Chapter 1. Introduction

Background 

Individual recreation residences have existed on public lands administered by the Federal 

Government since passage of the Organic Administration Act of June 4, 18971

. The act provided 

for construction and occupancy of residences on National Forest System (NFS) lands and other 

public lands, 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 Act2

 provided Federal agencies with the authority to provide up to 5 

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 the 

improvements sold. Shortly thereafter, during the 1920s, the Coronado National Forest (Coronado 

or forest) recreation residence program was established. 

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

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

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

Graham in 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) improved 

access to the area. Turkey Flat cabins were first constructed between 1929 and 1966, and like 

those at Columbine, most have been remodeled or expanded within the last 50 years. 

USDA Forest Service direction for issuing new term special-use permits (SUPs) for recreation 

residences is governed by the Recreation Residence Policy established on June 2, 1994 (USDAFS, 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). 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 to a consistency evaluation prior to new permits being issued, 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, complete the appropriate 

environmental analysis and documentation (FSH 2709.11, Chapter 41.23a (1)(b)).” 

 

1

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

2 16 U.S.C. 497, as amended; signed on March 4, 1915 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 1 
Chapter 1. Introduction 

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)). Use of the categorical exclusion (CE) is contingent 

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

listed in 36 CFR 220.6 (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 has 

been a history of controversy regarding special uses on Mt. Graham for several recent decades, 

based on 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. Thus, the Forest Service determined that the use of a CE would not be 

acceptable as 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 on the Coronado 

NF are scheduled to expire on December 31, 2008. The purpose of the proposed action is to issue 

new SUPs to those parties holding permits that expire on December 31, 2008. Action is needed 

by the forest to comply with the Forest Service policy of continuing recreation residence use 

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

holders to maximize public recreational benefits (FSM 2347.1 (USDA-FS, 2006b) and USDAFS, 1986, pp. 9, 41 and 59). 

Proposed Action 

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

upon their expiration on December 31, 2008. Each newly issued SUP term would extend 20 

years, from January 1, 2009, through December 31, 2028. Current permit holders would be 

required to abide by all terms and conditions expressed in their respective SUPs and an annual 

operation and maintenance (O&M) plan that is conveyed with each SUP. Prior to a new SUP 

being issued, each recreation residence will be inspected by the Forest Service to confirm that 

occupancy is in compliance with the terms and conditions of the expiring permit (FSH 2709.11, 

41.23a (3) (USDA-FS, 2005)). An example of an annual O&M plan is provided in appendix A. 

The Old Columbine tract has 14 recreation residences on 25 acres 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. The Coronado NF 

encompasses 1,780,000 acres, mostly in southeastern Arizona, and includes areas of the 

Peloncillo Mountains of southwestern New Mexico. Elevations on the Coronado NF 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 

2 DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 1. Introduction 

ranges on the Coronado NF. Mt. Graham in the Pinaleños, at an elevation of 10,720 feet, is the 

highest peak in southern Arizona. 

Figure 1. Location of the Coronado National Forest in southeastern 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). Forestwide standards and guidelines are augmented by standards and 

guidelines for individual management areas (MAs) (USDA-FS, 1986, pp. 25-46). The Safford 

recreation residences are located in MAs 3A and 3B; applicable standards and guidelines, both 

forestwide and MA specific, are referenced in chapter 3 with each resource impact analysis. 

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. 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 3 
Chapter 1. Introduction 

Figure 2. General location of Safford Ranger District recreation residence tracts 

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.” 

4 DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 1. Introduction 

 “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 proposed action was evaluated with regard to forestwide and MA specific goals, objectives, 

standards, and guidelines established in the forest plan and found to be consistent with them. 

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

Decision Framework 

The Coronado National Forest supervisor is the responsible official who will decide whether or 

not to issue new SUPs for recreation residences at Old Columbine and Turkey Flat. 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 and appeal opportunities; 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, with its listing in a schedule 

of proposed actions (SOPA) on the Coronado NF Web site3

. 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 during two scoping 

meetings and written and oral responses to a scoping notice sent to Coronado NF stakeholders 

and interested parties, Native American tribes and nations, and publication of a notice of intent 

(NOI) in the Federal Register on March 9, 2006. 

The NOI provided the public with information on the two public meetings held to provide the 

public with information about the project and to assist the Agency in scoping the NEPA analysis. 

The publication of the NOI initiated the opportunity for public comment on the proposal through 

April 8, 2006, although comments were accepted well beyond that date. 

 

3 www.fs.fed.us/r3/coronado

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 5 
Chapter 1. Introduction 

A scoping notice was mailed to 154 stakeholders, including the general public, agencies, 

government officials, and various organizations, also on March 9, 2006. The scoping notice 

requested public comments on the proposed action through April 8, 2006, and announced the 

same two public meetings (project record, item 10). 

On March 24, 2006, a government-to-government scoping letter was sent to 31 tribal leaders and 

individuals among 12 Indian Nations with historic ties to southeast Arizona. Comments were 

requested of Indian Nations by April 28, 2006. 

Two public open house meetings were held during the scoping period: one in Tucson, Arizona, 

on March 27, 2006, which had 27 attendees (project record, item 66) and the other in Safford, 

Arizona, on March 28, 2006, which had 48 attendees (project record, item 70). 

Comments Received from the Public 

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

interdisciplinary team of resource specialists (see chapter 4), catalogued by resource and/or issue, 

and designated as relevant or beyond the scope of this environmental review4

 (project record, 

item 184). Then, each specialist developed an approach to analyze potential impacts related to 

specific issues. 

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

telephone, person-to-person) during the scoping period. Ninety-three comment letters expressed 

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

list for this 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 164), 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 74). 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 draft EIS by the forest archeologist, 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. 

Future Public Review Opportunities 

In accordance with FSH 1909.15, Chapters 23.2 and 23.3, the public will be offered a 45-day 

period to review this draft EIS. A notice of availability (NOA) of the DEIS for public review will 

be published in the Federal Register, and copies of the DEIS will be distributed to those parties 

 

4

 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. 

6 DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 1. Introduction 

who offered comments during the scoping period. Public comments will be evaluated and 

considered during the subsequent preparation of a final EIS. The EIS will contain a summary of 

comments submitted on the DEIS and their disposition. 

No sooner than 90 days after publication of the NOA, the responsible official will issue a final 

EIS and a record of decision (ROD), both of which will be noticed in the Federal Register. 

Persons who offer oral or written comments on the DEIS or who otherwise express an interest in 

the project during the DEIS comment period will be mailed the ROD and will be eligible to 

appeal a subsequent decision on its implementation following publication of the record of 

decision (36 CFR 215.13). 

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 conifers, and 

its only remaining population is found in the upper elevations of the Pinaleño Mountains. 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 species 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. 

Past logging in the area reduced available MGRS habitat, and it has declined more recently 

because of drought, insect infestation, and catastrophic fire. Recreational use of the area is 

limited, and occupancy of the recreation residences is not known to have contributed to the 

population decline. 

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

and used for about 30 years before the red squirrel was reported to be extinct. From the 

perspective of some individuals, their continued presence inhibits the restoration of 

approximately 25 acres of the forest to historic conditions, although this acreage is a very small 

percent of estimated suitable MGRS habitat on Mt. Graham (between 17,000 and 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 

manmade facilities (the wildland-urban interface or WUI), 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 at the Old Columbine tract, an 

alternative to issue new permits at Turkey Flat only is evaluated in this EIS. 

Requirements of the Arizona-Idaho Conservation 

Act Regarding Mt. Graham International Observatory 

About 2 decades ago, a special-use permit was issued to the University of Arizona by the 

Coronado NF to authorize construction and operation of telescopes and associated facilities on 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 7 
Chapter 1. Introduction 

Mt. Graham (Mt. Graham International Observatory or MGIO). The realization of this project 

was also the subject of great concern regarding potential adverse impacts on the MGRS. 

A draft EIS analyzing the effects of the 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 completed by the Coronado NF and submitted to the FWS, as required by the consultation 

requirements in Section 7 of the Endangered Species Act (ESA). While formal consultation was 

underway, however, the university modified its preferred alternative, which necessitated the 

preparation of a second BAE and reinitiation of formal consultation with the FWS. 

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

preferred alternative, concluding 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 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. 

Controversy was generated by the BO, and Congress intervened by passing the Arizona-Idaho 

Conservation Act of 1988 (AICA), which, among other things, altered the requirements of the 

RPAs. The primary change was effected by Section 602 (a) of the AICA, which 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 Arizona 

Bible Camp. While the 1988 BO RPA 3 recommended that 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 U.S. Fish and Wildlife Service.” 

Research and field studies on the red squirrel have been ongoing since 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 the 

FWS on January 24, 2007, as formal ESA Section 7 consultation. A BO was issued by the FWS 

on August 18, 2008 (see appendix C). 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.” 

Potential Effects on the Western Apache 

Traditional Cultural Property, Dził Nchaa Si’an 

The recreation residences are located on Mt. Graham, which is known to Western Apaches as 

Dził Nchaa Si’an (big-seated mountain). The mountain is a place of longstanding and ongoing 

historical, cultural, religious and spiritual importance to the Western Apache. 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 

8 DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 1. Introduction 

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 Service 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 and is mandated by 

legislation and executive orders to consider the effects of projects on historic properties, to ensure 

American Indian access to sacred sites, and to protect the physical integrity of such sites wherever 

possible. During the scoping of this draft EIS, the chairman of the White Mountain Apache Tribe 

commented that the ongoing presence of the residences continues the damage and desecration to 

the Western Apache sacred mountain. Individuals, families, and guests are often not aware of the 

mountain’s role in Western Apache history and culture, and any effects that the residences have 

on the natural wildlife, soils, vegetation, and streams are considered by the 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 premised on the protection of private property 

rather than on the restoration of ecosystem functions or the protection and expansion of 

endangered species habitat. 

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. Affected Environment and 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. 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 9 
Chapter 1. Introduction 

10 DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 

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

preparers and identifies agencies, stakeholders, and others consulted during the 

EIS analysis. 

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

the EIS.

Appendix: The appendix provides supplemental information to the analysis 

presented in the EIS.
Chapter 1. Introduction 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 11