INTERSTATE 17 

WIRELESS COMMUNICATION 

SYSTEM PROPOSAL 

Orme Road to Flagstaff 

ENVIRONMENTAL ASSESSMENT 

April 2001 

Coconino National Forest 
 
Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment Page i 

Table of Contents 

1.0 PROJECT SCOPE...............................................1 

1.1 Background...................................................................1 

 1.1.1 Current Situation....................................................2 

1.2 Purpose and Need...........................................................2 

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

1.4 Decision to be Made........................................................2 

2.0 ALTERNATIVES..................................................3 

2.1 Summary of Alternative Development................................3 

 2.1.1 Public Comments to Proposed Action.......................4

2.2 System Alternatives Considered but Dropped.....................7 

2.2.1 Tower Heights Greater Than 200 feet........................7 

2.2.2 Limit Tower Height to 110-feet..................................7 

2.2.3 Solar Power............................................................8 

2.2.4 Median Pole Placement...........................................8 

2.2.5 Light Poles.............................................................8

2.3 Alternatives Analyzed in Detail..........................................9 

2.3.1 Proposed Action.....................................................9 

2.3.2 No Action...............................................................9 

3.0 AFFECTED ENVIRONMENT..................................9 

3.1 Environmental Consequences of The System....................10 

3.1.1 Visual Quality........................................................11 

3.1.2 Recreation (ROS)...................................................12 

3.1.3 Biological Resources.............................................12 

3.1.4 Cultural Resources................................................14 

3.1.5 Soils and Water......................................................14 

3.1.6 Air........................................................................15 

3.1.7 National Interests...................................................15 

3.1.8 Cumulative Effects.................................................15 

3.1.9 Environmental Justice............................................16 

3.1.10 No Action..............................................................16 

3.2 Affected Environment of Individual Sites............................17 

3.2.1. Proposed Action - Onion Mountain...........................20 

3.2.3 Proposed Action – Rarick Canyon............................27 

3.2.2 Proposed Action – Rocky Park.................................31 

3.2.3 Proposed Action – Woods Canyon...........................36 

3.2.4 Proposed Action – Douglas Mountain.......................41 

3.2.5 Proposed Action – Ritter Mountain...........................46 

3.2.6 Proposed Action – James Canyon............................51 

4.0 CONSULTATION WITH OTHERS............................56 

4.1 List of Persons Consulted...................................................56 
 

 ii Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

List of Figures 

Figure 1. Map of all proposed tower locations..................................18 

Figure 2. Map of all Onion Mountain Alternative Locations................19 

Figure 3. Photo simulations of Onion Mountain Site..........................20 

Figure 4. Map of Rarick Canyon Location.........................................26 

Figure 5. Photo simulations of Rarick Canyon Site............................27 

Figure 6. Map of Rocky Park Location..............................................31 

Figure 7. Photo simulations of Rocky Park Site.................................32 

Figure 8. Map of Woods Canyon Location........................................36 

Figure 9. Photo simulations of Woods Canyon Site............................37 

Figure 10. Map of Douglas Mountain Location....................................41 

Figure 11. Photo simulations of Douglas Mountain Site.......................42 

Figure 12. Map of Ritter Mountain Location........................................46 

Figure 13. Photo simulations of Ritter Mountain Site............................47 

Figure 14. Map of James Canyon Location..........................................51 

Figure 15. Photo simulations James Canyon Site................................52 
 1 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

1.0 PROJECT SCOPE 

1.1 Background 

A coalition of Commercial Mobile Radio Service companies (INDUSTRY) has entered into 

an agreement with the Coconino and Prescott National Forests (Forest Service), to analyze 

the prospect of constructing seven new wireless telecommunications sites along Interstate 

17 (I-17) between Orme Road and Flagstaff, Arizona. 

Commercial Mobile Radio Service is a category of wireless communications service 

established and regulated by the Federal Communications Commission (FCC). This 

category of wireless communications service includes cellular, PCS and ESMR technology. 

The FCC regulates this service through issuance of licenses. The FCC license assigns 

frequencies and geographic areas to service providers (carriers). This proposal is the 

product of an extraordinary collaboration of the wireless communication carriers licensed by 

the FCC in Yavapai and Coconino Counties. The carriers included in this proposal are: 

Alltel, AT&T Wireless, Texas Telecommunications (Sprint), Qwest Wireless, Verizon, and 

VoiceStream. 

The Forest Service has been given direction from Congress and the President to facilitate 

implementation of the Nation’s strategy for wireless communications. On August 10, 1995, 

President Clinton released a memorandum entitled “Facilitating Access to Federal Property 

for the Siting of Mobile Services Antennas.” (Project record document #1a.) In this 

memorandum, the following is stated: 

Upon request, and to the extent permitted by law and where practicable, 

executive departments and agencies shall make available, Federal 

Government buildings and lands for the siting of mobile service antennas. 

On February 8, 1996, the Telecommunications Act of 1996 (project record document #1b)

was enacted, giving further direction to federal agencies. In response to the memorandum 

and the Telecommunications Act, the General Services Administration released a bulletin 

listed in the Federal Register on June 16, 1997, titled “Placement of Commercial Antennas 

on Federal Property.” (Project record document #3a) This bulletin provides general 

guidelines and processes for implementation of President Clinton’s memorandum. 

Regarding granting of siting requests, the bulletin states: 

Requests for the use of property, right-of-way, and easements by duly 

authorized telecommunications service providers should be granted unless 

there are unavoidable conflicts with the department’s or agency’s mission, or 

current or planned use of the property or access to that property. 

Communications sites on National Forest lands must be designated in Forest Land 

Management Plans before development can occur. The proposed amendments to the 

Forest Land Management Plans, in response to INDUSTRY needs, are the reasons the 

Forest Service has directed that an Environmental Assessment (EA) be prepared in 

compliance with the National Environmental Policy Act (NEPA). This EA will analyze the 

impacts of constructing a wireless telecommunications system along the I-17 corridor 

between Orme Road and Flagstaff, Arizona. 
 

 2 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

1.1.1 Current Situation 

I-17 is a major north/south transportation corridor for Arizona that travels through the 

Coconino and Prescott National Forests. Currently, there are many areas along the I-17 

corridor where there are long breaks in wireless telephone coverage. The wireless carrier’s 

FCC licenses require that they provide continuous coverage for certain geographic areas, 

including the I-17 corridor, by a specified time. The I-17 corridor between Orme Road and 

Flagstaff has seven wireless communications providers licensed by the FCC. 

There are existing towers on private land located at Kachina Village, the Verde Valley, 

Cordes Junction, and Orme Road that will be used in addition to the proposed new tower 

sites to complete the wireless communications system for the I-17 corridor between Orme 

Road and Flagstaff, Arizona. 

1.2 Purpose and Need 

The Commercial Mobile Radio Service providers need more tower sites in northern Arizona, 

particularly along the I-17 corridor, to provide service that the public is demanding, and to 

fulfill obligations mandated by their FCC licenses. There is very little private land in this 

area; consequently, INDUSTRY has proposed to develop new communication sites on 

National Forest System lands. INDUSTRY has requested that the USDA Forest Service 

analyze the prospect of constructing seven new tower sites located on National Forest 

System lands along (I-17), between Orme Road and Flagstaff, Arizona. 

The Telecommunications Act of February 8, 1996, directs federal agencies to help facilitate 

implementation of the Wireless Telephone Industry’s system, in compliance with existing 

law, by making federal lands and facilities available for communications sites. 

1.3 Proposed Action 

The proposed action is to designate seven new Commercial Mobile Radio Services 

(cellular, PCS, ESMR) communications sites on Forest Service lands along I-17 between 

Orme Road and Flagstaff, Arizona as shown on Figure 1 and described in Chapter 3.2. 

The proposed new communications sites will each consist of a land allocation 

approximately 100 feet by 200 feet, on which will be located an equipment building(s) and a 

communication tower(s). The tower height at each proposed site varies depending on the 

location, however in all cases will not exceed 200 feet. A typical site layout and tower 

configuration is represented in Appendix A. Technical details for each site can be found in 

the project record (Wireless Communications Facilities Plan, revised January 22, 2001. 

Project record document #94.) 

1.4 Decision to be Made 

The decision to be made by the Forest Supervisors for the Coconino and Prescott National 

Forests is whether to authorize construction of the proposed communications sites and 

associated utility connections, as a complete system, individually, or not at all. The Forest’s 

Land Management Plans must also be amended to designate new communication sites. 
 3 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Following new communication site designations, the Forest Service will issue a prospectus 

to solicit applications from interested parties for communication site leases that authorize 

construction and management of those sites. Provided that the proposals are within the 

development objectives identified in this EA and subsequent Decision Notice, the Forest 

Supervisors may select the proposal or proposals for site development, that best meet 

Forest Service goals. 

The Forest Service is required to approve site plans before any development can proceed, 

and as part of this approval process, must ensure compliance with the National 

Environmental Policy Act of 1969 (NEPA), the National Forest Management Act of 1976, 

the Forest Service special-use permit regulations in 36 C.F.R. 251, and other applicable 

statutes, regulations, Executive Orders, and the Forest Service Manual and Handbook 

direction (collectively, the applicable legal requirements).

2.0 ALTERNATIVES 

2.1 Summary of Alternative Development 

The rapidly expanding demand for wireless communications has resulted in a focused and 

determined effort by INDUSTRY to locate new tower sites throughout the Nation. This 

effort has historically been conducted by individual carriers working on their own in attempts 

to gain a competitive edge by securing new sites for towers. Collocation of carriers at the 

same site has been difficult in the past because of the competitive nature of the industry. 

The first companies to approach the Forest Service were the cellular carriers. The Forest 

Service was able to meet their basic needs by authorizing use of existing communications 

sites. With the entry into the market of digital systems (PCS) it became apparent that 

existing sites could not provide the coverage that is mandated by the carrier’s FCC 

licenses. Consequently, INDUSTRY began an aggressive campaign to secure new tower 

sites in northern Arizona. Licensed carriers and tower companies wanting to develop new 

communication sites along the I-17 corridor first approached the Forest Service individually. 

Working with individual carriers made it difficult for the Forest Service to understand or 

effectively evaluate the scope of the potential environmental impacts of accommodating 

INDUSTRY needs. In an attempt to understand the cumulative impacts to the area from 

this new INDUSTRY and to avoid a proliferation of new towers, the Forest Service directed 

the INDUSTRY to develop a comprehensive collocation proposal that included all licensed 

wireless carriers. 

In an unprecedented effort, INDUSTRY formed a coalition that included all but one of the 

licensed wireless carriers and began work collaboratively designing a system of new tower 

sites along the I-17 corridor that would meet all of their technical needs through collocation. 

The Forest Service directed INDUSTRY to use the following objectives for development of 

the proposed action: 

• Design new sites to facilitate co-location of all carriers. 

• Design the system to meet the technical needs of all licensed carriers. 

• Minimize the number of new sites to reduce environmental impacts. 
 

 4 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

• Avoid FAA lighting requirements for towers by limiting height to 200 feet. 

• Locate new sites to minimize visual impacts. 

• Address wireless communication needs for the next five to ten years. 

Using the Forest Service design objectives, INDUSTRY identified seven potential sites for 

new towers that would complete a system that would provide continuous coverage on I-17 

between Orme Road and Flagstaff. 

A qualified landscape architect then conducted a visual assessment of the proposed tower 

locations (Project record document #46a). The visual assessment resulted in several 

modifications of the original proposal to address visual concerns. In addition, preliminary 

environmental investigations were conducted for each proposed site in order to avoid 

environmentally sensitive areas. The result of this effort is the proposed action. The original 

proposal has been modified several times to take into account the different technical 

requirements of the various carriers and the concerns expressed by the Forest Service to 

minimize environmental impacts. The technical details of the proposed action can be found 

in the project record (Project record document #46b titled “Wireless Communications 

Facilities Plan for Coconino and Prescott National Forests”.

2.1.1 Public Comments to the Proposed Action 

In April 2000, a project proposal letter describing the proposed action was mailed out to the 

Prescott and Coconino National Forests’ list of interested parties (see Chapter 5). The 

comments that were received during this scoping process were categorized and 

summarized below with a response to the concern identified. 

Comment #1. Several people expressed concern over the visual impact of the 

proposed towers. Response: Visual quality is an issue that has been identified 

and has been evaluated and analyzed as part of this EA. Wireless communications 

towers require line-of-sight to the target areas to provide coverage. Consequently, 

locating tower in areas that are not intervisible will not work technically. The Forest 

Service gave INDUSTRY direction to reduce the visual impacts of the new towers 

by proper location based on a visual analysis (Section 2.1) (project record document 

#46). A visual analysis has been completed for each site to ensure the best 

possible location for individual towers under the 200-foot tower height objective for 

system design. Each of the proposed site locations were considered based on the 

silhouette conditions, distance zone, angle of viewer exposure, and duration of view 

of the proposed towers from I-17. 

Comment #2. The need for cellular towers is short lived with continuous 

technological development. What happens if the towers become obsolete? 

Response: If the need for cellular towers becomes obsolete in the future, the 

improvements will be removed and the sites will be rehabilitated. Removal of the 

improvements and restoration of the sites are part of the terms of a communication 

site lease. 

Comment #3. The effects of microwaves on plants and animals are still unknown. 

The Forest Service should wait until further studies of these effects have been 

conducted. Response: Many studies have been conducted on the effects of radio 

frequency emissions (RF). A collection of reference material compiled by biologist 

Sandra Nagiller titled “Radio Frequency Electromagnetic Fields, Effects on Human 
 5 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

health” can be found in the project record (document #58a). In a publication by the 

Federal Communications Commission (FCC), OET Bulletin 561 it was stated: 

Measurements made near typical cellular and PCS installations, 

especially those with tower-mounted antennas, have shown that 

ground-level power densities are well below limits recommended by 

RF/microwave safety standards...Calculations corresponding to a 

“worst-case” situation (all transmitters operating simultaneously and 

continuously at the maximum licensed power) show that in order to 

be exposed to levels near the FCC’s limits for cellular frequencies, an 

individual would essentially have to remain in the main transmitting 

beam (at the height of the antenna) and within a few feet from the 

antenna. Measurements and calculations have verified that the 

power densities associated with cellular radio cell-site antennas to 

which the public may be exposed are not significantly different from 

“RF background” levels in urban areas which are produced from 

radio and television broadcast stations present in every modern 

community, are well below the limits recommended by national and 

international safety standards. 

Low powered cellular and PCS devises must comply with the safety standards for 

radio frequency emissions issued by the FCC. The FCC requires an evaluation of 

all wireless devices by the manufacturers for compliance with the Specific 

Absorption Rate (SAR) prior to receiving FCC approval. These evaluations ensure 

that wireless telephones operate within the FCC’s safe exposure limits. To this 

date, there is no evidence of bio-effects danger from the use of wireless telephones. 

(Siting Wireless Antennae, page 81, CTIA, project record document #3b). 

 The Telecommunications Act of 1996, states: 

“No State or local government or instrumentality thereof may regulate 

the placement, construction, and modification of personal wireless 

service facilities on the basis of the environmental effects of radio 

frequency emissions to the extent that such facilities comply with the 

Commission’s regulations concerning such emissions”. 

Comment #4. The Forest Service should make the easements/access roads to the 

new sites restricted to non-motorized vehicles. Response: Road and utility 

access is an issue that has been identified and evaluated as part of the EA. Most of 

the sites are located on existing Forest Service roads. There is only one site, 

(Onion Mountain) that will require construction of a new road. The Forest Service 

has determined that if this site is designated, the access road will be gated and 

restricted to communication site administrative use only. In addition, the access 

road to the Rocky Park site will be gated to maintain the Rattlesnake Seasonal 

Closure. 

 1

U.S. Federal Communications Commission (FCC), Office of Engineering and Technology, “Questions 

and Answers about Biological Effects and Potential Hazards of Radiofrequency Electromagnetic 

Fields,” OET Bulletin 56, Edition 99-04, August 1999, Washington, D.C. 20554.
 

 6 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Comment #5. The Forest Service should require the utilities to be underground to 

prevent the visual impacts of the lines. Response: In general, the Forest 

Service agrees that underground utilities are preferred from a visual quality aspect. 

All of the proposed sites with the exception of Onion Mountain, Woods Canyon, and 

Rocky Park have access to existing overhead utilities within a short distance. 

Access to existing utilities was an objective for system design. Utility corridors to 

service the proposed Onion Mountain, Woods Canyon, and Rocky Park sites will be 

designated to be within the access roads as part of this NEPA process. 

Underground utilities have been identified as recommended mitigation for the Onion 

Mountain site utility corridor and for portions of the Rocky Park and Woods Canyon 

utility corridors that are visible from I-17. 

Comment #6. The Forest Service should require shorter towers. Response: Shorter 

towers were evaluated but dropped from detailed consideration because of several 

factors. Generally, if shorter towers were constructed, then more towers would be 

required. Due to the predicted environmental effects of providing access and 

utilities under a shorter tower scenario, it is preferred to minimize the number of 

tower sites. For example, if towers were limited to 110 feet, the number of towers 

required to provide the same level of coverage would increase from seven to 

twenty six. See Section 2.2.2 for more information.

Comment #7. The development of new cellular sites would only benefit the cellular 

providers. This proposal is for profit of these companies only. Wireless 

Communications sites are not an appropriate use of National Forest System 

lands. Response: A part of the Forest Service mission is to provide for a variety of 

uses, values, products, and services for present and future generations. In areas 

like northern Arizona, local communities and society are dependent upon National 

Forest System lands to provide for uses such as right-of-ways for power-lines, 

pipelines, highways and communication sites. Development of a reliable 

communication system is in the public interest and is supported by the President of 

the United States and Congress. This is supported by Executive Order dated 

August 10, 1995 and passage of the Telecommunications Act of 1996, which directs 

federal agencies to help facilitate siting of wireless communications sites. 

Comment #8. Concerned with potential impacts to wildlife habitat from clearing 

vegetation for construction of the site and access roads. Response: Three of 

the proposed sites will be located on previously disturbed or developed areas such 

as the McGuireville Rest Stop (Rarick Canyon), ADOT Little Antelope Maintenance 

Facility (Douglas Mountain), and Willard Springs Transfer Station (Ritter Mountain). 

James Canyon site has existing road access and electrical power adjacent to the 

site. Woods Canyon and Rocky Park have existing road access. Electrical power is 

approximately 2.5 miles away and would follow the existing access road. Onion 

Mountain is the only site that would require new road construction. The proposed 

sites not on previously disturbed ground were located to minimize the need for tree 

clearing. All towers will be designed to follow U.S. Fish and Wildlife guidelines for 

communication towers, which were established to address impacts to migratory 

birds (see section 3.1.3.3. for more information) 

Comment #9. Other technology should be used instead of Cellular and PCS 

telephones such as satellite telephones and call boxes or pay telephones. 

Response: The demand for wireless communications (voice and data) far 
 7 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

surpasses any ability of current or foreseen satellite communications. In addition, 

satellite communications are very expensive, which eliminates much of the general 

public from benefits of wireless communications. ADOT does not have the 

infrastructure in place to accommodate call boxes or pay telephones. Call boxes 

and pay telephones would require wire-line connections and electrical power, which 

currently do not exist. Developing the infrastructure for wire-line telephone 

connections and electrical power would be very costly and would have impacts to 

the environment far beyond those of wireless systems. 

Comment #10. Proposed communications towers could affect property value. 

Response: Rarick Canyon is the only proposed site that is close enough to private 

land to have any effect. A visual analysis was conducted as viewed from the closest 

residential property to the Rarick Canyon site. The visual analysis concluded that 

the proposed tower is similar to the elements of the existing rest area. The tower 

would repeat the form, line, and scale of an existing element in the setting, and 

therefore should not have any effect on adjacent private property. (Project record 

document #46a.) 

Comment #11. The carriers should use existing communication sites instead of 

building new facilities on National Forest land. Response: The existing 

designated communications sites on National Forest land are already being used by 

the wireless carriers. New technology (PCS) requires towers to be closer to the 

user and with line-of-sight placement. This requires new sites to provide the 

coverage to areas that are mandated by the carrier’s FCC licenses. 

Comment #12. Communication sites are responsible for killing migratory birds. 

Response: The U.S. Fish and Wildlife Service has recently published guidelines for 

communication towers that mitigates migratory bird mortality associated with towers 

(Project record document #75). All of the proposed tower designs are consistent 

with these guidelines (see Section 3.1.3.3) 

Comment #13. Suggested siting the James Canyon tower higher or closer to 

Highway 89. Response: Industry engineers examined relocating to the area 

suggested, and determined that the suggested site would not serve the purpose 

along I-17 for which it was designed. 

2.2 System Alternatives Considered but Dropped From Detailed 

Analysis 

In response to comments received during the scoping process and to verify the 

methodology for designing the system, the Forest Service directed INDUSTRY to analyze 

alternatives for system design. The following are discussions on alternatives for system 

design that were considered but dropped from detailed consideration: 

2.2.1 Tower Heights Greater Than 200 Feet 

When INDUSTRY first approached the Forest Service, it was proposed to have only five 

new sites on Forest Service land along I-17. The sites would have required towers 250 to 

300 feet in height in order to provide adequate signal coverage and meet the technical 
 

 8 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

requirements of the carriers. At that height, the towers would be required to have lighting at 

the top, and would be very massive to the eye. A reduction in tower height to a maximum 

of 200 feet eliminates the need for lighting required by the Federal Aviation Administration 

(FAA). Tower heights that exceed 200 feet and are lighted at night significantly increase 

the potential for avian mortality due to birds colliding with towers. 

The United States Fish and Wildlife Service recommends restricting tower heights to less 

than 200 feet. Due to the need for lighting, which increases visual impacts and potential 

avian mortality, this alternative was dropped from further consideration. 

2.2.2 Limit Tower Height to 110-feet 

Limiting tower heights to a maximum of 110-feet was reviewed. The number of towers 

would dramatically increase from 7 to 26. Each of the initial 7 sites would need two towers 

instead of one and an additional 6 new sites would be constructed, each of these with two 

towers. The number of towers increased for a variety of reasons: the height of the existing 

vegetation, topography, the number of carriers, and the amount of separation required 

between antennae on a tower. Each of the new sites would require the same 100’ x 200’ 

ground space, as well as power and ground access. Providing access and utilities to six 

additional sites would increase environmental effects. At the Rocky Park, Woods Canyon, 

Douglas Mountain, Ritter Mountain, and James Canyon sites the Forest canopy is generally 

around 75 feet. With a 110-foot tower height limitation a second tower would have to be 

constructed so that each of the carrier’s antennas would clear the canopy. In addition, at 

one site, (Rocky Park), the tower would have to be relocated to another location in order to 

maintain the tower’s line-of-sight with other towers and this other location would increase 

the tower’s visual impact. . Therefore, due to potential increase in impacts resulting from 

providing access and utilities to additional sites in addition to the increase in the visual 

impacts from the increased number of towers, this alternative was dropped from detailed 

consideration. 

2.2.3 Solar Power 

Solar Power was reviewed for use at the proposed sites. This was dropped from further 

analysis because of the increase in area that would be impacted due to the number of solar 

panels that would be required to provide sufficient power to the site. In order to supply 

adequate solar power, the area allocated for the communication site would have to be 

substantially increased. The necessary solar panels would cover an area approximately 

one half-acre in size. In addition, the panels must be orientated in a southerly direction to 

gain sun exposure for most of the day. At the Onion Mountain location this would 

substantially increase the visibility of the site from I-17. Solar panels would contribute to 

additional adverse visual effects and require more tree clearing to keep the panels free of 

shade. In addition, solar power with batteries does not supply the consistent reliable 

electrical power that is required for wireless telecommunications use. 

2.2.4 Median Pole Placement 

Placing the towers in the median of I-17 was considered. ADOT regulations will not allow 

this option because I-17 is a controlled access highway. ADOT has a policy to not allow 

access at locations not designed to accommodate access. Towers located in medians 

would not have appropriate and safe access. Additionally, in some areas this would 

increase the pole numbers by a factor of ten, requiring approximately 70 sites. Therefore, 
 9 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

this alternative was dropped from detailed analysis. 

2.2.5 Light Poles 

The Forest Service asked the Carrier Coalition to examine the feasibility of using a series of 

50-foot light poles along the ADOT right-of-way for I-17 as an alternative to a single site at 

Onion Mountain. The Onion Mountain site is designed to serve I-17 from private land sites 

in Camp Verde to existing private land sites near Orme Road. This area of I-17 has 

geologic features that prevent long line-of-sight connections between telecommunications 

facilities. In addition, the roadway has been carved through several hills that create a 

“canyon” effect that would require sites at both ends of the “canyon”. 

With these existing limitations, it is estimated that the number of sites required to serve this 

area would be at least 15 for this approximate 15-mile length of highway. In addition, 

electrical power would be needed. There are generally about 20 power poles per mile 

needed to supply electrical power to these sites; consequently the total number of new 

poles would be approximately 300. At each site, there needs to be sufficient ground space 

to locate the required electronics to operate the equipment. Though the carriers would 

probably not need the 100-feet by 100-feet area that would be required at the other sites, 

there would be a need for at least an area 50-feet by 50-feet area for equipment. 

There is one additional issue that probably overrides all others when examining this 

alternative. The Arizona Department of Transportation’s policies for controlled access 

roadways do not allow for installation of other facilities within the right-of-way (ROW). 

ADOT’s policies also do not allow for direct access off of the ROW. For most of this area 

there is no existing access along the side of the I-17 ROW. Consequently, implementation 

of this alternative would require many miles of new roads adjacent to the highway and was 

therefore dropped from further consideration. 

2.3 Alternatives Analyzed in Detail 

The no action and one action alternative (The Proposed Action) are considered in detail. 

2.3.1 Proposed Action 

After analysis of the differences in the importance or significance of environmental effects 

as it relates to visual quality versus the environmental effects of new roads and power lines, 

it was determined that the 200 foot limitation on tower height for the system was 

appropriate and would serve as a constraint for system design. 

2.3.2 No Action 

The Forest Supervisor could elect to authorize the entire system or some of the sites. If a 

no action alternative for specific sites were selected, it would require further analysis to 

develop an alternative to provide signal coverage for that specific location. The proposed 

action represents a system that will not be complete if a site or sites are not developed. 
 

 10 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.0 AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 

3.1 Affected Environment And Environmental Consequences of 

The System 

The following section summarizes the findings of all the studies conducted. Section 3.2 

describes the findings of the studies conducted on a site-specific basis. 

3.1.1 Visual Quality 

The visual resource impact assessment is a qualitative assessment of the difference in 

visual character, overall visual conditions, and compliance with the USDA Forest Service 

Visual Management System (VMS). For the purpose of the visual assessment, the study 

area included selected transportation corridors where the wireless communication towers 

may be visible. The major transportation corridors are portions of I-17, State Route (SR) 

169, Stoneman Lake Road, Schnebly Hill Road, and SR 89A. 

The majority of the landscape in the study area would be classified as common or Class 'B'. 

This landscape is typified by moderately varied terrain and vegetation patterns. Rounded 

hills and rock formations are the typical landform types within the foreground distance zone 

of the existing transportation corridors (I-17, SR 169, Stoneman Lake Road, Schnebly Hill 

Road, and SR 89A) within the study area. The vegetative cover is fairly continuous with 

typical species diversity. Areas of minimal or Class 'C' classification within the foreground 

of the interstate occur at Camp Verde, McGuireville, McGuireville Rest Area, and Munds 

Park/Pinewood area. These areas are classified as minimal in inherent scenic quality 

because of the extensive visual modifications to the rural development. There are also a 

few areas within the foreground of the corridor of highly varied or distinctive landform, 

vegetation, or waterform that would warrant a distinctive or Class 'A' classification. These 

areas are limited to Copper Canyon, Verde River and the scenic overlook location. The 

existing visual conditions where the potential towers would be visible from the roadways 

currently meet the Visual Quality Objectives (VQO) of Retention except for the McGuireville 

Rest Area. 

The changes in visual character and scenic integrity from existing conditions to post-project 

conditions along the corridors were evaluated based on several factors. These factors 

consider the silhouette conditions, distance zone, angle of viewer exposure, and duration of 

view of the wireless communication tower from the specified transportation corridors. 

Rarick Canyon would have the greatest magnitude of impact based on these factors. 

However, the potential tower facility is similar to the existing conditions at the McGuireville 

Rest Area with the architectural style of the buildings and the presence of high mass 

lighting for the parking areas. After consideration of each tower and evaluating the 

cumulative visual effect, Stoneman Lake Road and Rocky Park south were dropped from 

further consideration. The tower location at Woods Canyon was relocated to minimize 

head-on views. 

The VQOs are developed to be measurable standards for the visual management of Forest 

Service lands. Based on the National Forest Resource Management Plan, the management 
 11 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

objectives were compared to the post-project visual impacts for each site. For all potential 

site locations, the activities associated with the wireless communication features would not 

meet Retention because they would result in changes that would be evident to the casual 

observer from the specified transportation corridors. The existing conditions where the 

proposed towers would be visible from the roadways currently meet the VQO of Retention 

except for Rarick Canyon (McGuireville Rest Area). 

The introduction of the proposed improvements will create various degrees of alteration in 

the existing visual landscape. These alterations will be visually evident by the disruption of 

vegetation patterns and landform disturbance. The alterations are a result of contrast to the 

form, line, color, and texture of the existing landscape. There will be no cumulative effects 

to the visual resource of the area because addition of the towers to the existing highway 

corridor will not result in any significant changes to the area. (See the site-specific effects 

in section 3.2 for more detail) 

Recommended mitigation: The degree of impact will be reduced by minimizing the 

amount of cut and fill slopes, revegetation of disturbed areas, and by blending any 

structures into the surrounding landscape. Eliminating all reflective surfaces of the tower by 

painting the surfaces flat black or dark brown will reduce color contrast. 

3.1.2 Recreation (ROS) 

The Forest Service uses the Recreation Opportunity Spectrum (ROS) to provide a 

framework for defining and rating classes of outdoor recreation environments, activities, 

and experience opportunities. The system’s premise is that recreation users choose a 

specific setting for a particular activity or set of activities to have a desired experience. Six 

settings have been delineated ranging from pristine undisturbed landscapes to areas 

heavily impacted by human presence. The Coconino National Forest Land Management 

Plan states that total acres of any ROS class are allowed to change no more than plus or 

minus 15 percent from the updated inventoried levels during the first decade. The ROS 

classifications for the proposed communications site locations are all roaded natural. 

Hikers, motorized and non-motorized vehicles, and equestrian travel can access the areas 

in which most of the cellular towers are proposed. Existing Forest Service roads provide 

access to all of the sites with the exception of the Onion Mountain site. Restricting the new 

access road at Onion Mountain to communication site management use only will help 

reduce any impacts that increased motorized vehicle use might generate. 

Because of the presence of the interstate highway and its associated infrastructure that is in 

proximity to the proposed communications sites, there will be no change ROS settings and 

no cumulative effects as a result of construction of the communication facilities. 

3.1.3 Biological Resources 

3.1.3.1 Special Status Vertebrate/Invertebrate Species 

Special status species include federally threatened, endangered, or proposed species 

under the Endangered Species Act and all Forest Service sensitive species. All special 

status species on the Coconino and Prescott National Forest lists were considered (see 

Appendix B). Habitat evaluations for each species were determined by comparing project 

area features to published information on the species' life history, habitat, and range and 
 

 12 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

from occurrence information on file at the Coconino National Forest district offices. The cell 

tower sites include habitat for four special status species: the bald eagle and Mexican 

spotted owl, listed as threatened; the Navajo Mountain Mexican vole, a mammal species 

listed as Forest Service sensitive; and the northern goshawk, a Forest Service sensitive 

bird. 

Analysis at each individual tower site determined that the three special status birds (eagle, 

owl, goshawk) will not be impacted (see Section 3.2). The entire system of towers will also 

not impact these birds because the system is not located in important migratory, dispersal, 

or foraging flightpaths. Possible habitat for the Navajo Mountain Mexican vole may be 

impacted at four individual tower sites, totaling approximately four acres for the system. 

This vole is expected from meadows, riparian areas, and ponderosa pine with grassy 

understory vegetation from Mormon Lake to Williams. The loss of four acres of habitat for 

this species will not cause any population declines or changes or cumulative effects in the 

species distribution because of the large amount of potential habitat for this species on the 

Coconino Forest. 

3.1.3.2 Forest Service Management Indicator Species 

Other wildlife species considered for the cell tower sites include management indicator 

species. Forest Service indicator species are wildlife species representative of different 

vegetation communities. Long-term changes in the populations of these species serve as a 

barometer of the overall health of ecosystems. Coconino National Forest indicator species 

for the ponderosa pine and oak forest type include turkey, northern goshawk, pygmy 

nuthatch, hairy woodpecker, Mexican spotted owl, Abert's squirrel, red squirrel, and elk. 

Prescott National Forest indicator species for the woodland habitat are the mule deer and 

titmouse. This system of towers will not have cumulative effects or affect the population 

viability of any management indicator species because: (1) tower placement considered 

and avoided important breeding habitats, (2) habitat at each site and the combined total of 

all acres impacted is extremely small compared to the range of the species on the Forests, 

and (3) potential impacts can be mitigated. (Project record document #95) 

3.1.3.3 Bird Mortality from Collision with Cell Phone Towers 

Significant numbers of birds are killed every year from collision with tall human-made 

structures, such as power lines, high rise buildings, lighthouses, and towers. Single event 

bird kills numbering in the thousands occur along migration routes in inclement weather at 

tall, lighted towers. Migrating birds are attracted to tower lights during stormy weather 

because the birds are attempting to fly out of cloud and fog conditions into clear skies 

represented by the lights. There is a concern that bird mortality will increase because of the 

explosive growth in the number of towers being constructed for wireless services. The US 

Fish and Wildlife Service believes that proliferation of telecommunication towers over the 

next decade will create a significant cumulative negative impact on bird populations (project 

record document #58). The US Fish and Wildlife Service has recently adopted guidelines 

for siting, construction, operation, and decommissioning of communications towers (project 

record document #75). If the tower system is designed and constructed following the 

guidelines no cumulative impacts are predicted. The elements of the US Fish and Wildlife 

Service guidelines are implemented into the design of the proposed cell phone towers and 

are as follows: 

• All towers will be less than 200 feet high and will be unlighted. 
 13 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

• Towers will be self-supporting lattice or monopole design with no guy wires. 

• Towers and all utility and support structures will be painted with non-reflective paint. 

• Any service or security lighting around tower sites will be down-shielded. 

• None of the tower sites are located at or near important bird migration routes or 

concentrations of birds, such as adjacent riparian or aquatic habitat. 

• The number of towers has been minimized through cooperation of multiple providers 

to co-locate equipment at single sites. 

Recommended mitigation: Implement bird mortality monitoring according to the protocol 

under development by the National Communication Tower Working Group. Expand 

monitoring to record bat kills. 

3.1.3.4 Special Status Plants

All special status species on the Coconino and Prescott National Forests were considered. 

Appendix B documents all special status plant species considered. Habitat evaluations for 

each species were determined by comparing project area features to published information 

on the species' life history, habitat, and range and from occurrence information on file at the 

Coconino National Forest district offices. There is no habitat for federal listed plant species 

at any of the sites. No Forest Service sensitive plants were found during plant surveys, 

however a survey for Polygala rusbyi is still needed at one site. 

3.1.3.5 Exotic Weeds 

There are different suites and densities of non-native and native weed plants in the project 

area with the greatest concentrations found on disturbed ground along roads, at stock 

tanks, and around borrow pits. Exotic weeds are a significant issue for biologists, land 

managers, and ecologists because the explosive spread of noxious weeds has degraded 

millions of acres of range and forest land across the western United States by outcompeting and replacing native vegetation (Williams 1997). There are both Arizona state 

and federal guidelines and regulations to prevent the introduction of noxious weeds and 

control established populations. On February 3, 1999, (project record document #3b) 

President Clinton issued an Executive Order that establishes policy for all federal agencies 

to deny authorization for any actions on federal lands without plans to minimize the risk of 

promoting invasive plant populations. The Coconino, Kaibab, and Prescott National 

Forests are currently working on an Environmental Impact Statement to address a variety of 

methods of treating noxious weeds. At this time the Proposed Action is expected in Spring 

2001 and the DEIS in late Summer 2001. The 1998 Strategic Weed Management Plan for 

the Coconino, Prescott, and Kaibab National Forests places an emphasis on minimizing the 

spread of weeds to pristine and relatively uninfected areas. Appendix C lists all plant 

species identified in the project area, including exotic weed species. 

The construction of this system of towers could spread noxious weeds. Equipment could 

transport seeds of new noxious weeds onto the National Forests and could also transport 

seeds from existing plants from one tower site to another. A risk assessment and mitigation 

plan following the 1998 Strategic Plan will be prepared. Standard spread for noxious 

weeds preventative measures, such as cleaning equipment prior to initial construction and 

cleaning prior to moving from a site containing noxious weeds will minimize the risk of 

spread of noxious weeds. Preventative measures will be included as part of the terms and 

conditions of the lease for operation and construction of the facilities. With adoption of the 
 

 14 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

preventative measures as part of the lease, the proposed action will not have a cumulative 

effect or significant contribution to the spread of noxious weeds. 

3.1.4 Cultural Resources

A survey has been completed on the proposed tower locations. All archaeological sites will 

be avoided. A complete archaeological report can be found in the project record (document 

#88). There will be no cumulative effects to cultural resources because all archaeological 

sites will be avoided by construction. 

3.1.5 Soils and Water 

The areas proposed for the towers do not contain any perennial streams or rivers. There 

are some areas where there is a slope to the proposed site. These locations will require 

minimal grading for the tower site and access roads. During construction, all measures will 

be taken to reduce erosion at these sites. The most practical and effective means of 

controlling non-point pollution sources from forests and rangelands is through the 

development of preventative or mitigating land management practices, generally referred to 

as Best Management Practices (BMPs). BMPs were developed through an 

intergovernmental agreement between the State of Arizona, and the U.S. Forest Service. 

BMPs are a practice or a combination of practices that are determined to be the most 

effective, practicable means of preventing or reducing the amount of pollution generated by 

no-point sources such as logging, construction, road building and maintenance etc., to a 

level compatible with water quality goals (FSH 2509.22). All projects will abide by Best 

Management Practices. (Project record document # 1c.) 

The construction of the proposed towers will have no impact on the water in the areas. All 

measures will be taken to reduce the impacts to the soils and reduce the erosion. The 

proposed action will have no cumulative effects because the actual area of disturbance is 

relatively small and concentrated to an existing transportation corridor. 

Recommended mitigation: (1) All communication site access roads must be properly 

maintained and built to a standard that will allow for all weather travel. Road maintenance 

activities shall be completed according to a schedule specified in the Communication Site 

plan. (2) Best management Practices shall be required as part of the Communication Site 

Lease and Site Plan. 

3.1.6 Air 

During the construction of the cellular towers, minimal dust will be produced. Once the 

cellular towers are complete, they will not have any adverse environmental or cumulative 

effects on the air quality to the environment because the activities associated with 

construction of the facilities will be small and specific to the actual site. 

There will be no adverse effects or cumulative effects on the air quality, as a result of 

implementing the proposed action. 

3.1.7 National Interests 

The Forest Service has been given direction from Congress and the President to facilitate 

implementation of the nation’s strategy for wireless communications. On August 10, 1995, 
 15 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

President Clinton released a memorandum entitled “Facilitating Access to Federal Property 

for the Siting of Mobile Services Antennas.” In this memorandum, the following is stated 

“Upon request, and to the extent permitted by law and where practicable, executive 

departments and agencies shall make available Federal Government buildings and lands 

for the siting of mobile service antennas.” 

On February 8, 1996, the Telecommunications Act of 1996 was approved. In response to 

the memorandum and the Telecommunications Act, the General Services Administration 

released a bulletin listed in the Federal Register on June 11, 1997, titled “Placement of 

Commercial Antennas on Federal Property.” (Project Record document #3a.) This bulletin 

provides general guidelines and processes for implementation of President Clinton’s 

memorandum. Regarding granting of siting requests, the bulletin states “Requests for the 

use of property, right-of-way, and easements by duly authorized telecommunications 

service providers should be granted unless there are unavoidable conflicts with the 

department’s or agency’s mission, or current or planned use of the property or access to 

that property.” 

Implementing the proposed towers will comply with the current regulations. There are no 

conflicts with the Forest Service’s mission, or are there any conflicts with the current or 

planned use of the proposed properties and their accesses. 

3.1.8 Cumulative Effects

Cumulative effects are effects on the environment, which result from the incremental impact 

of the action when added to other past, present, and reasonable foreseeable future actions, 

regardless of what agency (federal or non-federal) or person undertakes such other actions. 

Past present and ongoing activities have been considered in conjunction with the No Action 

and the Proposed Action Alternatives. The current status of air, water, soil, vegetation, 

wildlife habitat, visuals, recreation, and cultural resources are described in Section 3.0 of 

this document. Ongoing and future actions as described in the “Schedule of Proposed 

Actions” for the Coconino National Forest have been reviewed and are located in the 

project record (document #83). 

Section 3.2 discloses and analyzes the specific environmental effects of each site 

individually. In section 3,2 the conclusion was that there is no significant effect to the visual 

quality because the proposed action meets visual quality objectives and there is no change 

in the ROS classifications. Therefore there will be no significant cumulative effects to visual 

quality and recreational experience, 

There are no cumulative effects to air, water, soil, and biological resources from the 

proposed action when considered with past, present, and ongoing activities because the 

area of disturbance associated with construction and operation of the communication site is 

relatively small in relation to the general landscape and the proposed improvements are 

within the area already influenced by the interstate highway (Section 3.0). Each site 

involves an area less than .46 acres and the combined or cumulative total of area impacted 

is approximately 3.22 acres (Appendix A). Three of the sites have been located to take 

advantage of previously developed areas. Rarick Canyon site is within the ADOT 

McGuireville Rest Stop. The Douglas Mountain Site is located within the ADOT Little 

Antelope Maintenance compound. Ritter Mountain is located within the area previously 

disturbed by the Willard Springs Transfer Station. All of the other sites with the exception of 
 

 16 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Onion Mountain have existing road access. There will be no significant effect to migrating 

birds as a result of this system if United States Fish and Wildlife guidelines for towers are 

followed (Section 3.1.3.3). U. S. Fish and Wildlife guidelines were used for system design; 

therefore there will be no cumulative effects to birds. 

3.1.9 Environmental Justice 

The issue of environmental equity and justice in natural resource allocation and decisionmaking is receiving increasing political and social attention. Following President Clinton’s 

Executive Order 12898 (Federal Register, February 1994), all Federal land management 

agencies have been mandated to address environmental justice in nonwhite and/or lowincome populations, with the goal of achieving environmental protection for all communities 

regardless of their racial and economic composition. 

The proposed alternatives do not result in disproportionate impacts to low-income 

populations, nor do they impact minority populations. The Flagstaff area, including its low 

income and minority populations is strongly tied to the tourism industry, with cellular 

companies having a very small percentage of the overall economy. 

3.1.10 No Action 

If the No Action Alternative is selected or authorized, it would result in continuance of the 

existing condition of less than adequate wireless telecommunications for this area. In 

addition, if the no action alternative were selected there would be no change to the visual 

quality, recreation, soil and water, cultural resources, and air quality. 

The effect of the “No Action” alternative on the licensed carriers would be multifaceted. 

• Public Safety would be put at risk. There are significant portions of I-17 and 

National Forests through which the highway travels, where there is little or no 

ability to communicate in case of emergency. If the carriers were prohibited from 

providing service, people in emergencies would continue to be at risk. 

• The carriers’ FCC licenses would be at risk. Each of the carriers are required as 

a condition of their licenses to serve a mandated portion of their service 

population by specified dates. If they do not meet these standards, they FCC 

can take possession of their licenses costing the carriers millions of dollars. 

• In all probability, the carriers would be forced to institute litigation against the 

Forest Service to be given the ability to locate communication facilities on public 

lands. The basis for the litigation would probably be violations of the 1996 

Telecommunications Act which proscribes limitations under which 

communication facilities cannot be denied: 1) unreasonable discrimination 

amongst carriers (the Forest Service has approved other similar sites for cellular 

providers that are not of significant value to PCS providers), and 2) have the 

effect of prohibiting the provision of personal wireless service. 
 17 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2 Affected Environment and Environmental Consequences of 

Individual Sites 

This section is broken into seven sub-sections, one for each proposed cellular site. Every 

sub-section will describe the site location and characteristics and will describe and analyze 

the environmental effects of the proposed sites on an individual basis. 
 

 18 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 1. Map showing the locations of all the proposed towers.
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 1 

Figure 2. Map showing the location of the proposed Onion Mountain site with utility 

alignment and Roadless Area boundary.
 

 2 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 3 - Photo of Onion Mountain Existing & Proposed 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 3 

3.2.1 ONION MOUNTAIN 

3.2.1.1 Onion Mountain Alternatives considered but dropped from Detailed 

Analysis 

Three alternative locations to the Onion Mountain site were evaluated relative to the 

existing proposed tower location. The alternative sites are referred to as Grassy Mountain, 

Reeves, and Plateau. In addition to Grassy Mountain, Reeves, and Plateau proposed sites, 

an alternative location for Onion Mountain was originally proposed. The original proposed 

site for Onion Mountain was within the boundaries of an inventoried roadless area. 

Because of potential conflicts with recently created national roadless management 

objectives, the site was moved out of the inventoried roadless area to the current proposed 

site. The following discusses the rationale for dropping the Onion Mountain Alternatives 

from detailed analysis: 

Grassy Mountain: 

The tower site located on Grassy Mountain would be visible for a total distance of 

3.9 miles, or for approximately 3.5 minutes from a vehicle traveling 75 miles per 

hour, along I-17 and only in the middle ground distance zone. Southbound travelers 

would be looking head-on at the tower for 2.4 miles (2.25 minutes). The tower 

would be located in a relatively undisturbed natural area and would attract some 

attention away from the natural landscape. The visual quality objective (VQO) for 

the middle ground area as viewed from I-17 would meet Partial Retention. The 

tower would be evident to the casual observer, but natural landscape would remain 

the dominant feature in the setting. This site was dropped from further analysis due 

to the visual impacts. 

When Grassy Mountain was dropped from further analysis, a combination of two sites 

(Reeves and Plateau) to serve this section of I-17 was analyzed. This was necessary 

because neither site on its own would provide the coverage required by the carriers. 

Reeves: 

The tower at the Reeves site would be visible for a total distance of 4.3 miles, or for 

approximately 3.5 minutes from a vehicle traveling 75 miles per hour along I-17, and 

only in the foreground and middle ground distance zones. Of the duration of view 

time, 74% of the viewer exposure (2.5 minutes) would be head-on from travelers on 

I-17. There would be tangential views of the tower in the foreground area for 0.6 

miles (29 seconds). The tower would be located in a relatively undisturbed natural 

area and would attract some attention away from the natural landscape. The visual 

quality objective (VQO) for the middle ground area as viewed from I-17 would meet 

Partial Retention. The tower would be evident to the casual observer, but natural 

landscape would remain the dominant feature in the setting. 

In addition to the identified visual issues, access to the Reeves site is problematic. 

The only viable access is directly from I-17, which would not be allowed by the 

Arizona Department of Transportation or the Federal Highway Administration. 

Without the use of I-17 for access, at least 5 miles of new road construction would 

be required. 
 

 4 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

This site was dropped from further analysis due to the visual impacts and access 

issues. 

Plateau: 

Located adjacent to Copper Canyon, the Plateau tower site would be visible for a 

total distance of 1.9 miles, or for approximately 1.75 minutes from a vehicle traveling 

75 miles per hour along I-17, and only in the middle ground distance zone. Of the 

duration of view time, 42% of the viewer exposure (45 seconds) would be viewed 

head-on by travelers on I-17. The portion of the interstate adjacent to the tower site 

is a notable section of I-17 because there is a significant change in elevation as the 

highway ascends from or descends into the Verde Valley. Within Copper Canyon, 

the surrounding mountainous terrain limits views. The tower would be located on 

top of a very prominent landform in the Canyon. Consequently, although the 

duration of view is relatively short compared to the other Onion Mountain 

alternatives, the tower would be an extremely prominent built feature and would 

attract attention away from the natural landscape. The VQO as viewed from I-17 

would meet Partial Retention within the middle ground area where the angle of view 

would be tangential, and meet Modification for the head-on view. The tower would 

be evident to the casual observer from tangential views, but natural landscape 

would remain the dominant feature in the setting. The tower would dominate the 

natural character of head-on views, but would reflect naturally established form, line, 

color, and texture. 

This site was dropped from further analysis due to the visual impacts. 

3.2.1.2 Proposed Action - Onion Mountain Site 

After analysis of the alternative sites, it was apparent that the Onion Mountain site was the 

best alternative visually. The proposed site is located to the south of Camp Verde, south of 

the Onion Mountain GPS benchmark. Take Exit #278 off I-17 to SR 169. Go west on SR 

169 and take the first dirt road on right. At the fork, go right for approximately one mile. 

Take the left fork for 2.7 miles to the site. 

Coordinates: 34-33-05.57 N / 111-59-29.13 W 

 SW1⁄4NE1⁄4 Sec 35 T14N R3E 

Access: Access is gained using an existing primitive road for 2.7 miles 

and a new road would be needed for an additional 1 mile. 

Some modifications to the existing jeep trail will be necessary. 

The access road will be limited to one surfaced travel lane. 

The road will be gated and locked at the new construction, 

near the intersection of the existing jeep trail. 

Proposed Lease Area: A 100' x 200' area south and east of Onion Mountain GPS 

benchmark. 

Proposed Structure: A 150-foot tower. 

Utility Status: Power and telephone located approximately 3 miles from site. 

Utilities will follow the access road as shown on figure 2. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 5 

RF Coverage Objective: This site located within the Prescott National Forest will 

provide coverage on I-17 between milepost 270 and milepost 

281. It will link coverage from the intersection of Cordes 

Junction to the Town of Camp Verde where there are existing 

towers. 

Carrier Antenna Heights: 

 VoiceStream - 150' Verizon - 140' US West - 130' 

 Alltel - 120' AT&T - 110' Sprint - 100'

3.2.1.2.1 Visual Quality 

The tower would be located in a relatively undisturbed natural area and would attract some 

attention away from the natural landscape. 

The VQO for the middle ground area as viewed from I-17 and SR 169 would meet Partial 

Retention. The tower and its associated facilities would be evident to the casual observer, 

but natural landscape would remain the dominant feature in the setting. 

Based on the results of the evaluation of the four alternative locations, the Onion Mountain 

site would be preferred as having the least visual impact on the visual character and 

inherent scenic quality of the landscape. It is the only site where the tower would have a 

backdrop of a landform and would not consistently be silhouetted above the horizon. The 

photographic simulation on an earlier page has the tower a bright white, however, one of 

the mitigation measures is to paint the tower a color that will blend with the background 

colors. The Onion Mountain tower would also have the shortest duration of head-on views 

from I-17 and SR 169. The Plateau tower site also has relatively short visibility duration, 

but would be an extremely prominent built feature. Reeves and Grassy Mountain both have 

relatively long visibility durations (approximately 3.5 minutes from a vehicle traveling 75 

mph) with the majority of the viewer angle being head-on. 

Recommended mitigation: (1) Painting the tower, fence and equipment building military 

olive drab; (2) Electrical power and phone lines should be placed underground within the 

access road prism; (3) All waste rock from road construction and site construction must be 

hauled off site to a designated disposal area; (4) Existing vegetation and trees will be 

protected where possible to help screen the facilities; (5) Large cuts or fills will not be 

allowed to level the lease area. 

3.2.1.2.2 ROS 

The Onion Mountain site is located in an area with a current ROS classification of roaded 

natural. Although the proposed site is 0.2 miles from the boundary of an inventoried 

Roadless Area, the ROS setting is roaded natural. The setting is considered roaded natural 

because of the proximity of I-17, located approximately 1.5 miles to the south. I-17 is 

clearly visible from the proposed site. Road building and power line construction will 

change the character of the adjacent areas because there will be development or structures 

where there were none. 

Development of a telecommunications site at the Onion Mountain site will require 
 

 6 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

construction of approximately one mile of new road and improvement to approximately 1.5 

miles of existing primitive road. It would also require development of approximately 3 miles 

of new utility corridor to bring in electrical power and telephone connection. Road building, 

power line construction, and construction of the telecommunication facilities will add to the 

impacts of human presence. However, the ROS setting will not change because the area is 

already altered by the presence of the Interstate highway. The existence of a new road to 

access the site will present management problems. Some of the impact can be mitigated 

by installation of a gate to restrict use of the road to authorized communication site 

management business only. 

Recommended mitigation: (1) Access road will be limited to 1 travel lane in width; (2) 

Access road will be gated at the point of new construction (see Figure 2) and will be 

restricted to communication site management use. 

3.2.1.2.3 Wildlife 

3.2.1.2.3.1 Special Status Species 

One Forest Service Sensitive species, the Arizona southwestern toad, could occur in the 

project area. This toad occurs in rocky streams, canyons, and floodplains with usually 

dense riparian vegetation. They breed in gently flowing waters. There is no breeding habitat 

within or affected by the project. There is a low probability that this toad may occur in the 

project area during the non-breeding season. The Onion Mountain site will not impact the 

southwestern toad (project record document #85). 

The Onion Mountain site would not impact threatened or endangered species because 

none are known to exist in the area. 

3.2.1.2.4 Vegetation 

The Onion Mountain site is located within the Great Basin Conifer Woodland Biotic 

Community. The associated flora consists of Rocky Mountain juniper, one-seed juniper, 

Rocky Mountain pinyon pine, Gambel oak, mountain mahogany, sumac, Arizona cliffrose, 

barberry, Apache plumes, bitterbrush, and grasses. 

A noxious weed survey and risk assessment must be completed prior to construction. If 

noxious weeds are found, preconstruction weed eradication following approved FS 

methods may be required. The risk assessment will identify necessary mitigation measures 

to reduce the risk of noxious weed spread. 

The Onion Mountain site would not impact threatened, endangered, or sensitive plant 

species because none are known to exist in the area. 

3.2.1.2.5 Cultural Resources 

Archaeological sites were located and avoided during the site selection and access routes 

of the proposed Onion Mountain alternatives. An archaeological survey has been 

completed and can be found in the project record. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 7 

3.2.1.2.6 Soils/Water2

This ecosystem is characterized by shallow to moderately deep soils, high surface rock 

fragments and moderately steep-to-steep slopes. Erosion hazard is moderate. 

Maintenance of vegetative ground cover is essential to minimize sheet and rill erosion. 

Soils are subject to trafficability problems and damage (compaction, puddling and 

displacement) when wet. The low bearing strength, shallow depth, high surface rock 

fragments and steep slopes of these soils may limit management activities. 

 Landform: Hills 

 Bedrock: Basalt/schist 

 Parent Material: Colluvium/residuum, Basalt/schist 

 Soil Conditions: Impaired/unsatisfactory 

 Hazards Erosion: Moderate 

 Mass Wasting:Slight 

 TES Number: 462 

Recommended mitigation: Restrict ground disturbing activities associated with 

construction, to periods when the soils are dry. 

 

2

 The soils evaluation for the Onion Mountain site located in the Prescott National Forest was obtained from the 

USDA FS publication: Terrestrial Ecosystems Survey of the Prescott National Forest.
 

 8 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 4. Map showing the location of the proposed Rarick Canyon site. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 9 

Figure 5 - Photo of Rarick Canyon Existing & Proposed 
 

 10 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.2 Proposed Action - Rarick Canyon 

This site is located on the west side of the I-17 southbound McGuireville Rest Stop. 

Alternative A A 185-foot tower is proposed for this site. 

Alternative B Replace the 2 existing light poles at the Mcquireville Rest 

Area with 3 to 6 160-foot light poles. 

Coordinates: 34-40-28.06 N / 111-46-24.48 W 

 SE1⁄4SW1⁄4 Sec 24 T15N R5E 

Access: Access to the site is via the ADOT Rest Stop parking lot. 

Proposed Lease Area: A 100' x 200' area adjacent to the ADOT Rest Stop. 

Proposed Structure: Alternative A: A 185-foot tower 

 Alternative B: Up to six 160-foot light poles will be used for 

this site 

Utility Status: Utilities are located within feet from the proposed site. 

Comments: Little or no tree removal will be necessary. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 291 and milepost 

300 and on Highway 179 from I-17 to the Village of Oak 

Creek. It will link coverage from the Town of Camp Verde to 

Rocky Park. 

Carrier Antenna Heights: 

 Alternative A – 

 VoiceStream - 185' Verizon - 175' US West - 165' 

 Alltel - 155' AT&T - 145' Sprint - 135' 

 Alternative B – All carriers at 160 feet if six towers. 

3.2.2.1 Visual Quality 

In the February 2000 document (project record document #46b), one wireless 

communication tower at 185 feet in height was considered at Rarick Canyon. An 

alternative to the 185-foot tower would be to replace the existing light poles at the rest area 

with up to six 160-foot light poles. Six light pole towers would represent a compromise in 

service for some of the carriers and an improvement for others identified for the lower 

positions under alternative A. All the carriers desire the higher positions that will provide 

better service. The tower positions were determined by lottery. A minimum of three light 

pole towers would be required to provide adequate service for this area and connection with 

the system. If there were less than six light pole towers it would require two carriers on a 

pole requiring the pole to be larger to support the antennae. This would increase the 

visibility of the pole because of the greater mass required to support multiple antennae. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 11 

Located at the McGuireville Rest Area along I-17, the tower(s) would be visible for a total 

distance of almost four miles with head-on views for approximately three miles regardless if 

they were 185 or 160 feet in height. Two high mass light poles are present at the rest area 

facility, one on either side of the interstate. One 185-feet wireless communication tower 

would repeat the line and form scale of these existing elements. Reducing the height of the 

towers by 25 feet would not make a notable difference in the visibility of the towers from I17, nor would they appear to be substantially lower in the context of their setting when 

compared to other existing elements. An increase in the number of towers would however, 

increase the prominence of the towers in the landscape, and create more visual contrast in 

terms of spatial dominance. Constructing six 160-foot wireless communication towers 

would substantially change the existing visual character of the McGuireville Rest Area, 

because of the mass of towers with their associated arrays and microwave dishes. 

Constructing three 160 foot high mass light pole towers would have close to the same 

visual effect as six poles because the three poles would have to be larger in diameter to 

support multiple antennae. ADOT has made other rest areas available for wireless carriers 

by replacing light towers and is willing to make the McGuireville Rest Area available for 

such uses. Replacing and adding light poles used as antennae support structures could 

enhance the rest stop and contribute to ADOT’s management objectives for the area. If 

additional light poles are used for antennae support structures, the existing lights at the rest 

area could be lowered, reducing the nighttime visual effects. The Rarick tower(s) will have 

a total distance visible of 3.9 miles or duration of visibility of 3.2 minutes from a vehicle 

traveling 75 miles per hour. 

Recommended mitigation: (1) If the light pole alternative is selected, the lights should be 

located lower on the pole than the existing lights. (2) Require wire-line telephone 

connections and not allow microwave dishes to reduce the mass of the structures for both 

alternatives. 

3.2.2.2 ROS 

Because this site is within the developed area of the I-17 McGuireville Rest Stop, operated 

and maintained by ADOT the ROS setting is rural. Development of a communication site at 

this location will not change the ROS setting. 

3.2.2.3 Wildlife

Cell phone equipment installation would have no effect on wildlife because this is a 

developed site with heavy vehicular traffic and high levels of human activity. There are no 

issues for threatened, endangered, or sensitive species because none are present. 

3.2.2.4 Vegetation 

Native vegetation would not be impacted by the project and there are no federally protected 

plant species at the rest stop. There may be habitat for a Forest Service sensitive plant, 

Polygala rusbyi, which has been recorded at the rest stop and the Middle Verde exit off 

Interstate 17. There is a low probability that the plant is actually located at the site because 

of the amount of disturbance that has occurred here as part of the rest area development. 

Recommended mitigation: Conduct surveys for Polygala rusbyi prior to construction. If 

the plant is present, mitigation such as seed collection or transplanting may be required. 
 

 12 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.2.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 

3.2.2.6 Soils/Water3

These soils contain significant quantities of calcium carbonate throughout the profile or at a 

relatively shallow depth. A pH of 8 or more is common and may hinder revegetation efforts. 

Excessive ground disturbance, which may bring more calcareous soil to the surface, should 

be avoided. There are no surface water resources on site. 

 Landform: Elevated Plains 

 Bedrock: Limestone 

 Parent Material: Residuum, Limestone 

 Soil Conditions: Satisfactory 

 Hazards Erosion: Slight 

 TES Number: 385 

The area is already hardened by the existing development. The proposed improvements 

will have no effect on soils. 

 

3

 The soils evaluations for sites located in the Coconino National Forest were obtained from the USDA FS 

publication: Terrestrial Ecosystems Survey of the Coconino National Forest.
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 13 

Figure 6. Map showing the location of the proposed Rocky Park site. 

.
 

 14 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 7 Photo of Rocky Park Existing & Proposed 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 15 

3.2.3 Proposed Action - Rocky Park 

Coordinates: 34-49-08.58 N / 111-35-38.78 W 

 SW1⁄4SW1⁄4 Sec 30 T17N R8E 

Access: Access is gained using a dirt road off Exit 315 leading into 

Rattlesnake Seasonal Closure. 

Proposed Lease Area: A 100' x 200' area. 

Proposed Structure: A 195-foot structure. 

Utility Status: Utilities are located 3.5 miles from the site. 

Comments: Little or no tree removal will be necessary. This site is located 

north of the ADOT Scenic View stop, approximately 1,000 

feet from the ridgeline. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 300 and milepost 

313. It will link coverage from Rarick Canyon to Woods 

Canyon. 

Carrier Antenna Heights: 

 VoiceStream - 175' Verizon - 165' US West - 195' 

 Alltel - 185' AT&T - 145' Sprint - 155' 

3.2.3.1 Visual Quality 

The tower would be located in a relatively undisturbed area and would attract some 

attention away from the natural landscape. Originally, this site was located in the vicinity of 

the traffic pullout. This site was relocated to the present location to satisfy Forest Service 

concerns over visual impacts. The VQO of retention for the immediate foreground and 

foreground area where the angle of view was head-on would meet Modification because 

the tower would dominate the natural character. The VQO of Retention for the foreground 

and middle-ground areas viewed from I-17 would meet Partial Retention for the tangential 

angle of exposure. The tower and its associated facilities would be evident to the casual 

observer, but natural landscape would remain the dominant feature in the setting from 

these distance zones and angle of exposure orientation. The Rocky Park tower will have a 

visibility distance total of 1.2 miles or a duration of visibility of 59 seconds from a vehicle 

traveling 75 miles an hour on I-17. The need for electrical power and telephone 

connections will add to the visual impact if overhead power lines are used, particularly in 

the areas close to I-17. 

Recommended mitigation: Underground utilities placed within the existing road where 

visible from I-17. 

3.2.3.2 ROS 

The current site setting is roaded natural. The area is within the Rattlesnake Seasonal 
 

 16 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Closure . The area is closed to motorized use from August 15 through December 31 to 

provide non-motorized hunting opportunities. An existing road will be used for access to 

the site. The carriers will need access to the site during the closure period in case of 

equipment failure and some routine maintenance. Access to the site can be controlled by 

use of a gate to restrict use of the road to authorized communication site personnel. 

Because the need for operational site visits will be infrequent, the presence of the site will 

not affect the quiet area or compromise the objectives for the area. The presence of a 

communication site at this location will not change the ROS from roaded natural. 

3.2.3.3 Wildlife 

Of all the tower sites, the Rocky Park site is the most important for wildlife because it is not 

directly adjacent the freeway and the forest is transitional ponderosa pine and oak to pinyon 

and juniper. Habitat at the edges of two or more vegetation communities provide a greater 

variety of resources and generally over a longer season than homogenous vegetation type. 

The ponderosa pine and oak to pinyon and juniper transition at the Rocky Park site marks 

the edge of the Mogollon Rim and these forests are winter range for deer, elk, and turkey. 

There are known turkey roost sites northeast of the site. This tower site is also located 

within the Forest Service Rattlesnake Seasonal Closure, an area closed to motor vehicles 

from August 15 to December 31 to provide recreation opportunities in areas undisturbed by 

vehicles. Primarily bow hunters use the Rattlesnake Seasonal Closure. The access road 

for the proposed site would be restricted to communication site management purposes. 

Restricting the use of the access road would maintain current conditions and management 

objectives for the area. 

This is an important fall concentration area for turkey as flocks join together in preparation 

for winter. Construction activities could impact turkey flock survivability over the winter, if 

they occurred in the fall. Deer and elk would most likely avoid the construction site, and up 

to 1⁄2 mile from it during the day. Deer and elk commonly return to their routine use areas at 

night when human disturbance ceases. Turkey are not active at night and are more 

intolerant of disturbance, therefore would be more impacted. Construction activities would 

not be compatible with the Quiet Area objectives. 

Recommended mitigation: (1) Gate the access road at the boundary of the quiet area. 

(2) Apply Rattlesnake closure dates to restrict construction during August 15 - December 31 

to reduce impacts to turkey and for compatibility with Quiet Area designation. 

3.2.3.3.1 Threatened and Endangered and Sensitive Wildlife Species 

At the proposed Rocky Park tower site, there may be potential habitat in grassy areas for 

Navajo Mountain Mexican vole. Less than one acre of habitat for this small mammal would 

be lost. There is foraging habitat for northern goshawks at the proposed site. No 

goshawks were found during goshawk surveys in the project area completed in 2000 as 

part of the Rocky Park Prescribed Burn Project. Northern goshawks will not be impacted 

because (1) no modification of nesting habitat will occur and (2) the minor loss of foraging 

habitat would not be discernable to this raptor that forages over expansive areas exceeding 

6,000 acres. Bald eagles can commonly be seen in the vicinity of this site. There are 

known bald eagle winter roost sites located greater than three quarters of a mile from the 

site. The Rocky Park site will not affect the bald eagle (project record document #60). 

There is no suitable Mexican spotted owl habitat at the site. Two seasons (1999 and 2000) 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 17 

of Mexican spotted owl surveys have been completed in the project area as part of the 

Rocky Park Prescribed Burn Project and no owls have been detected. The Mexican spotted 

owl will not be affected because (1) no modification of suitable owl habitat will occur and (2) 

construction activities are sufficiently distant from known breeding pairs so that no 

disturbance will occur. 

3.2.3.4 Vegetation 

The forest at the Rocky Park site is open ponderosa pine with oak and a few alligator 

juniper. The forest is generally characterized by grassy openings over approximately 45% 

of the area with scattered pine and oak over 25% of the area and clumps of small pines 

(jack pine) less than 10 inches diameter at breast height over about 20% of the area. 

Grass is the dominant understory herbaceous plant. As discussed above, the Rocky Park 

site is at an ecotone where ponderosa pine and oak give way to pinyon and alligator juniper 

forest within one half mile south and west of the site. A greater variety of herbaceous 

plants generally characterize transitional communities because associated plants from both 

forests intergrade. Appendix C documents all plant species identified during field surveys. 

No high priority Forest Service weed species were identified at the Rocky Park site. Minor 

occurrences of mullein, toadflax, yellow sweet clover, and cheatgrass were documented 

along Forest Road 80, the access to the site, and mullein, cheat grass, and yellow sweet 

clover were documented at the site. 

3.2.3.4.1 Sensitive Plant Species 

Three Forest Service sensitive plant species were targeted during a September field survey 

of the tower site: Rusby's milkvetch (Astragalus rusbyi), Flagstaff beardtongue (Penstemon 

nudiflorus), and Mt. Dellenbaugh sandwort (Arenaria aberans). No sensitive plant species 

were found during the survey. 

3.2.3.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 

3.2.3.6 Soils/Water

These soils are subject to trafficability problems and soil damage (compaction, puddling 

and displacement) when wet. Upon removal of overstory, alligator juniper and Gambel oak 

may offer significant plant competition. There are no surface water resources at the site. 

 Landform: Elevated Plains 

 Bedrock: Basalt 

 Parent Material: Residuum, Basalt/cinders 

 Soil Conditions: Satisfactory 

 Hazards Erosion: Slight 

 Windthrow: Severe, low strength 

 Plant Comp: Moderate, alligator juniper, Gambel oak 

 TES Number: 578 

Recommended mitigation: Restrict ground disturbing activities to periods when the soils 

are dry. 
 

 18 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 8. Map showing the location of the proposed Woods Canyon site. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 19 

Figure 9 Photo of Woods Canyon Existing & Proposed 
 

 20 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.4 Proposed Action - Woods Canyon 

 Alternative A A 180-foot structure is proposed for the site. 

Alternative B Two 160-foot structures. 

Coordinates: 34-51-06.18 N / 111-36-30.24 W 

 NE1⁄4SW1⁄4 Sec 13 T17N R7E 

Access: Access is gained using a dirt road west off Exit 315 (Woods 

Canyon Road). 

Proposed Lease Area: A 100' x 200' area. 

Proposed Structure: Alternative A: A 180-foot structure 

 Alternative B: Two 160-foot structures 

Utility Status: Utilities are located 2.5 miles from the site. 

Comments: Minimal tree removal will be necessary. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 313 and milepost 

320. It will link coverage from Douglas Mountain to Rocky 

Park. 

Carrier Antenna Heights: 

 Alternative A – 

 VoiceStream - 160' Verizon - 140' US West - 170' 

 Alltel - 130' AT&T - 180' Sprint - 150' 

 Alternative B: 

 AT&T and Quest –160’ 

 VoiceStream and Sprint – 150’ 

 Verizon and Alltell – 140’ 

3.2.4.1 Visual Quality 

Constructing two 160-foot towers instead of one 180-foot tower at the proposed Woods 

Canyon site would substantially increase the spatial prominence of these built features in 

the natural landscape. The height differential would slightly lower the visibility of the towers 

from the interstate; however, the construction of two towers with their associated arrays and 

microwave dishes would attract more attention than a single tower. The construction of the 

two towers would also increase the area of disturbance compared with one tower, and 

lower the inherent scenic integrity of the area immediately adjacent to the tower site until 

the site can revegetate. The Woods Canyon tower(s) will have a distance visible total of 

1.5 miles or a duration of visibility of 1.3 minutes from a vehicle traveling 75 miles per hour 

on I-17. The need for electrical power and telephone connections will contribute to visual 

impacts if overhead lines are used, particularly in the area where the proposed access road 

and utility corridor are close to I-17. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 21 

Recommended mitigation: Underground utilities placed within the existing road that will 

be used for access where visible from I-17. 

3.2.4.2 ROS 

Because of the proximity of I-17 to the site, current ROS setting at the proposed site is 

Roaded/Natural. Development of a communication site at this location will not change the 

ROS setting of the area. 

3.2.4.3 Wildlife 

The Wood's Canyon site is located next to the right-of-way fence of I-17 and the Wood's 

Canyon exit, which decreases the habitat potential at the site for deer, elk, turkey, and 

some birds. Wildlife potential is also low at this site because there is no surface water at or 

near the site, neither seasonal nor perennial. There is important deer, elk, and turkey 

habitat in the general vicinity. The tower site is located within and near the boundary of the 

Woods Seasonal Closure area, which is closed to vehicles between December 15 and April 

01 to minimize disturbance to big game winter habitat. Perimeter roads along the Woods 

Seasonal Closure are open to vehicles. Big game would not be impacted by construction 

or operation or maintenance of the site because of its location adjacent to the freeway. 

3.2.4.3.1 Threatened and Endangered and Sensitive Wildlife Species 

There may be potential habitat in grassy areas for Navajo Mountain Mexican vole at the 

Woods Canyon tower site. Less than one acre of habitat for this small mammal would be 

lost. The forest architecture and composition is good foraging habitat for northern 

goshawks, but the stand is too open for nest habitat. No goshawks were found during 

goshawk surveys in the project area completed in 2000 as part of the Rocky Park 

Prescribed Burn Project. Northern goshawks will not be impacted because (1) no 

modification of nesting habitat will occur and (2) the minor loss of foraging habitat would 

not be discernable to this raptor that forages over expansive areas exceeding 6,000 acres. 

Bald eagles may forage in the project vicinity as they search along the freeway for roadkilled deer and elk carcasses. The Wood Canyon site will not affect the bald eagle (project 

record document #65). There is no suitable Mexican spotted owl habitat at the site. Two 

seasons (1999 and 2000) of Mexican spotted owl surveys have been completed in the 

project area as part of the Rocky Park Prescribed Burn Project and no owls have been 

detected. The Mexican spotted owl will not be affected because (1) no modification of 

suitable owl habitat will occur and (2) construction activities are sufficiently distant from 

known breeding pairs so that no disturbance will occur. 

3.2.4.4 Vegetation 

The Woods Canyon site is located in a broad swale. The forest is open second-growth 

ponderosa pine with scattered oaks and small clumps of pole-sized ponderosa pines. 

Understory plants are primarily grasses. The low summit of a ridge marking a lava flow just 

west of the site is a grassy meadow with sparse pines and rare juniper. Appendix C 

documents all plant species identified at the Woods Canyon site. No dense weed 

populations were noted at this site nor along the freeway exits. Toadflax is the dominant 

weed and was estimated at less than one percent of all ground cover plants. 
 

 22 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.4.4.1 Sensitive Plant Species 

Three Forest Service sensitive plant species were targeted during a September field survey 

of the tower site: Rusby's milkvetch (Astragalus rusbyi), Flagstaff beardtongue (Penstemon 

nudiflorus), and Mt. Dellenbaugh sandwort (Arenaria aberans). No sensitive plant species 

were found during the survey. 

 

3.2.4.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 

3.2.4.6 Soils/Water 

These soils are subject to trafficability problems and soil damage (compaction, puddling 

and displacement) when wet. Shallow soils and surface rock fragments limit most 

management activities. Upon removal of overstory, alligator juniper and Gambel oak may 

offer significant plant competition. There are no surface water resources at the proposed 

site. 

 Landform: Elevated Plains 

 Bedrock: Basalt 

 Parent Material: Residuum, Basalt/cinders 

 Soil Conditions: Satisfactory 

 Hazards Erosion: Slight 

 Windthrow: Severe, too shallow 

 Plant Comp: Severe, alligator juniper, Gambel oak 

 TES Number: 579 

Recommended mitigation: Restrict ground disturbing activities to periods when the soils 

are dry. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 23 

Figure 10. Map showing the location of the proposed Douglas Mountain site. 
 

 24 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 11- Photo of Douglas Mountain Existing & Proposed 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 25 
 

 26 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.5 Proposed Action - Douglas Mountain 

This site is located within the footprint of ADOT Maintenance Facility. A 190-foot structure 

is proposed. Utilities are located at the site. No tree removal would be necessary. 

Coordinates: 34-54-52.2 N / 111-38-43.1 W 

 NW1⁄4SW1⁄4 Sec 27 T18N R7E 

Access: Access is gained using Schnebly Hill Road exit into ADOT 

Maintenance Facility. 

Proposed Lease Area: A 100' x 200' area. 

Proposed Structure: A 190-foot structure 

Utility Status: Utilities are located at the site. 

Comments: No tree removal will be necessary. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 320 and milepost 

326. It will link coverage from Ritter Mountain to Woods 

Canyon. 

Carrier Antenna Heights: 

 VoiceStream - 180' Verizon - 170' US West - 160' 

 Alltel - 190' AT&T - 140' Sprint - 150' 

3.2.5.1 Visual Quality

An alternative site to the ADOT maintenance yard was considered in an attempt to mitigate 

visual issues. This alternative site is located on a hill approximately one half mile southwest 

of the ADOT Maintenance Yard at the Schnebly Hill Road exit. A 190-foot structure would 

also be required at this alternative site. Utilities are located in proximity to the site. Access 

is gained using Schnebly Hill Road. The alternative to the ADOT site was based on 

recommendations in the February 2000 document in an attempt to reduce the head-on 

views of the facility. However, further analysis indicated that if the tower were located at the 

ADOT Maintenance Yard, there would probably be no difference in the distance or duration 

of view or the angle of viewer exposure from I-17 and the structure would still need to be 

190 feet tall. The existing buildings and equipment at the ADOT Yard already lowers the 

visual integrity of the site. Construction of the communication tower within the maintenance 

facility would not substantially change the existing visual character of this portion of the 

forest, and would require minimal clearing of the vegetation as compared to the alternative 

Douglas Mountain site. No additional vegetation clearing for maintenance access or power 

would be required if the tower were built in the ADOT Maintenance Yard. In addition, there 

would be no need for new road or utilities construction. This proposed tower at the ADOT 

yard would have a distance visible total of 3.4 miles or a duration of visibility of 3.2 minutes 

from a vehicle traveling 75 miles per hour on I-17. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 27 

3.2.5.2 ROS 

The current ROS setting of the proposed site is Roaded Natural. The site is within an area 

previously disturbed by the Little Antelope Maintenance Yard, operated under special use 

permit from the Forest Service by ADOT. Development of a communication site at this 

location will not change the ROS setting. 

3.2.5.3 Wildlife 

Tower construction at the ADOT maintenance yard would have no effect on wildlife. This 

developed site is next to the I-17 freeway and the busy Schnebly Hill Road, and the current 

level of human activity and traffic decreases the habitat potential for deer, elk, turkey, and 

some birds. Lack of any surface water near the proposed site also reduces wildlife habitat. 

3.2.5.3.1 Threatened and Endangered and Sensitive Wildlife Species 

The original proposed site on Oak Hill was moved to the ADOT Maintenance camp to avoid 

impacts to a known goshawk nesting area. In addition to visual impacts, the original site 

would also have required road construction and tree removal, adding to resource impacts. 

There are no issues for threatened and endangered or sensitive wildlife species at the 

ADOT maintenance yard site. The site is too developed and too close to the freeway for 

most wildlife species. Goshawk and Mexican spotted owl surveys were completed the 

summer of 2000 in the vicinity of this project area and no goshawks or Mexican spotted 

owls were found. The site is sufficiently distant from the nearest known goshawk and 

Mexican spotted owl nesting areas so that no disturbance to breeding behavior will occur. 

Bald eagles may forage in the project vicinity as they search along the freeway for roadkilled deer and elk carcasses. The Douglas Mountain site will not affect the bald eagle 

(project record document #63). 

3.2.5.4 Vegetation 

Native vegetation would not be impacted by tower installation at the ADOT yard. An exotic 

weed species, diffuse knapweed, was identified at the maintenance yard and at the I-17 

Schnebly Hill exit. Diffuse knapweed is spreading along the Schnebly Hill Road from the 

freeway exit. Appendix C documents all plant and weed species identified in the vicinity of 

the Douglas Mountain site. Control of knapweed at the site will be coordinated with ADOT. 

Construction and maintenance equipment/vehicles leaving this site could spread 

knapweed. Standard operating procedures requiring equipment be cleaned will minimize 

spread. 

3.2.5.4.1 Sensitive Plant Species 

No sensitive plant species were found during September field surveys. 

3.2.5.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 
 

 28 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.5.6 Soils/Water

This map unit has a severe erosion hazard. Maintenance of vegetative groundcover is 

essential to prevent sheet and rill erosion. These soils are subject to trafficability problems 

and soil damage (compaction, puddling and displacement) when wet. Natural regeneration 

potential is high. There are no surface water resources on the site. 

 Landform: Cinder Cones 

 Bedrock: Basalt 

 Parent Material: Colluvium, Cinders/Basalt 

 Soil Conditions: Satisfactory 

 Hazards Erosion: Severe 

 Mass Wasting:Slight 

 Windthrow: Moderate, low strength 

 Plant Comp.: Moderate, Gambel oak, New Mexico locust

 TES Number: 565

Recommended Mitigation: Restrict ground disturbing activities to periods when the soils 

are dry. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 29 

Figure 12. Map showing the location of the proposed Ritter Mountain site. 
 

 30 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 13 Photo of Ritter Mountain Existing & Proposed 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 31 

3.2.6 Proposed Action - Ritter Mountain 

This site is east of the Yavapai County Transfer Station off of I-17 at the Willard Springs 

Road exit. 

Alternative A A 195-foot structure is proposed for this site. 

Alternative B Two 180-foot structures. 

Coordinates: 34-58-16.43 N / 111-41-23.49 W 

 NE1⁄4SW1⁄4 Sec 1 T18N R6E 

Access: Access is gained using paved road off Exit 326 that leads to 

Transfer Station. 

Proposed Lease Area: A 100' x 200' area. 

Proposed Structure: Alternative A: A 195-foot structure 

 Alternative B: Two 180-foot structures 

Utility Status: Utilities are located near the site. 

Comments: Minimal tree removal will be necessary. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 326 and milepost 

333. It will link coverage from James Canyon for Douglas 

Mountain. 

Carrier Antenna Heights: 

 Alternative A – 

 VoiceStream - 195' Verizon - 185' US West - 175' 

 Alltel - 165' AT&T - 155' Sprint - 145' 

 

 Alternative B: 

 VoiceStream and Verizon – 180’ 

 Quest and Alltell – 170’ 

 AT&T and Sprint – 160’ 

3.2.6.1 Visual Quality 

Similar to Woods Canyon, constructing two 180-foot towers instead of one 195-foot tower at 

the proposed Ritter Mountain site would substantially increase the spatial dominance of 

these built features in the natural landscape. The height differential would not noticeably 

lower the visibility of the towers from the interstate. The construction of two towers with 

associated arrays and microwave dished would attract more attention that a single tower. 

The construction of two towers would also increase the area of disturbance compared with 

one tower, and lower the scenic integrity of the area immediately adjacent to the tower site 

until the site can revegetate. This tower(s) will have a distance visible total of 1.1 miles or a 

duration of visibility of 51 seconds from a vehicle traveling 75 miles per hour on I-17. 
 

 32 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.6.2 ROS

Because the proposed site is located adjacent to the Coconino County Transfer Station and 

is within an area previously disturbed by past mining and the County landfill operations, the 

ROS setting is Roaded Natural. Development of a communication site at this location will 

not change the ROS setting. 

3.2.6.3 Wildlife 

Wildlife habitat potential is low at the proposed Ritter Mountain site because this site is next 

to an old landfill and the Yavapai County waste transfer station. There is moderate traffic 

into the transfer station and the level of human activity and vehicles discourage large game 

animals and turkey, as well as a variety of other wildlife species, such as owls and hawks. 

Lack of surface water at or near the site also decreases the wildlife potential in the area. 

There is no key wildlife habitat information on file at the Coconino National Forest District 

offices for this site. 

3.2.6.3.1 Threatened and Endangered and Sensitive Wildlife Species 

There may be potential habitat for Navajo Mountain Mexican vole at the site and across the 

old landfill area. Less than one acre of habitat for this small mammal would be lost. Bald 

eagles have been historically observed in this vicinity, attracted by the former landfill where 

they scavenged. Closure of the landfill has decreased the potential for eagles at the site, 

though eagles may occasionally forage and perch in the general vicinity. The Ritter site will 

not affect the bald eagle (project record document #66). The site is not suitable habitat for 

Mexican spotted owls or northern goshawks. The site is sufficiently distant from the nearest 

known goshawk and Mexican spotted owl nesting areas, so that no disturbance to breeding 

behavior will occur.

3.2.6.4 Vegetation 

Native vegetation has been cleared and scraped at the site pad and the dominant plants 

are grasses and native and non-native weeds and herbs. Appendix C lists all plant species 

identified in the project area, including exotic weeds. Diffuse knapweed was identified at 

the site, and this is a Forest Service high priority weed for control. Knapweed was 

documented growing on the road shoulder from the transfer station to approximately one 

half mile east of the station. Coconino County is currently preparing a weed management 

plan for the transfer station and access road. 

3.2.6.4.1 Sensitive Plant Species 

Three Forest Service sensitive plant species were targeted during a September field survey 

at the Ritter Mountain site: Rusby's milkvetch (Astragalus rusbyi), Flagstaff beardtongue 

(Penstemon nudiflorus), and Mt. Dellenbaugh sandwort (Arenaria aberans). No sensitive 

plant species were found. 

3.2.6.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 33 

3.2.6.6 Soils/Water 

These soils are subject to trafficability problems and soil damage (compaction, puddling 

and displacement) when wet. This component is well suited to timber production. Natural 

regeneration, reforestation and revegetation potentials are high. There are no surface 

water resources on the proposed site. 

 Landform: Elevated Plains 

 Bedrock: Basalt 

 Parent Material: Residuum, Basalt/cinders 

 Soil Conditions: Satisfactory 

 Hazards Erosion: Slight 

 Windthrow: Severe, low strength 

 Plant Comp.: Slight, Gambel oak 

 TES Number: 582 

Recommended mitigation: Restrict ground disturbing activities to periods when the soils 

are dry. 
 

 34 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Figure 14. Map showing the location of the proposed James Canyon site. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 35 

Figure 15 - Photo of James Canyon Existing & Proposed 
 

 36 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

3.2.7 Proposed Action - James Canyon 

Coordinates: 35-03-06.52 N / 111-41-08.54 W 

 NE1⁄4NE1⁄4 Sec 7 T19N R7E 

Access: Access is gained using an existing primitive road located just 

west of Exit 331 (Kelly Canyon Exit) 

Proposed Lease Area: A 100' x 200' area. 

Proposed Structure: A 170-foot structure 

Utility Status: Utilities are located near to the site. 

Comments: Some tree removal will be necessary for both access road 

and site. 

RF Coverage Objective: This site located within the Coconino National Forest will 

provide coverage on I-17 between milepost 333 and the 

Flagstaff area. It will link coverage from Ritter Mountain to 

sites on private fee land to the north. 

Carrier Antenna Heights: 

 VoiceStream - 150' Verizon - 160' US West - 170' 

 Alltel - 120' AT&T - 130' Sprint - 140' 

3.2.7.1 Visual Quality 

The James Canyon site tower would be visible for a total distance of one mile or for 

approximately 46 seconds along I-17 in the foreground and middleground distance zones. 

Of the duration of view time, 52% of the viewer exposure (24 seconds) would be head-on 

from travelers going southbound on I-17. The James Canyon tower would not be visible 

from SR 89A. 

3.2.7.2 ROS 

The current ROS setting at the proposed site is Roaded Natural. The proposed site is 

located within .2 miles of I-17 and near an existing overhead electric line. Development of a 

communication site at this location will not change the ROS setting of the area. 

3.2.7.3 Wildlife 

There is no key wildlife habitat information on file at the Coconino National Forest District 

offices for the James Canyon site. The wildlife potential is evaluated as low at this 

proposed tower pad. There is no seasonal or perennial surface water, and the site is 

located just west of the I-17 freeway on a ridge summit. Freeway traffic noise is especially 

noticeable, which may discourage some wildlife species. Numerous wildlife species, 

including black bear, can be found to the south in the canyon that this site is named for. 

The canyon is used as a big game movement corridor. Construction, operation, and 

maintenance of the site will not affect big game use of the nearby canyon because of 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 37 

topographic and distance separation. 

3.2.7.3.1 Threatened and Endangered and Sensitive Wildlife Species 

There may be potential habitat for Navajo Mountain Mexican vole in small forest openings, 

and especially in the cleared area beneath the phone line along the east boundary of the 

site. Less than one acre of habitat for this small mammal would be lost. The surrounding 

forest is suitable foraging habitat for northern goshawks and marginal foraging habitat for 

Mexican spotted owls, but the forest is too open for nesting habitat for either of these birds. 

Mexican spotted owl surveys conducted near the project area in 1990, 1991, 1993, and 

2000 did not document owls within the project area. The James Canyon site will not affect 

the Mexican spotted owl (project record document #67). Northern goshawk surveys in the 

project area were completed in 2000 for the Grand Canyon Forest Partnership project and 

no goshawks were detected. There are known northern goshawk and Mexican spotted owl 

nest sites in the general project area, but these are topographically separated from the site 

such that construction activities would not disturb birds during the breeding season. 

Wintering bald eagles may travel through the project area but would not be affected by the 

project (project record document # 67). 

3.2.7.4 Vegetation 

This site is characterized by 40 to 50 percent tree cover, primarily ponderosa pines less 

than twelve inches diameter at breast height. Approximately five percent of the forest stand 

is Gambel oak. There is little herbaceous ground cover at the site because only a thin 

veneer of soil covers volcanic bedrock. The forest is not multilayered and there is minimal 

down and dead logs and woody debris. Exotic weeds were minimal at this site composed 

only of minor occurrences of cheat grass. Diffuse knapweed, a Forest Service high priority 

exotic weed, was documented growing at the James Canyon exit off the I-17 freeway and 

for approximately one half mile northwest along the FR 631 access road. 

3.2.7.4.1 Sensitive Plant Species

Three Forest Service sensitive plant species were targeted during a September field survey 

at the James Canyon site: Rusby's milkvetch (Astragalus rusbyi), Flagstaff beardtongue 

(Penstemon nudiflorus), and Mt. Dellenbaugh sandwort (Arenaria aberans). No sensitive 

plant species were found. 

3.2.7.5 Cultural Resources 

No archaeological sites were found. An archaeological report has been completed and can 

be found in the project record. 

3.2.7.6 Soils/Water 

These soils are subject to trafficability problems and soil damage (compaction, puddling 

and displacement) when wet. Shallow soils and surface rock fragments severely limit most 

management activities. There are no surface water resources on the proposed site. 

 Landform: Elevated Plains 

 Bedrock: Basalt 

 Parent Material: Residuum, Basalt/cinders 
 

 38 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

 Soil Conditions: Satisfactory 

 Hazards Erosion: Slight 

 Windthrow: Severe, too shallow 

 Plant Comp.: Severe, Gambel oak 

 TES Number: 585 

Recommended mitigation: Restrict ground disturbing activities to periods when the soils 

are dry. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 39 

4.0 CONSULTATION WITH OTHERS 

4.1 List of Persons Consulted 

On April 10, 2000, a proposal letter for the proposed wireless communication towers 

located along I-17 between Flagstaff and just south of Camp Verde was mailed out to 1204 

addresses which includes organizations, agencies, and individuals on the Prescott and 

Coconino National Forests’ Land management Plan mailing list. On April 24, 2000, an 

additional 6 copies were mailed out. 

On April 23, 2000, an article appeared in the Arizona Daily Sun. 

As of June 12, 2000, only 35 responses were received either via telephone, mail, or e-mail. 

Only 6 of these mailings were returned due to insufficient or moved addresses. 

The results of the comments are as follows: 

 In Favor: 21 

 Against: 9 

 Neutral: 5 

Some of those in favor of the towers still listed issues of concern: 

• visibility (5) 

• removal of towers when obsolete/length of usefulness of towers (4) 

• restricted easements/access (3) 

• underground utilities (2) 

• use smaller towers/more sites (2) 

• siting James Canyon higher (1) 

• devaluation of property (1) 

• minimize impacts to habitat (1) 

• no clear cutting (1) 

The main issues of oppositions for the proposal: 

• visual (6) 

• believe that towers would only be for profit of the providers/money (2) 

• effects of microwaves on plants and animals (2) 

• opposed to cellular users, towers, payphones are fine 

• opposed to new roads 

• towers will become obsolete 

• use existing sites (Mingus, Elden, etc...) 

• use call boxes at strategic sites 

• shorter towers are needed 

• Forest Service should follow own guidelines (height <200', non-reflective paint, no 

guy wires) 

• communication towers are responsible for killing 4 million migrating birds 

 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 57 

APPENDIX A 

Typical Site Layout 
 

 58 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

APPENDIX B 

Threatened, Endangered, and Special Status 

Plant Species Considered in Project Area

Appendix sources include: species from the Coconino National Forest sensitive species list 

for the Peaks and Mormon Lake Districts, Threatened and Endangered species listed for 

Coconino County (from US Fish and Wildlife Service Internet web site--

http://ifw2es.fws.gov/endangeredspecies/lists/ListSpecies.cfm), and Wildlife Species of 

Concern in the State of Arizona from the Draft document, Wildlife of Special Concern in 

Arizona, October 14, 1996, Nongame Branch, Arizona Game and Fish, Phoenix. 

Habitat evaluations for each species were determined by comparing project area features 

(geography, elevation, topography, geology, and vegetation) with the species life history, 

habitat, and range as described in published resources and from occurrence information on 

file at the Coconino National Forest Mormon Lake and Peaks Districts offices. 

Common Name Species Name Federal, Arizona 

State, and Forest 

Service Status

Habitat Evaluation 

along I-17 

Corridor

Mammals 

1 black-footed ferret Mustela nigripes Endangered no 

2 Navajo Mtn. 

Mexican vole 

Microtus mexicanus 

Navaho

FS Sensitive4

 yes 

3 Hualpai Mexican 

vole 

Microtus mexicanus 

hualpaiensis

Endangered no 

4 Wupatki Arizona 

pocket mouse 

Perognathus amplus 

cineris

FS Sensitive no 

Birds 

5 American peregrine 

falcon 

Falco peregrinus anatum FS Sensitive no 

6 bald eagle Haliaeetus leucocephalus Threatened yes 

7 California condor Gymnogyps californianus Endangered no 

8 Mexican spotted owl Strix occidentalis lucida Threatened yes 

9 northern goshawk Accipiter gentilis FS Sensitive yes 

10 Southwestern willow 

flycatcher 

Empidonax traillii extimus Endangered no 

Reptiles 

11 narrow-headed garter 

snake 

Thamnophis rufipunctatus FS Sensitive no 

12 northern leopard frog Rana pipiens FS Sensitive no 

Fish 

13 humpback chub Gila cypha Endangered no 

14 Little Colorado 

spinedace 

Lepidomeda vittata Threatened no 

15 razorback sucker Xyrauchen texanus Endangered no 

Snail 

 

4 Endangered or Threatened status is the US Fish and Wildlife Service federal designation. FS Sensitive notes 

species not protected by the Endangered Species Act, but species that are managed for by the US Forest 

Service. 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 59 

Common Name Species Name Federal, Arizona 

State, and Forest 

Service Status

Habitat Evaluation 

along I-17 

Corridor

16 Kanab ambersnail Oxyloma haydeni 

kanabensis

Endangered no 

Insects 

17 Arynxa giant skipper Agathymus aryxna FS Sensitive no 

18 Freeman's agave 

borer 

Agathymus bauer 

freemani

FS Sensitive no 

19 early elfin Incisalia fotis FS Sensitive no 

20 Maricopa tiger beetle Cicindela oregona 

Maricopa

FS Sensitive no 

21 spotted skipperling Piruna polingii FS Sensitive no 

22 mountain silverspot 

butterfly 

Speyeria nokomis nitocris FS Sensitive no 

23 blue-black silverspot 

butterfly 

Speyeria nokomis nokomis FS Sensitive no 

Plants 

24 Arizona bugbane Cimicifuga arizonica FS Sensitive no 

25 Arizona sneezeweed Helenium arizonicum FS Sensitive no 

26 bearded gentian Gentiana barbellata FS Sensitive no 

27 Brady pincushion 

cactus 

Pediocactus bradyi Endangered no 

28 cliff fleabane Erigeron saxatilis FS Sensitive no 

29 crenulate moonwort Botrychium crenulatum FS Sensitive no 

30 disturbed rabbitbrush Chrysothamnus molestus FS Sensitive no 

31 Flagstaff 

beardtongue 

Penstemon nudiflorus FS Sensitive yes 

32 Flagstaff pennyroyal Hedeoma diffusum FS Sensitive no 

33 Mt. Dellenbaugh 

sandwort 

Arenaria aberans FS Sensitive yes 

34 Navajo sedge Carex specuicola Threatened no 

35 Polygala Polygala rusbyi FS Sensitive yes5

36 San Francisco Peaks 

groundsel 

Senecio franciscanus Threatened no 

37 Rusby's milkvetch Astragalus rusbyi FS Sensitive yes 

38 sentry milkvetch Astragalus cremnophylax 

cremnophylax

Endangered no 

39 Siler pincushion 

cactus 

Pediocactus sileri Threatened no 

40 Sunset Crater 

beardtongue 

Penstemon clutei FS Sensitive no 

41 Welsh's milkweed Asclepias welshii Threatened no 

 

5

 Polygala rusbyi is considered only for the Rarick Mountain site at the McGuireville rest stop. 
 60 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

APPENDIX C 

Plant Species Lists from Northland Research, Inc. 

September 1999 Field Surveys 

Plant Species Identified during September 2000 field work for the proposed Cell Tower Array along Interstate 17 from Flagstaff south tand the Rocky Park site (Northland Research, Inc.) 

Family Species Common Name I-17 

Corridor

James 

Canyon

Ritter 

Mtn.

Douglas 

Mtn.

Dougl

Borr

TREES Cupressaceae Juniperus deppeana Alligator Juniper X X 

Cupressaceae Juniperus osteosperma Utah Juniper X Cupressaceae Juniperus scopulorum Rocky Mountain Juniper X 

Pinaceae Pinus ponderosa Yellow Pine X X X Fagaceae Quercus cf. turbinella Shrub Live Oak X 

Fagaceae Quercus gambelii Gambel Oak X X 

Fabaceae Robinia neomexicana New Mexican Locust X X 

Salicaceae Salix sp. Willow X SHRUBS Asteraceae Brickellia californica California brickelbush X Rhamnaceae Ceanothus fendleri Buckbrush/ Redroot X X Fagaceae Quercus turbinella Shrub Live Oak Anacardiaceae Rhus ovata Sugar Sumac X 

Rosaceae Amelanchier utahensis Utah Serviceberry X 

Rosaceae Cercocarpus montanus Mountain Mahogany X 

Rosaceae Rosa woodsii Wood's Rose X  Unknown Shrub X NATIVE FORBS Anacardiaceae Rhus radicans Poison Ivy X Apiaceae Psuedocymopterus 

montana 

Mountain Parsley 

Asclepidaceae Asclepias sp. Milkweed X 

Asteraceae Achillea millefolium Yarrow X X 

Asteraceae Antennaria marginata Pussytoes X 

Asteraceae Antennaria parviflora Pussytoes X X Asteraceae Antennaria rosulata Rosy Pussytoes X Asteraceae Artemisia carruthii Sagewort X X X 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 61 

Family Species Common Name I-17 

Corridor

James 

Canyon

Ritter 

Mtn.

Douglas 

Mtn.

Dougl

Borr

Asteraceae Artemisia ludoviciana Sagewort X 

Asteraceae Aster falcatus Prairie White Aster X X 

Asteraceae Cirsium arizonica Arizona Thistle X 

Asteraceae Erigeron flagellaris Trailing Fleabane X Asteraceae Erigeron neomexicanus New Mexican Fleabane X 

Asteraceae Hieracium fendleri Hawkweed X Asteraceae Hymenopappus filifolia Fineleaf Hymenopappus X X 

Asteraceae Hymenoxys rusbyi Rusbyi's Goldflower Asteraceae Senecio multilobatus Groundsel X X Asteraceae Solidago sp. Goldenrod X X X Asteraceae Unknown Asteraceae Sunflower family Berberidaceae Berberis repens Oregon Grape X 

Brassicaceae Arabissp. Rock Cress X Brassicaceae Thlaspi montana Alpine Pennycress 

Cactaceae Echinocereussp. Hedgehog Cactus X Cactaceae Mammillaria sp. Pincushion Cactus X 

Cactaceae Opuntia sp. Prickly Pear X 

Caryophyllaceae Arenaria lanuginosa Sandwort X Ericaceae Pterospora andromedea Woodland Pinedrops X 

Fabaceae Astragalus sp. Locoweed X X X Fabaceae Dalea albiflora Prairie clover X 

Fabaceae Dalea sp. Prairie clover X Fabaceae Desmodium sp. Tick Clover X Fabaceae Hoffmanseggia sp. Hoffmanseggia X X Fabaceae Lotus wrightii Deervetch X X X 

Fabaceae Lupinus sp. Lupine X X 

Fabaceae Thermopsis pinetorum Goldenbanner X 

Fabaceae Unknown Fabaceae Pea Family Fabaceae Unknown Fabaceae #2 Pea Family X Fabaceae Vicia americana American Vetch X X Geraniaceae Geranium caespitosa Wild geranium X 

Iridaceae Iris missouriensis Rocky Mountain Iris X Lamiaceae Monarda pectinata Horsemint X 

Liliaceae Allium sp. Wild Onion 

Liliaceae Echeandia flavescens Torrey's Craglily 

Linaceae Linum neomexicanum Yellow Flax 
 62 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Family Species Common Name I-17 

Corridor

James 

Canyon

Ritter 

Mtn.

Douglas 

Mtn.

Dougl

Borr

Loasaceae Mentzelia pumila Desert Blazing Star X Nyctaginaceae Mirabilis decipiens Four O'Clock X Onagraceae Oenothera sp. Primrose X Polemoniaceae Gilia sp. Gilia X X Polemoniaceae Phlox gracilis Slender Phlox 

Polygonacae Polygonum douglasii Douglas' Knotweed X 

Polygonaceae Eriogonum racemosum Redroot Buckwheat X X Polygonaceae Eriogonum umbellatum Sulfur Buckwheat Polypodiaceae Pteridium aquilinium Bracken Fern X Portulacaceae Portulaca oleraca Little Hogweed X Ranunculaceae Thalitricum fendleri Meadowrue X Scrophulariaceae Castilleja sp. Paintbrush X X Scrophulariaceae Penstemon linarioides Toadflax Beardtongue X X Verbenaceae Verbena goodingii Vervain X Vitaceae Vitus arizonica Arizona Grape X NATIVE GRASSES Cyperaceae Carex geophila Sedge X X X 

Cyperaceae Carex sp. Sedge 

Cyperaceae Cyperus fendlerianus Fendler's Flatsedge X X Cyperaceae Eleocharis sp. Spike-rush X Poaceae Agropyron sp. Wheatgrass X 

Poaceae Aristida purpurea Purple Three-awn X 

Poaceae Bouteloua curtipendula Sideoats Grama X 

Poaceae Bouteloua gracilis Blue Grama X X X Poaceae Bromus ciliatus Nodding Brome X Poaceae Festuca arizonica Arizona Fescue 

Poaceae Hordeum jubatum Foxtail Barley X 

Poaceae Muhlenbergia minutissima Annual Muhly Poaceae Muhlenbergia montana Mountain Muhly X Poaceae Muhlenbergia wrightii Wright's muhly X Poaceae Panicum bulbosum Bulb Panicgrass X 

Poaceae Poa fendleriana Muttongrass X X X 

Poaceae Schizachyrium scoparium Little Bluestem Poaceae Sitanion hystrix Squirreltail X X X Poaceae Unknown Poaceae X Poaceae Unknown Poaceae #2 (Sand Bluestem?) X 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 63 

Family Species Common Name I-17 

Corridor

James 

Canyon

Ritter 

Mtn.

Douglas 

Mtn.

Dougl

Borr

Poaceae Unknown Poaceae #3 (Three Awn?) Poaceae Unknown Poaceae #4 (Brome?) X WEEDY NATIVE FORBS Amaranthaceae Amaranthus sp. Pigweed X X 

Apocynaceae Apocynum androsaefolium Spreading Dogbane X 

Asteraceae Bahia dissecta Ragleaf Bahia X Asteraceae Cirsium sp. Thistle X Asteraceae Conyza canadensis Canadian Horseweed X 

Asteraceae Conyza schiedeana Pineland marshtail X Asteraceae Dyssodia papposa Dogweed X 

Asteraceae Erigeron divergens Spreading fleabane X X 

Asteraceae Gnaphalium sp. Everlasting X 

Asteraceae Grindelia aphanactis Rayless Gumweed X 

Asteraceae Gutierrezia sarothrae Snakeweed X 

Asteraceae Helianthus annua Sunflower X 

Asteraceae Heliomeris multiflora Showy Goldeneye X X X 

Asteraceae Heterotheca villosa Hairy Golden Aster X 

Asteraceae Machaeranthera canescens Hoary Aster X X Chenopodiaceae Chenopodium graveolens Fetid goosefoot X 

Euphorbiaceae Euphorbia albomarginata Spurge X X 

Euphorbiaceae Euphorbia dentata Toothed Spurge 

Fabaceae Trifolium sp. Clover X Malvaceae Sphaeralcea sp. Globemallow X 

Onagraceae Gaura coccinea Scarlet Gaura X Onagraceae Gayophytum diffusum Ground Smoke X Polygonaceae Eriogonum pharnaceoides Buckwheat X X X X Scrophulariaceae Penstemon barbatus Scarlet Beardtongue X X Scrophulariaceae Penstemon sp. Beardtongue X 

Solanaceae Solanum americanum American Nightshade X 

Solanaceae Solanum triflorum Cutleaf Nightshade X EXOTIC WEED SPECIES Asteraceae Ambrosia psilostachya Ragweed X X X X 

Asteraceae Centaurea diffusa Diffuse Knapweed X 

Asteraceae Cirsium vulgare Bull Thistle Asteraceae Coreopsis tinctorum Calliopsis X 

Asteraceae Lactuca serriola Prickly Lettuce X 
 64 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

Family Species Common Name I-17 

Corridor

James 

Canyon

Ritter 

Mtn.

Douglas 

Mtn.

Dougl

Borr

Asteraceae Taraxacum officinale Dandelion X Chenopodiaceae Chenopodium album Lamb's Quarters X X Chenopodiaceae Salsola iberica Russian Thistle Convolvulaceae Convolvulus arvensis Bindweed X Fabaceae Medicago lupulina Black Medic X X 

Fabaceae Melilotus albus White Sweet Clover X Fabaceae Melilotus officinalis Yellow Sweet Clover X X Geraniaceae Erodium cicutarium Filaree X Lamiaceae Marrubium vulgare Horehound X Poaceae Avena sp. Oat X 

Poaceae Bromus tectorum Cheatgrass X X X 

Poaceae Poa pratensis Kentucky Bluegrass X 

Polygonaceae Polygonum aviculare Prostrate Knotweed X X 

Scrophulariaceae Linaria dalmatica Dalmatian Toadflax X X X 

Scrophulariaceae Verbascum thapsus Mullein X X X X 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 65 
 

 66 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment

APPENDIX D

Tower Site Evaluation Forms 

(to be filled out for all sites, the following is just an example) 

TOWER SITE EVALUATION FORM 

James Canyon 

1. Location (Provide maps if possible): 

State: AZ County: Coconino 

Latitude/Longitude/GPS Grid: 35-03-06.52N/111-41-08.54W 

City and Highway Direction (2 miles W on Hwy 20, etc.) Access is gained using trail which 

is located just west of Exit 331 (Kelly Canyon Exit) 

2. Elevation above mean sea level: 

3. Will the equipment be co-located on an existing FCC licensed tower or other 

existing structure (building, billboard, etc.)? (y/n) n___ 

 If yes, type of structure: 

 If yes, no further information is required. 

4. If no, provide proposed specifications for new tower: 

 Height: 170-foot Construction type (lattice, monopole, etc.) 

 Guy-wired? (y/n) n No., bands: Total No. Wires: 

 Lighting (Security & Aviation: 

If tower will be lighted or guy-wired, complete items 5-19. If not, complete only items 19 

and 20. 

5. Area of tower footprint in acres or square feet: 

6. Length and width of access road in feet: 

7. General description of terrain – mountainous, rolling hills, flat to undulating, etc. 

Photographs on the site and surrounding area are beneficial: 

8. Meteorological conditions (incidence of fog, low ceilings, etc.): 

9. Soil type(s): 

10. Habitat types and land use on and adjacent to the site, by acreage and percentage of 

total: 

11. Dominant vegetative species in each habitat type: 

12. Average diameter breast height of dominant tree species in forested areas: 
 Wireless Communications Site Proposal – Interstate 17 – Environmental Assessment 67 

13. Will construction at this site cause fragmentation of a larger block of habitat into two 

or more smaller blocks? (y/n) If yes, describe: 

14. Is evidence of bird roosts or rookeries present? (y/n) If yes, describe: 

Distance to nearest wetland area (forested swamp, marsh, riparian, marine, etc.), 

and coastline if applicable: 

Distance to nearest telecommunications tower: 

Potential for co-location of antennas on existing towers or other structures: 

Have measure been incorporated for minimizing impacts to migratory birds? (y/n) 

 If yes, describe: 

Has an evaluation been made to determine if the proposed facility may affect listed 

or proposed endangered or threatened species or their habitats as required 

by FCC regulation at 47 CFR 1.1307(a)(3)? (y/n) 

 If yes, present findings: 

Additional information required: