United States Department of Agriculture

Final Environmental Impact Statement for 

the Four-Forest Restoration Initiative

Volume 2

Coconino and Kaibab National Forests

Coconino County, Arizona

Forest Service Southwestern Region MB-R3-04-24 November 2014
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Printed on recycled paper – November 2014
Contents

Appendix A – Map Packet ........................................................................................................563

Appendix B - FEIS Forest Plan Amendments.........................................................................565

Background..............................................................................................................................565

Alternative B – Coconino National Forest Site-Specific Nonsignificant Forest Plan 

Amendments............................................................................................................................568

Alternative C – Coconino National Forest Site-Specific Nonsignificant Forest Plan 

Amendments............................................................................................................................598

Alternative D – Coconino National Forest Site-Specific Nonsignificant Forest Plan 

Amendments............................................................................................................................634

Appendix C – Design Features, Best Management Practices, and Mitigation.....................637

Appendix D – Alternative B through E Implementation Plan...............................................683

Description of Plan Components.............................................................................................683

Section A – Management Direction, Desired Conditions, and Treatment Design .................690

Section B – Decision Matrix....................................................................................................731

Section C – Old Tree Implementation Plan .............................................................................733

Section D – Modified Large Tree Implementation Plan (Alternatives C and E).....................735

Section E – Density Management and the Relationship Between Treatment Intensity, Tree 

Group Density, and Overall Average Density .........................................................................744

Appendix E – Four Forests Restoration Initiative Adaptive Management, Biophysical and 

Socioeconomic, Mexican Spotted Owl and Arizona Bugbane Monitoring Plan ..................747

Outline of This Plan.................................................................................................................747

Introduction..............................................................................................................................748

Adaptive Management Process:...............................................................................................748

Monitoring ...............................................................................................................................751

Attachment 1. Mexican Spotted Owl Project Monitoring .......................................................836

Attachment 2. Arizona Bugbane Administrative Study: Fire effects ......................................840

Arizona bugbane and fire.........................................................................................................840

Historic and recent Fire............................................................................................................842

Study design.............................................................................................................................845

Reporting .................................................................................................................................850

Attachment 3. Alternatives B through E springs, channel and road adaptive management 

actions......................................................................................................................................851

Appendix F – Cumulative Effects.............................................................................................857

Authorized Livestock Management.........................................................................................857

Timber Harvest ........................................................................................................................858

Natural Disturbances – Fire .....................................................................................................865

Natural Disturbances – Insect and Disease..............................................................................867

Private, State, and Other Agency Activities ............................................................................869

Summary of Current and Ongoing Projects.............................................................................870

Summary of Reasonably Foreseeable Projects........................................................................876

Reasonably Foreseeable Projects With Insufficient Information for Analysis.......................884

Appendix G – Bridge Habitat for Canopy-Dependent Wildlife ...........................................887

Introduction................................................................................................................................887

Bridge Habitat at the Landscape Scale ....................................................................................887

Ponderosa Pine Treatment Area Scale (507,839 acres)...........................................................889

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests i
Contents

Bridge Habitat at the Restoration Unit Scale ...........................................................................894

Bridge Habitat at the Mid-Scale...............................................................................................897

Conclusions about Bridge Habitat in the 4FRI Project............................................................902

Appendix H – Glossary..............................................................................................................905

Appendix I - Summary of Response to Comments on the DEIS ...........................................919

List of Commenters..................................................................................................................919

The Hopi Tribe.........................................................................................................................925

Flagstaff Fire Department........................................................................................................930

U.S. Environmental Protection Agency...................................................................................932

USDI National Park Service ....................................................................................................936

The State of Arizona Game and Fish Department ...................................................................937

Arizona State Forestry Division...............................................................................................940

Coconino Natural Resource Conservation District..................................................................944

Arizona Department of Environmental Quality.......................................................................946

U.S. Department of the Interior ...............................................................................................947

Eastern Arizona Counties Organization...................................................................................955

Summary of Response to Comments on the DEIS ..................................................................994

References Cited.......................................................................................................................1023

Index..........................................................................................................................................1047

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

ii Coconino and Kaibab National Forests
Contents

Tables

Table 103. Summary of Coconino NF forest plan amendments by alternative and theme .........................567

Table 104. Alternative B amendment 1; current and proposed Mexican spotted owl forest plan language 

(Coconino NF)....................................................................................................................................570

Table 105. Alternative B amendment 1 management area acres (Coconino NF)........................................581

Table 106. Alternative B Amendment 2 Management of Canopy Cover and Ponderosa Pine with an Open 

Reference Condition in Goshawk Habitat (Coconino NF) .................................................................583

Table 107. Alternative B amendment 2 management area (MA) acres (Coconino NF)..............................590

Table 108. Timber suitability calculation for the Coconino NF..................................................................591

Table 109. Alternative B amendment 3 effect determination for cultural resources (Coconino NF)..........594

Table 110. Alternative C amendment 1 Mexican spotted owl current and proposed forest plan language 

(Coconino NF)....................................................................................................................................600

Table 111. Alternative C Mexican spotted owl amendment 1 management area (MA) acres ....................616

Table 112. Alternative C amendment 2 management of canopy cover and ponderosa pine with an open 

reference condition in goshawk habitat (Coconino NF).....................................................................619

Table 113. Alternative C amendment 2 management area (MA) acres.......................................................626

Table 114. Timber suitability calculation for the Coconino NF..................................................................627

Table 115. Alternative C amendment 3 effect determination for cultural resources...................................630

Table 116. Alternatives B, C, D, and E design features, best management practices, and mitigation ........638

Table 117. Annual implementation checklist..............................................................................................685

Table 118. Planned acres by treatment type and restoration unit (RU).......................................................686

Table 119. NEPA, NFMA, ESA, CFLR Act compliance evaluation..........................................................688

Table 120. Supporting documentation checklist .........................................................................................689

Table 121. Mexican spotted owl restricted habitat target/threshold conditions for pine-oak forests ..........692

Table 122. Restricted other habitat treatment criteria .................................................................................695

Table 123. Minimum desired conditions for pine-oak forest areas managed for Recovery nesting/roosting 

habitat (USDI FWS 2012)..................................................................................................................699

Table 124. Percent of trees, tree groups, and interspaces by treatment intensity (landscapes outside of 

goshawk post-fledging areas) .............................................................................................................703

Table 125. Landscapes outside of goshawk post-fledging areas wildland-urban interface and unever-aged 

treatments stocking guidelines for tree groups ...................................................................................704

Table 126. Interspace percent and width in Landscapes Outside of Goshawk Post-fledging Areas wildlandurban interface (WUI) and uneven-aged (UEA) treatments...............................................................705

Table 127. Percent of area occupied by trees, tree groups, and interspace in landscapes outside of goshawk 

post-fledging areas intermediate thin (IT) ..........................................................................................706

Table 128. Stocking guidelines for VSS 4 to 6 tree groups in landscapes outside of goshawk post-fledging 

areas intermediate thin (IT) treatments...............................................................................................708

Table 129. Percent and width of interspace in landscapes outside of goshawk post-fledging areas 

intermediate thin (IT) treatments........................................................................................................708

Table 130. Stocking guidelines for tree groups in landscapes outside of goshawk post-fledging areas stand 

improvement (SI) treatments..............................................................................................................709

Table 131. Interspace percent and width landscapes outside of goshawk post-fledging areas stand 

improvement (SI) treatments..............................................................................................................709

Table 132. Stocking guidelines for VSS 4 to VSS 6 tree groups in landscapes outside of goshawk postfledging areas pine-sage treatments....................................................................................................712

Table 133. Percent of area occupied by individual trees, tree groups, and interspace in dispersal postfledging family areas / post-fledging family areas uneven-aged (UEA) treatments...........................715

Table 134. Stocking guidelines for tree groups in dispersal post-fledging family areas / post-fledging family 

areas wildland-urban interface and uneven-aged treatments..............................................................717

Table 135. Interspace percent and width in dispersal post-fledging family areas / post-fledging family areas 

wildland-urban interface and uneven-aged (UEA) treatments............................................................717

Table 136. Percent of area occupied by trees and interspace for dispersal post-fledging family areas / postfledging family areas intermediate thin (IT).......................................................................................719

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests iii
Contents

Table 137. Dispersal post-fledging family areas / post-fledging family areas intermediate thin (IT) 

treatments stocking guidelines for VSS 4 – 6 tree groups ................................................................. 720

Table 138. Interspace percent and width in dispersal post-fledging family areas / post-fledging family areas 

intermediate thin (IT)......................................................................................................................... 720

Table 139. Percent of area occupied by individual trees, tree groups, and interspaces in dispersal postfledging family areas / post-fledging family areas stand improvement (SI) treatments..................... 721

Table 140. Stocking guidelines for tree groups in dispersal post-fledging family areas / post-fledging family 

areas stand improvement (SI) treatments........................................................................................... 723

Table 141. Interspace percent and width in dispersal post-fledging family areas / post-fledging family areas 

stand improvement (SI) treatments.................................................................................................... 723

Table 142. Stocking guidelines for VSS 4–6 tree groups in dispersal post-fledging family areas / postfledging family areas pine-sage treatments........................................................................................ 725

Table 143. Minimum structural attributes in suitable goshawk nest stands*.............................................. 727

Table 144. Section B decision matrix for establishing tree groups, interspace, and regeneration openings731

Table 145. Section E the relationship between treatment intensity, tree group density, and overall average 

density................................................................................................................................................ 744

Table 146. Effectiveness monitoring tiers and prioritization...................................................................... 754

Table 147. Scale terms used by different groups and within this document............................................... 754

Table 148. Implementation monitoring questions and indicators............................................................... 756

Table 149 Suggested Indicators: Forest Service and multiparty monitoring needed for adaptive 

management ...................................................................................................................................... 781

Table 150. Four Forest Restoration Initiative socioeconomic monitoring framework for social systems.. 804

Table 151. Four Forest Restoration Initiative socioeconomic monitoring framework for economic systems

........................................................................................................................................................... 819

Table 152. Number of ignitions by month over a 25-Year period within the area shown in figure 71 ...... 843

Table 153. Arizona bugbane locations and sites in the Upper West Fork PAC ......................................... 845

Table 154. Selected alternative springs, channels, and roads adaptive management actions..................... 851

Table 155. Summary of past projects that have influenced existing conditions (2000 to 2014)................. 861

Table 156. Summary of past vegetation and prescribed fire project acres (2000 to 2014) adjacent to the 

project area......................................................................................................................................... 864

Table 157. Coconino and Kaibab NF documented wildfire acres 1940 to 2014 ........................................ 867

Table 158. Acres affected by insect and disease outbreaks by forest (within project area)........................ 868

Table 159. Past treatments on private, State, and other federally managed lands 2000-2013 .................... 870

Table 160. Current and ongoing vegetation, prescribed fire, and other ground-disturbing projects........... 870

Table 161. Current and ongoing other projects .......................................................................................... 875

Table 162. Reasonably foreseeable vegetation and ground-disturbing projects within and adjacent to the 

project area......................................................................................................................................... 878

Table 163. Other (non-vegetation) reasonably foreseeable projects within the project area ...................... 881

Table 164. Other agency and private lands foreseeable vegetation and prescribed fire projects................ 881

Table 165. Other foreseeable vegetation and prescribed fire projects outside the project area .................. 882

Table 166. Acres of treatment and non-treatment areas within the 4FRI project area................................ 888

Table 167. Acres of proposed treatment in terms of post-treatment openness ........................................... 890

Table 168. Post-treatment contributions to bridge habitat provided by each treatment designation .......... 892

Table 169. Proposed post-treatment openness condition (percent) by restoration unit .............................. 895

Table 170. Design features, BMPs, and mitigation measures contributing to bridge habitat ..................... 898

Table 171. Excerpt from section D of the 4FRI implementation guidelines .............................................. 902

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

iv Coconino and Kaibab National Forests
Contents

Figures

Figure 54. Alternative B amendment 1 Mexican spotted owl PAC treatments...........................................578

Figure 55. Alternative B goshawk habitat subject to canopy cover requirements in VSS 4 and VSS 6 

(Coconino NF)....................................................................................................................................587

Figure 56. Alternative B general locations of savanna and grassland restoration treatments (Coconino NF 

and Kaibab NF*) ................................................................................................................................588

Figure 57. Alternative C amendment 1 proposed activities in Mexican spotted owl PACs in relation to no 

treatment areas (Coconino NF)...........................................................................................................609

Figure 58. Alternative C amendment 1 prescribed fire within and outside of Mexican spotted owl core areas

............................................................................................................................................................610

Figure 59. Alternative C amendment 1 landscape target and threshold analysis ........................................611

Figure 60. Alternative C amendment 1 general locations of Mexican spotted owl target and threshold 

habitat managed from 110 to 150 basal area (Coconino NF) .............................................................612

Figure 61. Alternative C amendment 1 locations of Mexican spotted owl target and threshold treatments613

Figure 62. Alternative C general location of goshawk habitat subject to canopy cover requirements in VSS 

4 to VSS 6 (Coconino NF and Kaibab NF) ........................................................................................623

Figure 63. Alternative C amendment 2 general locations of savanna and grassland restoration treatments 

(Coconino NF)....................................................................................................................................624

Figure 64. Alternative B amendment 1 Mexican spotted owl PAC treatments...........................................635

Figure 65. Old tree characteristics (Thompson 1940) .................................................................................734

Figure 66. Old age tree characteristics continued (Thompson 1940)..........................................................734

Figure 67. Section E density management and stocking guidelines............................................................746

Figure 68. 4FRI adaptive management process...........................................................................................750

Figure 69. Arizona bugbane plants near the fire line on Fry Fire September 2004.....................................841

Figure 70. Arizona bugbane sprouting from roots about a month after the Slide Fire burned though this 

population...........................................................................................................................................842

Figure 71. Arizona bugbane populations are shown in orange. Lightning fires locations are shown as: 

Yellow = January through April; Pink = May through September; Blue = October through December. 

2) Perimeters of lightning fires that grew to 10 acres or larger are in green.......................................844

Figure 72. Map of the treatment areas. Arizona bugbane is shown in black...............................................847

Figure 73. Map showing soil units in Arizona bugbane areas to be treated ................................................849

Figure 74. Pre-1996 vegetation and prescribed fire projects within the project area ..................................859

Figure 75. General locations of past projects (post-1996) within the project area ......................................865

Figure 76. General locations of current and ongoing projects within or adjacent to the project area..........876

Figure 77. General locations of foreseeable projects within or adjacent to the project area .......................885

Figure 78. Relative, post-treatment forest density across the 4FRI project area, alternative C...................889

Figure 79. Restoration unit boundaries within the 4FRI treatment area......................................................895

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests v
List of Acronyms

4FRI Four-Forest Restoration Initiative

ACHP Advisory Council on Historic 

Preservation

ADEQ Arizona Department of Environmental 

Quality

AGFD Arizona Game and Fish Department

AUM Animal Unit Month

BA Basal area

BAER Burned Area Emergency Response

BCC Birds of Conservation Concern

BCR Bird Conservation Region

BE Biological evaluation

BMP Best management practice

CCF Hundred cubic feet

CEQ Council on Environmental Quality

CFLR Collaborative Forest Landscape 

Restoration

CFLRP Collaborative Forest Landscape 

Restoration Program

CFR Code of Federal Regulations

CHU Critical habitat unit

CNF Coconino National Forest

CO Carbon monoxide

CWD Coarse woody debris

d.b.h. Diameter at breast height

DEIS Draft environmental impact statement

dPFA Dispersal post-fledging area

d.r.c. diameter at root collar

EIS Environmental impact statement

EMA Ecosystem management area

EPA Environmental Protection Agency

EIS Environmental impact statement

FEIS Final Environmental Impact Statement

FLEA Flagstaff/Lake Mary Ecosystem 

Analysis

FRCC Fire regime condition class

FSH Forest Service Handbook

FSM Forest Service Manual

FVS Forest Vegetation Simulator

FWS United States Fish and Wildlife 

Service

GIS Geographic information system

HUC Hydrologic unit code

IBA Important bird area 

IMPLAN Impact Analysis for Planning

IT Intermediate thin

KNF Kaibab National Forest

LANL Los Alamos National Laboratory

LOPFA Landscapes outside post-fledging 

family area

LTIP Large tree implementation plan

LTRS Large tree retention strategy

MA Management area

MAUM Thousand animal unit month

MIS Management indicator species

ML Maintenance level

MRNG Management Recommendations for 

the Northern Goshawk in the 

Southwestern United States

MSO Mexican spotted owl

NAAQS National Ambient Air Quality 

Standards

NEPA National Environmental Policy Act

NF National Forest

NFMA National Forest Management Act

NHPA National Historic Preservation Act

NMED New Mexico Environment Department

NRV Natural Range of Variability

PAC Protected activity center

PFA Northern goshawk post-fledging 

family area

PJ Pinyon-juniper

PM Particulate matter

PNVT Potential natural vegetation type

ROS Recreation opportunity spectrum

ROW Right-of-way

RU Restoration unit

SDI Stand density index

SHPO State Historic Preservation Office

SI Stand improvement

SIO Scenery integrity objectives

SWCP Soil and water conservation practice

TAP Travel analysis process

TCP Traditional cultural properties

TES Threatened, endangered and sensitive 

TMR Travel Management Rule

TPA Trees per acre

UEA Uneven-aged

USDA United States Department of 

Agriculture

USDI United States Department of the 

Interior

VMS Visual Management System

VSS Vegetation structural stages

WEPP Water Erosion Prediction Project

WFLC Western Forest Leadership Coalition

WUI Wildland-urban interface

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests vi
Appendix A – Map Packet

Note: Paper copies of the FEIS include a packet of poster-sized maps for alternatives B, C, D and 

E. Electronic copies of the FEIS are available in DVD and web-based formats. For those viewing 

the FEIS electronically, maps can be viewed online or map packets are available upon request.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 563

Appendix B - FEIS Forest Plan Amendments

Background 

Table 103 summarizes the proposed forest plan amendments by alternative and theme. For 

electronic copy viewers, hyperlinks to each amendment are provided. Since the DEIS was issued 

in 2012, a revised Kaibab NF Forest Plan became effective (USDA FS 2014). All forest plan 

amendments for the Kaibab NF have been removed from the FEIS because the alternatives are 

consistent with the revised Kaibab NF forest plan. The project’s desired conditions for ponderosa 

pine were based on the best available science for the restoration of southwestern fire-adapted 

ecosystems (Reynolds et al. 2013). These desired conditions informed the Kaibab NF’s plan 

revision process. The amendments for Mexican spotted owl were removed because the project is 

consistent with the forest plan in that a guideline for threatened, endangered and sensitive species 

directs projects to integrate management objectives and protection measures from approved 

recovery plans (KNF forest plan, p. 51).With design features and mitigation, alternatives B 

through E are consistent with forest plan objectives, desired conditions, standards and guidelines, 

although movement towards desired conditions varies by alternative. Kaibab NF forest plan 

consistency evaluations are located in each resource report. A consolidated evaluation is in the 

project record. 

Three nonsignificant amendments for the Coconino NF were evaluated in the FEIS. The proposed 

forest plan amendments are authorized via 36 CFR 219, the Forest Service Planning Rule. Section 

219.17(b)(3) of the Rule provides the transition language that allows this project to propose 

amendments to the Coconino NF forest plan using the provisions of the 1982 Planning Rule. All 

amendments are a specific, one-time variance for the Coconino NF restoration project. Once the 

project is complete, current forest plan direction would apply to the project area. The language 

proposed does not apply to any other forest project. 

The purpose of amendment 1 is to bring the alternative in alignment with the revised Mexican 

Spotted Owl Recovery Plan (USDI FWS 2012) and defer monitoring to the U.S. Fish and 

Wildlife Service biological opinion that is specific to this project. Amendment 2 clarifies existing 

direction related to managing canopy cover and interspace in the forest plan. The purpose of 

amendment is to bring the project into alignment with the best available science (Reynolds et al. 

2013) that provides desired conditions for restoring fire-adapted ponderosa pine in the Southwest. 

Amendment 3 resolves a forest plan error related to the management of heritage resources and is 

specific to this project. The detailed significance analysis for each amendment is located in 

appendix B of the FEIS. 

Amendments 1 through 3 were evaluated in accordance with the significance amendment criteria 

in FSM 1926.51 and FSM 1926.52. The significance analysis for each amendment included in the 

selected alternative is displayed in this appendix. 

No amendment alters multiple use forest plan goals and objectives, adjusts management area 

boundaries or management prescriptions. The changes in standards and guidelines are considered 

to be minor because they reflect the latest, best available science (Reynolds et al. 2013). The 

amendments bring the alternatives into alignment with the revised Mexican spotted owl Recovery 

Plan, although the degree of alignment varies by alternative. No amendment would alter the longterm relationship between levels of multiple-use goods and services originally projected for the 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 565
Appendix B – Forest Plan Amendments

Coconino NF. These outputs were specific to a planning period ranging from 10 to 15 years (as 

identified in 1987). In the preferred alternative (alternative C): 

• Amendment 1: The amendment would affect 6,906 acres or 18 percent of Mexican spotted 

owl PAC habitat on the Coconino NF.

• Amendment 2 is clarification amendment. The canopy cover portion of the amendment would 

generally affect 137,242 acres (15 percent) of all goshawk habitats on the Coconino NF. 

Managing 28,653 acres of ponderosa pine for an open reference condition would affect 

approximately 3 percent of all suitable goshawk habitats on the Forest.

• Amendment 3 is specific to the 355,707 acres of proposed treatments in this project. The 

amendment would affect about 20 percent of the Coconino NF (which totals 1,821,495 

acres).

For these reasons, the amendments would not result in an important effect to the entire land 

management planning area. Each amendment is a specific, one-time variance for this restoration 

project. The best available science for management in Southwestern forests Reynolds et al. 2013), 

the (Coconino NF) forest plan revision process, is affecting ongoing and future analyses. The plan 

amendments that are specific to this project do not impose direction on ongoing or future 

analyses. 

Changes since Draft Environmental Impact Statement

A revised Mexican spotted owl Recovery Plan, issued by the U.S. Fish and Wildlife Service was 

finalized in December of 2012 (USDI FWS 2012). As consistency evaluation has been added to 

amendment 1 (Mexican spotted owl) for each alternative to demonstrate consistency with the 

2012 recovery plan. The portion of the amendment that adjusted the percent to target and 

threshold habitat has been removed. The percentages of target and threshold habitat on the 

Coconino NF meet or exceed requirements. 

Acreages in all amendments have been updated as needed (see chapter 1 for discussion on 

changes from DEIS to FEIS). Since the DEIS was released for public comment in 2013, a revised 

forest plan for the Kaibab NF became effective. No forest plan amendments would be needed on 

the Kaibab NF. All Kaibab NF plan amendments were removed (see Background section).

Related Planning Efforts

Currently, the Coconino NF is revising its forest plan. A DEIS and draft revised land and resource 

management plan (hereafter referred to as “Coconino NF draft revised plan” was released for 

comment in January of 2014 (USDA FS 2013). An analysis was conducted to determine how the 

proposed amendments align with the Coconino NF draft revised plan (as currently written in 

2013). The evaluation is located in the project record.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

566 Coconino and Kaibab National Forests
Appendix B – Forest Plan Amendments

Table 103. Summary of Coconino NF forest plan amendments by alternative and theme 

Alternative

Mechanical 

Treatments in PACs

Treatments in 

PAC Core Areas

Restricted Habitat 

Management

Basal Area in 

Restricted Target and 

Threshold Habitat

Population and Habitat 

Monitoring

Habitat Treatment in 

Incremental 

Percentages

Forest Plan Amendment 1: Theme - Management in Mexican Spotted Owl Habitat on the Coconino NF

A, E N/A

B Amendment 1: Allows 

mechanical treatment 

up to 16 inches d.b.h. 

in 18 PACs

N/A: No PAC core 

area treatments

Amendment 1: 

Adds definitions for 

target and threshold 

habitat 

N/A—basal area in 

restricted target and 

threshold habitat remains 

150 on both forests

Amendment 1: 

Defers monitoring to the 

project’s U.S. Fish and 

Wildlife Service (FWS) 

biological opinion

Amendment 1: Defers 

treatment design to the 

project’s FWS 

biological opinion

C Amendment 1:

Allows mechanical 

treatment up to 17.9 

inches d.b.h. in 18 

PACs and decreases the 

minimal basal area 

from 150 to 110 in the 

18 PACs

Amendment 1:

Allows prescribed 

fire in 54 core 

areas

Amendment 1: 

Adds definitions for 

target and threshold 

habitat

Amendment 1:Allows for 

managing 6,299 acres of 

restricted target and 

threshold habitat for a 

minimum range of 110 to 

150 basal area 

Amendment 1: 

Defers monitoring to the 

project’s FWS biological 

opinion

Amendment 1: Defers 

treatment design to the 

project’s FWS 

biological opinion

D Amendment 1:

Allows mechanical 

treatment up to 16 

inches d.b.h. in 18 

PACs

N/A: No PAC core 

area treatments

Amendment 1: 

Adds definitions for 

target and threshold 

habitat 

N/A—basal area in 

restricted target and 

threshold habitat remains 

150 

Amendment 1: 

Defers MSO monitoring 

to the project’s FWS 

biological opinion

Amendment 1: Defers 

treatment design to the 

project’s FWS 

biological opinion

Forest Plan Amendment 2: Theme - Management of Canopy Cover and Ponderosa Pine with an Open Reference Condition within Goshawk Habitat on the Coconino 

NF

A N/A

B-D Amendment 2: (1) adds the desired percentage of interspaces within uneven-aged stands to facilitate restoration, (2) adds the interspaces distance between tree 

groups, (3) adds language clarifying where canopy cover is and is not measured, (4) allows 28,952 acres (alternatives B and D) and 28,653 (alternative C only) 

to be managed for an open reference condition (up to 90 percent open with less than 3 to 5 reserve trees), and (5) adds a definition to the forest plan glossary 

for the terms: interspaces, open reference condition, and stands.

E N/A: No desired percentage of interspaces would be added. No language clarifying where canopy cover is and is not measured would be added. Zero acres 

would be managed for up to 90 percent open with less than 3 to 5 reserve trees. No definition of interspace and stands would be added.

Forest Plan Amendment 3: Theme - Effect Determination for Cultural Resources on the Coconino NF

A N/A

B-D Amendment 3: The amendment deletes the standard that would require achieving a “no effect” determination and adds the words “or no adverse effect” to the 

remaining standard. In effect, management strives to achieve a "no effect" or “no adverse effect” determination.

E N/A: Forest plan standard that would require achieving a “no effect” determination would remain in place.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 567
Appendix B – Forest Plan Amendments

Alternative B – Coconino National Forest 

Site-Specific Nonsignificant Forest Plan Amendments 

Amendment 1. Mexican Spotted Owl Habitat Management 

(Coconino NF)

Background

The treatment area contains about 35,019 total acres of Mexican spotted owl protected habitat, 

most of which occurs in Restoration Unit 1. There are 193 PACs occurring completely or partially 

on the Coconino and Kaibab National Forests. There are 70 PACs (about 34,183 acres) in the 

4FRI treatment area (in areas proposed for mechanical and prescribed fire treatments). The 

remaining protected habitat (836 acres) occurs on steep slopes where timber harvest has not 

occurred in the previous 20 years and is not proposed for mechanical treatment. Proposed 

treatments for steep-slope protected habitat consist of prescribed fire only – no mechanical 

treatments are proposed for this category of habitat. 

In 2011, biologists from the Coconino and Kaibab NFs, the 4FRI team, and the U.S. Fish and 

Wildlife Service worked together to review individual Mexican spotted owl PACs within the 

project area. Prior to conducting site visits, the team met with the Rocky Mountain Research 

Station (RMRS) and requested a summary and synthesize of existing knowledge on the status and 

ecology of Mexican spotted owls within the ecosystem management unit. Dr. William Block, 

Program Manager and Supervisory Research Wildlife Biologist at the RMRS and also senior 

author of the Recovery Plan for the Mexican spotted owl, and Dr. Joseph Ganey, Research 

Wildlife Biologist at the RMRS, member of the Mexican spotted owl recovery team, and lead 

scientist on multiple Mexican spotted owl research projects, agreed to our request. Dr. Ganey and 

other Mexican spotted owl experts published the “Status and ecology of Mexican spotted owls in 

the Upper Gila Mountains Recovery Unit, Arizona and New Mexico” in 2011 (RMRS-GTR-256). 

The intent of this report is to aid planners in evaluating potential benefits or impacts of 

management actions for Mexican spotted owls and their habitat.

The evaluation process included site visits and modeling silvicultural treatments and prescribed 

fire to move existing owl habitat toward the desired conditions described in the former 1995 

Mexican spotted owl recovery plan (USDI FWS 1995) and forest plan. A total of 117 PACs were 

evaluated within and near the project area. Of this total, 18 were identified as having habitat that 

could be improved with vegetation treatments. No PACs proposed for treatment are located in 

designated wilderness. Each stand within the 18 PACs was modeled to identify treatments that 

would yield the best existing and future Mexican spotted owl habitat conditions. See the wildlife 

specialist report “Methodology” section for complete details on the habitat evaluation process.

Also in 2011, a geographic layer for restricted habitat across the 4FRI treatment area was 

developed. Data from the Kaibab and Coconino NFs (based on polygons) was merged with pineoak data from the Lab of Landscape Ecology and Conservation Biology (raster data; Dr. Steve 

Sesnie and Jill Rundall, Northern Arizona University). This landscape-scale approach better met 

the goal of providing continuous replacement nesting and roosting habitat over space and time, as 

described in the previous (1995) recovery plan and the 1996 “Record of Decision for the 

Amendment of Eleven Forest Plans.” A new restricted layer was created within the 4FRI 

treatment area, including designation of target and threshold habitat as described in the former 

Mexican spotted owl recovery plan. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

568 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Mechanical Treatment Up to 16 inches d.b.h. in select PACs (6,906 acres)

Mexican spotted owl PAC field reviews, data evaluation, and vegetation simulation modeling 

indicated 18 Mexican spotted owl PACs (approximately 3,378 acres) would move toward revised 

Mexican spotted owl Recovery Plan desired conditions from mechanically cutting trees up to 9

inches d.b.h. Treatments up to 9 inches d.b.h. are consistent with the current Coconino NF forest 

plan. 

An additional 6,906 acres within 18 PACs would have nesting and roosting habitat benefits from 

cutting trees up to 16 inches d.b.h. Mechanical treatments above 9 inches d.b.h. would facilitate 

the removal of ladder and canopy fuels which would reduce the fire risk in the 18 PACs (to the 

extent possible). Increasing the range of the mechanical treatment thresholds up to 16 inches 

d.b.h. within 18 Mexican spotted owl PACs would provide for a higher degree of stand structure 

improvements to nesting and roosting habitat. The treatments (as allowed by the amendment) 

would address comments from the U.S. Fish and Wildlife Service and meet the intent of the 

Revised Mexican spotted owl Recovery Plan by improving nesting roosting habitat (USDI FWS

2012). Figure 54 displays the general location of mechanical treatment up to 16 inches d.b.h., 

prescribed fire, and areas where no treatment is proposed within Mexican spotted owl PACs.

Incremental Treatments and Monitoring Responses to Spotted Owl Treatments

Monitoring assesses the effectiveness of management actions and provides the adaptive 

framework for more successful management guidelines. Monitoring habitat allows for modeling 

future forest conditions to determine if there will be adequate habitat to support Mexican spotted 

owl populations. Occupancy, reproduction and habitat monitoring and final project design for all 

proposed activities in all Mexican spotted owl habitat was developed in consultation with the U.S. 

Fish and Wildlife Service. Monitoring requirements from the biological opinion have been 

incorporated into the FEIS in appendix E. 

Target and Threshold Restricted Habitat 

Because this project was developed while the former recovery plan was in place, many treatments 

were modeled specifically to meet target and threshold (future nesting and roosting) habitat 

requirements. Definitions of target and threshold habitat would be added since the current forest 

plan refers to “threshold” in terms of values and desired conditions (see Coconino NF forest plan, 

page 65-3.) within restricted habitat and there is no reference to “target” conditions. The 

continued use of the terms (and definitions) of target and threshold habitat (considered future 

nesting and roosting habitat as part of restricted habitat is consistent with Revised Mexican 

spotted owl Recovery Plan’s direction for nesting and roosting in recovery habitat (table C.1 to 

C.3). 

Amendment Description

The amendment would remove language that limits PAC treatments in the recovery unit to 10 

percent increments and language that requires the selection of an equal number of untreated PACs 

as controls. The amendment would remove language referencing monitoring (pre- and posttreatment, population, and habitat monitoring). Replacement language defers final project design 

and monitoring to the U.S. Fish and Wildlife Service biological opinion specific to Mexican 

spotted owl for the project. The final designs for the project (as required by the biological 

opinion) have been incorporated into the FEIS appendix D implementation plan. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 569
Appendix B – Forest Plan Amendments

The amendment would add language to allow mechanical treatments up to 16 inches d.b.h. to 

improve habitat structure (nesting and roosting habitat) in 18 Mexican spotted owl PACs 

(recovery habitat).

Edited or added text is shown in bold in table 104. 

Table 104. Alternative B amendment 1; current and proposed Mexican spotted owl forest plan 

language (Coconino NF)

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Mexican spotted owl Standards

No corresponding direction currently exists The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service.

Provide three levels of habitat management – 

protected, restricted, and other forest and woodland 

types to achieve a diversity of habitat conditions 

across the landscape (Coconino NF forest plan, page 

65).

No Change

Protected areas include delineated protected activity 

centers; mixed conifer and pine-oak forests with 

slopes greater than 40 percent where timber harvest 

has not occurred in the last 20 years; and reserved 

lands which include wilderness, research natural areas, 

wild and scenic rivers, and congressionally recognized 

wilderness study areas (Coconino NF forest plan, page 

65). 

No Change

Restricted areas include all mixed-conifer, pine-oak, 

and riparian forests outside of protected areas

(Coconino NF forest plan, page 65). 

No Change

Other forest and woodland types include all ponderosa 

pine, spruce-fir, woodland, and aspen forests outside 

protected and restricted areas (Coconino NF forest 

plan, page 65). 

No Change

Survey all potential spotted owl areas including 

protected, restricted, and other forest and woodland 

types within an analysis area plus the area 1/2 mile 

beyond the perimeter of the proposed treatment area 

(Coconino NF forest plan, page 65). 

No Change

Establish a protected activity center at all Mexican 

spotted owl sites located during surveys and all 

management territories established since 1989 

(Coconino NF forest plan, page 65). 

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

570 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Allow no timber harvest except for firewood and fire 

risk abatement in established protected activity 

centers. For protected activity centers destroyed by 

fire, windstorm, or other natural disaster, salvage 

timber harvest or declassification may be allowed after 

evaluation on a case-by-case basis in consultation with 

U.S. Fish and Wildlife Service (Coconino NF forest 

plan, page 65).

Allow no timber harvest except for firewood, fire risk 

abatement, in established protected activity centers 

except as follows: Allow firewood, fire risk 

abatement, and habitat structure improvement in 

the following established protected activity 

centers: Lake No. 1/Seruchos, Archies, Red Hill, 

Crawdad, Holdup, Bonita Tank, Red Raspberry, 

Bear Seep, Mayflower Tank, Knob, T6 Tank, Iris 

Tank, Frank, Rock Top, Lee Butte, Foxhole, Bar 

M, and Sawmill Spring. For protected activity 

centers destroyed by fire, windstorm, or other natural 

disaster, salvage timber harvest or declassification 

may be allowed after evaluation on a case-by-case 

basis in consultation with U.S. Fish and Wildlife 

Service.

Allow no timber harvest except for fire risk abatement 

in mixed conifer and pine-oak forests on slopes 

greater than 40 percent where timber harvest has not 

occurred in the last 20 years (Coconino NF forest 

plan, page 65). 

No Change

Limit human activity in protected activity centers 

during the breeding season (Coconino NF forest plan, 

page 65). 

No Change

In protected and restricted areas, when activities 

conducted in conformance with these standards and 

guidelines may adversely affect other threatened, 

endangered, or sensitive species or may conflict with 

other established recovery plans or conservation 

agreements; consult with US Fish and Wildlife 

Service to resolve the conflict (Coconino NF forest 

plan, page 65-1). 

No Change

Monitor changes in owl populations and habitat 

needed for delisting (Coconino National Forest plan, 

page 65-1).

The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service. 

Guidelines – General – No Change

Guidelines – Protected Areas, Protected Activity Centers

Delineate an area of not less than 600 acres around the 

activity center using boundaries of known habitat 

polygons and/or topographic features. Written 

justification for boundary delineation should be 

provided (Coconino National Forest plan, page 65-1).

No Change

The protected activity center boundary should enclose 

the best possible owl habitat configured in as compact 

a unit as possible, with the nest or activity center 

located near the center (Coconino National Forest 

plan, page 65-1).

No Change 

The activity center is defined as the nest site. In the 

absence of a known nest, the activity center should be 

defined as a roost grove commonly used during 

breeding. In the absence of a known nest or roost, the 

activity center should be defined as the best nesting 

and roosting habitat (Coconino NF forest plan, page 

65-1).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 571
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Protected activity center boundaries should not 

overlap (Coconino NF forest plan, page 65-1).

No Change

Submit protected activity center maps and descriptions 

to the recovery unit working group for comment as 

soon as possible after completion of surveys 

(Coconino NF forest plan, page 65-1).

No Change

Road or trail building in protected activity centers 

should be avoided but maybe permitted on a case-bycase basis for pressing management reasons 

(Coconino NF forest plan, page 65-1).

No Change

Generally allow continuation of the level of recreation 

activities that was occurring prior to listing (Coconino 

NF forest plan, page 65-1).

No Change

Require bird guides to apply for and obtain a special 

use permit. A condition of the permit shall be that they 

obtain a subpermit under the U.S. Fish and Wildlife 

Service Master Endangered Species permit. The 

permit should stipulate the sites, dates, number of 

visits, and maximum group size permissible 

(Coconino NF forest plan, page 65-1).

No Change

Harvest firewood when it can be done in such a way 

that effects on the owl are minimized. Manage within 

the following limitations to minimize effects on the 

owl (Coconino NF forest plan, page 65-2).

Retain key forest species such as oak.

Retain key habitat components such as snags and large 

downed logs.

Harvest conifers less than 9 inches in diameter only 

within those protected activity centers treated to abate 

fire risk as described below, except for the Clark PAC 

where trees less than 16 inches diameter will be 

harvested. 

Harvest firewood when it can be done in such a way 

that effects on the owl are minimized. Manage within 

the following limitations to minimize effects on the 

owl.

Retain key forest species such as oak.

Retain key habitat components such as snags and 

large downed logs.

Harvest conifers less than 9 inches in diameter only 

within those protected activity centers treated to abate 

fire risk as described below, except for the Clark 

PAC where trees less than 16 inches diameter will be 

harvested area except as follows:

Harvest conifers up to 16 inches diameter within 

the Lake No. 1/Seruchos, Archies, Red Hill, 

Crawdad, Holdup, Bonita Tank, Red Raspberry, 

Bear Seep, Mayflower Tank, Knob, T6 Tank, Iris 

Tank, Frank, Rock Top, Lee Butte, Foxhole, Bar 

M, and Sawmill Spring PACs to abate fire risk 

and improve habitat structure.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

572 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Treat fuel accumulations to abate fire risk.

–Select for treatment 10 percent of the protected 

activity centers where nest sites are known in each 

recovery unit having high fire risk conditions. Also 

select another 10 percent of the protected activity 

centers where nest sites are known as a paired sample 

to serve as control areas (Coconino National Forest 

plan, page 65-2).

–Designate a 100-acre “no treatment” area around the 

known nest site of each selected protected activity 

center. Habitat in the no treatment area should be as 

similar as possible in structure and composition as that 

found in the activity center.

–Use combinations of thinning trees less than 9 inches 

in diameter (or less than 16 inches in the Clark PAC), 

mechanical fuel treatment and prescribed fire to abate 

fire risk in the remainder of the selected protected 

activity center outside the 100-acre “no treatment” 

area.

Treat fuel accumulations to abate fire risk.

–Designate a 100-acre “no treatment” area around the 

known nest site of each selected protected activity 

center. Habitat in the no treatment area should be as 

similar as possible in structure and composition as 

that found in the activity center.

– Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the Clark 

PAC), mechanical treatment and prescribed fire to 

abate fire risk in the remainder of the selected 

protected activity center outside the 100-acre “no 

treatment” area except as follows:

Use combinations of thinning trees up to 16 inches

d.b.h. within the Lake No. 1/Seruchos, Archies, 

Red Hill, Holdup, Rock Top, Foxhole, Bar M, 

PACs, Crawdad, Bonita Tank, Red Raspberry, 

Bear Seep, Mayflower Tank, Knob, T6 Tank, Iris 

Tank, Frank, Lee Butte, and Sawmill Springs 

PACs, mechanical fuel treatment and prescribed fire 

to abate fire risk and improve habitat structure in 

the remainder of the selected protected activity center 

outside the 100-acre “no treatment” area.

Treat fuel accumulations to abate fire risk. Pre- and 

post-treatment monitoring should be conducted in all 

protected activity centers treated for fire risk 

abatement. (See monitoring guidelines) (Coconino 

National Forest plan, page 65-2).

The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service.

Steep Slopes (Mixed conifer and pine-oak forests outside protected activity 

centers with slopes greater than 40 percent that have not been logged 

within the past 20 years): No seasonal restrictions apply.

Treat fuel accumulations to abate fire risk.

–Use combinations of thinning trees less than 9 inches 

in diameter, mechanical fuel removal, and prescribed 

fire.

–Retain woody debris larger than 12 inches in 

diameter, snags, clumps of broadleafed woody 

vegetation, and hardwood tress larger than 10 inches 

in diameter at the root collar.

– Pre and post treatment monitoring should occur 

within all steep slopes treated for fire risk abatement. 

(See monitoring guidelines).

Treat fuel accumulations to abate fire risk.

–Use combinations of thinning trees less than 9 

inches in diameter, mechanical fuel removal, and 

prescribed fire.

–Retain woody debris larger than 12 inches in 

diameter, snags, clumps of broadleafed woody 

vegetation, and hardwood tress larger than 10 inches 

in diameter at the root collar.

–The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 573
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Reserved Lands (Wilderness, Research Natural Areas, Wild and Scenic Rivers, and Congressionally 

Recognized Wilderness Study Areas): 

Allow prescribed fire where appropriate – No change.

Restricted Areas (Mixed conifer, pine-oak, and riparian forests)

No corresponding direction Target habitat is a category of restricted habitat 

intended to provide future nesting and roosting 

habitat (see glossary definition for restricted 

habitat). The minimum values identified for the 

forest attributes represent the threshold for 

meeting nesting and roosting conditions (see the 

definition for threshold habitat). They can also be 

targets to be achieved with time and management. 

If less than 10 percent of the restricted habitat in 

ponderosa pine-Gambel oak qualifies as threshold 

habitat, the areas that can eventually achieve all 

threshold conditions simultaneously should be 

identified as target habitat and managed to 

achieve threshold conditions as rapidly as 

possible. Because no known nests or roosts occur 

in restricted habitat, target habitat is considered 

future nesting and roosting habitat.

No corresponding direction Threshold habitat is a category of restricted 

habitat intended to provide for future nesting and 

roosting habitat (see definition for restricted 

habitat). A variety of forest structural attributes is 

used to define when nesting and roosting habitat is 

achieved (summarized in table III.B.1 of the 1995 

recovery plan and table C-2 of the 2012 recovery 

plan). Threshold habitat meets or exceeds these 

values. When the minimum values identified for 

the forest attributes are met simultaneously, they 

represent the threshold of nesting and roosting 

conditions. Up to 10 percent of restricted habitat 

in ponderosa pine-Gambel oak should be 

designated as threshold habitat. Management in 

threshold habitat cannot lower any of the forest 

attribute values below the nesting and roosting

threshold unless a landscape analysis 

demonstrates an abundance of this habitat. 

Because no known nests or roosts occur in 

restricted habitat, target habitat is managed as 

future nesting and roosting habitat.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

574 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Mixed Conifer and Pine-oak Forests (see glossary 

definition): Manage to ensure a sustained level of owl 

nesting and roosting habitat well distributed across the 

landscape. Create replacement owl nesting and 

roosting habitat where appropriate while providing a 

diversity of stand conditions across the landscape to 

ensure habitat for a diversity of prey species. The 

following table displays the minimum percentage of 

restricted area which should be managed to have 

nesting and roosting characteristics. The minimum 

mixed conifer restricted area includes 10 percent at 

170 square feet of basal area and an additional amount 

of area at 150 square feet of basal area. The additional 

area of 150 square feet basal area is +10 percent in 

BR-E and +15 percent in all other recovery units. The 

variables are for stand averages and are minimum 

threshold values and must be met simultaneously. In 

project design, no stands simultaneously meeting or 

exceeding the minimum threshold values should be 

reduced below the threshold values unless a 

districtwide or larger landscape analysis of restricted 

areas shows that there is a surplus of restricted area 

acres simultaneously meeting the threshold values. 

Management should be designed to create minimum 

threshold conditions on project areas where there is a 

deficit of stands simultaneously meeting minimum 

threshold conditions unless the districtwide or larger 

landscape analysis shows there is a surplus. This table 

has been modified to contain only information 

pertinent to the Coconino NF. (Coconino NF forest 

plan, pages 65-3 to 65-5).

Mixed Conifer and Pine-oak Forests (See glossary 

definition): Manage to ensure a sustained level of owl 

nesting and roosting habitat well distributed across 

the landscape. Create replacement owl nesting and 

roosting habitat where appropriate while providing a 

diversity of stand conditions across the landscape to 

ensure habitat for a diversity of prey species. The 

following table displays the minimum percentage of 

restricted area which should be managed to have 

nesting and roosting characteristics. The minimum 

mixed conifer restricted area includes up to 10 

percent at 170 square feet of basal area and an 

additional amount of area at 150 square feet basal 

area. The additional area of 150 square feet of basal 

area is +10 percent in BR-E and +15 percent in all 

other recovery units. The variables are for stand 

averages, are minimum target and threshold habitat 

values, and must be met simultaneously. In project 

design, no stands simultaneously meeting or 

exceeding the minimum target and threshold habitat 

values should be reduced below target and threshold 

values unless a districtwide or larger landscape 

analysis of restricted areas shows that there is a 

surplus of restricted area acres simultaneously 

meeting target and threshold values. Management 

should be designed to create minimum target and

threshold habitat conditions on project areas where 

there is a deficit of stands simultaneously meeting 

minimum target and threshold habitat conditions 

unless the districtwide or larger landscape analysis 

shows there is a surplus. This table has been modified 

to contain only information pertinent to the Coconino 

NF.

Variable Mixed Conifer 

All 

Restoration 

Units

Mixed Conifer 

Other 

Restoration 

Units

Pine-Oak Target and Threshold 

Habitat

Restricted Area percent 10 percent +15 percent 10 percent

Stand Averages for:

Basal Area 170 150 150

18 inch+ trees/acre 20 20 20

Oak Basal Area NA NA 20

Percent total existing:

12–18 inch 10 10 15

18–24 inch 10 10 15

24+ inch 10 10 15

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 575
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Attempt to mimic natural disturbance patterns by 

incorporating natural variation, such as irregular tree 

spacing and various patch sizes, into management 

prescriptions (Coconino National Forest plan, page 

65-4).

No Change

Maintain all species of native trees in the landscape 

including early seral species (Coconino National 

Forest plan, page 65-4).

No Change

Allow natural canopy gap processes to occur, thus 

producing horizontal variation in stand structure 

(Coconino National Forest plan, page 65-4).

No Change

Emphasize uneven-aged management systems. 

However, both even-aged and uneven-aged systems 

may be used where appropriate to provide variation in 

existing stand structure and species diversity. Existing 

stand conditions will determine which system is 

appropriate (Coconino National Forest plan, page 65-

4).

No Change

Extend rotation ages for even-aged stands to greater 

than 200 years. Silvicultural prescriptions should 

explicitly state when vegetative manipulation will 

cease until rotation age is reached (Coconino National 

Forest plan, page 65-4).

No Change

Save all trees greater than 24 inches d.b.h. In pine-oak 

forests, retain existing large oaks and promote growth 

of additional large oaks (Coconino National Forest 

plan, page 65-4).

No Change

In pine-oak forests, retain existing large oaks and 

promote growth of additional large oaks (Coconino 

National Forest plan, page 65-4).

No Change

Encourage prescribed and prescribed natural fire to 

reduce hazardous fuel accumulation. Thinning from 

below may be desirable or necessary before burning to 

reduce ladder fuels and the risk of crown fire 

(Coconino National Forest plan, page 65-4).

No Change

Retain substantive amounts of key habitat 

components:

• Snags 18 inches in diameter and larger

• Down logs over 12 inches midpoint diameter

• Hardwoods for retention, recruitment, and 

replacement of large hardwoods

No Change

Riparian Areas – No Change

Domestic Livestock Grazing – No Change

Old-Growth – No Change

Other Forest and Woodland Types – No Change

Guidelines for Specific Recovery Units – No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

576 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Monitoring Guidelines

Monitoring and evaluation should be collaboratively 

planned and coordinated with involvement from each 

national forest, U.S. Fish and Wildlife Service Ecological 

Services Field Office, U.S. Fish and Wildlife Service

Regional Office, USFS Regional Office, Rocky 

Mountain Research Station, recovery team, and recovery 

unit working groups.

The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service. 

Population monitoring should be a collaborative effort 

with participation of all appropriate resource agencies. 

(Coconino National Forest plan, page 65-6).

Habitat monitoring of gross habitat changes should be a 

collaborative effort of all appropriate resource agencies. 

(Coconino National Forest plan, page 65-6).

Habitat monitoring of treatment effects (pre- and posttreatment) should be done by the agency conducting the 

treatment. (Coconino National Forest plan, page 65-6).

Prepare an annual monitoring and evaluation report 

covering all levels of monitoring done in the previous 

year. The annual report should be forwarded to the 

regional forester with copies provided to the recovery 

unit working groups, U.S. Fish and Wildlife Service

Ecological Services field offices, and the U.S. Fish and 

Wildlife Service Regional Office (Coconino National 

Forest plan, page 65-6).

Rangewide: Track gross changes in acres of owl habitat 

resulting from natural and human-caused disturbances. 

Acreage changes in vegetation composition, structure, 

and density should be tracked, evaluated, and reported. 

Remote sensing techniques should provide an adequate 

level of accuracy. (Coconino National Forest plan, page 

65-6)

In protected and restricted areas where silvicultural or 

fire abatement treatments are planned, monitor treated 

stands pre- and post-treatment to determine changes and 

trajectories in fuel levels; snag basal areas; live tree basal 

areas; volume of down logs over 12 inches in diameter; 

and basal area of hardwood trees over 10 inches in 

diameter at the root crown (Coconino National Forest 

plan, page 65-6).

Upper Gila Mountain, Basin and Range East, and Basin 

and Range West Recovery Units: Assist the recovery 

team and recovery unit working groups to establish 

sampling units consisting of 19 to 39 square mile 

quadrats randomly allocated to habitat strata. Quadrats 

should be defined based on ecological boundaries such as 

ridge lines and watersheds. Quadrat boundaries should 

not traverse owl territories. Twenty percent of the 

quadrats will be replaced each year at random.

Using the sample quadrats, monitor the number of 

territorial individuals and pairs per quadrat; reproduction; 

apparent survival; recruitment; and age structure. Track 

population density both per quadrat and habitat stratum.

The project will comply with biological opinion 

that has been developed in consultation with the 

U.S. Fish and Wildlife Service.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 577
Appendix B – Forest Plan Amendments

Figure 54. Alternative B amendment 1 Mexican spotted owl PAC treatments 

Consistency with the Mexican Spotted Owl Recovery Plan

A revised Mexican spotted owl recovery plan, issued by the U.S. Fish and Wildlife Service was 

finalized in December of 2012 (USDI FWS 2012). The current (1987) Coconino NF forest plan 

as amended is consistent with the previous Mexican spotted owl recovery plan (USDI FWS 

1995). For this analysis, a forest plan amendment is needed because the current Coconino forest 

plan provides direction from the former Mexican spotted owl Recovery Plan. Since the DEIS was 

released for public comment in 2013, direction from the current 2012 revised recovery plan has 

been incorporated. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

578 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

The need to evolve from managing solely for firewood collection and fire risk abatement is 

reflected in the revised 2012 recovery plan. In the revised plan, the U.S. Fish and Wildlife Service 

states, “Management recommendations are most conservative within PACs, but by no means 

advocate a “hands-off” approach. The recovery team recognizes situations exist where 

management is needed to sustain or enhance desired conditions for the owl, including fire-risk 

reduction, as well as monitoring owl response. Mechanical treatments in some PACs may be 

needed to achieve these objectives; determining which PACs may benefit from mechanical 

treatments requires a landscape analysis to determine where the needs of fire risk reduction and 

habitat enhancement are greatest (USDA FS 2012, page VIII). 

The continued use of the terms (and definitions) of target and threshold habitat (considered future 

nesting and roosting habitat as part of restricted habitat is consistent with Revised Mexican 

spotted owl Recovery Plan’s direction for nesting and roosting in recovery habitat. 

The plan amendment defers Mexican spotted owl occupancy and reproduction monitoring to the 

project’s biological opinion from the U.S. Fish and Wildlife Service. The monitoring plan 

developed in cooperation with U.S. Fish and Wildlife Service is in FEIS, Appendix E. Following 

the current forest plan direction would have resulted in few PACs being treated during the life of 

the project. Current plan direction suspends treatments until monitoring of the initial sample 

shows there are no negative impacts, or negative impacts are mitigated by modifying treatments. 

Following this direction could delay implementation for years, potentially decades’ if changes in 

populations had to be documented before additional treatments were implemented. Following the 

current forest plan direction would have resulted in few PACs being treated with the objective of 

fire-risk reduction or improving condition for the owl during the life of the project. 

The deviation from selecting PACs and monitoring in 10 percent increments is consistent with the 

revised 2012 Mexican spotted owl recovery plan. As noted above, the plan amendment defers 

monitoring to the project’s biological opinion from the U.S. Fish and Wildlife Service. 

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long-term land and resource management.

3. Minor changes in standards and guidelines. 

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

management prescription. 

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 579
Appendix B – Forest Plan Amendments

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

Analysis demonstrated that the proposed amendment is nonsignificant (FSM 1926.51) because 

the actions would not measurably alter the multiple-use goals and objectives for long term land 

and resource management. How actions could potentially affect timing, location, and size, 

relationship to forest goals, objectives, outputs, and management prescriptions was evaluated. 

Timing: In terms of timing, the forest plan has been in place and amended several times since 

1987, and revision efforts are underway. The forest plan incorporated direction (via an 

amendment) from the Forest Service Southwestern Region’s 1996 “Amendment of Forest 

Plans Record of Decision” (USDA FS 1996). The actions allowed via the amendment are 

consistent with existing forest plan direction in that it improves nesting and rooting habitat, 

reduces the risk of loss from fire, and will comply with the site-specific treatment and 

monitoring requirements in the U.S. Fish and Wildlife Service biological opinion. Forest plan 

direction may be amended to incorporate the revised Mexican spotted owl recovery plan 

(USDI FWS 2012) which recognizes that habitat restoration, in addition to the reduction of 

fire risk, is key to improving habitat quality.

Location and Size: The treatment area contains about 35,019 total acres of Mexican spotted 

owl protected habitat, most of which occurs in restoration unit 1. There are 70 PACs (about 

34,183 acres) in the 4FRI treatment area. The remaining protected habitat (836 acres) occurs 

on steep slopes where timber harvest has not occurred in the previous 20 years and is not 

proposed for mechanical treatment. Proposed treatments for steep-slope protected habitat 

consist of prescribed fire only – no mechanical treatments are proposed for this category of 

habitat. There are 187 PACs entirely on or overlapping Coconino National Forest lands. 

The amendment would affect 18 (10 percent) of the 187 Coconino NF PACs. The amendment 

would affect 6,906 acres (20 percent) of PAC habitat in the entire treatment area. Work would 

be accomplished incrementally over a 10-year period. On average, less than 1,000 acres of 

PAC habitat would be treated per year. This is expected to balance the need to reduce the risk 

of crown fire while allowing for monitoring and feedback loops that would allow 

management to be adaptive. 

Relationship to Forest Goals and Objectives: The amendment is consistent with forest plan 

goals for wildlife and fish of managing habitat to maintain viable populations of wildlife and 

fish species and improve habitat for selected species (Coconino National Forest plan, 

replacement page 22-1) and to improve habitat for listed threatened, endangered, or sensitive 

species of plants and animals and other species as they become threatened or endangered 

(Coconino National Forest plan, replacement page 23). The amendment is consistent with 

goals and objectives by protecting conditions and structures used by spotted owls where they 

exist and to set other stands on a trajectory to grow into replacement nest habitat or to provide 

conditions for foraging and dispersal (USDI FWS 2012). 

The amendment removes language that addresses pre- and post-treatment, population, and 

habitat monitoring and replaces it with language that focuses on implementing the 

requirements in the U.S. Fish and Wildlife Service biological opinion for this project. 

Delaying treatment in PACs would leave occupied Mexican spotted owl habitat at risk of loss 

from high-severity fire. Arizona’s two largest fires account for nearly a million and half acres 

of forested land burned since 2002. Both fires included high-severity fire in PAC habitat. 

Other fires in the Upper Gila Recovery Unit have charred additional acres of Mexican spotted 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

580 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

owl protected habitat. Most climate models suggest that the Southwest will experience higher 

temperatures and increased variability in precipitation, which will significantly affect fire 

regimes and forest health (Aumack et al. 2007). 

The U.S. Fish and Wildlife Service urges a deliberate and cautious approach to management 

activities within PACs (USDI FWS 2012). Silvicultural modeling of the proposed treatments 

indicates limited change to forest structure after implementation (FEIS, chapter 3). However, 

the treatments are expected to include increased tree growth rates to reduce the time needed 

for developing large trees (defined as 18 inches d.b.h. and greater in the current recovery plan 

for the Mexican spotted owl), maintaining existing large trees, and decreasing surface fuels 

and increasing crown base height. Combined, this should develop and maintain Mexican 

spotted owl nesting and roosting habitat, a key aspect of the Mexican spotted owl recovery 

plan. 

Forest restoration treatments would be evaluated over time (at least a 10-year period). 

Through formal consultation with U.S. Fish and Wildlife Service, occupancy, reproduction 

and habitat monitoring would be designed and implemented to evaluate the effects of 

prescribed fire and treatments on spotted owl habitat, and to retain or move toward Mexican 

spotted owl desired future conditions, as described in the recovery plan. The details on 

accomplishing the monitoring goals have been developed specifically through coordination 

with the U.S. Fish and Wildlife Service under formal consultation, as described in the 

Endangered Species Act. In this way, work to protect and improve PAC habitat can be 

accomplished in a timely manner while emphasizing monitoring and feedback loops to allow 

management to be adaptive. For these reasons, the amendment as it relates to pre- and posttreatment occupancy, reproduction and habitat monitoring is consistent with forest plan goals 

and objectives.

Designating target or threshold habitat in the project with the best potential would move 

toward desired percentages in restricted (recovery) habitat, consistent with forest plan goals 

and objectives.

Relationship to Management Prescriptions: Table 105 displays the forestwide management 

area acres that would be affected. The amendment would affect about 4,916 acres (1 percent) 

of MA 3 and about 1,773 acres (3 percent) of MA 35. Acres within other management areas 

(MA 4, MA 10, MA 5, MA 9, MA 12, and MA 6) are minor, totaling 217 acres. 

Table 105. Alternative B amendment 1 management area acres (Coconino NF)

Management 

Area

Management Area

Description

Forestwide 

Acres

Proposed 

Amendment 

Acres

Forestwide Acres 

Affected (Percent)

MA 3 Ponderosa Pine Below 

40 Percent Slopes

511,015 4,916 1 

MA 35 Lake Mary Watershed 62,536 1,773 3 

MA 4, 10, 5, 

9, 12, and 6

See chapter 1, table 14 307,011 217 less than 1

The amendment intent is consistent with the management emphasis in MA 3 and MA 35 which 

stresses improving and maintaining the quality of the habitat (MA 3) and moving ponderosa pine 

toward the desired forest structure, including northern goshawk and Mexican spotted owl habitats 

(MA 35). The amendment would not impose requirements on future management of Mexican 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 581
Appendix B – Forest Plan Amendments

spotted owl PACs as the amendment is site specific to this analysis and only addresses current 

conditions within protected habitat. 

Relationship to Outputs: Outputs identified in the forest plan are associated with million board 

feet (MMBF) of sawtimber sales and products (meet demand for timber while reducing conflict 

with other resources), MMBF of firewood sold and free use (provide access to firewood), grazing 

capacity, and permitted livestock use. Due to the minimal acres affected, the amendment would 

not alter outputs on a forestwide basis or change the long-term relationship between levels of 

goods (timber, firewood) and services. 

In comparison to the forest’s total suitable timber lands (626,326 acres), the amendment 

affects about 1 percent of those lands. For this reason, treatments within PACs do not 

measurably increase or decrease timber outputs or firewood availability. Treatment within 

PACs would not affect decisions that have been made through separate analyses on grazing 

capacity or permitted livestock use. There would be no measurable effect to outputs on a 

forestwide basis or the long-term relationship between levels of goods (timber, firewood) and 

services from managing restricted habitat up to 10 percent or deferring the final design of 

treatments and monitoring to the project’s biological opinion.

Amendment 2. Management of Canopy Cover and 

Ponderosa Pine with an Open Reference Condition 

within Goshawk Habitat (Coconino NF)

Background

Canopy cover is defined as “the percentage of a fixed area covered by the crowns of plants 

delimited by a vertical projection of the outermost perimeter of the spread of foliage” (Reynolds 

et al. 1992). Obtaining consistent results has been difficult; even the definition of the term is 

dependent on the method of measurement. To resolve this issue, the Forest Service used the 

Forest Vegetation Simulation (FVS) crown width model as the basis for developing stocking 

densities that would achieve desired canopy cover levels. Figure 55 displays general locations of 

goshawk habitat that is subject to canopy cover requirements in VSS 4 through VSS 6 on the 

forests.

Nonforested areas (interspaces) occur between individual trees, tree clumps, and tree groups. 

These nonforested areas (interspaces) are not equivalent to VSS 1. Whereas VSS 1 may provide 

openings in the short term, this structural stage is expected to regenerate tree cover in the long 

term. Refer to the silviculture report and the implementation plan (appendix D) which provides 

minimum stocking guidelines that have been developed to assure canopy cover requirements are 

met.

Approximately 195,640 acres (61 percent) of the forested areas (within the project area on the 

Coconino NF) have an open reference condition that corresponds to mollic-integrade soils. The 

desired condition is to have a portion of these acres (28,952 acres) managed as a relatively open

forest with trees typically aggregated in small groups within a grass/forb/shrub matrix (Woolsey 

1911, Cooper 1960, White 1985, Pearson 1950, Covington et a1.1997, Abella and Denton 2009). 

See the soils specialist report for detailed information. Figure 56 displays the location of acres 

that would be managed for an open reference condition. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

582 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Amendment Description

In the “Vegetation Management – Landscapes Outside Goshawk Post-fledging Family Areas” and 

“Vegetation Management –Within Post-fledging Family Areas” section of the forest plan, a sitespecific, nonsignificant plan amendment would: (1) add the desired percentage of interspace 

within uneven-aged stands to facilitate restoration, (2) add the interspace distance between tree 

groups, (3) add language clarifying where canopy cover is and is not measured, (4) allow 28,952 

acres to be managed for an open reference condition (which affects canopy cover guidelines for 

VSS 4 through VSS 6 groups and reserve trees), and (5) add a definition to the forest plan 

glossary for the terms interspaces, open reference condition, and stands. Edited or added text is 

shown in bold in the “Proposed New Guideline Language” column in table 106. 

The forest plan directs projects to manage for uneven-aged stand conditions within goshawk 

habitat. Forested groups consist of an interspersion of six vegetation structural stages (VSS 1 to 

VSS 6). For the purposes of this amendment, the following definitions apply: 

• Stands are defined as a contiguous area of trees sufficiently uniform in forest type, 

composition, structure, and age class distribution, growing on a site of sufficiently uniform 

conditions to be a distinguishable unit. Four classification characteristics are generally used to 

distinguish forest stands: biophysical site (soils, aspect, elevation, plant community 

association, climate, etc.), species composition, structure (density, and age (1-aged, 2-aged, 

uneven-aged)), and management emphasis (administrative requirements and local 

management emphasis that will shape structure over time). Based upon Agency guidelines, 

the minimum stand mapping size is 10 acres. 

• Interspaces are defined as the open space between tree groups intended to be managed for 

grass/forb/shrub vegetation during the long term. Interspaces may include scattered single 

trees.

• Open reference condition is defined as forested ponderosa pine areas with mollic-integrade 

soils to be managed as a relatively open forest with trees typically aggregated in small groups 

within a grass/forb/shrub matrix. 

Table 106. Alternative B Amendment 2 Management of Canopy Cover and Ponderosa Pine with an 

Open Reference Condition in Goshawk Habitat (Coconino NF)

Current Coconino NF 

Forest Plan Direction

Proposed New Guideline Language

Landscapes Outside Goshawk Post-fledging Family Areas

No similar direction in forest plan General: Within ponderosa pine stands, manage over 

time for uneven-aged stand conditions composed of 

heterogeneous mosaics of tree groups and single trees, 

with interspaces between tree groups. The size of tree 

groups, as well as sizes and shapes of interspaces, 

should be variable. Over time, the spatial location of 

the tree groups and interspaces may shift within the 

uneven-aged stand. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 583
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New Guideline Language

General: The distribution of vegetation structural 

stages for ponderosa pine, mixed conifer and 

spruce-fir forests is 10 percent grass/forb/shrub 

(VSS 1), 10 percent seedling-sapling (VSS 2), 20 

percent young forest (VSS 3), 20 percent midaged forest (VSS 4), 20 percent mature forest 

(VSS 5), 20 percent old forest (VSS 6). NOTE: 

The specified percentages are a guide and actual 

percentages are expected to vary + or – up to 3 

percent (Coconino NF forest plan, page 65-9).

General: For the areas managed for tree crown 

development, the distribution of vegetation structural 

stages for ponderosa pine, mixed conifer, and spruce-fir 

forests is 10 percent grass/forb/shrub (VSS 1), 10 percent 

seedling-sapling (VSS 2), 20 percent young forest (VSS 

3), 20 percent mid-aged forest (VSS 4), 20 percent mature 

forest (VSS 5), and 20 percent old forest (VSS 6). Note: 

the specified percentages are a guide and actual 

percentages are expected to vary plus or minus up to 3 

percent.

The distribution of VSS, tree density, and tree 

age are a product of site quality in the ecosystem 

management area. Use site quality to guide in the 

distribution of VSS, tree density and tree ages. 

Use site quality to identify and manage dispersal 

post-fledging family areas and nest habitat at 2–

2.5 mile spacing across the landscape (Coconino 

NF forest plan, page 65-9).

No change

Snags are 18" or larger d.b.h. and 30 feet or 

larger in height, downed logs are 12 inches in 

diameter and at least 8 feet long, woody debris is 

3 inches or larger on the forest floor, canopy 

cover is measured with vertical crown projection 

on average across the landscape (Coconino NF 

forest plan, page 65-9).

Snags are 18" or larger d.b.h. and 30 feet or larger in 

height, downed logs are 12 inches in diameter and at least 

8 feet long, woody debris is 3 inches or larger on the forest 

floor, canopy cover as defined by vertical crown 

projection is evaluated within mid-aged to old forest 

vegetation structural stage groups (VSS 4, 5, and 6).

No corresponding forest plan direction Develop and maintain a highly diverse vegetation 

mosaic: 30 to 90 percent of the uneven-aged stand 

should be under ponderosa pine and deciduous tree 

crowns. Within areas managed for an open reference 

condition, 10 to 30 percent of the uneven-aged stand 

should be under ponderosa pine and deciduous tree 

crowns.

No corresponding forest plan direction Tree group spatial distribution may be highly variable 

based on local site and current conditions; the 

interspaces between groups may range from 20 to 200 

feet, but generally between 25 and 100 feet apart from 

drip line to adjacent drip line. This spacing of groups is 

not affected by single trees in the interspace.

No corresponding forest plan direction Each tree group is generally dominated by one 

vegetation structure stage. The spatial arrangement of 

trees, high dispersion of VSS structural stage diversity, 

and interspaces comprise each uneven-aged forest 

stand. Collectively these stands aggregate to unevenaged forest landscapes, similar to natural conditions. 

The order of preferred treatment for woody 

debris is: (1) prescribed burning, (2) lopping and 

scattering, (3) hand piling or machine grapple 

piling, (4) dozer piling (Coconino NF forest plan, 

page 65-9).

No change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

584 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New Guideline Language

Canopy Cover: Canopy cover guidelines apply 

only to mid-aged to old forest structural stages 

(VSS 4, VSS 5, and VSS 6) and not to 

grass/forb/shrub to young forest structural stages 

(VSS 1, VSS 2, and VSS 3) (Coconino NF forest 

plan, page 65-9).

Canopy Cover: Canopy cover guidelines apply only to 

mid-aged to old forest structural stage groups (VSS 4, 

VSS 5, and VSS 6) and not to grass/forb/shrub to young 

forest structural stage groups (VSS 1, VSS 2, and VSS 3) 

or in interspaces, natural meadows, grasslands, or 

other areas not managed for forest cover.

Spruce-Fir: Canopy cover for mid-aged forest 

(VSS 4) should average 1/3 60 percent and 2/3 

40 percent, mature forest (VSS 5) should average 

60+ percent, and old forest (VSS 6) should 

average 60+ percent. Maximum opening size is 1 

acre with a maximum width of 125 feet. Provide 

2 groups of reserve trees per acre with 6 trees per 

group when opening size exceeds 0.5. Leave at 

least 3 snags, 5 downed logs, and 10–15 tons of 

woody debris per acre (Coconino NF forest plan, 

page 65-9).

No Change

Mixed Conifer: Canopy cover for mid-aged 

forest (VSS 4) should average 1/3 60+ percent 

and 2/3 40+ percent, mature forest (VSS 5) 

should average 50+ percent, and old forest (VSS 

6) should average 60+ percent. Maximum 

opening size is up to 4 acres with a maximum 

width of up to 200 feet. Retain 1 group of reserve 

trees per acre of 3–5 trees per group for openings 

greater than 1 acre in size. Leave at least 3 snags, 

5 downed logs, and 10–15 tons of woody debris 

per acre (Coconino NF forest plan, page 65-10).

No Change

Ponderosa Pine: Canopy Cover for mid-aged 

forest (VSS 4) should average 40+ percent, 

mature forest (VSS 5) should average 40+ 

percent, and old forest (VSS 6) should average 

40+ percent. Opening size is up to 4 acres with a 

maximum width of up to 200 feet. One group of 

reserve trees, 3–5 trees per group, will be left if 

the opening is greater than an acre in size. Leave 

at least 2 snags per acre, 3 downed logs per acre, 

and 5–7 tons of woody debris per acre (Coconino 

NF forest plan, page 65-10).

Ponderosa Pine: Canopy cover for mid-aged forest (VSS 

4) should average 40+ percent, mature forest (VSS 5) 

should average 40+ percent, and old forest (VSS 6) should 

average 40+ percent. Opening size is up to 4 acres with a 

maximum width of up to 200 feet. One group of reserve 

trees, three to five trees per group, will be left if the 

created regeneration opening is greater than an acre in 

size. Leave at least two snags per acre, three downed logs 

per acre, and 5 to 7 tons of woody debris per acre.

In acres managed for an open reference condition, 

canopy cover guidelines for VSS 4 through VSS 6 

groups do not apply. One group of reserve trees, with a 

minimum of one to two trees per group will be left if 

the interspace size is greater than an acre in size. 

Interspace size is up to 4 acres. Leave at least two snags 

per acre, three downed logs per acre, and 5 to 7 tons of 

woody debris per acre

Woodland: manage for uneven-age conditions to 

sustain a mosaic of vegetation densities 

(overstory and understory), age classes, and 

species composition well distributed across the 

landscape. Provide for reserve trees, snags, and 

down woody debris (Coconino NF forest plan, 

page 65-10).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 585
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New Guideline Language

Vegetation Management – Within Post-fledging Family Areas

General: Provide for a healthy sustainable forest 

environment for the post-fledging family needs 

of goshawks. The principle difference between 

within the post-fledging family area and outside 

the post-fledging family area is the higher 

canopy cover within the post-fledging family 

area and smaller opening size within the postfledging family area. Vegetative structural stage 

distribution and structural conditions are the 

same within and outside the post-fledging family 

area (Coconino NF forest plan, page 65-10). 

No Change

No similar direction in forest plan Canopy cover is evaluated at the group level within 

mid-aged to old forest structural stages groups (VSS 4, 

VSS 5 and VSS 6) and not within grass/forb/shrub to 

young forest structural stage groups (VSS 1, VSS 2, 

and VSS 3) or in interspaces, natural meadows and 

grasslands, or other areas not managed for forest 

conditions.

Spruce-fir: Canopy Cover for mid-aged forest 

(VSS 4) should average 60+ percent and for 

mature (VSS 5) and old forest (VSS 6) should 

average 70+ percent (Coconino NF forest plan, 

page 65-10).

No Change

Mixed Conifer: Canopy Cover for mid-aged 

(VSS 4) to old forest (VSS 6) should average 

60+ percent.

No Change

Ponderosa Pine: Canopy Cover for mid-aged 

forest (VSS 4) should average 1/3 60+ percent 

and 2/3 50+ percent. Mature (VSS 5) and old 

forest (VSS 6) should average 50+ percent 

(Coconino NF forest plan, page 65-10).

No Change

No corresponding forest plan direction Develop and maintain a highly diverse vegetation 

mosaic: 30 to 90 percent of the uneven-aged stand 

should be under ponderosa pine and deciduous tree 

crowns.

No corresponding forest plan direction Tree group spatial distribution may be highly variable 

based on local site and current conditions; the 

interspaces between groups may range from 20 to 200 

feet, but generally between 25 and 100 feet apart from 

drip line to adjacent drip line. This spacing of groups is 

not affected by single trees in the interspace.

No corresponding forest plan direction Each tree group is generally dominated by one 

vegetation structure stage. The spatial arrangement of 

trees, high dispersion of vegetation structural stage 

diversity, and interspaces comprise each uneven-aged 

forest stand. Collectively these stands aggregate to 

uneven-aged forest landscapes, similar to natural 

conditions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

586 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Proposed New Guideline Language

Forest Plan Direction

Glossary

No corresponding forest plan language Interspaces: The open space between tree groups intended 

to be managed for grass/forb/shrub vegetation during the 

long term. Interspaces may include scattered single trees.

No corresponding forest plan language Open reference condition: Forested ponderosa pine areas 

with mollic-integrade soils to be managed as a relatively 

open forest with trees typically aggregated in small groups 

within a grass/forb/shrub matrix.

No corresponding forest plan language Stands: Contiguous area of trees sufficiently uniform in 

forest type, composition, structure, and age class 

distribution, growing on a site of sufficiently uniform 

conditions to be a distinguishable unit.

Figure 55. Alternative B goshawk habitat subject to canopy cover requirements in VSS 4 and VSS 6 

(Coconino NF) 

Note: Although goshawk habitat on the Kaibab NF is reflected in this figure, only the Coconino NF plan has explicit 

canopy cover requirements in VSS4 to VSS 6 and subject to a plan amendment. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 587
Appendix B – Forest Plan Amendments

Figure 56. Alternative B general locations of savanna and grassland restoration treatments 

(Coconino NF and Kaibab NF*)

*Note: Although Kaibab NF treatments are reflected in this figure, only the Coconino NF is subject to a plan amendment. 

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long term land and resource management.

3. Minor changes in standards and guidelines. 

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

management prescription. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

588 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

Analysis demonstrated that the proposed amendment is nonsignificant (FSM 1926.51) because 

the actions would not measurably alter the multiple-use goals and objectives for long term land 

and resource management and the actions. How actions could potentially affect timing, location 

and size, relationship to forest goals, objectives, outputs, and management prescriptions was 

evaluated.

Timing: In terms of timing, the forest plan has been in place (and amended) since 1987 and plan 

revision efforts are underway.

Location and Size: There is approximately 892, 545 acres of goshawk habitat on the Coconino 

NF (Cote and Green 2014 personal communication email). 

• The canopy cover portion of the amendment would affect 137,313 acres (15 percent) of all 

goshawk habitat on the Coconino N. For this reason, location and size was determined to be 

nonsignificant. 

• Managing 28,952 acres of ponderosa pine for an open reference condition would affect 

approximately 3percent of all suitable goshawk habitats on the forest. 

For these reasons, location and size was determined to not have an important effect on the entire 

forest plan or affect a large portion of the planning area during the planning period. The “planning 

period” (estimated in the forest plan to be 10 to 15 years, page 1) for the 1987 plan has passed 

and a revised forest plan is imminent (by 2015). 

The amendment would facilitate moving over 137,000 acres toward the desired forest structure 

(tree groups and herbaceous openings) that maximizes prey base species habitat and allows for 

reintroduction of fire into the ecosystem; and moves approximately 29,000 acres toward historic 

reference conditions.

Relationship to Forest Goals and Objectives: Alternative B would meet goshawk forest plan 

canopy cover requirements in VSS 4 to 6 in all acres except the 28,952 acres managed for an 

open reference condition. In all acres but the open reference condition acres, actions would move 

toward forest plan desired VSS size class distribution.

The amendment is consistent with forest goals for wildlife and fish of managing habitat to 

maintain viable populations of wildlife and fish species and improve habitat for selected species 

(Coconino National Forest Plan, replacement page 22-1) and to improve habitat for listed 

threatened, endangered, or sensitive species of plants and animals and other species as they 

become threatened or endangered (Coconino National Forest Plan, replacement page 23). 

Relationship to Management Prescriptions: Table 107 displays the acres associated with 

Coconino NF management areas (MAs).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 589
Appendix B – Forest Plan Amendments

Canopy Cover: Approximately 137,313 acres of forestwide management areas would be affected 

by the canopy cover portion of the amendment. This equates to affecting less than 1 percent to 9 

percent of the management areas (see table 107).The amendment is specific to this project and 

would not impose definition and clarification requirements on the future management of canopy 

cover within goshawk habitat. 

Open Reference Condition: Approximately 28,952 acres of forestwide management areas would 

be affected by the open reference condition portion of the amendment. This equates to affecting 

less than 1 percent to 35 percent of the management areas (see table 107). The amendment is 

consistent with the management emphasis of providing for multiple uses that includes wildlife 

habitat (MA 3) and moving ponderosa pine toward desired forest structure, including northern 

goshawk habitats (MA 35). The amendment is specific to this project and would not impose 

requirements on the future management of the 28,952 acres of goshawk landscapes outside of 

goshawk post-fledging areas; however, forest plan revision decisions may change future 

management.

Table 107. Alternative B amendment 2 management area (MA) acres (Coconino NF)

MA MA Description

Forestwide 

Acres

Proposed 

Amendment 

Acres

Forestwide 

Acres 

Affected 

(Percent) 

Canopy Cover

MA 3 Ponderosa pine below 40 percent 

slopes

511,015 92,251 18

MA 35 Lake Mary watershed 62,536 14,334 23

MA 38 West 36,298 12,844 35

MA 6 Unproductive Timber Lands 67,146 4,929 7 

MA 37 Walnut Canyon 20,566 3,656 18

MA 20 Highway 180 corridor 7,608 2,087 27

MA 4 Ponderosa pine and mixed conifer 

greater than 40 percent

46,382 1,612 3 

MA 36 Schultz 21,289 798 4 

*MA 9, 28, 5, 4, 

10, 36, 34, 7, 12, 

18, 15, and 14

See chapter 1, table 14 549,579 4,804 less than 1

Open Reference Condition

MA 3 Ponderosa pine below 40 percent 

slopes

511,015 19,010 4 

MA 35 Lake Mary watershed 62,536 5,840 9 

MA 10 Transition grassland 160,494 1,288 1 

MA 38 West 36,298 1,073 3 

**MA 10, 9, 7, 

12, 34, 28, and 5

See chapter 1, table 14 474,169 1,740 less than 1

*Acres of MAs range from less than 1 to 1,232 and were aggregated into one category.

**Acres of MAs range from less than 1 to 655 and were aggregated into one category.

Relationship to Outputs: Outputs identified in the current forest plan are associated with MMBF 

of sawtimber sales and products (meet demand for timber while reducing conflict with other 

resources), MMBF of firewood sold and free use (provide access to firewood), grazing capacity, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

590 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

and permitted livestock use. No portion of the amendment would affect decisions that have been 

made through separate analyses on grazing capacity or permitted livestock use. 

Timber Suitability: The silviculture analysis evaluated the impact of treatments on timber 

suitability (see silviculture report). Within the analysis area approximately 214,200 acres on the 

Coconino NF were considered in the timber suitability class. Unsuitable lands include areas 

where prescription would preclude timber production such as critical wildlife habitat and 

developed recreation sites as well as areas where irreversible resource damage occur. Table 108

shows total acres for the Coconino NF as reported in the forest plan and used in the timber 

suitability calculation. 

Table 108. Timber suitability calculation for the Coconino NF

Land Category Coconino

Acres

Gross area 1,821,495*

Area not administered by the Forest 

Service (Camp Navajo and private lands) 

NFS lands 1,821,495

Non-forested -325,945

Irreversible resource damage

Adequate restocking not assured

Withdrawn (219.14(a)(4)) -101,401

Subtotal: Not-suitable for timber 

production

-427,346

Lands Tentatively Suitable for Timber 

production

1,394,149

Management prescriptions preclude timber 

production

-593,102

Management requirements cannot be met -154,214

Not cost efficient in meeting timber objectives

Forested Lands not appropriate for timber 

harvest

-13,359

Experimental Forest -6,148

Subtotal: Not appropriate for timber 

production

-766,823

Lands suitable for timber production 627,326

Note: Acreages of NFS lands may vary slightly over time due to factors such 

as resurvey, improved mapping technology, and updates to corporate GIS 

layers. 

*Based on 1987 Coconino Forest Plan (Appendix H)

The Coconino Forest Plan contains the following guidance that directs the management of 

suitable and unsuitable land.

• On forested lands identified as suitable for commercial timber production, design timber 

management activities to integrate considerations for economics, water quality, soils, wildlife 

habitat, recreation opportunities, visual quality, and other values. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 591
Appendix B – Forest Plan Amendments

• Evaluate timber lands adjacent to the Rim within the first decade to determine timber 

suitability.

• Management for the ponderosa pine/mixed conifer stands and the big tooth maple stands is 

the same as MA 3, foreground retention and for areas adjacent to foreground Retention lands. 

See MA 5 for direction for the aspen stands. 

• Manage the timber resource to provide a sustained-yield of forest products through integrated 

stand management. 

• Develop and implement a sustained-yield program for firewood and other miscellaneous 

forest products including posts, poles, Christmas trees, and wildings. Emphasize uneven-aged 

management for timber cutting areas.

Unsuitable lands within the Coconino NF are unproductive timber lands are within the ponderosa 

pine vegetation types. 

• They are unsuitable for timber harvest because they fall in at least one of the following two 

categories.

• They do not meet the minimum standards for productivity which is Site Index 40 and/or 20 

cubic feet per acre per year.

• There is not reasonable assurance that such lands can be adequately restocked as required by 

section 219.27(c)(13) of the planning regulations. 

Timber Suitability Consistency Evaluation by Forest Vegetation Community 

Ponderosa Pine (PP)

The ponderosa pine forest vegetation community generally occurs at elevations ranging from 

5,800 to 9,200 feet and is dominated by ponderosa pine and commonly includes other species 

such as oak, juniper, and pinyon. Species such as aspen, Douglas-fir, white fir, and blue spruce 

may also be present, but occur infrequently as small groups or individual trees. This forest 

vegetation community typically occurs with an understory of grasses and forbs although it 

sometimes includes shrubs.

The majority of the project area is the ponderosa pine plant association. Associations are named 

for the most shade tolerant tree species successfully regenerating, and for an understory species 

(shrub or herb) which is most diagnostic of the site. The ponderosa pine associations within the 

project area include two major sub-types: Ponderosa pine-bunchgrass and ponderosa pineGambel oak. 

Ponderosa pine commonly grows in pure stands and currently is found in even-aged1

 and unevenaged2

 structural conditions across the area. The open park-like stands characteristic of the 

reference conditions for ponderosa pine forests promoted greater faunal diversity and fire 

resilience than the dense stands of today. Ponderosa pine forests within the project are generally 

denser and more continuous than in reference conditions (See Chapter 1) and accumulations of 

forest litter and woody debris are much higher than would have occurred under the historic 

disturbance regime. Lack of fire disturbance has led to increased tree density and fuel loads that 

increase the risk of uncharacteristically intense wildfire and drought-related mortality. When fires 

1 Even-aged – pertaining to a stand composed of a single age class in which the tree ages are within + 20 

percent variability based upon the mature stand age (SAF 1998).

2 Uneven-aged – pertaining to a stand with trees of three or more distinct age classes (SAF 1998).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

592 Coconino and Kaibab National Forests 

 
Appendix B – Forest Plan Amendments

occur under current conditions, they tend to kill a lot of trees, including the large and old trees. 

These trees take longer to replace, moving the forest further from desired conditions, and 

increasing the time it would take to return to desired conditions. There is a high risk of insect 

and/or disease outbreak, which is also a function of increased tree density (see Forest Health 

Section). Within this plant series this project would not change any of the timber suitability acres 

with the proposed treatments.

Gambel Oak within Ponderosa Pine Forest

Gambel oak is frequently the only deciduous tree in otherwise pure ponderosa pine forests in the 

4FRI analysis area, adding diversity to these forests. A portion of the stands have a large enough 

component of Gambel oak to be considered pine-oak habitat for Mexican spotted owl (as 

described in the 1996 forest plan amendment for Mexican spotted owl and Mexican spotted owl

Recovery Plan). Similar to pure ponderosa pine forests, pine-Gambel oak forests have become 

altered since Euro-American settlement in the late 1800s resulting in an overall increase in smalland medium sized Gambel oak stems and a more simplified forest structure (Abella, 2008). Oak 

management strategies within this project includes conservation of all existing large, old oaks, 

maintaining a variety of growth forms and managing for densities similar to the range of 

variability of oak’s evolutionary environment. Within this plant series this project would not 

change any of the timber suitability acres with the proposed treatments.

Amendment 3. Effect Determination 

for Cultural Resources (Coconino NF)

Background

The Coconino NF forest plan as written has some conflicting direction regarding managing 

significant or potentially significant sites. One standard (which would be amended for this 

project) directs management to strive to achieve a “no effect” determination. A second standard 

(which would be deleted for this project) directs management to achieve a “no effect” 

determination in consultation with SHPO and ACHP (36 CFR 800). An amendment is proposed 

to recognize that there could be effects that are not adverse, and that there could be adverse 

effects that may or may not be fully mitigated. Table 109 displays current and proposed forest 

plan language. New or edited text is displayed in bold type.

Amendment Description

The amendment deletes the standard that addresses achieving a “no effect” determination and 

adds the words “or no adverse effect” to the remaining standard. Management strives to achieve a 

“no effect” or “no adverse effect” determination. Edited or added text is shown in bold. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 593
Appendix B – Forest Plan Amendments

Table 109. Alternative B amendment 3 effect determination for cultural resources (Coconino NF)

Current Coconino NF 

Forest Plan Direction

Proposed New Standards 

and Guidelines Language

Cultural Resources

Consult with Native Americans when projects and activities are planned 

in sites or areas of known religious or cultural importance (Coconino NF 

forest plan, page 52).

No Change 

Make boughs and herbaceous plant parts used for Native American 

religious and ceremonial purposes available under conditions and 

procedures that minimize restrictions, consistent with laws, regulations, 

and agreements with tribes. The written authorization to the Hopi Tribe 

for gathering without specific individual permits is an example. This 

authorization does not include such items as firewood removed from the 

forest or Kiva logs, which do require a permit (Coconino NF forest plan, 

page 52).

No Change

The forest complies with the National Historic Preservation Act (NHPA) 

in decisions involving interactions between cultural and other resources. 

Cultural resources are managed in coordination with the State Historic 

Preservation Plan (SHPO). Until evaluated, the minimal level of 

management for all sites is avoidance and protection (Coconino NF 

forest plan, page 52).

No Change

Specific standards and guidelines derived from the settlement agreement 

for the Save the Jemez lawsuit are subject to adjustment, should that 

agreement be modified. In that event an amendment to the forest plan 

will be issued (Coconino NF forest plan, page 52).

No Change

Project undertakings are inventoried for cultural resources and areas of 

Native American religious use. Inventory intensity complies with 

regional policy, and the settlement agreement for the Save The Jemez 

Lawsuit, and is determined in consultation with the State Historic 

Preservation Officer (SHPO). Generally, inventory standards are: One 

hundred percent survey of all projects causing complete surface 

disturbance; when less than 100 percent survey is deemed appropriate, 

the specific sample fraction surveyed is determined in consultation with 

the State Historic Preservation Officer and is generally greater than 10 

percent. Factors determining when sampling is appropriate include 

projects with dispersed or minimal impacts, low expected archaeological 

site density, ground cover, and types of archaeological sites present in 

the area; consultation with appropriate Native American groups; 

consultation with the SHPO, and if necessary, the Advisory Council on 

Historic Preservation (ACHP), before project implementation (Coconino 

NF forest plan, page 52-1).

No Change

Significant, or potentially significant, inventoried sites are managed to 

achieve a “No Effect” determination, in consultation with the SHPO and 

ACHP (36 CFR 800) (Coconino National Forest plan, page 53).

Deleted

Monitoring during and after project implementation is done to document 

site protection and condition (Coconino National Forest plan, page 53).

No Change

Management strives to achieve a “No Effect” determination (Coconino 

National Forest plan, page 53).

Management strives to achieve a 

“no effect” or “no adverse 

effect” determination

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

594 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New Standards 

and Guidelines Language

When sample surveys, rather than 100 percent survey coverage, are done 

for project clearances, survey locations and sample intensity are based on 

areas of greatest project impact, likely locations for cultural resource 

sites based on archaeological experience, land management planning, 

dispersion of sample coverage, certain topographic features specified in 

the Save the Jemez lawsuit settlement agreement, and likely areas based 

on the forest site density predictions (Coconino National Forest plan, 

page 53).

No Change

Identified sites are evaluated for their National Register eligibility when 

they are severely damaged, when they will be impacted by an 

undertaking, or information about the uniqueness, commonness, and 

characteristics of their site class are sufficiently known to make an 

informed decision. Sites for which determinations of eligibility have not 

been made are managed as if they are eligible, unless consultation with 

the SHPO indicates otherwise (Coconino National Forest plan, page 53).

No Change

For each full-time professional cultural resource specialist employed by 

the forest, at least two site nominations, one archaeological district 

nomination, or one thematic or multiple resource nomination will be 

made each year to the National Register of Historic Places. Or, 

alternatively, the forest will coordinate with other forests to prepare a 

joint district, thematic, or multiple resource nomination (Coconino 

National Forest plan, page 53).

No Change

Inventoried sites allocated to management categories, and/or eligible or 

potentially eligible for the NRHP or potentially eligible for the NRHP 

are systematically revisited by regularly scheduled patrols, and by 

cultural resources specialists to assess natural deterioration, vandalism, 

or pilfering. Inspections are made at least biannually of properties that 

have been listed in or nominated to the National Register. Sites most 

susceptible to natural deterioration and/or human disturbance are 

monitored frequently. Rapid natural deterioration, or susceptibility to 

such, requires stabilization, restoration, and/or data recovery. Vandalism 

or pilfering requires protective measures such as signing, remote sensing, 

increased patrolling, investigations, stabilization, restoration, and/or data 

recovery. Specific sites or areas may be closed to off-road driving and 

withdrawn from mineral entry. Law enforcement is planned and 

implemented to minimize resource damage and user conflicts. Signing is 

appropriate to inform and educate the public and minimize direct law 

enforcement activity. Aggressively pursue violations (Coconino National 

Forest plan, page 53).

No Change

Continue to interpret cultural resources through lectures, tours, papers, 

reports, publications, brochures, displays, films, trails, signs, and other 

opportunities (Coconino National Forest plan, page 54).

No Change

Develop a program to complete 100 percent coverage of the forest’s 

cultural resource inventory by 2000 (Coconino National Forest plan, 

page 54).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 595
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New Standards 

and Guidelines Language

The first priorities for cultural resources protection, enhancement, and 

interpretation are those sites that are easily accessible, have major 

interpretive potential, or are in major need of repair. Priority sites for 

signing are the C. Hart Merriam Base Camp, Honanki Cliff Dwellings, 

Elden Pueblo, Sacred Mountain, Palatki Cliff Dwellings, and Clear 

Creek Ruins. Priority sites for repair and stabilization are Honanki Cliff 

Dwellings, Palatki Cliff Dwellings, Sacred Mountain, Clear Creek Cliff 

Dwelling, and General Springs Cabin. Priority sites for developing 

interpretive brochures are Elden Pueblo, Sacred Mountain, Red Tank 

Draw Petroglyphs, Honanki Cliff Dwellings, Palatki Cliff Dwellings, 

and Clear Creek Ruins. Priorities are to:

Survey to clear projects.

Survey to fill in gaps in existing inventory coverage.

Survey areas of known high site densities.

Survey areas that would do the most to answer current archaeological 

questions (Coconino National Forest plan, page 54).

No Change

Computerize cultural resource site information by 1990 (Coconino 

National Forest plan, page 54).

No Change

Maintain a form for tracking compliance of each undertaking with the 

requirements of the National Historic Preservation Act (Coconino 

National Forest plan, page 54).

No Change

Stabilize or repair damaged National Register sites or other sites funded 

by regional priority (Coconino National Forest plan, page 54).

No Change

Continue to develop the Elden Pueblo Interpretive Site and the 

cooperative education program with the Museum of Northern Arizona 

(Coconino National Forest plan, page 54).

No Change

Encourage universities to conduct summer field schools to assist in 

cultural resource survey and excavation work and to provide the forest 

with scientific knowledge (Coconino National Forest plan, page 54).

No Change

Periodically focus media attention on Elden Pueblo and/or other sites to 

educate the public and further volunteer interest in resource 

management. Work with community organizations, businesses, and other 

agencies to promote Arizona Archaeology Week. Feature significant 

finds and significant damage in the media to increase public awareness 

of benefits and problems (Coconino National Forest plan, page 54).

No Change

* Edited and added text is shown in bold.

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long term land and resource management.

3. Minor changes in standards and guidelines. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

596 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

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

management prescription. 

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

The proposed amendment is nonsignificant (FSM 1926.51) because multiple-use goals and 

objectives for long term land and resource management and its actions would not be altered. How 

the amendment could potentially affect timing, location and size, relationship to forest goals, 

objectives, outputs, and management prescriptions was evaluated. 

Timing: In terms of timing, the forest plan has been in place (and amended) since 1987 and plan 

revision efforts are underway.

Location and Size: Amendment 3 is specific to the 351,529 acres of proposed treatments in this 

project. This amendment would affect about 19 percent of the Coconino NF (which totals 

1,821,495 acres).

This would not have an important effect on the entire land management plan or a large portion of 

the planning area. For this reason, location and size was determined to be nonsignificant. 

Relationship to Forest Goals and Objectives: The amendment would not affect attainment of 

forest goals and objectives for cultural resources. Cultural resource sites would be located and 

protected from project activities according to direction in FSM 2360 and 2430 (Coconino NF 

Forest Plan, page 50) and the requirements of 36 CFR 800 including 36 CFR 800.5, which 

provides direction for assessing adverse effects and proposing a finding of no adverse effect. 

Consultation with AZ SHPO would occur as required, and regulation 36 CFR 800 would be 

followed and met.

Relationship to Management Prescriptions: The amendment would apply to all 23 

management areas (MA) as described in the Coconino National Forest plan (pages 46 to 206-113) 

and in chapter 1 of the DEIS. The amendment would not affect management of the management 

areas. All cultural resources are currently managed to minimize impacts and to achieve a “no 

effect” or “no adverse effect” determination whenever possible, in consultation with AZ SHPO, 

the council, and other consulting parties.

Relationship to Outputs: Outputs identified in the forest plan are associated with MMBF of 

sawtimber sales and products (meet demand for timber while reducing conflict with other 

resources), MMBF of firewood sold and free use (provide access to firewood), grazing capacity, 

and permitted livestock use.The amendment would not affect outputs or change the long-term 

relationship between levels of goods (timber, firewood) and services. All cultural resources are 

managed to minimize impacts and to achieve a “no effect” or “no adverse effect” determination 

whenever possible, in consultation with AZ SHPO, the council, and other consulting parties 

regardless of forest plan desired outputs.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 597
Appendix B – Forest Plan Amendments

Alternative C – Coconino National Forest 

Site-Specific Nonsignificant Forest Plan Amendments 

Amendment 1. Mexican Spotted Owl Habitat Management 

(Coconino NF)

Background

How Mexican spotted owl PACs were initially identified for treatment is the same as described 

for alternative B, amendment 1. However, the additional treatments in Mexican spotted owl core 

areas and the change in basal area in target and threshold restricted habitat is a result of comments 

from the U.S. Fish and Wildlife Service on the proposed action (see chapter 2). The amendment 

directly aligns treatments with the revised Mexican spotted owl Recovery Plan (see table C.1 to 

C.3). 

Mechanical Treatment Up to 17.9 inches d.b.h. in Select PACs (6,942 acres)

Mexican spotted owl PAC field reviews, data evaluation, and vegetation simulation modeling 

indicated 18 Mexican spotted owl PACs (approximately 3,378 acres or 10 percent of all PACs 

acres within the treatment area) would move toward recovery plan desired conditions from 

mechanically cutting trees up to 9 inches d.b.h. Treatments up to 9 inches d.b.h. are consistent 

with the forest plan. See the wildlife specialist report “Methodology” section for complete details 

on the habitat evaluation process.

An additional 6,942 acres within 18 PACs would have nesting and roosting habitat benefits from 

cutting trees up to 17.9 inches d.b.h. Mechanical treatments above 9 inches d.b.h. would facilitate 

the removal of ladder and canopy fuels which would reduce the fire risk in the 18 PACs (to the 

extent possible). Increasing the range of the mechanical treatment thresholds up to 18 inches 

d.b.h. within 18 Mexican spotted owl PACs would provide for a higher degree of stand structure 

improvements to nesting and roosting habitat. The proposal addresses comments from the U.S. 

Fish and Wildlife Service and is in alignment with the revised Mexican spotted owl recovery plan 

(USDI FWS 2012). Figure 57 displays the general location of mechanical treatment up to 17.9- 

inch d.b.h., prescribed fire, and areas where no treatment is proposed within Mexican spotted owl

PACs.

Prescribed Fire within 54 PAC Core Areas (About 5,400 acres)

In order to improve habitat conditions outside of the 100-acre core area within 54 PACs, there is a 

need to use prescribed fire within select PAC core areas. Without the use of low-intensity 

prescribed fire within the core, each core area would need to have fire line constructed around it 

to prevent fire from entering the nest site during treatment in the surrounding PAC habitat. 

Depending on site and weather conditions, this could be anything from a 3-foot-wide hand line to 

a dozer line. The number of acres potentially affected from fire line activities within PACs would 

likely range from 0.80 (hand line) acre to 3.2 (dozer) acres. Most fire line would require posttreatment habitat rehabilitation.

Burning in Mexican spotted owl PACs is difficult as there is a need to address the high fuel 

loadings while maintaining many of the habitat elements that contribute to fuel loading. Burning 

has to be conducted in a very short timeframe to avoid the breeding season (i.e., the nonbreeding 

season – September 1 to February 28). Lining 54 core areas greater than or equal to 100 acres 

would be expensive in terms of time, money, and other resource commitments. In many projects, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

598 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

PAC treatments have been eliminated for these reasons. Applying low intensity prescribed 

burning within the 100-acre core areas would eliminate the need for fire line construction and 

would potentially minimize impacts to protected habitat. Figure 58 displays the general location 

of Mexican spotted owl PACs proposed for prescribed burning including where burning would 

occur within core areas.

Manage 6,299 Acres of Mexican spotted owl Restricted Target and 

Threshold Habitat for a Minimum of 110 to 150 Square Feet Basal Area

The development of 6,299 acres of restricted target and threshold habitats would be managed 

toward meeting a 110 to 150 square feet basal area for Mexican spotted owl nest and roost habitat 

as recommended in the revised Mexican spotted owl recovery plan (USDI FWS 2012). It would 

allow more of the uncharacteristic in-growth of mid-aged and mid-sized trees that currently 

dominate the 4FRI landscape to be removed while retaining nesting and roosting habitat 

components. Thinning more of these trees would improve forest health, increasing the ability to 

retain large trees and increase large tree growth rates as described in the revised recovery plan 

(USDI FWS 2012). This would increase forest spatial heterogeneity, improve tree age diversity, 

and benefit prey habitat. Increasing the basal area range would provide opportunities to mimic 

canopy gap processes which produce horizontal variation in stand structure. These changes would 

both increase and retain nesting and roosting structure and increase understory cover. Research 

suggests that small mammal biomass (including voles and mice) drives spotted owl reproductive 

output, and thinning smaller trees would improve subcanopy flight zone, thereby increasing 

Mexican spotted owl foraging effectiveness. Figure 59 displays the extent of the landscape 

analysis conducted to designate Mexican spotted owl restricted habitat for the project. Figure 60

displays the project’s designated Mexican spotted owl restricted habitat. Figure 61 displays 

treatments in Mexican spotted owl target and threshold habitat. 

Incremental Treatments and Monitoring Responses to Spotted Owl Treatments

Monitoring assesses the effectiveness of management actions and provides the adaptive 

framework for more successful management guidelines. Monitoring habitat allows for modeling 

future forest conditions to determine if there will be adequate habitat to support Mexican spotted 

owl populations. Occupancy, reproduction and habitat monitoring and final project design for all 

proposed activities in all Mexican spotted owl habitat was developed in consultation with the U.S. 

Fish and Wildlife Service. Monitoring requirements from the biological opinion have been 

incorporated into the FEIS in appendix E. 

Target and Threshold Restricted Habitat 

Because this project was developed while the former recovery plan was in place, many treatments 

were modeled specifically to meet target and threshold (future nesting and roosting) habitat 

requirements. Definitions of target and threshold habitat would be added since the current forest 

plan refers to “threshold” in terms of values and desired conditions (see Coconino NF forest plan, 

page 65-3.) within restricted habitat and there is no reference to “target” conditions. The 

continued use of the terms (and definitions) of target and threshold habitat (considered future 

nesting and roosting habitat as part of restricted habitat is consistent with Revised Mexican 

spotted owl Recovery Plan’s direction for nesting and roosting in recovery habitat (table C.1 to 

C.3). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 599
Appendix B – Forest Plan Amendments

Amendment Description

Amendment 1 would allow mechanical treatments up to 17.9 inches d.b.h. to improve habitat 

structure (nesting and roosting habitat) in 18 Mexican spotted owl PACs. It would allow low 

intensity prescribed fire within 54 Mexican spotted owl PAC core areas. The amendment would 

remove language that limits PAC treatments in the recovery unit to 10 percent increments and 

language that requires the selection of an equal number of untreated PACs as controls. The 

amendment would remove language referencing monitoring (pre- and post-treatment, population, 

and habitat). Replacement language would defer final project design and monitoring to the U.S. 

Fish and Wildlife Service’ biological opinion specific to Mexican spotted owl for the project (see 

table 110; replacement language is shown in bold throughout the table). 

Definitions of target and threshold habitat would be added since the current forest plan refers to 

“threshold” in terms of values and desired conditions (see Coconino NF forest plan, page 65-3.) 

within restricted habitat, and there is no reference to “target” conditions. In restricted pine-oak 

habitat, it would allow 6,299 acres of restricted target or threshold habitat to be managed for a 

minimum range of 110 to 150 feet of basal area.

Table 110. Alternative C amendment 1 Mexican spotted owl current and proposed forest plan 

language (Coconino NF)

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Mexican spotted owl Standards

No corresponding direction currently exists The project will comply with the biological 

opinion that has been developed in consultation 

with the U.S. Fish and Wildlife Service. 

Provide three levels of habitat management - 

protected, restricted, and other forest and woodland 

types to achieve a diversity of habitat conditions 

across the landscape (Coconino NF forest plan, page 

65).

No Change

Protected areas include delineated protected activity 

centers; mixed conifer and pine-oak forests with 

slopes greater than 40 percent where timber harvest 

has not occurred in the last 20 years; and reserved 

lands which include wilderness, research natural areas, 

wild and scenic rivers, and congressionally recognized 

wilderness study areas (Coconino NF forest plan, page 

65).

No Change

Restricted areas include all mixed-conifer, pine-oak, 

and riparian forests outside of protected areas 

(Coconino NF forest plan, page 65).

No Change

Other forest and woodland types include all ponderosa 

pine, spruce-fir, woodland, and aspen forests outside 

protected and restricted areas (Coconino NF forest 

plan, page 65).

No Change

Survey all potential spotted owl areas including 

protected, restricted, and other forest and woodland 

types within an analysis area plus the area 1/2 mile 

beyond the perimeter of the proposed treatment area

(Coconino NF forest plan, page 65).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

600 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Establish a protected activity center at all Mexican 

spotted owl sites located during surveys and all 

management territories established since 1989 

(Coconino NF forest plan, page 65).

No Change

Allow no timber harvest except for firewood and fire 

risk abatement in established protected activity 

centers. For protected activity centers destroyed by 

fire, windstorm, or other natural disaster, salvage 

timber harvest or declassification may be allowed after 

evaluation on a case-by-case basis in consultation with 

US Fish and Wildlife Service (Coconino NF forest 

plan, page 65).

Allow no timber harvest except for firewood and fire 

risk abatement in established protected activity 

centers except as follows: Allow firewood, fire risk 

abatement, and habitat structure improvement in 

the following established protected activity 

centers: Lake No. 1/Seruchos, Archies, Red Hill, 

Crawdad, Holdup, Bonita Tank, Red Raspberry, 

Bear Seep, Mayflower Tank, Knob, T6 Tank, Iris 

Tank, Frank, Rock Top, Lee Butte, Foxhole, Bar 

M, and Sawmill Spring. For protected activity 

centers destroyed by fire, windstorm, or other natural 

disaster, salvage timber harvest or declassification 

may be allowed after evaluation on a case-by-case 

basis in consultation with the U.S. Fish and Wildlife 

Service.

Allow no timber harvest except for fire risk abatement 

in mixed conifer and pine-oak forests on slopes 

greater than 40 percent where timber harvest has not 

occurred in the last 20 years (Coconino NF forest 

plan, page 65).

No Change

Limit human activity in protected activity centers 

during the breeding season (Coconino NF forest plan, 

page 65).

No Change

In protected and restricted areas, when activities 

conducted in conformance with these standards and 

guidelines may adversely affect other threatened, 

endangered, or sensitive species or may conflict with 

other established recovery plans or conservation 

agreements; consult with U.S. Fish and Wildlife 

Service to resolve the conflict (Coconino NF forest

plan, page 65-1).

No Change

Monitor changes in owl populations and habitat 

needed for delisting (Coconino NF forest plan, page 

65-1).

The project will comply with the biological 

opinion that has been developed in consultation 

with the U.S. Fish and Wildlife Service. 

Guidelines – General – No Change

Guidelines – Protected Areas, Protected Activity Centers

Delineate an area of not less than 600 acres around the 

activity center using boundaries of known habitat 

polygons and/or topographic features. Written 

justification for boundary delineation should be 

provided (Coconino NF forest plan, page 65-1).

No Change 

The protected activity center boundary should enclose 

the best possible owl habitat configured in as compact 

a unit as possible, with the nest or activity center 

located near the center (Coconino NF forest plan, page 

65-1).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 601
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

The activity center is defined as the nest site. In the 

absence of a known nest, the activity center should be 

defined as a roost grove commonly used during 

breeding. In the absence of a known nest or roost, the 

activity center should be defined as the best nesting 

and roosting habitat (Coconino NF forest plan, page 

65-1).

No Change

Protected activity center boundaries should not 

overlap (Coconino NF forest plan, page 65-1).

No Change

Submit protected activity center maps and descriptions 

to the recovery unit working group for comment as 

soon as possible after completion of surveys 

(Coconino NF forest plan, page 65-1).

No Change

Road or trail building in protected activity centers 

should be avoided but maybe permitted on a case-bycase basis for pressing management reasons 

(Coconino NF forest plan, page 65-1).

No Change

Generally allow continuation of the level of recreation 

activities that was occurring prior to listing (Coconino 

NF forest plan, page 65-1).

No Change

Require bird guides to apply for and obtain a special 

use permit. A condition of the permit shall be that they 

obtain a subpermit under the U.S. Fish and Wildlife 

Service Master Endangered Species permit. The 

permit should stipulate the sites, dates, number of 

visits, and maximum group size permissible 

(Coconino NF forest plan, page 65-1). 

No Change

Harvest firewood when it can be done in such a way 

that effects on the owl are minimized. Manage within 

the following limitations to minimize effects on the 

owl (Coconino NF forest plan, page 65-2).

Retain key forest species such as oak.

Retain key habitat components such as snags and large 

downed logs.

Harvest conifers less than 9 inches in diameter only 

within those protected activity centers treated to abate 

fire risk as described below, except for the Clark 

PAC where trees less than 16 inches diameter will 

be harvested. 

Harvest firewood when it can be done in such a way 

that effects on the owl are minimized. Manage within 

the following limitations to minimize effects on the 

owl. 

Retain key forest species such as oak.

Retain key habitat components such as snags and 

large downed logs.

Harvest conifers less than 9 inches in diameter only 

within those protected activity centers treated to abate 

fire risk as described below, except for the Clark 

PAC where trees less than 16 inches diameter will be 

harvested area except as follows:

Harvest conifers up to 17.9 inches diameter within 

the Lake No. 1/Seruchos, Archies, Red Hill, 

Crawdad, Holdup, Bonita Tank, Red Raspberry, 

Bear Seep, Mayflower Tank, Knob, T6 Tank, Iris 

Tank, Frank, Rock Top, Lee Butte, Foxhole, Bar 

M, and Sawmill Spring PACs to abate fire risk 

and improve habitat structure. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

602 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Treat fuel accumulations to abate fire risk. 

–Select for treatment 10 percent of the protected 

activity centers where nest sites are known in each 

recovery unit having high fire risk conditions. Also 

select another 10 percent of the protected activity 

centers where nest sites are known as a paired sample 

to serve as control areas (Coconino NF forest plan, 

page 65-2).

–Designate a 100-acre “no treatment” area around the 

known nest site of each selected protected activity 

center. Habitat in the no treatment area should be as 

similar as possible in structure and composition as that 

found in the activity center.

–Use combinations of thinning trees less than 9 inches 

in diameter (or less than 16 inches in the Clark PAC), 

mechanical fuel treatment and prescribed fire to abate 

fire risk in the remainder of the selected protected 

activity center outside the 100-acre “no treatment” 

area.

Treat fuel accumulations to abate fire risk.

–Designate a 100-acre “no treatment” area around the 

known nest site of each selected protected activity 

center. Habitat in the no treatment area should be as 

similar as possible in structure and composition as 

that found in the activity center.

– Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the Clark 

PAC), mechanical treatment and prescribed fire to 

abate fire risk in the remainder of the selected 

protected activity center outside the 100-acre “no 

treatment” area except as follows:

Use combinations of thinning trees up to 17.9

inches d.b.h. within the Lake No. 1/Seruchos, 

Archies, Red Hill, Holdup, Rock Top, Foxhole, 

Bar M, PACs, Crawdad, Bonita Tank, Red 

Raspberry, Bear Seep, Mayflower Tank, Knob, 

T6 Tank, Iris Tank, Frank, Lee Butte, and 

Sawmill Springs PACs, mechanical fuel treatment 

and prescribed fire to abate fire risk and improve 

habitat structure in the remainder of the selected 

protected activity center outside the 100-acre “no 

treatment” area. Use low intensity prescribed fire 

within 54 select 100-acre core areas to eliminate 

the need for fire line construction. 

– Retain woody debris larger than 12 inches in 

diameter, snags, clumps of broad-leafed woody 

vegetation, and hardwood trees larger than 10 inches 

in diameter at the root collar.

–Use light prescribed burns in nonselected protected 

activity centers on a case-by-case basis. Burning 

should avoid a 100-acre “no treatment” area around 

the activity center except as follows: Use low 

intensity prescribed fire within 54 select 100-acre 

core areas to eliminate the need for fire line 

construction. Large woody debris, snags, clumps of 

broad-leafed woody vegetation should be retained 

and hardwood trees larger than 10 inches diameter at 

the root collar.

– The project will comply with the biological 

opinion that has been developed in consultation 

with the U.S. Fish and Wildlife Service. 

Treat fuel accumulations to abate fire risk. Pre and 

post treatment monitoring should be conducted in all 

protected activity centers treated for fire risk 

abatement. (See monitoring guidelines) (Coconino NF 

forest plan, page 65-2)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 603
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

Steep Slopes (Mixed conifer and pine-oak forests outside protected activity 

centers with slopes greater than 40 percent that have not been logged 

within the past 20 years): No seasonal restrictions apply.

Treat fuel accumulations to abate fire risk.

–Use combinations of thinning trees less than 9 inches 

in diameter, mechanical fuel removal, and prescribed 

fire.

–Retain woody debris larger than 12 inches in 

diameter, snags, clumps of broadleafed woody 

vegetation, and hardwood trees larger than 10 inches 

in diameter at the root collar.

– Pre and post treatment monitoring should occur 

within all steep slopes treated for fire risk abatement. 

(See monitoring guidelines)

Treat fuel accumulations to abate fire risk.

–Use combinations of thinning trees less than 9 

inches in diameter, mechanical fuel removal, and 

prescribed fire.

–Retain woody debris larger than 12 inches in 

diameter, snags, clumps of broadleafed woody 

vegetation, and hardwood trees larger than 10 inches 

in diameter at the root collar.

– The project will comply with the biological 

opinion that has been developed in consultation 

with the U.S. Fish and Wildlife Service. 

Reserved Lands (Wilderness, Research Natural Areas, Wild and Scenic Rivers, and Congressionally 

Recognized Wilderness Study Areas): 

Allow prescribed fire where appropriate – No change.

Restricted Areas (Mixed conifer, pine-oak, and riparian forests)

No corresponding direction Target habitat is a category of restricted habitat 

intended to provide future nesting and roosting 

habitat (see glossary definition for restricted 

habitat). The minimum values identified for the 

forest attributes represent the threshold for 

meeting nesting and roosting conditions (see the 

definition for threshold habitat). They can also be 

targets to be achieved with time and management. 

If less than 10 percent of the restricted habitat in 

ponderosa pine-Gambel oak qualifies as threshold 

habitat, the areas that can eventually achieve all 

threshold conditions simultaneously should be 

identified as target habitat and managed to 

achieve threshold conditions as rapidly as 

possible. Because no known nests or roosts occur 

in restricted habitat, target habitat is considered 

future nesting and roosting habitat.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

604 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline Language

No corresponding direction Threshold habitat is a category of restricted 

habitat intended to provide for future nesting and 

roosting habitat (see definition for restricted 

habitat). A variety of forest structural attributes 

are used to define when nesting and roosting 

habitat is achieved (summarized in table III.B.1 of 

the 1995 recovery plan and table C-2 of the 2012 

recovery plan). Threshold habitat meets or 

exceeds these values. When the minimum values 

identified for the forest attributes are met 

simultaneously, they represent the threshold of 

nesting and roosting conditions. Up to 10 percent 

of restricted habitat in ponderosa pine-Gambel 

oak should be designated as threshold habitat.

Management in threshold habitat cannot lower 

any of the forest attribute values below the nesting 

and roosting threshold unless a landscape analysis 

demonstrates an abundance of this habitat. 

Because no known nests or roosts occur in 

restricted habitat, target habitat is managed as 

future nesting and roosting habitat.

Mixed Conifer and Pine-oak Forests (See glossary 

definition): Manage to ensure a sustained level of owl 

nesting and roosting habitat well distributed across the 

landscape. Create replacement owl nesting and 

roosting habitat where appropriate while providing a 

diversity of stand conditions across the landscape to 

ensure habitat for a diversity of prey species. The 

following table displays the minimum percentage of 

restricted area which should be managed to have 

nesting and roosting characteristics. The minimum 

mixed conifer restricted area includes 10 percent at 

170 square feet basal area and an additional amount of 

area at 150 square feet basal area. The additional area 

of 150 square feet basal area is +10 percent in BR-E 

and +15 percent in all other recovery units. The 

variables are for stand averages and are minimum 

threshold values and must be met simultaneously. In 

project design, no stands simultaneously meeting or 

exceeding the minimum threshold values should be 

reduced below the threshold values unless a districtwide or larger landscape analysis of restricted areas 

shows that there is a surplus of restricted area acres 

simultaneously meeting the threshold values. 

Management should be designed to create minimum 

threshold conditions on project areas where there is a 

deficit of stands simultaneously meeting minimum 

threshold conditions unless the district-wide or larger 

landscape analysis shows there is a surplus. This table 

has been modified to contain only information 

pertinent to the Coconino NF. (Coconino NF forest 

plan, pages 65-3 to 65-5).

Mixed Conifer and Pine-oak Forests (See glossary 

definition): Manage to ensure a sustained level of owl 

nesting and roosting habitat well distributed across 

the landscape. Create replacement owl nesting and 

roosting habitat where appropriate while providing a 

diversity of stand conditions across the landscape to 

ensure habitat for a diversity of prey species. The 

following table displays the minimum percentage of 

restricted area which should be managed to have 

nesting and roosting characteristics. The minimum 

mixed conifer restricted area includes up to 10 

percent at 170 square feet basal area and an 

additional amount of area at 150 square feet basal 

area. The additional area of 150 square feet basal area

is +10 percent in BR-E and +15 percent in all other 

recovery units. In pine-oak, the minimum 

restricted area includes up to 10 percent at 110 to 

150 square feet basal area. The variables are for 

stand averages and are minimum target and

threshold habitat values and must be met 

simultaneously. In project design, no stands 

simultaneously meeting or exceeding the minimum 

target and threshold habitat values should be 

reduced below target and threshold values unless a 

districtwide or larger landscape analysis of restricted 

areas shows that there is a surplus of restricted area 

acres simultaneously meeting target and threshold 

values. Management should be designed to create 

minimum target and threshold habitat conditions on 

project areas where there is a deficit of stands 

simultaneously meeting minimum target and

threshold habitat conditions unless the districtwide 

or larger landscape analysis shows there is a surplus. 

This table has been modified to contain only 

information pertinent to the Coconino NF.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 605
Appendix B – Forest Plan Amendments

Variable Mixed Conifer 

All 

Restoration 

Units

Mixed Conifer 

Other 

Restoration 

Units

Pine-Oak Target and Threshold 

Habitat

Restricted Area percent 10 percent +15 percent 10 percent

Stand Averages for:

Basal Area 170 150 110-150

18 inch+ trees/acre 20 20 20

Oak Basal Area NA NA 20

Percent total existing:

12–18 inch 10 10 15

18–24 inch 10 10 15

24+ inch 10 10 15

Proposed New Standard or Guideline 

Current Coconino NF Forest Plan Direction Language

Attempt to mimic natural disturbance patterns by No Change

incorporating natural variation, such as irregular tree 

spacing and various patch sizes, into management 

prescriptions (Coconino National Forest plan, page 65-4).

Maintain all species of native trees in the landscape No Change

including early seral species (Coconino National Forest 

plan, page 65-4).

Allow natural canopy gap processes to occur, thus No Change

producing horizontal variation in stand structure 

(Coconino National Forest plan, page 65-4).

Emphasize uneven-aged management systems. However, No Change

both even-aged and uneven-aged systems may be used 

where appropriate to provide variation in existing stand 

structure and species diversity. Existing stand conditions 

will determine which system is appropriate (Coconino 

National Forest plan, page 65-4).

Extend rotation ages for even-aged stands to greater than No Change

200 years. Silvicultural prescriptions should explicitly 

state when vegetative manipulation will cease until 

rotation age is reached (Coconino National Forest plan, 

page 65-4).

Save all trees greater than 24 inches d.b.h. In pine-oak No Change

forests, retain existing large oaks and promote growth of 

additional large oaks (Coconino National Forest plan, 

page 65-4).

In pine-oak forests, retain existing large oaks and promote No Change

growth of additional large oaks (Coconino National 

Forest plan, page 65-4).

Encourage prescribed and prescribed natural fire to No Change

reduce hazardous fuel accumulation. Thinning from 

below may be desirable or necessary before burning to 

reduce ladder fuels and the risk of crown fire (Coconino 

National Forest plan, page 65-4).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

606 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction

Proposed New Standard or Guideline 

Language

Retain substantive amounts of key habitat components:

• Snags 18 inches in diameter and larger

• Down logs over 12 inches midpoint diameter

• Hardwoods for retention, recruitment, and replacement 

of large hardwoods

No Change

Riparian Areas – No Change

Domestic Livestock Grazing – No Change

Old-Growth – No Change

Other Forest and Woodland Types – No Change

Guidelines for Specific Recovery Units – No Change

Monitoring Guidelines

Monitoring and evaluation should be collaboratively 

planned and coordinated with involvement from each 

national forest, U.S. Fish and Wildlife Service Ecological 

Services Field Office, U.S. Fish and Wildlife Service

Regional Office, FS Regional Office, Rocky Mountain 

Research Station, recovery team, and recovery unit 

working groups.

The project will comply with biological opinion 

that has been developed in consultation with 

the U.S. Fish and Wildlife Service. 

Population monitoring should be a collaborative effort 

with participation of all appropriate resource agencies. 

(Coconino National Forest plan, page 65-6).

Habitat monitoring of gross habitat changes should be a 

collaborative effort of all appropriate resource agencies. 

(Coconino National Forest plan, page 65-6).

Habitat monitoring of treatment effects (pre- and posttreatment) should be done by the agency conducting the 

treatment. (Coconino National Forest plan, page 65-6).

Prepare an annual monitoring and evaluation report 

covering all levels of monitoring done in the previous 

year. The annual report should be forwarded to the 

regional forester with copies provided to the recovery unit 

working groups, U.S. Fish and Wildlife Service

Ecological Services field offices, and the U.S. Fish and 

Wildlife Service Regional Office (Coconino National 

Forest plan, page 65-6).

Rangewide: Track gross changes in acres of owl habitat 

resulting from natural and human-caused disturbances. 

Acreage changes in vegetation composition, structure, 

and density should be tracked, evaluated, and reported. 

Remote sensing techniques should provide an adequate 

level of accuracy. (Coconino National Forest plan, page 

65-6)

In protected and restricted areas where silvicultural or fire 

abatement treatments are planned, monitor treated stands 

pre- and post-treatment to determine changes and 

trajectories in fuel levels; snag basal areas; live tree basal 

areas; volume of down logs over 12 inches in diameter; 

and basal area of hardwood trees over 10 inches in 

diameter at the root crown (Coconino National Forest 

plan, page 65-6).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 607
Appendix B – Forest Plan Amendments

Current Coconino NF Forest Plan Direction

Proposed New Standard or Guideline 

Language

Upper Gila Mountain, Basin and Range East, and Basin 

and Range West Recovery Units: Assist the recovery 

team and recovery unit working groups to establish 

sampling units consisting of 19 to 39 square mile quadrats 

randomly allocated to habitat strata. Quadrats should be 

defined based on ecological boundaries such as ridge 

lines and watersheds. Quadrat boundaries should not 

traverse owl territories. Twenty percent of the quadrats 

will be replaced each year at random.

Using the sample quadrats, monitor the number of 

territorial individuals and pairs per quadrat; reproduction; 

apparent survival; recruitment; and age structure. Track 

population density both per quadrat and habitat stratum.

The project will comply with biological opinion 

that has been developed in consultation with 

the U.S. Fish and Wildlife Service.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

608 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Figure 57. Alternative C amendment 1 proposed activities in Mexican spotted owl PACs in relation to 

no treatment areas (Coconino NF) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 609
Appendix B – Forest Plan Amendments

Figure 58. Alternative C amendment 1 prescribed fire within and outside of Mexican spotted owl core 

areas 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

610 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Figure 59. Alternative C amendment 1 landscape target and threshold analysis 

Note: Although the Kaibab NF is displayed on the figure, no plan amendments are needed/proposed. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 611
Appendix B – Forest Plan Amendments

Figure 60. Alternative C amendment 1 general locations of Mexican spotted owl target and threshold 

habitat managed from 110 to 150 square feet basal area (Coconino NF) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

612 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Figure 61. Alternative C amendment 1 locations of Mexican spotted owl target and threshold 

treatments

Note: Although the Kaibab NF is displayed on the figure, no plan amendments are needed/proposed. 

Consistency with the Revised Mexican spotted owl Recovery Plan 

The need to evolve from managing solely for firewood collection and fire risk abatement is 

reflected in the revised 2012 recovery plan. In the revised plan, the U.S. Fish and Wildlife Service 

states, “Management recommendations are most conservative within PACs, but by no means 

advocate a “hands-off” approach. The recovery team recognizes situations exist where 

management is needed to sustain or enhance desired conditions for the owl, including fire-risk 

reduction, as well as monitoring owl response. Mechanical treatments in some PACs may be 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 613
Appendix B – Forest Plan Amendments

needed to achieve these objectives; determining which PACs may benefit from mechanical 

treatments requires a landscape analysis to determine where the needs of fire risk reduction and 

habitat enhancement are greatest. PACs are the only form of protected habitat included in this 

revised Plan” (USDA FS 2012, page VIII). Treatments that would improve habitat by treating up 

to 17.9 inches d.b.h. is consistent with direction for retaining large trees in the revised Mexican 

spotted owl recovery plan (page 268 and table C.1-C.3 on pages 274 to 278). 

By definition, PAC habitat and especially core areas have high fuel loading and the 

uncharacteristic accumulation of ground fuels puts them at further risk. Reducing fuels to reduce 

the risk of high-severity fire in these important habitats would contribute toward conservation of 

this threatened species. The amendment (allowing low intensity prescribed burning within the 

100-acre core area) would eliminate the need for hand line and/or dozer line construction, allow 

for the maximum number of surrounding PAC acres to be treated with prescribed fire, and would 

potentially minimize up to 560 acres of ground disturbance to PAC habitat. Reducing fire risk in 

core areas is consistent with the direction in the Mexican spotted owl recovery plan, “Planned 

ignitions (prescribed fire) and unplanned ignitions (wildland fire) should be allowed to enter 

cores only if they are expected to burn with low fire severity and intensity. Fire lines, check-lines, 

backfiring, and similar fire management tactics can be used to reduce fire effects and to maintain 

key habitat elements (e.g., hardwoods, large downed logs, snags, and large trees)” (Revised 

Mexican spotted owl Recovery Plan, page 263). 

Managing for 110 to 150 square feet basal area is consistent with the minimum desired conditions 

for pine-oak forests managed for Recovery nesting/roosting habitat (page 278, table C.3). The 

continued use of the terms (and definitions) of target and threshold habitat (considered future 

nesting and roosting habitat as part of restricted habitat is consistent with Revised Mexican 

spotted owl Recovery Plan’s direction for nesting and roosting in recovery habitat (see page 274, 

table C1). 

The plan amendment defers monitoring to the project’s biological opinion from the U.S. Fish and 

Wildlife Service. Following the current forest plan direction would have resulted in few PACs 

being treated during the life of the project. Current plan direction suspends treatments until 

monitoring of the initial sample shows there are no negative impacts, or negative impacts are 

mitigated by modifying treatments. Following this direction could delay implementation for 

years, potentially decades’ if changes in populations had to be documented before additional 

treatments were implemented. Following the current forest plan direction would have resulted in 

few PACs being treated with the objective of fire-risk reduction or improving condition for the 

owl during the life of the project. 

The deviation from selecting PACs and monitoring in 10 percent increments is consistent with the 

revised 2012 Mexican spotted owl recovery plan which states mechanical treatments can be 

conducted in up to 20 percent of the total non-core PAC area within each ecosystem management 

unit (treatments can exceed 20 percent of the non-core acreage a single PAC (page 274, table 

C.1). As noted above, the plan amendment defers monitoring to the project’s biological opinion 

from the U.S. Fish and Wildlife Service. This amendment meets the intent of the revised (2012) 

recovery plan by reducing the potential for creating excessively fragmented habitat and managing 

stands based on their capability to attain desired stand conditions. This amendment does not affect 

habitat designated in previous projects or in mixed-conifer habitat. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

614 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long term land and resource management. 

3. Minor changes in standards and guidelines. 

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

management prescription. 

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

Analysis demonstrated that the proposed amendment is nonsignificant (FSM 1926.51) because 

the actions would not measurably alter the multiple-use goals and objectives for long term land 

and resource management and the actions. How actions could potentially affect timing, location 

and size, relationship to forest goals, objectives, outputs, and management prescriptions was 

evaluated.

Timing: In terms of timing, the forest plan has been in place and amended several times since 

1987, and revision efforts are underway. The forest plan incorporated direction (via an 

amendment) from the Forest Service Southwestern Region’s 1996 “Amendment of Forest Plans 

Record of Decision” (USDA FS 1996). ). The actions allowed via the amendment are consistent 

with existing forest plan direction in that it improves nesting and rooting habitat, reduces the risk 

of loss from fire, and will comply with the site-specific treatment and monitoring requirements in 

the U.S. Fish and Wildlife Service biological opinion. Forest plan direction may be amended to 

incorporate the revised Mexican spotted owl recovery plan (USDI FWS 2012) which recognizes 

that habitat restoration, in addition to the reduction of fire risk, is key to improving habitat 

quality. 

Location and Size: The treatment area contains about 35,019 total acres of Mexican spotted owl 

protected habitat, most of which occurs in restoration unit 1. There are 70 PACs (about 34,183 

acres) in the 4FRI treatment area. The remaining protected habitat (836 acres) occurs on steep 

slopes where timber harvest has not occurred in the previous 20 years and is not proposed for 

mechanical treatment. Proposed treatments for steep-slope protected habitat consist of prescribed 

fire only – no mechanical treatments are proposed for this category of habitat. There are 187 

PACs entirely on or overlapping Coconino National Forest lands. 

Mechanical treatment would affect 18 (10 percent) of the 187 Coconino NF PACs and 6,942 acres 

(20 percent) of PAC habitat in the entire treatment area. Prescribed burning within 54 core areas 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 615
Appendix B – Forest Plan Amendments

would potentially result in 5,400 acres of ground disturbance (100 acres per PAC). About 29 

percent of all Coconino NF PAC core areas would be affected by the amendment. 

Changing the minimum basal area value in restricted habitat would only apply to target and 

threshold acres (those restricted acres being managed for nesting/roosting habitat as defined in the 

forest plan). About 6,299 acres (8 percent) of restricted target or threshold habitat would be 

affected by using a basal area range of 110 to 150 within the treatment area. This equates to 

affecting about 13 percent of the total (48,292 acres) Mexican spotted owl restricted habitat on 

the Coconino NF’s portion of the project area. Note: There are 8,388 acres of restricted habitat 

total across both forests that would be managed for 110-150 square feet basal area. 

Work would be accomplished incrementally over a 10-year period. On average, less than 1,000 

acres of PAC habitat would be treated per year. This is expected to balance the need to reduce the 

risk of crown fire while allowing for monitoring and feedback loops that would allow 

management to be adaptive. 

Relationship to Forest Goals and Objectives: The amendment is consistent with forest plan 

goals for wildlife and fish of managing habitat to maintain viable populations of wildlife and fish 

species, and improving habitat for selected species (Coconino National Forest plan, replacement 

page 22-1). It is consistent with the goal to improve habitat for listed threatened, endangered, or 

sensitive species of plants and animals, and other species as they become threatened or 

endangered (Coconino National Forest plan, replacement page 23). The amendment is consistent 

with goals and objectives by protecting conditions and structures used by Mexican spotted owls 

where they exist and to set other stands on a trajectory to grow into replacement nest habitat or to 

provide conditions for foraging and dispersal (USDI FWS 1995, 2012).

Relationship to Management Prescriptions: Mechanical thinning up to 17.9 inches d.b.h. in 18 

Mexican spotted owl PACs would affect less than 1 to 3 percent of the forestwide management 

area acres (table 111). Using prescribed fire within 54 Mexican spotted owl PAC core areas 

(about 5,400 acres) would affect between 1 and 5 percent of the forestwide management area

acres. Managing 6,299 acres of restricted habitat to a range of 110 to 150 square feet basal area

would affect less than 1 percent to 3 percent of the forestwide management areas. The 

amendment intent is consistent with the management emphasis of providing for multiple uses that 

includes wildlife habitat and meeting Mexican spotted owl standards and guidelines which 

emphasize improving and maintaining the quality of the habitat (MA 3) and moving ponderosa 

pine toward desired forest structure, including northern goshawk and Mexican spotted owl 

habitats (MA 35). 

Relationship to Outputs: Outputs identified in the forest plan are associated with MMBF of 

sawtimber sales and products (meet demand for timber while reducing conflict with other 

resources), MMBF of firewood sold and free use (provide access to firewood), grazing capacity, 

and permitted livestock use. The amendment would not affect outputs or change the long-term 

relationship between levels of goods (timber, firewood) and services. Due to the minimal acres 

affected, the amendment would not alter outputs on a forestwide basis or change the long-term 

relationship between levels of goods (timber, firewood) and services. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

616 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

In comparison the forest’s total suitable timber lands (626,326 acres), the amendment would 

affect about 1 percent of those lands. For this reason, mechanical treatment within PACs and the 

minimal (6,299) acres treated in restricted habitat do not measurably increase or decrease timber 

outputs or firewood availability. There would be no measurable effect to outputs on a forestwide 

basis or the long-term relationship between levels of goods (timber, firewood) and services from 

using prescribed fire in 54 core areas, managing restricted habitat up to 10 percent, managing 

restricted habitat for a basal area of 110 to 150 square feet, or deferring the final design of 

treatments and monitoring to the project’s biological opinion. The amendment would not affect 

decisions that have been made through separate analyses on grazing capacity or permitted 

livestock use.

Table 111. Alternative C Mexican spotted owl amendment 1 management area (MA) acres

MA MA Description

Forestwide 

Acres

Proposed Amendment 

Acres

Forestwide Acres 

Affected (Percent)

Mechanical Treatment Up to 17.9 inches d.b.h.

MA 3 Ponderosa pine below 

40 percent slopes

511,015 4,941 1 

MA 35 Lake Mary watershed 62,536 1,782 3 

MA 4, 10, 5, 

9, 12, and 6

See chapter 1, table 14 307,011 218 less than 1

Prescribed Fire within 54 Mexican Spotted Owl PAC Core Areas

MA 3 Ponderosa pine below 

40 percent slopes

511,015 3,600 1 

MA 35 Lake Mary watershed 62,536 1,614 3 

MA 5 Aspen 3,450 186 5 

110 to 150 Square Feet Basal Area in Mexican Spotted Owl Restricted Habitat

MA 3 Ponderosa pine below 

40 percent slopes

511,015 3,957 1 

MA 35 Lake Mary watershed 62,536 1,903 3 

MA 37 and 

MA 38

Walnut Canyon and 

West 

20,566 to 36,298 312 less than 1

Various MAs Various 127

Amendment 2. Management of Canopy Cover and 

Ponderosa Pine with an Open Reference Condition 

within Goshawk Habitat (Coconino NF)

Background

Canopy cover is defined as “the percentage of a fixed area covered by the crowns of plants 

delimited by a vertical projection of the outermost perimeter of the spread of foliage” (Reynolds 

et al. 1992). Obtaining consistent results has been difficult; even the definition of the term is 

dependent on the method of measurement. To resolve this issue, the Forest Service used the 

Forest Vegetation Simulation (FVS) crown width model as the basis for developing stocking 

densities that would achieve desired canopy cover levels. Figure 62 displays general locations of 

goshawk habitat that is subject to canopy cover requirements in VSS 4 through VSS 6 on the 

forests.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 617
Appendix B – Forest Plan Amendments

Nonforested areas (interspaces) occur between individual trees, tree clumps, and tree groups. 

These nonforested areas (interspaces) are not equivalent to VSS 1. Whereas VSS 1 may provide 

openings in the short term, this structural stage is expected to regenerate tree cover in the long 

term. Refer to the silviculture report and the implementation plan (appendix D) which provides 

minimum stocking guidelines that have been developed to assure canopy cover requirements are 

met.

Approximately 195,640 acres (61 percent) of the forested areas (within the project area on the 

Coconino NF) have an open reference condition that corresponds to mollic-integrade soils. The 

desired condition is to have a portion of these acres (28,653 acres) managed as a relatively open 

forest with trees typically aggregated in small groups within a grass/forb/shrub matrix (Woolsey 

1911, Cooper 1960, White 1985, Pearson 1950, Covington et a1.1997, Abella and Denton 2009). 

See the soils specialist report for detailed information. 

Amendment Description

In the “Vegetation Management – Landscapes Outside Goshawk Post-fledging Family Areas” and 

“Vegetation Management –Within Post-fledging Family Areas” section of the forest plan, a sitespecific, nonsignificant plan amendment would: (1) add the desired percentage of interspace 

within uneven-aged stands to facilitate restoration, (2) add the interspace distance between tree 

groups, (3) add language clarifying where canopy cover is and is not measured, (4) allow 28,653 

acres to be managed for an open reference condition which affects canopy cover guidelines for 

VSS 4 through VSS 6 groups and reserve trees, and (5) add a definition to the forest plan glossary 

for the terms interspaces, open reference condition, and stands. 

The forest plan directs projects to manage for uneven-aged stand conditions within goshawk 

habitat. Forested groups consist of an interspersion of six vegetation structural stages (VSS 1 to 

VSS 6). For the purposes of this amendment, the following definitions apply: 

• Stands are defined as a contiguous area of trees sufficiently uniform in forest type, 

composition, structure, and age class distribution, growing on a site of sufficiently uniform 

conditions to be a distinguishable unit. Four classification characteristics are generally used to 

distinguish forest stands: biophysical site (soils, aspect, elevation, plant community 

association, climate, etc.), species composition, structure (density, and age (1-aged, 2-aged, 

uneven-aged)), and management emphasis (administrative requirements and local 

management emphasis that will shape structure over time). Based upon Agency guidelines, 

the minimum stand mapping size is 10 acres. 

• Interspaces are defined as the open space between tree groups intended to be managed for 

grass/forb/shrub vegetation during the long term. Interspaces may include scattered single 

trees.

• Open reference condition is defined as forested ponderosa pine areas with mollic-integrade 

soils to be managed as a relatively open forest with trees typically aggregated in small groups 

within a grass/forb/shrub matrix. 

Edited or added verbiage is shown in bold in table 112. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

618 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Table 112. Alternative C amendment 2 management of canopy cover and ponderosa pine with an 

open reference condition in goshawk habitat (Coconino NF)

Current Coconino NF 

Forest Plan Direction Proposed New Guideline Language

Landscapes Outside of Goshawk Post-fledging Areas

No similar direction in forest plan General: Within ponderosa pine stands, manage over time 

for uneven-aged stand conditions composed of 

heterogeneous mosaics of tree groups and single trees, 

with interspaces between tree groups. The size of tree 

groups, as well as sizes and shapes of interspaces, should 

be variable. Over time, the spatial location of the tree 

groups and interspaces may shift within the uneven-aged 

stand.

General: The distribution of vegetation 

structural stages for ponderosa pine, mixed 

conifer and spruce-fir forests is 10 percent 

grass/forb/shrub (VSS 1), 10 percent seedlingsapling (VSS 2), 20 percent young forest 

(VSS 3), 20 percent mid-aged forest (VSS 4), 

20 percent mature forest (VSS 5), 20 percent 

old forest (VSS 6). NOTE: The specified 

percentages are a guide and actual percentages 

are expected to vary + or – up to 3 percent 

(Coconino NF forest plan, page 65-9). 

General: For the areas managed for tree crown 

development, the distribution of vegetation structural stages 

for ponderosa pine, mixed conifer and spruce-fir forests is 10 

percent grass/forb/shrub (VSS 1), 10 percent seedling-sapling 

(VSS 2), 20 percent young forest (VSS 3), 20 percent midaged forest (VSS 4), 20 percent mature forest (VSS 5), and 20 

percent old forest (VSS 6). Note: the specified percentages 

are a guide, and actual percentages are expected to vary plus 

or minus up to 3 percent.

The distribution of VSS, tree density, and tree

age are a product of site quality in the 

ecosystem management area. Use site quality 

to guide in the distribution of VSS, tree 

density, and tree ages. Use site quality to 

identify and manage dispersal post-fledging 

family areas and nest habitat at 2 - 2.5 mile 

spacing across the landscape (Coconino NF 

forest plan, page 65-9).

No Change

Snags are 18" or larger d.b.h. and 30 feet or 

larger in height, downed logs are 12 inches in 

diameter and at least 8 feet long, woody 

debris is 3 inches or larger on the forest floor, 

canopy cover is measured with vertical crown 

projection on average across the landscape 

(Coconino NF forest plan, page 65-9).

Snags are 18" or larger d.b.h. and 30 feet or larger in height, 

downed logs are 12 inches in diameter and at least 8 feet 

long, woody debris is 3 inches or larger on the forest floor, 

canopy cover as defined by vertical crown projection is 

evaluated within mid-aged to old forest vegetation 

structural stage groups (VSS 4, 5, and 6).

No corresponding forest plan direction Develop and maintain a highly diverse vegetation mosaic: 

30 to 90 percent of the uneven-aged stand should be under 

ponderosa pine and deciduous tree crowns. Within areas 

managed for an open reference condition, 10 to 30 percent 

of the uneven-aged stand should be under ponderosa pine 

and deciduous tree crowns.

No corresponding forest plan direction Tree group spatial distribution may be highly variable 

based on local site and current conditions; the interspaces 

between groups may range from 20 to 200 feet, but 

generally between 25 and 100 feet apart from drip line to 

adjacent drip line. This spacing of groups is not affected 

by single trees in the interspace.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 619
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction Proposed New Guideline Language

No corresponding forest plan direction Each tree group is generally dominated by one vegetation 

structure stage. The spatial arrangement of trees, high 

dispersion of vegetation structural stage diversity, and 

interspaces comprise each uneven-aged forest stand. 

Collectively these stands aggregate to uneven-aged forest 

landscapes, similar to natural conditions.

The order of preferred treatment for woody 

debris is: (1) prescribed burning, (2) lopping 

and scattering, (3) hand piling or machine 

grapple piling, (4) dozer piling (Coconino NF 

forest plan, page 65-9).

No Change

Canopy Cover: Canopy cover guidelines 

apply only to mid-aged to old forest structural 

stages (VSS 4, VSS 5, and VSS 6) and not to 

grass/forb/shrub to young forest structural 

stages (VSS 1, VSS 2, and VSS 3) (Coconino 

NF forest plan, page 65-9).

Canopy Cover: Canopy cover guidelines apply only to midaged to old forest structural stage groups (VSS 4, VSS 5, and 

VSS 6) and not to grass/forb/shrub to young forest structural 

stage groups (VSS 1, VSS 2, and VSS 3) or in interspaces, 

natural meadows, grasslands, or other areas not managed 

for forest cover. 

No corresponding forest plan direction Canopy cover is evaluated at the group level within midaged to old forest structural stages groups (VSS 4, VSS 5 

and VSS 6) and not within grass/forb/shrub to young 

forest structural stage groups (VSS 1, VSS 2, and VSS 3) 

or in interspaces, natural meadows and grasslands, or 

other areas not managed for forest conditions.

Spruce-Fir: Canopy cover for mid-aged forest 

(VSS 4) should average 1/3 60 percent and 

2/3 40 percent, mature forest (VSS 5) should 

average 60+ percent, and old forest (VSS 6) 

should average 60+ percent. Maximum 

opening size is 1 acre with a maximum width 

of 125 feet. Provide 2 groups of reserve trees 

per acre with 6 trees per group when opening 

size exceeds 0.5. Leave at least 3 snags, 5 

downed logs, and 10–15 tons of woody debris 

per acre (Coconino NF forest plan, page 65-

9).

No Change

Mixed Conifer: Canopy cover for mid-aged 

forest (VSS 4) should average 1/3 60+ percent 

and 2/3 40+ percent, mature forest (VSS 5) 

should average 50+ percent, and old forest 

(VSS 6) should average 60+ percent. 

Maximum opening size is up to 4 acres with a 

maximum width of up to 200 feet. Retain 1 

group of reserve trees per acre of 3–5 trees per 

group for openings greater than 1 acre in size. 

Leave at least 3 snags, 5 downed logs, and 

10–15 tons of woody debris per acre 

(Coconino NF forest plan, page 65-10).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

620 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction Proposed New Guideline Language

Ponderosa Pine: Canopy Cover for mid-aged 

forest (VSS 4) should average 40+ percent, 

mature forest (VSS 5) should average 40+ 

percent, and old forest (VSS 6) should 

average 40+ percent. Opening size is up to 4 

acres with a maximum width of up to 200 

feet. One group of reserve trees, 3–5 trees per 

group, will be left if the opening is greater 

than an acre in size. Leave at least 2 snags per 

acre, 3 downed logs per acre, and 5–7 tons of 

woody debris per acre (Coconino NF forest 

plan, page 65-10).

Ponderosa Pine: Canopy cover for mid-aged forest (VSS 4) 

should average 40+ percent, mature forest (VSS 5) should 

average 40+ percent, and old forest (VSS 6) should average 

40+ percent. Opening size is up to 4 acres with a maximum 

width of up to 200 feet. One group of reserve trees, three to 

five trees per group, will be left if the created regeneration

opening is greater than an acre in size. Leave at least two 

snags per acre, three downed logs per acre, and 5–7 tons of 

woody debris per acre.

In acres managed for an open reference condition, canopy 

cover guidelines for VSS 4 through VSS 6 groups do not 

apply. One group of reserve trees, with a minimum of one 

to two trees per group will be left if the interspace size is 

greater than an acre in size. Interspace size is up to 4 

acres. Leave at least two snags per acre, three downed logs 

per acre, and 5–7 tons of woody debris per acre

Woodland: manage for uneven age conditions 

to sustain a mosaic of vegetation densities 

(overstory and understory), age classes, and 

species composition well distributed across 

the landscape. Provide for reserve trees, 

snags, and down woody debris (Coconino NF 

forest plan, page 65-10). 

No Change

Vegetation Management – Within Post-fledging Family Areas

General: Provide for a healthy sustainable 

forest environment for the post-fledging 

family needs of goshawks. The principle 

difference between within the post-fledging 

family area and outside the post-fledging 

family area is the higher canopy cover within 

the post-fledging family area and smaller 

opening size within the post-fledging family 

area. Vegetative Structural Stage distribution 

and structural conditions are the same within 

and outside the post-fledging family area 

(Coconino NF forest plan, page 65-10).

No Change

No similar direction in forest plan Canopy cover is evaluated at the group level within midaged to old forest structural stages groups (VSS 4, VSS 5 

and VSS 6) and not within grass/forb/shrub to young 

forest structural stage groups (VSS 1, VSS 2, and VSS 3) 

or in interspaces, natural meadows and grasslands, or 

other areas not managed for forest conditions.

Spruce-fir: Canopy Cover for mid-aged forest 

(VSS 4) should average 60+ percent and for 

mature (VSS 5) and old forest (VSS 6) should 

average 70+ percent (Coconino NF forest 

plan, page 65-10).

No Change

Mixed Conifer: Canopy Cover for mid-aged 

(VSS 4) to old forest (VSS 6) should average 

60+ percent.

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 621
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction Proposed New Guideline Language

Ponderosa Pine: Canopy Cover for mid-aged 

forest (VSS 4) should average 1/3 60+ percent 

and 2/3 50+ percent. Mature (VSS 5) and old 

forest (VSS 6) should average 50+ percent 

(Coconino NF forest plan, page 65-10).

No Change

No corresponding forest plan direction Develop and maintain a highly diverse vegetation mosaic: 

30 to 90 percent of the uneven-aged stand should be under 

ponderosa pine and deciduous tree crowns.

No corresponding forest plan direction Tree group spatial distribution may be highly variable 

based on local site and current conditions; the interspaces 

between groups may range from 20 to 200 feet, but 

generally between 25 and 100 feet apart from drip line to 

adjacent drip line. This spacing of groups is not affected 

by single trees in the interspace.

No corresponding forest plan direction Each tree group is generally dominated by one vegetation 

structure stage. The spatial arrangement of trees, high 

dispersion of VSS structural stage diversity, and 

interspaces comprise each uneven-aged forest stand. 

Collectively these stands aggregate to uneven-aged forest 

landscapes, similar to natural conditions.

Glossary

No corresponding forest plan language Interspaces: The open space between tree groups intended 

to be managed for grass/forb/shrub vegetation during the 

long term. Interspaces may include scattered single trees.

No corresponding forest plan language Open reference condition: Forested ponderosa pine areas 

with mollic-integrade soils to be managed as a relatively 

open forest with trees typically aggregated in small groups 

within a grass/forb/shrub matrix.

No corresponding forest plan language Stands: Contiguous area of trees sufficiently uniform in 

forest type, composition, structure, and age class 

distribution, growing on a site of sufficiently uniform 

conditions to be a distinguishable unit.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

622 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Figure 62. Alternative C general location of goshawk habitat subject to canopy cover requirements in 

VSS 4 to VSS 6 (Coconino NF and Kaibab NF) 

*Note: Although goshawk habitat on the Kaibab NF is reflected in this figure, only the Coconino NF plan has explicit 

canopy cover requirements in VSS4 to VSS 6 and subject to a plan amendment. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 623
Appendix B – Forest Plan Amendments

Figure 63. Alternative C amendment 2 general locations of savanna and grassland restoration 

treatments (Coconino NF) 

*Note: Although Kaibab NF treatments are reflected in this figure, only the Coconino NF is subject to a plan amendment. 

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long term land and resource management.

3. Minor changes in standards and guidelines. 

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

management prescription. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

624 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

Analysis demonstrated that the proposed amendment is nonsignificant (FSM 1926.51) because 

the actions would not significantly alter the multiple-use goals and objectives for long term land 

and resource management and the actions. How actions could potentially affect timing, location 

and size, relationship to forest goals, objectives, outputs, and management prescriptions was 

evaluated.

Timing: In terms of timing, the forest plan has been in place (and amended) since 1987 and plan 

revision efforts are underway.

Location and Size: There is approximately 892, 545 acres of goshawk habitat on the Coconino 

NF (Cote and Green 2014 personal communication email). 

The canopy cover portion of the amendment would generally affect 137,242 acres (15 percent) of 

all goshawk habitat on the Coconino NF. 

• The canopy cover portion of the amendment that clarifies measurement occurs at the 

group level-only would affect 98,986 acres (11 percent) of all goshawk habitat on the 

Coconino NF. 

• Managing 28,653 acres of ponderosa pine for an open reference condition would affect 

approximately 3 percent of all suitable goshawk habitats on the forest. 

For these reasons, location and size was determined to be nonsignificant. The amendment would 

facilitate moving over 137,000 acres toward the desired forest structure (groups and clumps with 

herbaceous openings) that maximizes prey base species habitat and allows for the reintroduction 

of fire into the ecosystem; and moves over 28,000 acres toward historic reference conditions. 

Relationship to Forest Goals and Objectives: Alternative C would meet goshawk forest plan 

canopy cover requirements in VSS 4 to 6 in all acres except the 28,653 acres managed for an 

open reference condition. In all acres but the open reference condition acres, actions would move 

toward the desired VSS size class distribution.

The amendment is consistent with forest goals for wildlife and fish of managing habitat to 

maintain viable populations of wildlife and fish species and improve habitat for selected species 

(Coconino National Forest plan, replacement page 22-1). It is consistent with the goal to improve 

habitat for listed threatened, endangered, or sensitive species of plants and animals and other 

species as they become threatened or endangered (Coconino National Forest plan, replacement 

page 23). 

Relationship to Management Prescriptions: Table 113 displays the acres associated with 

Coconino NF management areas (MAs).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 625
Appendix B – Forest Plan Amendments

Canopy Cover: The acres of forestwide management areas affected by the canopy cover portion 

of the amendment (137,242 acres total) would range from 3 percent (MA 4) to 35 percent (MA 

38). The amendment is specific to this project and would not impose definition and clarification 

requirements on the future management of canopy cover within goshawk habitat. 

Open Reference Condition: The acres of forestwide management areas affected by the open 

reference condition portion of the amendment (28,653 acres total) would range from 1 percent 

(MA 10) to 9 percent (MA 35). The amendment is consistent with the management emphasis of 

providing for multiple uses that includes wildlife habitat (MA 3) and moving ponderosa pine 

toward desired forest structure, including northern goshawk habitats (MA 35). The amendment is 

specific to this project and would not impose requirements on future management of the 28,653 

acres of goshawk non- post-fledging family areas; however, forest plan revision decisions may. 

Table 113. Alternative C amendment 2 management area (MA) acres

MA MA Description

Forestwide 

Acres

Proposed 

Amendment Acres

Forestwide Acres 

Affected (Percent)

Canopy Cover

MA 3 Ponderosa pine below 40 

percent slopes

511,015 92,251 18

MA 35 Lake Mary watershed 62,536 14,263 23

MA 38 West 36,298 12,844 35

MA 6 Unproductive timber lands 67,146 4,929 7 

MA 37 Walnut Canyon 20,566 3,656 18

MA 20 Highway 180 corridor 7,608 2,087 27

MA 4 Ponderosa pine and mixed 

conifer greater than 40 

percent

46,382 1,612 3 

MA 36 Schultz 21,289 798 4 

*MA 28, 4, 

9, 5, 8, 10, 7, 

34, 12, 15, 

14

See chapter 1, table 14 511,301 4,804 less than 1

Open Reference Condition

MA 3 Ponderosa pine below 40 

percent slopes

511,015 19,010 4 

MA 35 Lake Mary watershed 62,536 5,840 9 

MA 10 Transition grassland 160,494 1,288 1 

MA 38 West 36,298 1,073 3 

**MA 6, 20, 

4, 37, 9, 36, 

7, 12, 34, 28, 

5 

See chapter 1, table 14 221,928 1,806 less than 1

*All MA acres ranging from 1 to 1,215 were aggregated into the various categories.

**All MA acres ranging from 3 to 655 were aggregated into the various categories. 

Relationship to Outputs: Outputs identified in the forest plan are associated with MMBF of 

sawtimber sales and products (meet demand for timber while reducing conflict with other 

resources), MMBF of firewood sold and free use (provide access to firewood), grazing capacity, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

626 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

and permitted livestock use. The amendment would not affect outputs or change the long-term 

relationship between levels of goods (timber, firewood) and services. No portion of the 

amendment would affect decisions that have been made through separate analyses on grazing 

capacity or permitted livestock use. 

The canopy cover portion of the amendment provides clarification and disclosure of methods for 

meeting forest plan requirements. It has no relationship to outputs or to the relationship between 

the level of goods (timber, firewood) and services and would not result in a change in land 

productivity or timber suitability classification.

Timber Suitability: The silviculture analysis evaluated the impact of treatments on timber 

suitability (see silviculture report). Within the analysis area approximately 214,200 acres on the 

Coconino NF were considered in the timber suitability class. Unsuitable lands include areas 

where prescription would preclude timber production such as critical wildlife habitat and 

developed recreation sites as well as areas where irreversible resource damage occur. Table 114

shows total acres for the Coconino NF as reported in the forest plan and used in the timber 

suitability calculation. 

Table 114. Timber suitability calculation for the Coconino NF

Land Category Coconino

Acres

Gross area 1,821,495*

Area not administered by the Forest Service 

(Camp Navajo and private lands) 

NFS lands 1,821,495

Non-forested -325,945

Irreversible resource damage

Adequate restocking not assured

Withdrawn (219.14(a)(4)) -101,401

Subtotal: Not-suitable for timber 

production

-427,346

Lands Tentatively Suitable for Timber 

production

1,394,149

Management prescriptions preclude timber 

production

-593,102

Management requirements cannot be met -154,214

Not cost efficient in meeting timber objectives

Forested Lands not appropriate for timber 

harvest

-13,359

Experimental Forest -6,148

Subtotal: Not appropriate for timber 

production

-766,823

Lands suitable for timber production 627,326

Note: Acreages of NFS lands may vary slightly over time due to factors such 

as resurvey, improved mapping technology, and updates to corporate GIS 

layers. 

*Based on 1987 Coconino Forest Plan (Appendix H)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 627
Appendix B – Forest Plan Amendments

The Coconino Forest Plan contains the following guidance that directs the management of 

suitable and unsuitable land.

• On forested lands identified as suitable for commercial timber production, design timber 

management activities to integrate considerations for economics, water quality, soils, wildlife 

habitat, recreation opportunities, visual quality, and other values. 

• Evaluate timber lands adjacent to the Rim within the first decade to determine timber 

suitability.

• Management for the ponderosa pine/mixed conifer stands and the big tooth maple stands is 

the same as MA 3, foreground retention and for areas adjacent to foreground Retention lands. 

See MA 5 for direction for the aspen stands. 

• Manage the timber resource to provide a sustained-yield of forest products through integrated 

stand management. 

• Develop and implement a sustained-yield program for firewood and other miscellaneous 

forest products including posts, poles, Christmas trees, and wildings. Emphasize uneven-aged 

management for timber cutting areas.

Unsuitable lands within the Coconino NF are unproductive timber lands are within the ponderosa 

pine vegetation types. 

• They are unsuitable for timber harvest because they fall in at least one of the following two 

categories.

• They do not meet the minimum standards for productivity which is Site Index 40 and/or 20 

cubic feet per acre per year.

• There is not reasonable assurance that such lands can be adequately restocked as required by 

section 219.27(c)(13) of the planning regulations. 

Timber Suitability Consistency Evaluation by Forest Vegetation Community

Ponderosa Pine (PP) 

The ponderosa pine forest vegetation community generally occurs at elevations ranging from 

5,800 to 9,200 feet and is dominated by ponderosa pine and commonly includes other species 

such as oak, juniper, and pinyon. Species such as aspen, Douglas-fir, white fir, and blue spruce 

may also be present, but occur infrequently as small groups or individual trees. This forest 

vegetation community typically occurs with an understory of grasses and forbs although it 

sometimes includes shrubs.

The majority of the project area is the ponderosa pine plant association. Associations are named 

for the most shade tolerant tree species successfully regenerating, and for an understory species 

(shrub or herb) which is most diagnostic of the site. The ponderosa pine associations within the 

project area include two major sub-types: Ponderosa pine-bunchgrass and ponderosa pineGambel oak. 

Ponderosa pine commonly grows in pure stands and currently is found in even-aged3

 and unevenaged4

 structural conditions across the area. The open park-like stands characteristic of the 

3 Even-aged – pertaining to a stand composed of a single age class in which the tree ages are within + 20 

percent variability based upon the mature stand age (SAF 1998).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

628 Coconino and Kaibab National Forests 

 
Appendix B – Forest Plan Amendments

reference conditions for ponderosa pine forests promoted greater faunal diversity and fire 

resilience than the dense stands of today. Ponderosa pine forests within the project are generally 

denser and more continuous than in reference conditions (See Chapter 1) and accumulations of 

forest litter and woody debris are much higher than would have occurred under the historic 

disturbance regime. Lack of fire disturbance has led to increased tree density and fuel loads that 

increase the risk of uncharacteristically intense wildfire and drought-related mortality. When fires 

occur under current conditions, they tend to kill a lot of trees, including the large and old trees. 

These trees take longer to replace, moving the forest further from desired conditions, and 

increasing the time it would take to return to desired conditions. There is a high risk of insect 

and/or disease outbreak, which is also a function of increased tree density (see Forest Health 

Section). Within this plant series this project would not change any of the timber suitability acres 

with the proposed treatments.

Gambel Oak within Ponderosa Pine Forest 

Gambel oak is frequently the only deciduous tree in otherwise pure ponderosa pine forests in the 

4FRI analysis area, adding diversity to these forests. A portion of the stands have a large enough 

component of Gambel oak to be considered pine-oak habitat for Mexican spotted owl (as 

described in the 1996 forest plan amendment for Mexican spotted owl and Mexican spotted owl

Recovery Plan). Similar to pure ponderosa pine forests, pine-Gambel oak forests have become 

altered since Euro-American settlement in the late 1800s resulting in an overall increase in smalland medium sized Gambel oak stems and a more simplified forest structure (Abella, 2008). Oak 

management strategies within this project includes conservation of all existing large, old oaks, 

maintaining a variety of growth forms and managing for densities similar to the range of 

variability of oak’s evolutionary environment. Within this plant series this project would not 

change any of the timber suitability acres with the proposed treatments.

Amendment 3. Effect Determination for Cultural Resources

Background

The Coconino NF forest plan as written has some conflicting direction regarding managing 

significant or potentially significant sites. One standard (which would be amended for this 

project) directs management to strive to achieve a “no effect” determination. A second standard 

(which would be deleted for this project) directs management to achieve a “no effect” 

determination in consultation with SHPO and ACHP (36 CFR 800). An amendment is proposed 

to recognize that there could be effects that are not adverse, and that there could be adverse 

effects that may or may not be fully mitigated.

Amendment Description

The amendment deletes the standard that addresses achieving a “no effect” determination and 

adds the words “or no adverse effect” to the remaining standard. Management strives to achieve a 

“no effect” or “no adverse effect” determination. Table 115 displays current and proposed forest 

plan language. New or edited text is displayed in bold text.

4 Uneven-aged – pertaining to a stand with trees of three or more distinct age classes (SAF 1998).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 629

 
Appendix B – Forest Plan Amendments

Table 115. Alternative C amendment 3 effect determination for cultural resources 

Current Coconino NF 

Forest Plan Direction

Proposed New 

Standards and 

Guidelines Language

Cultural Resources

Consult with Native Americans when projects and activities are planned in 

sites or areas of known religious or cultural importance (Coconino NF 

forest plan, page 52).

No Change 

Make boughs and herbaceous plant parts used for Native American 

religious and ceremonial purposes available under conditions and 

procedures that minimize restrictions, consistent with laws, regulations, 

and agreements with tribes. The written authorization to the Hopi Tribe for 

gathering without specific individual permits is an example. This 

authorization does not include such items as firewood removed from the 

forest or Kiva logs, which do require a permit (Coconino NF forest plan, 

page 52).

No Change

The forest complies with the National Historic Preservation Act (NHPA) 

in decisions involving interactions between cultural and other resources. 

Cultural resources are managed in coordination with the State Historic 

Preservation Plan (SHPO). Until evaluated, the minimal level of 

management for all sites is avoidance and protection (Coconino NF forest 

plan, page 52).

No change

Specific standards and guidelines derived from the settlement agreement 

for the Save the Jemez lawsuit are subject to adjustment, should that 

agreement be modified. In that event an amendment to the forest plan will 

be issued (Coconino NF forest plan, page 52).

No Change

Project undertakings are inventoried for cultural resources and areas of 

Native American religious use. Inventory intensity complies with regional 

policy, and the settlement agreement for the Save The Jemez Lawsuit, and 

is determined in consultation with the State Historic Preservation Officer 

(SHPO). Generally, inventory standards are:

One hundred percent survey of all projects causing complete surface 

disturbance;

When less than 100 percent survey is deemed appropriate, the specific 

sample fraction surveyed is determined in consultation with the State 

Historic Preservation Officer and is generally greater than 10 percent. 

Factors determining when sampling is appropriate include projects with 

dispersed or minimal impacts, low expected archaeological site density, 

ground cover, and types of archaeological sites present in the area;

Consultation with appropriate Native American groups;

Consultation with the SHPO, and if necessary, the Advisory Council on 

Historic Preservation (ACHP), before project implementation (Coconino 

NF forest plan, page 52-1).

No Change

Significant, or potentially significant, inventoried sites are managed to 

achieve a “No Effect” determination, in consultation with the SHPO and 

ACHP (36 CFR 800) (Coconino NF forest plan, page 53).

Standard would be 

removed

Monitoring during and after project implementation is done to document 

site protection and condition (Coconino NF forest plan, page 53).

No Change

Management strives to achieve a “No Effect” determination (Coconino NF 

forest plan, page 53).

Management strives to 

achieve a “no effect” or 

“no adverse effect” 

determination

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

630 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New 

Standards and 

Guidelines Language

When sample surveys, rather than 100 percent survey coverage, are done 

for project clearances, survey locations and sample intensity are based on 

areas of greatest project impact, likely locations for cultural resource sites 

based on archaeological experience, land management planning, 

dispersion of sample coverage, certain topographic features specified in 

the Save the Jemez lawsuit settlement agreement, and likely areas based on 

the Forest site density predictions (Coconino NF forest plan, page 53).

No Change

Identified sites are evaluated for their National Register eligibility when 

they are severely damaged, when they will be impacted by an undertaking, 

or information about the uniqueness, commonness, and characteristics of 

their site class are sufficiently known to make an informed decision. Sites 

for which determinations of eligibility have not been made are managed as 

if they are eligible, unless consultation with the SHPO indicates otherwise 

(Coconino NF forest plan, page 53).

No Change

For each full-time professional cultural resource specialist employed by 

the forest, at least two site nominations, one archaeological district 

nomination, or one thematic or multiple resource nomination will be made 

each year to the National Register of Historic Places. Or, alternatively, the 

forest will coordinate with other forests to prepare a joint district, thematic, 

or multiple resource nomination (Coconino NF forest plan, page 53).

No Change

Inventoried sites allocated to management categories, and/or eligible or 

potentially eligible for the NRHP or potentially eligible for the NRHP are 

systematically revisited by regularly scheduled patrols, and by cultural 

resources specialists to assess natural deterioration, vandalism, or 

pilfering. Inspections are made at least biannually of properties that have 

been listed in or nominated to the National Register. Sites most susceptible 

to natural deterioration and/or human disturbance are monitored 

frequently. Rapid natural deterioration, or susceptibility to such, requires 

stabilization, restoration, and/or data recovery. Vandalism or pilfering 

requires protective measures such as signing, remote sensing, increased 

patrolling, investigations, stabilization, restoration, and/or data recovery. 

Specific sites or areas may be closed to off-road driving and withdrawn 

from mineral entry. Law enforcement is planned and implemented to 

minimize resource damage and user conflicts. Signing is appropriate to 

inform and educate the public and minimize direct law enforcement 

activity. Aggressively pursue violations (Coconino NF forest plan, page 

53).

No Change

Continue to interpret cultural resources through lectures, tours, papers, 

reports, publications, brochures, displays, films, trails, signs, and other 

opportunities. (Coconino NF forest plan, page 54).

No Change

Develop a program to complete 100 percent coverage of the Forest’s 

cultural resource inventory by 2000 (Coconino NF forest plan, page 54).

No Change

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 631
Appendix B – Forest Plan Amendments

Current Coconino NF 

Forest Plan Direction

Proposed New 

Standards and 

Guidelines Language

The first priorities for cultural resources protection, enhancement, and 

interpretation are those sites that are easily accessible, have major 

interpretive potential, or are in major need of repair. Priority sites for 

signing are the C. Hart Merriam Base Camp, Honanki Cliff Dwellings, 

Elden Pueblo, Sacred Mountain, Palatki Cliff Dwellings, and Clear Creek 

Ruins. Priority sites for repair and stabilization are Honanki Cliff 

Dwellings, Palatki Cliff Dwellings, Sacred Mountain, Clear Creek Cliff 

Dwelling, and General Springs Cabin. Priority sites for developing 

interpretive brochures are Elden Pueblo, Sacred Mountain, Red Tank 

Draw Petroglyphs, Honanki Cliff Dwellings, Palatki Cliff Dwellings, and 

Clear Creek Ruins. Priorities are to:

Survey to clear projects.

Survey to fill in gaps in existing inventory coverage.

Survey areas of known high site densities.

Survey areas that would do the most to answer current archaeological 

questions (Coconino NF forest plan, page 54).

No Change

Computerize cultural resource site information by 1990 (Coconino NF 

forest plan, page 54).

No Change

Maintain a form for tracking compliance of each undertaking with the 

requirements of the National Historic Preservation Act (Coconino NF 

forest plan, page 54).

No Change

Stabilize or repair damaged National Register sites or other sites funded by 

regional priority (Coconino NF forest plan, page 54).

No Change

Continue to develop the Elden Pueblo Interpretive Site and the cooperative 

education program with the Museum of Northern Arizona (Coconino NF 

forest plan, page 54).

No Change

Encourage universities to conduct summer field schools to assist in 

cultural resource survey and excavation work and to provide the forest 

with scientific knowledge (Coconino NF forest plan, page 54).

No Change

Periodically focus media attention on Elden Pueblo and/or other sites to 

educate the public and further volunteer interest in resource management. 

Work with community organizations, businesses, and other agencies to 

promote Arizona Archaeology Week. Feature significant finds and 

significant damage in the media to increase public awareness of benefits 

and problems (Coconino NF forest plan, page 54).

No Change

Significance Evaluation

Per FSM 1926.51, changes to the land management plan that are not significant can result from: 

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

and resource management.

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

further onsite analysis when the adjustments do not cause significant changes in the multipleuse goals and objectives for long term land and resource management.

3. Minor changes in standards and guidelines. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

632 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

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

management prescription. 

Per FSM 1926.52, circumstances that may cause a significant change to a land management plan 

include: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)), 

and 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

The proposed amendment is nonsignificant (FSM 1926.51) because multiple-use goals and 

objectives for long term land and resource management and its actions would not be altered. How 

the amendment could potentially affect timing, location and size, relationship to forest goals, 

objectives, outputs, and management prescriptions was evaluated. 

Timing: In terms of timing, the forest plan has been in place (and amended) since 1987, and plan 

revision efforts are underway.

Location and Size: Amendment 3 is specific to the 355,707 acres of proposed treatments in this 

project. In alternative C this would affect about 20 percent of the Coconino NF (which totals 

1,821,495 acres).

This would not have an important effect on the entire land management plan or a large portion of 

the planning area. For this reason, location and size was determined to be nonsignificant.

Relationship to Forest Goals and Objectives: The amendment would not affect attainment of 

forest goals and objectives for cultural resources. Cultural resource sites would be located and 

protected from project activities according to direction in FSM 2360 and 2430 (Coconino NF 

forest plan, page 50) and the requirements of 36 CFR 800 including 36 CFR 800.5 which 

provides direction for assessing adverse effects and proposing a finding of no adverse effect. 

Consultation with AZ SHPO would occur as required and regulation 36 CFR 800 would be 

followed and met.

Relationship to Management Prescriptions: The amendment would apply to all 23 

management areas (MAs) as described in the Coconino National Forest plan (pages 46 to 206-

113) and in chapter 1 of the DEIS. The amendment would not affect the management of the 

management areas. All cultural resources are currently managed to minimize impacts and to 

achieve a “no effect” or “no adverse effect” determination whenever possible, in consultation 

with AZ SHPO, the council, and other consulting parties. 

Relationship to Outputs: Outputs identified in the forest plan are associated with MMBF of 

sawtimber sales and products (meet demand for timber while reducing conflict with other 

resources), MMBF of firewood sold and free use (provide access to firewood), grazing capacity, 

and permitted livestock use. The amendment would not affect outputs or change the long-term 

relationship between levels of goods (timber, firewood) and services. 

The amendment would not affect outputs or change the long-term relationship between levels of 

goods (timber, firewood) and services. All cultural resources are managed to minimize impacts 

and to achieve a “no effect” or “no adverse effect” determination whenever possible, in 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 633
Appendix B – Forest Plan Amendments

consultation with AZ SHPO, the council, and other consulting parties regardless of forest plan 

desired outputs.

Alternative D – Coconino National Forest 

Site-Specific Nonsignificant Forest Plan Amendments 

Amendment 1. Mexican Spotted Owl Habitat Management 

(Coconino NF)

Amendment Description

This amendment is the same as described for alternative B in that the amendment allows 

mechanical treatment up to 16 inches d.b.h. in 18 PACs Mexican spotted owl PACs. Although 

alternative D reduces the acres that would receive prescribed fire, the amendment would still be 

required to address mechanical treatment above 9 inches d.b.h., eliminating incremental 

treatments within PACs, and deferring monitoring to the project’s U.S. Fish and Wildlife Service 

biological opinion. Figure 64 displays mechanical Mexican spotted owl PAC treatments locations. 

No prescribed fire would occur within PACs. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

634 Coconino and Kaibab National Forests 
Appendix B – Forest Plan Amendments

Figure 64. Alternative B amendment 1 Mexican spotted owl PAC treatments

Amendment 2. Management of Canopy Cover and Ponderosa Pine 

with an Open Reference Condition within Goshawk Habitat 

(Coconino NF)

This amendment is similar to alternative B. The key difference between the alternatives is the

acres that would receive prescribed fire. In alternative D, the acres of prescribed fire would be 

reduced by about 69 percent, from 583,330 acres in alternative B to 178,441 acres. Any 

difference in acres of prescribed fire would not eliminate the need for a plan amendment that 

addresses managing acres for an open reference condition.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 635
Appendix B – Forest Plan Amendments

Amendment 3. Effect Determination 

for Cultural Resources (Coconino NF)

Amendment 3 is the similar to alternative B. However, 331,794 acres or 18 percent of the 

Coconino NF would be affected by the amendment. The reduction in acres to receive prescribed 

fire in alternative D would not eliminate the need for a plan amendment that addresses managing 

for “no effect” or “no adverse effect” for heritage resources. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

636 Coconino and Kaibab National Forests 
Appendix C – Design Features, Best Management 

Practices, and Mitigation

Design features, best management practices (BMPs), and mitigation that are common to all action 

alternatives (B–E) are presented for each resource with one exception. Silviculture design 

features can be found in Appendix D – Implementation Plan. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 637
Appendix C – Design Features, BMPs, and Mitigation

Table 116. Alternatives B, C, D, and E design features, best management practices, and mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

Aquatics

A1 See Soil and Water: SW1 to SW 43

Botany

B1 Follow forest plan direction for special areas including botanical 

areas.

X Preserve special features and 

meet intent of designation.

B2 Determine potential occurrences and habitat of Southwestern 

Region sensitive plants in potential activity areas when planning 

for implementation. Identify potential species and survey the area 

to be treated before implementation.

X Complies with FSM direction 

2670. Manual direction (FSM 

2670.5(19)) emphasizes that 

management actions should 

avoid or minimize impacts to 

sensitive species.

B3 Mitigate negative effects from management actions on 

Southwestern Region sensitive plants during design and 

implementation.

X Complies with FSM direction, 

minimizes impacts to 

Southwestern Region sensitive 

plants.

B4 Prohibit slash pile construction within populations of Southwestern 

Region sensitive plants. Construct slash piles at least 10 to 20 feet 

away from known populations of Southwestern Region sensitive 

plants. Place slash piles on previously used locations such as old 

piling sites, old log deck sites, or other disturbed sites to avoid 

severe disturbance to additional locations where possible. Monitor 

slash pile sites after burning and control noxious or invasive weeds 

(see FE10).

X Mitigates effects of disturbance 

and burning. Reduces loss of 

native seed bank, limits extent 

of severe disturbances, and 

reduces severely disturbed sites 

that are more prone to invasion 

by noxious or invasive weeds.

B5 Prohibit temporary road construction and reconstruction, tracked 

vehicles, and pits within populations of Southwestern Region 

sensitive plants.

X Eliminates direct loss of plants.

B6 Prohibit construction and reconstruction of log landings in 

identified populations of Southwestern Region sensitive plants.

X Mitigates effects of disturbance. 

Follows management plan 

guidance of the management 

plan for Hedeoma diffusum

(Flagstaff pennyroyal).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

638 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

B7 Follow the guidance of the “Arizona Bugbane Conservation 

Assessment and Strategy, Coconino and Kaibab NFs” (1995) when 

planning activities near Arizona bugbane populations. An example 

of mitigation for this species includes preservation of shade and 

cool microsites for existing populations. This may require special 

attention in upland areas near canyon edges.

X Mitigates effects to Arizona 

bugbane, a U.S. Fish and 

Wildlife Service candidate 

species. Follows guidance of 

conservation assessment and 

strategy and complies with 

policy.

B8 Manage fire severity in all entries in or near Arizona bugbane 

populations to minimize tree mortality.

X Preserves the shady, mesic 

environment and overstory 

needed for Arizona bugbane.

B9 Follow the guidance of the management plan for Hedeoma 

diffusum (Flagstaff pennyroyal) when working in suitable habitat 

for this species. Examples of mitigations include restrictions on 

distance for building temporary roads near existing populations.

X Forest plan compliance.

B10 Deferrals and groups may include Southwestern Region sensitive 

plant groups where practical, using areas not occupied by the plants 

as interspaces.

X Provide protection and shade 

needed by the sensitive plants 

while allowing for the least 

impact on 

clump/group/interspace design 

and layout during 

implementation and help 

mitigate impacts to 

Southwestern Region sensitive 

plants.

B11 Survey springs and channels for Southwestern Region sensitive 

plants before implementation and identify locations. Inform the 

forest botanist if new locations are found and mitigate effects to 

plants and populations. Mitigations include avoiding plants, 

altering designs, or including plants in enclosures. Incorporates 

buffer strips along drainages. See soil and water SW8.

X Protects populations and habitat 

of Southwestern Region 

sensitive plants. Protects 

sneezeweed since it grows in 

ephemeral stream courses, 

springs, ponds, stock tanks, and 

meadows.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 639
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

B12 Survey springs and channels for Bebb’s willow before 

implementation and identify locations. Inform the forest botanist if 

new locations are found and mitigate effects to plants and 

populations. Mitigations include avoiding plants, altering designs, 

or including plants in enclosures. Identify opportunities to enhance 

Bebb’s willow where plants are decadent or dying. Manual 

grubbing of grasses may be used to increase the likelihood of 

planting success.

X – Coconino 

NF only

Protects populations and habitat 

of Bebb’s willow. Bebb’s 

willow stands would be 

enhanced by using cuttings, 

planting locally cultivated 

plants, and fencing existing or 

newly planted willows.

B13 Manage prescribed fires/burn to promote native species, hinder 

weed species germination, use as an aid to control of existing weed 

infestations, and to prevent the spread of existing weeds.

X Promote healthy native plant 

communities and reduces the 

risk of noxious or invasive weed 

invasions.

B14 Review watershed BMPs for project area and incorporate 

mitigations for Arizona sneezeweed into BMPs.

X Watershed BMPs often serve as 

good mitigations for Arizona 

sneezeweed since it grows in 

ephemeral stream courses, 

springs, ponds, stock tanks and 

meadows.

B15 Review various sites such as spring restoration for opportunities to 

introduce and restore Bebb’s willow to supplement existing 

locations on the forest and introduce young plants into areas where 

plants are decadent and dying. Bebb’s willow stands would be 

enhanced by using cuttings, planting locally cultivated plants, and 

fencing existing or newly planted willows. Manual grubbing of 

grasses may be used to increase the likelihood of planting success. 

Fire lines would be placed around Bebb’s willows and dead 

branches within the clumps would be removed before prescribed 

burning adjacent areas to reduce the risk of fire impacting willows.

X Aids in restoring Bebb’s willow 

which is a Southwestern Region 

sensitive species for the 

Coconino NF and a rare species 

on the landscape for both 

forests.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

640 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

B15 Follow the guidance in appendix B of the “Final Environmental 

Impact Statement for Integrated Treatment of Noxious or Invasive 

Weeds, Coconino, Kaibab, and Prescott NFs within Coconino, 

Gila, Mojave, and Yavapai Counties, Arizona” including: (1) 

surveying the treatment area and evaluating weeds present before 

implementation; avoiding or removing sources of weed seed and 

propagules to prevent new weed infestations and the spread of 

existing weeds; (2) treating weed infestations within treatment 

units before implementing treatments; (3) managing prescribed 

fires as an aid to control of existing weed infestations and to 

prevent the spread of existing weeds; and (4) monitoring slash pile 

sites after burning and control noxious or invasive weeds.

X Provides guidance and 

mitigation for noxious or 

invasive weeds and complies 

with amendment 20 of the 

Coconino NF forest plan.

B16 Treat weed infestations within treatment units before implementing 

treatments.

X Forest plan direction 

Amendment 20 Coconino 

National Forest Plan.

B17 Monitor slash pile sites after burning and control noxious or 

invasive weeds.

X Controls weeds, reduces risk of 

invasion and reduces risk to 

native species by reducing weed 

competition.

B18 Prevent spread of potential and existing noxious or invasive weeds 

by vehicles used in management activities by washing vehicles and 

equipment prior to entering the project area and when moving from 

one area to another.

X Mitigates effects of management 

actions on existing and potential 

noxious or invasive weed 

infestations, Forest plan 

direction is complementary to 

Timber Sale Contract Clause CT 

WO-C/CT 6. 36 and watershed 

best management practices.

B19 Review Timber Sale contract clauses for vehicle cleaning and 

incorporate appropriate clauses.

X Complementary to B18.

B20 Incorporate the Best Management Practices for noxious or invasive 

weeds as listed in appendix B of the Final Environmental Impact 

Statement for Integrated Treatment of Noxious or Invasive Weeds 

into all management actions. See appendix F of the botany report.

X Required by the forest plan 

(Amendment 20 of the 

Coconino National Forest Plan.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 641
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

B21 Monitor the effects of treatment on Region 3 sensitive plants after 

treatments are completed.

X Provides opportunities to obtain 

knowledge on local species that 

are often poorly understood. 

Allows for adaptive 

management in future 

treatments.

B22 Timing of prescribed fire and herbicide application in areas with 

leafy spurge will be determined by the District Fuels Specialist and 

District Weeds Coordinator at the time of implementation. The 

most successful herbicide treatments for populations of leafy 

spurge on the Coconino National Forest have been in the fall. 

However, the logistics of treating plants with herbicide in the fall 

after burning may be difficult. The above ground portions of the 

plants will be absent and resources would have been drawn into the

underground storage structures of the plants. A spring herbicide 

treatment following a fall burn may be necessary to address help 

facilitate control but this issue will be addressed on a site specific 

basis.

X Allows prescribed fire to occur 

in our near existing populations 

of leafy spurge while providing 

for control of it. Allows on the 

ground, site-specific assessment 

and coordination of the 

prescribed fire and control of 

leafy spurge on a site-specific 

basis.

B23 Fire should be excluded from leafy spurge areas where biological 

control insects for leafy spurge are active during the summer 

months generally from mid-May to August, except if monitoring 

and surveys fail to detect the presence of the biological control 

insects. Prescribed fire may be implemented during that time if the 

insects are absent from the site and there are no other resource 

concerns. Monitoring prior to implementation would be needed to 

confirm the presence/absence of the insects. 

X Protects the financial investment 

and potential control provided 

by the biological control insects 

that have been released in the 

past and may be released in the 

future while allowing prescribed 

fire to be implemented in the 

affected areas.

B24 Incorporate surveys for rare and endemic plants into surveys for 

Region 3 sensitive plants and/or noxious or invasive weeds prior to 

implementation. Survey needs will be dependent on known or 

potential occurrences in the treatment areas.

X Addresses the desired conditions 

for rare or endemic species in 

the Kaibab NF Plan (2014) and 

the Coconino NF plan (in 

revision).

B25 Apply mitigations B2 through B 8 and B10 through B12 and B14 

as needed to address the effects to rare and endemic plant species.

X Addresses management effects 

to rare and endemic species as 

well as to Region 3 sensitive 

plants.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

642 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

B26 Consult the Rare Plant Guidebook) in preparation) (if available) at 

the time of implementation. 

X Guidebook is designed to 

provide identification aids, 

potential habitat information and 

potential risks to species for 

analysis and implementation.

Fire Ecology

FE1 Burn unit size, as well as strategic placement, would be a 

consideration in designing units and implementation prioritization 

(Finney et al. 2003).

X Arrangements of large treatment 

areas are more effective at 

reducing fire behavior than 

arrangements of smaller ones. 

Larger burn blocks, when 

possible, would also be 

mitigation for emissions by 

increasing the potential number 

of acres that could be burned in 

a burn window. Larger burn 

units would produce more 

smoke when prescribed fires are 

implemented, but for a shorter 

duration.

FE2 Prescribed fire (pile, broadcast, and jackpot burning) would occur 

in accordance with Arizona Department of Environmental Quality 

(ADEQ) requirements.

X Regulatory requirement.

FE3 Emission reduction techniques (see FE8) would be utilized when 

possible to minimize impacts to sensitive receptors of burn unit(s). 

Project design for prescribed fire and strategies for managing 

wildfires should incorporate as many emission reduction 

techniques as feasible, subject to economic, technical, and safety 

criteria, and land management objectives. Decision documents 

(which define the objectives and document line officer approval of 

the strategies chosen for wildfires) should identify smoke-sensitive 

receptors, and include objectives and courses of action to minimize 

and mitigate impacts to those receptors as feasible.

X Emission reduction techniques 

are recommended by the ADEQ 

as techniques that can be 

effective for minimizing impacts 

to sensitive receptors.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 643
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

FE4 As needed, the burning of hand piles or machine piles would occur 

when conditions are favorable and risk of fire spread is low. Piles 

would be located far enough away from residual trees and shrub 

patches to minimize canopy scorch or damage to ponderosa pine or 

large oak (greater than 6 inch d.b.h.) where it is not desirable. 

Individual piles or groups of piles may have fireline cut around 

them if necessary to meet objectives.

X Prevent undesirable impacts.

FE5 Firelines would be used to facilitate broadcast burns or pile burning 

operations as needed: (1) Firelines may consist of natural barriers, 

roads and trails, or may be constructed as needed. Line 

construction may consist of removing woody and/or herbaceous 

vegetation, removing surface fuels, pruning, or cutting breaks in 

fuels by hand, ATV (drag lines), or a dozer as needed, (2) Fireline 

width would be determined as adjacent fuels and expected fire 

behavior dictate, assuming compliance with the requirements of 

cultural, wildlife, and other resource areas, (3) Constructed 

firelines would be rehabilitated, which may include pulling 

removed material back into the lines, hand constructing water 

diversion channels and/or water bars, laying shrubs or woody 

debris in the lines following burning, or other methods appropriate 

to the site, and (4) Fireline construction would be coordinated with 

wildlife and heritage.

X Facilitate broadcast burns or pile 

burning operations.

FE6 Mechanical treatments following broadcast burns would occur after 

surface vegetation has recovered sufficiently to minimize impacts 

from the mechanical treatments (generally 1 to 3 years). Prescribed 

fire treatments following mechanical treatments would occur after 

there has been adequate surface vegetation recovery that fuel loads 

are sufficient to meet the objectives of a prescribed burn.

X Minimize impacts from 

mechanical treatments on 

vegetation and soil.

FE7 Prescribed fires may be conducted before or after mechanical 

treatments. The sequencing of prescribed fires and mechanical 

treatments would be decided on a site-specific basis, depending on 

the site, burn windows, available resources, thinning schedules, etc.

X Increase the flexibility for 

implementing both prescribed 

fire and mechanical treatments.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

644 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

FE8 The following ADEQ emissions reduction techniques (ERTs) 

would be used when practicable to minimize impacts to sensitive 

receptors: pre-burn fuel removal, mechanical processing, increased 

burning frequency, aerial/ mass ignition, high moisture in large 

fuels, rapid mop-up, air curtain incinerators, burn before green-up, 

backing fire, maintain fireline intensity, underburn before litterfall, 

isolating fuels, concentrating fuels, mosaic/jackpot burning, moist 

litter and duff, burn before large activity fuels cure, and utilize 

piles.

X Reduce emissions from 

prescribed fire.

FE9 Mitigation and design features for smoke impacts include: (1) 

Reducing the emissions produced for a given area treated, (2) 

Redistributing/diluting the emissions through meteorological 

scheduling and by coordinating with other burners in the airshed. 

Dilution involves controlling the rate of emissions or scheduling 

for dispersion to assure tolerable concentrations of smoke in 

designated areas, and (3) Avoidance uses meteorological 

conditions when scheduling burning in order to avoid incursions of 

wildland fire smoke into smoke sensitive areas. Also see FE8 for 

ERTs.

X X See FE 9.

FE10 When prescribed burns are conducted in areas with, or near known 

populations of invasive weeds, follow-up monitoring would be 

conducted. Also see Botany B4.

X Detect new weed infestations 

before they spread.

FE 11 See Rangeland Management: R1, R4, and R5. X Prevent damage or loss of 

infrastructure.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 645
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

FE12 When practicable, damage or mortality to old trees, and large trees 

would be mitigated by implementing prescription parameters, 

ignition techniques, raking, wetting, thinning, compressing slash, 

or otherwise mitigating fire impacts to the degree necessary to 

meet burn objectives and minimize fireline intensity and heat per 

unit area in the vicinity of old trees. Trees identified as being of 

particular concern (e.g. trees with known nests or roots for herons, 

eagles, osprey, or other raptors, occupied nest cores, or critical 

areas in PACs) would be managed in accordance with wildlife 

design features (see wildlife). Prepare old trees 1 year or more 

before a burn if possible.

X Old trees are rare components 

and are under-represented across 

the project area. Implementing 

mitigation measures when 

possible is a critical component 

of restoration on a landscape 

scale. Large trees that are not 

old are not as susceptible to 

damage from fire. Mitigation 

measures that can be 

implemented a year or more 

before a burn, such as thinning 

or raking, may improve the 

health of the tree, improving its 

response to fire.

FE13 Mitigation measures and design features for wildlife species 

including Mexican spotted owl, golden eagle, bald eagle, 

pronghorn, northern goshawk, bats, northern leopard frog, turkey, 

deer, and other wildlife can be found in the wildlife section.

X Forest plan compliance.

FE14 Aspen, Gambel oak, pine-sage: fire effects would be managed 

primarily by implementing prescriptions and ignition techniques to 

meet objectives in pine-sage systems. In Gambel oak, avoid 

lighting near the bases of large oak boles.

X To meet burn objectives.

FE15 Concerned/interested public will be given as much warning as 

possible in advance of prescribed burns via notices, press releases, 

email lists, public announcements, phone lists, or other notification 

methods as appropriate.

X To provide advanced notice for 

publics concerned about 

potential impacts from 

emissions resulting from 

prescribed fires.

FE16 Range and fire managers will coordinate grazing schedules and 

prescribed fires on allotments within burn units to ensure there is 

sufficient surface fuel to allow burn objectives to be met. If grazing 

cannot cease long enough for sufficient fuel to build up to meet 

objectives, planned prescribed fires will be postponed until there 

can be sufficient fuel to meet objectives.

X To improve the ability of 

prescribed fire managers to meet 

objectives when implementing 

prescribed fires.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

646 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

FE17 Coarse woody debris will be managed to achieve forest plan 

direction, though it may take more than one entry when the current 

conditions are deficit (i.e. are below forest plan guidelines).

KNF: 1 – 5 tons per acre in wildland-urban interface unless there 

are conflicts with other resource needs. (Refer to KNF revised 

forest plan page 98). Other areas in ponderosa pine on the KNF 3 – 

10 tons per acre.

CNF: 5 – 7 tons per acre in ponderosa pine.

X To provide levels of coarse 

woody debris to address the 

need for habitat (cover), soils 

(organic material and limited 

areas of high burn severity), and 

fire (limited areas of high burn 

severity and a high resistance to 

control).

Heritage Resources and Tribal Relations

HR/TR-1 The forest would comply with the NHPA for all ground-disturbing 

undertakings. Effects to cultural resources would be determined in 

consultation with the SHPO and other consulting parties. Potential 

effects would be addressed through site avoidance strategies and 

implementing the site protection measures listed in the 

Southwestern Region programmatic agreement (PA), appendix J 

and in the 4FRI heritage strategy and section 106 clearance report.

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO.

HR/TR-2 Consult with Native Americans in compliance with NHPA, 

AIRFA, EO 13007, EO 13175, and other applicable Executive 

Orders and legislation, particularly when projects and activities are 

planned in sites or areas of known religious or cultural 

significance.

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO.

HR/TR-3 Project undertakings would be inventoried for cultural resources 

and areas of Native American religious and cultural use.

X Regulatory requirement. 

Compliance with NHPA and

Southwestern Region PA with 

AZ SHPO.

HR/TR-4 Eligible, or potentially eligible, cultural resources would be 

managed to achieve a “no effect” or “no adverse effect” 

determination whenever possible, in consultation with the SHPO 

and ACHP (36 CFR 800).

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO.

HR/TR-5 Monitoring during and after project implementation would occur to 

document site protection and condition. Also see FE5.

X Forest plan compliance.

HR/TR-6 See Recreation and Scenery RS3 and RS5 for mitigation related to 

historic roads and trails.

X Forest plan compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

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Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

HR-TR-7 Prior to initiating and during the heritage analysis for -specific task 

orders, the forests would consult with federally recognized tribes to 

identify traditional use areas and, if necessary, develop projectspecific mitigation measures to accommodate traditional use of the 

forest by tribal members.

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO. Forest plan 

compliance.

HR-TR-8 Fuels and other treatment timing would be adjusted as possible to 

avoid seasonal plant gathering and ceremonial use.

X Continued coordination with 

tribes during implementation.

HR-TR-9 See FE 5 . 

HR-TR-10 In accordance with regulations (43 CFR 10) governing application 

of the Native American Graves Protection and Repatriation Act of 

1990 (NAGPRA), if human remains, funerary objects, sacred 

objects, or objects of cultural patrimony are inadvertently 

encountered, operations in the area must immediately cease and the 

Forest Archaeologist notified. The Forest Archaeologist will work 

to initiate consultation with the affected tribe (s) to implement any 

requirements listed in NAGPRA and the PA and develop a plan to 

mitigate for the effects to the find.

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO. Forest plan 

compliance.

HR-TR 11 Should any previously unidentified cultural materials be discovered 

during project implementation, work must cease immediately and 

the Forest Archaeologist must be contacted to initiate the 

consultation process as outlined in the Advisory Council on 

Historic Preservation Regulations (36 CFR Part 800.13).

X Regulatory requirement. 

Compliance with NHPA and 

Southwestern Region PA with 

AZ SHPO. Forest plan 

compliance.

Rangeland Management

R1 Historic range monitoring sites including witness trees/posts, 1inch 

angle iron stakes, and any other site location markers would be 

protected. These sites would not be excluded from treatment but 

care needs to be taken to avoid loss of these site markers. These 

sites would not be used as locations for temporary access roads, 

skid trails, landing areas, or large slash piles.

X Avoid site damage.

R2 The sale administrator would work closely with the district range 

staff to determine pasture use during harvest activities.

X Avoid infrastructure damage, 

and retain allotment and pasture 

fences within a harvest area.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

648 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

R3 All fences in the cutting area would be protected from harvest 

activities. Skid trail layout would keep equipment on one side of 

the fence to avoid having to cut fences. Temporary cattle guards 

would be installed on all haul roads where gates exist within active 

grazed pastures. All cattle guards on harvest haul roads would be 

maintained throughout hauling activities.

X Protect infrastructure.

R4 Burning often damages/destroys wood stays and h-brace posts in 

existing pasture/allotment fencing. Protection of these fences is 

critical for implementation of planned grazing systems and is 

important to reduce the costs of replacing these items. Even with 

protection, wood stays and h-braces would be damaged by the fire. 

The cost of prescribed burning would include fence protection 

measures and replacement/reconstruction costs for burned wood 

stays and h-braces. Fire personnel will look at using the fence lines 

as burn area boundaries whenever possible to reduce these impacts.

X Limit the numbers of pastures 

affected by the fires in a given 

year. Protect fences that are 

critical to the implementation of 

planned grazing systems and 

reduce the costs of replacing 

these items.

R5 Fire personnel would coordinate with district range staff to 

schedule main pasture burning to limit impacts to allotment grazing 

management. The general goal would be to limit burns to no more 

than one main grazing pasture/year/allotment in allotments with a 

less than, or equal to, six pasture grazing system.

X Minimize disruption to grazing.

R6 Burns would be restricted to no more than two main grazing 

pastures/year/allotment in allotments with a greater than six pasture 

grazing system. Main pastures are pastures that are large enough to 

hold the allotment’s livestock for more than an average of 20 days 

per year. This is a general rule of thumb; however, each allotment 

has specific situations that would need to be addressed.

X Minimize disruption to grazing.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 649
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

R7 Restrictions in grazing of livestock would primarily occur after 

significant burns in a pasture. Post-fire grazing may resume within 

a pasture when soil and perennial plants, that would likely be 

grazed, would not be permanently damaged by livestock. The 

range management definition for this is range readiness. Plants are 

ready for grazing when at least one of the following characteristics 

is present: 1) seed heads or flowers, 2) multiple leaves or branches, 

and/or 3) a root system that does not allow plants to be easily 

pulled from the ground. These characteristics provide evidence of 

plant recovery, high vigor and reproductive ability. An estimate of 

this restriction is not available because of each pasture and burn is 

unique. Climatic conditions, soils, vegetation, the severity of fire 

effects, burn amount, and pasture management can vary greatly 

from year to year or from pasture to pasture.

X Assessment of post-fire range 

readiness.

R8 Range and fire managers will coordinate grazing schedules and 

prescribed fires on allotments within burn units to ensure there is 

sufficient surface fuel to allow burn objectives to be met. If grazing 

cannot cease long enough for sufficient fuel to build up to meet 

objectives, planned prescribed fires will be postponed until there 

can be sufficient fuel to meet objectives.

X Assessment of post-fire range 

readiness.

R9 The removal or exclusion of livestock water would be mitigated 

with alternative water sources, providing lanes to the water, or 

piping water to a livestock drinker.

X Provide alternate water sources.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

650 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

Recreation, Trails, Scenery, and Special Areas

RS1 Edges of Individual Units: (a) Edges of treatment units would be 

shaped and/or feathered (create gentle transitions from more to 

fewer trees or fewer to more trees) to avoid abrupt changes 

between treated and untreated areas; (b) where the treatment unit is 

adjacent to denser forest (treated or untreated), the percent of 

thinning within the transition zone (150–250 feet) would be 

progressively reduced toward the denser edges of the unit; (c) 

where the treatment unit interfaces with an opening (including 

savanna and grassland treatments, and natural openings) the 

transition zone would progressively increase toward the open edges 

of the unit; (d) soften edges by thinning adjacent to the existing 

unit boundaries. Treat up to the edges; do not leave a screen of 

trees. Favor groups of trees complying with the prescribed 

treatment that visually connect with the unit’s edge to avoid an 

abrupt and noticeable change; (e) treatment boundaries should 

extend up and over ridgelines to avoid the “Mohawk” look; and (f) 

avoid widely spaced individual trees that are silhouetted along the 

skylines.

X X Compliance with forest plans.

RS2 Unit Marking: (a) Avoid using trails as boundaries and (b) avoid 

abrupt changes between treatment units. Use the techniques 

suggested for edges of treatment units (above). Where feasible 

strive to have the minimal marking of trees within the Arizona 

Trail corridor.

X X Compliance with forest plans.

RS3 Road, Skid Trail, and Landing Construction: (a) Utilize dust 

abatement methods during haul of logs on the following roads 

shown in the table during the season when dust is likely and 

funding is available. Coordinate with Coconino County on the 

application and timing of application of dust abatement on road 

segments that have county maintenance responsibilities:

X X Compliance with forest plans.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 651
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

(b) Where new temporary roads and skid trails meet a primary 

travel route, they should intersect at a right angle, then curve after 

the junction, to minimize the length of route seem from the primary 

travel route; (c) Log landings, temporary roads, and skid trails 

should be minimized within sensitive viewsheds such as those next 

to developed recreation sites, private homes or communities, paved 

and passenger car level roads and trails; (d) Highest emphasis for 

slash treatment, temporary road closures and road 

decommissioning will be placed on foreground (up to 300 feet) of 

developed recreation sites, private homes or communities, and 

concern level 1 roads (paved roads and passenger car level roads) 

and trails, especially those designated as national scenic, historic or 

recreation trails; (e) Log landings, skid trails and temporary roads 

will be rehabilitated including restoring proper drainage, and 

reseeding as needed with native species; (f) To hasten recovery and 

help eliminate unauthorized motorized and non-motorized use of 

skid trails and temporary roads, use physical measures such as recontouring, pulling slash and rocks across the line, placing cull 

logs perpendicular to the route, and disguising entrances, (g) Avoid 

using FS designated trails as skid trails or for temporary roads, 

(h) National Scenic, Historic, and Recreation Trails as well as 

forest system trails (motorized and non-motorized) will not be used 

for temporary roads or skid trails. It is acceptable to make 

perpendicular trail crossings. The locations of crossings will be 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

652 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

designated. Trail crossings will be restored to pre-project condition 

after use, (i) Crossing of the Arizona Trail will be done sparingly 

and only if no other alternative exists. These crossing locations will 

be coordinated with District Recreation Staff; and, (j) Large, 

upright trail cairns used on Beale Wagon Road and Overland Trail 

must be protected. Locate cairns ahead of time. Logging operations 

will not damage the cairns.

RS4 Cull Logs, Stump Heights, and Slash Treatments: Cull logs 

would not be abandoned on landings. Use cull logs for closing 

temporary roads and decommissioning roads. Cull logs may also 

be suitable to use as down woody material, but must be scattered 

away from the landings. Stump heights should be cut as low as 

possible, with a maximum height of 12 inches. In the foreground of 

sensitive roads, trails, recreation sites, private homes/ communities, 

strive to make stump heights 6 inches or lower, with 12 inch 

heights as the exception, and rarely occurring. Slash must be 

treated or removed. In the seen area immediate foreground of 

sensitive places (within 300 feet of the centerline of concern level 1 

roads or trails, or 300 feet from the boundary of a recreation site or 

private land/communities). Where whole tree logging occurs, 

machine piling may occur to the back of log landings. Prioritize 

slash burning in these locations within one year or as soon as 

possible after treatment.

If conventional logging is used and trees are delimbed and topped 

in the forest, machine piled slash should be placed at least 300 feet 

away from the centerline of roads and trails, developed recreation 

sites, or private land/communities. In these instances, piles should 

be burned as soon as possible or within 3 years. Root wads and 

other debris in sensitive foreground areas would be removed, 

buried, burned, or chipped. If materials are buried, locate in 

previously disturbed areas where possible. Beyond sensitive 

immediate foreground areas, it is acceptable to scatter these or use 

them to help close temporary roads or skid trails. If slash is not 

removed in grassland treatment areas, it is acceptable to create 

machine piles 300 feet away from the centerline of sensitive roads 

and trails, developed recreation sites, and private 

land/communities. Place project-generated slash outside of 

X X Compliance with forest plans.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 653
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

permitted utility line and pipeline rights-of-way; do not interfere 

with utility corridor management.

RS5 Fire Control Lines: (1) Generally restore control lines to a near 

undisturbed condition in the foregrounds (within 300 feet) of 

sensitive roads, trails, and developed recreation sites, (2) To hasten 

recovery and help eliminate unauthorized motorized and 

nonmotorized use of control lines in these areas, use measures such 

as recontouring, pulling slash and rocks across the line, and 

disguising entrances, and (3) Do not use motorized equipment on 

national scenic, historic and recreation trails, or other forest system 

trails if these are used for control lines. Coordinate with the district 

recreation staff regarding use of national trails as control lines.

X X Compliance with forest plans.

RS6 Coordinate with landscape architect prior to implementing 

jackstraw, spring, and road restoration treatments. Do not 

implement jack straw treatments within 1,000 feet of the Arizona 

Trail. Also see SW37 and T8.

X X Maintain scenic integrity.

RS7 Recreation and Other Trail Mitigation:

Recreation Sites: (i) Proposed mechanical treatments and 

prescribed fire adjacent to developed recreation sites must be 

reviewed and approved by the district ranger. Treatments may 

occur within Ten-X, Kaibab Lake and White Horse Lake 

Campgrounds. Work with the district recreation staff to determine 

boundaries or no treatment zones around constructed features that 

need to be protected in the campgrounds. Treatments around the 

perimeter of the campgrounds are encouraged. The timing of 

treatments must be worked out with districts. Treatment would 

generally occur in fall, winter, or spring. Activity slash must be 

piled in agreed upon locations, and treated as soon as possible. If 

campgrounds remain open into fall and winter, provide information 

about upcoming closures and management activities onsite, at FS 

offices, and FS Web sites.

Thinning and burning is appropriate at Garland Prairie Vista and 

Oakhill Snowplay Area, but constructed features must be protected 

from damage. Work with the district recreation staff to establish 

boundaries to protect constructed features. 

Provide public notice and information about treatment locations, 

X X Compliance with forest plans, 

inform public, and reduce 

impacts to recreational 

opportunities.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

654 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

timing, and the type of treatment occurring prior to and during 

vegetation and fire treatments.

(i) Consider use of a hotline or link on our Web pages that would 

indicate closures or hazards that may be encountered, also use 

media and make sure frontliners are well informed about activities 

occurring on the districts and forests.

(a) Place warning signs on all trail access points and along trails 

where treatment activities are occurring. It is also appropriate to 

place warning signs at developed recreation sites to inform 

visitors.

(b) When mechanical treatment and burning are occurring along 

open trails, slash will be pulled back immediately within 100 feet 

of the centerline of the trail corridor.

(c) If trails are temporarily closed due to harvesting, the trail tread 

will be cleared of all slash.

(d) Character trees that have unique shape or form along the 

Arizona Trail should be retained where feasible within the 

applicable prescription. Avoid lines of trees; strive to achieve a 

grouped appearance to avoid abrupt changes in the landscape 

character along the trail corridor.

(e) Implement road closures, one-way traffic, and area closure 

restrictions as deemed necessary by forest officials for health and 

safety concerns during any operation.

(f) Work with District Recreation specialists to ensure well 

marked and publicized detour routes for the Arizona Trail during 

operational closures within the project, and

(g) Prohibit treatment activities in specifically designated units 

and the forest system roads associated with these units during 

times of highest recreation use. The highest recreation use and 

associated traffic occurs during the weeks of Federal observed 

Memorial Day, July 4th, and Labor Day.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 655
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

RS8 In Semiprimitive Nonmotorized recreation opportunity 

spectrum classes specifically (occurring on about 7 percent of the 

approximately 598,764 acres): (a) Temporary roads should not 

generally be built. If they are used, they would be restored to 

original conditions when projects are completed, (b) Strive to make 

stump heights 6 inch or lower, with 12 inch heights the exception, 

and rarely occurring, (c) Slash must be treated or removed in these 

areas, and (d) Use existing barriers (roads) and natural barriers as 

control lines whenever possible.

X Compliance with forest plans.

RS9 Cave and karst protection, see W40 X Compliance with forest plans.

RS10 See SW21, SW37, W46, and W47 for additional fence mitigation. X 

Silviculture – See Appendix D, Implementation Plan

Soils and Watershed

SW1 Implement best management practices prior to project 

implementation.

X Minimize impacts to soil and 

water resources from project 

implementation, to minimize 

nonpoint source pollution, to 

adhere to the Clean Water Act, 

and to adhere to the 

intergovernmental agreement 

between the Southwestern 

Region of the Forest Service and 

the ADEQ.

SW2 Minimize mechanical operations when ground conditions are such 

that soil compaction can occur. All activities should be 

limited/restricted to when soils are dry or frozen. If compaction 

occurs, mitigate through ripping, seeding, and covering compacted 

areas with slash.

X Minimize soil compaction, soil 

detachment, and sediment 

transport. To maintain long term 

soil productivity.

SW3 All fueling of vehicles would be done on a designated protected, 

upland site. If more than 1,320 of gallons of petroleum products are 

to be stored onsite above ground or if a single container exceeds 

660 gallons, then a spill prevention control and countermeasures 

plan (SPCC) would be prepared as per 40 CFR 112.

X Prevent contamination of waters 

from accidental spills.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

656 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW4 The following applies to any personnel implementing grounddisturbing actions: Prior to moving off-road equipment onto a 

project area, contractor shall identify the location of the 

equipment’s most recent operation. Contractor shall not move any 

off-road equipment that last operated in an area infested with one 

or more invasive species of concern onto the sale area without 

having cleaned such equipment of seeds, soil, vegetative matter, 

and other debris that could contain or hold seeds, and having 

notified the Forest Service, as provided in (iii). If the location of 

prior operation cannot be identified, then contractor shall assume 

that the location is infested with invasive species of concern. If the 

contractor has worked in areas where potential chytrid fungus 

could occur, contractor shall assume chytrid fungus is present and 

must disinfect equipment prior to work adjacent to water bodies.

(i – intentionally omitted)

(ii) Prior to moving off-road equipment from a cutting unit or 

cutting area that is shown on contract area or sale area map to be 

infested with invasive species of concern to, or through any other 

area that is shown as being free of invasive species of concern, or 

infested with a different invasive species, contractor shall clean 

such equipment of seeds, soil, vegetative matter, and other debris 

that could contain or hold seeds and/or disinfect as necessary, and 

shall notify the Forest Service, as provided in (iii).

(iii) Prior to moving any off-road equipment subject to the cleaning 

and disinfecting requirements set forth above, contractor, shall 

advise the Forest Service of its cleaning measures and make the 

equipment available for inspection. Forest Service shall have 2 

days, excluding weekends and Federal holidays, to inspect 

equipment after it has been made available. After satisfactory 

inspection or after such 2-day period, contractor may move the 

equipment as planned. Equipment shall be considered clean when a 

visual inspection does not disclose seeds, soil, vegetative matter, 

and other debris that could contain or hold seeds. Contractor shall 

not be required to disassemble equipment unless so directed by the 

Forest Service after inspection.

X Minimize the spread of 

nonnative species.

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Coconino and Kaibab National Forests 657
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

(iv) If contractor desires to clean off-road equipment on national 

forest land, such as at the end of a project or prior to moving to, or 

through an area that is free of invasive species of concern, 

contractor shall obtain prior approval from contracting officer as to 

the location for such cleaning and measures, if any, for controlling 

impacts.

SW5 If construction crews are to live onsite, then an approved camp and 

suitable sanitation facilities must be provided.

X Protect surface and subsurface 

water from unacceptable levels 

of bacteria, nutrients, and 

chemical pollutants.

SW6 On areas to be prescribed burned, fire prescriptions should be 

designed to minimize soil temperatures over the entire area. High 

severity fire should occur on no more than 10 percent of the 

treatment area. Fire prescriptions should be designed so that soil 

and fuel moisture temperatures are such that burn severity is 

minimized and soil health and productivity are maintained. If 

containment lines are put in place, rehabilitate lines after use by 

either rolling berm back over the entire fire line, spreading slash 

across the fire line, or waterbarring the fire line. If line is only to be 

waterbarred, disguise the first 400 feet of line to discourage use as 

a trail.

X X Maintain long term soil 

productivity and minimize 

sediment delivery from 

containment lines.

SW7 On areas to be prescribed burned, manage for 5–7 tons per acre of 

coarse woody debris in ponderosa pine on the Coconino NF and 3-

10 tons per acres in ponderosa pine on the Kaibab NF to maintain 

long term soil productivity outside of the buffers around private 

land. Within the pinyon-juniper cover type, snags would be 

managed for one per acre over 75 percent of the area and coarse 

woody debris would be managed for an after-treatment average of 

1–3 tons per acre (Huffman personal communication 2012). Where 

available, a portion of the coarse woody debris in pinyon-juniper 

would include two logs greater than or equal to10 inch and greater 

than or equal to10 feet in length.

X X Maintain long term soil 

productivity.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

658 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW8 On areas to be prescribed burned, establish filter strips (also known 

as streamside management zones). These stream reaches would be 

designated as protected stream courses. The following are 

recommendations to protect stream courses.

Riparian stream course:

• Severe erosion hazard: 120 feet on each side of stream course.

• Moderate erosion hazard: 100 feet on each side of stream course.

• Slight erosion hazard: 70 feet on each side of stream course.

Nonriparian stream course:

• Severe erosion hazard: 100 feet on each side of stream course.

• Moderate erosion hazard: 70 feet on each side of stream course.

• Slight erosion hazard: 35 feet on each side of stream course.

Do not ignite fuels within this buffer area. Some creep may occur 

into the buffer (also see SW31).

X Minimize sediment and/or ash 

delivery into drainages and 

maintain water quality.

SW9 All burning will be coordinated daily with the Arizona Department 

of Environmental Quality (ADEQ). Burning will not take place on 

any portion of the project without prior approval from ADEQ. 

Coordination with ADEQ will take place through the Kaibab and 

Coconino National Forest Zone Dispatch Center and the Prescribed 

Burning Boss.

X To ensure that smoke 

management objectives are met.

SW10 Complete all required permitting (404 permits) and Water Quality 

Certification (if necessary), prior to project implementation.

X To comply with Clean Water 

Act provisions.

SW11 Site rehabilitation on upland sites for stream channel and road 

rehabilitation projects where ground disturbance occurs: seed at 5 

pounds per acre with native, certified weed-free seed mix. Potential 

vegetation for individual sites should utilize the Kaibab and 

Coconino NFs TES to identify species to be utilized. Where

feasible, protect site with slash spread across the disturbed area to 

create microclimates and protect from grazing ungulates.

X X To minimize soil erosion and 

minimize noxious weed spread.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 659
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW12 Site rehabilitation on riparian sites for stream channel and road 

reconstruction projects where ground disturbance occurs: seed at 5 

pounds per acre with certified weed-free native seed mix to 

rehabilitate the site and minimize impacts of noxious weeds. 

Potential vegetation for individual sites should utilize the Kaibab 

and Coconino NFs TES to identify species to be utilized. Where 

feasible, protect site with a variety of methods (e.g., ungulate proof 

fence, spreading slash, etc.).

X X To comply with State and 

Federal water quality standards 

by minimizing soil erosion 

through the stabilizing influence 

of vegetation ground cover. 

Minimize noxious weed spread.

SW13 Install silt fences and/or waddles downstream from grounddisturbing activities in stream channels to minimize the chance of 

sediment being lost downstream during construction and until 

revegetation is completed.

X Comply with State and Federal 

water quality standards by 

minimizing soil erosion through 

the stabilizing influence of 

vegetation ground cover. 

Minimize noxious weed spread.

SW14 Provide site protection on newly disturbed soils (e.g., hydromulch, 

erosion mat, spread slash, etc.) in channel restoration and road 

reconstruction sites on all sites as needed and where feasible.

X To comply with State and 

Federal water quality standards 

by minimizing sediment 

delivery to drainages, minimize 

impacts on severe erosion 

hazard soils, to create 

microclimate for regeneration of 

grass/forb community, and 

minimize noxious weed spread.

SW15 Bring rock material from a local upland site to any headcut drop 

structures that may be installed in channel restoration projects.

X Minimize disturbance in 

drainage systems and minimize 

sediment production within 

channel.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

660 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW16 Site rehabilitation on disturbed sites and stream channel shaping on 

previously decommissioned roads: site rehabilitation consists of 

several revegetation methods, such as, but not limited to: (1) Store 

sod removed from the initial ground disturbance and replace the 

sod from the top of the bank on the disturbed site; (2) Seed with a 

native seed mix (see BMPs above); (3) Protect site with slash 

spread across the disturbed area to create microclimates and protect 

from grazing ungulates. Slash placement would be limited to the 

upper two-thirds of the bank to limit transport downstream of 

woody material; (4) Fence out ungulates for 1 to 2 years (or until 

the site has reestablished); (5) consider the use of mycorrhizal 

inoculum on severely disturbed sites where no topsoil is left; and 

(6) install erosion mat.

X X Comply with State and Federal 

water quality standards by 

minimizing soil erosion through 

the stabilizing influence of 

vegetation ground cover. 

Minimize noxious weed spread.

SW17 Do not borrow road fill or embankment materials from the stream 

channel or meadow surface on road maintenance projects. Endload all material hauled onsite and compact fill.

X Minimize disturbance in 

drainage systems and minimize 

sediment production within 

channel.

SW18 Where feasible, relocate roads out of filter strips into an upland 

position. If this is not feasible, use riprap or velocity checks to 

stabilize or disperse outfall on road maintenance projects when 

roads are located within filter strips.

X Minimize sediment delivery into 

drainage, minimize disturbance 

in drainage systems, and 

minimize sediment production 

within channel.

SW19 At riparian stream reach restoration sites, restore riparian 

dependent grasses through (1) seeding of native species and (2) 

planting plugs of rushes, sedges, and spike rushes to improve 

success of regeneration efforts. Fence with ungulate proof fencing 

for 1 to 2 years (or until plants are established) if grazing is 

inhibiting regeneration efforts.

X Comply with State and Federal 

water quality standards by 

minimizing soil erosion through 

stabilization of ground cover. 

Minimize noxious weed spread.

SW20 On areas that have had roads previously decommissioned and the 

remaining roadbed will be removed, add slash/or erosion mat and 

seed to the disturbed areas.

X Add surface roughness a to 

comply with State and Federal 

water quality standards by 

minimizing soil erosion through 

stabilization of ground cover 

and to diminish the impact of 

the first rain event and to speed 

recovery of the site.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 661
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW21 As a condition of approval for use of a temporary road within a 

Timber Sale Contract or Stewardship Contract, temporary roads 

will be decommissioned by the purchaser/contractor immediately 

after use using the adaptive management actions listed in appendix

A of the Transportation Specialist Report and BMPs for 

rehabilitation of ground disturbed sites in the soils design feature 

section.

X To restore to desired conditions 

and ensure that temporary roads 

do not become de facto new 

roads.

SW22 Do not allow or approve new temporary road construction in filter 

strips. If feasible, avoid new temporary road locations in severe 

erosion hazard soils. If necessary to have a temporary road on 

severe erosion hazard soils, utilize BMPs outlined in the Soil and 

Water section to avoid affects from severe erosion hazard soils.

X To minimize adverse 

environmental effects within 

stream filter strips and on severe 

erosion hazard soils.

SW23 At spring restoration sites, restore riparian dependent species 

through (1) seeding of native species and (2) planting 

plugs/cuttings of native plants to improve success of regeneration 

efforts. Fence with ungulate proof fencing for 1 to 2 years (or until 

plants are established) if grazing is inhibiting regeneration efforts. 

See W46 and W47 for additional fence mitigation.

X Comply with State and Federal 

water quality standards by 

minimizing soil erosion through 

stabilization of ground cover. 

Minimize noxious weed spread.

SW24 Do not blade roads when the road surface is too dry. If the road 

surface is too dry, a water truck can apply water or the project can 

be scheduled for when adequate moisture occurs to complete the 

project.

X Minimize sediment detachment 

and to minimize impacts on 

severe erosion soils.

SW25 In grassland restoration sites, limit skidding and designate skid 

trails if wood is to be removed. Where material is not to be 

removed, do not skid logs in meadows, and lop and scatter is the 

preferred method of treating slash. Do not machine pile within 

meadows. If skidding has to occur across a riparian or nonriparian 

stream course, designate any crossing prior to skidding.

X Minimize impacts to streams 

and soils in meadows from tree 

harvesting operations.

SW26 Skid trails and decommissioned roads would have slash placed on 

the trail or cross-ditched (waterbarred) to break the energy flow of 

water. Placing slash on skid trails is the preferred method to 

dissipate the energy flow of water. Waterbars are only to be 

implemented with equipment with an articulating blade (no 

skidders) or by hand.

X Minimize soil erosion and 

maintain soil productivity. 

Minimize impacts on severe 

erosion soils.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

662 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW27 Landing locations will be in upland positions out of meadows and 

riparian and nonriparian filter strips.

X Minimize sediment delivery into 

drainage and minimize impacts 

on severe erosion soils.

SW28 Mechanical harvest or mechanical fuel treatment are only allowed 

on cinder cones greater than 25 percent slope with designated skid 

trails and slash mats placed on the skid trails. On other sites, 

mechanized harvesting can occur up to 40 percent slopes.

X - Coconino 

NF only

Maintain long term soil 

productivity on slopes with 

severe erosion hazard potential.

SW29 Designated skid trails and log landings would be required within 

the Integrated Resource Service Contract (IRCS) (BMP 24.18 in 

FSH 2509.22) on all cutting units. Skid trail design should not have 

long, straight skid trails that would direct water flow. Skid trails 

should also be located out of filter strips (exceptions are at 

approved crossings).

X Minimize the number of acres 

disturbed and minimize impacts

on severe erosion soils.

SW30 Felling to the lead would be required within the integrated resource 

service contract to minimize ground disturbance from skidding 

operations (BMP 24.18).

X Felling of timber should be done 

to minimize ground disturbance 

from skidding operations and to 

minimize impacts on severe 

erosion soils.

SW31 The integrated resource service contract outlines the timing and 

application of erosion control methods to minimize soil loss and 

sedimentation of stream courses. Seed mix can include any of the 

following certified weed-free native species at a minimum of 5 

pounds per acre pure live seed. Potential vegetation for individual 

sites should utilize the Kaibab and Coconino NFs’ TES to identify 

species to be utilized. Corresponding BMPs from FSH 2509.22 to 

minimize soil loss and sedimentation include 24.13, 24.21, 24.22, 

24.23, 24.24, and 24.25. The preferred erosion control method on 

the skid trails in the harvest areas would be by spreading slash. 

Other acceptable erosion control measures include, but are not 

limited to, waterbarring (waterbars should not be more than 2 feet 

deep and need at least a 10 feet leadout). Waterbars are only to be 

implemented with equipment with an articulating blade (no 

skidders) or by hand to remove berms, seed, mulch, and cross-rip. 

Erosion control after skidding operations must be timely to 

minimize the effects of log skidding.

X Minimize soil loss and 

sedimentation of stream courses 

from skidding operations. 

Minimize noxious weed spread 

and reestablish native 

vegetation. Minimize impacts 

on severe erosion soils.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 663
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW32 Road drainage is controlled by a variety of methods (BMP 41.14) 

including rolling the grade, insloping, outsloping, crowning, water 

spreading ditches, and contour trenching. Sediment loads at 

drainage structures can be reduced by installing sediment filters, 

rock and vegetative energy dissipaters, and settling ponds. Design 

of roads is included in the transportation plan of the IRSC and Tspecs.

X Minimize soil movement, 

maintain water quality, and 

minimize impacts on severe 

erosion soils.

SW33 Road maintenance (BMP 41.25) through the integrated resource 

service contract should require pre-haul and post-haul maintenance 

on all roads to be used for haul.

X To minimize soil movement, 

maintain water quality, and to 

minimize impacts on severe 

erosion soils.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

664 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW34 The designation of filter strips (also known as streamside 

management zones) minimizes onsite soil movement from timber 

harvest activities along stream courses (BMP 24.16). These stream 

reaches will be designated as protected stream courses.

Locations of protected stream courses are included in the 

individual task order maps and will be designated with a protected 

stream course designation. The following are recommendations to 

protect stream courses within the proposed tree harvest units in 

relation to riparian and nonriparian stream courses. The guidelines 

for filter strip designation are as follows:

Riparian stream course:

• Severe erosion hazard: 120 feet on each side of stream course.

• Moderate erosion hazard: 100 feet on each side of stream course.

• Slight erosion hazard: 70 feet on each side of stream course.

Nonriparian stream course:

• Severe erosion hazard: 100 feet on each side of stream course.

• Moderate erosion hazard: 70 feet on each side of stream course.

• Slight erosion hazard: 35 feet on each side of stream course.

Accepted harvest activities within riparian and nonriparian filter 

strips include mechanical and conventional tree felling and limited 

skidding on designated skid trails and not across stream courses. 

Landings, decking areas, machine piles, and roads (except at 

designated crossings) are planned outside of riparian and 

nonriparian filter strips.

X Filter sediment and/or providing 

bank stability on all stream 

courses and to minimize impacts 

on severe erosion soils. To 

implement the Oak Creek E. 

Coli TMDL and Lake Mary 

Region Mercury TMDL and to 

filter sediment and/or provide 

bank stability.

SW35 Manage for 5 to 7 tons (forest plan consistency) per acre of coarse 

woody debris in ponderosa pine sites that will be left on-site on all 

cutting unit sites except in areas of identified wildland-urban 

interface treatments. Within the pinyon-juniper cover type maintain 

the following where possible: 1 snag per acre and 1 to 3 tons of 

coarse woody debris (CWD) per acre (specialist recommendation). 

Where available, a portion of the coarse woody debris would 

include two logs greater than or equal to10 inches and greater than 

or equal to 10 feet in length (specialist recommendation).

X Promote long term soil 

productivity.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 665
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW36 Mechanical crushing of lopped slash can only occur on 0–25 

percent slopes.

X Incorporate slash into the soil to 

promote long term soil 

productivity.

SW37 Identify landings, staging area for heavy equipment, and sites for 

any in-woods processing sites outside of filter strips and meadows. 

Sites would be rehabilitated after use by methods such as, but not 

limited to: (1) ripping to remove compaction, (2) seeding with 

certified weed-free native seed to 5 pounds per acre. Potential 

vegetation for individual sites should utilize the Kaibab and 

Coconino NFs’ TES to identify species to be utilized, and (3) 

spreading of slash to disguise the site and provide for a mulch for 

seeds.

X Minimize and mitigate impacts 

from activities that compact 

sites, restore long term soil 

productivity, and minimize 

impacts on severe erosion soils.

SW38 Within the pinyon-juniper cover type, snags would be managed for 

1 per acre over 75 percent of the area and coarse woody debris 

(CWD) would be managed for an after treatment average of 1 to 3 

tons per acre. Where available, a portion of the coarse woody 

debris would include two logs greater than or equal to 10 inches 

and greater than or equal to 10 feet in length (Huffman per. Com 

from Brewer, 2008).

X To promote long-term soil 

productivity.

SW39 Provide soil and site protection on newly disturbed soils located on 

temporary roads on soils with severe erosion hazard as needed. 

Avoid locating temporary roads on soils with severe erosion 

hazard. Where unavoidable, provide soil protection through 

implementation of any of the following methods to control 

sediment and protect water quality.

Methods may include, but are not limited to: wattling, 

hydromulching, straw or woodshred mulching, spread slash, 

erosion mats, terraces, blankets, mats, silt fences, riprapping, 

tackifiers, soil seals, seeding and side drains, and appropriately 

spaced water bars or water spreading drainage features. Temporary 

roads will be decommissioned and footprint obliterated and 

protected with any of the above methods.

To protect long-term soil 

productivity and water quality

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

666 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

SW40 Defer mechanical thinning and prescribed fire activities in the Slide 

Fire (perimeter) until 5 years after the signed decision at the 

earliest. 

X X To minimize impacts to Oak 

Creek (Arizona Unique Water) 

from sediment. This BMP will 

allow for adequate post-fire 

recovery of soil and vegetation 

resources and minimize the 

cumulative effects from the fire

SW41 Defer mechanical thinning and prescribed fire activities within the 

Slide Fire perimeter until adequate vegetative ground cover (plant 

litter, duff and basal area) is present (minimum of about 60 percent 

in ponderosa pine vegetation types) to filter and reduce sediment 

delivery into streamcourses.

X X To minimize impacts to the 

water quality of West Fork of 

Oak Creek and Oak Creek 

(Arizona Unique Water) from 

sediment. The BMP will assure 

streamside management zone is 

capable of filtering into 

connected perennial waters 

downstream.

SW42 Within the pinyon-juniper cover type, snags would be managed for 

1 per acre over 75 percent of the area and coarse woody debris 

(CWD) would be managed for an after treatment average of 1 to 3 

tons per acre. Where available, a portion of the coarse woody 

debris would include two logs greater than or equal to 10 inches 

and greater than or equal to 10 feet in length (Huffman per. Com 

from Brewer, 2008).

X To promote long-term soil 

productivity

SW43 Provide soil and site protection on newly disturbed soils located on 

temporary roads on soils with severe erosion hazard as needed. 

Avoid locating temporary roads on soils with severe erosion 

hazard. Where unavoidable, provide soil protection through 

implementation of any of the following methods to control 

sediment and protect water quality. Methods may include, but are 

not limited to: wattling, hydromulching, straw or woodshred 

mulching, spread slash, erosion mats, terraces, blankets, mats, silt 

fences, riprapping, tackifiers, soil seals, seeding and side drains, 

and appropriately spaced water bars or water spreading drainage 

features. Temporary roads will be decommissioned and footprint 

obliterated and protected with any of the above methods.

X To protect long-term soil 

productivity and water quality

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 667
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

Transportation

T1 Utilize accepted engineering practices and manual direction for 

maintenance and reconstruction practices.

X Maintain a safe and economic 

road system.

T2 Coordinate any road use in association with the El Paso and 

Transwestern high-pressure natural gas pipelines. Hauling can 

occur at designated crossings with sufficient pad material. No 

hauling is proposed down these gas pipelines on Forest Roads 160, 

796, 6796, 09007P, 09008P, 09228D, 09229Y, and 09231Q.

X Prevent damage to high-pressure 

gas pipelines.

T3 On areas to be prescribed burned, if decommissioned roads are to 

be used as fire lines, return decommissioned roads to that condition 

post-burning. Rehabilitation of the surface should refer to the soil 

and water BMPs for rehabilitation of fire lines and disturbed areas.

X Discourage use on previously 

decommissioned roads and 

maintain a safe and economic 

road system.

T4 Utilize road safety signage with any project road activities that are 

related to project implementation.

X Provide for user safety.

T5 See SW22

T6 Utilize the closest material source that has the specified material 

type for all road maintenance/reconstruction/relocation to projects.

X Minimize energy use for road 

maintenance/reconstruction/relo

cation activities.

T7 Road maintenance through the timber sale contract or stewardship 

contract should require pre-haul and post-haul maintenance on all 

roads to be used for haul.

X Provide for a safe travel surface 

and provide for access to the 

project area.

T8 Utilize mitigation measures for soil and water, recreation, cultural 

resources, timber/silviculture, wildlife and botany/noxious weeds 

in project design to minimize resource impacts from the 

transportation system. Work with landscape architect to design

structures that reduce impacts to scenic quality.

X Minimize resource impacts from 

the transportation system.

T9 As a condition of approval for use of a temporary road within a 

Timber Sale Contract or Stewardship Contract, temporary roads 

will be decommissioned by the purchaser/contractor when 

mechanical treatments are finished using the adaptive management 

actions listed in appendix A of the Transportation Report. 

X X To restore to desired conditions 

and ensure that they do not 

become de facto new roads.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

668 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

T10 Do not allow or approve new temporary road construction in filter 

strips. If feasible, avoid new temporary road locations in severe 

erosion hazard soils. If necessary to have a temporary road on 

severe erosion hazard soils, utilize BMPs outlined in the Soil and 

Water section to avoid affects from severe erosion hazard soils.

X X To minimize adverse 

environmental effects within 

stream filter strips and on severe 

erosion hazard soils.

T11 Temporary roads locations should be located in existing openings 

out of filter strips and avoid removal of trees where feasible. If 

trees need to be removed, avoid old and large trees and oaks and 

aspen trees where feasible.

X X To minimize adverse effects to 

tree structure, filter strips and 

minimize road disturbance from 

temporary roads and need for 

fills in stump holes.

Wildlife

W1 Coordinate and implement management activities within PACs to 

reduce potential disturbance and minimize the frequency and 

duration of operations within and immediately adjacent to these 

areas.

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W2 Survey all potential spotted owl areas including protected, 

restricted, and other forest and woodland types within the 

implementation area plus the area 1/2 mile beyond the perimeter of 

the proposed treatment area.

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W3 Establish a protected activity center at all new Mexican spotted owl 

sites located during project surveys.

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W4 If new PACs are established in areas with planned or ongoing 4FRI 

activities then existing design features would apply to management

activities. 

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 669
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W5 All contractors associated with thinning and burning activities, 

transportation of equipment and forest products, research, or 

restoration activities would be briefed on the Mexican spotted owl, 

know to report sightings and to whom, avoid harassment of the 

owl, and are informed as to who to contact and what to do if an owl 

is incidentally injured, killed, or found injured or dead on the 

Coconino and/or Kaibab NF.

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W6 Meet annually with the U.S. Fish and Wildlife Service to discuss 

planned management activities, review past activities in Mexican 

spotted owl habitats, and report any known incidental take in the 

project area. These results will also be provided in a written annual 

report. 

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W7 Develop and implement a monitoring plan in coordination with the 

U.S. Fish and Wildlife Service designed to evaluate the effects of 

thinning and prescribed fire on owls as described in the Mexican 

spotted owl Recovery Plan (see appendix E).

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W8 Trees greater than 24 inch d.b.h. would not be harvested in 

Mexican spotted owl restricted and protected habitat.

X To minimize adverse effects to 

Mexican spotted owl habitat 

while restoring Mexican spotted 

owl habitat, contribute towards 

the recovery of the owl, and 

meet forest plan (ESA) 

compliance.

W9 Pre-and post-treatment habitat monitoring would occur in Mexican 

spotted owl restricted and protected habitat to ensure retention or 

development of desired habitat conditions (see appendix E).

X To minimize adverse effects to 

Mexican spotted owl habitat 

while restoring Mexican spotted 

owl habitat, contribute towards 

the recovery of the owl, and 

meet forest plan (ESA) 

compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

670 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W10 In Mexican spotted owl PACs, spring restoration would not occur 

during the breeding season (March 1 to August 31), if occupied, in 

Rocktop, Sawmill Spring, Red Raspberry and Weimer Spring 

PACs (i.e., 5 out of 74 proposed spring restoration sites would be 

affected).

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W11 In Mexican spotted owl PACs, ephemeral stream restoration would 

not occur during the breeding season (March 1 to August 31), if 

occupied, in Bear Seep, Clark, Holdup, Coulter Ridge and Meadow 

Tank Mexican spotted owl PACs.

X To minimize adverse effects to 

Mexican spotted owls while 

restoring Mexican spotted owl

habitat, contribute towards the 

recovery of the owl, and meet 

forest plan (ESA) compliance.

W12 In Mexican spotted owl PACs, temporary road construction, 

obliteration, relocation, and maintenance would not occur during 

the breeding season (March 1 to August 31) if occupied.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W13 In Mexican spotted owl PACs, no treatments would occur in PACs 

during the breeding season (March 1 to August 31) if occupied.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W14 In Mexican spotted owl PACs, hauling would generally avoid 

PACs during the breeding season (March 1 to August 31) unless 

specific analysis has documented that impacts would not lead to 

adverse effects. If hauling does occur in a PAC during nesting 

season vehicles would remain greater than or equal to 0.25 miles 

from cores areas unless topographic features would reduce noise; 

trucks would drive less than or equal to 25 miles per hour in PACs.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W15 In Mexican spotted owl PACs, no new wire fencing would be 

constructed in PACs to minimize the risk of owls colliding with 

new fences. Other alternatives would be used for aspen, seep, 

spring and ephemeral drainage restoration exclosures. Alternatives 

would be coordinated with other specialists. If suitable alternatives 

cannot be identified restoration work would be postponed.

X To minimize adverse effects to 

Mexican spotted owls and 

contribute towards the recovery 

of the owl while restoring 

Mexican spotted owl habitat.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 671
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W16 In Mexican spotted owl PACs, coordinate burning spatially and 

temporally to limit smoke impacts to nesting owls, particularly for 

PACs with nests in low-lying area (Effective March 1 to August 

31).

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W17 All stands included in the proposed mechanical treatments for 18 

Mexican spotted owl PACs would be marked for harvest by hand 

and marking would be coordinated with the US Fish and Wildlife 

Service.

X To contribute towards the 

recovery of the owl, and 

continue coordination with the 

U.S. Fish and Wildlife Service

during implementation. 

W18 Fireline associated with preventing fire from entering Mexican 

spotted owl PACs and/or core areas would be constructed outside 

the nesting season in alternatives B D and E.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W19 In Mexican spotted owl PACs nest trees would be protected in the 

design and implementation of prescribed fires.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W20 In Mexican spotted owl habitat, burn plans would include 

mitigations to minimize smoke impacts to nesting birds.

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance.

W21 Implementation would be phased in across the landscape so that 

not all Mexican spotted owl habitat would be treated in 1 year

X To minimize adverse effects to 

Mexican spotted owls and meet 

forest plan (ESA) compliance 

while restoring Mexican spotted 

owl habitat.

W22 In Mexican spotted owl PACs, target, threshold, and goshawk postfledging family areas no old trees would be cut during the 

rehabilitation of temporary roads.

X To protect/retain old trees and 

maintain or develop key habitat 

components.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

672 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W23 In northern goshawk nest stands, burn plans covering areas with 

nesting goshawks and/or known nest trees would include 

mitigations to minimize smoke impacts to nesting birds and nest 

trees would be protected

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meet forest 

plan compliance.

W24 Fuels in goshawk nesting areas would be evaluated and, if 

necessary, would be manipulated outside of the breeding period 

(March 1 to September 30) to ensure low severity fire effects from 

prescribed fire.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meeting 

forest plan compliance.

W25 In northern goshawk nest stands mechanical treatments would not 

occur within nest stands, or within replacement nest stands.

X To minimize disturbance to 

goshawks.

W26 In northern goshawk post-fledging family areas (PFAs), harvest 

activities would not occur in occupied PFAs during the breeding 

season unless specific analysis has documented impacts would not 

trend to listing or loss of viability. PFAs can be cleared for 

treatment if pre-treatment surveys determine the area is no longer 

occupied.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

W27 Hauling will not occur within PFAs during the breeding season 

(March 1 through September 30) unless monitoring determines the 

PFA is not occupied. Exceptions are the Devil Dog PFA 

(030701015), Barney PFA (030701011), and Black Mesa Tank 

PFA (030701017) in which there would be no timing restrictions.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

W28 In northern goshawk post-fledging family areas (PFAs), spring and 

ephemeral drainage restoration projects would not occur in the 

Barney Spring, Tree Spring, Schultz Pass, Squaw, Marteen, 

Coxcombs, Pumphouse, Walnut, Faye, Marshall Mesa, Newman, 

Cherry Canyon and Monument 36 PFAs during the breeding 

season (March 1 to September 30) if occupied. However, work 

could potentially occur on an individual basis through coordination 

with the District biologist if specific analysis has documented that 

impacts will not trend to listing or loss of viability.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meeting 

forest plan compliance.

W29 In northern goshawk post-fledging family areas (PFAs), logging 

trucks would not exceed 25 miles per hour when traveling through 

PFAs during the breeding season (March 1 to September 30).

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 673
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W30 In northern goshawk post-fledging family areas (PFAs) road 

construction, obliteration, relocation, and maintenance would not 

occur during the breeding season (March 1 to September 30) if 

occupied.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meeting 

forest plan compliance.

W31 In northern goshawk post-fledging family areas (PFAs) created 

openings would not exceed 2 acres in goshawk PFAs

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

W32 In northern goshawk home range burn units would not include 

more than 5,000 acres of a goshawk pair’s home range as per 

applicable forest plan guidance.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meeting 

forest plan compliance.

W33 In bald eagle winter concentration areas, retain the tallest snags 

greater than 18 inch d.b.h.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat and meeting 

forest plan compliance.

W34 In bald eagle nest sites, no mechanical treatments would occur 

within a 300 foot radius of bald eagle nest trees (there are 3 bald 

eagle nest within 300 feet of the project analysis boundary).

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

W35 In bald eagle nest sites, no vegetation treatments would occur 

within a buffer of up to 1⁄2 mile (2,500 feet), unless mitigated by 

topography, of an occupied bald or golden eagle nest between 

March 1 and August 31 (there are 3 bald eagle nests and 19 golden 

eagle nests within a 1⁄2 mile of the project analysis area). Other 

project activities would be assessed by the district biologist and 

limited activities may be acceptable.

X To minimize disturbance to 

goshawks while restoring 

goshawk habitat.

W36 In bald and golden eagle nest sites burn plans within subunits 1-1, 

1-3, 3-5 and 5-2 would be coordinated with the district wildlife 

biologist to insure nesting eagles would not be adversely impacted 

from smoke.

X To minimize disturbance to 

eagles while restoring forest 

habitat.

W37 In bald eagle winter roost sites, no mechanical treatments would 

occur around confirmed bald eagle roost sites (300 feet radius 

around roosts on the Coconino NF and a 10 chain radius on the 

Kaibab NF).

X To minimize disturbance to 

eagles while restoring forest 

habitat and meeting forest plan 

compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

674 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W38 In bald eagle communal roost sites, no project activities would 

occur within 500 feet of confirmed bald eagle communal roosts 

from October 15 – April 15.

X To minimize disturbance to 

eagles while restoring forest 

habitat and meeting forest plan 

compliance.

W39 In bald eagle winter concentration areas, retain the tallest snags 

with diameters greater than or equal to 18 inches.

X To minimize disturbance to 

eagles while restoring forest 

habitat and meeting forest plan 

compliance.

W40 All contractors would be instructed to avoid interacting with 

condors and to immediately contact the appropriate FS personnel if 

occurs in the project area. Sighting locations would be forwarded 

to the Peregrine Fund and the U.S. Fish and Wildlife Service. 

X To minimize adverse effects to 

condors, contribute towards the 

recovery of the species, and 

meet forest plan compliance.

W41 Any project activity that may cause imminent harm to condors 

would temporarily cease until permitted personnel determine the 

correct course of action.

X To minimize adverse effects to 

condors, contribute towards the 

recovery of the species, and 

meet forest plan compliance.

W42 Project-related work areas would be kept clean (e.g., trash disposed 

of, scrap materials picked-up, etc.) in order to minimize the 

possibility of condors accessing inappropriate materials. The FS 

would complete site visits to ensure clean-up is adequate.

X To minimize adverse effects to 

condors, contribute towards the 

recovery of the species, and 

meet forest plan compliance.

W43 A hazardous material spill plan would be developed and 

implemented with details on how each hazardous substance would 

be treated in case of leaks or spills.

X To minimize adverse effects to 

wildlife, including condors, 

contribute towards the recovery 

of the species, and meet forest 

plan compliance.

W44 Pesticide use would follow the guidelines for California condors as 

described in the April 2007 Recommended Protection Measures for 

Pesticide Applications in Region 2 of the U.S. Fish and Wildlife 

Service.

X To minimize adverse effects to 

condors, contribute towards the 

recovery of the species, and 

meet forest plan compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 675
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W45 In turkey foraging and roosting cover, retain medium to high 

canopy cover in ponderosa pine stringers in the pinyon-juniper 

transition zone and retain clumps of large and old trees along 

ridges and slopes above the pine and pinyon-juniper transition 

zone. Target low severity fire to retain yellow pine and roosting 

cover.

X To minimize disturbance to 

turkeys while restoring forest 

habitat and meeting forest plan 

compliance.

W46 No dominant or co-dominant trees would be cut in great blue heron 

rookeries. Nest trees would be prepped prior to implementing 

prescribed fire and ignition mitigations would apply. Timing would 

avoid mechanical tree harvest while birds are in the nest. Activities 

would be coordinated with the local biologist.

X Minimize disturbance to 

rookeries while restoring forest 

habitat.

W47 Forest plan direction would be met for all raptor species (nest 

sites): Raptor nests located during project surveys would be 

monitored prior to project activities. Known nest trees for any 

raptor species would be prepped prior to implementing prescribed 

fire. Forest plan buffers would be provided if nests are active:

Sharp-shinned hawk: no mechanical treatment buffer of 10 acres 

around occupied nests;

Cooper’s hawk: no mechanical treatment buffer of 15 acres around 

occupied nests;

Osprey: no mechanical treatment buffer of 20 acres around nest 

sites (occupied or unoccupied) and all logging activities would be 

restricted within 1⁄4 mile of active nests from March 1 to August 15; 

Use site specific analysis to determine no-treatment zone around 

nest site; restrict activities within 1⁄4 mile of nest sites from March 1 

to August 15; and,

Other raptors: 50 feet buffer around occupied nests would be left 

uncut.

X To minimize disturbance to 

raptors while restoring forest 

habitat and meeting forest plan 

compliance.

W48 In known deer fawning areas defer logging activities between June 

15 and August 31 because of declining trends in populations.

X To minimize disturbance to 

fawns while they are most 

vulnerable, restore forest 

habitat, and meet forest plan 

compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

676 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W49 In pronghorn migration routes on the Williams RD, avoid thinning 

and burning within the known travel way during the first major 

snowfall of a given year to allow for seasonal migration. See 

appendix 8 of the wildlife report.

X Minimize disturbance to 

migrating pronghorn in a key 

movement corridor while 

restoring ecosystem health.

W50 In pronghorn fawning habitat, prescribed fire in Garland Prairie 

would not occur during May when most fawning occurs.

X Minimize disturbance to 

pronghorn fawns when they are 

most vulnerable while restoring 

grassland habitat.

W51 Prairie dog surveys would be completed in documented prairie dog 

towns within treatment areas to determine if towns are active. If 

active towns form a large enough complex to support ferrets, 

black-footed ferret surveys would be completed prior to 

implementation within prairie dog towns. Coordinate with local 

biologists.

X Minimize disturbance to ferrets

if undiscovered populations 

exist in the treatment area, 

increase information on status of 

prairie dogs, and meet forest 

plan (ESA) compliance while 

restoring grassland habitat.

W52 A 300-foot no mechanical treatment buffer would be designated 

around 34 cave entrances and around sink hole rims (i.e., karst) to 

protect cave ecosystems from siltation, protect human health and 

safety, and reduce potential disturbance to roosting bats. Existing 

roads could be used for mechanical harvest but no new skid trails 

would be created. Ignition and other management actions 

associated with prescribed fire would maintain existing vegetation 

patterns and follow forest plan guidance for snags and logs while 

reducing potential for undesirable fire behavior and effects. The 

intent is to avoid changing the cave/karst microclimate, (including 

altering vegetation near the inside and outside of the entrance/rim), 

hydrology, and prevent sedimentation while reducing surface fuels.

X Minimize disturbance to fragile 

ecosystem components, 

maintain biodiversity, and meet 

forest plan compliance while 

restoring ecosystem health.

W53 In tassle-eared squirrel nest stands, operators would avoid felling 

trees with active squirrel nests. Coordinate with local biologists.

X Protect active squirrel nests 

while restoring forest 

conditions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 677
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W54 In northern leopard frog designated occupied/critical breeding sites 

(6 sites), a no-treatment buffer (no thinning, no direct ignition) 1⁄4 

mile distant from tanks or designated along logical topographic 

breaks (appendix 16). In some cases, the district wildlife biologist 

may work with implementation teams to determine the habitat 

protection buffer boundary

X Minimize disturbance while 

restoring forest conditions and 

meeting forest plan compliance.

W55 In northern leopard frog potential breeding sites, seasonal 

restrictions (April 15 through September 15) for all proposed 

activities would be implemented within a 200 feet buffer (or along 

logical topographic breaks) at all designated important water sites

(i.e., 10 sites in restoration unit 1; appendix 16). In some cases, the 

district wildlife biologist may work with implementation teams to 

determine the habitat protection buffer boundary.

X Minimize disturbance while 

restoring forest conditions and 

meeting forest plan compliance.

W56 In northern leopard frog dispersal habitat, a 200-ft protection zone 

(100 feet either side of the stream) would be established around 

designated stream courses (appendix 16). There would be no 

thinning and no direct ignition within the protection zones. 

Designated skid trail crossings through the buffer zone are allowed. 

Fall burning and burn plans should be coordinated with district 

wildlife biologists in Subunits 1-2, 1-4, 1-5 and 1-6.

X Minimize disturbance while 

restoring forest conditions and 

meeting forest plan compliance.

W57 In northern leopard frog designated occupied/ critical breeding 

sites (6 sites) mechanized equipment would avoid wetted soils in 

northern leopard frog habitat unless decontamination practices for 

Chytrid are employed first.

X Minimize disturbance while 

restoring forest conditions and 

meeting forest plan compliance.

W58 In springs identified for restoration, springs would be surveyed for 

northern leopard frogs prior to implementation of restoration 

activities.

X Minimize disturbance while 

restoring springs and spring 

habitat.

W59 Do not use tanks for water sources that are known to have 

populations of northern and Chiricahua leopard frogs as water 

sources for prescribed fire activities. Activities in and around 

natural or constructed waters would use decontamination 

procedures to prevent the spread of chytrid (Bd) fungus and other 

invasive aquatic species, unless an evaluation by a forest biologist 

determines it unnecessary.

X Minimize disturbance while 

managing fire and meeting 

forest plan compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

678 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W60 In Arizona black rattlesnake occupied den sites, avoid management 

practices with potential to cause impacts to hibernacula.

X Minimize disturbance to a key 

habitat component while 

restoring forest conditions and 

meeting forest plan compliance.

W61 In Arizona black rattlesnake occupied den sites, avoid temporary 

road construction within 300 feet of identified hibernacula 

locations.

X Minimize disturbance where the 

species congregates while 

restoring forest conditions and 

meeting forest plan compliance.

W62 Within 1⁄4 mile of Arizona black rattlesnake occupied den sites, 

conduct prescribed fires from November 1 to March 31 (denning 

season) within 1⁄4 mile of den sites to minimize impacts to snakes. 

Avoid prescribed fire within 1⁄4 mile of dens outside the denning 

season.

X Minimize disturbance where the 

species congregates while 

restoring forest conditions and 

meeting forest plan compliance.

W63 Within 1⁄4 mile of Arizona black rattlesnake occupied den sites, 

ignite slash piles in winter or ignite from the exterior, lighting no 

more than a contiguous 25 percent of the pile’s edge to minimize 

impacts to Arizona Black Rattlesnake from April 1 to September 

30.

X Minimize disturbance where the 

species congregates while 

restoring forest conditions and 

meeting forest plan compliance.

W64 Do not create interspaces and openings where hiding cover exists 

near dependable waters identified by the Arizona Game and Fish 

Department (e.g. stock tanks, lakes, and riparian stream reaches) 

and through implementation of watershed BMPs.

X Maintain hiding cover where 

wildlife congregates while 

restoring forest structure.

W65 Snags and Logs: Protect snags and logs wherever possible by 

placing landings in existing openings or in areas where snags 

and/or logs, and old trees would be minimally impacted.

X Maintain key but limited 

wildlife habitat components 

while restoring forest structure 

and meeting forest plan 

compliance.

W66 Snags and Logs: Protect/provide snags and logs wherever possible 

through site prep, implementation planning, green tree selection, 

and ignition techniques to retain greater than 2 snags per acre 

greater than or equal to 30 feet high and greater than or equal to 18 

inch d.b.h. + greater than or equal to 3 logs greater than or equal to 

8 feet long and greater than or equal to 12 inch mid-point diam. + 

5-7 tons of coarse woody debris (greater than 3 inch diameter) per 

acre in pine and pine-oak habitat.

X Maintain key but limited 

wildlife habitat components 

while restoring forest structure 

and meeting forest plan 

compliance.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 679
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W67 Snags: Retain trees greater than or equal to 18 inch d.b.h. with dead 

tops, cavities, and lightning strikes wherever possible to provide 

cavity nesting/foraging habitat (i.e., the living dead) in ponderosa 

pine habitat.

X Maintain key but limited 

wildlife habitat components 

while restoring forest structure.

W68 In pinyon-juniper cover type, snags would be managed for at least 

1 per acre over 75 percent of the area (current direction is 1 per 

acre over 65 percent of the area) and course woody debris would 

be managed for an after treatment average of 1-3 tons per acre. 

Where available, woody debris would include 2 logs greater than 

or equal to 10 inches mid-point diameter and greater than or equal 

to 10 feet in length.

X X Maintain key wildlife habitat 

components while restoring 

forest structure and meeting 

forest plan compliance.

W69 Snags: Emphasize retention of snags exhibiting loose bark to 

provide habitat for roosting bats.

X Maintain a key but limited 

wildlife habitat component 

while restoring forest structure 

and meeting forest plan 

compliance.

W70 Within Group Density (VSS 4-6): Manage mid-aged tree groups 

for a range of density and structural characteristics by thinning 

approximately 50 percent of the mid-aged groups to the lower 

range of desired stocking conditions, approximately 20 percent 

each to the middle and upper range of desired stocking conditions 

and approximately 10 percent remain unthinned.

X Maintain a range of structure 

conditions (i.e., wildlife habitat 

heterogeneity) while restoring 

forests and meeting forest plan 

compliance.

W71 Within Group Structure (VSS 4-6): Enhance and maintain midaged, mature or old group structure by retaining individual and 

clumps of vigorous ponderosa pine seedlings, sapling and poles 

within the larger group

X Maintain a range of structure 

conditions (i.e., wildlife habitat 

heterogeneity) while restoring 

forest conditions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

680 Coconino and Kaibab National Forests 
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W72 For wildlife cover and stand heterogeneity in ponderosa pine cover 

type: Gambel oak, juniper and pinyon species would not be cut 

with the following exceptions: seedling/sapling, young and midaged pinyon and juniper up to 11 inch diameter at the root collar may 

be cut within a 50 foot radius of individual or groups of old 

ponderosa pine (as defined in the old tree implementation strategy); 

and when there is no other option to facilitate logging operations 

(skid trail and landing locations). Gambel oak, juniper and pinyon 

species greater than 5 inch diameter at the root collar (diameter 

root collar) may be considered as residual trees in the target group 

spacing and stocking

Manage for large oaks (10 inch diameter at the root collar or

larger) by removing ponderosa pine up to 18 inch d.b.h. that do not 

meet the “old tree” definition and do not have interlocking crown 

with oaks and occur within 30 feet of base of oak 10 inch diameter 

at the root collar or larger:

In areas of savanna restoration and wildland-urban interface PJ 

mechanical treatment, seedling/sapling, young and mid-aged 

pinyon and juniper may be cut.

X Maintain a range of structure 

conditions (i.e., wildlife habitat 

heterogeneity) while restoring 

forest conditions.

W73 Burn Plans and Ignition Techniques: Apply fire prescriptions to 

maintain forest plan levels of coarse woody debris and to maintain 

the sage in the understory community in pine-sage habitat.

X (coarse 

woody debris) 

X (Sage) Maintain a range of structure 

conditions (i.e., wildlife habitat 

heterogeneity) while restoring 

forest conditions.

W74 Burn Plans: Ensure that the potential cumulative effects of multiple 

fires burning in a given area do not produce negative effects to 

local wildlife; coordinate burning between administrative units and 

between wildlife and fire management to minimize potential 

disturbance.

X Minimize disturbance to wildlife 

while conducting restoration 

activities.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 681
Appendix C – Design Features, BMPs, and Mitigation

Design 

Criteria 

Number Description

Purpose

Comment or Purpose

Forest Plan 

Compliance

Specialist 

Recommendation

W75 Mixed Conifer: 4FRI activities would not include mechanical or 

fire treatments in mixed conifer habitat. Mixed conifer stands 

occurring as inclusions within ponderosa pine forest would not be 

treated, (e.g., nest and roost buffers in Bear Seep and Red 

Raspberry PACs). Similarly, islands of pine occurring within 

mixed conifer forest would not be treated. For example, the 

Mexican spotted owl PAC on Sitgreaves Mtn was dropped from 

treatment consideration; although there are contiguous stands of 

ponderosa pine within the PAC, they are surrounded by mixed 

conifer forest.

X Clarification that restoration 

treatments do not include mixed 

conifer forest. 

W76 The stakeholder-developed old tree protection strategy would be 

incorporated into all action alternatives, the implementation plan 

and the monitoring and adaptive management plans.

X Maintain a key but limited 

wildlife habitat component 

while restoring forest structure.

W77 Defer logging in a 1⁄4 mile radius around known black bear den 

sites from April 15 to June 30.

X Minimize potential for 

disturbance

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

682 Coconino and Kaibab National Forests 
Appendix D – Alternative B through E

Implementation Plan

The environmental impact statement (EIS) describes the purpose and need, alternatives and the 

effects of managing the 4FRI project area. This implementation plan is designed to be integral to 

the selected alternative and record of decision (ROD). 

The implementation plan is designed to be consistent with the Coconino NF and Kaibab NF 

forest plans and with Collaborative Forest Landscape Restoration Act (CFLRA). The 

Collaborative Forest Landscape Restoration Act requires that restoration treatments maintain or 

contribute to the development of old growth components, maximizes the retention of large trees, 

focuses on small diameter tree thinning, does not allow for the establishment of permanent roads, 

and requires decommissioning of all temporary roads built for treatment purposes.

The process described in this appendix describes the linkage from the EIS to the project specific 

work without the need for additional NEPA analysis. It must be considered in conjunction with 

appendix C that provides the design criteria, best management practices, and mitigation measures. 

Table 117 to table 120 are checklists designed to ensure compliance with the analysis, decision, 

and other requirements. Essentially, if the quantity of treatments in table 117 and table 118 by 

resource unit are within the bounds of the treatments analyzed in chapter 3 of the EIS and the 

specialist’s reports, then the program of work is considered to be consistent with the effects 

analysis.

Table 119 and table 120 show the compliance evaluation and documentation requirements to also 

demonstrate this compliance. Sections A through E provide direction that would be used by 

implementation personnel to ensure that implementation meets the purpose and need and forest 

plan standards and guidelines. It is the foundation for the formal silvicultural prescriptions. The 

silvicultural prescriptions would document the desired conditions presented in the analysis, 

incorporate design features and mitigation (appendix C), and provide the course of action needed 

to move toward those desired conditions. 

Description of Plan Components 

Table 117: Annual Implementation Checklist. The checklist is designed to track compliance 

with the NEPA decision and ensure activities are consistent and compliant with the analysis and 

decision (correct location, appropriate number of acres by treatment type). The checklist is 

designed to be used by the implementation team leader. Sources of data to populate row three are 

found in chapter 3 and the specialists reports.

Table 118: Planned Acres by Treatment Type and Restoration Unit. The checklist is designed 

to facilitate accomplishment reporting. The checklist is designed to be used (at a minimum) by 

the implementation team leader and forest program managers. Sources of data to populate row 

three are found in chapter 3 and the specialists reports.

Table 119: National Environmental Policy Act (NEPA), National Forest Management Act

(NFMA), Endangered Species Act (ESA), and Collaborative Forest Landscape Restoration 

Act (CFLRA) Compliance Evaluation. The checklist is designed to ensure resource surveys are 

completed as required by the forest plan, policy, U.S. Fish and Wildlife Service biological 

opinion, the Collaborative Forest Landscape Restoration Act, or other requirements. The checklist 

also ensures that the site-specific treatments are compliant with the NEPA analysis and decision. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 683
Appendix D – Alternatives B-E Implementation Plan

The checklist is designed to be used by the resource specialists who comprise the implementation 

team and by the Agency’s (delegated) approving official.

Table 120: Supporting Documentation. This checklist is designed to ensure required plans and 

surveys are tracked annually and are readily accessible to the implementation team and approving 

official. It would be used in combination with appendix E that shows the adaptive management 

strategy.

Section A: This section includes existing forest plan management direction, desired conditions, 

and treatment specific silvicultural design. It is designed to be used by the project silviculturist 

and implementation team.

Section B: Section B is a decision matrix to be used by the project silviculturist and 

implementation team to facilitate establishing tree groups, interspace, and regeneration openings 

as appropriate for each individual treatment.

Section C: This section provides old tree descriptions, illustrations, and guidance used to 

implement the old tree implementation plan. 

Section D: Section D includes guidance and the “Modified Large Tree Implementation Plan”. 

The guidance is designed to be reviewed by the project’s silviculturist during development of 

prescriptions and during implementation. Section D only applies to alternative C and E.

Section E: Section E describes the relationship between treatment intensity, tree group density, 

and overall average density. It includes density management and stocking guidelines. It is 

designed to be used by the project silviculturist (in the design of prescriptions) and 

implementation team.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

684 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Table 117. Annual implementation checklist

Implementation Checklist Details

Project name:

Project location (legal):

Summary of activities proposed in this phase: 

Is the project located within the project 

boundary displayed in the FEIS/ROD?

Identify the restoration unit (RU) in which the 

project phase is located based on the 

FEIS/ROD.

RU1 RU3 RU4 RU5 RU6

(1) How many acres have been treated by RU 

since the ROD was signed?

(2) How many remaining acres are available 

for treatment by RU over the lifetime of the 

decision? (1–2) 

(3) How total many acres will this project (or 

task order) treat by RU?

(4) Are the acres to be treated by RU less than 

remaining acres available for treatment? (3–4)

Are acres proposed for treatment by RU 

within the limits approved by the decision? Yes_____________ No_______________

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 685
Appendix D – Alternatives B-E Implementation Plan

Table 118. Planned acres by treatment type and restoration unit (RU) 

Acre/Miles by Treatment Type to be 

Implemented in this Phase RU1 RU3 RU4 RU5 RU6

Aspen

Prescribed Fire Only 

ADGF Research

Grassland Restoration 

Grassland Mechanical

Intermediate Thin (IT) 10 

(10 to 25% interspace)

Intermediate Thin (IT) 25 

(25 to 40% interspace)

Intermediate Thin (IT) 40 

(40 to 55% interspace) 

MSO Threshold 

MSO Target

MSO Restricted

MSO PAC 

MSO PAC Grassland Mechanical

Pine-sage

Savanna (70 to 90% interspace)

Stand Improvement (SI) 10 

(10 to 25% interspace)

Stand Improvement (SI) 25

(25 to 40% interspace)

Stand Improvement (SI) 40 

(40 to 55% interspace) 

Uneven-aged (UEA) 10 

(10 to 25% interspace)

Uneven-aged (UEA) 25 

(25 to 40% interspace) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

686 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Acre/Miles by Treatment Type to be 

Implemented in this Phase RU1 RU3 RU4 RU5 RU6

Uneven-aged (UEA) 40 

(40 to 55% interspace) 

Wildland-Urban Interface (WUI)

Pinyon-juniper 

Wildland-Urban Interface (WUI) 55

Pile Burning

Broadcast Burning

Jackpot Burning

Fire Line Construction

Existing System and Unauthorized Road 

Decommission

Temporary Road Construction 

Temporary Road Decommission as required by 

CFLRA

Road Reconstruction/Relocation

Springs Remove Trees to Pre-settlement 

Condition 

Remove Noxious Weeds

Prescribed Fire

Protective Measures

Ephemeral 

Channels

Reestablish Drainage, Slopes, 

Vegetation

Site Protection

Remove or Rehab Stock Tanks

Other

Construct Protective Fencing: Springs/Aspen

Are acres proposed for treatments in this phase 

within the limits authorized in the decision? Yes_____________ No_______________

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 687
Appendix D – Alternatives B-E Implementation Plan

Table 119. NEPA, NFMA, ESA, CFLR Act compliance evaluation

Compliance Evaluation Yes No N/A

Is the project within the maximum treatment acres identified in the NEPA decision?

Is treatment design consistent with desired conditions, design criteria, and mitigation?

Are wildlife and botanical surveys, if necessary, complete? Is the action consistent with the FWS biological opinion dated__________?

Are heritage surveys complete? Is the action consistent with the letter of concurrence form the AZ SHPO dated________?

Have contacts with tribal representatives been made?

Are rights-of-way and land line locations in place (if applicable)?

Do treatments fully maintain or contribute toward the restoration of old growth stands as required by CFLRA and as consistent with the Old Tree 

Implementation Plan (section C)

Do treatments maximize the retention of large trees as required by CFLRA and as consistent with the Large Tree Implementation Plan (section D)?

Has the monitoring and adaptive management plan been evaluated to document compliance with law, regulation, policy, and forest plans? 

Have additional implementation and effectiveness monitoring needs been identified?

As required by CFLR Act, is multiparty monitoring underway?

As required by CFLRA, are no new permanent roads required and has the decommissioning plan been followed?

Are adaptive management actions being proposed? If so, clearly analyzed and covered by the decision made?

Has the administrator checklist been completed and signed by the appropriate resource specialists?

Is the treatment (burn) plan completed and signed?

• Objectives have been developed in interdisciplinary manner and are clearly delineated?

• Objectives are consistent with management direction?

• Objectives match those described for RU in NEPA analysis?

Complexity rating______

Do conditions match those described in NEPA analysis? Examples where conditions have changed:

New listed species in project area; New invasive species in project area; Change in regulations

Burn/treatment plan doesn’t allow implementing design criteria

Have issues identified in the NEPA analysis been reviewed?

Has a post-implementation review been completed (may be filled out after approval)?

Alternative C and E Only: Are treatments consistent with Large Tree Implementation Plan? (section D)

Has there been any new or additional NEPA decisions that also need to be considered and is the proposal consistent with these decisions?

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

688 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Table 120. Supporting documentation checklist

Document Name Attached?

Y/N

Silviculture Prescriptions

Burn Plan (includes coordination with ADEQ)

Transportation Safety Plan

Wildlife Surveys

Botany Surveys

Archaeological Surveys

Monitoring Results

404/401 permit from the U.S. Army Corps of Engineers for channel restoration projects

ADEQ Water Quality Certification

Coordination with Tribes on individual task orders

Project Resource Specialist Review 

Based on my review, the project is consistent with the Coconino and Kaibab National Forests 

final environmental impact statement and record of decision (FEIS/ROD) implementing the 

Coconino and Kaibab NFs restoration project. 

Name/Signature Date Resource Area

Terrestrial and Aquatic Wildlife

Botany

Range

Recreation

Scenery

Archaeology and Tribal Relations

Fire 

Air Quality/Smoke

Lands

Soils and Hydrology

Silviculture

Planning/NEPA

Transportation

Public Affairs

Approving Official

I have reviewed the activities proposed for this year. Based on my review, the project is 

consistent with the Coconino and Kaibab National Forests final environmental impact statement 

and record of decision implementing the Coconino and Kaibab NFs restoration project. 

_____________________________________________________ ___________________ 

Agency Approving Official, Title Date

ATTACHMENTS: (add to as necessary)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 689
Appendix D – Alternatives B-E Implementation Plan

Section A – Management Direction, 

Desired Conditions, and Treatment Design 

Mexican Spotted Owl Habitat

Alternative B, D and E on the Coconino NF only

The following guidance applies to alternatives B, D and E on the Coconino National Forest. 

Initial treatment design is based on the previous (1995) Mexican spotted owl Recovery Plan. 

However, a crosswalk between the former (1995) Recovery Plan, the 2012 Revised Mexican 

spotted owl Recovery Plan and the project to document consistency has been developed and is in 

the project record. On the Coconino NF, alternatives B, D and E treatments exceed the minimal 

basal areas recommended in the revised recovery plan and alternative E restricts mechanical 

treatments in PACs to 9 inch d.b.h. 

Protected Activity Center (PAC) - Alternatives B, D, and E 

Vegetation Management Direction: Retain key forest species such as oak; retain key habitat 

components such as snags and large down logs; in alternative E harvest conifers less than 9 

inches in diameter only within those PACs treated to abate fire risk and avoid treatment in 100-

acre nest cores as described in the Mexican spotted owl recovery plan. In alternatives B and D, 

further 4FRI guidelines include the primary objective of improving Mexican spotted owl habitat 

when mechanically treating PACs potentially cutting trees greater than 9 inches d.b.h. (see plan 

amendments in FEIS appendix B). 

Desired Conditions: Table III.B.1 (USDI FWS 1995) lists guidance for minimum desired 

structural elements within PACs. This includes 150 square feet of basal area (BA), 30 percent or 

more of the stand density index in ponderosa pine trees at least18 inches d.b.h., 15 percent or 

more of the stand density index in ponderosa pine trees between 12- and 18 inches d.b.h., at 

least20 trees per acre at least18 inches d.b.h., and at least 20 square feet basal area of Gambel 

oak. Other key habitat components includes snags 18 inches plus, down logs over 12 inches 

midpoint diameter, hardwoods, and an understory vegetation layer that includes shrubs and 

herbaceous species.

PAC Mechanical Thin and Burn Treatment Design

Each PAC has 100-acre no treatment area around the known nest or roost sites.

Outside the 100-acre no treatment area, trees may be thinned and/or prescribed burns may be used 

to treat fuels and mitigate fuel hazards where feasible.

Each PAC to be thinned would have an upper diameter limit of trees that may be cut. All trees 

above that limit would be retained. 

Intermediate thinning would be used to increase residual tree health and vigor and reduce fire 

hazard. 

Manage for 150 square feet of basal area where present. Attain 150 square feet of basal area in 

areas with the site potential capable of sustaining high tree density in alternatives B, D and E. 

Manage for irregular tree spacing to create canopy gaps and other structural conditions that would 

be conducive to low intensity prescribed fire treatment. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

690 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to the treatment diameter limit that 

do not meet the old tree definition and whose crowns are outside the old tree crown drip line (1) 

within a 50-foot radius that are in the intermediate or suppressed crown positions and (2) that 

would eliminate direct crown competition on two of the four sides of the old tree. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at root collar 

(diameter at the root collar) or larger as follows: (1) On the southerly side of the oak (135 to 315 

degrees) trees up to 18 inches d.b.h., and (2) On the northerly side of the oak (316 to 134 degrees) 

trees in the intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to 

removal would be trees that meet the old tree definition and trees that have interlocking crown 

with oaks.

Gambel oak, juniper, and pinyon species would not be cut as part of the treatments. These species 

may only be cut when there is no other option to facilitate logging operations (skid trails and 

landings).

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height and reducing litter/duff cover and other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl PAC habitat 

forest structure, tree densities, snag densities, and coarse woody debris levels.

PAC Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl PAC habitat 

forest structure, tree densities, snag densities, and coarse woody debris levels.

Steep Slopes

Vegetation Management Direction: Treat fuel accumulations to abate fire risk. Use 

combinations of thinning trees less than 9 inches in diameter, mechanical fuel removal, and 

prescribed fire; retain woody debris larger than 12 inches in diameter, snags, clumps of broadleafed woody vegetation, and hardwood trees larger than 10 inches diameter at the root collar. 

Desired Conditions: Table III.B.1 (USDI FWS 1995) lists structural elements. Other key habitat 

components includes snags 18 inches plus, down logs over 12 inches midpoint diameter, 

hardwoods, and an understory vegetation layer that includes shrubs and herbaceous species.

Steep Slopes Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 691
Appendix D – Alternatives B-E Implementation Plan

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl protected 

forest structure, tree densities, snag densities, and coarse woody debris levels.

Restricted Habitat (Table 121) 

Definition: Pine-oak – ponderosa pine habitat type series; within the Gambel oak or Gambel oak 

phase of the habitat type; at least 10 percent of the stand basal area or 10 square feet per acre of 

basal area consists of Gambel oak at least 5 inches diameter at the root collar. 

General Vegetation Management Direction: Manage to ensure a sustained level of owl nesting 

and roosting habitat well distributed across the landscape. Habitat variables are documented in 

table III.B.1 of the Mexican spotted owl recovery plan (USDI FWS 1995). Management would 

attempt to mimic natural disturbance patterns by incorporating natural variation, such as irregular 

tree spacing and various patch sizes. Allow natural canopy gap processes to occur, thus producing 

horizontal variation in stand structure. Emphasize uneven-aged management systems. Both evenaged and uneven-aged systems may be used where appropriate to provide variation in existing 

stand structure and species diversity. Save all trees greater than 24 inches d.b.h. Retain existing 

large oaks and promote growth of additional large oaks. Encourage prescribed fire to reduce 

hazardous fuel accumulation. Retain substantive amounts of key habitat components (snags 18 

inches plus, down logs over 12 inches midpoint diameter, and hardwoods). 

Table 121. Mexican spotted owl restricted habitat target/threshold conditions for pine-oak forests

Stand Averages

Basal Area (BA) at least 150 square feet basal area

18-inch + trees per acre (TPA) at least 20

Oak BA (square feet) at least 20 square feet basal area

Percent Total Existing stand density index by Size Class

12–18 in. at least 15

18–24 in. at least 15

24+ in. at least 15

Threshold Habitat

Vegetation Management Direction: Stand averages currently meet or exceed threshold values in 

table III.B.1 of the 1995 Mexican spotted owl recovery plan. Management would not reduce 

variables below the threshold values.

Desired Conditions: Irregular tree spacing and various patch size. Horizontal variation in stand 

structure. Other key habitat components includes snags 18 inches plus, down logs over 12 inches

midpoint diameter, and hardwoods. 

Threshold Mechanical Thin and Burn Treatment Design

Intermediate thinning would be used to increase residual tree health and vigor and reduce fire 

hazard. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

692 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Manage for at least 150 square feet of basal area where present, with a portion of those acres at 

least 170 square feet of basal area in alternatives B, D and E. Manage to attain 150 square feet of 

basal area in areas with site potential capable of sustaining high tree density in all alternatives.

Manage for irregular tree spacing to create canopy gaps and other structural conditions that would 

be conducive to low intensity prescribed fire treatment.

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition and whose crowns are outside the old tree crown drip line (1) within a 50-

foot radius that are in the intermediate or suppressed crown positions, and (2) that would 

eliminate direct crown competition on two of the four sides of the old tree. 

No trees larger than 24 inches d.b.h. would be cut. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak, juniper, and pinyon species would not be cut as part of the treatments. These species 

may only be cut when there is no other option to facilitate logging operations (skid trails and 

landings).

Snags would be managed for two per acre at least 18 inches and at least 30 feet in height, coarse 

woody debris would be managed for 5 to 7 tons per acre, and downed logs would be managed for 

three per acre at least 12 inches and a minimum of 8 feet in length. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height and reducing litter/duff cover and other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

threshold habitat forest structure, tree densities, snag densities, and coarse woody debris levels.

Threshold Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

threshold habitat forest structure, tree densities, snag densities, and coarse woody debris levels.

Target

Vegetation Management Direction: Stand averages currently meet or exceed some threshold 

values in table III.B.1 of the 1995 Mexican spotted owl recovery plan. Management would not 

reduce variables that are currently at or above the threshold value below the threshold values. 

Management would encourage development of threshold values that are lacking.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 693
Appendix D – Alternatives B-E Implementation Plan

Desired Conditions: Irregular tree spacing and various patch size. Horizontal variation in stand 

structure. Other key habitat components include snags 18 inches plus, down logs greater than 12 

inches midpoint diameter, and hardwoods. 

Target Mechanical Thin and Burn Treatment Design

Intermediate thinning would be used to increase residual tree health and vigor and reduce fire 

hazard. 

Manage for 150 square feet of basal area where present. Attain 150 square feet of basal area in 

areas where site potential is capable of sustaining high tree density in alternatives B, D, and E. 

Manage for irregular tree spacing to create canopy gaps and other structural conditions that would 

be conducive to low intensity prescribed fire treatment. 

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition and whose crowns are outside the old tree crown drip line: (1) within a 50-

foot radius that are in the intermediate or suppressed crown positions and (2) that would eliminate 

direct crown competition on two of the four sides of the old tree. 

No trees larger than 24 inches d.b.h. would be cut. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h. and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks. 

Gambel oak, juniper, and pinyon species would not be cut as part of the treatments. These species 

may only be cut when there is no other option to facilitate logging operations (skid trails and 

landings).

Snags would be managed for two per acre at least 18 inches and at least 30 feet in height, coarse 

woody debris would be managed for 5 to 7 tons per acre, and downed logs would be managed for 

three per acre at least 12 inches and a minimum of 8 feet in length. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height and reducing litter/duff cover and other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

target habitat forest structure, tree densities, snag densities, and coarse woody debris levels.

Target Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

target habitat forest structure, tree densities, snag densities, and coarse woody debris levels.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

694 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Restricted Other (Table 122) 

Vegetation Management Direction: Current stand averages meet few of the threshold values in 

table III.B.1 of the Mexican spotted owl recovery plan (USDI FWS 1995). Management would 

encourage development of threshold values that are lacking. 

Desired Conditions: Uneven-aged (3-plus size classes). Irregular tree spacing and various patch 

size. Horizontal variation in stand structure. Other key habitat components includes snags 18 

inches plus, down logs over 12 inches midpoint diameter, and hardwoods. 

Restricted Other Mechanical Thin and Burn Treatment Design

Uneven age thinning and group selection would be used to establish interspace between tree 

groups, thin tree groups, and create regeneration openings. 

Treatments would strive to attain the following overall average density and structural 

characteristics described in table 122. 

Table 122. Restricted other habitat treatment criteria

Stand Averages

Basal Area (BA) 70–90 ft2

Stand density index – % of max 25–40

18-inch + trees/acre (TPA) at least 20 

Oak BA (square feet) at least 20+

Percent Total stand density index by Size Class

12–18 in. at least 15

18–24 in. at least 15

24+ in. at least 15

Manage for a range of density and structural characteristics by thinning areas with a southerly 

aspect to an overall average of 60 to 80 square feet of basal area Manage areas with northerly 

aspect to an overall average of 80 to 100 square feet of basal area Density would vary within 

these ranges depending on existing stand structure. 

Individual trees and tree groups would occupy approximately 60 to 75 percent of the area. 

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C) and old trees would not be targeted for cutting. Live conifer trees 

with existing cavities, dead tops, and lightning scars would also be favored for retention.

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions and (2) that would eliminate direct crown competition on two of the four sides of the 

old tree. 

No trees larger than 24 inches d.b.h. would be cut. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 695
Appendix D – Alternatives B-E Implementation Plan

Tree groups, on average, would range in size from 0.1 to 1 acre with northerly aspects. Sites with 

a preponderance of large trees and highly productive microsites would have larger average group 

sizes. Overall, average group size would vary within this range depending on site quality, existing 

stand structure, and pre-settlement tree evidence.

Manage for tree groups with different size classes by retaining individual and clumps of vigorous 

ponderosa pine seedlings, sapling, and poles within larger mid-aged, mature, or old tree groups. 

To meet the desired condition of increasing VSS 5 and 6 size classes, the priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where size class diversity is not present, 1 to 10 suppressed and 

intermediate trees per group would be retained for vertical diversity.

Interspace would occupy approximately 25 to 40 percent of the area.

Interspace width between tree groups would average from 25 to 60 feet with a maximum width of 

200 feet. 

To meet the desired condition of increasing VSS 1 and 2 size classes, regeneration openings 

(group selection) would account for 10 to 20 percent of tree groups. The percentage would vary 

within this range depending on current size class distribution. They would average 0.3 to 0.8 acre 

and would not exceed 200 feet wide. In general, regeneration openings would not be larger than 2 

acres. However, they may extend up to 4 acres in specific areas where ponderosa pine mistletoe 

infections are heavy. Regeneration openings would be created adjacent to tree groups and would 

not be surrounded by interspace. Where stand structure dictates, regeneration openings would be 

established by removing groups of trees of VSS3 and smaller diameter VSS4. 

Manage moderate to heavy dwarf mistletoe infection centers that are not intended for 

regeneration openings for improved tree vigor and growth by retaining the best growing large 

trees (dominant and codominant trees) with the least amount of mistletoe. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

defined in the old tree implementation plan in section C), and when there is no other option to 

facilitate logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches and at least 30 feet in height, coarse 

woody debris would be managed for 5 to 7 tons per acre; downed logs would be managed for 

three per acre at least 12 inches and a minimum of 8 feet in length. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

696 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation. Prescribed fires are designed to 

maintain and enhance desired Mexican spotted owl restricted other habitat forest structure, tree 

densities, snag densities, and coarse woody debris levels.

Alternative B through E Kaibab NF and Alternative C, Coconino NF

The following vegetation management direction, desired conditions and mechanical treatment 

and burn for Mexican Spotted Owl habitat applies to alternatives B through E on the Kaibab 

National Forest and alternative C on the Coconino National Forest which has been designed to 

implement the current revised Mexican spotted owl Recovery Plan (USDI FWS 2012). 

Restricted Other Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height, reduce litter/duff cover, and 

produce effects that stimulate regeneration and growth of native herbaceous vegetation. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

other forest structure, tree densities, snag densities, and coarse woody debris levels.

Core Area

Vegetation Management Direction: Desired conditions should guide management within PACs 

(USDI FWS 2012). The intent of the core area is to define parts of the PAC that should receive 

maximum protection by limiting activities that have a high likelihood of disturbing owls or 

causing abandonment (primarily habitat alteration and certain forms of mechanical noise). The 

nesting and roosting core area should include habitat that resembles the structural and/or floristic 

characteristics of the nest and/or roost sites as much as possible (USDI FWS 2012). Vegetation 

management needs to be coordinated with US Fish and Wildlife Service.

Desired Conditions: Table C2 (USDI FWS 2012) lists guidance for desired conditions within 

PACs. The desired conditions include the following: Strive for a diversity of patch sizes with 

minimum contiguous patch size of 1 ha (2.5 ac) with larger patches near activity center; mix of 

sizes towards periphery. Forest type may dictate patch size (i.e., mixed conifer forests have larger 

and fewer patches than pine-oak forest). Strive for between patch heterogeneity; horizontal and 

vertical habitat heterogeneity within patches, including tree species composition. Patches are 

contiguous and consist of trees of all sizes, unevenly spaced, with interlocking crowns and high 

canopy cover; tree species diversity, especially with a mixture of hardwoods and shade-tolerant 

species; diverse composition of vigorous native herbaceous and shrub species; opening sizes 

between 0.04 - 1 ha (0.1 - 2.5 ac). Openings within a forest are different than natural meadows. 

Small canopy gaps within forested patches provide for prey habitat diversity. Openings should be 

small in nesting and roosting patches, may be larger in rest of PAC; and Minimum canopy cover 

of 40 percent in pine-oak and 60 percent in mixed conifer. Measure canopy cover within stands 

(USDI FWS 2012). 

Protected Activity Center (PAC)

Vegetation Management Direction: Desired conditions should guide management within PACs 

(USDI FWS 2012). The intent of the core area is to define parts of the PAC that should receive 

maximum protection by limiting activities that have a high likelihood of disturbing owls or 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 697
Appendix D – Alternatives B-E Implementation Plan

causing abandonment (primarily habitat alteration and certain forms of mechanical noise). The 

nesting and roosting core area should include habitat that resembles the structural and/or floristic 

characteristics of the nest and/or roost sites as much as possible (USDI FWS 2012). Vegetation 

management needs to be coordinated with US Fish and Wildlife Service. 

Desired Conditions: Table C2 (USDI FWS 2012) lists guidance for desired conditions within 

PACs. The desired conditions include the following: Strive for a diversity of patch sizes with 

minimum contiguous patch size of 1 ha (2.5 ac) with larger patches near activity center; mix of 

sizes towards periphery. Forest type may dictate patch size (i.e., mixed conifer forests have larger 

and fewer patches than pine-oak forest). Strive for between patch heterogeneity; Horizontal and 

vertical habitat heterogeneity within patches, including tree species composition. Patches are 

contiguous and consist of trees of all sizes, unevenly spaced, with interlocking crowns and high 

canopy cover; Tree species diversity, especially with a mixture of hardwoods and shade-tolerant 

species; Diverse composition of vigorous native herbaceous and shrub species; Opening sizes 

between 0.04 - 1 ha (0.1 - 2.5 ac). Openings within a forest are different than natural meadows. 

Small canopy gaps within forested patches provide for prey habitat diversity. Openings should be 

small in nesting and roosting patches, may be larger in rest of PAC; and minimum canopy cover 

of 40 percent in pine-oak and 60 percent in mixed conifer. Measure canopy cover within stands 

(USDI FWS 2012). 

Forested Recovery Habitat

Definition: Any stand within the Ponderosa pine series that meets the following criteria 

simultaneously: a. The stand is located in the Upper Gila Mountain ecosystem management unit; 

b. Habitat types that reflect Gambel oak or a Gambel oak phase of the habitat type; c. more than 

10 percent of the stand basal area or 4.6 m2/ha (20 ft2

/ac) of basal area consists of Gambel oak 

over13 cm (5 in) in diameter at root collar. 

For planning purposes in Forested Recovery Habitat, there are two types of stands with respect to 

desired nesting and roosting conditions: those that meet or exceed the conditions and those that 

do not. The overriding goal is to manage a specified portion of the landscape (see table 123) as 

recovery nesting and roosting habitat. Thus, managers should identify and protect stands that 

meet or exceed nesting and roosting conditions and then assess whether or not these stands satisfy 

the area requirements in table 123. If these stands are not sufficient to meet the area requirements 

in table 123, managers should identify those stands in the planning area that come closest to 

meeting nesting and roosting conditions and manage those stands to develop nesting and roosting 

conditions as rapidly as reasonably possible to meet recommended percentages. Prescriptions 

may include thinning to promote growth of large trees. Stands that do not meet nesting and 

roosting conditions and are not designated for development of such can be managed to meet other 

resource objectives.

Forested Recovery Habitat Managed as Nesting and Roosting Habitat

Vegetation Management Direction: The following are excerpts from the current Mexican 

spotted owl Recovery Plan that display guidelines for forested recovery nesting and roosting 

habitat (formerly known in USDI FWS 1995 as threshold and target/threshold) as outlined on 

pages 267 and 268 of the plan. 

Recovery nesting and roosting stands that currently meet nesting and roosting conditions:

Treatments are allowed within Recovery Habitat stands identified as meeting nesting and roosting 

conditions, as long as stand conditions remain at or above the values given in table 123. This 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

698 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

approach allows for treatments to reduce fire risks, lessen insect or disease problems, maintain 

seral species, or meet other ecosystem objectives. 

Recovery nesting and roosting stands that currently do not meet nesting and roosting

conditions: Stands currently not meeting nesting and roosting conditions but are being managed 

to meet nesting and roosting area percentages as outlined in table 123 are managed to develop 

nesting and roosting conditions as rapidly and as reasonably possible to meet recommended 

percentages. Prescriptions may include thinning to promote growth of large trees. 

Desired Conditions: Management activities that influence the owl and its habitat should be 

conducted according to the following guidelines: 

Manage for Nest / Roost Habitat. Manage mixed-conifer and pine-oak forest types in the 

designated proportions of Table C.3 (USDI FWS 2012, p. 278) to provide continuous nesting and 

roosting habitat over space and time. Table C.3 from the Recovery plan is displayed in table 123. 

Management of particular stands should be based on their capability to attain the desired 

conditions (USDI FWS 2012, Table C-2, pp. 275-277). 

Table 123. Minimum desired conditions for pine-oak forest areas managed for Recovery 

nesting/roosting habitat (USDI FWS 2012)

Forest Type

% of 

area1

% basal area (BA) 

by size class

Minimum 

tree BA2

Minimum 

density of 

large trees3

30-46 cm 

d.b.h.

(12-18 in)

over46 cm 

d.b.h.

(over18 in)

Pine-oak4 20 over30 over30 25.3 (110) 30 (12)

1. Percent of area pertains to the percent of the planning area, subregion, and/or region in the specified forest 

type that should be managed for threshold conditions.

2. As in m2

/ha (ft2/acre), and include all trees over1 inch d.b.h. (i.e., any species). We emphasize that values 

shown are minimums, not targets.

3. Trees over 46 cm (18 inches) d.b.h. Density is tree/ha (trees/acre). Again, values shown are minimums rather 

than targets. We encourage retention of large trees.

4. Pine-oak forest type: at least 10 percent of the stand basal area or 4.6 m2

/ha (20 ft2/ac) of basal area consist 

of Gambel oak at least 13 cm (5 in) diameter at the root collar

Recovery Nesting and Roosting Stands that Currently Do Not Meet Nesting and

Roosting Conditions and Recovery Nesting and Roosting Stands that Currently Do Not 

Meet Nesting and Roosting Conditions Thin and Burn Treatment Design 

Treatments Within Recovery Nesting and Roosting Stands: No stand that meets table 123

conditions should be treated in such a way as to lower that stand below those conditions until 

ecosystem assessments can document that a surplus of these stands exist at larger landscape levels 

(e.g., no less than the size of a FS District). This does not preclude use of treatments to reduce fire 

risks or lessen insect or disease problems, nor does it preclude management to meet other 

ecosystem objectives, as long as stand-level conditions remain at or above the values given in 

table 123. 

Select Appropriate Stands to Manage: Management should emphasize attainment of nesting 

and roosting conditions as quickly as reasonably possible (USDI FWS 2012). Identify and assign 

stands that would reach these conditions soonest to satisfy area requirements in table 123. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 699
Appendix D – Alternatives B-E Implementation Plan

Retain Large Trees: Stand conditions that provide the owl’s nesting habitat frequently vary 

above the minimum values given in table 123. Further, important stand conditions cannot be 

replaced quickly. In particular, removing large trees in a stand identified as habitat could reduce 

its suitability as nesting habitat or increase the time required to develop suitable nesting habitat. 

Because it takes many years for trees to reach large size, that trees at least 46- cm (18 inches) 

d.b.h. not be removed in stands designated as recovery nesting and roosting habitat unless there 

are compelling safety reasons to do so or if it can be demonstrated that removal of those trees will 

not be detrimental to owl habitat (USDI FWS 2012). 

Strive for Spatial Heterogeneity: Incorporate natural variation, such as irregular tree spacing 

and various stand/patch/group/clump sizes, into management prescriptions. Strive for 

heterogeneity both within and between stands. Attempt to mimic natural disturbance patterns and 

natural landscape heterogeneity. Allow natural canopy gap processes to occur, or mimic those 

processes through active management, thus producing horizontal variation in stand structure 

(USDI FWS 2012). 

Manage for Species Diversity. Maintain all species of native vegetation on the landscape, 

including early seral species. Allow for variation in existing stand structures and provide for 

species diversity (USDI FWS 2012). 

Emphasize Large Hardwoods. Within pine-oak and other forest types where hardwoods are a 

component of owl habitat, emphasis should be placed on management that retains, and promotes 

the growth of additional, large hardwoods (USDI FWS 2012). 

Recovery Nesting and roosting Stands that currently meet Nesting and roosting

Conditions and Recovery Nesting and roosting Stands that currently do not meet 

Nesting and roosting Conditions Burn Only Treatment Design 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl habitat forest 

structure, tree densities, snag densities, and coarse woody debris levels.

Forested Recovery Foraging/Non-Breeding Habitat

General Vegetation Management Direction: The following are excerpts from the current 

Mexican spotted owl Recovery Plan that display guidelines for Forested Recovery Foraging/Nonbreeding Habitat as outlined on pages 268-270 of the plan. The intent is to manage recovery 

habitat so that important but difficult-to-replace habitat elements are conserved while allowing 

management flexibility. Management should strive to maintain conditions where multiple 

components occur in proximity to one another. The collective goal of guidelines for Forested 

Recovery Habitat is to provide spotted owl habitat that is well distributed over space and time. 

Accomplishing this goal requires maintaining or creating stand structures typical of nesting and 

roosting habitats, and sustaining them in sufficient amounts and distribution to support a healthy 

population of Mexican spotted owls (USDI FWS 2012). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

700 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Forested Recovery Foraging/Non-Breeding Habitat Mechanical and Burn Treatment 

Design

The following treatment designs apply to alternative C on the Coconino NF and alternatives B 

through E on the Kaibab NF. The treatments are designed to implement the current Mexican 

spotted owl recovery Plan (USDI FWS 2012). 

Emphasize Large Hardwoods: Within pine-oak and other forest types where hardwoods are a 

component of owl habitat, emphasis should be placed on management that retains, and promotes 

the growth of additional, large hardwoods (USDI FWS 2012). 

Retain Large Trees: Strive to retain (do not cut) all trees over 61 cm (over 24 inches) d.b.h., the 

average diameter of nest trees, unless overriding management situations require their removal to 

protect human safety and/or property (e.g., the removal of hazard trees along roads, in 

campgrounds, and along power lines), or in situations where leaving large trees precludes 

reducing threats to owl habitat (e.g., creating a fuel break). Manage to take reasonable steps to 

minimize the loss of trees over 61 cm (24 in) d.b.h. Large trees killed by fire will provide a source 

for recruitment of large snags and eventual large logs; these snags should be retained unless their 

removal is necessary for public or worker safety (USDI FWS 2012). 

Retain Key Owl Habitat Elements: Design and implement management treatments within 

Forested Recovery Foraging/Non-breeding habitat so that most hardwoods, large snags (over 46 

cm [18 in] d.b.h.), large downed logs (over 46 cm [18 in] diameter at any point), trees (over 46 

cm [18 in] d.b.h.) are retained, unless this conflicts with forest restoration and/or owl habitat 

enhancement goals. When implementing this guideline, managers should strive to achieve a 

balance between retaining a sufficient density and distribution of important features that spotted 

owls may require and reducing the risk of losing existing roosting and nesting habitat from insect 

epidemics and stand-replacing fires.

Forested Recovery Foraging/Non-Breeding Habitat Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height, reduce litter/duff cover, and 

produce effects that stimulate regeneration and growth of native herbaceous vegetation. 

Prescribed fires are designed to maintain and enhance desired Mexican spotted owl restricted 

other forest structure, tree densities, snag densities, and coarse woody debris levels.

Goshawk Habitat

General – Ponderosa Pine

The description below includes language from RMRS GTR 217 (1992 Reynolds et al.) and is 

used for this project as a means to track movement towards desired conditions. This language is 

consistent with the current Coconino NF forest plan, but the language is absent from the Kaibab 

NF forest plan. The language is consistent Kaibab NF forest plan components including 

objectives, desired conditions and guidelines (see forest plan consistency crosswalk in the 

vegetation specialist report). The following applies to alternatives B through E on all guidance, 

unless noted otherwise. 

Vegetation Management Direction: Manage for uneven-age stand conditions for live trees and 

retain live reserve trees, snags, downed logs, and woody debris levels throughout ponderosa pine 

forest cover types. Manage for old age trees such that as much old forest structure as possible is 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 701
Appendix D – Alternatives B-E Implementation Plan

sustained over time across the landscape. Provide for or preserve existing clumps of trees with 

interlocking crowns. Sustain a mosaic of vegetation densities (overstory and understory), age 

classes, and species composition across the landscape. Encourage aspen and oak regeneration. 

Provide habitat for goshawk prey. 

Desired Conditions: Highly interspersed, heterogeneous pattern and size of tree groups and 

interspace across the landscape. Tree groups are dominated by trees of a similar age and range 

from young to old (uneven-aged). Interspace has a robust herbaceous layer. Where possible create 

smooth transitions between treated and untreated areas by shaping and feathering edges to make 

the forest more natural appearing.

Landscapes Outside of Goshawk Post-fledging 

Areas (LOPFA) – Ponderosa Pine

Vegetation Management Direction: On the Kaibab NF, the predominate vegetation management 

strategies are for uneven-aged management systems. This is because vegetation management 

objectives were only developed for the ponderosa pine and frequent fire vegetation types, both of 

which have uneven aged desired conditions. Even aged management prescriptions are, however, 

used as a strategy for achieving the desired uneven-aged conditions over the long term. On the 

Coconino NF for Northern goshawk habitats, distribution of vegetation structural stages for 

ponderosa pine – 10 percent grass/forb/shrub (VSS 1), 10 percent seedling-sapling (VSS 2), 20 

percent young forest (VSS 3), 20 percent mid-aged forest (VSS 4), 20 percent mature forest (VSS 

5), 20 percent old forest (VSS6). The distribution of VSS, tree density, and tree age are a product 

of site quality in the EMA. Use site quality to guide in the distribution of VSS, tree density, and 

tree ages. Snags are at least 18 inches d.b.h. and at least 30 feet in height, downed logs are 12 

inches in diameter and are at least 8 feet long, woody debris is at least 3 inches on the forest floor, 

canopy cover is measured with vertical crown projection on average across the landscape. 

Canopy cover guidelines apply only to mid-aged to old forest structural stages (VSS 4, VSS 5 and 

VSS 6). The VSS distribution of the Coconino NF plan is consistent with the Kaibab NF direction 

of uneven-aged management and would be used as a metric for moving toward the uneven-aged 

desired conditions on the Kaibab NF.

In alternatives B-D, additional project-specific direction is documented in the forest plan 

amendments that clarify openness and clarify that guidelines for canopy cover apply to mid-aged 

to old forest structural stage dominated tree groups across the landscapes outside of goshawk 

post-fledging areas. See FEIS, appendix B. 

Desired Conditions: Uneven-aged with a balance of size classes. Within group structure specific 

to mid-aged to old classes (VSS 4 to 6) includes open understories, interlocking tree crowns, 

abundant large limbs, and shade. 

Landscapes Outside of Goshawk Post-fledging Areas, WUI55, UEA40, UEA25 and 

UEA10 Mechanical Thin and Burn Treatments Design

Uneven-age thinning and group selection would be used to establish interspace between 

individual trees and tree groups, thin tree groups, and create regeneration openings within 

landscapes outside of goshawk post-fledging areas with none to low dwarf mistletoe infections 

that are uneven age or even age with a quadratic mean diameter at least 8.5 inches. 

Treatments would strive to attain an overall average density of 50 to 70 square feet of basal area 

and 15 to 35 percent of maximum stand density index inclusive of groups, interspaces, and 

regeneration openings. Density would vary within this range depending on treatment intensity 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

702 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

and existing stand structure. See section E for more detail on the relationship of overall density to 

interspace, tree groups, and regeneration openings.

Individual trees, tree groups, and interspaces would occupy the following percent of the area by 

treatment intensity as displayed in table 124. 

Table 124. Percent of trees, tree groups, and interspaces by treatment intensity (landscapes outside 

of goshawk post-fledging areas) 

Treatment Type 

and Intensity

Percent of Area Occupied by 

Individual Trees and Tree

Percent of Area 

Occupied by Interspace

WUI55 30–45 55–70

UEA40 45–60 40–55

UEA25 60–75 25–40

UEA10 75–90 10–25

Individual trees, tree groups, and interspaces would be managed to move toward a balance of age 

classes, both within and from tree group to tree group, by reducing the most abundant tree size 

classes and maintaining the underrepresented tree size classes.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C) and old trees would not be targeted for cutting. Live conifer trees 

with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 size class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions, and, (2) that would eliminate direct crown competition on two of the four sides of the 

old tree. 

Openings, on average, would range in size from 0.1 to 1 acre with some exceeding 1 acre (but not 

to exceed 4 acres). Expected outcomes include treatment unit and landscape heterogeneity. The 

range of openings would be implemented with variable distribution of opening size. Variability of 

opening size and location would be determined by aspect, site quality, existing stand structure and 

pre-settlement tree evidence. Tree groups, on average, would range in size from 0.1 to 1 acre with 

northerly aspects. Sites with a preponderance of large trees and highly productive microsites 

would have larger average group sizes. Overall, the average group size would vary within this 

range depending on site quality, existing stand structure, and pre-settlement tree evidence.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 703
Appendix D – Alternatives B-E Implementation Plan

On the Kaibab NF, the predominant vegetation management strategies are for uneven-aged 

management systems. This is because vegetation management objectives were only developed for 

the ponderosa pine and frequent fire vegetation types, both of which have uneven aged desired 

conditions. Even aged management prescriptions are, however, used as a strategy for achieving 

the desired uneven-aged conditions over the long term. On the Coconino NF tree group density in 

goshawk habitat would be managed to meet the canopy cover requirement (Coconino NF only) of 

40 plus percent within mid-aged forest (VSS4), mature forest (VSS5), and old forest (VSS6) tree 

groups except as noted in non- wildland-urban interface stands below. There is no specific 

guidance in the current Kaibab NF plan for goshawk habitat except in post-fledging family areas. 

The guidance for the Coconino NF would be used as guidance on the Kaibab NF as well and is 

consistent with the uneven-aged management guidance of the Kaibab NF plan. This would assure 

that immature tree groups (VSS 2 and 3) are managed to maintain tree stocking necessary to 

provide for the desired canopy cover as the groups mature to VSS 4, 5, and 6. By following the 

stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group 

density would meet and exceed the canopy cover requirements. Stocking guidelines for tree 

groups for the WUI55, UEA40, UEA25, and UEA10 mechanical thin treatments are as described 

in table 125. 

Table 125. Landscapes outside of goshawk post-fledging areas wildland-urban interface and uneveraged treatments stocking guidelines for tree groups

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1 Within Group Trees Per Acre Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

1 & 2 

(20)

0–4.9 19 48 96 144 193 134–302 NA NA

3 (20) 5–11.9 14 34 68 102 136 83–215 NA NA

4 (20) 12–17.9 5 12 23 35 46 35–115 70–146 89–185

5 (20) 18–23.9 3 8 15 23 30 19–59 43–79 54–96

6 (20) at least 24 2 5 11 16 21 18–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4, 5, and 6 classes are 

equivalent to 40 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest TPA number for the range pertains to the largest diameter of the VSS class; the highest TPA number for the 

range pertains to the smallest diameter of the VSS class. See section E for further detail on stocking by diameter.

On approximately 23,500 acres (about 12,200 acres on the Coconino and 11,300 acres on the 

Kaibab NF, respectively) of uneven-aged (UEA) 40 and UEA 25 non- wildland-urban interface 

stands with a preponderance of large trees (at a minimum all VSS 5 and 6 stands and VSS 4 

stands with a mean basal area greater than 70 of the VSS4 size class and a mean trees per acre

less than 100 of the VSS 4 size class) would be managed for greater residual canopy cover and 

density of large trees. Residual stand structure would be managed at the upper end of natural 

range of variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes (see below), and/or retaining additional 

large trees Post treatment canopy cover in these stands would meet or exceed forest plan 

guidance for canopy cover, and is intended to achieve 40 percent canopy cover at the 

stand scale (alternative C and E only). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

704 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Manage for tree groups with different size classes by retaining individual and clumps of vigorous 

ponderosa pine seedlings, sapling, and poles within larger mid-aged, mature, or old tree groups. 

Large trees would be the basis for forming groups. Large trees (generally, dominant and 

codominant crown position) would have priority for retention within groups. Where size class 

diversity is not present, 1 to 10 suppressed and intermediate trees per group would be retained for 

vertical diversity.

Interspace width between tree groups would average from 25 to 120 feet with a maximum width 

of 200 feet. Average interspace width would vary depending on treatment intensity as described 

in table 126. 

Table 126. Interspace percent and width in Landscapes Outside of Goshawk Post-fledging Areas 

wildland-urban interface (WUI) and uneven-aged (UEA) treatments

Treatment Type and 

Intensity

Percent of Area 

Occupied by Interspace

Average Interspace Width 

(feet) 

WUI55 55–70 80–120

UEA40 40–55 60–100

UEA25 25–40 40–60

UEA10 10–25 25–40

Regeneration openings (group selection) account for 10 to 20 percent of tree groups. The 

percentage would vary within this range depending on current VSS distribution. They would 

average 0.3 to 0.8 acre and would be no larger than 4 acres or 200 feet wide. Where stand 

structure dictates, establish regeneration openings by removing groups of trees of VSS3 and 

smaller diameter VSS4. Regeneration openings would be created adjacent to tree groups and 

would not be surrounded by interspace. 

One group of reserve trees, three to five trees per group, would be left in created regeneration 

openings greater than an acre in size.

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h. and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks. 

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

defined in the old tree implementation plan in section C), and when there is no other option to 

facilitate logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 705
Appendix D – Alternatives B-E Implementation Plan

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired landscapes outside of goshawk 

post-fledging areas uneven-aged forest structure, tree densities, snag densities, and coarse woody 

debris levels.

Landscapes Outside of Goshawk Post-fledging Areas Uneven-aged (UEA) Treatment– 

Arizona Department of Game and Fish Design Mechanical Thin and Burn (Alternative C) 

Design

The design is the same as landscapes outside of goshawk post-fledging areas UEA 10 with the 

exception of group size. Tree group size is dependent on experimental design and would range in 

size from 1 to 15 acres. 

Landscapes Outside of Goshawk Post-fledging Areas Intermediate Thin (IT) 40, 25, and 

10 Mechanical Thin and Burn Treatments Design

Intermediate thinning (IT) would be used to establish interspace between individual trees and tree 

groups and thin tree groups within landscapes outside of goshawk post-fledging areas sites with 

moderate to high dwarf mistletoe infection that are uneven age or even age with a quadratic mean 

diameter at least 8.5 inches.

Treatments would strive to attain an overall average density of 70 to 90 square feet of basal area 

and 25 to 40 percent of maximum stand density index inclusive of groups and interspaces. 

Density would vary within these ranges depending on treatment intensity and existing stand 

structure. See section D for more detail on the relationship of overall density to interspace and 

tree groups. 

Individual trees, tree groups, and interspaces would occupy the following percent of the area by 

treatment intensity as described in table 127. 

Table 127. Percent of area occupied by trees, tree groups, and interspace in landscapes outside of 

goshawk post-fledging areas intermediate thin (IT) 

Treatment Type and 

Intensity

Percent of Area Occupied by 

Individual Trees and Tree Groups

Percent of Area Occupied 

by Interspace

IT40 45–60 40–55

IT25 60–75 25–40

IT10 75–90 10–25

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

706 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

To meet the desired condition of increasing VSS 5 and 6 size class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 11,600 acres (about 8,900 acres on the Coconino and 2,700 acres on the 

Kaibab NF, respectively) of IT 40 and IT 25 non-wildland-urban interface stands with a 

preponderance of large trees (at a minimum all VSS 5 and 6 stands and VSS 4 stands with a mean 

basal area greater than 70 of the VSS4 size class and a mean trees per acre less than 100 of the 

VSS 4 size class) would be managed for greater residual canopy cover and density of large trees. 

Residual stand structure would be managed at the upper end of natural range of variability for 

ponderosa pine in the non- wildland-urban interface stands that meet these conditions. This would 

be accomplished by focusing treatments towards the lower end of the identified intensity range, 

managing for larger group sizes (see below), and/or retaining additional large trees. Post 

treatment canopy cover in these stands would meet or exceed forest plan guidance for canopy 

cover, and is intended to achieve 40 percent canopy cover at the stand scale (alternative C and E 

only). 

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions, and, (2) that would eliminate direct crown competition on two of the four sides of the 

old tree. 

Openings, on average, would range in size from 0.1 to 1 acre with some exceeding 1 acre (but not 

to exceed 4 acres). Expected outcomes include treatment unit and landscape heterogeneity. The 

range of openings would be implemented with variable distribution of opening size. Variability of 

opening size and location are determined by aspect, site quality, existing stand structure and presettlement tree evidence. Tree groups, on average, would range in size from 0.1 to 1 acre with 

northerly aspects. Sites with a preponderance of large trees and highly productive microsites 

would have larger average group sizes. Overall, average group size would vary within this range 

depending on site quality, existing stand structure, and pre-settlement tree evidence.

Tree groups would be managed to improve tree vigor and growth by retaining the best growing 

dominant and codominant trees with the least amount of mistletoe within each group. 

On the Kaibab NF, the predominant vegetation management strategies are for uneven-aged 

management systems. This is because vegetation management objectives were only developed for 

the ponderosa pine and frequent fire vegetation types, both of which have uneven aged desired 

conditions. Even aged management prescriptions are, however, used as a strategy for achieving 

the desired uneven-aged conditions over the long term. The following metrics (below) may be 

used on the Kaibab NF to assess movement towards uneven-aged conditions. Tree group density 

would be managed to meet the canopy cover requirement (Coconino NF only) of 40 plus percent 

within mid-aged forest (VSS4), mature forest (VSS5), and old forest (VSS6) tree groups. By 

following the stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, 

tree group density would meet and exceed the canopy cover requirements. Stocking guidelines for 

VSS 4, 5, and 6 tree groups for the IT40, IT25, and IT10 mechanical thin treatments are as 

described in table 128 and table 129. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 707
Appendix D – Alternatives B-E Implementation Plan

Table 128. Stocking guidelines for VSS 4 to 6 tree groups in landscapes outside of goshawk postfledging areas intermediate thin (IT) treatments

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per 

Acre Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

4 (20) 12–17.9 5 12 23 35 46 35–115 70–146 89–185

5 (20) 18–23.9 3 8 15 23 30 19–59 43–79 54–96

6 (20) at least 

24

2 5 11 16 21 18–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4, 5, and 6 classes are 

equivalent to 40 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class. The highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section E for further detail on 

stocking by diameter.

Interspace width between tree groups would average from 25 to 80 feet with a maximum width of 

200 feet. Average interspace width would vary depending on treatment intensity as described in 

table 129. 

Table 129. Percent and width of interspace in landscapes outside of goshawk post-fledging areas 

intermediate thin (IT) treatments 

Treatment Type 

and Intensity

Percent of Area 

Occupied by Interspace

Average Interspace Width 

(feet) 

IT40 40–55 60–80

IT25 25–40 40–60

IT10 10–25 25–40

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

Tree groups would be managed to improve tree vigor and growth by retaining the best growing 

dominant and codominant trees. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

708 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Landscapes Outside of Goshawk Post-fledging Areas Stand Improvement (SI) 40, 25, 

and 10 Mechanical Thin and Burn Treatments Design

On the Kaibab NF, the predominate vegetation management strategies are for uneven-aged 

management systems. This is because vegetation management objectives were only developed for 

the ponderosa pine and frequent fire vegetation types, both of which have uneven aged desired 

conditions. Even aged management prescriptions are, however, used as a strategy for achieving 

the desired uneven-aged conditions over the long term. The following metrics may be used on the 

Kaibab NF to assess movement towards uneven-aged conditions. Tree group density would be 

managed to meet the canopy cover requirement (Coconino NF only) of 40 plus percent within 

mid-aged forest (VSS 4), mature forest (VSS 5), and old forest (VSS 6) tree groups. This would 

assure that immature tree groups (VSS 2 and 3) are managed to maintain tree stocking necessary 

to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6. By following the 

stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group 

density would meet and exceed the canopy cover requirements. Stocking guidelines for tree 

groups for the SI40, SI25, and SI10 mechanical thin treatments are as described in table 130. 

Table 130. Stocking guidelines for tree groups in landscapes outside of goshawk post-fledging areas 

stand improvement (SI) treatments

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

1 & 2 

(20)

0–4.9 19 48 96 144 193 134–302 NA NA

3 (20) 5–11.9 14 34 68 102 136 83–215 NA NA

4 (20) 12–17.9 5 12 23 35 46 35–115 70–146 89–185

5 (20) 18–23.9 3 8 15 23 30 19–59 43–79 54–96

6 (20) at least 

24

2 5 11 16 21 18–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4, 5, and 6 classes are 

equivalent to 40 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Interspace width between tree groups would average from 25 to 80 feet with a maximum width of 

200 feet. Average interspace width would vary depending on treatment intensity as described in 

table 131. 

Table 131. Interspace percent and width landscapes outside of goshawk post-fledging areas stand 

improvement (SI) treatments 

Treatment Type 

and Intensity

Percent of Area 

Occupied by Interspace

Average Interspace Width 

(feet) 

SI40 40–55 60–80

SI25 25–40 40–60

SI10 10–25 25–40

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 709
Appendix D – Alternatives B-E Implementation Plan

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation strategy, and old trees would not be targeted for cutting. Live conifer trees with 

existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments are designed to 

focus on small diameter tree thinning, with the objective of maximizing the retention of large 

trees – thus meeting desired conditions of increasing VSS 5 and 6 age classes as soon as possible. 

Treatments would follow the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would ill focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 22 acres (22 acres on the Coconino) of SI 25 non-wildland-urban interface 

stands with a preponderance of large trees (at a minimum all VSS 5 and 6 stands and VSS 4 

stands with a mean basal area greater than 70 of the VSS4 size class and a mean trees per acre

less than 100 of the VSS 4 size class) would be managed for greater residual canopy cover and 

density of large trees. Residual stand structure would be managed at the upper end of natural 

range of variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes (see below), and/or retaining additional 

large trees Post treatment canopy cover in these stands would meet or exceed forest plan 

guidance for canopy cover, and is intended to achieve 40 percent canopy cover at the 

stand scale (alternative C and E only).

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and, (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

defined in the old tree implementation plan – section C), and when there is no other option to 

facilitate logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

710 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Prescribed fires are designed to maintain and enhance desired landscapes outside of goshawk 

post-fledging areas stand improvement (SI) forest structure, tree densities, snag densities, and 

coarse woody debris levels.

Landscapes Outside of Goshawk Post-fledging Areas Pine Sage Mechanical and Burn 

Treatment Design

Restore pre-settlement tree density and pattern using pre-settlement evidence as guidance.

Treatment would strive to attain an overall average density of 30 to 50 square feet of basal area 

and 15 to 25 percent of maximum stand density index inclusive of individual trees, tree groups, 

and interspaces. Density would vary within this range depending on existing stand structure. See 

section E for more detail on the relationship of overall density to interspace and tree groups.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C) and old trees would not be targeted for cutting. Live conifer trees 

with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

Retain all pre-settlement trees and the largest post-settlement trees available that most closely 

resemble old trees in size and form as replacement trees adjacent to pre-settlement tree evidences. 

Some younger trees would also be retained to maintain uneven-aged structure. On the Kaibab NF, 

the predominate vegetation management strategies are for uneven-aged management systems. 

This is because vegetation management objectives were only developed for the ponderosa pine 

and frequent fire vegetation types, both of which have uneven aged desired conditions. Even aged 

management prescriptions are, however, used as a strategy for achieving the desired uneven-aged 

conditions over the long term. The following metrics may be used on the Kaibab NF to assess 

movement towards uneven-aged conditions. Replacement tree density would be managed to meet 

the attain a canopy cover of 40 plus percent within mid-aged forest (VSS 4), mature forest (VSS 

5), and old forest (VSS 6) tree groups. By following the stocking guidelines and maintaining 

interlocking or nearly interlocking tree crowns, tree group density would meet and exceed the 

canopy cover requirements. See table 132 for the stocking guidelines for VSS 4, 5, and 6 tree 

groups for the pine-sage mechanical thin treatments.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 711
Appendix D – Alternatives B-E Implementation Plan

Table 132. Stocking guidelines for VSS 4 to VSS 6 tree groups in landscapes outside of goshawk 

post-fledging areas pine-sage treatments

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

4 (20) 12–17.9 5 12 23 35 46 35–115 70–146 89–185

5 (20) 18–23.9 3 8 15 23 30 19–59 43–79 54–96

6 (20) at least 

24

2 5 11 16 21 18–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4, 5, and 6 classes are 

equivalent to 40 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h. and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks. 

Gambel oak would not be cut unless there is no other option to facilitate logging operations (skid 

trail and landing locations).

Juniper and pinyon species in the seedling/sapling, young, and mid-aged stages would generally 

be cut except where needed as replacements for pre-settlement trees. Mature juniper and pinyon 

would only be cut when there is no other option to facilitate logging operations (skid trail and 

landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired understory composition and cover 

as well as landscapes outside of goshawk post-fledging areas pine sage forest structure, tree 

densities, snag densities, and coarse woody debris levels.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

712 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Savanna/Grassland Restoration 

Mechanical and Burn Treatments Design

Note: Savanna treatments only apply to alternatives B-D. 

In alternatives B-D only, restore pre-settlement tree density and pattern using pre-settlement 

evidence as guidance. Manage for an open reference condition with 10 to 30 percent of the area 

under ponderosa pine and deciduous tree crowns (see forest plan consistency evaluation in 

silviculture report).

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C) and old trees would not be targeted for cutting. Live conifer trees 

with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

Tree group arrangement, size, and density are a function of existing pre-settlement trees and 

evidence. Retain all pre-settlement trees and the largest post-settlement trees that most closely 

resemble old trees in size and form as replacement trees adjacent to pre-settlement tree evidences 

at a 1:1 ratio. Some younger trees would also be retained to maintain uneven-aged structure. A 

higher leave tree to evidence ratio may be required to maintain the desired tree cover range.

In Alternatives B-D, manage for a range of 70 to 90 percent of the treatment area as interspace 

(grass/forb) between tree groups or individuals. Amount of interspace would vary within this 

range depending on current conditions. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and, (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak would not be cut unless there is no other option to facilitate logging operations (skid 

trail and landing locations). 

Juniper and pinyon species in the seedling/sapling, young, and mid-aged stages would generally 

be cut except where needed as replacements for pre-settlement trees. Mature juniper and pinyon 

would only be cut when there is no other option to facilitate logging operations (skid trail and 

landing locations). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 713
Appendix D – Alternatives B-E Implementation Plan

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

In alternative B-D, prescribed fires are designed to maintain and enhance desired landscapes 

outside of goshawk post-fledging areas savanna/grassland forest structure, tree densities, snag 

densities, and coarse woody debris levels. In alternative E, prescribed fires are designed to 

maintain and enhance desired landscapes outside of goshawk post-fledging areas unevenaged/grassland forest structure, tree densities, snag densities, and coarse woody debris levels. 

Landscapes Outside of Goshawk Post-fledging Areas Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height, reduce litter/duff cover, and 

produce effects that stimulate regeneration and growth of native herbaceous vegetation. 

Prescribed fires are designed to maintain and enhance desired landscapes outside of goshawk 

post-fledging areas forest structure, tree densities, snag densities, and coarse woody debris levels.

Goshawk Post-Fledging Family Area – Ponderosa Pine

Vegetation Management Direction: Provide for a healthy, sustainable forest environment for the 

post-fledging family area (PFA) needs. The principle difference between “within the postfledging family area” and “outside the post-fledging family area” is the higher canopy cover and 

smaller opening size within the post-fledging family area. Forest conditions in the post-fledging 

family areas contain 10 to 20 percent higher basal area in mid-aged to old tree groups than in the 

general forest for the Kaibab NF. The following guidance for the Coconino NF can be used as a 

metric to arrive at the higher density of 10 to 20 percent higher basal area recommended in the 

current Kaibab NF plan. For the Coconino NF, vegetative structural stage distribution and 

structural conditions are the same within and outside the post-fledging family area. Ponderosa 

pine canopy cover for mid-aged forest (VSS 4) should average one-third 60 plus percent and twothirds 50 plus percent. Mature (VSS 5) and old forest (VSS 6) should average 50 plus percent. In 

alternative B-D, forest plan amendment direction (FEIS, appendix B) clarifies that canopy cover 

guidelines apply to mid-aged to old forest structural stage dominated tree groups (see forest plan 

consistency crosswalk for the Kaibab NF in the vegetation report)

Desired Conditions: Uneven-aged with a balance of age classes. Within group structure specific 

to mid-aged to old classes (VSS 4 to 6) includes open understories, interlocking tree crowns, 

abundant large limbs, and shade. 

Dispersal Post-fledging Family Areas / Post-fledging Family Areas in Uneven-aged 

Treatment (UEA) Types 40, 25, and 10 Mechanical Thin and Burn Treatments Design

Uneven-age thinning and group selection would be used to establish interspace between 

individual trees and tree groups, thin tree groups, and create regeneration openings within 

dispersal post-fledging family areas / post-fledging family areas with none to low dwarf mistletoe 

infections that are uneven age or even age with a quadratic mean diameter at least 8.5 inches. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

714 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Treatments would strive to attain an overall average density of 70 to 80 square feet of basal area

and 25 to 40 percent of maximum stand density index inclusive of groups, interspaces, and 

regeneration openings. Density would vary within this range depending on treatment intensity 

and existing stand structure. See section E for more detail on the relationship of overall density to 

interspace, tree groups, and regeneration openings.

Individual trees, tree groups, and interspaces would occupy the following percent of the area by 

treatment intensity as described in table 133. 

Table 133. Percent of area occupied by individual trees, tree groups, and interspace in dispersal 

post-fledging family areas / post-fledging family areas uneven-aged (UEA) treatments

Treatment Type and 

Intensity

Percent of Area Occupied by 

Individual Trees and Tree Groups

Percent of Area 

Occupied by Interspace

UEA40 45–60 40–55

UEA25 60–75 25–40

UEA10 75–90 10–25

Individual trees, tree groups, and interspaces would be managed to move toward a balance of age 

classes, both within and from tree group to tree group, by reducing the most abundant tree size 

classes and maintaining the underrepresented tree size classes.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C) and old trees would not be targeted for cutting. Live conifer trees 

with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 2,000 acres (about 700 acres on the Coconino and 1,300 acres on the Kaibab) 

of dispersal post-fledging family area UEA 25, dispersal post-fledging family area UEA 40, postfledging family area UEA 25 and post-fledging family area UEA 40 non- wildland-urban 

interface stands with a preponderance of large trees (at a minimum all VSS 5 and 6 stands and 

VSS 4 stands with a mean basal area greater than 70 of the VSS4 size class and a mean trees per 

acre less than 100 of the VSS 4 size class) would be managed for greater residual canopy cover 

and density of large trees. Residual stand structure would be managed at the upper end of natural 

range of variability for ponderosa pine in the non-wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes (see below), and/or retaining additional 

large trees. Post treatment canopy cover in these stands would meet or exceed forest plan 

guidance for canopy cover, and is intended to achieve for mid-aged forest (VSS 4) on average 1/3 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 715
Appendix D – Alternatives B-E Implementation Plan

60+ percent and 2/3 50+ percent and for mature (VSS 5) and old forest (VSS 6) should average 

50+ percent canopy cover at the stand scale (alternative C and E only). 

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions, and (2) that would eliminate direct crown competition on two of the four sides of the 

old tree. 

Openings, on average, would range in size from 0.1 to 1 acre with some exceeding 1 acre (but not 

to exceed 4 acres). Expected outcomes include treatment unit and landscape heterogeneity. The 

range of openings would be implemented with variable distribution of opening size. Variability of 

opening size and location would be determined by aspect, site quality, existing stand structure and 

pre-settlement tree evidence. Tree groups, on average, would range in size from 0.1 to 1 acre with 

northerly aspects. Sites with a preponderance of large trees and highly productive microsites 

would have larger average group sizes (.25 to 1 acre). Overall, average group size would vary 

within this range depending on site quality, existing stand structure, and pre-settlement tree 

evidence.

Forest conditions in some areas contain 10 to 20 percent higher basal area in mid-aged to old tree 

groups than in the general forest for the Kaibab NF. The following guidance for the Coconino NF 

can be used as a metric to arrive at the higher density recommended in the current Kaibab NF 

plan. Tree group density would be managed to meet the canopy cover requirement (Coconino NF 

only) of mid-aged forest (VSS 4) should average one-third 60 plus percent and two-thirds 50 plus 

percent. Mature (VSS 5) and old forest (VSS 6) should average 50 plus percent tree groups and to 

assure that immature tree groups (VSS 2 and 3) are managed to maintain tree stocking necessary 

to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6. By following the 

stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group 

density would meet and exceed the canopy cover requirements. Stocking guidelines for tree 

groups for the dispersal post-fledging family areas / post-fledging family areas UEA40, UEA25, 

and UEA10 mechanical thin treatments are described in table 134. 

Manage for tree groups with different age classes by retaining individual and clumps of vigorous 

ponderosa pine seedlings, sapling, and poles within larger mid-aged, mature, or old tree groups. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

716 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Table 134. Stocking guidelines for tree groups in dispersal post-fledging family areas / post-fledging 

family areas wildland-urban interface and uneven-aged treatments

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

1 & 2 

(20)

0–4.9 19 48 96 144 193 134–302 NA NA

3 (20) 5–11.9 14 34 68 102 136 83–215 NA NA

4 (20) 12–17.9 7 18 35 53 70 51–115 70–146 89–185

5 (20) 18–23.9 4 10 20 29 39 28–59 43–79 54–96

6 (20) at least 

24

3 7 14 20 27 26–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4 classes are equivalent 

to 55 percent canopy cover (guidance for 1/3 60 percent and 2/3 50 is actually 53 percent, 55 percent is a higher 

average percent canopy cover than the minimum guidance); Densities within the VSS 5 and VSS 6 classes are 

equivalent to 50 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Interspace width between tree groups would average from 25 to 70 feet with a maximum width of 

200 feet. Average interspace width would vary depending on treatment intensity as described in 

table 135. 

Table 135. Interspace percent and width in dispersal post-fledging family areas / post-fledging family 

areas wildland-urban interface and uneven-aged (UEA) treatments 

Treatment Type and 

Intensity

Percent of Area 

Occupied by Interspace Average Interspace Width (feet)

UEA40 40–55 55–70

UEA25 25–40 40–55

UEA10 10–25 25–40

Regeneration openings (group selection) account for 10 to 20 percent of tree groups. They would 

average 0.3 to 0.8 acre and would be no larger than 2 acres or 200 feet wide. Where stand 

structure dictates, establish regeneration openings by removing groups of trees of VSS3 and 

smaller diameter VSS4. Regeneration openings would be created adjacent to tree groups and 

would not be surrounded by interspace. 

One group of reserve trees, three to five trees per group, would be left in created regeneration 

openings greater than an acre in size.

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 717
Appendix D – Alternatives B-E Implementation Plan

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

defined in the old tree implementation strategy), and when there is no other option to facilitate 

logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired dispersal post-fledging family areas 

/ post-fledging family areas with uneven-aged forest structure, tree densities, snag densities, and 

coarse woody debris levels.

Dispersal Post-fledging Family Areas / Post-fledging Family Areas Uneven-aged (UEA) 

Forest– Arizona Department of Game and Fish Design Mechanical Thin and Burn 

(Alternative C) Design

Treatment design is similar to dispersal post-fledging family areas / post-fledging family areas 

UEA10 with the exception of group size. Tree group size is dependent on experimental design 

and would range in size from 1 to 15 acres. 

Dispersal Post-fledging Family Areas / Post-fledging Family Areas Intermediate Thin 

(IT)40, 25 and 10 Mechanical Thin and Burn Treatments Design

Intermediate thinning would be used to establish interspace between individual trees and tree 

groups and thin tree groups within dispersal post-fledging family areas / post-fledging family 

areas with moderate to high dwarf mistletoe infection that are uneven age or even age with a 

quadratic mean diameter at least 8.5 inches. 

Treatments would strive to attain an overall average density of 70 to 90 square feet of basal area

and 25 to 40 percent of maximum stand density index inclusive of groups and interspaces. 

Density would vary within this range depending on treatment intensity and existing stand 

structure. See section E for more detail on the relationship of overall density to interspace and 

tree groups. 

Individual trees, tree groups, and interspaces would occupy the following percent of the area by 

treatment intensity as described in table 136. 

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation strategy and old trees would not be targeted for cutting. Live conifer trees with 

existing cavities, dead tops, and lightning scars would also be favored for retention. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

718 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Table 136. Percent of area occupied by trees and interspace for dispersal post-fledging family areas / 

post-fledging family areas intermediate thin (IT) 

Treatment Type and 

Intensity

Percent of Area Occupied by 

Individual Trees and Tree Groups

Percent of Area 

Occupied by Interspace

IT40 45–60 40–55

IT25 60–75 25–40

IT10 75–90 10–25

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation plan (section C) by reducing crown competition and increasing growing 

space adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet 

the old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions, and (2) that would eliminate direct crown competition on two of the four sides of the 

old tree.

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 1,100 acres (about 900 acres on the Coconino and 200 acres on the Kaibab) of 

dispersal post-fledging family areas IT 25, dispersal post-fledging family areas IT 40, postfledging family areas IT 25 and post-fledging family areas IT 40 stands that are not wildlandurban interface with a preponderance of large trees (at a minimum all VSS 5 and 6 stands and 

VSS 4 stands with a mean basal area greater than 70 of the VSS4 size class and a mean trees per 

acre less than 100 of the VSS 4 size class) would be managed for greater residual canopy cover 

and density of large trees. Residual stand structure would be managed at the upper end of natural 

range of variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes (see below), and/or retaining additional 

large trees. Post treatment canopy cover in these stands would meet or exceed forest plan 

guidance for canopy cover, and is intended to achieve for mid-aged forest (VSS 4) on 

average 1/3 60+ percent and 2/3 50+ percent and for mature (VSS 5) and old forest (VSS 

6) should average 50+ percent canopy cover at the stand scale (alternative C and E only).

Openings, on average, would range in size from 0.1 to 1 acre with some exceeding 1 acre (but not 

to exceed 4 acres). Expected outcomes include treatment unit and landscape heterogeneity. The 

range of openings would be implemented with variable distribution of opening size. Variability of 

opening size and location would be determined by aspect, site quality, existing stand structure and 

pre-settlement tree evidence. Tree groups, on average, would range in size from 0.1 to 1 acre with 

northerly aspects. Sites with a preponderance of large trees and highly productive microsites 

would have larger average group sizes (0.25-1 acre in size). Overall, average group size would 

vary within this range depending on site quality, existing stand structure, and pre-settlement tree 

evidence.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 719
Appendix D – Alternatives B-E Implementation Plan

Tree groups would be managed to improve tree vigor and growth by retaining the best growing 

dominant and codominant trees with the least amount of mistletoe within each group. 

Forest conditions in some areas contain 10 to 20 percent higher basal area in mid-aged to old tree 

groups than in the general forest for the Kaibab NF. The following guidance for the Coconino NF 

can be used as a metric to arrive at the higher density recommended in the current Kaibab NF

plan. Tree group density would be managed to meet the canopy cover requirement (Coconino NF 

only) of mid-aged forest (VSS 4) should average one-third 60 plus percent and two-thirds 50 plus 

percent. Mature (VSS 5) and old forest (VSS 6) should average 50 plus percent tree groups. By 

following the stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, 

tree group density would meet and exceed the canopy cover requirements. Stocking guidelines for 

VSS 4, 5, and 6 tree groups for the dispersal post-fledging family areas / post-fledging family 

areas IT40, IT25, and IT10 mechanical thin treatments are described in table 137 and table 138. 

Table 137. Dispersal post-fledging family areas / post-fledging family areas intermediate thin (IT) 

treatments stocking guidelines for VSS 4 – 6 tree groups

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

4 (20) 12–17.9 7 18 35 53 70 51–115 70–146 89–185

5 (20) 18–23.9 4 10 20 29 39 28–59 43–79 54–96

6 (20) at least 

24

3 7 14 20 27 26–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4 classes are equivalent 

to 55 percent canopy cover(guidance for 1/3 60 percent and 2/3 50 is actually 53 percent, 55 percent is a higher 

average percent canopy cover than the minimum guidance); Densities within the VSS 5 and VSS 6 classes are 

equivalent to 50 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5 and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Interspace width between tree groups would average from 25 to 80 feet with a maximum width of 

200 feet. Average interspace width would vary depending on treatment intensity as described in 

table 138. 

Table 138. Interspace percent and width in dispersal post-fledging family areas / post-fledging family 

areas intermediate thin (IT) 

Treatment Type and 

Intensity

Percent of Area Occupied by 

Interspace Average Interspace Width

IT40 40–55 60–80

IT25 25–40 40–60

IT10 10–25 25–40

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and, (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

720 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

defined in the old tree implementation plan, section C); and when there is no other option to 

facilitate logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired dispersal post-fledging family areas 

/ post-fledging family areas intermediate thin forest structure, tree densities, snag densities, and 

coarse woody debris levels.

Dispersal Post-fledging Family Areas / Post-fledging Family Areas Stand Improvement 

(SI)40, 25, and 10 Mechanical Thin and Burn Treatments Design

Stand improvement thinning would be used to establish interspace between individual trees and 

tree groups and thin tree groups within dispersal post-fledging family areas / post-fledging family 

areas even-age sites with a quadratic mean diameter ≤ 8.5 inches and with none to low dwarf 

mistletoe infection.

Treatments would strive to attain a stand average density of 20 to 25 percent of maximum stand 

density index inclusive of groups and interspaces. These ranges would vary depending on 

treatment intensity and existing stand structure. See section E for more detail on the relationship 

of overall density to interspace and tree groups.

Individual trees, tree groups, and interspaces would occupy the following percent of the area by 

treatment intensity as described in table 139. 

Table 139. Percent of area occupied by individual trees, tree groups, and interspaces in dispersal 

post-fledging family areas / post-fledging family areas stand improvement (SI) treatments 

Treatment Type and 

Intensity

Percent of Area Occupied by 

Individual Trees and Tree Groups

Percent of Area 

Occupied by Interspace

SI40 45–60 40–55

SI25 60–75 25–40

SI10 75–90 10–25

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 721
Appendix D – Alternatives B-E Implementation Plan

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 37 acres (about 37 acres on the Coconino) of post-fledging family area SI 25 

non- wildland-urban interface stands with a preponderance of large trees (at a minimum all VSS 5 

and 6 stands and VSS 4 stands with a mean basal area greater than 70 of the VSS4 size class and 

a mean trees per acre less than 100 of the VSS 4 size class) would be managed for greater 

residual canopy cover and density of large trees. Residual stand structure would be managed at 

the upper end of natural range of variability for ponderosa pine in the non-wildland-urban 

interface stands that meet these conditions. This would be accomplished by focusing treatments 

towards the lower end of the identified intensity range, managing for larger group sizes (see 

below), and/or retaining additional large trees. Post treatment canopy cover in these stands 

would meet or exceed forest plan guidance for canopy cover, and is intended to achieve 

for mid-aged forest (VSS 4) on average 1/3 60+ percent and 2/3 50+ percent and for 

mature (VSS 5) and old forest (VSS 6) should average 50+ percent canopy cover at the 

stand scale (alternative C and E only).

Manage for the sustainability of individual/isolated old ponderosa pine trees as defined in the old 

tree implementation strategy by reducing crown competition and increasing growing space 

adjacent to these trees. Remove ponderosa pine trees up to 18 inches d.b.h. that do not meet the 

old tree definition: (1) within a 50-foot radius that are in the intermediate or suppressed crown 

positions, and, (2) that would eliminate direct crown competition on two of the four sides of the 

old tree. 

Openings, on average, would range in size from 0.1 to 1 acre with some exceeding 1 acre (but not 

to exceed 4 acres). Expected outcomes include treatment unit and landscape heterogeneity. The 

range of openings would be implemented with variable distribution of opening size. Variability of 

opening size and location would be determined by aspect, site quality, existing stand structure and 

pre-settlement tree evidence. Tree groups would be managed to improve tree vigor and growth by 

retaining the best growing dominant and codominant trees. 

Forest conditions in some areas contain 10 to 20 percent higher basal area in mid-aged to old tree 

groups than in the general forest for the Kaibab NF. The following guidance for the Coconino NF 

can be used as a metric to arrive at the higher density recommended in the current Kaibab NF 

plan. Tree group density would be managed to meet the canopy cover requirement (Coconino NF 

only) of mid-aged forest (VSS 4) should average one-third 60 plus percent and two-thirds 50 plus 

percent. Mature (VSS 5) and old forest (VSS 6) should average 50 plus percent tree groups and to 

assure that immature tree groups (VSS 2 and 3) are managed to maintain tree stocking necessary 

to provide for desired canopy cover as the groups mature to VSS 4, 5 and 6. By following the 

stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

722 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

density would meet and exceed the canopy cover requirements. Stocking guidelines for tree 

groups for the dispersal post-fledging family areas / post-fledging family areas stand 

improvement types SI40, SI25, and SI10 mechanical thin treatments are described in table 140

(see Kaibab NF forest plan consistency crosswalk in the vegetation report).

Table 140. Stocking guidelines for tree groups in dispersal post-fledging family areas / post-fledging 

family areas stand improvement (SI) treatments 

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

1 & 2 

(20)

0–4.9 19 48 96 144 193 134–302 NA NA

3 (20) 5–11.9 14 34 68 102 136 83–215 NA NA

4 (20) 12–17.9 7 18 35 53 70 51–115 70–146 89–185

5 (20) 18–23.9 4 10 20 29 39 28–59 43–79 54–96

6 (20) at least 

24

3 7 14 20 27 26–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4 classes are equivalent 

to 55 percent canopy cover(guidance for 1/3 60 percent and 2/3 50 is actually 53 percent, 55 percent is a higher 

average percent canopy cover than the minimum guidance); densities within the VSS 5 and VSS 6 classes are 

equivalent to 50 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5, and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Interspace width between tree groups would average from 25 to 80 feet with a maximum width of 

200 feet. Average interspace width would vary depending on treatment intensity as described in 

table 141. 

Table 141. Interspace percent and width in dispersal post-fledging family areas / post-fledging family 

areas stand improvement (SI) treatments 

Treatment Type and 

Intensity

Percent of Area 

Occupied by Interspace Average Interspace Width (feet)

SI40 40–55 60–80

SI25 25–40 40–60

SI10 10–25 25–40

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak, juniper, and pinyon species would not be cut with the following exceptions: 

seedling/sapling, young, and mid-aged pinyon and juniper up to 11 inches diameter at the root 

collar may be cut within a 50-foot radius of individual or groups of old ponderosa pine (as 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 723
Appendix D – Alternatives B-E Implementation Plan

defined in the old tree implementation plan, section C); and, when there is no other option to 

facilitate logging operations (skid trail and landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired dispersal post-fledging family areas 

/ post-fledging family areas stand improvement (SI) forest structure, tree densities, snag densities, 

and coarse woody debris levels.

Dispersal Post-fledging Family Areas / Post-fledging Family Areas Pine Sage 

Mechanical and Burn Treatment Design

Restore pre-settlement tree density and pattern using pre-settlement evidence as guidance.

Treatments would strive to attain an overall stand average density of 30 to 50 square feet of basal 

area and 15 to 25 percent of maximum stand density index inclusive of individual trees, tree 

groups, and interspaces. Density would vary within this range depending on existing stand 

structure. See section E for more detail on the relationship of overall density to interspace and 

tree groups. 

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Retain all pre-settlement trees and the largest post-settlement trees available that most closely 

resemble old trees in size and form as replacement trees adjacent to pre-settlement tree evidences. 

Some younger trees would also be retained to maintain uneven-aged structure.

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

On approximately 87 acres (about 87 acres on the Kaibab NF) of post-fledging family areas pine 

sage non- wildland-urban interface stands with a preponderance of large trees (at a minimum all 

VSS 5 and 6 stands and VSS 4 stands with a mean basal area greater than 70 of the VSS4 size 

class and a mean trees per acre less than 100 of the VSS 4 size class) would be managed for 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

724 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

greater residual canopy cover and density of large trees. Residual stand structure would be 

managed at the upper end of natural range of variability for ponderosa pine in the non- wildlandurban interface stands that meet these conditions. This would be accomplished by focusing 

treatments towards the lower end of the identified intensity range, managing for larger group 

sizes (see below), and/or retaining additional large trees. Post treatment canopy cover in these 

stands would meet or exceed 40 percent, measured at the stand scale (alternative C and E only).

Replacement tree density would be managed to meet the canopy cover requirement of mid-aged 

forest (VSS 4) should average one-third 60 plus percent and two-thirds 50 plus percent. Mature 

(VSS 5) and old forest (VSS 6) should average 50 plus percent tree groups. By following the 

stocking guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group 

density would meet and exceed the canopy cover requirements. Stocking guidelines for VSS 4, 5 

and 6 tree groups for the pine sage mechanical thin treatments are as described in table 142. 

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

inches d.b.h., and, (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks. 

Gambel oak would not be cut unless there is no other option to facilitate logging operations (skid 

trail and landing locations). 

Table 142. Stocking guidelines for VSS 4–6 tree groups in dispersal post-fledging family areas / postfledging family areas pine-sage treatments

VSS 

Class

(% of 

area)

d.b.h. 

Class 

(inches)

Typical Trees Per Group Stocking at the 

Midpoint Diameter of the VSS Class1

Within Group Trees Per Acre 

Range2

1/10-ac 

group

1⁄4-ac 

group

1⁄2-ac 

group

3⁄4-ac 

group

1-ac 

group

Lower 

Density

Middle 

Density

Upper 

Density

4 (20) 12–17.9 7 18 35 53 70 51–115 70–146 89–185

5 (20) 18–23.9 4 10 20 29 39 28–59 43–79 54–96

6 (20) at least 

24

3 7 14 20 27 26–38 40–49 51–61

1. These are typical values for the mid-point diameter of the VSS class. Densities within the VSS 4 classes are equivalent 

to 55 percent canopy cover(guidance for 1/3 60 percent and 2/3 50 is actually 53 percent, 55 percent is a higher 

average percent canopy cover than the minimum guidance); Densities within the VSS 5 and VSS 6 classes are 

equivalent to 50 percent canopy cover. Densities within the VSS 1, 2, and 3 classes are to maintain tree stocking 

necessary to provide for desired canopy cover as the groups mature to VSS 4, 5 and 6.

2. Variation in tree group stocking above the minimum required to maintain canopy cover can occur and is desired. The 

smallest trees per acre number for the range pertains to the largest diameter of the VSS class, the highest trees per 

acre number for the range pertains to the smallest diameter of the VSS class. See section D for further detail on 

stocking by diameter.

Juniper and pinyon species in the seedling/sapling, young, and mid-aged stages would generally 

be cut except where needed as replacements for pre-settlement trees. Mature juniper and pinyon 

would only be cut when there is no other option to facilitate logging operations (skid trail and 

landing locations). 

Gambel oak, juniper, and pinyon species greater than 5 inches diameter at the root collar may be 

considered as residual trees in the target group spacing and stocking. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 725
Appendix D – Alternatives B-E Implementation Plan

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation. Prescribed fires are designed to 

maintain and enhance desired dispersal post-fledging family areas / post-fledging family areas 

savanna/grassland forest structure, tree densities, snag densities, and coarse woody debris levels.

Dispersal Post-fledging Family Areas / Post-fledging Family Areas Burn Only Treatment 

Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height, reduce litter/duff cover, and 

produce effects that stimulate regeneration and growth of native herbaceous vegetation. 

Prescribed fires are designed to maintain and enhance desired dispersal post-fledging family areas 

/ post-fledging family areas forest structure, tree densities, snag densities, and coarse woody 

debris levels.

Nest Area

Vegetation Management Direction: Provide unique nesting habitat conditions for goshawks. 

Important features include trees of mature to old age with high canopy cover. The structure of the 

vegetation within nest areas is associated with the forest type, and tree age, size and density, and

the developmental history of the stand. Table 143 represents RMRS-GTR-217 attributes required 

for goshawks on location with “low” and “high” site productivity. The nesting area contains only 

mature to old forest (VSS 5 and 6) having a canopy cover (measured vertically) between 50 to 70 

percent with old forest VSS 6 trees 200 to 300 years old. Nonuniform spacing of tree and 

clumpiness is desirable (see Kaibab NF forest plan consistency crosswalk in the vegetation 

report). 

Desired Conditions: Even-aged dominated by mature and/or old forest structural stages. 

Goshawk Nest Area Burn Only Treatment Design

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible.

Prescribed fires are designed to increase tree canopy base height and reduce litter/duff cover and 

other surface fuel loading. 

Prescribed fires are designed to maintain and enhance desired dispersal post-fledging family areas 

/ post-fledging family areas forest structure, tree densities, snag densities, and coarse woody 

debris levels. Desired goshawk nest stand structural attributes are as described in table 143. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

726 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Table 143. Minimum structural attributes in suitable goshawk nest stands*

Structural Attribute Minimum Metrics

Site Index under 55 at least 55

Trees/Acre 40 30

Mean d.b.h. (in.) 16 22

Age (yrs.) 200+ 200+

Total basal area (sq. ft./acre) 120 140

Overstory canopy cover 50+ 60+

VSS 5B-6 5B-6 

* GTR-RM-217, southwest ponderosa pine cover types

Landscapes Outside of Goshawk Post-fledging Areas (LOPFA) – Pinyon-Juniper

Vegetation Management Direction: Manage for uneven-age conditions to sustain a mosaic of 

vegetation densities (overstory and understory), age classes, and species composition well 

distributed across the landscape. Provide for reserve trees, snags, and down woody debris. 

Desired Conditions: Mosaic of young and mature, species diverse patches of trees interspersed 

with interspace across the landscape to promote the growth of sagebrush, oak, cliffrose, and other 

shrubs and herbaceous understory species. Mature patches would be structurally diverse, 

containing large live and dead standing trees as well as trees with dead or broken tops, gnarls, and 

burls. The structure and composition reflects the natural range of variability. 

Pinyon Juniper (PJ) Wildland-urban Interface Mechanical Thin and Burn Treatment 

Design

Uneven-age thinning would be used to establish interspace between tree groups and thin tree 

groups within landscapes outside of goshawk post-fledging areas pinyon juniper sites.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities and dead tops would also be favored for retention. 

Retain one to three groups per acre containing approximately 5 to 30 trees each (averaging 30 to 

60 trees per acre across the site). Form groups around existing concentrations of large, mature 

trees. Retain additional healthy, young, free-to-grow trees within groups where possible. 

Between groups, thin from below to 16 inches diameter at the root collar for pinyon and juniper 

and 16 inches d.b.h. for ponderosa pine. 

Where ponderosa pine is present, retain all pre-settlement yellow pines and one to two 

replacement blackjacks per existing yellow pine or pre-settlement evidence (i.e., to approximate 

the naturally occurring stand composition). Replacement blackjacks should be comprised of a 

variety of size classes. Blackjacks would be retained within 100 feet of the yellow pine or presettlement evidence they are replacing.

Manage for the sustainability of large oaks by removing ladder fuels and overtopping trees. 

Remove ponderosa pine that are within 30 feet of the base of oak 10 inches diameter at the root 

collar or larger as follows: (1) On the southerly side of the oak (135 to 315 degrees) trees up to 18 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 727
Appendix D – Alternatives B-E Implementation Plan

inches d.b.h., and, (2) On the northerly side of the oak (316 to 134 degrees) trees in the 

intermediate or suppressed crown positions up to 18 inches d.b.h. Exceptions to removal would 

be trees that meet the old tree definition and trees that have interlocking crown with oaks.

Gambel oak would not be cut with the exception of when there is no other option to facilitate 

logging operations (skid trail and landing locations). 

Snags would be managed for one per acre over 75 percent of the area and coarse woody debris

would be managed for an after treatment average of 1 to 3 tons per acre. Where available, a 

portion of the coarse woody debris would include two logs at least 10 inches and at least 10 feet 

in length. 

Prescribed burns may be used to treat fuels and mitigate fuel hazards where and when feasible by 

increasing tree canopy base height, reducing litter/duff cover, and producing effects that stimulate 

regeneration and growth of native herbaceous vegetation.

Prescribed fires are designed to maintain and enhance desired landscapes outside of goshawk 

post-fledging areas pinyon juniper wildland-urban interface forest structure, tree densities, snag 

densities, and coarse woody debris levels.

Other Areas outside Mexican Spotted Owl and Goshawk Habitats

Aspen

Vegetation Management Direction: Conifer removal, partial removal of overstory aspen, 

ground-disturbing activities, and fire would be used to stimulate aspen sprouting in areas that 

have or previously had aspen. 

Desired Conditions: Aspen is successfully regenerating and recruiting into older and larger size 

classes. Size classes have a natural distribution, with the greatest number of stems in the smallest 

classes. Coniferous species comprise less than 10 percent of the overstory.

Aspen Mechanical Thin and Burn Treatment Design

Inclusions of aspen remnants within portions of ponderosa pine stands would be regenerated by 

removing all post-settlement conifers from within 100 feet of the aspen clone. Some removal of 

aspen within the clone as well as ground-disturbing activity or burning may occur to stimulate 

suckering.

Per the Collaborative Forest Landscape Restoration Act requirements, treatments in alternatives B 

through E are designed to focus on small diameter tree thinning, with the objective of maximizing 

the retention of large trees – thus meeting desired conditions of increasing VSS 5 and 6 age 

classes as soon as possible. In alternatives C and E, treatments would also follow the guidance in 

section D, the large tree implementation plan.

To meet the desired condition of increasing VSS 5 and 6 age class, priority of tree retention 

within groups would focus on existing large trees (generally, trees within the dominant and 

codominant crown position). Where age class diversity is not present, suppressed and 

intermediate trees would be retained for vertical diversity.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

728 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities, dead tops, and lightning scars would also be favored for retention. 

Snags would be managed for two per acre at least 18 inches, coarse woody debris would be 

managed for 5 to 7 tons per acre, and downed logs would be managed for three per acre at least 

12 inches. 

Each clone would be evaluated as to need for fencing or creation of other barriers to reduce 

ungulate browsing of regenerating aspen. 

Prescribed burns may be used where and when feasible to treat fuels, mitigate fuel hazards, and to 

produce effects that stimulate aspen suckering and regeneration, and growth of native herbaceous 

vegetation. Prescribed fires are designed to maintain and enhance desired aspen forest structure, 

tree densities, snag densities, and coarse woody debris levels.

Aspen Burn Only Treatment Design

Inclusions of aspen remnants within portions of ponderosa pine stands would be regenerated by 

prescribed burning to stimulate suckering. 

Prescribed burns are designed to reduce post-settlement conifer stocking within 100 feet of the 

aspen clone and disturb the site with sufficient intensity to encourage aspen regeneration.

Each clone would be evaluated as to need for fencing or creation of other barriers to reduce 

ungulate browsing of regenerating aspen. 

Grassland

Vegetation Management Direction: Reduce conifer encroachment within grasslands as 

identified by mollisol soils.

Desired Conditions: Restore historic grassland/forest edge as indicated by existing presettlement conifers and evidence of pre-settlement conifers.

Grassland Mechanical Thin and Burn Treatment Design (Alternative C Only)

Treatments are designed to promote and reestablish the historic meadow edge as defined by presettlement trees and evidences and the current forest structure of young trees encroaching on the 

edge of the grassland.

Treatments are designed to manage for old age trees in order to have and sustain as much old 

forest structure as possible across the landscape. Treatments would follow the old tree 

implementation plan (section C), and old trees would not be targeted for cutting. Live conifer 

trees with existing cavities and dead tops would also be favored for retention. 

Tree group arrangement, size, and density are a function of existing pre-settlement trees and 

evidence. Retain all pre-settlement trees and the largest post-settlement trees that most closely 

resemble old trees in size and form as replacement trees adjacent to pre-settlement tree evidences 

at a 1:1 ratio. Ponderosa pine, pinyon, and juniper not meeting long-lived characteristics may be 

removed. 

Gambel oak would be retained. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 729
Appendix D – Alternatives B-E Implementation Plan

Prescribed burns may be used where and when feasible to treat fuels, mitigate fuel hazards, and to 

produce effects that stimulate regeneration and growth of native herbaceous vegetation. 

Prescribed fires are designed to maintain and enhance desired grassland conditions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

730 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Section B – Decision Matrix 

Table 144. Section B decision matrix for establishing tree groups, interspace, and regeneration openings

Feature Placement

Reserve Trees 

within Feature Thinning

Thinning Leave Tree 

Criteria

Large Tree Implementation Plan

(Alternative C)

Tree Group 1 – Abundance of presettlement tree evidence

2 – Underrepresented 

tree classes (e.g., free to 

grow seedling/saplings; 

trees of different cohort 

than neighboring trees)

3 – High percentage of 

trees exhibiting good 

health and vigor

 4- Groups dominated by 

a preponderance of large 

young trees

1 – Old tree 

characteristics (old tree 

implementation plan) 

regardless of size

2 – Oak, pinyon, and 

juniper with exceptions

3 – Wildlife trees 

(cavities, dead tops)

Tree group 

stocking 

guidelines.

1 – Trees in the dominant and 

codominant crown position 

exhibiting vigor relative to age 

regardless of size (usually large 

young trees)

2 – Crown ratio >40% desirable; 

crown ratio 25–40% acceptable

3 – Free of mistletoe or low 

dwarf mistletoe rating relative to 

neighboring trees; free of pine 

beetle activity

4 – Trees >12′′ high percentage 

of interlocking crown; Trees 

<12′′ ability to develop 

interlocking crown

Heavily-Stocked Stands (with high BA) Generated 

by a Preponderance of Large, Young Trees

Does the decision matrix meet the conditions 

described by the large tree implementation plan 

category:

Yes ______

No ______

If no, describe what the condition(s) is, and why it 

does not meet the exception:

_____________________________________

_____________________________________

Ponderosa Pine/Gambel Oak Forest

Does the decision matrix meet the conditions 

described by the large tree implementation plan 

category:

Yes ______

No ______

If no, describe what the condition(s) is, and why it 

does not meet the exception:

_____________________________________

_____________________________________

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

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Appendix D – Alternatives B-E Implementation Plan

Feature Placement

Reserve Trees 

within Feature Thinning

Thinning Leave Tree 

Criteria

Large Tree Implementation Plan

(Alternative C)

Interspace 1 – Little to no pre–

settlement tree evidence

2 – Existing nonstocked 

openings

3 – High percentage of 

trees exhibiting poor 

health and vigor

4 - Contiguous area of 

well-represented cohorts

1 – Old tree 

characteristics (old tree 

implementation plan) 

regardless of size.

2 – Oak, pinyon and 

juniper

3 – Wildlife trees 

(cavities, dead tops)

NA NA Within-Stand Openings:

Does the decision matrix meet the conditions 

described by the large tree implementation plan 

category:

Yes ______

No ______

If no, describe what the condition(s) is, and why it 

does not meet the exception:

____________________________________

____________________________________

Regeneration 

Opening

1 – Contiguous area of 

well-represented cohort.

2 – Isolated patch of 

mistletoe infected trees 

within the wellrepresented cohort.

3 – Adjacent to seed 

bearing tree groups that 

are free of mistletoe 

infection.

4- Where stand structure 

dictates, establish 

regeneration openings 

by removing groups of 

trees of VSS3 and 

smaller diameter VSS4. 

Avoid placing in 

preponderance of large 

young trees.

1 – Old tree 

characteristics (old tree 

implementation plan)

regardless of size.

2 – Oak, pinyon, and 

juniper

3 – Wildlife trees 

(cavities, dead tops)

4 – Largest, healthiest, 

seed bearing ponderosa 

pine (within openings 

>1 ac)

NA NA NA

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

732 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Section C – Old Tree Implementation Plan 

Old Tree Descriptions and Illustrations

Old trees (approximately over 150 years old) would be retained, with few exceptions, regardless 

of their diameter, within the 4FRI on the Coconino and Kaibab NF’s EIS area. Removal of old 

trees would be rare. Exceptions would be made for threats to human health and safety, and those 

rare circumstances where the removal of an old tree is necessary in order to prevent additional 

habitat degradation. Old trees would not be cut for forest health issues or to balance age or size 

class distributions. 

One example of a situation where the removal of an old tree is necessary in order to prevent 

additional habitat degradation is in the rare case of an old tree growing on the side of an existing 

curve in a road. Logging equipment may require a wider turning radius. The options are to 

relocate the road or cut the old tree and widen the curve to accommodate the larger turning radius. 

Relocating the road would result in a larger area of the forest being permanently disturbed, versus 

cutting the large tree and widening the curves radius. This is an example where cutting the old 

tree would result in less habitat degradation then relocating a road. 

Old trees would be determined by the following characteristics described by Thomson (1940) as 3 

(intermediate-mature) and 4 (mature to over-mature). 

• Age – Approximately 150 years and older.

• D.b.h. – Site dependent.

• Bark – ranging from reddish brown, shading to black in the top with moderately large plates 

between the fissures to reddish brown to yellow, with very wide, long, and smooth plates. 

• Tops – ranging from pyramidal or rounded (occasionally pointed) to flat (making no further 

height growth). 

• Branching – ranging from upturned in upper third of the crown, horizontal in the middle 

third, and drooping in the lower third of the crown to mostly large, drooping, gnarled, or 

crooked. Branch whorls range from incomplete and indistinct except at the top to completely 

indistinct and incomplete. 

Figure 65 and figure 66 display illustrations of size class 3 (intermediate-mature) and size class 4 

(mature-overmature) from Thompson 1940. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

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Appendix D – Alternatives B-E Implementation Plan

Figure 65. Old tree characteristics (Thompson 1940)

Figure 66. Old age tree characteristics continued (Thompson 1940)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

734 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Section D – Modified Large Tree Implementation Plan 

(Alternatives C and E) 

Introduction 

The large tree implementation plan is specific to alternative C and E. It is designed to reflect the 

Collaborative Forest Landscape Restoration Act requirements regarding large tree retention by 

clarifying the intent to focus restoration treatments on small-diameter tree thinning, to retain large 

trees whenever possible, and to more specifically design treatments so that large trees would be 

retained unless they must be cut to meet the desired conditions listed in the categories below. It 

responds to comments received during scoping (August 2011). The plan’s desired conditions are 

consistent with the summarized desired conditions found in the project’s purpose and need and 

the plan provides additional citations that support the desired conditions. It incorporates the old 

tree implementation plan by reference.

For the purpose of this document, large post-settlement trees, as defined by the socio-political 

process, are those that are 16 inches d.b.h. or larger. Trees greater than or equal to 18 inches d.b.h. 

represent VSS 5 and 6. VSS 5 and 6 represent the largest and (sometimes) oldest trees. These size 

classes best correspond with the successional age classification system that was developed to 

address the forest dynamics of southwestern ponderosa pine. 

The plan may not include every instance where large post-settlement trees may be cut. There may 

be additional areas and/or circumstances where large post-settlement trees need to be removed in 

order to achieve restoration objectives. During implementation (prescription development), if a 

condition exists that does not the meet the desired conditions included in this strategy, no large 

trees would be cut until the NEPA decision is reviewed by the Forest Service implementation 

team. The team would decide whether the action is consistent with the analysis and the decision 

made. This information would be made part of the annual implementation plan 

checklist/compliance review that is recommended by the team and approved by the forest 

supervisor. 

Seeps and Springs

Seeps are locations where surface-emergent groundwater causes ephemeral or perennial moist 

soil or bedrock. Standing or running water is infrequent or absent. Vegetation and other biological 

diversity are adapted to mesic soils. Springs are small areas where surface-emergent groundwater 

causes ephemeral or perennial standing or running water and wet or moist soils. Vegetation and 

other biological diversity are adapted to mesic soils or aquatic environments (Feth and Hem 

1963). 

Seeps and springs exhibit unique, often isolated biophysical conditions that can sustain unique, 

mesic-adapted biological diversity, and can facilitate endemism and speciation. Springs also 

provide water and other habitat to terrestrial wildlife. Due to the absence of frequent fires in the 

presence of livestock grazing, the establishment of large post-settlement trees may reduce 

available soil moisture (Simonin et al. 2007) and block the sunlight necessary to support the 

unique biophysical conditions associated with seeps and springs. 

Removal of trees that have encroached upon seeps and springs may constitute a relatively small 

part of an overall seep and spring restoration effort, when compared to fully addressing root 

causes of overall degradation. Thinning alone, without addressing other sources of degradation, is 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 735
Appendix D – Alternatives B-E Implementation Plan

unlikely to fully restore seeps and springs (Thompson et al. 2002). However, it is a necessary step 

leading to the restoration of these ecologically important areas.

Desired Conditions

• The biophysical conditions in seeps and springs upon which terrestrial, mesic-adapted, and 

aquatic native biological diversity depend are conserved and restored.

• The integrity of the spring’s unique biophysical attributes is not compromised by tree 

shading. 

• Mesic soils associated with a seep or spring are not encroached upon by conifers. 

• If treatment occurs, an equivalent number of large replacement trees remain where there is 

evidence that pre-settlement trees have grown in similar root and crown proximity to a 

particular seep or spring in the past.

Riparian 

Riparian areas occur along ephemeral or perennial streams or are located downgradient of seeps 

or springs. These areas exhibit riparian vegetation, mesic soils, and/or aquatic environments.

Riparian areas exhibit unique biophysical conditions that can sustain unique, mesic-adapted, or 

aquatic biological diversity. Riparian areas and the streams, springs, and seeps connected to them 

often harbor imperiled species that can be sources of endemism. Riparian areas also provide 

water and other habitat to terrestrial wildlife. In the absence of frequent fires and in the presence 

of other competing factors, large post-settlement trees may have become established and grown 

within riparian areas to the point that they compromise available soil moisture or light that 

support the unique biophysical conditions that are associated with the riparian areas. However, it 

is likely to be a very rare circumstance that conifer trees of any size would need to be removed 

from forested riparian zones. 

Desired Conditions

• The biophysical conditions in riparian habitat upon which terrestrial and aquatic native 

biological diversity depends are conserved and restored.

• The use of soil and water best management practices (BMPs) minimize the impacts of cutting 

trees within riparian areas.

• Removal of trees constitutes a relatively small part of an overall riparian area restoration 

effort, when compared to the fundamental causes of overall degradation. Riparian areas are 

fully restored by using an array of tools that address all sources of degradation. 

• Available soil moisture or light that support that area’s unique biophysical conditions is not 

compromised by growing (rooted) trees. 

• If treatment occurs, an equivalent number of large replacement trees remain where there is 

evidence that pre-settlement trees have grown in similar root and crown proximity to a 

particular seep or spring in the past.

• Post-treatment snags and logs that include large trees are available onsite.

Wet Meadows

High elevation streamside or spring-fed meadows occur in numerous locations throughout the 

Southwest. However, less than 1 percent of the landscape in the region is characterized as wetland 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

736 Coconino and Kaibab National Forests 
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(Dahl 1990), and wet meadows are just one of several wetland types that occur. Patton and Judd 

(1970) reported that approximately 17,700 hectares of wet meadows occur on national forests in 

Arizona and New Mexico.

Wet meadows may be referred to as riparian meadows, montane (or high elevation) riparian 

meadows, sedge meadows, or simply as wet meadows. Wet meadows are usually located in 

valleys or swales, but may occasionally be found in isolated depressions, such as along the 

fringes of ponds and lakes with no outlets. Where wet meadows have not been excessively 

altered, sedges (Carex spp.), rushes (Juncus spp.), and spikerush (Eleocharis spp.) are common 

species (Patton and Judd 1970, Hendrickson and Minckley 1984, Muldavin et al. 2000). Willow 

(Salix) and alder (Alnus) species often occur in or adjacent to these meadows (Long 2000, Long 

2002, Maschinski 2001, Medina and Steed 2002). High elevation wet meadows frequently occur 

along a gradient that includes aquatic vegetation at the lower end and mesic meadows, dry 

meadows, and ponderosa pine or mixed conifer forest at the upper end. These vegetation 

gradients are closely associated with differences in flooding, depth to water table, and soil 

characteristics (Judd 1972, Castelli et al. 2000, Dwire et al. 2006). While relatively rare, wet 

meadows are believed to be of disproportionate value because of their use by wildlife and the 

range of other ecosystem services they provide. Wet meadows perform many of the same 

ecosystem functions associated with other wetland types, such as water quality improvement, 

reduction of flood peaks, and carbon sequestration. 

Wet meadows are one of the most heavily altered ecosystems. They have been used extensively 

for grazing livestock, have become the site of many small dams and stock tanks, have had roads 

built through them, and have experienced other types of hydrologic alterations. Most notably, the 

lowering of their water tables due to stream downcutting, surface water diversions, or 

groundwater withdrawal (Neary and Medina 1996) has occurred. In the presence of livestock 

grazing and hydrologic changes, large post-settlement trees may have established and grown 

within wet meadows such that they compromise available soil moisture or light creating unique 

biophysical conditions.

Desired Conditions

• The biophysical conditions of wet meadows upon which terrestrial native biological diversity 

depend are conserved and restored.

• Wet meadow function is not impaired by growing (rooted) trees. 

• If treatment occurs, an equivalent number of large replacement trees remain where there is 

evidence that pre-settlement trees have grown in similar root and crown proximity to a 

particular seep or spring in the past.

• Removal of large trees constitutes a relatively small part of an overall riparian area restoration 

effort, when compared to the fundamental causes of overall degradation. Wet meadows are 

fully restored by using an array of tools that address all sources of degradation. 

Encroached Grasslands

Encroached grasslands are herbaceous ecosystems that have infrequent to no evidence of pine 

trees growing prior to settlement. The two prevalent grassland categories in the 4FRI landscape 

are montane (includes subalpine) grasslands and Colorado Plateau (a subset of Great Basin) 

grasslands, with montane grasslands being most common (Finch 2004). A key indicator of 

grasslands is the presence of mollisol soils. Mollisol soils are typically deeper with higher rates of 

accumulation and decomposition of soil organic matter relative to soils in the surrounding 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 737
Appendix D – Alternatives B-E Implementation Plan

landscape. Grasslands in this region evolved during the Miocene and Pliocene periods, and the 

dark, rich soils observed in grasslands today have taken more than 3 million years to produce. In 

addition to their association with mollic soils, grasslands in this region are maintained by a 

combination of climate, fire, wind desiccation, and, to a lesser extent, by animal herbivory (Finch 

2004). 

Typical montane grasslands in this region are characterized by Arizona fescue (Festuca arizonica) 

meadows on elevated plains of basaltic and sandstone residual soils. Montane grasslands 

generally occur in small (under 100 acres) to medium sized (100 to 1,000 acres) patches. Historic 

maintenance of the herbaceous condition in these grasslands is subject to some debate though 

appears to be primarily driven by periodic fire. The cool-season growth of Arizona fescue also 

plays a large role in maintenance of parks and openings by directly competing with ponderosa 

pine seedlings. Identification of grasslands in this region should use a combination of the TES, 

Southwest Regional GAP Analysis, and Brown and Lowe Vegetation Classification (Brown and 

Lowe 1982, TNC GIS Layer 2006) among other existing vegetation and soils data. 

Prior to European settlement, pine trees were rarely established in grasslands because they were 

either outcompeted by production of cool-season grasses or killed by frequent fire (Finch 2004). 

In the late 1800s, unsustainable livestock grazing practices significantly reduced herbaceous 

cover, reducing competition pressure on pine seedlings. Coupled with the onset of fire 

suppression in the early 1900s, pine trees rapidly encroached and recruited into native grasslands 

(e.g., Moore and Huffman 2004, Coop and Givnish 2007). Plant diversity is particularly 

important in grassland ecosystems. Grassland plots with greater species diversity have been found 

to be more resistant to drought and to recover more quickly than less diverse plots (Tilman and 

Downing 1994). This resilience will become even more important in a warming climate. Pine tree 

removal, restoration of fire, and complementary reductions in livestock grazing pressure are all 

necessary to restore structure and function of native grasslands.

Desired Conditions

• Grasslands are enhanced, maintained, and function with potential natural vegetation (as 

defined by vegetative mapping units). 

• Grasslands function with a natural fire regime.

• Existing grasslands are not encroached upon by conifers.

• If treatment occurs, an equivalent number of large replacement trees remain where there is 

evidence that pre-settlement trees have grown in similar root and crown proximity to a 

particular seep or spring in the past.

Aspen Forest and Woodland

Quaking aspen (Populus tremuloides) occurs in small patches throughout the 4FRI project area. 

Bartos (2001) refers to three broad categories of aspen: (1) stable and regenerating (stable), (2) 

converting to conifers (seral), and (3) decadent and deteriorating. Almost all of the aspen 

occurring within ponderosa pine forests of the 4FRI project area is seral aspen, which regenerates 

after disturbance through root sprouting and rarely from seed production (Quinn and Wu 2001). 

Favorable soil and moisture conditions maintain stable aspen over time. Aspen stands have been 

mapped across the entire 4FRI area and map layers are available from existing databases.

Aspen occurs within ponderosa pine forests. It is ecologically important due to the high 

concentration of biodiversity that depends on aspen for habitat (Tew 1970, DeByle 1985, Finch 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

738 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

and Reynolds 1987, Griffis-Kyle and Beier 2002). In addition, stable aspen stands serve as an 

indicator of ecological integrity (Di Orio et al. 2005). Aspen is currently declining at an alarming 

rate (Fairweather et al. 2008).

The lack of fire as a natural disturbance regime in southwestern ponderosa pine forests since 

European settlement has caused much of the aspen dominated lands to cede to conifers (Bartos 

2001). Other factors contributing to gradual aspen decline over the past 140 years include reduced 

regeneration from browsing ungulates (Pearson 1914, Larson 1959, Martin 1965, Jones 1975, 

Shepperd and Fairweather 1993, Martin 2007). More recently, aerial and ground surveys indicate 

more rapid decline of aspen, with very high mortality occurring in low and mid-elevation aspen 

sites. Major factors thought to be causing this rapid decline of aspen include frost events, severe 

drought, and a host of insects and pathogens (Fairweather et al. 2008) that have served as the 

“final straws” for already compromised stands.

Desired Conditions

• Aspen forests and woodlands are conserved and restored to their appropriate fire regime.

• Aspen is effectively being regenerated or maintained, and regeneration, saplings, and juvenile 

trees are protected from browsing.

• There is decreased competition from ponderosa pine. Post-settlement ponderosa pine tree 

numbers do not exceed residual targets that have been identified using pre-settlement conifer 

tree evidences, site visitations, and collected data.

• Removal of large trees constitutes a relatively small part of the aspen restoration effort, when 

compared to the fundamental causes of overall degradation. Aspen forests and woodlands are 

fully restored by using an array of tools that address all sources of degradation. 

Ponderosa Pine/Gambel Oak Forest (Pine-Oak PIPO/QUGA) 

A number of habitat types exist in the southwestern United States that could be described as pineoak. Ponderosa pine forests are interspersed with Gambel oak trees in locations throughout the 

4FRI area in a habitat association referred to as PIPO/QUGA (USDA FS 1997, USDI FWS 1995). 

In southwestern ponderosa pine forests, Gambel oak has several growth forms distinguished by 

stem sizes and the density and spacing of stems within clumps. These include shrubby thickets of 

small stems, clumps of intermediate-sized stems, and large, mature trees that are influenced by 

age, disturbance history, and site conditions (Kruse 1992, Rosenstock 1998, Abella and Springer 

2008, Abella 2008a). Different growth forms provide important habitat for a large number and 

variety of wildlife species (Neff et al. 1979, Kruse 1992). These include hiding cover in a 

landscape with limited woody shrub cover, cavity substrate for birds and bats, roost potential for 

bats, nest sites for birds, and bark characteristics used by invertebrates. Whether as saplings, 

shrubby thickets, or larger sized trees, oak adds a high value for wildlife in ponderosa pine 

forests.

Gambel oak provides high quality wildlife habitat in its various growth forms and is a desirable 

component of ponderosa pine forests (Neff et al. 1979, Kruse 1992, Bernardos et al. 2004). 

Gambel oak enhances soils (Klemmedson 1987), wildlife habitat (Kruse 1992, Rosenstock 1998, 

USDI FWS 1995, Bernardos et al. 2004), and understory community composition (Abella and 

Springer 2008). Large oak trees are particularly valuable since they typically provide more 

natural cavities and pockets of decay that allow excavation and use by cavity nesters than 

conifers. In addition to its important ecological role, Gambel oak has high value to humans as it is 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 739
Appendix D – Alternatives B-E Implementation Plan

a popular firewood that possesses superior heat-producing qualities compared to other tree 

species (Wagstaff 1984).

Although management on public lands with regard to oak has changed to better protect the 

species, illegal firewood cutting of Gambel oak, and elk and livestock grazing negatively impact 

oak growth and regeneration (Harper et al. 1985, Clary and Tiedemann 1992). Illegal firewood 

cutting of Gambel oak continues to result in the removal of rare, large diameter oak trees 

(Bernardos et al. 2004). 

A literature review by Abella and Fulé (2008) found that Gambel oak densities appear to have 

increased in many areas with fire exclusion, especially in the small and medium diameter stems 

(under 8 inches d.b.h.). Chambers (2002) found that Gambel oak on the Kaibab and Coconino 

NFs was distributed in an uneven-aged distribution, dominated by smaller size classes (under 5 

centimeter d.b.h.) and few large diameter oak trees. Because of Gambel oak’s slow growth rate, 

there may be little opportunity for these small Gambel oak trees to attain large diameters (over 85 

centimeters) (Chambers 2002). 

Pine competition with oak has been identified as an issue in slowing oak growth, particularly for 

older oaks (Onkonburi 1999). Onkonburi (1999) also found that for northern Arizona forests, pine 

thinning increased oak incremental growth more than oak thinning and prescribed fire. Fulé 

(2005) found that oak diameter growth tended to be greater in areas where pine was thinned 

relative to burn only treatments and controls. Thinning of competing pine trees may promote 

large oaks with vigorous crowns and enhanced acorn production (Abella 2008b), and may 

increase oak seedling establishment (Ffolliott and Gottfried 1991). 

Desired Conditions

All Gambel Oak

• Small oak trees develop into larger size classes.

• Fire treatments retain small and shrubby oak in numbers and distribution. 

• All growth forms of Gambel oak are present and larger, older oak trees are enhanced and 

maintained.

• Large, post-settlement trees are not restricting oak development.

• Frequent, low intensity surface fire occurs in ponderosa pine-Gambel oak forests.

• Brushy thicket, pole, and dispersed clump growth forms of Gambel oak are present and 

maintained by allowing natural self-thinning, thinning dense clumps, and/or burning. 

• Gambel oak growth forms are protected from damage during restoration treatments including 

thinning and post-thinning slash burning. 

• Non-wildland-urban interface stands with a preponderance of large trees (at a minimum all 

VSS 5 and 6 stands and VSS 4 stands with a mean basal area greater than 70 and a mean trees 

per acreless than 100) would be managed for greater residual canopy cover and density of 

large trees. Residual stand structure would be managed at the upper end of natural range of 

variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes, and/or retaining additional large 

trees.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

740 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

In Mexican Spotted Owl Restricted Habitat

• Within Mexican spotted owl habitat and designated critical habitat, the recovery plan for the 

Mexican spotted owl improves key habitat components and primary biological factors, which 

includes Gambel oak. 

• Within 30 feet of oak 10- inch diameter at the root collar or larger, post-settlement mixed 

conifer trees up to 18 inches d.b.h. (that do not have interlocking crowns with oak) are not 

restricting oak development. 

Outside Mexican spotted owl Restricted Habitat

• Large post-settlement trees’ drip lines or roots do not overlap with those of Gambel oak trees 

over 8 inch diameter at the root collar. 

Within-stand Openings

Within-stand openings are small openings (generally 0.05 to 1.0 acres) that were occupied by 

grasses and wildflowers before settlement (Pearson 1942, White 1985, Covington and Sackett 

1992, Sánchez Meador et al. 2009). For the purposes of this strategy, within-stand openings are 

equivalent to interspaces. The within-stand opening management approach described below is 

distinct from, and should not be considered as guidance relating to regeneration openings. 

Pre-settlement openings can be identified by the lack of stumps, stump holes, and other evidence 

of pre-settlement tree occupancy (Covington et al. 1997). These openings are most pronounced 

on sites with heavy textured (e.g., silt-clay loam) soils (Covington and Moore 1994). Current 

openings include fine-scaled canopy gaps. It is not necessary to have desired within-stand 

openings and groups located in the same location that they were in before settlement (the site 

fidelity assumption). Trees might be retained in areas that were openings before settlement, and 

openings might be established in areas which had previously supported pre-settlement trees.

Within-stand openings appear to have been self-perpetuating before overgrazing and fire 

exclusion (Pearson 1942, Sánchez Meador et al. 2009). Fully occupied by the roots of grasses and 

wildflowers as well as those of neighboring groups of trees, these openings had low water and 

nutrient availability because of intense root competition (Kaye et al. 1998). Heavy surface fuel 

loads insured that tree seedlings were killed by frequent surface fires, reinforcing the competitive 

exclusion of tree seedlings (Fulé et al. 1997).

These natural openings appear to have been very important for some species of butterflies, birds, 

and mammals (Waltz and Covington 2004). Often the largest post-settlement trees, typically a 

single tree, became established in these natural within-stand openings as soon as herbaceous 

vegetation was removed by overgrazing (Sánchez Meador et al. 2009). Contemporary withinstand openings or areas dominated by smaller post-settlement trees should be the starting point 

for restoring more natural within-stand heterogeneity. 

Desired Conditions

• The pattern of openings within stands that provide natural spatial heterogeneity for biological 

diversity are conserved.

• Openings break up fuel continuity to reduce the probability of torching and crowning and 

restore natural heterogeneity within stands. 

• Openings promote snowpack accumulation and retention which benefits groundwater 

recharge and watershed processes at the fine (1 to 10 acres) scale.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 741
Appendix D – Alternatives B-E Implementation Plan

• The presence of such trees does not prevent the reestablishment of sufficient within-stand 

openings to emulate natural vegetation patterns based on current stand conditions, presettlement evidences, desired future conditions, or other restoration objectives.

• Groups of trees typically range in size from 0.1 acre to 1 acre. Canopy gaps and interspaces 

between tree groups or individuals are based on site productivity and soil type and range from 

10 percent on highly productive sites to as high as 90 percent on those soil types that have an 

open reference condition. 

• Suitable openings for successful natural regeneration in this project would range in size from 

3/10 to 8/10 of an acre. Openings would be created by focusing on removal of VSS 3 and 

lower VSS 4, given the excess of such trees across the project area.

• Non-wildland-urban interface stands with a preponderance of large trees (at a minimum all 

VSS 5 and 6 stands and VSS 4 stands with a mean basal area greater than 70 and a mean trees 

per acreless than 100) would be managed for greater residual canopy cover and density of 

large trees. Residual stand structure would be managed at the upper end of natural range of 

variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes, and/or retaining additional large 

trees.

Heavily-Stocked Stands (with High Basal Area) 

Generated by a Preponderance of Large, Young Trees

In some areas, the increase in post-settlement trees has been so rapid that current stand structure 

is characterized by high density and high basal area in large, young ponderosa pine trees. These 

stands or groups of stands exhibit continuous canopy which promotes unnaturally severe fire 

effects under severe fire weather conditions. At the fine scale, the management approach would 

apply on a case-by-case basis. The cutting of large trees may be necessary to meet site-specific 

ecological objectives as listed below. For example, the cutting of large trees may be necessary in 

order to reduce the potential for crown fire to spread into communities or important habitats that 

include Mexican spotted owl and/or goshawk nest stands. This approach would apply when other 

options would not alleviate severe fire effects.

In stands where pre-settlement evidences, restoration objectives, community protection, or other 

ecological restoration objectives indicate much lower tree density and basal area would be 

desirable, large post-settlement pines may need to be removed to achieve post-treatment 

conditions consistent with a desired restoration trajectory. Where evidence indicates higher tree 

density and basal area would have occurred pre-settlement, only a few large pines may need to be 

removed. Many of these areas would support crown fire and, thus, require structural modification 

to reduce crown fire potential and restore understory vegetation that supports surface fire.

Desired Conditions

• Natural heterogeneity of forest, savanna, and grasslands occurs at the landscape scale and 

within stands.

• Groups are restored by retaining the largest trees on the landscape to reestablish old growth 

structure in the shortest timeframe possible.

• Decreased shading and interception from the canopy, decreased needle litter and duff, and 

surface fire restore and maintain a mosaic of natural vegetative communities.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

742 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

• Decreased shading and interception from the canopy fuels allow the growth of continuous 

herbaceous surface fuels to carry surface fire.

• Reduced horizontal and vertical canopy fuels reduce the potential for crown fire. 

• Fire is the principle regulator of forest structure over time.

• Regeneration openings that contribute to the ecological objective of natural heterogeneity of 

historical forest structure and age class diversity are not encroached upon by trees.

• Non-wildland-urban interface stands with a preponderance of large trees (at a minimum all 

VSS 5 and 6 stands and VSS 4 stands with a mean basal area greater than 70 and a mean trees 

per acreless than 100) would be managed for greater residual canopy cover and density of 

large trees. Residual stand structure would be managed at the upper end of natural range of 

variability for ponderosa pine in the non- wildland-urban interface stands that meet these 

conditions. This would be accomplished by focusing treatments towards the lower end of the 

identified intensity range, managing for larger group sizes, and/or retaining additional large 

trees.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 743
Appendix D – Alternatives B-E Implementation Plan

Section E – Density Management and the Relationship 

Between Treatment Intensity, Tree Group Density, and 

Overall Average Density

Table 145. Section E the relationship between treatment intensity, tree group density, and overall 

average density

Treatment 

Intensity

Percent of Area Percent of Treed Area

Average Group basal area (BA) to 

Achieve Overall BA of:

Interspace Tree

Groups 

and 

Individuals Regeneration 40 50 60 70 80 90

10–25 10 90 90 0 56 67 78 89 100

85 5 59 71 82 94

80 10 63 75 88 100

75 15 67 80 93 107

70 20 71 86 100 114

15 85 85 0 59 71 82 94 106

80 5 63 75 88 100

75 10 67 80 93 107

70 15 71 86 100 114

65 20 77 92 108 123

20 80 80 0 63 75 88 100 113

75 5 67 80 93 107

70 10 71 86 100 114

65 15 77 92 108 123

60 20 83 100 117 133

25–40 25 75 75 0 67 80 93 107 120

70 5 71 86 100 114

65 10 77 92 108 123

60 15 83 100 117 133

55 20 91 109 127 145

30 70 70 0 71 86 100 114 129

65 5 77 92 108 123

60 10 83 100 117 133

55 15 91 109 127 145

50 20 100 120 140 160

35 65 65 0 77 92 108 123 138

60 5 83 100 117 133

55 10 91 109 127 145

50 15 100 120 140 160

45 20 111 133 156 178

40–55 40 60 60 0 67 83 100 117 133 150

55 5 73 91 109 127 145

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

744 Coconino and Kaibab National Forests 
Appendix D – Alternatives B-E Implementation Plan

Treatment 

Intensity

Percent of Area Percent of Treed Area

Average Group basal area (BA) 

Achieve Overall BA of:

to 

Interspace Tree

Groups 

and 

Individuals Regeneration 40 50 60 70 80 90

50 10 80 100 120 140 160

45 15 89 111 133 156 178

40 20 100 125 150 175 200

45 55 55 0 73 91 109 127 145 164

50 5 80 100 120 140 160

45 10 89 111 133 156 178

40 15 100 125 150 175 200

35 20 114 143 171 200 229

50 50 50 0 80 100 120 140 160 180

45 5 89 111 133 156 178

40 10 100 125 150 175 200

35 15 114 143 171 200 229

30 20 133 167 200 233 267

55–70 55 45 45 0 89 111 133 156

40 5 100 125 150 175

35 10 114 143 171 200

30 15 133 167 200 233

25 20 160 200 240 280

60 40 40 0 100 125 150 175

35 5 114 143 171 200

30 10 133 167 200 233

25 15 160 200 240 280

20 20 200 250 300 350

65 35 35 0 114 143 171 200

30 5 133 167 200 233

25 10 160 200 240 280

20 15 200 250 300 350

15 20 267 333 400 467

BA = basal area

Note: Red fill indicates red stand density index zone for all diameters. Red zone group BA ranges from 125 square feet of 

basal area for 8 inches quadratic mean diameter to 195square feet of basal area for 24 inches quadratic mean diameter. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 745
Appendix D – Alternatives B-E Implementation Plan

Figure 67. Section E density management and stocking guidelines

Grp QMD 55 60 65 70 75 80 85 90 95 100 105 110 115 120 125 130 135 140 145 150 155 160 165 170 175 180 185 190 195

8 158 172 186 200 215 229 243 258 272 286 301 315 329 344 358

9 125 136 147 158 169 181 192 204 215 226 238 249 260 272 283 294

10 101 110 119 128 138 147 156 165 174 183 193 202 211 220 229 238 248 257

11 83 91 99 106 114 121 129 136 144 152 159 167 174 182 189 197 205 212 220

12 70 76 83 89 96 102 108 115 121 127 134 140 146 153 159 166 172 178 185 191

13 60 65 71 76 81 87 92 98 103 109 114 119 125 130 136 141 147 152 157 163 168

14 51 56 61 66 70 75 80 84 89 94 98 103 108 112 117 122 126 131 136 140 145 150

15 45 49 53 57 61 65 69 73 77 81 86 90 94 98 102 106 110 114 118 122 126 130

16 39 43 47 50 54 57 61 65 68 72 75 79 82 86 90 93 97 100 104 107 111 115 118

17 35 38 41 44 48 51 54 57 60 63 67 70 73 76 79 83 86 89 92 95 98 102 105 108

18 31 34 37 40 42 45 48 51 54 57 59 62 65 68 71 74 76 79 82 85 88 91 93 96 99

19 28 31 33 36 38 41 43 46 48 51 53 56 58 61 63 66 69 71 74 76 79 81 84 86 89 91

20 25 28 30 32 34 37 39 41 43 46 48 50 53 55 57 60 62 64 67 69 71 73 76 78 80 83

21 23 25 27 29 31 33 35 37 40 42 44 46 48 50 52 54 56 58 60 62 64 67 69 71 73 75 77

22 21 23 25 27 28 30 32 34 36 38 40 42 44 46 47 49 51 53 55 57 59 61 63 64 66 68 70 72

23 19 21 23 34 26 28 30 31 33 35 36 38 40 42 43 45 47 49 50 52 54 56 57 59 61 62 64 66

24 18 19 21 22 24 26 27 29 30 32 33 35 37 38 40 41 43 45 46 48 49 51 53 54 56 57 59 61 62

Color coding key: 

Green = SDI zones 1 and 2 (15 to 35% of maximum SDI). This is considered the lower range of stocking. 

Yellow = SDI zone 3 (36 to 45% of maximum SDI). This is considered the middle range of stocking. 

Orange = SDI zone 3 (46 to 55% of maximum SDI). This is considered the upper range of stocking.

Red = SDI zone 4 (56% + of maximum SDI). Tree groups will not be managed within this zone.

Note: SDI "zones" are explained in the silviculture report.

TPA by QMD and BA:

Grp BA

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

746 Coconino and Kaibab National Forests 
Appendix E – Four Forests Restoration Initiative 

Adaptive Management, Biophysical and 

Socioeconomic, Mexican Spotted Owl

and Arizona Bugbane Monitoring Plan

Outline of This Plan 

1) Introduction 

2) Adaptive management process

3) Monitoring 

a) Requirements for Monitoring

b) Types of Monitoring

c) Monitoring: Desired Conditions, Indicators, Thresholds, and Triggers 

d) Monitoring Tiers – Prioritization of Monitoring

e) Scales of Monitoring

f) Implementation Monitoring Overview and Plan 

g) Biophysical Monitoring Overview and Plan 

h) Socioeconomic Monitoring Plan 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 747
Appendix E – Monitoring Plan

Introduction 

The pace and scale of 4FRI is likely to affect many aspects of the ponderosa pine ecosystems of 

northern Arizona. The anticipated effects of our treatments are disclosed in the first analysis area 

Environmental Impact Statement (EIS). Monitoring will help determine if the intended effects are 

achieved, recognizing that our management should improve as monitoring information is 

collected and applied. 

This section is intended to: 1) clarify the process for both monitoring and adaptive management 

in the 4FRI landscape; 2) clarify the requirements for monitoring; and 3) describe the 

collaboratively-developed monitoring and adaptive management plan that is the foundation of the 

multi-party monitoring framework. The 4FRI Collaborative Stakeholders Group (stakeholders) 

and the U.S. Forest Service (USFS) coordinated on the design of this monitoring and adaptive 

management plan, with the intent of integrating it in FEIS and implementing it within the entire 

4FRI project. The 4FRI Stakeholder group will also create a Multi-Party Monitoring Board 

(Monitoring Board) which will work with the USFS to oversee monitoring prioritization, 

implementation, data storage and assessment. All monitoring results, including positive progress 

towards desired conditions, and unexpected benefits or challenges, will be used for stakeholder 

learning and developed into outreach material for broader dissemination.

The selected indicators are based on the desired conditions that were described in not only the 

purpose and need section but also within each specialist report for the 4FRI project. The emphasis 

of this project is the restoration of a fire adapted ecosystem. Restoration is defined as “the process 

of assisting the recovery of resilience and adaptive capacity of ecosystems that have been 

degraded, damaged, or destroyed. Restoration focuses on establishing the composition, 

structure, pattern and ecological process necessary to make terrestrial and aquatic ecosystems 

sustainable, resilient and healthy under current and future conditions.” (FSM 2020.5) The 

monitoring and adaptive management plan outlines how we will use a multi-scaled suite of 

indicators and sampling strategies to assess the changes that result from management actions and 

determine the degree to which they meet desired conditions. Monitoring is intended to determine 

whether management actions positively affect the ecological processes within the project area and 

the greater landscape. 

While the 4FRI project as a whole encompasses a 2.4-million acre landscape, this analysis area 

only represents approximately one half of that area. The monitoring and adaptive management 

plan details the framework and process for monitoring within this analysis area; however, we 

intend to apply it across the entire initiative area. 

Adaptive Management Process: 

The 4FRI Project is a long-term forest restoration effort that is unprecedented in scale in the 

southwest region. Implementation of the entire project is anticipated to take over 20 years. 

Coupled with this size and scope, the project is occurring as the southwest is experiencing 

increased climatic changes, such as periods of extended drought and increased temperatures—the 

effects of which are unknown or at a minimum, untested. The uncertainties inherent in a project 

of this magnitude mandate that management actions be flexible to accommodate needed 

modifications. This adaptive management plan is intended to provide information that can help 

the Agency respond to changing conditions and new knowledge.

Adaptive management refers to a “rigorous approach for learning through deliberately designing 

and applying management actions as experiments” (Murray and Marmorek 2003). Monitoring of 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

748 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

alternative management actions provides the data for the adaptive management process. When 

used in an adaptive management framework, monitoring should link landscape management with 

learning, and ultimately allow for improved efficiency in planning and implementation. 

The USFS and Stakeholder Group have collaboratively developed the monitoring and adaptive 

management plan by taking the desired conditions, and selecting a suite of indicators and metrics 

that best measure trends towards those desired conditions. To assure that adequate metrics are 

used to assess trends, the indicators were selected based on attributes that can be easily measured, 

are precise, sensitive to changes over time, and that satisfy multiple objectives of the monitoring 

process (Eagan and Estrada-Bustillo 2011, Moote 2011, Derr et al. 2005). Once the indicators 

were selected, triggers (sometimes described by thresholds) were identified that signify a 

movement towards an undesired outcome; triggers can help indicate whether or not a change in 

management is advisable. In some cases, the most current scientific knowledge still does not 

provide sufficient information to identify quantitative triggers; when this occurs, monitoring data 

will be analyzed to help develop triggers for future management. 

To assure success of the monitoring program, a clear link describing how monitoring information 

will be utilized in future decision-making is essential (Noon 2003, Williams 2009). In the past, 

this has been achieved administratively (Mulder et al. 1999, Sitko and Hurteau 2010), legally via 

the NEPA process (Buckley et al. 2001, CERP 2009), or through collaborative agreements (Gori 

and Schussman 2005, Greater Flagstaff Forest Partnership 2005). When there is sufficient 

information to develop a threshold that suggests a trend away from the desired conditions, this 

plan goes on to describe and outline the potential adaptive management actions. Initially, when a 

trigger or threshold is reached, the monitoring framework focuses on the need to assess if or how 

management actions have contributed to the outcomes. The USFS and the multi-party monitoring 

board will collaboratively evaluate the monitoring data and other relevant data to establish causal 

relationships. Based on the evaluation, follow-up actions will be developed. These may include, 

for example, continued monitoring, collecting more refined data, implementing the existing 

adaptive management action or developing a new adaptive management action. The Stakeholder 

group may choose to recommend adaptive management actions to the USFS. USFS staff may 

also develop new adaptive management actions internally. This is a collaborative process; 

however, ultimately, the deciding official determines what management actions will be 

implemented. 

As the project matures and baseline data is collected, thresholds can be refined to describe 

specific quantitative ranges that will trigger adaptive management actions. Stakeholders and the 

USFS are committed to a strong adaptive management process. Concerned stakeholders are more 

likely to support management actions if they are confident that the results from those actions are 

not only carefully monitored, but are also used to modify future actions (Rural Voice for 

Conservation Coatlition 2011). As such, we expect that the Stakeholders will continue to work 

closely with the USFS and recommend adaptive management actions. 

The monitoring and adaptive management plan is intentionally designed as a living document. 

There is an expectation that indicators, metrics, methods, thresholds, adaptive management 

actions and monitoring priorities will change (adapt) over the course of the project as information 

is gained and new questions are revealed. The USFS will collaborate with the Stakeholder Group 

as we make changes and assess monitoring priorities throughout the life of this document. 

However, adaptive management actions and their anticipated effects must fall within the scope of 

those analyzed within the FEIS. If management actions or effects are anticipated to exceed the 

scope, additional NEPA analysis may be required. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 749
Appendix E – Monitoring Plan

Figure 68. 4FRI adaptive management process

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 750
Appendix E – Monitoring Plan

Monitoring 

Requirements for Monitoring

The 4FRI Project is supported by multiple federal mandates, regulations, and funding programs. 

As such, there are different monitoring requirements for each of these programs.

Collaborative Forest Landscape Program

In 2010, the 4FRI project was selected for funding under the Collaborative Forest Landscape 

Program. The purpose of the Collaborative Forest Landscape Program is to encourage the 

collaborative, science-based ecosystem restoration of priority forest landscapes through a process 

that: 1) encourages ecological, economic and social sustainability; 2) leverages local resources 

with national and private resources; 3) facilitates the reduction of wildfire management costs, 

including through reestablishing natural fire regimes and reducing the risk of uncharacteristic 

wildfire; and 4) demonstrates the degree to which various ecological restoration techniques 

achieve ecological and watershed health objectives and affect wildfire activity and management 

cost; and where the use of forest restoration byproducts can offset treatment costs while 

benefitting local rural economies and improving forest health (U.S. Congress 2009). 

Section g-3 of the Act specifies annual reporting on the accomplishments of each selected project. 

Annual reporting includes: 1) a description of all acres treated and restored through projects 

implementing the strategy; 2)an evaluation of progress, including performance measures and how 

prior year evaluations have contributed to improved project performance; 3) a description of 

community benefits achieved, including any local economic benefits; 4) the results of multiparty 

monitoring, evaluation, and accountability process. Items 1-3 are compiled locally and sent to the 

USFS’s Washington Office for annual reporting. The multi-party monitoring (item 4) focuses on 

effectiveness monitoring and reporting timeframes are dependent on the variables measures but 

will be included in the 5, 10 and 15-year Collaborative Forest Landscape Restoration Act 

reporting. Multi-party indicator monitoring is accomplished through a partnership of USFS and 

partner funding and staff.

The Collaborative Forest Landscape Restoration Project requires multiparty monitoring and 

reports at 5, 10 and 15 years post the authorizing Act (2009) that include national indicators to 

assess project goals. Each year, the Four Forest Restoration Initiative receives congressionally 

appropriated funds under the CFLN budget line item. The amount varies annually; however, the 

USFS agrees to dedicate 10 percent of the annual CFLN funds to monitoring activities. 

Monitoring activities covered by this 10 percent allocation are expected to include some of the 

pre-treatment monitoring, post-treatment effectiveness monitoring and TES species monitoring; 

however, it will not typically cover implementation monitoring which is funded through the 

operational budget. More details are provided below. 

As the first 15,000 – 30,000 acres of task orders within the 4FRI project area are implemented, 

monitoring activities will test the assumptions within this document, verify that desired 

conditions are being achieved, and help refine the adaptive management process. The USFS may 

use funding sources other than CFLN to support monitoring; however, collaborative partners are 

expected to support monitoring efforts by soliciting and contributing both in-kind and monetary 

funds from other sources. National forests may complete project level implementation and 

compliance monitoring with funding from stewardship retained receipts (see Stewardship 

Contracting below) as outlined in FSM 2409.19 section 67.2, when there is interest and support 

from local collaborative partners. Retained receipts may defray some of the direct costs of local 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 751
Appendix E – Monitoring Plan

multi-party monitoring and support the collaborative monitoring process by paying for 

facilitation, meeting rooms, travel, incidental expenses, data collection, and dissemination of 

monitoring findings to the public.

Stewardship Contracting

Stewardship contracting is only one of several administrative tools that can be used for project 

implementation. While the use of stewardship contracts is beyond the scope of this NEPA 

analysis, there are monitoring requirements associated with stewardship that have been included 

in this collaboratively-developed monitoring and adaptive management plan. Currently, the 

authorizing language for stewardship contracting only requires programmatic process monitoring 

of: 1) the status of development, execution and administration of stewardship contracts or 

agreements; 2) the specific accomplishments that have resulted; and 3) the role of local 

communities in development of agreements or contract plans.

Types of Monitoring

Ecological (also referred to as environmental) monitoring is generally undertaken to 

determine whether the current state of the biophysical system matches or is trending toward some 

desired condition (Noon 2003). When conducted systematically, monitoring can provide valuable 

feedback regarding the effects of land management on resource conditions (Palmer and Mulder 

1999, Lindenmayer and Likens 2010). 

Social monitoring is done to assess society’s perceptions on an issue or groups of issues. 

Changes in these perceptions are assessed through time as issues change in scope or context.

Economic monitoring is done to assess the economic impact of the 4FRI project. Monitoring 

activities related to land management can be further classified into three categories: 

implementation, effectiveness, and validation (Busch and Trexler 2003).

Implementation monitoring is designed to determine the extent to which a management action 

was carried out as designed (did we do what we said we were going to do?). Implementation 

monitoring is closely associated with Process monitoring as described above.

Effectiveness monitoring tracks the extent to which the management action achieved its ultimate 

objective. Effectiveness monitoring refers to an assessment of treatment effects, rather than to 

measuring whether they were applied as intended or whether they validate a pre-existing concept.

Validation monitoring assesses the degree to which underlying assumptions about ecosystem 

relationships are supported (Block et al. 2001, Busch and Trexler 2003). Validation monitoring is 

often closely associated with research and is not integrated in this monitoring plan. 

Monitoring: Desired Conditions, 

Indicators, Thresholds, and Triggers

A vital component of a successful adaptive management and monitoring program is an explicit 

statement of desired conditions that will be a result of the proposed actions. Monitoring efforts 

use indicators to determine how progress is made towards desired conditions. Thresholds and 

triggers can be considered as benchmarks that inform management directions (i.e. maintain or 

modify) (Ringold et al. 1999, Lindenmayer and Likens 2010). These desired conditions should 

provide information that results in timely adjustment of management activities to better meet 

objectives and support informed decision making (Noon et al. 1999, Noon 2003). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

752 Coconino and Kaibab National Forests
Appendix E – Monitoring Plan

In the 4FRI monitoring program, the monitoring indicators are organized by desired conditions 

that guide the project strategy. The desired conditions are taken from chapter 1, the purpose and 

need, as well as in chapter 3, the Effects Analysis. The desired conditions and the associated 

monitoring indicators, thresholds and triggers are presented in table 148. Quantitative standards 

have been used wherever possible, but many of the desired conditions are qualitative and 

generalized. Indicator ranges have been described where possible for both desirable as well as 

undesirable conditions. Triggers and thresholds were developed through literature reviews, expert 

input, and social values. 

Prioritization – Monitoring Tiers

Financial resources (both USFS and Stakeholder contributions) will be dedicated to monitoring. 

However, it is well understood that there will be insufficient funds to monitor all the indicators 

over the entire treatment area. A multiparty monitoring board will meet periodically to, among 

other things, prioritize indicator monitoring and identify geographic locations to be monitored. 

Budgetary limitations will dictate how much and what type of monitoring can be accomplished. 

Implementation/compliance monitoring will meet legal and regulatory requirements (table 148) 

and will be completed annually by the Forest Service using the operational budget. Effectiveness 

monitoring is also a priority and a key component in meeting our adaptive management goals; 

however, only a subset of the 4FRI treatment areas will be monitored and, at any one location, 

only some of the monitoring indicators will be assessed. To help the multiparty monitoring board 

determine what effectiveness monitoring will be accomplished with available funds, this plan 

provides a tiered system for monitoring. 

Prioritization of the indicators within each tier is expected. All of the Tier 1 indicators need not be 

monitored before those in Tier 2. Monitoring activities described in the Mexican Spotted Owl and 

Arizona Bugbane sections will take priority over all other monitoring activities since the 

biological opinion provided by the US Fish and Wildlife Service is contingent upon that 

monitoring. Indicators associated with socioeconomic monitoring are considered Tier 1 and will 

be prioritized along with all of the biophysical indicators.

As new information becomes available and new questions are raised, the indicators or their order 

of priority may change. Research, which is a part of validation monitoring, is independent of 

implementation and effectiveness monitoring and will be funded strictly by external entities. The 

results of relevant research should inform future monitoring prioritization and adaptive 

management decisions. Table 146 displays the effectiveness monitoring tiers and how they will 

be prioritized.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 753
Appendix E – Monitoring Plan

Table 146. Effectiveness monitoring tiers and prioritization

Monitoring Priority for Type of 

Tier Completion Who Will Complete Monitoring Type of Funding

Tier 1 1 Multiparty Effectiveness Appropriated, Partner

• USFS

• Stakeholders

• Agency Partners

Tier 2 

(includes 

research)

2 Multiparty

• USFS

• Stakeholders

• Agency Partners

• Research Advocate

Effectiveness, 

Research, Validation

Appropriated, Partner, 

Research Advocate

Monitoring Scale

The 4FRI will implement management activities at scales beyond those typically used in the 

management of the National Forests. As such, it is helpful to provide clarification of the scales 

described in this document. The Forest Service and the Stakeholders sometimes use different 

terms to describe the same scales. For example, the Forest Service uses the term restoration unit 

to represent areas ranging in size from 10,000 acres to 100,000 acres. However, stakeholders 

consider some of the sizes within that range to be a treatment area and some to be a firescape. 

Table 147 provides a crosswalk of the terminology used by the Forest Service and the 

Stakeholders to describe various spatial scales. For ease of understanding, all terms have been 

simplified and grouped as “fine” or “broad” scales indicators. In some cases, it is appropriate to 

measure an indicator at both scales. However, this does not preclude monitoring efforts that may 

make finer distinctions; for example, some monitoring can occur at both, or either, the “group” 

and “site” scale, depending on the questions and information needed to make informed decisions. 

Table 147. Scale terms used by different groups and within this document 

Size in Acres

Stakeholders: 

4FRI Landscape Strategy

Forest Service: 

4FRI EIS Coconino 

and Kaibab

Desired Conditions 

and Monitoring 

Indicators used in the 

Monitoring Plan

< 1 Group Fine 

1-1,000 Site Stand Fine

1,000-10,000 Treatment Area Sub-unit Broad 

10,000-100,000 Treatment Area / Firescape Restoration Unit Broad 

100,000-1,000,000+ Firescape, Analysis Area, 

Landscape Analysis Area Broad 

Implementation Monitoring Plan 

Introduction: Implementation monitoring is designed to determine the extent to which a 

management action was carried out as designed. Not only is this a regulatory requirement, but 

also a means by which the Forest Service is able to demonstrate measureable progress towards 

the desired conditions established within this analysis and the forest plans. Appendix C describes 

a series of design features, BMPs and mitigations that are common to all action alternatives (BFinal Environmental Impact Statement for the Four-Forest Restoration Initiative

754 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

D). Appendix D contains the silvicultural design features and the implementation plan. The 

directions in these appendices are the foundation for all management actions. 

Indicator: We employ two indicators to monitor implementation. The first is a quantitative 

measure of area, volume or distance treated for each natural resource. The second measure is 

compliance; either the activities were completed in full compliance with all design features, best 

management practices and mitigations, or they were not. 

Scale: As these indicators are related to implementation, they are evaluated at a spatial scale of 

either the treatment unit area or full task order area. 

Method: Compliance with the design features, BMPs, mitigations and the implementation plan 

will be evaluated at multiple stages. During the development of formal prescriptions, the 

silviculturist will use the directions in Appendix C and Appendix D to develop the site-specific 

treatment design. The relevant directions will be brought forward as needed into contract 

documents. The contract administrators will monitor day to day activities of the contractors as 

they implement the treatments to ensure compliance. After the task order is completed, resource 

specialist will also evaluate the finished product to ensure that there is full compliance.

Quantitative implementation monitoring ensures compliance through annual reporting 

requirements.

Data Source: The data sources for compliance indicators are typically sale administrators who 

monitor the day to day execution of each task order or resource specialists who conduct postproject inspections. The data sources for quantitative indicators are the Forest Service databases 

of record. 

Cost: The cumulative cost associated with ensuring compliance and proper reporting across all 

the resource areas is expected to range from $500,000 – $700,000 annually. The costs cover 

contract administration, inspection, data recording and resource specialist reviews.

Trigger/Threshold: The trigger for adaptive management is a compliance failure or failure to 

report land management activities.

Adaptive Management: In the event of a compliance issue, the adaptive management action will 

be to re-evaluate the implementation process to determine the source of the failure and if 

necessary, develop additional compliance monitoring protocols. In the event of a reporting 

failure, the reports will be corrected to properly reflect the relevant land management activities. 

The reporting process will be re-evaluated and additional assurance measures may be put in 

place.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 755
Appendix E – Monitoring Plan

Table 148. Implementation monitoring questions and indicators 

Monitoring Questions Derived from Desired Condition Monitoring Indicator Assessment Method

Frequency of 

Measurement

Are ponderosa pine restoration treatments occurring within the 

project area?

Acres thinned /green tons 

removed, acres prescribed burned

Database Records Reported annually

If mechanical treatments occurred, were they implemented in 

accordance with design features, BMPs, mitigation measures 

and the silvicultural implementation guide?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did treatments designed to naturalize non-system roads occur? Miles of road effectively closed to 

motor vehicle traffic

Database Records Reported annually

If roads were closed to motor vehicle traffic, were the treatments 

implemented in accordance with design features, BMPs, and 

mitigation measures? When appropriate, were adaptive actions 

employed as described in chapter 2, Table 19? 

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

If roads were used, were they maintained or rehabilitated after 

use in accordance with design features, BMPs, and mitigation 

measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

If roads were used, were undesired impacts to surrounding 

resources minimized or mitigated in accordance with design 

features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

If temporary roads were created, were they decommissioned 

prior to the close of the associated task order as required in the 

Collaborative Forest Landscape Restoration Act ? 

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities minimize or mitigate undesired 

impacts to scenery, recreation resources and recreation 

opportunities in accordance with design features, BMPs, and 

mitigation measures? 

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities minimize or mitigate undesired 

impacts to soil and water in accordance with design features, 

BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities maintain or promote long-term soil 

productivity in accordance with design features, BMPs, and 

mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 756
Appendix E – Monitoring Plan

Monitoring Questions Derived from Desired Condition Monitoring Indicator Assessment Method

Frequency of 

Measurement

Did channel restoration treatments occur? Miles and acres of channel 

restored

Database Records Reported annually

If channel restoration treatments occurred, were they 

implemented in accordance with design features, BMPs, and 

mitigation measures? When appropriate, were adaptive actions 

employed as described in chapter 2, Table 19? 

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities minimize impacts to water resources 

in a manner that adheres to the Clean Water Act, State and 

Federal Water Quality Standards, and the intergovernmental 

agreement between the Southwestern Region and the ADEQ

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities occur in Mexican spotted owl

habitat?

Acres of vegetation treated/green 

tons removed, acres prescribed 

burned, acres burned in managed 

fire

Database Records Reported annually

If management activities occurred in Mexican spotted owl

habitat, were they implemented in accordance with design 

features, BMPs, mitigation measures, and the project biological 

opinion?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Were design features, BMPs, mitigation measures and forest 

plan requirements met for not only threatened, endangered, 

sensitive species, but also the other wildlife species listed in 

Appendix C?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did treatments designed to reduce or manage noxious weeds 

and invasive species occur?

Acres treated Database Records Reported annually

Did management activities minimize or mitigate the spread of 

noxious weeds, invasive species or non-native species in 

accordance with design features, BMPs, and mitigation 

measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities minimize or mitigate undesired 

impacts to sensitive plants, Arizona Bugbane and Flagstaff 

pennyroyal; and preserve special areas in accordance with 

design features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 757
Appendix E – Monitoring Plan

Monitoring Questions Derived from Desired Condition Monitoring Indicator Assessment Method

Frequency of 

Measurement

Did management activities adequately protect Bebb’s willow 

from fire and ungulates in accordance with design features, 

BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities prevent, minimize or mitigate 

damage to grazing range sites and infrastructure in accordance 

with design features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities limit disruption to grazing activities 

and ensure post-fire range readiness in accordance with design 

features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Were planned prescribed fires coordinated with neighboring 

forests and other affected agencies and communities?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did prescribed fires occur in accordance with ADEQ 

requirements and did they minimize or mitigate undesired

impacts to wildlife, soil, water, vegetation and air quality in 

accordance with design features, BMPs, and mitigation 

measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities minimize old and large tree 

mortality?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities result in reduced crown fire potential 

and movement toward FRCC 1?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did the Forest Service consult with the SHPO, ACHP and tribes 

as required and comply with the requirements of the NHPA and 

the Southwestern Region PA with the AZ SHPO? 

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Did management activities prevent, minimize or mitigate 

undesired impacts to cultural resources in accordance with 

design features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Was the public provided information and notification related to 

vegetation treatments and prescribed fires in accordance with 

design features, BMPs, and mitigation measures?

Compliance Contract inspection and 

specialist review

Ongoing and at postproject review

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

758 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Biophysical Monitoring Plan

Biophysical Monitoring for Structure and Pattern:

The USFS distinguishes between desired conditions related to pattern versus those related to 

structure. Structure relates to the age distribution and the vertical spatial arrangement of the 

overstory of the forest, while pattern refers to the horizontal distribution of vegetation across a 

stand or a landscape.

Relevant Desired Conditions

I. Conservation of Biological Diversity:

a. Ponderosa pine ecosystems provide the necessary ... structure, abundance, 

distribution... that contributes to the diversity of native plant and animal species... 

b. Where fire use is not possible, mechanical treatments are designed to restore and/or 

maintain forest structure over time.

c. Ponderosa pine ecosystems are composed of all age and size classes within the 

analysis area and are distributed in patterns more consistent with reference 

conditions. 

d. Ponderosa pine ecosystems are heterogeneous in structure and distribution at the 

analysis area scale. Openings and densities vary within the analysis area to maintain a 

mosaic appropriate to support resilience of individual trees and groups of trees.

II. Ecosystem Resilience:

a. Ponderosa pine ecosystems are restored to more natural tree densities in order to 

maintain availability of moisture and nutrients to support adaptation to climate 

change without rapid, large-scale type shifts.

III. Conservation and maintenance of soil, water, and air resources: 

a. Forest structure supports a variety of natural resource values and processes, including 

hydrologic function, which meets ecological and human needs. 

b. Forest openings are designed to improve snow accumulation and subsequent soil 

moisture and surface water yield.

Description and Justification

Many of the desired conditions related to structural components of ponderosa pine forests specify 

a need for heterogeneous forests that more closely approximate reference conditions. 

Investigations of historical ponderosa pine conditions indicate that forests were generally open in 

structure wherein trees occurred in multi-aged clumps of differing size among abundant 

understory plant communities (Mast et al. 1999, Waltz et al. 2003, Sánchez Meador et al. 2011). It 

has been suggested that restoration treatments that focus on creating this structure of uneven-aged 

tree groups interspersed with openings of various sizes will provide the greatest benefit in terms 

of biological diversity and ecosystem function (Sabo et al. 2009, Kalies et al. 2010).

Determining the extent to which restoration treatments benefit and affect native plant and animal 

diversity will require a multi-scaled approach to characterizing several aspects of structural 

diversity. Wildlife and plants respond to their environment across multiple spatial and temporal 

scales (Wiens 1989). Indeed, management that creates or maintains structural complexity at the 

stand or patch scale while preserving a diverse assemblage of stands (or patches) that differ in

size and spatial arrangement at broader scales has been identified as a necessary component of 

managing forested systems for diversity (Lindenmayer et al. 2006). Understanding the 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 759
Appendix E – Monitoring Plan

contribution of forest structure and composition to biodiversity is further complicated by the 

potential existence of “domains of scale” (i.e., areas where a process may behave predictably, but 

beyond which the process may change in an unpredictable and non-linear way) and that any 

single scale of measurement is likely to be arbitrary with respect to the process of interest (Wiens 

1989). 

Forest structure is a multi-dimensional attribute that is not assessed adequately by any single 

measure. Similarly, heterogeneity in forest structure occurs at multiple scales requiring multiple 

indicators (Cushman et al. 2008). Thus, two distinct sets of indicators will be used to assess 

changes in forest structure that result from 4FRI-implemented treatments.

Fine-scale Assessment

Tier 1 Suggested Indicators: Age Structure, spatial aggregation 

• Age Structure (Diameter Distribution): While collecting this information pre-treatment and 

post-treatment will likely require a fairly intensive field effort, it will allow us to measure 

structural complexity in terms of age (size) structure and will also provide information for 

calculating changes in density and basal area that result from treatment.

♦ Assessment: Field sampling of tree diameter (both pre- and post-treatment) of treated 

sites

♦ Frequency: Immediately post-treatment (either mechanical or prescribed fire); every 10 

years thereafter.

♦ Threshold/Trigger: No threshold determined for this indicator. Also see implementation 

plan which includes if and how the Large Tree Implementation Plan will be used for 

specific task orders.

♦ Adaptive Management: Evaluate reasoning for implementing large tree removal. If 

needed, appropriate adaptive management actions will be developed.

• Spatial Aggregation (Ripley’s K and/or Getis Ord): Measures of spatial aggregation can be 

used to determine “patchiness”. Statistical tests such as Ripley’s K and Getis Ord can be used 

to describe spatial properties such as the distribution and clustering of trees as well as canopy 

cover. These properties can be compared to those of “restored” areas to measure our progress 

towards historic conditions. 

♦ Assessment: Freely available pre- and post-treatment aerial photography of stands 

identified for treatment

♦ Frequency: Immediately post-treatment (either mechanical or prescribed fire) or as soon 

as appropriate aerial photography becomes available; every 10 years thereafter.

♦ Threshold/Trigger: No threshold has been identified for this indicator. It will be 

developed as new information becomes available.

♦ Adaptive Management: No management action has been identified at this time. 

However, once a threshold has been identified, the corresponding data will be thoroughly 

reviewed and appropriate adaptive management actions will be developed.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

760 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Broad-Scale Assessment

Tier 1 Suggested Indicators: Canopy openness, patch size, patch configuration, patch 

diversity, and patch evenness. 

• Canopy Openness (Percent and Characteristics of Openings): Because many of the 

treatment types being applied within 4FRI are designed explicitly to achieve a particular posttreatment percentage of canopy openness, we will measure the pre- and post-treatment 

percentage of canopy cover. This indicator in conjunction with the spatial aggregation 

statistics can help describe the degree to which 4FRI treatments are achieving “patchiness” 

and the degree to which those patches vary. Also, tracking the size and orientation of forest 

openings is important to determine their impacts on snowpack accumulation and retention 

that affect soil moisture, plant- available soil water and system resilience to climate 

variability.

♦ Assessment: Utilize USFS tools developed by the Remote Sensing and Application 

Center (RSAC) to process input images (NAIP, LiDAR, etc.) into canopy/ non canopy 

patches and assess for spatial pattern (Landscape Indices, FRAGSTATS). 

♦ Frequency: Immediately post-treatment (either mechanical or prescribed fire) or as soon 

as appropriate aerial photography becomes available; every 3-10 years thereafter.

♦ Threshold/Trigger: A deviation from the structure described in table 64 of the 

Silviculture report

♦ Adaptive Management: Assess potential sources of deviation, including prescription 

and implementation; increase monitoring efforts in future task orders.

• Patch Size (Patch area, Patch density, Patch Size Distribution): Patch area is a 

fundamental quantity for understanding landscape composition that can be used both to 

calculate a variety of other indicators as well as model species richness, occupancy, and 

distribution in conjunction with field data. Patch density can be used as an index for spatial 

heterogeneity across a landscape, but has the added utility of being comparable across areas 

of differing size (e.g., comparisons between treatment areas or restoration units) (McGarigal 

and Marks 1995). Distribution of patch size provides information on the variability of patch 

sizes within a particular class (e.g., groups, openings, etc.). These data, in conjunction with 

mean patch size, can provide information on key aspects of landscape heterogeneity and 

composition, particularly as patch size changes as a result of restoration treatments. These 

indicators can provide an indication of the ability of restoration treatments to achieve 

heterogeneity (and diversity) at spatial extents beyond the stand-level and can be calculated 

within the freely available FRAGSTATS program (McGarigal et al. 2002). 

♦ Assessment: Categorical maps (e.g., groups, openings, etc.) based on satellite imagery 

and/or aerial photography

♦ Frequency: Annually to track broad-scale change or when suitable imagery becomes 

available.

♦ Threshold/Trigger: No threshold has been identified for this indicator. It will be 

developed as new information becomes available.

♦ Adaptive Management: No management action has been identified at this time. 

However, once a threshold has been identified, the corresponding data will be thoroughly 

reviewed and appropriate adaptive management actions will be developed.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 761
Appendix E – Monitoring Plan

• Patch Configuration (Nearest neighbor distance distribution and Contagion): These two 

indicators provide information on landscape configuration (i.e., the spatial arrangement of 

patches, treatment areas, etc.). Nearest neighbor distances that are narrowly distributed (i.e., 

little variation) tend to indicate a fairly even distribution of patches across the landscape. 

Contagion measures both the intermixing of different patch types as well as their spatial 

distribution. These two indicators provide a characterization of heterogeneity in terms of 

landscape configuration (i.e., spatial relationships among differing patch types) and has been 

used to characterize a variety of different landscapes (McGarigal and Marks 1995, Cushman 

et al. 2008). These indicators are also available within FRAGSTATS (McGarigal and Marks 

1995, McGarigal et al. 2002). 

♦ Assessment: Categorical maps (e.g., groups, openings, etc.) based on satellite imagery 

and/or aerial photography

♦ Frequency: Annually to track broad-scale change or when suitable imagery becomes 

available.

♦ Threshold/Trigger: No threshold has been identified for this indicator. It will be 

developed as new information becomes available.

♦ Adaptive Management: No management action has been identified at this time. 

However, once a threshold has been identified, the corresponding data will be thoroughly 

reviewed and appropriate adaptive management actions will be developed.

• Diversity and Evenness (Simpson’s Diversity and Evenness Indices): These measures 

have been historically associated with estimates of species diversity; however, in this case 

they are being used to assess the diversity of patch types across the landscape. Simpson’s 

diversity index represents the probability that any two randomly drawn patches will be of a 

different type. A higher value indicates greater diversity of patch types. Similarly, larger 

values of evenness indicate greater landscape diversity (i.e., less dominance by any particular 

patch type). FRAGSTATS implements a variety of diversity and evenness indices; however, 

these were selected because they are considered easier to interpret (McGarigal and Marks 

1995, Magurran 2004).

♦ Assessment: Categorical maps (e.g., groups, openings, etc.) based on satellite imagery 

and/or aerial photography

♦ Frequency: Annually to track broad-scale change or when suitable imagery becomes 

available.

♦ Threshold/Trigger: No threshold has been identified for this indicator. It will be 

developed as new information becomes available.

♦ Adaptive Management: No management action has been identified at this time. 

However, once a threshold has been identified, the corresponding data will be thoroughly 

reviewed and appropriate adaptive management actions will be developed. 

Tier 1 Suggested Indicators: Soil moisture relative to forest opening size and orientation

• Forest openings, depending on their size and orientation, promote greater snowpack 

accumulation and retention and hence greater soil water storage (Baker and Ffolliott 2003). 

Deeply rooted plants, such as mature ponderosa pines, that depend on moisture from winter 

precipitation are expected to be the most affected by changes in snowpack. Per-tree plantavailable soil moisture is expected to be higher in thinned ponderosa pine stands than in 

unthinned stands (Zou et al. 2008), which should promote plant vigor, resilience to climate 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

762 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

variability and perhaps even resistance to wildfire. If, however, restoration treatments push 

soil moisture in the opposite direction, recognizing such a trend is critical information that 

can direct adjustments in treatment approaches. Monitoring of lower elevations, south facing 

slopes and shallow soils that are susceptible to drying are a priority.

♦ Assessment: Soil moisture measurements made using soil moisture probes, portable 

Time Domain Reflectometer (TDR) and/or gravimetric analysis at shallow and deep 

rooting depths according to a statistical design. Soil moisture may be analyzed within the 

context of a paired watershed study, but additional monitoring could also be conducted at 

sensitive sites such as lower elevations, south facing slopes and shallow soils

♦ Frequency: Pretreatment, post-treatment, annually during pre- and post-monsoon water 

stress periods

♦ Threshold/Trigger: Trends of decreasing soil moisture (after adjusting for climatic 

variability) in stands with similar treatment types and/or physiographic characteristics.

♦ Adaptive Management: Evaluate treatments and make adjustments in treatment 

methods and forest pattern as appropriate, especially at lower elevations, on south facing 

slopes and on shallow soils that are susceptible to drying.

Monitoring for Composition

Relevant Desired Conditions

I. Conservation of Biological Diversity:

a. Ponderosa pine ecosystems provide the necessary ... composition... that contributes 

to the diversity of native plant and animal species...

b. Viable, ecologically functional populations of native species that include common, 

listed, rare, and sensitive species persist in natural patterns of distribution and 

abundance. 

c. All pre-settlement trees are retained.

d. Understory vegetation composition and abundance are consistent with the natural 

range of variability. 

e. Protect old-growth forest structure during planned and unplanned fires. 

[Implementation Monitoring]

f. Natural and prescribed fires maintain and enhance but do not degrade habitat for 

listed, rare, and sensitive species.

g. Habitat management is contributing to the recovery of listed species.

h. Planned an unplanned fires support diverse native understory communities and their 

associated biodiversity.

i. Populations of native species occur in natural patterns of distribution and abundance. 

II. Ecosystem Resilience: 

a. There is reduced potential for introduction, establishment, and spread of invasive 

species. Additionally, efforts are made to reduce existing infestations.

b. Exotic species are rare or absent and do not create novel ecological communities 

following disturbance. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 763
Appendix E – Monitoring Plan

III. Conservation and Maintenance of Soil, Water, and Air Resources: Emissions factors, 

smoldering and smoke residence times are reduced as fires burn more grass and less green or 

woody biomass over time.

Description and Justification

Many desired conditions are specified to reflect a number of aspects of forest composition. Both 

the USFS desired conditions for ponderosa pine and 4FRI Stakeholder desired conditions identify 

certain patch components (e.g., Gambel oak (Quercus gambelii), snags, coarse woody debris, and 

old-growth) that contribute disproportionately to habitat values and the diversity of a patch or 

landscape (Bennetts et al. 1996, Kotliar et al. 2002, Bunnell and Houde 2010). In contrast, desired 

conditions for the understory and wildlife are specified both for their contributions to diversity 

and their ability to indicate ecosystem functionality.

Monitoring of understory composition could be used as an indication of both ecosystem resilience 

and soil productivity. Reductions in overstory pine volumes can be correlated with increased 

understory production (Laughlin and Grace 2006, Laughlin et al. 2005), and this increased 

understory productivity is a key assumption being used in the 4FRI NEPA analysis. However, 

stand replacing wildfire in ponderosa pine forests may lead to shifts toward exotic, invasive 

species dominance in understory plant communities (Crawford et al. 2001). Minimal or 

temporary increases over time in invasive species populations indicate high ecological resilience. 

Establishment and rapid spread of invasive species populations may lead to native species 

replacement and indicate low ecological resilience. Additional consideration for soil properties 

will be given below; however, for the purposes of this document soil productivity is interpreted as 

the ability of the soil to sustain native vegetation.

Many of the desired conditions for wildlife species are specified with respect to both viability and 

natural patterns of distribution and abundance. Historically, viability has been difficult or 

impossible to assess particularly when resources are limited due to the difficulty of gathering 

reliable estimates of all of the relevant population rates. Literature searches can provide a 

valuable starting point; however, case studies of viability rarely reveal generalizations useful for 

conservation management (Traill et al. 2007). As a potential solution to this issue, Flather et al. 

2011 recommend focusing on those factors most likely to cause declines in a species such that it 

may become unviable particularly when the demographic data necessary for calculating fitness or 

viability are unknown. Monitoring of population response (particularly productivity and 

abundance) of threatened, endangered, and rare species should be focused on those areas directly 

impacted by treatment (e.g., Mexican Spotted Owl Protected Activity Centers within some yet to 

be determined distance of restoration treatments or wildfire) as these are likely to be directly 

impacted by the presence of personnel, equipment, and infrastructure associated with treatments 

and disturbance. 

The majority of species affected by 4FRI are likely to be affected through changes in habitat 

particularly at larger scales. Site occupancy can be used in a monitoring context to reflect the 

current state of the population, and, through multi-season extensions, provide information related 

to population trends. Estimating occupancy often require fewer detections than other density 

estimation techniques allowing for more precise estimates of rare or infrequently detected species 

(MacKenzie et al. 2003, MacKenzie et al. 2005). Furthermore, efforts to relate occupancy to 

habitat-relevant covariates allow estimation and prediction of changes in population state due to 

coarser-scale changes in land-use and climate (e.g., Dickson et al. 2009, Mattsson and Marshall 

2009). Deriving these habitat-occupancy relationships using high-resolution satellite imagery 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

764 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

provides the opportunity to identify the impacts of more localized changes (e.g. forest restoration 

treatments) across larger spatial scales.

Monitoring for forest composition will require both field measurements and sophisticated 

modeling techniques to determine the degree to which restoration treatments are achieving 

desired conditions at all scales. Given uncertainties in the response of both wildlife and invasive 

species, this monitoring is especially important. Many of the indicators identified below will 

require significant resources to assess. Financial support from stakeholders and other 

organizations will be required to adequately monitor these indicators.

Fine-scale Assessment

Tier 1 Suggested Indicators: Rare Ecosystem Elements (Springs Protection)

Forest restoration thinning has the potential to improve the hydrogeology of springs by increasing 

soil water storage and groundwater recharge (McCarthy and Dobrowolski 1999). Because springs 

create rare habitat for multiple threatened species as well as more common wildlife species, 

understanding the relationship between treatments and spring responses is critical for making 

adaptive management decisions to optimize springs restoration projects. A collaborative group 

with skills in spring assessment is available to assist Coconino and Kaibab National Forests in 

selecting springs for monitoring and restoration. Current partners in the collaboration include 

Northern Arizona University (NAU), Grand Canyon Trust, Grand Canyon Wildlands Council and 

the Spring Stewards, but more partners may join in the collaboration at any time.

• Assessment:

♦ Groundwater Dependent Ecosystems Protocol (USDA FS 2011) 

♦ Spring discharge measurements

• Frequency: Pre- and post-treatment, every two years following treatment for the first 6 years 

after treatment, then every 5 years.

• Threshold/Trigger: 

♦ No net increase in facultative and obligative wetland species at springs or wet meadows 

targeted for both forest and spring restoration.

♦ Decrease in spring discharge (adjusted for climate variation) following treatments.

• Adaptive Management: Review spring restoration techniques. Review treatment methods in 

the recharge area. Make appropriate adjustments.

Tier 1 Suggested Indicators: Understory Species Composition (Percent Foliar Cover, 

Percent Bare Ground) 

Native species composition and the percentage of bare mineral soil provide an indication of soil 

productivity. In addition, restoration treatments have potential to increase abundance of native 

plant communities (Laughlin et al. 2006, Moore et al. 2006, McGlone et al. 2009b); however, 

invasive plant species may also increase in cover on sites where restoration thinning, prescribed 

fire, and livestock grazing occur (McGlone et al. 2009b). Native plant communities that are 

minimally disturbed during thinning or burning activities may better resist compositional shifts 

toward invasive species (Korb et al. 2004, McGlone et al. 2011). While assessment at the 

“Group” scale is not necessary, stand-scale assessment will require field sampling that can be 

accomplished more easily with university and volunteer partners.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 765
Appendix E – Monitoring Plan

• Assessment: Field collected quadrats.

• Frequency: 

♦ Within 5 years of treatment for cover

♦ Within 5 years of treatment for bare soil

♦ Within 10 years of treatment for seedlings

• Threshold/Trigger: 

♦ Within 5 years of mechanical treatment, the cover should increase 20 percent +/- 5 

percent (15-25 percent) above controls (Laughlin et al 2011). 

♦ Within 5 years of treatment (mechanical and/or fire), bare soil should comprise less than 

20 percent of area affected by treatment. 

♦ Within 10 years of treatment, seedling and sapling density should be within 0.4 to 3.6 

plants/hectare/decade on basalt soils (Mast et al 1999).

• Adaptive Management: 

♦ If cover threshold is not reached, then re-evaluate treatment for management change, 

taking into account soils and burn treatment (e.g. reduce overstory basal area). 

♦ If bare soil exceeds 20 percent of area within plots, re-evaluate restoration treatment for 

modification. 

♦ If seedlings and saplings fall below this range across sub-units where regeneration is a 

desired condition, then evaluate implementation of BMPs to increase probability of 

successful regeneration. If regeneration falls above this range, then more aggressive 

prescription burning may be necessary to reduce plant density. 

Tier 1 Suggested Indicators: Understory Species Composition (Invasive species) 

With regards to invasive species control, the first and most important management strategy is 

preventing the establishment or spread of invasive species. The best way to achieve this is by 

increasing the health and resilience of native plant communities. Below is a list of species most 

likely to be affected by management. 

Watch List: These species are currently not known to fall within 4FRI treatment areas, and if 

they do show up and are detected, aggressive eradication efforts should be a top priority and 

applied quickly. 

These species include Malta starthistle (Centaurea melitensis L.), Russian olive (Eleagnus 

angustifolia), Himalayan blackberry (Rubus armeniacus and Rubus discolor), giant reed (Arundo

donax), sulfur cinquefoil (Potentilla recta), tree of heaven (Ailanthus altissima), Siberian elm 

(Ulmus pumila), halogeton (Halogeton glomeratus), dyer’s woad (Isatis tinctoria), Eurasian 

water-milfoil (Myriophyllum spicatum), oxeye daisy (Leucanthemum vulgare), and Canada thistle 

(Cirsium arvense).

High Risk: These species currently have limited geographic distribution within 4FRI treatment 

areas, and if current inventories indicate their presence within treatment areas, these species 

should be eradicated immediately. 

These species include leafy spurge (Euphorbia esula), camelthorn (Alhagi maurorum), yellow 

starthistle (Centaurea solstitalis), spotted knapweed (Centaurea biebersteinii), diffuse knapweed 

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(Centaurea diffusa), Russian knapweed (Acroptilon repens), white top (Cardaria draba), 

Mediterranean sage (Salvia aethiopis), Scotch thistle (Onopordum acanthium), tamarisk (Tamarix

spp.), common teasel (Dipsacus sylvestris), and musk thistle (Carduus nutans).

Medium Risk: These species have widespread distribution within 4FRI treatment areas in large 

populations, with either no effective treatment, or cost-prohibitive effective treatment, or for 

which effectiveness of current treatment strategies is unknown or not monitored. Areas should be 

prioritized for treatment based on risk to conservation value (presence or proximity of TES 

species) and areas of high wildlife habitat value (e.g., pine- sagebrush ecotones). Weed treatment 

strategies be monitored for effectiveness to gauge return on investment.

These species include Dalmatian toadflax (Linaria dalmatica), bull thistle (Cirsium vulgare), and 

wild oats (Avena fatua).

Cheatgrass (Bromus tectorum): Cheatgrass invasion of ponderosa pine systems after restorationbased treatments is a burgeoning issue of significant concern (Keeley and McGinnis 2007, 

McGlone et al. 2009a and b). Widespread invasion of cheatgrass often shifts invaded ecosystems 

into irreversible alternate stable states where cheatgrass-mediated fire intervals exclude native 

understory plants (Brandt and Rickard 1994, D’Antonio and Vitousek 1992, Brooks et al. 2004). 

Means of prevention and treatment have not been adequately tested or found successful in 

ponderosa pine systems; however the risk of ecological transformation caused by cheatgrass 

warrants aggressive monitoring and adaptive management in the 4FRI project. Preventative 

actions pre-treatment will be just as critical as adaptive management responses post-treatment, 

and will require identification of areas at risk for cheatgrass invasion prior to project 

implementation, such as areas where cheatgrass is already present or ecotonal areas adjacent to 

existing cheatgrass populations. 

• Assessment: Percent cover of native and non-native species based on field sampling.

• Frequency: Pre- and immediately post-disturbance (i.e., mechanical thinning, prescribed fire, 

and wildfire); every 5 years thereafter.

• Thresholds/Triggers: 

♦ Identification of new or existing “watch list” or “high risk” invasive species populations. 

♦ Identification of new or existing “medium risk” invasive species populations.

♦ Identification of areas at high risk of cheatgrass introduction or spread.

• Adaptive Management: 

♦ If inventories, surveys and map checks indicate presence of 'high risk' or 'watch list' 

species (see narrative), evaluate all BMPs, especially for cleaning equipment moving 

from infested sites to clean sites. Consider aggressive treatments leading to population 

eradication. If treatments do not reduce the cover of “watch list” species by 90 percent in 

one year or “high risk” species by 50 percent in 2 years, consider new approaches to 

eradication.

♦ If inventories, surveys and map checks indicate presence of 'medium risk' species (see 

narrative), consider controlling these species on individual basis especially when high 

value areas or habitats are at risk. If treatments do not reduce the cover of “medium risk” 

species by 20 percent in 5 years, consider new approaches to weed management.

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♦ If inventories, surveys and map checks indicate areas with a high risk of cheatgrass 

introduction or spread, treatments could include (but should not be limited to):5

 Chemically treating and native reseeding of small infestations of cheatgrass prior 

to thinning and burning 

 Avoiding whole-tree skidding and other actions that cause significant soil 

disturbance 

 Removing slash and avoiding creation of large slash piles resulting from thinning 

operations 

 Properly manage grazing so that perennial grasses are maintained

 Deferring burns in heavily infested areas 

 Delaying burns and lengthening fire return intervals post-thinning to allow native 

perennials time to establish

 Applying native, perennial seed (e.g., bottlebrush squirrel tail, which has shown 

promise in successfully competing with cheatgrass) after fire.

 Cleaning equipment and clothing after working in infested areas 

Tier 2 Suggested Indicators: Old trees

Old Trees (Number of Old Trees): The 4FRI Landscape Strategy places a large emphasis on 

pre- settlement trees. Furthermore, higher levels of biodiversity have been attributed to those 

areas that still contain old-growth components (Binkley et al. 2007) and these components may 

be susceptible to mortality immediately post-treatment (Fulé et al. 2007, Roccaforte et al. 2010). 

Evidence suggests, however, that this mortality can be avoided through a variety of “protection” 

measures and that over time restoration treatments can increase the vigor of old trees (Kolb et al. 

2007). 

• Assessment: Rapid assessment conducted while collecting diameter distribution data on plots 

(or use of aerial imagery once techniques become available)or other evidence

• Frequency: Immediately post-treatment (either mechanical or prescribed fire); every 5 years 

thereafter

• Threshold/Trigger: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Tier 2 Suggested Indicators: Habitat Suitability (Occupancy Probability)

Occupancy, in cases where sample sizes are large, can be defined as the proportion of total area 

occupied and can provide a useful alternative to density or abundance, especially for uncommon 

species (MacKenzie et al. 2006). More generally, occupancy can also be interpreted as the 

probability of locating an individual of species x in location y. This interpretation (probability of 

occupancy) reflects an a priori expectation that a site will be occupied based on a hypothesis 

5 If cheatgrass begins to dominate restoration sub-units after thinning and burning treatments within the 

4FRI project area, consider delaying further treatments in areas of high risk until the Forest Service, 

stakeholders and experts can be convened to evaluate alternative management options. 

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about the underlying process determining occupancy. The former interpretation (proportion of 

area occupied) is the realization of that process, given large sample sizes (MacKenzie et al. 2006). 

Higher probabilities of occupancy may be interpreted to indicate more “use” of a habitat by a 

particular species. Information on songbird occupancy (based on existing Rocky Mountain Bird 

Observatory Data) will be used to evaluate changes in songbird species richness and its associated 

adaptive management strategy.

• Assessment: Field surveys of presence & absence at both treated and untreated sites

• Frequency: Immediately post-treatment and every 2 years thereafter

• Threshold/Trigger: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Tier 1 Suggested indicator: Songbird Species Richness (Jackknife2, Chao 2, or ICE 

Species Richness Estimator) 

While estimating the changes in the aforementioned forest structural components provides some 

indication of how 4FRI treatments may be contributing to diversity goals, documenting the ways 

in which restoration treatments facilitate ponderosa pine forests contribution to native diversity 

ultimately requires knowledge of how diversity is changing over time. We anticipate that the 

abundance of species will change due to treatment and incidence or occurrence-based estimators 

are a way of documenting the actual change in the number of species. These incidence based 

species richness estimators have been shown to be more accurate and potentially less biased than 

historical estimators of species richness (e.g., Shannon’s Index, Simpson’s Diversity Index) 

(Walther and Moore 2005). These estimators can be computed within EstimateS, 

(http://viceroy.eeb.uconn.edu/estimates), a freely available diversity-estimation software program, 

using existing, ongoing surveys conducted by Rocky Mountain Bird Observatory in conjunction 

with the Forests. 

• Assessment: Field sampling of communities of interest (e.g., songbirds) 

• Frequency: Immediately post-treatment (either mechanical or prescribed fire); every 3-5 

years thereafter.

• Threshold/Trigger: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Tier 2 Suggested Indicators: Rare Ecosystem Elements (Percent Cover of Gambel Oak, 

Aspen, and other Riparian Communities)

Oak, aspen, and riparian areas contribute heavily to the diversity of ponderosa pine forests in the 

Southwest. For example, pine-oak forests tend to have a greater diversity of songbirds and small 

mammals than ponderosa forests that lack an oak component (Block et al. 2005, Jentsch et al. 

2008). Removal of overstory competition from ponderosa pine and more regular low-severity fire 

are likely to alter the cover and composition of the oak component within treated stands. Removal 

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of ponderosa pine competition may also encourage aspen regeneration and increase the size of 

riparian communities due to increases in available water. 

• Assessment: Assessment of plot-based percent cover while collecting diameter distribution 

data (or use of aerial imagery once techniques become available)

• Frequency: Immediately post-treatment (either mechanical or prescribed fire); every 5 years 

thereafter 

• Threshold/Trigger: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Tier 2 Suggested Indicators: Snags, rare ecosystem elements, understory species 

composition; responses of rare, sensitive, threatened, and endangered species; habitat 

“suitability”, species richness, evenness

Snags (Number, Size Distribution, Condition): The number and size of snags present will be 

sampled within treated sites due to their role in providing valuable habitat for a variety of wildlife 

species (e.g., Kotliar et al. 2002) and the potential for restoration treatments to alter snag 

composition within treated sites (Bagne et al. 2008, Hessburg et al.2010). In addition, assessing 

the condition of the snags (sound vs. soft) can provide an indication of the expected longevity for 

those snags.

• Assessment: Rapid assessment conducted while collecting diameter distribution data on plots 

(or use of aerial imagery once techniques become available)

• Frequency: Immediately post-treatment (either mechanical or prescribed fire); every 5 years 

thereafter 

• Threshold/Trigger: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Broad-Scale Assessment

Tier 1 Suggested Indicators: Response of Rare, Threatened, and Endangered Species 

and Regional Sensitive Species (Population trends)

Treatments conducted under 4FRI may affect rare, threatened, or endangered species through a 

variety of mechanisms and at a variety of scales. This is particularly true for wildlife species such 

as the Northern Goshawk and Mexican Spotted Owl. Understanding the effects of treatment on 

productivity (and thus viability) of these species likely requires a research effort beyond the scope 

of the monitoring proposed here. We will monitor Mexican Spotted Owl as directed by the 

biological opinion provided by U.S. Fish and Wildlife Service. Northern Goshawk will be 

monitored according to the field protocols established in the USFS National Goshawk Inventory 

Guidelines with additional modifications such as those developed by NAU’s Lab of Landscape 

Ecology and Conservation Biology (LLECB) and the Kaibab National Forest and in current 

literature. 

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• Assessment: 

♦ Mexican spotted owl monitored as directed in the U.S. Fish and Wildlife Service 

biological opinion. 

♦ Northern goshawk occupancy monitored using USFS protocols (USDA FS 2006) with 

modifications developed by LLECB/KNF and current literature. 

• Frequency: In accordance with the aforementioned protocols. 

• Thresholds/Triggers: 

♦ As directed in the Mexican spotted owl section of the U.S. Fish and Wildlife Service 

biological opinion 

♦ If northern goshawk occupancy trends show a decline over a 5 to 10 year average at 

treatment and 4FRI landscape scales.

• Adaptive Management:

♦ As directed in the Mexican spotted owl section of the U.S. Fish and Wildlife Service 

biological opinion and in consultation with U.S. Fish and Wildlife Service. 

♦ Evaluate treatments and consider increasing or focusing monitoring on area where 

northern goshawk is declining. Consider comparing to regional monitoring data trends. 

As a high profile species, additional monitoring may be conducted even if the decline is 

not a statistically significant.

Tier 2 Suggested Indicators: Wildlife Response (Landscape Predictions of Songbird 

Species, Richness)

Field assessment of these indicators (with the exception of connectivity) can be used in 

conjunction with remotely sensed habitat covariates to track changes at larger scales and provide 

information on landscape distribution patterns. In addition, hierarchical modeling could provide a 

multi-scalar inference by using other information collected from other field assessments 

identified here. These models can be used to create “map-based” depictions of occupancy and 

richness that can then be summarized at multiple scales. Development and subsequent validation 

of these models will be especially critical for threatened, endangered, sensitive, and rare species 

and will likely require partnership with research institutions. Ongoing field assessment of 

songbird populations and the subsequent ability to estimate occupancy as a function of forest 

structural covariates will be critical for this indicator.

• Assessment: Field sampling in conjunction with remote sensing 

• Frequency: Annual interpretations of new satellite imagery

• Thresholds/Triggers: Any non-zero decline over a 5-year period within the functional 

groups listed below 

• Adaptive Management:

♦ Closed Canopy Species: Evaluate data and best science available, including upcoming 

research by AZ Game and Fish. Adaptive management could include implementing one 

of the following changes: 

 Increase group density for all treatments. 

 Increase group size for all treatments.

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 Reduce intensity of UEA 40-55 treatments within the treatment category to be 

applied to the next round of task orders. 

 Identify 25 percent of planned UEA 40-55 treatments and reduce intensity to 25-

40 interspace.

♦ Open Canopy Species: Evaluate implementing one of the following changes: 

 Increase the size of openings in all treatment types. 

 Identify 25 percent of planned UEA 25-40 treatments and increase intensity to 

40-55 

♦ Pine-Sage Species: Alter timing of treatment to reduce impacts on sage; Delay posttreatment burning to allow sage recover

♦ Pine-Oak Species: Evaluate implementing one of the following changes: 

 Restrict ungulate access to stands to allow oak regeneration. 

 Increase emphasis on management of oak component in non-“Restricted Habitat” 

stands

Tier 2 Suggested Indicator: Landscape Connectivity and Permeability

Changes in landscape connectivity and permeability for several species representing closed 

canopy (black bear OR grey fox) and open canopy (pronghorn) conditions. Building connectivity 

models for species that are predicated on various aspects of patch structure, density, and 

orientation provides an opportunity to evaluate the effects of landscape heterogeneity on a key 

ecosystem process. Furthermore, these models can be validated through the use of telemetry 

studies, a property not shared by fire models (our other landscape metric). While a variety of 

factors can and do influence connectivity, the models will be formulated to reflect specific 

hypotheses related to landscape structure.

• Assessment: Field sampling in conjunction with remote sensing 

• Frequency: Immediately post-treatment; five years post-treatment, ten years post-treatment

• Thresholds/Triggers: 

♦ Restriction in bear/fox movement after treatment (reduced connectivity between patches)

♦ No increase in pronghorn movement after treatment 

• Adaptive Management: 

♦ Bear/Fox: Evaluate implementing one of the following changes: 

 Increase group size.

 Decrease treatment intensity within known pathways 

♦ Pronghorn: Evaluate implementing one of the following changes: 

 Increase opening sizes. 

 Increase treatment intensity within known pathways

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Appendix E – Monitoring Plan

Biophysical Monitoring for Function (or Process)

Relevant Desired Conditions

I. Conservation of Biological Diversity: 

a. Ponderosa pine ecosystems provide the necessary ... processes...that contributes to 

the diversity of native plant and animal species...

b. Natural disturbance processes (e.g., fire, drought-mortality, endemic levels of forest 

pests and pathogens) are the primary agents shaping forest ecosystem structure, 

dynamics, habitats, and diversity over time.

c. There is low potential for unnaturally severe fire to spread across the Restoration 

Unit.

d. Wherever practicable, natural fire regimes regulate forest structure and composition.

e. Planned and unplanned fires support diverse native understory communities and their 

associated biodiversity.

II. Ecological Resilience: 

a. Ponderosa pine ecosystems in the 4FRI are capable of adapting to or persisting with 

climate change without rapid, large scale type shifts.

b. Low intensity frequent fire operates as the primary natural process maintaining forest 

structure and function.

c. Mixed severity fire is sometimes used as a restoration tool in appropriate ecological 

and social settings (e.g., non-wildland-urban interface areas) to restore and maintain 

natural forest types[Implementation Monitoring – not addressed in this document]

d. Forest insects and pathogens occur and operate at endemic levels.

e. Ponderosa pine ecosystems in the 4FRI are capable of regeneration and recovery 

following natural disturbance (e.g., fire, outbreaks of insects and pathogens). 

f. A majority of the ponderosa pine ecosystems supports frequent, low-intensity fire.

g. Mixed severity fire is used as a restoration tool where it is consistent with reference 

conditions and safe to do so. [Implementation Monitoring – not addressed in this 

document . 

h. Natural disturbance processes (e.g., fire, endemic pests, and pathogens) are within the 

natural range of variability. 

i. Strategically placed treatments allow fire managers to safely manage planned and 

unplanned natural ignitions fires in a way that benefits and enhances the resilience of 

forest ecosystems.

j. Restoration results in forests that are trending toward natural variability, selfregulating, and positioned to adapt to climate change without large, rapid type shifts.

III. Conservation of Soil, Water, and Air Resources: 

a. Soil productivity, watershed function, and air quality are not at risk of being degraded 

by uncharacteristically severe disturbances (e.g., landscape level high- severity fire).

b. Sensitive soils are protected through use of appropriate timber harvesting equipment 

and techniques to reduce erosion and sedimentation that could otherwise damage 

aquatic life, increase flooding, reduce reservoir capacity, and increase costs of 

maintaining infrastructure in the vicinity of waterways. [Implementation Monitoring]

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c. Fire is used as a management tool to support hydrologic function while minimizing 

impacts to soils and other natural resource values. [Implementation Monitoring]

d. Rare and ecologically valuable springs and wet meadows are protected and enhanced 

through appropriate restoration treatments where needed. 

e. Ponderosa pine vegetation treatments are implemented so as to minimize negative 

impacts to water quality, soil productivity, and air quality. Short- term impacts are 

minimized through the implementation of best management practices and strategies. 

f. Restored ponderosa pine ecosystems accommodate natural and other fires without 

uncharacteristic impacts to soil productivity and or watershed resources.

g. Ponderosa pine vegetation within the analysis area is managed strategically and at a 

level appropriate to prevent degradation of air quality beyond regulatory standards 

(through wildland fire or managed fire). 

h. Hydrologic processes are re-established to restore springs and wet meadow 

ecosystems.

i. Strategically placed treatments allow fire managers to manage planned and 

unplanned fires in locations, seasons and conditions that maximize smoke dispersion 

and minimize smoke impacts.

j. Stable, restored ecosystems foster watersheds that yield enhanced water quantity and 

quality and are resilient to climatic variability.

Description and Justification

The majority of 4FRI desired conditions focus on the need to maintain ecosystem processes 

within the natural range of variability. While the desired conditions are numerous, indicators for 

assessing them fall into several major categories: ecosystem type shifts, fire size and severity, 

forest pests and pathogens, soil stability and sedimentation, and the generation of smoke. 

An ecosystem that is resilient shows persistence in relationships and low probability of extinction 

(Holling 1973). A resilient system absorbs fluctuations in state variables (e.g., population 

numbers) and processes. Persistence and return of characteristic ecosystem structure and function 

following disturbance indicate high ecological resilience. Rapid, large-scale type shifts indicate 

low ecological resilience.

Future climate models for the southwestern United States predict warmer and drier conditions 

(Seager et al. 2007). Potential impacts of climate changes include increased tree morality as a 

function of drought, fire, and pathogens. In addition, tree regeneration may be affected by loss of 

seed trees and drought-induced seedling mortality. Potential impacts of climate change are likely 

to be exacerbated under current forest conditions. Restoration treatments in ponderosa pine 

forests have the potential to increase growth and vigor of residual trees, lower potential for crown 

fire, provide growing space and microsites for tree regeneration, and increase available resources 

for native plant communities (Laughlin et al. 2006, Kolb et al. 2007, Roccaforte et al. 2008). Such 

effects are likely to buffer the ecosystem against climate change and enhance resilience at fine to 

coarse scales (Fulé 2008).

Ponderosa pine forests were historically resilient and persisted under a frequent, low-intensity fire 

regime. Current forest conditions are outside the historical range of variability in terms of tree 

density and structure. Fire under current structural conditions has greater potential to be standreplacing, indicating conditions of low ecological resiliency. Restoration treatments that reduce 

forest density and fuel loading can in turn reduce potential for stand-replacing crown fire (Fulé et 

al. 2001, Roccaforte et al. 2009). 

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Ponderosa pine trees are coevolved with native insect herbivores and pathogens. Forests with 

endemic levels of insects and pathogens do not experience large-scale and long-term type shifts. 

Epidemic levels of insects and pathogens may lead to rapid ecological shifts, which represents 

conditions of low ecological resilience.

Bark beetles, dwarf mistletoe, and to some extent root diseases are the major damaging insects 

and pathogens of ponderosa pine forests (Wilson and Tkacz 1996). Overly dense forest conditions 

may lead to increased susceptibility to these agents and result in extensive tree mortality (Wilson 

and Tkacz 1996, Negrón et al. 2000). Restoration thinning can enhance tree resistance to various 

insects and pathogens (Kolb et al. 2007). Severe fire effects, whether from prescribed burning or 

wildfire, can increase susceptibility to damaging insects and pathogens (McHugh et al. 2003). 

Hydrologically, there are five fundamental watershed functions, and two secondary functions: (1) 

collection of the water from rainfall, snowmelt, and storage that becomes runoff, (2) storage of 

various amounts and durations, (3) discharge of water as runoff (4) sediment transport, and (5) 

groundwater recharge. In fact, the first and third of these functions have long been incorporated in 

the commonly-used terms, "catchment" and "watershed"; storage is the inevitable consequence of 

water being detained within an area between "catching" and "shedding." Ecologically, the 

watershed functions in two additional ways: (1) it provides diverse sites and pathways along 

which vital chemical reactions take place, and (2) it provides habitat for the flora and fauna that 

constitute the biological elements of ecosystems. Large, uncharacteristically severe wildfires such 

as the Rodeo- Chediski, Schultz and Wallow have had deleterious effects on watershed function 

through downcutting of channels, soil erosion, and excessive sediment transport (Gottfried et al. 

2003, Moody and Martin 2009). Mechanical thinning and prescribed burning can help maintain 

hydrologic function of ponderosa pine forests. Yet, side effects of restoration treatments, such as 

soil compaction from heavy equipment and fire-related damage to the soil biotic community and 

soil nutrient balance, must be monitored to inform adaptive management. 

Smoke is a natural consequence of ponderosa pine forest material combustion, and can be 

managed through a variety of prescribed conditions that managers use in controlling fire, 

including fuel moisture content, fuel loading and arrangement, air temperature, relative humidity, 

wind direction and speed, and seasonality of burn (lower atmosphere ventilation). Smoke from 

forest combustion is also a contributor to visual haze, and the timing, amount, and quality of its 

generation from controllable sources such as prescribed burns is regulated by the Arizona 

Department of Environmental Quality (ADEQ) because of smoke’s impacts on human health. 

While restoration activities accomplished by 4FRI will generate a substantial amount of smoke, 

coordinated efforts to manage underlying and prescribed conditions will help to mitigate the 

amount and quality of smoke released, and reduces total impacts on air quality. 

With the exception of tree mortality and regeneration dynamics, the ecosystem processes 

described above operate at broad scales. Thus, assessing progress towards desired conditions will 

require a variety of remotely sensed and modeled data to interpret the effects of restoration 

treatments within the context of the larger landscape. Developing more robust and accurate 

models of these processes will benefit greatly from information gathered as part of a field 

sampling effort.

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Fine-Scale Assessment

Tier 2 Suggested Indicators: Tree mortality, regeneration, insect pathogen dynamics, 

fuel hazard

Tree Mortality (Stand Density, Basal Area, and Species Composition): Monitoring for desired 

conditions with respect to ecosystem type shifts should focus on tree mortality and tree 

regeneration. Values for stand density, basal area, and percentage species composition can be used 

to track tree mortality as well as contribute to determining effects of restoration treatments on fire 

behavior. 

• Assessment: Field sampling within treated sites

• Frequency: Immediately post-treatment and every five years thereafter

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Regeneration (Density of Seedlings, Poles and Saplings): Regeneration is the second critical 

component of determining whether type shifts are occurring. These measurements require field 

sampling since it is not possible to assess regeneration accurately using remote sensing 

technology. 

• Assessment: Field sampling within treated sites

• Frequency: Immediately post-treatment and every five years thereafter

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Insect and Pathogen Dynamics (Bark Beetle Rating, Dwarf Mistletoe Rating, and Number 

of Trees Affected by Pests/Pathogens): Monitoring of insects and pathogens should focus on 

levels of tree mortality as described above. In addition, bark beetle and mistletoe rating systems 

(Hawksworth 1977, Sánchez-Martínez and Wagner 2002) should be used in field plot 

measurements in order to track changes in levels of occurrence.

• Assessment: Field sampling within treated sites 

• Frequency: Immediately post-treatment and every five years thereafter

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

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Appendix E – Monitoring Plan

Fuel Hazard (Crown Bulk Density, Crown Base Height, and Surface Fuel Loading): 

Monitoring of forests’ potential to support frequent, low-intensity fire should be focused on 

structural conditions and fuel loading.

• Assessment: Field sampling within treated sites

• Frequency: Immediately post-treatment and every five years thereafter

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Broad-Scale Assessment

Tier 1 Suggested Indicators: Fuel/fire hazard, fire occurrence, soil and watershed 

function

Fuel/Fire Hazard (Crown Bulk Density, Crown Base Height, Surface Fuel Loading, and 

Predicted Fire Behavior): These indicators allow assessment of the ability of restoration 

treatments to meet strategic goals with respect to large-scale, uncharacteristically severe fire. Data 

to assess these conditions can be obtained from remote sensing techniques (Landfire updates and 

future LIDAR as data becomes available), although ground truth and calibration plots are likely 

to be necessary.

• Assessment: Remote sensing information

• Frequency: Immediately post-treatment and every five years thereafter

• Thresholds/Triggers: 

♦ After 5 years, less than 25 percent of the analysis land area described as Fire Regime I is 

predicted to predominantly carry passive or active crown fire

♦ After 10 years, less than 10 percent of the analysis land area described as Fire Regime I is 

predicted to predominantly carry passive or active crown fire

• Adaptive Management: Evaluate the potential causes and develop appropriate adaptive 

management actions.

Fire Occurrence (Severity and Size of Fires, Acres of High Severity Fire, Total Acres 

Burned,): As restoration progresses, the size and severity of wildfire should decrease. Use of 

freely-available information from the Monitoring Trends in Burn Severity program and Forestlevel databases on managed fire can be used to assess how treatments affect size and severity of 

fires. It should be noted that this assessment is limited to those portions of the landscape where 

restoration treatments are complete.

• Assessment: Monitoring Trends in Burn Severity data 

• Frequency: Available annually for all fires larger than 1000 acres

• Thresholds/Triggers: 

♦ Patch size of adjacent pixels expressing stand replacing fires is greater than 50 acres after 

5 years

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 777
Appendix E – Monitoring Plan

♦ Patch size of adjacent pixels expressing stand replacing fires is greater than 10 acres after 

10 years 

• Adaptive Management: Evaluate the potential causes (e.g. number of acres treated, 

prescription type) and develop appropriate adaptive management actions.

Tier 1 Suggested Indicator: Soil & Watershed Function (Water Balance)

An important component of forest restoration is to understand the link between forest health or 

functionality and ecosystem services such as water discharge to human communities. While 

paired watershed studies in Arizona's ponderosa pine forests have previously established that 

thinning can increase surface water yield for a period of 6-10 years (Baker 2003), none of the 

previous treatment types were consistent with restoration treatments, no studies examined the 

effects of follow-up treatments (e.g. re-establishment of the natural fire return interval), and none 

of the previous studies quantified the effects on recharge to shallow or regional groundwater 

aquifers. Also, since none of the previous treatments were on a scale of 4FRI, they did not they 

have the potential to significantly impact regional water availability or nor did they provided the 

opportunity to adapt to climate change. 

A paired watershed study is planned within the 4FRI boundary that will take advantage of the 

restoration treatments for study the effects of large-scale treatments on water quality and quantity. 

A watershed function will be quantified through a water balance determination that includes 

measurements of precipitation, snow water equivalence (SWE), soil moisture, evapotranspiration 

(ET), water runoff, and groundwater recharge. Other indicators may be monitored, including 

sediment discharge from erosion and surface water quality (turbidity and total organic carbon) 

which may be directly affected by treatments. The watershed study may include collaboration 

from partners such as NAU, ERI, Salt River Project and potentially other. 

• Assessment: 

♦ Field data: some snow water equivalence and soil moisture data

 Automated data collection - weather stations, precipitation sampling, soil 

moisture probes, evapotranspiration, stream gages, water quality probes, water 

quality autosampler 

 Laboratory analysis - precipitation and runoff water quality (Chloride balance of 

precipitation and runoff can be used to estimate evapotranspiration and 

groundwater recharge. Turbidity and total organic carbon measure soil erosion 

due to thinning and fire treatments) 

♦ Remote sensing: snow water equivalence, soil moisture, evapotranspiration and 

groundwater 

• Frequency: Immediately pre- and post-treatment; annual summary each year following 

treatment with biennial recommendations after 3 years monitoring 

• Thresholds/Triggers: 

♦ Static or decreasing soil moisture post-treatment

♦ Static or decreasing surface water discharge

♦ Diminished water quality (measured by turbidity and total organic carbon) 

♦ Increase in water stress (after accounting for climate variability) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

778 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

• Adaptive Management: Evaluate treatment methods and/or BMPs, and consider making 

adjustments or implementing additional mitigation measures 

Tier 1 Suggested Indicator: Soil and Watershed Function (Sensitive Soils Protection)

Highly and moderately erodible soils and slopes are classified within the Terrestrial Ecosystem 

Survey Units (TESU). Forest management activities are planned to avoid impacting these areas to 

reduce compaction, erosion, and sediment transport downstream. TESU maps can be overlain 

with management activity maps to ensure that protection has occurred, and field plots could 

sample areas where mitigation measures were implemented to assess the percentage of area that 

has been affected. 

While the USFS Soil Disturbance Protocol (Page-Dumroese et al. 2009) is a useful qualitative 

method for evaluating soil impacts from operator actions and for guiding BMPs and mitigation. 

This information can be supported with additional quantitative measurements that can be used in 

statistical analyses of trends (DeLuca and Archer 2009).

• Assessment: 

♦ Remotely sensed data, TESU maps, field plots

♦ Forest Disturbance Monitoring Protocol 2009 (WO82A and WO82B)

♦ Bulk density and infiltration capacity 

• Frequency: Immediately post -treatment and every 5 years thereafter, with more frequent 

follow -up in heavily impacted places to assess recovery

• Thresholds/Triggers: 

♦ Soil disturbance is over 15 percent of the treated area

♦ Increasing bulk density trend 

♦ Decreasing infiltration rate trend

• Adaptive Management: Evaluate treatment methods and/or BMPs, and consider making 

adjustments or implementing additional mitigation measures 

Tier 1 Suggested Indicator: Soil and Watershed Function (Soil Productivity)

Forest management actions may sometimes cause a reduction in the ability of plants to use 

nitrogen (an essential nutrient) from soil; these changes are related to soil productivity and can be 

identified by tracking shifts in the Carbon:Nitrogen ratio (Steve Overby personal communication 

2012). Soil productivity can be impacted by restoration activities, especially where soils and soil 

organisms are disturbed by mechanical treatments and prescribed fire (Owen et al. 2009). Also, 

changes in forest pattern that affect exposure to solar radiation and soil moisture can change 

biochemical processes that influence the balance of soil nutrients (Paul and Clark 1996). Because 

soil nutrition is fundamentally important for plant metabolism, tracking soil nutrition is an 

effective approach for assessing the effects of restoration treatments on some aspects of forest 

health. 

• Assessment: Test carbon- to-nitrogen ratios from soil samples collected according to a 

statistical design

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 779
Appendix E – Monitoring Plan

• Frequency: Pre-treatment, post-treatment, annually in the first 3 years if a shift in 

Carbon:Nitrogen is found following treatment until ratio recovers or stabilizes, otherwise 

every 5 years

• Thresholds/Triggers: Carbon:Nitrogen ratios increasing from ratio values of 12-14 upwards 

to 30, indicating a reduction in nitrogen availability that would impact plant productivity

• Adaptive Management: Evaluate treatment methods and consider changes in treatment 

methods and target forest pattern

Tier 2 Suggested Indicators: Tree mortality, Airshed function

Tree Mortality (Canopy Cover, Number of Pathogen-affected Patches, Size of Mortality 

Patches, and Percent of Landscape in Mortality Patches): These indicators can help assess 

changes in mortality dynamics across the larger 4FRI landscape particularly those that result from 

endemic pests and pathogens. Freely available data from the National Agricultural Image 

Program (NAIP) and the National Forest Health Monitoring (NFHM) Program can be used to 

generate these estimates.

• Assessment: NFHM assessment and NAIP imagery

• Frequency: NFHM data is available annually, NAIP imagery is available every 3 years

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Airshed Function (Air Quality): There are air quality attainment goals for each geographical 

“airshed” dictated by ADEQ. Several measures could be used to qualitatively assess the 

contribution of prescribed burning activities toward the attainment of those ADEQ goals 

including: the percent of prescribed burns within prescriptions that reduce smoke generation, the 

percent (by area) of prescribed fires conducted during high ventilation periods (May -September), 

modeled outputs of smoke from burned slash piles (grams/hectare treated), modeled outputs of 

smoke from broadcast burns (grams/hectare) and modeled output of smoke avoided from 

uncharacteristic wildfire (grams/hectare)

• Assessment: Model runs, ADEQ attainment or exceedance ranking

• Frequency: During prescribed and other burns 

• Thresholds/Triggers: No threshold has been identified for this indicator. It will be developed 

as new information becomes available.

• Adaptive Management: No management action has been identified at this time. However, 

once a threshold has been identified, the corresponding data will be thoroughly reviewed and 

appropriate adaptive management actions will be developed. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

780 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Table 149 Suggested Indicators: Forest Service and multiparty monitoring needed for adaptive management 6 Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate 

1 1 Composition Effects to Threatened or 

Endangered Species are 

within those disclosed in 

the Biological Assessment 

for the 4FRI project 

As directed in 

the U.S. Fish

and Wildlife 

Service

(USFWS) 

biological 

opinion

Various As directed in 

the biological 

opinion

Broad 

Scale

As described in 

the biological 

opinion for this 

project

As directed in the 

Mexican spotted owl

section of the USFWS 

biological opinion and in 

consultation with 

USFWS

Mexican 

spotted owl

survey 

$10/acre; 

PAC survey 

$175

2 1 Composition Effects to Regional 

Forester designated 

Sensitive species within 

those disclosed in the 

Sensitive Species 

Biological Analysis/ 

Evaluation for the project

Forest trends Various Regional field 

protocols

Broad 

Scale

When indicator 

trends suggest a 

need for listing 

under the 

Endangered 

Species Act

As appropriate in 

consultation with 

USFWS

TBD

6 Fine Scale = Group, Site and Stand Scale; Broad Scale = Subunit, Restoration unit, Forest, Analysis Area, Landscape

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 781

 
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

3 1 Structure There is reduced potential 

for introduction, 

establishment, and spread 

of invasive species. 

Additionally, efforts are 

made to reduce existing 

infestations.

Invasive Plants Species cover Field methods Fine Scale Identification of 

new or existing 

“watch list” or 

“high risk” 

invasive species 

populations

If inventories, surveys 

and map checks indicate 

presence of 'high risk' or 

'watch list' species (see 

narrative), evaluate all 

BMPs, especially for 

cleaning equipment 

moving from infested 

sites to clean sites. 

Consider aggressive 

treatments leading to 

population eradication. If 

treatments do not reduce 

the cover of “watch list” 

species by 90 percent in 

one year or “high risk” 

species by 50 percent in 

2 years, consider new 

approaches to 

eradication.

$80/acre

4 1 Structure There is reduced potential 

for introduction, 

establishment, and spread 

of invasive species. 

Additionally, efforts are 

made to reduce existing 

infestations.

Invasive Plants Species cover Field methods Fine Scale Identification of 

new or existing 

“medium risk” 

invasive species 

populations

If inventories, surveys 

and map checks indicate 

presence of 'medium 

risk' species (see 

narrative), consider 

controlling these species 

on individual basis 

especially when high 

value areas or habitats 

are at risk. If treatments 

do not reduce the cover 

of “medium risk” species 

by 20 percent in 5 years, 

consider new approaches 

to weed management.

$80/acre

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

782 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

5 1 Structure There is reduced potential 

for introduction, 

establishment, and spread 

of invasive species. 

Additionally, efforts are 

made to reduce existing 

infestations.

Invasive Plants Cheatgrass Resource 

specialist 

assessment

Fine Scale Identification of 

areas at high 

risk of 

cheatgrass 

introduction, 

spread or 

dominance

Potential preventative 

measures are described 

in the narrative.

$80/acre

6 1 Structure Restore forest structure and 

pattern, forest health, and 

vegetation composition and 

diversity. Ponderosa pine 

ecosystems are 

heterogeneous in structure 

and distribution at the 

analysis area scale. 

Openings and densities 

vary within the analysis 

area to maintain a mosaic

appropriate to support 

resilience of individual 

trees and groups of trees. 

(Many additional)

Landscape 

Structure 

Landscape 

metrics (patch 

characteristics; 

configuration; 

diversity and 

evenness)

Remote 

sensing and 

spatial pattern 

analysis tools

Fine and 

Broad 

Scale

TBD TBD 20,000

7 1 Composition Understory vegetation 

composition and abundance 

are consistent with the 

natural range of variability. 

Diversity 

(understory 

communities)

percent cover 

native species

Field 

collected - 

quadrats

Fine Scale Within 5 years 

of mechanical 

treatment, the 

cover should 

increase 20

percent +/- 5 

percent (15-25

percent) above 

controls 

If this threshold is not 

reached, then re-evaluate 

treatment for 

management change, 

taking into account soils 

and burn treatment, (e.g. 

reduce overstory basal 

area).

*Included in 

Plot Costs 

Below

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 783
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

8 1 Composition Understory vegetation 

composition and abundance 

are consistent with the 

natural range of variability. 

Diversity 

(understory 

communities)

Percent Bare 

Soil within 

treatment blocks

Field 

collected - 

quadrats

Fine Scale Within 5 years 

of treatment 

(mechanical 

and/or fire), 

bare soil should 

comprise less 

than 20 percent

of area affected 

by treatment. 

If bare soil exceeds 20

percent of area within 

plots, re-evaluate 

restoration treatment for 

modification.

*Included in 

Plot Costs 

Below

9 1 Composition Understory vegetation 

composition and abundance 

are consistent with the 

natural range of variability. 

Diversity 

(understory 

communities)

Seedlings and 

saplings density

Field 

collected - 

quadrats

Fine Scale Within 10 years 

of treatment, 

seedling and 

sapling density 

should be 

within 0.4 to 3.6 

plants/hectare/d

ecade on basalt 

soils.

If seedlings and saplings 

fall below this range 

across sub-units where 

regeneration is a desired 

condition, then evaluate 

implementation of BMPs 

to increase probability of 

successful regeneration. 

If regeneration falls 

above this range, then 

more aggressive 

prescribed burning may 

be necessary to reduce 

plant density.

*Included in 

Plot Costs 

Below

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

784 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

10 1 Process There is low potential for 

unnaturally severe fire to 

spread across the 

Restoration Unit.

Fuel/Fire 

Hazard

Crown bulk 

density, crown 

base height, 

surface fuels, 

and predicted 

fire behavior

Remote 

sensing and

modeling

Broad 

Scale

§ After 5 years, 

less than 25

percent of the 

analysis land 

area described 

as Fire Regime I 

is predicted to 

predominantly 

carry passive or 

active crown 

fire

§ After 10 

years, < 10

percent of the 

analysis land 

area described 

Evaluate the potential 

causes and develop 

appropriate adaptive 

management actions.

10000

11 1 Process There is low potential for 

unnaturally severe fire to 

spread across the 

Restoration Unit.

Fire 

Occurrence

Severity and 

size of fire; 

acres of high 

severity fire; 

and total acres 

burned

Remote 

sensing and 

modeling

Broad 

Scale

§ Patch size of 

adjacent pixels 

expressing stand 

replacing fires 

is greater than 

50 acres after 5 

years

§ Patch size of 

adjacent pixels 

expressing stand 

replacing fires 

is greater than 

10 acres after 10 

years

Evaluate the potential 

causes (e.g. number of 

acres treated, 

prescription type) and 

develop appropriate 

adaptive management 

actions.

TBD

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 785
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

12 1 Process Sensitive soils are protected 

through use of appropriate 

timber harvesting 

equipment and techniques 

to reduce erosion and 

sedimentation that could 

otherwise damage aquatic 

life, increase flooding, 

reduce reservoir capacity, 

and increase costs of 

maintaining infrastructure 

in the vicinity of 

waterways. 

Soils Sensitive soil 

protection

Remotely 

sensing and 

field methods

Fine and 

Broad 

Scale

Fine Scale- 

§ Increasing 

bulk density 

trend

§ Decreasing 

infiltration rate 

trend

Broad Scale- 

§ Soil 

disturbance is > 

15 percent of 

the treated area

Evaluate treatment 

methods and/or BMPs, 

and consider making 

adjustments or 

implementing additional 

mitigation measures

TBD

13 1 Process Sensitive soils are protected 

through use of appropriate 

timber harvesting 

equipment and techniques 

to reduce erosion and 

sedimentation that could 

otherwise damage aquatic 

life, increase flooding, 

reduce reservoir capacity, 

and increase costs of 

maintaining infrastructure 

in the vicinity of 

waterways. 

Soils Soil 

productivity

Field methods Fine Scale C:N ratios 

increasing from 

12-14 toward 

30, indicating a 

reduction in 

nitrogen 

availability that 

would impact 

plant 

productivity

Evaluate treatments in 

light of soil processes 

and make adjustments in 

treatment methods and 

forest pattern. 

TBD

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

786 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

14 1 Process Sensitive soils are protected 

through use of appropriate 

timber harvesting 

equipment and techniques 

to reduce erosion and 

sedimentation that could 

otherwise damage aquatic 

life, increase flooding, 

reduce reservoir capacity, 

and increase costs of 

maintaining infrastructure 

in the vicinity of 

waterways. 

Soils Soil moisture Soil moisture 

sensors, time 

domain 

reflectometer 

and 

gravimetric 

analysis

Broad 

Scale

Trends of 

decreasing soil 

moisture (after 

adjusting for 

climatic 

variability) in 

stands with 

similar 

treatment types 

and/or 

physiographic 

characteristics. 

Evaluate treatments and 

make adjustments in 

treatment methods and 

forest pattern as 

appropriate, especially at 

lower elevations, on 

south facing slopes and 

on shallow soils that are 

susceptible to drying. 

? 

15 1 Process Restored ponderosa pine 

ecosystems accommodate 

natural and other fires 

without uncharacteristic 

impacts to soil productivity 

and watershed resources. 

Watershed 

Function

Springs 

protection

Groundwater 

Dependent 

Ecosystems 

Protocol, 

discharge 

measurements

Fine Scale Triggers: 1. No 

net increase in 

facultative and 

obligative 

wetland species 

at springs or wet 

meadows 

targeted for 

both forest and 

spring 

restoration, 2. 

Decrease in 

spring discharge 

(adjusted for 

climate 

variation) 

following 

treatments

Review spring 

restoration techniques. 

Review treatment 

methods in the recharge 

area. Evaluate making 

appropriate adjustments 

such as improving 

structure of patches and 

openings to promote 

snow accumulation and 

retention to enhance 

recharge. 

TBD

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 787
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

16 1 Structure Ponderosa pine ecosystems 

are heterogeneous in 

structure and distribution at 

the analysis area scale. 

Openings and densities 

vary within the analysis 

area to maintain a mosaic 

appropriate to support 

resilience of individual 

trees and groups of trees. 

Ponderosa pine ecosystems 

provide the necessary 

composition, structure, 

abundance, distribution and 

process that contribute to 

the diversity of native plant 

and animal species across 

the 2.4 million acre 4FRI 

landscape.

Canopy 

Openness

Canopy cover Remote 

sensing, 

spatial pattern 

analysis tools 

or field 

sampling

Fine and 

Broad 

Scale

A deviation 

from the 

structure 

described in 

Table 64 of the 

Silviculture 

report. 

Assess potential sources 

of deviation and increase 

monitoring efforts in 

areas with unexpected 

deviations

TBD

17 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Songbird 

species 

occupancy and 

richness: closed 

canopy species

Field (RMBO 

songbird 

surveys), RS, 

Modeling, 

Statistics 

Fine and 

Broad 

Scale

Fine ScaleTBD 

Broad ScaleAny non-zero 

decline over a 

5-year period 

Fine Scale- TBD 

Broad Scale-Evaluate 

implementing one of the 

following changes: 

§ Increase group density 

for all treatments. 

§ Increase group size for 

all treatments [based on 

AGFD experiment]. 

§ Reduce intensity of all 

UEA 40-55 treatments . 

§ Identify 25 percent of 

planned UEA 40-55 

treatments and reduce 

intensity to 25-40

$1000 per 

grid (1 grids 

per 1,000 

acres?)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

788 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

18 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Songbird 

species 

occupancy and 

richness: open 

canopy species

Field (RMBO 

songbird 

surveys), RS, 

Modeling, 

Statistics 

Fine and 

Broad 

Scale

Fine ScaleTBD 

Broad ScaleAny non-zero 

decline over a 

5-year period 

Fine Scale-TBD

Broad Scale- Evaluate 

implementing one of the 

following changes: 

§ Increase the size of 

openings in all treatment 

types. 

§ Identify 25 percent of 

planned UEA 25-40 

treatments and increase 

intensity to 40-55

TBD

19 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Songbird 

species 

occupancy and

richness: pinesage species

Field (RMBO 

songbird 

surveys), RS, 

Modeling, 

Statistics 

Fine and 

Broad 

Scale

Fine ScaleTBD 

Broad ScaleAny non-zero 

decline over a 

5-year period 

Fine Scale- TBD 

Broad Scale-Evaluate 

altering timing of 

treatment to reduce 

impacts on sage; 

Evaluate delaying posttreatment burning to 

allow sage recover

TBD

20 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Songbird 

species 

occupancy and 

richness: pineoak species

Field (RMBO 

songbird 

surveys), RS, 

Modeling, 

Statistics 

Fine and 

Broad 

Scale

Fine ScaleTBD 

Broad ScaleAny non-zero 

decline over a 

5-year period 

Fine Scale- TBD 

Broad Scale-Evaluate 

implementing one of the 

following changes:

§ Increase the size of 

openings designated for 

oak regeneration

§ Restrict ungulate 

access to stands to allow 

oak regeneration. 

§ Increase emphasis on 

management of oak 

component in non-

“Restricted Habitat” 

stands

TBD

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 789
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

21 1 Composition Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Northern 

goshawk

Occupancy USFS 

National 

Goshawk 

Inventory 

Guidelines 

with 

modifications 

developed by 

LLECB/KNF 

and current 

literature

Broad 

Scale

If northern 

goshawk

occupancy 

trends show a 

decline over a 5 

to 10 year 

average at 

treatment and 

4FRI landscape 

scales

Evaluate treatments and 

consider increasing or 

focusing monitoring on 

area where northern 

goshawk is declining. 

Consider comparing to 

regional monitoring data 

trends. As a high profile 

species, additional 

monitoring may be 

conducted even if the 

decline is not a 

statistically significant

TBD

22 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Changes in 

landscape 

connectivity and 

permeability: 

bear/fox

Field 

sampling in 

conjunction 

with remote 

sensing

Broad 

Scale

Restriction in 

bear/fox 

movement after 

treatment 

(reduced 

connectivity 

between 

patches)

Evaluate implementing 

one of the following 

changes: 

§ Increase group size.

§ Decrease treatment 

intensity within known 

pathways

125000

23 1 Structure Viable, ecologically 

functional populations of 

native species that include 

common, listed, rare, and 

sensitive species persist in 

natural patterns of 

distribution and abundance.

Diversity 

(wildlife 

communities)

Changes in 

landscape 

connectivity and 

permeability: 

pronghorn

Field 

sampling in 

conjunction 

with remote 

sensing

Broad 

Scale

No increase in 

pronghorn 

movement after 

treatment 

Evaluate implementing 

one of the following 

changes: 

§ Increase opening sizes. 

§ Increase treatment 

intensity within known 

pathways 

125000

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

790 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

24 1 Structure, 

Composition 

& Process

Ponderosa pine ecosystems 

are composed of all age and 

size classes within the 

analysis area and are 

distributed in patterns more 

consistent with reference 

conditions. 

Diameter 

Distributions

Tree diameters, 

density

Field Methods Fine Scale TBD TBD $2000/plot to 

install, $1000 

to remeasure 

includes 

analysis time. 

(500m grid; 1 

plot per 25ha, 

61.2 acres)

25 2 Structure, 

Composition 

& Process

Protect old-growth forest 

structure during planned 

and unplanned fires. 

Old Trees Old tree density, 

conditions

Field Methods Fine Scale Any loss old 

tree that is cut 

outside of those 

identified as 

allowed in the 

Old Tree 

Implementation 

Plan

TBD; however, when an 

old tree is cut, the cause 

or rationale will be 

reviewed by the MPMB 

(*Included in 

Plot costs)

26 2 Structure Forest insects and 

pathogens occur and 

operate at endemic levels.

Insect 

Pathogens

Bark beetle 

rating, dwarf 

mistletoe rating, 

number of trees 

affected by 

pests

Field Methods Fine Scale TBD TBD (*Included in 

Plot costs)

27 2 Composition Rare and ecologically 

valuable springs and wet 

meadows are protected and 

enhanced through 

appropriate restoration 

treatments where needed. 

Oak and Aspen stands are 

maintained and enhanced 

across the landscape.

Rare/ Unique 

Habitats

Percent cover Field Methods Fine Scale TBD TBD TBD

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 791
Appendix E – Monitoring Plan Indicator No. Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

28 2 Process Restored ponderosa pine 

ecosystems accommodate 

natural and other fires 

without uncharacteristic 

impacts to soil productivity 

and watershed resources. 

Watershed 

Function

Water balance § Field data: 

some snow 

water 

equivalence 

and soil 

moisture data

§ Remote 

sensing: snow 

water 

equivalence, 

soil moisture, 

evapotranspira

tion and 

groundwater

Broad 

Scale

§ Static or 

decreasing soil 

moisture posttreatment

§ Static or 

decreasing 

surface water 

discharge

§ Diminished 

water quality 

(measured by 

turbidity and 

total organic 

carbon)

§ Increase in 

water stress 

(after 

accounting for 

climate 

variability) 

Evaluate treatment 

methods and/or BMPs, 

and consider making 

adjustments or 

implementing additional 

mitigation measures

TBD

29 2 Process Ponderosa pine vegetation 

within the analysis area is 

managed strategically and 

at a level appropriate to 

prevent degradation of air 

quality beyond regulatory 

standards (through 

wildland fire or managed 

fire). 

Air Quality Smoke output Modeling Broad 

Scale

TBD TBD USFS - 1st 

Analysis EIS

30 2 Structure, 

Composition 

& Process

Ponderosa pine ecosystems 

are composed of all age and 

size classes within the 

analysis area and are 

distributed in patterns more 

consistent with reference 

conditions.

Snags Snag sizes, 

density, 

conditions 

Field Methods Fine Scale TBD TBD (*Included in 

Plot costs)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

792 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Indicator No.

Monitoring Tier

Ecological 

Framework

Desired Condition or 

Resource and 

monitoring Questions Indicator

Indicator 

Metric

Method and

Sampling 

Techniques

Fine 

Scale or 

Broad 

Scale

Trigger 

(Threshold 

indicating 

possible 

need for 

change)

Adaptive 

Management

Annual 

Cost 

Estimate

31 2 Structure, 

Composition 

& Process

Protect old-growth forest 

structure during planned 

and unplanned fires. 

Tree Mortality Stand Density, 

basal area, and 

species 

composition, 

Canopy cover, 

number of 

pathogenaffected 

patches, size of 

dead patches 

and percent of 

mortality on 

landscape 

Field 

Methods, 

NFHM and 

Remote 

sensing

Fine and 

Broad 

Scale

TBD TBD (*Included in 

Plot costs)

32 2 Process A majority of the 

ponderosa pine ecosystems 

supports frequent, lowintensity fire.

Fuel Hazard Crown bulk 

density, crown 

base height, and 

surface fuels

Fuel load Fine Scale TBD TBD (*Included in 

Plot costs)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 793
Appendix E – Monitoring Plan

Socioeconomic Monitoring

Introduction and Background

Preparation and tracking of both the social and economic impacts of the Four Forest Restoration 

Initiative (4FRI) project is paramount to the success of the project. Social awareness, knowledge 

and support coupled with economic viability, such as a prepared workforce, adequate 

infrastructure, and reliable wood supplies, are critical factors that will be primary drivers of the 

project’s progression. Typically, social and economic monitoring has not been a priority and was 

identified as one of the five major challenges by the Rural Voice for Conservation Coalition’s 

(RVCC) Issue Paper (2011) in stating, “There is insufficient monitoring of the social and 

economic impacts of land management” and they further stressed this as a key recommendation 

for the U.S. Forest Service (USFS). Robbins and Daniels (2011) affirm this by reiterating, “...that 

the socioeconomic aspects of restoration are ‘underemphasized, or often ignored all together’” 

(Aronson et al. 2010). Thus, ensuring integration of ecological, social and economic impacts will 

augment effective management actions that will address multiple criteria necessary for 

community health and sustainability. 

As the monitoring frameworks were conceptualized, beginning with a broad vision for both social 

and economic factors affected by restoration can be drawn from the 4FRI Stakeholder Group’s 

foundational documents, such as the Path Forward (2010a). Within the Path Forward, the 

importance of integrating monitoring that includes ecological, social and economic impacts was 

raised in stating, “Landscape-scale restoration efforts should adopt and make full use of rigorous 

science, including research, monitoring, and adaptive management that enhances our 

understanding about their ecological, social, and economic implications” (4FRI Stakeholder 

Group 2010a). 

Purpose and Application

The purpose of this report is to provide a framework to guide socioeconomic monitoring of the 

4FRI project for the First Analysis Area Environmental Impact Statement (EIS). Both the 4FRI 

Science and Monitoring Working Group (S&MWG) and the USFS will contribute to monitoring 

the socioeconomic aspects of the project. The 4FRI project is funded through the Omnibus Land 

Management Act of 2009, Title IV-Forest Landscape Restoration. The 4FRI socioeconomic 

monitoring process is geared towards the purpose of the Act:

The purpose of this title is to encourage the collaborative, science-based ecosystem restoration of 

priority forest landscapes through a process that-- 

1) encourages ecological, economic, and social sustainability; 

2) leverages local resources with national and private resources; 

3) facilitates the reduction of wildfire management costs, including through reestablishing natural 

fire regimes and reducing the risk of uncharacteristic wildfire; and 

4) demonstrates the degree to which-- 

(A) various ecological restoration techniques-- 

(i) achieve ecological and watershed health objectives; and 

(ii) affect wildfire activity and management costs; and 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

794 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

(B) the use of forest restoration byproducts can offset treatment costs while benefitting local 

rural economies and improving forest health. 

The monitoring objectives identified in this report overlap with many of the key social and 

economic issues analyzed by the USFS in the “Environmental Consequences” section of the EIS. 

In the EIS, the USFS will assess the social and economic elements of 4FRI implementation. This 

analysis will include the Coconino and Kaibab National Forests and Coconino, Yavapai and 

Maricopa counties. Although Maricopa County is not within the Kaibab and Coconino National 

Forests, it is included in the analysis due to the social and economic linkages between Maricopa 

County and the assessment area. 

There are two main components to the USFS social and economic analysis that include: 1) the 

affected environment description and, 2) the assessment of environmental consequences. The 

USFS analysis of the social and economic affected environment description in the EIS considers 

population and demographic characteristics and trends (e.g. population change and educational 

attainment), employment and income data (e.g. economic specialization and median income), and 

environmental justice concerns (e.g. the distribution of minority and low income populations in 

the study area and their relationship to the Forest lands). This will include estimates of 

employment and income consequences during the 4FRI implementation lifecycle. Input- outputanalyses using IMPLAN (http://www.implan.com) will estimate the employment and income 

effects of the 4FRI project. Ultimately, the estimates from IMPLAN can be compared to actual 

economic outcomes that will be collected as primary data from contractors, subcontractors, etc. 

The USFS environmental consequences analysis estimates will be primarily a qualitative 

assessment and will describe how 4FRI implementation activities will affect quality of life, nonmarket economic values and employment and income in the study area. For quality of life, some 

of the key indicators are: 1) Particulate matter (PM) pollution from wildfire and prescribed fire 

(air quality modeling) and how PM pollution may lead to reduced quality of life through activity 

days, respiratory events, hospital admissions, etc.; 2) recreation opportunities (e.g., 4FRI 

implementation may temporary displace some activities; uncharacteristic wildfire can have longterm displacement consequences, etc.) and; 3) local economic sustainability; this will extend the 

quantitative economic discussion of employment and income to the social sphere to discuss how 

changing economic conditions affect community well-being. Non-market values will be 

measured chiefly through ecological indicators provided by other USFS specialists in their 

analysis (e.g. effects on habitat, water quality, soil quality, etc.). The economic efficiency of 4FRI 

implementation will also be analyzed by the USFS by using data on federal and private 

expenditures and the projected benefits of ecological restoration. 

To supplement the USFS socioeconomic monitoring data and analyses, through multiparty 

monitoring, the 4FRI Collaborative will utilize the information contained in this report to 

complete both social and economic monitoring of the 4FRI project. Although this report contains 

an extensive list of possible objectives that could be monitored, based on the 4FRI 

Collaborative’s priorities and the information gaps contained in the USFS required 

socioeconomic monitoring, specific objectives/questions will be targeted. To assure the project’s 

success and longevity, it is recommended that socioeconomic monitoring is conducted before 

project implementation and there is immediate and ongoing execution within approximately the 

first five years of project implementation (Personal Communication, Nielsen 2011). Once 

socioeconomic monitoring data verifies the 4FRI project is socially and economically on track, 

the pressing need to conduct this type of monitoring will dissipate and the priority socioeconomic 

factors can be monitored less frequently to assess longitudinal changes. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 795
Appendix E – Monitoring Plan

The purpose of the joint effort of the S&MWG and the USFS monitoring process is to assess the 

accuracy of USFS estimates and provide data for adaptive management. In this way, the 

information provided by the USFS in the EIS, coupled with this monitoring framework, are 

linked to support a thorough and on-going assessment of social and economic conditions in the 

study area. 

Methodology in Developing Social and Economic Monitoring Framework

The 4FRI Science and Monitoring Working Group developed both social and economic 

monitoring frameworks to assess relevant socioeconomic factors that will determine these effects 

in planning, implementation and adaptive management of the 4FRI project. Relative to other land 

management activities, monitoring issues that need to be addressed within ecological restoration 

projects are broader and should encompass objectives that affect the widest variety of 

stakeholders (Egan and Estrada-Bustillo 2011; Fulé 2003). As a starting point, social and 

economic desired conditions from the Landscape Restoration Strategy for the First Analysis Area 

(landscape restoration strategy) (4FRI Stakeholder Group 2010b) were compiled from the report 

(appendix A). Additional economic desired conditions were extrapolated from appendix A of the 

landscape restoration strategy report. Within the landscape restoration strategy report, both 

economic and social desired conditions were defined within three spatial scales that include 

landscape, analysis area and firescape. These spatial scales are more applicable to biophysical 

conditions; therefore, for the purpose of developing this monitoring framework, the 

socioeconomic desired conditions were not delineated by these spatial scales. At times, the 

original sets of desired conditions were either repeated within each scale or they were not 

applicable as a socioeconomic desired condition for monitoring. 

Once the final set of desired conditions, or broad goals, were determined, firm, measurable 

monitoring objectives (University of Oregon 2011) were developed through broad stakeholder 

input. As objectives were developed, considerations were based on those that the stakeholder 

group and/or the USFS have the ability to influence and adapt (University of Oregon 2011). 

Monitoring questions were matched to the objectives to ensure the questions asked provide 

essential information that is needed to measure the stated objectives. Indicator selection was 

based on attributes that can be easily measured, are precise, and concisely describe current 

conditions (Moote 2011) as well as those that are sensitive to changes overtime (Moote 2011; 

Eagan and Estrada-Bustillo 2011). In addition, indicators that can satisfy multiple objectives 

should be recognized to assist in the efficacy of the monitoring process (Derr et al. 2005). The 

methods used to evaluate the selected indicators are described in the Toolbox section of this 

report. Once the appropriate assessment(s) were delineated, the recommended frequencies of the 

assessments, how often the monitoring data and analyses are completed, were matched to the 

assessment. Lastly, data sources, whether primary or secondary, were delineated to retrieve the 

necessary data to answer the questions. It is important to note that these frameworks should be 

viewed as a “continuing, inclusive and evolutionary process” (A. Egan Personal Communication 

2011) that is malleable and adaptive over time.

Consideration of temporal and spatial scales is critical to the monitoring process and effects 

should be addressed at micro and macro levels as well as in the short and long-term. For example, 

results from project-level monitoring will provide necessary information to assess a variety of 

programmatic (cumulative) monitoring objectives/questions that can be tracked over time 

(University of Oregon 2011). 

The social and economic framework matrices included in this report are not exhaustive; however, 

provide a basis for framing a 4FRI social and/or economic monitoring project (appendix C and 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

796 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

D). For example, there may be several monitoring questions for a specific objective; however, the 

associated monitoring questions may not be relevant and/or appropriated funding will only 

support answering one of the monitoring questions. Similarly, there is a fairly comprehensive list 

of indicators; however, not all will be measured for a respective monitoring project. In the end, 

the purpose of the study, the constituency requesting the information, how the information will be 

used and, respective funding will ultimately dictate a specific methodology of the monitoring 

project.

Due to the groundbreaking nature of the landscape scale 4FRI project and the unpredictability of 

the results, the “If Statements” or triggers for adaptive management, are described as 

“Undesirable Conditions” (Personal Communication, T. Cheng 2011). The “Undesirable 

Conditions” have been initially expressed as broad qualitative statements that will delineate 

trends. As the project matures, and a baseline is established, these triggers can be adjusted to 

more specific acceptable quantitative ranges that will indicate whether or not adaptive 

management is necessary for each specific objective/question that is being assessed. In addition, 

once a contract(s) is awarded and contractors’ business plans are identified, economic triggers can 

be more clearly delineated and assessments can be designed to determine whether implementation 

is in line with contractors’ business plans. 

In most cases, when socioeconomic studies are conducted, several monitoring questions can be 

addressed simultaneously, thus increasing the efficiency of the monitoring project. For example, a 

telephone survey to residents in the first analysis area can provide necessary data for multiple 

monitoring questions. As economic studies are planned and conducted, when contractor surveys 

are designed and distributed before project implementation, several indicators can be tracked and 

these data can be used for multiple monitoring requirements. 

Program Evaluation

As monitoring protocols are established and implemented for the 4FRI project, program 

evaluation can be used as an appropriate social science methodology. Program evaluation is a set 

of “systematic procedures used in seeking facts or principles” so that theoretical positions can be 

tested (Royse et al. 2010). Program evaluation follows a simple research design procedure that 

includes four main steps: 1. formulate a problem or question, 2. develop a research design for 

data collection efforts, 3. collect data, and 4. analyze the data (Royse et al. 2010). Although this 

design is similar to a traditional research design, the underlying distinction is based on the results. 

In most instances, in a research design, results can be generalized to a broader population, while 

results from a program evaluation may only be applicable to the specific project or multiple 

projects that have distinct similarities. Moreover, program evaluation is designed to facilitate a 

“structured comparison” so that conclusions have a type of relative valuation (Royce 2010). 

Ideally monitoring should be conducted before and after implementation so that pre- and postmeasurements can be compared. Due to the ongoing and malleable nature of monitoring, a 

process evaluation can be conducted throughout the life of the project that provides a program’s 

description, a program’s monitoring protocol and quality assurance measures (Royse et al. 2010). 

Due to the nature of process evaluation, operations are documented and will provide the 

necessary information to replicate or convey the technology of a specific project. Process 

evaluations are typically used for research and demonstration projects as they provide information 

that will inform what was learned during project implementation (Royse et al 2010). 

To take this one step further, a program logic model developed by the W. K. Kellogg Foundation 

(2004) supports this application whereas evaluations are seen as adaptive, applying mid-course 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

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Appendix E – Monitoring Plan

adjustments as needed, while at the same time, documenting its successes (W. K. Kellogg 

Foundation 2004). This evaluative approach also encourages a broad participatory base of all 

involved stakeholders, from developing the question to analyzing the data. The logic model does 

not just focus on the outcome but explains what you are doing, the expected results and a series of 

outcomes from immediate to long-term (W. K. Kellogg Foundation 2004). Moreover, this model 

helps to identify whether the project is on-track and emphasizes learning as an ongoing process - 

an integral part of the evaluation.

Institutional Review Board (IRB)

When collecting information on human subjects, an Institutional Review Board (IRB) should 

complete a review of the proposed project. As subjects participate in research projects, he/she 

should be informed their participation is voluntary and all of their answers are confidential and 

reported as an aggregate, or as a group response. If research is conducted remotely, through the 

telephone or the Internet, informed consent is completed verbally or in a screen that is read by the 

respondent. If participants are interviewed face-to-face, participants should sign consent forms 

before the interview/focus groups begin. The consent and reviews protect the rights of human 

subjects when used in research and prevent unethical treatment during the process (Northern 

Arizona University 2014). 

Tool Box for Assessment

Scale – Sampling Frame

As the purpose of socioeconomic studies is conceptualized, and objectives/questions are designed 

to study a specific population (e.g. “local”), a concise, self-determined definition is necessary to 

pinpoint the sampling frame, or scale, of the population under study (University of Oregon 2011). 

Since this definition is dependent on the purpose of the study and, ultimately how the information 

will be used, it could vary considerably from study to study. The definition of the study’s 

population, or the sampling frame, should reflect one or more factors that include geographic 

(natural, physical), administrative, social, and/or economic boundaries/conditions that are 

adequately representative of the location, political and/or public service jurisdictions, group of 

people or economic factors (Environmental Protection Agency 2002).

Study Design

Both social and economic monitoring should begin with an assessment of current conditions by 

establishing baseline data before project implementation and/or education and outreach programs 

or events. Once a baseline is established, proceeding data collection should occur after major 

interventions to assess the change from the baseline to post-intervention and continue to assess 

changes longitudinally to track them over time. Depending on the selected social or economic 

analysis, accounting for specific issues and concerns within the population or the designated area 

of the study (e.g. community, city, county, EIS Analysis Area, etc.) should be considered and 

integrated in the study design (Egan and Estrada-Bustillo 2011). In addition, the study’s design 

will be dependent on the goals of the study, the constituency, or who is requesting the monitoring 

results, and ultimately, how the monitoring information will be used. Ideally, socioeconomic 

monitoring should be a priority and should be implemented immediately and tracked for the first 

five years to assure the project’s success (Personal Communication, Nielsen 2011).

The type of study that is initiated will dictate whether the purpose of the study is exploratory, 

descriptive or explanatory. Exploratory studies are typically conducted when researchers are 

breaking new ground, want to better understand the issue at hand, test the feasibility of 

developing a more extensive study and/or develop methods to employ in a subsequent study 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

798 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

(Babbie 2010). Descriptive research is precise reporting or measurements and answers the what, 

when, how and where questions and explanatory research reports relationships among the area of 

study and answers the question, why (Babbie 2010). In general, as socioeconomic research 

designs are conceptualized, more than one study type will be integrated in its design. 

To illustrate utilizing multiple study types in assessing social systems affected by the 4FRI 

project, understanding the general publics’ perceptions will most likely take two types of research 

to adequately answer the monitoring questions. First, an exploratory study that consists of focus 

groups of the general public and personal interviews with land managers will provide information 

that is specific to the defined area of study (e.g. 1st Analysis Area, city, county, Forest etc.). Once 

this qualitative data is analyzed, this information will give researchers a basis for a more 

structured (quantitative/qualitative) descriptive and/or explanatory study that is geared towards 

the population in question. For example, if exploratory studies were conducted in the first and 

second analysis areas, commonalities and differences can be identified between the 

subpopulations and subsequently, questions relevant to both populations can be formulated as 

well as modules that are specific to each subpopulation. 

Another key driver in the study’s design is how the information will be used. If the constituency 

requesting monitoring data requires findings to be representative of the population in question, 

probability sampling must be employed. This occurs if all of the individuals in the population 

have an equal chance of being selected and the selection method is randomized. If this is the case, 

the results of the study can be generalized to the population as a whole (Babbie 2010). Probability 

sampling verifies the sample is not biased and enables estimates of the precision that the results 

reflect the study’s population (Fowler 2002). These results can be statistically verified with a 

sampling error, the degree of inaccuracy in the sampling design, as well as a confidence level, 

that the results are representative of the population. Non-probability sampling can be appropriate 

when a complete list of the study’s population is unavailable, resources are limited, study 

requirements do not dictate stringent probability sampling results or the purpose of the study is 

exploratory. For example, “purposive sampling” is appropriate when a select number of key 

informants provide information needed to understand the key issues and is either used to 

understand specific circumstances and/or develop a more stringent study that can be generalized 

to a broader population. 

To the greatest extent possible, we should ensure that the results of socioeconomic studies are 

reliable (results consistently yield similar findings) and valid (results adequately represent the 

concept under consideration) (Royse et al. 2010). However, at times, there is a tradeoff between 

reliability and validity. Factors such as the purpose of the study, the constituency, and how the 

results will be used, will aid in determining the degree to which a greater emphasis should be 

placed on reliability or validity or whether this distinction is necessary. 

Data Sources

Data sources listed in both the social and economic frameworks include both primary and 

secondary data. The social analyses primary data collection includes focus groups, interviews, 

surveys and content analysis. Data collections of this type, if federally sponsored, are subject to 

the Paperwork Reduction Act (PRA) and must receive PRA clearance from the Office of 

Management and Budget prior to implementation. Secondary data sources for social analyses 

included reports by forests, government reports (city, county state and federal) and federal and 

private databases, such as Headwaters Institute and Firewise Communities USA. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 799
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The economic analyses primary data sources include contractor, visitor and business surveys. 

These data collections, if federally sponsored, are also subject to PRA clearance. Secondary data 

for the economic analyses include various government reports (forest, municipal, state and 

federal), previous studies and government databases used in similar studies. As monitoring 

projects are developed and conducted, data sources in the frameworks will be reassessed and 

refined and new data sources will be added.

Literature Review

Generally, upon initiation of a socioeconomic study, background research through a literature 

review is conducted to assess previous research on the topic. More specifically, previous studies 

can assist with determining a study’s design, questionnaire/protocol development, relevant data 

sources, and various analyses that were used and, whether previous studies reveal consistent 

findings. In addition, this information can reveal whether there are consistent flaws in previous 

research that may be remedied (Babbie 2010). 

Census Research

Census data provide information that is inclusive of all individuals in a population (Fowler 2002). 

Census data covers 200 specific topics that describe a population or a “community” that includes 

demographic information such as employment, education, income, a population’s size, and 

“urban” versus “rural” communities (EPA 2002). Census data can also be used to verify the 

demographic data in the study group is reflective of the demographics of the area under study.

Survey Research

The choice of data collection mode, whether it’s through the mail, telephone, personal interviews 

or group administration will be based on the sampling frame, the research question, 

characteristics of the sample, required response rates, question format, availability of trained staff 

and facilities and funding available for the project (Fowler 2002). 

Surveys are one of the best methods used to describe a population’s attitudes and orientations that 

are too large to observe directly and provide a standardized measurement across individuals in a 

given population (Fowler 2002). There are self-administered questionnaires and survey 

administered by interviewers. Self-administered surveys through the mail or on the Internet are 

generally less representative of a population due to typically low response rates. In administering 

Internet surveys, many times the population is not representative as the sampling frame is not 

inclusive of the entire population, nor is the Internet regularly accessible to a broader population. 

However, Internet surveys can be appropriate to populations that have known computer access, 

such as USFS employees. In general, telephone surveys delivered by a live interviewer tend to be 

the most reliable method to collect data as the response rate is much higher, thus reveling results 

that are more indicative of the group that is being studied. Also, telephone survey methodology, 

although not perfect, provides a sampling frame that is most inclusive of a population. A note of 

caution - automated telephone surveys will not yield reliable results for many reasons such as, the 

respondent’s identity is not verified (e.g. a child on the phone), there may be screener questions 

that verifies specific information about a respondent in the household and there is no assurance 

that the question was understood and did not need to be repeated. In general surveys, coupled 

with valid operationalization of concepts through appropriately worded questions, provide 

uncanny accuracy of a population’s beliefs and attitudes (Babbie 2010). In addition, data 

collection through surveys can also provide a population’s characteristics (demographics) that can 

be linked to the responses thus, increasing understanding of specific group’s perceptions or 

beliefs (EPA 2002).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

800 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Data collection of telephone surveys is streamlined through the use of computer programs, such 

as Computer Assisted Telephone Interviewing (CATI). These programs allow for survey question 

programming and results are recorded as the interview is conducted. Not only does this improve 

data collection entry error but also, the phone numbers in the sample are randomized (Random 

Digit Dialing -RDD) and shown on the screen for the interviewer to call. In addition, programs 

such as these allow for responses, whether they are closed- or open-ended, to be directly exported 

into programs such as Statistical Package for the Social Sciences (SPSS) for analysis.

For the 4FRI project, generally if researchers are seeking broad public opinion and attitudes about 

a number of issues, telephone surveys will yield results that can be generalized to the population. 

For more specific economic data, if secondary data is available from reliable sources, these will 

be used. In addition, primary data collected through self-administered surveys from contractors or 

others involved in the restoration process, are the best method, as contractors need to track the 

information and refer to their records. In collecting primary data from contractors, the sooner they 

are aware of these efforts and receive the survey forms/files, the easier it will be for them to track 

the necessary information.

Personal Interviews and Focus Groups

Personal interviews that occur face-to-face can be appropriate when the questions require: 

qualitative in-depth answers, high response rates, interviewer observation, longer interviews, 

rapport building and allow for multi data collection modes that could include diagrams (Fowler 

2002). Personal interviews can include key informants that will provide valuable in-depth 

information such as, USFS personnel and community leaders such as, the County Board of 

Supervisors. Focus groups are a useful tool and usually engage 12-15 people in a guided 

discussion of a topic. The participants would not statistically represent segments of the

population; therefore, this mode of observation is used to more deeply explore a topic and 

become more familiar with the issues under consideration (Babbie 2010). These results can be 

used to design a descriptive or explanatory study and/or used for strategic planning efforts (EPA 

2002).

Content Analysis

Content analysis is used when various mediums of communication provide information in either a 

written form, such as newspaper articles, or in a multimedia format such as movies, speeches, 

photos etc. (Environmental Protection Agency 2002). These analyses reveal recorded historic 

human communication or the artifacts of a social group (Babbie 2010). Content analysis will 

reveal what has been communicated and the analysis will answer the question “why” it was

communicated and “what was the effect” of the communication (Babbie 2010). To complete the 

qualitative analyses of the various formats, a software program, NVivo (2012), can be used for 

evaluation of the data.

Collaborative Performance

The first collaborative performance evaluation has been conducted through a Survey Monkey 

instrument developed in conjunction with the 4FRI Stakeholders and the US Institute for Conflict 

Resolution (October 2011, Appendix E). In addition, a separate evaluation conducted by Northern 

Arizona University (W. Greer, E. Nielsen) and Colorado State University (T. Cheng) that includes 

a 4FRI Case History and a Collaborative Governance Case History will supplement the 4FRI 

Collaborative’s effectiveness and performance measures (May 2012). The intent is to track 

performance over time and to adaptively manage the Collaborative so that improvements are 

made to key areas identified by stakeholders.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 801
Appendix E – Monitoring Plan

Economic Analyses

Economic analyses are essential tools for planning, prioritizing and evaluating restoration projects 

(Robbins and Daniels 2011). Economics will provide a suite of tools to inform decision-making 

and improve transparency in selecting projects (Robbins and Daniels 2011). Based on a recent 

review of literature in describing economic concepts in the context of ecological restoration, 

Robbins and Daniels (2011) outline decision-analysis frameworks that incorporate an inclusive 

array of restoration benefits and costs. A “travel costs method” is employed to determine values 

associated with recreational sites by assessing visitor time and expenditures. “Stated preference 

method” or assessing willingness to pay for environmental improvements is used when indirect 

values, such as watershed protection, are being assessed. The stated preference method can be 

measured by a “contingent valuation,” or how much individuals are willing to pay for a policy or 

project. As an alternative, an “experimental choice method” can be employed as a non-monetary 

valuation that asks individuals to choose from a set of alternatives and rank their preferences. 

“Benefit costs analysis” includes total benefits or revenues and costs (using a weighted 

distribution of each) of a project over time with a defendable discount rate. Alternatively, “cost 

effective analysis” can provide a framework to compare relative costs of alternative methods 

geared towards achieving the same outcome. Lastly, “multi-criteria decision analysis” uses 

nonmonetary values through relative quantitative or qualitative performance scores. This review 

also revealed that although direct costs and revenues should be easy to capture, they are rarely 

reported. To address this lack of accounting, as suggested early in this report, streamlining 

expenditure, revenue and employment data reporting with prepared protocols and contractor 

reporting forms as well as creating a centralized data base prior to project implementation, should 

assist in closing this gap.

Additionally, to capture local economic conditions, economic base theory, a causal model, can be 

employed that divides the local economy into two sectors: 1) a basic, or non-local and 2) nonbasic, or local. This theory is grounded on the premise that the basic sector, or those businesses 

that are dependent on non-local firms to buy their products, is the driver of the local economy. 

Thus, the local economy is strongest when it is not dependent on local factors and can better 

insulate itself from local economic downturns. This distinction is important because the means of 

strengthening a local economy is to develop and enhance the basic sector (McClure 2009).

Prioritization

Although there are a multitude of monitoring objectives/questions in both the social and 

economic frameworks, due to identified preferences of the stakeholders and limitations in 

resources, objectives/questions need to be prioritized by the 4FRI Stakeholders. A basis for 

prioritizing the questions/objectives are issues and concerns that are relevant to the communities 

that are directly affected by the ensuing forest restoration efforts as well as those across the four 

Forests and the State. 

In a study conducted by Egan and Estrada-Bustillo (2011), a model to prioritize socioeconomic 

indicators was developed through a Delphi process. Based on project objectives and availability 

of resources, results indicate there are three levels of indicators that include: 1) a core set that 

utilizes minimum effort at the forest or stand level; 2) includes the set of core indicators and 

balances ecological with socioeconomic dimensions and is used for long-term projects requiring 

more time and expertise and; 3) includes the first two sets of indicators; however, the primary 

focus is socioeconomic outcomes and is used across jurisdictions on landscape-scale projects and 

requires the highest level of expertise and resources. In addition to the recommended intensity of 

the socioeconomic monitoring, specific indicators can be weighted in using an average/median 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

802 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

rating. Based on these results, overall socioeconomic objectives/questions can be identified, will 

provide guidance in selecting the best indicators for the assessment, and can guide resource 

allocation for a given project. 

Adaptive Management

To complete the adaptive management loop, an initial assessment of the public’s awareness, 

knowledge and support of pressing issues, as well as critical economic factors and conditions, is 

necessary to determine effects of outreach as well as implementation. Once these factors are 

understood, hypothesis testing of changes in behavior are developed, empirical data is collected 

and tracked to monitor the effectiveness of future outreach and implementation efforts. These 

steps tie back in to the logic model that explains what you are doing, the expected results and a 

series of outcomes from immediate to long-term (W.K. Kellogg Foundation 2004). Using this 

model helps to identify whether the project is on-track and emphasizes learning as an ongoing 

process - an integral part of the evaluation and a critical component of the adaptive management 

model. 

According to a study conducted by Brown and Squirrell (2010), adaptive management is 

premised on flexibility and job security that enables risk taking. To integrate consistent adaptive 

management within the USFS, results from this study suggest the need to establish mutual trust 

between key stakeholders, such as other agencies, nongovernmental organizations, citizens, 

politicians and the courts, and the USFS. Due to the groundbreaking nature of the 4FRI project 

and the lack of science based adaptive management within the USFS, solidifying the adaptive 

management process is a critical step in ensuring the project’s success. Stakeholders that are 

concerned about potential management outcomes are more likely to support management actions 

if they are confident results from these actions are carefully monitored (Rural Voice for 

Conservation Coalition 2011). In the end, monitoring should not be viewed as an added expense, 

but as an instrument that can ultimately reduce overall costs by minimizing ineffective 

management practices and potentially reducing objections and litigation (Rural Voice for 

Conservation Coalition 2011). Table 150 and table 151 show the socioeconomic monitoring 

framework.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 803
Appendix E – Monitoring Plan

Table 150. Four Forest Restoration Initiative socioeconomic monitoring framework for social systems 

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

I. GOAL: There is broad public awareness, understanding, knowledge and support for collaboratively based forest restoration decisions, processes, and outcomes, including the use of 

fire as a management tool.

There is broad public 

awareness for 

collaboratively based 

forest restoration. 

Is the public aware of 

the collaborativelybased 4FRI forest 

restoration project (e.g. 

current decisions, 

processes and 

outcomes)?

Awareness of the 

collaborativelybased 4FRI 

forest restoration 

project (e.g. 

current 

decisions, 

processes and 

outcomes).

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is 

unaware of the 

collaborativelybased 4FRI forest 

restoration 

project (e.g. 

current decisions, 

processes and 

outcomes).

There is broad public 

understanding/ 

knowledge for 

collaboratively based 

forest restoration. 

Is the public 

knowledgeable of the 

collaboratively-based 

4FRI forest restoration 

efforts (e.g. current 

decisions, processes and 

outcomes)?

Public's 

understanding/ 

knowledge for 

collaborativelybased forest 

restoration. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

knowledgeable of 

collaborativelybased forest 

restoration. 

There is broad public 

support/acceptance for 

collaboratively based 

forest restoration.

Is there broad public 

support/acceptance for 

the collaborativelybased 4FRI forest 

restoration project (e.g. 

current decisions, 

processes and 

outcomes)?

Support 

/acceptance for 

collaborativelybased 4FRI 

forest restoration 

project (e.g. 

current 

decisions, 

processes and 

outcomes).

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public does 

not 

support/accept

collaborativelybased forest 

restoration.

Number of objections 

and lawsuits for 4FRI 

projects are minimized.

Are the number of 

objections and lawsuits 

for 4FRI projects at a 

minimum and/or 

decreasing?

Number & 

length of time of 

lawsuits.

Objections database 

available at: 

http://www.fs.fed.us/e

mc/applit/(Cortner et. 

al 2003).

Track annually for 

first 5 years 

post/analysis area.

Objections database available at: 

http://www.fs.fed.us/emc/applit/

(Cortner et. al 2003).

Objections and 

lawsuits for 4FRI 

projects are 

delaying project 

implementation.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

804 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

There is broad public 

awareness for the use 

of fire as a 

management tool.

Is the public aware of 

the use of fire as a 

management tool?

Public awareness 

for the use of fire 

as a management 

tool.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is 

unaware of the 

use of fire as a 

management tool.

There is broad public 

understanding/ 

knowledge for the use 

of fire as a 

management tool.

Does the public 

understand/have 

knowledge of the use of 

fire as a management 

tool?

Public 

understanding/ 

knowledge for 

the use of fire as 

a management 

tool.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public does 

not have the 

understanding/ 

knowledge for 

the use of fire as 

a management 

tool.

There is broad public 

support/acceptance for 

the use of fire as a 

management tool.

Does the public 

support/accept the use 

of fire as a management 

tool?

Public 

support/acceptan

ce for the use of 

fire as a 

management 

tool.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public does 

not 

support/accept 

the use of fire as 

a management 

tool.

II. GOAL: The public is knowledgeable/understands, accepts/supports the byproduct of smoke from prescribed and managed fires. 

The public is 

knowledgeable/ 

understands the 

byproduct of smoke 

from 

prescribed/managed/ 

pile fires (presence & 

duration.)

Is the public 

knowledgeable/ 

understands why 

prescribed/managed/pile 

fires are necessary and 

will have the byproduct 

of smoke?

Public 

knowledgeable / 

understanding of 

why prescribed 

fire is necessary 

and will have the 

byproduct of 

smoke.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. USFS complaint 

logs.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Public does not 

understand why 

prescribed fire is 

necessary and 

will have the 

byproduct of 

smoke.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 805
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The public 

accepts/supports the 

byproduct of smoke 

from 

prescribed/managed/pil

e fires (presence & 

duration.).

Does the public 

accepts/support the 

byproduct of smoke 

from 

prescribed/managed/pile 

fires?

Public 

acceptance/ 

support of the 

byproduct of 

smoke from 

prescribed fire.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. USFS complaint 

logs.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Public does not 

accept/support 

the byproduct of 

smoke from 

prescribed fire.

III. GOAL: The public understands, accepts, and supports fire’s natural role in forest ecosystems.

The public understands 

fire’s natural role in 

forest ecosystems.

Does the public 

understand fire’s natural 

role in forest 

ecosystems?

Public 

understanding 

fire’s natural role 

in forest 

ecosystems.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Public does not 

understand fire’s 

natural role in 

forest 

ecosystems.

The public accepts/ 

supports fire’s natural 

role in forest 

ecosystems.

Does the public 

accept/support fire’s 

natural role in forest 

ecosystems?

Public 

acceptance/ 

support for fire’s 

natural role in 

forest 

ecosystems.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Public does not 

accept/ support 

fire’s natural role 

in forest 

ecosystems.

IV. GOAL: Rural communities are protected from high-severity fire and their quality of life is enhanced through forest restoration.

Rural communities' 

risks from highseverity fire are 

reduced.

Is the frequency and 

size of high severity 

fires decreasing?

1. Frequency of 

wildfires.

2. Size (acres) of 

wildfires.

Frequency and & size 

of wildfires 5 years 

post-4FRI 

implementation vs. 

frequency and 

duration of wildfires 5 

years pre-4FRI 

implementation.

5 years USFS by Forests (Greater Flagstaff 

Forest Partnership 2010).

Rural 

communities' risk 

from highseverity fire are 

not decreasing.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

806 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

Rural community 

residents' perceived 

risk of high-severity 

fire is reduced.

[If frequency and size of 

high severity fires are 

decreasing] Do rural 

community residents' 

perceive rural 

communities are being 

protected from highseverity fire? 

Rural 

community 

residents' 

perception of 

risk of high 

severity fires. 

1. Focus groups with

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Rural community 

residents' 

perceived risk of 

high-severity fire 

is not decreasing.

Landowners adjacent 

to or in the proximity 

of the four forests (e.g. 

state, private, tribal, 

municipal, etc.) are 

encouraged to 

participate in restoring 

all forested lands in 

Northern Arizona.

Q1: Are landowners 

adjacent to or in the 

proximity of the four 

forests participating in 

restoring their forested 

lands?

Q2: What programs are 

in place to encourage 

land owners to treat 

their lands?

Q1/Q2: 1. Land 

ownership, 

location, number 

and total dollar 

value of: State 

Fire Assistance 

grants, Tribal 

Forest Protection 

Act, AZ Forest 

Health Program, 

Forest 

Stewardship 

Program, etc.

2. Fire behavior 

including 

adjacent nonUSFS lands.

Q1: Tracking land 

ownership/location 

and respective 

treatments (fire 

behavior).

Q2: 1. Tracking 

outreach efforts to 

state, private, tribal, 

municipal landowners.

2. Tracking land 

ownership, location 

number and total $ 

value of grants 

awarded.

5 years 1. Headwaters Institute.

2. State, private, tribal, municipal 

grant/project reports.

3. USFS by Forests.

4. 4FRI Stakeholder Group.

Landowners 

adjacent to or in 

the proximity of 

the four forests 

(e.g. state, 

private, tribal, 

municipal, etc.) 

are not 

encouraged to 

participate/are 

not restoring 

forested lands in 

Northern 

Arizona.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 807
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

V. GOAL: Social values and recreational opportunities are protected and/or enhanced through forest restoration activities. 

Recreational 

opportunities are 

protected through 

forest restoration 

activities.

Q1: Are recreational 

opportunities protected 

as restoration projects 

are implemented?

Q2: Does the public 

perceive recreational 

opportunities are 

protected through forest 

restoration activities?

Q1: Number & 

type of 

recreational 

activities.

Q2: Public 

perception of 

protection of 

recreational 

opportunities 

through forest 

restoration 

activities.

Q1: Analysis of 

USFS, AZG&F, 

USFWS reports.

Q2: 1. Focus groups 

with community 

members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Q1: 1. National Visitor Use 

Monitoring Program (USDA FS 

2011).

2. Headwaters Institute

3. AZG&F The Economic 

Importance of Fishing and Hunting 

(utilizes IMPLAN input/output 

model) (Silberman2002).

4. USFWS National Survey of 

Fishing, Wildlife, Hunting, & 

Wildlife Assoc. Recreation (USDI 

FWS 2006).

5. Visitor surveys.

Q2: Focus group, interview and 

survey results.

Recreational 

opportunities are 

not protected as 

forest restoration 

activities occur.

Recreational 

opportunities are 

enhanced through 

forest restoration 

activities.

Q1: Are recreational 

opportunities improving 

as restoration projects 

are implemented?

Q2: Does the public 

perceive recreational 

opportunities are 

improving as forest 

restoration activities are 

occurring?

Q1: Number & 

type of 

recreational 

activities.

Q2: Public 

perception of 

improving 

recreational 

opportunities as 

forest restoration 

activities are 

occurring.

Q1: 1. Analysis of 

USFS, AZG&F, 

USFWS reports.

2. Visitor surveys

Q2: 1. Focus groups 

with community 

members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

Pre- postimplementation/ 

outreach. Track 

annually for first 5 

years post.

As above. Q1: Recreational 

opportunities are 

not improving as 

restoration 

projects are 

implemented.

Q2: Public 

perceives 

recreational 

opportunities are 

not improving as 

forest restoration 

activities are 

occurring.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

808 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

Aesthetic values are 

protected through 

forest restoration 

activities. 

Does the public 

perceive aesthetic 

values are protected 

through forest 

restoration activities?

Public 

perception that 

aesthetic values 

are protected 

through forest 

restoration 

activities.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Comparative 

analysis of field trips 

to treated vs. untreated 

sites (*timing relevant 

to postimplementation is 

critical-minimum oneyear post).

1. Pre- postimplementation/ 

outreach. Track 

annually for first 5 

years post.

1. Focus group, interview and survey 

results.

2. Headwaters Institute.

The public 

perceives that 

aesthetic values 

are not being 

protected as 

forest restoration 

activities are 

occurring.

Aesthetic values are 

enhanced through 

forest restoration 

activities.

Does the public 

perceive aesthetic 

values are enhanced 

through forest 

restoration activities?

Public 

perception that 

aesthetic values 

are enhanced 

through forest 

restoration 

activities.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Comparative 

analysis of field trips 

to treated vs. untreated 

sites (*timing relevant 

to postimplementation is 

critical-minimum oneyear post).

1. Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

1. Focus group, interview and survey 

results.

2. Headwaters Institute. 

The public 

perceives that 

aesthetic values 

are not enhanced 

as forest 

restoration 

activities are 

occurring. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 809
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

VI. GOAL: Rural communities play an active part in reducing fire risk by implementing FireWise actions and creating defensible space around their property. 

Rural community 

residents are aware/ 

knowledgeable of 

FireWise principles/ 

FireWise communities.

Are rural community 

residents aware/ 

knowledgeable of 

FireWise 

principles/FireWise 

communities?

Public 

awareness/ 

knowledge for 

FireWise 

principles.

1. Focus groups with 

community members.

2. Interviews with fire 

prevention managers.

3. Telephone survey 

with residents in study 

area.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Rural community 

residents are 

unaware/not 

knowledgeable of 

FireWise 

principles/ 

FireWise 

communities.

Rural community 

residents are aware/ 

knowledgeable of 

implementing 

defensible space.

Are rural community 

residents aware/ 

knowledgeable of 

implementing 

defensible space?

Public 

awareness/ 

knowledge of 

implementing 

defensible space.

1. Focus groups with 

community members.

2. Interviews with fire 

prevention managers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Rural community 

residents are 

unaware/not 

knowledgeable of 

implementing 

defensible space.

Number of 

communities that are 

recognized as FireWise 

increases.

Are the number of 

communities that are 

recognized as FireWise 

increasing?

Number of 

communities 

recognized as 

FireWise.

Track no. of 

communities 

recognized as 

Firewise.

Pre- postimplementation 

/outreach. 5 years.

Firewise Communities USA 

(http://www.firewise.org/Communiti

es/USA-Recognition-Program.aspx).

Number of 

communities that 

are recognized as 

FireWise is not 

increasing. 

VII. GOAL: There is broad public support for the 4FRI Collaborative as forest restoration activities are implemented.

The public is aware of 

the 4FRI 

Collaborative.

Is the public aware of 

the 4FRI Collaborative?

Public awareness 

of the 4FRI 

Collaborative. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

aware of the 

4FRI 

Collaborative.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

810 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The public is 

knowledgeable/underst

ands the 4FRI 

Collaborative's role in 

the 4FRI Initiative.

Is the public 

knowledgeable/understa

nds the 4FRI 

Collaborative's role in 

the 4FRI Initiative?

Public's 

knowledge of the 

4FRI 

Collaborative's 

role in the 4FRI 

Initiative.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation/outre

ach. Track annually 

for first 5 years post.

Focus group, interview and survey 

results.

The public does 

not understand 

the 4FRI 

Collaborative's 

role in the 4FRI 

Initiative.

The public is 

supportive of the 4FRI 

Collaborative.

Is the public supportive 

of the 4FRI 

Collaborative?

Public support 

for the 4FRI 

Collaborative.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

supportive of the 

4FRI 

Collaborative.

VIII. GOAL: There is public support for the US Forest Service (USFS) as forest restoration activities are implemented.

The public is aware of 

the USFS's 

involvement/role with 

the 4FRI 

Collaborative.

Is the public aware of 

the USFS's 

involvement/role with 

the 4FRI Collaborative?

Public awareness 

for the USFS's 

involvement/role 

with the 4FRI 

Collaborative.

1. Focus groups with 

community members. 

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

aware of the 

USFS's 

involvement/role 

with the 4FRI 

Collaborative.

The public is aware of 

the USFS's 

involvement with the 

4FRI Project.

Is the public aware of 

the USFS's involvement 

with the 4FRI Project?

Public awareness 

for the USFS's 

involvement/role 

with the 4FRI 

Project.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

aware of the 

USFS's 

involvement with 

the 4FRI Project.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 811
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The public is 

supportive of the 

USFS's involvement 

with the 4FRI 

Collaborative.

Is there public 

support/acceptance for 

the USFS's involvement 

with the 4FRI 

Collaborative?

Public support 

for the USFS's 

involvement 

with the 4FRI 

Collaborative.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

supportive of the 

USFS's 

involvement with 

the 4FRI 

Collaborative.

The public is 

supportive of the 

USFS's involvement 

with the 4FRI Project.

Is there public 

support/acceptance for 

the USFS's involvement 

with the 4FRI Project?

Public support 

for the USFS's 

involvement 

with the 4FRI 

Project.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The public is not 

supportive of the 

USFS's 

involvement with 

the 4FRI Project.

IX. GOAL: The general public is aware, knowledgeable and supportive of 4FRI implemented treatments within the analysis area. 

The general public is 

aware of 4FRI 

implemented 

treatments within the 

analysis area.

Is the general public 

aware of 4FRI 

implemented treatments 

within the analysis area?

Public awareness 

of 4FRI 

implemented 

treatments 

within the 

analysis area.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The general 

public is unaware 

of 4FRI 

implemented 

treatments within 

the analysis area.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

812 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The general public is 

knowledgeable/ 

understands 4FRI 

implemented 

treatments (mechanical 

thinning, road 

alteration, etc. as 

necessary tools) for 

ecological restoration 

within the analysis 

area.

Is the general public 

knowledgeable/ 

understands 4FRI 

implemented treatments 

for ecological 

restoration within the 

analysis area?

Public 

knowledge/

understanding 

4FRI 

implemented 

treatments 

(mechanical 

thinning, road 

alteration, etc.) 

as necessary 

tools for 

ecological 

restoration 

within the 

analysis area.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation/outre

ach. Track annually 

for first 5 years post.

Focus group, interview and survey 

results.

The general 

public is not 

knowledgeable/d

oes not 

understand 4FRI 

implemented 

treatments 

(mechanical 

thinning, road 

alteration, etc.) as 

necessary tools 

for ecological 

restoration within 

the analysis area.

The general public is 

supportive of 4FRI 

implemented 

treatments within the 

analysis area.

Is the general public 

supportive of 4FRI 

implemented treatments 

within the analysis area?

Public support 

for 4FRI 

implemented 

treatments 

within the 

analysis area.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation/outre

ach. Track annually 

for first 5 years post.

Focus group, interview and survey 

results.

The general 

public is not 

supportive of 

4FRI 

implemented 

treatments within 

the analysis area.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 813
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

There is ample 

notification to the 

public of 4FRI 

implemented projects 

that may include road 

construction, 

mechanical thinning, 

prescribed and 

managed fires, etc. 

Q1: Does the public 

believe there is ample 

notification of 

restoration projects?

Q2: What campaigns 

and public notifications 

are in place to inform 

the public of restoration 

treatments and/or prep 

for those treatments?

Q1: Public 

perception of 

notification of 

restoration 

projects/activitie

s.

Q2: Website 

postings, 

newspaper, 

radio, direct 

signage in the 

forest, 4FRI 

800#, etc.

Q1: 1. Focus groups 

with community 

members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

Q2: Number, type, 

content analysis of 

public campaigns/ 

notifications.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Q1: Focus group, interview and 

survey results.

Q2: Results from content analysis.

Q1: Public 

perception of 

notifications of 

4FRI 

implemented 

projects is not 

sufficient (road 

construction, 

mechanical 

thinning, 

prescribed and 

managed fires, 

etc.).

Q2: An 

insufficient 

amount of 

campaigns and 

public 

notifications are 

in place to 

adequately 

inform the public 

of restoration 

treatments and/or 

prep for those 

treatments.

X. GOAL: The general public is aware of 4FRI educational and outreach programs and has the opportunity to participate in the 4FRI effort.

The general public is 

aware of 4FRI 

educational and 

outreach programs.

Is the general public

aware of 4FRI 

educational and 

outreach programs?

Public awareness 

of 4FRI 

educational and 

outreach 

programs. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

The general 

public is unaware 

of 4FRI 

educational and 

outreach 

programs. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

814 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The general public has 

the opportunity to 

participate in the 4FRI 

educational and 

outreach programs.

Does the general public 

have the opportunity to 

participate in the 4FRI 

educational and 

outreach programs?

Public's 

opportunity to 

participate in the 

4FRI educational 

and outreach 

programs. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Number, frequency, 

type of educational 

and outreach 

programs. 

Annual 1. Focus group, interview and survey 

results.

2. USFS by forest.

3. 4FRI Collaborative Stakeholder 

group.

The general 

public has not 

had ample 

opportunity to 

participate in the 

4FRI educational 

and outreach 

programs. 

Youth are aware of 

4FRI educational and 

outreach programs.

Are youth aware of 

4FRI educational and 

outreach programs?

Youth awareness 

for 4FRI 

educational and 

outreach 

programs. 

1. Focus groups with 

community 

members.2. Interviews 

with land 

managers/key 

decision-makers.3. 

Telephone survey with 

residents in study area. 

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Youth are not 

aware of 4FRI 

educational and 

outreach 

programs. 

Youth has the 

opportunity to 

participate in the 4FRI 

educational and 

outreach programs.

Do youth have the 

opportunity to 

participate in the 4FRI 

educational and 

outreach programs?

Opportunities for 

youth to 

participate in the 

4FRI educational 

and outreach 

programs. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Survey local youth 

group coordinators.

5. Number, frequency, 

type of youth 

programs related to 

the 4FRI effort.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Youth have not 

had ample 

opportunity to 

participate in the 

4FRI educational 

and outreach 

programs. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 815
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

Low income/minority 

populations are aware 

of 4FRI educational 

and outreach programs.

Are low 

income/minority 

populations aware of 

4FRI educational and 

outreach programs?

Awareness of 

low 

income/minority 

populations of 

4FRI educational 

and outreach 

programs. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Oversample low 

income/minority 

populations.

5. Number, frequency, 

type of outreach 

programs geared 

towards low 

income/minority 

populations related to 

the 4FRI effort.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Low 

income/minority 

populations are 

unaware of 4FRI 

educational and 

outreach 

programs. 

Low income/minority 

populations have the 

opportunity to 

participate in the 4FRI 

educational and 

outreach programs.

Do low 

income/minority 

populations have the 

opportunity to 

participate in the 4FRI 

educational and 

outreach programs?

Low 

income/minority 

populations 

opportunity to 

participate in the 

4FRI educational 

and outreach 

programs. 

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Oversample low 

income/minority 

populations.

5. Number, frequency, 

type of outreach 

programs geared 

towards low 

income/minority 

populations related to 

the 4FRI effort.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Low 

income/minority 

populations have 

not had ample 

opportunity to 

participate in the 

4FRI educational 

and outreach 

programs. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

816 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

The general public has 

the opportunity to 

participate in the 4FRI 

effort. 

Does the general public 

have the opportunity to 

participate in the 4FRI 

effort? 

Public's 

opportunity to 

participate in the 

4FRI effort.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Number, frequency, 

type of outreach 

programs for public 

participation in the 

4FRI effort.

Pre- postimplementation/outre

ach. Track annually 

for first 5 years post.

Focus group, interview and survey

results.

The general 

public has not 

had ample 

opportunity to 

participate in the 

4FRI effort.

XI. GOAL: Treatments within the analysis area minimize short-term impacts and enhance vegetation characteristics valued by Forest users over the long-term.

Treatments within the 

analysis area minimize 

short-term impacts 

such as skid trails, 

decks, excessive slash, 

roads etc.

Q1: What are the shortterm impacts of concern 

to Forest users?

Q2: Are treatments 

within the analysis area 

minimizing short-term 

impacts such as: skid 

trails, decks, excessive 

slash, roads etc.?

Q1: Treatments' 

short-term 

impacts of 

concern to forest 

users.

Q2: Public's 

perception of 

short-term 

impacts of 

treatments.

Q1: Review BMP 

monitoring reports.

Q2: 1. Focus groups 

with community 

members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Field trips/focus 

groups to restoration 

sites.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Q1: BMP Reports

Q2: Focus group, interview, field trip 

and survey results.

Treatments 

within the 

analysis area are 

not minimizing 

short-term 

impacts of 

concern to forest 

users (e.g. skid 

trails, decks, 

excessive slash, 

etc.).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 817
Appendix E – Monitoring Plan

Objective Monitoring Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF 

(Undesirable 

Conditions)

Treatments within the 

analysis area enhance 

vegetation 

characteristics valued 

by Forest users over 

the long-term.

Q1: What are the 

vegetative 

characteristics valued 

by Forest users over the 

long-term?

Q2: Do these treatments 

enhance vegetation 

characteristics valued 

by Forest users over the 

long-term?

Q1: Vegetative 

characteristics 

valued by Forest 

users over the 

long-term.

Q2: Public's 

perception of 

vegetative 

characteristics 

that are valued 

by Forest users 

over the longterm.

1. Focus groups with 

community members.

2. Interviews with 

land managers/key 

decision-makers.

3. Telephone survey 

with residents in study 

area.

4. Field trips/focus 

groups to restoration 

sites.

Pre- postimplementation 

outreach. Track 

annually for first 5 

years post.

Focus group, interview and survey 

results.

Treatments 

within the 

analysis area do 

not enhance 

vegetation 

characteristics 

that are valued by 

Forest users over 

the long-term.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

818 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Table 151. Four Forest Restoration Initiative socioeconomic monitoring framework for economic systems 

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

I. GOAL: The byproducts of mechanical forest restoration offset the costs of treatment implementation.

Wood byproduct 

sales exceed the costs 

of implementation 

(Contractors are 

operating at a profit 

and the USFS does 

not have to pay 

contractors' treatment 

costs).

Q1: Do byproduct sales 

exceed operational 

costs?

Q2: Are treatments 

adequately sequenced 

to enable contractors to 

offset their overall 

operational costs?

Q3: Are USFS 

contracting costs 

decreasing?

Q1: 1. Operational 

costs of treatments:

a. Mobilization: to 

move equipment from 

site to site, to move 

operators (daily) from 

homebase to site.

b. Loading: cutting, 

skidding, delimbing, 

piling slash, loading 

stems.

c. Haul: transport 

costs from landing to 

processing site (time 

& distance).

2. Amount of wood 

and its value (4FRI 

Stakeholder Group 

2010c). 

3. Degree of deviation 

from business plan(s).

Q2: 1. No. of task 

orders and location.

2. Wood yields/task 

order ((4FRI 

Stakeholder Group 

2010c). 

Q1: Operational costs 

of treatments vs. 

amount of wood & its 

value ((4FRI 

Stakeholder Group 

2010c). 

Q2: Average wood 

yields vs. No. of task 

orders balanced on a 

semi-annual or 

quarterly basis ((4FRI 

Stakeholder Group 

2010c). 

Dependent on 

business plan(s).

1. Contractor surveys

2. USFS business plans (D. 

Jaworski Personal 

Communication 2011).

3. Contracts: federal databases

a.USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

4. Headwaters Institute

Q1: Operational 

cost of treatments 

exceeds byproduct 

sales.

Q2: Average wood 

yields per task 

order does not 

support contractors 

operating at a 

profit.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 819
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

II. GOAL: The economic value of ecosystem services provided by restored forests (such as the value of recreation or water) are captured and reinvested to support forest restoration 

and ecosystem management. 

The economic value 

of ecosystem services 

provided by restored 

forests, such as the 

value of 

recreation/tourism, 

are captured and 

reinvested to support 

forest restoration and 

ecosystem 

management. 

Q1: What is the 

increase (percent) in 

direct service revenues 

related to 

recreation/tourism?

Q2: What is the 

increase (percent) in 

revenues associated 

w/fee imposed 

recreation activities 

(e.g. hunting, fishing, 

pass/entry fees etc.)?

Q3: 1. Has a portion of 

the determined value of 

increased recreational 

revenues been 

reinvested in forest 

restoration?

2. How many 

collaborators are 

involved in contributing 

to this program?

Q1: 1. Lodging,

2. Restaurant,

3. Groceries,

4. Gas/Oil,

5. Other 

transportation,

6. Activities,

7. Admissions/ Fees,

8. Souvenirs/ Other 

expenditures (USDA 

FS 2011). 

Q2: 1. AZG&F 

license sales by 

County.

2. Visitor fees.

Q3: Dollar value of 

fees invested in forest 

restoration activities.

Q1-Q3: Travel cost 

method using: USFS, 

AZG&F, USFWS 

reports tracked with 

investments made in 

forest restoration from 

fees/licenses/ private 

revenues.

5 years (USDA FS 

2011; USDI FWS 

2006) 

Q1: 1. National Visitor Use 

Monitoring Program (USDA FS 

2005).

2. Headwaters Institute

Q2: 1. AZG&F The 

Economic Importance of Fishing 

and Hunting

(utilizes IMPLAN input/output 

model) (Silberman 2002). 

2. USFWS National Survey of 

Fishing, Wildlife, Hunting, & 

Wildlife Assoc. Recreation 

(USDI FWS 2006).

3. Visitor surveys.

Q3: S&MWG database 

Q1/Q2: Direct 

service revenues 

and license fees 

related to 

recreation/tourism 

are decreasing as 

forest restoration 

activities are 

occurring.

Q3: A portion of 

revenues generated 

from recreation and 

tourism are not 

being reinvested in 

forest restoration 

activities. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

820 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

The economic value 

of ecosystem services 

provided by restored 

forests, such as the 

value of water, are 

captured and 

reinvested to support 

forest restoration and 

ecosystem 

management. 

Q1: What is the effect 

in water yield, prepost-restoration?

Q2: What is the effect 

in sedimentation, prepost-restoration?

Q3: What is the 

economic value of 

increase/loss of water 

yield?

Q4: [If increased] Has a 

portion of the

determined value of 

increased water yield 

been reinvested in 

forest restoration?

Q5: Are restoration 

projects reducing the 

costs of producing a 

potable water supply?

Q6: How many 

collaborators are 

involved in contributing 

to this program and 

what is the $ value of 

each?

Q1/Q2: SRP Paired 

Watershed Study 

Costs associated w/:

a. Transport,

b. Treating,

c. Developing 

new/existing water 

supplies,

d. Capture,

e. Delivery

Q3-Q5: Watershed 

fund revenues (e.g. 

assess a fee to each 

water consumer based 

on use per 5,000 

gallons per month 

(Santa Fe Watershed 

Association 2009; 

City of Flagstaff

2010).

a. Operation & 

maintenance expenses

b. Taxes/transfers

c. Capital 

additions/replacement

d. Debt services 

(principle/interest)

e. Allocated indirect 

costs

f. Administration 

(City of Flagstaff

2010).

Q1/Q2: SRP Paired 

Watershed Study 

compares results to 

Beaver Creek and

Castle Creek 

Watershed Studies 

(Arizona Forest 

Resource Task Group

2010).

Q3-Q5: Determined 

value of increased 

water yield vs. 

proportion of this 

value invested in forest 

restoration activities.

Dependent on SRP 

Study and Promotion 

of Ecosystem 

Services Investment.

Q1/Q2:

1.SRP/NAU

2. Beaver Creek Watershed 

Study

3. Castle Creek Watershed Study 

(Arizona Forest Resource Task 

Group 2010).

4. Watershed Conditions 

Framework (USFS).

Q4/Q5/Q6:

1. City of Flagstaff Utilities 

(Water) Dept.

2. Long-term Financial Plan & 

Rate & Fee Study (City of 

Flagstaff 2010).

3. S&MWG database. 

Q1: Water yield is 

decreasing as 

restoration 

activities are 

occurring.

Q2: Sedimentation 

is increasing as 

restoration 

activities are 

occurring.

Q3: A portion of 

revenues generated 

from watershed 

restoration and 

protection are not 

being reinvested in 

forest restoration 

activities.

Q5: Restoration 

projects are not 

assisting in 

reducing the costs 

of producing a 

potable water 

supply.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 821
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

The economic value 

of ecosystem services 

provided by restored 

forests, such as 

wildlife habitat 

creation and 

preservation, are 

captured and 

reinvested to support 

forest restoration and 

ecosystem 

management. 

Are forest restoration 

activities maintaining 

and enhancing habitat 

for wildlife to an extent 

that biodiversity offsets 

and compensation 

programs can be 

implemented and 

resulting funds are 

reinvested into forest 

restoration activities?

1. Wetland & Stream 

Ecosystems 

Compensation.

2. Endangered 

Species 

Compensation.

3. Conservation 

Banking (Madsen et 

al. 2010). 

Value of compensation 

for preservation of 

wetland and stream 

ecosystems and 

endangered species vs. 

the proportion 

reinvested into forest 

restoration activities 

(Madsen et al. 2010).

10 years USFWS NMFS (Madsen et al.

2010).

Forest restoration 

activities are not 

maintaining and 

enhancing habitat 

for wildlife to an 

extent that 

biodiversity offsets 

and compensation 

programs can be 

implemented and 

resulting funds are 

reinvested into 

forest restoration 

activities.

The economic value 

of ecosystem services 

provided by restored 

forests, such as 

wildfire cost savings, 

are captured and 

reinvested to support 

forest restoration and 

ecosystem 

management. 

Q1: What are the fire 

suppression costs 

incurred 5 years post 

4FRI implementation 

and how does this 

compare to 5 years pre 

4FRI implementation? 

Q2: What is the amount 

of cost savings (avoided 

costs vs. treatment 

costs) of wildfire 

suppression that has 

been reinvested in 

forest restoration 

activities?

Q1: Federal, state and 

local suppression 

costs,

Private property 

losses (insured & 

uninsured),

Damage to utility 

lines,

Damage to recreation 

facilities,

Loss of timber 

resources,

Aid to evacuees 

(WFLC 2010), 

resurveying land 

boundaries (M. Lata

Personal 

Communication

2011).

Q2: 1. Acres treated 

& $ amount/acre of 

risk reduction.

2. Dollar value 

reinvested in 

restoration activities.

Wildfire suppression 

costs 5 years post4FRI implementation 

(control for increases 

in population and 

housing) vs. the 

amount of cost savings 

that is reinvested in 

forest restoration 

activities.

5 years postimplementationQ1: 1. Direct suppression costs 

obtained from: USFS, BLM, 

NRCD, NIFC, State, County, 

FEMA, DHS, Insurance 

companies, American Red Cross 

(Western Forestry Leadership 

Coalition 2010).

Q1/Q2: 1. Direct treatment costs 

obtained from: USFS, 

contractors. 

2. Headwaters Economics 

(population/housing).

3. USFS budget staff 

(D. Jaworski Personal 

Communication 2011)

4. S&MWG database.

Q1: Fire 

suppression costs 

are not decreasing 

(5 years post 4FRI 

when compared to 

5 years pre 4FRI).

Q2: A proportion 

of cost savings of 

wildfire 

suppression has not 

been reinvested in 

forest restoration 

activities.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

822 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

III. GOAL: Rural communities receive direct and indirect economic benefits and ecosystem services as a result of forest restoration and resilient forests.

Forest restoration 

activities will create 

direct quality jobs in 

rural communities in 

Arizona.

Q1: How many direct 

jobs have been created 

by forest restoration 

activities?

Q2: What is the quality 

of the jobs?

Q3: Are the jobs filled 

by local residents?

Q4: How many direct 

jobs have been filled by 

low-income/minority 

populations?

Q1-Q3: Number, 

Types (FT vs. PT vs. 

seasonal), Positions, 

percent of jobs over 

total employment 

(Egan and EstradaBustillo 2011)

Average length of 

employment, percent 

receiving benefits or 

payments in lieu of, 

Wages 

(average/worker, 

family-supported), 

Locations, percent of 

contracts w/ on the 

job training, Safety 

(percent and number 

of contracts without 

job related 

injuries/illnesses 

resulting in lost work 

time), percent and 

number of local 

workforce (resident 

zip codes), Distance 

traveled to work 

(University of Oregon

2011).

Economic Impact 

Analysis: Direct 

reporting of primary 

and secondary data.

Annual 1. Contractor reporting 

form/survey.

2. Headwaters Institute (EPSHDT Socioeconomic profiles).

3. Bureau of Labor Statistics 

(Stynes 1992).

Q1: Forest 

restoration 

activities have not 

created a sufficient 

number of direct 

jobs.

Q2: Forest 

restoration 

activities have not 

created a sufficient 

number of quality 

jobs (e.g. FT, 

positions, benefits, 

trainings, safety, 

etc.).

Q3: Forest 

restoration 

activities have not 

created a sufficient 

number of jobs that 

are filled by local 

residents.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 823
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Forest restoration 

activities will create 

indirect jobs in rural 

communities in 

Arizona.

How many indirect jobs 

have been created by 

forest restoration 

activities?

Direct Jobs: Number, 

Types (FT vs. PT), 

Average length of 

employment 

(University of Oregon

2011).

Region specific dollartracking and multiplier 

effects of direct 

employment (for every 

dollar spent by a 

business, some number 

of dollars are created) 

(Egan and EstradaBustillo 2011, Sitko 

and Hurteau 2010, 

Stynes 1992).

Annual 1. Contractor reporting 

form/survey.

2. Headwaters Institute (EPSHDT Socioeconomic profiles).

3. Bureau of Labor Statistics 

(Stynes 1992).

Forest restoration 

activities have not 

created a sufficient 

number of indirect 

jobs. 

Forest restoration 

activities will create 

increased retail 

sales/services in rural 

communities in 

Arizona. 

Q1: Has city/county 

sales tax on goods and 

services increased as 

forest restoration 

activities have 

occurred?

Q2: Have retail 

sales/service revenues 

increased as forest 

restoration activities 

have occurred?

Q1: City/county sales 

tax on goods and 

services.

Q2: Retail sales & 

services revenue.

Dollar-tracking and 

multiplier effects 

(region-specific) 

(Sitko and Hurteau

2010) of business 

activity (Stynes 1992).

Annual 1. AZ Dept. of Revenue. 

2. City reports.

3. County reports.

4. US Census Bureau.

5. U.S. Department of Labor, 

Bureau of Labor Statistics.

6. Arizona Indicators (Morrison 

Institute of Public Policy 2011).

Q1: City/county 

sales tax on goods 

and services has 

not increased as 

forest restoration 

projects have been 

implemented.

Q2: Retail sales & 

services revenue 

has not increased 

as forest restoration 

projects have been 

implemented.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

824 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Forest restoration 

activities will create 

increased tax 

revenues (e.g. 

property tax, business 

expenditures) in rural 

communities in 

Arizona. 

Q1: Have taxes 

generated from forest 

industry business 

expenditures increased 

as forest restoration 

activities have 

occurred?

Q2: Have property/sales 

tax/school revenues 

generated from forest 

industry employees 

(direct/indirect jobs) 

increased as forest 

restoration activities 

have occurred?

Q1: 1. Sales of wood 

products.

2. Capital 

expenditures of 

project materials.

3. Subcontract 

thinning services 

(Sitko and Hurteau

2010).

Q2: 1. Sales/property 

taxes generated by 

employees (direct & 

indirect) (by county).

2. School revenues 

generated by avg. 

family.

3. Sales tax generated 

by avg. per capita 

expenditures on 

consumable 

goods/supplies (by 

county) (Sitko and 

Hurteau 2010).

Q1/Q2: Total net 

employee revenue 

based on jobs 

estimates and 

economic 

contributions from 

forest industry 

employees 

(direct/indirect). 

Indirect jobs: use 

regional multiplier 

effect, input/output 

modeling) (Sitko and 

Hurteau 2010).

Annual 1. Contractor reporting 

form/survey.

2. U.S. Bureau of Economic 

Analysis (Sitko and Hurteau

2010).

3. Headwaters Institute (EPSHDT Socioeconomic profiles).

Q1: Taxes 

generated from 

forest industry 

business 

expenditures have 

not increased as 

forest restoration 

activities are 

implemented.

Q2: Property/sales 

tax/school 

revenues generated 

from forest 

industry employees 

(direct/indirect 

jobs) have not 

increased as forest 

restoration 

activities are 

implemented.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 825
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Forest restoration 

activities will 

increase 

recreation/tourism in 

rural communities in 

Arizona. 

Q1: Has recreation 

increased as forest 

restoration activities 

have occurred?

Q2: Has tourism 

increased as forest 

restoration activities 

have occurred?

Q3: Has tourism related 

jobs/housing increased 

as forest restoration 

activities have 

occurred? 

Q1: 1. AZG&F

license sales by 

County.

2. Visitor days

Q2: 1. Lodging

2. Restaurant 

3. Groceries

4. Gas/Oil

5. Other 

transportation

6. Activities

7. Admissions/Fees

8. Souvenirs/Other 

expenditures (USDA 

FS 2005). 

9. Tourism tax (e.g. 

Flagstaff Bed, Board 

& Booze (BBB) tax).

Q3: 1. Travel and 

tourism jobs (seasonal 

employment).

2. Housing related to 

tourism jobs.

Economic Impact 

Analysis: Track flow 

of economic activity 

associated with 

tourism.

5 years (USDA FS 

2011; USDI FWS 

2006).

1. National Visitor Use 

Monitoring Program (USDA FS 

2005).

2. AZG&F The Economic 

Importance of Fishing and 

Hunting (utilizes IMPLAN 

input/output model) (Silberman 

2002). 

3. USFWS National Survey of 

Fishing, Wildlife, Hunting, & 

Wildlife Assoc. Recreation 

(USDI FWS 2006).

4. Sales Tax by City (if 

applicable, Tourism tax).

5. AZG&F

6. Headwaters Institute (EPSHDT SE profiles).

7. Visitor surveys.

Q1: Recreation has 

decreased as forest 

restoration 

activities have 

occurred.

Q2: Tourism has 

decreased as forest 

restoration 

activities have 

occurred.

Q3: Tourism 

related 

jobs/housing has 

decreased as forest 

restoration 

activities have 

occurred.

Opportunity for local 

contractors to 

conduct restoration 

work increases.

Q1: Have opportunities 

for local contractors to 

conduct restoration 

work increased? 

Q2: What is the 

proportion of local to 

non-local awards?

Q3: Where are the 

contractors located?

Q1/Q3: Location of 

businesses (zip code 

by county)

Q2: Percentage of 

local contracted 

businesses (contractor 

and subcontractors) 

and total contractual 

amount for each 

(University of Oregon

2011).

Comparative analysis 

of local contract 

awards vs. non-local 

number of contracts 

and respective value).

Every ten years or 

length of the 

contract.

1. Contracts: federal databases

2. USAspending.gov

3. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

Q1: Opportunities 

for local 

contractors to 

conduct restoration 

work has not 

increased.

Q2/Q3: Local 

awards are 

proportionally 

lower than nonlocal awards (# of 

contracts and 

respective value).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

826 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Construction and/or 

improvement of 

infrastructure 

required for forest 

restoration activities 

increase revenues to 

local businesses.

Have revenues to local 

businesses providing 

supplies for 

infrastructure 

increased? 

Revenues of local 

businesses providing 

supplies for 

infrastructure. 

Economic Impact 

Analysis: Track flow 

of economic activity 

associated with 

construction and/or 

improvement of 

infrastructure.

Dependent on timing 

of infrastructure 

development/improv

ement.

1. Contractor reporting 

form/survey. 

2. Local business reporting 

form/survey.

3. U.S. Bureau of Economic 

Analysis (Sitko and Hurteau

2010).

Revenues to local 

businesses 

supporting 

construction and/or 

improvement of 

infrastructure does 

not increase. 

IV. GOAL: The average net cost per acre of treatment and/or prep, administrative costs in the 4FRI project/analysis area are reduced significantly. 

The average net cost 

(operational costs of 

the contract) of 

treatment per acre in 

the 4FRI project area 

over a thirty-year 

period (the life of the 

project) is decreasing 

over time.

Are the average net cost 

of treatment per acre 

that are attached to the 

contract in the 4FRI 

project area decreasing 

as new contracts are 

released and awarded?

Operational cost (per 

acre) attached to the 

contract (D Fleishman 

Personal 

Communication 

2011).

Tracking and 

comparison of 

operational costs of 

contracts.

Every ten years or 

length of the contract.

1. Contracts: federal databases: 

a. USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

The average net 

costs of treatment 

per acre that are 

attached to the 

contract in the 

4FRI project area 

are increasing as 

new contracts are 

released and 

awarded.

The average net cost 

of treatment per acre 

in the analysis area 

for preparation and 

administration costs 

are reduced over 

time.

Q1: What is the 

difference in average net 

cost of treatment per 

acre in the analysis area 

for preparation and 

administrative costs 

associated with different 

restoration designations 

(e.g., description vs. 

prescription)?

Q2: Is average net cost 

of treatment per acre in 

the analysis area for 

preparation and 

administration costs 

reduced over time?

Costs include:

1. Project prep

2.Task order/contract 

administration

3. Planning under 

NEPA/NFMA

4. Project 

management

5. Project-level 

monitoring

6. Contract 

monitoring (4FRI 

Stakeholder Group 

2010c; Sitko and 

Hurteau 2010). 

Q1: Cost effective 

analysis (Robbins and 

Daniels 2011).

Q2: Tracking and 

comparison of prep 

and admin costs of 

contracts.

Every ten years or 

length of the contract.

Southwestern Region 

Restoration Task Group (4FRI 

Stakeholder Group 2010b).

Q1: Various 

restoration 

designation costs 

are not analyzed 

and compared.

Q2: The average 

net cost of 

treatment per acre 

in the analysis area 

for preparation and 

administration 

costs is increasing 

over time.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 827
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Mechanical treatment 

costs are reduced.

* See Rx fire costs

GOAL: Wildfire 

management costs 

are reduced; 

aggressive fire 

suppression is 

unneeded or rare 

(below). 

Are mechanical 

treatment costs 

decreasing over time?

1. Move equipment 

and operators 

2. Cutting

3. Skidding 

4. Delimbing

5. Loading

6. Slash piling

7. Road Maintenance

8. Overhead (4FRI 

Stakeholder Group 

2010c). 

Tracking of 

mechanical costs over 

time.

5 years Contractor surveys. Mechanical 

treatment costs 

increasing over 

time.

V. GOAL: Sufficient harvest and manufacturing capacity exists to achieve restoration of at least 300,000 acres in the next ten years. 

Sufficient contractor 

capability exists to 

harvest approx. 

30,000 acres per 

year. 

Is there sufficient 

contractor capability to 

harvest approx. 30,000 

acres per year? 

1. Total number of 

contracts by work 

type, size and 

distribution (# of task 

orders & 

corresponding acres) 

(Mosley & Davis, 

2010; University of 

Oregon 2011; 4FRI 

Stakeholder Group 

2010c).

2. Financial incentive 

programs (e.g. grants, 

loan guarantees, tax 

incentives) available 

to contractors (4FRI 

Stakeholder Group 

2010c).

1. Track contracts by 

work type, size and 

distribution.

2. Track financial 

incentive programs.

Every ten years or

length of the contract.

1. Contracts, federal databases

a. USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

2. Contractor surveys

3. Headwaters InstitutePayments from federal lands 

(financial incentive programs). 

There is 

insufficient 

contractor 

capability to 

harvest approx. 

30,000 acres per 

year.

Sufficient private 

infrastructure exists 

to utilize woody 

biomass extracted 

from approx. 30,000 

acres per year.

Is there sufficient 

private infrastructure to 

utilize woody biomass 

extracted from approx. 

30,000 acres per year?

1. Volume of material 

produced per biomass 

plant vs. volume 

utilized.

2. Location of private 

infrastructure relative 

to harvesting 

activities.

Track type of 

infrastructure, location 

and corresponding 

processing capability. 

Tracked annually 

across ten years (or 

length of the 

contract).

Contractor surveys. There is 

insufficient private 

infrastructure to 

process woody 

biomass extracted 

from approx. 

30,000 acres per 

year.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

828 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

A sufficient 

workforce (public & 

private) exists to 

harvest and utilize 

wood byproducts 

extracted from 

approx. 30,000 acres 

per year.

Is there a sufficient 

workforce (public & 

private) to harvest and 

utilize wood byproducts 

extracted from approx. 

30,000 acres per year?

1. # of FTE USFS 

employees designated 

for project planning, 

administration, and 

implementation.

2. # of FTE private 

sector employees 

designated for 

harvesting & 

processing.

3. USFS workload 

(dependent on current 

conditions-e.g. shift 

from overgrown 

forest to savannah 

system, shift from 

planning to 

implementation).

4. USFS workforce by 

position.

1. # of FTE USFS 

employees designated 

vs. # of USFS 

employees needed to 

plan/administer/ 

implement 30,000 

acres per year.

2. # of private 

employees trained and 

hired vs. # of 

employees needed to 

harvest/process 30,000 

acres per year.

3. USFS workload vs. 

USFS positions (M. 

Lata Personal 

Communication 2011).

Tracked annually 

across ten years or 

length of the contract.

1. USFS by forest.

2. Headwaters Institute (EPSHDT Socioeconomic profiles).

3. Bureau of Labor Statistics 

(Stynes 1992).

4. Contractor reporting 

form/survey.

There is an 

insufficient 

workforce (public 

& private) to 

harvest and process 

woody biomass 

extracted from 

approx. 30,000 

acres per year.

VI. GOAL: Wildfire management costs are reduced; aggressive fire suppression is unneeded or rare.

Direct wildfire 

suppression costs in 

4FRI treated areas 

are reduced.

Q1: Are direct costs 

associated with wildfire 

suppression in 4FRI 

treated areas decreasing 

as forest restoration 

projects are 

implemented over time?

Q2: What is the 

difference between 

direct wildfire 

suppression costs in 

4FRI treated areas and 

treatment (planning, 

prep, admin & 

operational) costs?

Q1: Wildfire 

Suppression Costs: 

(as above).

Q2: 1. Planning, prep, 

admin costs: (as 

above).

2. Operational Costs: 

(as above). 

Q1: Wildfire 

suppression costs 5 

years post-4FRI 

implementation 

(control for increases 

in population and 

housing) vs. wildfire 

suppression costs 5 

years pre-4FRI 

implementation.

Q2: Wildfire 

suppression costs 5 

years post-4FRI 

implementation vs. 

treatment costs 

(planning, prep, admin 

& operational costs).

5 years Q1: 1. Direct suppression costs 

obtained from: USFS, BLM, 

NRCD, NIFC, State, County, 

FEMA, DHS, Insurance 

companies, American Red Cross 

(Western Forest Leadership 

Coalition 2010).

2. Headwaters Institute (EPSHDT Socioeconomic profiles).

3. USFS budget staff (D. 

Jaworski Personal 

Communication 2011).

Q2: 1. Southwestern Region 

Restoration Task Group (4FRI 

Stakeholder Group 2010c ). 

2. Contractor surveys.

Q1: Direct costs 

associated with 

wildfire 

suppression are 

increasing as forest 

restoration projects 

are implemented 

over time.

Q2: Direct wildfire 

suppression costs 

are higher than 

treatment 

(planning, prep, 

admin & 

operational) costs.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 829
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Short-term (direct) 

rehabilitation costs 

are reduced.

Are short-term (direct) 

rehabilitation costs 

associated with wildfire 

rehabilitation 

decreasing as forest 

restoration projects are 

implemented over time 

(e.g. Burned Area 

Emergency 

Rehabilitation 

(BAER))? 

BAER funds 

appropriated (tracked 

annually) (Western 

Forest Leadership 

Coalition 2010).

BAER expenditures 5 

years post-4FRI 

implementation vs. 

BAER expenditures 5 

years pre-4FRI 

implementation.

5 years (annual 

expenditures)

USFS BAER expenditure 

database (Western Forest 

Leadership Coalition 2010).

Short-term (direct) 

rehabilitation costs 

associated with 

wildfire 

rehabilitation are 

increasing as forest 

restoration projects 

are implemented 

over time.

Wildfire suppression 

frequency and 

duration in 4FRI 

treated areas are 

reduced.

Are wildfire 

suppression efforts in 

4FRI treated areas 

frequency and duration 

decreasing as forest 

restoration projects are 

implemented over time?

1. Frequency of 

wildfires.

2. Duration of 

wildfires.

Frequency and 

duration of wildfires 5 

years post-4FRI 

implementation vs. 

frequency and duration 

of wildfires 5 years 

pre-4FRI 

implementation.

5 years USFS by Forests (Greater 

Flagstaff Forest Partnership

2010).

Wildfire 

suppression efforts 

frequency and 

duration are 

increasing as forest 

restoration projects 

are implemented.

Managed fire 

frequency and 

duration are 

increasing.

Are managed fire 

frequency and duration 

increasing as forest 

restoration projects are 

implemented over time?

1. Frequency of 

managed fires.

2. Duration of 

managed fires.

Frequency and 

duration of managed 

fires 5 years post-4FRI 

implementation vs. 

frequency and duration 

of managed fires 5 

years pre-4FRI 

implementation.

5 years USFS by Forests (Greater 

Flagstaff Forest Partnership

2010).

Managed fire 

frequency and 

duration are 

decreasing as forest 

restoration projects 

are implemented.

Prescribed fire 

frequency and 

duration are reduced.

Are prescribed fire 

frequency and duration 

decreasing as forest 

restoration projects are 

implemented over time?

1. Frequency of 

prescribed fires.

2. Duration of 

prescribed fires.

Frequency and 

duration of prescribed 

fires 10 years post4FRI implementation 

vs. frequency and 

duration of prescribed 

fires 10 years pre-4FRI 

implementation.

10 years USFS by Forests (Greater 

Flagstaff Forest Partnership

2010).

Prescribed fire 

frequency and 

duration are 

increasing as forest 

restoration projects 

are implemented.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

830 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Prescribed fire costs 

are reduced.

Are prescribed fire 

costs decreasing as 

forest restoration 

projects are 

implemented over time?

1. Burn plans

2. Prep work

3. Cutting hand lines”

4. Implement burn

5. Monitor burn (4FRI 

Stakeholder Group 

2011c). 

Costs of prescribed 

fires 10 years post4FRI implementation 

vs. costs of prescribed 

fires 10 years pre-4FRI 

implementation.

10 years USFS budget staff (D. Jaworski 

Personal Communication 2011).

Prescribed fire 

costs are increasing 

as forest restoration 

projects are 

implemented.

Reduce size, and 

frequency of pile 

burns. 

Q1: Is the frequency 

and size of pile burns 

decreasing as forest 

restoration projects are 

implemented over time?

Q2: Is the volume of 

slash that is chipped 

(not burned) 

increasing?

Q1: 1. Frequency of 

pile burns.

2. Size of pile burns.

Q2: Volume of slash 

that is chipped.

Q1: Frequency and 

size of pile burns 10 

years post-4FRI 

implementation vs. 

frequency and size of 

pile burns 10 years 

pre-4FRI 

implementation.

Q2: Volume of slash 

chipped 10 years post4FRI implementation 

vs. volume 10 years 

pre-4FRI 

implementation.

10 years USFS by Forests (Greater 

Flagstaff Forest Partnership

2010).

Size and frequency 

of pile burns is 

increasing and 

volume of slash 

that is chipped is 

decreasing as forest 

restoration projects 

are implemented.

VII. GOAL: There is a sufficient market place for small diameter wood products.

A sufficient market 

exists to consume 

wood biomass 

products.

Is there a sufficient 

market to sell wood 

biomass products?

1. # of businesses and 

type of wood biomass 

material purchased 

(e.g. clean chips, dirty 

chips, roundwood and 

sawtimber) (Sitko and 

Hurteau 2010).

2. Dollar amount 

and/or percent of 

available 

inventory/sales 

businesses purchased.

Economic Impact 

Analysis: include # of 

businesses, type of 

small diameter wood 

material purchased and 

dollar amount and/or 

percent of available 

inventory/sales 

businesses purchased.

5 years Business surveys There is an 

insufficient market 

to sell small 

diameter wood 

products.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 831
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Economic value of 

wood biomass 

products is sufficient 

to profitably process 

small diameter wood 

products.

Does the market value 

of wood products 

exceed production 

costs?

1. Sales ($ value) of 

wood products.

2. Production costs: 

raw materials (wood 

products), hauling, 

petroleum products, 

mill equipment/parts, 

heavy 

equipment/parts, 

electricity, vehicle 

parts/tires, and 

transport equipment 

(Sitko and Hurteau

2010). 

Financial analysis: 

Compare sales of 

wood products to 

production costs.

5 years Business surveys The market value 

of wood products 

does not exceed 

production costs.

Increase the amount 

of wood products 

(wood biomass and 

value-added) that are 

processed locally.

What is the proportion 

of biomass processed 

locally vs. non-local?

1. Number of local 

businesses processing 

small diameter wood 

products.

2. Number of nonlocal businesses 

processing small 

diameter wood 

products.

3. Amount of wood 

(volume) products 

processed locally.

4. Amount of wood 

(volume) products 

processed non-locally 

(Greater Flagstaff 

Forest Partnership

2005).

1. Compare # of local 

vs. non-local 

businesses (percent 

each).

2. Compare local vs. 

non-local business 

volume of wood 

product production 

(percent each). 

5 years 1. Contractor surveys.

2. Contracts, federal databases

a. USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

The proportion of 

biomass processed 

locally is lower 

than biomass 

processed outside 

of the defined local 

area.

Increase the amount 

of wood products 

(wood biomass and 

value-added) that are 

distributed locally.

Q1: Where are the 

wood products 

distributed?

Q2: What is the 

proportion of endproducts distributed 

locally vs. non-local?

Q1: Location of wood 

product distribution.

Q2: Volume/quantity 

of wood products 

distributed locally and 

non-local.

Compare location of 

wood product 

distribution and 

proportion of volume 

of wood products 

distributed locally vs 

non-local.

5 years 1. Contractor surveys.

2. Contracts, federal databases

a. USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

Q1/Q2: The amount 

of wood products 

(small diameter and 

value-added) that are 

distributed locally are 

not increasing.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

832 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

Investment, research 

and development in 

utilization of wood 

biomass are

increasing. 

Is investment, research 

and development in 

utilization of wood 

biomass increasing? 

1. Number of forest 

product industries 

involved in market 

research for small 

diameter wood uses.

2. Amount invested 

by businesses for 

development and 

research.

3. Type and amount 

of market analysis.

4. Number of 

companies applying 

for grants that support 

small diameter market 

research (Greater 

Flagstaff Forest 

Partnership 2005).

Track # involved in 

market research for 

small-diameter wood 

uses, amount invested, 

type and intensity of 

market research, # of 

companies applying 

for grants supporting 

small diameter product 

development.

5 years 1. Contractor/ business surveys.

2. Headwaters Institute 

Investment, 

research and 

development in 

utilization of small 

diameter trees is 

not increasing.

Uses for wood 

biomass and/or 

value-added products 

are expanded and 

diversified. 

Q1: What is the type 

and proportion of the 

production of wood 

biomass end-products?

Q2: Are uses for wood 

biomass and/or valueadded products 

expanding and 

diversifying?

Q1/Q2: Percentage 

production of: Pellets, 

Pallets, Molding, 

Small lumber, 

Biomass-energy, 

Livestock bedding, 

Soil fertilizers, (Sitko 

and Hurteau 2010) 

OSB, Plywood, 

Particle board, 

Fiberboard, 

Roundwood products 

(4FRI Stakeholder 

Group 2010c).

Compare percent of 

production of type of 

wood products and 

track over time.

5 years Contractor/business surveys. Q1/Q2: Uses for 

small diameter 

material and/or 

value-added 

products are not 

expanding and 

diversifying. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 833
Appendix E – Monitoring Plan

Objective 

Monitoring 

Question

Monitoring 

Indicator(s) 

(Metric) Assessment

Frequency of 

Assessment Data Source

Threshold IF... 

(Undesirable 

Conditions)

GOAL: There is a predictable wood supply throughout the life of the 4FRI project.

Ensure the 

availability of forest 

material at a 

sustainable, 

consistent level to 

support appropriate 

forest product 

industries throughout 

the life of the 4FRI 

project. 

Q1: Are the length of 

contracts sufficient to 

recover costs and 

realize return on 

investment?

Q2: Do contracts 

provide the flexibility to 

respond to fluctuating 

markets (e.g. pile and 

burn slash vs. removal) 

& redetermination of 

wood product's value?

Q3: Do contracts 

provide guaranteed 

treatable acres that will 

provide a return on 

investment? 

Q4: Are objections and 

lawsuits for 4FRI 

projects hampering the 

project's progression?

Q1: 1. Length of 

contracts.

2. Operational cost 

incurred to complete 

contracts (as above).

3. Wood yields and 

respective 

value/contract.

4. Number of 

acres/year USFS 

admin planning are 

complete.

Q2: 1. Pile/burn costs

2. Slash removal costs

3. Wood product 

value

Q3: 1. Avg. wood 

yield/ treatable 

acres/contract

2. Operational cost 

incurred to complete 

contracts (as above).

Q4: Number and 

length of time (each) 

of objections and 

lawsuits that are 

delaying the 4FRI 

project's progression.

Q1: Economic Impact 

Analysis:

1. Operational costs 

vs. wood yields and 

respective value.

2. # of acres USFS 

admin/planning are 

complete vs. # of 

acres/contract. 

Q2: Contract analysis 

of:

1. Pile/burn slash costs 

vs. removal costs.

2. Valuation of wood 

products.

Q3: Avg. wood yield 

per treatable 

acres/contract and its 

respective value vs. 

operational costs.

Q4: # & length of time 

of lawsuits; # of 

delayed treatable 

acres, volume and its 

value. 

Ten years or length 

of the contract.

Q1-Q3:

1. Contractor surveys

2. USFS business plans (D. 

Jaworski Personal 

Communication 2011).

3. Contracts: federal databases

a. USAspending.gov

b. USFS Natural Resource 

Manager Database (University 

of Oregon 2011).

4. Headwaters Institute

Q4: Objections database 

available at: 

http://www.fs.fed.us/emc/applit/

(Cortner et. al 2003).

Q1: The contracts 

are not long 

enough to recover 

costs and realize a 

return on 

investment.

Q2: Contracts do 

not provide the 

flexibility to

respond to 

fluctuating markets 

& redetermination 

of wood product's 

value.

Q3: Contracts do 

not provide 

guaranteed 

treatable acres that 

will yield a return 

on investment.

Q4: Objections and 

lawsuits for 4FRI 

projects are 

significantly 

delaying the 

project's 

progression (acres 

treated & 

respective value).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

834 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Acronyms used within Socioeconomics Framework Tables

• AZG&F Arizona Game & Fish Department

• BAER Burned Area Emergency Rehabilitation

• BLM Bureau of Land Management 

• DHS Department of Homeland Security 

• FEMA Federal Emergency Management Agency 

• NEPA National Environmental Protection Act

• NIFC National Interagency Fire Center

• NFMA National Forest Management Act 

• NMFS National Marine Fisheries Service 

• NRCD Natural Resource Conservation Districts

• SRP Salt River Project Power & Water

• SWRRTG Southwestern Region Restoration Task Group

• WMSC White Mountain Stewardship Contract

• USFS United States Forests Service

• FWS United States Fish & Wildlife Service

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 835
Appendix E – Monitoring Plan

Attachment 1. Mexican Spotted Owl Project Monitoring 

Prepared by: Shaula Hedwall, U.S. Fish and Wildlife Service and 

the 4FRI Core Team

As part of the Four Forest Restoration Initiative Project (4FRI), fuels reduction and prescribed 

burning activities will occur within Mexican spotted owl protected activity centers (PACs). By 

definition, PACs are occupied habitat. The effects of treatments to owls and nesting/roosting 

habitat are not fully known. The Mexican spotted owl Recovery Team felt that PACs can be 

afforded substantial protection by emphasizing fuels reduction and forest restoration in 

surrounding areas outside of PACs and nesting and roosting habitat. They also stated that this by 

no means advocates for a “hands-off” approach in PAC habitat, recognizing that in some cases 

protection of PAC habitat requires management actions. Some PACs could benefit from welldesigned treatments. The Mexican spotted owl Recovery Plan, First Revision (USDI FWS 2012) 

provides guidance for these treatments and emphasizes the need for monitoring and feedback 

loops for adaptive management. Well-designed monitoring could provide valuable information on 

the effects of activities on owls and their habitat. In the long-term, properly designed treatments 

are known to create habitat conditions that are recognized as not only improving nesting and 

foraging opportunities, but also reducing the risk of habitat loss to unmanaged wildfires. 

However, in order to understand the short-term effects of thinning and burning on Mexican 

spotted owls and their habitat, the Forest Service (FS) and the U.S. Fish and Wildlife Service 

(FWS) worked together to develop a monitoring plan that focuses on the years immediately 

before, during and after treatment. 

During project analysis, the FS and the U.S. Fish and Wildlife Service collaboratively reviewed 

117 PACs in the general 4FRI area. Forest conditions were individually evaluated within each 

PAC in terms of their potential to support resident Mexican spotted owls and their prey. PAC 

assessments included dominant forest type (e.g., pine-oak, mixed conifer), habitat structure, 

available demographic data (based on ongoing occupancy surveys or past research), topographic 

attributes (e.g., aspect and slope), human access, designated wilderness boundaries, recent and 

ongoing projects affecting PAC habitat, fire history, status of current habitat and, ultimately, 

whether mechanical treatments could potentially move the forest towards desired conditions 

described in the Recovery Plan. It was agreed that no mechanical treatments would occur in core 

areas.

Once the status of each PAC was determined, potential mechanical treatments were considered in 

terms of whether they could: 

3. Decrease the amount of time needed to increase tree height and diameter; 

4. Decrease overall tree density while maintaining overall canopy cover, and 

5. Reduce the threat of surface fires becoming crown fires and increase canopy base height to 

improve flight zone (i.e., improve owl foraging ability). 

PACs were not considered for treatment if they were treated in previous projects (n = 32), habitat 

was not suitable for 4FRI treatments (PACs occurred in habitats outside the scope of 4FRI such as 

mixed conifer, designated wilderness, or canyon habitat; n = 20), habitat had been previously 

burned (n = 10), habitat conditions inside PACs were such that treatment was not necessary (n = 

11), the balance of conditions inside and outside PACs were such that treating outside the PACs 

would be adequate and active management would not be necessary inside the PACs (n = 24), or 

there simply was not enough information available to identify a need for treatment (n = 2). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

836 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Because historical fire return intervals have not been met across most of this landscape, 

prescribed fire was recommended for all PACs, including a recommendation for using prescribed 

fire in core areas. 

Ultimately, we concluded that 99 of the 117 PACs assessed did not need mechanical treatments. 

Most of the remaining 18 PACs selected for mechanical treatment are not only believed to have 

among the lowest quality habitat (in terms of number/density of large trees, canopy cover and 

other predictors of owl nesting and roosting sites), but also have the greatest potential for longterm improvement if mechanical treatments are implemented. 

The U.S. Fish and Wildlife Service and the FS completed field reconnaissance of a subset of 

PACs chosen for treatments (see the 4FRI Wildlife Specialist Report for more detail). The U.S. 

Fish and Wildlife Service also reviewed field observations for most of the other PACs proposed 

for both mechanical thinning and prescribed fire. Vegetation simulation modeling was done to 

develop potential treatments tailored to individual stand conditions within each PAC. Modeling 

indicated mechanical treatments could move 10,741 of 35,566 acres (31 percent of total PAC 

acres) onto a trajectory that better meets the above criteria for habitat within the 18 PACs (see the 

4FRI Silviculture report).

While existing occupancy data for these 18 PACs is not comprehensive, there is strong evidence 

from other PACs supporting the assertion that occupancy rate declines as habitat quality declines. 

In other words, some of the PACs with low habitat quality are likely to be only intermittently 

occupied, if at all. There is an acknowledged risk that measuring the effects of treatment on 

Mexican spotted owl PACs of marginal quality may be confounded by intermittent occupancy 

prior to treatment. A short-term absence of occupancy post-treatment could be indistinguishable 

from pre-treatment use if occupancy was originally intermittent. It is, nevertheless, valuable to 

monitor short-term impacts of treatments in low quality habitat as these are the areas in greatest 

need of treatment. Additionally, the results may be leveraged with those of other related 

monitoring efforts to better describe broader trends and there is potential that this effort could setup long-term monitoring efforts that better address changes to forest structure and the resulting 

effects to Mexican spotted owls. 

The proposed monitoring plan would pair treated and reference PACs within the project area to 

compare occupancy, reproductive success, and habitat changes. There will be two groups of study 

PACs. The first group will consist of PACs receiving thinning and burning treatments and 

corresponding paired reference PACs (Group 1) and the second group of PACs will consist of 

PACs receiving prescribed fire-only treatments and their corresponding paired reference PACs 

(Group 2). Criteria for pairing selected treatment and reference PACs will include the following:

• Both treatment and reference PACs must be currently occupied by a pair of spotted owls. It is 

recognized that this may be problematic due to the potential for inconsistent occupancy in 

some of the PACs.

• Both treatment and reference PACs should consist of similar habitat (e.g., percentage of pineoak, etc.).

• Both treatment and reference PACs should have similar environmental conditions (e.g., fire 

history, management history, etc.). 

• Treatment and reference PACs should not have other confounding factors (e.g., heavy 

recreation, multiple land managers, etc.) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 837
Appendix E – Monitoring Plan

• Treatments in selected PACs should ideally occur across the majority of their spatial extent to 

maximize the ability to detect cause and effect.

• Reference PACS may come from a pool of PACs including those not proposed for any 

treatment or PACs where treatment has been deferred in order to maintain an “untreated” 

condition during the monitoring period. In order to achieve maximum similarity, reference 

PACs may also be selected from PACs outside of the 4FRI project area.

• PACs may be stratified by treatment type, year of treatment, etc.

Guiding Question:

• How do planned thinning and fire treatments affect habitat in the short-term and do the 

resulting changes affect short-term occupancy and reproductive success in treated versus 

untreated PACs? 

Identified Response Variables: 

• Owl occupancy (the percent of PACs occupied before and after treatments). 

• Owl reproductive success (ideally the number of fledglings observed per adequately checked 

pair before and after treatments).

• Habitat change (post-treatment changes for key variables selected from Table C.2 (USDI 

FWS 2012, pp. 276-277) showing description of desired conditions [DCs]) in forest cover 

types typically used by Mexican spotted owls for nesting and roosting. 

Planned Treatments:

• Treatments will likely be variable in spatial extent and intensity (intensity measured by 

degree of change in key habitat variables related to desired conditions [see Table C.1]). 

General Study Design Approach:

• Monitoring will contrast a set of reference PACs to a set of treatment PACs for each PAC 

treatment group. As stated above, reference PACs will match the environmental conditions as 

closely as possible in PACs where treatments are proposed. Treatment PACs will be 

prioritized for management actions soon after the initiation of the 4FRI. If reference PACs are 

selected from PACs with assigned treatments, then those treatments will not occur for at least 

5 years. 

♦ Group 1 PACs are proposed to have both thinning and prescribed fire treatments and will 

be drawn from those PACs listed in Table 5 of the biological opinion or as described 

above. Three treatment PACs and 3 paired reference PACs will be selected for Group 1 

comparisons. Final treatment PACs and reference PACs will be collaboratively identified 

by the FS and U.S. Fish and Wildlife Service after occupancy is determined. 

♦ Group 2 PACs are proposed to have prescribed fire-only treatments and will be drawn 

from those listed in Table 6 of the biological opinion or as described above. Three 

treatment PACs and 3 paired reference PACs will be selected for Group 2 comparisons. 

Final treatment PACs and reference PACs will be collaboratively identified by the FS and 

U.S. Fish and Wildlife Service after occupancy is determined. 

• Surveys for occupancy and reproductive success will be conducted for at least 2 seasons 

before treatment.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

838 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

• Surveys for occupancy and reproductive success will also be conducted in consecutive years 

post-treatment starting with the year of mechanical treatment and continuing until 2 years 

post-prescribed fire treatments. We expect this will total at least 5-6 years of surveys per PAC 

requiring 3-6 visits per PAC per year.

• Vegetation data will be collected prior to treatment, then 1 year post-mechanical treatment 

and 2 years post-fire treatment for a total of 3 visits per PAC.

• Vegetation and spotted owl survey protocols will remain consistent across treatments groups 

and throughout the monitoring period. Combined, this effort could require anywhere from 

300 to about 550 PAC visits. 

Sampling Considerations:

• Sample response variables have been selected to allow estimation of the short-term effects of 

treatment on occupancy, reproductive success, and habitat desired conditions. 

• Mexican spotted owl data will come from standard survey protocols and should ideally yield 

determinations of occupancy and reproductive success 

• Vegetation data will come from nested variable radius and fixed plot surveys, large diameter 

woody debris transects and spatial analysis of 1-meter resolution aerial photography. These 

methods should yield measures of tree species diversity, basal area, large tree frequency 

(more than 12 inches and more than 18inches d.b.h.), canopy cover and horizontal structural 

diversity. We have a protocol developed for monitoring conducted on the Flagstaff Watershed 

Protection Project with U.S. Fish and Wildlife Service and ERI that could be used or 

modified. 

Potential Analytic Approaches:

• Simple treatment effect stratified by treatment type and geographic area/cover type. Twosample tests, ANOVA, regression-based approaches, power dependent on sample size and 

variability.

• Subsequent analyses only if treatment effects are apparent – gradient analysis, AIC based 

model selection if sample size permits use of treatment /habitat covariates.

Quality Control / Assurance

• The monitoring plan is a result of agreements reached with the U.S. Fish and Wildlife Service 

during the consultation process for the 4FRI. 

• FS and U.S. Fish and Wildlife Service will coordinate and plan monitoring work 

cooperatively 

• A written annual report with survey results will be submitted to U.S. Fish and Wildlife 

Service

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 839
Appendix E – Monitoring Plan

Attachment 2. Arizona Bugbane Administrative Study: Fire 

Effects 

The FS is collaborating with the U.S. Fish and Wildlife Service to finalize a strategy to monitor 

the impacts of prescribed fire on Arizona bugbane. 

Introduction 

Arizona bugbane is endemic to northern and central Arizona. It requires shade from forest or 

riparian overstory. Arizona bugbane is known to occur in mesic habitats, typically along the 

bottoms and lower slopes of steep, narrow canyons, where the overstory often includes a 

combination of coniferous and deciduous tree species. Important overstory species include 

Douglas fir (Pseudotsuga menziesii), white fir (Abies concolor), big tooth maple (Acer saccharum 

ssp. grandidentatum), Arizona alder (Alnus oblongifolia) and red osier dogwood (Cornus 

stolonifera). 

Preliminary modelling data for Arizona bugbane indicates that it occurs primarily on a certain soil 

type, soil unit 555. This unit is composed of colluvium material and formed from sandstone and 

limestone. It tends to occupy a northern aspect, which provides cooler and moister conditions and 

has a severe erosion hazard. The dominant plant communities are composed of ponderosa pine 

and mixed conifer with Gambel oak and various shrubs. Within our area of interest, Arizona 

bugbane also occurs on soil unit 549, which is a colluvium soil of cherty bedrock. Here, the 

dominant overstory species include ponderosa pine and gambel oak (USDA Forest Service, 

1995). 

Arizona Bugbane and Fire

Arizona bugbane often grows in rocky areas with poor soil where surface fuel may be 

discontinuous in and/or around the populations. Current knowledge of fire effects on Arizona 

bugbane is based largely on observations from two local wildfires: the Fry Fire in 2003, and the 

Slide Fire in 2014, both on the Coconino National Forest (Crisp et al. 2004, 2014 personal 

observation). The Fry Fire covered 180 acres of upland and canyon habitats in Fry Canyon and 

was of mixed severity. The highest severity fire effects in areas with individual Arizona bugbane 

plants initially included loss of the above ground portions. On a subsequent visit in 2004, some 

Arizona bugbane plants were observed resprouting along the fire line near the canyon bottom, 

including in some severely burned areas. Observers noted a variety of plant sizes and ages, 

ranging from immature plants to adults with mature fruits. An adult plant with fruits and 

blackened soil at the base is shown in (figure 69). The lower portion of the canyon supports 

mixed-conifer forest and is more mesic than the upland ponderosa pine forest along the rim of the 

canyon. Arizona bugbane populations were informally monitored again in 2005 and 2010, and 

plants were persisting and thriving. Although quantitative data has not yet been compiled from 

the Slide Fire, similar effects immediately post-fire were observed in most affected populations 

(figure 69 and figure 70). As such, it is possible that Arizona bugbane may be adapted to fire, 

although the historic fire frequency in areas where it is found may be less than in the surrounding 

vegetated areas.

A literature search did not return any published data for fire effects to Arizona bugbane. However, 

based on taxonomic information for the genus Cimicifuga in the Flora of North America, 

members of the genus Cimicifuga have long-lived perennial rhizomes (see Vol. 3 page 177) that 

would persist after the top portions of the plants senesces in the fall. This allows the plants to 

regenerate from the underground rhizomes when conditions are favorable in the spring. Pyke et 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

840 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

al. (2010) addressed the persistence of plants after wildfires using several traits including life 

form. Perennial species such as bugbane are categorized as cryptophtyes (see table 1 of article). 

Plants with this life form are generally one of the most protected from death during fire because 

the soil insulates the underground portions of the plants. In these cases, the top portions of the 

plant may be killed, but the underground structures, such as rhizomes, are able to persist (Pyke et 

al. 2010). 

A related species in the same genus, Actaea rubra, has been studied in the Northwestern US. Data 

are available on the Fire Effects Information System website (Crane 1990). In that species, the 

tops of plants are removed by fire and then plants regenerate from thick underground caudices, 

but seedlings did not appear for several years post-fire.

Figure 69. Arizona bugbane plants near the fire line on Fry Fire September 2004

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 841
Appendix E – Monitoring Plan

Figure 70. Arizona bugbane sprouting from roots about a month after the Slide 

Fire burned though this population

Given the frequency of fire in the areas surrounding the populations (figure 71) it seems unlikely 

that it would not have some adaptations. Even if separated from the frequent fire areas, there 

would be years when embers would spot near or in populations, an occurrence that is more likely 

in dry years, or between the end of the spring precipitation and the onset of monsoons. 

Historic and recent Fire 

Over a 25 year period, the majority of natural ignitions within an area of approximately 55,000 

acres around known populations of Arizona bugbane occurred from May to September (table 

152). Yet in order to help maintain control, prescribed fires are typically implemented before May 

or after mid-September. It is possible that implementing prescribed fire at these times may 

produce stress on bugbane, because the plant’s adaptations are likely related to fires occurring 

during this peak period. The Fry Fire and the Slide Fire are known to have burned into an Arizona 

bugbane population between May and September. 

There is an unnaturally high surface fuel buildup in areas surrounding these populations and 

possibly within them as well. Although we do not know the details of its fire adaptations, there 

are concerns about the potential for unnaturally high severity fire effects in and around bugbane 

populations. Therefore, it seems advisable, based on the limited information available, to use 

prescribed fire in a manner that seems most likely to benefit the species and to document the 

effects for informing future management actions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

842 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Table 152. Number of ignitions by month over a 25-Year period within the area shown in figure 71

January February March April May June

0 0 1 1 12 30

July August September October November December

146 106 39 17 1 0 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 843
Appendix E – Monitoring Plan

Figure 71. Arizona bugbane populations are shown in orange. Lightning fires locations are shown as: Yellow = January through April; Pink = May 

through September; Blue = October through December. 2) Perimeters of lightning fires that grew to 10 acres or larger are in green.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

844 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Study Design 

To address concerns over the potential fire effects to Arizona bugbane, we are proposing to 

incorporate into the 4FRI analysis a prescribed burning and monitoring project for population sites in 

the Upper West Fork area that are currently proposed for treatment. The burning and monitoring 

project may be carried out as part of this analysis or as a separate administrative study. 

Pre-and post-monitoring would occur across multiple Arizona bugbane populations. Areas outside of 

the 4FRI analysis area may be used for controls or treatment after consultation with district personnel. 

All activities would be subject to limitations such as human safety, timing restrictions as they apply to 

Mexican spotted owl nesting seasons, burn windows, wilderness considerations, etc. 

As part of 4FRI implementation, prescribed burning may occur in or near some populations of 

Arizona bugbane. Direct effects to Arizona bugbane could include death or top killing of individual 

plants, or parts of plants. Indirect effects may come from the decreased shade from decreased canopy 

cover if trees or portions of tree crowns are killed in the surrounding area; increased sprouting and/or 

flowering resulting from the post-fire nutrient pulse and decreased litter cover; increased seedling 

establishment from increased area of exposed mineral soil; or other more complex effects resulting 

from changes to surface albedo, precipitation reaching the soil, decreased competition, and/or other 

changes resulting from the fire and the antecedent conditions. Under the current NEPA analysis, 

mitigations would include managing prescribed fires to keep severity low in and near the bugbane. 

This monitoring/burning project was designed by Fire Ecologist, Mary Lata and Forest Botanist, 

Debra Crisp. We would coordinate with the U.S. Fish and Wildlife Service and a fire specialist in the 

selection of sites in the West Fork Area for study. 

The proposed study area consists of stands within the Upper West Fork Mexican spotted owl PAC 

(figure 72 and table 156). No bugbane test burning would occur in the core area. The Recovery Plan 

(USDI FWS 2012) does not recommend burning in Mexican spotted owl PACs during the breeding 

season (March 1 to August 31) except when non-breeding is confirmed or inferred that year. The area 

would be surveyed for Mexican spotted owl before implementation of the raking and burning 

treatments to determine reproductive status of Mexican spotted owl in the PAC. 

Table 153. Arizona bugbane locations and sites in the Upper West Fork PAC

Restoration subunit Date Collected Location Site Alternative C 

3-5 9/12/2012 167 33 Burn Only

3-5 9/12/2012 167 34 Burn Only

3-5 9/12/2012 176 3 Burn Only

3-5 9/1/1980 176 7 Burn Only

3-5 9/12/2012 176 10 Burn Only

The study would include 2 to 3 different treatments as follows: 

1. Control (a population with characteristics and location as similar as possible to the one being 

treated, or a portion of a single large population if treated and untreated areas can be separated by 

at least 50 meters): The control area would not be burned although, as stated above, it would 

receive whatever mechanical treatments have been prescribed for the area, and would serve as a 

comparison for the other two treatments. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 845
Appendix E – Monitoring Plan

2. Prescribed fire (as stated above, this area would be at least 50 meters from a control, or as similar 

as possible to a control): This area would be subjected to a burning treatment as proposed for the 

location/site and already incorporated in this alternative. Fire within and adjacent to the bugbane 

population would be managed to produce only low severity effects. 

3. Partial raking with no burning (a portion of the control population): The intent of this treatment is 

to mimic historical levels of litter and duff under characteristic fire levels without necessarily 

using fire as a treatment. It would be included in the design if there are sufficient populations or 

they are sufficiently large to accommodate additional treatments. If historically, these areas 

burned periodically, even if it was a lower frequency than surrounding areas (there are no sitespecific, definitive data for fire frequency in Bugbane populations) it is likely that there would 

normally have been less litter and duff than is currently observed. 

Fireline would be created as needed to aid in administering consistent fire treatments. Individual 

treatments including controls would be separated by at least 50 meters to minimize the risk of effects 

from adjacent controls. 

The preferred time for conducting burn treatments would be between May and August, when fire 

would have been historically expected to burn in this area. However, since most areas containing 

bugbane are near or adjacent to Mexican spotted owl habitat, timing restrictions for Mexican spotted 

owl may take precedence over the burning treatment and a fall burn would be implemented. A fall 

burn would be expected to be less harmful than a spring burn because individual plants would have 

had the preceding growing season to produce and store energy. In addition, plants are emerging in the 

spring and allocating stored energy to growth and reproduction. Raking (if used) and fire line 

construction (if needed) would occur immediately prior to the ignition of fire to assure that there is no 

effect from timing of the raking or the fireline construction. The area to be burned will be on the 

downhill side (if there is a slope) in order to prevent overland flow from carrying nutrients from the 

burned area into one of the non-burned areas, potentially biasing results. 

Unless safety concerns preempt it, the fire would be monitored during ignition and burning to 

document fire behavior (rate of spread, flame depth) as it burned through the bugbane. Scorch would 

be kept to less than five feet in and adjacent to bugbane populations. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

846 Coconino and Kaibab National Forests 
Appendix E – Monitoring Plan

Figure 72. Map of the treatment areas. Arizona bugbane is shown in black. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 847
Appendix E – Monitoring Plan

Design Features

1. Implementation will require coordination between the Forest Botanist, District Wildlife 

Biologists, Fuels, Fire Ecologist and Wildlife Biologist, and the U.S. Fish and Wildlife 

Service. 

2. If Mexican spotted owl associated with the Upper West Fork PAC are determined to be nonnesting or are absent based on protocol surveys in zones selected for burning treatments, we 

would likely burn between May and August. If Mexican spotted owl are nesting, then the 

burn would occur in the late/summer or fall. 

3. Three or more replicates are needed. Areas outside of the current 4FRI analysis area can be 

considered for use as controls and possibly for burning. Consultation with district personnel 

should occur before treatment areas outside of 4FRI are selected.

Pre-treatment Data 

The following data would be collected before burning occurred. The data should be collected less 

than two weeks prior to treatment, but as close to the implementation of the burn as possible. Fuel 

moisture data must be collected within a few days of implementation, and not before a 

precipitation event preceding the fire. 

Data to be Collected

Collection of the plant data one year prior to the implementation of the treatment, within one 

week of the date of implementation one year after treatment and then three years after treatment. 

For example, if the prescribed fire is implemented on September 1st, data would be collected 

between August 25th and September 7th in years one and three following the burn. 

1. Stems per area. Individual stems will be counted as opposed to clumps of plants to avoid the 

need to determine underground connectivity of the plants. The intent of this metric is to 

document changes in plant vigor by measuring changes in the number of stems per area 

2. Spatial area occupied by the sample population. The intent of this metric is to document the 

expansion or contraction of the population over time. 

3. Evidence of other activities at the site such as grazing by wildlife and/or livestock, recreation, 

etc. 

4. Evidence of past natural events such as flooding, storm damage, insect mortality in the 

overstory, etc. 

5. Canopy/shading including abiotic structures such as cliffs that may be providing shade to the 

bugbane groups being treated. We anticipate that canopy cover would be measured by a 

spherical densiometer or a similarly appropriate tool. The same type of instrumentation 

should be used for each visit and, if possible, the same person/s should collect the data each 

year since the sample size is small and the collection of this type of data is likely to vary 

significantly between surveyors. 

6. Soil type should be recorded for each site (figure 73). 

7. These data should be collected for populations in each treatment (untreated, raking and 

burning). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 848
Appendix E – Monitoring Plan

Figure 73. Map showing soil units in Arizona bugbane areas to be treated

Fire/fuels 

1. Surface fuel loading (litter, duff, downed woody material (pre and post)). This will be 

determined by establishing a Brown’s fuel transect. 

2. Exposed mineral soil (pre and post) 

3. Timing of fire (month/week/day) 

4. Fuel moisture (particularly litter and duff)

5. Rate of spread, flaming depth (used to determine residence time)

6. Fire weather at the site.

7. Precipitation on the site, gathered from the nearest reliable source.

Brown’s lines should be read at each visit to the treatment population (untreated, raking, and 

burning), along with exposed mineral soil. Recent deadfall and tree mortality rates should also be 

recorded. 

Weather

Weather data for the date of collection and the season prior should be noted in order to consider 

the effects of weather on plant growth at the treatment sites. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 849
Appendix E – Monitoring Plan

Reporting

Data sheets will be prepared and data recorded in a standard manner on each visit to assure data 

consistency. Data sheets and field notes will be entered electronically into the 2670 Arizona 

bugbane file in an area established and designated for the monitoring/study. Data will also be 

shared with the U.S. Fish and Wildlife Service, 4FRI monitoring coordinator and other interested 

parties.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

850 Coconino and Kaibab National Forests
Appendix E – Monitoring Plan

Attachment 3. Alternatives B through E Springs, Channel and Road Adaptive Management 

Actions

Table 154. Selected alternative springs, channels, and roads adaptive management actions

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Roads and 

unauthorized 

routes located in 

upland (nonmeadow) and in 

meadows

Soils are in satisfactory 

condition so that soil can 

resist erosion, recycle 

nutrients, and absorb 

water. Understory species 

(grasses, forbs, and 

shrubs) diversity is 

consistent with site 

potential and provides for 

infiltration of water and 

reduction of accelerated 

erosion. The understory 

has a variety of heights of 

cool and warm season 

vegetation.

Up to 904 miles of 

road/route are in 

unsatisfactory soil 

condition due to 

accelerated erosion, 

lack of effective 

ground cover, and 

compaction.

1.Reestablish former drainage 

patterns, stabilize slopes, and 

restore vegetation;

2.Block the entrance to a road 

or install water bars;

3.Remove culverts, reestablish 

drainages, remove unstable 

fills, pull back road shoulders, 

and scatter slash on the 

roadbed;

4.Eliminate the roadbed by 

restoring natural contours and 

slopes; and

5.Other methods designed to 

meet the specific conditions 

associated with the unneeded

road.

• Miles of road 

treated

• Soil condition 

assessment

Soil condition is 

impaired or 

unsatisfactory as 

defined in a soil 

condition assessment. 

Time is 5 years after 

treatment.

• Additional drainage

• Additional 

revegetation efforts 

(including 

mulching)

• Short-term fencing 

to protect 

revegetation

• Complete removal 

of roadbed

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 851
Appendix E – Monitoring Plan

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Roads and 

unauthorized 

routes located in 

the filter strips of 

identified riparian 

and nonriparian 

stream courses

Soils are in satisfactory 

condition so that the soil 

can resist erosion, recycle 

nutrients, and absorb 

water.

Understory species (e.g., 

grasses, forbs, and shrubs) 

diversity is consistent with 

site potential and provides 

for infiltration of water 

and reduction of 

accelerated erosion. The 

understory has a variety of 

heights of cool and warm 

season vegetation.

All roads are in 

unsatisfactory soil 

condition due to 

accelerated erosion, 

lack of effective 

ground cover, and 

compaction.

1.Reestablish former drainage 

patterns, stabilize slopes, and 

restore vegetation;

2.Block the entrance to a road 

or install water bars;

3.Remove culverts, reestablish 

drainages, remove unstable 

fills, pull back road shoulders, 

and scatter slash on the 

roadbed;

4.Eliminate the roadbed by 

restoring natural contours and 

slopes; and

5.Other methods designed to 

meet the specific conditions 

associated with the unneeded 

road.

• Miles of road 

treated

• Soil condition 

assessment

Soil condition is 

impaired or 

unsatisfactory as 

defined in the soil 

condition assessment. 

Time is 5 years after 

treatment.

• Additional drainage

• Additional 

revegetation efforts 

(including 

mulching)

• Short-term fencing 

to protect 

revegetation

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

852 Coconino and Kaibab National Forests
Appendix E – Monitoring Plan

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Undeveloped 

spring in a 

forested setting.

Vegetation and 

soils range from 

satisfactory 

condition 

(waterflow is 

occurring) to 

vegetation/ soils 

are below 

potential or are 

impaired/ 

unsatisfactory 

(there is no 

evidence of 

waterflow from 

spring).

Springs and associated 

streams and wetlands have 

the necessary soil, water, 

and vegetation attributes to 

be healthy and functioning 

at or near potential. 

Waterflow patterns, 

recharge rates, and 

geochemistry are similar 

to historic levels and 

persist over time. Water 

quality and quantity 

maintain native aquatic 

and riparian habitat and 

water for wildlife and 

designated beneficial uses, 

consistent with water 

rights and site capability. 

Plant distribution and 

occurrence are resilient to 

natural disturbances. Soils 

are in satisfactory

condition.

Undeveloped 

springs occur on 

both forests in a 

forested setting. 

Note: Of the total 

number of springs, 

there are six springs 

on the Coconino NF 

that are located in 

forested areas, but 

the status of 

development is 

unknown.

If vegetation/soils are 

satisfactory options include:

• Remove tree canopy to presettlement condition within 2–

5 chains of the spring;

• Apply for water right if none 

exists;

• Prescribe burn, or

• No action.

If vegetation/soils are below 

potential or are 

impaired/unsatisfactory options 

include:

• Remove tree canopy to presettlement condition within 2–

5 chains of the spring;

• Apply for water right if none 

exists;

• Remove noxious weeds;

• Prescribe burn; or

• Identify stressor and provide 

protection measure for the 

stressor (fence, jackstraw, 

remove/relocate road/trail 

etc.) and/or

• Other methods designed to 

meet the desired conditions.

Properly 

functioning 

condition (PFC), 

Museum of 

Northern Arizona 

level 1 

monitoring, 

waterflow 

(possible new 

direction for 

spring monitoring 

from FS), photo 

points

Drop in proper 

functioning condition

class, monitoring 

displays a dropping 

trend.

Monitoring every 1–10 

years

• ID stressor, protect 

from stressor (fence/ 

jackstraw, close 

road, relocated road, 

etc.)

• No action

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 853
Appendix E – Monitoring Plan

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Developed springs 

in a forested 

setting.

Vegetation and 

soils range from 

satisfactory 

condition 

(waterflow is 

occurring) to 

vegetation/ soils 

are below 

potential or are 

impaired/ 

unsatisfactory 

(there is no 

evidence of 

waterflow from 

spring).

Springs and associated 

streams and wetlands have 

the necessary soil, water, 

and vegetation attributes to 

be healthy and functioning 

at or near potential. 

Waterflow patterns, 

recharge rates, and 

geochemistry are similar 

to historic levels and 

persist over time. Water 

quality and quantity 

maintain native aquatic 

and riparian habitat and 

water for wildlife and 

designated beneficial uses, 

consistent with water 

rights and site capability. 

Plant distribution and 

occurrence are resilient to 

natural disturbances. Soils 

are in satisfactory 

condition.

There are 26 springs 

on the Kaibab NF 

that are located in 

forested areas and 

the status of 

development is 

unknown.

There are 40 

developed springs 

on the Coconino NF 

that are located in 

forested areas.

There are six springs 

on the Coconino NF 

that are located in 

forested areas and 

the status of 

development is 

unknown.

Negotiate with holders of water 

rights that are non-Forest 

Service at Alto, Chimney, 

Dairy, Double, Garden, 

Griffiths, Howard, Little Elden, 

Lower Hull, Mud, Pat, Sawmill, 

Seven Anchor, and Upper Hill 

Springs on the Coconino 

National Forest and springs on 

the Kaibab NF to explore the 

possibility of releasing water 

above their water right for 

riparian conditions.

If vegetation/soils are below 

potential or are 

impaired/unsatisfactory:

• Remove tree canopy to presettlement condition within 2–

5 chains of the spring,

• Prescribe burn,

• Remove existing water right 

(see list above) to expand 

current riparian conditions,

• Identify stressor and provide 

protection measure for the 

stressor (fence, jackstraw, 

remove/relocate road/trail 

etc.), and/or

• Apply other methods designed 

to meet the desired conditions.

proper 

functioning 

condition, 

Museum of 

Northern Arizona 

level 1 

monitoring, 

waterflow 

(possible new 

direction for 

spring monitoring 

from FS), photo 

points

Drop in proper 

functioning condition 

class, monitoring 

displays a dropping 

trend. Monitoring every 

1–10 years

• ID stressor, protect 

from stressor (fence/ 

jackstraw, close 

road, relocated road, 

etc.)

• No action

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

854 Coconino and Kaibab National Forests
Appendix E – Monitoring Plan

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Undeveloped 

spring in a 

meadow setting.

Vegetation and 

soils range from 

satisfactory 

condition 

(waterflow is 

occurring) to 

vegetation/ soils 

are below 

potential or are 

impaired/ 

unsatisfactory 

(there is no 

evidence of 

waterflow from 

spring).

Springs and associated 

streams and wetlands have 

the necessary soil, water, 

and vegetation attributes to 

be healthy and functioning 

at or near potential. 

Waterflow patterns, 

recharge rates, and 

geochemistry are similar 

to historic levels and 

persist over time. Water 

quality and quantity 

maintain native aquatic 

and riparian habitat and 

water for wildlife and 

designated beneficial uses, 

consistent with water 

rights and site capability. 

Plant distribution and 

occurrence are resilient to 

natural disturbances. Soils 

are in satisfactory 

condition.

Springs occur on the 

two national forests 

that are not 

developed and occur 

in a meadow setting. 

There is one spring 

on the Coconino NF 

(Scott Spring) that is 

located in meadow 

areas, but the status 

of development is 

unknown. There is 

one spring on the 

Kaibab NF that is 

located in meadow 

areas, but the status 

of development is 

unknown.

If vegetation/soils are 

satisfactory:

• Apply for water right if none 

exists,

• Prescribe burn, and/or

• Take no action.

If vegetation/soils are below 

potential or are 

impaired/unsatisfactory:

• Apply for water right if none 

exists,

• Remove noxious weeds,

• Prescribe burn,

• Identify stressor and provide 

protection measure for the 

stressor (fence, jackstraw, 

remove/relocate road/trail 

etc.), and/or select

• Other methods designed to 

meet the desired conditions.

proper 

functioning 

condition, 

Museum of 

Northern Arizona 

level 1 

monitoring, 

waterflow 

(possible new 

direction for 

spring monitoring 

from FS), photo 

points

Drop in proper 

functioning condition 

class, monitoring 

displays a dropping 

trend. Monitoring every 

1–10 years

• ID stressor, protect 

from stressor (fence/ 

jackstraw, close 

road, relocate road, 

etc.)

• No action

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 855
Appendix E – Monitoring Plan

Evaluation 

Criteria

Desired Condition Existing Condition Possible Management 

Actions*

Monitoring 

Measure

Trigger Indicating 

Additional Action is 

Needed (What/When)

Adaptive Options*

Developed spring 

in a meadow 

setting.

Vegetation and 

soils range from 

satisfactory 

condition 

(waterflow is 

occurring) to 

vegetation/ soils 

are below 

potential or are 

impaired/ 

unsatisfactory 

(there is no 

evidence of 

waterflow from 

spring).

Springs and associated 

streams and wetlands have 

the necessary soil, water, 

and vegetation attributes to 

be healthy and functioning 

at or near potential. 

Waterflow patterns, 

recharge rates, and 

geochemistry are similar 

to historic levels and 

persist over time. Water 

quality and quantity 

maintain native aquatic 

and riparian habitat and 

water for wildlife and 

designated beneficial uses, 

consistent with water 

rights and site capability. 

Plant distribution and 

occurrence are resilient to 

natural disturbances. Soils 

are in satisfactory 

condition.

Springs occur on the 

two national forests 

that are developed 

and occur in a 

meadow setting. 

There are four 

springs on the 

Coconino NF that 

are located in 

meadow areas and 

are developed.

If vegetation/soils are 

satisfactory:

• Prescribe burn,

• Re-plumb spring to allow for 

water above existing water 

right to be released to expand 

current riparian conditions, 

and /or

• Other methods designed to 

meet the specific conditions 

associated.

If vegetation/soils are below 

potential or are 

impaired/unsatisfactory:

• Prescribe burn,

• Remove noxious weeds,

• Re-plumb spring to allow for 

water above existing water 

right to be released to expand 

current riparian conditions,

• Identify stressor and provide 

protection measure for the 

stressor (fence, jackstraw, 

remove/relocate road/trail 

etc.), and/or

• Other methods designed to 

meet the desired conditions.

proper 

functioning 

condition, 

Museum of 

Northern Arizona 

level 1 

monitoring,

waterflow 

(possible new 

direction for 

spring monitoring 

from FS), photo 

points

Drop in proper 

functioning condition 

class, monitoring 

displays a dropping 

trend. Monitoring every 

1–10 years

• ID stressor, protect 

from stressor (fence/ 

jackstraw, close 

road, relocated road, 

etc.)

• No action

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

856 Coconino and Kaibab National Forests
Appendix F – Cumulative Effects

In response to comments on the DEIS, this appendix has been updated to clarify how this 

appendix is intended to be used. In addition, activities in the on-going and reasonably foreseeable 

category have been updated to reflect new information since the DEIS was released in March of 

2013. 

A summary of past, present, and reasonably foreseeable management actions and natural 

disturbances are presented here. See the project record for the comprehensive master list of all 

projects for additional information on each project. Electronic maps that display much more detail 

are available on the project’s Web site or upon request. 

This summary of activities and disturbances is intended to provide the reader of snapshot of those 

projects and events that have influenced the existing condition of the project area (in terms of 

vegetation structure, composition, diversity and function). It provides a summary of ongoing and 

reasonably foreseeable actions that may cumulatively affect specific resources. This appendix is 

not intended to serve as the project’s cumulative effects analysis. This appendix represents the 

best available information made available to each resource specialist to determine relevancy to 

their specific resource. Each resource specialist identified the cumulative effects analysis 

boundary relevant to their specific resource. The direct and indirect effects of a resource are what 

drives the cumulative effects analysis. Each specialist reviewed the list (presented here) of actions 

and events and determined what was relevant to their resource. In some cases, they may have 

added other projects or events. See chapter 3 for the cumulative effects analysis by resource. 

The information provided below for livestock management, timber harvest, post-1996 vegetation 

management and natural disturbances is intended to summarize past management actions that 

have influenced (contributed to) existing conditions. 

Authorized Livestock Management

The information found in this section has been summarized from the range specialist report 

(Hannemann 2014). It is incorporated by reference. Livestock grazing has occurred on the project

area at least since the 1800s. Livestock (sheep and cattle) grazing can be traced back to the 1800s 

when roads within the forests were used to drive herds between New Mexico and California. By 

the early 1890s, overgrazing had resulted in changes to understory vegetation by reducing grasses 

and forbs. By the 1970s, the forests had assigned livestock numbers to allotments and rangeland 

improvements had been put in place to improve livestock distribution and avoid overutilization 

on sensitive areas (such as riparian). In 1987 and 1988, the forests’ land management plans were 

put in place addressing grazing capacity and utilization.

Historic range monitoring data for the project area was reviewed in 2011 (Brewer 2011). Data 

indicates cool season species increased through the 1990s in response to an increase in cool 

season moisture. In the last 10 plus years, decreased cool season moisture and increased warm 

season moisture has increased warm season species like blue grama. Today, excessive tree density 

(related to past land management practices) is causing a plant conversion to more shade tolerant 

species (such as bromes and mountain muhly).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 857
Appendix F – Cumulative Effects

Timber Harvest

Information on past timber harvests is summarized from the silviculture specialist report and is 

incorporated by reference (McCusker et al. 2014). Past timber harvest practices influenced 

vegetation structure, pattern, and composition on about 90 percent of the project area. From the 

late 1880s to the 1940s, logging that facilitated construction of the railroads was conducted by 

several lumber and timber companies in the Flagstaff and Williams area. By 1940, the railroads

had removed all the profitable lumber that could be easily accessed. In terms of vegetation 

structure, the largest and oldest tree sizes (VSS 5 and VSS 6) were removed from the project area 

(and across the Forests in general). Extensive regeneration with no large trees interspersed within 

the younger age classes became the norm. The pattern on the landscape no longer resembled the 

historic condition with historic tree groups and patch sizes ranging from 0.1 to 0.75 acre in size 

and with 2 to 40 or more trees (White 1985).

Past timber sales within the project area such as the 49’er, El Paso (1991), and Moritz sales 

(1985), all implemented prior to the Southwestern Region’s 1996 amendment of forest plans, 

targeted the harvest of medium and large diameter trees. In some cases, all trees over 12 inches in 

diameter were removed. This affected the presence of pre-settlement trees. Today, at the 

landscape (project area) scale, pre-settlement trees are rare.

The focus on even-aged forest management continued until the mid-1990s, leaving the legacy of 

current forest conditions. Approximately 50 percent of the project area that received some type of 

regeneration or shelterwood harvest has regenerated. Many stands are even-aged, dense, and lack 

age class diversity. Today, at least 84 percent of goshawk non- post-fledging family areas habitat 

vegetation structural stage 3 (young-aged forest) and 4 (mid-aged forest) is even-aged (FEIS 

chapter 1 2014). Approximately 74 percent of the project area is classified as having moderately 

closed to closed tree canopies (4FRI Proposed Action 2011, FEIS chapter 1 2014). Figure 74

(next page) displays the general location of past vegetation projects that occurred prior to 1996.

Post-1996 Vegetation Treatments – Uneven-aged 

Management, Fire Risk, Restoration

After the region-wide 1996 amendment, vegetation objectives included uneven-aged 

management. A review of the FACTS timber database indicates that treatments designed to 

promote uneven-aged management began being recorded in 1991 on the Kaibab NF and as early 

as 1987 on the Coconino NF. However, acres treated in this category continued to be minor in 

comparison to acres treated with even-aged methods until about 2005 (McCusker et al. 2014).

After 1996, the objective of most vegetation projects in the project area was to reduce the risk of 

high-severity fire, improve forest health (stand and tree resilience and vigor), and improve 

understory diversity. Retention of snags and managing for coarse woody debris was further 

enhanced with the 1996 amendment and made part of project requirements.

The 1996 forest plan amendment also changed treatments in Gambel oak and the species was 

recognized for its role in managing for ecological diversity and high quality wildlife habitat. 

From 1996 to 2000, at least seven projects (Spring Valley wildland-urban interface, Upper Basin, 

Marteen, Ten X and Red Horse Mudderbach, Elk Lee, Beacon, and Parks) totaling 30,000 acres 

on the Kaibab NF, were treated with objectives including reduced fire risk, savanna and meadow 

restoration, oak improvement, improved age class structure and diversity, and to maintain 

industry.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

858 Coconino and Kaibab National Forests
Appendix F – Cumulative Effects

On the Coconino NF, at least 68,800 acres were planned for treatment for similar purposes (Fire 

Data FY96 to FY99, 2011). Large projects on the Coconino NF that addressed fire risk included 

Mint Spring (7,778 acres of mechanical and 12,000 acres of prescribed fire, 1998) and the A-1 

project (14,500 acres with mechanical and broadcast prescribed fire, 2000). 

Figure 74. Pre-1996 vegetation and prescribed fire projects within the project area

With the exception of older projects that removed large, old trees and promoted even-aged 

management, most vegetation projects that contributed to the current condition within the project 

area occurred from 2000 to 2010. Projects implemented from 2010 to 2013 have resulted in minor 

to no changes(less than 1 percent change) to the current condition as most vegetation and 

prescribed fire analyses have recent decisions and have not been implemented. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 859
Appendix F – Cumulative Effects

From 2000 to 2014, most vegetation project objectives have included reducing fire risk to

communities, improving wildlife habitat in sagebrush (Tusayan district, Kaibab NF) and 

grasslands, improving winter range wildlife habitat, improving forest health and diversity 

(moving toward a balance of age classes, reducing mistletoe infection, promoting growth in old, 

large ponderosa pine, promoting aspen, and restoring ponderosa pine savanna conditions). 

On the Coconino NF, examples of projects designed primarily to address fire risk in the project 

area include Rocky Park Fuels Reduction (13,651 acres, 2001), Kachina Village (11,029 acres, 

2003), and Mormon Lake Fuels Reduction (1,820 acres, 2005-2013). Examples of similar 

projects on the Kaibab NF include Williams High Risk Precommercial Thin (756 acres, 2001), 

Dogtown Fuels Reduction (8,209 acres, 2004), and Pineaire Fuels Reduction (650 acres, 2004). 

Since 2000, at least 6,149 acres have been mechanically treated and prescribed burned on the 

Kaibab NF to improve wildlife habitat, and 2,485 acres have been treated to improve/restore 

grasslands. Wildlife habitat improvement projects included Potato Hill Habitat Improvement 

Project (1,275 acres, 2003), Upper Basin Project (1,884 acres, 2000), and Moqui Antelope 

Habitat Improvement Project (2,990 acres, 2006). Grassland restoration projects included Garland 

Prairie (500 acres, 2005), Ida Grassland Restoration (1,800 acres, 2008), and Community Tank 

Grassland Restoration (185 acres, 2011). On the Coconino NF, almost 7,000 acres were treated 

(up to 2010) to directly improve wildlife habitat (habitat improvement was the treatment 

objective). Some of the larger projects (within the project area) on the Coconino NF designed to 

restore grasslands, woodlands, and wildlife habitats include Hart Prairie Fuels Reduction (9,815 

acres, 2010), Elk Park Fuels Reduction (11,100 acres, 2007), and the Slate Mountain Pronghorn 

Project (2,250 acres, 2010). Projects adjacent to, but outside of, the project area include the 

Anderson Mesa Project.

Since 2000, over 13,829 acres of treatment on the Kaibab NF have focused on forest health and 

diversity objectives. Projects include Frenchy (9,319 acres of thinning that include savanna and 

meadow restoration and prescribed burning, 2003). On the Coconino, projects that addressed fire 

risk but also included restoration objectives such as meadow, riparian, and grassland restoration 

include Fort Valley (1,700 acres, 2000), Apache Maid Grass (54,528 acres, 2004), and Woody 

Ridge (8,599 acres, 2004). 

However, even some of the more recent tree thinning projects (from 2000 to 2010) have focused 

thousands of acres of treatment on the removal of the smallest trees. Some of these treatments 

were limited in order to comply with the forest plans when treating in Mexican spotted owl 

protected and restricted habitats. This has produced results similar to treatments conducted in the 

1980s – rapid regeneration and high tree density. Projects that focused on removing only the 

smallest trees (usually up to 9 inches d.b.h.) were primarily focused on reducing fire risk adjacent 

to public areas such as residential areas and campgrounds. Available data was reviewed and 

assumptions were made on some projects where data was incomplete.

From 2000 to 2010 on the Kaibab NF, about 3 percent of the project area (of the 596,000 acres 

proposed for treatment) was treated in a manner that resulted in prolific regeneration. 

On both forests, vegetation projects have typically included the construction (and 

decommissioning) of temporary roads and have decommissioned roads (Fleishman 2014). From 

approximately 2000 to 2013, approximately 47 miles of temporary road were constructed (and 

decommissioned), 251 miles of existing road were decommissioned (117 miles on the Kaibab NF 

and 44 miles on the Coconino NF), and approximately 1 mile was relocated to reduce impacts on 

resources. Table 155 displays past vegetation, prescribed fire and other ground-disturbing projects 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

860 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

that have influenced the existing condition. Figure 75 displays the general location of projects 

post-1996. Table 156 lists projects that are outside but adjacent to the project area.

Table 155. Summary of past projects that have influenced existing conditions (2000 to 2014) 

Project Name

Year 

(NEPA 

Decision) Treatment Type

Acres*

Mechanical 

/Prescribed Fire

Forest/District

Coconino Kaibab

Williams High 

Risk 

2001 Mechanical treatment 

and pile burn

756/756 Williams

Potato Hill 2003 Mechanical treatment, 

lop and scatter

1,275/0 Williams

Frenchy 2003 Mechanical treatment 

and pile burn

9,319/9,319 Williams

Dogtown 2004 Mechanical treatment 

and pile burn

6,509/6,509 Williams

Clover High 2004 Mechanical treatment 

and pile burn

385/385 Williams

Pineaire 2004 thin and prescribe, pile 

burn

650/650 Williams

Williams 

Followup 

Mistletoe

2004 Mechanical treatment 

and pile burn

368/368 Williams

Government 

Mountain/ 

Coleman

2005

Mechanical

75/0 Williams

Garland Prairie 2005 Mechanical treatment 

and lop, pile burn

500/47 Williams

City

2005 Mechanical treatment 

and pile burn/ 

prescribed fire

8,667/12,400 Williams

Kendrick 2005 Mechanical treatment 

and prescribed fire

Unknown Williams

Flag Tank 2007 Mechanical treatment 

and prescribed fire

22/36 Williams

IDA Grassland 2008 Mechanical treatment 

and prescribed fire

1,800/1,800 Williams

Bill Williams Cap 2009 Thin and prescribe 

burn

10/10 Williams

Community Tank 2011 Mechanical treatment 

and prescribed fire

185/185 Williams

Upper Basin 2000 Prescribed fire 0/1,884 Tusayan

Tusayan West 2001** Mechanical treatment 

and prescribed fire

549/850 Tusayan

Tusayan 

South/Boggy Tank

2000–2002 Mechanical treatment 

and prescribed fire

2,948/2,948 Tusayan

Ten X 2004 Mechanical treatment 

and prescribed fire

1,780/700 Tusayan

Topeka 2004 Mechanical treatment 

and prescribed fire

1,100/1,100 Tusayan

Moqui Antelope 2006 Mechanical 2,990/2,990 Tusayan

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 861
Appendix F – Cumulative Effects

Project Name

Year 

(NEPA 

Decision) Treatment Type

Acres*

Mechanical 

/Prescribed Fire

Forest/District

Coconino Kaibab

Scott 2001 Mechanical, pile, and 

prescribed fire

721/9,434 Tusayan

X Fire 2009 Mechanical 140/0 Tusayan

O’Connell < 2009 Mechanical 500/0 Tusayan

Arboretum WUI 2000 Mechanical treatment 

and prescribed fire

602/602 Flagstaff

Eagle Rock 

Reforestation 

http://www.fs.fed.

us/nepa/nepa_proj

ect_exp.php?proje

ct=39790

2013

Tree Planting

300 acres Williams

Fort Valley 2000 Mechanical 1,700/0 Mogollon 

Rim/Flagstaff

A-1 East, West 2000 Mechanical, pile, and 

prescribed fire

5,517/8,638 Flagstaff

Rocky Park 2001 Mechanical treatment 

and prescribed fire

5,651/8,000 Flagstaff

Lake Mary 2005 Mechanical treatment 

and prescribed fire

1,845/3,245 Flagstaff

APS Hazard Tree 2003 Prescribed fire 0/315 Flagstaff

APS Powerline 2007 Mechanical 167/0 Flagstaff

Blue Ridge 69kV 2005 Mechanical treatment 

and prescribed fire

50/1,300 Mogollon Rim

Doney Park 69kV 2007 Mechanical 9/0 Flagstaff

Kachina Village 2003 Mechanical treatment 

and prescribed fire

3,801/2,147 Flagstaff

Apache Maid 

Grass

2004 Mechanical 54,528/0 Mogollon Rim

Woody Ridge 2004 Mechanical treatment 

and prescribed fire

7,987/11,184 Flagstaff

Mormon Lake 

Basin Fuels 

Reduction1

2005-2013 Mechanical treatment 

and prescribed fire

1,820/1,820 ( of 

2,388)

Flagstaff

Skunk Canyon 2005 Prescribed fire 0/831 Flagstaff

Elden1 2002 Mechanical and 

prescribed fire

200/200 Flagstaff

Eastside 2006-2008 Mechanical treatment 

and prescribed fire

7,819/20,197 Flagstaff

East Clear Creek 2006 Mechanical treatment 

and prescribed fire

83/14,500 Mogollon Rim

Elk Park 2007 Mechanical treatment 

and prescribed fire

1,800/3,500 Flagstaff

Little Draw Aspen 2009 Mechanical 107/0 Flagstaff

Mormon 

Mountain 

(thinning around 

towers)

2007-2008

Mechanical 

11 Flagstaff

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

862 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Project Name

Year 

(NEPA 

Decision) Treatment Type

Acres*

Mechanical 

/Prescribed Fire

Forest/District

Coconino Kaibab

Munds Park 2009 Mechanical treatment 

and prescribed fire

990/2,950 Flagstaff

Slate Mountain 2010 Mechanical 2,250/0 Flagstaff

Schultz Fire 

BAER

2010 Mechanical (snag 

removal)

150 snags 

removed/0

Flagstaff – Not 

included in 

acreage tally

Other Ground Disturbing Projects

Tusayan Flood 

Reduction Project

http://www.fs.fed.us/

nepa/nepa_project_ex

p.php?project=39791

2013

Construct 6 water 

catchment basins

6 acres of 

disturbance

 Tusayan

Stone and Steel 

Interpretive Trail 

http://www.fs.fed.us/

nepa/nepa_project_ex

p.php?project=34040

2013

non-motorized trail 

construction

less than1 mile Williams

124 Road Quarry 

Expansion 

http://www.fs.fed.us/

nepa/nepa_project_ex

p.php?project=38561

2012

Pit expansion

2 acres Williams

Acre Summary

Total mechanical/vegetation treatment acres 138,486 

(less than 1 percent change since 2010) 

Total prescribed fire acres

131,800 

(less than 1 percent change since 2010 due to data 

refinement)

Total “Other” acres 9 (9 acres added since 2010) 

*Some projects are still in the implementation phase. Acres included here only include acres that have been implemented.

**The decision for Tusayan West was 1998 and implementation was 2001.

1. Project information from the Flagstaff Watershed Protection Project (2013)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 863
Appendix F – Cumulative Effects

Table 156. Summary of past vegetation and prescribed fire project acres (2000 to 2014) adjacent to 

the project area

Project Name Year 

(NEPA 

decision)

Treatment Type Acres

Mechanical/ 

Prescribed Fire

Forest/District

Coconino Kaibab

Williams High 

Risk 

2001 Mechanical treatment 

and pile burn 

756/756 data not 

available

Williams

Potato Hill 2003 Mechanical, lop and 

scatter

1,275/0 data not 

available

Williams

Frenchy 2003 Mechanical treatment 

and prescribed fire

9,319/9,319 data not 

available

Williams

Dogtown 2004 Mechanical treatment 

and prescribed fire

6,509/6,509 data not 

available

Williams

Acre Summary

Total mechanical/vegetation treatment acres 17,859 acres (no change since the DEIS) 

Total prescribed fire acres 16,584 acres (no change since the DEIS) 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

864 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Figure 75. General locations of past projects (post-1996) within the project area

Natural Disturbances – Fire

Information on natural disturbances (fire) is summarized from the fire ecology specialist report 

(Lata 2014) and the report is incorporated by reference. 7

Most of the vegetation types on the Kaibab and Coconino NFs are adapted to the frequent, lowseverity fire that occurred periodically prior to Euro-American settlement. In fire-adapted 

7 Please note, the fire ecology report also considered projects outside of the project area. For this reason, the 

project list may vary.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 865

 
Appendix F – Cumulative Effects

vegetation types, ecosystem function is dependent on this regular disturbance. However, 

suppressing all fires was common practice, dating back to the late 1800s and mid-1900s. During 

this time, extensive livestock grazing consumed the abundant grasses with forest reserve 

management plans often urging heavy grazing to eliminate the herbaceous fuels that allowed 

surface fires to sweep across the land (Drake 1910). In addition to grazing, early settlers also 

suppressed fire to protect their livelihood and homes.

Organized fire suppression efforts by the Forest Service date back to the first decade of the 20th 

century, largely in response to unacceptable fire effects due to heavy slash loads left by railroad 

logging. In 1935, the Forest Service further instituted a policy that all fires were to be 

extinguished by 10 a.m. of the day following their detection (Pyne 1982). Throughout most of the 

20th century, foresters continued to extinguish all fires regardless of ignition cause, intensity, or 

degree of danger to human safety or property. Widespread fire suppression efforts continue and a 

high percentage of Federal resources are focused on suppression (Covington 2003). 

As noted in the vegetation management section, without fire, understory seedlings in pine and 

mixed conifer forests had unprecedented survival rates. White fir, Douglas-fir, and even 

Engelmann spruce seedlings became established under ponderosa pine stands. Juniper and pinyon 

seedlings invaded former grassland savannas. The increase in tree density and resulting buildup 

of woody fuels led to unnaturally large and severe wildfires, insect outbreaks, and reduced 

biodiversity (Friederici 2004).

Data on wildfire acreages from 1940 to 1970 was derived from Covington 2003. Data on past 

wildfires that have occurred within the project area from 1970 to 2010 was derived from the 

project’s fire ecology specialist report (Lata 2014) and data from 2011 to 2013 was derived from 

the Forest’s fire database using a Forest Service database query, Fire Family Plus, for those 

districts of the Coconino and Kaibab NFs that are located south of the Grand Canyon in (largely) 

ponderosa pine vegetation. Acres may include portions of some pinyon-juniper and some mixed 

conifer vegetation. In addition to this data, each forest’s FACTS database was accessed to provide 

a subset of individual fires and acres for each forest (Lata 2014). In 2014, the 21,227-acre Slide

Fire occurred on the Coconino NF. Burn severity was assessed via Rapid Assessment of 

Vegetation Condition After Wildfire (RAVG) and soil severity was estimated by Burned Area 

Reflectance Classification (BARC). Collectively, about 46 percent of the fire burned in the 

moderate or high soil burn severity class.

Table 157 summarizes (estimates) acres of wildfire since 1940. Overall, wildfire has influenced at 

least 24 percent (239,433 acres) of the project area since 2001 to June 2014. Severe effects 

associated with past wildfires are attributed to about 20 to 30 percent (of about 240,000 acres) of 

the area burned within the project area. These fires affected structure, pattern, composition, and 

function by creating an even-aged plantation-type tree structure with grass and brush that are no 

longer contributing to a forested structure. The remaining 70 to 80 percent of the 240,000 acres of 

wildfires were low- to mixed-severity fires that provided beneficial impacts. These events 

affected structure, pattern, composition, and function by returning fire—a natural process—to the 

ponderosa pine system. 

As noted in table 155 and table 156, thousands of acres in and adjacent to the project area have 

been (or are currently being) treated to reduce hazardous fuels or restore the Forests to more 

resilient conditions. Vegetation was thinned and residual slash reduced/removed through various 

methods including machine piles and hand piles, chipping, lop and scatter, mastication, and 

mowing. From 2000 to 2013, at least 47,747 acres on the Williams and Tusayan districts and 

90,932 acres on the Coconino NF were treated within the project area. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

866 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Table 157. Coconino and Kaibab NF documented wildfire acres 1940 to 2014 

Time Period

Project Area Wildfire 

(acres affected)

1940–1960 10,139 (Coconino NF only)

1960–1969 1,090 (Coconino NF only)

1970–1980 49,631

1981–1990 7,399

1991–2000 63,397

2001–2010 180,499

2011-2013 37,707

2014 21,227 (Coconino NF, Slide Fire) 

Total acres 371,088

Natural Disturbances – Insect and Disease 

Information on natural disturbances (fire) is summarized from the silviculture specialist report 

(McCusker et al. 2014) and the report is incorporated by reference.

The Coconino NF experienced significant bark beetle outbreaks in the mid-1920s, late 1930s, 

mid-1960s, late 1970s through early 1980s, and late 1990s through the mid-2000s. The 1950s and 

2000s outbreaks appear to be more extensive than other outbreaks, damaging at least 200,000 and 

72,000 acres, respectively. Ponderosa pine needleminer defoliated over 9,000 acres of ponderosa 

pine on the Coconino NF in 1999 (USDA FS 2000). 

On the southern portion of the Kaibab NF, western pine beetle activity was reported in late 1970s 

and early 1980s. The contemporary (2000s) bark beetle outbreak is probably more severe than 

past outbreaks. Ponderosa pine mortality approached 100 percent in some stands (Gitlin et al. 

2006), but averaged only 3.4 percent in a limited number of plots distributed across Williams 

Ranger District (RD) and Tusayan RD (Negrón et al. 2009). 

Southwestern dwarf mistletoe is dispersed throughout the project area where 2 to 31 percent of 

the commercial ponderosa pine type was infected in the 1980s on the northern half of the 

Coconino NF, and 25 to 38 percent of the commercial ponderosa pine type was infected on the 

Williams district (Hessburg and Beatty 1985). 

Annual aerial surveys on the Coconino and Kaibab NFs in the summer of 2010 detected 

ponderosa pine mortality associated with bark beetles on approximately 6,500 acres within the 

project area. This mortality is most likely associated with the Ips beetle (USDA FS 2011). This 

survey indicates a tenfold increase in beetle mortality from the 2008 and 2009 surveys, although 

bark beetle activity in ponderosa pine is currently considered to be at endemic levels. Preliminary 

results of the 2011 survey indicate a minor reduction in ponderosa pine mortality from 2010. In 

pinyon-juniper woodlands, both localized and widespread mortality events have occurred over 

time on the Coconino and south Kaibab NFs. These events have typically been pinyon Ips 

outbreaks associated with periods of drought, such as occurred in the 1950s, and more recently in 

the mid-1990s and 2001 through 2003. From 2010 to 2014, saw fly defoliation occurred in the 

Bull Basin area on the Coconino and Kaibab NFs. Approximately 1 to 5 percent ponderosa pine 

mortality occurred (Cote personal communication with Gonzalez, 2014). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 867
Appendix F – Cumulative Effects

Juniper mortality from wood borers and Phloeosinus beetles has occurred in areas of poor site 

quality within the project area during the recent drought (Mueller et al. 2005, USDA FS 2002).

Juniper mortality averaged 3.3 percent within an 80 kilometer radius of Flagstaff, with greater 

mortality on grassland versus nongrassland sites (Gitlin et al. 2006). 

In aspen, mortality has been attributed to the severity of the 1999 frost damage, severe drought 

conditions, and western tent caterpillar defoliation in 2004 and 2005. Although dying trees 

sprouted, survival has been very low due to browsing by elk. Mortality has been greatest in the 

low-elevation range. In 2008, Faithweather et al. found that more than 50 percent of surveyed 

aspen sites below 7,500 feet elevation experienced 97 percent mortality (Fairweather et al. 2008). 

In summary, as agents of change, forest insects and diseases have a significant role in forest 

ecosystem dynamics. Forest insect and disease driven change alters forest ecological processes, 

forest structure, and composition. At one time or another, all of the vegetation types within the 

project area have incurred extensive damage by one or more agents (table 158). The transitory 

agents causing the most extensive and severe damage have been pinyon Ips in pinyon pine, Ips 

bark beetle species in ponderosa pine, and multiple biotic and abiotic agents in aspen. Each of the 

vegetation types shows distinct periods of increased insect damage that can be associated with 

droughts. The most extensive and damaging persistent agent is southwestern dwarf mistletoe in 

ponderosa pine. More detailed information can be found in Lynch et al. 2008a and 2008b. 

Table 158. Acres affected by insect and disease outbreaks by forest (within project area) 

Time Period Insect/Disease Type

Acres and/or Percent of Forest Affected

Coconino Kaibab

1950s Bark beetle (ponderosa pine) damage 200,000 NA

1950s Wood borers and Phloeosinus beetle 

(juniper woodland) mortality

Unquantified – described as extensive

1970s to 1980s Western bark beetle (ponderosa pine) NA Unquantified

1980s Southwestern dwarf mistletoe 

(ponderosa pine) infection 

19,773 to 306,489 

(2 to 31 percent)

247,169 to 375,696 

(2 to 38 percent) 

1999 Needleminer (ponderosa pine) 9,000 NA

2000s Bark beetle (ponderosa pine) damage 72,000 NA

2000s Bark beetle (ponderosa pine) mortality 100 percent mortality in 

select stands

29,660 (3 percent) 

2002–2005 Wood borers and Phloeosinus beetle 

(juniper woodland) mortality

3 percent mortality within 

50 mile radius around 

Flagstaff*

Extensive

2005–2008 1999 frost and 2004–2005 western tent 

caterpillar defoliation (aspen) mortality

97 percent mortality in greater than 50 percent of 

surveyed aspen sites below 7,500 feet 

(Fairweather et al. 2008).

2010 Bark beetle (ponderosa pine) mortality 6,500

2010-2014 Saw Fly (ponderosa pine defoliation) Bull Basin Area - 2,000 acres with 1 to 5 percent 

mortality across both Forests

*Accurate acreage number not feasible given the amount of non-FS lands included in the 50 mile radius. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

868 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Private, State, and Other Agency Activities 

Since 2000, over 105,000 acres of treatments designed to reduce fire risk and/or improve forest 

resiliency have occurred on private, State, and other agency- managed lands in or adjacent to the 

project area (table 159). 

On the Kaibab NF, from 2001 to 2004, the Rural Communities Fuels Management Partnership 

thinned over 200 acres of trees on private property in the Parks, Sherwood Forest Estates, 

Williams, and Sherwood Forest Estates communities to reduce the risk of wildland fire and 

improve the forest (Kaibab NF news release, August 2004).

The Camp Navajo Army Depot borders both the Kaibab and Coconino NFs and is within the 

project area. Camp Navajo implemented post tornado recovery by removing storm damaged trees 

on 939 acres in 2011 and 2012. The project was completed in October of 2012, reducing the risk 

of bark beetle infestation and resistance to control of wildfires. In addition, pre-commercial 

thinning (159 acres) and prescribed burning (115 acres) were accomplished in 2012. Commercial 

thinning began in 2011 on the West Side Timber Sale, but no cutting units have yet been 

completed. This sale is expected to resume in 2013 (Camp Navajo 2013 data). 

Approximately 78,429 acres of fuels reduction treatments were conducted on State and/or private 

lands from 2000 to 2013 through the Greater Flagstaff Forest Partnership (GFFP) and Arizona 

State Forestry Division cost-share program (GFFP 2010 Report). Of this amount, over 49,000 

acres8 of treatment has occurred within the 180,000-acre GFFP boundary and the GFFP boundary 

is within the 4FRI project area (GFFP 2011 Report). The GFFP Report (GFFP 2011) states, “The 

Partnership continues to receive various grants from AZ State Forestry Division to provide cost---

share assistance to cover a portion of the cost of treating private lands within the Flagstaff 

wildland/urban interface. To date, more than $500,000 has been distributed to 132 property 

owners to treat 1,200+ acres of land. 

Examples of projects include NAU (1,893 acres), Sunset Crater (316 acres), Aizona Department 

of Game and Fish (54,988 acres), Flagstaff Fire Department (9,203 acres) and 245 acres of fuels 

reduction on private lands (2013). Treatments were designed for the wildland-urban interface 

(WUI). 

From 2011 to 2013, the City of Flagstaff completed 1,065 acres of thinning, 1,594 acres of debris 

disposal (pile burning and chipping) and 302 acres of prescribed burning (Summerfeldt 2014). 

From 2000 to 2013, the Grand Canyon NP conducted approximately 22,990 acres of mechanical 

treatment (fuels reduction) and prescribed burning along the south rim. Activities conducted in 

this vicinity are adjacent to the Tusayan district, Kaibab NF. 

Foreseeable hazardous fuels reduction projects (2013 awards from Arizona State Forestry) 

include 160 acres of treatment in Williams, 100 acres in Tusayan (Tusayan Fire District), 90 acres 

in the Saskan Ranch Subdivision (Ponderosa Fire District), http://www.azsf.az.gov/WFHF-Grants

(March 17, 2014), 190 acres (4 to 10 parcels) in 2014, and 100 acres of prescribed burning 

through 2014 (Flagstaff Fire Department, personal communication, February 24, 2012). The 

Grand Canyon NP expects to mechanically treat 311 acres and prescribe burn approximately 

2,862 acres in 2014 (Marks and Lata personal communication 2014). 

8 Total acres treated include treatment by USFS and all others within the GFFP boundary (GFFP 2011 

Report). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 869

 
Appendix F – Cumulative Effects

Table 159. Past treatments on private, State, and other federally managed lands 2000-2013

Years Agency/Organization Acres Treated

2000–2004 Rural Communities Fuels Management Partnership 200

2000–2013 Arizona State Forestry and Greater Flagstaff Forest 

Partnership (GFFP)a

 

78,429b

2000-2013 City of Flagstaff Forest Treatment Activities 2,961

2000–2013 Grand Canyon NP – South Rim 22,990

2011-2012 Camp Navajo Army Depot 1,213

Total 105,793

a. Arizona State Forestry has been included in the GFFP category to display treatment acres that focus on the greater 

Flagstaff urban interface. ASF does fund and implement treatments separate from the GFPP.

b. Reflects completion of 245 acres in 2013 since the 4FRI DEIS was released in March of 2011.

Summary of Current and Ongoing Projects 

Approximately 166,897 acres of vegetation treatments and 195,076 acres of prescribed fire (as of 

2013) are in the current and ongoing category within the project area (table 160 and figure 76). 

Table 161 includes other projects considered. 

The ongoing and current projects category focuses on those projects that have the potential to 

affect vegetation (structure, pattern, and composition), natural processes (such as fire), and 

movement toward increased forest resiliency and function. Specialists evaluated whether 

additional projects (not included in this list) are relative to their cumulative effects analysis. This 

category includes vegetation and prescribed fire projects that still have acres remaining for 

implementation. This list has been updated to reflect data up to 2013. 

The Forests have been annually implementing a portion of the total acres specified in the NEPA 

decisions. It is typical for vegetation and prescribed fire projects to be implemented over a course 

of 1 to 10 years, depending on size and complexity. Only those acres that remain to be 

implemented are reflected in this category. Projects that included periodic (maintenance) 

prescribed fires are included in this category. The assumption for other projects such as power 

line maintenance conducted by special use permit holders is that the vegetation within the entire 

right-of-way could be maintained annually. 

Table 160. Current and ongoing vegetation, prescribed fire, and other ground-disturbing projects

Project Name Treatment Type

Mechanical / 

Prescribed Fire 

(acres)

Forest/District

Coconino Kaibab

Pomeroy Mechanical and prescribed fire 1,740 / 1,740 Williams

KA 1,050 / 1,050 Williams

Russell 5,000 / 5,000 Tusayan 

Community Tank 865 / 865 Williams 

Bill Williams Cap 10 / 10 Williams

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

870 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Project Name Treatment Type

Mechanical / 

Prescribed Fire 

(acres)

Forest/District

Coconino Kaibab

Ten X Prescribed fire 700 Tusayan

Airport 602 Tusayan

South Williams 290 Williams

Long Jim 1,300 Tusayan

Dogtown Mechanical and prescribed fire 1,700 / 1,700 Williams

McCracken Project

http://www.fs.fed.us

/nepa/nepa_project_

exp.php?project=18

988

Mechanical and prescribed fire 

including pine and woodland 

savannah treatments

2012 NEPA decision

15,262 / 17,337 Williams

Aspen Restoration 

Project 

http://www.fs.fed.us

/nepa/nepa_project_

exp.php?project=24

584

Mechanical and prescribed fire 

2011 NEPA decision

402 / 402 Williams

Twin Prescribed fire 1,400 Williams

Frenchy 6,529 Williams

Tusayan 

South/Boggy Tank

2,948 Tusayan

Tusayan East 2,600 Tusayan

Arboretum 602 Flagstaff

Woody Ridge 11,184 Flagstaff

Post-Tornado Mechanical

(tree removal)

18,756 Flagstaff and 

Mogollon Rim 

Hart Prairie Mechanical and prescribed fire 9,815 / 9,815 Flagstaff

Munds Park Prescribed fire / 2,950 Flagstaff 

A-1 East and West / 8,274 Flagstaff

East Clear Creek

http://www.redrockc

ountry.org/nepa/200

5-06/east-clearcreek-watershed/dnand-fonsi.pdf

Mechanical and prescribed fire 1,562 / 4,700 Flagstaff 

Marshall Fuels 

Reduction 

Mechanical and prescribed fire 

2012 NEPA decision

10,800 / 6,260 Flagstaff

Upper Beaver 

Watershed Fuels 

Reduction (90

percent outside the 

project area) 

Mechanical and prescribed fire 

2012 NEPA Decision

15,807 / 31,162 Mogollon

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 871
Appendix F – Cumulative Effects

Project Name Treatment Type

Mechanical / 

Prescribed Fire 

(acres)

Forest/District

Coconino Kaibab

Mountainaire (also 

covered in GFFP)

http://www.redrockc

ountry.org/nepa/200

5-

06/mountainaire/mt

nr-dn-4-15-06.pdf

Mechanical and prescribed fire

2006 NEPA Decision

13,780 / 15,256 Flagstaff

Wing Mountain 

http://data.ecosyste

mmanagement.org/ne

paweb/nepa_project

_exp.php?project=3

3853

Mechanical and prescribed fire, 

road decommission

2013 NEPA Decision 

10,190 / 10,767 Flagstaff 

Mormon Lake Basin 

2 

Mechanical treatment 568 acres / 0 Flagstaff

Mormon Lake Basin 

1 and 2

Prescribed fire 0 / 2,388 Flagstaff

Skunk Canyon

http://www.redrockc

ountry.org/nepa/200

5-06/skunkcanyon/skunkcanyon-scopingltr.pdf

0 / 831 Flagstaff

Eastside

http://www.redrockc

ountry.org/nepa/200

7-08-

09/eastside/eastside

_ea_dn_alvin_1226

06.pdf

0 / 20,197 Flagstaff

Power lines, oil and 

gas lines, natural 

gas/FERC, meter 

sites, gas 

compression and 

substation sites*

Right-of-way vegetation 

clearing for maintenance 

purposes and to reduce fire risk

30,710 / 0 Forestwide

Power lines, oil and 

gas lines, natural 

gas/FERC, meter 

sites, gas 

compression and 

substation sites*

Right-of-way vegetation 

clearing for maintenance 

purposes and to reduce fire risk

1,634 / 0 Forestwide

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

872 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Project Name Treatment Type

Mechanical / 

Prescribed Fire 

(acres)

Forest/District

Coconino Kaibab

Western Area 

Power 

Administration 

Glen Canyon to 

Pinnacle Peak 

http://data.ecosyste

mmanagement.org/ne

paweb/nepa_project

_exp.php?project=3

5015

Mechanical

2013 NEPA decision

4,584 / 0 Flagstaff 

Bobs (part of 

Woody Vegetation 

project)

http://www.redrockc

ountry.org/nepa/200

0-to-04/woodyridge/woody_dn_fo

nsi_alvins_final.pdf

Mechanical and prescribed fire 2,000 / 2,000 Flagstaff

Clark’s (part of Elk 

Park project)

http://www.redrockc

ountry.org/nepa/200

5-06/elk-park-fuelsreduc/2007-dnfonsi.pdf

1,600 / 1,600 Flagstaff

Elk Park Fuels

http://www.redrockc

ountry.org/nepa/200

5-06/elk-park-fuelsreduc/2007-dnfonsi.pdf

2,900 / 2,900 Flagstaff

Jack Smith-Schultz9

http://a123.g.akamai

.net/7/123/11558/ab

c123/forestservic.do

wnload.akamai.com

/11558/www/nepa/3

3456_FSPLT2_383

267.pdf

2,000 / 2,000 Flagstaff

Weatherford (part of 

Jack Smith Schultz 

and Eastside)

1,000 / / 1,000 Flagstaff

Railroad 250 / 250 Flagstaff

9 The Orion Timber Sale (891 acres) is scheduled to be offered for sale in 2014. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 873

 
Appendix F – Cumulative Effects

Project Name Treatment Type

Mechanical / 

Prescribed Fire 

(acres)

Forest/District

Coconino Kaibab

Clints Well Forest 

Restoration 

http://a123.g.akamai

.net/7/123/11558/ab

c123/forestservic.do

wnload.akamai.com

/11558/www/nepa/5

5233_FSPLT2_375

422.pdf

12,912 acres mechanical

(includes 10,522 acres of 

wildland-urban interface) 

3,987 acres no treatment

16,467 acres prescribed fire 

(includes 10,522 acres of 

wildland-urban interface) 

2013 NEPA Decision 

12,912 / 16,467 Mogollon Rim

(outside project 

area)

Kelly Motorized 

Trails 

http://data.ecosyste

mmanagement.org/ne

paweb/nepa_project

_exp.php?project=3

6911

Designate Motorized trails

2012 NEPA decision

95 miles of 

designated 

motorized trails 

includes 35 miles of 

motorcycle trail 

construction and 43 

miles of OHV trail 

construction , 13 

miles of road 

decommission – 

equates to 

approximately 

49,920 acres of new 

construction and 13 

miles of road 

decommission

Flagstaff district

Summary of Acres

Total acres of vegetation treatments (including 

powerline maintenance) and other ground disturbing 

actions

166,897 acres (increase of approximately 50 percent

since2010) 

78 miles (49,920 acres) of new motorized trail 

construction

13 net miles (8,320 acres) of road decommission 

Total acres of prescribed fire 195,076 (increase of approximately 50 percent since 

2010)

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

874 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Table 161. Current and ongoing other projects

Project Name Project Purpose Description

Forest/District

Coconino Kaibab

Coconino and Kaibab National Forests

Treatment of Noxious 

Weeds-3 Forests 

Direction incorporated into 

forest plans

Encompasses 

project area

Forestwide Forestwide

Firewood collection Forestwide policy Williams and 

Tusayan

Tusayan Travel 

Management

Tusayan

South Zone Travel 

Management 

http://www.fs.fed.us/nepa/

nepa_project_exp.php?proj

ect=42961

Williams

Decision 

expected 

09/2014

Coconino NF Travel 

Management

Coconino and Kaibab NFs 

road maintenance 

Annual road maintenance 500 miles per year on each forest

Grazing 

Continuation of authorized 

livestock grazing

791,250 acres / 80

percent of project 

area

47 active allotments within 

project area, see the range report 

for a complete list of allotments 

within project area 

Wildlife waters Water development 

maintenance 

24 water 

developments

Tusayan

Little Draw Aspen exclosure 

maintenance 

107 acres Flagstaff

Grapevine Interconnect 

(Grapevine Canyon Wind 

Project)

http://a123.g.akamai.net/7/

123/11558/abc123/forestse

rvic.download.akamai.com

/11558/www/nepa/72690_

FSPLT2_376210.pdf

9 miles of new 345 kV 

electric transmission line

2012 NEPA Decision (ROD)

9 miles vegetation 

removal 

Outside the 

4FRI project 

area

Bill Dick Springs 

Enhancement

http://data.ecosystemmanagement.org/nepaweb/

nepa_project_exp.php?proj

ect=38507

Restoration of 3 springs 

2013 NEPA Decision 

9.3 acres Mogollon Rim 

Other agency and private lands current and ongoing vegetation and prescribed fire projects

Camp Navajo (2013)

Commercial Thinning

Timber Stand Improvement 

7 inch d.b.h. or less

951 acres

399 acres

Flagstaff

Arizona State Forestry and 

Greater Flagstaff Forest 

Partnership, including 

private lands

See Past and Foreseeable Category

*The numbers in this category are for the entire permitted facility and likely include acres outside the project area. Data 

that would have been specific to the project area was not readily available.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 875
Appendix F – Cumulative Effects

Figure 76. General locations of current and ongoing projects within or adjacent to the project area

Summary of Reasonably Foreseeable Projects 

Reasonably foreseeable projects for this analysis (table 161, table 162, and figure 77) are defined 

as those Forest Service projects that have been listed in the forests’ schedule of proposed actions 

(SOPA). The most recent SOPA for both forests was reviewed in March 2014 (USDA FS 2014). 

Decisions are imminent or decisions have been made and implementation is about to begin; or the 

projects are poised for implementation by other (non-FS) parties. The reasonably foreseeable 

category mostly focuses on those projects that have the potential to affect vegetation (structure, 

pattern, and composition), natural processes (such as fire), and movement toward increased 

resiliency and function. Some project, such as the rock pits analysis, would not affect vegetation 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

876 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

structure, spatial pattern, or composition. However, this project has been included as it may affect 

how road proposals (and their associated costs) are analyzed and implemented. Specialists also 

evaluated whether additional projects (not included in this list) would be included in their 

cumulative effects analysis. In summary:

• Approximately 43,041 acres of vegetation (mechanical) treatments and 58,714 acres of 

prescribed fire and maintenance burning would be implemented by the Forests in the 

foreseeable future (within 10 years) (table 162). Table 163 displays other foreseeable 

projects.

• Approximately 18,448 acres of vegetation (mechanical) treatments and 19,082 acres of 

prescribed fire and maintenance burning is expected to be implemented on State, private, and 

other federally managed lands within the foreseeable future (within 10 years) (table 164).

• Projects that are foreseeable but located outside of the project area are displayed in table 165. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 877
Appendix F – Cumulative Effects

Table 162. Reasonably foreseeable vegetation and ground-disturbing projects within and adjacent to the project area

Project Name Treatment Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Bill Williams 

Mountain 

Restoration

Mechanical, 

prescribed fire, 

roads 

11,650 acres 

mechanical 15,200 

acres prescribed fire 

28 miles road 

decommission and 

23 miles temporary 

road construction 

Williams Reintroduce fire, reduce stand densities and fire potential, 

move toward balanced age classes, improve understory 

composition and productivity, includes 31 acres of cable 

logging in Mexican spotted owl PACs that would cause a loss 

of most snags and trees (including snags greater than 18 inch 

d.b.h. and trees greater than 24 inch d.b.h.) across 

approximately 15 percent of the area with this proposed 

treatment within the PAC in order to provide cable corridors 

and safe logging operations. Approximately 15 percent, or 5 

acres, of the PAC area treated with cable logging operations 

would have most trees removed within these corridors under 

Alternative 2 (SDEIS, page 6). removes timber suitability on 

8,954 acres, thinning above 9 inch d.b.h. in Mexican spotted 

owl PACs, burning greater than 1 acre in the AZ Bugbane 

Botanic Area

Status: analysis underway, DEIS was released in 2012, SDEIS 

was released in October of 2013, a decision is likely in 2014. 

Coconino and 

Kaibab NFs Rock 

Pit Development 

http://a123.g.akama

i.net/7/123/11558/a

bc123/forestservic.

download.akamai.c

om/11558/www/ne

pa/75515_FSPLT3

_1445519.pdf

Existing pit 

expansion and new 

pit development 

39 pits, 434 acres 

(new disturbance)

Forestwide Forestwide Create source of materials for road maintenance and 

management for both forests. Scoping occurred in 2011. An 

initial assessment of materials occurred in the 1990s. 

Status: analysis underway, decision likely in 2014. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

878 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Project Name Treatment Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Juan Tank Japanese 

Tank Brome

http://www.fs.fed.u

s/nepa/nepa_project

_exp.php?project=4

1566

Prescribed Fire 12, 133 acres Williams Contain and control Japanese brome

Status: Scoping expected in March 2014 and decision in May 

2014

Watts Vegetation 

Project

http://www.fs.fed.u

s/nepa/nepa_project

_exp.php?project=4

1569

Mechanical and 

prescribed fire

3,000 acres Tusayan Scoping 01/2014 with decision expected 05/2014

Turkey/

Barney Pasture 

Forest Health 

Restoration 

http://www.fs.fed.u

s/nepa/nepa_project

_exp.php?project=3

7244

Mechanical and 

prescribed fire 

Potentially 17,838 

acres of mechanical 

and prescribed fire

Flagstaff Reduce dwarf mistletoe, tornado salvage, improve Mexican 

spotted owl habitat

Status: analysis underway, decision may occur in October 

2014; however, 2014 Slide Fire resulted in changed conditions. 

Mt. Elden/Dry Lake 

Hills Recreation 

http://www.fs.fed.u

s/nepa/nepa_project

_exp.php?project=3

8239

Trail construction, 

reconstruction and 

relocation, trailhead 

expansion and/or 

consolidation and 

the decommission 

of unauthorized 

roads and trails in 

the Mt. Elden ESA 

and Dry Lake Hills 

area

Construct: 8 miles 

of horse trail, 3.5 

miles of bike trail, 

11 miles of hiking 

trail, 0.5 mile of 

climbing trail

Relocate 10.5 miles 

of existing trail 

Decommission 

unauthorized trails 

and roads in Mt. 

Elden ESA

The purpose of the project is to provide enhanced recreation 

opportunities, mitigate impacts to wildlife habitat, 

archaeological sites, soil, water, and address community 

interests. 

Status: Scoping occurred in 2013 and a decision is expected in 

10/2015

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 879
Appendix F – Cumulative Effects

Project Name Treatment Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Expand and/or 

consolidate 

trailheads 

Flagstaff Watershed 

Protection Project

Mechanical and 

Prescribed Fire 

10,543 acres (7,569 

acres Dry Lake 

Hills and 2,974 

acres Mormon 

Mountain) 

Flagstaff 4FRI treatments in Dry Lake Hills and Mormon Mountain

removed – deferred to FWPP

Treatments include 1,825 acres of PAC treatments in Mormon 

Mountain, 1,221 PAC treatments in DryLake Hills, 424 acres 

of Mexican spotted owl core area treatment in Mormon 

Mountain, and 396 acres of Mexican spotted owl core area 

treatment in Dry Lake Hills,103 acres of goshawk nest fuels 

reduction in Dry Lake Hills, 59 acres of grassland restoration 

in Dry Lake Hills and 1.733 acres of no treatment due to 

previous NEPA or site condition

Status: Scoping conducted in April, 2013, decision likely in 

2014 with implementation in 2015

Acre Summary

Vegetation treatments and foreseeable ground disturbance 43,041 acres (mechanical) 

5 net miles of temporary road increase and 23 miles of net trail increase 

434 acres (net increase in ground disturbance from pits) 

Prescribed fire (including maintenance burning) 58,714 acres

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

880 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Table 163. Other (non-vegetation) reasonably foreseeable projects within the project area

Project Name

Treatment 

Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Highway 180 Antelope Crossing 

http://www.fs.fed.us/nepa/nepa_p

roject_exp.php?project=42905

Fence setback to 

facilitate 

pronghorn 

crossing between 

summer and 

winter range 

2 miles Williams Scoping will be conducted in March of 2014 and 

implementation expected in April of 2014

APS NO1 Youngs to Mormon 

Lake 69kV Powerline

http://a123.g.akamai.net/7/123/11

558/abc123/forestservic.downloa

d.akamai.com/11558/www/nepa/

75515_FSPLT3_1445519.pdf

Existing aerial 

and buried cable 

lines – permit 

reissuance began 

in 2013

21 miles Flagstaff APS NO1 Youngs to Mormon Lake 69kV Powerline – 

Red Rock portion of project is outside 4FRI project area

Status: Analysis underway, decision likely in 2014

Moonset Pit Existing pit 

expansion

4.4 acres Williams County request – pit is located in Parks area

Status: Decision likely in 2014

Table 164. Other agency and private lands foreseeable vegetation and prescribed fire projects

Project Name Treatment Type Metric

Forest/District Project Objective Summary and 

Coconino Kaibab Status

Camp Navajo Commercial thinning and 

Mexican spotted owl

target nesting (2014)

154 acres Stand 32 259 

acres Stand 70

Flagstaff Williams Reduce fire risk, improve diversity of 

forest conditions, and reducing tree 

density in 5 inches to 18 inches d.b.h. 

Status: 2013 implementation

Department of Defense 

AZARNG Thin and Burn 

Mechanical and 

prescribed fire

17,049 acres mechanical 

and prescribed fire

Ponderosa pine, pine-oak, and grasslands 

restoration to mitigate fire risk, provide 

diversity in forest conditions, improve 

ecosystem health, reduce tree density in 

5 inches to 18 inches d.b.h. 

Greater Flagstaff Forest 

Partnership (GFFP) 

Mechanical and 

prescribed fire

535 acres mechanical and 

prescribed fire

Flagstaff Reduce fire risk on private property

Status: implement in 2013 and 2014

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 881
Appendix F – Cumulative Effects

Project Name Treatment Type Metric

Forest/District Project Objective Summary and 

Coconino Kaibab Status

Navajo Nation Mechanical and 

prescribed fire

140 acres mechanical and 

prescribed fire

Flagstaff Information provided via the Flagstaff 

Watershed Protection Project

Grand Canyon NP (South 

Rim)

Mechanical and 

prescribed fire

311 acres mechanical and 

2,862 acres prescribed fire

Adjacent to 

Kaibab

Information provided by GCNP

Acre Summary

Vegetation mechanical treatments 18,448 acres (less than 1 percent change since 2010)

Prescribed fire and maintenance burning 19,082 acres (less than 1 percent change since 2010)

Table 165. Other foreseeable vegetation and prescribed fire projects outside the project area

Project Name Treatment Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Mahan-Landmark 

Forest Restoration

http://www.fs.fed.us/

nepa/nepa_projectt_e

xp.php?project=3797

2

Fuels reduction and 

restoration 

42,000-acre project area 

(there is a slight overlap into 

the project area but overall 50 

percent is outside of the 

project area) 

Mogollon Rim wildland-urban interface treatments on 

11,468 acres and 36,621 Acres of 

restoration treatments including 18,849 acre 

Of pine restoration, 4,799 acre Mexican 

spotted owl PAC treatment, 2,620 acre 

Mexican spotted owl restricted habitat 

maintenance, 3,183 acre Mexican spotted 

owl target/threshold maintenance, 1,0344 

acres of goshawk post-fledging family 

areas maintenance, 958 acre Grassland 

maintenance, 4,730 acre Savannah 

maintenance, 247 acre Spring maintenance, 

247 acre Powerline ROW maintenance.

Allen Lake 

Restoration 

http://www.fs.fed.us/

nepa/nepa_project_e

xp.php?project=4176

2

Wetland restoration 17 acres Mogollon Rim Decision in 2/2014 – implementation will 

occur in 2014

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

882 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Project Name Treatment Type Metric

Forest/District

Coconino Kaibab Project Objective Summary and Status

Greater Flagstaff 

Forest Partnership 

(GFFP) 

Mechanical and 

prescribed fire

535 acres Flagstaff Reduce fire risk on private property

Status: implement in 2013 and 2014

Coulter Exper. 

Forest 

Mechanical and 

prescribed fire

800 acres RMRS Removed from 4FRI treatment acres and 

analyzed as cumulative

Chiricahua leopard 

frog

Habitat No specifics available Red Rock Rehab Sycamore and Walts Tank – pinyonjuniper removal

Status: Decision expected in 03/2014

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 883
Appendix F – Cumulative Effects

Reasonably Foreseeable Projects 

With Insufficient Information for Analysis 

The Four-Forest Restoration Initiative, Mogollon Rim of the Coconino NF, ApacheSitgreaves NFs and Tonto NF, as of March 2014, has no tangible information that would be 

meaningful for this cumulative effects analysis. No project boundary has been finalized, no 

decision has been made on the existing and desired condition of resources (no purpose and need 

for action); therefore, no specific activities have been proposed. For this reason, it was not 

considered in the cumulative effects reasonably foreseeable category. 

Highway 180 Motorized Trails – This project proposes to construct up to 60 miles of motorized 

trails. As of March, 2014, the project is on hold. For these reasons, it has been eliminated from 

foreseeable cumulative effects. 

Red Rock District (Coconino NF) Pronghorn habitat improvements - The project was to be 

scoped in 2012. No additional information is available. For this reason, it has been eliminated 

from reasonably foreseeable cumulative effects. 

Mahan-Landmark Forest Restoration – In the DEIS the best available information was used to 

describe the potential for cumulative effects. Since that time the proposal has not been finalized. 

A notice of intent to prepare an environmental impact statement is expected to be published in 

September of 2014. A supplemental cumulative effects analysis will be completed as needed. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

884 Coconino and Kaibab National Forests 
Appendix F – Cumulative Effects

Figure 77. General locations of foreseeable projects within or adjacent to the project area

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 885

Appendix G – Bridge Habitat 

for Canopy-Dependent Wildlife

Sarah Reif, Habitat Program Manager, Region 2, Arizona Game and Fish Department 

Neil McCusker, 4FRI Silviculturist

Mark Nigrelli, 4FRI GIS Specialist

Bill Noble 4FRI Wildlife Biologist

Introduction

Because much of the 4FRI landscape is dominated by mid-aged trees, the 4FRI project would not 

achieve desired conditions on all treatment acres immediately post-treatment. It would take time 

for the largely even-aged forests to develop uneven-aged structure, for trees to mature into larger 

diameter classes, and for tree canopies within tree groups to reach the desired interlocking crown 

condition. Because of this time lag, some stakeholders are concerned that post-treatment 

conditions within the 4FRI project area would not provide sufficient habitat for canopy-dependent 

wildlife in the short term.

The wildlife species of concern identified by our publics, relative to the delay in achieving 

desired conditions, include northern goshawks, Mexican spotted owls, Abert’s squirrels, turkeys, 

mule deer, black bears, and some songbird species. The information provided in this appendix 

clarifies how post-treatment conditions within the 4FRI project area would provide habitat for 

canopy-dependent wildlife in the short term. We are referring to those areas as “bridge habitat”, 

suggesting that these more densely-forested areas would be available to wildlife to bridge the 

time between treatment and the attainment of desired conditions across the broader landscape.

Bridge Habitat at the Landscape Scale 

For purposes of this discussion, the landscape is considered to be the 988,764-acre 4FRI

Coconino and Kaibab NFs’ analysis area. All treatment area acreages are calculated based on 

alternative C because it has the most comprehensive set of potential treatments that could impact 

canopy-dependent wildlife and it is the preferred alternative. To how much bridge habitat would 

be available to canopy-dependent wildlife post-treatment at the landscape scale it is important to 

review the acres of treatment and exclusion categories within the project area (table 166). About 

40 percent of the project area was excluded from management consideration under this EIS. 

Two bridge habitat categories (“other projects” and “wilderness, slopes, PACs”) were analyzed at 

the scale of the total project area to demonstrate the patch-mosaic of deferrals versus treated areas 

across the larger landscape. The remainder of the bridge habitat categories that were analyzed 

were within the ponderosa pine treatment area (507,839 acres) scale. This scale was used to 

demonstrate how bridge habitat would persist where mechanical treatments and prescribed fire 

are proposed. The percentages provided for each category are not necessarily additive. Some 

categories are merely subsets of other categories but they provide several different ways of 

looking at how we account for closed-canopy species through project design. As table 166

demonstrated, there is a highly diverse mosaic of forest structure that would vary in terms of 

overall density and openness post-treatment at the landscape scale. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 887
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Table 166. Acres of treatment and non-treatment areas within the 4FRI project area

Area Description Acres

Project Area Total area within 4FRI project 

boundary

988,764 

Exclusions Other projects 213,090 

Special management areas (wilderness, 

research natural areas, inventoried 

roadless areas, Camp Navajo, and 

experimental forests) 

30,668

Non-FS lands 145,156 

Miscellaneous (other cover types, notreatment protected activity center 

(PAC) core areas, inaccessible areas, 

etc.)

11,138 

Total excluded areas within 4FRI 

project boundary

400,052 

Treatment Area Ponderosa pine treatment area 507,839 

Other cover types treatment area 80,876

Area within the proposed treatment 

boundary (includes mechanical

treatment and prescribed burning)

588,716

Other Projects 

Excluded fuels reduction and forest restoration projects account for 213,090 (22 percent) acres of 

the total project area (988,764 acres). We can assume that some proportion of these projects 

would/do retain closed-canopy conditions after treatment, or remain untreated. On average, about 

37 percent of a given project on the Coconino and Kaibab NFs is untreated after implementation 

(Hampton et al. 2008, page 17). Untreated areas are a result of site-scale factors such as 

archaeological and historical sites, wildlife deferrals, funding issues, steep or rocky terrain, and 

areas with insufficient road access. Using the 37 percent estimate for untreated acres after project 

completion, we concluded about 78,843 acres would remain in deferral (i.e., untreated) due to 

site-scale logistics in the total 4FRI project area. There is no data to accurately estimate acres of 

closed-canopy conditions in excluded projects. However, we can assume that some proportion of 

this area would contribute habitat for canopy-dependent species.

Wilderness areas, slopes over 40 percent, and Mexican spotted 

owl protected activity centers (PACs) not identified for mechanical 

treatment 

These areas have not been identified for mechanical treatment and are generally characterized by 

dense forest conditions used by canopy-dependent wildlife. These areas account for 8 percent 

(79,699 acres) of the total project area, including 81 of 99 Mexican spotted owl PACs. The 18 

PACs with mechanical treatments were not included here, but little change in canopy conditions 

are expected in those PACs (see “Affected Environment section of the Wildlife report).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

888 Coconino and Kaibab National Forests 
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Ponderosa Pine Treatment Area Scale (507,839 acres) 

Although the 4FRI proposes to treat over 1⁄2 million acres, treatment intensities are highly variable 

(table 167 and figure 78). Very open treatments include grasslands and savannas. The most 

common treatment in the open category would range from 40 to 55 percent open. 

Figure 78. Relative, post-treatment forest density across the 4FRI project area, alternative C

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 889
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Table 167. Acres of proposed treatment in terms of post-treatment openness

Post-treatment Openness Category Acres Percent of Ponderosa 

Pine Treatment Area

Very Open 67,553 13

Open 228,860 45

Moderately Closed 141,530 28

Closed 69,897 14

Total 507,839 100

Closed and Moderately-Closed Conditions

This category includes mechanically treated and prescribed fire only areas where post-treatment 

conditions maintain 60 to 90 percent forested cover. Included in this category were some Mexican 

spotted owl and northern goshawk habitats. Post-treatment openness would range from 10 to 25 

percent and 25 to 40 percent open. Mexican spotted owl restricted and target/threshold habitats, 

and 18 Mexican spotted owl PACs proposed for mechanical treatment would also be in this 

openness category. About 211,427 acres (42 percent) of the ponderosa pine treatment area would 

be in this category. About 69,897 acres (14 percent) of the ponderosa pine treatment area would 

remain in closed condition (75 to 90 percent forested) post-treatment. This percentage includes all 

those areas listed above, but excludes areas in the 25 to 40 percent open category and areas that 

are not currently in a closed condition.

Mexican Spotted Owl Protected, Target and Threshold, and Restricted Habitats

These habitat designations have specific guidelines per the Mexican spotted owl Recovery Plan to 

ensure denser forest conditions selected for by the owl. Within the 4FRI project, these 

designations could be ranked in terms of their forest density, and therefore their provision for 

other closed-canopy species. Protected habitat is generally densely forested, target and threshold 

habitats are similar to protected habitat, and restricted habitat is less dense than protected but 

more densely forested relative to areas outside Mexican spotted owl designations. In regards to 

4FRI, habitat definitions are specific to pine-oak forest.

• Protected owl habitat accounts for roughly 35,262 acres, which is about 7 percent of the 

ponderosa pine treatment area (table 168, see the “Mexican spotted owl PAC Mechanical” 

and “Protected Prescribed Fire Only” row in the “Post-treatment Density” column). Of this 

total, 26,120 acres are currently in a closed condition. This includes 70 PACs (18 of which are 

proposed for some mechanical thinning) and slopes over 40 percent (proposed for prescribed 

fire only). Protected owl habitat is designed to provide a multi-layered, more closed canopy 

condition relative to the other habitats in the ponderosa pine treatment area, with an emphasis 

on managing for large trees (18 inches d.b.h. or greater). The average basal area for protected 

habitat, based on modeled projections for the year 2020, is 155 square feet per acre.

• Target and threshold habitats include those areas that meet or are approaching nesting and 

roosting habitat conditions. These areas account for about 2 percent (8,692 acres) of the 

ponderosa pine treatment area (see Mexican spotted owl target and Mexican spotted owl

threshold rows in table 168). Of this total, about 7,489 acres are currently in a closed canopy 

condition. Per the 1995 Mexican spotted owl Recovery Plan, target and threshold habitats are 

to be managed for at least 15 percent of total stand density index in each of the three defined 

ponderosa pine tree size classes (12- to18 inches d.b.h., 18- to 24 inches, and over 24 inches). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

890 Coconino and Kaibab National Forests
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

The revised Recovery Plan (USDI FWS 2012) addressed the misinterpretation of nest stand 

data, recommending a stand average of 110 square feet per acre or greater basal area with a 

preponderance of large trees (18 inches d.b.h. and larger).

• Restricted habitat accounts for 66,419 acres (table 168), which is 13 percent of the ponderosa 

pine treatment area. Of this total, 42,538 acres (about 64 percent) are currently in a closed 

condition and another 17,179 acres (about 26 percent) are currently in a moderately closed 

condition. The guidelines for restricted habitat are less specific in order to meet multiple 

objectives and operate in conjunction with ecosystem management and existing management 

guidelines. Objectives for the 4FRI include managing for an abundance of ponderosa pine 

trees 18 inches d.b.h. and greater, maintain tree form oak, and manage for a stand average of 

70 to 90 square feet per acre basal area at the stand level.

Northern goshawk habitat

Closed canopy conditions would also be realized within areas managed according to the northern 

goshawk guidelines. Higher tree density, canopy cover, and larger group sizes would be retained 

in post-fledging family areas (PFAs) and lands outside post-fledging family areas (LOPFAs)

where the current condition and proposed treatments are for 10 to 25 percent interspace (14,933

acres). Denser forest structure would also be retained in northern goshawk nest areas that 

currently have closed conditions (3,234acres). Areas within post-fledging family areas and 

landscapes outside of goshawk post-fledging areas that are proposed for prescribed fire only 

treatments or no treatments that are currently in a closed condition would retain higher tree 

densities and canopy cover post treatment (16,310 acres). Together, these categories account for 

about 7 percent of the ponderosa pine treatment area (about 34,477 acres). In addition, postfledging family areas and landscapes outside of post-fledging areas currently in a moderate closed 

or closed condition and proposed for moderately-dense treatments (25 to 40 percent interspace) 

account for about another 8 percent of the ponderosa pine treatment area. Areas within postfledging family areas, landscapes outside of post-fledging areas and goshawk nest areas that are 

proposed for prescribed fire only treatments or no treatments account for 22,312 acres, which is 

about 4 percent of the ponderosa pine treatment area. Together these two categories account for 

nearly 13 [8+4] percent of the ponderosa pine treatment area and would remain in a moderately 

closed condition post treatment. 

About 41 percent of the ponderosa pine treatment area is landscapes outside of post-fledging 

areas and post-fledging family areas goshawk habitat proposed for low-density condition 

(savanna/grassland restoration and 40 to 55 percent interspace) (table 168).

Wildlife movement corridors

Efforts were taken to ensure habitat connectivity for canopy-dependent wildlife at the landscape 

scale using data from known wildlife movement corridors for black bear, turkey, mule deer, and 

tassel-eared squirrels (AGFD 2011, figure 51). While tassel-eared squirrels are dependent on 

sufficient areas with connected canopies, black bears and mule deer are habitat generalists that 

seek cover, but largely use habitat elements independent of forest canopy closure. Closed canopy 

forest corridors would provide hiding cover for these species. Landscape-scale movement 

corridors were examined on a stand-by-stand basis. Where closed canopy wildlife corridors 

overlapped with proposed mechanical treatments, treatment intensities were adjusted to provide 

closed or moderately-closed canopy conditions post-treatment. In addition to treatment areas that 

would remain in closed or moderately-closed conditions, roughly 4,169 acres were actively 

changed from more open to more closed treatments. Treatments were adjusted in five different 

wildlife movement corridors within the project area. The expected result is the retention of 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 891
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

thermal and hiding cover in addition to closed-canopy conditions to facilitate movement across 

the landscape for a suite of species.

In summary, there are four key considerations with regard to bridge habitat for closed-canopy 

species at the landscape and treatment scales:

1. A patch-mosaic of bridge habitat would remain available for canopy-dependent wildlife. At a 

minimum, 8 percent of the project area would be in deferral due to wilderness, slope, and 

untreated Mexican spotted owl PACs. Potentially another 8 percent of the project area would 

be in deferral as part of other excluded projects.

2. About 1 in 5 acres (nearly 22 percent of the ponderosa pine treatment area) would be 

managed as Mexican spotted owl habitat, creating conditions that also provide habitat for 

other canopy-dependent wildlife.

3. Bridge habitat would be maintained across 42 percent of the ponderosa pine treatment area.

4. Connectivity for closed-canopy species was specifically built into treatment designs 

separately from Mexican spotted owl and northern goshawk guidelines.

Table 168 provides a detailed summary of acreages and percentages for each treatment category 

within the ponderosa pine treatment area in terms of post-treatment density and contributions to 

bridge habitat. Table 168 illustrates the patch-mosaic of post-treatment forest density relative. 

Table 168. Post-treatment contributions to bridge habitat provided by each treatment designation

Treatment Post-treatment Density Landscape 

Scale 

Bridge 

Habitat

Midscale 

Bridge 

Habitat

Total Acres Percent (%) 

of 

Ponderosa 

Pine 

Treatment 

Area

Mechanical Treatment

Low Density Savanna/Grassland 

Restoration

X X 56,372 11

landscapes outside of postfledging areas 40–55% 

Interspace

X Some 141,267 28

post-fledging family areas 

40–55% Interspace

X Some 12,834 3

Low Density 

Total

210,472 41

Moderate 

Density

landscapes outside of postfledging areas 25–40% 

Interspace

X X 52,574 10

Mexican spotted owl

Restricted

X X 62,785 12

post-fledging family areas 

25–40% Interspace

X X 4,406 1

Moderate 

Density Total

119,766 24

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

892 Coconino and Kaibab National Forests
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Treatment Post-treatment Density Landscape 

Scale 

Bridge 

Habitat

Midscale 

Bridge 

Habitat

Total Acres Percent (%) 

of 

Ponderosa 

Pine 

Treatment 

Area

High Density landscapes outside of postfledging areas 10–25% 

Interspace

X X 29,511 6

post-fledging family areas 

10–25% Interspace

X X 2,670 1

High Density 

Total

32,181 6

Very High 

Density

Mexican spotted owl

Threshold

X X 1,892 less than 1

Mexican spotted owl

Target

X X 6,495 1

Mexican spotted owl PAC 

Mechanical

X X 10,284 2

Very High 

Density Total

18,672 4

Prescribed Fire Only Areas and Areas with No Proposed Treatments

Low Density landscapes outside of postfledging areas Prescribed 

Fire Only

Some Some 86,869 17

landscapes outside of postfledging areas No 

Proposed Treatments

Some Some 858 less than 1

Low Density 

Total

87,728 17

Moderate 

Density

post-fledging family areas 

Prescribed Fire Only

X X 3,216 1

post-fledging family areas 

No Proposed Treatments

X X 92 less than 1

Restricted Prescribed Fire 

Only

X X 4,187 less than 1

Restricted No Proposed 

Treatments

X X 1,280 less than 1

Moderate 

Density Total

6,898 1

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 893
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Treatment Post-treatment Density Landscape 

Scale 

Bridge 

Habitat

Midscale 

Bridge 

Habitat

Total Acres Percent (%) 

of 

Ponderosa 

Pine 

Treatment 

Area

High/Very 

High Density

post-fledging family areas 

Nest Area Prescribed Fire 

Only

X X 6,836 1

post-fledging family areas 

Nest Area No Proposed 

Treatments

X X 4 less than 1

Threshold Prescribed Fire 

Only

X X 217 less than 1

Threshold No Proposed 

Treatments

X X 1 less than 1

Target Prescribed Fire 

Only

X X 84 less than 1

Target No Proposed 

Treatments

X X 2 less than 1

Protected Prescribed Fire 

Only

X X 25,714 5

Protected No Proposed 

Treatments

X X 244 less than 1

High/Very 

High Density 

Total

32,122 6

Grand Total 507,839 100

Bridge Habitat at the Restoration Unit Scale

At the restoration unit scale (figure 79), there are additional ways of accounting for bridge 

habitat. Factors contributing to bridge habitat at the restoration unit scale include the area 

remaining in closed and moderately-closed condition post-treatment and areas allocated for old 

growth.

Closed (less than 25 percent Interspace) to Moderately-Closed (25 

to 40 percent Interspace) Canopy Conditions

Table 169 summarizes the range of post-treatment openness by restoration unit under alternative 

C. (Also, see table 64 in the silviculture specialist’s report). The overall range in openness 

indicates a variety of conditions within restoration units post-treatment. Most of the area within 

each restoration unit would range from open to moderately closed canopy conditions. Very open 

and closed conditions would also be represented in each restoration unit, ranging from 2 to 20 

percent and from 4 to 21 percent respectively. Restoration unit 1 has the highest percentage of 

post-treatment habitat in a closed condition, due in large part to ecological conditions such as soil, 

climate, and site quality that result in a denser reference condition relative to the other restoration 

units. Restoration unit 1 also contains the highest proportion of Mexican spotted owl habitat 

relative to the other restoration units. Note that restoration unit 3, 4, and 6 include large areas of 

savanna, grassland, and pine/sage habitats (e.g., Garland Prairie in restoration unit 3, Government 

Prairie in restoration unit 4, and pine-sage in restoration unit 6). Savanna and grassland 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

894 Coconino and Kaibab National Forests
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

restoration is based on soil characteristics, and would total 56,372 acres of very open treatment. 

While maintaining adequate closed canopy conditions has been a topic of concern for some 

stakeholders, the lack of grassland and savanna habitat is a more significant issue ecologically 

(Merola-Zwartjes 2005, North American Bird Conservation Initiative 2011, Brown and Makings 

2014). 

Figure 79. Restoration unit boundaries within the 4FRI treatment area

Table 169. Proposed post-treatment openness condition (percent) by restoration unit

restoration unit Very Open Open Moderately Closed Closed 

1 11% 40% 29% 21%

3 13% 40% 32% 15% 

4 20% 52% 18% 10% 

5 14% 58% 24% 4% 

6 2% 41% 47% 11% 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 895
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Old-growth Allocations 

Desired conditions for old growth in ponderosa pine under the Coconino forest plan direction: 

• 20 trees per acre at 18 inches d.b.h. and greater and at least 180 years old,

• one snag per acre at least 14 inches d.b.h. and 25 feet tall, 

• two down dead tree pieces 12 inches in diameter and 15 feet long, 

• basal area at least 90 square feet, and

• canopy cover of at least 50 percent. 

Guidelines from the Kaibab forest plan include: 

Multi layered canopy, interlocking canopy and old growth

Ponderosa Pine Desired Condition: Fine-scale: Crowns of trees within the mid-aged to old 

groups are interlocking or nearly interlocking and consist of approximately 2 to 40 trees per 

group. Where Gambel oak comprises more than 10 percent of the basal area, it is not uncommon 

for canopy cover to be greater than 40 percent. Mid-scale: The ponderosa pine forest vegetation 

community is characterized by variation in the size and number of tree groups depending on 

elevation, soil type, aspect, and site productivity. The mosaic of tree groups generally comprises 

an uneven-aged forest with all age classes and structural stages present. Forest conditions in some 

areas contain 10 to 20 percent higher basal area in mid-aged to old tree groups than in the general 

forest (e.g. goshawk post-fledging family areas, Mexican spotted owl nesting and roosting 

habitat, drainages, and steep north facing slopes). Landscape: The ponderosa pine forest 

vegetation community is a mosaic of forest conditions composed of structural stages ranging 

from young to old trees. The forest is generally uneven-aged and open. Groups of old trees are 

mixed with groups of younger trees. Denser tree conditions exist in some locations such as north 

facing slopes, canyons, and drainage bottoms. Old growth occurs throughout the landscape, 

generally in small areas as individual old growth components, or as clumps of old growth. Old 

growth components include old trees, dead trees (snags), downed wood (coarse woody debris) 

and structural diversity. The location of old growth shifts on the landscape over time as a result of 

succession and disturbance (tree growth and mortality). 

Vegetation Management in All Forested Communities Guideline: Projects in forested 

communities that change stand structure should generally retain at least historic frequencies of 

trees by species across broad age and diameter classes at the mid-scale. On suitable timberlands, 

projects should retain somewhat higher frequencies of trees across broad diameter classes to 

allow for future tree harvest. Project design should manage for replacement structural stages to 

assure continuous representation of old growth over time. 

The microhabitat diversity provided by the old trees, multi-storied canopies, snags, and downed 

logs within old growth areas are rare across the landscape. Functional Mexican spotted owl 

habitat and portions of northern goshawk habitat are comprised of old-growth forest (see chapter 

1, existing and desired conditions for more details). The Coconino forest plan direction is to 

allocate and maintain at least 20 percent old growth forest within each ecosystem management 

unit (EMU). For the purposes of the 4FRI project, an ecosystem management unit resembles the 

4FRI restoration units, therefore old growth was allocated by restoration unit (see table 38 in the 

silviculture specialist report).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

896 Coconino and Kaibab National Forests 
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Forty percent of the ponderosa pine treatment area on the Coconino NF (127,009 acres) and 35 

percent (65,810 acres) of the Kaibab NF are allocated for old growth. Old-growth conditions do 

not currently occur in sufficient quantity on the Coconino and Kaibab NFs. Areas selected for 

old-growth allocation represent current conditions that most closely resemble old growth. The 

4FRI has incorporated a large tree retention policy and alternative C (the preferred alternative) 

would also include an old tree protection strategy. It is the intent of the 4FRI project to manage 

allocated areas according to old growth standards to move them towards mature, diverse forests 

over time. Similar provisions were made for pinyon-juniper habitats. A portion of these areas 

currently support closed canopy conditions and will continue to do so. More closed canopy 

conditions will develop in these areas over time, contributing further to closed canopy habitat. 

Bridge Habitat at the Mid-Scale 

Bridge habitat for canopy-dependent wildlife would also occur at the mid-scale in the 4FRI 

project. Some densely forested areas would be deferred simply due to the vagaries of 

implementation. The 4FRI project also intentionally plans for bridge habitat at the mid-scale 

through its desired conditions, design features/best management practices/mitigation, the old and 

large tree implementation plans, and the silvicultural design and implementation guide. These 

factors are described below. 

Desired Conditions for Bridge Habitat 

The 4FRI EIS describes treatments intended to meet the described desired conditions. During 

implementation of the 4FRI project, site specific prescriptions would be developed to implement 

the treatments and they too would be based on meeting desired conditions. The following subset 

of desired conditions would help ensure bridge habitat is maintained in the proposed project area 

(see chapter 1 purpose and need for the full set of desired conditions): 

• The desired condition is to restore tree density and pattern to the natural range of variability, 

while meeting forest plan requirements for Mexican spotted owl protected, target, threshold, 

and restricted habitats and goshawk nest areas. 

• At the fine scale, the desired condition is a ponderosa pine ecosystem consisting of groups of 

trees that typically range in size from 0.1 acre to 1.0 acre in size. Tree groups would exceed 

1-acre in size as needed to respond to site-specific conditions such as the presence of presettlement trees or mature trees that are developing old-tree characteristics.

• Tree groups in the mid-age and older VSS classes would have canopies that provide 

moderate-to-closed conditions and connectivity for wildlife that are dependent on this type of 

habitat. These conditions are widely distributed on the landscape. At the landscape scale 

(extent of ponderosa pine vegetation), all canopy density conditions exist and provide for 

heterogeneity. 

• Moderate-to-closed canopy conditions (and the connectivity between groups supporting these 

conditions) are met in a variety of ways: habitat for goshawk and Mexican spotted owl, steep 

slopes, buffers for several resources including bald eagle roosts, other raptor nests, heron 

rookeries, caves, sink holes, and special designations that would not be treated (including 

wilderness and most research natural areas).

• There is a need to use management strategies that: (1) promote tree regeneration and 

understory vegetation, (2) move tree canopy density, tree group pattern and interspaces 

towards the historic range of variability, and (3) provide a mix of open, moderately-closed, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 897
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

and closed-canopy conditions at the fine (group) to landscape (ponderosa pine vegetation) 

scale.

• There is a need to implement uneven-aged management strategies and manage for highdensity, relatively uneven-aged stands in Mexican spotted owl restricted habitat, including 

target and threshold habitats to meet forest plan and Mexican spotted owl Recovery Plan 

requirements.

Wildlife Design Features/Best Management Practices/Mitigation 

Measures 

Design features, best management practices, and mitigation measures are intended to avoid or 

minimize adverse effects of management actions on natural resources. They provide safeguards 

for wildlife and other resources during the implementation phase. Some of these actions would 

result in a well-distributed network of bridge habitat for wildlife across the larger landscape (table 

170). A more complete list of design features, BMPs, and mitigation can be found in appendix C 

and appendix D of the EIS (the silvicultural design and implementation guide). Selected 

silvicultural design features that contribute to bridge habitat are described in greater detail below. 

Table 170. Design features, BMPs, and mitigation measures contributing to bridge habitat

Species/Resource Description

Bald Eagle Nests No mechanical treatments would occur within a 300-foot radius of bald eagle 

nest trees (about a 6 acre patch for each nest).

Bald Eagle Roosts No mechanical treatments will occur around confirmed bald eagle roost sites 

(300’ radius around roosts on the Coconino NF and a 10-chain radius on the 

Kaibab NF).

Vegetation Structural Stages 4, 

5, and 6

Within group density – Manage mid-aged tree groups for a range of density 

and structural characteristics by thinning approximately 50 percent of the midaged groups to the lower range of desired stocking conditions, approximately 

20 percent each to the middle and upper range of desired stocking conditions, 

and approximately 10 percent would not be thinned.

Within group structure – Enhance and maintain mid-aged, mature, or old 

group structure by retaining individual and clumps of vigorous ponderosa pine 

seedlings, saplings, and poles within the larger group.

Caves and Sinkholes A 300-ft no mechanical treatment buffer would be designated around 34 cave 

entrances (about 6.5 acres each) and around an undetermined number of sink 

holes (i.e., karst) to protect cave ecosystems from siltation, protect human 

health and safety, and reduce potential disturbance to roosting bats. Existing 

roads could be used for mechanical harvest but no new skid trails would be 

created.

Dependable Waters Hiding cover would be maintained near dependable waters by not targeting 

drainages for interspaces and openings and through implementation of 

watershed BMPs.

Great Blue Herons No dominant or co-dominant trees would be cut in rookeries. Nest trees will 

be prepped prior to implementing prescribed fire.

Mexican spotted owl Trees greater than 24 inches d.b.h. would not be harvested.

Mixed Conifer 4FRI activities would not include mechanical or fire treatments in the mixed 

conifer inclusions within the ponderosa pine forest (e.g., Mexican spotted owl

core areas in treated PACs). Similarly, islands of ponderosa pine within mixed 

conifer forest would not be treated as part of this project.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

898 Coconino and Kaibab National Forests 
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Species/Resource Description

Northern Leopard Frogs A no-treatment buffer (no thinning, no direct ignition) would extend 1⁄4-mile 

from tanks with known northern leopard frog sites, or be designated along 

logical topographic breaks. In some cases, the district wildlife biologist could 

work with implementation teams to determine the habitat protection buffer 

boundary.

Northern Leopard Frogs A 200-ft protection zone (100 feet either side of streamcourse) would be 

established around designated stream courses for northern leopard frogs. 

There would be no thinning and no direct ignition of prescribed burning 

within the protection zones. Designated skid trail crossings through the buffer 

zones are allowed.

Raptor Nests No mechanical treatment buffers would be designated around raptor nests. 

Sharp-shinned hawk nests = 10 acres, Cooper’s hawk nests = 15 acres, osprey 

nests = 20 acres, other raptors = no mechanical treatment buffers within a 50 

foot radius (about 0.2 of an acre).

Snags Emphasize retention of snags at least 18 inches d.b.h.. 

Snags Retain trees at least 18 inches d.b.h. with dead tops, cavities, and lightning 

strikes wherever possible to provide cavity nesting/foraging habitat (i.e., the 

living dead).

Streamside Management Zones On areas to be prescribed burned, establish filter strips (also known as 

streamside management zones). Applies to riparian and non-riparian 

streamcourses. Deferral widths range from 35 to 120 feet on each side of the 

streamcourse.

Turkeys Retain medium to high canopy cover in pine stringers in the pinyon-juniper 

transition zone and target low-severity burns to retain yellow pine and 

roosting cover.

Wildlife Cover Gambel oak, juniper, and pinyon species may only be cut as necessary to 

facilitate logging operations (skid trails and landings) and by design as 

follows:

Within UEA, IT, SI, and wildland-urban interface treatments, pinyon/juniper 

seedling/sapling and young/mid-aged trees may be cut within a 40-foot radius 

of individual or groups of old ponderosa pine (as defined in the old tree 

implementation strategy).

Within savanna and wildland-urban interface pinyon-juniper mechanical 

treatment areas, pinyon/juniper seedling/sapling and young/mid-aged trees 

may be cut.

Habitat Heterogeneity Manage mid-aged tree groups for a range of density and structural 

characteristics by thinning approximately 50 percent of the mid-aged groups 

to the lower range of desired stocking conditions, approximately 20 percent 

each to the middle and upper range of desired stocking conditions and 

approximately 10 percent remain unthinned.

Canopy Cover/ Habitat 

Heterogeneity

Enhance and maintain mid-aged, mature and old group structure by retaining 

individual and clumps of vigorous ponderosa pine seedlings, sapling and 

poles within the larger group.

Old and Large Tree Implementation Plans 

In response to public input from several stakeholders requesting a design feature that included no 

cutting of pre-settlement old-growth trees, the 4FRI project would implement an Old Tree 

Protection Strategy. Old trees (approximately 150 years and older) would be retained regardless 

of their diameter within the 4FRI project area. Exceptions would be made for threats to human 

health and safety and those rare circumstances where the removal of an old tree is necessary in 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 899
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

order to prevent additional habitat degradation (e.g., moving a road out of stream channel). 

However, exceptions are not expected. Retention of old trees as individuals and groups will 

contribute significantly to bridge habitat, providing old growth structure for wildlife in the short 

term.

In response to input from some stakeholders, alternative C includes a Large Tree Retention 

Strategy. The strategy identifies areas where post-settlement trees 16 inches d.b.h. and larger

would be retained and exceptions where removal of trees 16 inches d.b.h. and larger would be 

necessary to move toward ecological desired conditions. Elsewhere, those trees would be 

retained, adding to the mid-scale provision of bridge habitat for canopy-dependent wildlife.

Silvicultural Design and Implementation Guide 

Vertical and horizontal heterogeneity are important components of wildlife habitat in ponderosa 

pine forests. Restoring variability and diversity to forest structure and pattern is a central desired 

condition of the 4FRI project. The silvicultural design and implementation guide (hereafter 

“implementation guide”; appendix D, attachment 1) is intended to translate desired conditions, 

management direction, and design features into guidance for the district silviculturists responsible 

for writing site-specific prescriptions in the implementation phase. The intent is to balance the 

need for flexibility to adapt to on-the-ground realities while ensuring adequate sideboards to 

minimize or avoid impacts to important resources. Below are examples of how maintenance of 

bridge habitat would be ensured through the implementation guide. 

Implementation Guide—Mexican Spotted Owls 

Several features of the implementation guide treatment design for the Mexican spotted owl would 

serve as a proxy for other canopy-dependent wildlife. Design features for the owl are too 

numerous to list here, but those listed below serve to illustrate specifically how bridge habitat 

would be maintained at the mid-scale:

• Each PAC has a 100-acre (or greater) core area that would not have mechanical treatments. 

• Each PAC to be thinned would have an upper diameter limit of trees that may be cut.

• Manage for 110 to 150 square feet of basal area (depending on alternative) in protected, 

target, and threshold habitats; basal area in restricted other habitat would range from 70 to 90 

ft2

. 

• Individual trees and tree groups would occupy approximately 60 to 75 percent of the area 

within restricted other habitat.

• Treatments are designed to manage for old age trees and to sustain as much old forest 

structure as possible across the landscape. Treatments would follow the Old Tree Protection 

Plan.

• No trees larger than 18 inches d.b.h. would be cut in protected habitat and no trees larger than 

24-inches d.b.h. would be cut in restricted habitats. 

• In restricted other habitat, tree groups would, on average, range in size from 0.1 to 1 acre; 

northerly aspects and highly productive microsites would have larger average group sizes.

• In restricted other habitat, manage for tree groups with different age classes by retaining 

individual and clumps of vigorous ponderosa pine seedlings, saplings and poles within the 

larger mid-aged, mature or old tree groups. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

900 Coconino and Kaibab National Forests 
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

• In restricted other habitat, interspace width between tree groups would average from 25 to 60 

feet with a maximum width of 200 feet. 

• Manage for large oak and pine snags.

• Retain non-ponderosa pine species in the canopy.

• Retain young trees growing within the dripline of old trees in PACs to maximize roosting 

potential.

Implementation Guide—Northern Goshawks 

Several features of the treatment design for the northern goshawk would serve as a proxy for 

other canopy-dependent wildlife. Design features that would contribute towards this goal are

numerous, but a few key features are highlighted to illustrate maintenance of bridge habitat. 

Relevant design features from table 170 are not repeated below. 

• Treatments are designed to manage for old age trees, following the Old Tree Protection Plan.

• Treatments would strive to attain an overall stand average density ranging from 40 to 90 

square feet of basal area and 15 to 40 percent of maximum stand density index. Density 

would vary within this range depending on treatment type, intensity, existing stand structure, 

and site conditions. 

• Tree group density would be managed to meet the canopy cover requirement of 40 plus 

percent within mid-aged forest (VSS4), mature forest (VSS5), and old forest (VSS6) tree 

groups and to assure that immature tree groups (VSS 2 and 3) are managed to maintain tree 

stocking necessary to provide for desired canopy cover as the groups mature.

• To achieve overall stand average density targets, basal area and stand density index within 

tree groups would often need to exceed average target values. Table 171 illustrates how this 

could work for basal area (see the implementation guide for greater detail). For example, a 

treatment intensity of 10 to 25 should result in 10 to 25 percent of a stand open and 75 to 90 

percent treed. If the objective for a specific stand was 20 percent interspace and 80 percent 

trees, including 10 percent regeneration, then 70 percent of the treed area would be groups 

and individual tree. If the overall target basal area was 60, tree groups in the 70 percent treed 

area would have to average 86 basal area. 

• Within-group structure specific to mid-aged to old tree classes (VSS 4 to 6) would include 

open understories, interlocking tree crowns, abundant large limbs, and shade. 

• Tree groups, on average, would range in size from 0.1 to 1 acre. Overall average group size 

would vary within this range depending on existing stand structure, and pre-settlement tree 

evidence.

• Maximum interspace width of 200 feet. 

• Maximum regeneration opening size of 4 acres or 200 feet wide. 

• One group of reserve trees, three to five trees per group, would be left in created regeneration 

openings larger than 1 acre in size.

• Manage for large oaks.

• Within the proposed Arizona Department of Game and Fish research areas, tree group size is 

dependent on experimental design and would range in size from 1 to 15 acres. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 901
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

Table 171. Excerpt from section D of the 4FRI implementation guidelines

Treatment 

Intensity

Percent Area Percent Area with Tree Cover

Average Group Basal Area to Achieve 

Overall Basal Area

Interspace Tree

Groups & 

Individuals Regeneration 40 50 60 70 80 90

10–25 10 90 90 0 56 67 78 89 100

85 5 59 71 82 94

80 10 63 75 88 100

75 15 67 80 93 107

70 20 71 86 100 114

15 85 85 0 59 71 82 94 106

80 5 63 75 88 100

75 10 67 80 93 107

70 15 71 86 100 114

65 20 77 92 108 123

20 80 80 0 63 75 88 100 113

75 5 67 80 93 107

70 10 71 86 100 114

65 15 77 92 108 123

60 20 83 100 117 133

Conclusions about Bridge Habitat in the 4FRI Project 

Closed-canopy, high-density, mid-aged forest conditions are currently common in the 4FRI 

project area. To achieve ecological objectives (e.g., achieve or move towards the natural range of 

variability, increase forest resiliency to continuing climate change, maintain existing large and old 

trees and increase large tree growth rates) and modify landscape-scale fire behavior, continuity of 

canopy connectedness and overall forest density must be significantly reduced. Given the 

evolutionary history of canopy-dependent wildlife on this landscape, we can assume that closedcanopy conditions were present within the natural range of variability. The question of how much 

of the pre-settlement landscape was in this condition remains unanswered, but the literature, 

including historic stand inventories, stand reconstructions, and site descriptions, combined with 

soil mapping and photo documentation, consistently concludes that this was not the predominant 

condition. Nevertheless, the 4FRI project proposes to maintain more closed canopy conditions 

than likely occurred historically. Some closed canopy forest areas are proposed for long-term 

management (e.g., Mexican spotted owl habitats) and others could change the next time a 

management planning analysis is conducted on this landscape (e.g., nest and roost sites for other 

raptor species that might not be in use in the future). Together, they would provide bridge habitat 

for canopy-dependent wildlife to span the time between restoration treatments and achievement 

of desired conditions. 

In summary, bridge habitat would be managed for at the mid-scale in four key ways: 

1. Desired conditions that strive to attain the full range of natural variability which includes 

areas for canopy-dependent wildlife, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

902 Coconino and Kaibab National Forests 
Appendix G – Bridge Habitat for Canopy-dependent Wildlife

2. Design features/BMPs/mitigation measures would result in a well-distributed mosaic of 

small-scale deferrals in a landscape dominated by prescribed fire and mechanical treatments,

3. Implementation guidance for Mexican spotted owl habitat that retains higher forest density 

and canopy cover relative to the surrounding landscape, and 

4. Implementation guidance for northern goshawks that allows for higher density within tree 

groups given the contribution of interspaces and openings to overall stand averages. 

About 40 percent of the landscape within the 4FRI project boundary would be deferred from 

treatment (table 166). Of those acres treated, about 42 percent would remain in a moderatelyclosed to closed condition after treatment. Landscape-scaled movement corridors that were 

independent of site-specific treatment assessments were included in the project design. Old 

growth allocations account for 38 percent of the ponderosa pine treatment area and are welldistributed across the landscape and would be managed for closed canopy conditions in the longterm. A patch-mosaic of small deferrals would be created all across the 4FRI project area to 

maintain wildlife-related features such as sinkholes and hiding cover. Implementation guidance in 

Mexican spotted owl and northern goshawk habitats includes provisions for higher tree densities

and canopy cover relative to the surrounding landscape. All of these measures would provide 

bridge habitat for canopy-dependent wildlife. It is our assumption that by providing more closedcanopy conditions than likely occurred historically, adequate habitat will be provided habitat for 

canopy-dependent wildlife. Monitoring would be an important test of this assumption, and 

adaptive management would be employed if outcomes prove otherwise.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 903

Appendix H – Glossary

Active crown fire – A fire in which a solid flame develops in the crowns of trees, but the surface 

and crown phases advance as a linked unit dependent on each other. 

Adaptive management – Provides an implementation tool that goes beyond the “predictmitigate-implement” model and incorporates an “implement-monitor-adapt” strategy that 

provides flexibility to account for inaccurate initial assumptions, to adapt to changes in 

environmental conditions, or to respond to subsequent monitoring information that indicates that 

desired conditions are not being met (Forest Service 1909.14.1). 

Age class – A distinct aggregation (grouping) of trees originating from a single natural event 

commonly consisting of trees of similar age.

Basal area (BA) – The cross-sectional area of all trees, measured in square feet per acre.

Biomass – Multiple definitions include: organic matter produced by plants and other 

photosynthetic organisms; total dry weight of all living organisms that can be supported at each 

level of a food chain or web; dry weight of all organic matter in plants and animals in an 

ecosystem; plant materials and animal wastes that function as fuel for fire.

Bridge Habitat- Bridge habitat refers to post-treatment conditions within the 4FRI project area 

that would provide habitat for canopy-dependent wildlife in the short term. Bridge habitat 

suggests more densely-forested areas would be available to wildlife to bridge the time between 

treatment and the attainment of desired conditions across the broader landscape.

Burn – An effect produced by heating. To undergo combustion, consuming fuel and giving off 

light, heat, and gasses. Also, an area where fire has occurred in the past.

Canopy – A layer of foliage, generally the uppermost layer, in a forest stand. Can be used to refer 

to midstory or understory vegetation in multilayered stands. 

Canopy base height (CBH) – A critical factor in crown fire initiation and can be used as an 

indicator of the potential for crown fire initiation (Agee and Skinner 2005, Stratton 2009, Scott 

2003). The desired condition is for CBH to be greater than 18 feet in ponderosa pine. 

Canopy bulk density (CBD) – For ponderosa pine and pine-oak stands. CBD is a good indicator 

of potential active crown fire (Stratton 2009, Scott 2003). The desired condition is for average 

CBD to be less than 0.05 kg/m3 in ponderosa pine.

Canopy characteristics – Canopy characteristics include canopy cover, canopy base heights 

(CBH), and canopy bulk density (CBD) which contribute significantly toward the type of fire that 

can occur (Scott and Reinhardt 2001). Canopy cover, CBH, and CBD directly affect the incidence 

and behavior of crown fires and are used for modeling potential fire behavior (Scott 2003, Scott 

and Reinhardt 2005, Agee and Skinner 2005). 

Canopy cover – As used in modeling fire in the fire ecology analysis, canopy cover is the 

horizontal fraction of the ground that is covered directly overhead by tree canopy, the percent of 

vertically projected canopy cover in the stand (Scott and Reinhardt 2005).

Canopy density – In this analysis, the term “openness” is used interchangeably with the term 

“canopy density.” Openness is the percentage of the forested area that is grass/forb/shrub 

interspace.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 905
Appendix H – Glossary

Clean Water Act (CWA) – Act that provides the structure for regulating pollutant discharges to 

waters of the United States. The act’s objective is “...to restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters,” and is aimed at controlling both point 

and nonpoint sources of pollution. The U.S. EPA administers the act, but many permitting, 

administrative, and enforcement functions are delegated to state governments. In Arizona, the 

designated agency for enforcement of the Clean Water Act is the Arizona Department of 

Environmental Quality (ADEQ).

Closed road – Intermittent service roads that are closed to vehicular traffic. However, these roads 

may be available and suitable for nonmotorized uses. The closure period must exceed 1 year. 

Basic custodial maintenance is performed to keep damage to adjacent resources to an acceptable 

level and to perpetuate the road to facilitate future management activities. Emphasis is normally 

given to maintaining drainage facilities and runoff patterns. Planned road deterioration may occur 

at this maintenance level (USDA Forest Service 2005). 

Clump – A tight cluster of two to five trees of similar age and size originating from a common 

rooting zone that typically lean away from each other when mature. A clump is relatively isolated 

from other clumps or trees within a group of trees. A stand-alone clump of trees can function as a 

tree group. 

Condition class (reference FRCC) – A measure of departure from reference conditions that can 

be used to determine how “at risk” key ecosystem components are in the event of a disturbance 

event such as fire.

Conditional crown fire – A crown fire that is dependent on ladder fuels in adjacent stands in 

order for fire to access the crowns. In an area with conditional crown fire, ladder fuels are 

insufficient in a stand for crown fire to initiate, but canopy fuels are sufficient to support crown 

fire if it moves in from an adjacent stand.

Contemporary uses – The use of the forest for traditional and cultural purposes by tribes that 

have aboriginal ties to the land.

Controlled burn – Synonymous with prescribed fire. 

Coarse woody debris (CWD) – Woody debris larger than 7.5 cm (3 inches) in diameter (Graham 

et al. 1994). 

Cover type – Refers to a forest or woodland type, such as ponderosa pine, pine-oak, or mixedconifer.

Crown fire – A fire that advances from top to top of trees or shrubs more or less independent of a 

surface fire. Crown fires are sometimes classed as independent, conditional, or dependent (active 

or passive) to distinguish the degree of independence from the surface fire. Crown fires are 

common in coniferous forests and chaparral shrublands. 

Declining – The senescent (aging) period in the lifespan of plants that (for trees) includes the 

presence of large dead and/or dying limbs, snag tops, large, old lightning scars, and other 

characteristics that indicate the later life stages.

Density-related mortality – Based upon established forest density/vigor relationships, densityrelated mortality begins to occur once the forest reaches 45 to 50 percent of maximum stand 

density, and mortality is likely at density levels over 60 percent of maximum stand density (Long 

1985).

Diameter at breast height (d.b.h.) – A standard measure of tree diameter measured 

approximately 1.5 meters (4.5 feet) above the ground. 

Disturbance – Any relatively discrete event or series of events, either natural or human induced 

that causes a change in the existing condition of an ecosystem, community, or population 

structure and alters the physical environment.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

906 Coconino and Kaibab National Forests 
Appendix H – Glossary

Disturbance regime – A set of recurring conditions due to a variety of disturbances (e.g., fire, 

flooding, insect outbreak) and their interaction, which characterize an ecosystem within a historic, 

natural, or human-induced context, within a given climate. This set of recurring conditions 

includes a specific range for each of the attributes of these disturbances. These attributes include: 

frequency, rotation period, intensity, severity, seasonality, patch size and distribution, residual 

structure, causal agent, the relative influence of each causal agent, and how they interact (Suffling 

and Perera 2004). The attributes researchers choose to represent a regime will vary depending on 

a researcher’s area of interest (Sousa 1984, Pickett and White 1985, Agee 1993, Skinner and 

Chang 1996, Turner et al. 2001). An accurate description of a disturbance regime must include the 

full range of disturbance events, including those that are rare. 

Diversity – The distribution and abundance of different plant and animal communities and 

species within the area covered by a land and resource management plan. 

Drought – Periods of abnormally dry weather sufficiently long enough to cause a serious 

hydrological imbalance. Drought is a relative term; therefore, any discussion in terms of 

precipitation deficit must refer to the particular precipitation-related activity that is under 

discussion. For example, there may be a shortage of precipitation during the growing season 

resulting in crop damage (agricultural drought), or during the winter runoff and percolation 

season affecting water supplies (hydrological drought). 

Duff – The fermentation and humus layer lying below the litter layer and above mineral soil; 

consisting of partially decomposed organic matter whose origins can still be visually determined, 

as well as the fully decomposed humus layer. This layer does not include the freshly cast material 

in the litter layer, nor in the post-burn environment ash (Brown 2000). The top of the duff is 

where needles, leaves, fruits, and other castoff vegetative material have noticeably begun to 

decompose. Individual particles usually are bound by fungal mycelia. The bottom of the duff is 

mineral soil. There is a gradient, not a clear division between litter and duff.

Ecological restoration – The process of assisting the recovery of resilience and adaptive capacity 

of ecosystems that have been degraded, damaged, or destroyed. Restoration focuses on 

establishing the composition, structure, pattern, and ecological processes necessary to make 

terrestrial and aquatic ecosystems sustainable, resilient, and healthy under current and future 

conditions (USDA Forest Service 2008). 

Ecosystem resiliency - The ability of an ecosystem to absorb and recover from disturbances 

without altering its inherent functions (SER 2004) 

Ecosystem sustainability – The capacity of ecosystems to maintain ecosystem services in 

perpetuity without degradation of its productivity and function at all scales. For example, in the 

context of a restoration framework, sustainability results in maintaining the key elements in space 

and time (USDA Forest Service 2013).

Environmental justice – The fair treatment and involvement of all people regardless of race, 

color, national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies. The White House, with Executive 

Order 12898, elevated environmental justice issues to the Federal agency policy agenda. EO 

12898 instructs each Federal agency to identify and address “disproportionately high and adverse 

human health or environmental effects of its programs, policies, and activities on minority 

populations and low-income populations” (Clinton 1994). 

Ephemeral stream – A stream that flows only briefly during and following a period of rainfall in 

the immediate locality.

Erosion – The wearing away of the land surface by rain or irrigation water, wind, ice, or other 

natural or anthropogenic agents that abrade, detach, and remove geologic parent material or soil 

from one point on the earth’s surface and deposit it elsewhere.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 907
Appendix H – Glossary

Even-aged stand – A stand of trees composed of a single age class in which the range of tree 

ages is usually plus or minus 20 percent of rotation (SAF 2008). 

Even-aged management – The application of a combination of actions that result in the creation 

of stands in which trees of essentially the same age grow together. Managed even-aged forests are 

characterized by a distribution of stands of varying ages (and, therefore, tree sizes) throughout the 

forest area. The difference in age between trees forming the main canopy level of a stand usually 

does not exceed 20 percent of the age of the stand at harvest rotation age. Regeneration in a 

particular stand is obtained during a short period at or near the time that a stand has reached the 

desired age or size for regeneration and is harvested. Clearcut, shelterwood, or seed tree cutting 

methods produce even-aged stands. 

Evidence-based restoration – Using indicators of trees standing at the time of settlement that are 

no longer present as living trees including snags, downed logs, stumps, and stump holes to guide 

restoration objectives (ERI 2009). 

Fire-adapted ecosystem – An associated group of plant and animals that have made long term 

genetic changes in response to the presence of fire in their environment.

Fire ecology – The study of fire’s interaction with ecosystems.

Fire line intensity – Rate of heat release in the flaming front. 

Fire regime – A set of recurring fire conditions that characterize an ecosystem, within a historic, 

natural, or human induced context, within a given climate. This set of recurring conditions 

includes a specific range of attributes. Sugihara et al. (2006) use the following attributes: 

seasonality, frequency (fire return interval), intensity, severity, size, spatial complexity, and fire 

type. An accurate description of a fire regime will include the full range of fire events, including 

those that are rare and connect to the larger disturbance regime which contains the fire regime as 

a subset. There are five fire regimes:

Fire Regime I – 0 to 35 year frequency and low (surface fires most common, isolated torching 

can occur) to mixed severity (less than 75 percent of dominant overstory vegetation replaced);

Fire Regime II – 0 to 35 year frequency and high severity (greater than 75 percent of dominant 

overstory vegetation replaced);

Fire Regime III – 35 to 100+ year frequency and mixed severity;

Fire Regime IV – 35 to 100+ year frequency and high severity; and 

Fire Regime V – 200+ year frequency and high severity. 

Fire regime condition class (FRCC) – An ecological evaluation protocol that uses three classes 

for describing the relative degree of departure from historical fire regimes.

Fire return interval – The number of years between two successive fires in a designated area 

(i.e., the interval between two successive fires); the size of the area must be clearly specified 

(McPherson and others 1990). 

Fire risk – In the context of technical risk assessments, the term “risk” considers not only the 

probability of an event, but also includes values and expected losses. Within wildland fire, “risk” 

refers only to the probability of ignition (both man- and lightning-caused) (Hardy 2005). 

Fire type – Flaming front patterns that are characteristic of a fire.

First order fire effects – Effects resulting directly from the fire, such as fuel consumption and 

smoke production. 

Forage – Browse and herbage which is available and can provide food for animals or be 

harvested for feeding; or to search for or consume forage (ITR 1734-4). 

Forbs – A broadleaved, herbaceous plant (e.g., columbine).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

908 Coconino and Kaibab National Forests 
Appendix H – Glossary

Forest health – The perceived condition of a forest derived from concerns about such factors as 

its age, structure, composition, function, vigor, presence of unusual levels of insects or disease, 

and resilience to disturbance. Note perception and interpretation of forest health are influenced by 

individual and cultural viewpoints, land management objectives, spatial and temporal scales, the 

relative health of the stands that comprise the forest, and the appearance of the forest at a point in 

time (SAF 2008). 

Fuel loads – The amount of combustible material present per unit area.

Group – A cluster of two or more trees with interlocking or nearly interlocking crowns at 

maturity surrounded by an opening. The size of tree groups is typically variable depending on 

forest community and site conditions and can range from fractions of an acre (a two-tree group) 

to many acres. Trees within groups are typically non-uniformly spaced, some of which may be 

tightly clumped (SAF 2008). 

Group selection – A cutting procedure which creates a new age class by removing trees in groups 

or patches to allow seedlings to become established in the new opening (SAF 1998). 

Habitat: A place where an animal or plant normally lives, often characterized by a dominant 

plant form or physical characteristic. Often described for individual species, e.g., spotted owl 

habitat, it is usually used as a generalization of where an animal may live (Fire Ecology Report 

2013). 

Heritage strategy – A strategy developed in consultation with the Arizona State Historic 

Preservation Officer to assist in reaching a “No Adverse Effect” determination for the project (see 

heritage specialist report).

Heterogeneity – For the purposes of this analysis, heterogeneity refers to having biodiversity in 

terms of habitat and forest structure across the landscape.

Historic range of variation (HRV) – Refers to ecosystem composition, structure, and process for 

a specified area and time period. Historic range of variation (HRV) is often used to determine our 

best estimate of “natural” conditions and functions and, thus, is often our best estimate of the 

natural range of variability (NRV). Ecosystems change over time. It is assumed that native 

species have adapted over thousands of years to natural change and that change outside of NRV 

may affect composition and distribution of species and their persistence (Fire Ecology Report 

2013). 

Hydrologic condition – The current state of the processes controlling the yield, timing, and 

quality of water in a watershed (FSM 2521.05).

Impaired waters – Under section 303(d) of the 1972 Clean Water Act, states, territories, and 

authorized tribes are required to develop lists of impaired waters. These impaired waters do not 

meet water quality standards that states, territories, and authorized tribes have set for them, even 

after point sources of pollution have installed the minimum required levels of pollution control 

technology. The law requires that these jurisdictions establish priority rankings for waters on the 

lists and develop TMDLs for these waters. See the water quality and riparian specialist report for 

additional information.

Intermediate thinning – The thinning or cutting of trees to improve the composition, structure, 

condition, health, and growth of remaining trees (SAF 1998). 

Interspace(s) – The open space between tree groups intended to be managed for grass/forb/shrub 

vegetation during the long term. Interspace(s) may include scattered single trees.

Invasive – any species which can establish, persist, and spread in an area, and be detrimental or 

destructive to native ecosystems, habitats, or species, and is difficult to control or eradicate.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 909
Appendix H – Glossary

Kaibab health focus: Multi-stakeholder, collaborative process that prioritized areas most in need 

of treatment. Primary indicators were related to high risk and high value such as those with closed 

canopies containing large trees. These areas were identified as high priority for restoration 

because they already contain many components of the desired condition, and a single treatment 

may come close to meeting the desired condition, but if lost, would take centuries to replace. See 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5120031.pdf. 

Ladder fuel – Fuel, such as branches, shrubs, or an understory layer of trees, which allow a fire 

to spread from the ground to the canopy. 

Landscape scale – A spatial scale and extent expressed in geographic terms within which to 

target action, e.g., projects aimed at forest landscape restoration. In this analysis, the landscape 

scale for vegetation is the ponderosa pine extent.

Large tree – A large tree as defined in the revised “Mexican Spotted Owl Recovery Plan” (USDI 

FWS 2012) is a tree greater than 18 inches d.b.h. 

Litter – The top layer of the forest, shrubland, or grassland floor above the duff layer, including 

freshly fallen leaves, needles, bark, flakes, fruits (e.g., acorns, cones), cone scales, dead matted 

grass, and a variety of accumulated dead organic matter which is unaltered or only slightly 

decomposed. This layer typically does not include twigs and larger stems. One rough measure to 

distinguish litter from duff is that you can pick up a piece of litter and tell what it was (a leaf or 

leaf part, a needle, etc.). Duff is generally not identifiable. There is a gradient, not a clear division 

between litter and duff. 

LOPFA – Landscapes outside of goshawk post-fledging family areas as referenced in the 

Coconino NF forest plan. 

Management area – The mission, goals, and objectives for the forest are realized by applying 

groups of management activities to specific units of land. Groups of management activities are 

called “prescriptions” and the land units are called “management areas.”

Mature tree – A tree that has attained most of its potential height growth.

Mechanical treatment – Any activity (e.g., silvicultural thinning, biomass removal) performed 

by human-controlled tools (e.g., chain saw, feller-buncher) that results in the removal or alteration 

of wood fiber. Does not include the use of fire. 

Monitoring – A systematic process of collecting and storing data related to natural systems at 

specific locations and times. Determining a system’s status at various points in time yields 

information on trends, which is crucial in detecting changes in systems. 

Mosaic – The spatial arrangement of habitat where there is stand heterogeneity, measured at 

many spatial scales from the patch, the stand, and the vegetative community.

Natural Range of Variability – See historic range of variation 

Native species – a species which is an indigenous (originating where it is found) member of a 

biotic community. The term implies that humans were not involved in the dispersal or 

colonization of the species.

Nesting and roosting recovery habitat – Areas managed to replace nesting and roosting habitat 

lost to disturbance or senescence and to provide new nesting and roosting habitat for a recovering 

owl population (USDI FWS 2012). 

Nonmarket values – The benefits and values associated with national forests that do not have a

monetary price including clean water and air, biodiversity, forest products, and other goods and 

services.

Nutrient cycling (soil) – The circulation of chemicals necessary for life, from the environment 

(mostly from soil and water) through organisms and back to the environment. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

910 Coconino and Kaibab National Forests 
Appendix H – Glossary

Old growth – In Southwestern forested ecosystems is defined differently than the traditional 

definition based on Northwestern infrequent-fire forests. Due to large differences among 

Southwest forest types and their characteristic disturbances, old growth forests vary extensively 

in tree size, age classes, presence and abundance of structural elements, stability, and presence of 

understory. Important structural features of old growth in frequent-fire forests are large trees, old 

trees, age variability, snags, large dead and downed fuels, and between-patch structural variability 

(USDA Forest Service 2013) ( Reynolds et al. 2013).

Old growth protection and large tree retention strategy (OGP and LTRS) – Strategy 

developed by the 4FRI stakeholders in 2010 (finalized in 2011), which provides 

recommendations relating to the retention of large post-settlement and old growth trees.

Openness – The percentage of the forested area that is grass/forb/shrub interspace. In this 

analysis, the term “openness” is used interchangeably with the term “canopy density.” 

Classifications of openness for the 4FRI analysis are:

Very Open = 70 to 90 percent interspace

Open = 40 to 70 percent interspace 

Moderately Closed = 25 to 40 percent interspace

Closed = less than 25 percent interspace

Operational road maintenance levels – The level of service provided by, and maintenance 

required for, a specific road, consistent with road management objectives and maintenance 

criteria (FSH 7709.58, 12.3). There are five levels: 

Level 1: These are roads that have been placed in storage between intermittent uses. The period 

of storage must exceed 1 year. Basic custodial maintenance is performed to prevent damage to 

adjacent resources and to perpetuate the road for future resource management needs. 

Level 2: Assigned to roads open for use by high-clearance vehicles. Passenger car traffic, user 

comfort, and user convenience are not considerations. 

Level 3: Assigned to roads open and maintained for travel by a prudent driver in a standard 

passenger car. 

Level 4: Assigned to roads that provide a moderate degree of user comfort and convenience at 

moderate travel speeds. Most roads are double lane and aggregate surfaced. 

Level 5. Assigned to roads that provide a high degree of user comfort and convenience. These 

roads are normally double lane, paved facilities. 

Overmature tree – A tree that has reached that stage of development when it is declining in 

vigor and health and reaching the end of its natural lifespan. Indications of later life stages in 

southwestern ponderosa pine include yellowing bark, large limbs, dead and/or dying limbs, flat 

tops, snag tops, lightning scars, and burn scars (cat face).

Passive crown fire – A fire in the crowns of trees in which trees or groups of trees torch, ignited 

by the passing front of the fire. The torching trees reinforce the spread rate, but these fires are not 

basically different from surface fires.

PFA – Goshawk post-fledging family area as referenced in the Coconino NF and Kaibab NF 

forest plans.

Pile burning – Activity fuels, once piled by machine or by hand, are burned in place.

Planned ignition – The intentional initiation of a wildland fire by hand-held, mechanical, or 

aerial device where the distance and timing between ignition lines or points, and the sequence of 

igniting them is determined by environmental conditions (weather, fuel, topography), firing 

technique, and other factors which influence fire behavior and fire effects (see prescribed fire).

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 911
Appendix H – Glossary

Precommercial thinning – The removal of trees not for immediate financial return but to reduce 

stocking to concentrate growth on the more desirable trees (SAF 2008). 

Prescribed fire – A wildland fire originating from a planned ignition to meet specific objectives 

identified in a written, approved, prescribed fire plan for which NEPA requirements (where 

applicable) have been met prior to ignition (see planned ignition). 

Proper functioning condition (PFC) – A methodology for assessing the physical functioning of 

riparian and wetland areas. The term PFC is used to describe both the assessment process and a 

defined, on-the-ground condition of a riparian-wetland area (National Riparian Service Team 

Definition, 2013).

Protected habitat (Mexican spotted owl) – Protected habitat consists of protected activity 

centers (PACs), slopes greater than 40 percent where timber harvest has not occurred in the last 

20 years (steep slopes), and reserved lands which include wilderness, research natural areas, wild 

and scenic rivers, and congressionally recognized wilderness study areas. The primary objective 

for protected habitat is the protection of the best available habitat for Mexican spotted owls while 

retaining management flexibility to abate high fire risk and to improve habitat conditions for the 

owl and its prey. 

Proposed action – In terms of the National Environmental Policy Act, the project, activity, or 

action that a Federal agency intends to implement or undertake (Coconino NF forest plan 

glossary).

Recovery unit – A specific geographic area, identified mainly from physiographic provinces, 

used to evaluate the status of Mexican spotted owls and within which to develop specific 

management guidelines (USDI FWS 2012). The recovery unit specific to this analysis is the 

Upper Gila Mountain Recovery Unit. 

Recreational opportunity spectrum (ROS) – A classification system that describes different 

outdoor recreation settings across the forests using seven standard classes that range from 

primitive, undeveloped settings to urban, highly developed settings. Attributes typically 

considered in describing the settings are size, scenic quality, type, and degree of access, 

remoteness, level of development, social encounters, and the amount of onsite management. See 

the recreation and scenery report for additional information. 

Reference condition (also referred to as historic reference condition) – A range of conditions 

(found in the present or the past) against which the effects of past and future actions can be 

compared. These states can provide an explicit, historically-based context for comparing different 

management effects. Examples include periods before fire suppression or the arrival of an 

invasive species, or a similar but “healthier” modern ecosystem. Ideally, these environmental 

conditions are based on functioning ecosystems where natural ecosystem structure, composition, 

and function are operating with limited human intervention (very minor human-caused ecological 

effects).

Regenerate – The act of renewing tree cover by establishing young trees naturally or artificially 

(SAF 2008). 

Research natural area (RNA) – An area in as near a natural condition as possible that 

exemplifies typical or unique vegetation and associated biotic, soil, geologic, and aquatic 

features. RNAs are set aside to preserve a representative sample of an ecological community, 

primarily for scientific and educational purposes. Normally between 300 and 1,200 acres in size 

(Coconino NF forest plan glossary).

Residence time – Time required for the flaming front of a fire to pass a stationary point at the 

surface of the fuel. The length of time the flaming front occupies one point; relates to downward 

heating and fire effects below the surface.

Resiliency – The capacity of a (plant) community or ecosystem to maintain or regain normal 

function and development following disturbance (SAF 2008). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

912 Coconino and Kaibab National Forests 
Appendix H – Glossary

Resource protection measures – Measures (design features or mitigation) implemented to 

minimize nonpoint source pollution as outlined in the intergovernmental agreement between the 

Arizona Department of Environmental Quality and the Southwestern Region of the Forest Service 

(ADEQ 2008). 

Restoration subunit (SU) – A contiguous geographic area that ranges from 4,000 acres to 

109,000 acres in size. Boundaries are based on 6th code watershed boundaries, state and forest 

transportation systems, and forest administrative boundaries. 

Restoration treatments – Treatments that help recover forest ecosystem resilience and the 

adaptive capacity of forest ecosystems that have been degraded, or are otherwise outside the 

natural range of variability that would preclude sustainability through time. 

Restoration unit (RU) – A contiguous geographic area that ranges from 46,000 acres to 335,000 

acres in size where a need for change (vegetation structure, pattern, spatial arrangement, potential 

for destructive fire behavior and effects) has been identified. Restoration unit boundaries are 

based on 6th code watershed boundaries, state and forest transportation systems, and forest 

administrative boundaries 

Restricted habitat (Mexican spotted owl) – In the case of the 4FRI, restricted habitat is 

ponderosa pine-Gambel oak habitat that does not meet the definitions of protected habitat, i.e., 

there are no known resident Mexican spotted owls, it is not on a slope with 40 percent or greater 

slope and has not had timber harvested in the last 20 years, and is not considered a reserved land 

(e.g., designated wilderness, research natural areas, etc.). The objective in restricted habitat is to 

manage the landscape to maintain and create replacement owl habitat where appropriate while 

providing a diversity of stand conditions and stand sizes across the landscape. 

Riparian area – Riparian ecosystems are distinguished by the presence of free water within the 

common rooting depth of native perennial plants during at least a portion of the growing season. 

Riparian ecosystems are normally associated with seeps, springs, streams, marshes, ponds, or 

lakes. The potential vegetation of these areas commonly includes a mixture of water (aquatic) and 

land (phreatic) ecosystems (Coconino NF forest plan glossary).

Road construction or reconstruction – Supervising, inspecting, actual building, and incurrence 

of all costs incidental to the construction or reconstruction of a road (36 CFR 212.1). 

Road decommission – Activities that result in the stabilization and restoration of unneeded roads 

to a more natural state (36 CFR 212.1, FSM 7705—Transportation System, USDA FS 2003). 

FSM 7712.11- Exhibit 01 identifies five levels of treatments for road decommissioning which can 

achieve the intent of the definition. These include blocking the entrance, revegetation 

waterbarring, removing fills and culverts, establishing drainageways and removing unstable road 

shoulders, and full obliteration, recontouring, and restoring natural slopes. 

Road reconstruction and improvement – Any activity that results in an increase of an existing 

road’s traffic service level, expansion of its capacity, or a change in its original design function. 

Activities include, but are not limited to, the construction of bridges and major culverts, placing 

bar ditches, subgrade repairs, shoulder widening, lane widening, ditch widening, roadway prism 

widening, horizontal and vertical alignment changes, curve widening, and improving site distance 

at road intersections. Vegetation would likely be removed with these activities.

Road reconstruction and relocation – Any activity that moves all or parts of the horizontal and 

vertical alignment of a road, i.e., the roadway prism to a new location and decommissions the old 

alignment. Generally, realignments are for the purpose of moving the road location to a more 

suitable area to mitigate impacts to streams, critical wildlife habitat, and other natural or cultural 

resources. Often, reconstruction is used interchangeably with road relocation. This activity 

includes creating a new road alignment in an upland position, installing the proper drainage 

features, signage, and surfacing on the new road alignment, and decommissioning of the old road 

alignment. The new road alignment would require the removal of vegetation at the new alignment 

site.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 913
Appendix H – Glossary

Road (route) obliteration – See road decommission.

Road realignment – Activity that results in a new location of an existing road or portions of an 

existing road and treatment of the old roadway. 

Scenery management systems (SMS) – Guidance developed by the Forest Service for managing 

scenery and determining the relative value and importance of scenery in the national forest (also 

see VMS and the scenery specialist report for additional information).

Second order fire effects – The secondary effects of fire such as tree regeneration, plant 

succession, and changes in site productivity. Although second order fire effects are dependent, in 

part, on first order fire effects, they also involve interaction with many other nonfire variables 

(e.g., weather).

Severity – The quality or state of distress inflicted by a force. The degree of environmental 

change caused by a disturbance (e.g., fire).

Slash – The residue left on the ground after timber harvest or as a result of storms, fire, girdling, 

or poisoning. Slash includes unused logs, uprooted stumps, broken or uprooted stems, and the 

heavier branchwood, lighter tops, twigs, leaves, bark, and chips. 

Snag – Standing dead tree from which the leaves or needles have fallen.

Soil function – The characteristic physical and biological activity of soils that influences 

productivity, capability, and resiliency (FSM 2521.05). 

Soil productivity – The capacity of soil, in its normal environment, to support plant growth. 

(Soil) Tolerance – The point beyond which there is high risk that potential may be permanently 

altered or impaired through changes in specified physical, chemical, and biological factors 

brought about by management activities or natural events (FSM 2521.05). 

Spatial pattern – Arrangement of forested areas and openings on the landscape.

Spring – In this analysis, springs are natural water features that existed prior to Euro-American 

settlement and were probably functional due to lack of human disturbances (USDA FS 2009). 

Stand – A contiguous area of trees sufficiently uniform in forest type, composition, structure, and 

age class distribution, growing on a site of sufficiently uniform conditions to be a distinguishable 

unit. Four classification characteristics are generally used to distinguish forest stands: biophysical 

site (soils, aspect, elevation, plant community association, climate, etc.), species composition, 

structure (density, and age (1-aged, 2-aged, uneven-aged)), and management emphasis 

(administrative requirements and local management emphasis that will shape structure over time). 

Based upon Agency guidelines, the minimum stand mapping size is 10 acres. 

Stand density – A measure of the degree of crowding of trees within stocked areas commonly 

expressed by various growing space ratios (e.g., height/spacing) (SAF 2008).

Stand density index (SDI) – A measure of the stocking of a stand of trees based on the number 

of trees per unit area and diameter at breast height (d.b.h.) of the tree of average basal area. It may 

also be defined as the degree of crowding within stocked areas, using various growing space 

ratios based on crown length or diameter, tree height or diameter, and spacing. The computed 

value of SDI is often compared to the species maximum to determine the relative “stand density” 

or stocking of the stand. 

Stand structure – The horizontal and vertical distribution of components of a forest stand

including the height, diameter, crown layers, and stems of trees, shrubs, herbaceous understory, 

snags, and down woody debris (SAF 2008). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

914 Coconino and Kaibab National Forests 
Appendix H – Glossary

State Historic Preservation Office (SHPO) – The state office responsible for consultation and 

assistance regarding the presence and significance of cultural resources in a project area, efforts 

needed to find and evaluate them, whether the project will cause harmful effects to the cultural 

resource, and how to reduce or avoid the harm.

Stratum/strata (plural) – A layer of soil with internally consistent characteristics that distinguish 

it from other layers.

Surface fire – A fire that burns over the forest floor, consuming litter, killing aboveground parts 

of herbaceous plants and shrubs, and typically scorching the bases and crowns of trees. See also 

backing fire, crown fire, fire, flanking fire, ground fire, head fire, and understory fire. 

Surface fuel – Fuels lying on or near the surface of the ground, consisting of leaf and needle 

litter, dead branch material, downed logs, bark, tree cones, and low stature living plants. See also 

duff, fuel, large woody debris, and litter.

Target habitat – A category of Mexican spotted owl restricted habitat intended to provide future 

nesting and roosting habitat (see definition for restricted habitat). A variety of forest structural 

attributes is used to define nesting and roosting habitat (summarized in table III.B.1 of the 

recovery plan and table C-2 of the draft recovery plan). The minimum values identified for the 

forest attributes represent the threshold for meeting nesting and roosting conditions (see the 

definition for threshold habitat). They can also be targets to be achieved with time and 

management. If less than 10 percent of the restricted habitat in ponderosa pine-Gambel oak 

qualifies as threshold habitat, the areas that can eventually achieve all threshold conditions 

simultaneously should be identified as target habitat and managed to achieve threshold 

conditions as rapidly as possible. Because no known Mexican spotted owl nests or roosts occur in 

restricted habitat, target habitat is considered future nesting and roosting habitat.

Temporary road or trail – A road or trail necessary for emergency operations or authorized by 

contract, permit, lease, or other written authorization that is not a forest road or trail and that is 

not included in a forest transportation atlas (36 CFR 212). 

Threatened and endangered species – Species identified by the Secretary of the Interior in 

accordance with the 1973 Endangered Species Act, as amended. See the wildlife report for 

additional information.

Threshold habitat – A category of Mexican spotted owl restricted habitat intended to provide for 

future nesting and roosting habitat (see definition for restricted habitat). A variety of forest 

structural attributes is used to define when nesting and roosting habitat is achieved (summarized 

in table III.B.1 of the recovery plan and table C-2 of the draft recovery plan). These values are 

targets that can be achieved with time and management (see definition for target habitat). When 

the minimum values identified for the forest attributes are met simultaneously, they represent the 

threshold of nesting and roosting conditions. Ten percent of restricted habitat in ponderosa pineGambel oak should be designated as threshold habitat. Management in threshold habitat cannot 

lower any of the forest attribute values below the nesting and roosting threshold unless a 

landscape analysis demonstrates an abundance of this habitat. Because no known Mexican 

spotted owl nests or roosts occur in restricted habitat, target habitat is managed as future nesting 

and roosting habitat. 

Total maximum daily load (TMDL) – A written analysis that determines the maximum amount 

of a pollutant that a surface water can assimilate (the “load”), and still attain water quality 

standards during all conditions. The TMDL allocates the loading capacity of the surface water to 

point sources and nonpoint sources identified in the watershed, accounting for natural background 

levels and seasonal variation, with an allocation set aside as a margin of safety. See the water 

quality and riparian specialist report for additional information.

Torching – See passive crown fire.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 915
Appendix H – Glossary

Traditional cultural property (TCP) – Traditional use areas and places that have been used by 

cultural groups over generations. TCPs within the project area include the San Francisco Peaks on 

the Coconino NF and Red Butte and Bill Williams Mountain on the Kaibab NF. Natural springs 

are also considered TCPs and/or sacred sites by some tribes. Many plants are gathered for 

ceremonial use on or near TCPs. See appendix A of the heritage report for additional discussion 

on management of TCPs.

Travel Management Rule (TMR) – On December 9, 2005, the Forest Service published the 

TMR. The Agency rewrote direction for motor vehicle use on National Forest System lands under 

36 CFR, Parts 212, 251, and 261, and eliminated 36 CFR 295. The rule was written to address, at 

least in part, the issue of unmanaged recreation. The rule provides guidance to the Forest Service 

on how to designate and manage motorized recreation on the forests. The rule requires each 

national forest and grassland to designate those roads, motorized trails, and areas that are open to 

motor vehicle use. 

Trees per acre (TPA) – a count of the total number of trees on an acre.

Unauthorized road – A road that is not a forest road or a temporary road or trail and that is not 

included in a forest transportation atlas (36 CFR 212). 

Understory – The trees and other woody species growing under a more or less continuous cover 

of branches and foliage formed collectively by the upper portion of adjacent trees and other 

woody growth. In this analysis, the term understory is also referred to as “herbaceous 

understory.” 

Uneven-aged forests – Forests that are comprised of three or more distinct age classes of trees, 

either intimately mixed or in small groups.

Uneven-aged management – The application of a combination of actions needed to 

simultaneously maintain continuous high forest cover, recurring regeneration of desirable species, 

and the orderly growth and development of trees through a range of diameter or age classes (to 

provide a sustained yield of forest products). Cutting is usually regulated by specifying the 

number or proportion of trees of particular sizes to retain within each area, thereby maintaining a 

planned distribution of size classes. Cutting methods that develop and maintain uneven-aged 

stands are single-tree selection and group selection. 

Vegetation structural stage (VSS) – A method of describing forest age and tree size from 

seedling to old forests. The VSS classification is based on the tree size class with the highest 

square foot of basal area and is an indication of the dominant tree diameter distribution (see 

silvicultural report for details (McCusker, 2013). 

Visual Management System (VMS) – The VMS was used to develop visual quality objectives 

(VQOs) that are prescribed in the forest plan for all lands within the CNF. The VQO 

classifications range from preservation, retention, partial retention, modification, to maximum 

modification. The VMS process has been updated in the Scenery Management System (SMS). 

See the scenery report for additional information.

Watershed – The area that contributes water to a drainage or stream (Coconino NF forest plan 

glossary).

Watershed condition – The state of a watershed based upon physical and biological 

characteristics and processes affecting hydrologic and soil functions (FSM 2521.05). 

Watershed condition framework – A framework established by the Forest Service that provides 

a new consistent, comparable, and credible process for improving the health of watersheds on 

national forests and grasslands. The framework includes a technical guide which provides 

protocol for assessing watershed condition across all 193 million acres of National Forest System 

lands (http://www.fs.fed.us/publications/watershed).

Water quality – See Clean Water Act

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

916 Coconino and Kaibab National Forests 
Appendix H – Glossary

Water yield – The total net amount of water produced including streamflow and groundwater 

recharge (Coconino NF forest plan glossary).

Wildland fire – A general term describing any nonstructure fire that occurs in the wildland.

Wildland-urban interface (WUI) – The line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetation fuels. Wildland-urban 

interface areas are spread across the project area and are located within or adjacent to the 

communities of Flagstaff (restoration unit 1, 3, 4, 5), Williams (restoration unit 3, 4), Tusayan 

(restoration unit 6), Parks (restoration unit 3, 4), Belmont (restoration unit 3, 4), and scattered 

developments such as Doney Park (restoration unit 5), Munds Park (restoration unit 1), and 

Kachina Village (restoration unit 3). 

Woody debris – The dead and downed material on the forest floor consisting of fallen tree trunks 

and branches.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 917

Appendix I - Summary of

Response to Comments on the DEIS

All comments received on the draft EIS from Federal, State and local agencies have been 

included in this appendix on pages 925 to 994. This satisfies Section 102 (c) of NEPA which 

states, “...comments and views of the appropriate Federal, State and local agencies, which are 

authorized to develop and enforce environmental standards, shall be made available to the 

President, the Council on Environmental Quality and to the public...” 

Although the project only directly affects Coconino County, comments from the Eastern Arizona 

Counties Organization has been included to reflect similar comments received from Apache, Gila, 

Graham, Greenlee and Navajo County. 

Per 40 CFR 1503.4, summarized responses to comments received on the draft EIS are included in 

this appendix. They have been organized by topic. All comments received on the draft EIS are

available for public review at: https://cara.ecosystemmanagement.org/Public/Letter/172405?project=34857. All comments received were reviewed and 

responded to individually. The complete comment analysis and response document is located in 

the project record and is available on the project’s website at: 

http://www.fs.usda.gov/main/4fri/planning. 

List of Commenters 

Organization Name

Letter 

Number

American Indian Govt. Agency /Elected Official 

The Hopi Tribe Kuwanwisiwma, Leigh 12

County Government Agency /Elected Official 

Apache County White, Tom 184

Coconino County NRDC Harger, Scott 176

Eastern Arizona Counties Organization Berlioux, Pascal 76, 133

Graham County John, Drew 89

Federal Agency/Elected Official 

DOI - Office of Environmental Policy and 

Compliance

Sanderson Port, Patricia; and 

Singh, Gurleen

175

Environmental Protection Agency, Region IX Martyn Goforth, Kathleen 71

National Park Service - Wupatki, Sunset Crater, 

Walnut Canyon

Whitefield, Paul 118

Municipal/City Government Agency 

/Elected Official

 

Flagstaff Fire Department Summerfelt, Paul 40

Coconino County Wolff, Ted 1 

Gila County Arizona Martin, Tommie 163, 164, 174

Greenlee County Pearson, Yvonne 158

Navajo County Nez, Jonathan 95

State Government Agency /Elected Official 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 919
Appendix I – Summary of Response to Comments on the DEIS

Organization Name

Letter 

Number

Arizona Department of Environmental Quality Busby, Brad 135, 156

ADEQ- Water Quality LeStarge, Wendy 16

Arizona State Forestry Division Hunt, Scott

Payne, Jerry

166

AZ Game & Fish Dept Rosenstock, Steve 113

Other groups 

4FRI Stakeholder Group Waltz, Amy 98, 155

Arizona Antelope Foundation Dickens, Glen 168, 173

Arizona Elk Society Clark, Steve 181

Arizona Wildlife Federation Mackin, Tom 179

Bellemont HOA Nielsen, Erik 50

Center for Biological Diversity Lininger, Jay 180, 196, 201-

212

Conservation Congress and Wildearth Guardians Boggs, Denise 107, 115, 137

Ecological Restoration Institute Waltz, Amy 165

Friends of Northern Arizona Forests Baierlein, Ralph 72

Grand Canyon Trust McKinnon, Taylor 172

Grand Canyon Wildands Council Burke, Kelly 197

Great Old Broads For Wilderness Hughes, Billie 198

Greater Flagstaff Forests Partnership Gatewood, Steve 169

John Muir Project & Center for Biological Diversity Hanson, Chad 148, 149 

NAU Ecological Restoration Institute Sensibaugh, Mark 2 

Northern Arizona University Dewhurst, Stephen 177

Northern Arizona University, School of Earth 

Sciences and Environmental Sustainability

Springer, Abraham 162

Physicians for Social Responsibility Warren, Barbara 6 

Salt River Project Ramirez, Celina T 105

Sierra Club - Grand Canyon Chapter Bahr, Sandy 199

Southeast Neighborhood Association, Santa Fe, NM Millard, Elizabeth 79

The Nature Conservancy Graham, Patrick 178

White Mountain Conservation League Winn, Russell 200

Wild wood Consulting Gatewood, Steve 151

Individuals

Alfonso, Leonardo 136

 Artley, Dick 8, 15, 216-224

Asselin, Dave 37

Aubin, Louise 32

 Bacon, Bren 147

 Bardwell, Avelina 106

Baric, Leonard 58

 Barris, Elizabeth 80

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

920 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Organization Name

Letter 

Number

 Barritt, Harrison 144

Beaty, C. Lee 186

 Beety, Nina 167

 beninato, stefanie 93

 Beste, Carolyn 159

 Beste, Michael 160

Bickel, Bettina 35

 Blakemore, Sally 87

Blat, Anja 70

Bower, Danielle 39

 Boyer, Jan 122

 Boyer, Jan 153

Bushbaum, Scott 103

Causer, Richard 26

 Chase, Deborah 53

cho, sun 120

 Chrisman, B. 117

 Clair, Laura 52

 Conwell, Douglas 104

Cook, Eryn 56

 Cote, Paula 4 

Cruz, Nayda 134

Culver, Angela 31

Cummings, Shane 60

Cupani, Shirley 193

Curley, June 25

De Souza, Caylie 194

 Decosse, Susan 92

 Draxler, Ron 18

 Drobeck, Charly 128

Duke, Kathy 187

Dysart, Lorrie 67

Finholt, Tom 114

 Firstenberg, Arthur 109

 Firstenberg, Arthur 183

 Fish, Mary 94

 Fleishman, Dick 154

 Forlano, Debrianna Mansini 86

 Free, Shastina 145

 Free, Shastina 150

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 921
Appendix I – Summary of Response to Comments on the DEIS

Organization Name

Letter 

Number

 Gannon, Connie 116

Gavin, Wili 21

Gibson, Craig 192

 Gold, K E 83

Goode, Cutter 127

Grossman, Ellen 110

 Gunst, Susan 214

 hart, ty 130

 Hatfield, Barry 82

 Hemenway, Kathy 161

Hicks, Bethany 19

 Hilding, Nancy 24

 Hildreth, Stephanie 49

 Holasek, Dorothy 74

 Holasek, Dorothy 75

 Honn, Marsha 11

 HONN, MELINDA 126

 Inch, Terry 119

 Ingold, John 213

 Jablonsky, Cara 46

 Jesse, Ellen 112

 jjrdm@npgcable.com, Anon 14

 Kerr, Patrice 170

 Krevit, Sheldon 142

Kuharsky, Merry 36

Laieski, Caleb 101

 Lamb, Antonia 146

Larsen, Areil 102

Lehan, Diana 69

 Lenz, Debby 125

Libbey, Rich 62

 Lopez, Maricruz 45

Love, Chris 61

Martinez, Frederick 44

 McCreary, R Bruce 88

Mccrohan, Shawn 29

 McGuire, Tom 73

 McGuire, Tom 182

 McLean, Mary 157

McMahon, Annie 30

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

922 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Organization Name

Letter 

Number

Moore , K E 141

Morris, Michelle 185

 Moses, Cate 121

Moskiman, Karen 42

 Nidess , Rael 17

 Nidess, Rael 3 

 odin, jane 171

 Page, Jennifer 129

 parker, carol 124

 Pinckard, Elaine 84

 Provencio, Henry 96

 Provencio, Henry 99

Provost, Clifford 108

 Pynn, Jessica 54

Richard, Michelle 68

Ritchie, John 28

Roberts, Jenny 20

Rockwell, Clyde 65

 Rogers, Ann 138

Romesburg, Denise 33

 Rose, Amanda 78

Sanchez, Yolanda 97

Santori, Nancy 23

 Schoonmaker, Duke 13

Seals, Joseph 66

Shaw, Thelma 64

Smallwood, Tracey 152

Smaluk-Nix, Kathleen 34

Smaluk-Nix, Kathleen 38

Smith, Iris 55

Smith, Iris 195

 Smith, Rocky 47

 Smith, Rocky 188

 Souza, Caylie 48

Steinhardt, Ann 43

 stewart, douglas 139

 Strom, Randy 57

Stuckey, Matthew 189

Sullenberger, Nathan 41

 Thomas, Reynold 27

Final Environmental Impact Statement for the Four-Forest Restoration Initiative 

Coconino and Kaibab National Forests 923
Appendix I – Summary of Response to Comments on the DEIS

Organization Name

Letter 

Number

Thurman, Ricky 190

Vollherbst, Karleen 140

 Wachsler, Sharon 123

 Warner, Charles 22

 Watson, Margaret 91

 Weibel, Annemarie 143

 Welker, Richard 85

Westcott, Mary 111

 Williams, Denise 131

Williamson, Martha 191

 winsten, martha 100

Wolf, Pauline 132

Wolslegel, Thomas 59

 Worsham, Michael 81

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

924 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

The Hopi Tribe

April 9, 2013 

Michael R. Williams, Forest Supervisor Kaibab 

National Forest

800 South Sixth Street Williams, 

Arizona 86046-2899

 

M. Earl Stewart, Forest Supervisor Coconino 

National Forest

1824 South Thompson Street Flagstaff, 

Arizona 86001-2529

Re: Four Forest Restoration Initiative-Coconino and Kaibab National Forests Draft Environmental Impact 

Statement

Dear Supervisors Williams and Stewart,

This letter is in response to the Draft Environmental Impact Statement for the Four Forest Initiative, 

Coconino and Kaibab National Forests regarding a proposal to conduct restoration activities within a 

587,923 acres ponderosa pine ecosystem over 10 years_ The Hopi Tribe claims cultural affiliation to 

prehistoric cultural groups in Coconino, Kaibab, Apache Sitgreaves and Tonto National Forests. The Hopi 

Cultural Preservation Office supports the identification and avoidance of prehistoric archaeological sites 

and we consider the prehistoric archaeological sites of our ancestors to be "footprints" and Traditional 

Cultural Properties. Therefore, we appreciate the Forest 's continuing solicitation of our input and your 

efforts to address our concerns.

In the enclosed letter dated March 21, 2011, the Hopi Cultural Preservation Office reviewed the Four 

Forest Restoration Initiative-Coconino and Kaibab National Forest Purpose and Need and Proposed 

Action. We stated in initial consultations we have been info1med that Appendix J, Standard Consultation 

Protocol for Large-Scale Fuels Reduction, Vegetation Treatment, and Habitat Improvement Projects 

pursuant to the First Amended Programmatic Agreement Regarding Historic Property Protection and 

Responsibilities will apply to these projects.

In the enclosed letter dated June 6, 2011 we reviewed the Heritage Resources Strategy and NEPA 

Compliance for the Four Forest Restoration Initiative. The Strategy states that 46% of the 530,187 acre 

project area in the Kaibab National Forest has been surveyed for cultural resources and 3,843 cultural 

resources have been identified, and 40% of the 817,151 acre project area in the Coconino National Forest 

has been surveyed and 3,366 cultural resources have been identified. 

The Strategy also states that Kaibab and Coconino National Forests have approached their methods of 

inventory in the ponderosa environments very differently, with the Kaibab conducting 100% survey and 

the Coconino conducting l 00% survey in high site density areas, but only sample surveys of around 15-

25% in low density areas. We understand that this multiple forest survey strategy generally adopts the 

Appendix J and Coconino approach, and that this strategy is intended to result in a determination of no 

adverse effect to historic properties.

In our June 6, 2011, letter we asked why the Forests don't adopt the approach Kaibab has employed since 

the 1970s, rather than the less rigorous Appendix J and Coconino approach to provide consistency in the 

way compliance is conducted. The Forest Service has acknowledged that the need to improve the health 

and condition of the forests has resulted from the fire suppression mismanagement of the forests over the 

last Century. Ifit has been possible for the Kaibab to conduct I 00% surveys for over forty years.is that 

approach now being diluted because of the sheer size of this proposal?

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 925
Appendix I – Summary of Response to Comments on the DEIS

We have also consulted on this proposal at our regular administrative meetings and have stated we looked 

forward to continuing consultations with the four Forests on the development and implementation of the 

cultural resources survey plans, and Traditional Cultural Properties and ethnographic studies. 

We have now reviewed the Draft Environm ental Impact Statement, and understand Alternative C the 

Preferred Alternative responds to the issues of conservation of large trees and increased restoration and 

research. Our March 21, 2011 letter is not cited on page 35, Tribal Consultation . We also understand that 

in addition to Appendix J, a heritage strategy, initial Section 106 report, and tribal relations analysis have 

been developed for the project, and that effects on cultural resources from the action alternatives are not 

considered to be adverse .

However, regardless of whether additional high impact or intense mechanical treatments occur under the 

preferred alternative, we look forward to continuing consultation on this project including the review of 

cultural resources survey reports, mitigation of adverse effects, identification and protection of Traditional 

Cultural Properties, and in the event of any inadvertent discoveries .

Regarding Forest Plan Amendment 3: Effect Determination for Cultural Resources, we understand this is 

a specific, one-time variance for the Coconino National Forest deletes the standard that addresses 

achieving a "no effect" determination and adds the words "or no adverse effect"to the remaining standard. 

More importantly than "no effect" or "no adverse effect" determinations, as demonstrated by both current 

and potential litigation in the Southwest and across the Country, the Forest Service has yet to integrate its 

Native American Sacred Sites and Traditional Cultural Properties consultations into its management 

decisions.

Nevertheless, we also look forward to continuing consultation with the Forest Service in the hope that in 

the future, these consultations will lead to the integration of the content of tribal consultations into the 

Forest Service's management decisions. Ifyou have any questions or need additional information, please 

contact Terry Margart at the Hopi Cultural Preservation Office at 928-734-3619 or tmon:rnrt@hopi.nsn 

.us. Thank you for your consideration .

Enclosure : March 21 and June 6, 2011 letters

xc: Arizona State Historic Preservation Office Henry Provencio, Coconino National Forest Mike Lyndon, 

Kaibab National Forest Craig Johnson , Coconino National forest Chris Knopp, Apache-Sitgreaves 

National Forest Neil Bosw01th, Tonto National Forest 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

926 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

The Hopi Tribe Attachment 1

June 6, 2011

M. Earl Stewart, Forest Supervisor

Attention: Craig Johnson, Tribal Relations Specialist Coconino National Forest 

1824 South Thompson Street Flagstaff, Arizona 86001-2529 

Re: Four Forest Restoration Initiative -Coconino and Kaibab National Forests Heritage Resources 

Srrategy and NEPA Compliance 

Dear Supervisor Stewaii,

This letter is in response to your correspondence dated May 12, 2011, regarding an enclosed Heritage 

Resources Strategy and NEPA Compliance for rhe Four Forest Restoration Initiative, a proposal to 

conduct restoration activities within a 750,000 acres ponderosa pine ecosystem over 10 years. The Hopi 

Tribe claims cultural affiliation to the Archaic, Sinagua, and Cohonina prehistoric cultural groups in the 

Coconino and Kaibab National Forests. The Hopi Cultural Preservation Office supports the identification 

and avoidance of prehistoric archaeological sites and we consider the prehistoric archaeological sites of 

our ancestors to be "footprints" and Traditional Cultural Prope1iies. Therefore, we appreciate the Forests' 

continuing solicitation of our input an your efforts to address our concerns. 

The Hopi Cultural Preservation Office has reviewed the enclosed Four Forest Restoration Initiative -

Heritage Resources Strategy and NEPA Compliance. Inour letter on this proposal dated March 21, 2011, 

we stated that in initial consultations on the Four Forest Restoration Initiative we have been informed that 

Appendix J, Standard Consultation Protocol for Large-Scale Fuels Reduction, Vegetation Treatment, and 

Habitat Improvement Projects pursuant to the First Am.ended Programmatic Agreement Regarding 

Historic Property Protection and Responsibilities will apply to these projects.

The Strategy states that 46% of the 530,187 acre project area in the Kaibab Nationa l Forest has been 

surveyed for cultural resomces and 3,843 cultural resources have been identified, and 40% of the 817, 151 

acre project area in the Coconino National Forest has been surveyed and 3,366 cultural resources have 

been identified.

The Strategy also states that Kaibab and Coconino National Forests have approached their methods of 

inventory in the ponderosa environments very differently, with the Kaibab conducting 100% survey and 

the Coconino conducting I 00% survey in high site density areas, but only sample surveys of around 15-

25% in low density areas. We understand that this multiple forest survey strategy generally adopts the 

Appendix J and Coconino approach, and that this strategy is intended to result in a determination of no 

adverse effect to historic properties.

To provide consistency in the way compliance is conducted, why don't the Forests adopt the approach 

Kaibab has employed since the 1970s, rather than the less rigorous Appendix J and Coconino approach? 

The Forest Service has acknowledged that the need to improve the health and condition of the forests has 

resulted from the fire suppression mismanagement of the forests over the last Century. Ifit has been 

possible for the Kaibab to conduct 100% surveys for over forty years, is that approach now being diluted 

because of the sheer size of this proposal?

We look fornrard to continuing consultations with the Forests on the implementation and review of the 

cultural resources surveys, as well as Traditional Cultural Properties and ethnographic studies. Ifyou have 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 927
Appendix I – Summary of Response to Comments on the DEIS

any questions or need additional information, please contact Terry Margart at the Hopi Cultural 

Preservation Office at 928-734-3619 or tmonrnrt@.hooi.nsn.us. Thank you for your consideration. 

Leigh J. Kuwanwishma, Director Hopi Cultural Preservation Office

Enclosure: March 21, 2011, letter to Kaibab and Coconino National Forests 

xc: Michael R. Williams, Michael Lyndon, Kaibab National Forest Arizona State Historic Preservation 

Office

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

928 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

The Hopi Tribe Attachment 2

March 21, 2011 

Michael R. Williams, Forest Supervisor Kaibab 

National Forest

800 South Sixth Street 

Williams, Arizona 86046-2899

M. Earl Stewart, Forest Supervisor Cocon ino 

National Forest

I 824 South Thompson Street 

Flagstaff, Arizona 86001-2529

R.e: Four Forest Restoration lnitiarive-Coconino and Kaibab National Foresr Purpose and Need and 

Proposed Action

Dear Supervisors Williams and Stewart,

This letter is in response to your correspondence dated January 27, 2011, regarding an enclosed proposal 

to conduct restoration activities within a 750,000 acres ponderosa pine ecosystem over J O years, part of 

the Four Forest Restoration Initiative. The Hopi Tribe claims cultural affiliation to prehistoric cultural 

groups in Coconino, Kaibab, Apache Sitgreaves and Tonto National Forests. The Hopi Cultural 

Preservation Office supports the identification and avoidance of prehistoric archaeological sites and we 

consider the prehistoric archaeological sites of our ancestors to be "footprints" and Traditional Cultural 

Properties. Therefore, we appreciate the Forest's continuin'g solkitation of our input and your efforts to 

address our concerns. 

The Hopi Cultural Preservation Office has reviewed the enclosed Four Forest Restoration lnitiativeCoconino and Kaibab National Forest Purpose and Need and Proposed Action. We routinely consult with 

Coconino, Kaibab, and Apache-Sitgreaves Forest Managers and Archaeologists during regular scheduled 

meetings on the Forests' Schedule of Proposed Actions. In initial consultations on the Four Forest 

Restorat ion Initiative we have been infonned that Appendix J. Standard Consultation Protocol for LargeScale Fuels Reduction, Vegetation Treatment, and Habitat Improvemen t Projects pursuant to the First 

Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities will 

apply to these projects.

Therefore, we look forward to continuing consultations with the four Forests on the development and 

implementation of the cultural resources survey plans, and Traditional Cultural Properties and 

ethnographic studies. If you have any questions or need additional infonnation, please contact Teny 

Margart at the Hopi Cultural Preservation Office at 928-734-3619 or tmorait@.hopi.nsn.us. Thank you for 

your consideration. 

Hopi Cultural Preservation Office

cc: Forest Supervisor, Attention: Scott Wood, Tonro National Forest

Forest Supervisor, Attention: Melissa Schroeder, Apache Sitgrcaves National Fo;csts Arizona State 

Historic Preservation Office

Mike Lyndon, Erin Woodard, Kaibab National Forest Craig Johnson, Coconino National Forest 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 929
Appendix I – Summary of Response to Comments on the DEIS

Flagstaff Fire Department 

3 May 2013 

Earl Stewart Forest Supervisor

Coconino National Forest -4FRI 1824 S. Thompson St

Flagstaff AZ 86001

SUBJECT: Draft Environmental Impact Statement (DEIS) Four Forests Restoration Initiative

Supervisor Stewart:

On behalf of the City of Flagstaff Fire Dept, we appreciate the huge amount of work that has gone into 

development of this document, and the opportunity provided to comment. This is truly a historic approach

to the pressing need to protect and ensure the long-term sustainability of our forests (and communities) in 

the greater Flagstaff and northern AZ area. Congratulations are in order for all those who have worked so 

long and hard to get us to this point. 

The four key issues captured on p. iv of the Summary -Prescribed Fire Emissions , Conservation of Large 

Trees, Post-treatment Canopy Cover and Landscape Openness, and Increased Restoration and Research - 

seem to adequately describe key issues. Specifically in regards to these issues:

Prescribed Fire Emissions -Emissions from any wildland fire are of concern, but we recognize that 

emissions produced under prescribed fire conditions are more tolerable, of shorter duration, and far less 

impactful than that produced by large-scale, destructive wildfire events. We cannot prevent smoke -our 

forests will burn, and the trend over the past decade or more is toward more severe wildfires. Nor can we 

afford to overlook the fact that prescribed fire, where we manage both conditions and results, is required 

for ecosystem health and one of the most cost-effective and proactive tools we have to prevent and/or 

reduce the catastrophic wildfire (s) in our near future. We applaud the Forest Service for recognizing the 

challenges of managing fire, but including this treatment in the DEIS. 

Conservation of Large Trees - The Large Tree Retention Strategy (LTRS) was developed by various 

stakeholders over an extended period of time. Although excluded from the August 2011 Proposed Action, 

it's inclusion in the DEIS is certainly a good-faith effort by the Agency to honor the work of those who 

labored over its creation and adoption: undoubtedly , there will be comments provided by others in 

regards to the Strategy incorporation and use, and we encourage the Agency to further incorporate those 

issues where appropriate and possible.

Post-treatment Canopy Cover and Landscape Openness - We recognize the historical "open forest", and 

welcome a return to that condition where appropriate and to the extent possible. Such a condition reduces 

the threat of severe-and-damaging wildfire, and improves resilience to climate change and insect 

outbreaks. Improvements of understory bio-diversity • and water recharge/yield are also positive aspects 

of this condition. But we also recognize that for many, too much "openness" can be an issue that moves 

them away from support of the project, rather than toward it. Recognition of this social reality , and taking 

steps to address it so it does not become a divisive issue, are marks of an attentive and responsive Agency 

and we urge you to continue to seek common-ground and understanding. 

Increased Restoration and Research: This effort certainly provides unique and valuable opportunities to 

adaptively manage both treatments and effects, in their broadest possible context (technology, social, 

ecosystem, etc). Incorporation of new material , such as the MSO Recovery Plan -2012, is an excellent 

approach. We should not be afraid of seeking out and using such information, for after all, we know very 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

930 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

well the inevitable results of inaction, slow implementation , outdated processes, and the short shelf-life 

of "state-of-the-art " methodology. 

Another issue sure to draw attention is that of Cumulative Effects, especially over such a large landscape 

and abutting other completed , on-going, or to-be-planned projects. In this regard, I only a different 

viewpoint: that the cumulative effects of non-action , or action undertaken on the current small-scale 

model is unsustainable , and that we can no longer stand-by or only nibble at- the-edges while our forests, 

environment, and our communities are being devastated. Thinking BIG is not easy, and the Agency, and 

all collaborating entities, is to be congratulated for doing so. 

Three particular items drew our attention that if revised would more accurately reflect current reality :

l ) Table 150 (p. 686) -City of Flagstaff efforts are not included (they are separate from, and not 

necessarily reflected by, the Greater Flagstaff Forests Partnership) ;

2) Table 156 (p. 694) -City of Flagstaff projects and acres are not listed, and, as above, are not 

necessarily included in or reflected by projects and acres attributed to the Greater Flagstaff Forests 

Partnership; and

3) Acres identified for the Flagstaff Watershed Protection Project -FWPP - (p. 697) is inaccurate (we 

recognize that at the time the document was created, what is shown was a rough idea, but the acreage of 

the FWPP has since been firmly identified). 

In closing, we concur with selection of Alternative C as the Preferred Alternative. It treats the most 

acreage, has the longest positive effect over time, responds to key issues, and incorporates a number of 

innovative features and approaches. Others will likely provide recommendations or other options to 

critical items and issues that will warrant evaluation for inclusion in the final EIS. But, we are satisfied 

with the plan as it now stands, knowing full well that our communities, forests, and all of the northern AZ 

area is dependent upon this project moving forward. 

We look forward to the Record of. Decision (ROD), our continued joint collaboration, treatment 

implementation , and the opportunity to collectively learn and make a difference in our community and 

area. Thanks for your leadership, and your eagerness to partner with others, in this effort! 

yours for a better tomorrow . . . . 

Paul Summerfelt

Wildland Fire Management Officer psummerfel t@flagstaffaz.gov

CC: Flagstaff City Council and Leadership Team

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 931
Appendix I – Summary of Response to Comments on the DEIS

U.S. Environmental Protection Agency

United States Environmental Protection Agency 

Region IX

75 Hawthorne Street San Francisco, CA 94105

May 16, 2013 

Mr. Henry Provencio 4FRI Team Leader

1824 South Thompson Street Flagstaff, Arizona 86001

Subject: Draft Environmental Impact Statement for the Four-Forest Restoration Initiative, Coconino 

County, Arizona (CEQ# 20130076)

Dear Mr. Provencio:

The U.S. Environmental Protection Agency has reviewed the Draft Environmental Impact Statement for 

the Four-Forest Restoration Initiative pursuant to the National Environmental Policy Act, Council on 

Environmental Quality regulations (40 CFR Parts 1500-1508), and Section 309 of the Clean Air Act. 

The EPA recognizes the Forest Service's commitment, demonstrated in the Four-Forest Restoration 

Initiative (4FRI or Project) DEIS, to restoration activities within the Coconino and Kaibab National 

Forests. We also acknowledge the Forest Service's dedication to public outreach and collaboration during 

the 4FRI NEPA process, and the efforts made to incorporate the best available science into the DEIS. In 

particular, we appreciate the 4FRI team talcing Jason Gerdes, of my staff, on a site visit of the 4FRI 

planning area, and working with Jason and EPA Region VIII's Richard Graham to include information inthe-DEIS-on the potential for smoke-fr.om-the -prnposed-pr-escribed fir-e tr-eatments to contain 

radioactive substances.

Based on our review of the subject DEIS, we have rated the Preferred Alternative and the docwnent as 

L0-1,Lack of Objections -Adequate (see enclosed EPA Rating Definition'\). The EPA acknowledges the 

need for the use of mechanical thinning and prescribed fire to achieve long-term restoration objectives. 

We commend the Forest Service for committing, in the Preferred Alternative, to strong best management 

practices and soil and water conservation practices to protect sensitive resources during mechanical 

harvest and fire treatments.

We recognize the challenge the Forest Service faces in implementing a restoration project that will rely

heavily on prescribed bums and wildfire to achieve Project objectives. The "Fire Ecology Report" that the 

Forest Service prepared for this Project explains these challenges well. Although the planning area has 

good air quality and meets all federal ambient air quality standards, the fine particulate matter generated 

during wildland fire does present a hwnan health risk. We recommend that the Forest Service work with 

the interagency Smoke Management Group and commit, in the Final EIS and Record of Decision, to 

implement best management practices to reduce emissions from prescribed burns and wildfires to the 

greatest possible extent. We also recommend that the Forest Service analyze and include a description, in 

the FEIS, of the potential for further reductions in air emissions from future forest treatments by lessening 

or eliminating pile burning of residual fuels in favor of biomass energy production. 

The DEIS includes a detailed and thorough description of the possible effects of climate change on the 

Project, and is strengthened by incorporating elements of two good planning documents: the "Kaibab 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

932 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

National Forest's Climate Change Approach for Plan Revision," and the "Southwestern Region Climate 

Change Trends and Forest Planning."We recommend that the Project's adaptive management plan include 

a commitment to monitor, mitigate, and respond to, the effects of climate change throughout the life of the 

4FRI.

We appreciate the opportunity to review this DEIS, and are available to discuss our comments. When the 

Final EIS is released, please send one CD copy to this office. Ifyou have any questions, please contact me 

at 415-972-3521, or contact Jason, the lead reviewer for this project. Jason can be reached at 415-947-

4221or gerdes.jason@epa.gov . 

Enclosure: Summary of the EPA Rating System

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 933
Appendix I – Summary of Response to Comments on the DEIS

Summary of EPA Ratings Definitions

This rating system was developed as a means to summarize the U.S. Environmental Protection 

Agency's(EPA) level of concern with aproposed action. Theratings area combination of alphabetical 

categories for evaluation of the environmental impacts of the proposal and numerical categories for 

evaluation of the adequacy of the Environmental Impact Statement (EIS). 

Environmental Impact of the Action

''LO" (Lack of Objections)

The EPA review has not identified any potential environmental impacts requiring substantive changes to 

the proposal. The review may have disclosed opportunities for application of mitigation .measures that 

could be accomplished with no more than minor changes to the proposal. 

"EC" (Environmental Concerns)

The EPA review has identified environmental impacts that should be avoided in order to fully protect the 

environment. Corrective measures may require changes to the preferred alternative or application of 

mitigation 11:1casures that can reduce the environmental impact. BPA would like to work with the lead 

agency to reduce these impacts.

"EO"(Environmental Objections)

The EPA review has identified significant environmental impacts that should be avoided in order to 

provide adequate protection for the environment. Corrective measures may require substantial changes to 

the preferred alternative or consideration of some other project alternative (including the no action 

alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts.

"EU"(Environmentally Unsatisfactory)

The BPA review has identified adverse environmental impacts that arc of sufficient magnitude that they 

an: unsatisfactory from the standpoint of public health orwelfare orenvironmental quality.EPA intends to 

work with the lead agency toreduce these impacts. Ifthe potentially unsatisfactory impacts an: not 

corrected at the finaJ EIS stage, this proposal will be recommended for referral to the Council on 

Environmental Quality (CEQ).

Adequacy of the Impact Statement

"Category 1" (Adequate)

EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative 

and those of the alternatives reasonably available to the project or action. No further analysis or data 

collection is necessary, but the reviewer may suggest the addition of clarifying Janguage or infonnation. 

"Category 2" (Insufficient Information)

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that 

should be avoided in order to fully protect the environment, or the EPA reviewer has identified new 

reasonably available alternatives that are within the spectrum of alternatives analysed in the draft EIS, 

which could reduce the environmental impacts of the action. The identified additional information, data., 

analyses, or discussion should be included in the final EIS. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

934 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

"Category 3"(Inadequate)

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts 

of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of 

the spectrum of alternatives analysed in the draft EIS, which should be analysed in order to reduce the 

potentially significant environmental impacts. EPA believes that the identified additional information, 

data, analyses, or discussions are of such a magnitude that they should have full public review at a draft 

stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 

309 review, and thus should be formally revised and made available for public comment in a 

supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal 

could be a candidate for referral to the CEQ.

•From EPA Manual 1640, Policy and Procedures for the Review of Federal Actions Impacting the 

Environment 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 935
Appendix I – Summary of Response to Comments on the DEIS

USDI National Park Service 

United States Department of the Interior

NATIONAL PARK SERVICE

INTERMOUNTAIN REGION

12795 West Alameda Parkway

PO Box 25287

Denver, Colorado 80225-0287

IN REPLY REFER TO:

ER-13/0194 

VIA ELECTRONIC COPY ONLY - NO HARD COPY TO FOLLOW

Memorandum 

To: Cheryl Eckhardt, National Park Service

From: Vanessa Sanchez, U.S. Fish and Wildlife Service

Subject: National Park Service Comments on ER-13/0194, Draft Environmental Impact Statement, FourForest Restoration Initiative, Coconino and Kaibab Forests 

Thank you for the opportunity to review and comment on the Draft Environmental Impact Statement 

(DEIS) for the Four Forest Restoration Initiative (4FRI). The proposed fire risk reduction and forest 

health restoration actions under the DEIS are in proximity to and have the potential to affect visitor 

experience, and cultural and natural resources within Walnut Canyon and Sunset Crater Volcano National 

Monuments. The Coconino National Forest is already implementing numerous smaller-scale projects 

covering much of the watersheds and viewsheds for the two national monuments, including the 

Mountainaire, Elk Park, Eastside, Jack Smith-Schultz, and Marshall wildfire risk reduction and forest 

health restoration projects. The 4FRI would address fire risk reduction and forest heath within the 

remaining watershed and view-shed areas.

Over the last eight years, resource management staff with the Flagstaff Area National Monuments have 

participated in the Coconino National Forest’s collaborative planning process for these earlier projects. As 

a result, NPS concerns were addressed while planning the earlier projects, and are being carried forward 

into the landscape-scale 4FRI. The 4FRI action alternatives are also being collaboratively planned with 

the Greater Flagstaff Forest Partnership and other stakeholders, incorporate the best available ponderosa 

pine fire ecology science, and fully involve the U.S. Fish and Wildlife Service in the design and 

implementation of treatments in Mexican spotted owl habitat. The three action alternatives under the 

4FRI DEIS are each well planned and will meet mutual NPS objectives for ponderosa pine forest 

restoration, wildfire risk reduction, wildlife habitat management, watershed function, and scenic quality 

retention within Walnut Canyon and Sunset Crater Volcano National Monuments. 

The NPS fully supports the need to address existing conditions, along with implementing one of the three 

action alternatives under the Final Environmental Impact Statement.

Thank you very much for the opportunity to comment on this EIS. Please feel free to contact Paul 

Whitefield, Natural Resource Specialist, Flagstaff Area Monuments, (928) 526-1157 ext.235, with any 

questions. 

cc: Tom Flanagan, NPS-WASO-EQD

Paul Whitefield, NPS-FLAG

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

936 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

The State of Arizona Game and Fish Department 

5000 W. Carefree Highway 

Phoenix, AZ 85086-5000 

(602) 942-3000 

WWW.AZGFD.GOV

Mr. Henry Provencio 

4FRI Team Leader 

USDA Forest Service, Coconino National Forest 

1824 S. Thompson St. 

Flagstaff, AZ 86001 

Re: Arizona Game and Fish Department Comments, Draft Environmental Impact Statement for the Four 

Forest Restoration Initiative 

Dear Mr. Provencio, 

The Department appreciated the opportunity to participate as a cooperating agency in preparation of the 

4FRI DEIS, the largest forest restoration project yet undertaken in the western U.S. Our partnership will 

help ensure that 4 FRI yields the greatest possible benefits to Arizona wildlife and people who value those 

resources. The Department likewise appreciated the open, transparent, and collaborative approach taken 

by the Forest Service and incorporation of the recommended watershed and wildlife research efforts. We 

look forward to continued cooperation with USFS to make this landmark effort a success on the ground. 

Our general and specific comments on the DEIS follow. 

General Comments -DEIS 

The Old Tree and Modified Large Tree Implementation Plans address challenging social concerns, while 

providing a science-based framework for retaining ecologically-valuable old trees and providing 

flexibility needed to meet restoration objectives across a complex landscape. We encourage using similar 

approaches where appropriate, in future restoration efforts on other Arizona forests. 

The Bridge Habitat section of the DEIS does much to address concerns expressed by some stakeholders 

about the degree of forest openness following treatment and potential effects on canopy-associated 

wildlife. It would be helpful if these spatial data could also be presented in a temporal context, i.e., 

illustrating progressive change at multi-year intervals over expected duration ofthe project. We understand 

that an analysis of this type may not feasible at project area scale; however an example at watershed or 

similar level would be informative.

The Department welcomes the focus on grassland restoration. Restoring encroached and degraded 

grasslands will have considerable benefits to pronghorn and other grassland-associated wildlife. In 

planning these treatments, it is important to ensure connectivity between extant grasslands and areas that 

will be restored. Please coordinate with our staff to help prioritize and coordinate these efforts. 

Riparian, wetland, and spring habitats are uncommon on the project area and of tremendous importance to 

wildlife. The Department welcomes and supports active improvement and restoration of these areas. 

Please coordinate with our staff to help prioritize and coordinate these efforts. 

Given the spatial extent and duration of the project, it would be helpful if fire and thinning treatments and 

their effects were analyzed with greater temporal resolution, i.e., more than just before/after snapshots. It 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 937
Appendix I – Summary of Response to Comments on the DEIS

would also be helpful if the fire ecology section of the DEIS addressed the potential for large wildfires 

that could occur on the analysis area during implementation. 

The Preferred Alternative includes decomissioning 770 miles of existing roads and 134 miles of 

unauthorized roads, previously identified through the Travel Management Rule (TMR) process. The 

Department previously provided comments on travel management for areas included in the 4FRI EIS. We 

remain committed to fulfilling our public trust responsibilities, preventing resource damage and ensuring 

that the public has adequate motorized access for wildlife-oriented and other recreational activities. 

Treatments on much of the analysis area reflect a regulated forest, sustained yield paradigm, which 

appears somewhat at odds with the considerable volume of material on natural range of variability, 

disturbance regimes, and restoration practice cited in the DEIS. For example, the Department has 

previously expressed and continues to have uncertainty about the use of regeneration openings in the 

context of forest restoration. That said, we understand that they reflect current guidance in the Forest 

Plans. However, for future projects, we encourage including alternatives that are more oriented toward 

ecologically-based restoration. 

The Adaptive Management component of the 4FRI project will be key to its success, but is incomplete in 

the DEIS. The Department recommends continued engagement with the 4FRI stakeholder group to 

complete this critical element. 

The DEIS acknowledges that the preferred alternative will put the analysis area on a trajectory toward 

restoration but doesn't speak to "what next." When mechanical thinning is completed, will the landscape 

be maintained by natural and prescribed fire? Or will subsequent entries of mechanical thinning be 

needed? It would be helpful to give a sense of the long-term management strategy for the area. 

Specific Comments -DEIS 

1. (Ch1 :Table 3). Please indicate percent interspace ranges (Silvi Report p 33) for canopy openness 

categories.

2 (Ch1: p21). Please provide more detailed plant community description for "pine-sage" type. 

3 (Appendix 3: p 707). Please add definition of "Mid-scale" at first mention, as done for Landscape 

Scale (p 699). 

Specific Comments -Wildlife Specialist's Report 

1. (Table 2, p 165). Fawning dates for deer are stated as May IS-August 31. Deer-fawning in the 

4FRI area would be later, from July IS basically to Aug 31. Please modifY accordingly. 

2 (Table 2, p 165). With respect to roosting habitat for turkey, clumps of older-aged trees along 

ridges and on slopes above drainages in forests above the transition zone are also important. Please 

modifY accordingly. 

3 (Table 2, p 165). Prescribed, broadcast burning during the nesting season for turkey (April ISJune IS) could result in loss of eggs or poults. We understand this is outside the normal window for such 

treatments, but nonetheless recommend deferring prescribed broadcast burning during this period. 

4 (Table 2, p 165). With respect to pronghorn, we would recommend avoiding mechanical thinning 

and hauling activities in or near known pronghorn fawning areas during times when fawns are still in the 

hiding phase (April IS-June IS). 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

938 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Specific Comments -Fisheries Specialist's Report 

1. The BMPs describe ways of reducing the impacts of prescribed burns and thinning activities to 

springs and to streams with sensitive species. These BMPs are designed to stay compliant with water 

quality standards of the clean water act. These BMPs are well thought out and are likely to accomplish 

their intended goal. However, this document recognizes the likely impact to some locations including 

those with sensitive aquatic species. Please consider monitoring ofwater quality or aquatic resources. This 

monitoring is necessary for understanding the impacts ofproposed activities to sensitive species within the 

project area. Monitoring is also necessary when determining if additional mitigation will be necessary for 

disturbed areas. 

2 (p 40). It is implied that Western Mosquitofish is a Sportfish within the state of Arizona. It is not. 

Pleas remove the term sportfish and replace with fish. 

3 (p 40). It is stated that Munds canyon would support native fish species if Odell Lake did not 

have non-native sport fish. This is speculation. Much of Munds canyon is dry during periods of drought 

and may not sustain any fish population during dry years. 

4 (p 61, 63)The terms "natural state", "natural condition" and "unnatural condition" are used when 

describing effects of vegetation management and prescribed fire (example p 61 paragraph 3 and p 63 

paragraph I) please define "natural" or delete the term and simply define the changes described within the 

altered or unaltered springs.

In summary, the 4FRl DEIS reflects a fundamental and welcome shift toward restoring natural function 

ofponderosa pine forests in Northern Arizona and bringing these areas closer to the historical range of 

natural variability. The Department is pleased to express its support for the Preferred Alternative and 

associated Forest Plan amendments. 

Sincerely, 

Craig McMullen Regional Supervisor

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 939
Appendix I – Summary of Response to Comments on the DEIS

Arizona State Forestry Division 

Office of the State Forester

1110 W. Washington Street, Suite 100

Phoenix, AZ 85007

(602) 771-1400

May 28, 2013 

Earl Stewart Forest Supervisor

Coconino National Forest -4FRI 

1824 S. Thompson Street 

Flagstaff, AZ 86001.

Re: Arizona State Forestry comments, Draft Environmental Impact Statement for the Four Forest 

Restoration Initiative

Dear Mr. Stewart:

Arizona State Forestry is very pleased to submit comments on the Four Forest Restoration Initiative - 

Draft Environmental Impact Statement prepared by the Coconino, Kaibab, Apache-Sitgreaves, and Tonto 

National Forests. State Forestry would like to commend the size and scope ofthis project. The analysis of 

988,674 acres with the potential treatment of 593,211 acres has the capability to make a significant 

difference in catastrophic wildfire loss, forest and watershed restoration, and rural economic 

development. The Draft Environmental Impact Statement (DEIS) document is the culmination of years of 

work begun in the Governor's Forest Health Council and continued in the Four Forest Restoration 

Initiative (4FRI) Collaborative.

This 4FRI project is an example of the collaborative and your staff working together to air the issues, 

followed by a negotiated zone of agreement, and ending with this huge volume of work. The effort and 

commitment of all the participants is impressive. We are very pleased to have been included and a partner 

in this process.

State Forestry is a charter member of the 4FRI Collaborative and was fully involved with the 

development of their submitted comments. We firmly believe that time is of the essence and that what can 

be done to expedite the NEPA process and begin treatments is of utmost importance.

The more time that passes before these acres are treated and the fire risk reduced, the more chance there is 

for catastrophic wildfire with the associated loss of more homes, loss of habitat, and extreme impacts to 

our watersheds.

We appreciate the opportunity to submit comments from our Agency. We wish to thank the USFS 4FRI 

team for all of their effort and cooperation in the development of the historic scale DEIS. 

Issue 1: Economic Consideration

While the DEIS does contain a Socioeconomic Resource Report, we believe that not enough attention was 

paid to the real potential of income generation. The analysis recognizes a $100 million offset of treatment 

costs, but the value of the material removed seems overlooked. This is highlighted in a footnote on page 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

940 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

24 of the Socioeconomic Resource Report, which states that the "Chediski fire burned approximately 1 

billion board feet of timber, valued at more than $300 million (Morton et al 2003)." While the details of 

these figures are not given in the DEIS, it is assumed that these figures represent values beyond stumpage.

This project is anticipated to produce "360,000 CCF of timber ...on an average annual basis throughout 

the 10-year treatment period," DEIS page 280. This is approximately 1.79 billion board feet of timber, 

that using the same numbers in the DEIS would generate approximately 

$537 million. Even though the values in the study may be outdated, we believe the scale and term of this 

4FRI project dictate a more thorough economic analysis of the potential timber revenue projections, not 

just offsetting costs of the federal government. 

Restoration and hazardous fuel reduction are commendable goals that could easily be met while 

purposefully generating revenue to benefit the forests and citizens of the country. Projects of this size, 

with equal consideration given to economic benefit have the potential of revitalizing the payments in lieu 

of taxes fund, and could make much more revenue available for local schools and counties. 

Issue 2: Prescribed Fire

One of the goals of this project is the restoration of natural fire regimes to fire-dependent landscapes and 

vegetation types. This is a goal that Arizona State Forestry supports. However, it must be done in a well 

thought out manner and cannot be done when and where conditions do not warrant. 

The DEIS, page 40 states: "Two prescribed fires would be conducted on all acres proposed for treatment 

over the 10-year period." With this hard and fast proclamation, there is a concern that natural resource 

objectives, public safety, public health, and protection of private property could be compromised. We 

request that this statement be replaced with one that emphasizes an accelerated prescribed fire program 

with a goal of burning each proposed acre twice over a ten year period. 

Issue 3: Large Tree Retention Strategy

State Forestry believes that the essence of stakeholder-produced Old Growth Protection and Large Tree 

Retention Strategy are included in the DEIS's Old Tree and Modified Large Tree Implementation Plan.

The explanations for this decision given on Table 15, pages 60-61 DEIS show that the USFS incorporated 

the substance and intent of the stakeholder documents. USFS land managers need the flexibility provided 

in this strategy to make appropriate on-the-ground decisions across this diverse landscape.

Issue 4: Impact to Local Roads and Highways

The DEIS, page 302, states "The 4FRI project area encompasses the Arizona communities of Flagstaff, 

Mountainaire, Munds Park, Kachina Village, Mormon Lake, Doney Park, Parks, Williams, and Tusayan. 

Major access routes include Interstates 40 and 17, U.S. Highways 89, 180, and 66, State Route 64, 

County Road 73, and Lake Mary Road (Forest Highway 3)." This project is anticipated to significantly 

increase logging truck traffic on all these major access routes. A preliminary analysis done by Arizona 

State Forestry, Governor's Forest Health Council, Eastern Arizona Counties, and others, found that 

implementing 4FRI will result in approximately a $2 million increase in road maintenance for State, 

County, and municipal roads. 

The Transportation Specialist's Report does not include any analysis of roads not located on the National 

Forests. We would like to request a more thorough analysis of the impact and cumulative impacts to the 

local infrastructure be completed and included in the Final EIS and Record of Decision. We offer to help 

with this analysis and to work with other State and local agencies.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 941
Appendix I – Summary of Response to Comments on the DEIS

Issue 5:Water Yield

In the DEIS pages 38-39 and 47, water yield is considered, but only as a potential research item. There is 

not any emphasis on actually designing treatments to capture snowfall and increase water flow. The 

effects analysis recognized that water yield from these forest "is likely reduced from historic conditions 

due to forest ingrowth and dense stand conditions" DEIS, page 102. On this same page, the analysis of 

alternatives recognizes "Water yield would be expected to increase only slightly in areas where vegetation 

treatments remove 25 to 50 percent of the overall tree canopy cover within a given watershed." There is 

not any focus on this issue nor is there text stating that this is an issue of concern. There is no recognition 

that within the present alternatives, implementation could be designed with the intent of increasing 

snowfall retention and water yield.

With Arizona's continued drought and significant water demands, this project should do what it can and 

where it can to consciously increase water yield. We request that the Forest Service recognize this is an 

important issue that deserves more consideration. In many places, where there are no substantial conflicts 

with other resource needs, the FS should consider increasing the width of openings to 1.5 to 2 times the 

tree heights with the intent of increasing snow pack; with the openings generally situated perpendicular to 

the slope. This should especially be considered on north facing slopes that receive less direct sunlight, 

thus allowing the snow pack to last longer and get deeper and produce more ground water. The Forest 

Service should work with experts in this field to design and implement other aspects of treatments that 

will increase water yield.

Increased snow pack will mean more soil moisture for the trees and shrubs, benefiting wildlife, and 

should lead to increased water yield. InArizona particularly, this should be something that the National 

Forests strive for, especially where these treatment designs would work well with the other resources of 

concern.

Issue 6: Cumulative Effects

Two employees of State Forestry met with the Forest Service 4FRI development team to examine the 

extent of site specific analysis and cumulative effects analysis that was done for this project. Given this, 

we do have concerns with the cumulative effects analysis. Trying to assess and determine if the 

cumulative effects analysis was thorough was extremely difficult. The DEIS contains Appendix F - 

Cumulative Effects, but this has only a portion of the actual cumulative effects in it. Much of the 

cumulative effects are presented in Chapter 3 - Affected Environment, and most of it is "incorporated by 

reference" in the specialist reports. In all these places, the cumulative effects were presented in a wide 

variety of formats. The degree of analysis also varied widely; some analysis was in-depth, gave the 

measures, and the conclusions were well supported; while other analysis was brief and appears to only be 

a statement of professional opinion. This could be satisfactory if the measures and the rationale for the 

professional opinion were also included. 

We request that a hard look be given to the cumulative effects analysis; that it be organized and 

thoroughly indexed. The index should link Chapter 3, Appendix F, and the Specialist reports.

We also request that a common format be used, and the measures be clearly presented. We make this 

request because cumulative effects as presented may present a very strong vulnerability of the DEIS.

Issue 7: Missing Information

In Chapter 3, Affected Environment, page 311, and in Appendix F the Cumulative Effects, page 675, it 

states "A summary from the range specialist report is presented here and the complete report is 

incorporated by reference (Hannemann 2013)." On the Forest Service web site, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

942 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

http://www.fs.usda.gov/detail/4fri/home/?cid=STELPRDB5292025 the referred to range specialist report 

is not listed. We request that this be made available for review.

Summary

The agency is supportive of the preferred alternative and associated Forest Plan amendments. State 

Forestry commends this historic landscape project that offers the potential to make substantial progress in 

protection of our forested communities, restoring our forests and watersheds, and providing much needed 

economic opportunities in our forest dependent communities. The comments submitted by Arizona State 

Forestry are done so with the intent to strengthen and help speed the implantation ofthis project.

Sincerely,

Scott Hunt State Forester

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 943
Appendix I – Summary of Response to Comments on the DEIS

Coconino Natural Resource Conservation District 

28 May 2013 

Scott Harger

Program Range Conservationist

Coconino Natural Resource Conservation District (CNRCD) 703 E. Sawmill Road

Flagstaff, AZ 86001

928.527.9050

cannonbone@msn.com

Henry Provencio 4FRI Team Leader 1824 Thompson St.

Flagstaff, AZ 66001

928.226.4684

hprovencio@fs.fed.us

Earl Stewart

Forest Supervisor, Coconino National Forest – 4FRI 1824 S. Thompson St.

Flagstaff, AZ 86001

Comments submitted via 4fri_comments@fs.fed.us

Subject: 4FRI DEIS, 29 March, 2013 (Based on NOA) 

Dear All:

CNRCD is pleased to respond to your request for comments on the subject DEIS.

1. This DEIS is a very impressive accomplishment. Despite its unprecedented scope, the 

collaborative effort associated with 4FRI has made it very familiar and relatively easy to follow, 700 plus 

pages notwithstanding. We are particularly pleased with the appendices C, F, and G. 

CNRCD hopes that Alternative C will be chosen to implement the much needed restoration of this portion 

of the 4FRI. 

2. That same familiarity has raised our confidence level considerably. As a stakeholder in the 4FRI 

collaboration, we have considered and endorsed the comments submitted by that organization. We think 

that the DEIS evaluation committee and subcommittees were also the beneficiaries of the extended 

collaborations, and have submitted a very minimalist set of comments. From the CNRCD standpoint, we 

wish to emphasis our interest in the USFS responses to 4FRI Key Issues 1 (Degree of Openness) and 6 

(Monitoring and Adaptive Management.)

4FRI Issue 1 (Openness.) Since the success of implementing this vast project is largely a product of how 

treatments are implemented at the stand level, we will be looking hard at the response to collaborative 

comments regarding quantification of openness, operator training, monitoring, and adaptive management. 

4FRI Issue 6 (Monitoring and Adaptive Management.) We always try to stay focused on implementation, 

impacts, and mitigation when we review an EIS. It is hard for us to know if we should expect the 

Implementation Plan or the Monitoring and Adaptive Management Plan to be more complete at this stage. 

Again, we will be looking very hard at the USFS responses to all five recommendations under Key Issue 

6, (Monitoring and Adaptive Management,) of the 4FRI Comments. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

944 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

3. CNRCD is a long-time member of the Greater Flagstaff Forest Partnership (GFFP) and sits on 

their board. We have reviewed their comments, and endorsed them. 

4. CNRCD has the following specific comments and requests to make:

Page 24: Is there a need to “reduce excessive surface fuel loadings in areas adjacent to and within...” 

values at risk besides MSO habitat, like WUI’s, streamside protection zones, recreation infrastructure, 

nest sites, and other patches of “dense” forest? We suspect the answer must be yes and needs expansion 

for the FEIS.

Page 38 1st Para under Response: It is unclear how elements of the Vegetation Analysis have been 

incorporated. Is it referenced? The results of this analysis probably made their way into one or more 

tables – could you include a pointer in the text?

Pages 55-56 Grazing and Livestock bullets: Although we are nominally satisfied with the content of the 

bullet arguments made here regarding grazing as part of an alternative, we strongly suggest that the USFS 

make a fine point of the adjustments to past practices that will come from reintroduction of fire as a 

management tool to restored areas with grazing allotments. 

Page 339: “Scott Harger, NRCS” should read “Scott Harger, CNRCD”

Pages 397 and 689, Table 152, Grazing; Please send a copy of the Range Specialist Report, Coconino and 

Kaibab Four-Forest Restoration Initiative (4FRI), DEIS. Ms. Said to be on file at CNF, 4FRI project 

record. 44pp, to Scott Harger. E-mail preferred.

Pages 573-575 Rangeland Management section: We are surprised to read the statement that “Restrictions 

in grazing of livestock would primarily occur after prescribed fire in a pasture.” We are not surprised by 

post-fire restrictions, but by the omission of pre-burn grazing prescriptions to allow for sufficient fine 

fuels accumulation to support a prescribed burn. If pre-burn restrictions are not needed or expected, 

would you please specifically say so? This would provide the clarity that is craved by our ranching 

constituency. This issue has been raised in stakeholder meetings.

Pages 622-625: This is another comment regarding quantification of openness, specifically proportions. 

We are concerned about ranging sufficiently about the median values for BA, interspaces, etc. We look 

forward to this discussion in the FEIS.

Page 628, LOPFA Burn Only Treatment Design: Should say “Prescribed fire will be used...” instead of 

“...may be used...” This is the only case where “may” needs substitution, although we would like to see 

“will” used in all treatment designs.

Page 641 Prescribed fire bullets, and page 674 App E Table 145: Do the USFS fire regime or FRCC 

model(s) function for Pine-Sage and Grassland ecotypes? In other words, do the results change after 

treatment? This is important to understand so that in monitoring we use the right criteria to measure 

effectiveness. Is it judged by FRCC change, or the fact that prescribed fire may be used subsequent to 

treatment? A brief clarification in the FEIS would be helpful. 

Scott Harger

Cc: CNRCD Clerk of the Board GFFP Admin

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 945
Appendix I – Summary of Response to Comments on the DEIS

Arizona Department of Environmental Quality 

Brad Busby, Smoke Management Coordinator

1110 West Washington Street

Phoenix, AZ 85007

(602) 771-7676

busby.bradley@azdeq.gov

5/29/2013

Thank you for the opportunity to comment on the Draft Environmental Impact Statement for the FourForest Restoration Initiative. The alternatives described may include the use of prescribed fire, amongst 

other methods, to achieve land management objectives throughout much of the project area. As you are 

aware, prescribed fire creates smoke that includes a complex mix of air pollutants. Prescribed fire 

planning must consider the effects of smoke on sensitive areas and address potential impacts of smoke on 

air quality and the public in terms of health, nuisance, and visibility. 

The project area is large, encompassing many smoke sensitive communities, with some proposed burn 

areas located near Class I Areas. Clean Air Act (CAA) requirements include the protection of visibility in 

Class I Areas and avoidance of violations of the National Ambient Air Quality Standards. All Prescribed 

fire projects must also comply with the requirements of Arizona Administrative Code R18-2-1501 

through 1515, Forest and Range Management Burns. These are rules which manage for smoke emissions 

that are produced from prescribed fire activities in Arizona. A copy of those rules can be obtained at the 

following Web site:

http://www.azsos.gov/public_services/Title_18/18-02.htm 

In addition to these initial measures for air quality, we appreciate your willingness to work within the 

Arizona Enhanced Smoke Management Program. We encourage you to actively

pursue any emission reduction techniques that can be utilized to mitigate smoke emissions. These 

techniques should be included in future analyses as measures that will be used to help reduce impacts on 

air quality. Conducting burns using aerial ignition, burning in a mosaic pattern, isolating fuels, burning 

before green-up, and using backing fire are just some of the techniques commonly used to reduce 

emissions from prescribed burns. Additionally, it is always helpful to do a public notification for smokesensitive individuals prior to burning as a way to address the public’s potential smoke concerns.

Please contact me if I can be of any assistance or clarify any of the above statements.

Sincerely,

Brad Busby 

Arizona Department of Environmental Quality 

Smoke Management Coordinator 

(602) 771-7676 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

946 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

U.S. Department of the Interior 

Office of the Secretary

Office of Environmental Policy and Compliance

Pacific Southwest Region

333 Bush Street, Suite 515

San Francisco, CA 94104

29 May 2013 

Henry Provencio Team Leader

Tonto National Forest Supervisor Office

U.S. Forest Service 2324 E. McDowell Road Phoenix, Arizona 85006

Subject: Draft Environmental Impact Statement (DEIS) US Forest Service (USFS), Four- Forest 

Restoration Initiative, Coconino and Kaibab National Forest, AZ 

Dear Mr. Provencio:

The Department of the Interior (Department) is providing comments on the U.S. Forest Service’s (USFS) 

Draft Environmental Impact Statement (DEIS) for the Four-Forest Restoration Initiative (4FRI) on the 

Coconino and Kaibab National Forests (NFs), Arizona. 

We would like to express our support for this important project and appreciation for your willingness to 

work with us to incorporate listed and sensitive species’ needs into proposed action alternatives. Over the 

last 8 years, resource management staff within Departmental bureaus have participated in the 4FRI 

collaborative planning process. The 4FRI would address fire risk reduction and forest health within 

remaining watershed and view-shed areas.

Mexican Spotted Owl Recovery Plans

Overall, the DEIS is inconsistent in how it cites or refers to the original 1995 Mexican Spotted Owl 

Recovery Plan or the 2012 Revised Recovery Plan for the Mexican Spotted Owl. We recommend the 

Final EIS and supporting documents clearly articulate which Recovery Plan is being referred to in the 

text, use the appropriate terminology, and cite it appropriately.

We understand the existing Land and Resource Management Plans (Forest Plans) for the Coconino and 

Kaibab National Forests include standards and guidelines from the 1995 Recovery Plan, and we 

appreciate efforts to incorporate information from the 2012 Revised Recovery Plan. However, it is unclear 

how or which guidance is being applied from which Recovery Plan. If there is any technical assistance we 

can offer you to provide clarity, please contact the U.S Fish and Wildlife Service (FWS), Flagstaff 

Ecological Services Field Sub-Office.

Summary

Summary, page iii: In the summary, and throughout the DEIS, the word “mortality” is used improperly. 

“Mortality” is a rate and” fatality” is the act of dying. For example, third paragraph of the summary 

section states, “The remaining old pines are at risk of mortality from the increased overcrowding of 

trees...” The old trees are at risk of fatality from the stated factors. We recommend as the DEIS is edited, 

the use of these terms be corrected throughout.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 947
Appendix I – Summary of Response to Comments on the DEIS

Major Conclusions, page xi: This section states to varying degrees, all action alternatives (B-D) meet the 

forest structure and pattern, forest health, and vegetation composition and diversity elements of the 

purpose and need. However, when reviewing summary data and information provided in Chapter 3 

(Affected Environment and Environmental Consequences), it is unclear how Alternatives B and D 

improve large oaks, compared to Alternative C (eighth bullet, page xi). 

Large Gambel oak trees are an important key habitat component in ponderosa pine forests for the 

threatened Mexican spotted owl (Strix occidentalis lucida), their prey species, and many migratory bird 

species. Alternative C would be more conducive to maintenance and development of large oaks. We 

recommend providing more clarity regarding this determination in the Final DEIS. 

Major Conclusions, page xii: The top of this page states, “All action alternatives provide and sustain 

long-term Mexican spotted owl nesting and roosting habitat and reduce the risk of high severity wildland 

fire and other natural disturbances.” After reading Chapter 3, it seems that not all action alternatives are 

equal in this respect. Both Alternatives B and D allow for burning in 72 Mexican spotted owl Protected 

Activity Centers (PACs), but exclude the nesting and roosting cores.

One of the comments the Mexican Spotted Owl Recovery Team received consistently from USFS fire 

management staff over the years is it is unrealistic to implement prescribed burns in most PACs, but 

exclude the core areas. Since neither Alternative B nor D allows for prescribed fire to enter core areas, 

these important habitats could be at higher risk for high severity wildland fire in the future and may be 

adversely impacted by efforts to prevent fire from entering core areas through the creation of fire breaks 

between the adjoining PAC habitat and the core areas. 

We recommend the USFS continue to work with us to determine what actions will provide the most longterm benefit to the Mexican spotted owl nesting and roosting core habitat.

This section also states, “Alternative D (reduced use of prescribed fire) increases forest resiliency to 

large-scale impacts (including climate) in the short term. In the long term, however, over 300,000 acres 

would return to pretreatment conditions and would be susceptible to high-severity surface effects, which 

equates to reduced resiliency to natural disturbance.”

From this description, Alternative D, which allows for prescribed fire on 178,790 acres (or 414,421 acres 

less than the Preferred Alternative C), does not meet the purpose and need of the project as described on 

page iii and in Chapter 1. We recommend providing more clarification in the summary and Chapter 3 

discussions of Alternative D to better demonstrate how this alternative will reestablish and restore forest 

structure and pattern, forest health, and vegetation composition and diversity by allowing for the return of 

fire on only approximately 30 percent of the acres proposed for prescribed burning in Alternatives B and 

C.

Chapter 1 – Purpose and Need for Action

Mexican Spotted Owl Habitat, page 13: The Northern goshawk section on page 12 begins with a 

summary of the existing acres of habitat in the project area. We recommend this be done for the Mexican 

spotted owl section as well to improve clarity of the discussion in this section. The habitat acreages are 

provided in Table 7, but there is no description in the text of the total acres of Mexican spotted owl habitat 

or definitions of protected, restricted other, and restricted target/threshold habitat. 

Final Proposed Action, Amendment 1, page 41: There is a significant typographical error in the second 

paragraph under this header. The amendment which would allow for designating less than 10 percent of 

restricted habitat should be for the Kaibab NF, not the Coconino NF. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

948 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Final Proposed Action, Amendment 2, page 42: This paragraph is unclear. Is the paragraph stating 

Amendment 2 would allow for both designating less than 10 percent restricted habitat in pine-oak as 

target or threshold AND remove language that limits PAC treatments in the recovery unit to 10 percent?

In addition, though the current Forest Plan incorporates the 1995 Recovery Plan language regarding 

treating only 10 percent of the PACs within a Recovery Unit and then evaluating those treatment effects 

before treating additional acres, this language does not discuss treating in “increments of 10 percent.”

We recommend clarifying the description of this amendment so it is clear to the reader what this 

amendment is modifying in the Kaibab NF Plan.

Chapter 2 – Alternatives

Incorporate the Original Large Tree Retention Strategy (LTRS), pages 56-58: All though this section 

is designed to articulate to the public why the LTRS was not an alternative analyzed in detail, it neglects 

to provide information indicating how the USFS intends to protect large trees. We recommend providing 

examples from proposed Mexican spotted owl and northern goshawk habitat management (included in all 

action alternatives to some degree) that will work to maintain and protect large, old trees throughout the 

project area.

This section focuses on all of the reasons why the USFS may need to cut large trees, but does not describe 

how the alternatives analyzed in detail provide for large tree protection. This comment also applies to the 

following section regarding limiting mechanical treatments to 16 inches diameter-at-breast height (d.b.h.) 

trees as a means to preserve large trees. This information could be included by reference with a single 

sentence added to each section that references later sections in the DEIS.

Although we understand the need to keep these sections brief and to the point regarding why these 

alternatives were not analyzed in detail, we believe it would support the argument to include a short 

statement indicating that removal of large, old trees would still be the exception and not the common 

practice of any of the action alternatives.

Alternative B – Proposed Action, page 63: This section lists several bullets describing the alternative 

(e.g., number of acres to be thinned and burned, number of acres to be burned only, etc.). This format is 

repeated for Alternatives C (page 80) and D (page 87). We recommend after each bullet, the Final DEIS 

provide where the appropriate documentation or data can be found for each of these alternative 

components. For example, the bullet “Utilize prescribed fire only on approximately 199,435 acres” would 

be followed by where in the document, website, or other location the information regarding that 

component could be found. 

This would assist the public in finding the information needed to understand each of these alternatives and 

provide for better communication. 

Alternative B Tables and Figures, Table 17, page 70: The treatment description/objective for Mexican 

spotted owl threshold and target habitat are listed as being the same treatment in this table (this is also 

true in Tables 24 and 27 for Alternatives C and D, respectively). Threshold habitat is habitat coming close 

to providing replacement nesting and roosting habitat for Mexican spotted owls.

Though treatments can occur in threshold habitat, it is important key habitat components not be reduced 

beyond specified points. However, target habitat is habitat on a trajectory to becoming threshold habitat, 

but may need more active management to develop the habitat components of nesting and roosting habitat. 

Therefore, habitat identified as threshold should not have the same treatment description/objective as 

target habitat. We recommend providing additional clarity in the biological assessment regarding 

treatment descriptions and objectives for Mexican spotted owl target and threshold habitats.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 949
Appendix I – Summary of Response to Comments on the DEIS

Amendment Descriptions for Alternatives B, C, and D (pages 64, 80-81, 87-88): We recommend 

including information regarding the benefit to the Mexican spotted owl from including the proposed 

amendments. Currently, these sections clearly articulate how the Forest will not be following the existing 

forest plans, but do not describe how the use of the amendments could benefit Mexican spotted owl 

habitat. There may be less confusion regarding the public’s acceptance of these amendments if their 

habitat management needs were articulated as well.

For example, for Alternative C, Amendment 1 (page 80), the initial cause for and amendment could be 

modified to state (italicized text is our addition): “Amendment 1 would allow mechanical treatments up to 

18-inches d.b.h. in order to improve habitat structure by promoting large tree growth, creating small 

openings to increase prey habitat diversity, and other site- specific goals in 18 Mexican spotted owl PACs.

Large trees in owl PACs would not be targeted for removal, but would be removed as indicated to meet 

habitat and fuels protection objectives.”

Adding additional explanation clarifies the need and justification for the amendment and should be 

provided for each of the amendment descriptions.

Tables 21 (page 76), 26 (page 85), and 29 (page 92): We recommend providing clarification as to 

whether the “Protected Habitat (Acres)” listed in these tables include only PAC acres or if it also includes 

protected steep-slope habitat. If the acreage includes both PACs and steep-slope habitat, we recommend 

splitting these out for ease of analysis in the biological assessment.

Chapter 3 – Affected Environment and Environmental Consequences

Soils and Watershed, Forest Plan Amendments, Alternative B and D, Coconino NF, Amendment 1 

(page 117): This paragraph states Amendment 1 would result in the removal of more trees in 18 Mexican 

spotted owl PACs since trees up to 16 inches d.b.h. could be removed. The paragraph then goes on to 

describe removal of additional trees would improve vegetative ground cover. However, we question 

whether this would result in more trees being removed versus different trees being removed.

The point of increasing the diameter cap is not necessarily to remove more trees (though that may occur), 

but to improve our ability to implement uneven-aged management. We recommend this analysis should 

focus more on the desired conditions in PACs (see Revised Recovery Plan, Appendix C, pages 275-277) 

and less on the number of trees to be removed. We recommend focusing the discussion of effects on how 

increasing the diameter cap better allows us to meet the desired conditions for owl nesting and roosting

habitat (uneven sized/aged groups, multistory canopy), versus merely removing more trees.

This comment also applies to the analysis for the increased diameter cap of 18 inches d.b.h. for 

mechanical removal of trees in Alternative C.

Soils and Watershed, Forest Plan Amendments, Alternative C, Coconino NF, Amendment 1 (page 

118): We recommend including language discussing how there may be adverse effects to PACs from 

attempting to keep prescribed fire out of nest cores while burning the rest of the PAC. This section 

describes the benefits of introducing low intensity prescribed fire, but should also include what 

management actions would need to be implemented (e.g., creation of fire line, cutting of snags) to 

preclude fire from these areas.

We also recommend stating there would likely be additional acreage within the PAC that would not be 

burned in order to keep fire from the nest core, so these areas would continue to be at risk from highseverity fire.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

950 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Vegetation, Kaibab NF, Amendment 2 in alternatives B and D (page 144) and Amendment 3 in 

alternative C (page 145): This section states if this amendment did not occur, treatments within Mexican 

spotted owl habitat would continue to meet the intent of the Mexican spotted owl Recovery Plan. We 

respectfully disagree with these statements as meeting the intent of both the original 1995 and 2012 

Recovery Plans. Though there were specific recommendations to not cut above 9 inches d.b.h. in PACs in 

the 1995 Recovery Plan, this was included as a protective measure until more could be learned about 

thinning and burning within PACs. 

The overall intent of both plans is to implement actions that maintain and/or enhance owl nesting and 

roosting habitat while monitoring to learn from these actions. If these amendments are not included and 

we are unable to use uneven-aged management to remove trees in PACs and increase the resiliency and 

sustainability of these areas, while monitoring the effects of our actions on owls, we will not meet the 

intent of the Recovery Plan. We recommend the USFS consider modifying this language throughout the 

DEIS to better articulate what will happen without the amendments.

Our interpretation is that limited thinning would occur within these PACs (up to 9 inches d.b.h.) that 

would remove some ladder fuels, but would not allow for release of overtopped Gambel oak, would not 

allow for creating small openings to increase prey habitat diversity, and would likely not allow us to learn 

how to treat these areas to maintain Mexican spotted owl occupancy and reproduction. 

Terrestrial and Semi-aquatic Wildlife and Plants

Table 65, Threatened, endangered, candidate, and sensitive species evaluated in this analysis (page 

175): We recommend including in the “Status” column of this table: “the bald eagle (Haliaeetus 

leucocephalus) is also protected under the Bald and Golden Eagle Protection Act (BGEPA).” In addition, 

the golden eagle (Aquila chrysaetos) is also a federally-protected species under the BGEPA, and should 

be included in this table.

The Bald and Golden Eagle Protection Act (16 U.S.C. 668-668c), enacted in 1940, and amended several 

times, prohibits anyone, without a permit issued by the Secretary of the Interior, from "taking" bald 

eagles, including their parts, nests, or eggs. BGEPA provides criminal penalties for persons who "take, 

possess, sell, purchase, barter, offer to sell, purchase or barter, transport, export or import, at any time or 

any manner, any bald eagle ... [or any golden eagle], alive or dead, or any part, nest, or egg thereof." The 

Act defines "take" as "pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or 

disturb." 

"Disturb" means: “to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, 

based on the best scientific information available, 1) injury to an eagle, 2) a decrease in its productivity, 

by substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest abandonment, 

by substantially interfering with normal breeding, feeding, or sheltering behavior." 

In addition to immediate impacts, this definition also covers impacts that result from human- induced 

alterations initiated around a previously used nest site during a time when eagles are not present, if, upon 

the eagle's return, such alterations agitate or bother an eagle to a degree that interferes with or interrupts 

normal breeding, feeding, or sheltering habits, and causes injury, death or nest abandonment. 

Mexican spotted owl, Summary of Habitat Conditions (pages 179-180): Though we agree many 

Mexican spotted owl habitats are at risk from stand density-related mortality, we recommend more detail 

regarding the current stand conditions be included. 

Owls currently reproduce successfully across the project area; if all Mexican spotted owl habitats were in 

a non-functioning condition, this would not be the case. Though there is much opportunity to improve the 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 951
Appendix I – Summary of Response to Comments on the DEIS

resiliency and sustainability of these habitats, we would expect to maintain patches of habitat that 

continue to be denser than the majority of the landscape in order to provide the canopy cover and other 

habitat conditions typical of nesting and roosting locations. 

In addition, we recommend including a citation for the statement, “There is decreased quality in prey 

habitat due in part to uncharacteristic canopy connectivity from in-growth of smaller trees inhibiting 

herbaceous understory development.” 

MSO Habitat – Environmental Consequences

Alternatives B, C, and D – Direct and Indirect Effects (page 181) and Springs, Ephemeral 

Channels, Meadows, and Aspen (page 186): Please include in the analysis of effects, the effect of 

constructing fence within PACs to protect aspen. We would like to see the amount of proposed fencing to 

be constructed and what materials will be used included in the description of potential effects from the 

aspen treatments.

Forest Structure in PACs (page 181): For the Final DEIS, we recommend removing all references to the 

“draft recovery plan.” The Final Revised Recovery Plan for the Mexican Spotted Owl was issued in 

December 2012 and is no longer a draft document. 

Disturbance (page 184): We recommend including more information regarding hauling and potential 

effects to Mexican spotted owls. It is our understanding that hauling could occur at any hour, including 

the middle of the night in the early breeding season (March – April) in order for trucks to operate on 

frozen ground. 

In addition, it is possible over the life of this project (10 to 15 years) that with all of the additional trucks 

moving through Mexican spotted owl habitat at all hours of the day and night, it is possible owl could be 

struck by a truck. This possibility should be disclosed in the effects section. 

This section states, “Core areas would be protected from prescribed fire by using roads, natural barriers, 

or new fire line to contain burn units. Building line would occur outside the nesting season.” Fire line 

construction in PACs frequently results in the loss of key habitat components (snags, large logs). Fire 

lines can also turn into social trails used by motorized vehicles. 

We recommend including information regarding these potential effects of eliminating low intensity 

prescribed fire from all nest cores.

Forest Service Sensitive Species

Table 70 and Table 71, Northern leopard frog (pages 194-195, 201): We appreciate you working with 

us and the Arizona Game and Fish Department to develop and include protective measures for the 

northern leopard frog (Lithobates pipiens) as a part of this project. Your continued efforts to assist with 

the conservation of this imperiled species are appreciated.

Table 71, Bald Eagle (page 202): The effects analysis for the bald eagle should include a determination 

of whether or not take will be avoided (and how) per the BGEPA. In addition, we recommend the analysis 

of effects include the definition of disturbance from the BGEPA (included in our comments above). The 

description of effects in this table indicates there could be disturbance of eagles, which would be 

considered take under the BGEPA. 

We will continue to provide technical assistance in regards to the effects analysis and work with you to 

develop conservation measures to reduce and/or remove adverse effects from the proposed action.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

952 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Table 71, Narrow-headed gartersnake (page 211): In the description of environmental consequences 

for the gartersnake, spring restoration is noted as providing beneficial effects for the species. Which 

springs has the Forest identified for restoration to improve habitat for the narrow-headed gartersnake?

Northern Goshawk, Environmental Consequences, Other Activities (page 222): This section states 

that Mexican spotted owl habitat supports lower densities of rodent prey species than would habitat 

treated to meet goshawk habitat direction in the forest plan. Please provide information in the DEIS to 

support this statement. Though we agree that providing habitat for a generalist species, such as the 

northern goshawk, across a large landscape would likely provide for higher densities of some prey 

species, we disagree that Mexican spotted owl nesting and roosting, foraging, and dispersal habitat does 

not also provide habitat for a variety of prey species. 

In addition, habitat management recommendations in the Revised Recovery Plan for the Mexican Spotted 

Owl should result in increased prey species diversity and densities across large areas as well (FWS 2012).

Other Protected Species, Golden Eagle (page 222): Because the golden eagle is protected by the 

BGEPA, we recommend moving the information and discussion regarding the golden eagle up to the 

section that includes federally-protected species, and so that it is presented closer to the discussion 

regarding the bald eagle. 

Appendix D – Alternatives B Through D Implementation Plan, Section A – Management Direction, 

Desired Conditions, and Treatment Design, MSO Habitat (pages 610-617): We are available to work 

with the USFS staff to refine the implementation plan for the Mexican spotted owl and its habitat. We 

recommend planning an upcoming meeting to refine this guide in order to meet our mutual project 

tracking needs.

Appendix E – Alternatives B Through D Monitoring and Adaptive Management Plan (pages 659- 

674): There will be monitoring conducted to evaluate the effects of the proposed treatments on Mexican 

spotted owls that has yet to be defined, but will be included in the biological opinion for this project.

When completed, we would like to see the monitoring plan adopted into the Adaptive Management Plan. 

Appendix G – Bridge Habitat, MSO Protected, target/threshold, and restricted habitats (page 703): 

This section states, “Protected habitat is generally densely forested, target/threshold habitat is similar to 

protected habitat, and restricted habitat is slightly less dense than protected but still more densely forested 

relative to the surrounding treated areas outside of Mexican spotted owl designations.” Tree density is not 

a key habitat component of Mexican spotted owl habitat. 

If we are trying to convey nesting/roosting habitat within protected activity centers and replacement

nesting and roosting habitat patches (i.e., target/threshold habitat) provides higher canopy cover, more 

large trees, and tends to be more decadent than random or other patches of habitat, we would concur. 

However, we do not believe tree density is a measure of owl habitat. In addition, other restricted habitat 

(not identified as target/threshold) is treated to varying degrees as described in the DEIS, but our 

understanding is that it will be relatively open (70 to 90 square feet per acre basal area). We recommend 

re-wording this initial description to reflect the relatively more closed-canopy condition it will provide 

versus describing it as “dense.”

Appendix G – Bridge Habitat, Implementation guide – MSO guidance (page 709): We recommend 

these guidelines be modified to reflect the proposed alternatives. For example, the first bullet states, 

“Each PAC has a 100-acre, no treatment area around the known nest or roost site.” Depending upon 

which alternative is implemented this may or may not be true. In Alternative C, some nest cores may be 

mechanically treated and burned. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 953
Appendix I – Summary of Response to Comments on the DEIS

We encourage the USFS to clearly state this in the appendix to be clear to the reader what design feature 

will be implemented under each alternative.

We appreciate the opportunity to review 4FRI DEIS. The Department agrees with the USFS that moving 

forward with the 4FRI project is vital to landscape restoration, wildfire risk reduction, wildlife habitat 

management, watershed function, and scenic quality and visitor retention with the project area.

The Arizona Ecological Services Field Sub-Office is available to discuss these comments with the USFS.

If you have any questions or need additional information, please contact Steve Spangle, Supervisor, 

Arizona Ecological Services Field Office, Phoenix, Arizona, at 602-242- 0210, or Paul Whitefield, 

Natural Resource Specialist, Flagstaff Area Monuments, Flagstaff, Arizona, at 928-526-1157 extension 

235. 

Sincerely,

Patricia Sanderson Port Regional Environmental Officer 

cc:

Director, OEPC

OEPC Staff Contact: Lisa Chetnik Treichel Regional Director, FWS, Albuquerque, NM Steve Spangle, 

Supervisor, FWS 

Paul Whitefield, Flagstaff Area Monuments

Michelle Shaughnessy, Assistant Regional Director, FWS Vanessa Burge, NEPA/ER/Sikes Act 

Coordinator, FWS 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

954 Coconino and Kaibab National Forests 
Eastern Arizona Counties Organization 

550 N. 9th Place 

Show Low, AZ 85901 

(928) 637 3037

May 25, 2013 

Earl Stewart, Forest Supervisor,

Coconino National Forest – 4FRI

1824 S. Thompson Street

Flagstaff,

AZ 86001

Electronic filing: 4fri_comments@fs.fed.us

File Code: Four-Forest Restoration Initiative EIS: Kaibab and Coconino #34857 

Re: Eastern Arizona Counties Organization comments on the Draft Environmental Impact 

Statement for the Four-Forest Restoration Initiative.

Dear Responsible Official,

The Eastern Arizona Counties Organization is a local government organization created in 1993 by 

joint resolutions of the Boards of Supervisors and an Intergovernmental Agreement (IGA) 

between the Counties of Apache, Gila, Graham, Greenlee and Navajo to implement Presidential 

Executive Order 12372 (P.E.0. 12372) Intergovernmental Review of Federal Programs related to 

the clearinghouse process for review of Federal programs which affect the custom, cultures and 

economic well-being of the Counties. 

The Eastern Arizona Counties Organization has been a stakeholder in the effort to develop and 

implement landscape scale forested ecosystems restoration for the last decade and has been 

involved in the creation of the White Mountains Stewardship Project; the Governor’s Forest 

Health Council’s Statewide Strategy for Restoring Arizona Forests; the collaborative Analysis of 

Small-Diameter Wood Supply in Northern Arizona; and, what has become the Four Forest 

Restoration Initiative.

The Eastern Arizona Counties Organization appreciates the opportunity to comment on the Draft 

Environmental Impact Statement for the Four-Forest Restoration Initiative, and would like to 

offer the following comments, gap analysis and suggested actions.

For ease of reading, the Eastern Arizona Counties Organization comments have been organized in 

chapter form, and a table of contents is inserted on the following page to facilitate the navigation 

of the document. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 955
Appendix I – Summary of Response to Comments on the DEIS

Eastern Arizona Counties Organization’s Objectives as Expressed 

in its Plans and Policies

Eastern Arizona Counties Organization

The Eastern Arizona Counties Organization is a local government organization created in 1993 by 

joint resolutions of the Boards of Supervisors and an Intergovernmental Agreement (IGA) 

between the Counties of Apache, Gila, Graham, Greenlee and Navajo to implement Presidential 

Executive Order 12372 (P.E.0. 12372) Intergovernmental Review of Federal Programs related to 

the clearinghouse process for review of Federal programs which affect the custom, cultures and 

economic well-being of the Counties. 

Following Arizona Governor Executive Orders 90-21 and 83-6, the Policies and Procedures for 

Arizona’s Review Process in Compliance with Presidential Executive Order 12372 were 

established, and Apache, Gila, Graham, Greenlee and Navajo Counties, regrouped into the 

Eastern Arizona Counties Organization, were designated as County Official Reviewers (COR) for 

the explicate review of direct federal projects by the U.S . Department of Agriculture and its 

respective agencies (U.S. Forest Service, Soil Conservation Service and Farmers Home 

Administration) and the U.S. Department of the Interior and its respective agencies (Bureau of 

Land Management, National Park Service and U.S. Fish and Wildlife Service) affecting their 

areas.

For 20 years since its creation, the Eastern Arizona Counties Organization has been representing 

the custom, culture, health, safety and economic well-being needs of its county members’ 

residents and visitors with Federal and State agencies engaging in projects addressing a broad 

range of issues, with an emphasis on natural resources management.

The five counties (“the Counties”) of the Eastern Arizona Counties Organization (“ECO”) are 

located in eastern Arizona along and beneath the Mogollon Rim that marks the southern edge of 

the Colorado Plateau. Five characteristics of the Counties are particularly relevant to the Draft 

Environmental Impact Statement for the Four-Forest Restoration Initiative (“the 4FRI DEIS”):

1) Three of the four national forests regrouped into the Four Forest Restoration Initiative 

(“4FRI”): the Coconino National Forest, the Apache-Sitgreaves National Forests, and the Tonto 

National Forest, are located within four of the five ECO Counties: Navajo, Apache, Gila, and 

Greenlee.

2) The national forests of 4FRI, and other federal lands, occupy a very large proportion of the 

area of the ECO Counties: 9% of the land in Navajo County, 11% in Apache County, 55% in Gila 

and 77% in Greenlee County. 

3) The landscape scale catastrophic wildfires in the national forests of the Southwest have a 

disproportionately large impact on the ecological, social and economic life of the ECO Counties, 

and on the health and safety of their residents and visitors. Four of the five largest wildfires in 

Arizona, including two of the largest wildfires in the nation, have occurred within the ECO 

Counties in the last decade: the Rodeo Chediski Fire of 2002 that consumed 460,000 acres; the 

Willow Fire of 2004 that burned 120,000 acre; the Cave Creek Complex Fire of 2005 that blazed 

through 244,000 acres and the Wallow Fire of 2011 that charred 538,000 acres. 

4) Outdoor recreational activities conducted in the 4FRI national forests, such as, but not limited 

to, camping, motorized recreation, hunting, fishing, hiking, etc. by the local residents, and by 

visitors to the ECO Counties recreating from metro Arizona to the Rim Country, have a 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

956 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

disproportionately large impact on the economic well-being and the economic development of the 

Counties. 

5) The ECO Counties individually and collectively have made long term commitments to 

proactively participate in, assume leadership roles in and provide political support at the state and 

federal levels for forest restoration and wildfire prevention efforts at local and landscape scales, 

such as the White Mountain Stewardship Project and the Four Forest Restoration Initiative that 

the ECO Counties have been instrumental in creating and fostering. 

As such, the Eastern Arizona Counties Organization has a special interest in the Draft 

Environmental Impact Statement for the Four-Forest Restoration Initiative.

While the Eastern Arizona Counties Organization recognizes that it is only one of the many 

constituents of the U.S. Forest Service, and does not seek special consideration in the current 

comments and review process, we urge the Responsible Official to pay careful attention and give 

due consideration to the following comments in view of the uncommonly large effect that Forest 

Service land management decisions regularly have directly, or may occasionally have indirectly, 

on the ECO Counties’ residents and visitors’ enjoyment, custom, culture, health, safety and 

economic well-being. 

The ECO Counties individually and collectively have been uniquely involved in: 

• Developing the concept of industry funded landscape scale restoration in Arizona;

• Fostering the collaborative agreement that resulted in the 4FRI project;

• Organizing the political support at the state and federal levels that made 4FRI possible; 

• Lobbying for the funding of landscape scale restoration in general, and 4FRI in particular, 

through the Collaborative Forest Landscape Restoration Program (CFLRP); and, 

• Resolving regulatory issues with the U.S. Department of Agriculture (USDA) and the U.S. 

Forest Service Washington Office (USFS WO), such as the cancellation ceiling issue, which 

hindered the implementation of industry funded landscape scale restoration. 

The Eastern Arizona Counties Organization, therefore, understands particularly well the issues at 

hand, the management processes engaged, the desired future conditions, and the difficulties and 

challenges involved. ECO appreciates fully the USFS 4FRI Team’s intent to: i) ensure an adaptive 

management planning and implementation process that is inclusive, efficient, collaborative and 

science-based to promote healthy, resilient, diverse and productive national forests and 

grasslands; ii) support natural resources-based rural economic development and employment; 

and, iii) ensure the enjoyment of the 4FRI national forests by the current and future generations in 

a balanced approach of preservation, conservation and sustainable exploitation of the natural 

resources.

In a spirit of continuous improvement, and based on the direct practitioner knowledge and 

experience gained through a uniquely long, diverse, often productive and sometimes difficult 

participation in the Forest Service planning and implementation processes, the Eastern Arizona 

Counties Organization would like to share its comments, its appreciation for the obvious work put 

into the 4FRI DEIS, and its concerns and suggestions as follows. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 957
Appendix I – Summary of Response to Comments on the DEIS

Role of the Eastern Arizona Counties Organization in the 4FRI DEIS Process

The Eastern Arizona Counties Organization recognizes that the 4FRI DEIS is a Forest Servicedriven technical process, and generally supports the analysis mechanisms deployed by the USFS 

4FRI Team to complete the assessment and the technical part of the planning.

Although the Eastern Arizona Counties Organization and the ECO Counties retain and employ 

many talented individuals at the peak of the knowledge curve in their respective fields, ECO does 

not generally define its role in the public lands management process as a role of science provider 

or resources technical specialist. Rather, as an organization representing the most direct and local 

expression of democratic government at the individual district or national forest level, ECO more 

generally defines its role at the policy-making level as it relates to public lands management 

processes.

Therefore, although several of the following comments do apply to the technical aspects of the 

4FRI planning processes, they purposefully do not address specific technical mechanisms thereof, 

and the Eastern Arizona Counties Organization is mostly satisfied that the USFS methodology is 

generally satisfactory, and that the studies that the USFS 4FRI Team in their expertise deem 

reliable, are adequate to support their technical conclusions (Lands Council v. McNair 537 F.3d 

981 - 9th Cir. 2008). 

Therefore, the Eastern Arizona Counties Organization will focus its engagement in the 4FRI 

DEIS process, and its comments and suggestions, at the policy-making level and on whether the 

4FRI Preferred Alternative contributes to the ECO Counties’ residents’ and visitor’s enjoyment, 

custom, culture, health, safety and economic well-being. ECO will further focus its engagement 

on whether the 4FRI Preferred Alternative is consistent with the objectives of the ECO Counties 

as expressed in their plans and policies; on how the 4FRI project impacts related planning efforts 

by the ECO Counties; and, on the compatibility with and interrelated impacts of the 4FRI project 

and the ECO Counties’ plans and policies. 

Coordination between the 4FRI Project and the Eastern Arizona Counties 

Organization’s Objectives, Plans and Policies

Per the requirements contained in the 2012 Planning Rule, Title 36 - Parks, Forests, And Public 

Property, Part 219 - Planning, Subpart A - National Forest System Land Management Planning, 

Section 4 - Requirements for public participation, subsection (b) Coordination with other public 

planning efforts, the Eastern Arizona Counties Organization expects that: “The responsible 

official shall coordinate land management planning with the equivalent and related planning 

efforts of federally recognized Indian Tribes, Alaska Native Corporations, other Federal agencies, 

and State and local governments” (36 CFR 219.4 (b)(1)). 

The Eastern Arizona Counties Organization further expects that: “The results of this review shall 

be displayed in the environmental impact statement (EIS) for the plan”, and that “this review shall 

include consideration of: (i) The objectives of federally recognized Indian Tribes, Alaska Native 

Corporations, other Federal agencies, and State and local governments, as expressed in their plans 

and policies; (ii) The compatibility and interrelated impacts of these plans and policies; (iii) 

Opportunities for the plan to address the impacts identified or to contribute to joint objectives; 

and, (iv) Opportunities to resolve or reduce conflicts, within the context of developing the plan's 

desired conditions or objectives” (36 CFR 219.4 (b)(2)). 

The Eastern Arizona Counties Organization posits that these statutory requirements are meant by 

Congress to imply more than a perfunctory review process resulting in a check mark in a 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

958 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

‘coordination box’ and imply a sincere and proactive resolution effort to reduce and resolve 

potential conflicts between aspects of 4FRI DEIS and objectives expressed in the ECO Counties’ 

plans and policies; such as, but not limited to, those relevant to forested ecosystems restoration 

and catastrophic wildfire prevention objectives, watersheds restoration objectives, rangelands 

resources management objectives, or forest products resources management objectives.

Eastern Arizona Counties Organization Request for Cooperating 

Agency Status

The Eastern Arizona Counties Organization is committed to resolve or reduce potential conflicts 

between the 4FRI DEIS and the ECO Counties’ plans and policies, and understands that such 

resolution must take place within the context of developing the 4FRI project’s desired conditions 

or objectives.

To this effect, it is the intent of the Eastern Arizona Counties Organization to avail itself of the 

opportunity contained in the 2012 Planning Rule that specifies that: “Where appropriate, the 

responsible official shall encourage States, counties, and other local governments to seek 

cooperating agency status in the NEPA process for development, amendment, or revision of a 

plan” (36 CFR 219.4 (a)(1)(iv)). 

Eastern Arizona Counties Organization’s Objectives as Expressed 

in their Plans and Policies

Eastern Arizona Counties Organization’s Plans

The ECO Counties’ policy making decisions and management actions are guided by the ECO 

Counties plans. These plans guide the actions of the Boards of Supervisors and their county staff 

toward meeting the present and future enjoyment, custom, culture, health, safety and economic 

well-being needs of the Counties’ residents or visitors. The ECO Counties planning effort 

integrates the principles of:

1) Monitoring the effects and impacts of the implementation of the Counties policies, as well as 

the direct, indirect, individual and cumulative effects and impacts on the Counties and their 

residents and visitors of the policy decisions and management actions taken by state and federal 

agency partners;

2) Monitoring all demographic, social, economic, cultural and other variables, whether internal or 

external, which are relevant to the Counties’ policy making decisions and management actions; 

and, 

3) Dynamic and generally informal adaptive management.

As such, the ECO Counties plans are evolving dynamic plans that constantly adapt, often 

informally, in response to the evolving ecological, economic, social and cultural environment, and 

that are formulated as much through the regular deliberations of the ECO Counties’ Boards of 

Supervisors and the resulting Resolutions of the Boards, as they are in the formal planning 

documents. 

For the purpose of compliance with the statutory requirements of coordination between the 4FRI 

EIS and the ECO Counties’ objectives as expressed in their plans and policies (36 CFR 219.4 

(b)), the ECO Counties plans defined as the accumulation of the formal ECO Counties planning 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 959
Appendix I – Summary of Response to Comments on the DEIS

documents and the ECO Counties public record of Boards of Supervisors deliberations and 

resolutions, are hereby entered into the 4FRI NEPA record. 

Eastern Arizona Counties Organization’s Objectives Relating to the 4FRI EIS

The Eastern Arizona Counties Organization appreciates and supports the extensive and thorough 

analysis performed by the USFS 4FRI Team for the 4FRI DEIS, and the discussion of the effects 

of the no action alternative and the three action alternatives on: Soils and Watershed; Vegetation; 

Fire Ecology; Air Quality; Terrestrial and Semiaquatic Wildlife and Plants; Aquatics; Noxious 

and Invasive Weeds; Heritage Resources; Tribal Relations; Socioeconomics; Recreation; Lands 

and Minerals; Scenery; Range; Transportation; Climate Change; Short-term Uses and Long-term 

Productivity; Unavoidable Adverse Effects; Irreversible and Irretrievable Commitments of 

Resources; and, Cumulative Effects.

Multiple resources analyzed individually by the USFS 4FRI Team in the 4FRI DEIS are 

regrouped in a smaller number of overarching natural resources management policy objectives by 

the ECO Counties. In no particular order, the Counties’ natural resources management objectives 

relevant to the 4FRI DEIS comments include: 

1) Rangelands Resources Management Objectives.

Rangelands Resources Management Objectives address issues such as, but are not limited to, 

grazing availability, suitability, sustainability; ecological, economic and social carrying capacity; 

access; contribution to rural economic development; and, contribution to local Western custom 

and culture.

2) Forest Products Resources Management Objectives.

Forest Products Management Resources Objectives address issues such as, but are not limited to, 

logging availability, suitability, sustainability, productivity, access; contribution to rural economic 

development; and, contribution to rural Western custom and culture. 

3) Mineral and Energy Resources Management Objectives.

Mineral and Energy Resources Management Objectives address issues such as, but are not limited 

to, the availability, suitability, sustainability, productivity, access, and contribution to rural 

economic development of (a) solid, liquid or gaseous mineral resources and (b) solar, wind, 

hydropower, geothermal and other natural renewable energy resources.

4) Motorized Travel and Recreation Management Objectives.

Motorized Travel and Recreation Management Objectives address issues such as, but are not 

limited to, motorized access; motorized travel; motorized big game retrieval; motorized dispersed 

camping; motorized gathering of firewood; motorized access to dispersed fishing; motorized 

recreation opportunities; inventoried roadless areas; wilderness area designation; motorized 

access to grazing and logging opportunities; contribution of motorized access, recreation and 

travel to rural economic development; and, contribution to local Western custom and culture. 

5) Forested Ecosystems Restoration and Catastrophic Wildfire Prevention Objectives.

Forested Ecosystems Restoration and Catastrophic Wildfire Prevention Objectives address issues 

such as, but are not limited to, protection of Counties’ residents and visitors; protection of 

collective and individual real properties; protection of transportation, energy and water collection 

and distribution infrastructures; ecological restoration of forested ecosystems; local scale 

restoration projects; landscape scale restoration projects; social license required for the nonFinal Environmental Impact Statement for the Four-Forest Restoration Initiative

960 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

conflictual and non-litigious implementation of restoration efforts (such as the one requested in 

public statements by former USFS Southwestern Regional Forester Corbin Newman for the Four 

Forest Restoration Initiative); industry development required to implement and fund restoration 

efforts through economically viable utilization of the wood products; and, long term guarantees of 

wood supply necessary to attract private investments in a small diameter utilization infrastructure 

in northeastern Arizona.

6) Watershed Restoration Objectives.

Watershed Restoration Objectives address issues such as, but are not limited to, ecological 

restoration of watersheds; protection and development of water collection and distribution 

infrastructures; monetization of watershed ecosystem services; downstream consumption 

contribution to upstream production investments and maintenance; and, interactions between 

watershed functions and multiple use functions. 

7) Management Areas Designation Objectives.

Management Areas Designation Objectives address issues such as, but are not limited to, the 

nomination, designation, and management of (a) inventoried roadless areas (which are technically 

not management areas per se but are an administrative designation) and (b) wilderness areas, 

primitive areas, research natural areas, wildlife quiet areas, and wild and scenic rivers; and, 

effects on socioeconomic resources and impacts on the other County objectives.

The Eastern Arizona Counties Organization understands that some of these objectives are not 

directly relevant to the 4FRI DEIS inasmuch as, for example, the 4FRI alternatives are not 

contemplating the designation of management areas. However, most of these objectives are 

relevant to the 4FRI DEIS, inasmuch as the 4FRI alternatives either have direct effects on some 

Counties’ objectives, such as Forested Ecosystems Restoration and Catastrophic Wildfire 

Prevention Objectives; Forest Products Resources Management Objectives; Watershed 

Restoration Objectives; and, Rangelands Resources Management Objectives; or, may have 

indirect effects on some Counties’ objectives, such as Motorized Travel and Recreation 

Management Objectives.

For the purpose of compliance with the statutory requirements of coordination between the 4FRI 

EIS and the ECO Counties’ objectives as expressed in their plans and policies (36 CFR 219.4 

(b)), this document: Eastern Arizona Counties Organization comments on the Draft 

Environmental Impact Statement for the Four-Forest Restoration Initiative is hereby incorporated 

into the ECO Counties’ expressed plans and policies. 

The Eastern Arizona Counties Organization, therefore, expects that: i) the Responsible Official 

shall coordinate land management planning with the ECO Counties equivalent and related 

planning efforts (36 CFR 219.4 (b)(1)); ii) the consistency review and coordination action shall 

include consideration of the objectives of the ECO Counties as expressed in their plans and 

policies; and, iii) the Responsible Official shall consider opportunities to resolve or reduce 

conflicts, should some arise between the 4FRI DEIS and the ECO Counties’ objectives (36 CFR 

219.4 (b)(2)). 

Request for Disclosure of Consistency Review and Coordination Action

Per the requirements of 36 CFR 219.4 (b)(2), 40 CFR 1502.16(c) and 40 CFR 1506.2, the Eastern 

Arizona Counties Organization hereby requests that the results of the consistency review and 

coordination action between the 4FRI DEIS and the ECO Counties’ objectives as expressed in 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 961
Appendix I – Summary of Response to Comments on the DEIS

their plans and policies shall be displayed in the Four Forest Restoration Initiative Environmental 

Impact Statement.

Forested Ecosystems Restoration and Catastrophic Wildfire 

Prevention Objectives

The Eastern Arizona Counties Organization appreciates and supports the fact that all three action 

alternatives include a clear priority for restoration treatments (PDEIS p. 62).

Constraint on the Eastern Arizona Counties Organization and the 4FRI DEIS 

Planning Efforts

The Eastern Arizona Counties Organization recognizes that the issues of forested ecosystem 

restoration and forest products management are fundamentally different, and are typically not 

discussed simultaneously in ecosystems non-departed or little departed from characteristic 

reference conditions. However, as the Forest Service and ECO both generally acknowledge: 

current conditions in the forested ecosystems and especially in the ponderosa pine and dry or wet 

mixed conifers-dominated forests of eastern Arizona are considerably departed from reference 

conditions, and at risk of continued uncharacteristic disturbances such as landscape scale 

catastrophic crown fires or insect infestations.

Also, the Eastern Arizona Counties Organization acknowledges and appreciates the efforts made 

by the Forest Service, and particularly the Arizona national forests, to pioneer larger scale 

restoration efforts such as the White Mountains Stewardship Project. ECO has been and continues 

to be supportive of the White Mountain Stewardship Project and of its funding as a practical tool 

to initiate larger scale treatments and to incentivize the creation of a small diameter trees 

utilization infrastructure. Simultaneously, ECO acknowledges that the model of subsidized 

restoration treatments is not scalable at landscape level, as is required to restore the forests of 

Arizona, for lack of agency funding. 

As proposed in the Four Forest Restoration Initiative, an initiative that ECO was instrumental in 

creating, fostering and developing, landscape scale forest ecological restoration appears currently 

feasible only if it is funded by the economically viable utilization of the forested byproducts of 

restoration by private industry. While it is actually not a novation when it comes to forest 

products, as timber sales have been for centuries an established form of natural resources 

valuation and have funded the management of the resources, the concept of ecosystem services 

monetization is relatively new to the discussion of ecological restoration funding, and its full 

implications are still being tested.

As a consequence, the Eastern Arizona Counties Organization suggests that both the Counties and 

the USFS 4FRI Team operate under a very specific constraint when it comes to forest restoration, 

inasmuch as the forest products industry in Arizona is the funding mechanism for landscape scale 

restoration in eastern Arizona, which imposes the concept of social acceptability or ‘social 

license’ for appropriate scale industry to fund restoration logging activities at the landscape scale 

throughout the 4FRI project. 

Eastern Arizona Counties Organization’s Forested Ecosystems Restoration and 

Catastrophic Wildfire Prevention Objectives

The Eastern Arizona Counties Organization’s Forested Ecosystems Restoration and Catastrophic 

Wildfire Prevention Objectives for the upcoming planning cycle include, among others: 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

962 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

1) Design and implement landscape-scale, consensus-based, industry-supported, accelerated 

community protection and forested ecosystems restoration in the 2.4 million acre ponderosa pine 

and mixed conifer-dominated forests of the Mogollon Rim. 

2) Develop and sustain the social license required by Southwestern Regional Forester Corbin 

Newman as a prerequisite to the implementation of industry-supported landscape scale 

restoration. 

3) Participate actively in the NEPA process, as a member of the public and as a Cooperating 

Agency, and provide robust comments to the Forest Service to ensure NEPA process integrity and 

survivability in the face of potential threats of litigation. Emphasize with the Forest Service a 

strategy of risk mitigation and focus on the end goal of accelerated restoration over partisan 

debates and exclusive focus on technical sciences to the detriment of social science and social 

license.

4) Create in eastern Arizona the wood supply conditions for private industry investments in a new 

economically viable small diameter trees and residual biomass utilization infrastructure capable 

of funding the initial ecological restoration thinning of at least 50,000 acres of ponderosa pine 

and/or mixed conifer-dominated forests annually for the next 20 years, then the maintenance of 

the desired future conditions in subsequent decades. 

5) Wherever and whenever possible, prioritize forest byproducts treatments (mechanical 

treatments) funded by economically viable utilization, over non-byproducts treatments (fire as 

first entry thinning treatments) in order to create and sustain the wood supply necessary for a new 

era of forest products industry-based economic growth and employment in eastern Arizona with 

multiple industrial scale new investments.

Forest Products Resources Management Objectives

The Eastern Arizona Counties Organization appreciates and supports the fact that all three action 

alternatives include a clear focus on mechanical restoration treatments yielding forest products 

(PDEIS p. 62). 

Challenge for the Eastern Arizona Counties Organization and the 4FRI DEIS 

planning efforts

The inherent challenge faced by the Eastern Arizona Counties Organization and the USFS 4FRI 

Team is that the priorities typically considered when managing forest products, such as a 

sustained yield of harvest volumes on a regulated non-declining even-flow basis for the long 

term, uneven age structures, long term sustained yield capacity (LTSYC), non-declining 

allowable sale quantity (ASQ), etc., are augmented and complicated, and to a large extent 

superseded, by the overwhelming priority to complete landscape scale restoration as rapidly as 

possible for fear of massively disruptive landscape scale catastrophic crown fires and/or 

landscape scale insect or disease infestations.

Owing to the fact that for the foreseeable future green forest products will likely be byproducts of 

restoration treatments, and green forest products will likely continue to be at risk of destruction 

by catastrophic fires if landscape scale restoration is not expeditiously implemented, ECO 

suggests that forest products management actions for the upcoming planning cycle must be 

dictated not only by traditional silviculture science and best practices, but primarily by the 

absolute priority of implementing landscape scale restoration as expeditiously as possible using 

mechanical treatments that produce the forest products necessary to not only sustain the existing 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 963
Appendix I – Summary of Response to Comments on the DEIS

forest industry in the White Mountains, but also to allow robust natural resources-based rural 

economic development through the creation of an entirely new infrastructure of small diameter 

trees utilization at industrial scale.

Eastern Arizona Counties Organization’s Forest Products Resources Objectives

The Eastern Arizona Counties Organization’s Forest Products Resources Objectives for the 

upcoming planning cycle include, among others: 

1) Create in eastern Arizona the wood supply conditions necessary for private industry 

investments in a new economically viable small diameter trees and residual biomass utilization 

infrastructure capable of funding the initial ecological restoration thinning of at least 50,000 acres 

of ponderosa pine and/or mixed conifer-dominated forests annually for the next 20 years, then the 

maintenance of the desired future conditions in subsequent decades. 

2) Sustain in the White Mountains the wood supply conditions necessary for the continued 

development and growth of the existing local industry, with expanded economically viable small 

diameter trees and residual biomass utilization facilities capable of funding the initial ecological 

restoration thinning of at least 15,000 acres of ponderosa pine and/or mixed conifer-dominated 

forests annually for the next 20 years, then the maintenance of the desired future conditions in 

subsequent decades.

3) Subordinate for as long as required in the upcoming planning cycle the scientific silviculture 

priorities and traditional forest products management methods for sustained yield of harvest 

volumes on a regulated, non-declining even-flow basis for the long term, to the overriding 

priority of implementing as expeditiously as possible landscape scale restoration based primarily 

on mechanical treatments producing forest products. 

4) Subordinate for as long as required in the upcoming planning cycle the scientific silviculture 

priorities and traditional forest products management methods for uneven age management to the 

overriding necessity of sustaining the social license required to implement landscape scale 

restoration expeditiously and in a non-conflictual and non-litigious manner, as relates to the 

protection of old growth and the retention of large trees (upcoming old growth) where vegetative 

structural stages (VSS) 5 and 6 are deficient at stand or forest scale.

Watershed Restoration Objectives 

The Eastern Arizona Counties Organization appreciates and supports the analysis performed by 

the USFS 4FRI Team using the Watershed Condition Framework (WCF) to identify 6th level 

Hydrologic Unit Code (HUC) Class 1 (Functioning), Class 2 (Functioning-At-Risk) and Class 3 

(Impaired) watersheds in the 4FRI project area, and to analyze the direct and indirect effects of 

the 4FRI project on water quality and water yield. 

Critical Role of the Mogollon Rim Watershed for Arizona

Uncharacteristic landscape scale forest crown fires in eastern Arizona have a demonstrated 

negative impact on the conservation and operation of the watersheds in which they occur. In 

addition to the damages caused to communities and ecosystems by the fires themselves, the most 

common negative effects on watersheds documented after the Rodeo-Chediski Fire, the Wallow 

Fire, in some areas, and the Schultz Fire, among others, are: uncharacteristic runoffs, catastrophic 

flooding, accelerated and aggravated soil erosion, streams and reservoirs sedimentation, and long 

term severe disturbance of the watershed functions.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

964 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

The Rim Country constitutes a large portion of the watersheds that contribute significantly to the 

water supply of the metro Arizona and greater Phoenix area. The threat of additional 

uncharacteristic landscape scale forest crown fires in eastern Arizona, especially on the south 

slopes of the Mogollon Rim, raises serious concerns about the conservation and operation of the 

eastern Arizona watersheds. Additionally, the specific risk to the East Clear Creek watershed 

poses an existential threat to the Town of Payson’s water supply.

With the growing realization that uncharacteristic landscape scale forest crown fires affect the 

conservation and operation of the watersheds in which they occur, efforts to protect watersheds 

have recently been initiated in the Southwest. Several of these efforts focus on the monetization 

of the ecosystem services provided by the watersheds, and on an attempt to enroll the financial 

contribution of the downstream beneficiaries of the services (water consumers in this case) to the 

financial costs of protecting the upstream provider areas and the utility corridors delivering the 

services (forests, watersheds and water collection and distribution infrastructures at risk of 

catastrophic fires in this case).

Such efforts were pioneered by the Denver Forest to Faucet project in Colorado, or the Santa Fe 

Municipal Watershed Protection project in New Mexico, among others. In Arizona, with the 

active contribution of the Eastern Arizona Counties Organization, an effort to create the Arizona 

Watersheds Investment Fund (AWIF) is underway, and in Flagstaff, Ballot Question #405 

received electors’ approval in November 2012 for the issuance of a $10 million municipal bond to 

finance the restoration treatments of high threat areas in the Rio de Flag and Lake Mary 

watersheds to provide greater protection to the community from the impacts of fires and floods. 

Therefore, the restoration of forested ecosystems, ponderosa pine and mixed conifer-dominated, 

in the watersheds of the Mogollon Rim in general, and specifically in the East Clear Creek 

watershed, is an objective priority, among other areas in eastern Arizona also in need of 

restoration treatments, for the Eastern Arizona Counties Organization, after the direct protection 

of communities and infrastructures. 

Eastern Arizona Counties Organization’s Watershed Restoration Objectives

The Eastern Arizona Counties Organization’s Watershed Restoration Objectives for the upcoming 

planning cycle include, among others:

1) Prioritize restoration and catastrophic fire prevention treatments in the watersheds, after the 

direct protection of communities and infrastructures, on the slopes of the Mogollon Rim in 

general, and specifically in the East Clear Creek, Verde River, Little Colorado River, Upper Gila 

River, and Upper Salt River watersheds.

2) Develop the Arizona Watersheds Investment Fund (AWIF), and/or similar initiatives in order to 

fund restoration treatments that cannot be funded by the wood industry utilization of the forest 

byproducts of restoration in areas where the merchantable material yield is insufficient for 

mechanical treatments to be economically viable, or access by mechanical harvesting equipment 

is restricted, such as in steep slopes, high erosion areas, riparian areas, etc.

3) Develop in parallel and in a complementary manner all models of watersheds restoration 

funding such as industry funding, ecosystem services funding, municipal bonds funding, etc. 

Rangelands Resources Management Objectives

The Eastern Arizona Counties Organization appreciates the addition of grassland restoration 

treatments to forestland treatments in Alternative C, the Preferred Alternative. ECO believes that 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 965
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this addition is significant not only because it implies the restoration of approximately 50,000 

acres of rangelands, but because it aptly diversifies the concept of landscape scale restoration 

from a restrictive interpretation of ‘forested ecosystems restoration’ toward a broader concept of 

truer ‘landscape restoration.’

Eastern Arizona Counties Organization’s Rangelands Resources Management 

Objectives

The Eastern Arizona Counties Organization’s Rangelands Resources Objectives for the upcoming 

planning cycle include, among others:

1) Restore encroached grasslands, including the most departed semi-desert, Great Basin, and 

montane subalpine grasslands that have been invaded by trees (subalpine grasslands) and shrubs 

(semi desert and Great Basin grasslands) by removing trees and shrubs where economically 

feasible, promoting a mixture of native perennial grass species, implementing the periodic 

prescriptive use of mixed classes of livestock matching animal feeding habits with specific plant 

material, and reintroducing a regime of cool surface fires in order to reduce trees and shrubs 

colonization and erosion hazards, and to increase livestock forage production. 

2) Adopt management practices that discourage the establishment of nonnative species and 

eradicate invasive weed species that have little to no forage value, recognizing the fact that the 

ecological or economic consequences of different exotic species are not all the same, and that the 

persistence of some nonnative species that are not necessarily undesirable or controllable, such as 

Kentucky bluegrass or Bermuda grass, may be beneficial from a socioeconomic perspective and a 

balanced management for multiple resource objectives.

3) Allocate grass reserves on an allotment-by-allotment basis through proper range management, 

rather than on a district-by-district basis, which requires additional financial considerations for 

improvement maintenance.

4) Shift the grassland management process from the concept of balancing livestock grazing with 

available forage - which only addresses stocking rate - toward the concept of managing the 

intensity, frequency, seasonality, duration and classes of livestock grazing to accomplish the 

rangelands resources management objectives.

5) Emphasize adaptive management of the rangelands using a three step rangelands resources 

management monitoring approach of quantitative monitoring using standard measurements such 

as stocking rate, ground cover, etc.; qualitative monitoring using measurements such as species 

composition, age, nutritional value, etc.; and, effectiveness monitoring using outcome 

measurements such as range health, soil water holding capacity, soil organic content, livestock 

weight gain, wildlife indicator species, etc., in order to measure whether the management actions 

produce the site specific and cumulative direct and indirect effects desired.

6) Integrate the scientific research and implement the science-based recommendations developed 

by rangelands resources management experts and scientists.

7) Preserve the contributions of the rangelands resources to the economic development and the 

custom and culture of the rural Arizona counties.

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Gap Analysis and Suggested Actions for the Final Environmental 

Impact Statement

Preliminary Comments

The Eastern Arizona Counties Organization would like to preface any subsequent comment by 

the following four preliminary comments: 

1. The quality and thoroughness of the work exhibited by the USFS 4FRI Team in the 4FRI DEIS 

is outstanding. The Eastern Arizona Counties Organization is fully conscious of the fact that an 

enormous commitment was made and delivered upon by the USFS 4FRI Team, and that a 

legitimate pride of ownership must rest with the authors of the DEIS, as well as the Specialists’ 

reports and other documents not published with the 4FRI DEIS but nonetheless part of the 4FRI 

project record. ECO urges the USFS 4FRI Team to consider the ECO comments NOT as a critic 

of their work, but as a goodwill effort toward continuous improvement of the 4FRI EIS, and as a 

proactive effort by ECO to disclose its objectives, plans and policies, and the rationales that 

support them, to facilitate the statutorily required consistency review, coordination action and 

conflict reduction regarding potential discrepancies between the 4FRI DEIS and the ECO 

Counties’ objectives as expressed in their plans and policies and as discussed in this document.

2. Strategically, the Eastern Arizona Counties Organization overwhelmingly supports the 4FRI 

project, the 4FRI DEIS effort, and the implementation of the 4FRI Preferred Alternative, provided 

that it is further refined per the following suggestions. Therefore, the following concerns and 

suggestions are not aimed at questioning the need to implement 4FRI but at pointing out to the 

USFS 4FRI Team potential issues, gaps or weaknesses in the substance and the process, which 

could be of a nature to compromise a non-conflictual and non-litigious implementation of the 

4FRI project as intended by ECO and the ECO Counties. 

3. The Eastern Arizona Counties Organization readily acknowledges that several of the following 

comments and suggestions have already been addressed and agreed upon by the USFS 4FRI 

Team in the course of the work conducted by the DEIS Review Workgroup of the 4FRI 

Stakeholders Group with the USFS 4FRI Team. Also, considering the participation of ECO in 

both the 4FRI Stakeholders Group and the DEIS Review Workgroup, there is a high probability 

that there will be some level of repetition and redundancy between the ECO comments and the 

4FRI Stakeholders Group comments, as well as comments from other stakeholders. Nonetheless, 

the NEPA process calls for comments on the DEIS as published, and for the formulation of ECO’s 

concerns and suggestions, regardless of whether these are echoed in other comments or not. 

4. As previously noted, although the Eastern Arizona Counties Organization and the ECO 

Counties retain and employ many talented individuals at the peak of the knowledge curve in their 

respective fields, ECO does not generally define its role in the public lands management process 

as a role of science provider or resources technical specialist. Rather, as a body representing the 

most direct and local expression of democratic government at the individual district or national 

forest level, the Eastern Arizona Counties Organization more generally defines its role at the 

policy-making level as it relates to public lands management processes. ECO, therefore, believes 

that it is appropriate to comment at the programmatic level, from a Forest Service perspective, 

and at the objectives level, from a Counties’ policy perspective. 

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Gap between the 4FRI DEIS and the Eastern Arizona Counties Organization’s 

Objectives, Plans and Policies

For clarification, the Eastern Arizona Counties Organization wants to emphasize that although it 

generally supports the use of Best Available Scientific Information (BASI) for management 

decision, it does not support the exclusive use of technical sciences to formulate policies or to 

make strategic decisions that have an important impact on people. ECO believes that these 

decisions must integrate social sciences in the decision making process. For example, ECO 

believes that while there is no overwhelming supporting science on either side of the long debated 

issue of a universal diameter cap for restoration treatments (whether it be 9”, 12”, 16” or 18”), 

analyzing the issue of a diameter cap from just a technical science perspective is at best 

incomplete, because the issue of large trees retention is not only a technical issue, but also a 

social issue that cannot be adequately addressed by an exclusively scientific approach.

Therefore, the Eastern Arizona Counties Organization comments will purposefully not emphasize 

technical issues of silviculture, such as uneven aged composition, regeneration openings, etc., but 

will be focused on what the Counties believe to be the crux of the successful and timely 

implementation of the overriding priority of landscape scale scientifically and socially acceptable 

– if admittedly imperfect – ecological restoration and catastrophic wildfire prevention. Namely: 

• Social acceptability of proposed treatments;

• Speed of completion of landscape scale restoration; and,

• Prioritization of treatments.

Alternative A

Gap analysis

Alternative A, the no action alternative, does not offer the option of continuing an existing 

management approach to landscape scale forested ecosystems restoration in eastern Arizona 

inasmuch as there is currently no such approach. Alternative A would nonetheless result in the 

mechanical treatment of approximately 87,000 acres, and in the prescribed fire treatment of 

approximately 143,000 acres over the next five years (DEIS p. 62). However, the scale and pace 

of these management actions are incompatible with the urgent need to implement landscape scale 

restoration as identified in the purpose and needs for the 4FRI NEPA process.

Therefore, the Eastern Arizona Counties Organization wants to communicate unambiguously to 

the USFS 4FRI Team its opposition to Alternative A.

The Eastern Arizona Counties Organization understands the NEPA requirement for the 4FRI 

DEIS to analyze a no action alternative, and ECO acknowledges and appreciates the existence of 

constituencies favoring no action. However, the Eastern Arizona Counties Organization cannot 

support an alternative that would result in the continuation of an unmitigated high risk of further 

landscape scale uncharacteristic disturbances such as catastrophic high intensity crown fires, or 

insect infestations, for the forests of eastern Arizona and their communities.

Consequently, the Eastern Arizona Counties Organization is concerned that Alternative A is in 

direct conflict with the Counties’ objectives as expressed in their plans and policies.

Suggested action

The Eastern Arizona Counties Organization regrets to suggest that there is no possible corrective 

action to mitigate the incompatibility of Alternative A with the Counties’ objectives as expressed 

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in their plans and policies, or to resolve or reduce the conflict between Alternative A and the 

Counties’ objectives as expressed in their plans and policies.

Alternative A is so departed from the Mogollon Rim residents’ and visitors’ past, current, and 

foreseeable future custom, culture, safety and economic well-being needs, and from the Eastern 

Arizona Counties Organization and the ECO Counties’ natural resources management objectives, 

that it does not warrant any further discussion from the Counties’ perspective. 

Alternatives B and C

Gap analysis

Alternative B (the original Proposed Action) and Alternative C (the Preferred Alternative) both 

generally meet the purpose and needs of landscape scale restoration in eastern Arizona, as 

analyzed by the USFS 4FRI Team, and the ECO Counties. 

For all practical purposes, Alternative B (the original Proposed Action) and Alternative C (the 

Preferred Alternative) share many similarities:

1. The acreages treated, both mechanically and by fire-as-a-first-entry (approximately 388,000 

acres treated mechanically and 588,000 treated with fire in Alternative B; and, approximately 

434,000 acres treated mechanically and 593,000 treated with fire in Alternative C) are very 

similar; and,

2. The differences in acreage treated mostly result from the addition of grassland treatments to 

forestland treatments in Alternative C.

Nonetheless, there are some differences between Alternative B (the original Proposed Action) and 

Alternative C (the Preferred Alternative):

1. The addition of grassland treatments to forestland treatments in the Preferred Alternative is 

significant inasmuch as it diversifies aptly the concept of landscape scale restoration from a 

restrictive interpretation of ‘forested ecosystems restoration’ toward a broader concept of truer 

‘landscape’ restoration;

2. The increase in mechanical treatments upper limit from 16” to 18” diameter at breast height 

(d.b.h.) in the Mexican Spotted Owl Protected Activity Centers (MSO PACs) in the Preferred 

Alternative, while relatively minor from a treatments perspective, is likely to have an impact on 

the social acceptability of the proposed treatments;

3. The integration of some reworded components of the stakeholders-developed Old Growth 

Protection and Large Trees Retention Strategy (OGPLTRS) in the Preferred Alternative is likely 

to have an impact on the social acceptability of the Preferred Alternative; and,

4. The integration of research projects in the Preferred Alternative is a welcome addition.

The Eastern Arizona Counties Organization clearly views the addition of grassland treatments to 

forestland treatments in Alternative C as a positive step toward meeting the ECO Counties’ 

Rangelands Resources Management Objectives, and generally supports the integration of 

research projects into restoration implementation projects, wherever and whenever feasible. ECO 

further supports the integration of stakeholders-developed strategies and foundational documents 

such as the Old Growth Protection and Large Trees Retention Strategy (OGPLTRS) in the 4FRI 

DEIS.

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Conversely, the Eastern Arizona Counties Organization is concerned that the adaptation of the 

stakeholders-developed Old Growth Protection and Large Trees Retention Strategy (OGPLTRS) 

into the USFS 4FRI Team Old Trees Implementation Plan (OTIP) and Large Trees 

Implementation Plan (LTIP) may have an impact on the social acceptability of the Preferred 

Alternative, as further discussed in the later section Old Growth And Large Trees.

Therefore, the Eastern Arizona Counties Organization generally supports the concepts presented 

in Alternative C, the Preferred Alternative, provided that it is further refined per the suggestions 

offered in the ECO comments, as well as comments from other stakeholders critical to the 

viability of the 4FRI social license.

However, the Eastern Arizona Counties Organization is concerned that some decisions made by 

the USFS 4FRI Team may compromise the social license developed for the implementation of the 

4FRI project. 

Consequently, the Eastern Arizona Counties Organization is concerned that the possible social 

license risk for the 4FRI DEIS potentially caused by some decisions made by the USFS 4FRI 

Team that may compromise the social license developed for the implementation of the 4FRI 

project, present a consistency gap between the 4FRI DEIS and the Counties’ objectives as 

expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team and 

the Responsible Officials exercise careful judgment in their decisions, in relation to: i) the true 

material importance of the issues, as opposed to their symbolic or emotional importance; and, ii) 

the potential effect of litigation on the implementation of the 4FRI project. ECO suggests that a 

careful and dispassionate costs / benefits analysis be conducted between the minor ecological or 

silviculture costs possibly attached to some stakeholders’ recommendations, and the major 

benefits attached to sustaining the 4FRI social license.

Alternative D

Gap analysis

Alternative D is identical to Alternative B (the Proposed Action) as regards mechanical 

treatments. It is also identical to Alternative C (the Preferred Alternative) as regards mechanical 

treatments, except for the minor difference of upper limit of diameter at breast height (d.b.h.) in 

the Mexican Spotted Owl Protected Activity Centers (MSO PACs).

The critical difference between Alternative D and Alternatives B and C is the use of fire as a 

treatment. In alternative D fire would be used on only approximately 179,000 acres, compared to 

588,000 acres in Alternative B and 593,000 acres in Alternative C. 

The Eastern Arizona Counties Organization is concerned that the drastic reduction in the use of 

fire as a thinning treatment in Alternative D could prevent the timely completion of landscape 

scale restoration on the Mogollon Rim within the next 20 years as intended with the 4FRI project. 

ECO favors, wherever and whenever possible, prioritizing forest byproducts treatments 

(mechanical treatments) funded by economically viable utilization, over non-byproducts 

treatments (fire as first entry thinning treatments) in order to create and sustain the wood supply 

necessary for a new era of forest products industry-based economic growth and employment in 

eastern Arizona, with multiple industrial scale new investments. However, ECO also recognizes 

that industry funded mechanical treatments are not appropriate in many sensitive areas such as 

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steep slopes, fragile soils, riparian areas, etc., or in areas where the merchantable yield of 

restoration treatments would be economically unviable. 

Further, the Eastern Arizona Counties Organization acknowledges that agency funded mechanical 

treatments or hand thinning are disproportionately expensive as compared to fire thinning, and 

ECO appreciates that, as discussed in a different context but still related to the implementation of 

4FRI treatments in the Apache-Sitgreaves National Forests Land Management Plan PDEIS: “the 

alternatives were realistically designed to reflect anticipated budgets and workforce capabilities,” 

and “none of the alternatives would actually treat enough acres fast enough to fully reach desired 

conditions within the first 5 decades” (A/S PDEIS p. 440). The use of fire as a treatment tool is, 

therefore, not a luxury from a timeline, economic or practicality perspective, but is instead a 

necessity.

Additionally, ECO believes that the ecological role of fire is absolutely critical to the long term 

ecological sustainability of the forested ecosystems of the Southwest, and that a management 

alternative that would reduce unduly the use of fire could compromise, in the long term, the 

implementation of post-treatment maintenance burns.

In consequence, the Eastern Arizona Counties Organization wants to communicate 

unambiguously to the USFS 4FRI Team its opposition to Alternative D. 

The Eastern Arizona Counties Organization understands the NEPA requirement for the 4FRI 

DEIS to analyze significantly different alternatives, and ECO acknowledges and appreciates the 

existence of constituencies concerned with prescribed fire emissions, and who favor alternatives 

such as Alternative D. However, the Eastern Arizona Counties Organization cannot support an 

alternative that could reduce the scope and significantly slow the pace of landscape scale 

restoration in eastern Arizona, which could result in the unnecessary prolongation of a high risk 

of further landscape scale uncharacteristic disturbances such as catastrophic high intensity crown 

fires, or insect infestations, for the forests of eastern Arizona and their communities.

Consequently, the Eastern Arizona Counties Organization is concerned that Alternative D is not 

compatible with the Counties’ objectives as expressed in their plans and policies.

Suggested action

The Eastern Arizona Counties Organization is concerned that there may not be a corrective action 

to mitigate the incompatibility of Alternative D with the Counties’ objectives as expressed in their 

plans and policies. 

Alternative D is too departed from the Mogollon Rim residents’ and visitors’ past, current, and 

foreseeable future custom, culture, safety and economic well-being needs, and from the Eastern 

Arizona Counties Organization and the ECO Counties’ natural resources management objectives, 

to warrant further discussion from the Counties perspective.

Range of action alternatives

Gap analysis

Notwithstanding any of the above, the Eastern Arizona Counties Organization is concerned about 

the three action alternatives and the range of alternatives that they represent.

Specifically, even though the Eastern Arizona Counties Organization recognizes differences 

between the three action alternatives as discussed in the previous sections Alternatives B and C 

and Alternative D, ECO is concerned that the mechanical treatments in each of the three action 

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alternatives are similar enough in scale, scope and intensity that the DEIS may not offer an actual 

range of alternatives when discussing mechanical thinning. Arguably, the difference of upper 

limit of diameter at breast height (d.b.h.) in the Mexican Spotted Owl Protected Activity Centers 

(MSO PACs) is minor, and the addition of grassland treatments in Alternative C or the reduction 

of fire treatments in Alternative D do not affect forestland mechanical treatments per se.

The Eastern Arizona Counties Organization itself is generally satisfied with the mechanical 

treatments proposed in alternatives B, C and D, provided these treatments are refined to integrate 

the suggestions of the ECO Counties and other stakeholders integral to the 4FRI social license. 

However, ECO is concerned that the 4FRI DEIS could be perceived as a DEIS based on a single 

alternative of mechanical treatments, with nonsignificant variations between the three action 

alternatives.

Therefore, the Eastern Arizona Counties Organization is concerned that the 4FRI DEIS may fail 

to comply with the Council on Environmental Quality (CEQ) requirements to provide and 

analyze a range of alternatives (Sec. 1505.1 (e) and Sec. 1502.14 (a)) and that the absence of a 

broader range of analyzed mechanical treatments alternatives may present a process risk for the 

4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the absence of a broader range of analyzed 

mechanical treatments alternatives, presents a consistency gap between the 4FRI DEIS and the 

Counties’ objectives as expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

request a third party legal review of the NEPA and CEQ requirements in, and of the 4FRI DEIS 

compliance with, Sec. 1505.1 (e) and Sec. 1502.14 (a). 

Degree of openness

Gap analysis

The degree of canopy openness in the immediate post-treatment conditions and in the long term 

desired future conditions has for several years been an issue of debate among the 4FRI 

stakeholders and the 4FRI collaborative group, including the USFS 4FRI Team, and is likely to 

remain one. This issue is linked to the discussion of whether vegetative structural stages (VSS) 

and canopy closure should be measured at group level, as proposed in the 4FRI DEIS, or at stand 

level, as currently implemented under the Coconino National Forest Plan. Amending the Forest 

Plan will resolve the technical compliance issue, but it does not address the more fundamental 

question of whether guidelines originally designed to be implemented at stand or even forest scale 

(outside Mexican Spotted Owl protected areas) are directly transferable, or not, to groups within 

stands. Additionally, the creation of interspaces between groups, in addition to the creation of 

regeneration openings within groups, will undoubtedly result in a significantly lower canopy 

density than was deemed desirable in the Management Recommendations for the Northern 

Goshawk in the Southwestern United States. 

Clearly, the USFS 4FRI Team has endeavored to be responsive to this concern, as evidenced in 

the 4FRI DEIS Appendix G Bridge Habitat, Appendix D Alternative B through D Implementation 

Plan, and in the silviculture Specialist Report. However, the Eastern Arizona Counties 

Organization is concerned that the issues raised by partner agencies such as the U.S. Fish and 

Wildlife Service and the Arizona Game and Fish Department, and by a broad range of 

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stakeholders, have not yet been fully resolved. Questions remain about how and at what scale 

post-treatment canopy openness will be measured, and how group size, basal area (BA), stand 

density index (SDI), interspaces, regeneration openings, trees per acre (TPA), and quadratic mean 

diameter (QMD) interrelate to result in a trajectory toward desired future conditions. 

As previously noted, the Eastern Arizona Counties Organization does not generally define its role 

in the public lands management process as a role of science provider or resources technical 

specialist. Further, ECO readily admits that it lacks the technical competence to contribute 

meaningfully to the resolution of arcane technical issues such as density management and the 

relationship between treatment intensity, tree group density, and overall average density, as relates 

to the implementation of post-treatment openness. Suffice it to say that the very fact that the 

discussion continues unabated is concern enough to ECO that a zone of agreement has not been 

reached, or that the issues have not been understood clearly and broadly enough for the 

emergence of a general zone of agreement.

The Eastern Arizona Counties Organization understands that differences of opinions will exist 

regarding desired canopy openness. What concerns ECO is the confusion that exists about 

questions that should be answered with data, such as: 

• Does science support the direct transfer of canopy density guidelines, originally designed to 

be implemented at stand or even forest scale, to groups (within stands)? 

• How does canopy openness measured at group level compare with the reference condition?

• How and at what scale will post-treatment openness be measured in 4FRI?

• Does a range of basal area of 50 to 70 in the largest treatment categories provide enough 

flexibility for a full range of treatments, considering other metrics such as trees per acre 

(TPA), stand density index (SDI), percentage of interspace, and percentage of openings? 

• How will habitat be provided to closed canopy and high closed canopy dependent species in 

the post treatment interim between the thinning of their current habitats and the natural 

development of high and dense canopy cover in the future old growth? 

Therefore, the Eastern Arizona Counties Organization is concerned that the direct transfer of 

canopy density guidelines, originally designed to be implemented at stand or even forest scale, to 

groups, may be both a process risk and a social license risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk and social license risk for the 4FRI DEIS potentially caused by the direct transfer of canopy 

density guidelines, originally designed to be implemented at stand or even forest scale, to groups, 

presents a consistency gap between the 4FRI DEIS and the Counties’ objectives as expressed in 

their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests the USFS 4FRI Team provide a 

clear and compelling analysis:

1. Presenting the science or, if science is lacking, the reasoning backing their decisions to transfer 

the canopy density guidelines originally designed to be implemented at stand or even forest scale, 

to groups; 

2. Answering specifically the stakeholders’ questions regarding the assumptions made in 

Appendix G Bridge Habitat (for example: percentage of openness at stand level including 

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interspaces and regeneration opening; percentage of existing old growth in old growth 

allocations; relative higher density of canopy in MSO and goshawk habitats post plan 

amendments; etc.);

3. Providing qualitative and quantitative ‘visual’ descriptions of post treatment objectives, 

including relative proportions and actual sizes of groups, stands, openings, etc., for each treatment 

type; and, 

4. Explaining clearly how openness will be measured post treatments, how it will be monitored, 

how the monitoring data will trigger adaptive management, and at what thresholds. 

Forest plans amendments

Gap analysis

As discussed above, and as analyzed in the 4FRI DEIS, forest plans amendments are technically 

required for 4FRI to be implemented under the current forest plans of the Coconino and Kaibab 

national forests. These amendments essentially address management actions (mechanical 

treatments up to 16” or 18” d.b.h., and low-intensity prescribed fire) in the Mexican Spotted Owl 

Protected Activity Centers (MSO PACs); and (a) resolve the issues of desired percentage of 

interspace within uneven-aged stands; (b) add the interspace distance between tree groups; and, 

(c) add language clarifying where canopy cover is and is not measured to facilitate restoration in 

goshawk habitat (excluding nest areas). The amendments also remove the cultural resource 

standard that requires achieving a “no effect” determination, and allow for a “no adverse effect” 

determination. The amendments further remove language referencing monitoring of Mexican 

Spotted Owl Protected Activity Centers (pre- and post-treatment, population, and habitat), and 

defer to the U.S. Fish and Wildlife Service the monitoring and design of the treatments in 

Mexican Spotted Owl protected habitats.

The Eastern Arizona Counties Organization understands the technical necessity of amending the 

forest plans and has no specific issue with the concept. However, ECO is concerned about the 

decision of the USFS 4FRI Team to characterize the amendments as nonsignificant, and to defer 

4FRI projects design and monitoring in Mexican Spotted Owl protected habitat to the U.S. Fish & 

Wildlife Service, without including the U.S. Fish & Wildlife Service monitoring plan and 

guidelines for projects design in the 4FRI DEIS. 

The Forest Service Manual provides guidance in Sec. 1926.52 Changes to the Land Management 

Plan That are Significant as follows: “2) Changes that may have an important effect on the entire 

land management plan or affect land and resources throughout a large portion of the planning area 

during the planning period.” 

In the USFS 4FRI Team’s own analysis in Appendix B Forest Plan Amendments: “The canopy 

cover portion of the amendment would affect 139,308 acres (18 %) of all goshawk habitat on the 

Coconino NF and about 35 % of goshawk habitat within the project area” (DEIS p. 466); and: 

“The amendment would affect approximately 20 % of all suitable goshawk habitats on the forest 

and about 27 % of goshawk habitat within the project area” (DEIS p. 482). It is unclear to the 

Eastern Arizona Counties Organization if there is an official percentage threshold for significance 

in the Forest Service regulations, but it seems that the common understanding of the word 

‘significant’ - “a noticeably or measurably large amount” (Merriam Webster) - would include 35 

% of goshawk habitat within the project area in the Coconino National Forest, or 27 % of 

goshawk habitat within the project area in the Kaibab National Forest. Citing these two 

percentages as precisely the reason why “For this reason, location and size (were) determined to 

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be nonsignificant” (DEIS p. 466 and p.482) seems questionable, unless guided by an agency 

guideline, in which case a reference would be useful. Additionally, it is unclear how the canopy 

cover portion of the amendments would affect only 35 % and 27 % of goshawk habitat 

respectively, although ECO speculates that it is related to higher vegetative structural classes 

(VSS).

Further, the Eastern Arizona Counties Organization is generally comfortable that habitat 

restoration and reduction of fire risk are key to improving Mexican Spotted Owl (MSO) habitat 

quality and, therefore, are aligned with both the current Coconino and Kaibab forest plans, as 

amended, and the U.S. Fish and Wildlife Service’s (USFWS) revised MSO recovery plan (2012). 

However, ECO is concerned that deference of treatments design to another agency (USFWS) 

without integrating this agency’s proposed treatments, or at least guidelines, in the 4FRI DEIS 

makes it impossible for the 4FRI DEIS Team to analyze the site specific and the cumulative 

effects of the treatments.

Therefore, the Eastern Arizona Counties Organization is concerned that the characterization of the 

forest plans amendments as nonsignificant, and the deferral of monitoring and treatments design 

to the U.S. Fish and Wildlife Service, without the inclusion of a USWFS monitoring plan or 

treatments guidelines, and without the possibility to analyze their effects in the 4FRI DEIS, may 

present a process risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the characterization of the forest plans amendments 

as nonsignificant, and the deferral of monitoring and treatments design to the U.S. Fish and 

Wildlife Service, without the possibility to analyze their effects in 4FRI, presents a consistency 

gap between the 4FRI DEIS and the Counties’ objectives as expressed in their plans and policies 

and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

request a third party legal review of the Forest Service Manual requirements in, and of the 4FRI 

DEIS compliance with, Sec. 1926.52 as relates to a determination of non-significance.

The Eastern Arizona Counties Organization further respectfully suggests that U.S. Fish and 

Wildlife Service monitoring plan and guidelines for the design of treatments in Mexican Spotted 

Owl protected habitats be incorporated into the 4FRI DEIS, and that their expected direct and 

indirect site specific effects be analyzed, presented, and integrated into the cumulative effects 

analysis.

Old growth

Gap analysis

The adaptation of the stakeholders-developed single document Old Growth Protection and Large 

Trees Retention Strategy (OGPLTRS) by the USFS 4FRI Team resulted in two documents: i) the 

Old Trees Implementation Plan (OTIP); and, ii) the Large Trees Implementation Plan (LTIP). The 

Large Trees Implementation Plan (LTIP) is discussed in the following section Large Trees.

Clearly, the focus of the 4FRI stakeholders on old growth protection has been integrated by the 

USFS 4FRI Team in the 4FRI DEIS. Section C Old Trees Implementation Plan of Appendix D 

Alternative B through D Implementation Plan captures the essence of the stakeholders’ old 

growth protection strategy: “Old trees would not be cut for forest health issues or to balance age 

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or size class distributions” (DEIS p. 644). The Eastern Arizona Counties Organization also 

observes that, as required in order to comply with the forest plans, old growth allocation in the 

4FRI DEIS meets the 20% minimum requirement for vegetative structural stage (VSS) 6 Old 

Forest; and Appendix D Section B Decision Matrix for establishing tree groups, interspace, and 

regeneration openings, preserves trees with old tree characteristics.

However, the Eastern Arizona Counties Organization observes that, past the affirmative 

statements in the 4FRI DEIS, the actual field decisions are left open to individual judgment. 

While “human health and safety” (DEIS p. 644) should be a fairly objective criteria, “additional 

habitat degradation” may be more open to interpretation, as illustrated in Section C Old Trees 

Implementation Plan itself where the example of prevention of additional habitat degradation 

involves ... road construction! 

Further, the Eastern Arizona Counties Organization also observes that the 4FRI DEIS states that 

“most sites (allocated to old growth) currently do not fully meet the minimum criteria for old 

growth conditions as listed in the forest plans” (p. 15). Considering that the purpose of allocating 

acres to old growth forest is to manage these acres for the fastest possible growth of existing trees 

toward VSS 6, there is a high likelihood that mature large trees in VSS 5 may be thinned in order 

to reduce competition for VSS 6 candidates. This decision also involves personal interpretation 

and individual judgment calls which may prove socially acceptable or disastrous based on the 

individual making the decision. 

Therefore, the Eastern Arizona Counties Organization is generally satisfied with the Old Trees 

Implementation Plan (OTIP) and old growth management objectives stated in the 4FRI DEIS, but 

remains concerned that its implementation may be a social license risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible social 

license risk for the 4FRI DEIS potentially caused by a misguided implementation of the Old 

Trees Implementation Plan (OTIP), may present a consistency gap between the 4FRI DEIS and 

the Counties’ objectives as expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

include strict and restrictive guidance regarding the possible removal of old growth, including a 

maximum number of trees removed according to appropriate metrics such as possibly: per 10 acre 

block, per mile, per project, or similar. 

Large trees

Gap analysis

Large trees are particularly precious inasmuch as they represent the ‘future old growth’ necessary 

to restore the forests of eastern Arizona to an ecologically sustainable condition, and to provide 

habitat to dense and high canopy dependent species. The old growth ‘allocation’ requirement of 

20% in the forest plan, as discussed in the previous section Old Growth, is a ‘paper’ allocation 

and should not be confused with the ‘actual’ old growth that exists in the lower single digit 

percentage across the forests, numerically far below the required 20% - or even 10% - and 

temporally far removed from reaching the required 20%. The deficit of actual vegetative 

structural stage (VSS) 6 Old Forest is what makes vegetative structural stage (VSS) 4 and 5 Midage Forest and Mature Forest important. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

976 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

This reasoning guided the Eastern Arizona Counties Organization when it participated to the 

stakeholders development of the Old Growth Protection and Large Trees Retention Strategy 

(OGPLTRS) that the USFS 4FRI Team adapted into two documents: i) the Old Trees 

Implementation Plan (OTIP); and, ii) the Large Trees Implementation Plan (LTIP). The Old Trees 

Implementation Plan (LTIP) is discussed in the previous section Old Growth. 

The purpose of the stakeholders’ large trees retention strategy is to emphasize the retention of 

large trees (VSS 4 and 5) in order to re-establish the old growth necessary for the ecological 

sustainability of eastern Arizona forests. However, the large trees retention strategy also includes 

a series of exception mechanisms that codify the socially acceptable removal of large trees (VSS 

4 and 5) with a diameter superior to 16” at breast height (d.b.h.), when their removal is necessary 

to achieve the ecological restoration objective, to increase heterogeneity, and/or to conserve 

biodiversity. The stakeholders’ document also includes provisions for collaborative adaptive 

management and collaborative participation to propose decision content, while complying with 

the statutory retention of the decision making authority by the Responsible Official. 

The Eastern Arizona Counties Organization is concerned that the adaptation of the stakeholdersdeveloped large trees retention strategy by the USFS 4FRI Team into the Large Trees 

Implementation Plan (LTIP) i) does not fully reflect the intent of the stakeholders; and, ii) does 

not take advantage of the products of the 4FRI collaboration. Specifically: 

1. The Forest Service determined that: “The original LTRS did not provide the ability to create 

regeneration openings using a group selection treatment method within the large, young tree and 

the within stand openings category” (DEIS p. 57). In so stating, the Forest Service apparently 

overlooks the fact that removal of individual large young trees is allowed under the exception 

mechanism, as required to meet the ecological restoration objective. The stakeholders’ intent in 

constraining the removal of groups of large young trees is to allow the development of future old 

growth as required in the forest plans, including old growth groups. 

2. The Forest Service further determined that: “this would result in a continued imbalance of size 

classes that would be contrary to the forest plan desired conditions” (DEIS p. 57). In so stating, 

the Forest Service fails to capitalize on the fact that the 4FRI DEIS already includes several forest 

plans amendments and that these amendments can address this issue as well. Further, the USFS 

4FRI Team does not disclose at what scale the imbalance would occur. Imbalance at group level, 

or even possibly at stand level, becomes balance at larger scales as groups of VSS 5 future old 

growth balance large areas devoid of them. 

3. The Forest Service also determined that: “The original LTRS would have required the Forest 

Service to consult with stakeholders should a new exception category be found during 

implementation (LTRS, page 25). To resolve the potential for Federal Advisory Committee Act 

(FACA) violations, this consultation requirement was removed” (DEIS p. 57). In so stating, the 

Forest Service misses an opportunity to take advantage of the MOU signed between the USFS 

and the stakeholders to address specifically such issues through collaboration incompliance with 

FACA.

Therefore, the Eastern Arizona Counties Organization is concerned that the adaptation of the 

stakeholders-developed large trees retention strategy by the USFS 4FRI Team into the Large 

Trees Implementation Plan (LTIP) is likely to be a significant social license risk for the 4FRI 

DEIS, and that the risk / benefits analysis of the social license risk vs. the restoration benefits may 

be unfavorable to 4FRI. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 977
Appendix I – Summary of Response to Comments on the DEIS

Consequently, the Eastern Arizona Counties Organization is concerned that the social license risk 

for the 4FRI DEIS likely caused by the adaptation of the stakeholders-developed large trees 

retention strategy by the USFS 4FRI Team into the Large Trees Implementation Plan (LTIP), 

presents a consistency gap between the 4FRI DEIS and the Counties’ objectives as expressed in 

their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

provide a clear and compelling analysis:

1. Presenting at what scale the inability to create regeneration openings using a group selection 

treatment method within the large, young tree and the within stand openings categories would 

result in a continued imbalance of size classes;

2. Presenting a collaborative process that would allow the USFS Responsible Officials to comply 

with the FACA requirements while implementing stakeholders supported adaptive management in 

case a new exception category would be needed during implementation; and,

3. Presenting language for expanding the amendments plans, if actually necessary, should a 

multiple scale analysis not address the issue of continued imbalance of size classes.

Prioritization

Gap analysis

The Eastern Arizona Counties Organization observes that there are only a mere 5 instances of the 

word “prioritization” in the 744 page 4FRI DEIS. ECO further observes that none of these 

instances apply to the discussion of the concept of treatments prioritization, for the obvious 

reason that there is no discussion of treatments prioritization in the 4FRI DEIS, including in 

Appendix D Alternative B through D Implementation Plan, or in the specialist reports or in the 

project record.

The Eastern Arizona Counties Organization also observes that Appendix D Alternative B through 

D Implementation Plan contains no discussion of timing or sequencing of treatments and that the 

concept of ‘Implementation Plan’ seems interpreted in the 4FRI DEIS as ‘guidelines to 

implement’ rather than ‘action plan to implement’ or ‘work plan to implement.’ ECO certainly 

realizes that minute details of implementation are not a NEPA concern but a contracting 

management concern. However, ECO also posits that the implementation of a management action 

as far reaching in scope and temporal and geographical scale as 4FRI, requires a discussion of 

timing and sequencing, inasmuch as timing and sequencing of treatments are of a nature to 

potentially impact significantly the site specific effects of individual treatments and the collective 

cumulated effects of the treatments (understood as the effects of the cumulated treatments within 

4FRI, as opposed to the NEPA understanding of cumulative effect of the 4FRI treatments plus 

other projects). 

Further, the concept of ‘Strategic Placement’ of the treatments, in relation to values to be 

protected, dominant winds, modeled fire behaviors, etc., is critical in the determination of what 

treatments are most appropriate, how many treatments are required, what treatment intensities are 

required, and what is the best distribution between treatment types (mechanical vs. fire).

The 4FRI stakeholders worked extensively to produce the Landscape Restoration Strategy for the 

First Analysis Area (2010) that addressed in detail the concept of geographical and temporal 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

978 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

prioritization. This work was further refined with the participation of the USFS 4FRI Team into a 

classification of High Resource Values (HRVs) and Medium Resource Values (MRVs). Some 

elements of this work were utilized by the USFS 4FRI Team in the 4FRI analysis process, but the 

discussion of strategic placement; geographical and temporal prioritization; and, their impact on: 

number, type, intensity, individual and cumulated effects of treatments, is missing. 

The Eastern Arizona Counties Organization is not inferring the need to re-analyze the location of 

the treatments. ECO is generally satisfied with the map of treatments location. Rather, ECO is 

suggesting the need to integrate in the NEPA analysis when and in what order the treatments 

already identified spatially will take place, as timing and sequencing have a direct impact on the 

number, type, intensity and effects of treatments.

The Eastern Arizona Counties Organization is not inferring the need to re-analyze the location of 

the treatments. ECO is generally satisfied with the map of treatments location. However, because

the timely implementation of the restoration treatments is critical to meeting the purpose and 

needs of the proposed action, ECO is concerned that the spatial and temporal sequencing of the 

treatments may have a significant effect on: i) whether the purpose and needs will be met; and, ii) 

the number, type, intensity, and individual and cumulated effects of the treatments required to 

meet the purpose and needs. Consequently, the absence in the 4FRI DEIS of spatial and temporal 

strategic timing and sequencing of the treatments, and integration of the influence of spatial and 

temporal prioritization of the treatments on the number, type, intensity, and individual and 

cumulated effects of treatments, may present a process risk for the 4FRI EIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the absence of a discussion of strategic placement, 

spatial and temporal prioritization, and their influence on the number, type, intensity, and 

individual and cumulated effects of treatments, presents a consistency gap between the 4FRI 

DEIS and the Counties’ objectives as expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

provide a clear and compelling analysis:

1. Presenting a temporal prioritization of the treatments and a sequenced timeline of 

implementation for the treatment of 30,000 acres annually over the 10 year life of the 4FRI 

project;

2. Presenting a spatial prioritization of the treatments and the sequenced locations of the 

treatments, for the treatment of 30,000 acres annually over the 10 year life of the 4FRI project; 

and, 

3. Presenting how the temporal and spatial prioritization affect the number of treatments, type of 

treatments, intensity of treatments, direct, indirect, site specific, and cumulated effects of the 

treatments.

Fire modeling

Gap analysis

Fire behavior modeling is a critical part of the 4FRI site specific and cumulative analysis process, 

and the Eastern Arizona Counties Organization appreciates the fact that a major effort was made 

along the entire 4FRI analysis process, starting well before the DEIS, or even the Proposed 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 979
Appendix I – Summary of Response to Comments on the DEIS

Action, to model the cumulative effects of landscape scale restoration treatments on fire behavior. 

To ECO, post-treatments and long term future desired conditions fire behaviors represent much of 

the ‘end game’ in 4FRI, as the restoration of a natural regime of regular cool surface fires is 

fundamental to the long term ecological sustainability of the forests of eastern Arizona.

Probably as a consequence of the fact that the 4FRI DEIS does not include a specific treatments 

implementation plan including timing, prioritization and sequencing of treatments in Appendix D 

Alternative B through D Implementation Plan (see section Prioritization here above), the fire 

behavior modeling in the 4FRI DEIS only provides a theoretical modeling based on the 

unrealistic premise that all treatments would happen simultaneously. This is unfortunate because 

the fire behavior modeling cannot include accurate canopy characteristics (base height, bulk 

density and cover) or surface fuel loading for any given large area at any given point in time as a 

result of some treatments being implemented; some treatments not being implemented yet, with 

fuel load further increasing and canopy characteristics further degrading; and, some treatments 

having been implemented, possibly as earlier as a decade earlier, with canopy and fuel loading 

characteristics at various stages of regrowth.

Accordingly, the Eastern Arizona Counties Organization is concerned that post-treatment fire 

behavior as modeled may not represent reality, and that the analysis of the cumulated effects of 

the treatments (understood as the effects of the cumulated treatments within 4FRI, as opposed to 

the NEPA understanding of cumulative effect of the 4FRI treatments plus other projects) may be 

tainted. 

Therefore, the Eastern Arizona Counties Organization is concerned that the modeling of the fire 

behavior effects of the treatments based on the assumption that all treatments are performed 

simultaneously, due to the lack of timing and sequencing of the treatments, may present a process 

risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the modeling of the fire behavior effects of the 

treatments based on the assumption that all treatments are performed simultaneously, presents a 

consistency gap between the 4FRI DEIS and the Counties’ objectives as expressed in their plans 

and policies and in these comments. 

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that subsequent to the 

completion of an analysis presenting a temporal and spatial prioritization of the treatments, the 

USFS 4FRI Team provide a clear and compelling analysis of the effects of the treatments on fire 

behavior, presenting 

ECO comments on the 4FRI DEIS page 30 of 43 

Eastern Arizona Counties Organization 550 N. 9th Place Show Low, AZ 85901 (928) 637 3037 

annual or bi-annual fire behavior modeling based on the outcome of the progressive 

implementation of 30,000 acres of restoration treatments annually over the 10 year life of the 

4FRI project, and that the impact of this analysis be integrated in the analysis of the number, type 

and intensity of treatments required to meet the purpose and needs, and the direct, indirect, site 

specific, and cumulated effects of the treatments.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

980 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Watersheds

Compatibility analysis

The ponderosa pine vegetation type in the 4FRI DEIS analysis area is dominated by Class 2 

functional at-risk 6th level Hydrologic Unit Code (HUC) watersheds on about 451,500 acres or 

46 % of the analysis area. Class 3 impaired watersheds represent about 316,800 acres, or about 32 

% of the analysis area. Class 1 properly functioning watersheds represent about 220,400 acres, or 

about 22 % of the analysis area (DEIS p. 107).

Per the Specialist report, and as summarized in the 4FRI DEIS, the 4FRI restoration treatments 

under Alternative B (the Proposed Action) and Alternative C (the Preferred Alternative) are 

expected to result in an improvement in 23% of Class 2 functioning at-risk watersheds (~104,000 

acres), and 42% of Class 3 impaired watersheds (~133,000 acres), with 28 miles of improved 

water flow regimes overall, including 19 miles in Class 2 watersheds that are functioning at risk 

and 9 miles in Class 3 watersheds currently impaired (DEIS p. 114). 

The Eastern Arizona Counties Organization is generally satisfied that the effects of the 4FRI 

restoration treatments under Alternative B and Alternative C contribute significantly toward the 

ECO Counties’ objectives as expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization encourages the USFS 4FRI Team to prioritize 

wherever and whenever possible restoration and catastrophic fire prevention treatments in the 

watersheds, after the direct protection of communities and infrastructures.

Continuity between the USFS 4FRI Team work, the 4FRI project record, and the 4FRI 

DEIS

Gap analysis

During its participation in the DEIS Review Workgroup of the 4FRI Stakeholders Group, and the 

associated work with the USFS 4FRI Team, the Eastern Arizona Counties Organization observed 

that site specific information can be virtually impossible to access by anyone not deeply 

immersed with or, for all practical purposes, not a member of the USFS 4FRI Team. Additionally, 

the site specificity verification process revealed that some of the required Geographic Information 

System (GIS) data tables or layers were not entered into the official project record.

Therefore, the Eastern Arizona Counties Organization is concerned that the integrity or 

completeness of the official project record as required under NEPA may be compromised by the 

accidental omission of technical data and may present a process risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the fact that the integrity or completeness of the 

official project record as required under NEPA may be compromised by the accidental omission 

of technical data, presents a consistency gap between the 4FRI DEIS and the Counties’ objectives 

as expressed in their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

conduct a systemic and systematic review of all technical data, GIS or other, used in their 

analysis, and ensures that it is included in the 4FRI project record. ECO further suggests that the 

USFS 4FRI Team use the same methodology of random sampling as used by the DEIS Review 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 981
Appendix I – Summary of Response to Comments on the DEIS

Workgroup of the 4FRI Stakeholders Group to statistically verify that all required data is included 

in the project record. 

Site specificity

Compatibility analysis

During its participation in the DEIS Review Workgroup of the 4FRI Stakeholders Group, and the 

associated work with the USFS 4FRI Team, the Eastern Arizona Counties Organization verified 

to its satisfaction that the required site specificity as regards current condition, desired future 

condition, prescribed treatment, and site specific effects has been provided in the USFS 4FRI 

Team analysis process.

However, as stated in the above section Continuity between the USFS 4FRI Team work, the 4FRI 

project record, and the 4FRI DEIS, the site specificity verification process with the USFS 4FRI 

Team evidenced to both ECO and the USFS 4FRI Team that site specific information can be 

virtually impossible to access by anyone not deeply immersed with or, for all practical purposes, 

not a member of the USFS 4FRI Team.

Therefore, the Eastern Arizona Counties Organization is concerned that the difficulty to access 

site specificity information may present a process risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the difficulty to access site specificity information, 

presents a consistency gap between the 4FRI DEIS and the Counties’ objectives as expressed in 

their plans and policies and in these comments.

Suggested action

As discussed with the USFS 4FRI Team, the Eastern Arizona Counties Organization respectfully 

suggests that the interactive map presented on the 4FRI DEIS website be developed to allow easy 

‘point and click’ access to site specific information such as, but not limited to, current condition, 

desired future condition, prescribed treatment, site specific direct and indirect effects, and 

contribution to cumulative effects, as well as all the technical information regarding all relevant

resources as can be conveniently provided.

Alternatively, if technical or resource constraints preclude the USFS 4FRI Team to develop the 

above suggested interactive map, or to make it available to the public, the Eastern Arizona 

Counties Organization respectfully suggests that a ‘point and click’ function could provide 

information on how to procure the desired site specific data from the project record.

Cumulative effects

Gap analysis

Appendix F Cumulative Effects includes a comprehensive list of the past, current and reasonably 

foreseeable future projects and disturbances included in the cumulative analysis. These projects 

and disturbances include vegetation projects (mechanical thinning and prescribed fires); 

recreation projects; other projects; wildfires; insect and disease outbreaks; and, a short discussion 

of reasonably foreseeable projects with insufficient information for analysis. The list includes 

projects located on private, State, national forests and other federally managed lands that lie 

within, adjacent to and outside of the project area. Appendix F Cumulative Effects does not 

include a discussion of what the cumulative effects of all the projects are, and only includes a 

brief synopsis of Authorized Livestock Management; Timber Harvest; and, Post-1996 Vegetation 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

982 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Treatments – Uneven-aged Management, Fire Risk, Restoration summarized from the Specialists’ 

reports.

Chapter 3 Affected Environment and Environmental Consequences addresses extensively the 

concept of cumulative effects on Soils and Watershed; Vegetation; Fire Ecology; Air Quality; 

Terrestrial and Semiaquatic Wildlife and Plants; Aquatics; Noxious and Invasive Weeds; Heritage 

Resources; Tribal Relations; Socioeconomics; Recreation; Lands and Minerals; Scenery; Range; 

and, Transportation.

However, the format used to discuss the cumulative effects varies considerably from resource to 

resource. For example, the Soils and Watershed (DEIS p.105-121) and the Terrestrial and 

Semiaquatic Wildlife and Plants (DEIS p.173-245) sections include fairly comprehensive 

descriptions of the cumulative effects and of their rationale. Other sections formulate cumulative 

effects as opinions, or as summary statements that essentially posit that the past or current 

projects have achieved or are achieving their stated objectives.

The Cumulative Effects section itself of Chapter 3 is but a two sentence paragraph that states: “A 

summary of past, present, and reasonably foreseeable management actions and natural 

disturbances that were evaluated by most resources is located in appendix F. See the project 

record for the comprehensive master list of all projects and for additional information on each 

project” (DEIS p. 331). 

The Eastern Arizona Counties Organization is generally satisfied that the list of projects 

considered in the cumulative effect analysis is appropriate, with one notable exception. Since the 

completion of the 4FRI DEIS, the Flagstaff Watershed Protection Project Proposed Action (PA) 

has been released (April 2013) and will need to be integrated into the cumulative analysis in the 

final EIS.

The Eastern Arizona Counties Organization is generally satisfied that the resource specialists 

have conducted some form of cumulative effects analysis, and ECO realizes that the cumulative 

effect analysis methodology cannot be identical across resources. However, ECO is concerned 

that the methodologies for cumulative effects analysis are generally not satisfactorily explained, 

and may be inconsistent in depth and breadth across resources. ECO is further concerned that the 

issue of continuity between the project record, the specialists reports, and the DEIS - already 

identified regarding site specific effects -may also exist regarding cumulative effects.

Therefore, the Eastern Arizona Counties Organization is concerned that potential inconsistencies 

across resources in the depth, breadth and presentation of the methodologies used for cumulative 

effects analysis may present a process risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by potential inconsistencies across resources in the 

depth, breadth and presentation of the methodologies used for cumulative effects analysis, 

presents a consistency gap between the 4FRI DEIS and the Counties’ objectives as expressed in 

their plans and policies and in these comments.

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

include the Flagstaff Watershed Protection Project Proposed Action (April 2013) in the 

cumulative analysis in the final EIS.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 983
Appendix I – Summary of Response to Comments on the DEIS

The Eastern Arizona Counties Organization further respectfully suggests that each resource 

section of Chapter 3 Affected Environment and Environmental Consequences include a 

methodology subsection describing the methodology used for cumulative effects analysis. ECO 

also suggests that the USFS 4FRI Team review methodologies across resources to ensure 

consistency of depth and breadth of cumulative effects analysis.

Monitoring

Gap analysis

Appendix E Alternative B through D Monitoring and Adaptive Management Plan offers brief one 

or two sentence descriptions of: types of monitoring (ecological, implementation, effectiveness, 

validation and Collaborative Forest Landscape Restoration Act (CFLRA)); monitoring 

prioritization, scales, question and indicators; and, a ten line description of adaptive management. 

Appendix E also includes Table 143 Implementation monitoring questions, indicators, frequency 

of measurement, data source, and cost; Table 144 Landscape-scale effectiveness desired 

conditions, indicators, frequency of measurement, data source, and cost; and, Table 145 

Effectiveness monitoring plan. 

However, the Eastern Arizona Counties Organization observes that about half of Table 143 

Implementation Monitoring is left blank, and for most questions for which the table is not blank, 

the indicators are crude and the frequency is minimal (typically: annual acres and miles). Table 

143 looks more like an annual budgetary reporting table than a project implementation 

monitoring plan. The quantitative aspect of implementation monitoring seems addressed but the 

qualitative aspect of implementation monitoring seems largely unaddressed or unanswered. It is 

surprising that half the table is incomplete, indicating an unfinished product. 

The Eastern Arizona Counties Organization also observes that Table 142 Monitoring scales, is left 

incomplete inasmuch as it does not include any monitoring scale below the sub-unit for the 4FRI 

DEIS. This, too, indicates an unfinished product. Further, there appears to be a gap in the 

effectiveness monitoring plan inasmuch as most of the treatments focus on achieving treatments 

objectives and desired conditions at the stand or even group level, while most of the effectiveness 

monitoring appears to be planned at the landscape scale.

The Eastern Arizona Counties Organization further observes that Table 144 Landscape-scale 

Effectiveness offers a fairly comprehensive list of desired future conditions: Conservation of 

Biological Diversity; Ecosystem Resilience; Water and Air Resources; Economics; Social 

Systems; and, Heritage Resources. However, the indicators listed are macro level indicators and 

the frequency of measurement is generally annually or every 5 years, and many sections of the 

table in the “Data Source/Spatial Scale/Cost” column indicate “No numbers provided.” This 

further indicates an unfinished product. 

The Eastern Arizona Counties Organization also observes that Table 145 Effectiveness 

Monitoring Plan actually seems to be more of an adaptive management decision matrix than an 

effectiveness monitoring plan. Adaptive management is addressed in the following section 

Adaptive Management.

The Eastern Arizona Counties Organization is concerned that the 4FRI DEIS, the Specialists 

reports and the project record do not include a specific ‘action plan’ or ‘work plan’ and budget, or 

funding mechanisms, for the monitoring plan. Although the question of who will monitor, and 

potential funding sources, are nominally mentioned in Table 141 Monitoring plan tiers, the scale, 

scope and complexity of 4FRI require addressing these questions in a comprehensive fashion that 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

984 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

goes well beyond a passing mention in Table 141. How many man-hours will the implementation 

of the monitoring plan require? Who will provide these man-hours? How much will it cost? How 

will it be funded? What are the quality control mechanisms to ensure that monitoring itself - if 

provided by volunteer (amateur?) third parties - meets required criteria? What mechanisms exist 

to ensure the integrity of the measures?

Further, the reliance on “stakeholders” and “multiparty (monitoring boards)” in the 4FRI DEIS 

monitoring plan tiers (Table 141, DEIS p. 660) raises questions which are left unanswered 

regarding the functioning of the monitoring plan. For example: What is the USFS mechanism to 

utilize third party developed monitoring data to make agency action adaptive management 

decisions? What are the mechanisms to deal with adaptive management decisions that may be of 

a nature to significantly alter the management actions identified in the Record of Decision? Etc.

The Eastern Arizona Counties Organization is further concerned that the ability of the public to 

review and comment on the 4FRI monitoring ‘action plan’ or ‘work plan’ and budget has been 

compromised inasmuch as even if the USFS 4FRI Team develops such a plan and budget as an 

outcome of the comments process, the plan will not be available for public review and comments 

until a notice of decision is published, unless the USFS 4FRI Team decides to release a second 

4FRI Draft EIS (DEIS) or a Supplemental EIS (SEIS). Considering that the 4FRI monitoring 

‘action plan’ or ‘work plan’ and budget currently do not exist, it is not possible to submit 

substantive comments on them and, therefore, a potential objection could be ineligible based on 

51.52 - Issues Not Based on Previously Submitted Substantive Formal Comments.

In contrast, the current Forest Service Manual requirements for Plan Monitoring Program Design 

(Sec. 1921.51) are extremely specific:

“In designing the plan monitoring program, the Responsible Official: 

1. Should consider ongoing project and activity monitoring. 

2. Should establish and apply a screening process (FSH 1909.12, section 12.1) to ensure that only 

feasible and meaningful monitoring activities are conducted, and in a manner that is practical and 

affordable.

3. Should store and manage monitoring data in corporate applications such as Natural Resource 

Information System whenever the capability exists.

4. Should develop a multi-year monitoring guide that describes protocols, databases, and a 

monitoring schedule. 

5. Shall develop an annual monitoring action or work plan to identify the specific monitoring 

tasks to be accomplished and the budget and personnel associated with those tasks.”

The Eastern Arizona Counties Organization fully understands that Sec. 1921.51 was initially 

written to apply at Forest Plan level, and that the 4FRI DEIS is nested at project level within the 

Coconino and Kaibab forest plans. However, CEQ has made very clear that when mitigation is 

involved in the NEPA analysis – such as the adaptive management mechanism integrated within 

the 4FRI DEIS – monitoring is automatically invoked.

Therefore, the Eastern Arizona Counties Organization is concerned that the 4FRI Monitoring Plan 

may fail to comply with the requirements of Forest Service Manual Sec. 1921.51 in general, and 

with subsections 4) and 5) in particular; that the ability of the public to review and comment on 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 985
Appendix I – Summary of Response to Comments on the DEIS

the 4FRI monitoring action or work plan may have been compromised; and, therefore, the 4FRI 

Monitoring Plan may present a process risk for the 4FRI DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the fact that the 4FRI Monitoring Plan may fail to 

comply with the requirements of Forest Service Manual Sec. 1921.51 in general, and with 

subsections 4) and 5) in particular, and that the ability of the public to review and comment on the 

4FRI monitoring action or work plan may have been compromised, presents a consistency gap 

between the 4FRI DEIS and the Counties’ objectives as expressed in their plans and policies and 

in these comments.

Suggested action

Monitoring ‘action plan’ or ‘work plan’

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

include in very specific terms: i) quantitative, qualitative and effectiveness monitoring processes; 

ii) a monitoring ‘action plan’ or ‘work plan’ and budget; and, iii) the resources allocation and 

funding necessary to implement monitoring in the 4FRI DEIS, to ensure that the monitoring of 

the 4FRI project implementation is quantifiably and qualitatively implemented.

Practically, the Eastern Arizona Counties Organization suggests a three step monitoring process 

articulated as follows:

1) Quantitative implementation compliance monitoring.

The purpose of the quantitative implementation compliance monitoring is to answer the question: 

“Was the job done?” While, generally, this assessment is made by the Forest Service contract 

management team when a contractor is involved, it is suggested that this step becomes the 

beginning of the process rather than what is often the end of it. 

Specific quantitative implementation compliance monitoring measures can be defined at the 

planning stage and specific resources requirements can be calculated at the planning stage. The 

‘action plan’ or ‘work plan’ must include, disclose and commit the Responsible Officials to 

provide the resources and budget required. 

2) Qualitative implementation compliance monitoring. 

The purpose of the qualitative implementation compliance monitoring is to answer the question: 

“Was the job done correctly?” The need for qualitative implementation monitoring increases 

rapidly with the complexity of the actions undertaken. Complex forest restoration prescriptions 

implemented using designation by description (DxD) or designation by prescription (DxP) create 

substantial room for interpretation by the operators, and may result in outcomes substantially 

different on the ground from those intended by the resources specialists who wrote the 

prescriptions. Verifying that implementation complies not only quantitatively but qualitatively 

with the management decision is especially important when the third step of monitoring is 

intended, as effectiveness can only be meaningfully analyzed if the actual treatments outcomes 

are in compliance with the intended outcomes.

Specific qualitative implementation compliance monitoring measures can be defined at the 

planning stage and specific resources requirements can be calculated at the planning stage. The 

‘action plan’ or ‘work plan’ must include, disclose and commit the Responsible Officials to 

provide the resources and budget required. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

986 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

3) Multi-tier and multiple scales effectiveness monitoring.

The purpose of the effectiveness monitoring is to answer the question: “Do the outcomes of the 

management decision produce the intended effects?” The need for effectiveness monitoring 

increases rapidly with the complexity and spatial and temporal scopes of the management actions 

undertaken, especially in projects where cumulative effects analysis assumes a speculative nature 

owing to the scale and duration of the management actions. Landscape scale forest restoration 

over 2 million acres in 20 years, as endeavored in the 4FRI project, is largely inconceivable 

without the concept of adaptive management. However, adaptive management is but an empty 

rhetoric, and any management action and the NEPA analysis thereof is flawed, if robust three step 

monitoring as described here above is not planned and implemented. 

Specific effectiveness monitoring processes can be defined at the planning stage and specific 

resources requirements can be calculated at the planning stage. The ‘action plan’ or ‘work plan’ 

must include, disclose and commit the Responsible Officials to provide the resources and budget 

required. 

A three functional steps monitoring process articulated as above can be easily adapted to the three 

priority tiers identified in the 4FRI stakeholders suggested monitoring plan (2012) and the three 

monitoring scales identified in Appendix E Alternative B through D Monitoring and Adaptive 

Management Plan (DEIS p. 660). In presenting the above monitoring process, the Eastern 

Arizona Counties Organization does not intend to propose an alternative to the stakeholders 

developed Biophysical and Socioeconomic Monitoring for the desired conditions of the Four 

Forest Restoration Initiative plan, but to suggest a framework for the associated monitoring 

‘action plan’ or ‘work plan’ and budget required under FSM Sec. 1921.51 (4) & (5). 

Multi-party monitoring

The Eastern Arizona Counties Organization respectfully suggests that the 4FRI DEIS include in 

very specific terms the requirements for the Responsible Officials to be bound by the findings of 

multi-party monitoring boards. It is not suggested here that responsible officials surrender their 

decision making authority to a multi-party monitoring board, or violates the requirements of 

FACA, but that they should be required to act upon the findings of a multi-party monitoring board 

in a manner that appropriately addresses the issues raised.

Adaptive management

Gap analysis

The Eastern Arizona Counties Organization observes that the words ‘adaptive management’ are 

used in 61 distinct instances throughout the 4FRI DEIS, and that adaptive management is referred 

to, throughout the entire 4FRI DEIS, as an integral part of the 4FRI project and as a management 

tool fully integrated in the 4FRI NEPA process. ECO applauds the commitment of the USFS 

4FRI Team to adaptive management, as projects on the scale of 4FRI (~2 million acres in 20 

years), or even the first DEIS of 4FRI (~1 million acres in 10 years), where direct, indirect and 

cumulative effects analysis assumes a speculative nature owing to the scale and duration of the 

management actions, are largely inconceivable without the concept of adaptive management.

However, the Eastern Arizona Counties Organization observes that aside from a five line 

description in the Glossary (DEIS p. 341), and a nine line general description in the Appendix E 

Alternative B through D Monitoring and Adaptive Management Plan (DEIS p. 661-662), there is 

no presentation or description in the 4FRI DEIS, the specialists reports or the project record, of 

the adaptive management process. The entire adaptive management plan for the 4FRI project is 

described as follows: “Monitoring of alternative management actions provides the data for the 

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adaptive management process. As a result of comparing monitoring results to the predicted 

outcomes, the plan provides a roadmap for adjusting actions or applying new science as long as 

the anticipated effects are within the scope of impacts analyzed and disclosed in the EIS and 

record of decision” (DEIS p. 661-662). 

The fundamental issues of characterization of system uncertainty through multi-model inference; 

definition of temporal and spatial scales; indicators selection; analysis, modeling, and 

conclusiveness of quantitative, qualitative and effectiveness multi-tier and multiple-scale 

monitoring data; identification of thresholds; evaluation of strategic alternatives; amplitude, 

timing, scale and iteration of corrective actions; etc., are left untouched.

Additionally, as mentioned in the above section Monitoring, the Eastern Arizona Counties 

Organization also observes that Table 145 Effectiveness Monitoring Plan actually seems to be 

more an attempt at an adaptive management decision matrix rather than an effectiveness 

monitoring plan per se. The table includes some indicators, triggers, and adaptive actions based 

on landscape scale desired conditions, but many adaptive actions applying to macro level desired 

conditions are “discontinue” or “prohibit until alternative approach is development (sic)” or 

“increase” or “re-evaluate”. These are binary or vague. In addition, many of the triggers timelines 

are 5 or even 10 years long, which may be adapted for some resources, but may not allow, for 

other resources, the identification of trends, and the implementation of adaptive management 

actions before the entire 4FRI project, or half of it, is completed.

Similarly, the few lines of adaptive management narrative are vague and general: “Some of the 

effectiveness monitoring objectives have adaptive management actions that would be taken if the 

established thresholds are reached or exceeded. Alternatives B, C, and D have specific adaptive 

management actions for springs, channels, and roads that have been made part of the alternative 

(see DEIS chapter 2)” (DEIS p. 662). 

The Eastern Arizona Counties Organization is concerned that adaptive management is only a 

concept at this stage; that the specialized techniques and processes of adaptive management may 

not be fully grasped; and that adaptive management has not been truly engineered into the 4FRI 

project as an executable management mechanism integral to the 10 year implementation of the 

4FRI EIS over one million acres.

Further, the Eastern Arizona Counties Organization is concerned by the reaction to date of the 

USFS 4FRI Team to such observations: “Adaptive management is not a NEPA requirement.” 

ECO is concerned that, while it is correct that adaptive management is indeed not a NEPA 

requirement in the 1982 Planning Rule, it has become one under the 2012 Planning Rule (Forest 

Service Handbook FSH 1909.12 – 41). Maybe more importantly, ECO is concerned that by 

making adaptive management a key process of the 4FRI NEPA analysis, the USFS 4FRI Team 

has in effect constrained itself into designing and implementing a true adaptive management 

process.

Therefore, the Eastern Arizona Counties Organization is concerned that the absence of a robust 

adaptive management process, despite the stated reliance on adaptive management to implement 

restoration treatments on one million acres over 10 years, may present a process risk for the 4FRI 

DEIS.

Consequently, the Eastern Arizona Counties Organization is concerned that the possible process 

risk for the 4FRI DEIS potentially caused by the absence of a structured adaptive management 

plan, presents a consistency gap between the 4FRI DEIS and the Counties’ objectives as 

expressed in their plans and policies and in these comments.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

988 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Suggested action

The Eastern Arizona Counties Organization respectfully suggests that the USFS 4FRI Team 

develop and include in the 4FRI EIS a robust adaptive management plan that includes 

standardized processes such as:

• Characterization of system uncertainty through multi-model inference; 

• Definition of temporal and spatial scales;

• Analysis of indicators selection;

• Analysis, modeling, and conclusiveness of quantitative, qualitative and effectiveness multitier and multiple-scale monitoring data;

• Analysis of thresholds; 

• Analysis of strategic alternatives; and,

• Analysis of amplitude, timing, scale and iteration of corrective actions.

Planning Process Issues

In its review of the proposed directives revising the Forest Service Handbook (FSH 1909.12) and 

the Forest Service Manual (FSM 1920), and establishing procedures and responsibilities for 

implementing the 2012 National Forest System Land Management Planning Regulation set out at 

36 CFR part 219, the Eastern Arizona Counties Organization identified issues and shortcomings 

that are likely to affect the 4FRI DEIS.

The Eastern Arizona Counties Organization fully understands that the opportunity to comment on 

the 4FRI DEIS is neither an opportunity to comment on the 2012 Planning Rule, nor on its 

implementation directives. Nonetheless, precisely because the 4FRI DEIS will establish the 

parameters for all subsequent management actions in the 4FRI project for the upcoming 10 years 

or more, ECO believes that it is appropriate for the 4FRI EIS to specifically include and, 

therefore, integrate into any subsequent management action, guidelines on: i) how to use of best 

available scientific information to inform the land management planning process; ii) public 

participation and the role of collaboration; and, iii) the objection process.

Use of Best Available Scientific Information to Inform the Land Management 

Planning Process

The Eastern Arizona Counties Organization appreciates and supports the important role given to 

the use of best available scientific information to inform the land management planning process 

in the proposed directives and in the 4FRI DEIS. 

The Eastern Arizona Counties Organization further appreciates and supports the important role 

given to assessing social and economic sustainability and multiple uses in the assessment process.

Issue 

However, the Eastern Arizona Counties Organization believes that the proposed directives miss a 

critical opportunity to provide substantially clear directives to responsible officials in actually 

integrating social and economic sustainability and multiple uses, and in integrating social and 

economic science to the framework of best available scientific information to inform their land 

management planning process, and their management decision making process. Specifically, the 

assessment of the social, cultural and economic values becomes essentially an exercise in futility 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 989
Appendix I – Summary of Response to Comments on the DEIS

if these values are not reflected in the management decisions, and do not balance other values. 

This lacking is reflected in the 4FRI DEIS.

The Eastern Arizona Counties Organization clearly supports robust science and the full 

integration of ecological, bio diversity, restoration and conservation values in the management 

process, and ECO is on record for participating in, and often leading, efforts designed to reintroduce to the ecosystems of eastern Arizona natural ecologically sustainable processes such as 

a frequent cool surface fire regime. Nevertheless, ECO is observing, and when necessary is 

committed to mitigate, a tendency to develop and implement pure, uncompromised and 

uncompromising science, or the currently accepted state of best science - which often proves to 

be a temporary state, to the detriment of the enjoyment, custom, culture, health, safety and 

economic well-being of the people. 

Additionally, the Eastern Arizona Counties Organization is also observing, and when necessary is 

also committed to mitigate, the fact that the same temptation to develop and implement pure, 

uncompromised and uncompromising science, also often causes the weakening of the social 

consensus with stakeholders who would support the implementation of management decisions 

based on a balanced approach, but are unwilling to support the invasive implementation of a 

monolithic and intransigent interpretation of science. For example, many stakeholders are 

reluctant to support unconditionally the 4FRI DEIS, owing to the science-based decision to cut 

some of the large trees necessary for the development of the future old growth, in order to create 

regeneration openings in the name of scientifically driven silviculture. Such decisions may make 

sense at group level, in forests featuring well balanced classes of vegetative structural stages 

(VSS), but are difficult to support at stand level or forest level in forests where older VSS classes 

(VSS 5 and 6) are in recognized deficit at landscape scale, while younger VSS classes (VSS 2, 3 

and 4) are overabundant, choke the landscape, and transform it into a ticking fire bomb. 

Suggested action

The Eastern Arizona Counties Organization suggests that the 4FRI EIS provide clear and 

unambiguous guidelines to responsible officials to integrate social sustainability and social 

science into the framework of best available scientific information to inform their management 

decision making process.

Specifically, the Eastern Arizona Counties Organization suggests that the 4FRI EIS guide 

responsible officials to implement substantive - even though possibly scientifically imperfect - 

management actions that move the ecosystems significantly toward the desired future conditions, 

when such actions are supported by social consensus, rather than spend years attempting to 

forcibly impose management actions that may be deemed scientifically more perfect but that do 

not benefit from the support of the social consensus. In other words, ECO suggests that the 4FRI 

EIS emphasize executing well less than perfect projects now, over developing scientifically 

perfect projects that are not implemented.

To quote a famous Arizonan: “Extremism in the defense of liberty is no vice” (Barry Goldwater), 

but the Eastern Arizona Counties Organization would like to propose to the USFS 4FRI Team that 

extremism in the pursuit of best available scientific information (BASI) may become 

counterproductive when it results in paralysis by analysis, or inaction by litigation.

Public Participation and the Role of Collaboration

The Eastern Arizona Counties Organization appreciates and supports the important role given to 

public participation and the role of collaboration in the proposed directives and in the 4FRI DEIS. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

990 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Issue 

However, the Eastern Arizona Counties Organization believes that the proposed directives miss a 

critical opportunity to provide substantially clear directives to responsible officials on two 

fundamental and overlapping aspects of public participation and the role of collaboration. 

Specifically: i) sustained and meaningful public participation and engagement require that the 

public’s input actually influence substantially the decision making process; and, ii) sustained and 

meaningful collaboration requires that the products of collaboration be honored by the Forest 

Service. This lacking is reflected in the 4FRI DEIS.

The Eastern Arizona Counties Organization has acquired a long, ineffective, inefficient, 

unproductive and oftentimes frustrating experience of responsible officials paying lip service to 

public participation and to the role of collaboration, and ECO believes that the 4FRI EIS must 

focus the concept of public participation and collaboration away from complying with a process 

and ‘managing the problem,’ toward developing executable products and ‘resolving the problem.’ 

Suggested action

The Eastern Arizona Counties Organization recognizes that under current federal statutes Forest 

Service line officers are not allowed to share their decision making authority. Nonetheless, ECO 

believes that a statutory monopoly of decision making authority does not necessarily imply an 

operational monopoly on decision content. Therefore, ECO suggests that the 4FRI EIS emphasize 

that while the line officers retain their sole legal ability to make the decision, they are also 

required by law and regulation “to meet the needs of present and future generations” (Forest 

Service Mission Statement), as expressed through true public participation and collaboration, and 

meaningful consistency reviews with the local governments’ objectives, among other channels.

The Eastern Arizona Counties Organization further suggests that the 4FRI EIS guide responsible 

officials in retaining their legal decision making authority while allowing the public to participate 

meaningfully in, influence substantially, and, when appropriate, contribute to alter the content of 

their decision.

Objection Process

The Eastern Arizona Counties Organization appreciates the attempt made by the Forest Service 

to: i) allow the public a more effective involvement; ii) support the collaborative processes; and, 

iii) develop better decision-making (U.S. Forest Service Chief Tom Tidwell) by replacing the 

previous appeal process with the new pre-decisional administrative review, or “objection 

process”, to be applied under federal regulation to all projects and activities that implement landmanagement plans and that are documented in an environmental assessment or environmental

impact statement.

The Eastern Arizona Counties Organization acknowledges that the U.S. Forest Service announced 

on March 26, 2013 the final rule governing the objection process for projects and activities 

implementing land-management plans, and that the final rule was published in the Federal 

Register on March 27, 2013 after a review of public comments submitted in response to the 

publication of the proposed rule in 2012. Consequently, ECO fully understands that this 

comments letter is not an opportunity to comment on the objection process. 

Issue 

However, the Eastern Arizona Counties Organization believes that the recent decision made by 

the Forest Service to replace the previous appeal process with the new objection process in the 

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Coconino and Kaibab National Forests 991
Appendix I – Summary of Response to Comments on the DEIS

4FRI NEPA process does provide an opportunity to address concerns about the objection process 

implementation, as follows.

Among other significant differences, a critical difference between the previous appeal process and 

the new objection process is that an objection must be filed prior to an actual decision being made 

and published. This creates a potentially difficult situation inasmuch as there is a possibility, and 

in certain cases a probability, that several objections may be filed by several different parties, and 

that the resolution of these objections may result in a final decision significantly different from 

the one disclosed in the document published with the notice of a plan subject to objection. 

Although the list of objections will be public, the timing of filing of potential objections within 

the objections filing period may result in the requirement for the public to decide to file, or to 

abstain to file an objection based on the speculation of what other parties may decide to file, and 

what the resolutions to such objections might be. Additionally, since a final decision may be 

influenced significantly by the resolution of an objection that, by definition, happens only after 

the comments period is closed, parties may be unwillingly put in a situation where, per 51.52 - 

Issues Not Based on Previously Submitted Substantive Formal Comments, their potential 

objection may be ineligible. 

Additionally, the Eastern Arizona Counties Organization is concerned that Chapter 50 Objection 

Process in general, section 51.66 - Reviewing Officer Response to Objections and section 51.6 - 

Resolution of Objections in particular, and specifically section 51.6 paragraph 4: “The reviewing 

officer responds to the outstanding issues in the objection; The reviewing officer’s response may 

include instructions to the responsible official as part of the disposition of the objection. The 

response must be sent to the objecting party(ies) by certified mail, return receipt requested, and 

posted online” (36 CFR 219.57(b) and sec. 51.64) are focused on the administrative process of 

disposing of an objection, rather than on the substantial process of actually resolving it. 

Suggested action

The Eastern Arizona Counties Organization suggests that the 4FRI EIS guide the reviewing 

officers to exercise careful judgment in their resolution or rejection of objections, in relation to 

the true material importance of the objections – as opposed to their symbolic or emotional 

importance, and the potential effect of litigation on the implementation of the project. ECO 

suggests that a careful and dispassionate costs / benefits analysis be conducted between the minor 

ecological or silviculture costs possibly attached to some stakeholders’ objections, and the major 

benefits attached to sustaining the 4FRI social license.

In so suggesting, the Eastern Arizona Counties Organization wants to emphasize that it does not 

promote indiscriminate and aberrant acceptance of any and all parties’ whims or irrational 

demands, but a well-considered costs and benefits analysis by Forest Service responsible 

officials, line officers and reviewing officers of public input in their decision process in view of 

the relative actual significance or lack thereof of such input, and the overwhelming urgency to 

act, even if imperfectly in some specific cases, such as the protection of the forests of eastern 

Arizona against catastrophic landscape scale wildfires.

Summary

In summary, the Eastern Arizona Counties Organization wants to re-state its overwhelming 

support for the 4FRI project, the 4FRI DEIS effort, and the implementation of the 4FRI Preferred 

Alternative, provided that it is further refined per the suggestions provided by ECO and other 

stakeholders integral to the sustainability of the 4FRI social license.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

992 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

Therefore, the concerns and suggestions provided by the Eastern Arizona Counties Organization 

are not aimed at questioning the need to implement 4FRI, but at pointing out to the USFS 4FRI 

Team potential issues, gaps or weaknesses in the substance and the process that could be of a 

nature to compromise a non-conflictual and non-litigious implementation of the 4FRI project, as 

intended by ECO and the ECO Counties. 

The Eastern Arizona Counties Organization is fully aware that per Sec. 1503.4 Response to 

comments, the USFS 4FRI Team may elect to “Explain why the comments do not warrant further 

agency response, citing the sources, authorities, or reasons which support the agency's position 

and, if appropriate, indicate those circumstances which would trigger agency reappraisal or 

further response” (Sub Sec. 5). However, this is not the expectation of ECO. Rather, ECO expects 

that the USFS 4FRI Team will receive ECO’s comments in the spirit of continuous improvement 

and risk mitigation in which they were written, and elect to “Modify alternatives including the 

proposed action” (Sub Sec. 1), and “Supplement, improve, or modify its analyses” (Sub Sec. 3) as 

allowed for under Sec. 1503.4. 

The Eastern Arizona Counties Organization respectfully submits that the above comments and 

suggestions are substantive in nature and warrant careful consideration and adoption by the Forest 

Service.

The Eastern Arizona Counties Organization requests to be kept informed as the 4FRI NEPA 

process progress; hereby reserves its right to provide further comments as the process unfolds; 

and, requests that the Forest Service commit to receiving and integrating further comments from 

ECO as provided. 

The Eastern Arizona Counties Organization appreciates the opportunity to comment on the 4FRI 

DEIS and thanks the USFS 4FRI Team for this opportunity. ECO is committed to partner with the 

U.S. Forest Service to meet the ECO Counties’ residents’ and visitors’ enjoyment, custom, 

culture, health, security and economic well-being needs.

Thank you for your consideration. 

Respectfully Submitted on behalf and with the approval of the Board of Directors, 

Pascal Berlioux, Ph.D. MBA

Executive Director

Eastern Arizona Counties Organization

pberlioux@easternarizonacounties.us

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 993
Appendix I – Summary of Response to Comments on the DEIS

Summary of Response to Comments on the DEIS 

Approximately 213 letters and/or emails were received on the DEIS. Of these, 71 were form 

letters. In sum, about 1,000 individual comments were received. This section summarizes and 

responds to comments by topic. Some topics categorized as outside the scope of this analysis 

have been included because they were raised in both scoping and DEIS comments and remain 

unresolved. The complete comment analysis and response document is located in the project 

record and is available for review on the project website at: 

http://www.fs.usda.gov/main/4fri/planning. The page numbers referenced in this appendix are 

from the web version of the DEIS. 

Topic 1: NEPA and NFMA Compliance 

Topic 1-1: Analysis Site-Specificity: Approximately 8 commenters (CARA 8, 107, 137, 180, 

196, 198, 199 and 200) stated the DEIS presented an analysis that was programmatic in nature 

and not site-specific. 

Response: The DEIS displays up to 20 specific silvicultural and prescribed fire treatments for 

each alternative (DEIS, pages 71-72, 83-84 and 90-91). At least 20 treatments were applied to 

~30,000 stands based on site specific characteristics (VSS class, species, single story/multi-story 

structure, etc.) the result was well over 1,000 different outcomes. Table 18 (DEIS, page 74) 

displays road activities by restoration unit and table 19 (DEIS, page 74) displays miles and/or 

acres of springs, ephemeral channels and aspen treatments by restoration unit. Figures 27 and 28 

in the DEIS display the locations for road, springs and stream treatments (DEIS, pages 75-76). 

Examples of site-specific analysis are located in chapter 3 of the DEIS (page 105 to page 322) 

where site-specific effects for each resource are disclosed. For wildlife and overstory tree metrics, 

the stand (location/site) is the site specific unit that was used to aggregate data up to the 

individual metrics displayed within the DEIS. For soil and water, the base unit is the terrestrial 

ecosystem map unit that aggregates up by stand, by treatment type and intensity. For 

recreation/scenery, the basic units are the respective recreation opportunity class (ROS) and

scenery management classes (SMS) that aggregate up. For economics, the timber volumes are 

aggregated up from location/sites. For range, the basic unit is the range allotment. For 

transportation, the basic units are the individual road segments. For botany and rare plants, the 

basic units tie to select Terrestrial Ecosystem Units where the plants are likely to occur as well as 

previous survey data for both rare plants and noxious weeds. For fire ecology, the base unit is 30 

meter pixels from land fire data that are aggregated up. 

The Implementation Plan (DEIS, appendix D, page 601) states, “The process described in this 

appendix describes the linkage from the EIS to the project specific work without the need for 

additional NEPA analysis. It must be considered in conjunction with appendix C that provides the 

design criteria, best management practices, and mitigation measures. Tables 112 to 115 are 

checklists designed to ensure compliance with the analysis, decision, and other requirements. 

Essentially, if the quantity of treatments in table 112 and table 113 by resource unit are within the 

bounds of the treatments analyzed in chapter 3 of the EIS and the specialist’s reports, then the 

program of work is considered to be consistent with the effects analysis. Table 114 and table 115 

show the compliance evaluation and documentation requirements to also demonstrate this 

compliance. Sections A through E provide direction that would be used by implementation 

personnel to ensure that implementation meets the purpose and need and forest plan standards and 

guidelines. It is the foundation for the formal silvicultural prescriptions. The silvicultural 

prescriptions will document the desired conditions presented in the analysis, incorporate design 

features and mitigation (appendix C), and provide the course of action needed to move toward 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

994 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

those desired conditions (DEIS, page 601). The narrative for table 114 states, “The checklist is 

designed to ensure resource surveys are completed as required by the forest plan, policy, U.S. 

Fish and Wildlife Service (FWS) biological opinion, Comprehensive Forest Landscape 

Restoration Act (CFLR), or other requirements. The checklist also ensures that the site-specific 

treatments are compliant with the NEPA analysis and decision. The checklist is designed to be 

used by the resource specialists who comprise the implementation team and by the Agency’s 

(delegated) approving official” (DEIS, page 601). 

The site-specificity of the analysis was tested by the 4FRI stakeholder group on May 12, 2013. In 

response to comments on the DEIS, the stakeholders wrote, “The Stakeholder Group is concerned 

that in such a large analysis area, the DEIS might not be detailed enough to disclose site specific 

impacts of the proposed treatments. To test this concern, three randomly-selected sites were 

presented to the USFS DEIS development team. For these three stands, we asked to see the data 

that describes the existing condition, desired condition, proposed treatment, the effects of this 

treatment on the various resources, and how these effects are considered in the cumulative effects 

analysis. It took several hours to find all of the requested information for the three sites, but it 

does appear that extensive site specific analysis went into the DEIS document and we are 

satisfied that site-specificity is not an issue” (4FRI Stakeholder, 2013 Cara Letter 155). 

Most examples of using site-specific data to inform the environmental consequences in the DEIS 

can be found in the each resource report in the methodology sections. Examples in the DEIS 

include fire which discloses fire behavior at specific locations of concern, at the subunits, the 

restoration unit, landscape scales and specific locations (such as Pulliam Airport, Kachina Village, 

Perkins Telescope, etc. (DEIS, p. 150). How individual Mexican spotted owl PAC treatments 

were identified for treatment in appendix B pp. 443-444 of the DEIS. 

Topic 1-2: Connected Actions: One commenter (CARA 180) stated the analysis was not 

compliant with NEPA because there are undisclosed connected actions. This concern was 

addressed in response to comments received on the January 2011 (initial) draft proposed action. 

Response: Although the objective for 4FRI is to complete landscape restoration across four 

forests, this is not equivalent to having a connected action. There is no analysis underway in this 

EIS that renders decisions that would be needed by the next analysis in order to move forward. 

By the time the analysis for the Coconino NF and Kaibab NF is complete (with a final FEIS and 

ROD expected in late 2014 or early 2015) a different strategy may be used for any future 

analysis. It is unknown whether there may be one analysis or several. Even addressing the next 

analysis (or analyses) in terms of cumulative effects was too speculative as there are no 

reasonably foreseeable (quantifiable) proposed activities that can be evaluated in terms of overlap 

in time and space to the Coconino NF and Kaibab NF analysis. Decisions such as the location of 

the next analysis or analyses (including analysis boundaries) and the existing and desired 

conditions for that landscape have not been determined. There is no evidence that the Coconino 

NF and Kaibab NF proposals as displayed in the DEIS and FEIS will: (i) automatically trigger 

other actions which may require environmental impact statement, (ii) cannot or will not proceed 

unless other actions have been taken previously or simultaneously, or (iii) they are interdependent 

parts of a larger action and depend on the larger action for its justification (40 CFR § 1508.25(a) 

(1) (i)-(iii)).

We carefully considered if the Rock Pit Development: Coconino and Kaibab National Forests 

project (http://data.ecosystem-management.org/nepaweb/nepa_project_exp.php?project=34858) 

that is being conducted for both forests was a connected action. The project was initiated in 2011, 

The purpose of this project is to develop up to 39 rock pits to provide materials for surfacing 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 995
Appendix I – Summary of Response to Comments on the DEIS

roads to maintain safe and sustainable road conditions on both forests. Rock pit development will 

benefit this project. However, the intent of the project is to provide road maintenance materials 

for all roads on both forests –it is not specific to this project. For these reasons, the rock pit 

project was addressed in cumulative effects. 

Topic 1-3: Cumulative Effects: Several commenters (CARA 76, 89, 107, 115, 133, 137, 151, 

155, 180, 183, 184 and 197-200) stated that the cumulative effects analysis did not include 

specific projects, such as the Flagstaff Watershed Protection Project (FWPP). Some commenters 

stated it was unclear how the cumulative effects appendix in the DEIS was to be used since it 

appeared to be a list of projects with no analysis. Some commenters stated the cumulative effects 

analysis for Mexican spotted owl and goshawk was inadequate (also see the NEPA and NFMA 

Compliance section on Connected Actions). 

Response: In response to comments on the DEIS and changes that have occurred since the DEIS 

was published (see chapter 2) all cumulative effects analyses have been updated in the FEIS and 

specialists’ report to include projects that are reasonably foreseeable, including the FWPP and 

other natural disturbances (such as the 2014 Slide Fire on the Coconino NF). 

Clarifying language has been added to the “Cumulative Effects Appendix F” in the FEIS to 

reduce the potential for confusion. The intent of the appendix F in the DEIS was to document past 

and/or historic events and actions that had resulted in the existing/current condition. The intent 

was to display those actions and events that had the ability to affect vegetation structure, pattern, 

composition and disturbance regimes. The intent was not to replace the site-specific cumulative 

effects analysis that each resource conducts. 

In the DEIS, the Mexican spotted owl cumulative effects analysis was located on pages 187-189 

of the DEIS. The analysis references appendix 12 of the wildlife report where there is an 

extensive list of projects with notes on the type, size, and objective of each project. Baseline 

conditions were defined in the text. Table 196 of the wildlife report (page 705) described past 

projects conducted by the FS and identified the projects by National Forest and Ranger District. 

Table 197 of the wildlife report (page 719) listed similar information for past projects conducted 

by other agencies or private land managers. Table 198 (page 720) listed past wildfires to help 

inform baseline conditions. Table 199 of the wildlife report (page 723) described current and 

ongoing projects by the FS and identified each project by National Forest and Ranger District. 

Table 200 (wildlife report) described reasonably foreseeable projects (pp. 734-739). Reasonably 

foreseeable means that intent and acreage might be known, but until a record of decision is 

signed, change could occur in the type of treatments proposed, the size of treatments, and the 

location of treatments. All of these projects (i.e., wildlife report, pp. 705 – 739) were summarized 

in terms of Mexican spotted owl habitat. An introductory paragraph and seven summary tables 

followed (wildlife report, pp. 740 – 745). The cumulative effects analysis for past and ongoing 

projects related to the Mexican spotted owl was divided into effects to forest structure and effects 

to prey habitat, in line with the project analysis (wildlife report, pp. 319 – 321). The type of 

action, associated acres, and effects to Mexican spotted owl were discussed. Because there is no 

certainty as to what might happen, when it will occur, or how large the project will be, reasonably 

foreseeable actions were addressed separately (page 321). The above actions were summarized on 

page 187-189 of the DEIS. How these effects relate cumulatively to the 4FRI project was 

discussed by alternative on pages 188-189 of the DEIS. 

However, based on comments on the DEIS and changes between DEIS and FEIS (see the wildlife 

report for changes that were specific to wildlife), the cumulative effects analysis for Mexican 

spotted owl was revised. The FEIS wildlife report states, “Because of the size of the 4FRI 

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analysis area and the large portion of the western Upper Gila Mountain Recovery Unit that it 

occupies, the analysis area itself was considered adequate for assessing habitat effects to PACs. 

However, due to the potential for disturbance to owls, the cumulative effects boundary was 

extended 1⁄2 mile beyond the analysis area periphery to account for the spatial component of this 

analysis...The temporal component in this analysis was defined as 10 years for short-term effects 

and 30 years for long-term effects” (Wildlife Report, page 400). Projects before 1996 are 

incorporated into existing conditions. Aspects of existing conditions that are a result of these early 

projects include a deficit in large trees and snags and even-aged conditions. Pre-1996 projects 

also had heavy selection pressure for preferred tree genetics to provide healthy trees with good 

form. This latter effect resulted from harvested areas being regenerated from planting stock or 

from the selected reserve trees left in seed tree harvest units (Higgins, pers. comm. 2006). 

Wildlife habitat in the form of nesting, feeding, and loafing sites was reduced by selecting for 

disease-free trees with symmetric shapes, eliminating fork-top trees, trees with unusual branching 

patterns, and replanting with selected genetic stock from nurseries.

Current and foreseeable projects within the 4FRI boundary have or will thin a total of 39,111 

acres of Mexican spotted owl habitat and use prescribed fire on 37, 585 acres. This is mostly (84 

percent) due to work conducted in restricted habitat (Wildlife Report, table 153). Most work done 

in Mexican spotted owl habitat involves mechanical thinning or prescribed fire. Thinning and 

burning in Mexican spotted owl habitat would follow forest plan/Recovery Plan guidance with 

rare exceptions such as powerline right of ways. Other projects also include slash disposal, 

invasive weed treatments, and limited acres of animal damage control, erosion control, and 

disease tree harvest (Wildlife Report, Appendix 17). Effects to Mexican spotted owl habitat are 

broken down into two broad categories: Forest structure and prey habitat. The FEIS cumulative 

effects analysis for Mexican spotted owl is located on page 400 to page 412 of the wildlife report. 

Similar to Mexican spotted owl, the goshawk cumulative effects analysis has been revised since 

the DEIS was published, see the FEIS, chapter 3. 

Topic 1-4: Forest Plan Compliance - Scales of Analysis: One comment (CARA 180) stated the 

DEIS was not compliant with the forest plans requirement for evaluating old growth habitat at 

multiple scales – (1) the ecosystem management area; (2) one scale above the ecosystem 

management area; and (3) one scale below the ecosystem management area. This concern was 

originally addressed in the June 2011 4FRI Scoping Report (pp. 53-54). 

Response: The old growth standards for the Coconino NF states, “Until the forest plan is revised, 

allocate no less than 20 percent of each forested ecosystem management area to old-growth as 

depicted in the table below. In the long term, manage old-growth in patterns that provide for a 

flow of functions and interactions at multiple scales across the landscape through time. 

Allocations will consist of landscape percentages meeting old-growth conditions and not specific 

acres” The old growth guideline for the Coconino NF states, “All analyses should be at multiple 

scales—one scale above and one scale below the ecosystem management areas” (USDA FS 1987, 

page 70-1). 

The DEIS disclosed the scales of analysis (and rationale) on page 15. To be consistent with the 

Coconino NF forest plan, scales of analysis based on existing divisions of the landscape were 

developed specifically for the project. The smallest scale is represented at the stand level with 

stands averaging less than 100 acres in size. The Ecosystem Management Area (EMA) is the 

restoration sub-unit. Sub-units range in size from 4,000 to 109,000 acres. The scale above the 

ecosystem management area is the restoration unit, which ranges in size from 46,000 to 335,000 

acres. 

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Direction specific to the Coconino NF Management Area 3, Ponderosa Pine Mixed Conifer Less 

Than 40 percent Slope, Old Growth (Coconino NF Forest Plan, replacement page 127) includes 

direction written as a standard: “Stands managed for old-growth are 100 to 300 acres in size”. 

There is no corresponding direction in the revised Kaibab NF plan (USDA FS 2014). 

For the Coconino NF, forest plan direction for goshawk, old growth, wildlife hiding and thermal 

cover, and timber resource management, references conducting evaluations at the ecosystem 

management areas (EMAs) scale. However, beyond this forest-wide direction, which is a result of 

the 1996 amendment of 11 forest plans, there is no additional direction in the forest plan 

regarding the use of ecosystem management areas. For example, there is no relationship or 

crosswalk between the ecosystem management area to plan management areas. Across the forest, 

vegetation projects that are required to stratify vegetation and habitat at a scale above and below 

the ecosystem management area have directly linked the ecosystem management area to a 

10,000-acre (10K) block analysis. The 10K blocks have been based on stand boundaries. For 

those projects that exceeded 10,000 acres, the scale above the ecosystem management area was 

often a conglomeration of 10,000-acre units (Cote, personal communication with Flagstaff RD 

2011). 

Using a 10,000-acre scale would have been meaningless for a project of this size. The 10K block 

was used as a surrogate as a means to get to a landscape scale of analysis. A 10K analysis for this 

project would be too small to use for assessing impacts at the landscape and ecosystem scale. A 

key assumption in using the 10K block was if objectives were being met at the 10K, objectives 

were being met at the larger scale. There was a need to use scales which allowed for meaningful 

analysis from the small scale to the landscape scale. Coconino NF plan language specifically says 

blocks may be larger or smaller if approved by the forest supervisor. The Coconino NF supervisor 

may sign a project record document demonstrating the need, and rationale for, deviating from the 

10K analysis (Coconino NF Forest Plan, page 70). 

Since the DEIS was published, the Kaibab NF revised its forest plan (USDA FS 2014). Desired 

conditions (paraphrased) at the fine scale include having tree groups of various age classes and 

size classes, having crowns of trees within the mid-aged to old groups (Kaibab NF forest plan, p. 

17). The (paraphrased) desired condition at the landscape scale (over 10,000 acres) is to have old 

growth occur throughout the landscape as a component of uneven-aged management with the 

location of old growth shifting on the landscape as a result of succession and disturbance. Old 

growth components include old trees, snags, coarse woody debris, and structural diversity 

(Kaibab NF forest plan page 18). The FEIS reflects the new plan direction. The vegetation 

analysis in the FEIS (chapter 3) describes how the alternatives move towards desired conditions. 

The implementation plan (appendix D in both the DEIS and FEIS) describes in detail how 

treatments would be designed to protect old trees. 

Topic 1-5: Interconnected Relationship between the NEPA Analysis and the 4FRI 

Stewardship Contract: One comment (CARA 180) stated the Forest Service was required to 

prepare the comprehensive EIS for the 4FRI program before awarding the “Phase 1” contract to 

Pioneer Forest Products. The Agency violated 40 C.F.R. § 1500.1(b) which states “NEPA 

procedures must insure that environmental information is available to public officials and citizens 

before decisions are made and before actions are taken”. 

Response: This comment was categorized as outside the scope of this analysis. The Phase 1 4FRI 

Stewardship contract was not a NEPA decision and is utilizing existing, signed NEPA decisions to 

implement the contract. Each NEPA decision is designed to meet the intent of their respective 

forest plans, not a comprehensive restoration strategy. The phase 1 4FRI contract is a mechanism 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

998 Coconino and Kaibab National Forests 
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to implement individual NEPA decisions that, in turn, implement the respective forest plan. The 

cumulative effects of implementing signed NEPA decisions are disclosed in each respective 

NEPA document and are tied to future foreseeable actions that were outlined in the Schedule of 

Proposed actions at the time of the analysis (see DEIS and FEIS appendix F) 

Topic 1-6: Programmatic EIS: Approximately 5 commenters (CARA 180, 196, 198, 199, and 

200) stated a programmatic EIS should have been conducted as there are connected actions 

between the 4FRI analyses and segmentation has occurred. 

In 2011, conducting a programmatic EIS was ultimately considered outside the scope of this 

analysis. This concern was addressed in responses to the January 2011 (initial) draft proposed 

action. Although the objective for 4FRI is to complete landscape restoration across four forests, 

this is not equivalent to having a connected action. There is no analysis underway in this EIS that 

renders decisions that would be needed by the next analysis in order to move forward. By the 

time the analysis for the Coconino NF and Kaibab NF is complete (with a FEIS and draft ROD 

issued in 2014) a different strategy may be used for any future analysis. It is unknown whether 

there may be one analysis or several. Even addressing the next analysis (or analyses) in terms of 

cumulative effects was too speculative as there are no reasonably foreseeable (quantifiable) 

proposed activities that could be evaluated in terms of an overlap in time and space to the 

Coconino NF and Kaibab NF analysis. 

Decisions such as the definitive location of the next analysis or analyses (including analysis 

boundaries) and the existing and desired conditions for that landscape have not been determined. 

As of August 2014, data is being collected. There is no evidence that the Coconino NF and 

Kaibab NF proposed actions, currently under analysis, will: (i) automatically trigger other actions 

which may require environmental impact statement, (ii) cannot or will not proceed unless other 

actions have been taken previously or simultaneously, or (iii) they are interdependent parts of a 

larger action and depend on the larger action for its justification (40 CFR § 1508.25(a) (1) (i)-

(iii)). 

Conducting a programmatic EIS would require numerous, segmented analyses in order to move 

towards the landscape restoration objective. The issue of moving forward with a programmatic 

EIS versus as project specific EIS was discussed with CEQ on October 14, 2009 when the 

landscape restoration proposal was being prepared as a CFLR proposal. The Coconino and 

Kaibab NFs, the Southwestern Regional Office, NEPA/planning representatives from the 

Agency’s Washington Office, CEQ and 4FRI stakeholder representatives were on the conference 

call. The notes from this landscape strategy conference call are located in the project record.

Topic 1-7: Range of Alternatives and Comparison of Alternatives: Approximately ten 

comments (CARA 76, 89, 95, 98, 107, 115, 133, 137, 151, 155, 162, 163, 164, 165, 172, 174, 

177, 180, 184, and 196-200) questioned whether an adequate range of alternatives had been 

evaluated in the DEIS. This topic was categorized as a procedural concern statement and was 

added to chapter 1 in the FEIS. 

Response: The Agency is required to: “Study, develop, and describe appropriate alternatives to 

recommended courses of action in any proposal which involves unresolved conflicts concerning 

alternative uses of available resources as provided by section 102(2)(E) of the Act”(40 CFR 

1501.2(c)). “The EIS shall document the examination of reasonable alternatives to the proposed 

action. An alternative should meet the purpose and need and address one or more significant 

issues related to the proposed action. Since an alternative may be developed to address more than 

one significant issue, no specific number of alternatives is required or prescribed “(36 CFR 

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Coconino and Kaibab National Forests 999
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220.5(e)). Reasonable alternatives include those that are practical or feasible from the 

technical and economic standpoint and using common sense, rather than simply desirable 

from the standpoint of the applicant (40 CFR Section 1502.14). The phrase "range of 

alternatives" refers to the alternatives discussed in environmental documents. It includes all 

reasonable alternatives, which must be rigorously explored and objectively evaluated, as well 

as those other alternatives, which are eliminated from detailed study with a brief discussion 

of the reasons for eliminating them (40 CFR Section 1502.14).

The DEIS (page 62) included 9 alternatives including no action, three action alternatives and five 

alternatives that were considered but eliminated from detailed study. The alternatives responded 

to the issues received from the public (2011 Scoping Report, project record). In response to 

comments received on the DEIS, a fourth action alternative that would propose no forest plan 

amendments was analyzed in the FEIS. This increased the number of fully analyzed alternatives 

to five (four action alternatives and the no action alternative), and increased the number of 

alternatives considered but eliminated from detailed study to six. More important than the actual 

number of alternatives, is whether unresolved issues have been addressed through alternative 

development or environmental analysis. The range of alternatives considered by the responsible 

officials includes all reasonable alternatives to the proposed action that are analyzed in the 

document, as well as other alternatives eliminated from detailed study. 

Topic 1-8: Significant Forest Plan Amendments: Approximately 22 comments were submitted 

on this topic (CARA 76, 89, 95, 98, 107, 115,133, 137, 151, 155, 162, 163, 164, 165, 169, 172, 

174, 175, 184, and 197-200). Some commenters stated the DEIS (alternatives B-D) failed to 

support a finding that the plan amendments are nonsignificant. Some commenters stated the 

public cannot use the data in the analysis to determine the acres affected and to understand how 

these acres are related to other anticipated uses. Some commenters stated the proposed 

amendments are significant because they may bring about changes that may have an important 

effect on the entire land management plan or affect land and resources throughout a large portion 

of the planning area, see FSM 1926.52 (Jan. 31, 2006). 

The environmental cause and effect relationship is the perceived dramatic change in management 

for Mexican spotted owl that may result in harm to the Mexican spotted owl. On the Coconino 

NF, the amendments authorized (alternative B-D) mechanical treatments in Mexican spotted owl

PACs that exceed 9 inch d.b.h. and authorize the use of prescribed fire in Mexican spotted owl

PAC core areas (alternative C). In alternatives B-D all Mexican spotted owl existing monitoring 

requirements were removed and specific monitoring requirements were deferred to the FWS 

biological opinion. For goshawk, the amendments on the Coconino NF authorized managing 

acres for an open reference condition ( up to 90 percent open) and clarified how (and where) 

canopy cover would be measured. 

Some commenters stated the plan amendments are significant because the Forests are including 

identical plan amendments in similar vegetation projects; therefore, providing direction that must 

be followed by other projects. Some commenters asked for examples of other projects with 

nonsignificant plan amendments. Some commenters suggested wording to improve clarity.

Response: In the DEIS, amendments for both the Coconino NF and Kaibab NF were analyzed 

and determined to be site-specific, nonsignificant forest plan amendments (DEIS, pp. 439-564). . 

The significance of each amendment was evaluated in accordance with FSH 1926.51 and FSH 

1926.52(DEIS appendix B). This topic was added to chapter 1 in the FEIS as a procedural 

concern. 

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1000 Coconino and Kaibab National Forests 
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In response to comments on the DEIS, an alternative that proposes no forest plan amendments for 

the Coconino NF (alternative E) was developed. The purpose of the alternative is to allow the 

public another way to compare and contrast environmental consequences between alternatives. It 

also (partially) responds to the significance topic. In alternative E, treatments in Mexican spotted 

owl PAC habitat would be restricted to 9 inch d.b.h. (current Coconino NF forest plan direction). 

The basal area in threshold habitat would remain 150. There would be no prescribed fire use in 

Mexican spotted owl PAC core areas. In goshawk habitat, there would be no savanna treatments 

and there would be no clarification language that describes the relationship between interspaces 

and canopy closure. 

Since the DEIS was issued in 2012, a revised Kaibab NF Forest Plan became effective (USDA FS 

2014). All forest plan amendments for the Kaibab NF have been removed from the FEIS because 

the alternatives are consistent with the revised Kaibab NF forest plan. The project’s desired 

conditions for ponderosa pine were based on the best available science for the restoration of 

southwestern fire-adapted ecosystems (Reynolds et al. 2013). These desired conditions informed 

the Kaibab NF’s plan revision process. The amendments for Mexican spotted owl were removed 

because the project is consistent with the forest plan in that a guideline for threatened, endangered 

and sensitive species directs projects to integrate management objectives and protection measures 

from approved recovery plans (KNF forest plan, p. 51).With design features and mitigation, 

alternatives B through E are consistent with forest plan objectives, desired conditions, standards 

and guidelines, although movement towards desired conditions varies by alternative. Kaibab NF 

forest plan consistency evaluations are located in each resource report. A consolidated evaluation 

is in the project record. 

Three nonsignificant amendments for the Coconino NF were evaluated in the FEIS. The proposed 

forest plan amendments are authorized via 36 CFR 219, the Forest Service Planning Rule. Section 

219.17(b)(3) of the Rule provides the transition language that allows this project to propose 

amendments to the Coconino NF forest plan using the provisions of the 1982 Planning Rule. All 

amendments are a specific, one-time variance for the Coconino NF restoration project. Once the 

project is complete, current forest plan direction would apply to the project area. The language 

proposed does not apply to any other forest project. 

The purpose of amendment 1 is to bring the alternative in alignment with the revised Mexican 

spotted owl Recovery Plan (USDI FWS 2012) and defer monitoring to the FWS biological 

opinion that is specific to this project. Amendment 2 clarifies existing direction related to 

managing canopy cover and interspace in the forest plan. The purpose of amendment is to bring 

the project into alignment with the best available science (Reynolds et al. 2013) that provides 

desired conditions for restoring fire-adapted ponderosa pine in the Southwest. Amendment 3 

resolves a forest plan error related to the management of heritage resources and is specific to this 

project. The detailed significance analysis for each amendment is located in appendix B of the 

FEIS.

Amendments 1 through 3 were evaluated in accordance with the significance amendment criteria 

in FSM 1926.51 and FSM 1926.52. The significance analysis for each amendment included in the 

selected alternative is displayed in this appendix.

No amendment alters multiple use forest plan goals and objectives, adjusts management area 

boundaries or management prescriptions. The changes in standards and guidelines are considered 

to be minor because they reflect the latest, best available science (Reynolds et al. 2013). The 

amendments bring the alternatives into alignment with the revised Mexican spotted owl Recovery 

Plan, although the degree of alignment varies by alternative. No amendment would alter the longFinal Environmental Impact Statement for the Four-Forest Restoration Initiative

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term relationship between levels of multiple-use goods and services originally projected for the 

Coconino NF. These outputs were specific to a planning period ranging from 10 to 15 years (as 

identified in 1987). In the preferred alternative (alternative C): 

• Amendment 1: The amendment would affect 6,906 acres or 18 percent of Mexican 

spotted owl PAC habitat on the Coconino NF. 

• Amendment 2 is clarification amendment. The canopy cover portion of the amendment 

would generally affect 137,242 acres (15 percent) of all goshawk habitats on the 

Coconino NF. Managing 28,653 acres of ponderosa pine for an open reference condition 

would affect approximately 3 percent of all suitable goshawk habitats on the Forest.

• Amendment 3 is specific to the 355,707 acres of proposed treatments in this project. The 

amendment would affect about 20 percent of the Coconino NF (which totals 1,821,495 

acres).

For these reasons, the amendments would not result in an important effect to the entire land 

management planning area. Each amendment is a specific, one-time variance for this restoration 

project. The best available science for management in Southwestern forests ( Reynolds et al.

2013), the (Coconino NF) forest plan revision process, is affecting ongoing and future analyses. 

The plan amendments that are specific to this project do not impose direction on ongoing or 

future analyses. 

Some commenters stated the project amendments would impose direction for other ongoing and 

future vegetation projects. We reviewed the list of vegetation projects that were included in 

comments on the DEIS. Overall, the forest plan amendments that have been proposed in other 

vegetation projects reflect the ongoing Coconino NF forest plan revision process, using the best 

available scientific information ( Reynolds et al. 2013), and being compliant with the revised 

Mexican spotted owl Recovery Plan (USDI FWS 2012). A complete analysis of other proposed 

forest plan amendments by project is located in the project record. 

In the FEIS, all amendments have been updated to reflect changes in acres (see Changes from 

DEIS to FEIS in chapter 2of the FEIS). 

Topic 2: Project Design, Implementation and the Protection of 

Large Trees and Old Trees

Topic 2-1: Heterogeneity: Approximately 19 comments (CARA 76, 89, 95, 98, 151, 155, 158, 

162, 165, 169, 174, 175, 180, 184 and 196-200) and approximately 56 form letters (CARA 19 – 

form master) asked how the project is designed to contribute to heterogeneity at the landscape 

scale. Features contributing to heterogeneity include old trees, large trees, seedlings/saplings and 

young trees (typically ponderosa pine 2 feet tall to ~8.5 inches d.b.h.), Gambel oak, overall tree 

density, tree group size, tree group density, and openness. The DEIS implementation plan 

(appendix D) addressed design for each of these criteria: Also see topic 2-5 which addresses the 

protection of old and large trees.

Old Trees: The DEIS included specific treatment designs that manage for the sustainability of old 

trees in appendix D (implementation plan) on pages 613-629, 631-637, 639 to 641. Examples of 

treatment design include: “Treatments are designed to manage for old age trees in order to have 

and sustain as much old forest structure as possible across the landscape. Treatments would 

follow the old tree implementation strategy and old trees would not be targeted for cutting. Live 

conifer trees with existing cavities, dead tops, and lightning scars would also be favored for 

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1002 Coconino and Kaibab National Forests 
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retention” (page 627). Page 627 of the plan also states, “Retain all pre-settlement trees and the 

largest post-settlement trees that most closely resemble old trees in size and form as replacement 

trees adjacent to pre-settlement tree evidences at a 1:1 ratio. Some younger trees would also be 

retained to maintain uneven-aged structure. A higher leave tree to evidence ratio may be required 

to maintain the desired tree cover range”. 

Large Trees: The DEIS included specific treatment designs that manage for the sustainability of 

large trees in appendix D (implementation plan) on pages 610, 612-614, 616, 618-620, 622-627, 

629-630, 632 and 634. In response to feedback and comments received on treating less 

aggressively and leaving more large trees, canopy cover would be measured at the stand level on 

about 38,256 acres of goshawk habitat where there is a preponderance of VSS 4, 5 and 6. 

Seedlings/Saplings and Young Trees: The DEIS provided direction on how seedlings/saplings 

and young trees would be managed on pages 616, 620, 629 and 630. For example, the 

implementation plan states on page 616, “Regeneration openings (group selection) account for 10 

to 20 percent of tree groups. The percentage would vary within this range depending on 

depending on current age class distribution. They would average 0.3 to 0.8 acre and would not 

exceed 200 feet wide. In general, regeneration openings would not be larger than 2 acres. 

However, they may extend up to 4 acres in specific areas where ponderosa pine mistletoe 

infections are heavy. They would only be established by removing groups of trees comprised of 

the most abundant tree size classes. Regeneration openings would be created adjacent to tree 

groups and would not be surrounded by interspace”. 

Gambel Oak: The DEIS included specific treatment designs that manage for the sustainability of 

Gambel oak in appendix D (implementation plan) on pages 610-611, 613-614, and 616-617. 

Pages 611 and 613-614 state, “Gambel oak, juniper, and pinyon species will not be cut as part of 

the treatments. These species may only be cut when there is no other option to facilitate logging 

operations (skid trails and landings)”. Pages 620, 622-623, 625-627, 631, 633, 635, 636, and 639 

address managing for the sustainability of large oaks by removing ladder fuels and overtopping 

trees. 

Overall Tree Density is addressed in the DEIS (appendix D, implementation plan) on pages 610, 

612, 614, 615, 618, 621, 623, 625, 628, 631, 633 and 636. For example, the language on page 610 

states, “Manage for 150 square feet of basal area where present or to attain 150 square feet of 

basal area in areas with site potential capable of sustaining high tree density in alternative B and

D. In alternative C, manage for a minimum of 110 square feet of basal area where present or to 

attain 150 square feet of basal area in areas with site potential capable of sustaining high tree 

density”. 

Tree Group Size is addressed in the DEIS (appendix D, implementation plan) on pages 616, 619, 

622, 624, 629, 632, and 634. For example, language on page 616 states, “Tree groups, on average, 

would range in size from 0.1 to 1 acre with northerly aspects and highly productive microsites 

having larger average group sizes. Overall, average group size would vary within this range 

depending on site quality, existing stand structure, and pre-settlement tree evidence”...

Tree Group Density is addressed in the DEIS (appendix D, implementation plan) on pages 619, 

624, 626, 629, 632, 634 and 636. For example, the language on page 619 states, “Tree group 

density would be managed to meet the canopy cover requirement of 40 plus percent within midaged forest (VSS4), mature forest (VSS5), and old forest (VSS6) tree groups and to assure that 

immature tree groups (VSS 2 and 3) are managed to maintain tree stocking necessary to provide 

for desired canopy cover as the groups mature to VSS 4, 5, and 6. By following the stocking 

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guidelines and maintaining interlocking or nearly interlocking tree crowns, tree group density 

would meet and exceed the canopy cover requirements. Stocking guidelines for tree groups for 

the WUI55, UEA40, UEA25, and UEA10 mechanical thin treatments are as described in table 

119”. 

Openness is addressed in the DEIS (appendix D, implementation plan) on pages 610, 613-614, 

616, 620-624, 627, 629 and 632-635. For example, page 616 states, “Interspace would occupy 

approximately 25 to 40 percent of the area; Interspace width between tree groups would average 

from 25 feet to 60 feet with a maximum width of 200 feet”. Table 118 on page 618 displays the 

percent of area occupied by interspace ranges from 10-70 depending on treatment type and 

intensity.

In the FEIS, additional analysis conclusions have been included for heterogeneity. For example, 

in the summary comparison of alternatives table (FEIS chapter 2), a heterogeneity category has 

been included. Metrics including percent openness or interspace (at landscape and habitat type 

sub-scale) and spatial arrangement have been used to describe the post-treatment condition. Also 

see the silviculture report. 

Topic 2-3: Alternative C Research Proposal (Paired Watershed Study): Two comments (Cara 

98 and 162) recommended refinement of the research proposals included in the DEIS in 

Alternative C and to identify water yield as a primary objective. 

Response: While treatments were not designed solely to benefit water yield, the DEIS evaluated 

the potential for changes in water yield from treatments, see table 31 and pages 111 to 115. Page 

45 (paragraph 3 and 4) of the water quality specialist report evaluates the cumulative differences 

on water yield between no action (alternative A) and Alternative C. Pages 46 and 47 of the report 

discuss potential change to water yield associated with prescribed fire. The FEIS evaluates water 

yield differences by alternative. Recommendations on finalizing the treatments and clearly 

identifying control watersheds were incorporated into the FEIS. In addition, the title of the 

proposed activity was changed to paired watershed study to clarify the purpose of the study is not 

simply to assess water yield but to also assess how landscape-scale treatments affect watersheds.

Topic 2-4: Monitoring and Adaptive Management: Approximately 22 letters (CARA 76, 89, 

98, 107, 115, 133, 137, 151, 155, 162, 163, 164, 169, 172, 175, 180, 184 and 196-200 ) and 

approximately 56 form letters (CARA 19 – master form) were received on the monitoring and 

adaptive management plan that was included as appendix E in the DEIS. The comments stated the 

monitoring plan included in the DEIS was incomplete and lacked trigger points for monitoring 

goshawk. Some commenters stated it was unclear whether Mexican spotted owl monitoring 

would occur and range-wide Mexican spotted owl monitoring was recommended.

Response: At the time the DEIS was released, formal consultation with FWS (which resulted in a 

biological opinion) had not been initiated. The FWS signed the biological opinion (AESO/SE 

22140 -2011-F-014) for the project on October 20, 2014. Since the DEIS was published, the 

Forest Service worked with stakeholders and finalized the Adaptive Management, Biophysical 

and Socioeconomic Monitoring Plan (appendix E); and, a multi-party monitoring board was 

created to manage and guide monitoring through project implementation.

Appendix E of the FEIS includes goshawk monitoring. A monitoring protocol for Mexican 

spotted owl was developed by the FWS in collaboration with the Forest Service during the formal 

consultation process. The protocol includes monitoring breeding pair occupancy reproductive 

output, and key habitat components across multiple pairs of treatment and reference PACs and 

also across different treatment types. The data that results from implementing this monitoring 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1004 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

protocol will help provide important information about the effects of restoration treatments on 

Mexican spotted owl and will be used to inform adaptive management. A description of these 

protocols is included in appendix E. 

Conducting range-wide monitoring for Mexican spotted owl was considered beyond the scope of 

this project. Population monitoring at a biologically meaningful scale requires large landscapes 

that include multiple states and jurisdictions. An undertaking of this scale has been initiated by 

the USFS Regional Office in cooperation with the Rocky Mountain Bird Observatory. In addition 

to Mexican spotted owl monitoring, appendix E now incorporates monitoring for Arizona 

bugbane. 

Topic 2-5: Old and Large Tree Protection: Approximately 19 comments (CARA 76, 89, 95, 98, 

151, 155, 158, 162, 165, 169, 174, 175, 180, 184, and 196-200) and approximately 56 form letters 

(CARA 19 – form master) stated it was unclear how old and large trees would be protected. 

Comments indicated the proposed actions did not adequately protect old trees and promote large 

trees. Also see topic 2-1 (heterogeneity). 

Response: The DEIS included specific treatment designs that manage for the sustainability of old 

trees in appendix D (implementation plan) on pages 613-629, 631-637, 639 to 641. Examples of 

treatment design include: “Treatments are designed to manage for old age trees in order to have 

and sustain as much old forest structure as possible across the landscape. Treatments would 

follow the old tree implementation strategy and old trees would not be targeted for cutting. Live 

conifer trees with existing cavities, dead tops, and lightning scars would also be favored for 

retention” (page 627). Page 627 of the plan also states, “Retain all pre-settlement trees and the 

largest post-settlement trees that most closely resemble old trees in size and form as replacement 

trees adjacent to pre-settlement tree evidences at a 1:1 ratio. Some younger trees would also be 

retained to maintain uneven-aged structure. A higher leave tree to evidence ratio may be required 

to maintain the desired tree cover range”. 

The vegetation analysis disclosed post treatment impacts to old and large trees on pages 140 of 

the DEIS: “Restoration treatments proposed in alternatives B, C, and D are designed to manage 

for old age trees in order to have and sustain as much old forest structure as possible across the 

landscape. Old trees would not be targeted for cutting. Reference the old tree implementation plan 

in appendix D of the DEIS. The analysis presented for Mexican spotted owl indicates the posttreatment distribution of size classes has good representation in the 18- to 24 inches size classes 

in all habitats. Stocking in the 24 inches plus size class would have good representation in the 

restricted other habitat and would be underrepresented in the target/threshold habitat. The 

goshawk analysis indicates that mature and old forest structural stages that are currently 

underrepresented would trend toward improved representation in all habitats. Treatments within 

areas currently allocated old growth would maintain existing old growth structural attributes and 

would be managed to move toward those conditions over time. The ponderosa pine old growth 

analysis above indicates old growth structural attributes would continue to develop and improve 

across the landscape. The forest health discussion presents that the overall sustainability of the 

ponderosa pine forest would be improved across the landscape including the large/old tree 

component”. 

In response to comments on the DEIS, the purpose and need in chapter 1 was edited to include 

more language on Collaborative Forest Landscape Restoration Act requirements (a focus on 

smaller diameter trees) and a large tree desired condition section. The implementation plan 

(appendix D) was updated to add consistency checks to the Collaborative Forest Landscape 

Restoration Act (CFLRA). See the annual implementation checklist and NEPA, NFMA, ESA and 

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Coconino and Kaibab National Forests 1005
Appendix I – Summary of Response to Comments on the DEIS

CFLRA compliance evaluation tables. Additional design features were added to clarify when

large, young trees would be cut. An example of the language can be found in the goshawk LOPFA 

WUI55, UEA 40, UEA 25 and UEA 10 section. 

In response to feedback and comments received on treating less aggressively and leaving more 

large trees, canopy cover will be measured at the stand level on about 38,256 acres of goshawk 

habitat where there is a preponderance of VSS 4, 5 and 6. 

Topic 2-6: Group Size, Regeneration Openings and Post-Treatment Openness (also see 

Heterogeneity): Approximately 18 letters (CARA 76, 89, 95, 113, 133, 151, 155, 162, 169, 172, 

174, 180, 184, and 196-201) and approximately 56 form letters (CARA 19 – form master) 

included comments on this topic. Some commenters questioned creating regeneration openings in 

ponderosa pine forests. Some commenters stated (this action) is not supported because there is 

little evidence that this pattern exists in historic reconstructions. Some commenters were 

concerned that regeneration openings would remove young, large trees that should be retained. 

Clarification on how regeneration groups would be designed (and from what age and size class) 

was requested. Conversely, some commenters were concerned that the post treatment group 

density would be too high as a result of having regeneration opening treatments that are too 

conservative (and will result in an excess of small trees). In this scenario, movement towards 

stakeholder desired conditions may not be achieved. Some recommendations included adding a 

proportion of different tree group sizes for each treatment type so that it is clear how much 

heterogeneity there will be in tree group sizes. Some recommendations asked the FS to provide 

more detail on the impacts associated with not being able to create regeneration openings, and 

define the point at which movement towards desired conditions is not achieved. 

Response: The implementation plan (DEIS Appendix D) included a variety of designs that utilize 

a “read the land” approach. For example pages 616, 619, 622, 624, 629, 632, and 634 addressed 

design. Overall, the average group size would vary depending on site quality, existing stand 

structure, and pre-settlement tree evidence. Table 139 includes guidance on the placement of tree 

groups, interspace, and regeneration openings. The placement would vary depending on existing 

conditions. Along with the design, table 140 (DEIS page 654) emphasizes that interspace, 

regeneration openings, tree group density, and overall density need to be considered together as 

opposed to individual entities in order to achieve the desired conditions. This concept is further 

highlighted in figure 74 (DEIS, page 657) by disclosing the confines at which tree group stocking 

can be managed in order to achieve a sustainable and resilient forest. For treatments that prescribe 

interspace and regeneration openings, adjustments to interspace width (and therefore tree group 

size), and the amount of regeneration openings, may be made during implementation to ensure 

tree group density remains outside of the “red zone” density. 

Group stocking in VSS 4, 5, 6 in goshawk habitat is designed to meet forest plan canopy cover 

requirements (Coconino NF forest plan) and desired conditions (Kaibab NF forest plan). The 

amount of regeneration openings that would be implemented is a combination of existing and 

created regeneration openings that would achieve 10 to 20 percent of the landscape within a 

treatment area. If there is regeneration on the landscape (existing condition) it would be 

accounted for and site specific treatments would not be designed to create regeneration. What is 

existing on the site would dictate the treatment. The stocking guide includes a red zone for the 

purpose of displaying how the prescriptions would not allow for remaining in or moving into the 

red zone. For example, 20 percent would be the maximum in the red zone. The project would 

manage for 10 percent of that. We would adjust the regeneration rate to keep out of the red zone. 

We would manage for less regeneration openings based on what is on the ground. There may be 

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1006 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

some sites where regeneration openings would not be put in because it would put us into the red 

zone stocking. This would be determined on site. 

In response to comments on the DEIS, additional clarifications regarding the creation of 

regeneration openings have been made. The implementation plan now emphasizes that when 

outside of the wildland urban interface (WUI) restoration treatments in goshawk habitat would 

focus on the removal of small diameter trees and would emphasize large trees retention to move 

towards deficit stand structure, were applicable. This would be accomplished by placing an 

emphasis on creating regeneration openings and interspace in areas where vegetation structural 

class 3 and the smaller VSS 4 trees dominate. The placement of tree groups reserved for retention 

would focus on areas where the largest trees are already aggregated. These groups would 

generally range between 0.25 and 1 acre in size. This would result in stands being composed of 

larger tree groups intermixed with relatively small openings. In stands with a preponderance of 

large young trees the treatment intensity would be managed to the lower end of the available 

spectrum. Management in these stands still recognizes the need to create regeneration openings to 

be able to promote uneven aged stand conditions. The FEIS includes analysis which displays the 

effects on restoration objectives when adequate interspace and regeneration openings cannot be 

created (alternative E). This analysis is derived from the silviculture report. 

Topic 2-7: Sequencing (prioritization) of Mechanical and Prescribed Fire Treatments: 

Approximately 21 commenters (CARA 76, 89, 95,133, 151, 155, 158, 162, 163, 164, 165, 172, 

174, 180, 184 and 196-201) recommended the environmental analysis address the sequencing of 

mechanical and prescribed fire treatments. Commenters stated sequencing would assure that those 

areas that are at most risk from high severity wildfire (or in most need of treatment) being 

prioritized and treated first. 

Response: This recommendation was categorized as outside the scope of this analysis. The 

disclosure of sequencing within a NEPA document would be problematic because it would bind 

the Agency to a fixed schedule that may be unattainable due to weather, fires, markets, or other 

unforeseen circumstances. It would likely result in inaccurate assumptions being used to analyze 

the environmental consequences for all resources. Although the FEIS does not address 

implementation sequencing, the operations component of 4FRI will continue working with 

stakeholders in the spirit of implementing the requirements of the CFLR Act. A 10-year 

operational plan will be developed. This recommendation is most appropriately addressed in 

implementation and operations.

Topic 2-8: Strategic Placement of Treatments: Approximately 23 commenters (CARA 76, 89, 

95, 107, 115, 133, 137, 151, 155, 158, 162, 163, 164, 165, 172, 174, 180, 184 and 196-201) stated 

treatments should be strategically placed to promote fire use for resource benefits and increase 

effectiveness of fire suppression. 

Response: This recommendation was categorized as being outside the scope of the analysis and 

not in alignment with the purpose and need for the project. Treating only strategic locations is a 

strategy used for hazardous fuels treatments when the primary objective is to modify fire behavior 

and to reduce high severity fire effects. In ponderosa pine, there is an overlap between hazardous 

fuel treatments and restoration treatments because restoring ponderosa pine forests generally 

results in reducing the severity of potential fire effects. Fuel treatments can include such 

strategies as thinning from below or leaving a minimum distance between tree crowns or boles. 

Neither of these would put a ponderosa pine forest on a trajectory towards health and resilience. 

The treatments displayed in the DEIS (alternative C, preferred alternative) and FEIS are designed 

to put the landscape on a trajectory towards the desired condition by treating the entire landscape, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 1007
Appendix I – Summary of Response to Comments on the DEIS

not just ‘strategically’ placed treatments. Additionally, on a landscape the size of the 4FRI, it 

would be a gamble to guess where a fire might start, and the variables would be too numerous to 

make such an assessment valid. 

Topic 2-9: Unplanned Ignitions: Approximately 9 commenters (CARA 107, 115, 137, 180, and 

196-201) suggested the analysis needed to evaluate and plan for spatially explicit unplanned 

ignitions. 

Response: This recommendation was categorized as outside the scope of the analysis. The only 

discussion of the management of unplanned ignitions relates to how 4FRI treatments would be 

expected to increase decision space for line officers when they are considering how to manage 

unplanned ignitions. Page 129 of the fire ecology report (for the DEIS) states, “Decision space for 

managing unplanned ignitions would expand as 4FRI (and other projects) are implemented”. 

Management of unplanned ignitions is also mentioned on pages 158 and 188 of the DEIS. 

Topic 2-10: Evidence-Based Full Restoration and Movement towards the Natural Range of 

Variability: Approximately three commenters (CARA letter 98, 165, and 177) stated designing 

treatments based on the goshawk guidelines (forest plan) is not ecologically-based restoration. 

Without developing an evidence-based, full restoration analysis, there is no way to adequately 

compare the tradeoffs between: a restoration alternative that replicates the historic range of 

variability (HRV, referred to as the natural range of variability (or variation) in this analysis) and 

restores forests to pre-fire exclusion conditions, or an analysis that is designed to address 

restoration and issues associated with forest openness, closed canopy species, and canopy 

cover/closure. Science that supports ecological restoration includes (but is not limited to) 

Woolsey (1911), Cooper (1960), White (1985), Pearson (1950), Covington et a1. (1997), and 

Abella and Denton (2009). 

Response: An evidence-based full restoration alternative was considered but eliminated from 

detailed study (FEIS, chapter 2). Only a summary of the rationale is provided here. See the FEIS 

chapter 2 and the project record for additional details. 

Mexican spotted owl habitat: The evidence-based full restoration alternative would adversely 

affect the quality and quantity of 100 percent (35,262 acres) of Mexican spotted owl protected 

habitat. This alternative would not be compliant with the Coconino NF forest plan or the revised 

Mexican spotted owl Recovery Plan. Because the alternative is not compliant with the revised 

Mexican spotted owl Recovery Plan, it would not be compliant with the Kaibab NF forest plan 

(USDA FS 2014). The full restoration alternative is not consistent with the purpose and need for 

the project. 

In target and threshold habitat, forest resiliency and the understory grass/forb/shrub matrix would 

be improved. However, the low basal area would delay or prevent the development of 8,692 acres 

of future nesting and roosting habitat. This would limit recovery potential. The full restoration 

alternative would move the species further away from recovery objectives. The full restoration 

alternative would not be compliant with the Coconino National forest plan or the revised Mexican 

spotted owl Recovery Plan. Because it is not compliant with the revised Mexican spotted owl 

Recovery Plan, it would not be compliant with the Kaibab Land and Resource Management Plan. 

In Mexican spotted owl restricted other habitat, due to the low basal area, the full restoration 

alternative is likely to decrease the quantity and quality of owl habitat even though the basal area 

averages are similar because there would be a substantial decrease in oak in the full restoration 

alternative. Reducing oak would not be in alignment with the purpose and need to maintain and 

promote oak for several species of wildlife in general including Mexican spotted owl (DEIS, 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1008 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

pages 19, 616-617). Actions that reduce the quality and quantity of the habitat are not consistent 

with recovery objectives. The full restoration alternative would provide the most understory 

response (benefit to Mexican spotted owl prey species) and increase the resiliency of the habitat 

the most to stochastic events such as bark beetle outbreak and climate-influenced changes. 

However, due to the post treatment basal area and actions that reduce oak, the full restoration 

alternative would not be consistent with the forest plans or the revised Mexican spotted owl 

Recovery Plan.

Goshawk Habitat: In goshawk post-fledging family areas nest areas, the lower percent max 

stand density index range in the full restoration alternative would increase resiliency to natural 

disturbances. However, approximately 75 percent of nest habitat would be compromised by 

converting the forested environment to an open landscape interspersed with individual trees or 

tree groups. Although goshawk habitat use is variable across its range, goshawk consistently seek 

larger trees and higher canopy cover for nesting. The reduction in coarse woody debris (CWD) 

that would be expected with full restoration would not be in alignment with forest plan desired 

conditions for managing coarse woody debris between 3 to 10 tons per acre on the Kaibab NF 

and 5 to 7 tons per acre on the Coconino NF. The full restoration alternative would reverse the 

upward trend found in alternative B to a range of 0.6 to 0.8 snags greater than 18 per acre. The 

downward trend would not be in alignment with desired conditions. 

In goshawk dispersal post-fledging family areas / post-fledging family areas, the lower percent 

max stand density index range in the full restoration alternative would increase resiliency to 

natural disturbances. However, approximately 68 percent of dispersal post-fledging family areas / 

post-fledging family areas would be compromised by converting the forested environment to an 

open landscape interspersed with individual trees or tree groups. Although goshawk habitat use is 

variable across its range, goshawk consistently seek larger trees and higher canopy cover for 

nesting. The downward trend that would be expected with full restoration in coarse woody debris 

would not be in alignment with forest plan desired conditions for managing coarse woody debris 

between 3 to 10 tons per acre on the Kaibab NF and between 5 and 7 tons per acre on the 

Coconino NF. The full restoration alternative would result in less movement towards desired 

conditions for large snags, prolonging poorer habitat conditions. 

Topic 2-11: Incorporation of the original Large Tree Retention Strategy: Approximately 17 

comments (CARA 76, 89, 95, 133, 158, 163, 164, 174, and 184 [eastern Counties including 

Apache, Graham, Greenlee, Navajo and Gila], 172, 180, 196-201) stated that incorporating a 

modified large tree retention strategy did not meet the intent of what the 4FRI stakeholders had 

provided. Large, young trees and old trees would not be protected and regeneration openings 

would be developed “on the back” of large, young trees that should be retained. The 4FRI 

stakeholders (CARA 155) stated, “Some stakeholders felt strongly that the USFS did not meet the 

intent of the OGP & LTRS in all areas, while other felt that the Old Tree and Modified Large Tree 

implementation plans included in the DEIS reflected the substance and intent of the stakeholder 

document and were otherwise sufficient. Consequently, the stakeholder group does not have a 

100 percent consensus statement regarding incorporation of the OGP and LTRS into the 

DEIS”. (pp. 13-14). Approximately 66 (Sierra Club) form letters (CARA 19 – master form) stated 

the large tree retention strategy should be made integral to the proposed action. Also see Topic 2-

5. 

Response: The conservation of large trees was identified as issue 2 in the DEIS. In addition to 

evaluating the issue of large trees, an alternative that addresses the large tree retention strategy 

was considered but eliminated from detailed study (DEIS, pp. 56 to 58). Since the topic of 

retaining large trees has (in the past) implied the need for a d.b.h. cutting diameter limit, the DEIS 

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Coconino and Kaibab National Forests 1009
Appendix I – Summary of Response to Comments on the DEIS

includes an alternative considered but eliminated that would limit mechanical treatments to 16 

inches d.b.h. as a means to protect large trees (DEIS, pp. 58-61). 

The DEIS included a process (appendix D) that addressed large tree retention during project 

implementation. The large tree implementation plan (LTIP) provides guidance on how to 

conserve and promote large (young) trees in order to increase age classes that are underrepresented (while moving towards the desired condition of having uneven-aged forest 

conditions). 

In response to comments on the DEIS, the implementation plan now emphasizes that when 

outside of the wildland urban interface (WUI) restoration treatments in goshawk habitat would 

focus on the removal of small diameter trees and would emphasize large trees retention to move 

towards deficit stand structure, where applicable. This would be accomplished by placing an 

emphasis on creating regeneration openings and interspace in areas where vegetation structural 

class 3 and the smaller VSS 4 trees dominate. The placement of tree groups reserved for retention 

would focus on areas where the largest trees are already aggregated. These groups would 

generally range between 0.25 and 1 acre in size. This would result in stands being composed of 

larger tree groups of larger trees intermixed with relatively small openings. In stands with a 

preponderance of large young trees the treatment intensity would be managed to the lower end of 

the available spectrum. Management in these stands still recognizes the need to create 

regeneration openings to be able to promote uneven aged stand conditions. 

In addition, in response to questions raised and comments made on the DEIS about treating less 

aggressively and leaving more large trees, canopy cover would be measured at the stand level on 

about 38,256 acres where there is a preponderance of VSS 4, 5 and 6. 

Topic 2-5: Old and Large Tree Protection: Approximately 19 comments (CARA 76, 89, 95, 98, 

151, 155, 158, 162, 165, 169, 174, 175, 180, 184, and 196-200) and approximately 56 form letters 

(CARA 19 – form master) stated it was unclear how old and large trees would be protected. 

Comments indicated the proposed actions did not adequately protect old trees and promote large 

trees. Also see topic 2-1 (heterogeneity). 

Response: The DEIS included specific treatment designs that manage for the sustainability of old 

trees in appendix D (implementation plan) on pages 613-629, 631-637, 639 to 641. Examples of 

treatment design include: “Treatments are designed to manage for old age trees in order to have 

and sustain as much old forest structure as possible across the landscape. Treatments would 

follow the old tree implementation strategy and old trees would not be targeted for cutting. Live 

conifer trees with existing cavities, dead tops, and lightning scars would also be favored for 

retention” (page 627). Page 627 of the plan also states, “Retain all pre-settlement trees and the 

largest post-settlement trees that most closely resemble old trees in size and form as replacement 

trees adjacent to pre-settlement tree evidences at a 1:1 ratio. Some younger trees would also be 

retained to maintain uneven-aged structure. A higher leave tree to evidence ratio may be required 

to maintain the desired tree cover range” . 

The vegetation analysis disclosed post treatment impacts to old and large trees on pages 140 of 

the DEIS: “Restoration treatments proposed in alternatives B, C , and D are designed to manage 

for old age trees in order to have and sustain as much old forest structure as possible across the 

landscape. Old trees would not be targeted for cutting. Reference the old tree implementation plan 

in appendix D of the DEIS. The analysis presented for Mexican spotted owl indicates the posttreatment distribution of size classes has good representation in the 18- to 24-inch size classes in 

all habitats. Stocking in the 24-inch plus size class would have good representation in the 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1010 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

restricted other habitat and would be underrepresented in the target/threshold habitat. The 

goshawk analysis indicates that mature and old forest structural stages that are currently 

underrepresented would trend toward improved representation in all habitats. Treatments within 

areas currently allocated old growth would maintain existing old growth structural attributes and 

would be managed to move toward those conditions over time. The ponderosa pine old growth 

analysis above indicates old growth structural attributes would continue to develop and improve 

across the landscape. The forest health discussion presents that the overall sustainability of the 

ponderosa pine forest would be improved across the landscape including the large/old tree 

component”. 

In response to comments on the DEIS, the purpose and need in chapter 1 was edited to include 

more language on CFLRA requirements (a focus on smaller diameter trees) and a large tree 

desired condition section. The implementation plan (appendix D) was updated to add consistency 

checks to CFLRA. See the annual implementation checklist and NEPA, NFMA, ESA and CFLRA 

Act compliance evaluation tables. Additional design features were added to clarify when large, 

young trees would be cut. An example of the language can be found in the goshawk landscapes 

outside of goshawk post-fledging areas WUI55, UEA 40, UEA 25 and UEA 10 section. 

In response to feedback and comments received on treating less aggressively and leaving more 

large trees, canopy cover would be measured at the stand level on about 38,256 acres of goshawk 

habitat where there is a preponderance of VSS 4, 5 and 6. 

Topic 3: Herbicide Use and Prescribed Fire Emissions

Topic 3-1: Use of Herbicides: Commenters (CARA 8 with attachments 9a [CARA 220], and 18 

[CARA 223]), 153 and 183) recommended no herbicides be used to treat non-native invasive 

weeds due to the potential effects to human health and biotic resources. Commenters stated the 

DEIS did not adequately address the impacts associated with the use of herbicides. 

Response: This comment was categorized as being already decided by a previous analysis. The 

effects of herbicide use were analyzed and disclosed in the Final Environmental Impact Statement 

for Integrated Treatment of Noxious or Invasive Weeds (2005) for the Kaibab and Coconino NFs. 

The analysis was incorporated into the Coconino NF Forest Plan as Amendment 20. In the 

previous Kaibab NF Forest Plan, the analysis and decision had been incorporated as amendment 

7. This analysis tiers to the noxious weeds FEIS and decision. 

The Noxious or Invasive Weed EIS evaluated the impacts of glyphosate based herbicides and 

proposed restrictions on the use of these chemicals within limited spray zones (buffers around 

human habitation and recreation sites), near water and other critical wildlife habitat areas. 

Restrictions and extra protective measures are outlined in the Appendix B - Design Features, Best 

Management Practices, Required Protection Measures, and Mitigation Measures of the weed EIS. 

BMP B15 (DEIS, page 567) incorporates the weeds mitigation measures (appendix B of the weed 

EIS) in their entirety. The DEIS (page 256) references the incorporation of Appendix B of the 

Weed EIS into Forest Plan Amendments 20 (CNF) and 7 (KNF). In the FEIS, this language has 

been updated to reflect a new Kaibab NF Land and Resource Management Plan (USDA FS 

2014). While the direction provided in the noxious weeds FEIS still provides direction, it is no 

longer incorporated into the forest plan. 

Topic 3-2: Prescribed Fire Emissions: Approximately 22 comments (CARA 6, 11, 18, 22, 83, 

88, 93, 104, 106, 112, 116 - 117, 119, 123,126, 128 – 131, and 159 - 161,) recommended using no 

prescribed fire due to fire-related emissions and concerns related to public health. This issue was 

categorized as key in the DEIS (chapter 1, Issue 1). 

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Coconino and Kaibab National Forests 1011
Appendix I – Summary of Response to Comments on the DEIS

Response: The DEIS included an alternative that would have eliminated the use of prescribed fire 

and utilize other methods (DEIS, Eliminate the Use of Prescribed Fire, p. 54). The alternative was 

considered but eliminated from detailed study because it would not meet various elements of the 

purpose and need (see DEIS, page 54-56). It would be possible to use mechanical treatments to 

move biomass offsite and reduce some surface fuels that would have been burned and produced 

smoke. However, mechanical treatment would not replace the role fire has in improving 

vegetation composition and diversity on: (1) 59,391 acres of existing grasslands, (2) over 56,000 

acres of ponderosa pine with a savanna or grassland reference condition, (3) grassland inclusions 

within 308,000 acres of ponderosa pine forested areas, (4) 5,261 acres of pine-sage, (5) 1,471 

acres of aspen, and (6) thousands of acres where Gambel oak exists within the pine forest. 

Additional rationale on why the alternative was considered but eliminated is located in the DEIS 

at page 56. 

In response to the concern over emissions from prescribed fire, Alternative D was developed. 

Alternative D decreases the acres that would receive prescribed fire by over 60 percent when 

compared to alternative B (proposed action) (DEIS, page v). 

The DEIS describes mitigation and design features that would be used to reduce emissions from 

prescribed fire including:(1) Reducing the emissions produced for a given area treated, (2) 

Redistributing/ diluting the emissions through meteorological scheduling and by coordinating 

with other burners in the airshed. Dilution involves controlling the rate of emissions or scheduling 

for dispersion to assure tolerable concentrations of smoke in designated areas, and (3) Avoidance 

uses meteorological conditions when scheduling burning in order to avoid incursions of wildland 

fire smoke into smoke sensitive areas (DEIS, FE9, page 570). 

Prescribed fire (pile, broadcast, and jackpot burning) would occur in accordance with Arizona 

Department of Environmental Quality (ADEQ) requirements. Coordination with ADEQ would 

take place through the Kaibab and Coconino NF Zone Dispatch Center and the prescribed fire 

Burn Boss (DEIS, FE2, page 568). Emission reduction techniques (ERTs) that are recommended 

by Arizona ADEQ would be utilized when possible to minimize impacts to sensitive receptors 

(including communities) of burn unit(s) (DEIS, FE3, page 568). 

The following emission reduction techniques would be used when practicable to minimize 

impacts to sensitive receptors: pre-burn fuel removal, mechanical processing, increased burning 

frequency, aerial/mass ignition, high moisture in large fuels, rapid mop up, air curtain 

incinerators, burn before greenup, backing fire, maintain fire line intensity, underburn before 

litterfall, isolating fuels, concentrating fuels, mosaic/jackpot burning, moist litter and duff, burn 

before large activity fuels cure, and utilize piles (DEIS, FE8, page 569). In addition to prescribed 

fire, the 4FRI is proposing over 388,000 acres of mechanical treatments (DEIS page 40). On the 

majority of these acres, there would be little slash available for burning which means reduced 

emissions. 

The DEIS (pp. 166-173) and the FEIS (chapter 3) addresses and discloses impacts from 

prescribed fire as required by the Clean Air Act which establishes National Ambient Air Quality 

Standards (NAAQS) for six principal pollutants that pose health hazards: carbon monoxide (CO), 

lead, nitrogen dioxide, particulate matter less than 10 microns in size (PM10), particulate matter 

less than 2.5 microns in size (PM2.5), ozone, and sulfur dioxide. The DEIS at page 169 addresses 

regulatory requirements, “Prescribed fire is implemented only with approved site specific burn 

plans and with smoke management mitigation and approvals. All burning is conducted according 

to ADEQ standards and regulations. These standards include the legal limits to smoke emissions 

from prescribed burns as imposed by Federal and State law. The ADEQ enforces these laws by 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1012 Coconino and Kaibab National Forests 
Appendix I – Summary of Response to Comments on the DEIS

regulating the acres that are treated based on expected air impacts. These regulations ensure that 

effects from all burning meet Clean Air Act requirements. Prescribed fires are initiated under 

conditions that allow managers to meet both control objectives (fire behavior) and resource 

objectives (fire effects, including air quality impacts)”. The information disclosed in the 

environmental consequences of the DEIS and FEIS provide the Responsible Officials and the 

public with sufficient and relevant information to evaluate the potential adverse effects to the 

human environment from prescribed fire per CEQ Sec. 15022.22 (b) 3. The disclosure of impacts 

related to potential emissions from prescribed fire is consistent with CEQ Sec. 1502.22 (b) 4. 

Responses to the DEIS raised the issue of mercury as a potential emission from prescribed fire. In 

the FEIS, the water quality report includes an assessment of the potential for mercury to affect the 

Lake Mary watershed because the Lake Mary total maximum daily loads (TMDL) indicates the 

major source of mercury in the Lake Mary Region (LMR) is atmospheric deposition with some 

mercury originating from natural geologic materials (primarily from former volcanic activity). 

The analysis concludes specific BMPs (see FEIS appendix B) would minimize or mitigate the 

potential for mercury to be mobilized in sediment and delivered to water bodies (Water Quality 

and Riparian Report, pp. 54-55). 

The FEIS fire ecology report includes a discussion on mercury and emissions. Experts at the 

Environmental Protection Agency (Region 9), the Agency’s liaison to the Arizona Department of 

Environmental Quality, and the Agency’s Washington Office were contacted in order to consider 

the best available information. Overall, after reviewing available literature (Selin 2009, Obrist et 

al. 2008, Biswas et al. 2007, Wiedinmyer and Friedli 2007, Friedli et al. 2003) and consulting the 

Environmental Protection Agency (Jason Gerdes, personal communication 3/11/2014) and the 

Agency’s Washington Office Air Quality lead (Peter Lahm, personal communication 3/11/2014) 

and the USFS’s liaison to the Air Quality Division of the Arizona Department of Environmental 

Quality (Ron Sherren, personal communication 3/11/2014). Information available for analyzing 

the potential for mercury emissions as a result of prescribed fire is considered to be incomplete 

and unavailable relevant to determining reasonably foreseeable adverse impacts to the human 

environment as directed by CEQ Sec. 1502.22 (b) 1. 

Topic 4: Wildlife and Its Habitat

Topic 4-1: Adverse Effects to Mexican spotted owl: Approximately 9 commenters (CARA 24, 

107, 137, 180, and 196-200) stated that the level of treatment and acres of treatment within 

Mexican spotted owl habitat was excessive and would result in uncertainty in terms of how 

Mexican spotted owl and its habitat would be affected. Some commenters stated all action 

alternatives (via forest plan amendments) would remove forest plan monitoring requirements to 

the detriment of the species. Some commenters concluded the analysis was not compliant with 

the 2012 (revised) Mexican spotted owl Recovery Plan. 

Response: The DEIS states that treatments in alternative C (preferred alternative), “includes 

recommendations from the U.S. Fish and Wildlife Service (FWS) by increasing prescribed 

burning treatments within protected Mexican spotted owl habitat (to improve the quality of owl 

roosting and nesting habitat), and aligning treatments in threshold habitat with the “Mexican 

Spotted Owl Recovery Plan, First Revision” (USDI FWS 2012) (DEIS, page 47). Alternatives BD included forest plan amendments. In response to comments on the DEIS, an alternative that 

proposes no forest plan amendments was developed (alternative E). In the FEIS, each resource 

discloses the effects associated with omitting plan amendments. 

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Additional analysis has been added to the FEIS. A summary in chapter 2 on the environmental 

consequences for Mexican spotted owl habitat states, “In Mexican spotted owl nesting and 

roosting habitat, there would be no change between alternatives A-E in percent of openness. The 

percent openness (degree of heterogeneity) would remain the same as the existing condition. This 

is because thinning treatments would limit the removal of the overstory structure. In alternative A 

in Mexican spotted owl restricted (all) habitat, the percent of openness would remain the same as 

in the existing condition. Existing interspace would continue to be encroached upon by expanding 

tree crowns and ingrowth. In alternatives B through E there would be little change in the very 

open to open categories”. 

In Mexican spotted owl protected habitat, several of the forest metrics are similar across 

alternatives in 2020 because minimal actions are proposed in PACs. Thinning, (not group 

selection) is proposed in PACs, in part to limit affects to overstory structure The percent of stand 

density index max would decrease in all alternatives as a result of the proposed thinning. PACs 

would still remain in the highest density category (“extremely high density”), although alternative 

C would move the percent of maximum stand density index to the bottom of this category in 

2020, almost achieving a “high density” ranking (high density equals percent maximum stand 

density index of 55 and lower). The potential decrease in crown fire risk is most prominent in 

alternative C, and alternative D makes the least change relative to the no action alternative. 

Implementing two prescribed fires would decrease surface fuel loading and increase canopy base 

height. The reduction in surface fuel loading would decrease the potential surface fire flame 

lengths. The higher canopy base height would mean it would take longer flame lengths to initiate 

crown fire. These two changes decrease the potential of high severity fire effects.

Alternative D is the only (action) alternative where at least 30 percent of the habitat would return 

to fire regime condition class (FRCC) 3, contrary to the purpose and need. A key result of these 

treatments would be increases in the percent of trees 24 inches d.b.h. and greater. Alternatives BD would increase the density of this size-class the most. A similar pattern is evident among 

alternatives for trees in the next largest size-class (18 to 23.9 inches d.b.h.). Growing trees into 

the largest size-classes takes time and creating more large trees would be an important 

contribution to nesting and roosting habitat. Decreasing competition around presettlement trees 

should enhance their survival and overall health and potentially result in more large trees than 

displayed in the model results. Reducing abundant quantities of mid-sized trees and increasing 

areas dominated by large trees should improve Mexican spotted owl nesting and roosting habitat 

(USDI FWS 1995, May and Gutierrez 2002, May et al. 2004, Blakesley et al. 2005). 

The biological assessment for the project was submitted to the FWS in February of 2014. The 

biological assessment concluded long-term effects of the 4FRI should be beneficial to Mexican 

spotted owls by enhancing key habitat components for Mexican spotted owl and their prey. The 

likelihood of maintaining Mexican spotted owl habitat into the future is also enhanced by 

reducing the predicted risks from climate change-induced changes in temperature and 

precipitation patterns. However, there is potential for short-term adverse effects to owls and their 

habitat (Noble 2014). Because of the short-term risks of adverse effects, the project “may affect 

and is likely to adversely affect Mexican spotted owls and their habitat, g critical habitat”, 

(Biological Assessment, pp. 238-239). The FWS biological opinion (AESO/SE 22140-2011-F0145), which was signed by the FWS on October 20 , 2014 affirmed this effects determination. 

The FWS found the selected alternative will not jeopardize the continued existence of the 

Mexican spotted owl, and will not destroy or adversely modify its designated critical habitat 

(USDI FWS 2014, page 33). 

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Appendix I – Summary of Response to Comments on the DEIS

Topic 4-2: Adverse Effects to Northern Goshawk: Approximately 8 commenters (CARA 107, 

137, 180, 196-200) stated that the level of treatment and acres of treatment within goshawk 

habitat was too intense and would result in fragmentation of the habitat and cause a decline in the 

species. 

Response: Post treatment landscape openness in goshawk habitat was presented as issue 3 in the 

DEIS. In the DEIS, the analysis of goshawk habitat components is located on pages 126 to 133 of 

the DEIS. 

In response to comments on the DEIS and to address changes since the DEIS was published, the 

goshawk analysis was revised and additional analysis has been added to the FEIS. A summary in 

chapter 2 on the environmental consequences for goshawk includes the following effects: 

• Alternative A would not improve habitat quality, resiliency and sustainability. In all goshawk 

habitat, no action results in the habitat being at highest risk of increasing densities, increased 

fire risk, and increased to insect and disease risk. These results are contrary to forest structure, 

forest health, and resiliency and function desired conditions. 

• Mechanical treatments in alternatives B, C, and-D would improve age-class diversity and 

move towards more open, uneven-aged conditions. The percent of stand density index max 

would decrease in all action alternatives as a result of the proposed thinning. The percent of 

stand density index max in landscapes outside of goshawk post-fledging areas habitat would 

decrease to the high end of moderate density in alternatives B and C and decrease to high 

density in alternatives D and E in the short term (2020). All action alternatives would shift or 

remain in high density by 2050. Primary benefits from these changes in forest structure are 

that the risks of large scale loss of habitat from disturbances such uncharacteristic fire, bark 

beetles, and density-related mortality would be reduced.

• Trees greater than 24 inches d.b.h. in uneven-aged forest structure would increase as a result 

of these treatments in all alternatives. Alternatives B and C would increase the distribution of 

this size class to 20 percent of the area by 2020 whereas alternative D would increase to 15 

percent, and alternative E would increase to 18 (from an existing distribution of 11 percent). 

In alternative A increases the percent to 13 by 2020. Trees greater than 24 inches d.b.h. in 

even-aged forest structure would increase to 4 percent in alternatives B and C; 3 percent in 

alternative D; 2 percent in alternative E; and not change in alternative A (from an existing 

level of 1 percent). 

• Alternatives D and E would increase the distribution of trees in the next largest size-class (18 

to 23.9 inches d.b.h.) in uneven-aged condition to 28 percent; alternative C would increase 

the distribution to 30 percent and would increase to 29 percent in alternative E. In 

comparison, alternative A decreases the percent in 2020 to 12 percent but increases by 2050 

to 27 percent. In even-aged forest structure, this next largest size class would increase to 22 

percent in alternatives B and C, increase to 19 percent in alternative D and increase to 18 

percent in alternative E, from an existing level of 8 percent. In alternative A, there is an 

increase of 21 percent by 2050. Growing trees into the largest size-classes takes time and 

creating more large trees would be an important contribution to prey and foraging habitat. 

• Substantial increases in the average pounds per acre of understory biomass in all action 

alternatives would improve cover and food for birds and mammals preyed upon by goshawks 

as well as the invertebrates that are an important food source for goshawk prey. Alternatives 

B and C would have the most improvement followed by alternatives E, then D. This would 

also favor conditions conducive to the spread of low severity fire rather than crown fire. 

Crown fire would have more severe effects to vegetation and soil. Prey habitat would 

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improve as coarse woody debris increases to desired conditions by 2050. In the short term, 

tons per acre of coarse woody debris would fall below desired in alternatives B, C, and E. 

Only alternative D would meet desired conditions in the short term (2020). Alternative A, 

since there are not treatments proposed, would be at the highest risk of increasing densities, 

increased fire risk, increases to insect and diseases, and increased risks to goshawk 

landscapes outside of goshawk post-fledging areas habitat.

In response to feedback and comments received on treating less aggressively and leaving more 

large trees, in alternatives C and E canopy cover would be measured at the stand level on about 

38,256 acres of goshawk habitat where there is a preponderance of VSS 4, 5 and 6. 

In the wildlife report that has been prepared for the FEIS, the determination of effect for goshawk 

for the preferred alternative states, “Implementation of alternative C may impact individuals, but 

is not likely to cause a trend to federal listing or loss of viability” (Wildlife Report, page 473, 

FEIS, chapter 3). 

Topic 4-3: Habitat Fragmentation: One commenter (CARA 217 (Opposing View Attachment 4) 

and 224 (Opposing View Attachment 1) stated that road construction, salvage logging, and clearcutting timber operations would fragment the habitat of many wildlife species including 

Ovenbirds, grizzly bears, martens, and fishers, among other species. 

Response: Issues related to salvage logging were considered to be outside the scope of this 

analysis as no salvage is being proposed. The purpose of the project is to reestablish and restore 

forest structure and pattern, forest health, and vegetation composition and diversity (DEIS, page 

9). The wildlife biologist for the project reviewed the comments and literature provided and 

found an unpublished paper that discusses the effects of habitat fragmentation had been 

submitted. The project does not have any prescription that proposes clearcuts. The DEIS 

discusses habitat connectivity for wildlife species on page 174. The complete analysis for bridge 

habitat for canopy-dependent wildlife can be found in appendix G of the DEIS and appendix 3 of 

the wildlife report. The terrestrial wildlife specialist report discloses habitat fragmentation for 

wildlife species in several areas: page 120 for four spotted skippling; page 144, 585 and 592 for 

pronghorn; page 176 discusses climate change and habitat fragmentation; page 194 for the 

Mexican spotted owl; page 375 for nitocris fritillary; page 380 for Navajo Mogollon vole; page 

385 for long-tailed vole; page 386 for the drawf shrew; page 388 for the Merriam’s shrew; page 

521-523, 634, and 674 for effects to understory species. Habitat effects could be similar to those 

that would occur with severe wildfire and could ultimately lead to habitat fragmentation or 

vegetation type conversions (DEIS, chapter 1). A portion of the article discusses buffers. Part of 

the topic description as presented by the commenter implies the paper addresses the specific use 

of clearcutting – which is not relevant to this project.

Topic 5: Soil and Water

Topic 5-1: Clarification and Corrections: Some comments requested clarification on the 

watershed research and suggested clarification or correction language for the FEIS and final 

reports (CARA 98, 151, 155, 162 and 166). 

Response: As requested, the water quality and soils report made corrections (to affected 

watersheds) and revised the language related to the watershed research. The FEIS (chapter 1 and 

2) reflects the recommendations and corrections.

Topic 5-2: Adverse Impacts to soil and water resources: Some comments (approximately 10) 

stated new road construction and ground-based logging may significantly impact soils and water 

quality; therefore, soil and water impacts are a significant issue for the EIS (CARA 180, 196-201, 

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217 and 224). Some opposing views included literature from other geographic locations including 

Michigan and the northwest (CARA 8). Some comments (CARA 8) included (popular not peer 

reviewed) science that suggested the project (timber harvest and road actions) would result in 

high soil erosion due to debris slides. 

Response: The potential impacts to soil and water resources would not result in significant 

environmental effects. Therefore, it was not categorized as a “significant” issue. The project has 

been designed to maintain soil productivity and function and meet the Clean Water Act (routine 

disclosures). 

Chapter 3 of the DEIS disclosed the affected environment for each resource (including roads) and 

the direct/indirect environmental consequences associated with the action alternatives in chapter 

3, from page 105 to page 332 . Effects analysis of roads (transportation) can be found in the DEIS 

on pages 318-321. Table 31, chapter 2, page 96 of the DEIS provides a comparison of the 

predicted effects of proposed treatments by alternative. The best (and relevant) available science, 

information, first-hand knowledge of the resources within the project area and experience with 

past and similar projects informed the effects analysis. 

The DEIS included design features, mitigation measures and the following soil and water BMPs

in appendix C, page 565 of DEIS. These features would be implemented (for temporary road 

construction) to maintain and protect soil productivity, minimize sediment delivery and improve 

and protect water quality. The chapter 3 soil and water analysis (DEIS, table 32) and the soils 

specialist report (pp. 62-92 and attachment 1, page 165) show less than 15 percent soil 

disturbance would occur (including temporary road construction) under all action alternatives. 

The alternatives would not exceed the 15 percent soil disturbance threshold that has been 

identified as maintaining long term soil productivity. 

No new permanent roads would be constructed for this project. Temporary roads would be 

constructed to provide necessary access for forest treatments and decommissioned after use. The 

effects of roads are analyzed and disclosed in chapter 3 of the DEIS. Appendix C provides design 

features, BMPs, and mitigation measures to protect soils and water quality as they relate to roads.

The Riparian and Water Quality Specialist’s Report provides a detailed description of the effects 

of forest roads on page 50 and 62-64. 

In response to comments on the DEIS, a new design feature which addresses activities on soils 

with severe erosion hazard was developed. Design feature SW43 (FEIS appendix C) was 

developed to protect long-term soil productivity and water quality: “Provide soil and site 

protection on newly disturbed soils located on temporary roads on soils with severe erosion 

hazard as needed. Avoid locating temporary roads on soils with severe erosion hazard. Where 

unavoidable, provide soil protection through implementation of any of the following methods to 

control sediment and protect water quality. Methods may include, but are not limited to: wattling, 

hydromulching, straw or woodshred mulching, spread slash, erosion mats, terraces, blankets, 

mats, silt fences, riprapping, tackifiers, soil seals, seeding and side drains, and appropriately 

spaced water bars or water spreading drainage features. Temporary roads would be 

decommissioned and protected with any of the above methods”. A new design feature was 

developed (FEIS, appendix C) to clarify temporary roads would be decommissioned by the 

purchaser/contractor when mechanical treatments are finished using the adaptive management 

actions listed in appendix A of the Transportation Specialist report. 

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Appendix I – Summary of Response to Comments on the DEIS

Soil and site productivity can be negatively affected if protective design features and best 

management practices are not made part of the action. The 4FRI project minimizes vegetation 

treatment impacts to soil and site productivity through implementation of design features, 

mitigation measures and the following soil and water BMPs listed and located in appendix C of 

the DEIS. They have been developed and will be implemented (for timber harvest and fuels 

operations and retention of coarse woody debris) to maintain and protect soil productivity, 

minimize sediment delivery and improve and protect water quality. The chapter 3 soil and water 

analysis (and soils specialist report) shows less than 15 percent soil disturbance (average at the 

watershed level) would occur (including temporary road construction) under all action 

alternatives which is less than 15 percent soil disturbance threshold identified that would maintain 

long term soil productivity. 

Topic 6: Opposing Science

Some comments (CARA 148 and 149) stated the DEIS failed to consider new science for 

Mexican spotted owl and wildland fire and fire regime condition class (FRCC). One comment 

(CARA 8 with attachment 221) stated the DEIS failed to adequately address the latest science 

regarding the sufficiency of only treating in the wildland urban interface. Approximately three 

form letters (Cara 109 is the master form letter) questioned the best available science used to 

evaluate potential impacts from climate change. The complete response to the comments and 

questions on climate-related science is in the fire ecology report in appendix H. The complete 

response to CARA 109 is in the project record. 

Response: Only a summary response is provided here. Each resource evaluated all literature 

submitted as part of comment letters. A complete review of the science is included in the 

individual response report and in the specialist reports. An opposing science discussion by 

resource (as applicable) is presented in chapter 3 of the FEIS. 

A few commenters (CARA 148, 149, 8 with attachments, 183 and 153) cited publications that 

suggest that crown fire was historically much more prevalent in the project area, even in 

ponderosa pine, than is concluded in the DEIS and in the specialists’ reports, in particular the Fire 

Ecology, Silvicultural, and Wildlife Reports (Williams and Baker 2013, Williams and Baker 

2012). One of the assumptions which is used to make this claim is that the science supporting 

frequent, low severity fires, is based on “small, scattered studies”. In fact, the Fire Ecology report 

cites over 25 studies that are specific to the project area, and about 50 additional studies that 

specifically include the rest of Arizona and/or the southwest. Included is a 110 page General 

Technical Report (Dahms and Geils 1997), that completed an assessment of forest ecosystem 

health in the southwest, and an 85 page report by The Nature Conservancy (Smith 2006) on 

historical and current landscape conditions for ponderosa pine in the southwest. The 

preponderance of science does not agree with Williams and Baker, and was soundly refuted by 

Fulé et al. (2013). Fulé et al. (2013) has 18 co-authors, including many of the leading researchers 

of fire ecology in southwestern United States. Reconstructions of dry western U.S. forests in the 

late 19th century in Arizona, Colorado and Oregon based on General Land Office records were 

used by Williams and Baker (2012) to infer past fire regimes that had substantial moderate and 

high-severity burning. They concluded that the patterns of present-day large, high-severity fires 

are not distinguishable from historical patterns. Fulé et al. (2013) presented evidence of important 

errors in their study. First, the use of tree size distributions to reconstruct past fire severity and 

extent is not supported by empirical age–size relationships nor by studies that directly quantified 

disturbance history in these forests. Second, the fire severity classification of Williams and Baker 

(2013) is qualitatively different from most modern classification schemes, and is based on 

different types of data, leading to an inappropriate comparison. Third, while Williams and Baker 

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1018 Coconino and Kaibab National Forests 
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(2013) asserted ‘surprising’ heterogeneity in their reconstructions of stand density and species 

composition, their data are not substantially different from many previous studies which reached 

very different conclusions about subsequent forest and fire behavior changes. Contrary to the 

conclusions of Williams and Baker (2013), the preponderance of scientific evidence indicates that 

conservation of dry forest ecosystems in the western United States and their ecological, social and 

economic value is not consistent with a present-day disturbance regime of large, high severity 

fires, especially under changing climate (Fulé et al. 2013). 

Many papers cited by commenters objecting to mechanical treatments attempted to apply the 

ecology and/or fire regimes of ecosystems other than ponderosa pine (mixed conifer, spruce fir) 

or ponderosa pine in the northwest (Northern California, Oregon, Idaho). Ponderosa pine has 

distinct variations within its geographic range (Oliver and Ryker 1990), and the populations of 

ponderosa pine in northern Arizona have some fundamental genetic differences from pines in 

other areas within the range of Ponderosa species (Conkle and Critchfield 1988). There are 

differences in the openness of crown growth, number of needles, and other characteristics. These 

two populations would not be expected to have identical fire regimes, even if the study was 

restricted to ponderosa pine. 

There were multiple comments from people objecting to ‘fuels treatments’, ‘hazardous fuels 

treatments’, and/or ‘fuels project/s’ (CARA 8, 180). Ecosystem restoration treatments and fuel 

treatments are not synonymous. Some ecosystem restoration treatments reduce fuel hazard, but 

not all fuel treatments restore ecosystems. Ecosystem restoration treatments are often designed to 

recreate presettlement fire regimes, stand structures and species compositions while fuel 

treatment objectives are primarily to reduce fuels to lessen fire behavior or severity—this is 

known as ‘hazard reduction’ (Reinhardt et al. 2008). 

Finney (2001, 2007), and Finney et al. (2007) focused on ‘fuels management’, which is 

appropriately used for managing fire behavior when that is the primary concern. However, 

treating only 20 percent of the landscape, which Finney has shown can be effective in managing 

fire behavior, would not achieve ecosystem restoration on a landscape scale. An analysis that 

focuses on where treatments would best minimize fire behavior, may or may not support 

restoration objectives across the landscape (which include conservation of large and old trees, 

enhancing large oak, enhancing aspen clones, and other treatments). 

Of the 586,110 acres proposed for treatment in this EIS, there are about 535 acres of proposed 

wildland-urban interface (fuels) treatments. All of the 535 are contiguous and are in restoration 

unit6 adjacent to the town of Tusayan. With the exception of these acres, the objectives of this 

EIS are restoration, not hazardous fuels reduction. 

One commenter (Cara 8) made multiple references to the work of Jack Cohen (Cohen 1996-2001, 

2003, 2008) and related papers. Cohen’s research generally addresses concerns about structure 

protection, as evidenced by the titles of the 9 Cohen papers referenced by the commenter: 

• Reducing the Wildland Fire Threat to Homes: Where and How Much (1999) 

• Examination of the Home Destruction in Los Alamos Associated with the Cerro Grande Fire 

(2000) 

• Preventing Disaster – Home Ignitability in the Wildland-Urban Interface (2000)

• What is the Wildland Fire Threat to Homes? (2000) 

• Thoughts on the Wildland-Urban Interface Fire Problem (2003) 

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• The Wildland-Urban Interface Fire Problem: A Consequence of the Fire Exclusion Paradigm 

(2008) 

• Modeling Potential Structure Ignitions from Flame Radiation Exposure with Implications for 

Wildland/Urban Interface Fire Management (1996)

• Structure Ignition Assessment Can Help Reduce Fire Damages in the wildland-urban 

interface (1997) 

• Saving Homes from Wildfires: Regulating the Home Ignition Zone (2001) 

We reviewed all these papers, and found the relevancy in these papers was limited to that portion 

of the 4FRI treatments (~535 acres) that have a fuels/ wildland-urban interface focus, and how 

that treatment would be expected to decrease the intensity of a wildfire approaching a wildlandurban interface area. 

On those ~535 acres where the proposed treatments are actually fuels treatments, the treatments 

proposed align with the suggestions here that ‘fuels treatments’ should focus on creating 

conditions in which fire can occur without devastating consequences, rather than on creating 

conditions conducive to fire suppression. There was no new information or information that could 

otherwise inform the analysis. In summary, treating only wildland-urban interface areas would 

not meet the purpose and need for restoration and the request to create an alternative was 

considered to be beyond the scope of the 4FRI and not reasonable enough to warrant alternative 

development. 

Climate Change: The first contention stated the use of Woods et al. (2012) was not valid because 

the literature was an unpublished report. The final report was issued later in 2013, with no 

changes in conclusions, and the reference has been updated in the final report. Reviews and 

syntheses of multiple research studies have always been a valuable source of information. 

Combining and/or comparing multiple datasets in one document can produce added value 

because the studies can be viewed in context with others, and the combined data sets may 

strengthen or weaken conclusions from the individual studies, and/or produce new conclusions by 

remixed data and conclusions. Woods et al. (2012) took data and results from published studies 

(mostly from northern Arizona) and synthesized a new study to estimate the potential for 

restoration efforts (4FRI in particular) to mitigate the risk of catastrophic wildfire and stabilize 

carbon storage in ponderosa pine forests. The study specifically addressed the area proposed for 

treatment by the 4FRI, so is pertinent. This report is available upon request and is in the project 

record. 

A second contention in the form letter was that Hurteau and North (2009) was not a relevant 

study to the project and the conclusions not consistent with the project analysis because the 4FRI 

DEIS did not consider soil carbon. The commenter found the conclusions and assumptions in this 

paper questionable. However, no specifics were provided that would assist with a response. 

The stated purpose of this study was to “determine if current aboveground forest carbon stocks in 

fire-excluded southwestern ponderosa pine forest are higher than pre-fire exclusion carbon stocks 

reconstructed from 1876, quantify the carbon costs of thinning treatments to reduce high-severity 

wildfire risk, and compare post treatment (thinning and burning) carbon stocks with reconstructed 

1876 carbon stocks.” This study is not cited in the DEIS or in the Fire Ecology report as a 

reference for the idea that ‘burning a forest turns it into a carbon sink’, though it does point out 

that high severity fire can turn a forest into a carbon source. It is cited to support the statement 

(which we agree with) that fire-excluded forests contain more carbon that non-fire excluded 

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forests. It also supports the idea that these forests are at greater risk of high-severity fire than nonfire excluded forests.

The third contention stated Savage and Mast (2005) was cited in the DEIS to support of a 

statement about carbon emissions but the study does not even contain the word “carbon.” The fire 

ecology analysis cited Savage and Mast to describe potential effects from high severity fire. On 

page 251 of the fire ecology report states, “Savage and Mast (2005) showed that these conditions 

can persist for decades”. The integrity of a forest structure and species composition (Savage and 

Mast 2005) is relevant to carbon sequestration and climate change dynamics. 

The fourth contention stated Finkral and Evans (2008) data was not relevant to the 4FRI analysis 

because “Their study area was near Flagstaff, in the region of this project, and they estimated a 

2.8 percent annual risk of fire in the area. This is a 36-year fire rotation, contradicting the 

frequent-fire assumption that the Forest Service is using to justify burning the area every 5 years”. 

Finkral and Evans discuss some of the research that has been done on restoration and carbon 

sequestration, and point out that “...dense forests have become a sink for carbon and an offset to 

the rising concentrations of greenhouse gases in the atmosphere...’, but conclude that in a standreplacing fire, a thinned stand would release 2410 kg C ha_1 less to the atmosphere than an 

untreated stand. However, the thinning treatment resulted in stand structural changes that make 

the stand less likely to support a crown fire and therefore more likely to avoid the carbon releases 

associated with crown fires, even under extreme fire conditions. So the decrease in C released 

would be even lower. The 2.8 percent number includes all the successful suppression efforts over 

the 15 years used to calculate the annual risk (1986 – 2000), and only included fires over 50 

acres. The actual number of ignitions is much greater than that, and forest conditions that support 

high severity/high intensity fire have increased in the 14 years since the (Sisk et al. 2004) study 

was completed. It is unclear where the ‘every 5 years’ number comes from. Regardless of the 

source, fire rotation and ‘every 5 years’ are not the same thing. Fire rotation is the length of time 

necessary for an area equal to the entire area of interest to burn. Fire return interval (implied by 

‘every 5 years’) is the period of time between fires at a given point, or the arithmetic average of 

all fire intervals in a given area over a given time period. The 4FRI analysis does not discuss fire 

rotation, as it is not relevant to the analysis. The preferred average fire return interval in the 

ponderosa pine in the project area is 10 years. This is supported by the preponderance of 

published scientific literature (see Fire Ecology Report pg. 48). 

A final contention related to using Baker 2009 and Campbell 2012 in the context of fuel 

treatments. Regarding Baker (2009), if all else is the same (surface fuel loading, etc.), we agree 

there can be more intense fire in an area that is thinned. The following is from the Fire Ecology 

report (pgs. 28 – 29): “Reducing canopy fuel loading may increase surface fire behavior because 

more wind and sunlight can reach the surface, however overall fire behavior is more significant:

“Modifying canopy fuels as prescribed in this method may lead to increased surface fire intensity 

and spread rate under the same environmental conditions, even if surface fuels are the same 

before and after canopy treatment. Reducing crown bulk density to preclude crown fire leads to 

increases in the wind adjustment factor (the proportion of 20-ft windspeed that reaches midflame 

height). Also, a more open canopy may lead to lower fine dead fuel moisture content. These 

factors increase surface fire intensity and spread rate. Therefore, canopy fuel treatments reduce 

the potential for crown fire at the expense of slightly increased surface fire spread rate and 

intensit. However, critical levels of fire behavior (limit of manual or mechanical control) are less 

likely to be reached in stands treated to withstand crown fires, as all crown fires are 

uncontrollable. Though surface intensity may be increased after treatment, a fire that remains on 

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the surface beneath a timber stand is generally controllable” (Scott 2003). However, following 

prescribed fire, surface fuel loading would be lower, effectively decreasing the potential fire 

intensity.” 

Campbell et al. 2012 evaluated the effects of fuel treatments and wildfire on forest C stocks. With 

the exception of 535 acres of fuel reduction in a wildland-urban interface area, the 4FRI is 

proposing restoration treatments, not fuel treatments. They state: “...removing fine canopy fuels 

(i.e. leaves and twigs) practically necessitates removing the branches and boles to which they are 

attached, conventional fuel-reduction treatments usually remove more C from a forest stand than 

would a wildfire burning in an untreated stand”. The treatments proposed in the 4FRI are not at 

all ‘conventional fuel-reduction’ treatments. They are restoration treatments which are designed 

to produce and/or promote multi-story/multi-age stands.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

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Western Forestry Leadership Coalition. 2010. Lead Author: Dale, Lisa. The True Cost of Wildfire 

in the Western U. S. Lakewood, CO. 

Wiens, J.A. 1989. Spatial scaling in ecology. Functional ecology 3(4):385−397. 

Williams, B.K. 2009. Markov decision processes in natural resources management: Observability 

and uncertainty. Ecological Modelling 220(6):830−840. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1040 Coconino and Kaibab National Forests 
References Cited

Williams, B.K., R.C. Szaro, and C.D. Shapiro. 2009. Adaptive Management: The U.S. 

Department of the Interior technical guide. Adaptive Management Working Group, U.S. 

Department of the Interior, Washington, D.C. 

Wilson, J.L., and B.M. Tkacz. 1996. Historical perspectives on forest insects and pathogens in the 

Southwest: implications for restoration of ponderosa pine and mixed conifer forests. In 

Proceedings of conference on adaptive ecosystem restoration and management: 

Restoration of cordilleran conifer landscapes of North America (pp. 26−31). 

Woodbridge, B., and C. Hargis. 2006. Northern Goshawk Inventory and Monitoring Technical 

Guide. Gen. Tech. Rep. WO-71. U.S. Department of Agriculture, Forest Service. 

Zou, C.B., D.D. Breshears, B.D. Newman, B.P. Wilcox, M.O. Gard, and P.M. Rich. 2008. Soil 

water dynamics under low-versus high-ponderosa pine tree density: Ecohydrological 

functioning and restoration implications. Ecohydrology 1:309–315 

(http://www.interscience.wiley.com) DOI: 10.1002/eco.17. 

Appendix F – Cumulative Effects 

Adams, Judy. 2011. Personal communication with Paula Cote. WAPA Proposal for treating 1,400-

foot KV Corridor within the 4FRI Project Area. October 20, 2011. 

Arizona State Forestry. 2012. Personal communication with Aaron Greene, Assistant Fire 

Management Officer. State and Private Lands Fuels and Vegetation Data for 2011. 

January 9, 2012. 

Brewer, D.G. 2011. Parker 3 Step analysis for 4FRI project area. Manuscript on file at the 

Coconino NF 4FRI Project Record. 

Centennial West Clean Line, LLC. 2011. Project Introduction Sheet: Proposed Centennial West 

Clean Line Transmission Project. October 26, 2011. 7 pp. 

Covington, Wallace. 2003. The Evolutionary and Historical Context for Restoration. In: 

Friederici, P. Ecological Restoration of Southwestern Ponderosa Pine Forests. Arizona: 

Arizona Board of Regents. Page 40. 

Drake, W.M. 1910. A report on the Coconino National Forest. Unpublished report, Coconino 

National Forest, Flagstaff, AZ.

Fairweather, M.L., K. Barton, B. Geils, and M. Manthei. 2008. Aspen Decline on the Coconino 

National Forest. In: McWilliams, M.G. comp. Proceedings of the 55th Western 

International Forest Disease Work Conference; October 15–19, 2007; Sedona, AZ. 

Salem, OR; Oregon Department of Forestry. 

Flagstaff Fire Department. 2012. Foreseeable Fuels Reduction Treatments. Personal 

Communication with Paula Cote, 4FRI. February 24, 2012. 

Fleishman, Richard. 2012. Coconino Timber Sales First EIS Area Late 1960s to Early 1980s. 

Mormon Lake District, Coconino NF Timber Atlas. 

Fleishman, Richard. 2011. Final Revised Shelfstock Acres. April 24, 2011. 1 page. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 1041
References Cited

Fleishman, Richard. 2014. Transportation Specialist’s Report, Four-Forest Restoration Initiative, 

Coconino and Kaibab National Forest. 31 pp. 

Friederici, P. 2004. Establishing reference condition for southwestern ponderosa pine forest. 

Working papers in southwestern ponderosa pine forest restoration. Ecological Restoration 

Institute. Flagstaff, AZ. 16 pp. 

Gonzalez, Richard. 2014. Personal communication with Paula Cote. Insect and Disease Updates 

for cumulative effect. March 17, 2014. 

Greater Flagstaff Forest Partnership. 2010. Annual Report. Available online: 

http://www.gffp.org/docs/GFFP_2010_Annual_Report.pdf. 2 pp. 

Greater Flagstaff Forest Partnership. 2011. Annual Report. Available online: 

http://www.gffp.org/docs/GFFP_20101_Annual_Report.pdf. 

Gitlin, A.R., C.M. Sthultz, M.A. Bowker, S. Stumpf, K.L. Paxton, K. Kennedy, A. Muñoz, J.K. 

Bailey, and T.G. Whitham. 2006. Mortality gradients within and among dominant plant 

populations as barometers of ecosystem change during extreme drought. Conservation 

Biology 20:1477–1486. 

Hannemann, Mike. 2014. Range Specialist Report, Coconino and Kaibab Four-Forest Restoration 

Initiative (4FRI), FEIS. Manuscript on file at Coconino NF, 4FRI project record. 43 pp. 

Hessburg, P.F., and J.S. Beatty. 1985. Incidence, severity, and growth losses associated with 

ponderosa pine dwarf mistletoe on the Coconino National Forest, Arizona. USDA Forest 

Service, Southwestern Region, R3-85-12, 30 pp. 

Holmes, John. 2011. Personal communication with Paula Cote. South Kaibab Sale History. 

August 18, 2011. 

Lata, Mary. 2014. Fire Ecology, Fuels and Air Quality Specialist Report, Four-Forest Restoration 

Initiative. Manuscript on file at Coconino NF, 4FRI project record. October 15, 2014. 

Lata, Mary. 2014. Grand Canyon National Park 2011 and 2011 Fires. Personal communication 

with Christopher Marks, AFMO, Grand Canyon National Park. March 19, 2014. 

Lynch, A.M., J.H. Anhold, and J.D. McMillin, S.M. Dudley, R.A. Fitzgibbon, and M.L. 

Fairweather. 2008a. Forest insect and disease activity on the Coconino NF, 1918–2006. 

USDA Forest Service, Report for the Coconino NF/Regional Analysis Team. Available 

online: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_021382.pdf. 

Lynch, A.M., J.H. Anhold, and J.D. McMillin, S.M. Dudley, R.A. Fitzgibbon, and M.L. 

Fairweather. 2008b. Forest insect and disease activity on the Kaibab NF and Grand 

Canyon N.P., 1918–2006. USDA Forest Service, Draft Report for the Kaibab NF 

Regional Analysis Team. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_021515.pdf. 

MacDonald, Christopher D. 2014. Water Quality and Riparian Areas Specialist Report, 4FRI, 

Coconino and Kaibab National Forests. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1042 Coconino and Kaibab National Forests 
References Cited

Marks, Chris. 2014. Assistant Fire Management Officer for Grand Canyon NP personal 

communication with Mary Lata, March 19, 2014. Status of ongoing and reasonably 

foreseeable vegetation and prescribed fire projects at Grand Canyon National Park. 

McCusker, Neil. 2012. Coconino FACTS database queries run by 4FRI Silviculturist Neil 

McCusker. 3 pp. 

McCusker, Neil, Richard Gonzalez, and Randy Fuller. 2014. Four-Forest Restoration Initiative, 

Silvicultural Specialist Report. Manuscript on file at Coconino NF, 4FRI project record.

Mueller, R.C., C.M. Scudder, M.E. Porter, R.T. Trotter, C.A. Gehring, and T.G. Whitham. 2005. 

Differential tree mortality in response to severe drought: evidence for long-term 

vegetation shifts. Journal of Ecology 93:1085–1093. 

Negrón, J.F., J.D. McMillin, J.A. Anhold, and D. Coulson. 2009. Bark beetle-caused mortality in 

a drought-affected ponderosa pine landscape in Arizona, USA. Forest Ecology and 

Management 257:1353–1362. 

Newbauer, Kim. 2012. Coconino Cut Volume by Fiscal Year: 1946 to 1989. 

Newbauer, Kim. 2012. Coconino Historic Sold Offered Volumes: 1999. 

Newbauer, Kim. 2012. Sale History: 1995. 

Pyne, Stephen J. 1982. Fire in America: A Cultural History of Wildland and Rural Fire.

Princeton, NJ: Princeton University Press. pp. 79−80. 

Rowe, Julie. 2012. Personal communication with Paula Cote and Henry Provencio. Acres of 

power, oil, and gas lines. March 27, 2012. 

Steinke, Rory. 2014. Soil and Watershed Resources Specialist’s Report, 4 Forest Restoration 

Initiative. Manuscript on file at Coconino NF, 4FRI project record. 

U.S. Department of Defense. 2012. Camp Navajo Army Depot. Camp Navajo Treatments. Bruce 

Buttrey. March 12, 2012. 

U.S. Department of Defense. 2013. Camp Navajo Army Depot. Camp Navajo Treatments. Bruce 

Buttrey. April 1, 2013. 

U.S. Department of Agriculture, Forest Service. 2000. Forest insect and disease conditions in the 

Southwestern Region, 1999. USDA Forest Service, Southwestern Region, R3-00-01: 

Albuquerque, NM. 17 pp. 

______. 2003. Assessment of Grassland/Savannah Invasion by Trees on the Williams Ranger 

District Kaibab National Forest. Kaibab National Forest. October 30, 2003, corrected 

January 19, 2005. 

______. 2004. News release: Crews To Begin Tree Removal on Private Property Next Month. 

Kaibab National Forest Newsroom. August 30, 2004. 

______. 2005. Socio-Economic Assessment for the Kaibab National Forest. Prepared for the 

Southwest Region. The University of Arizona School of Natural Resources. 145 pp. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 1043
References Cited

______. 2008. Kaibab National Forest Ecological Sustainability Report. Manuscript on File at the 

Coconino National Forest, 4FRI Project Record. Kaibab National Forest. Southwestern 

Region. 104 pp. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsm91_050014.pdf. 

_____. 2009. Coconino National Forest Ecological Sustainability Report. September 2009. 

Coconino National Forest. Southwestern Region. 208 pp.

_____. 2011. Forest insect and disease conditions in the Southwestern Region, 2010. USDA 

Forest Service, Southwestern Region, Forestry and Forest Health, PR-R3-16-7, 45 pp. 

Albuquerque, NM. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5316384.pdf. 

_____. 2011. Proposed Action for Four-Forest Restoration Initiative, Coconino and Kaibab 

National Forests, Coconino County, Arizona. Four-Forest Restoration Initiative Coconino 

and Kaibab National Forests Proposed Action. Manuscript on file at the Coconino 

National Forest, 4FRI Project Record. 127 pp. 

_____. 2012. FACTS timber database query. Neil McCusker, 4FRI Silviculturist. Manuscript on 

file at the Coconino National Forest, 4FRI Project Record. 3 pp. 

_____. 2012–1971. Coconino and Kaibab NF File Code 1950 NEPA Project Records. Manuscript 

on file at the Coconino National Forest, 4FRI Project Record. 500 pp. 

_____. 2013. Coconino National Forest Schedule of Proposed Actions (SOPA). Accessed online 

at: http://www.fs.fed.us/sopa/forest-level.php?110304 on January 8, 2013. 

_____. 2013. Kaibab National Forest Schedule of Proposed Actions (SOPA). Available online: 

http://www.fs.fed.us/sopa/forest-level.php?110307. Accessed on January 8, 2013. 

_____. 2014. Coconino National Forest Schedule of Proposed Actions (SOPA). Accessed online 

at: http://www.fs.fed.us/sopa/forest-level.php?110304 on March 7, 2014. 

_____. 2014. Kaibab National Forest Schedule of Proposed Actions (SOPA). Available online: 

http://www.fs.fed.us/sopa/forest-level.php?110307. Accessed on March 7, 2014.

Walton, Colby. 2012. Tusayan Wildlife Waters. Arizona Department of Game and Fish Personal 

communication with Paula Cote, 4FRI. January 31, 2012. 

White, A.S. 1985. Pre-settlement regeneration patterns in a Southwestern ponderosa pine stand. 

Ecology 66:589–594. 

Appendix G – Bridge Habitat 

Arizona Game and Fish Department. 2011. The Coconino County Wildlife Connectivity 

Assessment: Report on Stakeholder Input. 52 pp. 

Brown, D.E., and E. Makings. 2014. A guide to North American grasslands. Desert Plants

29:1−160. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1044 Coconino and Kaibab National Forests 
References Cited

Hampton, H.M., S.E. Sesnie, B.G. Dickson, J.M. Rundall, T.D Sisk, G.B. Snider, and J.D. Bailey. 

2008. Analysis of Small-Diameter Wood Supply in Northern Arizona. Forest Ecosystem 

Restoration Analysis Project, Center for Environmental Sciences and Education, 

Northern Arizona University. 210 pp. 

Merola-Zwartjes, M. 2005. Birds of Southwestern grasslands: Status, conservation, and 

management. In: Finch, Deborah M., Editor. Assessment of grassland ecosystem 

conditions in the Southwestern United States: wildlife and fish—volume 2. Gen. Tech. 

Rep. RMRS-GTR-135-vol. 2. Fort Collins, CO: U.S. Department of Agriculture, Forest 

Service, Rocky Mountain Research Station. 71−140 

North American Bird Conservation Initiative, U.S. Committee. 2011. The State of the Birds 2011: 

Report on Public Lands and Waters. U.S. Department of Interior: Washington, DC. 2011 

USDA Forest Service. 1987. Coconino National Forest Plan. USDA Forest Service. Southwestern 

Region. 274 pp. Available online: 

http://www.fs.usda.gov/detail/coconino/landmanagement/planning/?cid=stelprdb5334653

USDA Forest Service. 2014. Land and Resource Management Plan for the Kaibab National 

Forest. USDA Forest Service. Southwestern Region. 208 pp. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3791580.pdf

USDI Fish and Wildlife Service. 2012d. Recovery Plan for the Mexican Spotted owl (Strix 

occidentalis lucida), First Revision. Albuquerque, NM USA. 414 pp. 

Appendix I – Response to Comment 

Conkle, M.T., and W.B. Critchfield. 1988. Genetic Variation and Hybridication of Ponderosa Pine 

in Symposium Proceedings, Ponderosa Pine the Species and its Management. 

Morphologically. Pullman, Washington, USA: Washington State University, 27–43. 

Finney, M.A. 2001. Design of Treatment Patterns for Modifying Fire Growth and Behavior. 

Forest Science 47(2).

Finney, M.A., R.C. Seli, C.W. McHugh, A.A. Ager, B. Bahro, and J.K. Agee. 2007. Simulation of 

long-term landscape-level fuel treatment effects on large wildfires. International Journal 

of Wildland Fire 16:712–727. 

Fulé, P.Z., T.W. Swetnam, P.M. Brown, D.A. Falk, D.L. Peterson, C.D. Allen, G.H. Aplet, M.A. 

Battaglia, D. Binkley, C. Farris, R.E. Keene, E.Q. Margolis, H. Grissino-Mayer, C. 

Miller, C. Hull Sieg, C. Skinner, S.L. Stephens, and A. Taylor. 2013. Unsupported 

inferences of high-severity fire in historical dry forests of the western United States: 

response to Williams and Baker. Global Ecology and Biogeography 23(7):925−830. 

Higgins, B.J. 2008. Personal communications. Forest Planner, Kaibab National Forest, Williams, 

AZ.

Nobel, William. 2014. Biological Assessment for the Four-Forest Restoration Initiative. On file in 

the project record at the Coconino NF. February, 2014. pp. 238−239. 

Oliver, W.W. and R.A. Ryker. 1990. Pinus ponderosa. Pp. 413-424 in R.M. Burns and B.H. 

Honkala (technical coordinators) Silvics of North America, Vol. 1. Agri. Handbook 654, 

USDA Forest Service, Washington, D.C. 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 1045
References Cited

Reinhardt, E.D., R.E. Keane, D.E. Calkin, and J.D. Cohen. 2008. Objectives and considerations 

for wildland fuel treatment in forested ecosystems of the interior western United States. 

Forest Ecology and Management 256:1997–2006. 

USDA Forest Service 2014. Land and Resource Management Plan for the Kaibab National 

Forest. USDA Forest Service. Southwestern Region. 208 pp. Available online: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3791580.pdf

Williams, M.A., and W.L. Baker. 2012. ‘Spatially extensive reconstructions show variableseverity fire and heterogeneous structure in historical western United States dry forests’. 

Global Ecology and Biogeography 21(10):1042−1052. 

Williams, M.A., and W.L. Baker. 2013. Variability of historical forest structure and fire across 

ponderosa pine landscapes of the Coconino Plateau and south rim of Grand Canyon 

National Park, Arizona, USA. Landscape Ecology 28:297−310. DOI 10.1007/s10980-

012-9835-z.

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1046 Coconino and Kaibab National Forests 
Index

adaptive management, i, ii, iii, v, vi, 642, 

662, 668, 682, 684, 688, 747, 748, 749, 

750, 751, 752, 753, 755, 760, 761, 762, 

763, 765, 766, 767, 768, 769, 770, 771, 

772, 775, 776, 777, 778, 779, 780, 781, 

785, 794, 796, 797, 803, 836, 851, 903, 

933, 938, 944, 953, 957, 959, 966, 974, 

977, 978, 984, 985, 987, 988, 989, 1004, 

1005, 1017 

air quality, vii, 689, 758, 773, 774, 775, 780, 

792, 795, 932, 946, 960, 983, 1012, 1013 

emissions, iii, 643, 645, 646, 764, 930, 

932, 946, 971, 1011, 1012, 1013, 1021 

alternatives

alternative A (no action), 968, 969, 1015, 

1016 

alternative B (proposed action), i, iv, vi, 

568, 570, 578, 581, 583, 587, 588, 589, 

590, 594, 635, 683, 690, 697, 948, 949, 

950, 969, 970, 972, 975, 978, 980, 981, 

984, 987 

alternative C (preferred alternative), i, iv, 

vi, 598, 600, 609, 610, 611, 612, 613, 

616, 619, 623, 624, 625, 626, 630, 688, 

697, 706, 718, 729, 731, 845, 926, 931, 

944, 948, 950, 953, 965, 969, 970, 972, 

981, 1004 

alternative D, i, 634, 948, 970, 971, 1012, 

1014 

comparison, 999, 1004

aquatic species, 678, 939

bark beetle, 776, 867, 868, 869, 1009, 1015 

best management practices, i, ii, iii, iv, v, 

637, 638, 640, 641, 656, 661, 662, 663, 

668, 669, 679, 683, 736, 754, 755, 756, 

757, 758, 766, 767, 774, 779, 782, 784, 

786, 792, 897, 898, 903, 932, 939, 994, 

1011, 1013, 1017, 1018 

climate change, 759, 773, 774, 778, 902, 

930, 932, 960, 1014, 1016, 1018, 1020, 

1021 

Collaborative Forest Landscape Restoration 

Program, vii, 683, 703, 706, 708, 710, 

711, 713, 715, 719, 722, 724, 728, 735, 

751, 756, 957, 984, 1005, 1040 

critical habitat, 741, 1014 

design features, i, ii, iii, iv, 565, 637, 638, 

645, 646, 669, 683, 754, 755, 756, 757, 

758, 848, 897, 898, 900, 901, 913, 994, 

1001, 1006, 1011, 1012, 1017, 1018 

desired conditions, i, 690, 691, 692, 694, 

695, 697, 698, 699, 702, 714, 726, 727, 

728, 729, 736, 737, 738, 739, 740, 741, 

742, 747, 752, 754, 756, 759, 763, 773, 

781, 851, 896, 953 

dwarf mistletoe, 696, 702, 706, 714, 718, 

721, 731, 775, 776, 791, 867, 868, 879 

economic impact, 752, 794, 823, 826, 827, 

831, 834 

employment and income, 795 

federal, state, and local agencies, ii, 919

fire ecology, 643, 865, 866, 905, 909, 932, 

936, 938, 960, 983, 994, 1008, 1013, 

1018, 1020, 1021 

fire behavior, 643, 644, 677, 776, 777, 

785, 807, 846, 902, 905, 911, 913, 978, 

980, 995, 1007, 1013, 1019, 1021 

fire regime condition class, vii, 758, 906, 

908, 945, 1014, 1018 

forest health, vi, 581, 593, 599, 629, 733, 

751, 774, 778, 779, 780, 783, 795, 807, 

858, 860, 879, 889, 890, 892, 902, 903, 

906, 909, 936, 940, 941, 947, 948, 955, 

975, 1005, 1011, 1015, 1016 

forest plan amendments, i, iii, 565, 568, 598, 

634, 950, 974, 1000, 1011, 1023 

amendment 1, i, 568, 598, 634 

amendment 2, i, 582, 617, 635 

amendment 3, i, 593, 629, 636 

forest products, iii, 592, 628, 670, 910, 916, 

959, 960, 961, 962, 963, 964, 970, 998 

goshawk habitat, i, iv, vi, 566, 567, 582, 

583, 587, 589, 590, 617, 618, 619, 623, 

625, 626, 635, 673, 674, 701, 702, 704, 

728, 890, 891, 896, 903, 949, 953, 974, 

1001, 1002, 1003, 1006, 1007, 1009, 

1010, 1011, 1015, 1016 

post-fledging family areas (PFAs), 583, 

586, 618, 621, 714, 718, 721, 724, 726 

grazing allotments, 945

habitat connectivity, 891, 1016 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

Coconino and Kaibab National Forests 1047
Index

heritage resources, 565, 636, 647, 925, 927, 

960, 983, 984, 1001 

implementation plans 

Large Tree Implementation Plan, i, ii, 

684, 688, 731, 735, 760, 899, 937, 941 

Old Tree Implementation Plan, i, 688, 

733, 791 

project implementation plan, 994 

issues, iii, 944, 985, 989, 992, 1016, 1026 

Issue 1 – prescribed fire emissions, iii, 

940, 944, 1011 

Issue 2 – conservation of large trees, iii, 

941 

Issue 3 – post-treatment canopy cover and 

landscape openness, iii, 941 

Issue 4 – increased restoration and 

research, iii, 941 

livestock grazing, 735, 737, 738, 740, 765, 

866, 875, 966 

Mexican spotted owl habitat, i, 567, 568, 

569, 580, 581, 598, 599, 616, 634, 669, 

670, 671, 672, 690, 700, 741, 757, 846, 

879, 892, 894, 896, 902, 903, 936, 948, 

950, 951, 952, 953, 996, 997, 1008, 1013, 

1014 

monitoring, i, ii, iii, 567, 569, 577, 594, 599, 

607, 630, 642, 647, 689, 747, 748, 751, 

752, 753, 754, 756, 759, 763, 764, 765, 

773, 774, 776, 777, 779, 780, 781, 794, 

796, 804, 808, 819, 820, 826, 836, 838, 

851, 853, 854, 855, 856, 903, 910, 939, 

944, 953, 959, 984, 985, 986, 987, 988, 

1004 

natural range of variability (NRV), vii, 704, 

707, 710, 715, 719, 722, 725, 727, 740, 

742, 743, 763, 773, 774, 783, 784, 897, 

902, 909, 910, 913, 938, 1008 

opposing science, iii, 1018 

prescribed fire, iii, 598, 617, 686, 687, 861, 

864, 870, 879, 880, 890, 893, 894, 930, 

941, 1007, 1011, 1012 

range resources, 857, 942

recreation opportunity spectrum (ROS), 656 

resiliency, 774, 869, 870, 876, 902, 907, 

912, 914, 948, 951, 952, 1008, 1009, 1015 

scenery, 912, 916 

sensitive species, 565, 571, 580, 589, 601, 

616, 625, 638, 640, 757, 763, 770, 781, 

788, 789, 790, 939, 947, 951, 952, 1001 

smoke sensitive areas, 645, 1012 

soil and water resources, 656, 773, 775, 777, 

778, 779, 787, 792, 936, 950, 954, 960, 

961, 964, 983 

erosion, 659, 660, 662, 663, 665, 666, 

667, 669, 840, 966, 1017 

soil productivity, 656, 658, 662, 663, 665, 

666, 667, 756, 764, 765, 774, 779, 787, 

792, 1017, 1018

stand density, 690, 692, 695, 702, 706, 711, 

715, 718, 721, 724, 745, 776, 793, 890, 

901, 906, 914, 951, 973, 1009, 1014, 

1015, 1019 

threatened, endangered, and proposed 

candidate species, 639

traditional cultural properties, 925, 926, 927, 

929 

tribal relations, 647, 689, 926, 927, 960, 983 

unavoidable adverse effects, 960 

vegetation analysis, 998, 1005, 1010 

water quality and quantity, 853, 854, 855, 

856, 964 

Final Environmental Impact Statement for the Four-Forest Restoration Initiative

1048 Coconino and Kaibab National Forests