 

vegetative diversity. Grass is known to be a very important component of the bear’s diet in the 

spring (April through June). In summer, insects and grubs are added to the diet, and in fall, berries 

and acorns (Hoffmeister 1956).

Protective cover, such as that which is offered by chapparal and pine-oak woodlands, is also very 

important to bears, especially that which is in the 6-foot height class (LeCount 1984). Summer 

habitat use often is centered on riparian areas where water is available. Suitable black bear habitat 

occurs throughout both tracts, with highest densities expected in steep, brushy canyons at upper 

elevations. Lower elevation sites in the desert grassland and open woodlands may be used 

seasonally, but are not considered high-quality habitat. There are 641,113 acres of black bear 

habitat forestwide; the two tracts (77 acres) could reasonably be considered as 0.01 percent of this 

total.

In general, black bear populations are primarily affected by environmental factors, such as 

rainfall, and by pressure from human activities, such as hunting and depredation removal (USDAFS, 2005). Population-level trends are difficult, if not impossible to detect. Poor mast crops in the 

early part of this decade may have led to a decreased carrying capacity for bears on the forest. 

However, most historically occupied habitat is still utilized by black bears (USDA-FS, 2005).

Hunting in the Pinaleños is managed by AGFD as Management Unit 31; the recent black bear 

sport harvest has been reported as follows:

 1996 7

 1997 8

 1998 7

 1999 27

 2000 23

 2001 no data

 2002 10

 2003 8

 2004 5

 2005 7

 2006 6

(Personal communication, Duane Aubuchon, AGFD, with Anne Casey, Safford Ranger District, 

February 12, 2008; and Coronado National Forest Management Indicator Species Population 

Status and Trends (USDA-FS, 2005).
Chapter 3. Affected Environment and Environmental Consequences

148 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

No Action

If no action is taken, the tracts would revegetate naturally, providing additional bear habitat as 

shrubs and grasses replenish areas denuded by residence removal activities. Grass and shrub 

habitat would be available until trees begin to populate the site; they would provide additional 

acorns (mast) for foraging. During residence removal, bears would experience temporary 

disturbance and would likely avoid the area. Given the bear’s mobility and the wide availability 

of nearby habitat, these effects would be discountable. In the long term, natural succession would 

result in an increase in the understory of non-woody species, which may include berry bushes, 

and eventual growth of oak trees that would increase the mast crop. Overall, these effects would 

have no measurable impact on the local and forestwide black bear population trajectory.

Proposed Action

If the proposed action is implemented, no change in bear density or abundance is expected. The 

openings maintained around the recreation residences may have a positive effect in that additional 

nutrients would be available to surrounding trees, which, in turn, would increase mast crops, 

particularly in the Turkey Flat area. Intermittent human presence may temporarily disturb bears, 

who would likely avoid the area. Overall, these effects would have no measurable impact on the 

local and forestwide black bear population trajectory.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. These sites provide openings that, in many areas, encourage the growth of 

shrubs, including berry bushes and locust trees that are a food source for black bears. Some 

human disturbance occurs in these areas; however, black bears continue to be reported near 

recreation residence tracts and campgrounds. Overall, effects of these sites on black bear habitat 

and population are negligible.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) and thinning around special use sites (#24) are 

ongoing in the understory, where trees up to 9 inches DBH are being removed. Because of the 

small size of trees being removed and the limited acreage affected, the availability of quail habitat 

is unlikely to be measurably impacted. Removal of a few larger-diameter trees in the Turkey Flat 

area may stimulate further understory grass, forb, and shrub growth, which would, thus, improve 

quail foraging habitat, but would not result in a measurable benefit to the local or forestwide

population trajectory.

Wildland fire and fire suppression damage and/or destroy overstory trees that provide cover for 

the black bear. However, fires also stimulate grass and shrub growth by opening the canopy; this 

provides additional food sources for bear. Recent wildland fires on the Safford Ranger District 

(Clark Peak Fire and Nuttall Complex wildland fire), the Santa Catalina Ranger District (Aspen 

and Bullock fires), and the Nogales District (Florida Fire) adversely affected black bear habitat in 

areas that burned at high intensity. Bears were likely displaced to other habitat on the forest or on 

adjacent private, state, and BLM lands. Despite this displacement, natural succession after the 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 149

fires will, in the long term, improve bear habitat as a mosaic of vegetation associations and seral 

stages progress.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire on these tracts, if 

unsuppressed, could reduce black bear habitat by 77 acres. This increment of habitat alteration 

would not be expected to change the population trajectory on the forest for this species.

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and bear habitat would eventually increase. This would be an additive benefit when 

considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a change in the population trajectory 

on the forest for the black bear.

White-tailed Deer (Odocoileus virginianus couesi)

White-tailed deer use a variety of habitats but prefer areas of thick cover. During the fawning 

period, these deer rely on hiding-cover to maintain fawn survival and recruitment (Ockenfels et 

al. 1991). Shrubs comprise the majority of a white-tailed deer diet, although forbs are seasonally 

important.

The white-tailed deer harvest in southern Arizona remained stable from 1990 through 2001, 

despite a slightly downward statewide trend. Recent fires on the forest were followed by 

regeneration in shrubs and forbs that benefitted this species (USDA-FS, 2005). In addition, 2005 

to 2007 represented fairly wet years in terms of monsoon precipitation, and local grasses and 

forbs grew rapidly in response, providing further food sources for white-tailed deer.

There are 1,430,071 acres of white-tailed deer habitat forestwide; these deer are regularly

observed at and near both residence tracts. Thus, the 77 acres of residence tracts could reasonably 

be considered as white-tailed deer habitat. They comprise less than 0.01 percent of available 

habitat forestwide. Because of the relatively small size of the project area in relation to the 

available habitat forestwide, impacts would not contribute significantly to the forestwide

population trajectory of white-tailed deer.

Like bear, deer populations are influenced by environmental factors, such as rainfall and its effect 

on food availability, predation, and pressure from human activities, such as hunting (USDA-FS,

2005). Population changes related to any of the alternatives evaluated in this EIS would be 

difficult to detect.

No Action

If no action is taken, the tracts would revegetate naturally, providing additional deer habitat as 

shrubs and grasses replenish areas denuded by residence removal activities. Grass and shrub 

habitat would be available until trees begin to populate the site and provide additional cover for 

deer. During residence removal, deer would experience temporary disturbance and would likely 

avoid the area. Given the deer’s mobility and the wide availability of nearby habitat, these effects 

would be discountable. In the long term, natural succession would increase the understory growth 
Chapter 3. Affected Environment and Environmental Consequences

150 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

of forbs and shrubs. Overall, these effects would have no measurable impact on the local and 

forestwide deer population.

Proposed Action

If the proposed action is implemented, no change in deer density or abundance is expected. The 

openings maintained around the recreation residences could have a positive effect in that they 

provide additional nutrients that encourage understory growth and higher-quality shrub forage. 

Intermittent human presence may temporarily disturb deer, who would likely avoid the area.

Overall, these effects would have no measurable impact on the local and forestwide trajectory of 

the white-tailed deer population.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. These sites provide openings that, in many areas, encourage the growth of 

grasses, forbs, and shrubs, including berry bushes and locust trees that are a food source for deer. 

Some human disturbance occurs in these areas; however, deer continue to be reported near 

recreation residence tracts and campgrounds. Overall, beneficial and adverse effects on 

forestwide white-tailed deer habitat and population are negligible.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) and thinning around special use sites (#24) are 

ongoing in the understory, where trees up to 9 inches DBH are being removed. Because of the 

small size of trees being removed and the limited acreage affected, the availability of quail habitat 

is unlikely to be measurably impacted. Removal of a few larger-diameter trees in the Turkey Flat 

area may stimulate further understory grass, forb, and shrub growth, which would, thus, improve 

quail foraging habitat, but would not result in a measurable benefit to the local or forestwide

population trajectory.

Wildland fire and fire suppression damage and/or destroy overstory trees that provide cover for 

the deer. However, fires also stimulate grass, forb and shrub growth by opening the canopy; this 

provides additional food sources for the species. Recent wildland fires on the Safford Ranger 

District (Clark Peak Fire and Nuttall Complex fire), the Santa Catalina Ranger District (Aspen 

and Bullock fires), and the Nogales District (Florida Fire) adversely affected deer habitat in areas 

that burned at high intensity. Deer were likely displaced to other habitat on the forest or on 

adjacent private, state, and BLM lands. Despite this displacement, natural succession after the 

fires will, in the long term, improve deer habitat as a mosaic of vegetation associations and seral 

stages progress.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire on these tracts, if 

unsuppressed, could temporarily reduce deer habitat by 77 acres. This increment of habitat 

alteration would not be expected to change the population trajectory on the forest for this species.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 151

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and deer habitat would eventually increase. This would be an additive benefit when 

considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a change in the population trajectory 

on the forest for the white-tailed deer.

Mearn’s Quail (Cyrtonyx montezumae mearnsi)

Mearn’s quail occupy a wide variety of vegetation associations, including desertscrub, grasslands, 

chaparral, broadleaf evergreen woodlands, coniferous woodlands, and riparian areas (USDA-FS,

2005). They have also been known to use areas of aspen (Populus spp.). Roosting and foraging 

sites generally have high total cover of grasses (49 to54 percent). Diet consists mainly of acorns 

(Quercus spp.) and underground tubers (wood sorrel [Oxalis spp.], sedges [Cyperus spp.]); an 

insect component becomes important during the summer months (Stromberg 2000).

Forestwide, the population of Mearn’s quail shows no clear trend, but AGFD harvest data indicate 

that harvest levels remain approximately the same as when this species was selected as an MIS in 

1986.). There are 225,410 acres of Mearn’s quail habitat forestwide (USDA 2005). The Pinaleño 

Mountains are not considered among the highest density areas for Mearn’s quail (USDA-FS,

2005). The 77 acres of recreation residence tracts are 0.03 percent of available forestwide habitat. 

Because of the small size of the project area relative to this, impacts of any alternatives evaluated 

in this EIS would not measurably affect forestwide populations of Mearn’s quail.

No Action

If no action is taken, the tracts would revegetate naturally, providing additional habitat as shrubs, 

grasses, and forbs replenish areas denuded by residence removal activities. It is likely that this 

stage of succession would allow for increased insect populations, which would also provide 

additional food sources for Mearn’s quail. Additional grass and shrub habitat would be available 

until succession progresses to a later stage with the growth of trees, which would provide 

additional food sources and cover for quail. During residence removal, quail might experience 

temporary disturbance and would likely avoid the area. Because of the mobility of this species 

and the amount of habitat available forestwide, negative impacts of no action on the population 

trajectory of Mearn’s quail would be discountable. However, effects would be of benefit in the 

long term, because of an increase in understory growth of forbs and shrubs.

Proposed Action

If the proposed action is implemented, no change in quail density or abundance is expected. 

Openings maintained around recreation residences may provide additional nutrients and 

encourage understory growth in the surrounding area. However, human presence may cause 

temporary disturbance to quail when residences are occupied. Overall, these effects would have 

no measurable impact on the local and forestwide Mearn’s quail population trajectory.

Cumulative Effects

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. These sites provide openings that, in many areas, encourage the growth of 
Chapter 3. Affected Environment and Environmental Consequences

152 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

grasses, forbs, and shrubs that are a food source for the quail. Intermittent human disturbance on 

the tracts may cause quail to avoid the area. Overall, the beneficial and adverse effects of 

activities in these areas on forestwide quail habitat and population are negligible.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The PEM project (#10) and thinning around special use sites (#24) are 

ongoing in the understory, where trees up to 9 inches DBH are being removed. Because of the 

small size of trees being removed and the limited acreage affected, the availability of quail habitat 

is unlikely to be measurably impacted. Removal of a few larger-diameter trees in the Turkey Flat 

area may stimulate further understory grass, forb, and shrub growth, which would, thus, improve 

quail foraging habitat, but would not result in a measurable benefit to the local or forestwide

population trajectory.

Wildland fire and fire suppression damage and/or destroy overstory trees that provide cover for 

quail. However, fires also stimulate grass, forb and shrub growth by opening the canopy; this 

provides additional food sources for the species. Recent wildland fires on the Safford Ranger 

District (Clark Peak Fire and Nuttall Complex fire), the Santa Catalina Ranger District (Aspen 

and Bullock fires), and the Nogales District (Florida Fire) adversely affected quail habitat in areas 

that burned at high intensity. Individuals were likely displaced to other habitat on the forest or on 

adjacent private, state, and BLM lands. Despite this displacement, natural succession after the 

fires will, in the long term, improve foraging habitat as a mosaic of vegetation associations and 

seral stages progress.

Because fire is a randomly occurring event of unpredictable intensity and duration, the additive 

effects that it might have in combination with the no action or the proposed action are impossible 

to quantify. However, in general, damage caused by a wildland fire on these tracts, if 

unsuppressed, could temporarily reduce quail habitat by 77 acres. This small increment of habitat 

alteration would not be expected to change the population trajectory on the forest for this species.

If the recreation residences are removed, vegetation at the tracts would replenish through natural 

succession, and quail habitat would eventually increase. This would be an additive benefit when 

considered cumulatively with the impacts of other foreseeable activities.

If the permits are issued, habitat and human disturbance would remain the same. There would be 

no additive impacts with other actions that would result in a change in the population trajectory 

on the forest for Mearn’s quail.

Peregrine Falcon (Falco perigrinus anatum)

The peregrine falcon is both a FSS and an MIS. A species and habitat description and an 

assessment of potential impacts from no action and the proposed action, including cumulative 

effects, were provided in the discussion of FSS earlier in this EIS. There is no estimate of 

forestwide habitat available for this species, however, surveys indicate that the forestwide

population has been increasing since 1986 (USDA 2005).

Based on the impacts analysis reported in the FSS discussion, neither no action nor the action 

alternatives would have a measurable effect on the forestwide population trajectory of the 

peregrine falcon.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 153

Apache trout (Oncorhyncus apache)

There are 19.6 miles of Apache trout habitat documented forestwide. However, populations in the 

Pinaleño Mountains is considered unsuitable for contributing to species recovery efforts because 

of the potential for genetic contamination with other salmonid species. As a result, removals of 

this species occurred in Ash and Frye Creeks in 2009 and 2010, so that they could be replaced 

with pure-strain Gila trout, a species more likely to have historically occurred along the northfacing slopes of these mountains. 

The Old Columbine tract lies at the headwaters of Ash Creek, which no longer contains any 

Apache trout. There are no trout streams on or downstream of Turkey Flat.

Neither alternative has any potential for impacting this species or the forestwide population 

trajectory, since removals occurred. 

Twin-spotted Rattlesnake (Crotalus pricei pricei)

This rattlesnake is locally common on talus slopes in ponderosa pine, aspen, and mixed conifer, 

generally above 8000 feet in elevation. It eats lizards and small mammals, and breeding occurs 

from late June through August. Habitats for this species are relatively secure on the Coronado NF. 

The greatest threat to the species appears to be illegal collecting (USDA 2005). Recent research 

efforts have indicated that historic habitat in the Pinaleño Mountains remains occupied.

There are 46,351 acres of twin-spotted rattlesnake habitat forestwide, and this snake is considered 

fairly common within a restricted range (USDA 2005). The 77 acres comprising the recreation 

residence tracts are not considered twin-spotted rattlesnake habitat, because no talus slopes fall 

within their boundaries. Because of this, no impacts are expected from no action or the action 

alternatives, and there would be no changes in the trajectory of forestwide populations of twinspotted rattlesnakes.

Other reasonably foreseeable actions in the project area include activities at the Arizona Bible 

Camp, the astrophysical site, Heliograph and Ladybug electronic sites, recreation sites, and 

administrative sites. Of these sites, only the Heliograph electronic site occurs directly adjacent to 

an area with a talus slope. This talus slope was at one time under the canopy cover of mixed 

conifer forest, but high-intensity fire burned the north side of the slope during the Nuttall 

Complex Fire of 2004, essentially clearing the overstory and leaving many large snags scattered 

across the area. The area has since become stabilized with some grasses growing among the talus, 

and some small patches are starting to become populated with aspen saplings. Thus, it is unlikely 

that there are twin-spotted rattlesnakes at the Heliograph site that could be affected by human 

presence.

Three thinning projects (see table 2, #10, 11, 24) are currently in the planning or implementation 

stages in the mountain range. These projects have a combined objective of restoring the 

vegetation component of the forest to a condition wherein fire will play a natural role in 

ecological processes. The areas of the PEM project (#10) and special-use project (#24) do not 

contain talus slopes, so their activities would not affect twin-spotted rattlesnakes. The PERP 

project boundary encompasses areas of talus, but because talus slopes are generally steep (more 

than 40 percent slope), treatments would not be undertaken there. Thus, it is unlikely that thinning 

projects would have a measurable impact on the forestwide population trajectory of the twinspotted rattlesnake.
Chapter 3. Affected Environment and Environmental Consequences

154 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Recent wildland fires on the Safford Ranger District (Clark Peak Fire and Nuttall Complex 

wildland fire), the Santa Catalina Ranger District (Aspen and Bullock fires), and the Nogales 

District (Florida Fire) reduced forestwide habitat for this rattlesnake in areas that burned at high

intensity. Ongoing research indicates that historical habitats in the Pinaleños are still occupied by 

this snake; therefore, it is unlikely that the Safford District fires have contributed adversely to a 

decline in the forestwide population.

There is no habitat for the rattlesnake on the residence tracts. Therefore, wildland fire in the tracts 

would not change the population trajectory on the forest for this species.

There is no habitat for the rattlesnake on the residence tracts. Therefore, implementation of the no 

action or the action alternatives in combination with the effects of other reasonably foreseeable 

actions would not change the population trajectory on the forest for the twin-spotted rattlesnake.

Mount Graham Red Squirrel (Tamiasciurus hudsonicus grahamensis)

A species and habitat description and an assessment of potential impacts from no action and the 

action alternatives, including cumulative effects, were provided in the discussion of the Federally 

endangered MGRS earlier in this EIS.

Past estimates of red squirrel habitat on Mt. Graham reported that approximately 11,700 acres of 

coniferous forest were occupied (FWS 1992, FWS 1999). More recent studies by AGFD indicate 

that approximately 16,680 acres of “potentially suitable” habitat occurs above 7,750 feet 

elevation (Hatten 2000). The most recent estimate of total suitable MGRS habitat on Mt. Graham 

was also provided by Hatten (2000), who reported that as much as 27,181 acres on Mt. Graham 

may be suitable MGRS habitat and that only a portion of this is presently occupied.

The 25-acre Old Columbine tract is suitable habitat for the MGRS. Recent (2006) surveys38

reported no middens within the tract, and two active middens outside the tract, the closest being 

15 feet from an outhouse near one of the residences.

The 52-acre Turkey Flat tract is lower in elevation and drier than Old Columbine because of its 

southern aspect; it is not considered to be prime MGRS habitat. Nevertheless, during a 2006 

survey33 midden was observed within 500 feet away from a water tank that serves the residences. 

For this analysis, both tracts were considered to be red squirrel habitat. When considered relative 

to Hatten’s estimate, the tracts comprise between 0.3 to 0.5 percent of “potentially suitable” 

habitat that is available forestwide.

No Action

If no action is taken, temporary disturbance by humans and vehicles during removal of 

improvements may disturb the squirrel, but in the long term, the tracts would experience natural 

succession that would in 50 to 100 years become red squirrel habitat. As a result, a slight increase 

in potential squirrel habitat of up to 77 acres (between 0.3 to 0.5 percent of present forestwide

habitat) would be realized. This is a very small increment and is not likely to contribute 

significantly to a change in the forestwide population trajectory of the MGRS.

 

38 Field visit by Anne Casey, Safford District Biologist, and Ms. Thetis Gamberg, FWS.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 155

Proposed Action

The area around the Old Columbine recreation residences has long been occupied by the MGRS 

despite the presence of residences and humans. While human disturbance would continue with 

permit renewal, the acreage of habitat available to the species would not change. The recent 

Biological Opinion issued by FWS regarding potential impacts to the endangered MGRS 

concurred with the Forest Service assessment that the proposed action “may affect, and is likely 

to adversely affect” the MGRS (USDA 2007). The BO reported that an incidental “take” of two

squirrels may occur if the proposed action is implemented. Such a loss would not contribute 

significantly to the forestwide population trajectory of the squirrel.

Cumulative Effects

Cumulative effects of other reasonably foreseeable actions were reported earlier in this EIS in the 

TES discussion. Based on the analysis, no action and the action alternatives would not have a 

measurable effect on the forestwide population trajectory of the MGRS.

Gould’s Turkey (Meleagris gallopavo mexicana)

Gould’s turkey is listed as both a FSS and MIS. A description of the species and habitat and an 

assessment of impacts are provided in the FSS discussion above.

There is no estimate of acres of available habitat forestwide, but this species also occurs in the 

Huachuca, Peloncillo, and Galiuro Mountains of the Coronado NF (USDA 2005). Since 

reintroductions in specific locations in the Pinaleños in 2004 and 2005, turkeys have increased in 

number and spread to all areas of the mountains (Safford Ranger District Sighting Information, 

unpublished data).

The 77 acres comprising both tracts could reasonably be considered turkey habitat; turkeys are 

regularly seen in and around the Old Columbine area. Gould’s turkey habitat available within the 

Pinaleño Mountains is about 198,400 acres, which includes areas of spruce-fir forest, mixed

conifer forest, pine-oak woodlands, chaparral areas, and desert grasslands; recent sightings have 

been reported in all of these vegetation associations (Safford Ranger District Sighting 

Information, unpublished data). The 77 acres of the two tracts comprises less than 0.04 percent of 

locally available turkey habitat.

No Action

If no action is taken, the tracts would revegetate naturally, providing additional habitat as shrubs, 

grasses, and forbs replenish areas denuded by removal activities. It is likely that this stage of 

succession would allow for increased insect populations, which would also provide additional 

food sources for Gould’s turkeys. Additional grass and shrub habitat would be available until 

succession progresses to a later stage, allowing the growth of trees, which could also provide 

additional food sources and roosting sites for turkeys.

During residence removal, turkeys may be temporary disturbed by human presence and noise and 

would likely avoid the area. However, they would benefit in the long term, because of an increase 

in understory growth of forbs and shrubs. In the short term, habitat alteration on the tracts may 

disturb the turkey, but in the long term, natural succession would result in an incrementally small 

net local increase (0.04 percent) in turkey habitat. This change would not alter the Gould’ turkey 

population trend either locally in the Pinaleños or forestwide.
Chapter 3. Affected Environment and Environmental Consequences

156 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Proposed Action 

If the proposed action is implemented, no change in turkey density or abundance is expected. 

Openings maintained around recreation residences may provide additional nutrients and 

encourage understory growth in the surrounding area. However, human presence may cause 

temporary disturbance to turkeys when residences are occupied.

These changes would have a negligible impact on turkey populations locally and forestwide.

Cumulative Effects

Cumulative effects of other reasonably foreseeable actions on Gould’s turkey were reported 

earlier in this EIS in the FSS discussion. Based on the analysis, no action and the action 

alternatives would not have a measurable effect on the forestwide population trajectory of the 

turkey.

Fire Management

The presence of the recreation residences and other human-made structures on Mt. Graham

influences choices made by the forest with regard to prescribed fire application for the 

management of fuels, use of wildland fire (natural ignitions) for resource improvement and fuel 

reduction, fire suppression, and public and firefighter safety.

Many ecosystems depend on fire for their composition and health. Fire, ranging from low to highintensity and frequent to infrequent intervals, is an important natural process in forest, brush, and 

prairie environments. Some vegetation communities, such as open ponderosa pine stands, depend 

on frequent lower-intensity fires in cycles of five to 25 years (Danter 2008). Others, such as 

chaparral (manzanita/scrub oak), depend on periodic higher-intensity fires with intervals of 15 to 

20 years (Danter 2008). In mixed conifer regimes, fire tends to occur less frequently but with 

greater intensity. Prior to European settlement, Southwestern ponderosa pine forests had far fewer 

trees than today and had frequent, low-intensity surface fires. Each fire unique to a vegetation 

community is important in maintaining the sustainability of that ecosystem. 

When natural processes or aggressive fire suppression results in the elimination of periodic

natural fires from fire-dependent environments, changes in species density, composition, and 

structure can occur, leading to overcrowding, decline in species health, and an increased potential 

for insect and disease outbreak. Concurrently, vegetative fuels accumulate, increasing the 

probability of catastrophic wildland fire.

The Forest Service seeks to improve overall forest health and lessen the risk of catastrophic

wildland fires by taking actions that alter specific characteristics of forest communities so that 

they more closely reflect historic, ecological conditions. At the same time, the Forest Service 

recognizes that community resources, including human life and structures, warrant protection and 

mitigation from the devastating effects of catastrophic fire. Balancing these competing objectives 

continues to be difficult.

Regulatory Framework

The Coronado Fire Management Plan (USDA-FS, 2006a) documents the various strategies used 

to determine the Appropriate Management Response (AMR) to wildland fires, including methods 

for managing the burnable vegetation (fuel) in the management areas identified in the forest plan; 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 157

Fire Management Units (FMUs); Fire Management Analysis Zones (FMAZs); and Ecosystem 

Management Areas (EMAs).

The National Fire Plan describes various approaches for accomplishing hazardous fuel reduction 

and for assisting communities that have been or may be threatened by wildland fire. Federal 

Wildland Fire Management Policy states that the protection of human life is the single overriding 

suppression priority. Fires are suppressed at minimum cost, considering firefighter and public 

safety, and all values to be protected, consistent with resource objectives.

Fire Management Analysis Zones 

The Coronado NF is presently divided into planning units, referred as Fire Management Analysis 

Zones (FMAZs), which are grouped according to common fire management direction and fire 

behavior characteristics. These include:

FMAZ A: This zone occurs at high elevations having high resource value. Seventy-five 

percent of the Pinaleño Mountains EMA lies in this zone. Vegetation includes mixed 

conifer, ponderosa pine, and oak woodland communities. The high resource values of 

this zone are linked to the presence of recreation residence tracts, private land and 

structures, multiple high use recreation areas, threatened and endangered species, and 

astrophysical sites.

FMAZ B: This zone occurs at low elevations having low resource values. Twentyfivepercent of the Pinaleño EMA is in this zone.

FMAZ C: This zone occurs at low elevations having high resource values. There are no 

FMAZ C zones in the project area.

Fire Suppression Considerations

Over an analysis period from 1985 to 2010, FMAZ A has experienced 414 fires. Of these, 302 

were the results of a natural occurrence (lightning) and 112 were of human origin, compared to 

FMAZ B, which experience 27 fires, nineteen of which were natural (lightning) and 8 were 

human caused. Both tracts were threatened by recent large wildland fires in their immediate 

vicinity: the Nuttall fire in 2004 and the Clark Peak fire in1996. Other fires that have threatened 

the recreation residences and Federally listed species (specifically, Mt. Graham red squirrel and 

Mexican spotted owl) were suppressed during the initial attack. The Helldive fire of 2011 is one 

example.

Affected Environment

Vegetation in the Old Columbine tract is primarily mixed conifer with a considerable amount of 

intermixed spruce. Some of these stands have been previously thinned. This tract sits at the head 

of the Ash Creek drainage, which makes it vulnerable to wildland fire because of the high 

potential for uphill runs.

In the Turkey Flat area, the lower elevation stand is a pine-oak mix, and the upper elevation is a 

drier mixed conifer with small amounts of spruce intermixed. This area has a moderate fuel 

loading as a result of continued fuels treatments in the area, which could support low to high

intensity fire behavior. Adjacent to Turkey Flat are high fuel loadings that could create moderate 

to extreme fire behavior outside of the tract. These fire conditions are dependent on the weather 
Chapter 3. Affected Environment and Environmental Consequences

158 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

and time of year. This tract sits approximately mid-slope of the drainage, which places the 

structures in an adverse part of the canyon for fire protection. 

In both tracts, the potential for moderate to high fire intensity behavior is possible due to ongoing 

drought conditions, higher than normal fuel loads adjacent to the tracts, and steep slopes. Inside 

the tract boundaries, the vegetation (trees and brush) and ground debris (pine needles and sticks) 

are intermixed with burnable material, including structures, vehicles, propane tanks, wood piles, 

and outdoor furniture.

Fire regime condition classes measure the degree of an ecosystem’s departure from reference 

conditions. The three fire regime condition classes are based on no or low (FRCC 1), moderate 

(FRCC 2), and high (FRCC 3) departure from the central tendency of the reference conditions 

(Hann et al, 2003). This departure is identified by changes in key ecosystem components, such as 

vegetation characteristics (species composition, structural stage, stand age, canopy closure, and 

mosaic pattern); fuel composition; fire frequency, severity, and pattern; and other associated 

disturbances, such as insect and disease mortality, grazing, and drought. 

The Fire Regime Condition Class (FRCC)39 for Turkey Flat was formerly Class 3, but it has been 

reduced to a Class 2 as a result of fuels treatments and prescribed fires. Treatments were designed 

to return the area to a more natural (historical) range (Hahn et al, 2003). The Turkey Flat tract is 

situated in the interior of a canyon, and the fuels in the area can best be described as both fuel 

model 8 (mixed conifer stand of white pine, Douglas-fir, and white fir) and fuel model 9 

(ponderosa pine with needle cast as the primary carrier) .

The FRCC for the Old Columbine tract is Class 1, which is within the natural range or reference

condition of what the regime would have been prior to Euro-American settlement in the area. The 

natural range is preferable for ecosystem restoration. The Old Columbine tract is located at the 

top (head) of the canyon as the slope starts to level out. This area is located in an area that 

transitions from fuel model 8, into fuel model 10 (mixed conifer with heavy dead and down 

ground fuels) which burns at a much higher intensity due to the heavier concentration of ground 

fuels (Anderson,1982).

Environmental Consequences

Direct and Indirect Effects, Old Columbine

No Action – Alternative 1

Old Columbine tract is vulnerable to wildland fire because of its location at the head of Ash 

Creek. Fires in or near Ash Creek have the potential to run up-canyon, creating moderate to 

extreme fire behavior and threatening the recreation residences. In the Old Columbine tract, a 

considerable amount of hazardous tree removal has been accomplished over the last 15 years as 

well as some thinning in the surrounding area during the Pinaleño Ecosystem Management 

Project (PEM) and the Nuttall fire of 2004.

 

39 A fire regime condition class (FRCC) is a classification of the degree of departure from the natural 

(historic) regime. There are no wildland vegetation and fuel conditions or wildland fire situations that do 

not fit within one of the three classes (see 

http://www.nwcg.gov/teams/wfewt/message/FrccDefinitions.pdf).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 159

If the residences are removed from Old Columbine, thinning (at a cost of $300-$1000/acre plus) 

would not need to be repeated to maintain a defensible space40 but would be necessary on a lessfrequent basis to maintain ecosystem health and FRCC1. There would be a lesser need for the 

removal of hazard trees, and future structure protection would not be necessary during a wildland 

fire event. With the structures removed and as a result of fuels treatments within the area, fire 

managers may have greater ability to apply managed wildland fire techniques and allow natural 

ignition fires to burn for resource benefit with less need for point-source protection and reduced 

liability issues.

Current fuels management policies dictate that the majority of fuels funding will be prioritized in 

areas having a WUI. With the residences removed, funding for treatments may decrease. The 

likelihood of future fuels treatments occurring may decline as funding priorities for landscape 

fuels treatment projects may be more difficult to secure due to the lack of resource values present. 

However, as stewardship contracting becomes more common on the forest, fuels treatments could 

likely be completed with lower overall federal expense, as matching and grant dollars aid in 

project prioritization.The District has just completed a non-WUI landscape-scale EIS [Pinaleño 

Ecosystem Restoration Project (PERP)], for which a Record of Decision was signed onOctober 

31, 2011. The PERP will treat 3,000 acres of fuels beginning in the fall of 2012.

With the structures removed, prescribed fire would be easier to implement as a management tool 

to improve the FRCC. However, concerns about effects on Federally listed species also influence 

decisions to not allow naturally ignited fires to burn in the general area until further fuels 

treatment can be completed. Pre-treatment will allow for more desirable fire effects and help limit 

the loss of individuals and habitat (specifically, Mt. Graham red squirrel and Mexican spotted 

owl).

Current fuel loading, lack of funding, species concerns, and policy mandates could cause 

degradation of vegetation communities and encourage the succession of a a less fire-tolerant 

landscape if naturally-ignited fires with low to moderate fire behavior are not allowed to burn. 

However, as current and planned treatments are implemented, fuels conditions will improve; 

managed wildfire and prescribed fire will become more viable options in these areas with the 

cabins removed.

Proposed Action – Alternative 2

If new permits are issued, the need for Forest Service fuels thinning projects and fire suppression 

would continue due to structures and listed species in the area. However, the presence of 

structures allows the area to continue to receive a higher priority rating than a non-WUI area 

would normally receive. Therefore, continued abilities to secure funds to treat the surrounding 

area are more probable with cabins present.

Given the current conditions within the Old Columbine tract, structure protection and fuels 

treatment projects are more cost effective than previous, due to continued maintenance within the 

tract. The treatments already completed could aid in implementation of treatment on landscape 

 

40 Defensible space is an area around a structure where fuels and vegetation are treated, cleared or reduced 

to slow the spread of wildland fire towards the structure. It also reduces the chance of a structure fire 

moving from the building to the surrounding forest. Defensible space is an area where flame lengths and 

fire intensity are reduced enough to allow firefighters to contain the spread of wildland fire.
Chapter 3. Affected Environment and Environmental Consequences

160 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

surrounding the immediate structure area, ultimately improving the surrounding habitat and 

returning the area to a natural fire cycle. 

However, as stewardship contracting becomes more common on the forest, fuels treatments could 

likely be completed with lower overall federal expense as matching and grant dollars assist with 

project prioritization. The Safford Ranger District has just completed a non-WUI landscape-scale 

EIS [Pinaleño Ecosystem Restoration Project (PERP)], for which a Record of Decision was 

signed on October 31, 2011. The PERP will treat 3,000 acres, beginning in the fall of 2012.

If permits are issued, there is a possibility of fires being ignited within the recreation tracts and 

spreading to the surrounding areas. The Forest Service could, and in 2011 did, exercise its 

authority to close the forest or limit use of recreation residence tracts during peak fire danger 

periods. This would limit the possibility of a catastrophic fire igniting inside these tracts. It would 

not affect the likelihood of fire starts from natural occurrences.

The presence of structures in a forested setting also increases the need for protection and 

firefighting resources, which increases concerns about firefighter and public safety as well as 

costs of fire suppression. The presence of structures within treatment areas also increases the 

complexity and cost for prescribed fires, and will factor into the potential for allowing natural 

ignition fires to burn for resource benefit.

Direct and Indirect Effects, Turkey Flat

No Action – Alternative 1

Fuel reduction projects are currently being implemented to aid in the protection of structures and 

alter fire behavior. If the structures are removed after the expiration of the 10-year closeout 

permit, these projects would likely fall to a lower priority level due to the agency direction that 

mandates high percentages of fuels budget be used for WUI protection. However, as stewardship 

contracting becomes more common on the forest, fuels treatments could likely be completed with 

lower overall federal expense as matching and grant dollars aid in project prioritization.

With the structures removed and as a result of fuels treatments within the area, fire managers may 

have greater ability to apply managed wildland fire techniques and allow natural ignition fires to 

burn for resource benefit with less need for point-source protection and reduced liability issues. . 

This ability could be affected by the prioritization of fuels funding on the forest.

Current fuel-loading, lack of funding, species concerns, and policy mandates could cause 

degradation of vegetation communities and encourage the succession of a less fire-tolerant 

landscape if naturally-ignited fires with low to moderate fire behavior are not allowed to burn. 

However, as current and planned treatments are implemented, fuels conditions will improve; 

managed wildfire and prescribed fire will become more viable options in these areas with the 

cabins removed.

Proposed Action – Alternative 2

If new permits are issued, the need for Forest Service fuels thinning projects and fire suppression 

would continue. The presence of the structures should continue to elevate the priority level and 

allow for treatments to continue in the area. The return of a natural fire cycle of low-intensity 

fires and restoration of the natural ecosystem will progress, due to the current and future fuels 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 161

treatments within the area. This allows fire managers to manage wildfires to help return the 

landscape to pre-European conditions.

Under the proposed action, there is a possibility of fires being ignited within the recreation tracts 

and spreading to the surrounding areas. The Forest Service could, and in 2011 did, exercise its 

authority to close the forest or limit use of recreation residence tracts during peak fire danger 

periods. This would limit the possibility of a catastrophic fire igniting inside these tracts.

The presence of structures in a forested setting increases the need for protection and firefighting 

resources which increases the risk for firefighter and public safety, as well as costs of fire 

suppression. The presence of structures within treatment areas also increases the complexity and 

cost for prescribed fires, and will factor into the potential for allowing natural ignition fires to 

burn for resource benefit.

Issue Turkey Flat Only – Alternative 3

Impacts would be the same as those described for alternative 1 at Old Columbine and alternative 

2 for Turkey Flat.

Issue Old Columbine Only – Alternative 4

Impacts would be the same as those described for alternative 1 at Turkey Flat and alternative 2 at

Old Columbine.

Cumulative Effects

No Action

The cumulative effects of removing the recreation residences, in conjunction with adjacent acres 

burned by recent large fires and the adjacent past and future fuel reduction projects, may give fire 

managers more management options (i.e., manage wildland fire for resource benefits and apply 

prescribed fire over larger acreage) across the entire Pinaleño EMA. Agency policy on decreased 

funding of fuels treatments in non-WUI situations could have an effect on this and other projects 

proposed for the Pinaleño Mountains. Fuels treatments currently completed around the cabins 

could improve the potential for managed use of natural ignitions, as liability and values at risk are 

reduced. Current fuel-loading, lack of funding, species concerns, and policy mandates may 

contribute to the degradation of vegetation communities and encourage the succession of a less 

fire-tolerant landscape if naturally-ignited fires with low to moderate fire behavior are not 

allowed to burn. However, as current and planned treatments are implemented, fuels conditions 

will improve; managed wildfire and prescribed fire will become more viable options in these 

areas with the cabins removed.
Chapter 3. Affected Environment and Environmental Consequences

162 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Proposed Action

Fuels treatment projects are considerably more expensive than similar projects in sparsely 

populated areas of the Forest because of the presence of the structures on the recreation residence 

tracts. Given the large number of acres affected by recent large wildland fires and the need for

future fuels reduction projects in the project area, issuing new permits for the residences on both 

tracts would likely increase requests for and disbursement of funding for fuels and fire 

management on the District. A risk-benefit analysis would continue to play an essential role in a 

wildland fire suppression response; the cabins would continue to be considered a value at risk that 

requires protection. Nevertheless, firefighter safety will always be the most critical determinant in

the Forest Service’s response to a wildland fire.

Issue Turkey Flat Only – Alternative 3

Cumulative effects for alternative 1 would apply to the Old Columbine Area; cumulative effects 

for alternative 2 would apply to Turkey Flat.

Issue Old Columbine Only – Alternative 4

Cumulative effects for alternative 2 would apply to the Old Columbine Area; cumulative effects 

for alternative 1 would apply to Turkey Flat.

Climate Change

In a Biological Opinion on April 30, 2012, with regard to reinitiated consultation with the Forest 

Service, Region 3, regarding the effects of direction in the Coronado Forest Plan on listed species 

and habitat, the FWS reported the following about the issue of climate change, also referred to as 

global warming:

“According to the Intergovernmental Panel on Climate Change (IPCC 2007) ‘Warming of the

climate system is unequivocal, as is now evident from observations of increases in global

average air and ocean temperatures, widespread melting of snow and ice, and rising global

average sea level.’ Average Northern Hemisphere temperatures during the second half of the

20th century were very likely higher than during any other 50-year period in the last 500 years

and likely the highest in at least the past 1300 years (IPCC 2007). It is very likely that over the

past 50 years cold days, cold nights and frosts have become less frequent over most land areas,

and hot days and hot nights have become more frequent (IPCC 2007). Data suggest that heat

waves are occurring more often over most land areas, and the frequency of heavy precipitation

events has increased over most areas (IPCC 2007).

The IPCC (2007) predicts that changes in the global climate system during the 21st century 

will very likely be larger than those observed during the 20th century. For the next two 

decades a warming of about 0.2°C (0.4°F) per decade is projected (IPCC 2007). Afterwards, 

temperature projections increasingly depend on specific emission scenarios (IPCC 2007). 

Various emission scenarios suggest that by the end of the 21st century, average global 

temperatures are expected to increase 0.6°C to 4.0°C (1.1°F to 7.2°F) with the greatest 

warming expected over land (IPCC 2007).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 163

Localized projections suggest that the Southwest may experience the greatest temperature 

increase of any area in the lower 48 states (IPCC 2007), with warming in southwestern states 

greatest in the summer (IPCC 2007b). The IPCC also predicts hot extremes, heat waves, and 

heavy precipitation will increase in frequency (IPCC 2007). There is also high confidence that 

many semi-arid areas like the western United States (U.S.) will suffer a decrease in water 

resources due to climate change (IPCC 2007), as a result of less annual mean precipitation and 

reduced length of snow season and snow depth (IPCC 2007). 

The increase in global temperature is already putting pressure on ecosystems and the plants 

and animals that co-exist in those systems. Warmer temperatures during the second half of the 

20th century have begun to shift the growing season in many parts of North America by 

increasing it as much as two weeks (Regonda et al. 2005). In addition, spring is coming 

earlier. This change in the growing season affects the broader ecosystem. Migrating animals 

have to start seeking food sources earlier. The shift in seasons may already be causing the 

lifecycles of pollinators, like bees, to be out of synch with flowering plants and trees. This 

mismatch can limit the ability of both pollinators and plants to survive and reproduce, which 

would reduce food availability throughout the food chain.

An extended growing season also means that plants need more water to keep growing 

throughout the season or they will dry out, increasing the risk of wildfire. Once the growing 

season ends, the shorter, milder winters fail to kill dormant insects, increasing the risk of 

large-scale insect infestations in subsequent seasons (Seager et al. 2007).

In some ecosystems, maximum daily temperatures might climb beyond the tolerance of

indigenous plants and animals. To survive the extreme temperatures, both marine and landbasedplants and animals have started to migrate towards the poles. Those species, and in some 

cases, entire ecosystems, that cannot quickly migrate or adapt, may ultimately face extinction.

Emissions of atmospheric pollutants from man-made sources at the recreation-residence tracts 

(e.g., heaters, mechanical equipment, vehicles) are not measurable nor are their effects relative to

the larger context of climate change. While these effects would continue over the 20-year period 

of the newly issued permits, the effects on climate change would continue to be unknown. 

If no action is taken, and the residences are removed, these sources would cease to exist.

Unavoidable Adverse Effects

Unavoidable adverse impacts of the proposed action are those that occur when:

 There are no reasonably practicable mitigation measures to avoid or minimize 

adverse impacts.

 There are no reasonable alternatives to the proposed action that satisfy the purpose of 

and need for the action, eliminate the impact(s), and/or in themselves, do not result in 

other or similar adverse impacts.

In essence, unavoidable adverse impacts on natural and human resources are those that would 

exist after project implementation, even after mitigation measures have been applied.
Chapter 3. Affected Environment and Environmental Consequences

164 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

The proposed action of reissuing permits for the recreation residences on the Safford Ranger 

District would not result in any unavoidable adverse impacts to the various resources evaluated in 

this EIS.

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments result in the absolute loss of a resource, such as the extinction of a 

species or the removal of a mineral or an ore from the earth. Irretrievable commitments are those 

that are lost for a limited period of time, such as the decrease in timber productivity of forested 

areas that are cleared for use as a power line right-of-ways or road. An irreversible commitment is 

one that lasts forever; an irretrievable commitment is one that constrains the production or use of 

a renewable resource for a short to medium period of time (i.e., several or many years).

There will be no irreversible commitments of resources from any of the alternatives or actions 

analyzed in this EIS. Implementation of the proposed action would continue recreational use of 

the tracts for a minimum of 20 years, which is an irretrievable commitment that would delay 

natural succession and the eventual full restoration the tracts to historic forest conditions.
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 165

Chapter 4. Consultation and Coordination

This EIS was prepared by the following Forest Service staff:

Interdisciplinary Team Members

Duane Bennett Zone Lands and Special Uses Specialist

Robert Lefevre Coronado NF Watershed and Forestry Program Manager*

Anne Casey Safford Ranger District Wildlife Biologist

Debby Kriegel Coronado NF Landscape Architect

Andrea Campbell Coronado NF NEPA Coordinator*

Larry Jones Coronado NF Acting Wildlife Program Manager*

Sarah Davis Coronado NF Public Affairs Office*

Pete Schwab Coronado NF Fire and Aviation Officer

Mary Anna Wheat Recreation Specialist*

Celeste Gordon Recreation and Special Uses Program Manager*

Mary Farrell Coronado NF Archaeologist/Heritage Program Manager*

MiMi Battin Geographic Information System Mapping

Forest Service Enterprise Team: Recreation Solutions

Joni Akin ID Team, Administrative Support

Tracy Anderson Interdisciplinary Team Leader 

David DelSordo Writer/Editor

Miles Friend Writer/Editor

*No longer with Forest

The Forest Service consulted the many individuals, Federal, State, and local agencies, Tribes and 

non-Forest Service persons during the development of this EIS. Among them were the following 

agencies and Tribes:

Federal, State, and Local Agencies

U.S. Fish and Wildlife Service

Advisory Council on Historic Preservation

Arizona Department of Economic Security

Arizona Department of Environmental Quality
Chapter 4. Consultation and Coordination

166 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

Arizona Department of Water Resources

Arizona Game and Fish Department

Arizona State Historic Preservation Office

University of Arizona

Graham County Assessor

Graham County Treasurer

Tribes:

Ak-Chin Indian Community

Ft. Sill Apache Tribe

Gila River Indian Community

Hopi Cultural Preservation Office

Mescalero Apache Tribe

Pascua Yaqui Tribe

Pueblo of Zuni

Salt River Pima-Maricopa Indian Community

San Carlos Apache Tribe

Tohono O’odham Nation

White Mountain Apache Tribe

Yavapai-Apache Nation
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 167

Chapter 5. Literature Cited 
Chapter 5: Literature Cited

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 168

Angle, L. 2006. Personal communication (electronic mail) from Lisa Angle, Safford Ranger 

District Recreation Staff; Duane A. Bennett, Zone Lands and Special Uses Staff, Sierra 

Vista Ranger District, Coronado National Forest; to Barbara Ott, Social Scientist, USDAFS, TEAMS Enterprise Team, regarding the history and acreage of the Old Columbine 

and Turkey Flat recreation residence tracts.

——. 2006a. Personal communication (electronic mail) from L. Angle to B. Ott, regarding access 

and fees for Old Columbine and Turkey Flat recreation residence tracts.

——. 2006b. Personal communication (electronic mail) from L. Angle to B. Ott, regarding

residence sales at Old Columbine and Turkey Flat recreation residence tracts.

——. 2006c. Personal communication (electronic mail) from L. Angle to B. Ott, regarding Cabin 

Owners Associations, season of use, and springs at the Turkey Flat and Old Columbine 

recreation residence tracts.

Anderson, H.E. 1982. “Aids to Determining Fuel Models for Estimating Fire Behavior,” GTR 

INT -122. InterMountain Forest and Range Experiment Station, Ogden, Utah.

Arizona Breeding Bird Atlas, edited by T. Corman and C. Wise-Gervais, 2005. University of New 

Mexico Press, Albuquerque. pp. 324-325.

Arizona Department of Economic Security, R. A. 2006. Arizona population projections 2006 to 

2055, Arizona Department of Economic Security, Population Statistics Unit, Arizona.

Arizona Department of Environmental Quality (ADEQ). 2002. “Morenci Sulfur Dioxide Nonattainment Area State Implementation and Maintenance Plan,” Arizona Department of 

Environmental Quality, Air Quality Division, June 2002. Available online:

http://www.azdeq.gov/environ/air/plan/download/morencisip.pdf (March 27, 2007)

——. 2004. “2004 Integrated 305(b) Assessment and 303(d) Listing Report,” Arizona 

Department of Environmental Quality. Available online: 

http://www.azdeq.gov/environ/water/assessment/2004.html and 

http://www.azdeq.gov/environ/water/assessment/index.html (March 27, 2007)

——. 2006. Air quality plans: non-attainment areas and attainment area with maintenance plans, 

Arizona Department of Environmental Quality, 

http://www.azdeq.gov/environ/air/plan/notmeet.html (March 27, 2007)

Arizona Department of Water Resources (ADWR). 1931. Certificate of Water Right (CWR) #479

——. 1938. Certificate of Water Right (CWR) #1089

——. 1985. Water Right Application, Turkey Flat and Old Columbine, 33-94735

Arizona Game and Fish Department (AGFD). 1999. Astragalus cobrensis var maguirei.

Unpublished abstract compiled and edited by the Heritage Data Management System, 

Arizona Game and Fish Department, Phoenix, AZ. 3 pp.

——.. 2000. Hackelia ursina. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 3 pp.
Chapter 5: Literature Cited

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 169

——. 2000. Hedeoma dentatum. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 pp.

——. 2001. Cicindela purpurea cimarrona. Unpublished abstract compiled and edited by the 

Heritage Data Management System, Arizona Game and Fish Department, Phoenix, AZ. 3 

pp.

——. 2001. Eumorsea Pinaleño . Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 3 pp.

——. 2001. Neophasia terlootii. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 3 pp.

——. 2001. Strix occidentalis lucida. Unpublished abstract compiled and edited by the Heritage 

Data Management System, Arizona Game and Fish Department, Phoenix, AZ.

——. 2003. Accipiter gentilis. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 8 pp.

——. 2003. Microtus longicaudus leucophaeus. Unpublished abstract compiled and edited by the 

Heritage Data Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 

pp.

——. 2003. Sonorella imitator. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 pp.

——. 2004. Heuchera glomerulata. Unpublished abstract compiled and edited by the Heritage 

Data Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 pp.

——. 2004. Eupatorium bigelovii. Unpublished abstract compiled and edited by the Heritage 

Data Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 pp.

——. 2004a. Hieracium rusbyi. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 4 pp.

——. 2005. Otus flammeolus. Unpublished abstract compiled and edited by the Heritage Data 

Management System, Arizona Game and Fish Department, Phoenix, AZ. 7 pp.

——. 2008. Estimates for the Mt. Graham Red Squirrel Since the Inception of a Biannual 

Interagency Survey in 1986, personal communication with Anne Casey, Safford District.

Arizona Tax Research Association. 2006. Budget reviews: county Fiscal Year 2006-07 total fund 

tentative budgets.

Basso, Keith. 1996. Wisdom Sits in Places: Landscape and Language Among the Western 

Apache. University of New Mexico Press, Albuquerque.

Bennett, D. A. 2006. Personal communication (electronic mail) between Duane Bennett, Zone 

Lands and Special Uses Staff, Sierra Vista Ranger District, Coronado National Forest and 

Barbara Ott, Social Scientist, USDA-FS, TEAMS Enterprise Team. Correspondence

provides estimated costs relative to recreation residence term special use permit analysis.
Chapter 5: Literature Cited 

170 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

——. 2006a. Personal communication (electronic mail) between D. Bennett and B. Ott regarding 

changes in recreation residence ownership within Old Columbine and Turkey Flat 

recreation residence tracts.

——. 2006b. Personal communication (electronic mail) between D. Bennett and B. Ott regarding 

the names of the cabin owner's associations at the Old Columbine and Turkey Flat 

recreation residence tracts.

——. 2006c. Personal communication (electronic mail) between D. Bennett and B. Ott regarding 

the capacities served by the home owner's associations and infrastructure at the Old 

Columbine and Turkey Flat recreation residence tracts.

——. 2006d. Personal communication (electronic mail) between D. Bennett and B. Ott regarding 

users and facilities at the Old Columbine and Turkey Flat recreation residence tracts.

——. 2006e. Personal communication (electronic mail) between D. Bennett and Tracy Anderson, 

Interdisciplinary Team Leader, USDA-FS, Recreation Solutions Enterprise Team 

regarding acreages of Turkey Flat and Old Columbine recreation residence tracts. 

Carleton et al. 1991. (Carleton, J.O., Robbie, W.A., Shaw, D.; Gass, J.; Brown, H.G. III; Spann, 

C., Robertson, G., Miller, G., Popp-Galeano, R., Fletcher, R., Potter, D.U., Moir, W.H.,

and T. Robison. General ecosystem survey. U.S. Department of Agriculture, Forest

Service, Southwestern Region, Albuquerque, NM.

Culbert, Mike. 2006. Personal communication with Debby Kriegel, Forest Supervisor’s Office, 

September 28, 2006.

Danter, K. Jeffery. 2000. “Fire Dependent Ecosystems of the United States”. (article in 

Communicator’s Guide: Wildland Fire, pgs 2.11 – 2.19, by Mullins, Gary W., Ohio State 

University, United States Department of Agriculture, Forest Service. 173pp. NIFC

website: http://www.nifc.gov/preved/comm_guide/wildfire/fire_6.html (Accessed 

October 15, 2008).

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Appendices

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 179

Appendix A:

Examples of Special-Use Permit and Related 

Operation and Maintenance Plan 

Authorization ID______ FS-2700-5a (8/99)

Contact ID______ OMB No. 0596-0082

Expiration Date______ (mm/dd/yyyy)

U.S. DEPARTMENT OF AGRICULTURE

Forest Service 

TERM SPECIAL USE PERMIT

For Recreation Residences

As of March 4, 1915, As Amended

(Ref. FSM 2710)

<Holder Name> of <Address, City, State, Zip Code> (hereafter called the holder) is hereby 

authorized to use national forest lands, for a recreation residence for personal recreational use on 

the <NF Name> National Forest, subject to the provisions of this permit including items I.A 

through___, on page(s)___through___. This permit covers___acres.

Described as: (1) Lot___of the <Name of Tract> tract.

(A plat of which is on file in the office of the Forest Supervisor.)

OR (2) <Legal Description> as shown on the attached map.

The following improvements, whether on or off the lot, are authorized in addition to the residence 

structure:

This use shall be exercised at least 15 days each year, unless otherwise authorized in writing. It 

shall not be used as a full-time residence to the exclusion of a home elsewhere.

THIS PERMIT IS NOT TRANSFERABLE

PURCHASERS OF IMPROVEMENTS ON SITES AUTHORIZED BY THIS PERMIT MUST 

SECURE A NEW PERMIT FROM THE FOREST SERVICE. 

THIS PERMIT IS ACCEPTED SUBJECT TO ALL OF ITS TERMS AND CONDITIONS.

ACCEPTED _____________________________________________ ________

 HOLDER'S NAME AND SIGNATURE DATE 

APPROVED _____________________________________________ ________

 AUTHORIZED OFFICER'S NAME AND SIGNATURE, TITLE, DATE 
Appendix A: Examples of Special-Use Permit and Related Operation and Maintenance Plan

180 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

TERMS AND CONDITIONS

I. AUTHORITY AND USE AND TERM AUTHORIZED. 

A. This permit is issued under the authority of the Act of March 4, 1915, as amended (16 

U.S.C. 497), and Title 36, Code of Federal Regulations, Sections 251.50-251.64. 

Implementing Forest Service policies are found in the Forest Service Directives System 

(FSM 1920, 1950, 2340, 2720; FSH 2709.11, Chap. 10-50). Copies of the applicable 

regulations and policies will be made available to the holder at no charge upon request 

made to the office of the forest supervisor.

B. The authorized officer under this permit is the forest supervisor, or a delegated 

subordinate officer. 

C. This permit authorizes only personal recreation use of a noncommercial nature by the 

holder, members of the holder's immediate family, and guests. Use of the permitted 

improvements as a principal place of residence is prohibited and shall be grounds for 

revocation of this permit.

D. Unless specifically provided as an added provision to this permit, this authorization is for 

site occupancy and does not provide for the furnishing of structures, road maintenance, 

water, fire protection, or any other such service by a Government agency, utility 

association, or individual.

E. Termination at End of Term: This authorization will terminate on <Insert Date>.

II. OPERATION AND MAINTENANCE.

A. The authorized officer, after consulting with the holder, will prepare an operation and 

maintenance plan which shall be deemed a part of this permit. The plan will be reviewed 

annually and updated as deemed necessary by the authorized officer and will cover 

requirements for at least the following subjects:

1. Maintenance of vegetation, tree planting, and removal of dangerous trees and other 

unsafe conditions

2. Maintenance of the facilities.

3. Size, placement and descriptions of signs.

4. Removal of garbage or trash.

5. Fire protection.

6. Identification of the person responsible for implementing the provisions of the plan, 

if other than the holder, and a list of names, addresses, and phone numbers of persons 

to contact in the event of an emergency.

III. IMPROVEMENTS.

A. Nothing in this permit shall be construed to imply permission to build or maintain any 

improvement not specifically named on the face of this permit or approved in writing by 

the authorized officer in the operation and maintenance plan. Improvements requiring 

specific approval shall include, but are not limited to: signs, fences, name plates, 

mailboxes, newspaper boxes, boathouses, docks, pipelines, antennas, and storage sheds.

B. All plans for development, layout, construction, reconstruction or alteration of 

improvements on the lot, as well as revisions of such plans, must be prepared by a 

licensed engineer, architect, and/or landscape architect (in those states in which such 

licensing is required) or other qualified individual acceptable to the authorized officer. 
Appendix A: Examples of Special-Use Permit and Related Operation and Maintenance Plan

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 181

Such plans must be approved by the authorized officer before the commencement of any 

work.

IV. RESPONSIBILITIES OF HOLDER.

A. The holder, in exercising the privileges granted by this permit, shall comply with all 

present and future regulations of the Secretary of Agriculture and all present and future 

federal, state, county, and municipal laws, ordinances, or regulations which are applicable 

to the area or operations covered by this permit. However, the Forest Service assumes no 

responsibility for enforcing laws, regulations, ordinances and the like which are under the 

jurisdiction of other government bodies.

B. The holder shall exercise diligence in preventing damage to the land and property of the 

United States. The holder shall abide by all restrictions on fires which may be in effect 

within the forest at any time and take all reasonable precautions to prevent and suppress 

forest fires. No material shall be disposed of by burning in open fires during a closed fire 

season established by law or regulation without written permission from the authorized 

officer. 

C. The holder shall protect the scenic and esthetic values of the National Forest System 

lands as far as possible consistent with the authorized use, during construction, operation, 

and maintenance of the improvements.

D. No soil, trees, or other vegetation may be removed from the National Forest System lands 

without prior permission from the authorized officer. Permission shall be granted 

specifically, or in the context of the operations and maintenance plan for the permit. 

E. The holder shall maintain the improvements and premises to standards of repair, 

orderliness, neatness, sanitation, and safety acceptable to the authorized officer. The 

holder shall fully repair and bear the expense for all damage, other than ordinary wear 

and tear, to national forest lands, roads and trails caused by the holder's activities.

F. The holder assumes all risk of loss to the improvements resulting from acts of God or 

catastrophic events, including but not limited to, avalanches, rising waters, high winds, 

falling limbs or trees and other hazardous natural events. In the event the improvements 

authorized by this permit are destroyed or substantially damaged by acts of God or 

catastrophic events, the authorized officer will conduct an analysis to determine whether 

the improvements can be safely occupied in the future and whether rebuilding should be 

allowed. The analysis will be provided to the holder within 6 months of the event.

G. The holder has the responsibility of inspecting the site, authorized rights-of-way, and 

adjoining areas for dangerous trees, hanging limbs, and other evidence of hazardous 

conditions which could affect the improvements and or pose a risk of injury to 

individuals. After securing permission from the authorized officer, the holder shall 

remove such hazards.

H. In case of change of permanent address or change in ownership of the recreation 

residence, the holder shall immediately notify the authorized officer.

V. LIABILITIES.

A. This permit is subject to all valid existing rights and claims outstanding in third parties. 

The United States is not liable to the holder for the exercise of any such right or claim. 

B. The holder shall hold harmless the United States from any liability from damage to life or 

property arising from the holder's occupancy or use of national forest lands under this 

permit. 
Appendix A: Examples of Special-Use Permit and Related Operation and Maintenance Plan

182 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

C. The holder shall be liable for any damage suffered by the United States resulting from or 

related to use of this permit, including damages to national forest resources and costs of 

fire suppression. Without limiting available civil and criminal remedies which may be 

available to the United States, all timber cut, destroyed, or injured without authorization 

shall be paid for at stumpage rates which apply to the unauthorized cutting of timber in

the state wherein the timber is located.

VI. FEES.

A. Fee Requirement: This special use authorization shall require payment in advance of an 

annual rental fee. 

B. Appraisals:

1. Appraisals to ascertain the fair market value of the lot will be conducted by the Forest 

Service at least every 20 years. The next appraisal will be implemented in <Insert 

Date>.

2. Appraisals will be conducted and reviewed in a manner consistent with the Uniform 

Standards of Professional Appraisal Practice, from which the appraisal standards 

have been developed, giving accurate and careful consideration to all market forces 

and factors which tend to influence the value of the lot. 

3. If dissatisfied with an appraisal utilized by the Forest Service in ascertaining the 

permit fee, the holder may employ another qualified appraiser at the holder's expense. 

The authorized officer will give full and complete consideration to both appraisals 

provided the holder's appraisal meets Forest Service standards. If the two appraisals 

disagree in value by more than 10 percent, the two appraisers will be asked to try and 

reconcile or reduce their differences. If the appraisers cannot agree, the Authorized 

Officer will utilize either or both appraisals to determine the fee. When requested by 

the holder, a third appraisal may be obtained with the cost shared equally by the 

holder and the Forest Service. This third appraisal must meet the same standards of 

the first and second appraisals and may or may not be accepted by the authorized 

officer.

C. Fee Determination:

1. The annual rental fee shall be determined by appraisal and other sound business 

management principles. (36 CFR 251.57(a)). The fee shall be 5 percent of the 

appraised fair market fee simple value of the lot for recreation residence use. Fees 

will be predicated on an appraisal of the lot as a base value, and that value will be 

adjusted in following years by utilizing the percent of change in the Implicit Price 

Deflator – Gross National Product (IPD-GNP) index as of the previous June 30. A 

fee from a prior year will be adjusted upward or downward, as the case may be, by 

the percentage change in the IPD-GNP, except that the maximum annual fee 

adjustment shall be 10 percent when the IPD-GNP index exceeds 10 percent in any 

one year with the amount in excess of 10 percent carried forward to the next 

succeeding year where the IPD-GNP index is less than 10 percent. The base rate from 

which the fee is adjusted will be changed with each new appraisal of the lot, at least 

every 20 years. 

2. If the holder has received notification that a new permit will not be issued following 

expiration of this permit, the annual fee in the tenth year will be taken as the base, 

and the fee each year during the last 10-year period will be one-tenth of the base 

multiplied by the number of years then remaining on the permit. If a new term permit 
Appendix A: Examples of Special-Use Permit and Related Operation and Maintenance Plan

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 183

should later be issued, the holder shall pay the United States the total amount of fees 

foregone, for the most recent 10-year period in which the holder has been advised 

that a new permit will not be issued. This amount may be paid in equal annual 

installments over a 10-year period in addition to those fees for existing permits. Such 

amounts owing will run with the property and will be charged to any subsequent 

purchaser of the improvements.

D. Initial Fee: The initial fee may be based on an approved Forest Service appraisal existing 

at the time of this permit, with the present day value calculated by applying the IPD-GNP 

index to the intervening years. 

E. Payment Schedule: Based on the criteria stated herein, the initial payment is set at $ per 

year and the fee is due and payable annually on <Insert Date>. Payments will be credited 

on the date received by the designated collection officer or deposit location. If the due 

date(s) for any of the above payments or fee calculation statements fall on a nonworkday, the charges shall not apply until the close of business of the next workday. Any 

payments not received within 30 days of the due date shall be delinquent.

F. Late Payment Interest, Administrative Costs and Penalties: Pursuant to 31 U.S.C. 3717, 

et seq., interest shall be charged on any fee amount not paid within 30 days from the date 

the fee or fee calculation financial statement specified in this authorization becomes due. 

The rate of interest assessed shall be the higher of the rate of the current value of funds to 

the U.S. Treasury (i.e., Treasury tax and loan account rate), as prescribed and published 

by the Secretary of the Treasury in the Federal Register and the Treasury Fiscal 

Requirements Manual Bulletins annually or quarterly or at the Prompt Payment Act rate. 

Interest on the principal shall accrue from the date the fee or fee calculation financial 

statement is due. 

In the event the account becomes delinquent, administrative costs to cover processing and 

handling of the delinquency will be assessed.

A penalty of 6 percent per annum shall be assessed on the total amount delinquent in 

excess of 90 days and shall accrue from the same date on which interest charges begin to 

accrue.

Payments will be credited on the date received by the designated collection officer or 

deposit location. If the due date for the fee or fee calculation statement falls on a nonworkday, the charges shall not apply until the close of business on the next workday. 

Disputed fees are due and payable by the due date. No appeal of fees will be considered 

by the Forest Service without full payment of the disputed amount. Adjustments, if 

necessary, will be made in accordance with settlement terms or the appeal decision.

If the fees become delinquent, the Forest Service will:

Liquidate any security or collateral provided by the authorization.

If no security or collateral is provided, the authorization will terminate and the holder will 

be responsible for delinquent fees as well as any other costs of restoring the site to it's 

original condition including hazardous waste cleanup.

Upon termination or revocation of the authorization, delinquent fees and other charges 
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184 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

associated with the authorization will be subject to all rights and remedies afforded the 

United States pursuant to 31 U.S.C. 3711 et seq. Delinquencies may be subject to any or 

all of the following conditions:

Administrative offset of payments due the holder from the Forest Service. Delinquencies 

in excess of 60 days shall be referred to United States Department of Treasury for 

appropriate collection action as provided by 31 U.S.C. 3711 (g), (1).

The Secretary of the Treasury may offset an amount due the debtor for any delinquency 

as provided by 31 U.S.C. 3720, et seq.)

G. Nonpayment Constitutes Breach: Failure of the holder to make the annual payment, 

penalty, interest, or any other charges when due shall be grounds for termination of this 

authorization. However, no permit will be terminated for nonpayment of any monies 

owed the United States unless payment of such monies is more than 90 days in arrears.

H. Applicable Law: Delinquent fees and other charges shall be subject to all the rights and 

remedies afforded the United States pursuant to federal law and implementing 

regulations. (31 U.S.C. 3711 et seq.).

VII.TRANSFER, SALE, AND RENTAL.

A. Non-transferability: Except as provided in this section, this permit is not transferable. 

B. Transferability Upon Death of the Holder:

1. If the holder of this permit is a married couple and one spouse dies, this permit will 

continue in force, without amendment or revision, in the name of the surviving 

spouse.

2. If the holder of this permit is an individual who dies during the term of this permit 

and there is no surviving spouse, an annual renewable permit will be issued, upon 

request, to the executor or administrator of the holder's estate. Upon settlement of the 

estate, a new permit incorporating current Forest Service policies and procedures will 

be issued for the remainder of the deceased holder's term to the properly designated 

heir(s) as shown by an order of a court, bill of sale, or other evidence to be the owner 

of the improvements.

C. Divestiture of Ownership: If the holder through voluntary sale, transfer, enforcement of 

contract, foreclosure, or other legal proceeding shall cease to be the owner of the physical 

improvements, this permit shall be terminated. If the person to whom title to said 

improvements is transferred is deemed by the authorizing officer to be qualified as a 

holder, then such person to whom title has been transferred will be granted a new permit. 

Such new permit will be for the remainder of the term of the original holder. 

D. Notice to Prospective Purchasers: When considering a voluntary sale of the recreation 

residence, the holder shall provide a copy of this special use permit to the prospective 

purchaser before finalizing the sale. The holder cannot make binding representations to 

the purchasers as to whether the Forest Service will reauthorize the occupancy. 

E. Rental: The holder may rent or sublet the use of improvements covered under this permit 

only with the express written permission of the authorized officer. In the event of an 

authorized rental or sublet, the holder shall continue to be responsible for compliance 

with all conditions of this permit by persons to whom such premises may be sublet.

VIII. REVOCATION.

A. Revocation for Cause: This permit may be revoked for cause by the authorized officer 

upon breach of any of the terms and conditions of this permit or applicable law. Prior to 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 185

such revocation for cause, the holder shall be given notice and provided a reasonable time 

– not to exceed ninety (90) days – within which to correct the breach.

B. Revocation in the Public Interest During the Permit Term:

1. This permit may be revoked during its term at the discretion of the authorized officer 

for reasons in the public interest. (36 CFR 251.60(b)). In the event of such revocation 

in the public interest, the holder shall be given one hundred and eighty (180) days 

prior written notice to vacate the premises, provided that the authorized officer may 

prescribe a date for a shorter period in which to vacate ("prescribed vacancy date") if 

the public interest objective reasonably requires the lot in a shorter period of time.

2. The Forest Service and the holder agree that in the event of a revocation in the public 

interest, the holder shall be paid damages. Revocation in the public interest and 

payment of damages is subject to the availability of funds or appropriations.

a. Damages in the event of a public interest revocation shall be the lesser amount of 

either (1) the cost of relocation of the approved improvements to another lot 

which may be authorized for residential occupancy (but not including the costs of 

damages incidental to the relocation which are caused by the negligence of the 

holder or a third party), or (2) the replacement costs of the approved 

improvements as of the date of revocation. Replacement cost shall be determined 

by the Forest Service utilizing standard appraisal procedures giving full 

consideration to the improvement's condition, remaining economic life and 

location, and shall be the estimated cost to construct, at current prices, a building 

with utility equivalent to the building being appraised using modern materials 

and current standards, design and layout as of the date of revocation. If 

revocation in the public interest occurs after the holder has received notification 

that a new permit will not be issued following expiration of the current permit, 

then the amount of damages shall be adjusted as of the date of revocation by 

multiplying the replacement cost by a fraction which has as the numerator the 

number of full months remaining to the term of the permit prior to revocation 

(measured from the date of the notice of revocation) and as the denominator, the 

total number of months in the original term of the permit.

b. The amount of the damages determined in accordance with paragraph a. above 

shall be fixed by mutual agreement between the authorized officer and the holder 

and shall be accepted by the holder in full satisfaction of all claims against the 

United States under this clause: Provided, That if mutual agreement is not 

reached, the authorized officer shall determine the amount and if the holder is 

dissatisfied with the amount to be paid may appeal the determination in 

accordance with the Appeal Regulations (36 CFR 251, Subpart C) and the 

amount as determined on appeal shall be final and conclusive on the parties 

hereto: Provided further, That upon the payment to the holder of the amount 

fixed by the authorized officer, the right of the Forest Service to remove or 

require the removal of the improvements shall not be stayed pending final 

decision on appeal.

IX. ISSUANCE OF A NEW PERMIT.

A. Decisions to issue a new permit or convert the permitted area to an alternative public use 

upon termination of this permit require a determination of consistency with the Forest 

Land and Resource Management Plan (Forest Plan).
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186 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

1. Where continued use is consistent with the Forest Plan, the authorized officer shall 

issue a new permit, in accordance with applicable requirements for environmental 

documentation.

2. If, as a result of an amendment or revision of the Forest Plan, the permitted area is 

within an area allocated to an alternative public use, the authorized officer shall 

conduct a site specific project analysis to determine the range and intensity of the 

alternative public use.

a. If the project analysis results in a finding that the use of the lot for a recreation 

residence may continue, the holder shall be notified in writing, this permit shall 

be modified as necessary, and a new term permit shall be issued following 

expiration of the current permit.

b. If the project analysis results in a decision that the lot shall be converted to an 

alternative public use, the holder shall be notified in writing and given at least 10 

years continued occupancy. The holder shall be given a copy of the project 

analysis, environmental documentation, and decision document.

c. A decision resulting from a project analysis shall be reviewed two years prior to 

permit expiration, when that decision and supporting environmental 

documentation is more than 5 years old. If this review indicates that the 

conditions resulting in the decision are unchanged, then the decision may be 

implemented. If this review indicates that conditions have changed, a new project 

analysis shall be made to determine the proper action. 

B. In issuing a new permit, the authorized officer shall include terms, conditions, and special 

stipulations that reflect new requirements imposed by current Federal and State land use 

plans, laws, regulations, or other management decisions. (36 CFR 251.64).

C. If the 10-year continued occupancy given a holder who receives notification that a new 

permit will not be issued would extend beyond the expiration date of the current permit, a 

new term permit shall be issued for the remaining portion of the 10-year period.

X. RIGHTS AND RESPONSIBILITIES UPON REVOCATION OR NOTIFICATION THAT A 

NEW PERMIT WILL NOT BE ISSUED FOLLOWING TERMINATION OF THIS 

PERMIT.

A. Removal of Improvements Upon Revocation or Notification That A New Permit Will 

Not Be Issued Following Termination Of This Permit: At the end of the term of 

occupancy authorized by this permit, or upon abandonment, or revocation for cause, Act 

of God, catastrophic event, or in the public interest, the holder shall remove within a 

reasonable time all structures and improvements except those owned by the United 

States, and shall return the lot to a condition approved by the authorized officer unless 

otherwise agreed to in writing or in this permit. If the holder fails to remove all such 

structures or improvements within a reasonable period – not to exceed one hundred and 

eighty (180) days from the date the authorization of occupancy is ended – the 

improvements shall become the property of the United States, but in such event, the 

holder remains obligated and liable for the cost of their removal and the restoration of the 

lot.

B. In case of revocation or notification that a new permit will not be issued following 

termination of this permit, except if revocation is for cause, the authorized officer may 

offer an in-lieu lot to the permit holder for building or relocation of improvements. Such 

lots will be nonconflicting locations within the national forest containing the residence 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 187

being terminated or under notification that a new permit will not be issued or at 

nonconflicting locations in adjacent national forests. Any in-lieu lot offered the holder 

must be accepted within 90 days of the offer or within 90 days of the final disposition of 

an appeal on the revocation or notification that a new permit will not be issued under the 

Secretary of Agriculture's administrative appeal regulations, whichever is later, or this 

opportunity will terminate.

XI. MISCELLANEOUS PROVISIONS.

A. This permit replaces a special use permit issued to: <Previous Holder> on <Date>.

B. The Forest Service reserves the right to enter upon the property to inspect for compliance 

with the terms of this permit. Reports on inspection for compliance will be furnished to 

the holder.

C. Issuance of this permit shall not be construed as an admission by the Government as to 

the title to any improvements. The Government disclaims any liability for the issuance of 

any permit in the event of disputed title.

D. If there is a conflict between the foregoing standard printed clauses and any special 

clauses added to the permit, the standard printed clauses shall control.
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188 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

OPERATION AND MAINTENANCE PLAN

FOR

RECREATION RESIDENCE

UNDER PERMIT TO

Permit Holder/Owner

__________________________________

____________Tract, Lot No.______

____________RANGER DISTRICT

CORONADO NATIONAL FOREST
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 189

I. INTRODUCTION

A. As owner of a recreation residence (cabin) on National Forest System (NFS) lands, you

have been issued a term special-use permit, which is a contract between the Forest 

Service and the person(s) who signed that permit.

1. Clause II.A. of the special use permit requires that the Forest Service prepare (in 

consultation with the permit holder) an Operation and Maintenance Plan. This 

document fulfills that requirement, and is hereby made a part of the special-use 

permit. It will be reviewed annually and updated as necessary by the District Ranger.

2. If a change in the operation and maintenance plan warrants an environmental 

analysis, it will be conducted in accordance with National Environmental Policy Act 

(NEPA) and the effects of the changes documented. 

B. To ensure that the lot and cabin are being appropriately maintained, an inspection will be 

scheduled annually, with a copy of the findings sent to you. A copy of the checklist we 

will use is available for review at the Ranger Station. If this Operation and Maintenance 

Plan is followed, in conjunction with the Term Special-Use Permit, together we can 

assure that mutual objectives are met.

C. The permit holder responsible for implementing this plan is: 

______________________________________________________________________________

NAME

______________________________________________________________________________

ADDRESS

______________________________________________________________________________

PHONE

The person(s) to contact in the event of an emergency (if other than the holder) is: 

__________________________________________ __________________________

NAME PHONE
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190 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

II. LOT MAINTENANCE

A. Hazard Removal

It is the permit holder's responsibility to inspect the lot, driveway, and immediate 

adjoining areas to their lot for dangerous trees, hanging limbs, and other evidence of 

hazardous conditions and, after securing written permission from the Forest Service, to 

remove such hazards. If it is felt that any snag (a dead, standing tree), large limb, leaning 

tree (whether dead or green), etc., on or off the lot, is (or could become) a safety hazard, 

notify Douglas District Ranger. It is the permit holder's responsibility to remove any 

hazard, on or off the lot, which may pose a threat to safety.

B. Vegetation Maintenance

Vegetation maintenance, other than the fire prevention requirements (VIII. B.) of this 

plan, is discouraged due to a number of potential adverse impacts, such as erosion 

problems, reduction of wildlife habitat, and visual screening. If there is some vegetation 

removal that the holder considers necessary, contact the Ranger District office with a 

written proposal. 

Planting of native species of trees, shrubs and flowers may be done to enhance or restore 

a natural appearing forested setting – after securing written permission from the Forest 

Service. Remember that little trees become big ones, so do not plant them too close to 

buildings. Planting of non-native species of trees, shrubs and flowers, is prohibited.

C. Miscellaneous Items

1. Swings, yard lights, signs, wires or other materials shall not be attached to trees. 

2. Outdoor fire rings or pits are not authorized.

3. All items not specifically stated on the permit must be stored inside the cabin or 

removed from NFS lands when the residence is not in use. This includes all sports 

and play equipment (including horseshoe stakes, swings, etc), tools, signs, barbeque 

grills, picnic tables, fake plants, etc.

4. Authorization for outside lights needed for safety may be granted. Lights must be 

mounted on buildings. All outside lights must be shielded so the light shines directly 

on the yard or on entrances and not affect adjacent lots or NFS lands.

5. When approved, new electric lines (excluding the main service line) must be buried. 

Existing over-head lines will be buried when they are in need of replacement. All 

electrical work will meet current county codes.

6. Precautions to prevent soil erosion will be taken by keeping vehicles on established 

roads and by parking only in approved areas. Approved areas will be sufficient to 

hold two vehicles. Enlarging areas to allow additional vehicles is prohibited. Road 

culverts and water bars will be maintained free of debris and replaced when 

damaged.

7. The lot is not intended to be used as a storage area. After securing written permission 

from the District Ranger, all building materials that will be used within three months 

must be stored out-of-sight or neatly stacked. All other materials will be removed. No 

items will be stored on or under decks or patios.

8. The storage of motor vehicles, and the storage or use of camp trailers, fifth-wheeled 

trailers, recreational vehicles, etc, is prohibited.

9. Television antennas and satellite dishes may be used but must be removed and stored 

indoors when the cabin is not occupied. Antennas/dishes may not be attached to trees. 

10. Gates, fences and walls will not be constructed.
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 191

11. The national flag of the United States of America and/or the flag of its States or 

Territories may be displayed. No other flags, banners, holiday ornaments, or lights 

may be displayed.

12. The District Ranger will be consulted prior to any soil disturbing activity, and work 

will not begin until approval is granted.

III. FACILITY MAINTENANCE

A. Structures

1. The foundation of the cabin should be checked yearly to ensure that it is structurally 

sound and in good repair. If dirt or leaves have accumulated against the foundation, 

they must be cleared away. If the cabin is on a slope and has an open space under it, a 

screen or latticework enclosing the foundation is required to prevent debris from 

collecting under it. Combustible material should never be stored under any structure.

2. All roof areas and gutters must be kept free of limbs, needles, and other debris. Loose 

roofing or shingles must be repaired. Check the eaves and around flashing for wood 

rot. 

3. To blend with the national forest landscape and provide consistency between all 

recreation residence tracts on the Coronado National Forest, paint industry standards, 

to define appropriate colors, will be used. These standards include the Munsell Color 

System (combinations of hue, value and chroma are used to define each color) and 

light reflectance values (LRV). Generally, shades of green and brown are 

recommended; subdued grays may also be acceptable. Table 1 gives the range of the 

units that must be met within the authorized hues.

Table 1

Hue Green Green-Yellow Yellow Yellow-Red

Value <5 <4 <5 <6

Chroma <7 <4 <8 <4

a. Additionally, the following requirements must be met:

(1) The cabin, roof, and all other improvements must meet the color standards 

listed in Table 1. The only exception is propane tanks, which may be left 

white.

(2) Do not use glossy colors

(3) Colors of paint, stains, and other building materials (such as roofing) shall 

have a light reflectance value under 30. 

(4) If roof color is different than wall color, avoid highly contrasting colors.

(5) Color of trim, doors, and windows shall be the same or similar color as 

siding.

4. Prior to selecting your paint, stain, or any other exterior materials, permittee must 

secure approval from the Forest Service. If a deck is to be left in unfinished natural 

wood color, the surface must be treated with some type of clear waterproofing or 

linseed oil. Once a surface has been painted, it must be repainted regularly.

5. Exceptions to the color requirements include newly installed wood with clear 

protective coatings, existing cabins constructed of red brick or natural block.

IV. ADDITION OF STRUCTURES OR FACILITIES AND CABIN RECONSTRUCTION
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192 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

A. Only those structures listed on page 1 of the Term Special-Use Permit are authorized. 

Additional structures and facilities may be approved where and when appropriate. 

Environmental analysis for additional structures must be conducted, with the cost borne 

by the permit holder.

B. Construction of, addition to, or significant modification of, any building or structurallysignificant facility will require detailed review and written approval, as follows:

1. Proposals will be submitted to the District Ranger as per Clause III.B of the Term 

Special-Use Permit. The detail of the plans will be commensurate with the scope of 

the project. After review of the concept, a letter of approval or disapproval will be 

provided to the permit holder. 

2. Environmental analysis for the reconstruction of, addition to, or significant 

modification of, any building or structurally-significant facility may be necessary, 

with the cost borne by the permit holder.

3. Upon receipt of approval in concept, and the completion of any required 

environmental analysis, the permit holder shall apply for a building permit from the 

appropriate County. If the County does not require a construction permit, the holder 

will work with a registered/certified architect and acquire stamped plans.

4. Upon receipt of the County building permit or stamped plans, the permit holder will 

forward a copy to the District Ranger.

5. After review of the above documents by appropriate staff, the proposal will be 

approved by an amendment to the Term Special-Use Permit, returned for revisions, 

or disapproved by letter. 

6. Construction shall not begin until the project receives final approval. 

7. Reconstruction of any facilities, if approved, would be limited to the existing 

approved square footage.

8. Room additions, screened porches, etc., will not be approved. The only exception for 

an increase in the square footage is for an indoor toilet facility which would replace 

existing outdoor toilet facilities. This addition should blend with the existing 

structure and may be approved up to 100 square feet. County permit or stamped plans 

are required. Outdoor facilities must be removed when replaced and not utilized as a 

shed.

9. New sundecks may be authorized by the District Ranger and, if approved, would be 

no greater than the length of one side of the existing cabin by ten feet in depth.

10. Cabins shall be simple, traditional, compact forms, not modern in architecture. 

Modest structures that blend with the landscape will minimize their visual impact on 

the national forest landscape. Proposals that include elements that are not typical, or 

that draw attention to themselves, may be denied. Some examples of items to avoid 

include unnecessarily high foundations, unusual angles, nontraditional window styles 

or placement, ornate details, or synthetic siding (such as plastic or aluminum). 

Additional information can be found in The Environment Image Guide for the 

National Forests and Grasslands, which is available on the internet at 

http://www.fs.fed.us/recreation/programs/beig/. For guidance on recreation 

residences on the Coronado National Forest, refer to chapter 4.6 "The Rocky 

Mountain Province." 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 193

C. The construction and maintenance of a wood storage box measuring no greater than 3 

feet in width, 2 feet in height and 2 feet in depth may be constructed on a deck or 

adjacent to the cabin. This box must meet the color requirements.

D. The construction and maintenance of sports courts, including horseshoe pits, is not 

authorized. Sports equipment may be placed on site when the cabin is occupied, but must 

be removed when the cabin is not occupied.

E. Minor improvements and major maintenance activities can be authorized by the District 

Ranger.

V. SIZE, PLACEMENT AND DESCRIPTIONS OF SIGNS

Lot numbers will be posted at the driveway or on the cabin. The number must be plainly 

visible from the main road passing in front of the cabin. The owner’s last name may be 

posted as well in letters no greater than 4 inches in height. Only one sign may be installed, 

and no other message may be on the sign. It should blend with the forest environment in color 

and texture. It may not be attached to a dead or green tree. No other signs will be authorized, 

except for temporary real estate "For Sale" signs.

VI. WATER SYSTEMS (if applicable)

A. Drinking Water Systems

1. The holder, as the water supplier and owner or operator of the drinking water system, 

is responsible for compliance with all applicable Federal, State, and local drinking 

water laws and regulations for the operation and maintenance of a public water 

system. This includes, but is not limited to, developing, operating, and maintaining 

the system, and conducting drinking water testing and taking the appropriate 

corrective and follow-up actions in accordance with Federal, State, and any other 

applicable requirements. For the purposes of this authorization, public water systems 

are defined in the Safe Drinking Water Act, as amended (42 U.S.C. 300f et seq.), and 

in the National Primary Drinking Water Regulations, Title 40, Code of Federal 

Regulations, part 141 (40 CFR part 141), or by State regulations if more stringent. 

VII.WASTE DISPOSAL

A. Trash Disposal

1. "On-Site" trash disposal and the use of "burn barrels" or open pits are not authorized. 

All trash must be removed from NFS lands and disposed of in an approved sanitary 

landfill. If used, garbage cans must have secure lids; they must be emptied regularly. 

If the garbage cans are not bear proofed, they must be stored inside at night and when 

the cabin is not occupied.

2. Unless authorized, branches and logs will not be disposed of either on or near the lot.

B. Sewage and Gray Water Disposal

1. Septic tank systems, and alternative on-site disposal systems must be installed and 

maintained in compliance with all applicable Federal, State, and local laws and 

regulations. See Arizona Administrative Code Title 18, chapter 9 “Department of 

Environmental Quality Water Pollution Control” for the latest standards. 

2. Gray water (wastewater collected separately from a sewage flow that originates from 

a clothes washer, bathtub, shower, and sink, but does not include wastewater from a 

kitchen sink, dishwasher, or toilet) may be separated from the black water waste 

(toilet, kitchen sink wastes) if disposed of by an approved method. See Arizona

Administrative Code Title 18, chapter 9 “Department of Environmental Quality 

Water Pollution Control” for the latest standards.
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194 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

3. New Pit toilets (using vaults that are not sealed) are not allowed. Existing pit toilets 

shall be monitored and phased out (including building removal) within two years of 

permit issuance.

4. All outhouses must be fly-proofed, with a self-closing door.

VIII. FIRE PROTECTION

A. Structural Fires. The Forest Service limits action by its personnel on structural fires to the 

following, so long as such action can be carried out safely and is within the capability and 

training of the involved personnel:

1. Activities necessary for the protection of human life.

2. Activities necessary to control or contain the fire to the immediate area (using 

conventional wild-land fire suppression equipment).

YOU, AS THE PERMIT HOLDER, HAVE THE RESPONSIBILITY

FOR PROTECTION OF THE CABIN FROM FIRE.

B. Fire Prevention

1. Firewood will be stacked in piles at least thirty feet from the main building and at 

least ten feet from smaller structures. The reason for this separation is that a large 

concentration of fuels would increase the severity of a fire, if one occurred. Dead 

flammable fuels will also be cleared to a distance of thirty (30) feet around the main 

building and ten (10) feet around woodpiles, butane tanks, etc.

2. A twenty-inch path will be cleared of flammable vegetation down to mineral soil 

around every structure. A path 5 feet wide will also be cleared to mineral soil around 

barbecue pits and grills. It is advisable to keep a hose or a bucket of water handy 

when cooking outdoors. 

3. Permit holders shall abide by Coronado National Forest fire restrictions and closures. 

Fire restrictions and closures apply to indoor fires as well.

4. Stovepipes must extend at least 24" above the roof ridge and be equipped with spark 

arrester.

5. The spark arrester shall be twice the area of the chimney vent and constructed of 

corrosion resistant material of not less than 14 gauge mesh wire with openings not 

over 1/2" or less than 5/16".

6. Proper disposal of fireplace ashes requires that they be put in a covered metal 

container (no cardboard or wooden boxes!) and soaked with water. They should then 

sit overnight to make sure they are cold, before being taken off NFS lands to an 

appropriate disposal site. 

7. All wires shall be a minimum of four feet from the chimney or stove pipe.

8. The electric meter box must be grounded, and all electrical wires must meet the 

National Electrical Code (NFPA 70).

9. Tree limbs must be trimmed to at least five feet back from electrical wires, and at 

least ten feet from chimney, stovepipe, and flue outlets.

10. If the cabin has running water, it should have an outside faucet in case of fire. Largesize fire extinguishers (A, B, C – 10 pound or larger) and at least one smoke detector 

are also encouraged. 
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FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 195

11. No fireworks shall be stored or used on the land covered in the Term Special-Use 

Permit or in the structures thereon. Using fireworks will result in a citation and may 

result in the permit being suspended or terminated.

IX. ACCESS

The holder agrees to permit the free and unrestricted access to and upon the lot. See Section 

XI Miscellaneous Provision Clause R of the Term Special-Use Permit.

X. SALE OR TRANSFER OF THE CABIN

A. If a decision is made to sell the cabin, the following procedure will be followed:

1. Contact the appropriate Ranger District Office and advise them of your intent to sell; 

this action should also be verified in a letter to the District Ranger. If possible, a 

forest officer will make a transfer inspection, noting substandard items (if any) which 

need correction. A copy of the inspection form will be sent to the permit holder; any 

deficient items should either be corrected immediately, or discussed with the 

prospective purchaser to ensure that proper corrective action will be taken. Upon 

completion of the corrective work, notify District personnel. If the cabin is sold with 

major deficiencies, a short-term permit may be issued to the new owner to allow time 

to correct the situation. When corrected, the standard permit would be issued. 

2. A copy of the Special-Use Permit must be provided to the prospective purchaser 

before finalizing the sale. They will be informed that the cabin shall not be used as a 

principal place of residence, which is defined as the main residence where most of 

the year (more than 183 days per annum) is spent. See I.R.S. Publication #17. 

3. The current permit holder and prospective buyer will submit Form-2700-3a, “Holder 

Initiated Revocation of Existing Authorization/ Request for a Special-Use Permit or 

Term Special-Use." Permits may only be issued to an individual or to a husband and 

wife. The Forest Service may not issue permits to (and thus the improvements may 

not be owned by) corporations, partnerships, multiple individuals or trusts. In 

addition to this form, a recorded Bill of Sale (or comparable legal document) is 

required. The completed forms and recorded Bill of Sale should be mailed or 

delivered to the Ranger District office along with a $25.00 transfer fee (check or 

money order made payable to U.S.D.A. Forest Service).

4. The application will be processed and a new Permit prepared for signature(s), at 

which time the new owners will be contacted and an appointment made to review and 

issue the new Permit, and also prepare a new Operation and Maintenance Plan. This 

conference/phone call allows the opportunity for the prospective Permit Holder to ask 

questions, and to become a partner in the management of this area.

B. If a transfer of the cabin is necessary due to death or incapacity of the permit holder, the 

beneficiary or designee, so designated in a recorded will and testament, trust, or other 

legal document, must proceed as follows:

1. Contact the appropriate Ranger District Office and advise them of the situation; this 

action should also be verified in a letter to the District Ranger. Submit a copy of the 

death certificate or a certified letter by an attending physician, and the recorded legal 

document(s) granting new possession of the cabin. If not specifically stated in the 

document who shall receive the cabin, a document designating the one person to be 

responsible for the cabin, must be submitted. All heirs of the deceased or 

incapacitated permit holder must sign and have their signature notarized. 
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If possible, a forest officer will make a transfer inspection, noting substandard items 

(if any) which need correction. A copy of the inspection form will be sent to the 

prospective permit holder; any deficient items must be corrected prior to issuance of 

the new permit. 

XI. MISCELLANEOUS PROVISIONS

A. Wildlife. The permit holder is responsible for taking action on their lot to minimize 

conflicts with wildlife. 

1. Feeding wildlife is strictly prohibited, including, but not limited to, bears, birds and

squirrels. Treat all wild animals as dangerous.

2. All food must be stored indoors and shall not be left unattended where animals could 

have access to it.

3. Food preparation, cooking and eating areas shall be cleaned immediately after use 

and kept clean. Dishes and other food preparation materials shall be cleaned and 

stored indoors immediately after food service has been completed. Thoroughly clean 

barbecue grills after use; remove and dispose of grease and food particles in garbage 

cans. 

4. Do not bury garbage, scatter organic waste, or leave foil or other food packaging on 

or near grills.

5. Garbage storage shall not be allowed to overflow and will be brought indoors each 

night. They shall be cleaned weekly and prior to leaving with hot water, soap, and 

disinfectant in order to minimize odors.

6. All garbage shall be transported to an approved sanitary landfill at frequent intervals, 

but at a minimum of once per week.

Bears. Black bears are forest residents. They are wild and unpredictable. They 

normally do not attack or threaten people unless provoked, but food will attract their 

interest. Bears recognize food and food containers by sight and smell, including ice 

chests, grocery sacks, cardboard boxes, canned goods, freeze-dried foods and pet 

foods. Bears consider odorous products to be potential food. Odorous items include 

things such as food, garbage, toothpaste, insect repellent, suntan lotion, etc. It is 

important to prevent bears from detecting the presence of stored garbage, but if 

discovered by bears, it must be stored in a manner that will prevent them from getting 

to it. Bears are active at all hours, both day and night. They are clever and 

resourceful. If a bear is encountered, throw objects, bang pots, yell or clap hands to 

frighten them away. Do this before the bear gets close to you. Do not try to approach 

a bear and do not tease or crowd them. Avoid getting between a sow and her cubs.

Frighten bears away before they reach food, otherwise they will be difficult to 

remove. All employees, guests, and visitors must be informed that they are to abide 

by the following requirements. 

In additional to bears, other wildlife such as skunks, raccoons, and coatis, are also 

attracted to available foodstuffs. Therefore, the following requirements will be 

enforced at all times.

Further information and assistance to prevent conflicts with wildlife is available from 

the local Arizona Game and Fish Department, North American Bear Society, and 

your Forest Service office.
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B. Heritage Resources

1. If permit renewal or amendment authorizes ground-disturbing activities, removal or 

alteration of buildings or structures, or other potential impacts to significant heritage 

resources, the forest heritage staff will be contacted to initiate National Historic 

Preservation Act (NHPA) compliance.

2. If any external modifications, additions, or removals are approved for a National 

Register of Historic Places– eligible building during the life of the permit, the forest 

heritage staff must be contacted to initiate NHPA compliance. 

C. Other Miscellaneous

1. Domestic animals must be under physical control when outdoors. Leashes are limited 

to a maximum of 6 feet in length.

2. Building of impoundments to divert or hold surface water without water rights from 

the State is prohibited.

XII.CONCLUSION

As a part of this Operation and Maintenance Plan, you agree to conduct, if necessary, an 

annual Self-Inspection of your cabin and permit area. A self-inspection form will be mailed to 

you in the Spring prior to the main use season. This self-inspection form certifies your 

compliance with this Operation and Maintenance Plan.

This Operation and Maintenance Plan is not intended to unduly restrict the enjoyment of the 

National Forest, or the Recreation Residence within it. It is meant to protect the cabin and lot, 

the National Forest System lands and resources upon which the cabin lies, and the people 

utilizing them. After appropriate consultation, it will be amended and up-dated as often as 

needed. It can not, however, cover every possible operation and maintenance situation that 

could be encountered. Common sense and safety awareness must be the foundation for all 

activities.
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As the permit holder, I have read this plan, and understand that it is a part of my Term SpecialUse Permit.

_______________________________ ____________________________

Permit Holder Date

_______________________________ ____________________________

Permit Holder Date
FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 199

Appendix B:

Heritage Resources Consultation

SHPO Concurrence Letter 2006-1640-30130
Appendix B: Heritage Resources Consultation

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Appendix C: 

Endangered Species Act Consultation

Biological Opinion, U.S. Fish and Wildlife Service

Re: Issue Special-Use Permits for Safford Ranger District

Recreation Residences, August 18, 2008
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Re: Apache Trout Concurrence, Issue Special-Use Permits for 

Safford Ranger District Recreation Residences, May 6, 2011
Appendix C: Endangered Species Act Consultation

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Appendix D:

Comments Received on the Draft EIS
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Appendix E: Responses to Comments on the Draft EIS

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Appendix E: 

Responses to Comments on the Draft EIS

CENTER FOR BIOLOGICAL DIVERSITY

COMMENTS ON THE DRAFT EIS, NEW SPECIAL-USE PERMITS 

FOR RECREATION RESIDENCES ON THE SAFFORD RANGER DISTRICT,

CORONADO NATIONAL FOREST

COMMENT #1 (General Comment on EIS):

“Neither the Biological Opinion for Columbine cabin renewal, nor the draft Environmental 

Impact Statement addresses climate change. Inclusion of the effects of climate change and 

global warming is a critical element in the evaluation of the environmental baseline, 

cumulative effects, and foreseeable future condition for any proposed project in the arid 

Southwest. This omission must be corrected in the Final EIS.”

FOREST SERVICE RESPONSE:

The Forest Service does not have a responsibility or the authority to amend the Biological 

Opinion for this proposed action to address climate change.

The Final EIS has been modified (chapter 3) to briefly discuss climate change and global 

warming. Because there will be no change in use and occupancy of the Columbine and Turkey 

Flat cabins, the proposed action would result in no net change in man-made sources that 

contribute to climate change and/or global warming. Thus, all alternatives will have no

measurable effect on global warming and climate change. 

COMMENT #2 (page iii of EIS):

“The fact that Critical Habitat does not include the Columbine cabin and camp area is purely a 

factor of failure to update the Critical Habitat designation. This misleading statement is 

repeated throughout the document. It needs to be qualified so that the public is no longer 

intentionally misled with the intended impression that it is acceptable to perpetuate 

obstruction of recovery because of Fish and Wildlife Service's intransience. The area 

designated as Critical Habitat is now essentially unoccupied as nearly all the squirrels are 

found in mixed conifer. Critical Habitat needs to be updated to include all habitats necessary 

for recovery.”

FOREST SERVICE RESPONSE:

The Forest Service does not have the authority to update or otherwise alter designated critical 

habitat. This responsibility lies with the U.S. Fish and Wildlife Service (FWS). 

The area designated as critical habitat (DCH) by the FWS is, indeed, essentially unoccupied by 

the red squirrel. The EIS reports in Section 3 (wildlife) that the recreation residence tracts are 

not within DCH. In accordance with Section 7 consultation procedures, the analysis for this 

proposed action determined the effects on the red squirrel population and occupied red squirrel 

habitat within the project area. Because no red squirrel DCH is found in the project area, a 
Appendix E: Responses to Coimments on the Draft EIS

258 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

determination with regard to effects on DCH was not necessary. The determinations of effects 

on the species and occupied habitat were made based on the most current available scientific 

information and consulted upon with the FWS in accordance with federal law and policy.

COMMENT #3 (p. vi):

“Please see the critique of the Biological Opinion above. Preservation of the cabins and camp 

have much greater impact than the taking of two squirrels. The following statement 

concerning Alternative 1 (no action) is not accurate: "Increased tree density may reduce 

nutrients available for cone production. This, in turn, would negatively impact the squirrel's 

food supply." Recovery of closed canopy habitat in the Columbine cabin and camp area is 

more important now than ever.”

FOREST SERVICE RESPONSE:

Current habitat restoration planning for the Mount Graham red squirrel shows that tree 

densities are above sustainable levels within squirrel habitat in many areas within the Pinaleño 

Mountains (see http://www.fs.fed.us/nepa/nepa_project_exp.php?project=18628). Many 

stands in this mountain range are approaching or fall within what is referred to as the “zone of 

imminent mortality”. This zone is defined by compositions of approximately 60% of maximum 

stand density index (SDI) (Long, James N., 1985. A practical approach to density management. 

Forest Chronicle 6123-27). Such composition indicates that some type of treatment is necessary 

to reduce density of trees for nutrient release to remaining trees.

Cone production may be encouraged by thinning and/or release cutting. This is shown in Arista 

and Talavera, 1996 (Density effect on the fruit-set, seed crop viability and seedling vigour of

Abies pinsapo; Annals of Botany 77: 187-192) and Karlsson and Orlander, 2002 (Mineral 

nutrients in needles of Pinus sylvestris seed trees after release cutting and their correlations with 

cone production and seed weight. Forest Ecology and Management 166: 183-191). In both of 

these studies, lower tree densities encouraged increased cone production. 

COMMENT #4 (p. 13):

“Immediate removal is not simply precluded by Forest Service policy. The survival of 

endangered species is also Forest Service policy." See also the Biological Opinion critique 

above.”

FOREST SERVICE RESPONSE:

Immediate removal is not in accordance with Forest Service special-use policy; this is reported in 

the EIS. Maintaining habitat for endangered species is Forest policy as well. Thus, the Forest 

must weigh both policies and act in the best interest of the public. The presence of the 

recreation residences does not affect maintenance of habitat for the red squirrel. Immediate 

removal of the residences, if policy permitted, would accelerate restoration of the tract by 10 

years.

COMMENT #5 (p. 14):

“The following statement is disingenuous: "A notice that in the event of a wildland fire, the 

Forest Service is not responsible for protecting cabins from fire. Forest Service firefighters will 

limit their activities to the protection of human life and control or maintenance of the fire in 
Appendix E: Responses to Comments on the Draft EIS

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 259

the immediate area ... " Fire fighting has been and will continue to be dominated by 

preservation of structure to the detriment of forest and squirrel.”

FOREST SERVICE RESPONSE:

The Pinaleño Mountains comprise a sky island that extends from an elevation of approximately 

2,800 feet to 10,800 feet. The mountains rise up from the desert floor at a dramatic rate of 

elevation gain. This gain is what creates a unique situation for fire suppression activities. Because 

of the steepness of slope and relatively few places where fireline may be established, fire 

management teams, to include, but not limited to, the Agency Administrator, Line Officer, 

District specialists and FWS specialists must collaborate to determine where firelines should be 

established. Federal Wildland Fire Management Policy states that the protection of human life is 

the single overriding suppression priority. Fires are suppressed at minimum cost, considering 

firefighter and public safety, and all values to be protected, consistent with resource objectives.” 

The 2004 and 1996 fires that occurred in the Pinaleño Mountains and future fires on this 

landscape met the criteria of this category. Not all fire suppression activities will create the same 

results. Factors that have to be taken into consideration are slopes, winds, temperatures, 

humidity, drought indexes and a host of other factors. Although many factors are taken into 

account not all outcomes are positive.

COMMENT #6 (p. 60):

“Omission of the historic fact that Mount Graham was originally included within the boundary 

of the Fort Apache Reservation, but it was taken away from the Apaches by executive order in 

1873.”

FOREST SERVICE RESPONSE:

This fact was added to the description of the Affected Environment in the Heritage section of 

the FEIS.

COMMENT #7: (p. 64):

The Columbus or LBT is not the world's most powerful optical telescope. The same claims are 

made by the Keck and the Very Large Telescope. Astronomy Magazine supports the Keck.

FOREST SERVICE RESPONSE:

Comment noted. No change necessary in EIS as this is unrelated to the impacts analysis of the 

proposed action.

COMMENT #8 (p. 83-84):

“The habitat numbers need to be updated to reflect the fact that almost no squirrels are 

currently occupying spruce fir habitat. Consequently, citations of occupied habitat from 1992 

and 1999 most likely are no longer accurate. The ultimate numbers also need to assure the 

public that the occupied habitat acreage only includes the flatter areas favored and occupied 

by the squirrels.”

FOREST SERVICE RESPONSE:

In the EIS, more recent habitat numbers were also provided as reported by Hatten (2000). These 

numbers (16,680 acres of potentially suitable habitat, and 27,181 acres of suitable habitat), 

which would actually make the proportion of the habitat affected seem less, were used for 
Appendix E: Responses to Coimments on the Draft EIS

260 FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest

comparison with those provided by earlier publications. Both assessments resulted in extremely 

small percentages of available habitat being affected. These were the most recent published 

habitat assessment data specifically for the red squirrel at the time of writing and consultation.

COMMENT #9 (p. 84):

“The implication that the Columbine cabins deny the squirrel of only a tiny, insignificant 

amount of acreage is suspect owing to the questionably excessive total acreage and the 

disproportionate importance of the strategically located Columbine area. Habitat acreage 

numbers need to be modified based on new knowledge of global warming and climate change 

as it relates to past "suitable" habitat's ability to provide the necessary moisture and 

temperature requirements for midden creation and maintenance.”

FOREST SERVICE RESPONSE:

As stated above, the most current estimate of habitat for the red squirrel was used. The 

quantitative effects of global warming and/or climate change have not been determined for the 

project area. Therefore, defining suitable red squirrel habitat on the 25 acres of forest at 

Columbine relative to the effects of global warming and/or climate change on moisture and 

temperature required for midden creation and maintenance is impossible.

COMMENT #10 (p. 85):

“Figure 10 is completely disingenuous. Its implication is that the permitted areas are tiny in 

relationship to the huge area occupied by squirrels. The figure fails to reflect the small acreage 

of flatter areas actively occupied to the exclusion of the now unoccupied spruce-fir and the 

steeper areas shunned by squirrels. Critical habitat is now occupied to a much lesser degree 

since the fires, beetle infestation and the excessive and hot back burning by over zealous fire 

fighters protecting telescopes, cabins and camp to the detriment of forest and squirrel. A

fair presentation will confirm and highlight the strategic location of the cabins and camp and

will highlight the relationship to squirrels and the tiny acreages of flatter areas now being 

used by the squirrels.”

FOREST SERVICE RESPONSE:

Figure 10 accurately represents the spatial location of the recreation residence tracts relative to 

designated critical habitat (DCH), as the figure title states. This map was not intended to show 

the tracts in relation to areas occupied by red squirrels. Critical habitat is now occupied to a 

much lesser degree as at the time of designation, and this is, indeed, likely the result of the 

activities cited in the comment. A statement indicating that the DCH is much less occupied than 

when designated has been added to the Final EIS (wildlife section).

COMMENT #11 (p. 86):

“Removal of the inappropriately, Arizona Game and Fish introduced, nonnative to the 

Pinalenos, Abert's squirrels has been proposed for years. Loss of most of the spruce-fir 

highlights the need for this action.”

FOREST SERVICE RESPONSE:

Comment noted. Change necessary in EIS as this is unrelated to the impacts analysis of the 

proposed action. Comment should be directed to wildlife management agencies.
Appendix E: Responses to Comments on the Draft EIS

FEIS for New Special Use Permits, Recreation Residences, Safford RD, Coronado National Forest 261

COMMENT #12 (p. 87):

“It is ludicrous to highlight the new theoretical negative aspects of restoration when recovery 

of the Columbine cabin and camp area has been favorably proposed for twenty years.”

FOREST SERVICE RESPONSE:

Comment noted. The positive aspects of restoration of the 25 acres at Columbine are wellknown and well-publicized. As with many scientific debates, there is a valid perspective on the 

negative aspects of restoration that is based on research identified in our response to Comment 

#3.

COMMENT #13 (p. 88):

“The no effects analysis again reflects only the few middens directly affected by the cabins not 

the strategic locale, the perpetuation of piecemeal habitat destruction, and perpetuation of 

excess fire fighting methods.”

FOREST SERVICE RESPONSE:

It is possible to evaluate effects to known squirrel locations only. All thinning and prescribed fire 

projects on Mt. Graham have received and will continue to receive detailed attention to 

activities that could adversely affect the red squirrel and its habitat—in planning, consultation 

with FWS, and implementation. Firefighting methods are also subject to the guidance of a 

qualified Resource Advisor on the scene to educate firefighters and observe and modify firelines 

or other suppression actions. During the Nuttall Complex Fire of 2004, other agencies (FWS and 

Arizona Game and Fish Department) and organizations (University of Arizona) regularly 

contributed data and information about the red squirrel and its habitat to inform fire strategy 

and rehabilitation of firelines and burned areas. 

COMMENT #14 (p. 88):

“Inclusion of invertebrates such as the Pinaleno monkey grasshopper highlights the lack of 

past motivation to research the unique and rare assemblage of plants and animals that 

occupied or have occupied the upper elevations of the Pinalenos. This motivation has been 

crushed by the University of Arizona's telescope designs and and their suppression of the 

evaluation of alternative locations for their telescopes.”

FOREST SERVICE RESPONSE:

Research in the Pinaleño Mountains – plants, butterflies, snails, turtles, and voles, just to name a 

few – has been conducted for many years. This research is expected to continue.

COMMENT #15 (p. 123-124):

“What a blatant lie concerning the National Forest Management Act (NFMA):

"Section 219.19(a)(6) requires that "Population trends of the management indicator species 

will be monitored and relationships to habitat changes determined. This monitoring will be 

done in cooperation with State fish and wildlife agencies to the extent practicable." 

Management indicator species and their habitat are monitored to observe trends in resources, 

evaluate management actions, and provide a timely warning of problems or undesirable 

conditions affecting the resource." 
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In the Forest Service's 2004 interpretative rule, they state the NFMA regulations are only to be 

used for forest plan amendments and revisions. 69 Fed. Reg. 58055 (Sept. 29, 2004).”

FOREST SERVICE RESPONSE:

Population trends of management indicator species (MIS) are monitored and reported in a 

Forest Plan Monitoring and Evaluation Trends Report (http://www.fs.fed.us/r3/coronado/planrevision/documents/Monitoring&Evaluation_TrendsAnalysis_1986-2010.pdf). The effects of the 

proposed action on MIS are evaluated and reported in the EIS. Neither of these references is 

contrary to the direction in the NFMA. 

COMMENT #16 (p. 136):

“Repeated disingenuous percentage of acres occupied without qualification for slopes and 

current occupancy.”

FOREST SERVICE RESPONSE:

As stated in response to Comments #8 and 9, the most current assessments of habitat for the 

red squirrels were used during the preparation of this EIS.