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 

and need. These include: (1) the proposed action (to issue all permits for 88 recreation 

residences); (2) alternative 3 (to issue new permits for Turkey Flat residences only); and (3) 

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 CEQ regulations (40 CFR Part 1502.14(d)). It provides a baseline against which 

the impacts of the proposed action may be compared. 

With no action, SUPs for both recreation residence tracts will expire on December 31, 2008. New 

20-year term permits would not be issued. In accordance with FSM 2721.23(e)(2)(b), permit 

holders would be allowed 10 years of continued occupancy after notification that the permits will 

not be renewed. It is assumed that all recreation residence holders will use all 10 years for 

continued occupancy. 

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

timeframe after expiration to remove their structures and/or improvements and restore the site to 

natural conditions. Before removal of any structure or improvement, site-specific NEPA analysis 

would be completed. The process of removal may take up to 5 years. All structures and 

improvements are expected to be gone within 15 years after the decision not to issue new permits. 

In general, improvements at the tracts include small residences, decks, patios, outbuildings, 

permanent grills, and other stationary improvements; pumps; overhead wiring; propane gas tanks; 

water tanks; and concrete foundations. Upon expiration of the 10-year term, permit holders would 

be required, among other things, to secure their wells with welded-on 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 would be allowed to remain. Each site and associated 

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

Roads into the Old Columbine and Turkey Flat tracts would be gated to prevent motorized access. 

Vegetation would be allowed to grow on the roadbeds. 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. 

Alternative 2: Proposed Action 

The proposed action is to issue SUPs for 88 recreation residences on the Safford Ranger District 

upon their expiration on December 31, 2008. The new SUP term would be 20 years. Permit 

holders would be required to abide by all terms and conditions expressed in their respective SUPs 

and in accordance with an annual operation and maintenance (O&M) plan that is conveyed with 

each SUP. Prior to a new SUP being issued, each recreation residence would be inspected by the 

Forest Service to confirm that the permit holder is in compliance with the terms and conditions of 

the current permit (FSH 2709.11, Ch. 41.23a (3)). 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 11 
Chapter 2. Alternatives, Including the Proposed Action 

Alternative 3: Issue Turkey Flat Permits Only 

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

Turkey Flat tract upon their expiration on December 31, 2008. 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 in accordance with the 

annual O&M plan that is conveyed with the new SUP. Prior to new SUPs being issued, each 

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

in compliance with the terms and conditions of the current permit (FSH 2709.11, 41.23a (3)). 

With this alternative, the permits for 14 recreation residences within the Old Columbine tract 

would expire on December 31, 2008, but new permits would not be issued. Instead, Old 

Columbine permit holders would be issued an SUP that authorizes 10 years of occupancy, after 

which all improvements would be removed from the forest at the expense of the permit holders 

(FSM 2721.23a (10)). Removal activities at Old Columbine would be the same as those described 

for alternative 1 (no action). 

Alternative 4: Issue Old Columbine Permits Only 

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

Columbine tract upon their expiration on December 31, 2008. 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 in accordance with an 

annual O&M plan conveyed with the new SUP. Prior to new permits being issued, each 

recreation residence would be inspected by special uses program staff to confirm that the permit 

holder is in compliance with the terms and conditions of the current permit (FSH 2709.11, 41.23a 

(3)). 

With this alternative, the permits for 74 recreation residences within the Turkey Flat tract would 

expire on December 31, 2008, but new permits would not be issued. Instead, Turkey Flat permit 

holders would be issued an SUP that authorizes 10 years of occupancy, after which all 

improvements would be removed from the forest at the expense of the permit holders (FSM 

2721.23a (10)). Removal activities at Turkey Flat would be the same as those described for 

alternative 1 (no action). 

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). 

12 DEIS for New Special-Use Permits for Recreation Residen
Chapter 2. Alternatives, Including the Proposed Action 

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

is not a 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 

be removed (FSM 2721.23(e)). Therefore, it was dismissed from further consideration in this EIS. 

Mitigation - Proposed Action 

The entire 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. First, the presence of the residences has altered and continues to alter the mountain’s 

natural fire-adapted ecosystem, because the Forest Service’s response to wildland fire is 

suppression, which is necessary for the protection of private property. Second, 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. 

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

Freedom Restoration Act, and Executive Orders 13007 and 13175, the Forest Service consulted 

with the San Carlos Apache Tribe and White Mountain Apache Tribe to identify mitigation that 

would minimize the effects of the recreation residences on the Western Apache TCP. To this end, 

the Forest Service and the tribes developed the following stipulations that will be added to each 

recreation residence operating plan. If any of the action alternatives is selected, the operating plan 

that is issued with a new SUP will include the following items. These stipulations are consistent 

with other laws, regulations, and Forest Service goals of restoring the mountain’s ecosystem: 

1. Information about the importance of Mt. Graham (Dził Nchaa Si’an) in Apache history 

and culture. 

2. An explanation of the Forest Service’s trust responsibility to the Apache. 

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 13 
Chapter 2. Alternatives, Including the Proposed Action 

14 DEIS for New Special-Use Permits for Recreation Residen

3. Requirements regarding: 

 Color standards for all cabins, trim, roofs, and other structures to be approved by the 

Forest Service and designed to help the buildings blend in with the landscape; 

 Allowing public access to the sites; 

 Fire prevention measures; 

 Keeping domestic animals inside or on leashes not to exceed 6 feet in length; and 

 Minimizing conflicts with wildlife. 

4. Prohibitions against: 

 Expansion of structures or room additions; 

 Planting of nonnative vegetation; 

 Diverting or holding natural water runoff; 

 Ground disturbance without case-by-case district ranger approval; 

 Attaching swings, yard lights, signs, wires, or other materials to trees; 

 Outdoor firepits 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; 

 Construction of gates, fences, or walls; 

 Onsite trash burning or burial; and 

 Creating unreasonable or excessive noise. The Code of Federal Regulations (36 CFR 

261.10i, 261.10j) sets noise guidelines for recreation sites, and national forests 

generally establish quiet hours at developed sites from 10:00 p.m. to 6:00 a.m. 

5. 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 the immediate area. 

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, Includ

Table 1. Comparison of potential impacts of all alternatives evaluated in this environmental impact statement 

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Wildlife Mexican spotted owl (MSO) 

Turkey Flat 

Noise and human presence would sporadically disturb the owl during the removal of improvements. Thus, removal will not be allowed during MSO nesting season. As natural succession occurs, the loss of open areas on the tracts may result in a decrease in populations of small mammals, upon which the MSO preys. Eventual regrowth of trees (60 to 80 years afterward) may 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. A 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 2. 

Efthe idealt

Wildlife Mt. Graham red squirrel (MGRS) 

Old Columbine 

Removal of an outhouse at Old Columbine could directly impact one midden and possibly result in MGRS death or injury. Thus, a 

No change from existing conditions. Because of human presence at and near an 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 2. Alternatives, Including the Proposed Action 

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

determination that no action “may affect, is likely to adversely affect” the MGRS was made. Natural succession of trees on Old Columbine, but not Turkey Flat, may provide 25 acres of MGRS habitat over the long term. 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 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. 

active midden, a determination of “may affect, likely to adversely affect” was made for Old Columbine. A biological opinion issued by the 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. 

Wildlife Mt. Graham red squirrel (MGRS) 

Turkey Flat Removal of an outhouse at 

Old Columbine could directly impact one midden and possibly result in MGRS death or injury. Thus, a determination that no action “may affect, is likely to adversely affect” the MGRS 

No change from existing conditions. A 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. 

Efthe idealt

16 DEIS for New Special-Use Permits for Recreation Residences, 
Chapter 2. Alternatives, Includ

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

was made. Natural succession of trees on Old Columbine, but not Turkey Flat, may provide 25 acres of MGRS habitat over the long term. 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 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. 

Wildlife Apache trout 

Old Columbine 

Removal of improvements would increase erosion and runoff from the tracts in the 

short term. Impacts to water quality in the subwatershed would be insignificant. 

No change from existing conditions. A determination of “may affect, not likely to adversely affect” was made with regard to the 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 2. Alternatives, Including the Proposed Action 

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Turkey Flat This species does not occur at 

the Turkey Flat tract. 

potential impacts to the Apache trout at Old Columbine. 

Effects would be the same as those identified for alternative 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Wildlife Forest Service Sensitive Species 

Turkey Flat 

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 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Wildlife Management Indicator Species 

Turkey Flat 

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 2. 

Efthe idealt

Heritage Resources (Sites on or eligible for the National Register of Historic 

 Old Columbine 

A determination of “no adverse effect” on historic properties was made, per 36 CFR 800.5 (b). Removal is the preferred alternative of the Western 

Because residences were present prior to eligibility designation of the Traditional Cultural Property and their continued presence would not affect the qualities 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

18 DEIS for New Special-Use Permits for Recreation Residences, 
Chapter 2. Alternatives, Includ

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Places) Turkey Flat Apaches. that make the mountain 

eligible for the National Register, a 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 2. 

Efthe idealt

 Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Heritage Resources (Dził Nchaa 

Si’an, eligible Traditional Cultural Property) 

Turkey Flat 

Removal would enhance the sacredness of the mountain by fostering 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, for example, restoration of wildlife habitat and natural fire regime would be inhibited, visual and noise intrusions would continue. 

Effects would be the same as those identified for alternative 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Air Quality 

Turkey Flat 

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 2. 

Efthe idealt

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 2. Alternatives, Including the Proposed Action 

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Soils 

Turkey Flat 

Minimal short-term increase in erosion after improvements are removed. Use of best management practices would minimize impacts to insignificant levels. Sites would eventually return to a more natural slope. No change in soil productivity. 

No change from existing conditions. Natural soil bulk density and structure would remain slightly compacted and altered by foot and vehicle traffic within the 77 acres occupied by the tracts. 

Effects would be the same as those identified for alternative 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Water and Riparian Resources 

Turkey Flat 

Potential for increased erosion on 77 acres in the short term. 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. 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 2. 

Efthe idealt

20 DEIS for New Special-Use Permits for Recreation Residences, 
Chapter 2. Alternatives, Includ

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Recreation 

Turkey Flat 

Use of the tracts for developed recreation would discontinue after 10 years. Tracts would become dispersed-use sites. Minimal increase in use of other recreation sites on the district. 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 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Visual and Aesthetic Resources 

Turkey Flat 

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 2. 

Efthe idealt

Old Columbine 

Wild and Scenic Rivers 

Turkey Flat 

No change from existing conditions. 

No change from existing conditions. 

No change from existing conditions. 

No exco

DEIS for New Special-Use Permits for Recreation Residences, Safford Ranger District 
Chapter 2. Alternatives, Including the Proposed Action 

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Social and Economic Resources 

Turkey Flat 

Until improvements are removed after 10 years, the family culture and tradition of permit holders, the small positive effect on the economy of surrounding towns, and revenues to Forest Service and Graham County would continue. Removal of improvements would result in a cost to permit holders of about $3,000. No disproportionate impacts to low income and minority populations. 

No change from existing conditions. No disproportionate impacts to low income and minority populations. 

Effects would be the same as those identified for alternative 2. 

Efthe idealt

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Fire Management 

Turkey Flat 

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 2. 

Efthe idealt

22 DEIS for New Special-Use Permits for Recreation Residences, 
Chapter 2. Alternatives, Includ

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

Resource 

Recreation 

Residence 

Tract 

Alternative 1 – No Action 

Alternative 2 – 

Proposed Action, Issue Permits for Both Tracts 

Alternative 3 – Issue 

Turkey Flat Only 

A

C

Old Columbine 

Effects would be the same as those identified for alternative 1. 

Efthe idealt

Cumulative Effects 

Turkey Flat 

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. Subsequent 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 2. 

Efthe idealt
Chapter 2. Alternatives, Including the Proposed Action 

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