United States 

Department of 

Agriculture 

 

Forest 

Service 

August 2002 

Draft Environmental 

Impact Statement 

AMENDMENT TO THE COCONINO FOREST 

PLAN FOR THE FLAGSTAFF/LAKE MARY 

ECOSYSTEM ANALYSIS AREA 

Peaks and Mormon Lake Ranger Districts, Coconino National Forest 

Coconino County, Arizona 
 

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Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an 

equal opportunity provider and employer.
i

AMENDMENT TO THE COCONINO FOREST PLAN FOR THE 

FLAGSTAFF/LAKE MARY ECOSYSTEM ANALYSIS 

Draft Environmental Impact Statement 

Coconino County, Arizona 

Lead Agency: USDA Forest Service 

Responsible Official: JIM GOLDEN, COCONINO FOREST 

 SUPERVISOR 

 2323 E Greenlaw Lane, Flagstaff AZ 86004 

For Information Contact: DEBBIE KILL OR ALVIN BROWN 

 5075 N HWY 89, Flagstaff AZ 86004 

928-526-0866 

Abstract: 

This amendment provides clarification to current Forest Plan language and adds 

additional direction for management of lands surrounding the City of Flagstaff, the 

Flagstaff Area National Park Service National Monuments and the Lake Mary 

Watershed. This Forest Plan amendment will be referenced during project-level analysis 

and decision-making in the future. Implementation of the desired condition described in 

the Forest Plan, including this amendment, will occur over a period of years. The 

Proposed Action adds an emphasis on fire risk reduction and recreation management for 

lands in close proximity to residential areas. There are proposed objectives for 

recreation settings (including motorized versus nonmotorized settings) based on 

landscape analysis and design. Recreation settings provide a framework for future sitespecific planning and decision making for outfitter/guide and group uses, road 

management, and camping. There is new rock climbing direction. There are adjustments 

to wildlife cover and a redistribution of Mexican spotted owl habitat near residential 

areas. Items such as scenery, noxious weeds, land exchange, watershed, mountain 

meadows and riparian areas have added language for clarification and emphasis. There 

is language emphasizing continued cooperation and coordination with local, State, and 

Federal agencies. New Management Areas are delineated with additional emphasis 

items and direction. Management Areas were created based on land features, 

biophysical characteristics, and/or the lands relationship to adjacent communities. 

Issues include disagreement with the Proposed Action related to Recreation Opportunity 

Settings for certain places and requirements for big game hiding/thermal cover in areas 

of fire risk concern. Four alternatives have been developed that include a different mix 

of forest settings and wildlife cover requirements. All proposed amendment language is 

in addition to all the current Forest Plan direction. 

Reviewers should provide the Forest Service with their comments during the review 

period of the draft environmental impact statement. This will enable the Forest Service 

to analyze and respond to the comments at one time and to use information acquired in 

the preparation of the final environmental impact statement, thus avoiding undue delay in 

the decision making process. Reviewers have an obligation to structure their 
ii 

participation in the National Environmental Policy Act process so that it is meaningful 

and alerts the agency to the reviewers' position and contentions. Vermont Yankee 

Nuclear Power Corp. v. NRDC, 435 U.S. 519, 553 (1978). Environmental objections that 

could have been raised at the draft stage may be waived if not raised until after 

completion of the final environmental impact statement. City of Angoon v. Hodel (9th 

Circuit, l986) and Wisconsin Heritages, Inc. v. Harris, 490 F. Supp. 1334, 1338 (E.D. 

Wis. 1980). Comments on the draft environmental impact statement should be specific 

and should address the adequacy of the statement and the merits of the alternatives 

discussed (40 CFR 1503.3). 

Send Comments to: Jim Golden 

 Attn: FLEA 

 2323 E Greenlaw Lane 

 Flagstaff Arizona, 86004 

Date Comments Must Be Received: 
iii

 Summary 

The Proposed Action adds an emphasis on fire risk reduction and recreation management 

for lands in close proximity to residential areas. There are objectives for recreation 

settings (including recommendations for motorized versus nonmotorized settings) based 

on landscape analysis and design. Recreation settings provide a framework for future 

site-specific planning and decision making for outfitter/guide and group uses, road 

management, and camping. There is new rock climbing direction. There are adjustments 

to wildlife cover and a redistribution of Mexican spotted owl habitat near residential 

areas. Items such as scenery, noxious weeds, land exchange, watershed, mountain 

meadows and riparian areas have added language for clarification and emphasis. There is 

language emphasizing continued cooperation and coordination with local, State, and 

Federal agencies. New Management Areas are delineated with additional emphasis items 

and direction. Management Areas were created based on land features, biophysical 

characteristics, and/or the lands relationship to adjacent communities. 

The Flagstaff/Lake Mary Ecosystem Analysis (FLEA) Area surrounds the City of 

Flagstaff, and the Coconino County communities of Doney Park, Fort Valley, Kachina 

Village, Forest Highlands, Lake Mary Road, and Mountainaire. It also includes the Lake 

Mary watershed and lands between Sunset Crater Volcano and Wupatki National 

Monuments. Land features within the analysis area include Mt. Elden, the Dry Lake 

Hills, and numerous cinder cones that make up the San Francisco volcanic field, Walnut 

Canyon, Pumphouse Wash, Woody Ridge, Observatory Mesa, and A1 Mountain. There 

are approximately 300,423 acres of National Forest land within the FLEA area. This 

Draft Environmental Impact Statement is for National Forest lands only. 

This action is needed because the current Forest Plan is silent on some aspects of 

recreation management, limits flexibility for reducing fire risk near residential areas, and 

fails to address some unique circumstances that occur on National Forest lands that are 

located adjacent to residential areas. 

Scoping 

The scoping process for this project included the following activities. In May of 1999 the 

Ideas for Change was published; this document described the need for considering 

changes and a variety of ideas and as a formal scoping document. The public responded 

by attending open houses, writing letters and e-mails, or attending topic-oriented 

meetings. Analysis of these comments refined the scope of FLEA and the Proposed 

Action was published in September of 2001. The Proposed Action contained the actual 

replacement page language proposed for the Forest Plan. The replacement language 

consists of clarification, new language on topics where the Forest Plan was previously 

silent, and management direction changes. One open house was held in September 2001 

for the Proposed Action. The public is welcome to request presentations of information, 

obtain a copy of the DEIS, and write or e-mail in their comments. 
iv 

Issues 

The following significant issues were identified from the public comment on the 

Proposed Action. 

Issue 1: Not retaining 30 percent hiding and thermal cover within the Fire 

Management Analysis Zone will affect native species including management 

indicator species. Wildlife would be impacted in the vicinity of Walnut Canyon if 

no cover were provided. There are large sized wildlife that take advantage of the 

thermal and hiding properties of dense stands along the Walnut Canyon rim, part 

of which falls within the Fire Management Analysis Zone. Wildlife would be 

impacted in the area of Woody Ridge if no cover is provided. 

 

Issue 2: A Semiprimitive Motorized setting in the small area adjacent to private 

land in Fort Valley and south of A1 Mountain is not the best setting choice for 

this area. Fire risk reduction is better achieved with a nonmotorized setting where 

private lands are located in the path of prevailing winds. Wildlife habitat for elk, 

deer, fox, coyote, raptors, and prairie dogs is better served by a nonmotorized 

setting. The area is too small to be useful to motorized travel and many of the 

current routes dead-end. A quiet setting is desirable adjacent to homes. 

Issue 3: A Semiprimitive Motorized setting surrounding Skunk and Fay Canyons 

and areas north of Fisher Point is not the best choice for this area. The type of 

recreation experience desirable is nonmotorized recreation such as hiking, 

mountain biking, and horse riding. Absence of vehicles will maintain areas with 

limited erosion especially in canyon bottoms and steep slopes. Absence or 

limited vehicles will lessen levels of human disturbance to sensitive wildlife 

species so that the wildlife are more likely to successfully occupy the canyon and 

its rim 

Issue 4: The Semiprimitive Nonmotorized setting downslope from the Waterline 

Road (FR 146)1

 is not the best choice for this area. There are too many SPNM 

patches on the landscape, limiting opportunity for SPM experiences especially at 

high elevations and around the San Francisco Mountain. A nonmotorized setting 

is not necessary for disturbance sensitive species. Wildlife habitat can still be 

maintained with a well-designed SPM road system. 

Alternatives 

Four alternatives have been developed that include a different mix of ROS settings and 

wildlife cover requirements. Except for the issue areas, the action alternatives are similar 

in that most of the Forest Plan page language is the same for Alternatives A, C, and D. 

The Alternatives are different based on the four issues. When selecting an alternative, the 

 

1

 Waterline Road (FR 146) is on the eastern side of the lower slopes of the San Francisco Mountain and 

forms the eastern boundary of the Kachina Peaks Wilderness. 
v 

decision maker can select different components of alternatives as they relate to the issues. 

ROS maps are located at the end of this document. 

Under Alternative A, there is no cover requirement in the Fire Management Analysis 

Zone surrounding residential areas. In the remainder of the FLEA area, cover is provided 

on 30 percent of the forested lands within a 10K Block2

 with 10% in hiding cover, 10 

percent in thermal cover, and 10 percent in a combination of hiding and thermal cover. 

The Waterline Road area is Semiprimitive Nonmotorized. The A1 Mountain area 

adjacent to private lands in Fort Valley is Semiprimitive Motorized. The Skunk/Fay 

Canyon areas and lands north of Fisher Point are Semiprimitive Motorized. 

Under Alternative B, No Action which is a continuation of the current Forest Plan

direction, cover is provided on 30 percent of the forested areas of a 10K Block with 10 

percent in hiding cover, 10 percent in thermal cover, and 10 percent in a combination of 

hiding and thermal cover. The Waterline Road area is Semiprimitive Motorized. The A1 

Mountain area adjacent to private lands in Fort Valley is Roaded Natural. The 

Skunk/Fay Canyon areas and lands north of Fisher Point are Roaded Natural 

Under Alternative C, in the Fire Management Analysis Zone, cover is provided in a 

maximum of 15 percent of the forested acres per Section3

. In the remainder of the FLEA 

area, cover is provided on 30 percent of the forested areas of a 10K Block with 10 percent 

in hiding cover, 10 percent in thermal cover and 10 percent in a combination of hiding 

and thermal cover. The Waterline Road area is Semiprimitive Motorized with roads 

located to limit impacts to disturbance sensitive species. The A1 Mountain area adjacent 

to private lands in Fort Valley is Semiprimitive Nonmotorized. The Skunk/Fay Canyon 

areas and lands north of Fisher Point are Semiprimitive Nonmotorized with one 

Semiprimitive Motorized road corridor linking Old Walnut Canyon Road to the Herold 

Ranch area. 

Under Alternative D, cover is the same as C. The Waterline Road area is Semiprimitive 

Nonmotorized. The A1 Mountain area is Semprimitive Nonmotorized. The Skunk/Fay 

Canyon areas and lands north of Fisher Point are entirely Semiprimitive Nonmotorized 

ROS setting with no exceptions. 

Major Conclusions 

All alternatives make small changes to the existing direction in the Forest Plan, and 

therefore only small differences in effects are expected. All the changes are to improve 

conditions in the FLEA area, so possible future impacts could be lessened. Because is it 

unknown what will happen in the future, this effects are described for trends and 

expected outcomes, assuming partial implementation of the Forest Plan. 

 

2

10K Block is a designation used in the Forest Plan to identify an approximately 10,000 acre contiguous 

area to which some management direction is applied. For example, the amount of desired old-growth is 

identified on a 10K Block basis, which will insure distribution of this forest characteristic across the 

landscape. 

3

 A Section is 640 acres, 1 square mile. 
vi 

There is no significant environmental effect expected for air quality, soil and water 

quality, and vegetation. Slight effects to wildlife habitat occur where the amount and 

distribution of wildlife hiding and thermal cover is different than the current Forest Plan. 

The changes in cover guidelines continue to provide habitat necessary to support wildlife. 

There is no significant effect threatened or endangered species habitat in the FLEA area, 

(Mexican spotted owl, bald eagle, or black-footed ferret). There is not significant effect 

to sensitive species, management indicator species or migratory bird habitat. Slight 

improvements occur under all the action alternatives for these species. 

There are some social effects from implementing the Forest Plan direction changes as 

described in Alternatives A, C, and D. Managers have more flexibility to take actions to 

lessen the potential for high-intensity crown fire that could destroy structures or 

important forest resources. The miles and distribution of user-created (social) roads and 

trails will be less over time, as some are converted to system roads and trails while others 

are closed. Camping opportunities will change along the Highway 89A corridor and 

around residential areas. Some people may feel a sense of loss if a favorite campsite, 

road or trail is changed. 

In general, all the action alternatives set direction that, when implemented via sitespecific projects, will result in some trends that are different than if the current 

management direction was implemented. These different trends are: 

• Less potential for catastrophic wildfire in the wildland/urban interface 

• Less human disturbance to wildlife, especially those species that are vulnerable to 

disturbance 

• Increased opportunity for high quality recreation opportunities in a natural setting 

• Increased opportunity for semiprimitive settings with opportunities for solitude 

and self-exploration 

• Decreased impacts, where they are occurring, from high concentrations of 

dispersed campsites, social (user-created) roads and trails 

• Increased monitoring of human uses and impacts in key areas as a basis for future 

understanding of management needs 

• Decreased impacts and increased quality of the recreation experience in high-use 

areas. 

Based on the effects of the alternatives displayed in this EIS, the Coconino National 

Forest Supervisor will decide whether to adjust Forest Plan direction as proposed in one 

of the Alternatives, or with a mix of the Alternative direction, or not at all. 
 Table of Contents 

i

INTRODUCTION................................................................................................................... 1

DOCUMENT STRUCTURE................................................................................................ 1 

CHAPTER 1 - PURPOSE AND NEED FOR ACTION...................................................... 3

SCOPE OF THIS PROJECT ................................................................................................ 3 

LOCATION .......................................................................................................................... 5 

PURPOSE AND NEED FOR ACTION............................................................................... 6 

DECISION TO BE MADE................................................................................................. 14 

PROPOSED ACTION........................................................................................................ 14 

PUBLIC PARTICIPATION ............................................................................................... 15 

ALTERNATIVES NOT ANALYZED IN DETAIL.......................................................... 16 

ISSUES AND EVALUATION MEASURES .................................................................... 22 

CHAPTER 2 - ALTERNATIVES ....................................................................................... 25

INTRODUCTION .............................................................................................................. 25 

COMMON TO ALL ACTION ALTERNATIVES............................................................ 25 

ALTERNATIVES CONSIDERED IN DETAIL................................................................ 25 

HOW THE ACTION ALTERNATIVES MEET THE PURPOSE AND NEED............... 28 

COMPARISON OF ALTERNATIVES ............................................................................. 31 

CHAPTER 3 - AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES ............................................................................................................... 45

INTRODUCTION AND ASSUMPTIONS........................................................................ 45 

WILDLIFE.......................................................................................................................... 49 

SOIL AND WATER QUALITY........................................................................................ 65 

VEGETATION................................................................................................................... 66

FIRE RISK, HAZARD, AND FIRE POTENTIAL............................................................ 68 

AIR QUALITY................................................................................................................... 71 

SOCIAL .............................................................................................................................. 71 

MANAGEMENT AREAS.................................................................................................. 83 

NATIONAL MONUMENTS ............................................................................................. 85 

CHAPTER 4 - CONSULTATION AND COORDINATION ........................................... 91

PREPARERS AND CONTRIBUTORS ......................................................................................... 91 

DISTRIBUTION OF THE ENVIRONMENTAL IMPACT STATEMENT ............................................ 92 

LITERATURE CITED:............................................................................................................. 94 

INDEX.................................................................................................................................... 98

APPENDIX A FOREST PLAN NEW AND REPLACEMENT PAGES ...................... 101

APPENDIX B COMMENT ANALYSIS AND RESPONSE TO COMMENTS........... 111

COMMENTS #1-6 FROM STEVE AUTRY .............................................................................. 111 

COMMENT #8 FROM BRETT A. NAVIN ............................................................................... 112 

COMMENT #9 FROM ED LANGE ......................................................................................... 113 

COMMENT #10 FROM JACK WEISS ..................................................................................... 113 
ii 

COMMENTS #11-13 FROM STEVE AUTRY........................................................................... 113 

COMMENT #14 FROM NORM WALLEN ............................................................................... 113 

COMMENT #15 FROM SUSAN LAMB AND TOM BEAN ......................................................... 114 

COMMENT #16 FROM JOHN WAHL..................................................................................... 115 

COMMENT #17 FROM IVO LUCCHITTA ............................................................................... 115 

COMMENT #18 FROM BAERBEL K. LUCCHITTA ................................................................. 116 

COMMENT #19- FROM TAYLOR MCKINNON, GRAND CANYON TRUST.............................. 117 

COMMENTS #20-24 FROM RALPH BAIERLAIN.................................................................... 117 

COMMENTS #25-26 FROM CHRIS GEORGE ......................................................................... 119 

COMMENT #27 FROM LEANDRA GREYEYES....................................................................... 119 

COMMENT #28 FROM JULIA ALVARADO............................................................................ 119 

COMMENT #29 FROM BREAND BARRANDEY...................................................................... 120 

COMMENT #30 FROM JOSEPH GUTIERREZ.......................................................................... 120 

COMMENT #31 FROM DUSTIN BANBURY ........................................................................... 120 

COMMENT #32 FROM MIMI WALTON TAYLOR .................................................................. 120 

COMMENT #33 FROM BRIAN BEDONIE............................................................................... 121 

COMMENT #34 FROM RAQUEL JACKSON ........................................................................... 121 

COMMENT #35 FROM VALERIE ASHTON-CODY ................................................................. 121 

COMMENT #36 FROM SAMUEL CRUZ................................................................................. 121 

COMMENT #37 FROM DUSTIN BEAVER.............................................................................. 121 

COMMENT #38 FROM GEORGIA BEHNE ............................................................................. 122 

COMMENT #39 FROM ERIN KEAMS.................................................................................... 122 

COMMENT #40 FROM CODY SMITH.................................................................................... 122 

COMMENT #41 FROM DYLAN BUEHLER............................................................................. 122 

COMMENTS #42-#47 FROM BRIAN NOWICKI AND BRIAN SEGEE, SOUTHWEST FOREST 

ALLIANCE .......................................................................................................................... 123 

COMMENTS #48-#67 FROM BETSY MCKELLAR FROM FRIENDS OF WALNUT CANYON...... 125 

COMMENTS #68-#71 FROM C. JAMES KRAFFT................................................................... 130 

COMMENTS #71-#92 FROM TAYLOR MCKINNON, GRAND CANYON TRUST ...................... 132 

COMMENTS #93-#96 FROM JOHN SLIVA, PLANNING DIRECTOR, CITY OF FLAGSTAFF ...... 140 

COMMENTS #97-#134 FROM SAM HENDERSON, NATIONAL PARK SERVICE, FLAG-AREA 

MONUMENTS ..................................................................................................................... 143 

APPENDIX C - BACKGROUND INFORMATION FOR THE FOREST PLAN....... 153

DEFINITIONS FOR GOALS, OBJECTIVES, STANDARDS, AND GUIDELINES............................ 153 

COORDINATING REQUIREMENTS........................................................................................ 154 

MISSION STATEMENT......................................................................................................... 155 

OUTPUTS AND RANGE OF IMPLEMENTATION...................................................................... 155 

BACKGROUND INFORMATION ON OTHER PLANNING EFFORTS IN THE REGION ................. 155 

APPENDIX D - EXPLANATION OF NONSIGNIFICANT AMENDMENT.............. 157

APPENDIX E - SUMMARY OF DEVELOPMENT OF ROS OBJECTIVES............. 161

APPENDIX F - CROSSWALK FROM IDEAS FOR CHANGE TO DEIS ................. 163
1

 

INTRODUCTION 

This Draft Environmental Impact Statement for the Flagstaff/Lake Mary Ecosystem 

Analysis Area, (FLEA DEIS) contains changes and clarification for our current Forest 

Plan. The overall goals and objectives of the Forest Plan continue to guide our 

management. Since the mid-80’s, when the Forest Plan was originally written, there 

have been many amendments, which made either very minor changes in direction or 

more major shifts. The Flagstaff/Lake Mary Ecosystem Analysis (FLEA) Amendment 

needs to be considered within the context of the entire amended Forest Plan. It is not 

intended to be a stand-alone document. These proposals are focused on making needed 

changes to current management direction. 

There is very little site-specific direction here. Please remember that the purpose of this 

amendment is general management direction that will be referenced when the Forest 

Service plans and implements subsequent site-specific projects. 

DOCUMENT STRUCTURE 

The Forest Service has prepared this Environmental Impact Statement in compliance with 

the National Environmental Policy Act (NEPA) and other relevant federal and state laws 

and regulations. This Environmental Impact Statement discloses the direct, indirect, and 

cumulative environmental impacts that would result from the proposed action and 

alternatives. The document is organized into four chapters: 

• Chapter 1 Purpose and Need for Action: The chapter includes information on the 

history of the project proposal, the purpose of and need for the project, and the 

agency’s proposal for achieving that purpose and need. This section also details 

how the Forest Service informed the public of the proposal and how the public 

responded. 

• Chapter 2 Alternatives, including the Proposed Action: This chapter provides a 

more detailed description of the agency’s proposed action as well as alternative 

methods for achieving the stated purpose. These alternatives were developed 

based on significant issues raised by the public and other agencies. This 

discussion also includes mitigation measures. Finally, this section provides a 

summary table of the environmental consequences associated with each 

alternative. 

• Chapter 3 Affected Environment and Environmental Consequences: This chapter 

describes the environmental effects of implementing the proposed action and 

other alternatives. 

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

preparers and agencies consulted during the development of the environmental 

impact statement. 
2 

• Index The index provides page numbers by document topic 

• Appendices The appendices provide more detailed information to support the 

analyses presented in the environmental impact statement. They include, 

o Appendix A – Forest Plan New and Replacement Pages (with Maps) 

o Appendix B – Comment Analysis and Response to Comments 

o Appendix C – Background Information on Forest Plans 

o Appendix D – Explanation of Nonsignificant Amendment 

o Appendix E – Summary of Development of ROS Objectives 

o Appendix F – Crosswalk from Ideas for Change to DEIS 

For your comments to be most helpful they need to be clear and as specific to the DEIS 

as possible. If your comments are directly linked to a specific part of the DEIS, please 

indicate the page number(s) and paragraph(s). 

The texts of this DEIS, the Proposed Action and the Ideas for Change are all located on 

the Coconino Forest website at www.fs.fed.us/r3/coconino Click on the Management 

page, then the NEPA page. 

Some of you may be interested in reviewing the current Forest Plan. The Forest Plan is 

available at the Flagstaff and NAU public libraries and copies may be requested from the 

Coconino Supervisor’s Office. There have been many amendments since the Forest 

Plan’s adoption in 1987 (currently there are 16). It is important to obtain all the pages 

from the amendments to have a complete and accurate copy. Contact Katherine Farr at 

(928) 527-3411 to obtain copies of the Plan or its amendments. 

Additional documentation, including more detailed analyses of project-area resources, 

may be found in the project planning record located at the Peaks Ranger District. If you 

have questions about the information presented here, or would like to view larger scale 

maps, please contact Alvin Brown or Debbie Kill at the Peaks District Office, (928) 526-

0866. 

Please mail your comments to Jim Golden, Forest Supervisor, Attention FLEA, 2323 E. 

Greenlaw Lane, Flagstaff, AZ 86004. You may send your comments via e-mail to 

dkill@fs.fed.us. Please note that these proposed text changes apply to the FLEA area 

only. 
3 

 

CHAPTER 1 - PURPOSE AND NEED FOR 

ACTION 

SCOPE OF THIS PROJECT 

What this analysis is, and what it is not – the story of the NEPA triangle 

The Forest Service uses a two-phase planning process, which is represented by the 

planning triangle below. In the first phase (the “left side”), for a specific location, we 

compare the desired condition with the existing condition and determine if there is a need 

for change. If there is a need for change, we look for possible ways to accomplish that 

change, determine if they are consistent with the forest plan, and make them available for 

analysis. No decisions are made on the left side. The analysis for site-specific projects is 

on the “right side” of the triangle, and is the process we follow for the National 

Environmental Policy Act (NEPA). Only when a possible project is brought over to the 

right side with an official “proposed action” under NEPA does the NEPA process start, 

and end with a NEPA decision. 

From 1997 to 1999 team members were evaluating the Flagstaff/Lake Mary Ecosystem 

Analysis (FLEA) area for the ”left” side of the triangle. Forest Service staff reviewed 

existing conditions, and discussed where currently we are not progressing towards 

desired conditions, or where desired conditions described in the Forest Plan no longer 

”fit”. Options were identified for change (possible management practices) that ranged 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

4 

from site-specific items, to Forest Plan direction adjustments. The publication Ideas for 

Change documented this work. The Ideas for Change is the document that represents the 

”ecosystem analysis” for the FLEA area. It is not a decision document, but rather a 

summary of existing and desired conditions, goals and objectives, and a list of possible 

management practices. National Forest Management Act primarily governs this type of 

analysis. Public comment to the Ideas for Change is part of the package of information 

that represents the ”ecosystem analysis” or “left” side product for this area. The 

comments received are referenced regularly for this project as well as various other sitespecific projects on the Districts. 

In moving from the left side to the right side of the NEPA triangle, the ”ecosystem 

analysis” portion was complete and the task remained of choosing which management 

practices (changes to the Forest Plan) were most important to carry over in a Proposed 

Action for NEPA analysis. In addition, at this step, the choice was made to do separate 

proposed actions for some site-specific projects and gather the Forest Plan amendment 

actions into the Proposed Action to Amend the Coconino Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis (FLEA) Area (Proposed Action). Publishing the 

Proposed Action started us on to the right side of the planning triangle and the standard 

NEPA process for conducting a nonsignificant amendment to the Forest Plan. Appendix 

D describes the rationale for why this is a nonsignificant amendment in terms of National 

Forest Management Act, which guides the contents of forest plans.4

 The comments 

received in response to the Proposed Action are “scoping” as defined under NEPA and 

presented us with the information needed to determine the significant issues. Alternative 

actions were created in response to the significant issues. 

It is interesting to note that the interdisciplinary team reviewed the details of the current 

Forest Plan and found that many of the topic areas identified in the Ideas for Change did 

not require any changes or additions. Many concerns have been more about 

implementation of the current Forest Plan rather than changes to that Plan. Therefore 

this is not a revision of our Forest Plan, rather a set of course corrections applying only 

to the FLEA area. 

The Proposed Action (Alternative A) contains actual replacement page language. Some 

of this language provides clarification only, in that it brings the Forest Plan up to date 

with current concepts and terms the Forest Service currently uses. Some of the text 

provides direction where there previously was none, that is to say the Forest Plan was 

silent. The remainder of the text represents an additional or changed goal, objective, 

standard, or guideline. 

The discussion in the Draft Environmental Impact Statement will center around those 

items where change is proposed, including those items where issues were raised related to 

the proposed changes. Where the Proposed Action recommended clarification to the 

Forest Plan, and where no issue was identified with the clarification, there will be little 

discussion. The DEIS focuses on the items where the Forest Plan was silent, and items 

of change (usually additional direction for the FLEA area). 

 

4

 The 1982 planning regulations are being used for this amendment. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

5 

Since multiple site-specific proposed actions have and will be generated from the Ideas 

for Change, it might have been prudent to change the name of this project. However, so 

many people were familiar with the FLEA name it was retained. Other NEPA documents 

have their roots in the FLEA process but were not so named, such as Old Caves Crater 

Roads and Trails Project. 

Most of the new and replacement page text in the Proposed Action (Alternative A) is 

common to all alternatives. These pages are located in Appendix A. 

There are forces that can affect the production of outputs and implementation rates, such 

as weather, budget appropriations from Congress, local economies, and political 

decisions. This amendment, in conjunction with the current Forest Plan is used as the 

basis for developing budget 

proposals. The FLEA area is 

only a portion of the 

Coconino National Forest 

and priorities for FLEA will 

be balanced with other 

Forest priorities. This 

analysis assumes partial 

implementation of FLEA 

direction over the next 10 

years. The trends that result 

from partial implementation 

are described. 

LOCATION 

The Flagstaff/Lake Mary 

Ecosystem Analysis (FLEA) 

Area surrounds the City of 

Flagstaff, and the Coconino 

County communities of 

Doney Park, Fort Valley, 

Kachina Village/Forest 

Highlands, Lake Mary Road, 

and Mountainaire. It also 

includes the Lake Mary 

watershed and lands between 

Sunset Crater Volcano and 

Wupatki National 

Monuments. Land features within the analysis area include Mt. Elden, the Dry Lake 

Hills, numerous cinder cones that make up the San Francisco volcanic field, Walnut 

Canyon, Pumphouse Wash, Woody Ridge, Observatory Mesa, and A1 Mountain. There 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

6 

are approximately 300,423 acres of National Forest land within the FLEA area. This 

DEIS is for National Forest lands only. 

PURPOSE AND NEED FOR ACTION 

The purpose and need statements below are written to show the current Forest Plan

language, the desired Forest Plan language, and the gap between the two. There is not 

one overarching purpose and need statement that can be written for this project. Rather 

the Interdisciplinary Team (team) determined a variety of different needs based on what 

the current Forest Plan did or did not provide. The purpose and need statements below 

are more refined than the concepts presented in Chapter 1 and 2 of the Ideas for Change. 

Many of the management actions identified in the Ideas for Change, were already 

permitted under the current Forest Plan and are not carried on here. 

In addition to the topics discussed below, some Forest Plan text was updated for 

clarification reasons and did not substantially change the goals, objectives, standards, and 

guidelines already in place. 

A Zone of Influence 

National Forest lands adjacent to Flagstaff residential areas need to be managed 

somewhat differently than the remainder of the Coconino National Forest. This is 

because of the greater number of people using this zone, the concentrated regular use this 

zone receives, and the increasing amount of development immediately adjacent to the 

Forest. These areas are often referred to as wildland urban interface, where wildland 

characteristics are strongly influenced by human use. 

In most cases, the current Forest Plan treats acres similarly according to vegetation type; 

for example, management direction for “Ponderosa Pine and Mixed Conifer Less Than 

40% Slope” (MA3)5

 is similar whether or not it is adjacent to residential areas or miles 

away. The current Forest Plan defines the Urban Interface and places emphasis on fire 

risk reduction in these areas. 

There is a high risk of fire ignition. Because a wildfire in this zone could travel onto 

private property, and because a fire originating in this zone could impact important forest 

resources, this zone has the highest priority for fire risk reduction. 

The Forest Plan does not recognize that higher amounts and different types of recreation 

use occur adjacent to residential areas. The majority of these influences occur within 

approximately 1⁄2 mile of private land.6 Influences include user-created (social) trails, 

utility corridors, private land access roads, dogs, cats, and other pets, and some trash 

dumping. 

 

5

 MA = Management Area, which is a piece(s) of land with similar management direction. 

6

 Per interviews with Forest Service field personnel. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

7 

Some types of wildlife are negatively affected by frequent contact with people. It is 

difficult for these types of wildlife to successfully occupy and reproduce in areas that are 

highly used by people. Topography and vegetation play a role in the level of human 

disturbance that can occur. 

The desire is to have a Forest Plan that 1) continues to place emphasis on fire risk 

reduction, and gives even greater emphasis for fire risk reduction within approximately 1⁄2 

mile of private land, 2) recognizes the high levels and types of daytime recreation uses 

prevalent near residential areas, and 3) recognizes human disturbance to wildlife is 

greater in areas adjacent to residential areas. 

Forest Settings – Recreation Opportunity Spectrum Objectives 

The current Forest Plan uses Recreation Opportunity Spectrum (ROS)7

 primarily as an 

inventory tool. The current inventory was done based on a standard definition for each 

ROS class. The current Forest Plan also directs that Forest-wide ROS settings should 

only deviate +/- 15 percent from the ROS inventory completed at the time the Forest 

Plan was signed. Currently ROS definitions describe factors related to human 

experiences, that is to say the number of social encounters, opportunities for solitude and 

risk, administrative presence (signs, patrols, or regulations), facility development scale 

and character, and scenery. 

There is a need to describe an expected recreational experience and character that a land 

manager could strive for. When creating these objectives, it is beneficial to consider not 

only human experiences, but also human interactions with wildlife, quality of wildlife 

habitat, fire risk and hazard, and watershed conditions.8

 

The current ROS inventory shows 26.9 percent of the FLEA area9 in Semiprimitive 

Motorized (SPM10) ROS setting, 2.7 percent in Semiprimitive Nonmotorized (SPNM)11

and less than 1% in Primitive (P12) settings. The desired settings for the FLEA area are a 

greater amount of semiprimitive settings and a better distribution of these settings across 

the landscape. 

The current ROS inventory shows Roaded Natural(RN)13 settings where disturbance 

sensitive species live. The desire is for semiprimitive settings where disturbance 

sensitive species occur, thereby providing a level of human disturbance to wildlife that 

 

7

A land classification system that categorizes National Forest land into six classes, each class being 

defined by its setting and by the probable recreation experiences and activities it affords. 

8

 This kind of consideration is accomplished via landscape analysis. 

9

 All percentages are for percent of National Forest lands in the FLEA area and do not contain acres in 

other ownership. 

10 SPM areas include evidence of primitive roads and/or trails. 

11 SPNM areas have few and/or subtle modifications by people, and a high probability of isolation from the 

sights and sounds of people. 

12 Primitive settings are essentially unmodified, where trails may be present but structures are rare. 

13 RN settings are predominantly natural environments with evidence of moderate permanent resource use. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

8 

does not cause wildlife to leave or to be unsuccessful at rearing young. It is desirable for 

many of the areas currently supporting key wildlife habitat to be in Semiprimitive 

settings, either motorized or nonmotorized. 

The current Roaded Natural ROS objective, which is prevalent throughout the FLEA 

area, sometimes overlaps areas important to sensitive or threatened species. A 

semiprimitive objective would often be more compatible with the long-term needs of 

such species. It is desirable to have most threatened species habitat within a 

semiprimitive or primitive ROS objective zone. 

It is desirable to enhance and expand Primitive settings to include more of Walnut 

Canyon and some of the plateau above the canyon in order to protect canyon resources, 

such as disturbance sensitive species. In addition, this setting provides an area with 

relatively primitive nonmotorized recreation settings close to the residential/forest 

interface. 

The current ROS inventory shows some areas in a Rural or Urban setting. These settings 

are, in general, not desirable on National Forest lands because they represent more 

developed structures, and other resource uses than is appropriate to the overall goals and 

objectives in the Forest Plan. In addition, many people have expressed a desire for 

semiprimitive type settings, even adjacent to neighborhoods where social encounters are 

high.14 The desire is to move away from, not towards, Rural and Urban ROS settings. 

Camping Objectives (including description for designated dispersed 

camping) 

The current Forest Plan does not describe stay limits nor does it prohibit camping within 

one mile of recreation facilities such as campgrounds. The desire is for the Forest Plan

to recognize these ongoing practices. 

The current Forest Plan addresses dispersed camping. However, there is no mention of 

designated camping as a management tool. There is no differentiation between lands 

adjacent to residential areas and lands that are not. 

The desire is for a Forest Plan that describes a wider variety of camping management 

techniques. Examples of techniques include designated dispersed sites, area closures, or 

parking management. The Forest Plan should recognize that areas of high daytime 

recreation or very high concentrations of dispersed camping warrant special consideration 

for camping management. 

Currently, unacceptable impacts occur in some places where dispersed camping has 

become so concentrated that soil and water impacts are occurring. These areas are the 

Highway 89A corridor, Marshall Lake, Lake Mary, Pumphouse Wash, and Walnut 

Canyon. The desire is for camping that maintains soil and water quality, with improved 

conditions in all of these areas. 

 

14 Per comments to the Ideas for Change.
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

9 

In some places, the high numbers of people take away from the quality of the camping 

experience. The desire is for camping opportunities that provide high quality experiences 

in terms of scenery and opportunities to camp away from the sights and sounds of nearby 

campers. 

Camping adds to unacceptable fire risk in some areas. Currently 39 percent of the 

Urban/Rural Influence Zone is closed to camping. The desire is for more of this zone to 

be closed to camping. 

Outfitter/Guides and Group Use 

The current Forest Plan provides little direction on how outfitter/guide proposals are 

processed. Clear parameters are not in place, causing a more time-consuming review 

process by Forest Service staff. The desire is to have an efficient process for review, 

approval, or denial of outfitter/guide proposals. 

The current Forest Plan does not recognize the quality of recreation experience in areas 

with high levels of use and how that quality could be enhanced or degraded by adding 

outfitter/guide activities. The desire is for a tool by which forest settings are evaluated 

when approving outfitter/guides. The desire is to provide consistent direction and 

identify those areas where outfitter/guide activities may be suited, given ecological 

sensitivity or existing levels of non-commercial use or both. 

Rock Climbing 

The current Forest Plan is silent on the topic of rock climbing. The desire is a Forest 

Plan that recognizes this activity and provides management guidance. 

Current climbing activities occur in sites that are often fragile because of steep slopes, 

riparian or mixed conifer vegetation, and other rare plants. Climbing sites are often 

habitat for sensitive species. The desire is to provide climbing opportunities while 

protecting sensitive wildlife and vegetation. 

Trails 

The current Forest Plan does not differentiate between trail management near residential 

areas, and in outlying areas. The current Forest Plan does not recognize the high levels 

of use that occur on Forest Service system trails near residential areas. The current 

Forest Plan makes no mention of user-created trails. The desire is a Forest Plan that 

recognizes the trail situation that occurs adjacent to residential areas such as the higher 

levels of daytime use and many user-created (social) trails. 

Currently, user-created trails impact two Mexican spotted owl (MSO) Protected Activity 

Centers (PACs) in the FLEA area. The desire is Forest Plan language that reverses 

deleterious trends. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

10 

Currently, user-created trails impact fragile riparian areas including rare plants in certain 

drainages and lakebeds. The desire is Forest Plan direction that allows for reduction or 

elimination of impacts. 

Currently, there are so many user-created trails that site-specific management of each 

trail is beyond our abilities. The desire is Forest Plan language that progresses towards 

more ecologically sound trail conditions, without micromanaging each user-created 

(social) trail. 

Currently, the Forest Plan makes little mention of community linkages and access points. 

The desire is a Forest Plan that recognizes this need. 

Currently, the Forest Plan provides little guidance on the type of motorized or nonmotorized trail experiences to be provided. The desire is for a planning tool (ROS and 

transportation planning) that helps managers determine the locations and types of trails to 

construct. 

The current Forest Plan does not recognize the access issues currently occurring in some 

residential areas for motorized and nonmotorized trail use. The desire is a Forest Plan

that allows for neighborhood access where appropriate, and adequate parking at access 

points outside of neighborhoods. The desire is to cooperate with other landowners to 

provide public land trail access. 

The current Forest Plan does not discuss non-motorized off-trail use. The desire is to 

recognize those areas where stay-on-trail use is desirable in order to maintain areas of 

minimal human disturbance to forest resources. 

The current Forest Plan is silent on the topic of motocross.15 Current user-created 

motorcross/bmx tracks are causing resource damage. The desire is for Plan direction on 

this topic, and the reduction or elimination of impacts. 

Roads 

Although many criteria exist for road management in the current Forest Plan, the list 

lacks a few considerations.16 The current Forest Plan lacks mention of recreation 

experience (ROS settings) as a reason for maintaining or closing roads. The current 

Forest Plan lacks mention of redundant roads, the spread of noxious weeds, or illegal 

human activities, as reasons to close roads. The current Forest Plan does not list criteria 

for keeping roads open. The current Forest Plan does not address user-created (social) 

roads. There is a lack of priorities for where roadwork should occur first. 

 

15 Motocross is motorcycle or bmx bike riding on a small course with tight turns and bumps. Impromptu 

motocross courses occur in meadows, usually adjacent to residential areas. 

16 Road management criteria apply regardless of the type of road policy that currently exists, or change as 

a result of the five forest off-road driving amendment Cross-country Use of Motorized Vehicles in Five 

Arizona National Forests that is currently underway. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

11 

The desire is for a sense of priority when choosing areas to work on and updated road 

management criteria that takes into account the topics mentioned above. Such 

adjustments will make it easier for future land managers to make reasoned choices about 

individual roads. 

Wildlife Habitat – Mexican Spotted Owls – Fire and Human Uses 

The current Forest Plan fails to distinguish the impacts on wildlife and wildlife habitat of 

noise, pets, user-created trails, and other recreation uses that occur adjacent to residential 

areas. Current Forest Plan requirements for certain kinds of MSO habitat do not achieve 

low fire potential as is desired near residential areas. The desire is to recognize these 

factors in our Forest Plan and provide flexibility to land managers as they make 

management choices in the Urban/Rural Influence Zone. 

Wildlife Habitat – Northern Goshawk and Recreation 

The current Forest Plan is vague about recreation use in Post Fledgling Family Areas 

(PFAs). The desire is more concrete direction and recognition of the unavoidable level of 

human disturbances that will occur adjacent to residential areas. 

Wildlife Habitat – Threatened and Endangered Species and Human 

Disturbance 

The current Forest Plan is vague about monitoring human disturbance to these species. 

The desire is emphasis on monitoring human disturbances prior to approving new sitespecific projects. The desire is for Forest Plan language that allows for recreation use 

restrictions if needed in threatened and endangered species habitat. 

Wildlife Habitat – Big Game Hiding And Thermal Cover and Fire Risk 

Reduction 

The current Forest Plan states that 30 percent cover will be provided within a 10K 

Block.17 This has been interpreted to mean 30 percent of the forested acres within a 10K 

Block. The desired condition in the Urban/Rural Influence Zone, and in the Fire 

Management Analysis Zone (1U)18 is for low potential for catastrophic fire losses. The 

desired condition for fire hazard management cannot be achieved if the 30 percent 

guideline is applied. The desire is for Forest Plan language that adds flexibility to the 

implementation of wildlife cover within the Fire Management Analysis Zone. The 

 

17 10K Block is a designation used in the Forest Plan to identify an approximately 10,000 acre contiguous 

area to which some management direction is applied. For example, the amount of desired old-growth is 

identified on a 10K Block basis, which will insure distribution of this forest characteristic across the 

landscape. 

18 FMAZ 1U - 1 stands for ponderosa pine and U stands for Urban Interface as described in the Forest 

Plan page 93 –The FMAZ 1U boundary is shown on a map at the end of the replacement pages in 

Appendix A. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

12 

desired condition is to maintain cover at key sites such as northern goshawk post 

fledgling family areas, travelways, steep slopes and canyon rims, but to have flexibility to 

reduce cover outside of these areas. 

Wildlife Habitat – Wildlife Travelway 

The current Forest Plan does not mention wildlife travelways. The desire is a Forest 

Plan that recognizes the importance of wildlife travelways and the influences of people 

and fire risk reduction on the travelways. The desire is to maintain the usability of these 

areas by wildlife. 

Wildlife Habitat – Bald Eagle Winter Roost 

The current Forest Plan guidelines call for a 300-foot no-cut area around roost trees. Not 

allowing any cutting may increase risk of losing habitat to wildfire, decrease longevity of 

roost trees, and decrease availability of future replacement roost trees. The desire is to be 

able to conduct activities within this zone and in surrounding areas for the purpose of 

maintaining the longevity of the roost tree and promoting replacement roosts in the 

future. 

Forestry – Accomplish Fuel Treatments on Cultural Sites as Appropriate 

The current Forest Plan recommends avoiding cultural sites when conducting fuels 

reduction work such as thinning and broadcast burning. The desire is to evaluate each 

site to see if fuels reduction work can be accommodated, so as not to create islands of 

heavy fuels that, if burned in a wildfire, could damage the site. 

National Park Service, City, County, Research, and Centennial Forest 

Coordination 

The current Forest Plan does not recognize important communication and coordination 

needs with these entities. The desire is an emphasis on communication and coordination 

especially related to adjacent land uses and development. 

Viewshed to National Monuments 

The current Forest Plan does not mention the viewsheds to the National Monuments as 

areas where management activities could affect visitor experience within the Monuments. 

The desire is to recognize these viewsheds and consider them in site-specific planning on 

adjacent National Forest lands. 

Management Area Boundaries 

The current Forest Plan delineates Management Areas based on vegetation and 

topography, for example, ponderosa pine and mixed conifer on slopes greater than 40 

percent is MA4. The desire is to maintain this link to vegetation and topography, but also 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

13 

to identify relationships to communities and major land features. The desire is for 

management areas that describe easily recognizable locations that have an inherent 

“sense of place” associated with them. Another desire is for a more detailed breakdown 

of management areas that takes into account different land uses because of adjacency to 

residential areas. In addition, it is desirable to identify and set boundaries around 

currently established uses. Management areas do not currently follow watershed 

boundaries. In some areas watershed boundaries are a more advantageous boundary, 

such as the Lake Mary area. 

Cinder Hills OHV Area Management 19

The current Forest Plan designated the Cinder Hills Off Highway Vehicle (OHV) area 

and set management direction for the site. The current Forest Plan directs the use of 

designated routes in areas where resource concerns call for more controlled use. On 

steep slopes the idea of designated routes is unwieldy because it requires more signing, 

can add to confusion and because it does not allow for safe turn out of the off-road 

vehicles. The desire is Forest Plan direction that identifies other kinds of management 

techniques to respond to resource concerns. 

Under the current Forest Plan, riders are not distributed evenly within the area. Some 

areas receive very heavy use, and other areas receive little use. This is mostly due to road 

access and the location of popular camping areas. The desired condition is to change the 

location of improved roads, and relocate camping to better distribute OHV use to 

maintain enjoyment of the area and to respond to resource concerns. Increased use is 

anticipated in the future. 

The current Forest Plan does not recognize geologic features in the OHV area that are 

tied to the eruption of Sunset Crater. The desire is a Forest Plan that recognizes and 

manages for these sites because of the geologic story they provide for research and 

education. 

The current Forest Plan has allowed for impacts to the viewshed as seen from an 

overlook inside Sunset Crater Volcano National Monument, thereby distracting from 

visitor experience objectives for the Monument. The desired condition is for a reduction 

of these impacts and public education on different public land uses. 

Flagstaff MA – Lands within Growth Boundary 

There are currently small areas of National Forest land that fall within the Urban Growth 

Boundary for the City of Flagstaff. The desire is to recognize the situation that occurs 

here. Currently there is a potential land exchange that may transfer many of these lands 

to City of Flagstaff jurisdiction for city parks and increase the size of the airport. 

 

19 Much of the text in the replacement pages is clarification for this management area. This section lists the 

purpose and need statements for those places where the text is changed. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

14 

Parking 

The current Forest Plan does not speak to parking management. The desire is to 

recognize parking management as a tool for managing recreation use in popular areas. 

Environmental Study Areas (ESA’s) 

The current Forest Plan identifies one Environmental Study Area. The desire is to 

recognize the ongoing use by Flagstaff public schools of additional sites within the FLEA 

area. 

The current Forest Plan does not recognize the high levels of daytime recreation use in 

the Mt. Elden Environmental Study Area. The desire is to provide direction that 

maintains the landscape features that make these areas desirable to study and enjoy. 

Priority For Watershed Restoration and Maintenance 

The current Forest Plan does not emphasize watershed condition related to important 

waters such as Lake Mary and Oak Creek Canyon. The desire is to set priorities for 

conducting roadwork, meadow restoration, and other practices that recognize important 

watersheds. Examples are the importance of the Lake Mary watershed to municipal 

water supply and the importance of Oak Creek Canyon as a specially designated 

watercourse. 

DECISION TO BE MADE 

Based on the environmental analysis in the Final Environmental Impact Statement, the 

Coconino National Forest Supervisor will decide whether to adjust Forest Plan direction 

as proposed in one of the alternatives, or with a mix of the alternative direction, or not at 

all. 

PROPOSED ACTION 

When the Proposed Action was made available in September 2001, it consisted of the 

replacement pages that would be used to update our current Forest Plan. These pages are 

located in Appendix A. Based on public comment, some of the replacement pages were 

edited. These clarifications are shown as underlined if they are added text and overstrike 

if they are meant to be deleted.

Because of the volume of replacement page text, it is difficult to summarize the content 

of the Proposed Action. Readers are encouraged to look at Appendix A for details about 

the Proposed Action. Topics include: Forest Settings, Camping, Outfitter/Guides, Group 

Use, Rock Climbing, Trails, Scenery, Roads, Wildlife Habitat (including Mexican 

spotted owls and goshawks), Land Exchange, Forestry, Noxious Weeds, Watershed, 

Mountain Meadows, Riparian, Firewood, National Park Service Coordination, Research 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

15 

Coordination, Other Organization Coordination, and Data Management, Cinder Hills 

OHV area, Lakes Mary, Environmental Study Areas and Management Areas. 

Using comments received on the Proposed Action (see discussion of Significant Issues 

later in this chapter) and information from preliminary analysis, the interdisciplinary team 

developed alternatives to the Proposed Action. These are discussed in detail in Chapter 2 

in the section titled Alternatives Considered in Detail. 

PUBLIC PARTICIPATION 

The Council on Environmental Quality (CEQ) defines scoping as ”...an early and open 

process for determining the scope of issues to be addressed and for identifying the 

significant issues related to a proposed action” (40 CFR 1501.7). In addition to the 

following specific activities, the FLEA project has been listed on the Coconino National 

Forest Quarterly Schedule of Proposed Actions since January 1999, which is mailed to 

approximately 500 persons, organizations, and agencies. 

Proposed Action (PA) 

The Proposed Action was mailed to approximately 800 addresses. 

Notice of Intent (NOI) 

A Notice of Intent to prepare an EIS was published in the Federal Register on April 17, 

2002. 

Public Meetings 

An Open House was held on October 22nd, 2001, from 4 till 8 p.m. in the conference 

room of the Coconino Supervisor’s Office in Flagstaff, where people could view larger 

scale maps and ask team members questions about the Proposed Action. 

Local News Media 

A public service announcement was aired on local TV and Radio stations announcing the 

availability of the Proposed Action prior to the October 22nd Open House. On Friday, 

October 19th, a notice appeared in the community news section of the local newspaper, 

the Arizona Daily Sun, announcing the open house and availability of the Proposed 

Action. 

Meetings with Agencies, Communities, Native Groups, and Others 

During the weeks of October 22 to November 16th, meetings were held with 

representatives from the U.S. Fish and Wildlife Service, the Arizona Game and Fish 

Department, the Grand Canyon Trust, and Bruce Johnson. These meetings were at the 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

16 

request of these individuals so that they could ask team members questions about the 

Proposed Action. 

Other Sources 

Team members, when developing the Proposed Action reviewed public comment 

received in response to Ideas for Change for the Flagstaff/Lake Mary Analysis. This 

document was published in May of 1999. Three Open House meetings occurred, one on 

May 26th at the Flagstaff High School, one on May 27th at the Cromer School in Doney 

Park, and one on June 3rd at the Highlands Fire Station in Kachina Village. 

 

Responses to the Ideas for Change included: 150 letters or e-mails, 10 petitions, and 185 

open house comment sheets. Organizations that commented included: Friends of Walnut 

Canyon, Bullhead 4 Wheelers, Inc, Cinder Hills Rough Riders, American Motorcyclist 

Association, Arizona Snowbowl, and Southwest Forest Alliance and Mountain Mushers. 

Commenting agencies included Flagstaff Fire Department, Game and Fish Department, 

City of Flagstaff, White Mountain Apache, and Navajo Tribes. 

ALTERNATIVES NOT ANALYZED IN DETAIL 

The following options were considered by the interdisciplinary team, but were not carried 

forward for different reasons: they did not meet the Purpose and Need; they were already 

covered under another alternative; or because further analysis excluded a need for the 

alternative. The public comment that generated the alternatives considered but not 

analyzed in detail is written in italics. The rationale as to why the alternative was not 

carried forward for detailed analysis follows in regular type. Additional comments are 

located in Appendix B. 

Comment from Taylor McKinnon, Grand Canyon Trust 

The proposed management area delineations are arbitrary because they are 

primarily based on “sense of place” and other subjective recreational values 

rather than on natural geographical or biological boundaries on the 

landscape. We are concerned that the proposed management areas will not 

provide an ecologically based context for future environmental analyses, and 

does not represent the best and latest thinking in land management planning. 

The importance of using ecological or biogeographical boundaries to 

delineate management units has been emphasized in innumerable studies and 

Forest Service publications. Considering that the Forest Service has been 

moving towards using ecological or geographic boundaries such as 

watersheds in determining management units, the proposed Management 

Area delineation seems to represent a step backwards rather than forward in 

the Forest Service ecosystem management. Please consider an alternative 

that delineates management areas according to ecological or biogeographical 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

17 

units such as 6th order watersheds (or aggregations of these) or other natural 

boundaries. 

In a portion of the Coconino National Forest dominated by social concerns, it seems very 

appropriate to have a sense of place be the dominating reason for creating management 

areas. Many other National Forests are using sense of place for the designation of MAs 

where it is appropriate for communicating with the public and where it makes sense to 

have common management direction for an area. The ”sense of place” for each of the 

FLEA Management Areas is provided in part by landscape features. For example, the 

Walnut Management Area is drawn around the canyon itself and surrounding landscapes 

that affect the canyon. The addition of lands between Sunset Crater Volcano and 

Wupatki National Monuments was added based on concerns from the National Park 

Service for additional consideration of the ”cultural landscape” of ancient peoples. 

During the identification of these MAs many biophysical resources were also considered, 

such as MSO habitat and similar vegetation types. The FLEA analysis boundary does not 

follow watershed lines entirely, although portions do. Administrative allocations, such as 

wilderness and the OHV area, create anomalies if all of the management areas were 

based on watershed boundaries. Watershed boundaries also make more sense if you are 

in a landscape where the transportation system design has been strongly influenced by 

heavily dissected terrain, such as the Pacific Northwest or the Rockies. Here the 

watershed boundaries are often not even noticeable as one travels across the gentle 

rolling terrain that dominates most of the FLEA area. 

For many topics, management direction still comes from the current Forest Plan

direction that is based on vegetative type and topography. For example, Management 

Area 3 - Ponderosa Pine less than 40 percent slope – standards and guidelines still apply, 

with FLEA providing additional direction. 

There is a difference between management area delineations and the boundaries used to 

determine environmental effects. Effects analysis is ecologically based and will be 

accomplished using a variety of locations depending on the nature of the resource. For 

example, visual resources are addressed via lines of sight that are variable depending on 

topography and may cross watershed boundaries. 

Comment from Taylor McKinnon, Grand Canyon Trust 

Nonetheless, we have three specific concerns with the proposed ROS 

designations. Our first concern is that designations, whatever they are 

eventually determined to be, should be established as standards rather than 

guidelines (as proposed). Secondly, we are concerned that without 

maximizing the acreage of semi-primitive non-motorized designations in 

important habitats (as listed above), motorized designations will continue to 

facilitate trends of ecologically unsustainable use patterns of increasing road 

proliferation that are tremendously difficult and expensive to undo once 

established. We are concerned that without aggressively addressing these 

issues, we will continue to see increasing trends of road proliferation and 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

18 

associated effects consistent with those documented in our San Francisco 

Peaks Roads inventory project (much of which occurred within the FLEA 

area): 

• Only 45% of the 1300 roads had any evidence of being constructed, the 

rest were user-created or illegal ghost roads 

• Only 11% showed evidence of being maintained 

• 71% of all the roads showed signs of erosion 

• Roads were directly correlated with introduction of exotic species and 

illegal dumping 

• Road densities often significantly exceeded the Forest Service's road 

density guidelines for the study area. 

• In many areas road densities exceeded densities which have been shown 

to negatively impact habitat for black bear, mountain lion, elk, and deer. 

While we are greatly encouraged by and extremely supportive of the 5-forest 

ORV policy, we believe the effects listed above merit that all opportunities to 

improve road and recreation management—including ROS—should be 

addressed accordingly. We encourage the Forest Service to evaluate a range 

of alternatives for ROS designations that includes an alternative with 

significantly more acreage designated as semi-primitive non-motorized than is 

proposed for the explicit purpose of evaluating the greatest level of 

protections for important ecological values in the FLEA analysis area. 

The definition used in the Proposed Action for a guideline20 allows some flexibility as 

staffs implement site-specific projects with more detailed inventory information. 

Recreation Opportunity Spectrum (ROS) setting designations have been drawn based on 

a variety of resource information; however, site-specific analysis may indicate that some 

modification in the location of those lines is appropriate. Therefore, it is important to 

leave this option for future refinement available. 

This comment is asking for consideration of an increased amount of SPNM areas on the 

FLEA landscape. However, the rationale for this request is unsound in that it links ROS 

objectives with road policy and administration. Two separate agency activities. The 

ROS objectives are something to strive for, similar to the northern goshawk guidelines 

and other descriptions of desired conditions. These objectives are generally not based on 

how quickly they will be achieved. There is some confidence among land managers, that 

because of road policy and budget trends, the semiprimitive motorized objectives can be 

achieved, thereby creating patches of unroaded landscape in between the open roads. 

 

20 Guidelines describe a preferred or advisable course of action, desired policy or conduct. Variation of a 

project from a guideline does not trigger a forest plan amendment. Guidelines may be used for the 

following purposes: 1) To describe a preferred or advisable method for conducting resource activities 

specific to the forest plan area and 2) to describe a preferred or advisable sequence or priority for 

implementing various types of projects when such guidance is deemed useful in facilitating achievement of 

a forest plan goal.
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

19 

The concern of road proliferation is being addressed via other avenues outside of the 

FLEA process. As this comment mentions, the current mix of road policies has resulted 

in some areas with high mileages of user-created roads. Currently, approximately 26 

percent of the National Forest acres in the FLEA area are under either an area closure, or 

“drive only on designated open roads” policy. When the seasonal motorized closure in 

the Pinegrove Quiet area is considered, the total acreage rises to 30 percent. The 

remainder of the FLEA area has an “open unless designated closed” travel policy. This 

means a person may drive on a road or two-track or off of roads (provided resource 

damage does not occur) unless posted otherwise. Another factor in successful 

implementation of road management and subsequent ROS settings is the number of 

personnel available to patrol, public information campaigns, and signs. These factors are 

administrative in nature and best addressed in debates over funding and priorities. The 

ongoing Cross-country Use of Motorized Vehicles in Five Arizona National Forests 

analysis, may lead to policies that enhance our ability to successfully achieve the SPM 

setting. 

Settings that are SPM include patches of unroaded landscape in between the road 

network. Many of the ecological values maintained under SPNM settings are also 

maintained under SPM settings. A well-designed system of secondary roads, with 

unroaded patches in between, maintains the ecosystem and provides for a remote 

recreation experience. 

In addition, roads are only one element of ROS settings. Other items include vegetation 

management, facilities, and numbers of social encounters. 

Comment from Sam Henderson, Flagstaff Area Monuments, National Park 

Service 

In keeping with our comments and issues regarding motorized access to the 

Monument boundaries, we would prefer to see “semi-primitive nonmotorized” objectives emphasized in a buffer area surrounding each of the 

three monuments. This includes the area surrounding the eastern end of 

Walnut Canyon NM, where we are very concerned about continued 

convenient motorized access within close proximity to the canyon rim, and 

potential impacts to archaeological sites and sensitive raptor species (MSO, 

and Goshawk) which nest in the canyon. This would also require revising the 

ROS Objectives map. 

We propose specific emphasis be added for reducing all road access to within 

one mile of the Walnut Canyon rim (not the NM boundary). This would 

effectively deter access to the canyon slopes, cliff dwellings, and sensitive 

raptor nest sites throughout the canyon, preclude clandestine access via the 

heavily vegetated side canyons, and increase our ability to enforce general 

access restrictions within Walnut Canyon NM. 

A discussion of the effects of alternatives on the Monuments will be a part of Chapter 3. 

The ROS objectives do not lend themselves to strips of different settings. Physical road 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

20 

closures and road management policies are not required to follow ROS boundaries. On 

the contrary, actual roadwork and road policies will use easy-to-find landlines and 

physical features. The ROS objectives do not preclude continued efforts to close roads as 

needed that are adjacent to or enter the Monuments. 

Expanding the SPNM setting near the northeastern end of Walnut Canyon National 

Monument was considered but not carried forward. The SPM setting in this area is 

sufficient and recognizes the need for some open roads in this area to serve the range 

permittee, provide access to private land, and to provide road access to the First Fort area 

as mentioned in the National Park Service’s preferred alternative in the Draft General 

Management Plan for Walnut Canyon National Monument. 

Rather than use a statement such as ”reduce all road access within 1 mile of the Walnut 

rim” the ROS setting objectives provide a similar end product. There are alternatives 

analyzed for the area northeast of Fisher Point that will have different distances to open 

roads from the Walnut Canyon rim. In addition, the Roads Analysis Report for the FLEA 

Area, which is a concept plan for managers and not a site-specific decision, recommends 

road choices in keeping with the ROS objectives and goals for protection of Walnut 

Canyon. In some cases, a mile long distance may be too far for trailhead parking access. 

It is beneficial to have some places where people can park and hike, mountain bike or 

ride horses less than a mile to enjoy sites such as Fisher Point or Canyon Vista. 

Comment from Ivo Lucchitta 

According to your own statements, areas within 1⁄2 mile of private land have a 

high risk of fire ignition and have the highest priority for fire risk reduction. 

This is even more pressing when the private land contains dwellings, as it is 

the case here. Consequently, it would make sense to decrease the fire danger 

by eliminating access by vehicles to this 11⁄2 by 1 mile area (area between Fort 

Valley and A1 Mountain). For the same reason, the area should be assigned 

to the proposed No Camping/No Campfires category. There are just too many 

dwellings down wind. Other areas where people can travel in vehicles and 

camp are not in short supply. It is sobering to know that we have seen 

transients’ camps in the area. Eliminating vehicles and camping would have 

a positive impact on wildlife. 

Note: This response discusses the camping part of this comment. ROS alternatives were 

developed and analyzed in detail. 

Currently camping in this area is minimal. Implementing camping restrictions cannot be 

done everywhere given Forest Service personnel and funding levels, therefore camping 

restrictions are not proposed around the Fort Valley Community. However, if there are 

increased threats and disturbances, such as fire, trash, noise, or crime to residents, the 

Forest Plan language in Alternative A allows expansion of camping restrictions as 

necessary in the future without a Forest Plan Amendment. Contact the Recreation Staff 

of the Peaks Ranger District to report impacts. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

21 

Comment from Taylor McKinnon, Grand Canyon Trust 

First we are concerned that proposed actions to abandon recovery goals for 

the MSO will, when considered in combination with the region 3 Wildland 

Urban Interface MSO amendments, contribute to jeopardy of the Mexican 

spotted owl. Second, we question need for such a proposal: existing 

management directions outlined in the Recovery Plan provide for fire risk 

reduction treatments in MSO habitat, and the subject restricted habitat 

constitutes only 1539 acres (2%) of the approximately 65,000 acre U/RIZ. 

Surely management scenarios can be developed that provide for MSO habitat 

and a satisfactory reduction in fire risk for the community. Our third concern 

rests in the fact that this proposal (unnecessarily) pits ecosystem restoration 

goals against community protection goals when, in actuality, these values are 

entirely compatible—which may undermine existing collaborations based 

upon shared interest between the fire protection community and restoration 

community. 

We urge the Forest Service to evaluate an alternative that does not include 

changes to Mexican spotted owl habitat management. 

The No Action alternative will provide a basis for comparing no change to MSO habitat 

management. 

The Recovery Plan for the Mexican spotted owl as adopted by the Coconino Forest Plan 

Amendment 11 displays that 10 percent of pine-oak habitat and 15 percent of mixed 

conifer restricted area should be managed for target-threshold conditions and states the 

following: 

“In project design, no stands simultaneously meeting or exceeding the minimum 

threshold values should be reduced below the threshold values unless a districtwide or larger landscape analysis or restricted areas shows that there is a surplus 

of restricted area acres simultaneously meeting the threshold values. 

Management should be designed to create minimum threshold conditions on 

project areas where there is a deficit of stands simultaneously meeting minimum 

threshold conditions unless the district-wide or larger landscape analysis shows 

there is a surplus.”

To address issues of fuels reduction in the urban interface the Urban/Rural Influence 

Zone (U/RIZ) was created. No management changes are proposed for existing MSO 

PAC’s or protected habitat within this zone. 

A clarification to the FLEA proposed guideline for future projects within the FLEA area 

would be to not allocate target threshold stands within the U/RIZ. However, target 

threshold habitat would be allocated in other parts of the FLEA area. The replacement 

pages text have been clarified to indicate the allocation of target threshold habitat within 

the Lake Mary Watershed and Shultz Management Areas. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

22 

Existing condition displays 186 acres of mixed conifer and 850 acres of pine oak 

restricted habitat within the U/RIZ. The distribution and patch size of the restricted areas 

within the U/RIZ would provide marginal nest/roost habitat for Mexican spotted owls. 

Potentially, 100 acres of mixed conifer and 85 acres of pine oak habitat could be 

designated to maintain or promote target threshold conditions within the U/RIZ. The 

FLEA guideline to not designate target threshold habitat within the U/RIZ is in the best 

long-term interest of habitat management for the Mexican spotted owl. The FLEA 

allocation of target threshold habitat within the Lake Mary Watershed and Shultz 

Management Areas would better provide for long-term management of roost/nest habitat 

for the Mexican spotted owl. It is estimated that approximately 18 percent of the Shultz 

Management Area and 11 percent of the Lake Mary Watershed would be managed for 

target-threshold conditions in the future, due to not allocating target threshold conditions 

in the U/RIZ. 

ISSUES AND EVALUATION MEASURES 

Significant issues for the FLEA Project were identified through public scoping. The 

issue statements that follow were written by the interdisciplinary team, and represent a 

synthesis of a variety of public comments. The following issues were determined to be 

significant and within the scope of the project decision. These issues are addressed in the 

Proposed Action and alternatives to the Proposed Action. Additional concerns were 

considered but determined to be non-issue questions or comments, or nonsignificant 

issues. These concerns are discussed separately in Appendix B, Comment Analysis and 

Response to Comments. 

Issue 1 – Wildlife Cover 

Not retaining 30 percent hiding and thermal cover within the FMAZ 1U will affect native 

species including management indicator species. Wildlife would be impacted in the 

vicinity of Walnut Canyon if no cover were provided. There are large-sized wildlife that 

take advantage of the thermal and hiding properties of dense stands along the Walnut 

Canyon rim, part of which falls within the FMAZ 1U. Wildlife would be impacted in the 

area of Woody Ridge if no cover were provided. 

Evaluate this issue by estimating the amount of cover that would likely occur in Post 

Fledgling Family Areas (PFA’s), steep slopes, wildlife travelways, and canyon rims 

within the Fire Management Analysis Zone. Determine the effect to wildlife. Describe 

whether or not the amount and configuration of low fire potential stands that can be 

achieved meets fire management goals. 

Issue 2 – A1 Mountain Area ROS 

A SPM setting in the small area adjacent to private land on the south side of Fort Valley 

and south of A1 Mountain may not be the best setting choice for this area. Fire risk 

reduction is better achieved with a nonmotorized setting where private lands are located 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

23 

in the path of prevailing winds. Wildlife habitat for elk, deer, fox, coyote, raptors, and 

prairie dogs is better served by a nonmotorized setting. The area is too small to be useful 

to motorized travel and many of the current routes dead-end. 

Evaluate this issue by describing the recreation experience achieved under a SPNM and 

SPM setting. Describe risk of fire ignition under the two settings. Describe big game use 

under the two scenarios and the relative importance of this area to big game. Describe 

prairie dogs and raptor use under the two scenarios. 

Issue 3 – Skunk/Fay Canyons and North of Fisher Point ROS 

A SPM setting surrounding Skunk and Fay Canyons and lands north of Fisher Point may 

not be the best choice for this area. The type of recreation experience desirable is 

nonmotorized recreation such as hiking, mountain biking, and horse riding. Absence of 

vehicles will maintain areas with limited erosion especially in canyon bottoms and steep 

slopes. Absence or limited vehicles will lessen levels of human disturbance to sensitive 

wildlife species so that the wildlife are more likely to successfully occupy the canyon and 

its rim. 

Evaluate this issue by describing the recreation experience achieved under a SPNM and 

SPM setting. Describe trends in soil erosion especially on steep slopes and canyon 

bottoms under the two setting scenarios. Describe disturbance sensitive species in the 

area (turkey and MSO) and whether or not there is a difference in levels of human 

disturbance under the two different settings. 

Issue 4 – Waterline Road Area ROS 

The SPM setting downslope from the Waterline Road (FR 14621) may not be the best 

choice for this area. The Proposed Action creates too many SPNM patches on the 

landscape, limiting opportunity for forest driving experiences especially at high 

elevations and around the San Francisco Mountain. A nonmotorized setting is not 

necessary for disturbance sensitive species. Wildlife habitat can still be maintained with 

a well-designed SPM road system. 

Evaluate this issue by describing the overall percentage of the FLEA area in the SPM 

settings under various alternatives. Make a statement about the overall amount and 

quality of motorized experiences in the FLEA area, and cumulatively around the San 

Francisco Mountain, especially related to the ability to enjoy remote, rough road, driving 

experiences. Describe disturbance sensitive species in the area (turkey and MSO) and 

whether or not there is a difference in levels of human disturbance under a SPM or 

SPNM setting. This includes estimating the amount and types of human use that occurs 

here. 

 

21 FR146 travels along the Kachina Wilderness boundary on the east side of the San Francisco Mountain. 

It is gated and used as a recreation trail and provides maintenance access to the City of Flagstaff wells in 

the Inner Basin. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 1 – Purpose and Need for Action 

24 
25 

 

CHAPTER 2 - ALTERNATIVES 

INTRODUCTION 

This chapter describes and compares the alternatives considered for the Flagstaff/Lake 

Mary Ecosystem Analysis. It includes a description of each alternative considered. This 

section also presents the alternatives in comparative form, sharply contrasting the 

differences between each alternative and providing a clear basis for choice among options 

by the decision maker and the public. Some of the information used to compare the 

alternatives is based upon the design of the alternative and some of the information is 

based upon the environmental, social and economic effects of implementing each 

alternative. 

COMMON TO ALL ACTION ALTERNATIVES 

Based on the comments received on the Proposed Action, most of the proposed changes 

to the Forest Plan remain the same for the alternatives. This is because we received no 

comments that could have been a basis for evaluating a change. Some adjustments were 

made to the Proposed Action for clarification, but they did not change the intent. This 

type of change is highlighted in the replacement page texts in Appendix A. 

Another item that is common to all alternatives is the definition of wildlife cover that is 

listed in the current Forest Plan on page 124. 

At the beginning of Chapter 3, there are assumptions related to Recreation Opportunity 

Settings (ROS) that were used throughout this analysis. These assumptions are common 

to all action alternatives. 

ALTERNATIVES CONSIDERED IN DETAIL 

Except for the issue areas, the action alternatives are similar, and most of the Forest Plan

replacement page language is the same for the action Alternatives A, C, and D. These 

alternatives are different based on the four issues. When selecting an alternative, the 

decision maker can select different components of alternatives as they relate to the issues. 

ROS maps are located in Appendix A. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

26 

Alternative A (Proposed Action) 

Alternative A consists of all the replacement page text located in Appendix A, plus the 

following changes from current management (Alternative B). 

• There is no cover requirement in the FMAZ 1U. In the remainder of the FLEA 

area, cover is provided on 30 percent of the forested areas of a 10K Block 22 with 

10 percent in hiding cover, 10 percent in thermal cover and 10 percent in 

combination hiding and thermal cover. 

• The Waterline Road area is classified as a SPNM. 

• The A1 Mountain area adjacent to private lands in Fort Valley is classified as a 

SPM. 

• The Skunk/Fay Canyon areas and lands north of Fisher Point are classified as a 

SPM. 

Alternative B (No Action) 

Alternative B does not use the replacement page text in Appendix A, rather the current 

Forest Plan text applies. 

• Under No-Action, cover is provided on 30 percent of the forested areas of a 10K 

Block with 10 percent in hiding cover, 10 percent in thermal cover and 10 percent 

in combination hiding and thermal cover. 

• The Waterline Road area is classified as SPM. 

• The A1 Mountain area adjacent to private lands in Fort Valley is classified as RN. 

• The Skunk/Fay Canyon areas and lands north of Fisher Point are classified as RN. 

Alternative C 

Alternative C consists of all the replacement page text located in Appendix A, plus the 

following changes from current management (Alternative B). 

• In the Fire Management Analysis Zone, cover is provided in a maximum of 15 

percent of the forested acres in a Section. In the remainder of the FLEA area, 

cover is provided on 30 percent of the forested areas of a 10K Block with 10 

 

22 10K Block is a designation used in the Forest Plan to identify an approximately 10,000 acre contiguous 

area to which some management direction is applied. For example, the amount of desired old-growth is 

identified on a 10K Block basis, which will insure distribution of this forest characteristic across the 

landscape. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

27 

percent in hiding cover, 10 percent in thermal cover and 10 percent in 

combination of hiding and thermal cover. 

• The Waterline Road area is SPM with roads located to limit impacts to 

disturbance sensitive species. 

• The A1 Mountain area adjacent to private lands in Fort Valley is SPNM. 

• The Skunk/Fay Canyon areas and lands north of Fisher Point are classified as 

SPNM ROS settings with one or two SPM road corridors.23

Alternative D 

Alternative D consists of all the replacement page text located in Appendix A, plus the 

following changes from current management (Alternative B). 

Cover is the same as Alternative C. 

• The Waterline Road area is classified as a SPNM. 

• The A1 Mountain area is classified as a SPNM ROS setting. 

• The Skunk/Fay Canyon areas and lands north of Fisher Point are entirely 

classified as SPNM. 

Table 1 Summary of Issues and Alternatives 

Issue Alt A Alt B Alt C Alt D 

#1 – Cover No 

requirement 

in FMAZ 

30% of 

forested 

acres in 

10K block 

15% of 

forested acres 

in a Section24

within FMAZ 

15% of 

forested acres 

in a Section 

within FMAZ 

#2 – A1 Mountain SPM RN SPNM SPNM 

#3 – Skunk/Fay SPM RN SPNM with 

SPM 

corridor(s) 

SPNM 

entirely 

#4 – Waterline SPNM SPM SPM roads 

designed for 

wildlife 

SPNM 

 

23 The map for this alternative shows a SPM road corridor linking Old Walnut Canyon Road to Fisher 

Point area. An alternate open road corridor may be chosen based on site-specific analysis. The final 

outcome would not be required to follow the existing FR301 alignment. 

24 A Section is 640 acres, 1 square mile. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

28 

HOW THE ACTION ALTERNATIVES MEET THE PURPOSE AND 

NEED 

Because there is a long list of items in Alternative A that do not change in the other 

action alternatives, it is advantageous to describe for the reader and decision maker how 

well these items meet the Purpose and Need. The items listed in the following table do 

not change by action alternative. Text changes for the Forest Plan apply to the FLEA 

area only. 

Table 2 Summary of Changes Common to All Action Alternatives and How They 

Meet Purpose and Need 

Topic Area Summary of Change 

Fuels 

Urban/Rural 

Influence Zone 

Changes create greater emphasis for fire risk reduction within 

approximately 1⁄2 mile of private land. There is recognition of 

the high levels and types of daytime recreation uses prevalent 

near residential areas. There is recognition that human 

disturbance to wildlife is greater in areas adjacent to residential 

areas. 

Recreation 

Opportunity 

Spectrum 

Changes provide a forest setting tool (ROS objectives) giving 

land managers a recreation experience and forest character to 

strive towards. 

Much of the areas currently supporting key wildlife habitat 

would be Semiprimitive ROS setting, either Motorized or 

Nonmotorized. 

Objectives include an increase in Semiprimitive recreation 

opportunities. 

Recreation

Camping 

Changes describe a wider variety of camping management 

options (an example is designated dispersed camping). 

Text is current concerning stay limits and no camping near 

developed recreation sites on the Peaks and Mormon Lake 

Ranger Districts. 

Text allows us to take actions to reverse deleterious trends and 

improve soil and water quality conditions in areas of very high 

concentrations of dispersed camping in the Highway 89A 

corridor, Pumphouse Wash, Marshall Lake, Lake Mary, and 

Walnut Canyon. 

Changes include a change from 53.7% to 75.9% of the
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

29 

Topic Area Summary of Change 

Urban/Rural Influence Zone closed to camping thereby reducing 

risk of fire ignition in this zone. 

Recreation

Outfitter/Guides 

and Group Use 

Changes create a more efficient process for review, approval, or 

denial of outfitter/guide proposals. New outfitter/guide permits 

will be awarded competitively by soliciting proposals. 

ROS objectives would provide a tool by which recreation 

experience is considered when approving outfitter/guides. There 

is recognition of areas where outfitter/guide activities may not be 

suited, given ecological sensitivity or levels of individual use or 

both. 

Recreation

Rock Climbing 

Changes provide direction for this activity. 

A desired condition is described to maintain climbing 

opportunities while protecting sensitive wildlife and vegetation. 

Recreation

Trails 

Changes recognize the trail situation that occurs adjacent to 

residential areas in terms of higher levels of daytime use, and 

user-created (social) trails. 

Changes place emphasis on reducing impacts of social trails to 

threatened and endangered species. 

Changes place emphasis on reducing or eliminating impacts of 

social trails to riparian sites (drainage bottoms and lakebeds). 

Changes emphasize the need for community linkages and access 

points. 

Changes provide for ecologically sound trail conditions, without 

micromanaging each user-created (social) trail. 

ROS objectives would provide a planning tool that helps 

managers determine the amount and type of trails to construct 

for nonmotorized and motorized use. 

Changes identify some areas where off-trail use by large 

numbers of nonmotorized recreationists is discouraged in order 

to maintain minimal human disturbance to wildlife or limit soil 

movement on steep cinder or canyon slopes. 

Changes identify motocross as an activity that is not suited for 

National Forest lands. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

30 

Topic Area Summary of Change 

Roads Changes add items to the list of criteria used to make road 

closure decisions. Examples include, recreation experience and 

opportunity, (ROS settings), redundant and/or poorly located 

social roads, noxious weeds, and illegal human activities. 

 

Changes create a list of criteria for keeping roads open. 

Changes provide direction on how to choose where roadwork 

should occur first. 

Wildlife Habitat

Mexican Spotted 

Owls 

Changes recognize the inevitable impacts of noise, pets, usercreated trails, and other recreation uses that occur adjacent to 

residential areas. 

Changes emphasize future allocation of target threshold habitat 

outside of the U/RIZ and in the Shultz and Lake Mary 

Management Areas. 

Wildlife Habitat

Northern Goshawk 

Changes provide more detailed direction concerning recreation 

use in PFA’s, and a recognition of high levels of human 

influences in PFA’s located adjacent to residential areas. 

Wildlife Habitat

Threatened and 

Endangered 

Species 

Changes emphasize monitoring human disturbances prior to 

approving new site-specific projects. Proposed changes allow 

for future recreation use restrictions, if needed, based on 

monitoring. 

Wildlife Habitat 

Bald Eagle Winter 

Roost Guidelines 

Changes allow management activities to occur within and 

adjacent to winter roost trees and in surrounding areas for the 

purpose of maintaining the longevity of the roost tree and 

promoting replacement roosts in the future. 

Wildlife Travelway Changes allow for the maintenance of wildlife travelways 

through balancing human uses and fire risk reduction needs with 

wildlife cover needs in travelways. 

Forestry 

Fuel treatments on 

Cultural Sites as 

Appropriate 

Changes allow for fire risk reduction activities to occur on 

cultural sites if those activities are determined to be 

nonimpacting and/or in the best interest of protecting the site. 

Coordination with 

Other Agencies

Changes emphasize communication and coordination especially 

related to adjacent land uses and development. 

Visuals

Viewshed to 

National 

Monuments 

Changes identify viewsheds of the National Monuments as 

important considerations in future decisions. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

31 

Topic Area Summary of Change 

Recreation

Cinder Hills OHV 

Area 

Changes allow for slope closures instead of designated routes to 

respond to resource concerns and provide for safe, enjoyable 

riding. 

Changes allow for distributing riders more evenly within the area 

and away from areas of resource concern by relocating improved 

roads and camping areas. 

Changes identify geologic features in the OHV area that are tied 

to the eruption of Sunset Crater. Proposed changes identify 

potential activities such as road relocations, camping relocation, 

slope closures, and an area closure around Gyp Crater to better 

maintain and protect these sites. 

Management Areas

Boundaries 

Changes maintain the link to vegetation and topography, but also 

provide references to communities and established uses. 

Management Areas

Flagstaff MA lands 

within growth 

boundaries 

Changes identify lands within the Urban Growth Boundary for 

the City of Flagstaff. These lands are suited for transfer to other 

ownership in keeping with local City plans. 

Recreation

Parking 

Parking Management is added as a tool for reducing impact and 

providing for recreationists. 

Environmental 

Study Areas

(ESA’s)

Changes adopt two new ESA’s at Old Caves Crater and Griffiths 

Springs and expand the existing ESA at the base of Mt Elden. 

Desired Conditions are described for the high levels of daytime 

recreation use and landscape features that make these places 

available to study and enjoy. 

Lake Mary and 

Oak Creek 

Watersheds

Priority for 

Watershed 

Restoration and 

Maintenance 

New language identifies the Lake Mary/Walnut and Oak Creek 

Canyon as important waters. Within the FLEA area, priorities 

are identified for conducting roadwork, meadow restoration, and 

other practices. 

COMPARISON OF ALTERNATIVES 

This section describes the effects of alternatives for the significant issues. In many 

environmental impact statements, Chapter 2 contains only a brief summary of the effects 

of the alternatives. However, in this document, Chapter 2 is larger and more detailed. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

32 

This is for two reasons, 1) because the issue areas are only a small percentage of the 

overall FLEA area and separate discussion was necessary and 2) to separate for the reader 

key issue information and other required topics. Both chapters should be read for an 

understanding of all the environmental and social effects. 

Issue 1 (Cover) Comparison of Alternatives 

How the Alternatives are Different

Alternative A would remove the wildlife cover guideline and not require the minimum 30 

percent guideline be applied per 10K Block within the U/RIZ and FMAZ 1U boundary’s. 

Dense stand conditions would be maintained within Mexican spotted owl PAC’s, 

northern goshawk PFA's, steep slopes, and wildlife travelways and provide 

approximately 16 percent cover within the U/RIZ and FMAZ 1U boundaries. The 

distribution of 16 percent cover would be in large blocks and concentrated in the Schultz 

MA, West MA, and along Walnut Canyon in the Walnut Canyon MA. 

Alternative B (No Action) is the current Forest Plan management direction. This 

guideline requires that a minimum of 30 percent cover be applied on the landscape per 

10K Block25 within MA3. Generally during site-specific project level environmental 

analysis cover is identified at the stand level and cover deferrals are made in key wildlife 

areas, such as Mexican spotted owl PAC’s, northern goshawk PFA’s, or wildlife 

travelways. 

Alternative C and D would apply a maximum 15 percent cover guideline within forested 

areas distributed by Section26. The cover would be distributed in small patches and linear 

patterns. Cover would not be in large patches. Recent examples are cover allocations 

made on the A1 Ecosystem Management Project, Fort Valley Ecosystem Restoration 

Project, and the upcoming Kachina Village Forest Health Project. Dense stand 

conditions would be maintained within Mexican spotted owl PACs, northern goshawk 

PFA's, steep slopes, and wildlife travelways and provide approximately 16 percent cover 

within the U/RIZ and FMAZ 1U boundaries. 

Fire Risk and Hazard

Both fire risk and fire hazard have increased within the Ponderosa Pine Urban Interface 

Fire Management Analysis Zone (FMAZ 1U). The retention of at least 30 percent of the 

forested area within this zone in dense cover conditions (Alternative B) prevents fire 

managers from achieving the desired future condition for fire potential within the FMAZ 

1U. It is conducive to a severe wildfire occurring in close proximity to residential and 

commercial development. 

 

25 10K Block is a designation used in the Forest Plan to identify an approximately 10,000 acre contiguous 

area to which some management direction is applied. For example, the amount of desired old-growth is 

identified on a 10K Block basis, which will insure distribution of this forest characteristic across the 

landscape. 

26 A Section is 640 acres, 1 square mile. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

33 

Alternative A would lift the cover requirement only within the FMAZ 1U, placing a clear 

emphasis on fire safety within the wildland urban interface. It would not prohibit the 

retention of wildlife cover. Some wildlife cover would be maintained within this zone 

under Alternative A. However, it would provide fire managers with the flexibility to thin 

dense stands that are particularly at risk of ignition or that are particularly hazardous to 

neighborhoods. The percentage and arrangement of wildlife cover retained within the 

FMAZ 1U for any subsequent project would be determined by the “fire risk” and “fire 

hazard” of the particular site. Under Alternative A fire managers could achieve the 

desired future condition for fire potential within the FMAZ 1U. 

Alternatives C and D both reduce the 30 percent wildlife cover requirement within the 

FMAZ 1U to a maximum 15 percent per Section. This would provide fire managers with 

less flexibility than Alternative A to thin dense stands that are particularly at risk of 

ignition or that are particularly hazardous to neighborhoods. However, if the cover 

patches (comprising the 15 percent) were kept small and distributed carefully with 

considerations for topography and the prevailing wind direction, fire managers could 

achieve the desired future condition for fire potential within the FMAZ 1U. 

Wildlife Habitat

Alternative A would result in a potential 50 percent reduction or 18,000 acres less cover 

within the FMAZ 1U boundary compared to Alternative B (No Action). The acres that 

would be managed for cover condition would be predominately large blocks of cover 

concentrated within the Schultz Management Area; West Management Area along 

Woody Ridge, Fry Canyon, Kelly Canyon; wildlife travelway between A1 Mountain and 

southern slopes of the San Francisco Mountain; and Walnut Canyon within the Walnut 

Canyon Management Area. Outside of the areas mentioned above, the general trend 

would be less cover in close proximity to the community of Flagstaff. This would result 

in fewer occurrences of species requiring dense stand conditions, including: Abert 

squirrel, turkey, mule deer, and elk. 

There are approximately 230 miles of private landline bordering the National Forest. 

Human use on these lands is high and increasing annually. Human impacts on wildlife 

have increased (Randall-Parker, USFS, BA&E Fort Valley Ecosystem Restoration 

Project, 2000). Dense stands providing cover for wildlife allow for screening and escape 

cover where human use is high and thus a reduction in cover will lead to fewer 

occurrences of animals requiring the escape and screening protection. Approximately 60 

percent of the FMAZ 1U area currently supports dense cover conditions, however, turkey 

are nearly absent from much of the Urban Interface. Local wildlife professionals 

frequently suggest that high human use has affected turkey within the FMAZ 1U area. A 

couple of exceptions are the Woody Ridge Wildlife Quiet Area, where turkey numbers 

have remained high, however this area is closed to vehicles and represents the outer 

reaches of the FMAZ 1U area, and the Dry Lake Hills area where turkey numbers have 

increased in recent years. The Dry Lake Hills area is also closed to motorized access, 

however daytime human use is high. 

Currently mule deer and elk numbers within the FMAZ 1U area are stable. The change 

in cover allocation for Alternative A is expected to have moderate to minimal effects on 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

34 

deer and elk use of the FMAZ 1U area. Cover is maintained in major travelways and in 

approximately 16 percent of the forested lands of the FMAZ 1U. This will maintain 

population numbers or lead to slight decreases. Due to increasing conflicts between 

wildlife and humans, such as deer and elk eating gardens, flowers, and frequent vehicular 

accidents, a reduction in deer and elk within the FMAZ 1U area is a benefit by reducing 

conflict with some people, however may be less socially acceptable to other people. 

Nesting habitat for Abert squirrel27 will be decreased with a reduction in cover. Recent 

studies by the Arizona Game and Fish Department, suggest that Abert squirrel use small 

patches of cover for nesting as small as possibly 35 trees per dense clump (Miller, Dodd 

personal communication). Alternative A would provide for Abert squirrel habitat on 

approximately 16 to 30 percent of the FMAZ 1U area, however declines in Abert squirrel 

populations are possible given the proposed guideline change from current management. 

This would not have a detectable effect on population trend for Abert squirrel on the 

Coconino National Forest.28

Alternative C and D would result in a reduction of 0 to 15 percent cover per Section of 

the FMAZ 1U area. The Craters, Deadman, Doney, Flagstaff, and Walnut Canyon 

Management Areas (excluding Walnut Canyon and its rim) have very few Mexican 

spotted owl PAC’s, northern goshawk PFA’s, steep slopes, or travelways. These 

management areas would be primarily managed with a 15 percent cover allocation. 

The effects of implementing Alternative C or D would be very similar to those of 

implementing the current Forest Plan guideline of 30 percent. The general trend and 

effects analysis for Alternatives A, C, and D are similar, however Alternatives C and D 

would provide for improved cover conditions for Abert squirrel and mule deer. 

Alternatives C and D would better meet nesting requirements for Abert squirrel based on 

recent research conducted by the Arizona Game and Fish Department. Cover patches as 

small as 35 trees may be important for squirrel nesting, (personal communication with 

Dodd and Miller). Recent projects such as the A1 Ecosystem Assessment Project, Fort 

Valley Ecosystem Restoration Project and the upcoming Kachina Village Forest Health 

Project have included small patches of cover to primarily benefit Abert squirrel, 

songbirds, and mule deer. Alternatives C and D would have 15 percent cover patches 

and increased number of patches, which when added to dense habitats maintained for 

Mexican spotted owl, northern goshawks, and travelways, should support populations of 

Abert squirrel and mule deer in the FMAZ 1U. 

All action alternatives provide increased protection of cover habitat from loss during a 

stand replacing wildfire in comparison to Alternative B. The effect of changing the patch 

size, distribution, and reducing the quantity of high-density stands will protect cover 

allocations from stand replacing wildfire. 

 

27 Abert squirrels are listed in the Forest Plan as a management indicator species for ponderosa pine and 

mixed conifer less than and greater than 40% slope (MA3 and MA4). 

28 Additional discussion of effects are located in Chapter 3. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

35 

The No Action Alternative (B) would maintain trends that currently exist for wildlife 

species habitat on the Coconino National Forest. 

• Alternative B would best meet cover requirements for wildlife habitat, however 

this alternative has the highest risk of loss of cover because it has the highest risk 

for a stand replacing wildfire to occur. 

• Alternative C or D will provide adequate wildlife habitat cover given the amount 

of human use in the FMAZ 1U and will also provide good protection for longterm cover habitat because of the reduced risk of stand replacing wildfire. 

• Alternative A is the least desirable for wildlife habitat management, however this 

alternative does pose the least risk of losing cover because it has the least 

likelihood of a stand replacing wildfire. 

Under Alternative A, C, and D, the change in cover guidelines would not result in a 

significant cumulative effect for the Forest. This is because the FMAZ 1U area 

represents a small portion of the Forest. Cover is maintained in key areas under all 

alternatives. 

Issue 2 (ROS between Fort Valley and A1 Mtn) Comparison of Alternatives 

Recreation Settings

The following discussion also applies to Issue 3 described in later sections of this chapter. 

It is usually desirable to create gradations in Recreation Opportunity Spectrum (ROS) 

settings rather than jump from say an Urban setting to SPNM. This is the recommended 

technique for mapping ROS objectives (USDA, ROS Handbook, 1986) that comes from 

collective agency experience in managing the effects of people in the landscape. It is 

generally impractical, for example, to locate “primitive” landscape objectives next to or 

within more urban environments and expect the more primitive attributes to prevail or 

even to survive. It is more practical to create buffer areas between areas with widely 

disparate characteristics and objectives.29

Table 3 ROS in the Area Between Fort Valley and A1 Mountain For Each 

Alternative

 Alt A Alt B Alt C Alt D 

ROS Setting SPM RN SPNM SPNM 

A good example of how this principle can facilitate the protection of Forest resources is 

in the interface between the growing “rural” residential communities that surround 

 

29 Exceptions to this concept have already been made in Alternative A, where some areas have SPNM 

settings adjacent to developed private land. These sites were chosen because of key resources such as 

archaeological sites. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

36 

Flagstaff proper, and the undeveloped public lands surrounding them. Inevitably, houses 

around the periphery of communities have trails from the houses onto public land that 

often makes the management and protection of National Forest resources more difficult. 

In several areas around the local communities a road will occur (either through design or 

convenience) that runs parallel to the private property line. These roads tend to act as 

collectors for traffic coming out of the neighborhoods. An SPNM zone objective next to 

residential areas could preclude such management options and should be reserved for 

areas with specific resource concerns. 

While the lack of motorized traffic would be desirable for an individual residence, 

designation of a small area as nonmotorized will often have the practical effect of 

pushing such traffic farther out into the forest, expanding the effect from the community 

periphery into the forest interior. The result would be an area that is difficult to manage 

for SPNM objectives and that will likely not enhance overall forest resource protection. 

Proposed designation of small SPNM areas30 elsewhere in the FLEA area (Alternative A) 

results from the recognition that important forest resources in some areas could best be 

managed if motorized vehicles were excluded. These areas typically have some 

combination of steep slopes, fragile soils, and some other resource concern such as 

important cultural resource, scenic, or wildlife values that are sensitive to motorized 

traffic. 

The area between A1 Mountain and Fort Valley suggested for SPNM has an adjacent 

SPNM area proposed for wildlife corridor purposes so there would be some utility in 

managing the area between the SPNM zone and the residences also as SPNM. This 

designation would help buffer the north side of the corridor from additional motorized 

traffic which would likely decrease overall human presence in the local area and in the 

wildlife corridor. Key to the effectiveness of SPNM next to residences is the willingness 

of the residents to help maintain SPNM characteristics, such as by limiting extent of 

neighborhood trail system access to the Forest, by not creating roads or “2 track” trails, 

and by being good stewards of National Forest lands adjacent their property. This project 

will set the stage for more detailed future transportation planning. A more refined level 

of planning will be needed to assess small areas near neighborhoods with more subtle 

resource concerns than were captured in the “coarse filter” analysis suitable for this 

FLEA assessment. 

Alternative A has a gradation from private land to SPM to a SPNM setting. Under 

Alternatives C and D there is a direct interface between private land and SPNM settings. 

Fire Risk and Hazard

Managing an area as non-motorized removes an ignition source of wildfires (fire risk) 

from that particular area and may decrease the number of visitors within that area. 

Managing motorized vehicle access does not however, eliminate all human-caused 

wildfires, nor does it address lightning ignited wildfires. Alternatives C and D would 

 

30Areas smaller than the national standard of 2,500 acres or more and designated with the name SPNM1 in 

this analysis. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

37 

tend to reduce the risk of a human-caused wildfire occurring slightly more than 

Alternatives A and B. 

Wildlife Habitat

This area provides potential habitat for bald eagle roosting, prairie dogs, mule deer, Abert 

squirrel, elk, and foraging opportunities for raptors. A bald eagle potential roosting area 

was designated during the design of the A1 Ecosystem Restoration Project, and District 

personnel actively searched for roost locations, however none have been located. Blackfooted ferret surveys were conducted in the area in 1996, as mitigation to the Rudd Tank 

Road Project adjacent to the FLEA analysis area. Prairie dog populations were abundant 

during surveys, however plague outbreaks have been reported in the Baderville (Fort 

Valley) area in recent years. Many forest raptors actively hunt this area, including redtailed hawk, ferruginous hawk, and Swainson’s hawk. The area is adjacent to an 

important wildlife movement corridor, where vehicular restrictions are currently in place 

and many roads have been obliterated. The movement corridor is important for 

emigration, immigration, regular seasonal movements, and extraordinary movements, 

such as those that might occur in a winter of exceptionally deep snow. This travelway for 

wildlife is the only corridor left on the southwest side of the San Francisco Mountain, 

connecting the mountain with lands south of A1 Mountain, and it is impacted by 

development and social trails and is at risk of crown fire, which could severely impact the 

corridor for several decades. The A1 Ecosystem Management Project and Fort Valley 

Ecosystem Restoration Project both include management to protect this important 

corridor including: fuels reduction thinning, prescribed burning, and road and trail 

relocation and/or obliteration. 

Alternative A would manage the area as SPM. The current ROS setting is RN. The 

change to SPM would be positive for wildlife habitat management given the adjacency to 

the wildlife movement corridor and species that use this area.31 

Alternative C and D manage the area as SPNM and would provide for the greatest degree 

of habitat protection. The designation of SPNM would improve the long-term habitat 

protection for the adjacent wildlife movement corridor. 

Alternative B manages the area as RN and provides the least amount of habitat protection 

for the area compared to all action alternatives, because the risk for wildfire is the 

greatest. Alternative B is least desirable for managing for the adjacent wildlife 

movement corridor. 

Conclusion: The Flagstaff/Lake Mary Forest Plan Amendment has proposed under 

Alternative A an increase of approximately 40,000 acres of SPNM compared to the 

existing condition. The SPNM areas were chosen based on many factors, including 

protection of key wildlife habitats. This area managed as SPNM would be valuable for 

wildlife, however other areas proposed are critical due to protection needed for 

reproductive areas, travelways and presence of TE&S species. The priority for 

 

31 See also the literature review in Chapter 3 regarding human interactions with wildlife. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

38 

implementation of this area as SPNM would be lower than other proposed SPNM areas 

described for Alternative A. 

• Alternative C and D would improve wildlife habitat and provide the greatest 

protection for the adjacent wildlife movement corridor. 

• Alternative A improves habitat conditions. 

• Alternative B offers the least protection for long-term management of wildlife 

habitat. 

Issue 3 (ROS setting around Skunk/Fay Canyon and Northwest of Fisher 

Point) - Comparison of Alternatives 

Background 

Based on current conditions, the estimated road distribution for the Skunk/Fay and Fisher 

Point areas is described in the following table. 

Table 4 Anticipated Road Distribution 

Alternative A Alternative B Alternative C Alternative D 

SPM RN SPNM with SPM 

corridor(s) 

SPNM with no 

SPM corridor 

A few open level 

II roads located 

up on top and not 

in drainages 

A few open level 

II roads located 

up on top and not 

in drainages 

One or two open 

level II roads 

located up on top 

and not in 

drainages 

Open roads on the 

exterior, no open 

roads in the interior 

Fire Hazard

Alternatives C and D would tend to reduce the risk of a human-caused wildfire occurring 

in this area slightly more than Alternatives A and B. Managing motorized vehicle access 

does not eliminate all human-caused wildfires, nor does it address lightning ignited 

wildfires. It is important to retain administrative motor vehicle access to this area for fire 

suppression and other management activities. 

Wildlife Habitat

The Skunk and Fay Canyon area surrounding Walnut Canyon provides habitat for deer, 

elk, pronghorn antelope, Abert squirrel, northern goshawk, and many other species. The 

habitat is diverse including ponderosa pine, Gambel oak, pinyon-juniper and small 

inclusions of mixed conifer. The area currently has a very low road density due to past 

closures and includes a non-motorized closure area. The past closures emphasized, in 

part, the protection of wildlife in Walnut Canyon by managing human use through the 

elimination of roads and social trails and development of Forest Service trail system. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

39 

Alternative A maintains current management for the area, same as Alternative B (No 

Action).32 There are two key access points to the area, one off Lake Mary Road and the 

other off of FR 301. The area as managed currently is providing for very low human 

disturbance and is resulting in positive habitat benefits for wildlife in the area. Positive 

benefits to pronghorn antelope, Mexican spotted owl, and deer have been observed. 

Alternatives C and D would assign the area an SPNM objective. Alternative C would 

manage one or two small open road corridors. The area as managed currently is 

providing for very low human disturbance, the addition a few additional road closures 

will result in slightly more positive habitat benefits for wildlife in the area. 

Conclusion: Alternative A proposes an increase of approximately 40,000 acres of SPNM 

compared to the existing condition. The SPNM areas were chosen based on many 

factors, including protection of key wildlife habitats. This area managed as SPNM would 

be valuable for wildlife, however other areas proposed for the SPNM setting are critical 

due to protection needed for reproductive areas, travelways, and presence of TE&S 

species. The classification of this area as SPNM would be a lower priority than other 

proposed SPNM areas described for Alternative A. 

• Alternative A and B maintain the current beneficial habitat conditions that exist. 

• Alternatives C and D have slightly more positive trends. 

Soil and Water Quality

Under Alternative A and B there are roughly 19 acres of land in a roaded condition. 

Assuming that the roads are located out of drainage bottoms and that there is adequate 

drainage, the surface soil erosion, and runoff produced by compacted surface is slight. 

Under Alternative C there are roughly 9 to 11 acres of land in a roaded condition. 

Assuming that the roads are located out of drainage bottoms and that there is adequate 

drainage, the surface soil erosion and runoff produced by compacted surface is probably 

very slight. 

Alternative D assumes no acres in a roaded condition. There is no effect from roads. 

Conclusion: There is very little difference between alternatives for soil and water quality. 

Recreation Setting

This assessment will include all of the discussion for Issue #2 as well as the following 

concerns 

Subject area as SPNM (Alternative D) 

The subject area for this issue is considerably larger than the one for Issue #2 and if the 

State Trust Lands could be inferred into the larger SPNM area (the Forest Service does 

 

32 The Alternative B ROS inventory map would continue to show the area RN, but current vehicle 

management policies would remain in place under Alternative B. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

40 

not make policy for State Trust Lands; however present state land management is 

compatible with the visible characteristics of semiprimitive ROS settings even if their 

access policy is not) management would be larger than the national standard of 2500 

acres minimum for SPNM settings (ROS Handbook, 1986). One reason for the minimum 

size suggestion is that the attributes that comprise the SPNM ROS setting include such 

things as “opportunities for solitude” and a scarcity of the “sights and sounds of others” 

that are easier to achieve in a larger contiguous area. 

However, some areas within FLEA have been proposed for SPNM that are considerably 

smaller than 2500 acres. All of these areas have some combination of resource value, 

such as cultural sites, steep slopes, wildlife habitat, that would be more effectively 

managed as SPNM. The Skunk/Fay Canyons contain some similar features of steep 

slopes. The remainder of the adjacent area is flatter to rolling terrain. 

The Skunk /Fay area is contiguous to a larger area (Walnut Canyon and west Anderson 

Mesa) that presently has, and is proposed for continuing, SPNM characteristics over a 

large contiguous area. If the Skunk/Fay areas are designated as SPNM, the combined 

extent of this classification would enhance the effectiveness of management SPNM in 

and around Walnut Canyon itself that otherwise would be inherently difficult to retain 

next to developing residential areas. 

The current management of this area is a motorized closure in the Skunk/Fay canyon 

areas and closure of obliteration of many of the existing roads. This roadwork would 

need to continue in order to meet the “high” scenic integrity standard for SPNM. There 

is likely to be more administrative presence needed, such as more signs, patrolling, and 

administrative access roads, to meet semiprimitive objectives for this area than would 

ordinarily be seen in SPNM not near to residential areas. This occurs in the other 

SPNM1 areas as well. 

Visitors to the area under Alternative D would be less likely to see or hear evidence of 

other people than under Alternatives A or B. Opportunities for solitude, natural scenery 

and sound, challenge and risk of a nonmotorized nature, would be much more likely than 

with Alternatives A and B. 

Under Alternative D, parking is within 1 to 2 miles of Fisher Point, a popular destination. 

This is the farthest distance of all the alternatives. 

Subject Area as SPNM with one or two motorized corridor(s) (Alternative C) 

This alternative is similar to Alternative D. Opportunities for solitude, natural scenery 

and sound, challenge and risk of a nonmotorized nature, would be more likely than with 

Alternatives A and B. 

Under this alternative, parking is 1⁄2 to 1 mile from Fisher Point, depending on the 

location of the open road corridors. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

41 

Subject Area as SPM Motorized (Alternative A) 

The area presently has many SPM characteristics because of the current motorized 

closure in the Skunk/Fay Canyon areas, and because of the deterioration of roads to more 

primitive conditions in the remainder of the area. Roadwork would need to continue 

efforts to achieve less road density to meet SPM objectives. Bringing roads down to 

below 2 miles of road per square mile of land and removing visible evidence of closed 

roads to meet basic scenic integrity levels for an SPM area could improve scenic quality 

of the area significantly and will improve opportunities for solitude, and experiencing 

natural sights and sounds away from other people for the areas presently heavily 

impacted by peoples activities and vehicles. 

The reasons to consider a SPM or RN ROS buffer near residential areas where many 

roads already exist, discussed in more detail for Issue #2, are also relevant for some parts 

of this discussion. Road locations should be fairly close (within 1⁄4 mile) and mostly 

parallel to property lines for the buffer effect between residential and semiprimitive areas 

to be effective. Roads that extend towards the interior of the SPM areas will tend to 

diminish semiprimitive characteristics. 

The distance from parking to Fisher Point is less than 1⁄2 mile under Alternative A. 

Subject Area as RN (Alternative B) 

The no-action Alternative B would retain the current ROS classification that shows a 

large portion of this area as a RN setting. The more refined inventory conducted for this 

project reveals more primitive conditions closer to development in areas where terrain or 

vegetation limit the influence of the developed environment. Current motorized road 

closures would also be retained. In the areas north and west of Fisher Point, management 

that meets RN ROS settings would result in the rehabilitation of a few sites and some 

road realignments or closures to eliminate some of the more unsightly erosion or rutting 

problems on the existing roads. A RN objective would allow for (but not prescribe) the 

existence of roads that are suitable for standard low clearance passenger vehicles as well 

as a higher road density over all than a semiprimitive objective would. Opportunities for 

solitude, and experiencing natural sights and sounds away from other people would 

remain as at present or decline due to increased use of the area. 

The distance from parking to Fisher Point is less than 1⁄2 mile. This alternative allows for 

passenger car road access in the area. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

42 

Issue 4 (ROS in the Waterline Road area) Comparison of Alternatives 

Background

The amount of each ROS class for the FLEA area by alternative is as follows: 

Table 5 ROS Setting by Alternative 

Recreation Setting

The high level of recreation use on public land adjacent to urban areas and neighborhoods 

is a trend noted in both nationwide and local surveys (Center for Social Research, 1990). 

It is desirable to offer a diverse array of recreation settings and opportunities in close 

proximity to residential areas in order to meet the diverse demands of National Forest 

visitors (Driver, Bown, Stankey, Gregoine, 1987). 

The Waterline area proposal for a large contiguous SPNM area between the Waterline 

Road (that is also the wilderness boundary) and the Timberline residential property 

boundary is an opportunity to designate additional high quality SPNM ROS setting where 

there are few designated roads at present and where there is an opportunity to enhance the 

protection of some sensitive wildlife habitat. SPNM areas presently comprise just 2.7 

percent of the FLEA area versus SPM that comprises 26.9 percent of the FLEA area. It 

would be desirable to increase the percentage of SPNM to help meet the demand for 

diverse ROS settings in close proximity to Flagstaff. 

There appears to be little shortage of high quality SPM opportunities within the FLEA 

area and within a short drive. Many outlying areas that were once RN in character are 

changing to SPM characteristics as roads built for logging operations during the last 

couple of decades change from passenger car roads into more primitive high clearance 

vehicle roads. Prospects for road improvement funding into the future appears to be 

 

33 The 1992 inventory used for Alternative B shows Urban and Rural ROS settings. These were not carried 

forward as objectives in Alternatives A, C, and D. See Recreation Settings under the Purpose and Need 

section of Chapter 1. 

ROS Setting Percent 

Alt A Alt B Alt C Alt D 

SPM 45.7 26.9 45.3 43.9 

SPNM 16.2 2.7 16.5 17.9 

RN 34.5 67.8 34.5 34.5 

P 3.6 0 3.6 3.6 

R33 0 2.0 0 0 

U 0 0.7 0 0 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

43 

slight. It is anticipated roads will continue to become more primitive and rugged 

throughout the Coconino National Forest and on adjacent Forests creating more SPM. 

The trend across the Colorado Plateau has been for roads to generally become more 

primitive as timber related funding for road maintenance and construction have 

decreased. The Waterline SPNM area would serve as a high quality recreation area while 

funding that would have been used for maintenance of area roads could go for road 

maintenance elsewhere. 

Present recreation use of the total area is light. Biking on the Waterline Road (closed to 

private vehicles) is probably the most popular use, though very few bikers venture off of 

that road. FR 420, the southern boundary of the area, is accessible by passenger car and 

is frequently used for dispersed camping. Equestrian access to and through the area is 

common because of the proximity to the Elden Horse Camp and from numerous local 

equestrians. Most people who venture into the interior of the Waterline area travel by 

high clearance vehicle. 

Table 6 Anticipated Road Distribution For Each Alternative in the Waterline Area 

Alt A Alt B Alt C Alt D 

SPNM 

Roads on the 

exterior 

No roads on the 

interior of the area 

SPM 

Fairly well distributed 

level II roads 

High clearance vehicles 

SPNM 

Fewer level II roads 

than B (high 

clearance) designed 

to limit wildlife 

impacts 

Same as A 

Driving high clearance and four wheeled drive vehicles (Alternatives B and C) through 

the scenic landscape on the primitive roads of the Waterline area is an opportunity valued 

by some people. The quality of the primitive road driving experience is considered to be 

high by those who use it. The entire interior of the area is accessible by primitive roads 

that normally require, at least, a high-clearance vehicle for passage. Road densities are 

not high, probably below 2 miles per square mile, and the present forest setting 

characteristics are well within the parameters for semiprimitive ROS setting objectives. 

Conflicts between different types of recreation users are rare at present and overall use is 

light. 

Closing the area to public motorized travel (Alternatives A and D) would eliminate a 

convenient and high quality opportunity to those seeking a SPM setting on the flanks of 

the San Francisco Mountain. There are plenty of other SPM opportunities in the FLEA 

area and adjacent to it. However, many areas below the Kachina Peaks Wilderness have 

been closed to motorized use for various reasons over the past few years and creating a 

new closure of this area would remove one of a few remaining areas open to vehicle use 

adjacent to the Kachina Wilderness at a high altitude. Closing the area to motorized 

access will likely reduce overall use significantly. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 2 - Alternatives

44 

Wildlife Habitat

The Waterline area provides key habitat for wildlife including the Mexican spotted owl, 

turkey, deer, elk, and northern goshawk. An important movement corridor for turkey 

exists near Jack Smith Peak. An elk calving area is present. Human use is increasing 

through use of previously closed roads and the addition of user-created (social) trails 

created by both motorcycle and mountain bike use. At present the increasing human use 

is affecting turkey movement according to Arizona Game and Fish Department personnel 

(Barsh, personal communication). 

Alternatives A and D would manage this area as SPNM which would increase habitat 

protection and curtail increasing human use. Mexican spotted owl, turkey, and elk would 

benefit from the proposed change. Turkey would be expected to benefit the most, with 

the change maintaining a key summer and fall movement corridor in the vicinity of Jack 

Smith Peak. Turkey travel from summer habitat in the waterline area to winter habitat 

north and east where there are pine stringers in pinyon/juniper woodlands. 

Alternative C would manage this area as SPM, which would improve the habitat 

protection for the area and curtail increasing human use, however not to the same degree 

as Alternative A or D. Alternative C includes the management of only key roads and 

closure of all others. Road and social trail closures would improve habitat for turkey and 

lessen habitat disturbance to the movement corridor. 

The area currently is inventoried as SPM, however the high human use and road density 

resembles management as RN. All action alternatives will improve trends that support 

positive wildlife management 

Conclusion: Alternative A would increase of approximately 40,000 acres of SPNM 

compared to the existing condition. The SPNM areas were chosen based on many 

factors, including protection of key wildlife habitats. This area managed as SPNM is a 

very valuable improvement for wildlife, and is critical due to protection needed for 

reproductive areas, travelways and presence of Threatened Endangered & Sensitive 

species. The designation of this area as SPNM or SPM Motorized with key road closures 

is a high priority within the FLEA area. 

• Alternative A and D provide for the best improvement of wildlife habitat and 

greatest protection for the turkey movement corridor. 

• Alternative C improves habitat conditions. 

• Alternative B offers the least protection for long-term management of wildlife 

habitat. 
45 

 

CHAPTER 3 - AFFECTED ENVIRONMENT 

AND ENVIRONMENTAL CONSEQUENCES 

INTRODUCTION AND ASSUMPTIONS 

This Chapter summarizes the physical, biological, social, and economic environments of 

the project area and the effects of implementing each alternative on that environment. It 

also presents the scientific and analytical basis for the comparison of alternatives 

presented in Chapter 2. The FLEA area covers approximately 300,423 National Forest 

acres, which is 16 percent of the Coconino National Forest (approximately 1,842,100 

acres).34 

A forest plan does not require that any activities or projects occur on the land. It is a 

permissive document that outlines what is allowed to happen in certain areas of the 

National Forest lands. The National Forest Management Act of 1976 requires that all 

site-specific projects be consistent with the forest plan’s goals, objectives, standards and 

guidelines, or that the plan be amended to allow the activity. The plan can also have a 

programmatic amendment (which this document is) to change management direction 

when needed. Again, this amended direction does not include any on-the-ground 

activities, but only the direction for any future proposed activities. Those future activities 

would all have to go through their own NEPA analysis and decision-making process. 

There is less than complete knowledge about many of the relationships and conditions of 

wildlife, fish, forests, jobs, and communities. The ecology, inventory, and management 

of a large area is a complex and developing science. The biology of wildlife species 

prompts questions about population dynamics and habitat relationships. The interaction 

of resource supply, the economy, and communities is the subject matter of an inexact 

science. However, the basic data and central relationships are sufficiently well 

established in the respective sciences for the deciding official to make a reasoned choice 

between the alternatives. New or improved information would be unlikely to reverse or 

nullify these understood relationships. 

The CEQ regulations implementing NEPA (40CFR 1500-1508) require a determination 

of possible conflicts between the Proposed Action and the objectives of Federal, State, 

and local land use plans, policies, and controls for the area. Alternative A (Proposed 

Action) and the other action alternatives do not conflict with other land use plans. In fact, 

the action alternatives are complementary to other plans. 

 

34 These averages are from the current Forest landownership data coverage. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 3 - Affected Environment and Environmental Consequences

46 

In the final environmental impact statement (FEIS) for the current Forest Plan, and 

subsequent amendments, the possible effects of implementing the Forest Plan were 

disclosed. The FLEA amendment makes small changes to the existing direction, and 

therefore only small differences in effects are expected. All the proposed changes are to 

improve conditions in the FLEA area, so possible future impacts could be lessened. 

Because we do not know what will happen in the future, this document describes trends 

and expected outcomes, assuming partial implementation of the Forest Plan. 

There are a variety of site-specific projects currently in the planning stages within the 

FLEA area (Coconino Forest Schedule of Proposed Actions published quarterly). These 

projects fall within current Forest Plan direction. Trends resulting from current sitespecific projects, are not different from trends that are expected to result from 

implementing Alternatives A, C and D. 

The sections that follow, refer to the current Management Areas that are drawn on 

topography and vegetation type, examples are Ponderosa Pine and Mixed Conifer less 

that 40 Percent Slope (MA3). This is because the direction in the current Forest Plan for 

many items still applies based on the existing Management Areas. This chapter also 

refers to the new proposed Management Areas common to Alternatives A, C, and D. 

Maps of the MA’s are located at the end of Appendix A. 

At earlier stages in the FLEA process there was discussion about changes that might lead 

to different outputs and implementation schedules related to forest thinning. These 

earlier discussions centered around which areas might be thinned and in what manner 

(site-specific planning). However, as the FLEA scope changed, this site-specific analysis 

was not completed, rather future analysis will determine actual thinning activities for a 

given area. Some people expected FLEA to analyze the cumulative effects of 

implementing forest thinning in the urban interface. Because the FLEA is programmatic 

and does not identify specific locations, timing, or intensity of thinning, this kind of 

cumulative effects analysis is not possible. Cumulative effects analysis will occur if and 

when site-specific occur across the landscape. 

The Use of Recreation Opportunity Spectrum (ROS) Objectives 

Recreation in the FLEA landscape is more than people camping, viewing scenery, hiking, 

biking, or riding horses. Research shows people choose a specific setting for each of 

these activities to gain certain benefits. For example, hiking in a large undeveloped 

setting with difficult access and few facilities offers a sense of solitude, challenge, and 

self-reliance. In contrast, hiking in a setting with easy access and highly developed 

facilities offers more comfort, security, and social opportunities. 

The Recreation Opportunity Spectrum (ROS) is a framework for understanding the 

relationships and interactions between these recreation settings and benefits. The key to 

providing these benefits is the setting and how it is managed. “Setting indicators” such as 

access, remoteness, naturalness, facilities, social encounters, visitor impacts, and the 

visitors themselves influence the benefits people gain from recreation. 
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It is known from research that setting characteristics are especially critical. People who 

visit and live here have high expectations for National Forest recreation settings. Setting 

characteristics can be affected by such simple things as number of signs, number of 

people, noise, natural vs. human-made materials, artificial lighting, disturbed soils, or 

curbs and sidewalks. Where developments occur, how they are placed and the materials 

from which they are constructed, profoundly affect the recreation setting. 

Definitions of ROS settings are as follows: 

Urban (U)35 - Paved roads, many encounters with other people, high management 

presence and facilities, low degree of “naturalness”. An Urban designation is found in 

areas such as the City of Sedona or Village of Oak Creek. 

Rural (R)36 - Less development than in Urban, typical of agricultural areas. Paved or 

gravel all-weather roads, moderate to high numbers of encounters with other people, high 

management presence, facilities are generally more rustic, but common and convenient, 

moderate degree of “naturalness”. 

Roaded Natural (RN) - Paved or gravel all-weather roads, moderate number of 

encounters, moderate management presence, rustic facilities, moderate to high degree of 

“naturalness”. 

Semiprimitive Motorized (SPM) - Primitive roads and trails, low number of encounters 

with other people, subtle and limited management presence, rustic facilities constructed 

of native materials, high degree of “naturalness” with infrequent evidence of human 

activity. 

Semiprimitive Nonmotorized (SPNM) - Trail access only - no motorized vehicles, low 

number of encounters with other people, subtle and limited management presence, scarce 

rustic facilities constructed of native materials, high degree of “naturalness” with 

infrequent evidence of human activity. 

Primitive (P) - Cross-country or primitive trail access, very few encounters with other 

people, low to non-existent management presence, facilities only for site protection - not 

for comfort, very high degree of “naturalness”. 

Semiprimitive Nonmotorized 1 (SPNM1) - High numbers of social encounters – 

Someone in a SPNM1 setting can expect similar setting as SPNM except that there may 

be more encounters with other people than other SPNM areas. These areas are near 

residential areas, or are places that draw large numbers of people. 

The objectives for where different ROS settings should occur in the future were 

developed using a landscape analysis and design process that incorporated wildlife, 

vegetation, topography, watershed, recreation, and road and trail data (see Appendix E). 

 

35 Urban settings were not used as objectives in Alternatives A, C, and D. 

36 Rural settings were not used as objectives in Alternatives A, C, and D 
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Chapter 3 - Affected Environment and Environmental Consequences

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The ROS objectives provide a mosaic of forest and nonforest conditions. The 

interactions among wildlife and watershed values with those values of roads, trails, and 

recreation settings were the basis for the designations. The SPM and SPNM settings 

distant from urban areas provide for solitude, remote dispersed recreation experiences, 

opportunities for challenge and risk, and many different kinds of wildlife species 

sensitive to human disturbance. The smaller SPM and SPNM areas in close proximity to 

residential-influenced areas provide a diversity of recreation settings that are easily 

accessible from the more developed areas. Some of the semiprimitive areas are smaller 

than the minimum area generally required using national ROS Guidelines, but the team 

felt these semiprimitive designations were valid considering the strong public demand for 

such areas close to Flagstaff. Many of these same areas have high social encounters. 

The table below summarizes all the ways that Forest setting objectives are used to guide 

management common to all action alternatives. 

Table 7 Summary of How ROS Objectives Guide Management Under Alternatives 

A, C, and D 

Type Of 

Activity 

Link to ROS Objectives 

Camping When designating dispersed camping, consider existing resource damage, 

closeness to riparian communities, degree of use, and ROS objectives. 

Signing and 

Scenery 

Strive towards social encounters, signing, and scenery, and a sense of 

exploration that meets the ROS objectives 

Groups and 

Special Uses 

Use ROS objectives to aid in determining appropriate types and numbers of 

individuals, groups, and outfitter/guides and special uses. 

Outfitter/ 

Guides 

Commercial activities are consistent with MA emphasis and ROS objectives. 

Use level allocations will range from no allocation within some P and SPNM 

settings to relatively high use allocations within some RN areas. Other more 

site-specific resource concerns, such as the presence of significant 

archaeological sites, threatened, endangered, or sensitive plant or wildlife 

habitat, and areas with sensitive soils, will also influence outfitter/guide 

allocations. 

Rock 

Climbing 

Rock climbing areas are managed and maintained for appropriate experience, 

natural settings, attributes, and conditions, considering ROS objectives, 

wildlife, heritage, and soil and water resources. 

Trails Non-motorized and motorized trail opportunities provide a variety of 

challenges and experiences and meet ROS objectives 

Roads Reasons for closure or obliteration may include. SPM or SPNM settings as 

set through environmental analysis. Road maintenance standards are 

compatible with ROS objectives. 

Priority for 

road work 

When choosing areas to conduct road maintenance and obliteration, focus 

efforts in SPM and SPNM areas. Of the SPM and SPNM areas, consider the 

Lake Mary/Walnut Creek and Oak Creek watersheds as priorities for water 

quality reasons. Also focus work adjacent to National Monuments. 
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Chapter 3 - Affected Environment and Environmental Consequences

49 

Table 8 Objectives For The Number Of Social Encounters Within Each Of The 

ROS Settings For Forest Service Permitted Commercial Tour Operators Only 

ROS Setting37 Social Encounters (All users) 

RN No objective 

SPM 15 per day 

SPNM 15 per day 

P 6 per day 

Common to all alternatives is the following relationship between ROS settings and roads. 

RN settings have Maintenance Level III passenger car roads and secondary roads off of 

the Level III roads. SPNM areas have most roads closed with access points at the 

exterior edges. SPM areas have relatively low density of mostly Maintenance Level II 

roads (high clearance vehicles). The Primitive setting has no roads and few trails. 

WILDLIFE 

This section describes affected environment and environmental consequences for 

threatened and endangered species, Forest Service sensitive species, management 

indicator species, and migratory birds. 

Background Information on the Effects of Roads, Trails, and Human Use 

The following provides an overview of the effects that roads, trails, and human 

disturbance can have on wildlife. The information was used to describe trends expected 

in wildlife habitat protection given the changes proposed for recreation, roads, and ROS 

classifications within the FLEA project area. 

Deer/Elk 

A great deal of research has been conducted on the effects of roads and recreation on both 

deer and elk. Deer are more highly vulnerable while elk are less affected. However, 

most studies found disturbance to be greatest within 1⁄4 mile of roads. An important 

factor is the frequency of road use combined with existing cover availability adjacent to 

roads. If human use is low and cover is good along roads, the disturbance factor is 

lessened for elk. However, disturbance still may be high for deer. High traffic volumes 

reduced elk use more than did low traffic volumes (Edge and Marcum 1991). There is 

little or no effect of roads on elk distribution and movements during the summer when 

there was little or no vehicle traffic. However, as road use increased (during hunting 

 

37 Although social encounter criteria apply to all users, limitations based on social encounters will only 

pertain to commercial operations. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

50 

season) elk tended to move further away from roads (Gruell and others 1976). Lyon 

(1979) found that avoidance of roads by elk was greater where tree density was less. 

With less than 75 percent canopy cover, elk use increased or stabilized at 0.9 miles from 

the nearest road and with canopy closure greater than 75 percent, elk use stabilized at 0.6 

miles from the road. Lyon (1980) found that avoidance of roads by elk was greater in 

meadows and openings and was least in heavy, dense cover. 

In the Blue Mountains of northeastern Oregon, roads reduced big game use of adjacent 

habitat from the road edge to over 1⁄2 mile. Main roads had the greatest impact as well as 

roads through open vegetative types (Perry and Overly 1976). Perry and Overly also 

found that all roads reduced elk and deer use in meadow habitats. Elk habitat use was 

greatly reduced within 1⁄2 mile of either side of roads and deer use was greatly reduced 

within 1/8 mile of roads. Truett (1980) also found that moving automobiles were 

disturbing to elk in meadows at a distance of 1/3 to 1⁄4 miles, and that response distance to 

humans on foot was generally less. 

Rost and Bailey (1979) found that deer exhibited a stronger avoidance response than did 

elk to roads. They found that avoidance of roads was more evident in shrub communities 

than in ponderosa pine or juniper habitats, and that both screening and road use affected 

the avoidance. Rost (1975) found that deer avoided even dirt roads, some of which were 

used only by four-wheel drive vehicles, trail bikes, and hikers. Strickland (1975) 

suggests that deer may tolerate traffic disturbances until a disturbance threshold is 

reached. Once this threshold is reached, deer alter their feeding habits and habitat 

selection. He also found that mule deer seem to prefer at least 1⁄4 mile distance from 

activities such as camping, fishing, and hiking. He also found that deer reacted much less 

to moving vehicles than to vehicles when they stopped. However, when trail bikes 

passed feeding deer, the deer ran into the nearest cover immediately. 

Holbrook and Vaughan (1985) found that high traffic roads adversely affected turkey 

home ranges by shifting home ranges dramatically. Bailey and Rinell (1968) concluded 

that in West Virginia, thriving turkey populations did not exist where roads open to the 

public exceeded four miles per 2,500 acres. They also found that turkeys did not frequent 

an off-road vehicle use area and were not known to inhabit areas closer than 3⁄4 mile to 

campgrounds. They also noted foot trail traffic had an adverse effect on the use of an 

area by turkeys. 

Jones and Barsch (1992) found that illegal take of turkey was high in northern Arizona 

and that high road density is facilitating the illegal take of wild turkey. Lindezey (1967) 

reported that turkeys are not compatible with heavily used recreation areas, and even 

occasional use in some areas may cause nest abandonment. 

Other Species 

Other species that most likely are impacted by high road densities and high human use 

are some passerines,38 bats, and fox. Chester (1976) found an inverse relationship 

between intensity of human use and frequency of wildlife observations. The frequency of 

 

38 Small perching birds of the order Passeriformes, examples are sparrows and bluebirds. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

51 

wildlife encounters by trail travelers is described as a function of time of year, altitude, 

noise, and party size. Garton and others (1977) found that the reaction of birds to humans 

in a campground was highly species-specific and varied even with the species. Birds 

were affected by modification of vegetation structure and actual human presence. Van 

der Zande and others (1984) found significant negative correlations between recreational 

intensities and bird densities for some species and not others. 

Threatened/Endangered Species 

Descriptions of these species’ environmental needs are located in the more detailed 

wildlife report in the project record. Habitat that occurs in FLEA is described in the 

following text. 

Effects are described for the action alternatives. There is no change in current trends 

under the No-Action Alternative B. 

Mexican Spotted Owl (Threatened) 

On the Coconino National Forest, the Mexican spotted owl (MSO) occupies mixed 

conifer and ponderosa pine/Gambel oak vegetation types, usually characterized by high 

canopy closure, high stem density, multi-layered canopies within the stand, numerous 

snags, and downed woody material. Much suitable nesting/roosting owl habitat is 

characterized by steep slopes and canyons with rocky cliffs. The breeding season occurs 

from March 1 through August 31. 

There are thirty-two Mexican spotted owl PACs located all, or partly within, the FLEA 

area. The owls occupy mixed conifer habitat predominately within canyons such as 

Walnut Canyon and Pumphouse Wash, the slopes of the San Francisco Mountain, 

ponderosa pine/Gambel oak habitat along Woody Ridge in the West MA, and areas of the 

Shultz and Lake Mary Watershed MA’s on mountain tops and along drainages. 

Mexican spotted owls within the FLEA area are managed following standards and 

guidelines provided in Amendment 11 to the Forest Plan. Amendment 11 is silent on the 

appropriateness and application of guidelines in an Urban Interface environment. Land 

managers have struggled with the application of some standards and guidelines for MSO 

in the urban interface where conflicting objectives have surfaced. Increasing human 

activities, fuels reduction, and development have conflicted with current standards and 

guidelines. 

A Landscape Analysis process for the FLEA project area included analysis of existing 

MSO PACs, protected, and restricted habitats. Existing PAC’s and protected habitats 

were key to the proposal to increase SPNM and SPM settings. Where the current Forest 

Plan fell silent on how to manage recreational activities, ROS was used to increase 

protective measures for management of MSO PAC’s and protected habitat. 

Under Alternative A, twenty-three PACs fall within SPNM ROS objectives and six of 

them fall all or mostly within SPM ROS objectives. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

52 

To address issues of fuels reduction in the urban interface, the Urban/Rural Influence 

Zone (U/RIZ) was created. No management changes are proposed for either existing 

MSO PAC’s or protected habitat within this zone. 

Within the FLEA project area boundary, there are approximately 6,400 acres of mixed 

conifer and 11,800 acres of pine/oak restricted habitat. To meet the Forest Plan and 

MSO Recovery Plan guidelines, the FLEA project area would manage for approximately 

940 acres of the mixed conifer and 1080 acres of pine oak restricted habitat to promote or 

maintain target threshold conditions. 

Existing condition displays 186 acres of mixed conifer and 850 acres of pine oak 

restricted habitat within the U/RIZ. The distribution and patch size of the restricted areas 

within the U/RIZ would provide marginal nest/roost habitat for Mexican spotted owls. 

Potentially, 100 acres of mixed conifer and 85 acres of pine oak habitat could be 

designated to maintain or promote target threshold conditions within the U/RIZ. The 

FLEA guideline to not designate target threshold habitat within the U/RIZ is in the best 

long-term interest of habitat management for the Mexican spotted owl. The FLEA 

allocation of target threshold habitat within the Lake Mary Watershed and Shultz 

Management Areas would better provide for long-term management of roost/nest habitat 

for the Mexican spotted owl. It is estimated that approximately 18 percent of the Shultz 

Management Area and 11 percent of the Lake Mary Watershed would be managed for 

target-threshold conditions in the future, due to not allocating target threshold conditions 

in the U/RIZ. 

The FLEA guideline for monitoring threatened and endangered species (Alternatives A, 

C, and D) was recommended due to the increased recreation activity on the Coconino 

National Forest since the time the Forest Plan was signed. This guideline will result in 

increased monitoring and possibly use restrictions where resource managers plan future 

projects within threatened and endangered species habitat and human disturbance 

concerns are raised. 

The consequences of not managing for target threshold conditions for MSO habitat in the 

U/RIZ will have no effect on the Mexican spotted owl. The likelihood of occupancy of 

any of the unoccupied habitat is extremely low given patch size, human disturbance, 

noise, and poor foraging habitat potential adjacent to the small patches of restricted 

habitat. The designation of target threshold habitat above the minimum required for the 

Lake Mary Watershed and Shultz Management Areas where owl occupancy is high and 

habitat conditions are favorable will benefit the species. 

The increase in SPNM and SPM ROS objectives in MSO PACs under the action 

alternatives will have beneficial trends to MSO habitat within the FLEA area. The ROS 

objectives will improve the bird’s ability to reproduce in these areas. Alternative A and 

D are slightly better for MSO habitat management with the ROS objective of SPNM. 

If the guidelines for social trail management are implemented as described under 

Alternatives A, C, and D, the trends likely to occur are decreasing impacts to MSO PACs 

from human disturbance. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

53 

All action alternatives improve habitat management for MSO. Alternatives A and D 

provide the greatest benefit due to the higher level of protection offered by SPNM 

designation within the Shultz MA along the Waterline Road. Alternative C would 

increase the number of MSO PACs managed as SPM from nine to twelve and reduce the 

number of SPNM by three compared to Alternatives A and D. The changes in the action 

alternatives are beneficial to the Mexican spotted owl. There are no significant 

cumulative effects expected under any alternative. 

Bald Eagle (Threatened) 

Bald eagles are primarily winter visitors to the Coconino National Forest occupying all 

habitat types and elevations. Wintering eagles arrive in the fall, usually late October or 

early November, and leave in early to mid-April. They feed on fish, waterfowl, terrestrial 

vertebrates, and carrion. Eagles are often seen perched in trees or snags near water or 

next to roadways where they feed on road-killed animals. At night, small groups (usually 

2 to 12) or individual eagles roost in clumps of large trees in protected locations such as 

drainages and hillsides. Eagles usually roost adjacent to or very near food sources. 

Although bald eagles are primarily winter visitors to the Coconino National Forest, there 

are known summer roosts within the FLEA area. 

There are six winter roosting areas and two summer roosting areas identified in the FLEA 

area. The largest concentration of roost trees is adjacent to Lake Mary. Other project 

level analysis have shown that these areas are decadent and at risk of wildfire and insect 

and disease.39 This is assumed to be the case of most winter roosts in the FLEA area. 

Threats to bald eagles include loss of existing or potential roosts due to catastrophic fires, 

disturbance, and fire. 

The guidelines proposed under Alternatives A, C, and D, will increase the ability to treat 

around roost trees. If treatments occur, the chance of wildfire or insect and disease losses 

will be less. The improvement in longevity of old ponderosa pine roost trees will benefit 

the species. 

All action alternatives will improve habitat conditions for the bald eagle. Alternatives C 

and D improve habitat slightly more with the inclusion of SPNM settings for the A1 

Mountain/Fort Valley area. The SPNM objective in this area would further reduce 

potential for human disturbance in potential bald eagle wintering habitat. 

There is no significant cumulative effects expected as future projects are implemented 

according to the management direction in Alternatives A, C and D 

Black-Footed Ferret (Endangered) 

The historical range of the black-footed ferret is nearly identical to that of three prairie 

dog species, the black-tailed prairie dog (cynomys. ludovicianus), Gunnison’s prairie dog 

(C. gunnisoni), and the white-tailed prairie dog (cynomys. leucurus). Gunnison’s prairie 

 

39 Reference the Lake Mary Fuels Reduction Project, Project Record located at the Peaks District Office. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

54 

dogs are the species found on the Coconino National Forest. Ferrets occupy the burrows 

made by prairie dogs and use prairie dogs as a main food source. They formerly ranged 

from the Great Plains of Canada to the intermontane region of the interior Rocky 

Mountains and the southwest. There is a 1952 specimen from an area 7 miles northeast 

of Williams, Arizona and another from the Bacas Ranch, 16 miles northeast of 

Springerville (Hoffmeister, 1986). 

A complex is a series of towns within 4.35 miles of each other, the distance a ferret could 

travel in a night. Burrow density counts have not been conducted and it is assumed that 

each colony is of sufficient minimum size to support ferrets. 

Implementing future projects based on the proposed language changes within the FLEA 

area will not change habitat trends for this species or its habitat. 

Impacts to prairie dogs include predation by coyotes, raptors and bobcats, and legal 

shooting. They are also subject to significant local declines due to diseases such as 

plague and distemper. 

Within the FLEA boundary there are numerous prairie dog towns. The best complex of 

habitats exist within the Doney, Craters, and Deadman Management Areas. All 

alternatives increase SPNM and SPM of these MAs and will benefit prairie dogs. 

However, adjacent to many grasslands are inclusions of private property which provide 

habitat for domestic pets. The likelihood of ever reintroducing ferrets into a complex 

located within the FLEA area is small, due to the likelihood of canine distemper and 

predation from domestic dogs and cats. 

There are no significant cumulative effects expected as future projects are implemented 

under any Alternative. 

Forest Service Sensitive Species 

Descriptions of these species’ environmental needs are located in the more detailed 

wildlife report in the project record. Habitat that occurs in FLEA is described in the 

following text. 

Effects are described for the action alternatives. There is no change in current trends 

under the No-Action Alternative B. 

This section on sensitive species describes trends. Where little to no change, or effect is 

expected, there is not a cumulative effect. 

Navajo Mountain Mexican vole 

Implementing future projects based on the proposed language changes within the FLEA 

area will trend towards positive habitat improvement for this species. 

The FLEA area provides approximately 1,100 acres of riparian habitat. Lake Mary, Dry 

Lake, and Marshall Lake are key to habitat management for this species. All of these 
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Chapter 3 - Affected Environment and Environmental Consequences

55 

areas have camping changes proposed for either closed to camping or designated 

camping. Proposed trail management direction emphasizes relocating or closing social 

trails and parking management at the lakes will help to control total number of people 

that can visit sites at one time. All action alternatives would improve trends for this 

species as new guidelines emphasize rehabilitation of water quality and non-motorized 

access. 

Navajo Mountain Mexican vole would occupy Mountain Meadows (MA9), or Grasslands 

with Sparse Pinyon/Juniper (MA10). Additional road management criteria for meadow 

and grassland environments will trend towards improved cover, forage, and increased 

ground cover important for cover and forage. The table below shows the percentage of 

MA9 and MA10 managed as SPM and SPNM. These settings will have trends towards 

reduced number of roads resulting in improved understory conditions. The table below 

also shows the percentage of these MA’s that are closed to camping under Alternatives 

A, C, and D. Camping closure limits site-specific locations of compaction and will help 

maintain cover. 

Table 9 Percent of MA9 and MA10 in SPM and SPNM or Closed to Camping 

Percent of NF Acres in the MA by 

Alternative 

Management Area 

Alt A, C, and D Alt B 

MA 9 Closed to camping 19.7 15.6 

MA9 in SPNM 9.7 0 

MA9 in SPM 32.2 16.8 

MA10 Closed to camping 35.8 4.5 

MA10 in SPNM 2.1 0 

MA10 in SPM 7.1 16.8 

The voles are also located throughout ponderosa pine less than 40 percent slopes (MA3) 

lands, within scattered openings that occur throughout MA3. Based on historical 

evidence, MA3 was much more open and probably used more by this species. Within the 

FMAZ 1U the cover guideline proposed in Alternative A would benefit this species by 

increasing open forest condition. Alternative A would provide for the greatest 

improvement in vole habitat and Alternatives C and D would cause a slight improvement. 

 

Wupatki Arizona Pocket Mouse 

Implementing future projects based on the proposed language changes within the FLEA 

area may benefit this species slightly. 

All existing habitat on the Coconino National Forest for this species is located within the 

FLEA boundary. The species occurs within the Deadman Wash Management Area and 
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Chapter 3 - Affected Environment and Environmental Consequences

56 

predominately within pinyon/juniper less than 40 percent slopes (MA 7). All action 

alternatives increase SPM and SPNM areas that will reduce roads and human impacts, in 

turn improving understory conditions that could potentially benefit this species. 

American Peregrine Falcon 

Recreational activities such as hiking, camping, rock climbing, and off-road vehicle use 

have the potential to cause adverse impacts to the peregrine falcon. Forest Service 

projects such as the clearing of trails and the construction of trails, trailheads, roads, and 

campsites have the potential to affect the peregrine falcon especially where these 

activities occur near peregrine eyries. Ellis (1982) states that camping and hiking 

activities can be compatible with nesting peregrines as long as a these activities do not 

occur within a 1⁄4 buffer zone. Other activities such as rock climbing and off-road vehicle 

use require broader buffer zones (Ellis 1982). 

Proposed management direction for the Recreation Opportunity Spectrum (ROS) will 

provide more protection and overall, more conservative, management of known eyrie 

locations. The changes in ROS guidelines will benefit peregrine eyrie locations. All 

known eyrie locations and the best potential habitat have ROS objectives of either P or 

SPNM settings. 

The current Forest Plan was silent on the management of peregrine falcon eyrie locations 

related to rock climbing. The proposed guideline changes include specific management 

direction within rock climbing areas. Rock climbing areas will be inventoried for 

peregrine falcon and other raptors. If monitoring shows a need, climbing and all other 

activites will be prohibited within 1⁄2 mile of peregrine eyrie locations during the breeding 

season. 

All action alternatives will benefit habitat management for the peregrine falcon. 

Northern Goshawk 

There are 20 PFA’s within FLEA. The changes to guidelines on human disturbance 

apply to all PFA’s but are most relevant to those within the Urban/Rural Influence Zone. 

There is no expected change in species viability or trends for northern goshawks from 

any alternative as no major changes to Amendment 11 (goshawk standards and 

guidelines) of the Forest Plan occur. 

Mountain Silverspot Butterfly and Blue-black Silverspot Butterfly 

Mountain and blue-black silverspot butterfly would have potential habitat within riparian 

areas and open water (MA12). Current databases show approximately 1,100 acres of 

riparian habitat. This habitat includes Lake Mary, Dry Lake, and Marshall Lake all of 

which are key to habitat management for this species. All of these areas have camping 

changes proposed to either close to camping or designate camping that will improve 

water quality and understory development. Proposed trail management direction 

emphasizes relocating or closing social trails and parking management at the lakes will 

help control total number of people that can visit sites at one time. All action alternatives 

would improve habitat trends for these species as new guidelines emphasize 
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Chapter 3 - Affected Environment and Environmental Consequences

57 

rehabilitation, improvements to water quality, and non-motorized access. Forest Plan 

language changes under any of the action alternatives would be beneficial to these 

species. 

Early Elfin 

Early elfin could occupy various habitat types throughout the FLEA project area. 

None of the action alternatives will have any detectable effect on habitat trends for this 

species because there are no changes in standards and guidelines which would cause 

future effects to this species. 

Freeman’s agave borer 

Habitat for this species may occur along the base of Mount Elden. None of the action 

alternatives will have any detectable effect on habitat trends for this species because there 

are no changes in standards and guidelines that would affect this species. 

Northern Leopard Frog 

Northern leopard frog would have potential habitat within riparian and open water 

(MA12). The FLEA area provides approximately 1,100 acres of riparian habitat. Lake 

Mary, Dry Lake, and Marshall Lake are key to habitat management for this species. All 

of these areas have camping changes proposed to either close to camping or designate 

camping. Proposed trail management direction emphasizes relocating or closing social 

trails and parking management at the lakes to help control total number of people that can 

visit sites at one time. All action alternatives would improve trends for this species as 

new guidelines emphasize rehabilitation, improvements to water quality, and nonmotorized access. 

Arizona Bugbane and Cliff Fleabane 

There is limited habitat within the FLEA area for these species. Riparian canyon bottoms 

within the Walnut MA and West MA hold the greatest potential. All known species 

occurrence are within areas proposed for management as SPNM. There are changes 

recommended for Pumphouse Wash to reduce camping that may lead to less vegetative 

disturbance to Arizona bugbane. There are modest estimated trends expected for 

improving habitat potential for these species, however all action alternatives will have no 

major effects on Arizona bugbane or cliff fleabane. 

Arizona Sneezeweed 

Arizona sneezeweed would occupy mountain meadows (MA9) within the FLEA project 

area. Improvements in guidelines that manage for roads within meadow and grassland 

environments will improve habitat for this species. Within road criteria guidelines there 

is a priority to improve hydrologic conditions, emphasizing improving conditions in the 

Lake Mary Watershed where this species occurs. Most all of the potential habitat within 

the Lake Mary Watershed area is within SPNM and SPM and approximately 20 percent 

of MA9 within the entire FLEA area is proposed for camping restrictions. There are 

positive trends expected for improving habitat potential for this species. As future project 

are implemented based on the new direction, the action alternatives will benefit this 

species. 
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Chapter 3 - Affected Environment and Environmental Consequences

58 

Flagstaff Pennyroyal 

Populations of Flagstaff pennyroyal are numerous and abundant throughout the FLEA 

area. Populations are primarily located within the Walnut, Lake Mary Watershed, and 

Flagstaff MA’s. The species has been studied by many and found to be quite hardy. 

Personal observations40 in the Walnut Canyon Area find the plant has increased in 

numbers and continued to flower and spread even when located on well-used roads. The 

plant appears to respond positively to disturbance. 

The plant is found most often growing in full sunlight with zero canopy closure. 

Alternative A would benefit this species where less area is managed for dense stand 

conditions (within the Fire Management Analysis Zone 1U). Alternatives C and D 

benefit the species more than B but somewhat less than A. Alternative B causes no 

change to future openness of stands from current management direction. 

Flagstaff Penstemon and Rusby’s Milkvetch

Numerous locations of Rusby’s milkvetch are known from the FLEA project area. Few 

penstemon are known. Habitat for both species is widespread within the project area and 

all action alternatives propose new guidelines, which will benefit these species. 

Alternative A, will reduce tree cover within the FMAZ 1U, thus providing more 

favorable habitat conditions for these plants. Alternative D would provide for better 

protection from trampling or disturbance due to fewer roads and less human use of 

potential habitat based on ROS objective to manage for increased SPNM areas. All 

action alternatives result in beneficial impacts to these species. 

Sunset Crater Beardtongue 

Large expanses of potential and occupied habitat for this species are proposed for 

management as SPM and SPNM. Road closures will benefit this species. Management 

direction proposed for the Cinder Hills OHV Area under Alternatives A, C, and D will 

benefit the plant somewhat more than B where slope closures occur. All action 

alternatives will benefit Sunset Crater beardtongue. 

Management Indicator Species 

The National Forest Management Act of 1982 requires that the effects of each alternative 

on fish and wildlife be estimated and that “certain vertebrate and/or invertebrate species 

present in the area be identified and selected as management indicator species” (36 CFR 

219.19(a)(1)). Management indicator species (MIS) were identified and selected for the 

Forest, as noted in the Forest Plan (USDA Forest Service 1987 as amended). 

The Forest Plan, signed on August 28, 1987, and amended 16 times since, identifies 17 

Management Indicator Species. MIS were developed by vegetative type and seral stage, 

plus the snag component of forested areas (USDA Forest Service 1987a) (Table 1). The 

Environmental Impact Statement for the Coconino Forest Plan (EIS) (USDA Forest 

Service 1987a) defined indicator species as: 

 

40 Personal observations by Tammy Randall Parker documented in field notes located in wildlife office. 
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“...a plant or animal whose population change reflects a population 

change in other species within a group. Indicator species respond to 

habitat changes early or at low levels of stress and, therefore, are sensors 

of the effect of management activities that occur in various habitats.” 

In the Coconino Forest Plan, management of species is emphasized as follows for the 

different Management Areas located within the FLEA area. 

• MA3 - Ponderosa pine and mixed conifer < 40 percent slope (110,400 acres) - 

pygmy nuthatches, Abert squirrel, red squirrel, hairy woodpeckers, turkey, and 

northern goshawk. 

• MA4 - Ponderosa pine and mixed conifer > 40 percent slope (14,444 acres) - 

Mexican spotted owl, turkey, elk, Abert squirrel, red squirrel, northern goshawk, 

hairy woodpecker, and pygmy nuthatch. 

• MA5 - Aspen (289 acres) - yellow-bellied sapsucker and mule deer. 

• MA7 and 8 - Pinyon-Juniper woodland less than and greater than 40 percent slope 

(79,036 acres) - plain titmouse, mule deer, and elk. 

• MA9 - Mountain meadow (9,031 acres) - pronghorn antelope and elk. 

• MA10 - Grassland and Sparse Pinyon-juniper (19,964 acres) - pronghorn 

antelope. 

• MA12 - Riparian and Open Water (1,100 acres) - cinnamon teal, Lincoln's 

sparrow, yellow-breasted chat, Lucy's warbler, and macroinvertebrates. 

The following sections describe habitat changes for the FLEA alternatives. 

Elk and Mule Deer 

The increase in ROS setting SPNM and SPM will improve habitat for all MA3 species, 

with both deer and elk benefiting from less disturbance. Under Alternatives A, C, and D, 

camping closures, designated camping, and campfire restrictions will be implemented on 

30.5 percent of the FLEA area and will lessen disturbance and improve habitat conditions 

by eliminating continuous human presence over a portion of the FLEA area. All action 

alternatives place emphasis on day-use and strategic recreation direction within the FLEA 

area and will help relieve some of the impacts from recreation. 

Outfitter/guide, road and motorized trail development include guidelines to meet ROS 

objectives, and again key wildlife habitats will be managed to reduce the number of 

human encounters. 

Forestry changes include reducing the amount and patch size of cover within the FMAZ 

area of FLEA. Less cover will have slight impacts on deer and elk. Alternatives C and D 

will have slightly less effect than Alternative A. The emphasis to improve understory 

and reduce wildfire potential will have positive impacts and trends on these species. All 

watershed, mountain meadow, and riparian guidelines will benefit these species. 
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Management of elk habitat is emphasized in Ponderosa Pine and Mixed Conifer greater 

than 40 percent slope (MA 4) within the FLEA project area. The effects are very similar 

to MA3, however due to topography this species is protected even more. 

Management of mule deer habitat is emphasized in aspen (MA 5). Aspen stands are 

popular locations for camping, wildlife viewing, and human exploration. Aspen areas 

within the FLEA area are concentrated within the Schultz and West MA’s. Under 

Alternatives A, C, and D, camping closures and designated camping have been proposed 

for 39 percent of aspen areas. SPM and SPNM designations occur within 92 percent of 

aspen areas and will provide fewer disturbances to mule deer and many other species, 

which use aspen habitats. 

Mule deer and elk are also emphasized in Pinyon/Juniper Woodland Less Than and 

Greater Than 40 Percent Slope (MA 7 and 8). Large blocks of the pinyon juniper 

woodlands in the Deadman Wash, Doney, and Craters MAs are proposed for SPM 

management. The reduction in roads will benefit wildlife species and protect key winter 

range for mule deer and elk. The trend is improved winter range habitat. 

Elk are also emphasized in Mountain Meadows (MA 9) within the FLEA project area. 

Road management guidelines, under Alternatives A, C and D, to locate roads outside of 

meadows and reduce road densities in grassland environments will improve forage and 

lessen disturbance. SPM and SPNM encompass 42 percent of mountain meadows and 

further will provide a trend for protection and improvement of these important habitats. 

All action alternatives improve habitat conditions for elk and mule deer through 

improved access management of social trails and roads to reduce impacts to important 

habitats such as riparian areas and meadows. All action alternatives provide increased 

protection of cover habitat from loss during a stand replacing wildfire in comparison to 

Alternative B. Alternative D best improves habitat for elk and deer due to the largest 

acreage managed as SPNM and 15 percent cover allocation. Alternative B or no action is 

the least desirable due to the distribution of current ROS classifications and less direction 

and guidelines for recreation and road management. Alternative A will have some effect 

to elk and mule deer due to loss of cover. Alternative C is the least desirable due to 

changes in ROS objectives from SPNM to SPM for the Schultz MA near the Waterline 

Road. There are modest estimated trends expected for decreasing habitat potential for 

these species, however all action alternatives would not have a detectable effect on 

forestwide habitat trends for either mule deer or elk on the Coconino National Forest. 

Pronghorn Antelope 

Road management guidelines, under Alternatives A, C and D, to locate roads outside of 

meadows and reduce road densities in grassland environments will improve cover, 

forage and lessen disturbance to pronghorn antelope. See Table 9 (shown previously) for 

percentages of habitat in SPM and SPNM settings and percentages of habitat closed to 

overnight camping. 

All action alternatives will result in a slight habitat improvement for this species. 
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Pronghorn antelope are not MIS for ponderosa pine and mixed conifer less than 40 

percent slope (MA3) lands, however scattered openings occur throughout MA3, and 

based on historical evidence, MA3 was more open and used by pronghorn antelope. 

Action alternatives reduce tree densities and may improve conditions for antelope 

movement between scattered openings. There would be no changes in the forest-wide 

habitat trend. 

Abert Squirrel 

Forestry changes include reducing the amount and patch size of cover within the FMAZ 

area of FLEA. Less cover will have slight impacts on Abert squirrel. Alternatives C and 

D will have slightly less effect than Alternative A. Alternative B would affect Abert 

squirrel the least in the short-term, however wildfire potential would remain high and 

threaten habitat for this species. Although action alternatives reduced habitat quality, 

they also provide protection from total loss of squirrel habitat from a stand replacing 

wildfire. There are modest estimated trends expected for decreasing habitat potential 

from action alternatives for this species. This decrease will not change forest-wide 

habitat trends. 

Red Squirrel 

No changes are proposed on slopes greater than 40 percent that would impact this 

species. However, red squirrels also use mixed conifer habitat on slopes less than 40 

percent. 

Forestry changes include reducing the amount and patch size of cover within the FMAZ 

area of FLEA. Less cover will have slight impacts on red squirrel. Alternatives C and D 

will have slightly less effect than Alternative A. Although action alternatives reduced 

habitat quality, they also provide protection from total loss of squirrel habitat from a 

stand replacing wildfire. There are modest estimated trends expected for decreasing 

habitat potential for this species. This change will not affect forest-wide habitat trends. 

Wild Turkey 

The increased acres in ROS settings SPNM and SPM will improve habitat for all MA3 

species, with turkey benefiting the most, as they are highly sensitive to disturbance. 

Camping closures and designated camping will be implemented on 30.5 percent of 

National Forest acres and will lessen disturbance and improve habitat conditions by 

eliminating continuous human presence over a large portion of the FLEA area. 

Different ROS settings can affect disturbance sensitive MIS species such as turkey. The 

proposed ROS changes will benefit this species. Analysis of the Flagstaff Area Open 

Spaces and Greenways Plan (City of Flagstaff, 1998) produced a map identifying key 

and high quality wildlife habitat within the Flagstaff urban interface. This map was used 

in the landscape assessment for FLEA and was key to identification of ROS changes 

needed for wildlife habitat protection. Sixty-five percent of key and high quality wildlife 

habitat is proposed for Primitive, SPM, and SPNM management. Outfitter/guide, road, 

and motorized trail development guidelines implement ROS objectives, and again key 

wildlife habitats are managed to reduce the number of human encounters. 
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Alternative D best improves habitat for this species due to the largest acreage managed as 

SPNM and 15 percent cover allocation. Alternative B or no action is the least desirable 

due to the distribution of current ROS classifications and the lack of direction for some 

aspects of recreation and road management. Alternative A will have some effect to 

turkey due to loss of cover. Alternative C is the least desirable due to changes in ROS 

objectives for the Schultz MA near the Waterline Road. 

All watershed, mountain meadow, and riparian guidelines in action alternatives will 

benefit turkey. Forestry changes include reducing the amount and patch size of cover 

within the FMAZ 1U area of FLEA. Less cover will have slight impacts on turkey. 

Alternatives C and D will have slightly less effect than Alternative A. Although action 

alternatives reduce cover habitat, they provide protection from loss of cover (forested 

stands) from stand replacing fires. These changes do not affect forest-wide trends. 

Northern Goshawk and Mexican Spotted Owl 

See the section on threatened and endangered species for a discussion of habitat within 

the FLEA area, and expected effects from the FLEA alternatives for the Mexican spotted 

owl. See the section on sensitive species for a discussion of northern goshawk. 

Pygmy Nuthatch, Hairy Woodpecker, Red-naped (Yellow-bellied) Sapsucker, and 

Juniper Titmouse 

None of the action alternatives will have any detectable effect on habitat trends for these 

species because there are no proposed changes in standards and guidelines, which would 

affect them. 

Lincoln’s Sparrow 

The FLEA area provides approximately 1,100 acres of riparian habitat, however, only a 

few small areas provide or have the potential to provide the scrub habitat preferred by 

this species. Some of the seeps and springs that drain into Lake Mary, such as Babbitt, 

Clark, and Hoxworth Springs, may have the greatest habitat potential. Changes in 

recreation management include proposals to either close to camping or designate 

camping sites in most of the riparian habitat, including Lake Mary, Dry Lake, and 

Marshall Lake. Trail management under Alternatives A, C, and D emphasizes relocating 

or closing social trails and parking management at the lakes to help control total number 

of people that can visit sites at one time. All action alternatives would improve 

vegetation along the shorelines, improving foraging habitat for this small secretive bird 

when it migrates through the area. New guidelines that emphasize rehabilitation, 

improvements to water quality, and nonmotorized access, will result in improved riparian 

habitat. There are modest estimated trends expected for improving habitat potential for 

this species. These improvements do not change forest habitat trends. 

Lucy’s Warbler and Yellow-breasted Chat 

There is limited habitat within the FLEA area for Lucy’s warbler and yellow-breasted 

chat. Riparian canyon bottoms within the Walnut MA and West MA hold the greatest 

potential. There are changes recommended for Pumphouse Wash to reduce camping that 

may lead to slightly less disturbance of shrub communities. Walnut Canyon has 

objectives for primitive settings. There are modest estimated trends expected for 
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improving habitat potential for these species. These improvements do not change forest 

habitat trends. 

Cinnamon Teal 

The FLEA area provides approximately 1,100 acres of riparian habitat. Lake Mary, Dry 

Lake, and Marshall Lake are key to habitat management for this species. Under 

Alternatives A, C, and D, all of these areas have camping changes that either close them 

to camping or change them to designated camping sites. Alternative A, C, and D trail 

management direction emphasizes relocating or closing social trails and parking 

management at the lakes to help control total number of people that can visit sites at one 

time. All action alternatives would improve trends for this ground nester by providing 

improved nesting vegetation and reducing human disturbance. New guidelines 

emphasize rehabilitation, improvements to water quality, and nonmotorized access. 

There are modest estimated trends expected for improving habitat potential for this 

species. These improvements do not change forest habitat trends. 

Macroinvertebrates 

The FLEA area provides approximately 1,100 acres of riparian habitat. Lake Mary, Dry 

Lake, and Marshall Lake are key to habitat management for macroinvertebrates. Under 

Alternatives A, C, and D, all of these areas have camping changes that either close them 

to camping or change them to designated camping. Trail management direction 

emphasizes relocating or closing social trails and parking management at the lakes to 

help control total number of people that can visit sites at one time. All action alternatives 

would improve trends for riparian rehabilitation, which should benefit 

macroinvertebrates. New guidelines emphasize rehabilitation, improvements to water 

quality, and nonmotorized access. There are modest estimated trends expected for 

improving habitat potential for macroinvertebrates. These improvements do not change 

forest habitat trends. 

Neotropical Migratory Birds 

Following is a listing of priority migratory bird species, by habitat type, (Latta et al. 

1999) that are or have the potential to be found within the project area. Northern 

goshawk and Mexican spotted owl are discussed in the early pages of this document. 

Mixed conifer habitat is found within the canyons and is deferred from treatment. 
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Table 10 Neotropical Migratory Bird Habitat in the FLEA Area 

Bird species Mixed 

Conifer 

Ponderosa 

Pine, PineOak 

High 

Elevation 

Grassland 

High 

Elevation 

Riparian 

Northern 

Goshawk 

X X 

Mexican 

Spotted Owl 

X X 

Olive-Sided 

Flycatcher 

X X 

Cordilleran 

Flycatcher 

 X X 

Purple 

Martin 

 X 

Ferruginous 

Hawk 

 X 

Swainson’s 

Hawk 

 X 

MacGillivray’s 

Warbler 

 X 

Red-Faced 

Warbler 

 X 

Information on the environmental needs of these species is located in the Wildlife Report 

in the project file. 

Under all action alternatives effects to reduce cover would benefit the olive-sided 

flycatcher, cordilleran flycatcher, and purple martin due to the creation of more open 

habitats. Canyons would remain dense and SPNM and Primitive ROS objectives will 

improve habitat for MacGillivray’s warbler and red-faced warbler. There would be 

improved conditions to meadows and increased prey for Swainson’s hawk and 

ferruginous hawk. 

Alternative B would retain dense stands and would favor cordilleran flycatcher. 

Additionally under Alternative B, the high fire hazard potential would persist. In the 

advent of a large wildfire, habitat for all species, except Swainson’s hawk and 

ferruginous hawk, would be destroyed. 

There is no significant cumulative effects expected as future projects are implemented 

according to the management direction in Alternatives A, C, and D 
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SOIL AND WATER QUALITY 

The FLEA area consists of portions of several 5th code watersheds and includes portions 

of both the Verde and Little Colorado River basins. The affected 5th code watersheds 

include: 

• Cedar/Deadman - 98,588 acres41

• Sycamore Canyon - 12,268 acres 

• Lake Mary42 - 90,460 acres 

• Flagstaff - 129,705 acres 

• Canyon Diablo - 18,116 acres 

• Mormon Lake - 522 acres 

• Oak Creek - 26,319 acres 

Changes in Forest Plan language relate primarily to two watersheds: Lake Mary and 

Oak Creek. Ninety-three percent of the Lake Mary watershed lies within the FLEA area, 

and nine percent of the Oak Creek Watershed is within the FLEA area. 

Future site-specific implementation of the language in the current Forest Plan or any of 

the alternatives does not change trends for soil and water quality, or overall watershed 

health. 

Best Management Practices apply to all future projects. Forest Service roads and trails 

will be designed according to standards that prevent site-specific erosion. 

By recognizing watersheds related to important waters such as Lake Mary and Oak Creek 

Canyon, there is a sense of priority for conducting roadwork, meadow restoration, and 

other practices. This will help ensure managers make choices with water quality in mind. 

The Lake Mary watershed is given its own Management Area to help with emphasis for 

management. 

Increased flexibility for managers to reduce fire potential within the U/RIZ and the 

FMAZ 1U will lessen the risk of catastrophic fire losses that have effects on watershed 

characteristics. On- and off-site impacts on hydrologic function resulting from severe 

fire include: 

• Precipitation flowing on the surface of the soil rather than infiltrating into it; 

• Excessive erosion during precipitation events; 

• Rapid stream flow response from precipitation; and 

• A reduction in base flow between storms. 

 

41 These acres include all ownerships. 

42 The Lake Mary 5th code watershed includes Walnut Creek. 
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Watershed function is maintained under any alternative in the Cinder Hills. Increased 

emphasis on dispersal of riders, location of camping hubs, and improved road access will 

help improve site-specific instances of erosion. 

Under Alternatives A, C, and D, many of the SPNM areas occur on steep slopes where 

erosion could be a concern. The sense of priority that the action Alternatives have 

because of the increased acres of SPNM areas within the Lake Mary and Oak Creek 

watersheds will focus attention where it is most needed for site-specific erosion concerns. 

Under Alternatives A, C, and D, implementation of changes in camping management in 

key areas will improve site-specific compaction, run-off, and lack of ground cover in 

areas currently experiencing impacts. This includes the riparian areas of Pumphouse 

Wash, Walnut Canyon, Marshall Lake, and Lake Mary. 

The increased emphasis on sanitation facilities will alleviate concerns at popular 

recreation sites including Lake Mary and Marshall Lake. 

The action alternatives recognition that motocross is not an appropriate activity on 

National Forest lands will help managers make decisions on how to handle makeshift 

tracks especially in meadows. Meadows are a relatively rare component of the 

landscape, and an integral part of watershed function. 

The overall amount of trails and to some extent roads on the landscape is lower in the 

action alternatives. As site-specific implementation occurs to accept, relocate, or remove 

user-created (social) trails and roads, there should be additional areas of vegetative 

ground cover versus bare soil. 

There are no significant cumulative effects expected as future projects are implemented 

according to the management direction in any Alternative. 

VEGETATION 

The areas where changes are proposed for vegetation management are related to wildlife 

cover and fire hazard management. The desired condition of pine forests outside of 

Mexican spotted owl habitat is guided by northern goshawk guidelines (described in the 

Forest Plan pages 65-3 through 65-6). This is because goshawks are a forest dweller at 

the top of the food chain. Maintaining food, shelter, and water for the goshawk does the 

same for the goshawk’s prey, the prey’s prey, and the prey’s prey’s food base, thus 

resulting in all the parts of an ecosystem maintained. The desired condition outlined for 

goshawks can be achieved with a variety of prescriptions. Single or multiple treatments 

may be used so that trees grow to desired sizes and desired canopy closures and so that 

desired interspaces between trees are achieved. 

The text additions proposed for the FLEA area are added direction for lands previously 

classified as ponderosa pine and mixed conifer less than 40 percent slope (MA 3). These 
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areas are where most vegetative treatments have occurred in the past, and where most 

vegetative treatments are likely to occur in the future. This is because of the large 

amount of ponderosa pine on the landscape, and the continued need to progress towards 

desired conditions. 

Suitability of all lands for removal of a commercial timber product in the FLEA area does 

not change. However, the emphasis for management may be adjusted. Before Forest 

Plan Amendment 11 was adopted many of the acres of suitable timberlands in ponderosa 

pine less than 40 percent slope were classified under timber component 500 (suitable 

forest land-timber emphasis). Since Amendment 11 was adopted, most if not all of these 

acres changed to timber component 650 (suitable forest land - wildlife habitat emphasis). 

Alternatives A, C, and D provide added emphasis of fuels reduction in the U/RIZ and 

these lands could change to another form of the 600 series of timber components to 

reflect emphasis on fuels reduction. 

There are no required rates of implementation listed in the Forest Plan, rather a range of 

outputs and acres were analyzed. Actions to progress towards goals, objectives, 

standards, and guidelines described in the FLEA additions, fall within the range of 

activities analyzed in the Forest Plan. 

There is little difference among alternatives for vegetation. Under Alternative A, there 

will be trends towards less wildlife hiding and thermal cover. This translates into fewer 

acres in dense conditions and more acres in open growing conditions over time. Tree 

health and vigor is best maintained when there is less competition between trees for water 

and sunlight. Alternative A, provides for somewhat better growing conditions for trees in 

the FMAZ 1U area when compared to Alternative B. Alternatives C and D have slightly 

more cover (dense forest) than Alternative A and slightly less cover than Alternative B. 

Over all forest health is not different between the action alternatives. 

Current Forest Plan direction (Alternative B) allows for thinning trees to reduce overstory 

canopy closure which promotes the growth of grass, forbes, and shrubs in the understory. 

Alternative A provides for slightly more openings than Alternative B, because 

Alternative A requires fewer acres to be held in dense wildlife cover conditions. 

Alternatives C and D fall in between Alternatives A and B, however, the difference is not 

great. The potential exists, for overall trends for composition, diversity, and quantity of 

grass, forbes to be upward under all action alternatives. 

The clarification language brings the Forest Plan up to date with the current strategy that 

is two fold: control or remove existing plants and take steps to lessen the spread of 

noxious weeds. The Noxious Weeds Strategy (USDA, Coconino, Kaibab and Prescott 

Forests 1998) provides methods for conducting risk assessments and contains a flow 

chart of mitigation measures, such as cleaning equipment. This is especially important in 

the FLEA area because of the major highways and roadways which provide corridors for 

plants to spread, and because many of the noxious weed species have the opportunity to 

increase after ground disturbing activities such as thinning, prescribed fire, and road 

obliteration. 
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There are no significant cumulative effects expected as future projects are implemented 

according to the management direction in any Alternative. 

FIRE RISK, HAZARD, AND FIRE POTENTIAL 

Fire risk is a term used to indicate the probability of a wildfire ignition (particularly, a 

human-caused ignition). Just the increase in population of the Flagstaff/Lake Mary Area 

(FLEA) has increased the likelihood of a human-caused fire occurring within a 

threatening distance of a neighborhood. There are more local residents recreating in the 

forest around our community. 

Other demographics have also shifted. Humans active in the forest now are more likely 

to come from urban settings and have less mastery of wildland fire prevention. The 

widespread use of sport utility vehicles has increased the number of visits into the forest, 

as well as the range or depth of those visits into the area surrounding residential 

developments. 

Over the last ten years, there are many more people who would be endangered by a 

severe wildfire. Neighborhoods have spread into forested areas making them more 

difficult to protect. The length of “neighborhood” perimeter that public agencies must 

defend has grown, increasing our community’s exposure. There is currently 230 miles of 

forest boundary adjacent to private land within FLEA. Each of these changing fire risk 

factors suggests a higher degree of fire safety is needed. 

Fire hazard is a term used to indicate the intensity with which a wildfire will burn and 

spread, once ignited. The fire hazard is influenced by many factors: the accumulated 

dead and down fuel, the number and spatial arrangement of living trees, the topography, 

the prevailing wind direction and speed, the air temperature and relative humidity, and 

typical site-dryness. A fire manager must also consider the site’s proximity to 

commercial and residential development. However, management actions can only reduce 

two of these factors to mitigate all of the other contributors, that is to say the dead and 

down fuel and spatial arrangement of living trees. 

Effective reduction of dead and down fuel is accomplished by prescribed burning. 

However, it is difficult to conduct such burns in close proximity to commercial and 

residential development. It is especially difficult to burn near developments frequently 

enough to be effective, because residents feel frequent burning causes unacceptable 

smoke impacts even if burning is within ADEQ guidelines. 

Creating open stand conditions near developments is a more viable option of reducing the 

fire hazard because of these constraints on prescribed burning in such areas. As the 

population of the Flagstaff/Lake Mary Area has grown, so have the number of fire-prone 

trees within it. The current Forest Plan direction limits fire managers’ ability to mitigate 

the increasing fire hazard quickly enough within FLEA because there is not enough 

flexibility in cover requirements to meet fire management needs. 
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Fire potential is a term often used to indicate the danger of a fire occurring when “fire 

risk” and “fire hazard” are considered together. Both fire risk and fire hazard have 

increased within the Urban/Rural Influence Zone (U/RIZ), within the larger Ponderosa 

Pine/Urban Interface Fire Management Analysis Zone (FMAZ 1U), and within FLEA, 

which is larger still. The action alternatives would reduce both fire risk and fire hazard to 

different degrees, and so reduce overall the fire potential of the three concentric areas. 

Environmental Consequences Across the Entire FLEA Area

The action Alternatives A, C, and D reduce the risk of a wildfire occurring throughout the 

FLEA area. Each of these alternatives proposes to increase the area within the FLEA 

boundary where camping is prohibited from 11.5 percent of National Forest lands to 19.1 

percent. This change would reduce one ignition source of wildfires (fire risk). In 

addition, Alternatives A, C, and D would increase the areas of designated dispersed 

camping from 0.1 percent to 9 percent of National Forest lands. Where designated 

dispersed camping could occur, agency managers could choose locations that are 

relatively less hazardous, such as areas where a low wildfire intensity is expected. 

Managing an area as nonmotorized removes another ignition source of wildfires (fire 

risk), but only from that particular area. Each of the action alternatives proposes 

managing additional acres toward a nonmotorized recreational setting (16.2 percent in 

Alternative A, 2.7 percent in Alternative B, 16.5 percent in Alternative C, and 17.9 

percent in Alternative D). 

Managing camping and motorized vehicle access does not however, eliminate all humancaused wildfires, nor does it address lightning ignited wildfires. The fire hazard 

(intensity with which a wildfire will burn and spread) must also be mitigated. 

Environmental Consequences only within the FMAZ 1U

Since prescribed burning near developments is limited by constraints cited above, 

reducing fire hazard depends almost entirely on managing the number and spatial 

arrangement of living trees. 

In 1987 when the Forest Plan was completed, forest fire managers believed the 

application of the 30 percent wildlife cover requirement across the Ponderosa Pine/Urban 

Interface Fire Management Analysis Zone (FMAZ 1U) provided an acceptable fire 

potential. With the demographic changes cited above in Affected Environment, leaving 

30 percent of the forested area within the FMAZ 1U in dense stands with closed canopies 

now presents an unacceptable combination of fire risk and fire hazard to our community. 

Alternative A proposes lifting this cover requirement within the FMAZ 1U. This would 

not prohibit the retention of wildlife cover. Some wildlife cover would be maintained 

within this zone. However, it would provide fire managers with the flexibility to thin 

dense stands that are particularly at risk of ignition or that are particularly hazardous to 

neighborhoods. 
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Under Alternative A, the percentage and arrangement of wildlife cover retained within 

the FMAZ 1U for any subsequent project would be determined by the “fire risk” and 

“fire hazard” of the particular site. Outside the FMAZ 1U (Ponderosa Pine/Urban 

Interface Fire Management Zone) and across the rest of the forest the requirement for 

retaining at least 30 percent of the forested area in wildlife cover would remain 

unchanged. 

Alternatives C and D both propose reducing the 30 percent wildlife cover requirement 

within the FMAZ 1U to 15 percent. This would provide fire managers with less 

flexibility than Alternative A to thin dense stands that are particularly at risk of ignition 

or that are particularly hazardous to neighborhoods. 

Under both Alternatives C and D, any subsequent projects would strive to ensure that 15 

percent of the FMAZ 1U is managed for conditions that could provide wildlife cover. 

The arrangement would be determined by the “fire risk” and “fire hazard” of the 

particular site. Outside the FMAZ 1U (Ponderosa Pine/Urban Interface Fire Management 

Zone) the requirement for retaining at least 30 percent of the forested area in wildlife 

cover would remain unchanged. 

Environmental Consequences only within the U/RIZ

Canopy cover requirements for target threshold habitat result in high potential for crown 

fire. When accumulating existing Mexican spotted owl Protected Activity Cores (MSO 

PACs), wildlife travelways, and potential MSO PACs (target threshold acres) 40 percent 

of the National Forest land within 1⁄2 mile of private land is in a dense canopy condition. 

Reducing this percentage is necessary to achieve the future desired condition for fire 

potential within the U/RIZ. 

Existing condition displays 186 acres of mixed conifer and 850 acres of pine oak 

restricted habitat within the U/RIZ. The location of these acres also makes them 

important for fire hazard reduction and the probability of a severe wildfire occurring is 

unacceptably high. The FLEA proposed allocation of target threshold habitat within the 

Lake Mary Watershed and Shultz Management Areas (Alternatives A, C, and D) would 

allow the creation of more open canopies within the U/RIZ. This would help achieve the 

desired condition of low fire potential within 1⁄2 mile of private land. 

Conclusion: 

Alternative A – Greatest ability to reach low fire potential in U/RIZ and FMAZ 1U 

Alternative B – Least ability to reach low potential in U/RIZ and FMAZ 1U 

Alternative C – More difficult, but likely to reach low fire potential in U/RIZ and 

moderate fire potential across FMAZ 1U 

Alternative D – Same as Alternative C 
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AIR QUALITY 

Management activities within the Flagstaff/Lake Mary Environmental Analysis Area 

would affect the Little Colorado River and the Verde River air sheds. Air quality over 

this area is generally good. Significant sources of air pollution are vehicle exhaust, 

smoke form prescribed burning and wildfires, and dust from unpaved roads. 

The Clean Air Act of 1977 places responsibility for managing air quality within its 

borders to the individual state governments. Air degradation may occur temporarily 

during prescribed burning, but will not exceed air quality standards. The Coconino 

National Forest receives a permit for prescribed burning each year and must receive 

specific approval for each prescribed burn on a daily basis. There are no significant 

cumulative effects expected under any alternative. 

There are no changes to Forest Plan direction for prescribed fire under any alternative. 

Current practices are not affected by any alternative. There is no change to current trends 

for smoke impacts to air quality under any alternative. 

SOCIAL 

Overall Outdoor Recreation Experiences 

Inventory of Recreation Opportunity Spectrum (ROS) on the Coconino Forest has been 

an ongoing and iterative process beginning with hand drawn maps when the Forest Plan

was signed in 1987. The past and present ROS maps (1979, 1993, and 2001) cannot be 

used as a rigid basis for comparison of changes to ROS settings over time due to 

differences in resolution and intent. In order to compare alternatives, a 1992 inventory 

was chosen because it had complete GIS information. The 1992 map was created at a 

grosser scale as a regional inventory map while the alternative maps for FLEA are more 

refined, and reflect updated information brought forward by team members during the 

analysis. When comparing the inventory map (no action Alternative B) to the action 

alternatives it is important to note that the comparison is between an inventory and a set 

of objectives. Regardless, such a comparison reflects differences in the future mix of 

ROS settings on the FLEA landscape under each alternative. 

Trends in ROS (regardless of the type of inventory used) have shown increases in both 

the Urban (U) and Rural (R) settings, as the Flagstaff area development expands, and in 

the SPM settings, as some of the Forest access roads throughout FLEA deteriorate 

because they do not receive regular maintenance. The expansion of semiprimitive areas 

has occurred as the RN setting has shrunk. 

The Alternative A map, located at the end of Appendix A, represents more refined and 

detailed knowledge, and a relaxed standard for the size of SPNM areas that would allow 

them to be smaller. The smaller minimum size for SPNM areas allows some flexibility in 

planning for complex areas such as within and near the FLEA U/RIZ, and has proven 
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useful for forest planning elsewhere in the Forest Service. The map produced for 

Alternative A represents a relaxed standard for social encounters for many of these 

smaller SPNM settings, shown as SPNM1. 

National Forests, National Monuments, and other public lands act as reservoirs of 

“naturalness” in a rapidly urbanizing world. The Flagstaff area, along with many 

formerly rural or primitive areas in Arizona and throughout the west, has changed 

character rapidly as development has encroached on the natural-appearing landscape. 

The formerly primitive landscape, devoid of the evidence of human activity, such as 

buildings, roads, power lines, cell towers, and stock tanks, has given way to a landscape 

where such evidence is pervasive. 

Research into the effects of natural settings on humans indicates that there are significant 

benefits to society from having natural settings available and accessible to people. The 

public lands of the FLEA area have special significance for the 50,000 plus residents and 

for the hundreds of thousands visiting the area annually. Surveys of local residents 

(Arizona Hospitality Research and Resource Center 1990) show that residents and 

visitors use the local National Forest lands extensively seeking natural settings for 

solitude, spiritual renewal, challenge, risk, and numerous other reasons. Existing 

recreation settings seem to meet the present needs of people for a variety of activities that 

are not always compatible in more crowded areas; however there is evidence that 

demands are starting to create conflicts with forest resources and between types of users. 

Comments to most planning efforts often include expressions of a desire for the retention 

or restoration of “natural” values and appearances to forest landscapes. Included in these 

comments are requests for more opportunities for relative solitude, natural quiet, 

uncrowded, or isolated forest settings, and natural scenery uncluttered with non-natural 

objects, all characteristics of semi primitive settings. Responses to the FLEA planning 

efforts related to existing or proposed ROS settings have included several requests for 

semiprimitive settings and none for settings less primitive than semiprimitive 

nonmotorized. The most recent local study of peoples’ desires for various forest 

recreation setting characteristics was for the recent Sedona area Forest Plan Amendment 

(12), which clearly expressed a preference for semi primitive and primitive setting 

characteristics for those Forest visitors (Lee and Pierskalla, 1996). 

Most debates about ROS settings involve whether an area should be open to motorized 

access. There are numerous advocates for both motorized and nonmotorized access for 

many sites in the FLEA area. Most Forest visitors use vehicles to get to their recreation 

destination, and many use their vehicles as a form of recreation. Motorized access to 

National Forest lands is considered to be a legitimate use of the National Forests within 

limits imposed by forest resource concerns. The Forests are also managed to provide a 

range of recreation settings that include some attributes, such as natural quiet, isolation 

from the sights and sounds of others and opportunities for solitude (USDA 1986), that are 

not always compatible with motorized use, especially where total recreation use levels 

are high. All of the action alternatives do not consider “motocross” activities on Forest 

lands as an appropriate activity in the FLEA area, since the sights, sounds, and effects of 
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such activities are not compatible with recreation settings or with other Forest resource 

values. 

The ROS settings under Alternatives A, C, and D, reflect a desire to provide a diversity 

of setting opportunities distributed around the FLEA area. The presence of the 

Strawberry Crater, Kachina Peaks, and Red Rock/Secret Mountain Wildernesses near or 

within the FLEA area contribute to P and SPNM settings available for local use; however 

Congressionally designated Wildernesses were not created to meet all demands for 

primitive recreation. 

Nonmotorized settings presently total less than 3 percent of National Forest lands in the 

FLEA area; although many areas are technically nonmotorized because of terrain 

limitations. Alternative D includes about 18 percent of the area as nonmotorized with 

other alternatives having slightly less. SPM settings would be the management objective 

on about 46 percent of the total area under all but the No Action (Alternative B) and RN 

settings would be the objective for approximately 35 percent of the area under all 

alternatives except for Alternative B. The most significant change from the existing 

Forest Plan 1992 inventory is the change from RN settings, which shrunk from about 68 

percent down to about 35 percent; and the subsequent change in SPM from about 27 

percent to about 46 percent of the total FLEA area. Primitive settings change from 0 to 

3.6 percent. 

There is a large demand for opportunities to explore the Coconino National Forest in a 

vehicle over rough roads that was expressed at our public meetings and that reflect 

national trends. The deterioration of Forest “system” roads over the past decade due 

largely to decreased emphasis on logging operations and on less funding for road 

maintenance, has caused many of those roads to become primitive roads. This has caused 

a large increase in the availability of primitive roads in the FLEA area. Areas where only 

primitive roads provide access make up about 46 percent of the FLEA area, or roughly 

135,000 acres under Alternatives A, C, and D. 

Road densities vary across the FLEA area and SPM settings in many places exceed 2 

miles per square mile. Desired conditions for these areas range for 0.5 to 2 miles per 

square mile depending on the area, with the 2 miles per square mile a suggested 

maximum threshold for meeting SPM objectives43. This would yield roughly 100 to 400 

miles of primitive road in SPM settings. This would not include primitive roads that 

would still exist in RN settings that could easily add another 200 miles or so of primitive 

road. Opportunities for traveling through the Forest on primitive roads will remain 

plentiful for all action alternatives. 

There is a large demand for opportunities to explore the Forest in a standard, low 

clearance passenger vehicle. RN ROS settings typically have roads that will allow such 

access. RN settings will occupy about a third of the FLEA area under all action 

alternatives. There has been a large decrease in areas accessible to passenger car type 

vehicles over the past decade, as the quality of Forest system roads has declined. This 

 

43 The 2-mile per square mile is described in the current Forest Plan for the ponderosa pine type. 
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decline in passenger car roads is one of the main reasons FLEA ROS setting objectives 

have shifted towards the more primitive; partially reflecting the reality of the situation in 

the Forest landscape. 

The allocation of recreation settings in the action alternatives represents a reasonable 

balance of motorized versus nonmotorized settings dispersed throughout the FLEA area 

in order to help meet demands for a variety of recreation settings. Subsequent travelway 

planning at a more refined scale will likely adjust the location and configuration of the 

different areas. 

Expected cumulative effects are as follows. Recreation settings have been used as 

objectives for defining future conditions on the landscape around Sedona under 

Amendment 12 to the Forest Plan. The remainder of the Coconino National Forest 

remains under recreation setting inventory. Generally, the ROS objectives around 

Sedona and Flagstaff (under Alternatives A, C and D) contain a higher percentage of 

SPM and SPNM settings than the remainder of the Coconino Forest. Wilderness areas 

continue to provide settings at the most primitive end of the ROS setting scale. Forestwide, there will continue to be a variety of recreation settings and recreation opportunity. 

People and Wildlife 

People enjoy seeing wildlife as referenced by comments to the Ideas for Change and 

Arizona Game and Fish Department questionnaires (copies located in Project File). 

People like to know wildlife, such as bear and turkey, are using an area, even if the 

people don’t get to see them everyday. Some species provide opportunities for hunting 

which is often an outing with family or friends or a source of meat for food. Some sites 

are becoming known for wildlife viewing opportunities just by word of mouth and from 

locally run news stories. Examples are the bald eagles at Lake Mary and the deer on the 

base of Mt. Elden. 

Because the mix of ROS objectives proposed in the action alternatives was designed to 

help maintain disturbance-sensitive species, it is likely that these species will remain 

available for human enjoyment in the FLEA area over time. Even in the face of 

increasing human uses, bear and turkey can co-exist with people in many of the SPM and 

SPNM ROS settings. 

The ability to view wildlife while driving is maintained in the SPM and RN settings. The 

ability to view wildlife while hiking, horse riding, or mountain bike riding, remains 

available throughout the FLEA area. The chances of seeing wildlife is greater if there is 

maintenance of the unroaded/untrailed patches on the landscape in between the open road 

and trail system. 

There is a difference between the alternatives related to the future presence of deer and 

elk, and thus the ability to view them. Under Alternative A there may be a slight 

decreasing trend in the amount of cover habitat elk and deer use of the FMAZ 1U. 

Alternatives C and D would maintain deer and elk in the FMAZ 1U similar to the no 

action Alternative B. 
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Camping Experiences 

The current mix of camping opportunities in the FLEA area is 87 percent general 

dispersed camping, 11.5 percent closed to camping and no campfires, 1.4 percent 

campfires not allowed, and 0.1 percent restricted to designated dispersed campsites. 

There are six developed campgrounds and additional private campground opportunities in 

Flagstaff. 

General dispersed camping is very popular. Some areas close to major highways and 

attractions are heavily used, while other dispersed areas are remote and less impacted. 

Forest Service recreation and fire prevention patrols have noticed a steady increase in 

general dispersed camping over the years. One example of significant increase in use and 

resource impacts is along the Highway 89A (south of Flagstaff) corridor that 

encompasses 1⁄2 mile on either side of the highway. As a result of limited number of 

camping sites in Oak Creek Canyon and increased visitation, recreationists have found 

Highway 89A north of Oak Creek Vista a good place to camp because of its close 

proximity to Flagstaff and Sedona. As a result of this increased use, dispersed campsite 

conditions suggest that user experiences and scenic quality have been adversely affected 

at some sites. Attractive settings and limited access have concentrated campsites within a 

confined area; therefore, many popular sites are located within sight and/or sound of each 

other. At these popular dispersed sites, occasional conflicts occur between parties due to 

loud noise, ATV use, and, in some cases, the use of firearms. Dispersed site conditions 

exhibit other characteristics that are a result of visitor behavior. It is common to find 

human waste near dispersed sites. In addition, litter is left at campsites and proliferates 

with each use if not removed promptly. This residue left by dispersed users is a health 

and safety concern, particularly during periods of peak use. The presence of human 

waste and litter, tree damage and loss, and denuded and compacted camp areas, suggest 

that both scenic quality and the intended recreation experience opportunity may be 

despoiled within high use and heavily impacted sites. Many visitors express concern 

about the damage to resources created by people and therefore the effect to recreational 

experience. 

Some people like developed campgrounds and enjoy such amenities as running water, 

flush toilets, showers, RV hook-ups, picnic tables, and campfire programs. For people 

who like campgrounds there is no difference between the alternatives because no 

campgrounds are added or changed with any alternative. 

Some people like to camp off of major highways and forest roads and often camp in close 

proximity to others in areas that are easy to find yet have no facilities. This is usually in a 

RN setting. In the FLEA area these people use Highway 89A corridor, Lake Mary Road, 

and Highway 180. 

Some people like to explore the forest by vehicle and find remote camping settings with 

few or no other people around. This is usually in a SPM ROS setting. Forest Service 
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patrols say they see many people on summer weekends in the Lake Mary Watershed area, 

than during the week or other seasons. 

Some people like to use horses, llamas, mountain bikes, or backpacking to carry in 

camping equipment and set up campsites in remote, natural forest settings with few 

encounters with others. This is usually in a SPNM ROS setting and current opportunities 

exist in Mt. Elden/Dry Lake Hills. 

On National Forest lands, for Alternative A, C, and D, there is 70.8 percent of FLEA 

available for general dispersed camping, 19.1 percent closed to camping and campfires, 

1.4 percent with camping with no campfires allowed and 9.0 percent with camping only 

in designated campsites. 

There is less camping opportunity overall as the no camping/no campfire zone expands 

from a current level of 11.5 percent to 19.1 percent. 

For people who like easy access, no facilities, and close proximity to others, the 

alternatives are different. The overall amount of this opportunity will be less as shifts are 

made to designated camping in some popular places. People will have to take a little 

more time finding a site and will need to read signs and follow the rules in these areas. 

Some people will feel that this restricts their recreational pursuits and therefore feel a loss 

of freedom would be greater in Alternatives A, C, and D than with Alternative B (No 

Action). The biggest change is along the Highway 89A corridor and the road to Marshall 

Lake. 

Although the overall general dispersed camping area is less, the quality of the camping 

experience is better. There will be less visible bare ground, fewer rock fire rings, and less 

trash, all of which take away from the beauty of the campsite area. Some visitors will 

feel displaced and may move to previously undisturbed areas causing other impacts 

elsewhere. 

For people who like to find remote out-of-the-way places, the quality of this camping 

experience is enhanced in SPM and SPNM ROS settings. All action alternatives strive to 

increase the amount of SPM and SPNM objectives and reduce the amount RN settings. 

There is a difference in opportunity for camping with horse, mountain bike, or 

backpacking. There is more of this opportunity in the different alternatives based on the 

amount of SPNM settings. 

Alternative B (No Action) provides the greatest amount of camping opportunities and 

freedom of where to camp because it has the least about of restrictions. However, it is 

expected more dispersed camping areas would become established over time and result in 

greater user conflicts, resource impacts, and complaints from residents who live adjacent 

to the forest. 

When considering cumulative effects it is important to note that restrictions in camping 

under Alternatives A, C and D occur on a very small percentage of the Coconino Forest. 
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Similar changes are occurring in the Sedona area and described in Amendment 12 to the 

Forest Plan. The remainder of the Forest continues to provide dispersed camping 

opportunities. 

Rock Climbing Experiences 

Rock climbing within the FLEA area has been an ongoing and increasing recreational 

activity for many years. Rocks climbing groups and individuals have identified many 

user-developed climbing areas, and routes throughout the FLEA area, which include a 

range of climbing opportunities from bouldering, and traditional climbing to sport routes 

protected by bolts and fixed hardware. Several popular climbing areas are less than 3⁄4 

miles from a developed trailhead and have trails that lead to the climbing sites, either 

Forest Service trails or user-created trails. These popular areas close to town include: 

West Elden, The Pit, and Priest Draw. Other remote sites exist in the area, with no 

parking and user-created trails accessing the site. 

A complete inventory of climbing routes in the FLEA area has not been done. Currently, 

the Forest Plan is silent, providing no specific management direction to either validate or 

promote climbing as a recreational activity or to manage resource impacts resulting from 

this use. 

Climbers are generally explorers who do not generally desire a lot of developments, 

signs, or rules. Climbers hear about remote areas from other climbers. 

Under all alternatives except B, there would be standards and guidelines that apply to 

climbing. In general, the availability of climbing opportunities is maintained. 

Monitoring will be done to collect information on resource conditions and use trends at 

climbing areas. This monitoring would be dependent upon available budget, and would 

likely rely heavily on partnerships and volunteer efforts. Where sensitive or rare plant or 

animal species exist, monitoring will be done to assess impacts. It could be that certain 

sites are closed seasonally, or different climbing routes are designated, based on 

monitoring. 

The proposed Forest Plan direction allows for stricter management if necessary, 

however, the exact level of restrictions is not known at this time. If a change in 

management is necessary, such as a seasonal closure due to wildlife, resource, or cultural 

impacts, climbers may feel displaced and a sense of lost of a particular route for the 

short-term. The variety of technical difficulty available is not expected to change under 

any alternative. 

For popular sites there may be changes in parking and trail locations, which will still 

maintain the area for use, but people may have to walk farther to access sites. For 

popular sites camping may be restricted, which does not change the climbing opportunity 

itself. 

The proposed Forest Plan direction emphasizes the importance of climber input to future 

site-specific decisions. 
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Alternative B would have increased potential for increased resource damage due to the 

lack of management direction. Without adequate resource monitoring, trends in resource 

conditions resulting from climbing activities would not be detected until impacts become 

severe. 

Trail Experiences 

It is difficult to describe the complex social situation related to National Forest lands in 

the U/RIZ. For years, residents have enjoyed the ability to strike out from their own 

backyards, or nearby access points, and hike, bike, ride horse, or ride ATV’s. Others 

exercise dog teams, or walk with llamas. For years, residents have not seen many Forest 

Service signs, developed facilities, or patrols. For years, trails have become established 

from use. The nearby forest is a leading factor in the quality of life in these communities. 

There is almost a sense of ”ownership” by residents of the lands near them. 

Sometimes use has resulted in unsightly impacts and trash. 

A rapidly growing and diversifying residential population adjacent to the National Forest 

and its contrast with rural values in less urban areas are resulting in conflicting user 

experiences and desires. 

The Forest Plan changes under Alternatives A, C, and D does not significantly change 

the ability of people to use and enjoy the U/RIZ. There may be a few more signs, some 

trails may be closed and others left open and debates over types of use will continue 

where conflicts exist. Access points may become more formalized over time, such as 

with signing and parking. The numbers of encounters with others remains high. 

Recreation use in the U/RIZ for all the action alternatives will be more concentrated and 

higher use levels can be expected. Users conflicts may increase as incompatible uses 

aren’t separated, or desired opportunities aren’t available. 

The proposed direction allows us to better manage forest settings to meet the needs and 

expectations of people using trails in the U/RIZ. There is an emphasis on keeping setting 

attributes, typical of remote and primitive forest areas, in close proximity to the places 

where people live. This expands the area of predominantly “natural” attributes, 

enhancing National Forest resource values while providing benefits to society in terms of 

settings that promote relaxation, outdoor exercise, and stress reduction close to where 

many people can benefit. 
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In the U/RIZ the ROS settings by alternative are: 

Table 11 ROS in the U/RIZ 

The successful management of Forest Service lands adjacent to privately owned lands 

(there are 230 miles of public/private boundary within the FLEA area) is dependent as 

much on the attitudes and actions of people living on the Forest boundary as it is on the 

actions of the Forest Service. Trails are an important manifestation of peoples’ attitude 

towards the Forest next to them. The action alternatives give added emphasis to fostering 

good “stewardship” practices for those people through a commitment to address both the 

needs of Forest “neighbors” and those aspects of Forest resources that can benefit from 

good planning and implementation. Good planning and the commitment of neighbors to 

implement those plans can result in an enhanced “natural appearing” Forest environment 

that will enhance and preserve the quality of the Forest environment and the quality of 

life of local residents. 

Much of the management direction in Alternatives A, C, and D focuses on the U/RIZ 

which is a very small portion of the Coconino. Road and trail management in this area 

will result in on-the-ground changes. People will appreciate many of these changes, 

other changes may be perceived negatively. Road and trail management will add 

cumulatively to similar effects from projects accomplished by Coconino County and the 

City of Flagstaff (see the Greater Flagstaff Open Spaces and Greenways Plan and the 

Regional Land Use and Transportation Plan). 

There are currently 90.7 miles of Forest Service system trail within the FLEA area. The 

amount of user-created trails in the FLEA area is unknown, however, the highest 

densities of user-created trails occur in the U/RIZ. 

Some user-created (social) trails that access National Forest land begin on private land 

and have been historically been used for access. Many of these trails have evolved where 

people like to hike, in drainage bottoms, and in fragile areas where there are threatened, 

ROS Setting Percent of ROS Setting by Alternative in the U/RIZ 

Alt A Alt B Alt C Alt D 

SPM 10.9 0 15.1 15.3 

SPNM 30.2 1.9 26.0 25.9 

RN 58.8 86.0 58.8 58.8 

P 0 0 0 0 

R 0 8.6 0 0 

U 0 0 0 0 
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endangered, and sensitive plants and animals. As population increases and demands 

change these user-created trails have also created conflicts between nonmotorized and 

motorized users groups. It is likely that most visitors use the Forest System trails 

primarily; while most local use is via user-created, non-system, neighborhood trails. 

Trail user experience is affected by many variables that include: parking, information, 

signing, trail conditions, maintenance, types of trail uses, and the number of trail users. 

Most trails are open to more than one type of user and there are some conflicts between 

user groups. 

Technology has changed and increased the users’ ability to access and use various parts 

of the National Forest that weren’t easily accessed before. The increase in population 

and changes in technology have made it challenging to manage for all types of 

nonmotorized and motorized trail opportunities. An increased demand for trail activities 

has placed a greater emphasis on trail system planning, maintenance, construction, and 

reconstruction. 

None of the action alternatives change the ability to use and enjoy the Forest Service trail 

system in the FLEA area. The proposed Forest Plan direction will, as implemented sitespecifically, decrease the miles of user-created trails, especially where they occur in 

sensitive sites such as riparian areas. 

The proposed direction allows us to evaluate and relocate or close user-created trails, and 

gives priority for this work to canyon bottoms, lake beds, cultural sites, steep slopes, 

threatened and endangered species habitat or for user safety. 

People may be re-directed from their favorite user-created trail and may feel a sense of 

loss or inconvenience when this happens. But overall, the site that they have come to 

visit will be maintained over the long-term. 

The action alternatives will provide opportunities for nonmotorized and motorized 

activities to increase over time with the addition of Forest Service system trails. 

Appropriate uses for each new trail would be decided on a case-by-case basis to help 

reduce user conflicts and resource impacts. 

Under the action alternatives, text changes do not result in immediate closure of areas to 

human entry. However, text changes allow area closures should they be necessary to 

maintain threatened or endangered species, cultural resources, or other important land 

features. The alternatives emphasize that choices should be made based on monitoring 

results. The monitoring direction in the Forest Plan will set the stage for trail location 

decisions based on good information. The increase in more “primitive” ROS settings will 

increase opportunities for attributes, such as solitude, natural quiet, and scenery within 

close proximity for Flagstaff area trail users and visitors. 

The action Alternatives A, C, and D will place additional demand on Forest Service 

resource and administrative overhead to maintain, construct, obliterate, and manage a 

larger Forest Service trail system in the FLEA area. Additional volunteer groups, 
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partnerships, and residential community support will be needed to help maintain the trail 

system. 

This amendment, in conjunction with the current Forest Plan, is used as the basis for 

developing budget proposals. The FLEA area is only a portion of the Forest and 

priorities for FLEA will be balanced with other Forest priorities for trail and other 

recreation management. Current recreation budgets are not keeping up with current 

maintenance needs or new demands. It is likely that the rate of implementation will be 

opportunistic and tied to other resource projects. Partnerships with communities and 

other agencies can help facilitate implementation. 

Scenery 

The action alternatives would generally raise scenic integrity standards as a result of 

changes to ROS settings. The action alternatives all have changes in overall ROS 

objectives that tend to be more towards “primitive” than they are at present. There would 

be no immediate noticeable change in scenic quality as a result of any action alternative 

selection, but the change in setting objectives from roaded natural to semiprimitive could 

help retain existing desirable scenic characteristics in some areas, and could help focus 

priorities for future action that would enhance or retain scenic integrity. 

Recent increases in off-road travel have led to increasing degradation of scenic quality in 

some areas as tracks and ruts proliferate. The problem varies by location, slope, soil 

type, and season of use, but is generally greatest close to communities and high use areas 

such as the Cinder Hill OHV area. Designation of SPNM areas will preclude most 

motorized use in those areas and could retain or enhance scenic quality in areas close to 

communities where scenic quality is highly valued. Areas managed to obtain an SPNM 

setting will eventually have a more natural appearance and will therefore maintain a 

higher degree of scenic integrity than areas with less primitive setting characteristics. 

The recent, on-going efforts to reduce tree stand densities in order to decrease fire risk 

and to improve forest health will likely continue regardless of which alternative is 

implemented. The effect of these treatments will generally help scenic quality by 

decreasing the “thicket” effect and by enhancing the longevity of older trees. 

Implementation of the new Scenery Management System will give us a tool for 

communicating with people to collectively develop a desired future condition for the 

overall landscape character of the FLEA area and for the entire Coconino National Forest 

eventually. In lieu of a definitive desired landscape character description, the action 

alternatives all advance actions such as thinning and transportation planning that will 

preserve options for future desired condition scenarios, and that will enhance scenic 

quality. 

Under the action alternatives, the Forest Plan direction allows us to progress towards 

clean up and re-vegetation of bare soil/trashed out areas. A recent example is the Old 

Caves Crater area and this can be seen as example of future projects. 
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Both within the U/RIZ and in the remainder of FLEA the action alternatives maintain the 

emphasis of clean up after activities especially near major roads, developed sites, and 

private lands. The new direction recognizes landowner input as an important 

consideration when designing thinning projects. 

The action alternatives will result in more semiprimitive and primitive settings that 

require a higher scenic integrity objective (FSM 2870). Eventually these areas will 

assume a more “natural” appearance with less evidence of human activity such as vehicle 

tracks and ruts. In addition, the rate of changes for those areas that still have largely 

“natural appearing” characteristics will be slowed or reversed. The result will be an 

improvement in scenic quality for those areas affected, assuming that scenic quality 

objectives are met. 

Alternative A could result in a substantial increase in scenic quality over the No Action 

Alternative B as a result of proposed changes to ROS settings, assuming that new scenic 

integrity objectives assigned to the more “primitive” settings are met. Alternatives C and 

D will have an almost identical effect on aesthetic quality to each other but alternative D 

has slightly more SPNM area designated than Alternative A. The additional lands in 

Alternative D with a SPNM objective are adjacent to Walnut Canyon, where there is a 

very high concern for scenic quality with potential for high visitation rates. Both 

Alternatives C and D will result in more area with SPNM settings and therefore higher 

scenic integrity objectives than the other alternatives. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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83 

MANAGEMENT AREAS 

The current Management Areas within FLEA are listed in the following table. These 

original MA’s will continue to exist and provide reference for management direction in 

the current Forest Plan. For example, management indicator species will continue to be 

identified according to the original MA’s. 

Table 12 Current Management Areas

MA Description Percent of 

NF lands in 

FLEA 

1 Wilderness 3.5 

3 Ponderosa Pine And Mixed Conifer Less Than 40% Slope 36.7 

4 Ponderosa Pine And Mixed Conifer Greater Than 40% 

Slope 

4.8 

5 Aspen 0.1 

6 Unproductive Timber Land44 8.7 

7 Pinyon And Juniper Woodland Less Than 40% Slope 23.0 

8 Pinyon And Juniper Woodland Greater Than 40% Slope 3.3 

9 Mountain Meadow 3.0 

10 Grassland And Sparse Pinyon And Juniper 6.6 

12 Riparian And Open Water 0.4 

13 Cinder Hills 7.9 

15 Developed Recreation Sites 0.5 

17 Special Areas 0.2 

18 Elden Environmental Study Area 0.1 

EXP Experimental Forest45 1.2 

Under Alternatives A, C, and D, Management Areas are delineated to provide a 

geographical reference and “sense of place.” Management emphasis is defined for each 

MA, and there is some management direction that is specific to a particular MA. Most of 

the MA’s are new. Two MA’s are re-drawn from the current Forest Plan. MA13 

 

44 Unproductive timberlands are ponderosa pine areas that do not meet minimum standards for 

productivity or where there is not reasonable assurance that lands can be restocked as required by 

CFR219.27. 

45 Experimental Forest lands are administered by the Rocky Mountain Forest and Range Experiment 

Station and are not affected by this amendment. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 3 - Affected Environment and Environmental Consequences

84 

previously covered the Cinder Hills OHV area and the surrounding landscapes. MA13 

was reduced to include only the OHV area. The remaining landscapes surrounding 

MA13 were delineated as the Craters, Doney, and Deadman MA’s. MA18 previously 

covered the Elden Environmental Study Area. The action alternatives move this 

classification to MA17, Special Areas. In addition, the action alternatives expand MA17 

to include additional environmental study areas for Old Caves Crater and Griffiths 

Spring. Acres shown for each MA are National Forest acres only. The FLEA MA map 

is located at the end of Appendix A. 

By separating the Cinder Hills OHV Area into its own MA (MA13) and placing the 

surrounding landscape in other MA’s there is a focused set of management direction. 

Implementers will no longer have to differentiate between different sets of guidelines for 

inside of outside of the OHV area. 

Delineating most of the Lake Mary Watershed in one MA helps focus a sense of identity 

and emphasis to that watershed. Delineating the Walnut Canyon MA provides a sense of 

place and emphasis to the canyon and its surrounding environment. Delineating the 

Deadman Wash MA helps focus discussions related to the geologic and cultural story of 

the lands between Sunset Crater Volcano and Wupatki National Monuments. These 

delineations are important given the set of resource and social values attached to these 

areas. 

Flagstaff Public schools have developed curricula and use the two new environmental 

study areas added to MA17. These areas also have important features, one being 

archaeological sites and the other being a perennial stream. 

Each MA has a relatively unique set of land features as described in the description 

section of the replacement pages. 

Cinder Hills OHV Area 

The Forest Plan currently states that slopes over 40 percent should have a dense network 

of designated trails. The new text, common to Alternatives A, C, and D, eliminates this 

language, as some slopes over 40 percent will be open to riding. On steep slopes, 

vehicles need the option of leaving intended travel routes, to have the option of making a 

quick loop to turn around and head back down without flipping over. In addition, 

designated routes cause difficulty because the large number of markers needed and the 

open nature of steep faces. Designated routes can create more impact than dispersed use 

on the slope. Safety concerns arise when many vehicles are driving two directions at 

high speeds on designated routes. 

Rather than implementing a system of trails as indicated in the current Forest Plan, a 

combination of designated routes, and open faces and closed faces on some of the hills is 

described under Alternatives A, C, and D. Closed faces will have no OHV travel and 

open faces will have drive anywhere opportunities. Designated routes will be provided to 

ensure access to areas affected by closed slopes. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

85 

Roads within the OHV area influence parking and camping opportunities and dispersal of 

use. Currently, camping is focused along improved roads causing heavy use in proximity 

to the improved roads. Under Alternatives A, C, and D, roads are improved that lead into 

the center of the OHV area and through traffic is eliminated between the Highway 89 

entrance and FR545.46 Camping and sanitation facilities will be installed as appropriate 

along improved roads. Implementation of future projects related to these guidelines will 

create better dispersal of riders, maintain or enhance the riding experience and lessen 

impacts in sensitive locations. Implementing future projects based on direction in 

Alternatives A, C, and D, help alleviate visual, noise, and dust as send from the 

Monument overlook, and commuter/user safety concerns on FR 776. 

This geologic area is tied to the Sunset Crater Volcano story. It is visible, in general, as a 

line of red cinders that extends from Sunset Crater to the Double Crater area, and 

includes Gyp Crater. Gyp Crater itself is a deep hole with dangerous rocks and cliffs. In 

addition to being a significant geologic feature, it is too dangerous for OHV riding. 

Forest Plan text changes, and the Cinder Hills Implementation Schedule outline specific 

actions to help protect these features. 

Common to all restricted slopes will be rehabilitation of major routes and ruts, as funding 

becomes available. Also, an additional criterion to pursue and develop is establishment 

of "no wake zones" where motors are kept quieter, (no engine revving) and speed is kept 

slow, using signs, information, and honor system. This avenue could be pursued in place 

of closing highly valued routes, as the Forest Service works with the OHV users on 

rehabilitation areas. 

NATIONAL MONUMENTS 

There are three National Monuments in or adjacent to the FLEA area managed by the 

National Park Service (NPS). This affected environment description is based on 

information in the three Draft Environmental Impact Statements for the General 

Management Plans of each Monument, published in September 2001. Additional details 

about each of the Monuments can be found in these documents. 

Like many things, concerns about Monument resources have been more about 

implementation of the current Forest Plan rather than changes to that Plan. However, the 

discussions that follow focus on how the Alternatives are different from the current 

Forest Plan (Alternative B). 

The following effects discussion focuses on these topics: 

• Visual Quality – what a visitor to the monument may see in the surrounding 

viewshed 

• Noise – what a visitor to the monument may hear in the surrounding area 

 

46 Through traffic is decreased by closing the intersection of FR 776 and FR 545. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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• Resources – wildlife, watershed, archaeological resources to name a few 

• Fire – potential for high intensity crown fire 

• Incursions47 – Instances of trespass into Monument lands outside of established 

Monument roads, trail and hours of operation. 

The MA boundaries were drawn in part due to the location of the Monuments. Each MA 

lists activities where there should be NPS and FS coordination. 

Walnut Canyon National Monument 

Walnut Canyon is approximately 3,600 acres.48 The park purpose is to protect ancient 

cliff dwellings and associated resources that are of great ethnographic, scientific, and 

educational interest and to properly care for and manage the cultural and natural 

resources of historic, social, and scientific interest within Walnut Canyon National 

Monument. Items related to the Monument’s significance include: 1) concentrations of 

ancestral Puebloan habitations are found and the distribution, diversity, and location of 

sites are unusual and include the only cliff dwelling architecture of the Northern Sinagua 

culture, 2) natural and cultural resources within the monument are known to be 

significant to contemporary native tribes, 3) ecological communities overlap to form 

ecotones bringing together species usually separated by elevation, and creating a rare 

compression of flora/fauna zones, 4) topographic relief and biotic diversity make the 

canyon an outstanding scenic resource, 5) Walnut Canyon was one of the first 

archeological areas to be heavily visited (Draft EIS Draft General Management Plan 

Walnut Canyon National Monument, AZ, September 2001) 

Implementing future projects based on the proposed guidelines will not result in 

dramatically different visual quality when compared to current Forest Plan direction. 

Current direction calls for a Visual Quality Objective of Retention along the entrance 

road. As with all National Forest lands, short-term visual impacts may occur as a result 

of activities such as thinning or broadcast burning, however long-term trends maintain 

visual quality. Projects immediately adjacent and within the viewshed of the Monument 

will be coordinated with NPS personnel to limit impacts. 

Some illegal incursions into the Monument may occur under any alternative, because 

they are difficult to completely prevent. However, implementation of trail management 

strategies around urban areas will trend towards use on planned Forest System trails and 

lessen impacts from social trail use over time. Forest Service trails currently in place 

help direct people along routes that discourage nonmotorized incursions in the Monument 

from the Fisher Point area. An example is the Arizona Trail that currently exists on the 

west side of the Monument. Under Alternatives A, C, and D, 47 percent of the Walnut 

Canyon National Monument boundary is adjacent to a SPNM ROS setting, 47 percent is 

adjacent to a SPM ROS setting and 12 percent is adjacent to a RN setting. These ROS 

objectives increase the area of SPM and SPNM adjacent to the Monument, when 

 

47 Incursions have occurred on foot, horse, bike, motorcycle, ATV, or vehicle, and by helicopter. 

48 Acreage figure from the DEIS for the General Management Plan, the outcome of ownership discussions 

about the entrance road may change this figure. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

87 

compared to the current inventory. The current inventory shows zero percent SPNM 

adjacent to the boundary, although some actual road closures immediately adjacent to the 

Monument have been completed. 

Strips of ROS objectives do not conform well to the intent of ROS objectives as a 

landscape scale expression of desired conditions. Within SPM area, site-specific projects 

could close individual roads adjacent to the boundary as appropriate. 

Impacts from noise are not likely to be different by alternative. Noise in this area is a 

result of the occasional vehicle passing close by the Monument. This discussion of ROS 

settings and roads management above applies. 

Alternative A gives managers increased flexibility to lessen potential for high intensity 

wildfire within the FMAZ 1U that lies north and west of the Monument. The risk of 

ignition in lands surrounding the Monument will be lessened as a result of camping 

management changes, and as road closures and open road maintenance are implemented. 

As the Forest Plan is implemented in ponderosa pine lands the resulting future forest 

conditions are similar between alternatives (northern goshawk and Mexican spotted owl 

guidelines). Northern goshawk guidelines provide for less potential for high intensity 

crown fire when compared to current conditions. Mexican spotted owl habitat in the 

canyon and along the rim will continue to have high fire potential, because this species 

thrives in thick, multi-layered forests. 

The increase in Primitive and SPNM settings within Mexican spotted owl habitat will 

improve habitat conditions, as this desired condition is implemented. FLEA management 

direction does not change water flows (or the lack of flow) from Lake Mary. Air quality 

may receive short-term impacts from broadcast burning, but these impacts are not likely 

to be different by alternative. Although there are instances of site-specific soil erosion in 

lands surrounding the Monument, erosion is limited and sediment is not expected to 

move off-site as projects are implemented under any of the action alternatives. 

Continuation of cooperative efforts to limit spread of invasive noxious weeds occurs 

under all alternatives. Wildlife cover adjacent to the Monument and along the rim of 

Walnut Canyon for big game such as turkey and elk is maintained under all alternatives. 

Sunset Crater Volcano National Monument

The purpose of the Monument is to preserve and protect Sunset Crater Volcano National 

Monument’s geological formations, features, and resources for scientific interests and 

research, and for public interest, including scenic, educational, and recreation pursuits. 

Items related to the Monument’s significance includes: 1) Sunset Crater Volcano is the 

Colorado Plateau’s most recent eruption of the San Francisco Peaks Volcanic Field and 

one of the longest-lived cinder cone volcanoes known in historic time; 2) The volcanic 

eruption left a unique archeological and ethnographic record of human adaptation, 

response, and recovery to volcanic eruption and Sunset Crater Volcano and its natural 

resources continue to have cultural significance to contemporary native tribes; 3) The 

Monument’s volcanic features are seen now with few human disturbances and provide 

excellent opportunities for science, education, and interpretation, including insight into 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

88 

plate tectonics, ongoing geologic and ecological processes, and a larger view of how this 

area is important in the context of southwester US and world geology; 4) The 

microhabitat and climate of Sunset Crater Volcano create an unusual species mix, 

including lichens, molds, and endemic species that are highly visible examples of the 

scientific concepts of succession and adaptation (Draft EIS Draft General Management 

Plan, Sunset Crater Volcano National Monument, Arizona, September 2001). 

Some of the results of the FLEA planning effort have been an identification of those 

areas where current Forest Plan direction was adequate, but where some ongoing 

activities were not meeting the intent of the Forest Plan. An example is the current 

Forest Plan guideline for a Visual Quality Objective of Retention along the paved FR 

545 Sunset-Wupatki Road. OHV use was occurring within the Retention area, detracting 

from visual quality as seen from the road. Better identification of OHV riding boundaries 

is needed. Implementation of this and other current Forest Plan direction has and will 

continue to occur in the lands surrounding the Monument. As with all National Forest 

lands, short-term visual impacts may occur as a result of activities such as thinning or 

broadcast burning, however long-term trends maintain visual quality. Projects 

immediately adjacent and within the viewshed of the Monument will be coordinated with 

NPS personnel to limit impacts. 

Some illegal incursions into the Monument may occur under any alternative, because is it 

difficult to limit them completely. All action alternatives decrease the potential for illegal 

incursions because of changes to management of the Cinder Hills OHV area. Increased 

signing, changes in maintained roads, and camping locations all lead to trends of 

decreasing riding immediately adjacent to the Monument, and increasing riding more to 

the interior of the area. In addition, if future projects were implemented according to 

FLEA direction for the O’Leary Group Campground area, trails would be located to give 

people a place to hike outside of the Monument. 

Under Alternatives A, C, and D, approximately 33 percent of the Sunset Crater Volcano 

NM boundary is adjacent to SPNM ROS settings. Approximately 28 percent of the 

boundary is adjacent to SPM setting. A RN corridor surrounds the paved FR 545, 

covering the remaining 39 percent. 

Noise is reduced somewhat as projects are implemented under the action alternatives. 

This is because of changes to camping locations and slope closures for some of the area 

visible from the overlook. On busy summer weekends, noise from OHV use will still be 

heard within some Monument areas. There is continued presence of noise from the 

campgrounds and the paved Sunset-Wupatki Scenic Loop Drive. 

Wupatki National Monument 

Wupatki National Monument was established as a two-piece area to preserve 

archeological resources. The purpose is to preserve, protect, and manage the ancestral 

Hopi sites, other prehistoric remains, and cultural and natural resources of historic, 

ethnographic, and scientific interest located within Wupatki National Monument. Items 

related to the parks significance include: 1) Wupatki is the only known location in the 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

89 

Southwest where physical evidence from at least three archeologically separate ancestral 

Puebloan cultures is found together in a number of archaeological sites. According to 

Puebloan oral tradition, Wupatki represents one ancestral Puebloan group; 2) The natural 

and cultural resources within the monument are known to be significant to contemporary 

native tribes, as evidenced by oral history and continuing practices and the archeological 

record; 3) Many sites are well preserved and have a high degree of cultural resource 

integrity; 4) Historic material reveals a rich record of human endeavor left by Navajo 

families over a period of 150 years and continuing through the present day and by 

ranchers, sheepherders, prospectors, Mormons, the Civilian Conservation Corps, park 

custodians, and the Museum of Northern Arizona. Their activities, combined with 

environmental changes, have created a complex cultural landscapes within the 

monument; 5) Wupatki protects one of the few native grasslands in the Southwest that is 

not being domestically grazed, and its integrity is essential to perpetuating a native 

species and natural ecosystem processes; 6) The setting of Wupatki, undeveloped and 

largely unpolluted, provides the exceedingly rare opportunity to see more than 60 miles, 

view the night sky and encounter quiet-and experience comparable to that experienced by 

prehistoric peoples. These qualities are a baseline against which change can be 

monitored, managed, and mitigated. (Draft EIS Draft General Management Plan Wupatki 

National Monument, AZ, September 2001). 

Incursions may occur into the monument from either motorized or nonmotorized means 

regardless of the alternative chosen. However, numbers of people are relatively low at 

present, and implementation of ROS settings under Alternatives A, C and D lessens the 

overall number of roads in lands immediately adjacent to Wupatki. Under Alternative A, 

approximately 65 percent of the Wupatki NM boundary is adjacent to SPM ROS settings 

and 35 percent of the boundary is adjacent to RN settings. This is because of the paved 

FR 545 that crosses in and out of the Monument along the boundary. These ROS 

objectives increase the area of SPM adjacent to the Monument, when compared to the 

current inventory. A narrow strip of SPNM adjacent to the Monument was considered, 

but not carried forward. Strips of ROS objectives do not conform well to the intent of 

ROS objectives as a landscape scale expression of desired conditions. Within SPM areas, 

future site-specific projects could close individual roads adjacent to the boundary as 

appropriate. Past discussions with NPS personnel have been recorded in the Roads 

Analysis Report for the FLEA Area’s data table. 

Noise is very minimal on National Forest lands adjacent to the Monument boundary. 

As with all National Forest lands, short-term visual impacts may occur as a result of 

activities such as tree cutting or broadcast burning, however long-term trends maintain 

visual quality. Future projects immediately adjacent to and within the viewshed of the 

Monument will be coordinated with National Park personnel to limit impacts. 

All alternatives, including Alternative B, provide emphasis on maintaining grassland 

habitat (current Forest Plan direction). All alternatives continue current Forest Plan

direction that permits activities such as broadcast burning and tree removal to promote 

grasslands. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 3 - Affected Environment and Environmental Consequences

90 
91 

 

CHAPTER 4 - CONSULTATION AND 

COORDINATION 

Preparers and Contributors 

The Forest Service consulted the following individuals, Federal, state and local agencies, 

tribes and non-Forest Service persons during the development of this environmental 

impact statement:

Table 13 ID Team Members and Experience 

Name Position / Organization Contribution Education 

Relevant 

Years of 

Experience 

Beard, James Forest Landscape Architect 

Coconino National Forest (NF) 

ROS and Visual 

Scenery 

Management 

B.S Landscape 

Architect 27 

Brown, Alvin 

Environmental Coordinator Peaks 

and Mormon Lake RDs 

Coconino NF 

Staff and NEPA 

Consultation B.S. Forestry 26 

Denton, Lori 

Recreation Forester 

Peaks and Mormon Lake RDs 

Coconino NF 

Recreation B.S. Recreation 

Management 11 

Geesey, 

Brenda 

GIS Coordinator, Peaks and 

Mormon Lake RDs 

Coconino NF 

Spatial Analysis 

Maps 

B.S. Natural 

Resources 

M.S. Forestry 

12 

Hink, Jeff 

Soil and Water Specialist, Peaks 

and Mormon Lake RDs 

Coconino NF 

Soil/Water 

Analysis 

B.S. Natural 

Resource 

Management 

26 

Kill, Debbie NEPA Coordinator Peaks RD 

Coconino NF NEPA Analysis B.S. Forestry 12 

RandallParker, Tammy 

Wildlife Biologist Environmental 

Coordination Group 

Peaks and Mormon Lake RDs 

Coconino NF 

IDT Leader 

Wildlife Biologist 

B.S. Biology 

B.S. Zoology 15 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 4 – Consultation and Coordination

92 

Name Position / Organization Contribution Education 

Relevant 

Years of 

Experience 

Stahn, Richard 

Silviculturist 

Mormon Lake RD 

Coconino NF 

Silviculture 

B.S. 

Forestry/Watershed 

Management 

27 

Thornton, 

Bruce 

Center Fuels Specialist Peaks and 

Mormon Lake RDs 

Coconino NF 

Fuels and Fire 

Behavior /Air 

Quality/Smoke 

B.S.B.A. Fire 

Behavior Analysis 

Graduate of 

Prescribed Fire 

Management 

27 

Farr, Katherine Forest Planner 

Coconino NF Forest Planning BS Forest Management 28 

Federal, State, And Local Agencies: 

Rick Miller, Bob Barsch and Lee Ludeker of the Arizona Game and Fish Department 

Michele James and Shaula Hedwall of the US Fish and Wildlife Service 

Al Hendricks of the Arizona State Land Department 

Ursula Montano of the City of Flagstaff – Community Development 

Bill Towler of the Coconino County – Community Development 

Sam Henderson, Kim Watson, Todd Metzger, Paul Whitefield and other staff of the National 

Park Service, Flagstaff-Area Monuments. 

Distribution of the Environmental Impact Statement 

This environmental impact statement has been distributed to individuals who specifically 

requested a copy of the document or commented on the Proposed Action. In addition, 

copies have been sent to the following Federal agencies, federally recognized tribes, State 

and local governments, and organizations representing a wide range of views regarding 

recreation and forest management in the Flagstaff area. 

Arizona Department of Environmental Quality 

Arizona Game and Fish Department 

Betsy McKellar 

Brett A Navin 

Bruce Johnson 

C. James Krafft 

Chris Newell 

Christensen Elementary - John Coe 

City of Flagstaff Planning Division, City Council, and Mayor 

Coconino County Community Development and Board of Supervisors 

Coconino County Parks and Recreation 

Darling Environmental and Surveying, LTD, Mary E. Darling 

Dave and Marcia Lamkin 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 4 – Consultation and Coordination

93 

Dirch Foreman 

Ed Lange 

Forest Guardians 

Forest Guardians 

Fort McDowell Yavapai Nation 

Friends of Walnut Canyon - Ralph Baerlein 

Grand Canyon Forest Partnership – Brian Cottam 

Grand Canyon Trust - Taylor McKinnon 

Havasupai Tribe 

Hopi Tribe 

Ivo & Baerbel Lucchitta 

Jack Weiss 

John Wahl 

Marilyn Hanna 

Motorcycle Industry Council, Deborah Napier 

National Park Service Flagstaff Area Monuments 

Navajo Nation 

Norm Wallen 

Pueblo of Acoma 

Pueblo of Zuni 

Ruth Wright 

San Carlos Apache Tribe 

San Juan Southern Paiute Council 

Southwest Forest Alliance - Brian Nowicki and Brian Seqee 

State Land Department 

Steve Autry 

Steve Autry 

Susan Lamb 

Tom Bean 

Tonto Apache Tribe 

White Mtn. Apache Tribe 

Yavapai-Apache Nation 

Yavapai-Prescott Indian Tribe 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Chapter 4 – Consultation and Coordination

94 

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Hoffmeister, D. F. 1986. Mammals of Arizona. University of Arizona Press and the 

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 602 pp. 

Kearney, T.H. and R.H. Peebles. 1951. Arizona Flora. University of California Press, 

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Latta, M. J., C.J. Beardmore, and T.E. Corman. 1999. Arizona Partners in Flight Bird 

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Technical Report 142. Arizona Game and Fish Department, Phoenix, AZ. 331 pp. 

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Lee, M.E., Pierskalla, C. 1996. Sedona Red Rock Visitor Study. Northern Arizona 

University 

Lee, R.L., J.D. Yoakum, B.W. O'Gara, T.M. Pojar and R.A. Ockenfels, Eds. 1998. 

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Monson, G. 1957a. Lucy's warbler. In The warblers of America, ed. L. Griscom and A. 

Sprunt, Jr. New York: The Devin-Adair Co. 

Nagiller, Sandra. 2/2000. USDA Forest Service Region 3, Coconino National Forest, 

Peaks Ranger District. TES Species Narratives. 
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Opler, P.A. and A.B.Wright. 1999. Western Butterflies. Boston: Houghton Mifflin 

Company. 540 pp. 

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Roger Radd, Personal communication, January 30 and 31, 1998 regarding Yuma clapper 

rail habitat use at Tavasci Marsh. 

Scott, J.S. 1986. The butterflies of North America. Stanford: Stanford University Press. 

583 pp. 

Sferra, S.J., R.A. Myer and T.E. Corman. 1995. Arizona partners in flight 1994 Arizona 

Game and Fish Department southwestern willow flycatcher Report. Non-game and 

endangered wildlife program technical report, Arizona Game and Fish Department, 

Phoenix, AZ. 

Spenser, J.A., T.E. Corman, S.J. Sferra, and M. Sumner. 1996. Arizona Partners in 

Flight 1995 southwestern willow flycatcher survey. Nongame and Endangered 

Wildlife Program Technical Report 97. Arizona Game and Fish Department, 

Phoenix, Arizona. 

Terres, J. K. 1991. The Audubon Society Encyclopedia of North American birds. New 

York, New York. Wings Books. 1109 pages. 

Todd, R.L. 1977. Black rail, little black rail, black crake, Farrallon rail (Laterallus 

jamaicensis). Pages 71-83 in G.C. Sanderson, ed. Management of Migratory Shore 

and Upland Game birds in North America. Int. Assoc. Fish and Wildl. Agencies, 

Washington, D.C. 358 pp. 

USDA Forest Service 1999. Coconino National Forest Management Indicator Species 

(updated 11/2/99). Unpublished report. Region 3. 5 pp. 

USDA Forest Service 1986. 1986 ROS Book. 

USDA Forest Service. 1987. Coconino National Forest Land and Resource Management 

Plan. 

USDA Forest Service. 1992. Forest Landscape Analysis and Design. Pacific Northwest 

Region. R6 ECO-TP-043-92 

USDA Forest Service, Coconino, Kaibab and Prescott National Forests. 1998. Noxious 

Weeds Strategic Plan Working Guidelines Coconino, Kaibab and Prescott National 

Forests. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Chapter 4 – Consultation and Coordination

97 

USDA Forest Service. 1996. Final Environmental Impact Statement For Amendment of 

Forest Plans, Amendment of Forest Plans Forest Service – Southwestern Region 

Arizona and New Mexico. Note: Replacement pages to Coconino Forest Plan 

completed in 1996. 

USDI. 1982. United Stated Department of the Interior, United States Fish and Wildlife 

Service. Southwestern Bald Eagle Recovery Plan. 74 pages. 

USDI. 1993. Functions and values of the Verde River riparian ecosystem and an 

assessment of adverse impacts to these resources. A supporting document of the 

initiation of the Verde River advance identification. Prepared by U.S. Fish and 

Wildlife Service for the U.S. Environmental Protection Agency, Region 9. 364 pp. 

USDI. 1993b. Fish and Wildlife Service. Proposed Rule to List the Southwestern 

Willow Flycatcher as Endangered with Critical Habitat. July 23, 1993. Federal 

Register 58, No. 140, pp. 39495-39522. 

USDI. 1996. United States Fish and Wildlife Service. Description and Assessment of 

Operations, Maintenance, and Sensitive Species of the Lower Colorado River. 

Prepared by U.S. Bureau of Reclamation, Lower Colorado Region for the USFWS 

and Lower Colorado River Multi-Species Conservation Program. 

USDI. 1999a. Fish and Wildlife Service. Final rule to remove the American Peregrine 

Falcon from the Federal List of Endangered and Threatened Wildlife, and to remove 

the similarity of Appearance Provision for Free-Flying Peregrines in the 

conterminous United States. August 25, 1999. Federal Register 64, No. 164, pp. 

46542 – 440875. 

USDI. 1999b. Fish and Wildlife Service. Proposed designation of critical habitat for the 

spikedace and the loachminnow. Proposed Rule. December 10, 1999. Federal 

Register 64, No. 237, pp. 69324 – 69355. 

USDI September 2001 National Park Service. Draft Environmental Impact Statement 

Draft General Management Plan Walnut Canyon National Monument Arizona 

USDI September 2001 National Park Service. Draft Environmental Impact Statement 

Draft General Management Plan Sunset Crater Volcano National Monument Arizona 

USDI September 2001 National Park Service. Draft Environmental Impact Statement 

Draft General Management Plan Wupatki National Monument Arizona 

Wallesz, Dave. 1999. Distribution of sensitive insects in Arizona. Unpublished report. 

USDA Forest Service, Region 3, Arizona Zone Entomology and Pathology. Prepared 

for Coconino National Forest, Sept. 10, 1999. 5pp. 
98 

Index 

A1 Mountain, 6, 20, 23, 26, 27, 33, 35, 36, 

53 

Abert Squirrel, 33, 34 

air sheds, 71 

American Peregrine Falcon, 56 

Area Closures, 80 

Arizona Bugbane, 57 

Arizona Sneezeweed, 57 

Bald Eagle, 12, 30, 53, 94 

Best Management Practices, 65 

Black-Footed Ferret, 54 

Blue-black Silverspot Butterfly, 56 

Campgrounds, 76 

Camping, 8, 21, 28, 75 

Cinder Hills OHV Area, 13, 31, 83, 84 

Cliff Fleabane, 57 

Cordilleran Flycatcher, 64 

Cover, 11, 22, 25, 32, 33 

Cultural Sites, 12 

Deadman Wash, 83 

Deer, 49 

Designated Campsites, 76 

Doney Park, 5 

Dry Lake Hills, 5, 34, 76 

Early Elfin, 57 

Ecosystem Analysis, 4 

Elk, 33, 34, 44, 49 

Environmental Study Area, 14 

Environmental Study Areas, 31 

Ferruginous Hawk, 64 

Fire, 11 

Fire Hazard, 33, 38, 68 

Fire Management Analysis Zone, 33, 69, 

70 

Fire Risk, 6, 33, 68 

Fisher Point, 40 

Flagstaff, 5 

Flagstaff Pennyroyal, 58 

Flagstaff Penstemon, 58 

Flagstaff Public Schools, 83 

Forest Highlands, 5 

Freeman’s agave borer, 57 

Griffiths Spring, 83 

Group Use, 9, 29 

Growth Boundary, 14 

Gyp Crater, 84 

High-Clearance Vehicle, 43 

Highway 89A, 76 

Hydrologic Function, 66 

Ideas for Change, 4 

Kachina Village, 5, 32, 34 

Lake Mary, 9, 28, 66 

Lake Mary Road, 5, 39 

Lake Mary watershed, 5, 14 

Lake Mary Watershed, 65, 83 

Location, 5 

MacGillivray’s Warbler, 64 

Management Areas, 13, 17, 31, 46, 82 

Marshall Lake, 9, 28, 66 

Mexican Spotted Owl, 11, 21, 30, 39, 44, 

51 

Motocross, 10, 66 

Motorized access, 73 

Mountain Silverspot Butterfly, 56 

Mountainaire, 5 

Mt. Elden, 5, 14, 74, 76 

Mule Deer, 33, 34 

National Monuments, 12, 31, 48, 126, 135 

National Park Service, 12, 19, 91, 95, 132 

Natural Settings, 72 

Navajo Mountain Mexican vole, 55 

NEPA Process, 3 

Northern Goshawk, 11, 30, 56 

Northern Goshawk Guidelines, 67 

Northern Leopard Frog, 57 

Noxious Weeds, 68 

Oak Creek Canyon, 14, 75 

Oak Creek Watershed, 65 

Old Caves Crater, 83 

Olive-Sided Flycatcher, 64 

Outfitter/Guides, 9, 29 

Parking, 14, 31 

Passenger Car, 74 

Passenger Car Roads, 49 
99 

Prescribed Burning, 69 

Primitive, 7, 47 

Proposed Action, 4, 14 

Public/Private Boundary, 79 

Pumphouse Wash, 6, 9, 28, 51, 57, 66, 151 

Purple Martin, 64 

Recreation Budgets, 81 

Recreation Opportunity Spectrum, 7, 18, 

28, 35, 46, 71 

Recreation Setting, 42 

Red-Faced Warbler, 64 

Residential Areas, 6, 42, 78 

Road Densities, 73 

Roaded Natural, 8, 47 

Roads, 10, 19, 30, 43, 73 

Rock Climbing, 9, 29, 77 

Rural, 47 

Rusby’s Milkvetch, 58 

San Francisco Mountain, 23, 51 

San Francisco volcanic field, 6 

Scenery, 81 

Semiprimitive Motorized, 7, 19, 47 

Semiprimitive Nonmotorized, 1, 7, 47, 72 

Skunk/Fay Canyons, 23, 26, 38, 40 

Smoke, 69 

Solitude, 72 

Suitable Forest Land, 67 

Sunset Crater Beardtongue, 58 

Sunset Crater Volcano, 84 

Sunset Crater Volcano National 

Monument, 5, 87 

Swainson’s Hawk, 64 

target threshold habitat, 52 

Timber Component, 67 

Trails, 9, 29, 78 

Turkey, 33, 44, 50 

U/RIZ, 32, 67, 69, 70, 78 

Urban, 47 

Urban/Rural Influence Zone, 28, 69 

User-Created (Social) Trails, 6, 10, 80 

Walnut Canyon, 6, 9, 16, 19, 22, 27, 28, 

33, 38, 51, 58, 66, 82, 83, 85, 86, 87, 95, 

108, 131, 155, 156 

Walnut Canyon National Monument, 85 

Waterline Road Area, 23, 26, 41 

Watershed, 14, 31, 66 

Wilderness, 73 

Wildfire, 69 

Wildlife Travelway, 12, 30 

Wildlife Viewing, 74 

Woody Ridge, 6, 22, 33, 34, 51 

Wupatki Arizona Pocket Mouse, 56 

Wupatki National Monument, 5, 88 
100 
101 

APPENDIX A Forest Plan New and 

Replacement Pages 

This appendix contains the Forest Plan pages that were originally published as part of the 

Proposed Action with slight adjustments for clarification or minor changes. The deleted 

text has a horizontal strike through and the new text is underlined. In addition, there is a 

vertical line on the outside margin, which will allow you to distinguish the headings that 

are underlined from the changes that are underlined. We tried to keep track of all 

changes that were made in response to your comments since these pages were published 

as part of the Proposed Action. However, it is possible that some typographical errors 

have been corrected and do not show as strikethroughs with the underlined corrections. It 

was not our intention to hide these, rather they are merely oversights during the editing 

process. 

The page numbers for this appendix reflect the approximate page numbers (location) in 

the Forest Plan. They are distinguished as either new pages or replacement pages. The 

numbering convention of the original Forest Plan from 1987 has been maintained, 

meaning that Chapter 4 still starts with page 21. If additional pages are required between 

pages 180 and 181, they are numbered as 180-1, 180-2, and so forth. Some of the 

Management Areas direction is on replacement pages and some are on new pages, hence 

the numbering convention you will find. When the Forest Plan revision has been 

completed, all of the page numbering will be refreshed. 
102 
103 

Map Urban rural influence zone – alternatives a, c, d, 
104 

Map Objective for recreation opportunity spectrum alt A a
105 

Map Objectives for recreation opp strum alt c 
106 

Map Objectives for recretion opp spectrum alt d 
107 

Map Objectives for camping alt a c and d 
108 

Map Fire management analysis zone 1u
109 

Map Management areas alternatives a, c, and d
110 
111 

APPENDIX B Comment Analysis and 

Response to Comments 

The Forest Service received a variety of comments during the fall of 2001 and early 2002 

in response to the Proposed Action (10/2001). Staffs have summarized the substantial 

comments and have numbered them in order of receipt. The responses were analyzed 

according to a series of filters. First, a determination was made as to whether or not a 

comment represented an issue as defined as a point of disagreement or debate with this 

Proposed Action (PA) based on some anticipated effect. A question is not normally an 

issue. Secondly, potential issues are screened to identify which ones are significant and 

require to the proposed action to be created and analyzed (40 CFR 1501(b)). Significant 

issues are those that meet all of the following criteria: 

• Within the scope of the analysis (directly related to the Proposed Action); 

• Not decided by law, regulation, or policy; 

• Related to the decision; 

• Amenable to scientific analysis rather than conjecture; 

• Not Limited in extent, duration, nor intensity; and 

• Not a point of clarification only 

In this document the interdisciplinary team has responded to all comments, whether or 

not they were significant issues. 

Comments #1-6 from Steve Autry 

#1 Keep Skunk/Fay Canyon closed to motor vehicles. Need to redo map to show it 

closed. 

Response: NonIssue Comment – The reason or effect that is of concern is not described. 

There is no change to motorized closure in this area proposed. See Comment #20 for 

more explanation of ROS in this area. 

#2 Also no timber sales in Walnut Canyon area. 

Response: NonIssue Comment - The reason or effect that is of concern is not described. 

The PA49 does not specifically propose timber sales. See Comments #57 and #68 for 

more discussion about suitability for timber production. 

#3 Close ghost roads in all of the National Forest 

Response: NonIssue Comment - reason (effect) is not described 

This analysis only covers the FLEA area not the whole forest. However, on page 27 of 

the PA there is a list of criteria for closing roads that would apply to user-created (ghost) 

roads. One of the criteria is a redundant road. In addition, the PA proposes that the 

Roads Analysis Report be reviewed and that roads not identified as part of the desired 

 

49 PA is the acronym for Proposed Action 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

112 

open road network be considered for closure. Site-specific analysis and public 

involvement would occur prior to closure. 

#4 Protection for Walnut Canyon 

Response: NonIssue Question – There is no disagreement with PA and the type of 

protection is not described. 

See Comment #8 

#5 Change ROS in Skunk/Fay Canyon area to SPNM. 

Response: Nonsignificant Issue – no reason or anticipated effect is given. 

See Comments #20 and #54 

#6 Continue to work in the understory of the forest and don't cut large trees 

Response: NonIssue Comment - because reason (effect) not described. 

Given current conditions in the FLEA area, forest thinning will focus on the understory in 

most cases. 

#7 Internal comment resolved and deleted 

Comment #8 from Brett A. Navin 

#8 I am writing to share my opinion on the Walnut Canyon Recreation Area on the 

Coconino National Forest near Flagstaff. I live in Ohio now, but lived in Flagstaff for 

eight years and hope to return again. Flagstaff is unique, as you know, and I vote for 

protecting the resources which make it unique. If you have any influence in this, I hope 

you’ll do your best to preserve and conserve the land. If you’ve ever been east, you know 

that much of the land has been destroyed by our need for natural resources. It’s time we 

learned how to use resources wisely rather than willy-nilly. Protection of the forest and 

of the land itself will promote healthy ecosystems which promote healthy humans. 

Protecting the forest around Flagstaff is valuable because it will provide educational 

opportunities for other communities to see how Flagstaff has learned form the mistakes 

of the past to make the world a better place. Thank you for your time. 

Response: NonIssue Comment – Comment not specific to the PA, nor is there an 

expression of disagreement with the PA. 

The comment uses words such as preserve and conserve and protection. These words 

mean different things to different people; however, they all depict a sense of concern and 

value for the Walnut Canyon area and lands around Flagstaff. The FLEA proposal 

represents a course correction, not a major change in land use, and therefore the area 

continues to be conserved as a generally undeveloped natural landscape. FLEA 

recognizes the values people hold for this particular portion of the landscape and we have 

adjusted the Walnut Canyon Management Area boundary accordingly. There are 

differences of opinion among various agencies and interest groups about the specific 

details of land management for this MA. These debates will likely continue. However, 

the desired condition is to maintain ecological processes and there is also an emphasis to 

keep these lands in public ownership. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

113 

Comment #9 from Ed Lange 

#9 The text does not discuss rationale for rescinding order 04-150 for the most of the 

areas. This matter was given careful consideration in the past and the FS has not 

changed its policy with no discussion. This is poor public policy. 

Response: NonIssue Comment because reason (effect) is not described. 

There is no change proposed to the current motorized closure. See comment #20 and 54. 

Comment #10 from Jack Weiss 

#10 I would like to provide my input into the Lake Mary Ecosystem area. As a Flag 

resident, I enjoy hiking and biking in the Skunk Canyon areas and would like to se it 

remain closed to motorized vehicles. Thank you. 

Response: NonIssue Comment 

There is no change proposed to the current motorized closure. See comment #20 and 

#54. 

Comments #11-13 from Steve Autry 

#11 Close FS Rd 522, 151, 794 after big snows so we can cross-country ski in peace. 

People drive their 4x4’s down these roads even after large storms. Most of last winter 

after huge storm you had gate open on FS RD 522. 

Response: NonIssue Comment because this is not specifically related to the PA. 

Two of these roads are not in the FLEA area and specific gating of roads is outside the 

scope of this Forest Plan amendment. However, this suggestion has been forwarded to 

District engineer who is responsible for implementing wet weather closures. 

#12 Also, people ride snowmobiles in wilderness areas all over the Peaks. You have no 

enforcement of the laws. 

Response: NonIssue Comment – Outside of the scope of the FLEA analysis. 

This comment has been forwarded to District Law Enforcement and Recreation staff. 

#13 Consider leaving some large timber on ground after thinning to slow down cross 

county travel 

Response: NonIssue Comment – Outside the scope of the FLEA analysis. 

This is an interesting suggestion for an implementation technique - this suggestion will be 

forwarded to District Staff. 

Comment #14 from Norm Wallen 

#14 I have concerns related to p31, section on Land Exchange. I was a member of the 

task force that produced, after much hard work, the Greater Flagstaff Open space and 

Greenways Plan. I was a member of the City Council which, along with the County 

Board of Supervisors, approved the recommendations as part of City policy. At the time, 

it was understood that agencies, including the Forest Service, could not enter into 

agreements that might conflict with agency policies. However, I believe it was agreed, as 

reflected in a Memorandum of Understanding, that Forest Service, could would, prior to 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

114 

placing into the base for exchange any propertied identified in the Plan as high priority 

for preservation, consult with the other partners to the OSG Plan. I think this should be 

stated in the proposed amendment. The highlighted statement that land to considered for 

exchange includes land within locally approved growth management boundaries appears 

to contradict this agreement. It was also my understanding that there were to be no 

properties so identified as high priority within the scope of OSG that were currently in 

the base for exchange. I would appreciate knowing whether this is the case . 

Nonsignificant Issue – Clarification. 

Response: We have made some management direction clarifications in the Forest Plan 

replacement pages, Appendix A, pages 16, 22, 59, and 62. It was not our intent to bypass 

any reviews by other agencies or government entities. We are not relying on the basefor-exchange map but placing more emphasis on the criteria and the maps in the Open 

Spaces and Greenways Plan (OS&G Plan) and the Regional Land Use and 

Transportation Plan (RLUTP) to aid in identifying how appropriate a proposal is to go 

forward with the NEPA analysis and pubic involvement. Therefore when someone 

comes to the Forest Service with a land adjustment proposal, the proposal will be 

evaluated against the criteria and the local governments’ plans. In addition, if the 

proposal makes it through our screening, then the City and County will be consulted. 

This consultation is not dependent on the OS&G Plan classification. 

Comment #15 from Susan Lamb and Tom Bean 

#15 We think it is important to clarify which roads are open and which are closed. There 

is a road that runs along the divide between Skunk and Fay canyons that has become a 

big problem. It is in frequent use regardless of the weather and has developed deep ruts 

and consequently, lots of ‘user-generated’ bypasses. On many evenings, especially warm 

summer nights or weekends, drinking parties are held along that road, complete with 

bonfires. Often, we can hear the noise from these parties until after midnight. Sometimes 

we report the parties, especially when we can hear women screaming, but it is not always 

possible for the police/Forest Service to respond (maybe because it is unclear from our 

groggy description just where the party is or because there is a jurisdictional problem or 

because the enforcement folks are so busy that night). We go out the following mornings 

and pick up the bottles, plastic cups, and cigarette butts. We check to be sure that the 

bonfires are out, and usually they are. We believe that there is a great danger of fire 

spreading into the forest from these frequent bonfires. IT worries us that there is so 

much screaming, and we feel that these parties are note in keeping with the intended use 

of our public lands. We also feel that the road is spreading out into the surrounding 

woods and introducing more and more invasive weeds. And because access to other 

party spots in the area has been reduced over the past year or so, the problem continues 

to worsen in the ridge between Fay and Skunk Canyons. In conclusion, we believe that 

the closure of this road is imperative. IF it is needed for access by authorities, perhaps it 

could be restricted with the use of a gate. Thanks for you attention on this, Debbie! 

Thanks for you reply, the road in question is shown on the newest Forest Service map. It 

is Road 720. The problem area lies beyond the site where they drilled for water a few 

years ago (they were unsuccessful and capped the well). The drill site sort of looks like 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

115 

the end of the road, but 720 actually continues to the right, past the drilling area, up and 

along the ridge between Fay and Skunk. 

Response: NonSignificant Issue – Outside the Scope of FLEA analysis. 

Specific road closures are not part of this Forest Plan Amendment. However, 

Alternatives C and D provide different ROS settings for the general area that could affect 

the future of this road. Future decision makers need to consider whether to close the 

road, or leave it open and perhaps provide more formalized trailhead facility and trails at 

the end of the road. In addition, this comment has been forwarded to the Mormon Lake 

District Ranger and appropriate staff for their consideration. 

Comment #16 from John Wahl 

#16 I’m writing to comment on proposed forest plan revisions which would affect the 

Walnut Canyon Recreation Area. Over the years I have frequently hiked, first from the 

bend on Lone Tree and more recently from the Rio Bridge on Lone Tree, to Fisher Point 

and beyond, often on to Marshall Lake suing the AZ Trail. Occasionally I go through 

lower Skunk Canyon on shorter hikes. Whatever the route or distance, I highly values the 

absence of motorized vehicles, although I see signs of their having trespassed now and 

then. It is of the utmost importance to continue the total ban on motors, including 

snowmobiles, over the entire area. It seems the FS is trying to deny the existence of 

WCRA, even to the point of considering logging some of the area. This area is a very 

important resource for hikers, bicyclists, runners, equestrians, and cross-country! 

skiers/snowshoers. I’m able to utilize the area without having to drive at all, and I would 

imagine that many others share that freedom; having these lands available so close to 

Flagstaff proper is among other things, a traffic reducer. Please construct FLEA so as to 

preserve the WCRA in its entirety, with a continued ban on all motorized use. 

Response: NonIssue Comment – The reason or effect that is of concern is not described. 

However, under the PA there is no change to motorized closure in Skunk/Fay Canyon 

areas. This comment requests that the current motorized closure areas in and around 

Walnut Canyon be maintained. The FLEA PA does not suggest changing these orders. 

Comment #17 from Ivo Lucchitta 

#17 I am concerned with the assignment of a small area in the West Management Area. 

north of A-1 Mountain, and specifically between the pipeline and Fort Valley, to the 

Semi-Primitive Motorized, and Campfires/Camping categories. Assigning this area thus 

rather than to the Semi-Primitive Non-Motorized, No Camping/No Campfires categories 

bring little advantage to anyone, and considerable disadvantages to many. 

Fire: According to your own statements, areas within 1⁄2 mile of private land have a high 

risk of fire ignition and have the highest priority for fire risk reduction. This is even more 

pressing when the private land contains dwellings, as it he case here. Furthermore, these 

dwellings are even more vulnerable because they are down the prevailing wind from the 

forest area in question. People going for walks or horseback ride generally are less 

likely to start a fire than people traveling in a vehicle to camping. Consequently, it would 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

116 

make sense to decrease the fire danger by eliminating access by vehicles to this 11/2 by 1 

mile area. 

For the same reason, the area should be assigned to the proposed No Camping/No 

Campfires category. There are just are too many dwellings down wind. Other areas 

where people can travel in vehicles and camp are not in short supply. It is sobering to 

know that we have seen transients camps in the area. 

Wildlife: The area is used by wildlife at least as much as the area to the east that has 

been designated as a Wildlife Corridor. We routinely see elk, deer, fox, and coyote. I 

have also seen badger. My neighbor reports mountain lion. Raptors of many kinds are 

common, and we have had Bald Eagles roosting in some of the snags we leave standing 

for such purposes on our property. The attraction is the large stock tank in Fort Valley 

below. We have large elk trails that lead from the mesa in the direction of the tank, and 

deer utilize some of the dog-hair pine thickets for cover. This in turn attracts the 

predators. Many of the raptors, including the eagles, are interested in the prairie-dog 

colonies below. Eliminating vehicles and camping would have a positive impact on 

wildlife. 

Response Significant Issue – both the disagreement with the PA and the reasons are 

given. In the DEIS, Alternatives C and D are related to this issue. 

Comment #18 from Baerbel K. Lucchitta 

#18 This note is in reference to the “Proposed Action to Amend the Coconino Forest 

Plan”. I would like to bring to your attention some inconsistencies in your proposed 

action pertaining to a section of land located in your management plan “West”, north of 

Interstate 40, north of A-1 Mountain, and south of the Fort Valley residential area. Your 

plan currently classifies this section as semi-primitive motorized and open to camping 

without any restrictions. However, on p 7 of your plan summary, you state that the area 

“West”, it is particularly important to reduce the fire risk in the A-1 Mountain region, 

because it lies upwind from a large number of residential areas. You also state, that the 

A-1 Mountain region should provide more hike-in hunting opportunities and increased 

semi-primitive non-motorized travel. We have lived near the forest boundary in this area, 

and we are aware that currently there is only one motorized access to this forest area. 

Consequently, cars enter from the pipeline road (the access) and rattle around within the 

fenced region, reoccupying abandoned old logging roads, creating more ghost roads, 

and causing erosion. Also, people camp, leave trash, and shoot, unaware of the nearby 

houses. In addition, this area is part of the important wildlife corridor and home to a 

large number of wild animals. They would greatly benefit from having this section 

treated the same as A-1 mountain. In fact, I fail to understand why you exclude this small 

area from assignment to the A-1 Mountain region in the proposal. We urge you to follow 

up on your own suggestions and declare this parcel in your management plan as 

semiprimitive non-motorized, closed to camping, and part of the wildlife corridor. I 

suggest that the parcel be assigned the same classification as A-1 Mountain. Thank you 

for your attention. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

117 

Response: Significant Issue – both the disagreement with the PA and the reasons are 

given. See comment #17 above. 

Comment #19- from Taylor McKinnon, Grand Canyon Trust 

#19 Grand Canyon Trust will provide comments no later than wed the 21st

Not a comment 

Comments #20-24 from Ralph Baierlain 

#20 ROS map. Please amend the ROS map to show as Semi-primitive Non-Motorized all 

the FS land west and north of Walnut Canyon that is currently coded as Semi-Primitive 

Motorized. The reasons for this request are several. Order 04-150 closed Skunk and 

Fay canyons to motorized vehicles. The ROS map will be most informative if it shows 

closed areas as closed. Showing closure according to Exhibit A of Order 04-150 would 

leave only portions of the sections 36, 31, and 29 as SPM. The Fisher-Campbell decision 

(25 March 19921) included further road closures in that general area. So the most 

consistent approach is to show all of the land as Semi-Primitive Non-Motorized. 

Non- Response: NonSignificant Issue – 

Although both the disagreement and the reason are provided, ROS does not necessarily 

match closure order boundaries. Often closure orders are placed on easy to recognize 

boundaries for ease of enforcement. ROS designations are more general and do not 

conform to easily recognizable boundaries. On the contrary, sometimes the sights and 

sounds of a road might cause the ROS objective to Roaded Natural or Semiprimitive 

Motorized, when a physical motorized closure may come right up to the road itself. 

Although as written this is not a significant issue, issues raised in comment #134 from the 

National Park Service and other information relayed to the District Ranger during 

discussions about Walnut Canyon National Monument Expansion ideas, combined to 

form a significant issue. Therefore Alternatives C and D were developed to analyze 

different ROS settings for this Skunk/Faye Canyon area. 

#20.1 In conjunction with amending the ROS map, please change the fourth sentence on 

page 70 to read “North and west of Walnut Canyon emphasize non-motorized, daytime 

recreation activities.” I understand that the ROS map is not the same as a motorized 

open-or-closed map. Nonetheless, I remain concerned about the apparent inconsistency 

between Order 04-150 and the “Roaded Natural” strip along Lake Mary Road. Will dirt 

roads that emanate from Lake Mary Road be signed “Closed to motor vehicles”? 

Response: NonIssue – Clarification. 

The text was changed in the replacement pages for the Walnut Canyon Management 

Area, located in Appendix A, to show this clarification. 

#21 Road closure. Please close FR 128B. FR 128B lies near the eastern border of the 

Skunk and Fay Canyon closure. Because the Proposed action shows much of the land 

immediately south of Walnut Canyon as Semi-Primitive Non-motorized, I presume that 

FR 128B would have motorized closures on both its west and east sides. Hunters on 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

118 

FR128B, however, would not stay on the road. The best way to gain compliance with the 

area closures is to close the road as well. 

Response: NonIssue comment – Outside scope of the FLEA analysis. 

Specific road closures are outside the scope of the FLEA analysis. The proposed ROS 

objectives in the area could affect the future of this road, but site-specific road decisions 

are not a part of the FLEA decision. The current boundary between SPM and SPNM in 

this area was drawn based on discussions with Arizona Game and Fish Department 

personnel and Forest Service fire management personnel. There was a desire to have the 

road be a boundary between the two ROS settings, and that the road continue to provide 

fire management and hunter access in the area. Driving that may occur off of this road 

will be managed though road policy, dependent on the outcome of the current Crosscountry Use of Motorized Vehicles in Five Arizona National Forests.

#22 Order for Campbell Mesa. Please request a formal order to close Campbell Mesa 

to motorized vehicles. The mesa has been closed to vehicles for a few years, and the 

rehabilitation is coming along well. It is long since time to give the closure the legal 

status of an order. 

Response: NonIssue Comment – Outside scope. 

A specific road closure order is outside the scope of the FLEA decision - ROS objectives 

show the area nonmotorized. A separate project on the District is underway in fiscal year 

2002 that proposes to close roads, convert some roads to trails, and adopt a motorized 

closure policy for the mesa. Contact Alvin Brown for more information. 

#23 Motorized trails. Please delete the suggestion (on p. 70) that some roads be 

converted to motorized trails. The Walnut MA is best suited to non-motorized recreation 

uses. Any motorized trail imposed on the MA would interfere with the conservation goals 

of the Monument or would detract seriously from the experience of those entering the MA 

from the urban interface. 

Response: NonIssue – Clarification. 

Forest Plan page 59 in Appendix A has been adjusted to indicate the areas south and east 

of Walnut Canyon, which had been the intent. 

#24 Road reduction. I understand that the FS is currently surveying Campbell Mesa 

with the intent of ensuring that all roads that should be eliminated are indeed eliminated. 

Please extend that process to the area between FR303 and Walnut Canyon itself. Road 

abuse south of FR303 is rampant. Virtually every drainage has a road; many ridges 

have them also. The best first step would be to convert those roads to trails (by closing 

one rut of the pair). Then one could wait a few years, see which trails are not used, and 

close them, there by eliminating the previous road entirely. Of course a very few roads 

should be maintained as two-track to provide access for fire trucks. Those roads should 

be gated. I am glad to see the FLEA process moving along toward completion. 

Response: NonIssue Comment – Outside the scope. 

Implementation of site-specific road closures is outside the scope of the FLEA decision. 

The District earmarks certain areas each year to conduct roadwork according to that years 

funding. This suggestion has been forwarded on to the District Staff and the District 

Ranger for their consideration in the program of work. The manner in which the District 

responds to driving off roads and the creation of new user-created (social) roads may 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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119 

change as a result of the Cross-country Use of Motorized Vehicles in Five Arizona 

National Forests. That analysis should provide consistency. The DEIS for that project 

should be out summer of 2002. Contact Jim Anderson of the Apache Sitgreaves National 

Forest at 520-333-4301 or e-mail janderson08@fs.fed.us 

Comments #25-41 from Christensen Elementary School 

The PA extends the current Mt Elden ESA to include lands behind Christensen School. 

Many of these comments talk about ‘saving’ the area (from development). Under the PA 

these lands remain National Forest regardless of the ESA extension. In general these 

comments support the idea of extending the Elden ESA to include lands behind 

Christensen School as described in the PA. These comments are a good reference for 

getting a sense of the overall values of the place. We are responding to them in a 

consolidated response at the end of comments. 

Comments #25-26 from Chris George 

#25 I am writing this letter to say that I want to keep the forest land behind Christensen 

the way that it is now. I want to keep it so the animals are not disturbed. I have seen 

deer come to the fence. If you build, all the animals may be forced to leave and they 

might not find anywhere else to stay. You could make animals become extinct in this 

area of the forest. 

#26 If you keep the forest, you should make more trails without doing much harm. There 

is a lot of space, maybe we could help plant trees. Thanks for reading this. We will be 

waiting for your decision. 

Comment #27 from Leandra Greyeyes 

#27 I am writing this letter to you because I want you to save the land behind the school. 

Because I think it is a good habitat for animals, Also a good migration route. So animals 

don’t have to risk there lives by crossing the streets. And going through the 

neighborhood. IT is also beneficial to us students. So we can learn about the 

environment. I also think you should save it because you can see many kinds of animals. 

You could see deer jump the fence sometimes elk eating grass around there. You can see 

rabbits hopping around and squirrels playing in the trees and don the ground. There 

might be human history around the places. Also there might some ruins there from the 

Native Americans who lived there long ago. There is also open space to see animals 

eating, playing, fighting, running and walking by to go to different places. So that is why 

I want you to try and help me save that land. For animals, humans and for the history 

that was there long ago. So thank you for reading my letter. Hope you help. And thank 

your or your time. Please! 

Comment #28 from Julia Alvarado 

#28 I am writing this letter to you because I want you to save the land behind 

Christensen School. WE would appreciate it a whole bunch if you did. IF you turn that 
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land into more the ESA we can learn about it more. We went on a hike a few days ago 

and I saw a lot of stuff that could teach us about the land. I also want you to save the 

land for use because there are lots of animals that we can learn bout. We love having 

pretty horses that come to our gate. WE can learn more about the history of the people 

who once lived there. It’s a special piece of land that has wide, open fore, but still has 

trees around it. IF you put something there like a building instead of saving it, the 

animals won’t have their migratory route. There is also a lot of useful plants that might 

be able cure diseases. It also could be beneficial for future students. Please we want you 

to save that land for us. Thank-you for listening to my letter. 

Comment #29 from Breand Barrandey 

#29 I am writing this letter because I want to help save the land behind my school. If 

you take the land behind my school you will take the homes of plants and animals. The 

forest behind my school means a lot to me and other students. There is a lot of use out 

there. In the forest behind my school there are a lot of trees that help us breath. We 

want the land behind by school as a Environmental Study Area. 

Comment #30 from Joseph Gutierrez 

#30 Please preserve the school woods for future students so that they can enjoy this are 

as much as I have while attending this school. If you build buildings in this area, we will 

not be able to see the wildlife. Their homes will be destroyed. IF a building is built, we 

will not be able to see the trees and the animals. Please make this area an 

Environmental Study Area to preserve the natural habitat. We will help prick up all the 

trash to make the area look nicer. Please allow the animals to run free and keep their 

homes. 

Comment #31 from Dustin Banbury 

#31 Please preserve the land behind our school. My classmates and I would like it if you 

did. So the school as an Environmental Study Area. Preserve it so people don’t build on 

it. Preserve it so the animal habitat is not destroyed by builders. IT would be preserving 

human and animal history. Preserve it for ecological reasons. IT would beneficial to 

students of the school for year to come. It is a migration path for animals. And it is the 

only way to get around the mountain safely for animals. 

Comment #32 from Mimi Walton Taylor 

#32 I am a 5th grader at Christensen Elementary. I think you should save the 

Christensen ESA because the animals that live here are not going to have a home 

anymore I you don’t save the place. Also people can come here to relax or to do work, 

study, people also can take pictures here or play. So if you do not save this place none of 

this stuff would be possible. So please save this beautiful place. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Comment #33 from Brian Bedonie 

#33 I want to save the land behind the school fence. It should be an environmental study 

area to learn all about animals and the history too. There is not replaceable stuff there. 

There are pieces of old building. If you don’t save the land, the animals we saw by the 

school, we won’t see them any more. If you don’t save it, the other kids in 4th wouldn’t 

go for a walk. 

Comment #34 from Raquel Jackson 

#34 I am writing to you about our forest. There are many reasons why you should leave 

our forest up. First of all it keeps our air clean and smells from the forest are very 

special. Many people come from all around to see many forests. The forest behind our 

school is very special. We use it for lots of things like to do reports, play, picnics, take 

pictures, tell scary stories, and fun stuff like that. We can also look at old things like 

rocks, holes in the ground, tunnels, old food, and many kinds of bugs. Please don’t take 

it way. If you take our forest away your taking animals like food and your taking there 

homes what if we take away your home you wouldn’t like it would you? Many kind of 

animals like there like birds, deer, bugs, lizards, and snakes. 

Comment #35 from Valerie Ashton-Cody 

#35 I’m writing this letter about the forest behind our school. It is a good place for 

animal’s to live, all kinds of them live back there. We don’t want anything to happen to 

it. If something did it would be ruining animals’ homes. So we want you to protect the 

forest behind our school. It is really neat back their so please protect the forest behind 

our school. We would like it so much if you would. 

Comment #36 from Samuel Cruz 

#36 I think that they should save that land for horses and deer and javelins and for elk. 

Kids from Christensen School don’t want to take the land and make a grocery store. To 

preserve land behind our school as an environmental study area. Human history 

ecological reasons beneficial to students (as well as) a migrating route (for wildlife). 

Comment #37 from Dustin Beaver 

#37 I am writing this letter to ask you to save the forest behind our school as an 

Environmental Study Area. There are a lot of animals live there, there is a lot of human 

history there, and it is beneficial to the students of Christensen Elementary School. That 

is why I want you to save the land behind our school as an Environmental Study Area. I 

want you to ask it so that no one can build anything in it or on it. And it is the safest way 

for animals to get from one side of the mountain to the other. So please save this area. It 

is also a beautiful place to take walks. If you do not grant this wish I will write a 

complaint letter and I do not want to write it, so please just grant my little favor I ask of 

you so not only me but everyone can study the forest behind our school. 
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Comment #38 from Georgia Behne 

#38 I think the Coconino National Forest behind Christensen School should become an 

Environmental Study Area because of many different reasons. There are the remains of 

cabins that used to be a home to people, and concrete that used to be the ground of a 

home. These are amazing to study. There are trees and other plants which aren’t usually 

found at this altitude. There are plants and trees that are about or older than 100 years 

old. These are amazing to study. There are places that are graves that once had 

tombstones. There are animals, deer that wander to our schools gate, which is neat to 

see and sometimes there are elk which wander all around, too. Horses, so beautiful, 

wander to our gate and graze beyond our fence. The migration route helps the deer and 

elk so they don’t have to cross the highway and risk their lives. There are squirrels and 

snakes all around that the forest is home to, too. There are plants that are so unique that 

there is hardly even one. Our forest is one of the best, cleanest, and most natural forests 

in Flagstaff. Please make it an Environmental Study Area. 

Comment #39 from Erin Keams 

#39 It would be a good idea to save the forest behind Christensen. So we can study the 

history and so we can go on walks. Also the rangers would be able to help the animals. 

It would be good to save the forest because we will clean it. It has been part of Flagstaff 

a very long time. By building some thing it would be bad because the animals would 

have no place to live. Also we wouldn’t have to go on field trips and pollute the air with 

the buses. Thank you for listening to my letter. 

Comment #40 from Cody Smith 

#40 I think the Forest Service should save the place behind our school because animals 

live in it. In different classes they study animals, trees, and plants. Last year, in my 

class, we studied animals and plants. It helped me a lot. That would be cool if we got to 

put little signs where all the different things are, and make new trails when all the little 

kids get older they can also use this are too. I think the deer like the grass and the pinyon 

trees whenever there is trash we will try our hardest to pick it up. It will be cool to have 

our own (area) and saved for use to use. There is a lot of human history up there. 

Comment #41 from Dylan Buehler 

#41 Please preserve the land behind the school for the students of Christensen 

Elementary School. You should because there is a lot of human history. All students 

could study there and get a better job. If you sell it then we won’t be able to study there 

because they will probably turn it into apartments or something very local. It would 

destroy animal habitats trees and more. If it became an ESA then it would be protected 

by responsible people. There would be less litter and trash. If it got protected then the 

future students could study it and learn more about the outdoors. There is also lots of 
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123 

animal food sources and if people destroyed it, it would kill animals. Thank you for 

listening to my letter! 

Response to comments #25-41: Nonsignificant Issues – 

Generally these comments support the extension of the Mt Elden ESA as described in the 

Proposed Action and common to all action alternatives. Some comments are outside the 

scope of this project because they mention specific trail locations or wildlife habitat 

needs. We appreciate your concerns for the trail, wildlife and general ecosystem health. 

We are glad to hear that you use the ESA in your studies. Perhaps in the future you and 

other classmates could be active in keeping the area clean and part of working on the 

trails. Specific trail locations and wildlife habitat ideas have been forwarded to District 

staff for future site-specific planning. 

Comments #42-#47 from Brian Nowicki and Brian Segee, 

Southwest Forest Alliance 

# 42 The FLEA requires an Environmental Impact Statement for a number of reasons. 

Many of the revisions involve landscape-scale plans affecting tens of thousands of acres, 

and significant changes to the forest structure. Also, the FLEA includes forest-wide 

impacts to northern goshawk and Mexican spotted owl in the Urban/Rural Influence 

Zone and the fire risk reduction forestry. 

Response: NonIssue – Comment. 

There is no disagreement with PA rather a comment on the type of document to be used. 

NEPA documentation will meet standard Forest Service NEPA practices. Per those, an 

EIS will be prepared for this project. 

#43 The map of the Urban/Rural Influence Zones shows that the Urban/Rural Influence 

Zone includes large areas that are much farther than 1⁄2 mile from private properties. In 

effect, the map shows that the Forest Service has simply “filled in” the spaces between 

the 1⁄2 mile radii surrounding private properties. This is significantly different from the 

definitions of the Urban and Rural Influence Zones provided on page 14 of the FLEA. It 

is not appropriate to designate large areas for a particular management simply because 

it is convenient. 

Response: NonSignificant Issue – Conjectural 

Our review of the “filled in” areas shows that these areas are suited to the desired 

conditions and guidelines proposed for the Urban/Rural Influence Zone. In addition, 

there is a need to conduct fuels reduction treatments on some lands that are beyond a 1⁄2 

mile strip area due to topography, dominant wind direction, and/or fuel hazard. 

#44 Furthermore, the FLEA fails to distinguish the Urban and Rural Influence Zones 

from the Fire Management Analysis Zone. These designations should be associated with 

distinct management goals, but such distinctions are missing from the FLEA. 

Response: Nonsignificant – Conjectural 

Rather than distinct management goals each zone has a few changes proposed from the 

current Forest Plan management goals. The Fire Management Analysis Zone is not 

intended to be a separate emphasis zone in FLEA except for the few places where Forest 
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124 

Plan language changes apply. These are wildlife cover, a goal statement about fire 

potential and reducing risk of catastrophic fire, and a sense of priority for fuels reduction 

work outside of the Urban/Rural Influence Zone. Also see response #45 below. 

#45 The Urban/Rural Influence Zones and the Fire Management Analysis Zone may 

contain many of the same management objectives as the Wildland-Urban Interface. The 

WUI has been discussed and appears to be the appropriate terminology for many of these 

management objectives. Why is the Coconino National Forest using a unique and 

unclear set of terms for these zones? 

Response: Non-Issue Question. 

WUI is a general term used in different ways. The U/RIZ in FLEA is specific to the 

FLEA area only and is used to describe a type of WUI. The FMAZ 1U boundary has 

been in existence for many years and used as a tool for allocating fire suppression 

resources (the zone is identified in the initial Forest Plan text in 1987). The FMAZ 1U 

boundary fits the definition of wildland urban interface as described in the current Forest 

Plan. The FMAZ 1U describes another kind of WUI. 

#46 The protection of houses and communities is best accomplished by treating houses 

and their immediately surrounding properties, and by creating a defensible space directly 

adjacent to the community. The Southwest Forest Alliance document “Protecting 

Communities from Forest Fires” discusses the effective treatment of the wildland-urban 

interface, and can be found on our website www.swfa.org 

Response: NonIssue Comment - No disagreement with this PA. 

The Forest Plan changes in the Proposed Action allow for treatments adjacent to houses 

as described in the comment above. The Forest Plan (as amended under the FLEA PA) 

also allows for treatments in areas distant from houses. The FLEA PA neither precludes 

nor prescribes the fire risk reduction occur immediately adjacent to homes. It is our 

understanding however, that reducing the risk of structure losses due to wildfire requires 

treatments in close proximity and a distance away. An example is the recent Kachina 

Village Forest Health Project DEIS that provided additional information on this topic. 

See the Coconino Forest website at www.fs.fed.us/r3/coconino 

#47 The FLEA states that livestock grazing is “covered by various Allotment 

Management Plans”. However, the FLEA includes plans for many forest “topics” that 

are inextricably linked to livestock grazing, such as vegetation changes, restoration, 

wildlife habitat, and fire risk reduction. Livestock grazing profoundly affects all of these 

topics and more, and must be analyzed as a component of the FLEA. 

Response: NonSignificant Issue - Outside scope. 

Livestock grazing related issues are best handled through allotment plans. Only 63 

percent of the FLEA area is an open allotment. This PA does not preclude or 

predetermine livestock grazing. We tried to stay focused on the human uses and the 

recreational aspects of management. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Appendix B – Comment Analysis and Response To Comments

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Comments #48-#67 from Betsy McKellar from Friends of Walnut 

Canyon 

#48 I’m sure you are aware that we think the area needs to still be considered the 

Walnut Recreation Area. This is even more obvious as we read the current document and 

see that very little emphasis was placed on the recreational use of the Walnut 

Management Area, or to the scenic values of the Walnut Canyon area. 

Response: NonSignificant Issue – Conjectural. 

In the Ideas for Change we discussed the option of whether or not to name this a 

Recreation Area. The Ideas for Change includes some of the reasons for not formally 

naming the Walnut Canyon Recreation Area in the Forest Plan. Instead the FLEA PA 

proposes the Walnut Management Area with the boundary delineated on the Proposed 

Management Areas map. To date, the Walnut Canyon Recreation Area name has been an 

informal name used on signs in the area. The name does not appear in the Environmental 

Assessment or the Decision Notice for the Fisher-Campbell Timber Sale. The District 

Ranger who initiated this idea did not have the authority, nor was it his intention that the 

name would be applied without a Forest Plan level analysis. Although it has been many 

years, the necessary Forest Plan analysis and discussion has occurred via the FLEA 

process and the conclusion brought forward in the PA is to remove the name Walnut 

Canyon Recreation Area from all signs and replace it with Walnut Management Area as 

appropriate. We have made some clarifications to the language for the Walnut MA (see 

Appendix A) to clarify the intended emphasis on recreation, scenic values, maintenance 

of the biological diversity of Walnut Canyon itself, and the reduction in fire hazard to 

adjacent residential areas. The text emphasizes a need to balance all of these needs with 

each other. To name the MA as a Recreation Area, fails to place enough emphasis on 

wildlife habitat and fire risk reduction. 

#49 One of the major issues addressed by the Fisher Campbell EA was the scenic quality 

of the area. The first line of Alternative 5, the chosen alternative, said “Silvicultural 

treatments emphasize wildlife habitat and scenic quality”. The first line of the decision 

summary reads: “Manage forest vegetation in the area as needed to support the area’s 

value for wildlife habitat, scenic quality and recreation.” These values have not been 

captured in the current document. Nor have many of the goals and objects listed in the 

Fisher Campbell decision and EA. Most of the following comments will be relative to 

these promises previously made for the area which we view as the existing proposed 

management. 

Response: Nonsignificant Issue – Clarification. 

The Proposed Action only added language or clarification where there was a need. Some 

of the items in this comment are already permitted under the current Forest Plan. This is 

because of changes in the Forest Plan that occurred after the Fisher Campbell decision 

was approved in 1991. For example, Amendment 11 changed the Forest Plan in 1996 so 

that “silvicultural treatments emphasize wildlife habitat” such as Mexican spotted owls 

and goshawks. The Forest Plan has direction for the Walnut Canyon MA that is also 

Forest-wide in nature. Items in the Walnut Canyon Management Area are additive to the 

Forest-wide direction. Additional clarification has been added to the replacement pages 

to include wording about scenery and other values of the area (see Appendix A for the 

Forest Plan new replacement pages). 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Appendix B – Comment Analysis and Response To Comments

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#50 Specific changes that we see need to be made: Page 70 – We’d like to see the 

Management Emphasis statement read more like the above quote, or even the opening 

paragraph of the Fisher Campbell decision. This area has special scenic qualities – see 

page 7 of the Fisher Campbell EA. Of course management should be protect wildlife 

habitat, but that should not be done at the expense of the scenic quality of the entire area. 

Response: NonSignificant Issue – Clarification. 

The Walnut MA description was reviewed and refined, to reflect the scenic and 

recreation values of the area (see Appendix A for the Forest Plan pages). There will be 

times when site-specific scenic values will be affected for the short-term, of wildlife 

habitat will receive long-term protection. 

#51 The text should not only concern the scenic quality of the viewshed of the National 

Monument, nor should it only meet the general forest guidelines of concern near houses 

or designated recreation sites. Both the thinning and the cleanup should reflect the 

special uses and values of this entire area. 

Response: Nonsignificant Issue – Conjectural. 

Page 26 of the PA suggests clarification language that emphasizes fast clean-up of slash 

along major roads, adjacent to homes and developed recreation sites. This guideline does 

not preclude additional areas from being set up for fast slash clean-up should site-specific 

analysis show the need. Additional language has been added to clarify the need to design 

project implementation so that scenic values are maintained in the Walnut MA. 

#52 Likewise the ME (Management Emphasis) should say something more about the 

recreational values of the area. This IS the primary use of the majority of this area, and 

maintaining the quality of the recreational experience is essential. 

Response: NonSignificant Issue – Clarification. 

There is additional clarification language in the replacement pages text for recreation (see 

Appendix A for the Forest Plan pages). There is a need to balance recreational use with 

other values such as wildlife habitat and fire hazard reduction. This is not a single use 

area. 

# 53 No mention is made of the campground which seems to be happening at Canyon 

Vista. How did this happen without public process? What are the plans for possible 

group sites and why is this even being considered so near to Walnut Canyon. 

Response: NonIssue -- Question. 

There has been concentrated use and facilities at this site since before the Forest Plan was 

approved. Originally a shooting range, the site now provides parking for system trails 

and a popular climbing area. Concentrated dispersed camping was changed to designated 

sites to limit resource impacts. Today, individuals and groups use the area. In the mid90’s the site was added to the Forest Service Region 3 Recreation Capital Investment 

Priorities. The site is listed on current Forest maps as a campground. The desired 

condition is to continue these uses and provide facilities that provide sanitation, limit 

erosion and compaction and control numbers of people at one time. There is not a 

specific proposal available related to group use sites at the campground. We have added 

clarification language to the Forest Plan replacement pages (Appendix A) related to this 

facility. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Appendix B – Comment Analysis and Response To Comments

127 

#54 We suggest that you expand the Semi Primitive non-motorized ROS setting to 

include the Skunk-Faye area order No 04-150, also to include the remaining area north 

of Walnut Canyon and south of the Continental area in consistency with the promise in 

the Fisher Campbell that these area be closed to motorized uses (Skunk-Fay) or off road 

travel (the other portion). 

Response: NonIssue Comment – no reason (effect) described. 

See comment #20. 

#55 Do thinning with extreme sensitivity to scenic values and recreational uses. If this 

were a “designated recreation site” then at the very least a 1-3 year clean-up would be 

used. This area deserves even more consideration than that, not just a quicker clean-up. 

Response: Nonsignificant Issue – Clarification. 

Additional clarification has been added about conducting implementation in manners that 

maintain scenery (see Appendix A for the Forest Plan pages). Refer to comment #51. 

#56 We do not feel that there are any locations suitable for motorized trails in the 

interior of the Walnut Management Area. Only roads along the eastern border should be 

considered for this type of corridor. 

Response: NonIssue Comment -no reasons provided for why motorized trails are not 

appropriate. See comment # 23. 

#57 Whether or not the area is capable of a timber sale, the area should be withdrawn 

from consideration for timber sales because of fragility and social sensitivity. 

Response: Nonsignificant Issue – Conjectural. 

This comment seems to be more related to larger scale Timber Sales of the past, such as 

the Fisher/Campbell proposal in the early 90’s or the Walnut Sale of the same vintage. 

There no longer is a Timber Sale Schedule for Timber Production in the Forest Plan. 

Timber Sales are now derived from specific project analysis as a tool to achieve other 

objectives and desired conditions. This shift in management emphasis has already taken 

place in the Forest Plan in the mid 1990’s with Amendment 11. Management for wildlife 

habitat, especially the Mexican spotted owl and northern goshawk, is the primary focus 

of timber management. To remove the ability to sell forest products would limit our 

ability to achieve ecosystem goals for the area. Reducing the fire hazard may be 

accomplished in the quickest and least damaging manner if we are able to sell the timber 

products. Please refer to the response to comment #68 for a more thorough discussion of 

timber suitability. 

#58 Considerable new signage is needed on Campbell Mesa

Response: NonIssue Comment – Outside the Scope. This comment will be forwarded to 

the District staff responsible for signing. 

#59 We feel that the current status of Campbell Mesa needs to be improved by having a 

signed order officially making it off-limits to motorized vehicles. The current situation 

makes enforcement of the so-called closure impossible. 

Response: NonIssue Comment – Outside the Scope. See Response to Comment #22. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

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Appendix B – Comment Analysis and Response To Comments

128 

#60 We realize that there is no prescription written for the thinning which will occur in 

the Walnut MA. However, we are concerned that the exclusion of most of the area from 

the existing thermal and hiding cover guidelines is inappropriate. The Fisher Campbell 

EA state that 

Vertical diversity – The presence of trees and shrubs of different ages and heights is 

important to wildlife habitat and scenic quality. (p7) 

On page 12 of the FC EA: 

Vertical Diversity is maintained on all acres 

Besides the scenic qualities involved there is a lot of large sized wildlife in the area which 

take advantage of the thermal and hiding properties of the small stands of dense trees 

which used to be considered cover and now are considered fire hazard. We tend to agree 

with the Game and Fish dept that the current method of thinning is not necessarily the 

best way to manage wildlife. 

Response: Significant Issue 

This comment refers to Walnut MA. The PA allows managers to deviate from the 

current Forest Plan management direction for wildlife cover but does not require that they 

do so. Fire hazard reduction is a higher priority than maintaining high levels of cover 

immediately adjacent to residential areas. When future site-specific projects are being 

analyzed, it may be that the cover direction can be met in a project area. However, this 

part of the PA provides more flexibility for the site-specific project to consider going 

below current cover guidelines in light of a future site-specific project’s needs. Please 

refer to the response to comment #80 for more information on this same concept. In 

addition, this issue is discussed in the EIS as an alternative action to the PA (Alternatives 

C and D). 

#61 We have been waiting since 1991 for the promised closure of the entire Fisher 

Campbell area to off-road travel. This is not addressed in the document.

Response: NonSignificant Issue - Outside the Scope. 

See response #24 and #59. 

#62 At an earlier stage in the process, we were asked if we agreed to the closure of road 

128B on Anderson Mesa. We still fell that this would be a good idea. Because that area 

is virtually unused except for hunting season, it is very well preserved, and very wild. 

That road is the only access to that particular region of Anderson Mesa, and the road is 

very, very, bad now. When bad weather occurs during hunting season, it only gets worse 

and multi-roading is occurring. 

Response: NonSignificant Issue – Outside the Scope. 

See response #21. 

#63 On promises. We have been waiting for the “FLEA Process” to end for the 

following things to occur: Confirmation of the trail system on Campbell Mesa and 

signage 

Response; NonIssue Comment - no reason (effect) described. 

See response #22 

#64 Completion of the Arizona Trail Trailhead south of Forest Dale mentioned in both 

the Fisher Campbell Decision and the Arizona trail Equestrian By-Pass Decision. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

129 

Response: NonIssue Comment - no reason (effect) described. 

This comment has been forwarded to District staff and the District Ranger for 

consideration as a future work item. 

#65 The order officially closing Campbell Mesa to vehicular travel. 

Response: NonIssue Comment – Outside the Scope 

See response #22. 

#66 Closure of the entire Fisher Campbell area to off-road travel. 

Response: NonIssue comment – no disagreement with the PA. 

See response #24 

#67 We find it extremely amusing that this document is considered to contain enough 

study and information to allow removal of the Walnut Recreation Area designation, but 

not to implement any of the actions that we have been waiting many years for. Many 

specific small projects, (and some large actions) largely those mentioned in the Fisher 

Campbell Decision, have been waiting for years because we were told that this document 

would somehow be necessary. When the Forest Service waits over 10 years to implement 

something clearly outlined in a legal decision, it makes the public suspect that they have 

no intention of ever taking that action. 

Response: NonIssue Comment - No disagreement with PA nor effect described. 

We are not removing a designation that never existed. We are identifying a Management 

Area for Walnut Canyon and surrounding lands. We also identify management direction 

that is tailored to the resources, values, and uses of this area, beyond existing Forest Plan 

direction. This type of area designation requires a Forest Plan analysis and decision, and 

an appropriate level of analysis has been completed to make this choice. 

Items in the Fisher Campbell decision have been already accomplished for the most part. 

NEPA decisions, such as the Fisher Campbell Decision to not require the agency to 

implement the action, rather the Fisher Campbell EA discloses the effects of taking the 

action and the Decision Notice makes a choice between alternative methods for 

accomplishing the activity. Although not preferable, it is sometimes common that actions 

approved in NEPA decisions are implemented at a later date than expected, or not 

implemented at all. There are many factors that affect implementation such as funding, 

weather and other priorities. The choice to work on a particular project in a particular 

year is made during the District and Forest program of work discussions. There is no law 

that governs these choices; rather activities are largely dictated by the budget passed by 

Congress. The Forest Supervisor and District Ranger guide the program of work process 

by identifying priorities. The Friends of Walnut Canyon were advised that projects 

would not occur until after FLEA was completed so that the District Ranger or Forest 

Supervisor could ratify the desired conditions for the area, and make sure the on-theground work matched agreed upon future conditions. Many projects are complete that 

were described in the Fisher-Campbell Decision. 

To summarize Fisher-Campbell items implemented include, 448 acres have been thinned 

in section 29 and 31, Portions of the rim adjacent to Walnut Canyon National Monument 

have been changed to SPNM settings through road closures (approximately 2-3 miles of 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

130 

road closed), no land exchanges have been considered, approximately 2-3 miles of road 

have been converted to nonmotorized trail (Arizona Trail), Approximately 5 miles of 

road have been closed or obliterated in section 35 and 36 and Public Order 04-150 

prohibits vehicles in the area of these sections (Skunk/Fay/Fisher Point area), Arizona 

Game and Fish Department has created a metro hunt unit which limits use of firearms for 

hunting, firewood gathering has been restricted to special permitted areas only, trash and 

abandoned vehicles have been removed, camping and campfire restrictions have been 

implemented, water sources have been improved with the construction of trick tanks. 

There are ongoing efforts to continue road closures and establish public order limiting 

vehicle use on Campbell Mesa (Fiscal Year 2002 project). Remaining work includes 

road closure and obliteration south of FR303 (Old Walnut Canyon Road). 

Comments #68-#71 from C. James Krafft 

I would like to voice my concerns about the recent Flagstaff Area Ecosystem Analysis as 

it pertains to Walnut Canyon. Please excuse my brevity, but I understand that this 

comment is late, and I want to get it in as quickly as possible. 

#67.1 After years of work by the Friends of Walnut Canyon on Campbell Mesa, I 

expected this document to include some method of signing the tails there 

Response: NonSignificant Issue – Outside the Scope. 

Methods of signing are specific implementation techniques. The FLEA PA changes to 

the current Forest Plan add ROS objectives and scenic management objectives a tool for 

designing future projects. 

 # 68. After serving on the Fisher Cambpell ID Team years ago, I am disappointed that 

almost one half of the “Walnut Management Area” is designated “suitable for timber.” 

Didn’t we have this discussion (same) over the Fisher Campbell sale which determined 

that a timber sale was not suitable for this area? 

Response: NonIssue Question. 

At the time of the Fisher-Campbell analysis, we did update our records with site-specific 

inventory data from this area and did conclude that some of the lands should have been 

classified as unsuitable for timber production according to the Forest Plan direction. 

Those updates to our database were made. The Fisher-Campbell decision did not change 

the lands ability to grow and regenerate trees (suitability) rather it decided not to conduct 

a timber sale as originally proposed with the Fisher-Campbell project. 

Some of the confusion seems to be caused by the national classification system, which 

categorizes lands as Tentatively Suitable for timber production or Unsuitable for timber 

production. Perhaps an explanation of how this classification system works and what it 

truly indicates would be helpful. 

There are some lands within the Walnut Management Area classified as “Suitable Timber 

Lands”. Because a piece of land is so classified does not mean that there has been a 

determination to have a timber sale. Classification of timber stands as “capable” or 

“suitable” does not equate to creation of a timber sale. For instance, there is no 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

131 

crosswalk that would lead from a stand classification as “suitable” to a schedule for 

timber sale. The classification indicates that certain silvicultural activities could be 

permitted in relation to a host of objectives, which could include, wildlife habitat 

improvement, fuels hazard reduction, visual quality, habitat restoration, or others. If you 

can accomplish desired conditions using cultural methods such as non-commercial 

thinning or fire, then a project would proceed without a timber sale. However, future 

site-specific analysis may indicate that a timber sale could be used as a tool to accomplish 

project objectives. An appropriate time to use a timber sale versus a non-commercial 

thinning treatment might be when the by-product of the treatment prevents you from 

meeting the desired condition if a large amount of material is left on the site. Many of 

the fuel hazard reduction treatments require removal of the thinned material to meet the 

fire hazard reduction objective. Using a Timber Sale to have this material removed is 

often much more cost efficient as the government is getting paid to have it removed, 

versus the Forest Service paying someone to remove the same material. There are many 

acres of suitable land where we have determined through site-specific analysis that tree 

harvest of any kind is not appropriate at this time. Though these lands are “deferred” 

from tree harvest at this time, it does not change their timber suitability classification. 

For land to be classified as “Suitable”, it must pass a rigorous series of filters. 

Is it Forest Land? (There are definitions on what distinguishes forestland from Nonforest land) 

Is the land Available Forest Land Area or has it been withdrawn from timber 

production? (Specific lands are withdrawn by legislation regardless of timber 

capability, such as congressionally designated wilderness) 

If not withdrawn, is it capable to produce wood? (There are amounts of annual 

growth requirements that must be met to qualify as physically capable) 

If it is capable, is it physically suited? (It must pass a regeneration requirement, 

have the assurance that timbering activities would not cause irreversible damage to 

soils or other ecosystem components, and other technical requirements before it can 

be classified as suitable).

In addition, this is only a first level of classification that helps categorize a timber stand. 

Once suitability has been established, the stand will be further classified by “Timber 

Component”. Timber Component identifies any special emphasis that has been 

determined for a stand. Timber Component can be assigned at the Forest Plan level or 

during and following specific analysis. For instance, as a result of Amendment 11 to the 

Coconino Forest Plan nearly all of the Suitable Forest Lands previously classified by a 

Timber Component of Land Suitable For Timber Production – Timber Emphasis (Timber 

Codes 500 – 521), on the Coconino have been re-classified to Suitable Forest Land – 

Resource Emphasis Other Than Timber (Timber Component Code 650, which is Land 

Suitable for Timber Production – Suitable Forest Land – Wildlife Emphasis). 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

132 

Hopefully this explanation alleviates your fear that this national classification system 

leads to a Timber Sale, and explains why having the Timber Sale tool available could be 

useful. In addition, there has been a shift in emphasis since the days of the FisherCampbell and Walnut Sale proposals (that were based in timber production objectives) 

and today’s emphasis on managing for healthy ecosystems, regardless of the vegetation 

classification. Please refer to the response to Comment 57 for related information. 

#69 For years the roads and trails around Skunk Canyon have been closed to motorized 

vehicles. Why does the ROS map show that the area is now suitable for motorized 

vehicles?

Response: NonIssue Question. 

See #20 

#70 And of course my biggest disappointment, why did the Ideas for Change text talk 

about the Walnut Recreation Area at some length, but it is never mentioned in this 

document? What does this mean as far as continuing the designation? I personally feel 

that people of Flagstaff have embraced Walnut Recreation Area over years, and that it 

has afforded protection for the area by its very existence. The Walnut Recreation Area 

signs have set the mood and theme for the area for the last many years; to remove them 

would certainly show degradation in the management of the area. 

Response: NonSignificant Issue – Conjectural. 

A name, or lack of a name, would not show degradation in management. See response 

#48. 

#71 The many “no this” and “no that” signs that are popping up all over the entrances 

to the Walnut Recreation Area certainly show a lack of concern over signage which is 

harsh in its wording and message, while the existing signs strove for saying “please” and 

giving an explanation for their action. At one time we were moving towards eliminating 

the profusion of individual harshly worded ones. Now it appears that we are moving 

back in the wrong direction. 

Response: NonIssue Comment - not specific to PA. 

Specific signs are outside scope of FLEA decision. This comment has been forwarded to 

District Recreation staff. 

Comments #71-#92 from Taylor McKinnon, Grand Canyon Trust 

#72 -The Proposed Action needs to include a vision statement, a statement of purpose 

and need, desired future conditions, and project objectives that unify and that are 

explicitly substantiated by the proposed Forest Plan amendments (as was done for in 

Ideas for Change). This is necessary for two reasons. First is for the simple purpose of 

placing the proposed amendments in context. That is to say, there are circumstances and 

needs unique to the FLEA area that have led to this proposal—what are these needs and 

how do we anticipate the proposed amendments will meet them? Second, because the 

project scope has changed since Ideas for Change due to new management priorities, 

duplication of existing Forest Plan direction, and jettisoned analyses, the original vision, 

background, needs and desired conditions need to be revisited accordingly. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

133 

Response: NonIssue Comment - No disagreement with PA, rather disagreement with 

document presentation. 

We referenced the Ideas for Change for these items and indicated you needed to use the 

two documents together. The DEIS contains statements of purpose and need. The DEIS 

adjusts the descriptions of desired conditions50 for some topics, and maintains current 

descriptions of desired conditions for other topics. The DEIS describes some additional 

objectives for some topics. A vision statement for the area has not been developed; rather 

the current statement in the Forest Plan under Mission continues to apply. 

#73 – Have the original circumstances and needs unique to management of the FLEA 

area changed? If so, how? How do the proposed amendments meet these needs. 

Response: NonIssue Question. 

Again we refer you to the Ideas for Change for this background material, which is also 

presented in the DEIS in the Purpose and Need section of Chapter 1. Also, Appendix F 

provides a summary crosswalk from the Ideas for Change to present. 

#74 Just as importantly, how do those parallel and/or jettisoned analyses intersect with 

FLEA? 

Response: NonIssue Question. 

A matrix that helps answer this question is in Appendix F of the DEIS. 

#75 Proposed action needs to consider and address the Grand Canyon Forests 

Partnership51 as a concurrent and relevant planning effort. The proposed action does 

not discuss the Grand Canyon Forests Partnership. Of particular importance, the 

proposed action does not specify how the proposed amendments for the Urban Rural 

Influence Zone (URIZ)—which constitutes approximately 65,000 acres of the 100,000-

acre Flagstaff Urban Wildland Interface—are consistent or inconsistent with the goals 

and objectives of the Grand Canyon Forests Partnership. If not carefully considered 

from the outset, we could end up with two sets of goals and objectives—one set forth in 

the GCFP Cooperative Agreement and the other in URIZ amendments—for the same 

65,000 acres. 

Response: Nonsignificant Issue –Conjectural. 

The Partnerships goals have, to date, been met under current Forest Plan direction. 

FLEA adjustments do not change this. There will not be two sets of goals for the area. 

Rather the Forest Plan describes the overarching desired conditions for the area. 

Partnership goals and objectives, and implementation techniques, fall within this Forest 

Plan framework. Appendix B of the DEIS describes the GFFP efforts as concurrent 

planning activities. 

#76 “First we are concerned that the proposed action to abandon recovery goals for the 

MSO will, when considered in combination with the region 3 Wild land Urban Interface 

MSO amendments, contribute to jeopardy of the Mexican spotted owl.” Second, we 

 

50 Desired conditions are described in a combination of goal statements, objective statements, and 

standards and guidelines. 

51 Since writing of this letter, the name of the partnership has changed to the Greater Flagstaff Forests 

Partnership 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

134 

question the need for such a proposal: existing management direction outlined in the 

Recovery Plan provide for fire risk reduction treatments in MSO habitat, and the subject 

restricted habitat constitutes only 1,539 acres (2%) of the approximately 65,0000 acre 

Urban Rural Influence Zone. Surely management scenarios can be developed that 

provide for MSO habitat and a satisfactory reduction in fire risk for the community” 

“This proposal unnecessarily pits ecosystem restoration goals against community 

protection goals when, in actuality, these values are entirely compatible- which might 

undermine existing collaboration based upon shared interest between the fire protection 

community and the restoration community”. 

Response: NonSignificant Issue – Clarification. 

See the DEIS under the section Alternatives Considered but Eliminated from Detailed 

Study for the response to this comment. 

#77 We urge the Forest Service to evaluate an alternative that does not include changes 

to Mexican spotted owl habitat management. Note: The background notes provided for 

this amendment in the proposed action on page 30 state that the question the 

interdisciplinary planning team asked themselves in developing this proposal was 

“whether or not the Forest Service could successfully manage for owls in the 

urban/Rural Influence Zone.” Considering the paramount importance of MSO recovery 

goals as described in the Recovery Plan, and the very real threat of endangerment and 

extinction of MSO, the appropriate question should of been “how”, not “if” the Forest 

Service can successfully manage for MSO in the URIZ. 

Response: Request for Alternative. 

The No Action alternative will provide a basis for comparing no change to MSO habitat 

management. 

#78 Proposed action to amend Forest Plan for threatened and endangered species. 

Human disturbance constitutes one of the greatest threats to the habitats of species at 

risk of becoming endangered or extinct as Flagstaff’s population and resulting human 

disturbances increase in time. The proposed management direction to monitor the effects 

of human disturbance to threatened and endangered species is excellent—but would be 

more appropriately proposed as standards rather than guidelines—this is clearly a case 

where the institutional commitment of designating standards rather than guidelines is 

appropriate and warranted by the importance of these species persistence on the 

landscape. 

Response: Nonsignficant Issue – Conjectural. 

Standards are usually quantifiable, i.e. a distance, and acreage or a percentage is used to 

quantify the standard. In the case of a monitoring requirement it is difficult less 

quantifiable. There is institutional commitment for applying a guideline. A standard is 

not necessary to ensure monitoring occurs. 

#79 Proposed action to amend Forest Plan for use of two Management Indicator Species 

(pygmy nuthatch and hairy woodpecker) in URIZ. The National Forest Management Act 

directs the Forest Service to identify and monitor Management Indicator Species (MIS) 

as surrogate and representative measures of biological diversity and ecosystem health. It 

is unclear why the Forest Service has proposed to reduce the number of MIS to two in the 

URIZ, however it is inconsistent with the original intent of MIS and NFMA. If the 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

135 

proposed amendment is based on a need to accommodate managing for more open forest 

conditions in the URIZ, then it should identify the appropriate representative suite of MIS 

for this forest condition consistent with the guidance and intent of NFMA. Reducing the 

number of MIS, however, is inconsistent with the guidance and intent of NFMA 

Response: NonIssue Comment – Clarification. 

The NFMA does not require that all Management Areas address Management Indicator 

Species. However, after thorough internal review and questions regarding this topic, the 

proposed action has been clarified and no change in MIS species will be evaluated in 

Alternative A (the Proposed Action). All management indicator species as currently 

defined for MA’s will be evaluated. 

#80 Proposed action to amend Forest Plan for hiding and thermal cover. We are 

concerned about the proposed amendment not to retain 30% hiding and thermal cover 

within each 10K block. Hiding and thermal cover are important habitat attributes for 

numerous native species that use the FUWI and URIZ, including many management

indicator species. It is likely that future management actions allowed by this guidance 

would fall short of accommodating the habitat needs of these species that require thermal 

cover, hiding cover, or the localized more dense patches of forest—which is again 

contrary to the guidance and intent of NFMA. 

As with the case of the MSO proposed amendment, we are concerned this proposed 

amendment falsely assumes that fire risk reduction goals are incompatible with species 

habitat management goals, which is why we so steadfastly maintain that a comprehensive 

ecosystem restoration approach that includes habitat and fire risk reduction goals is 

imperative, and that a narrow approach of fire risk reduction is inadequate. 

Response: Significant Issue. 

The EIS will include a No Action alternative that will evaluate the current management 

direction of 10% hiding, 10% thermal and 10% hiding/thermal cover. An alternative will 

be developed based on recent projects that have managed for cover at a smaller scale 

(small patches of cover, as described for Kachina Village Forest Health Project). 

Currently within the FMAZ area, habitat management for northern goshawks, Mexican 

spotted owl, and movement corridors in addition to steep slopes, would maintain nearly 

20% of the FMAZ in hiding and thermal cover conditions. The team had developed 

alternatives to address this issue and provide new ideas and concepts related to cover 

management (Alternatives C and D). 

#81 Therefore, we would like to see the Forest Service evaluate an alternative that 

maintains the 30% hiding and thermal cover guidance (and adheres to Recovery Plan 

management directions for MSO). 

Response: Request for Alternative. 

The No Action Alternative provides comparison of no change in cover guideline to 

change. 

#82 – Management area delineation. The proposed management area delineations are 

arbitrary because they are primarily based on “sense of place” and other subjective 

recreational values rather than natural geographical or biological boundaries on the 

landscape. We are concerned that the proposed management areas will not provide an 

ecologically based context for future environmental analyses, and does not represent the 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

136 

best and latest thinking in land management planning. The importance of using 

ecological or biogeographical boundaries to delineate management units has been 

emphasized in innumerable studies and Forest Service publications. Considering that the 

Forest Service has been moving towards using ecological or geographic boundaries such 

as watersheds in determining management units, the proposed Management Area 

delineation seems to represent a step backwards rather than forward in the Forest 

Service ecosystem management. We recommend the Forest Service evaluate an 

alternative that delineates management areas according to ecological or 

biogeographical units such as 6th order watersheds (or aggregations of these) or other 

natural boundaries. 

Response: Nonsignificant issue – Conjectural. 

Response to this comment is located in the Alternatives Considered but Eliminated from 

Detailed Study section . 

#83 We are encouraged to see management direction proposed for mountain meadows 

and riparian areas. The guideline to establish administrative exclosures on 

representative riparian areas to determine habitat potential is excellent. We encourage 

the Forest Service to consult with the research community in order to assess the adequate 

minimum sizes needed for assessment, to ensure that all local riparian types are 

represented, and to encourage research and documentation of these areas. 

Response: NonIssue – Support for PA. 

Several riparian exclosures have been established in the lake Mary watershed, primarily 

to establish a condition that is relatively un-impacted from grazing ungulates. Large 

areas (>4 acres) have been established to provide for areas that are grazed by cattle and 

elk, elk only, and neither ungulate. Research projects coordinated through Northern 

Arizona University are ongoing and include focus on vegetative diversity, insect diversity 

and abundance, small mammal habitat, and re-vegetation success. Some of the area has 

been the subject of successful stream channel restoration techniques designed to stabilize 

disrupted systems using elements of natural channel design and construction. 

#84 We would like to see these same principles of protecting habitats to assess habitat 

potential applied to other important vegetation communities. We suggest establishing 

similar areas for all Terrestrial Ecosystem Survey types within FLEA for research 

purposes in order to acquire a representative suite of study units documenting habitat 

potential.

Response: Nonsignificant Issue – Conjectural. 

The establishment of fenced exclosures in high elevation riparian systems came about, in 

some part, because of the favoritism shown by grazing ungulates for these highly 

productive areas. Other vegetation types that have been fenced from grazing ungulates 

include extensive aspen areas, and small areas in the piñon/juniper habitat showing heavy 

winter use by elk. These fences are expensive, and require frequent maintenance. If 

there were valid, long term, research interest and funds available, the current Forest Plan 

allows similar exclosures in other Terrestrial Ecosystem (TES) units. As many forested 

TES units are similar in nature, it would be unnecessary to establish a guideline for 

installing sites in all TES units found in the FLEA area. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

137 

#85 – Proposed Forest Plan amendment for USFS coordination with NPS. FLEA should 

explicitly articulate a commitment to exercise all options available to protect the 

resources that contribute to the significance of the Flagstaff National Monuments. 

Considering the special significance of the Monuments, it may worthwhile to consider 

creating a special management designation in areas where activities surrounding the 

monuments may fail to do so. Of particular importance, for example, would be the USFS 

lands between Wupatki and Sunset Crater Volcano National Monuments. 

Response: NonIssue Comment 

There is no disagreement with the Proposed Action. The MA boundaries were drawn in 

part due to the location of the Monuments. Each MA lists activities where the NPS and 

FS need to coordinate with each other. The ROS objectives were drawn, in part, based 

on NPS input. The Roads Analysis Report contains specific road management items 

developed from NPS input. Sometimes when an area is given special designation it 

draws more attention and use to the area often affecting the very resources that make the 

area special and unique. The FLEA team believes the Management Areas are sufficient 

designation at this time. 

#86 Proposed Forest Plan amendment for USFS coordination with research and data 

management efforts. Opportunity exists for the Forest Service to collaborate with the 

Forest Ecosystem Restoration Analysis project at Northern Arizona University in order 

to identify and answer research questions pertinent to forest management and to develop 

spatial data, spatial data management systems, and analyses that have the potential to 

further inform forest management. In fact, funding for the FERA project was secured for 

the purpose of helping forest managers’ efforts by providing state-of-the-art analytical 

capabilities. Therefore, we strongly encourage the Forest Service to include explicit 

mention of collaborating with FERA in FLEA, and, if possible to consider collaborating 

with FERA in the development and analysis of FLEA alternatives. 

Response: NonIssue Comment – Clarification. Although FERA is not mentioned 

specifically, additional language has been added to the replacement pages that encourages 

continued efforts in partnership with other organizations. 

#87 Proposed Forest Plan amendment for Recreation Opportunity Spectrum (ROS) 

designations. Our preliminary analyses of the proposed FLEA ROS designations 

indicate that designations within wildlife movement corridors are heavily weighted (76%) 

towards motorized designations. The purpose of this analysis was twofold; first, to 

assess the degree to which wildlife movement corridors were considered in ROS 

designations and second, to indicate the extent to which ROS designations may have 

considered important ecological values in general. 

However, in raising our concerns with Peaks Ranger District staff we learned that our 

findings are not surprising because 1) ROS designations, due to designation criteria, do 

not occur at a resolution compatible with accommodating wildlife movement corridors in 

all cases and 2) ROS designation criteria must account for permanent landscape features 

such as highways and system roads. And, in fact, numerous biological ecological values 

were accounted for in the ROS designations. Therefore, prior to providing more detailed 

comments on this issue, we would like to learn more about the analysis of the relationship 

of ecological and biological values (such as breeding areas, important seasonal habitats, 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

138 

movement corridors, etc) to ROS designations. Specifically, we would be interested to 

learn what information was employed in the analysis, what analytical protocols and 

criteria were employed, what assumptions were used, and how these results informed the 

ROS designations. In the future, in order to reduce the need for such inquiries and 

bolster public understanding of and support for proposals, it may be useful to disclose 

analyses such as this that have informed proposed actions and /or alternatives as 

appendix to the FLEA EA or EIS. 

Response: NonIssue Comment – No disagreement with the PA rather a request for 

information. 

Appendix E describes the process used to develop the proposed ROS objectives. 

#88 Nonetheless, we have three specific concerns with the proposed ROS designations. 

Our first concern is that designations, whatever they are eventually determined to be, 

should be established as standards rather than guidelines (as proposed). 

Response: NonSignificant Issue – Conjectural. 

The definition used in the FLEA PA for a guideline52 allows some flexibility as we go to 

do site-specific projects with more detailed inventory information. These ROS lines have 

been drawn based on a variety of resource information, however, site-specific analysis 

may indicate that some modification in the location of those lines is appropriate. 

#89 Secondly, we are concerned that without maximizing the acreage of semi-primitive 

non-motorized designations in important habitats (as listed above), motorized 

designations will continue to facilitate trends of ecologically unsustainable use patterns 

of increasing road proliferation that are tremendously difficult and expensive to undo 

once established. 

We are concerned that without aggressively addressing these issues, we will continue to 

see increasing trends of road proliferation and associated affects consistent with those 

documented in our San Francisco Peaks Roads inventory project (much of which 

occurred within the FLEA area): 

• Only 45% of the 1300 roads had any evidence of being constructed, the rest were 

user-created or illegal ghost roads 

• Only 11% showed evidence of being maintained 

• 71% of all the roads showed signs of erosion 

• Roads were directly correlated with introduction of exotic species and illegal 

dumping 

• Road densities often significantly exceeded the Forest Service's road density 

guidelines for the study area. 

 

52 Guidelines describe a preferred or advisable course of action, desired policy or conduct. Variation of a 

project from a guideline does not trigger a forest plan amendment. Guidelines may be used for the 

following purposes: 1) To describe a preferred or advisable method for conducting resource activities 

specific to the forest plan area and 2) to describe a preferred or advisable sequence or priority for 

implementing various types of projects when such guidance is deemed useful in facilitating achievement of 

a forest plan goal.
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

139 

• In many areas road densities exceeded densities which have been shown to 

negatively impact habitat for black bear, mountain lion, elk, and deer. 

While we are greatly encouraged by and extremely supportive of the 5-forest ORV policy, 

we believe the affects listed above merit that all opportunities to improve road and 

recreation management—including ROS—should be addressed accordingly 

Response: NonSignificant Issue – Conjectural. 

See DEIS in the Alternatives Considered but Eliminated from Detailed Study section for 

the response to this comment. 

 #90 We encourage the Forest Service to evaluate a range of alternatives for ROS 

designations that includes an alternative with significantly more acreage designated as 

semi-primitive non-motorized than is proposed for the explicit purpose of evaluating the 

greatest level of protections for important ecological values in the FLEA analysis area. 

Response: Alternative suggested by public. 

See DEIS in the Alternatives Considered but Eliminated from Detailed Study section for 

the response to this comment. 

 

#91 Elements of proposed action in need of clarification. The following elements of the 

proposed action are not clear. First is the relationship of this comment period and the 

Ideas for Change comment period to the NEPA process. We are not clear when the 

scoping process began or whether our comments on the Ideas for Change document were 

to be officially considered as scoping. 

Response: NonIssue Question. 

We are all learning the details of how ecosystem analyses fit within NEPA regulations. If 

you picture the Forest Services’ planning triangle and what we often refer to as the ‘left 

side’ there is a description of planning steps that include choosing an area, determining 

Existing conditions, Goals and objectives (Desired Conditions) Opportunities, Possible 

Management Practices and Forest Plan consistency. From 1997 to 1999 we were 

evaluating the FLEA area for these items. We reviewed existing conditions, and 

discussed where currently we are not progressing towards desired conditions, or where 

desired conditions described in the Forest Plan no longer ‘fit’. We then identified options 

for change (possible management practices) that ranged from site-specific items to Forest 

Plan direction adjustments. The Ideas for Change documented this work. The Ideas for 

Change is the document that represents the ‘ecosystem analysis’ for the FLEA area. It is 

not a decision document, but rather a summary of existing and desired conditions, goals 

and objectives, and a list of possible management practices. This type of analysis is 

primarily governed by NFMA. Public comment to the Ideas for Change is part of the 

package of information that represents the ‘ecosystem analysis’ or left hand side product 

for this area. The comments are referred to regularly for various projects. 

Comments to the Ideas for Change represent public participation on the left side of the 

planning triangle and do not provide for “scoping” described in NEPA regulations as 

“determining the scope of issues to be addressed and for identifying the significant issues 

related to the proposed action”. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

140 

In moving from the left hand side to the right hand side of the NEPA triangle, the 

‘ecosystem analysis’ portion was complete and the task remained of choosing which 

management practices (changes in the Forest Plan) were most important to carry over in a 

Proposed Action for NEPA analysis.53 Publishing the Proposed Action kicked off the 

right hand side of the planning triangle and the standard NEPA process for conducting a 

nonsignificant amendment to the Forest Plan. (The letter in Appendix D describes the 

rationale for why this is a nonsignificant amendment and this conclusion dictates our 

usual NEPA process from here on out). The comments received in response to the PA 

are “scoping” as defined under NEPA and they will determine the scope of issues to be 

addressed and they will identify the significant issues. The significant issues will drive 

alternatives to the PA. Although the CEQ regulations require scoping only for EIS 

preparation, the FS has broadened the concept to apply to all proposed actions. 

A note on the scope of the DEIS. 

Many people expect this Draft EIS to contain all the documentation suitable for an 

‘ecosystem analysis’. This will not be the case. It might have been prudent to change the 

name of the project at this time, but so many people were familiar with the FLEA name it 

was retained. Really, other NEPA documents have there roots in the FLEA process but 

were not so named (Old Caves Crater as an example). 

The Draft EIS is documentation of the NEPA analysis of those items proposed, and 

alternatives to those proposed items, and nothing more. The discussion in the DEIS will 

center around those items where change is proposed, including those items where issues 

were raised related to the proposed changes. Where the PA proposed clarification to the 

Forest Plan, and where there is no issue raised related to the clarification, there will be 

only brief discussion. 

#92 Second, the purpose and relevance of the Fire Management Analysis Zone is 

unclear and briefly referenced only a few times in the text of the proposed action. 

Response: NonIssue Question. 

The Fire Management Analysis Zone is not intended to be a separate emphasis zone in 

FLEA except for the few places where Forest Plan language changes apply. These are 

wildlife cover, a goal statement about fire potential, reducing risk of catastrophic fire, and 

a sense of priority for fuels reduction work outside of the Urban Rural Influence Zone. 

The Fire Management Analysis Zone was developed, as a FS tool for determining fire 

suppression, placement of personnel and vehicles, and fuels reduction needs. It 

represents the wildland urban interface and described in the current Forest Plan. 

Comments #93-#96 from John Sliva, Planning Director, City of 

Flagstaff 

Thank you for the opportunity to comment on the Proposed Action for the Flagstaff/Lake 

Mary ecosystem Analysis Area, containing proposed changes to the Forest Plan. In 

response, the City of Flagstaff’s Planning Division submits the following comments for 

 

53 In addition, at this step, we chose to do separate proposed actions for site-specific items, and lump forest 

plan amendment actions into the FLEA PA. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

141 

your consideration: As you are well aware, the City of Flagstaff, in conjunction with the 

Coconino County, has recently adopted a general/comprehensive plan titled the Flagstaff 

Area Regional Land Use and Transportation Plan (Regional Plan). While the 

boundaries of the Proposed Action and the Regional Plan are not the same, most of the 

Proposed Action Management Areas are within the Regional Plan boundaries. 

Consequently, it is important and mutually beneficial that the two plans be 

complementary and not conflict in their proposals for action. 

#93 The Regional Plan makes numerous references to cooperation and coordination with 

the Coconino National Forest. Most of these are in the form of policies and strategies for 

the development, protection and management of the public lands in and around the City 

of Flagstaff. Land Use Plan maps, through the designation of specific land use 

categories, indicate those Forest Service lands that are planned for some type of 

development or for their continued management by the Forest Service for multiple-use 

purposes. 

The lands tentatively classified as base-in-exchange by the Forest Service that fall within 

the boundaries of the Regional Plan should conform to those designated for development 

in the Regional Plan. The City of Flagstaff used the Greater Flagstaff Area Open Spaces 

and greenways Plan (OS&GS Plan) as a basis for the delineation of the Urban Growth 

Boundaries. Both documents-the Regional Plan and the OS&GW Plan-have the net 

effect of providing credence to and support for preservation of those public lands that are 

high priority for retention as open space in the greater Flagstaff area. Consequently, on 

page 31, it is respectfully requested that reference be made to changing the base-inexchange classifications to coincide with the lands considered high priority for retention 

as open space as indicated in the Regional Plan and the OS&GW Plan. It is also 

requested that the Proposed Action reference these two documents (Regional Plan and 

OS&GW Plan) and the reliance that the Forest Service has place don them in making the 

requested base0in-exchange amendment to the Forest Plan. 

Response: Nonsignificant Issue – Clarification. 

See comment #14 and review the adjusted text under the Land Exchange heading in the 

replacement pages (Appendix A). 

#94 It is requested that a section be added to the Forest Plan that calls for coordination 

with the City of Flagstaff. This request is based on the Memorandum of Understanding 

that was entered into by the various governmental entities when the OS&GW Plan was 

adopted, including the Forest Service and the City. It calls for the implementation of the 

OS%GW Plan through our collaboration by providing resource protection, on-theground improvements, participating in public outreach education projects, and creation 

of an open spaces coalition, among others. 

Response: NonSignificant Issue – Clarification. 

A new section has been added as clarification to the replacement pages titled 

Coordination with the City of Flagstaff and Coconino County. Also, there is adjusted 

text under the heading Land Exchange. See adjusted text in replacement pages 

(Appendix A). 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

142 

#95 Other forms of cooperative processes and long-term commitments are also proposed 

in the Regional Plan. Of major importance is the proposal to develop an intergovernmental agreement acceptable to the City and the Forest Service for the 

management and protection of the lands surrounding Walnut Canyon National 

Monument. Reference to these actions is respectfully requested in the Proposed Action, 

possible in Chapter Two-Area-wide Goals, Objectives, Standards, and Guidelines.

Response: NonSignificant Issue – Outside Scope. 

We look forward to continued conversations about this agreement, however, it should not 

be mentioned in FLEA at this time, because it is still being developed. 

#96 With specific reference to Chapter Three Walnut MA, the City requests that the FS 

consider adding the following to the PA setting forth the City’s commitment to protect 

Walnut Canyon NM and its surrounding natural and cultural resources. It is a course of 

action included in the Regional Plan and is based on conversations we have had with the 

FS, NPS and others about the protection and management of lands surrounding Walnut 

Canyon NM. 

It is proposed to protect natural and cultural resources around Walnut Canyon 

National Monument by simultaneously pursuing appropriate expansion of Walnut 

Canyon National monument and undertaking measures to formalize inter-reliant 

commitments by the various federal, state and local governmental entities. The 

City and County commit to providing the Forest Service with the support it needs 

to manage the intervening lands between the Monument and the Urban Growth 

Boundary in a manner that protects and mitigates impacts on the natural and 

cultural resources. To formalize each entity’s commitment, the objectives and 

intent are to: 

• Pursue and enter into an Intergovernmental Agreement with the various land 

managers to identify and confirm the issues and commit to addressing them in 

order to protect the natural and cultural resources in the urban interface 

area. 

• Support Forest Service efforts to manage the urban interface to mitigate 

future potential external threats to Monument resources through its FLEA 

process and amendment to the Forest Plan. The lands are being considered 

for recreation use with restricted motorized use. 

• Designate and require access points from developed to be developed areas 

onto public lands. 

• Provide a transition zone of open space or low density from higher density 

development where adjacent to public lands. 

• Support the National Park Service in this efforts to monitor the use of and 

impacts on the natural and cultural resources. 

• Pursue Arizona Preserve Initiative re-designation of State Trust lands as 

suitable for conservation purposes. 

Again we thank you for considering the City’s Planning Division’s comments to reflect in 

the Proposed Action either a varying direction for the management areas (e.g., 

intergovernmental agreement for Walnut Management Area and land exchanges 

respective of the Regional Plan and the OS&GW Plan) or placement of emphasis, 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

143 

principally on coordination with the City to achieve our respective objectives for the 

FLEA area. 

NonIssue Comment 

Response: Nonsignificant Issue – Clarification. 

The Walnut MA text has been clarified to include most of the language listed in this 

comment (see Appendix A replacement pages). 

Comments #97-#134 from Sam Henderson, National Park 

Service, Flag-Area Monuments 

We appreciate being given the opportunity to review and comment on the subject 

Proposed Action for the FLEA Amendment (FLEA PA). As you are well aware, the 

National Park Service (NPS) has concurrently been developing General Management 

Plans (GMP’s) for Wupatki, Sunset Crater Volcano, and Walnut Canyon National 

Monuments (Flagstaff Area National Monuments). The draft GMP’s are currently 

available for public review through January 7, 2002, and we look forward to receiving 

comments from you and your staff. Much of the scoping for the GMP’s and the FLEA 

Amendment was done collaboratively, and the two documents clearly complement each 

other and do not conflict in their proposed actions. We are pleased to see that many of 

the concepts we have discussed over the last few years have been incorporated into the 

FLEA PA. Overall, we concur with the state “Management Emphasis” for the Deadman 

Wash and Walnut Management Areas adjacent to the Flagstaff Area National 

Monuments. As would be expected, most of our issues are centered on motorized access 

and the future management of the Cinder Hills OHV MA. 

#97 We recognize that the contents and the nature of the PA have changed substantially 

from the previous draft, largely as a result of you efforts to identify broad objectives and 

guidelines for the FLEA area as appropriate to a Forest Plan amendment. We 

understand that numerous scoping issues and action items are to be addressed via a 

variety of separate planning, compliance, and implementation processes, while only a 

few issues and items have essentially be dropped from further consideration.” As a 

matter of organization, the PA would benefit from the inclusion of an introductory table 

or matrix which lists: (1) the issues and actions items from the FLEA Ideas for Change; 

(2) the reason they have been excluded, deferred, or dropped; and, (3) shows their 

current scheduling status in the planning framework. This would allow us to understand 

how specific action items from prior discussions may eventually be implemented. 

Response: NonIssue Comment – There is no disagreement with the PA. 

See Appendix F of the DEIS for this information. 

#98 All maps: The Walnut Canyon NM Entrance Road is displayed on all maps as a 

“highway,” while the Sunset Volcano-Wupatki Scenic Loop Road (FR545) is not shown 

at all. 

NonIssue Comment –No disagreement with the PA 

This clarification was added to the replacement pages. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

144 

#99 “Proposed management Areas” Maps: The northern boundary of the cinder Hills 

OHV Area MA should be corrected to match the boundary showing the 1991 Off-Road 

Driving Management Plan Map (copy enclosed). Although it may be difficult to convey 

at the scale of the map included in the FLEA PA document, it remains very important to 

us that forest users understand that off-road access is prohibited within 1⁄4 to 1⁄2 mile 

south of the Scenic Loop Road (FR545) and between the OHV Area boundary and the 

sunset Crater Volcano boundary. According to our best statistics, an estimated 225,000 

visitors per year travel the Scenic Loop Road from Wupatki to Sunset Volcano, and 124, 

000 travel the other way (these statistics exclude local road use for other purposes). Our 

visitors are seeking the traditional national park experience of outstanding natural 

scenery, and many are out-of-state and international travelers. The scenic loop was 

designed and constructed to meet this purpose, and we believe that it was the intent of the 

original Coconino NF LMRP and 1991 Amendment to exclude ORV use adjacent to the 

Monument boundary and the loop road. To our knowledge, the 1991 Off-road Driving 

Management Plan Map shows the most recent decision pertinent to this issue. IF the 

OHV area boundary has been changed via another planning process, we would 

appreciate receiving a copy of the NEPA decision document. If this boundary change is 

deemed to be part of the current FLEA PA, we believe the change clearly has an adverse 

impact upon visitors to the National Monuments. This issue will likely generate 

considerable public controversy, and may require an EIS instead of an EA prior to your 

decision. 

Response: Nonsignificant Issue – Clarification. 

You are correct that the MA13 (Cinder Hills OHV Area) boundary shown in the 

Proposed Action is in error. We have found that our various GIS coverages do not match 

the hard copy map in the Forest Plan. We have had a meeting to discuss this and the GIS 

specialist will make the changes in the data, so that the MA13 boundary is the same as 

the hard copy map in the current Forest Plan, except for slight adjustments for 

administration. This change will result in the MA13 boundary being located 

approximately 1⁄4 to 1⁄2 mile south of FR545. This also then matches the current Forest 

Plan objective for a visual quality of foreground retention along this road. 

#100 P5 Scenery – Include the scenery along the Sunset Volcano-Wupatki Scenic Loop 

Road (FR545) and the Walnut Canyon Entrance Road as important to visitor experience 

in the “Summary of Purpose and Need” column. 

Response: Nonsignificant Issue – Clarification for the Summary of the Proposed Action. 

This summary is not planned to be published with the DEIS, rather was only a document 

used at the Proposed Action stage of the process. However, this text was added to the 

appropriate places in the replacement pages (located in Appendix A). 

#101 Roads and Off Road Driving: – For detailed comments on road policy and off-road 

use adjacent to the National Monuments, please refer to NPS scoping comments and 

maps submitted to Jim Anderson as part of the proposed multi-forest amendment and EIS 

(enclosed). Regardless of the decisions on the FLEA Amendment and Road Policy 

Amendment, we look forward to cooperating with the Coconino NF to develop action 

plans for limiting motorized vehicle access to the Wupatki, Sunset Crater Volcano, and 

Walnut Canyon NM boundaries. 

Response: NonIssue Comment – No disagreement with the PA. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

145 

#102 Wildlife Habitat: We concur with the proposed forest management changes to 

reduce fire risk in the Urban/Rural Influence Zone. The resulting habitat changes in this 

zone should not affect sensitive species within the monuments. 

Response: NonIssue Comment – Support for the PA 

#103 Correct the name from Deadman to Deadman Wash in the MA column 

Response: NonIssue Comment - Clarification. 

See corrected replacement page text in Appendix A. 

#104 We noticed that much of the discussion regarding each MA relates to issues and 

need. However, the discussion for the OHV Area doesn’t appear to address the existing 

issues as the same level. We suggest that more detail be provided. 

Response: NonIssue Comment 

Although there is no clear disagreement with the PA this comment suggests ways to 

improve the writing related to the Cinder Hills OHV Area. We will take this into 

consideration writing the EIS. In addition, a copy of the Cinder Hills Implementation 

Report has been provided to the NPS. 

#105 Recreational Opportunity Setting – In keeping with our comments and issues 

regarding motorized access to the monument boundaries, we would prefer to see “semiprimitive non-motorized objectives emphasized in a buffer area surrounding each of the 

three monuments. This includes the area surrounding the eastern end of Walnut Canyon 

NM, where we are very concerned about continued convenient motorized access within 

close proximity to the canyon rim, and potential impacts to archaeological sites and 

sensitive raptor species (Mexican spotted owl and northern goshawk) which nest in the 

canyon. This would also require revising the ROS Objectives map. 

Response: Nonsignificant Issue 

See the response under Alternatives Considered but Eliminated from Detailed Study 

section. 

#106 Page 20 4th paragraph: We are unaware of the outfitter/guide activities that are 

occurring today in the Deadman Wash and Walnut Canyon from Fisher Point east. Can 

you inform use about these activities? If there are currently none, we suggest changing 

the sentence from “do no place additional outfitter/guide activities...” to “Do not place 

any outfitter/guide activities... in [list sensitive MA’s or specific sensitive area within 

MA’s] that have no current activity.” 

Response: Nonsignificant issue 

At the time of this writing there are no outfitter guides operating in the Deadman Wash 

area, issued by the Peaks RD. However, the Tonto National Forest issues some 

Statewide permits for hunting. The text will remain as is. 

#107 P21-22. We concur with the proposal to prepare a rock climbing management 

plan. We are concerned that new routes are being pioneered within Walnut Canyon 

(including the tributary to Cherry Canyon), and are interested in participating in the FS 

planning process when it is initiated. 

Response: NonIssue Comment – Support of PA. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

146 

#108 P26 “Guidelines” 2nd paragraph: Change sentence to “consider impacts to 

viewsheds of the three National Monuments, the Sunset Crater Volcano-Wupatki Scenic 

Loop Road (FR545), and the Walnut Canyon Entrance Road...”. 

Response: NonIssue Comment – Clarification. 

Although the reason for this change is not given, we agree that this clarification should be 

added, which follows current Forest Plan direction related to these roads (See 

replacement pages in Appendix A). 

#109 P31 Land Exchange: In order to address NPS and public concerns about 

development threats to Walnut Canyon, strong emphasis should be placed upon retaining 

USFS jurisdiction over all lands between the proposed Flagstaff Urban Growth 

Boundary and the Walnut Canyon NM boundary, regardless of future development of 

non-USFS lands in the area. We also remain concerned about the potential long-term 

threat of base exchanges within the Walnut Canyon watershed below Lower Lake Mary 

(the enclosed Regional Planning Map for Walnut Canyon NM shows the watershed 

boundary to the west and south of the monument). 

Response: Nonsignificant Issue – Clarification and Conjecture. 

The response to the first part of this comment is to review the clarified text in the 

replacement pages of Appendix A. The Walnut MA includes additional language about 

retaining USFS ownership of lands between the growth boundary and the monument. To 

answer the second part of this comment, the likelihood of exchange of lands in the 

Walnut Canyon watershed (a subset of the Lake Mary Watershed) is very low. The 

replacement pages have been clarified to include reference to City and County growth 

boundaries and consultation with City and County prior to exchange (see Land Exchange 

section of the replacement pages in Appendix A). 

#110 p35-37 Watershed, Mountain Meadows and Riparian and Open Water... These 

sections clearly emphasize desired future conditions in the Lake Mary Watershed MA. 

We want to remind the public that the Lake Mary watershed was formerly the Walnut 

Canyon watershed. The public benefits derived from the municipal water supply and 

popular recreation opportunities created by the lakes come at the cost of permanent 

adverse impacts downstream of the lakes in the Walnut Canyon and Little Colorado 

River riparian ecosystems. Within Walnut Canyon NM, documented effects include 

declining riparian tree cover (including box elder, Arizona walnut, and narrow leaf 

cottonwood), loss of seasonally reliable water for wildlife, and degradation of the 

presettlement cultural landscape setting along the canyon floor within Walnut Canyon 

NM. Although we have not scientifically documented other impacts, we remain 

concerned about observed increased storm run-off intensity from the tributary canyons 

below the reservoir (Cherry Canyon, and potentially Fay and Skunk Canyons), and 

reduced groundwater infiltration and recharge of the localized seeps within the canyon 

and tributaries (especially the Cherry Canyon seeps). In order to mitigate as much of 

these impacts as possible, we would prefer that emphasis also be placed on maintaining 

optimum vegetation cover conditions within the canyon and tributaries (especially the 

Cherry Canyon seeps). In order to mitigate as much of these impacts as possible, we 

would prefer that emphasis also be placed on maintaining optimum vegetation cover 

conditions within the Walnut Canyon watershed below Lower Lake Mary. Mitigating 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

147 

downstream impacts of the lakes is also emphasized in the recently concluded general 

adjudication of the Little Colorado River Basin water rights between the City of Flagstaff 

and the United States. 

Response: NonSignificant Issue - Clarification. 

The Walnut Canyon watershed is a subset of the Lake Mary Watershed as identified for 

this analysis. Vegetative cover conditions are described in the current Forest Plan under 

Mexican spotted owl and goshawk habitat direction. The FLEA PA does not change this 

direction. Current direction speaks to a variety of forest structural stages, and also 

discusses ground cover, understory composition and diversity. In addition, a paragraph – 

a copy of the one at the bottom of P57 in the Lake Mary MA will be added to the Walnut 

MA – to emphasize watershed health (see revised replacement pages in Appendix A). 

#111 P38 Coordination with National Park Service Under guidelines add... siting and 

management of NPS facilities on Coconino NF lands, NHPA (section 106), NEPA, and 

ESA compliance coordination to the list of MOU items. The items listed here differ from 

those listed under the topic heading for the Cinder Hills OHV Area MA (page 46), 

Deadman Wash MA (page 52), and Walnut MA (page 72). 

Response: NonSignificant Issue – Clarification. 

The items listed in this comment were added to the replacement pages text (see Appendix 

A). The lists of coordination were clarified to be consistent between area-wide and 

management area direction. The coordination items listed in the FLEA PA are not meant 

to be an all-encompassing list of items for coordination. Rather they were intended to 

point out some additions or highlights to current coordination. The MA items were 

supposed to be additions or highlights specific to that MA. Per this refinement, the list 

will be changed. 

#112 General comment: In comparing this section to the earlier draft, it is apparent that 

many details and specific actions are not included in the PA. We have not received the 

referenced Roads Analysis Report – FLEA area and Cinder Hills Off-Road Driving Area 

Report. While we recognize that many of the issues will be addressed through the 

Arizona OHV Forest Plan Amendment process, the Roads, Analysis Report-FLEA Area, 

and the NEPA analysis for the Cinder Hills Off-Road Driving Area Report, we do think 

that it would be appropriate to retain some of the pertinent text form the draft PA. 

Examples include the discussions regarding the management of designated routes and 

the improvement, relocation, and closure of roads within the MA. Brief discussions for 

some of these topics would complement what already is presented in the document. If 

nothing else, specific reference should be made as to how the “desired condition:” will 

be validated or changed. 

Response: NonSignificant Issue Clarification. 

Chapter 3 of the DEIS describes additional details. The Cinder Hills Off-Road Driving 

Area report draft has been forwarded to the NPS. The Roads Analysis Report has been 

mailed to NPS staff. Corrections and update will continue to the data table and map. 

#113 General comment Geologists, ecologists, and anthropologists do not view the 

cinder craters areas as a static “moonscape,” but as the current state of eight centuries 

of geomorphic weathering, soils development, and vegetation pioneering processes since 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

148 

the Sunset Volcano eruption. These processes would ultimately result in the entire area 

being weathered to mature terrain and fully vegetated by forest and woodland vegetation. 

Scientific and public curiosity over these processes has led to the intensive study of recent 

volcanic activity all over the world, including Mount Saint Helen and the Hawaii 

volcanoes, and we are also proposing to interpret these processes in new exhibits at the 

Sunset Crater Volcano Visitor Center. Undisturbed control areas are needed in the area 

surrounding the Cinder Hills OHV Area in order to make valid scientific comparisons to 

understand the ecological sustainability of continuous perturbation by OHV use. While 

Sunset Crater Volcano NM and the Strawberry Crater Wilderness may be suitable as 

control areas, they are dominated by basalt flows and may not encompass enough cinder 

dominated area to account for the full range of landscape variability. In order to address 

this issue, we suggest that management emphasis be placed on increasing enforcement of 

existing off-road closures in the adjacent Deadman Wash and Craters Mas which are 

shown on the 1991 Off-road driving management plan map. 

Response: NonSignificant Issue - Conjectural: 

Current management direction and the FLEA PA do not preclude setting up control areas 

for study if needed. There is language in the current FLEA PA with emphasis on 

maintaining road and trail use so as to maintain ‘untracked’ areas, P48 and P49 directs us 

to discourage off trail use of any kind on large Cinder cones. The text will has been 

clarified to include this statement in the Deadman Wash MA as well. In addition, the 

word moonscape was changed to landscape in the area description (see replacement 

pages in Appendix A). The Forest Plan sets objectives for areas. 

#114 P43 – The OHV area boundary is also currently posted in the wrong location on the 

northwest corner near the monument boundary and along the scenic loop road. The 

language in the last sentence leads the reader to conclude that the FLEA PA is intended 

to legitimize this error. Please refer to the comments on the Cinder Hills OHV Area 

boundary map, above, for our rationale why the language in the last sentence is 

unacceptable. 

Response: Nonsignificant Issue – Clarification. 

See response to comment #99 

#115 “Reasons for closing areas may include: We suggest adding the following bullet: 

Excessive erosion to hills or slopes resulting in exposed roots and soil erosion and loss.

Response: Nonsignificant Issue – Clarification. 

This text addition was made, see replacement pages in Appendix A. 

#116 p43 3RD paragraph: We advocate establishing a recreation use fee program to 

ensure the Cinder Hills OHV Area remains a world class recreational area. Additional 

revenues are likely needed to meet the stated objectives of improving and maintaining the 

proposed facilities (signs, camps, loading ramps, restroom, bulletin boards, physical 

barriers at the limits of off-road travel), ensuring routine safety patrols, and restoring 

eroded slopes. Given our observations of user-behavior, facility vandalism, and resource 

impacts, all of these items are needed on recurring basis. ... 

Response: Nonsignificant Issue – Support for PA. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

149 

#117 P44 “recreational signing”: The FLEA PA document presents a good opportunity 

to inform the public that the USFS is cooperating with the NPS to construct a physical 

barrier at the limits of off-road travel along the north boundary of the recreation area. 

We believe that language should be added giving the USFS the option of constructing 

physical barriers to define open travel areas if other attempts to gain user compliance 

fail. 

Response: Nonsignificant Issue – Clarification. 

See PA text clarification in replacement pages in Appendix A. 

#118 P45 Cultural/Historical: We suggest that the following statements be added to this 

section: “Conduct active monitoring of cultural resources to assess impacts from 

recreation and other human uses. Changes in management can occur in response to 

demonstrated adverse impacts.” 

Response: Nonsignificant Issue – Clarification. 

The same paragraph relating to cultural resources in the area-wide direction and some of 

the other MA’s has been added to this MA (see appendix A replacement pages). 

#119 P45 “Noxious Weeds”: Camelthorn is present in the Deadman Wash MA and may 

be expanding its range into the Cinder Hills and Crater MA’s 

Response: NonIssue Comment – Clarification. 

Added to text, see replacement pages in Appendix A. 

#120 P46 “Coordination with the National Park Service”: We suggest that statements 

be added to: (1) allow the NSP inventory, map, and assess conditions of specific geologic 

features associated with the Sunset Volcano eruption (which may form the basis of a 

geologic interpretive program), and (2) address interagency efforts to establish physical 

barriers at the limits of off-road travel on the north boundary of the recreation area. 

Response: Nonsignificant Issue – Clarification. 

A sentence was added to the replacement pages (see Appendix A) adding inventory, 

mapping and condition assessment and the use of physical barriers to the list of activities 

that could occur in this MA. 

#121 P47 3rd paragraph “Roads within the OHV area...” After reading this paragraph 

we are unsure of the continued USFS commitment to close FR776 to through traffic south 

of the Scenic Loop Road (FR545) or to gate FR 414 near Lenox Crater, which we 

understood were specific action items in prior drafts. 

Response: Nonsignificant Issue – Clarification. 

A sentence was copied from the Cinder Hills Implementation Report to the replacement 

pages in Appendix A. 

#122 Deadman Wash MA: General comment: Again, while we recognize that many of 

the issues regarding roads will be addressed through the site-specific analysis associated 

with the Roads Analysis Report-FLEA Area, we do think that it would be appropriate to 

include some broad objectives and guidance for the improvement, relocation, and closure 

of roads within this MA. As stated in our October 1999 correspondence on an earlier 

draft of the FLEA PA, we still strongly recommend the USFS protect significant cultural 

resources through strategic land-use withdrawals in this MA. If nothing else, more 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

150 

specific reference should be made as to how “desired conditions” will be validated or 

changed. 

Response: Nonsignificant Issue – Clarification and Conjecture. 

The paragraph on watershed health and roads that is currently written in the Lake Mary 

MA has been copied to the Deadman Wash MA (see replacement pages in Appendix A). 

Some of the criteria for reasons to close roads includes: Areas of important cultural 

resource sites vulnerable to damage that are being threatened or damaged, habitat for 

threatened, endangered, or sensitive species that is threatened, key wildlife areas being 

threatened or damaged, areas important to wildlife reproductions such as fawning or 

nesting areas, where disturbance is causing, or likely to cause, significant stress and 

reduction of reproductive success, semi-primitive non-motorized ROS objectives as set 

through environmental analysis, areas where the road system modifies the surface and 

subsurface hydrology, roads, which cause the introduction or spread of exotic plant 

species, insects, diseases, and parasites, and Redundant roads. These criteria provide the 

objectives and guidance for this and other MA’s. The ROS objectives are another form 

of guidance for the MA. Land use withdrawals mentioned in the October 1999 letter 

were mineral withdrawals. At the time this was considered, District efforts focused on 

the San Francisco Mountain Mineral Withdrawal. The analysis of additional areas was 

too much for staff to accomplish at that time. The NPS could bring forward proposals for 

consideration in separate analysis. Other types of land-use withdrawals such as removing 

domestic livestock grazing, firewood gathering, or pinyon nut gathering, to name some 

examples, were not deemed necessary at this time. The FLEA PA emphasizes 

monitoring of impacts and making changes based on the results of monitoring. The 

FLEA PA does not set precedent for, nor does it preclude future options. 

#123 Deadman Wash MA – “Description” This section should acknowledge that 

juniper densities have greatly increased during the last 100 years, and are encroaching 

into former grassland habitat for pronghorn and other grassland-dependent species. 

Response: NonIssue Comment – Suggestion for clarification. 

The FLEA PA does not propose changing current Forest Plan language related to MA10 

grassland with sparse pinyon and juniper. The management descriptions for MA 6, 7 and 

10 that are currently written in the Forest Plan still apply. These pages speak to the 

situation of increasing juniper densities and distributions. In the FLEA PA we emphasize 

the need to refer back the MA10 direction especially, because of the need to maintain and 

enhance grassland habitats for pronghorn and other species. 

#124 P50 Management emphasis”: We concur with the management emphasis on 

pronghorn, and wonder if this Species is formally designated as a MIS for the Colorado 

Plateau grassland habitat type. 

Response: NonIssue Question. 

In the current Forest Plan, pronghorn antelope is a management indicator species for the 

Coconino National Forest MA10 Grasslands and Sparse Pinyon Juniper. The FLEA PA 

does not change this. The Forest Plan does not make MIS designations for grasslands 

outside of the Coconino Forest. 

#125 P52 “Cultural/Historical,” 1st sentence... historical sites to assess impacts from 

recreation...” 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

151 

Response: NonIssue Comment – Clarification. 

This word was added to the sentence in the replacement pages in Appendix A. 

#126 P52 Coordination with NPS – Additional issue/topics include fencing 

placement/removal needs and issues and proposed minor administrative boundary 

adjustments. 

Response: NonIssue Comment – Clarification. 

These items were added, see the replacement pages in Appendix A. 

#127 Although we have not commented on this issue in prior scoping, we recommend 

that a “watershed management” topic be added. We are concerned about the decline of 

flows from Heiser Spring and Peshlaki Spring at Wupatki NM, which provide the only 

year-round sources of water for wildlife within the monument. Although the springs at 

Wupatki have been impacted by historic uses, we are in the initial stages of restoring 

them to presettlement conditions. According to hydrological studies, these springs are 

fed from a local, perched aquifer that is recharged via the basalts capping Woodhouse 

Mesa, immediately south of the monument boundary in the Deadman Wash MA. As with 

much of the MA, vegetation on Woodhouse Mesa has likely changed over the last century 

from open juniper grassland to dense juniper woodland with near barren cinder 

interstices. We believe restoring healthy vegetation cover within the recharge area is 

critical to maintaining flows at the springs. 

Response: Nonsignificant Issue – Outside scope. 

The current Forest Plan and the FLEA PA text do not preclude a future site-specific 

project to treat vegetation in the area described. This would a site-project. Please contact 

Alvin Brown or the District Ranger, Gene Waldrip, to discuss placing such a project on 

the District program of work. 

#128 Given the recent conclusion of the adjudication of water rights in the Little 

Colorado River Basin between the City of Flagstaff and the United States, and the 

resulting agreement between the City of Flagstaff, FS and NPS (pursuant to the 

stipulations), additional management emphasis and guidelines should be presented to use 

best management practices for livestock grazing, timber harvesting, road draining, and 

recreational activities to maintain municipal water supply values, and to evaluate the 

methods that may improve the inner-canyon environment in Walnut Canyon. 

Response: NonSignificant Issue – Conjectural. 

Adjudication has not concluded. As mentioned in this comment, an Intergovernmental 

Agreement has been signed between the City of Flagstaff, Forest Service and National 

Park Service. A reference to this agreement has been added to the replacement pages 

(see Appendix A). The use of Best Management Practices is already described in the 

current Plan with no changes proposed under FLEA. Per the agreement, best 

management practices will be identified for implementation of site-specific projects that 

that are consistent with municipal values. 

#129 Page 57 comments – As stated in our October 1999 correspondence on an earlier 

draft of the FLEA PA, the public should be provided more back ground information on 

the history and purpose of the lakes, and the respective management responsibilities of 

the USFS and City of Flagstaff for the lakes and dams. Our comments for pages 35-37 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix B – Comment Analysis and Response To Comments

152 

(“Watershed”, “Mountain Meadows”, and “Riparian and Open Water” Objectives) 

above, also apply here. 

Response: Nonsignificant Issue – Clarification and Outside the Scope. 

The management of the dams is outside the scope of the FLEA analysis. The FLEA PA 

does not change the Forest Plan related to the dams, so information on this topic is not 

needed in the NEPA document. Existing Recreation use and conditions of the lakes and 

use of the lakes by the City of Flagstaff is described in the Ideas for Change, which is to 

be used as a reference document for the PA. The history of the lakes and dams is not 

relevant to the NEPA analysis because the scope of FLEA is limited to small 

management changes to existing recreation. 

#130 Walnut Canyon Management Area: General Comment: We strongly concur with 

the proposed management emphasis for this MA. 

NonIssue Comment – Support for PA. 

#131 P70 “Highlights” Our comments for pages 35-37 (“Watershed”, “Mountain 

Meadows”, and “Riparian and Open water” Objectives) and for the Lake Mary 

Watershed MA above also apply here (Walnut MA) 

Response: See Response #110 

#132 Page 69 Our comments for Page 15, “Recreational Opportunity Setting” and the 

Recreational Opportunity Spectrum Map, above also apply here (Walnut MA) 

Response: See Response #105. 

#133 Page 70, “Highlights”, 4th bullet: the 2nd sentence should be corrected to reflect 

concern for wildfires started southwest of Walnut Canyon NM 

Response: NonIssue Comment – Clarification. See replacement pages in Appendix A. 

#134 Non-motorized and Motorized Trails – we propose specific emphasis be added for 

reducing all road access to within one mile of the Walnut Canyon rim (not the NM 

boundary). This would effectively deter access to the canyon slopes, cliff dwellings, and 

sensitive raptor nest sites throughout the canyon, preclude clandestine access via the 

heavily vegetated side canyons, and increase our ability to enforce general access 

restrictions within Walnut Canyon NM.

Response: Significant Issue. 

Under the PA, the Walnut rim is buffered by a semiprimitive nonmotorized polygon 

places roads as far away as 1 mile from the rim in some areas, and as close as 1⁄4 mile 

from the rim (FR301) in others. One alternative will be considered that changes the ROS 

objective to SPNM for a greater distance from the rim but allows FR301 to remain open. 

One alternative will be considered that changes the ROS objective to SPNM without 

FR301 thus creating an area over 1 mile from the rim with no open roads. We prefer to 

use the ROS map instead of a straight 1-mile criterion. Roads may suited farther away 

than 1 mile, or slightly less than 1 mile. The objective described in the FLEA PA is to 

consider the overall protection of the values mentioned in this comment. 
153 

APPENDIX C - Background Information For 

The Forest Plan 

 

National Forest System Land and Resource Management Planning regulations, 36 CFR 

Part 219, set forth a process for developing, adopting, and revising land and resource 

management plans. It states “the resulting plans shall provide for multiple-use and 

sustained-yield of goods and service... in a way that maximizes long-term net public 

benefits in an environmentally sound manner”. Plans determine resource management 

practices, levels of resource production, and management and availability and suitability 

of lands for resource management. The Forest Plan is a permissive document, which 

allows activities to occur rather than requiring activities to occur. There are 6 decisions 

that Forest Plans make. These are based on laws, regulations, and clarification from 

litigation. A Forest Plan establishes: 

Forest-wide multiple-use goals and objectives - Most of the Forest-wide goals and 

objectives will remain the same, with some refined goals and objectives language specific 

to the FLEA area. 

Management Area direction - New MA’s have been created or original MA’s have been 

adjusted. 

Lands suited/not suited for resource use and production - We will not review suitability 

for timber or range under the FLEA process, as that is more appropriate for the Forest 

Plan revision, that is currently scheduled to begin in 2006. 

Forest-wide management - We have reviewed Forest-wide standards and guidelines and 

developed additional management direction for the FLEA area. 

Monitoring and evaluation - Current monitoring and evaluation in the Forest Plan will 

be retained and additional items are added for the FLEA area. 

Recommendations for wilderness or wild and scenic rivers - There are no recommended 

changes for management direction for wilderness (Strawberry Crater Wilderness lies 

within the FLEA area) and there are no wild and scenic stream segments in this area. 

Definitions for Goals, Objectives, Standards, and Guidelines 

Goals

A goal is defined as “a concise statement that describes a desired condition to be 

achieved sometime in the future... it has no specific date by which it is to be completed.” 

(36CFR219.3). Goals have been identified for each resource element. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix C – Background Information for Forest Plan

154 

Objectives

An objective is defined as “a concise, time-specific statement of measurable, planned 

results that responds to pre-established goals” (36CFR219.3). Forest objectives are 

quantitative; they can be measured. They are completed in a given time and with a given 

budget level. The objectives are needed to meet mission and goal statements and are 

consistent with the missions and goals. Objectives are the annual activities implemented 

to accomplish the goals and to help address the issues. 

Standards54

Standards are limitations on management activities, a principle requiring a specific level 

of attainment, and a rule to measure against. Standards are limited to those actions that 

are within the authority and ability of the agency to meet or enforce. 1) Standards are 

the basis for determining whether a project is consistent with the Forest Plan as required 

by 36CFR 219.11(a). 2) Project compliance with relevant standards is mandatory. A 

project that would vary from a relevant standard may not be authorized, unless the 

Forest Plan is amended to modify, remove, or waive application of the standard. 

Guidelines55

Guidelines describe a preferred or advisable course of action, desired policy or conduct. 

Variation of a project from a guideline does not trigger a Forest Plan amendment. 

Guidelines may be used for the following purposes: 1) To describe a preferred or 

advisable method for conducting resource activities specific to the Forest Plan area and 

2) to describe a preferred or advisable sequence or priority for implementing various 

types of projects when such guidance is deemed useful in facilitating achievement of a 

Forest Plan goal. 

Coordinating Requirements 

The Coordinating Requirements section of the current Coconino Forest Plan describes 

Integrated Resource Management (IRM) as an interdisciplinary approach to project 

design and implementation that recognizes the complex biological, administrative, and 

political interrelationships on the Coconino National Forest. In addition, Integrated 

Stand Management (ISM) is a concept for designing complex vegetation treatments by 

identifying the stand (or portion of a stand) to be treated and incorporating within its 

treatment prescription consideration for all the appropriate resources. ISM also 

recognizes that all vegetative communities within a given area are interrelated and 

therefore, stands that are proposed for treatment must be INTEGRATED with each other 

and with the surrounding area. 

 

54 This definition has been used for previous Forest Plan Amendments on the Coconino National Forest 

Amendment 12, page 274 

55 This definition has been used for previous Forest Plan Amendments on the Coconino National Forest 

Amendment 12, page 272 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix C – Background Information for Forest Plan

155 

Mission Statement 

As stated on page 21 of the Forest Plan “A mission is a guiding principle toward which 

activities focus and contribute.”... “The mission of the Forest Service is to manage 

National Forest lands and resources using the best systems available to meet the needs 

and desires of present and future generations, while protecting and enhancing the 

environment and effectively and efficiently administering Forest programs. Conflicts 

over allocating resources are inevitable and will increase. The management challenge is 

to be responsive, equitable, efficient, and understanding in making resource management 

decisions.” 

Outputs and Range of Implementation 

There are forces that can affect the production of outputs and implementation rates, such 

as weather, budget appropriations from Congress, local economies, and political 

decisions. This amendment, in conjunction with the current Forest Plan is used as the 

basis for developing budget proposals. The FLEA area is only a portion of the Forest 

and priorities for FLEA will be balanced with other Forest priorities. 

Background Information On Other Planning Efforts In The 

Region 

Other planning efforts in the Region are listed below with a note about their relationship 

to the FLEA process. 

Cross-country Use of Motorized Vehicles in Five Arizona National Forests. – We have 

deferred changes to the off-road travel and travel management to this analysis. This 

analysis is running parallel to FLEA. Contact: Jim Anderson (928) 333-6370 – 

janderson08@fs.fed.us 

Roads Analysis Report – FLEA Area – This proposed action contains criteria for road 

management. The Roads Analysis for the FLEA area, applies these criteria in the form of 

a database and map. Subsequent site-specific NEPA analysis will make decisions about 

the future management of any particular road. The Roads Analysis for the FLEA Area is 

a document that outlines desired known open road network and maintenance levels based 

on the FLEA analysis; it is not a NEPA decision. It will be continually updated based on 

new information or site-specific decisions. 

Roads Analysis – Maintenance Level Three and Above – Coconino and Kaibab 

National Forests – Information from the FLEA roads analysis will be available for this 

analysis, that will outline the desired road networks for forest roads designed for 

passenger car travel. It will cover the entire Coconino and Kaibab National Forests. 

Contact: John O’Brien (928) 635-8371 

Integrated Treatment of Noxious and Invasive Weeds – Develop actions to control 

noxious and invasive weeds, including the application of herbicides and a variety of nonchemical methods for the Kaibab, Coconino, and Prescott National Forests. A decision 

is anticipated spring of 2002. Contact: Dave Brewer (928) 635-8221 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix C – Background Information for Forest Plan

156 

Livestock Allotment Analysis – In the FLEA area, 139,461 acres are closed to grazing 

by domestic livestock (not within a designated allotment) and various Allotment 

Management Plans cover 236,516 acres. These plans are either completed or we are in 

some stage of analysis. Contact: Mike Hannemann (928) 526-0866. 

Flagstaff Area Regional Land Use and Transportation Plan – This Plan updates the 

Coconino County Comprehensive plan on lands surrounding Flagstaff. This plan also 

covers the City of Flagstaff was ratified by voters on May 21 2002 as required under 

Growing Smarter legislation recently passed in Arizona. Contact: Ursula Montaño, City 

of Flagstaff, (928) 779-7685. 

Centennial Forest – The Centennial Forest was established in April 2000 through an 

intergovernmental agreement between the Arizona State Land Department and Northern 

Arizona University, to provide for forest health restoration, research, and management. 

Some Centennial Forest Parcels (State Land Sections) lie in the FLEA area. Contact: 

www.for.nau.edu/CentennialForest

Greater Flagstaff Forests Partnership – The Grand Canyon Forests Foundation (a 

nonprofit organization) and the Coconino National Forest have established a 

Cooperative Agreement to work together to demonstrate new forest management 

approaches in improving and restoring the ecosystem health of the ponderosa pine forest 

ecosystem where urbanized areas interface with National Forest lands (Flagstaff 

Urban/Wildland Interface). This cooperative effort seeks to involve the greater Flagstaff 

community extensively to develop a community-based solution to local forest health 

problems. This cooperative project is called the Greater Flagstaff Forests Partnership 

(previously called the Grand Canyon Forests Partnership). Contact Brian Cottam 

(928) 226-0644. 

National Park Service General Management Plans for Walnut Canyon, Wupatki and 

Susnset Crater National Monuments - The National Park Service has prepared three 

Draft Environmental Impact Statements, one for each Monument. These statements 

describe updated language for each Monument’s General Management Plan. They will 

guide future management of the Monument areas. Contact Sam Henderson, (928) 526-

1157 
157 

Appendix D - Explanation of Nonsignificant 

Amendment 
United States 

Department of 

Agriculture

Forest 

Service 

Coconino 

National Forest, 

Supervisor’s Office 

2323 E. Greenlaw Lane 

Flagstaff, AZ 86004-1810 

Phone: (928) 527-3600 

Fax: (928) 527-3620

158 

File Code: 1950 Date: July 25, 2002 

Route To: 

Subject: Determination of Non-Significant Amendment to the Coconino Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

To: The Files 

 

 

The FLEA project has created a Proposed Action (PA) to amend the Coconino National Forest 

Management Plan. Based on the contents of the PA, this amendment will not be significant 

under NFMA (36 CFR 219.10 (f)). 

FLEA has been an identified project for 4 years. Over that period of time the scope of the 

project has changed quite a bit. The amount of focusing and narrowing of the FLEA project has 

reduced the complexity of the task from the original topics that were scoped in 1998 and 1999. 

This project has been on hiatus for a variety of reasons: The worst fire season in 50 years 

(2000), the roadless policy evaluation under the Clinton administration (late 1999 and 2000), and 

conflicts in the scheduling of scarce human resources with other higher priority projects (range 

land management and the National Fire Plan projects). 

The ID Team did a lot of iterative scoping with local publics and groups in order to craft a 

specific and clear PA for the management of lands surrounding Flagstaff Arizona. Some sitespecific projects that had been scoped with FLEA have been separated from this project and are 

either proceeding on their own with NEPA or waiting for a proponent. One of the larger scale 

FLEA-wide topics (off-road driving policy) is being analyzed with a concurrent multi-forest 

project and has been removed from FLEA. The remaining topics for FLEA are focused on the 

amelioration of effects due to increased recreational use and projected demands on the lands 

immediately surrounding Flagstaff and a reduction of the fire hazard on these same lands. In 

addition, to create a sense of place, new management areas have been identified with varying 

management emphases. There are not many changes presented in the PA, but there is additional 

direction for clarification or for filling voids of the current Forest Plan. There are some topics 

upon which the Plan was silent and there is a need for consistent direction throughout the FLEA 

area that also needs the durability of Forest Plan status. For more information, see the Proposed 

Action to Amend the Coconino Forest Plan.

FSM 1909.12.5.32 – Process to Amend the Forest Plan, indicates 4 factors to consider when 

evaluating whether or not an amendment is a significant amendment under NFMA: Timing; 

location and size; goals, objectives, and outputs; and management prescriptions. 

The timing factor considers whether or not this change will occur during the life of the Forest 

Plan, or does the change occur in the future beyond the scheduled time for the next revision. The 

changes and clarification the PA contains are meant for immediate implementation, therefore, 
159 

The Files 2 

they meet the basic qualification of an amendment. At this time, the Revision is scheduled to 

begin in 2006 and will take from 3 to 5 years to complete. 

Location and size factor are meant to evaluate the relationship of the affected area to the overall 

planning area. FLEA covers approximately 300,423 National Forest acres, which is 16 percent 

of the Coconino National Forest (approximately 1,8420,100 acres).56 

The goals, objectives, and outputs factor considers whether or not the long-term relationship 

between the levels of goods and services projected by the Forest Plan will be changed with this 

amendment. FLEA does not change the land suitability definitions in the Forest Plan. The 

outputs that FLEA provides are essentially within those effects described by the Regional 

Amendment (1996) FEIS, because we are following that direction. There is little change in the 

number of recreational visitor days (RVD), however, the types of RVD’s will likely change as 

implementation occurs. The ROS setting changes in the PA reflect a change from the 1987 

Forest Plan for this areas original inventory. However, the changes represent a small percentage 

change Forest-wide. The change in FLEA is towards more semi-primitive settings. 

The management prescription factor is meant to evaluate whether or not the change for the 

standards and guidelines is meant to be planning area wide or for a specific part of the planning 

area. FLEA’s PA is meant to only apply to the FLEA area and not beyond to other Forest 

locations. Most standards and guidelines are in addition to the existing Forest Plan direction, 

rather than a change or replacement. There are only a few changes that apply to the FLEA area 

only. 

Though I feel these are important changes to make in our Forest Plan for the lands surrounding 

Flagstaff, when viewed in context of the entire planning area (Coconino National Forest), I do 

not feel the PA contains changes to the current Forest Plan that can be deemed as significant 

from an NFMA viewpoint. Therefore, this analysis will follow the appropriate public 

notification and satisfactory completion of NEPA procedures 40 CFR 1500 (CEQ regulations) 

and will fall under the 36 CFR 215 appeal regulations for the Forest Service. 

Sincerely, 

/s/ Jim Golden 

JIM GOLDEN 

Forest Supervisor 

 

56 These averages are from the current Forest landownership data coverage. 
 

160 
161 

Appendix E - Summary of Development of 

ROS Objectives 

A landscape analysis process was used to determine the boundaries of the MA’s and to 

identify ROS objectives. The process was modeled after the USDA Forest Service, 1992 

Forest Landscape Analysis and Design, Pacific Northwest Region. 

The first step undertaken by the interdisciplinary team was to describe existing on-theground conditions and existing management policy. Various topics were displayed on 

GIS maps including fire potential, fire management zones, forest type, forest structure, 

camping policy, dispersed sites, roads, trails, recreation opportunity spectrum (ROS) 

setting, land ownership, threatened, endangered and sensitive species habitat, wildlife 

travelways, and wildlife reproductive areas. Overlaying these maps provided a picture of 

the overall landscape. 

When overlaying the wildlife habitat and ROS maps we noted many areas where 

Semiprimitive Motorized and Nonmotorized recreation settings matched key wildlife 

reproductive areas or sensitive species habitat. Adding the main passenger car roads and 

wildlife travelway showed how people and wildlife accessed and moved through the 

areas. Adding the land ownership layer showed those lands highly influenced by 

residential areas. 

The initial sets of lines were refined with the addition of the fire management zone map. 

This map displayed residential/forest interface areas in need of fuels management to 

reduce the risk of future catastrophic fire. MA boundaries were adjusted so that lands 

categorized as urban interface were located within the MAs that surround the private 

developed lands. A more open forest where fire plays a more natural role became an 

objective for the residential influenced MA's and especially the Fire Management 

Analysis Zone 1U. This objective was already described for the most part in current 

Forest Plan direction. 

The Team gave each set of lands surrounding a particular residential area its own 

management area. The result was 12 potential "new management areas". 

Then the Team reviewed the current recreation settings (ROS) for each of the MAs. We 

then asked ourselves what the desired recreation settings should be. In many places the 

desired recreation setting stayed the same as current, and in some places the desired 

setting was different. Expected future residential development influenced the way 

desired recreation setting categories were drawn. For this analysis, we chose to include a 

desired recreation setting of "semiprimitive" even in places with high numbers of people. 

We have differentiated between those semiprimitive motorized and nonmotorized places 

where we expect high numbers of people and those with low numbers of people. It is 

also important to note that the Forest Service ROS categories do not exactly match those 

listed in the Flagstaff Open Spaces and Greenways Plan, however the concepts are 

similar. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix E – Summary of the Development of ROS Objectives

162 

Given the ROS objectives, wildlife habitat needs, and recreation opportunities desired, 

the Team identified a framework of passenger car Forest Service roads. Then they 

discussed overall density goals for secondary roads. The desired recreation and road 

objectives complemented many wildlife habitat needs. 

For each proposed MA the Team briefly described recommendations for camping, road 

and trail densities, and forest conditions. Additional meetings were held to refine 

proposals and discuss other needs. 

Discussions were conducted regarding the status of current direction from Amendment 

11 to the Forest Plan. These discussions along with information from the Fort Valley 

Analysis (in cooperation with the Grand Canyon Forests Partnership) resulted in a 

refined description of proposed future forest conditions surrounding residential areas. 

The watershed and range management specialists and the botanist provided additional 

information on watershed health and noxious weeds. 

Finally, we reviewed the unique sites that are visited by many people, and through 

meetings with appropriate staff, Arizona Game and Fish Department and individuals, we 

crafted site-specific proposals for these sites. These site-specific proposals each have or 

will undergo separate NEPA analysis. 

The outcome of this effort has been a discussion of the interplay between current patterns 

of human use, wildlife use, and fire potential along with biological capabilities of this 

landscape. Also considered were the Flagstaff Open Spaces and Greenways Plan and the 

Vision 2020. 
163 

Appendix F - Crosswalk from Ideas for Change 

to DEIS 

The Ideas for Change was published in May of 1999. 

Table 14 Summary of the Disposition of Items in the Ideas for Change 

Item Page# Disposition 

Vision for the Future 2 Current Forest Plan Mission (p21) although somewhat old, 

still fits. Better to have a Forest-wide vision than separate 

vision for FLEA area. Wait for Forest Plan revision. 

Background, Trends, and 

Needs 

Chp2 Good summary of information and trends to be used as 

reference for FLEA PA and other projects. Future on the 

ground projects need to verify existing conditions based on 

data specific to that area. Good tool general discussions with 

public. 

MA Descriptions and 

Desired Conditions 

61-69 MA’s were consolidated and much of the desired condition 

information transferred into management emphasis57 in the 

replacement pages (Appendix A).58 

Forest Health Proposals for 

Change 

70-74 The idea of a desired condition very different from current 

goshawk habitat direction (Amendment 11) was discarded. 

This was partly due to misconceptions among team members 

of what the guidelines actually allowed. A concept of 

progressing towards goshawk habitat conditions more 

aggressively in a zone around developed areas was carried 

forward as the Urban/Rural Influence Zone. 

Access Proposals For 

Change – Road Policy 

Viewpoints 

77-78 These pages give a good overview of the differences of 

opinion about off road driving policies. Neither policy was 

carried forward in the DEIS. This topic was deferred to the 

Cross-country Use of Motorized Vehicles in Five Arizona 

National Forests planning process. A Forestwide policy is 

more effective than a cookie cutter policy for the FLEA area 

only. 

Access Proposals for 

Change – Proposal 

Common to All New 

Management Areas 

78-80 Many of these ideas were carried forward in the DEIS. 

 

57 The language related to singing and information was not carried forward. Perhaps an oversight on our part 

– this language describes levels of contact with FS personnel, tools for sharing information and level of 

‘advertisement’. 

58 Forest conditions in the Ideas for Change are described very generally. Upon further review these 

descriptions are best met by the current Forest Plan direction for goshawk habitat. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

164 

Item Page# Disposition 

Access Proposals for 

Change – Proposals for 

Each New Management 

Area 

81-94 The ROS objectives carried forward into the DEIS with some 

slight adjustments. Many of the remaining ideas are sitespecific and are not carried forward in the DEIS. A roads 

analysis report is in draft form that captures this information 

as desired conditions with implementation dependent on sitespecific analysis and decision. Some items have been 

implemented (see the list below). 

Access Proposals for 

Change – Cinder MA and 

OHV Area 

95-97 Site-specific items were carried forward and additional items 

added in the Cinder Hills Implementation Report – on file at 

the Peaks District Office – contact Debbie Kill or Lori 

Denton. This report is not a NEPA decision but a list of 

actions to consider is site-specific analysis. 

Overall desired conditions are in the DEIS with a mix of 

viewpoints 2 and 3 being the final outcome. 

Unique Sites with High 

Visitation – Priest Draw, 

Canyon Vista, Pumphouse 

Wash, Old Caves Crater 

98-106 All of these projects were not carried forward in the DEIS. 

Some have been implemented or are ongoing – see list below. 

Environmental Study Areas 107-109 Elden and Griffiths Springs ESA’s are carried forward in the 

DEIS. Lake Mary ESA idea was dropped from further 

consideration. This was an idea brought forth from the public, 

however, schools were not linked to this site. 

Snowplay Sites 110 Dropped from FLEA analysis. SnowPlay sites may be 

considered as a separate project on the District if a proponent 

or other agency or organization comes forward with support. 

Outfitter/Guides 112-113 Carried forward in DEIS – funding for special use and 

outfitter/guide permit administration continues to be less than 

adequate. 

Camping 114-115 Carried forward in DEIS. 

Motocross 116-117 Per direction from Forest Supervisor motocross is described in 

DEIS as outside the mission of Forest Service and best suited 

to lands in other ownership. 

Noncommercial Group 

Uses 

118 Option 3 was carried forward (regulation of requiring groups 

of 75 or more to get a permit). However, the District still 

encourages groups of 25 or more to voluntarily get a letter of 

agreement from the District. 

Special Use Events 119 Current Forest Plan did not require change to continue to 

approve Special Use Events on a case-by-case basis. 

Commercial Use Special 

Uses (Forest Products) 

119 Lack of good data and other priorities resulted in this topic 

being placed on hold until the Forest Plan revision. 

Recreation Information and 

Education 

120 The methods discussed in the Ideas for Change are already 

allowed under the current Forest Plan. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

165 

Item Page# Disposition 

Mineral Withdrawals 120-121 The San Francisco Mountain Mineral Withdrawal has been 

accomplished via a separate analysis and decision. Other 

mineral withdrawals in the FLEA are dropped from further 

consideration. Mineral withdrawal analysis and decision is 

extensive and costly. There are no locatable minerals to date 

in these sites so the risk of large-scale mining under the 1872 

mining law is small. Nonlocatable mineral use will continue 

to be administered by FS under current Forest Plan direction. 

Land Exchange 124 Carried forward in DEIS 

Electronic Sites 125 Forest Plan amendments related to electronic sites are ongoing 

under separate analysis (see list below). 

Marshall Lake 126-127 Not carried forward in DEIS because site-specific project. 

Not yet added to District program of work as of FY02. 

Lower Lake Mary 128 Parking management carried forward to DEIS. Fence 

maintenance allowed under current Forest Plan. Idea for 

creating a pond was discarded after public input and analysis. 

Upper Lake Mary 130 Parking, camping and sanitation carried forward in DEIS 

Riparian Springs and 

Drainages in the Lake Mary 

Watershed 

131 General discussion carried forward in DEIS. Specific 

implementation deferred to site-specific analysis. 

Walnut Recreation Area 

Name Discussion 

132-133 Carried forward in DEIS with Walnut Management Area as 

the name. 

Completed or ongoing site-specific projects 

• Old Caves Crater (completed on-the-ground) 

• Priest/Howard (ongoing) 

• Cinder Hills small stuff (portions are currently being implemented on-the-ground) 

• Marshall Lake (coming up) 

• Griffiths Spring (completed on-the-ground) 

• Road obliteration in Deadman Area (completed on-the-ground) 

• Strawberry Trail and Trailhead and Wilderness Implementation Schedules (completed 

on-the-ground) 

• Kachina Village analysis, includes Pumphouse wash (ongoing) 

• San Francisco Mountain Mineral withdrawal (completed) 

• New metro hunt unit hunting regulations (completed) 

• Fort Valley Roads and Trails (ongoing) 

• Freidlein Prairie Road Designated Dispersed Camping (completed on-the-ground) 

• Wireless Communication along the I-17 corridor (currently being implement on-theground)
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

166 

The evolution of this project from the Ideas for Change to the Proposed Action 

The interdisciplinary team assumed a 10-year window between FLEA and the completion of 

Forest Plan revision. The following is a summary of the assumptions and conclusions that 

resulted from these discussions. Changing priorities placed an emphasis on finishing the 

FLEA analysis as soon as possible. 

Below is a summary of discussions held to determine which items to carry forward in the 

Proposed Action. 

There is probably nothing in FLEA related to vegetation management that we “can’t live 

without” until the Forest Plan revision. There ARE items related to recreation that are 

needed NOW, and cannot wait for Forest Plan revision. There are other items (watershed) 

that are low risk and will be helpful to complete now rather than waiting for revision. 

A majority of desired conditions for fuels treatment can be achieved in the Urban 

Interface under current Forest Plan direction. This is because the majority of the 

stands to be treated are VSS3. Aggressively thinning VSS3 stands and opening up 

canopies is allowed under current guidelines. We have discussed desired conditions 

and treatment parameters that work for this area and are consistent with Forest Plan. 

We have looked at this specifically for FLEA and both range and average is within 

what was modeled for the Forest Plan. There are only two MSO PACs that lie within 

the Urban Interface and they do not need treatments at levels that require amended 

Forest Plan language between now and the planned Forest Plan revision. 

What about sustainable timber production, minimal stocking levels and regeneration 

requirements? 

These things are Forest-wide requirements and the Urban Interface of FLEA is a 

small portion of the Forest total. We do not need to change these things for FLEA. 

All of the previous timber components 500 are changed via Amendment 11 to some 

form of 600. There may need to change timber components to track management 

emphasis changes such as in the U/RIZ. FLEA does not change suitability definition 

used in the Forest Plan. 

There are points of clarification that will help alleviate internal Forest Service debates about 

implementing Amendment 11 (owl and goshawk guidelines). 

Rather than carry these points through the NEPA process, the group recommended a 

Forest-wide letter, signed by the Forest Supervisor be prepared that documents 

internal agreement on the Forest. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

167 

There is some clarification language that is low-risk for generating issues and would be 

helpful to include in the Plan. These paragraphs are mostly related to Mountain Meadows 

and Watersheds in the FLEA area. 

The group chose to keep many paragraphs that fall into this category. The work 

needed to carry them forward is minimal. 

Recreation management direction specific to the Urban Interface and other parts of the 

FLEA area is not available in the Forest Plan, or what is written is not in enough detail. 

There is a need to add language to the Plan for Recreation. Recreation demands in the 

FLEA area have changed since the Forest Plan was written. 

It is important for FLEA to focus on the criteria used to make road management decisions. 

Criteria are appropriate for a Forest Plan amendment. Site-specific road decisions are not. 

We choose to create a left-hand side analysis product for roads that captures our work to 

date, and provides the District with desired conditions and information to be used in future 

site-specific NEPA analysis for actual roadwork. This product will compile our work to date 

but will not include additional analysis. Although the deadline for conducting roads analysis 

prior to decisions has been extended, the group felt this product is still a valuable one to 

complete now. 

In past discussions about the FLEA PA, trail concepts were included. However, site-specific 

references to trail locations will not be carried forward in the FLEA PA. 

The group then debated at length whether or not to delineate separate management areas 

within FLEA. 

The need for management areas is driven by a desire to describe a sense of place that 

people can identify and discuss with us. The other reason for having management 

areas is to capture the social/political trends of areas and identify a management 

emphasis different from other Forestlands. The new management emphases are a 

combination of recreation and vegetation management items. Management areas 

allow us to recognize areas that influence or are influenced by other entities such as 

the City, County, State Trust Lands and National Park Service. An example is the 

need for identifying emphasis in the Lake Mary watershed for its special connections 

to City water supplies. We recognized there are little specific differences between the 

management areas. 

The downside of separate management areas is that it places more work on us 

internally to find all the different places in the Plan where direction exists. Specialists 

will need to reference many places in the Plan, MA3, FLEA-Area wide and the 

Management Area itself for example. We discussed but dropped the idea of copying 

over all the plan language that applies to each MA. A paragraph will be added to the 

proposed FLEA language to explain the structure of the Plan. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

168 

Discussion of Lands North of Sunset Crater Volcano and South of Wupatki

Many of the items discussed in joint meetings between the FS and NPS are items best 

addressed in a revised Memorandum of Understanding (MOU) between the two agencies. 

The DEIS identifies some items to consider in the MOU. These items suited for the MOU 

include but are not limited to: management of Walnut Canyon entrance road and Sunset 

Crater-Wupatki Scenic Loop Road, management of fences, signs or other features related to 

maintaining the boundaries of the monuments and preventing illegal entrance into the 

Monuments, coordinated monitoring of geologic features and archaeological sites on NF and 

NPS lands, and coordinated information and interpretation services 

The following items were discussed but not carried forward in the FLEA PA. 

Table 15 Points of Discussion with National Park Service 

Item Source Disposition 

Training of special use 

permittees that includes a 

strong emphasis on 

minimizing impacts to 

natural and cultural 

resources 

Meetings 

and 

Letters59

Ongoing efforts by FS to improve 

administration of special use permits. Forest 

Plan amendment not required in order to 

accomplish. 

Add to the Forest Plan list of 

areas to withdraw from 

mineral entry 1) the 

viewsheds of the Monuments 

and 2) the Deadman Area 

Meetings 

and Letter 

The FS preferred course of action is to 

evaluate mineral withdrawal proposals on a 

case-by-case basis. At time this was 

considered, District efforts focused on the San 

Francisco Mountain Mineral Withdrawal. 

The analysis of additional areas was too much 

for staff to accomplish at the time. The NPS 

could bring forward proposals for 

consideration in separate analysis after FLEA. 

Increase patrols for 

enforcement and monitoring 

of impacts 

Meetings 

and 

Letters 

The Forest Plan does not provide direction for 

the number or type of patrol activities. Staff 

decisions, which weigh funding, needs, and 

available personnel govern administration and 

enforcement. 

Relocate the Bonito and 

O’Leary Group 

Campgrounds farther away 

from resources Sunset Crater

Meetings 

and 

Letters 

This concept was discussed in meetings, 

however decommissioning or moving 

facilities is a large endeavor. The FLEA PA 

does not change current Forest Plan language

 

59 Items that are covered in the discussions above, are not included in this table. 
Draft Environmental Impact Statement to Amend the Forest Plan for the 

Flagstaff/Lake Mary Ecosystem Analysis Area 

Appendix F – Crosswalk from Ideas for Change to DEIS

169 

Item Source Disposition 

Volcano National Monument related to these facilities. 

Restore Walnut Canyon, 

inner canyon, to pre-dam 

conditions 

Meetings 

and 

Letters 

The Lake Mary dam limits water flow into 

Walnut Canyon that historically occurred. 

This issue was deemed outside the scope of 

the FLEA process. During the FLEA process 

an adjudication process was underway 

between various entities related to water 

rights. See the LFEA area-wide guidelines 

under the heading Watershed for 

acknowledgement of this process. 

Other lessons learned

One process error that the Ideas for Change did not describe management direction that was 

already in place for the various topics. The Ideas for Change accomplishes two things 1) 

identifies areas where action is needed to implement the current Forest Plan (and implement 

it better) and 2) identifies areas where Forest Plan language change is needed. It would have 

been easier for FS personnel and public to sift through the large amount of information, if 

these categories had been listed in the document. It would also have been a cleaner transition 

from the Ideas for Change to the Proposed Action. That being said, the Ideas for Change is a 

good barometer for where we are today. 

The Ideas for Change also lists site-specific as well as general ideas. It was impossible to 

accurately identify the effects and come to a NEPA decision on both. So programmatic items 

were carried forward in the FLEA PA and site-specific items were or will be ‘peeled out’ for 

site-specific decisions. See the chart at the beginning of this Appendix for a listing of 

projects. The Ideas for Change compiles information about the FLEA area that was 

previously scattered in many different sources. 

Another process problem is that the lands north of Sunset Crater and east of Highway 89 

were added after the Ideas for Change was published. These lands missed out on receiving 

the overall description and discussion of needs for change. Documentation for these lands is 

in meeting notes in the project record. 

A landscape analysis process was used to determine the boundaries of the MA’s and to 

identify ROS objectives. The process was modeled after the USDA Forest Service, 1992 

Forest Landscape Analysis and Design, Pacific Northwest Region. The MA’s listed in the 

Ideas for Change are different from those in the DEIS. We consolidated some MA’s as we 

found more and more similarities and fewer differences between areas. The MA boundaries 

were used as a reference tool for describing Ideas for Change. Again, the lands north of 

Sunset Crater were not listed in the MA’s in the Ideas for Change.