United States Department of Agriculture

Forest Southwest MB-R3-04-26 June 2015

Service Region

Draft Record of Decision for the 

Flagstaff Watershed Protection 

Project 

Coconino National Forest 

Coconino County, Arizona

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Draft Record of Decision for the Flagstaff Watershed Protection Project EIS i

Draft Record of Decision

Coconino National Forest

Coconino Counties, Arizona

Lead Agency: U.S. Forest Service, Coconino National Forest

Responsible Official: Scott Russell, Acting Forest Supervisor

1824 S. Thompson St.

Flagstaff, AZ 86001

For Information Contact: Erin Phelps, FWPP Project Manager

5075 N Hwy 89

Flagstaff, AZ 86004

928-527-8240

Abstract: This document describes a draft decision based on the Coconino National Forest 

Flagstaff Watershed Protection Project Environmental Impact Statement. Information on the 

alternatives considered, justification for the chosen alternative, and details regarding the decision 

and future implementation are discussed.

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS v

Content

Draft Record of Decision................................................................................................................ i

Introduction ................................................................................................................................... 1

Background............................................................................................................................... 3

Purpose and Need ..................................................................................................................... 3

Decision and Rationale.................................................................................................................. 5

My Decision.............................................................................................................................. 5

Rationale for the Decision ...................................................................................................... 25

Public Involvement...................................................................................................................... 37

Scoping ................................................................................................................................... 37

Publication of the Draft Environmental Impact Statement..................................................... 38

Response to DEIS, and Changes from Draft to Final ............................................................. 39

Coordination with Federal, State, and County Organizations................................................. 40

Alternatives Analyzed in Detail.................................................................................................. 41

Alternative 1: No Action......................................................................................................... 41

Alternative 2: Proposed Action with Cable Logging Emphasis on Steep Slopes................... 41

Alternative 3: Proposed Action without Cable Logging......................................................... 41

Alternative 4: Minimal Treatment Approach.......................................................................... 42

Alternatives Considered But Eliminated from Detailed Study ............................................... 43

Alternative 5: No Temporary Road Use or Forest Plan Amendments & Hand Thinning Only

................................................................................................................................................ 43

Alternative 6: Kachina Peaks Wilderness............................................................................... 43

Environmentally Preferred Alternative..................................................................................... 43

Findings Required by Law and Regulation .............................................................................. 44

Clean Air Act of 1970 ............................................................................................................. 44

Clean Water Act ...................................................................................................................... 44

Endangered Species Act of 1973 ............................................................................................ 44

Bald and Golden Eagle Protection Act ................................................................................... 45

Migratory Bird Treaty Act and Executive Order 13186 ......................................................... 45

National Environmental Policy Act ........................................................................................ 46

National Forest Management Act ........................................................................................... 46

National Historic Preservation Act of 1966 ............................................................................ 47

Other Laws and Executive Orders.......................................................................................... 47

Predecisional Administrative Review Process........................................................................... 48

Appendix A: Forest Plan Amendments ..................................................................................... 50

Appendix B: Design Features..................................................................................................... 57

List of Tables

Table 1: Adaptive Harvesting Matrix........................................................................................ 9

Table 2: Summary of treated acres and harvesting methods across the project area .............. 12

Table 3: Treatment Descriptions, Objectives, Acres and Harvesting Systems for the Decision

........................................................................................................................................ 13

Table 4: Harvesting Methods for Dry Lake Hills................................................................... 17

Table 5: Harvesting Methods for Mormon Mountain............................................................. 18

Table 6: Ranges of reference conditions for ponderosa pine forests in the Southwestern 

United States from studies detailed in RMRS-GTR-310 (2013). ................................... 24

Table 8: Fire Hazard Post-Treatment, Dry Lake Hills............................................................ 26
Table 9: Fire Hazard Post-Treatment, Mormon Mountain...................................................... 26

Table 10: Crown Fire Potential under Schultz Fire Weather Conditions, Dry Lake Hills...... 26

Table 11: Crown Fire Potential under Schultz Fire Weather Conditions, Mormon Mountain 27

Table 12: Comparison of Alternatives .................................................................................... 30

Table 14: Amendment 1: Current and Proposed MSO Forest Plan Language........................ 51

Table 15: Amendment 2: Current and Proposed Steep Slope Forest Plan Language ............. 55

Table 16: Design Features Specific to Helicopter and Cable Logging Areas......................... 57

Table 17: General Project Design Features............................................................................. 58

List of Figures

Figure 1: Vicinity map of the project area ................................................................................ 2

Figure 2: Decision Treatment Map, Dry Lake Hills ................................................................. 7

Figure 3: Decision Treatment Map, Mormon Mountain........................................................... 8

Figure 4: Required Transportation System for the Dry Lake Hills......................................... 20

Figure 5: Required Transportation System for Mormon Mountain ........................................ 21

Figure 6: Predicted Soil Burn Severity for the Dry Lake Hills under the Decision................ 28

Figure 7: Predicted Soil Burn Severity for Mormon Mountain under the Decision............... 29
1

Introduction

General Location

The analysis area contains two distinct areas: the Dry Lake Hills (DLH) portion, which is north of 

Flagstaff, AZ, and the Mormon Mountain (MM) portion, which is south of Flagstaff (Figure 1). 

The DLH area is roughly bound by the City of Flagstaff to the south, Kachina Peaks Wilderness 

to the north, the watershed boundary to the east, and a closed forest road (FR 6275) to the west. 

The MM portion is located west of Forest Highway 3 (Lake Mary Road) and northwest of 

Mormon Lake and Mormon Lake Village, on the upper slopes of Mormon Mountain, and is 

generally bound by FR 132D to the north and FR 648 to the south. 

Figure 1 shows the project area locations relative to the watersheds in which they are located. The 

yellow and orange areas depict the areas analyzed in the Flagstaff Watershed Protection Project 

(FWPP) Environmental Impact Statement (EIS) for treatment. 

The FWPP project area is of high scenic, cultural, wildlife, and recreational value. Public use of 

the project area is very heavy, with many heavily-used trails (for both motorized and nonmotorized use), camping areas, and rock climbing areas. The area also has religious significance 

to several Native American tribes in the region. 

Overlap between the Four Forest Restoration Initiative (4FRI) project area and the FWPP area is 

present; those areas that were originally analyzed by the 4FRI DEIS were included in FWPP

planning effort to address additional treatment options (such as treatments on steep slopes) and 

were not carried forward into the 4FRI FEIS or Record of Decision. The Mount Elden/Dry Lake 

Hills (MEDL) Recreation Planning Project is also underway and overlaps a majority of the 

project area within the Dry Lake Hills. 

Approximately 1,872 acres within the general project boundary are already covered under 

previous NEPA decisions: Jack Smith/Schultz (2009) and Eastside (2007) Fuels Reduction and 

Forest Health Restoration Projects. The treatable areas covered under those decisions are either 

currently being implemented or will be implemented in the near future. For example, the Orion 

Task Order (from the Jack Smith/Schultz Decision, 2009) is within the project boundary and is 

anticipated to be treated under the 4FRI contract; those areas of overlap are included within the 

cumulative effects analysis within Chapter 3 of the FEIS. Some areas within the Jack 

Smith/Schultz project area were either determined to be untreatable by ground-based equipment 

or were designated as No Treatment during that planning effort due to steep slopes and 

accessibility issues; those areas were reanalyzed in the FWPP EIS. 
2 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Figure 1: Vicinity map of the project area1

 1 Ownership of a few parcels ofArizona State Lands has changed to the City of Flagstaff since 

this map was created. This does not affect the National Forest or management thereof.
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 3

Background

The City of Flagstaff has seen first-hand the devastating impacts of fire and post-fire flooding 

following the 2010 Schultz Fire on the east side of the San Francisco Peaks. The cost of fire 

suppression was approximately $10 million; however, the actual cost of the fire is many times 

greater than that figure. Many of those additional costs have been associated with severe, 

repeated flooding following the fire, with flows originating on the National Forest and traveling 

into semi-rural residential areas just outside the city limits. Almost five years after the actual 

wildfire, the Forest Service and Coconino County continue to work on mitigating the threat of 

flooding in those areas. 

After the 2010 Schultz Fire and subsequent flooding events, the Ecological Restoration Institute 

(ERI) of Northern Arizona University put together a study called A Full Cost Accounting of the 

2010 Schultz Fire, which detailed not only the cost of wildfire suppression, but also those costs 

associated with loss of property value and specific flood damage to property (2013). According 

to this study, the total impact of the Schultz Fire was estimated at between $133 million and $147 

million. This is considered a conservative estimate as it “excludes measures such as volunteer 

work by nonprofits; destruction of recreation areas, timber, and archaeological sites; physical and 

mental health costs; the degraded viewshed (beyond effects on property values); and the longterm impacts to the region’s amenity-based economy” (ERI 2013). 

During the November 2012 elections, residents of Flagstaff passed a $10 million bond with 

approximately 74 percent approval to support forest treatments within these two watersheds on 

the Coconino National Forest and also on State of Arizona lands. Identified on the ballot as the 

“Forest Health and Water Supply Protection Project,” the planning effort on the National Forest 

segment is now known as the “Flagstaff Watershed Protection Project (FWPP).” 

In 2014, the Rural Policy Institute (RPI) of Northern Arizona University conducted a study that 

estimated the potential financial damages mitigated by the implementation of FWPP (October 

2014). This study, known as the Flagstaff Watershed Protection Project Cost Avoidance Study (or 

Cost Avoidance Study), found that between the two treatment areas, financial damages 

potentially prevented range from $573 million to $1.2 billion.

Similar treatments may occur on approximately 3,000 acres of State of Arizona lands or on 

private lands, including an approximately 140-acre parcel in the middle of the Dry Lake Hills 

owned by the Navajo Nation, as part of the overarching project funded through the City bond; 

however these activities are not included in this Record of Decision nor in the FWPP EIS 

planning effort as it pertains strictly to those actions proposed on the National Forest. The 

implementation of watershed protection treatments on the National Forest System lands does not 

depend on the implementation of treatments on adjacent lands under other ownership, or vice 

versa. 

Purpose and Need 

From the start, the primary purpose of the Flagstaff Watershed Protection Project (FWPP) has 

been to reduce the potential for high severity wildfire and subsequent flooding in two key 

watersheds near Flagstaff, Arizona: in the Dry Lake Hills portion of the Rio de Flag Watershed 

and the Mormon Mountain portion of the Walnut Creek-Upper Lake Mary Watershed (see Figure 

1). There is a need to reduce the fire hazard and post-fire flooding that would likely damage the 

drinking water infrastructure south of town and which could also cause extensive damage to 
4 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

residential and commercial areas should a high-intensity wildfire occur in mountainous areas that 

make-up the Upper Lake Mary and Rio de Flag watersheds. 

More specifically, there is a need to reduce the potential for crown fire and high intensity surface 

fire, to reduce the likelihood of human-caused ignitions, and to increase the ability of fire 

suppression crews to control a wildfire occurring within the project area. Many of the treatments 

included in this decision will also move the project area closer to the historic range of variability 

in their desired condition to reduce the potential for severe wildfire. 

In order to accomplish these goals, there is a need to amend the Forest Plan to allow mechanical 

treatment on slopes greater than 40 percent and a need to amend the Forest Plan to better align

treatments within the FWPP Mexican spotted owl habitats with the Mexican Spotted Owl 

Recovery Plan, First Revision (USDI FWS, 2012). 

The purpose and need for the project focused on “reducing the potential for high severity wildfire 

and subsequent flooding” in order to streamline the necessary analysis and to maintain

consistency with public messaging. This more focused purpose and need allowed us to move 

through the planning process more quickly and with more transparency to the Flagstaff public 

who supported the city bond to fund treatments. They are the reason we’re able to move forward 

with planning and, when the planning process is complete with the final decision, treatment of 

these two critical watersheds.
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 5

Decision and Rationale

My Decision

This draft record of decision (ROD) documents my decision and rationale for the actions I am 

authorizing under the FWPP Environmental Impact Statement analysis process. This decision 

reflects many hours of dedicated time by not only the interdisciplinary team of specialists, but 

also by our partners and public. The high level of engagement by individuals, groups, agencies, 

Tribes, and local governments combined with the environmental analysis were all important and 

necessary components for me to make an informed decision (see the Public Involvement section 

of this document as well as the extensive Response to Comments document within the project 

record). I appreciate the time, energy, ingenuity and viewpoints that were contributed by so many 

to shape and inform a wide range of options that have been considered for this decision. As the 

draft EIS (DEIS) did not contain a preferred alternative in order to allow for more collaboration 

and insight by all interested parties, that input has been instrumental in the development of this 

decision.

Based on my review of the environmental effects disclosed in the Final Environmental Impact 

Statement (FEIS), the Coconino Land Management Plan (Forest Plan), the project record and in 

consideration of comments received on the draft EIS, I have decided to implement a blended 

decision, which includes components of all three action alternatives: Alternative 2: Proposed 

Action with Cable Logging; Alternative 3: Proposed Action without Cable Logging; and 

Alternative 4: Minimal Treatment. This decision authorizes treatment on approximately 8,667 

acres (see Table 2) and includes two Forest Plan amendments under the 2012 Planning Rule (36 

CFR 219.13(b)(3)). The amendments are summarized in the Forest Plan amendment section 

below and detailed in Appendix A of the FEIS. This decision also includes the establishment of a 

permanent campfire closure order in the DLH portion of the project area. 

This blending is based on the concept of using traditional ground-based equipment wherever 

possible, helicopter logging in the areas of greater visual and wildlife concern, and cable logging 

where visual impacts, effects on the Mexican spotted owl, and large tree retention issues are less 

significant (Figure 2 and Figure 3). Concepts from Alternative 4 (minimal treatment) were 

incorporated where possible, but this is predominantly a blend between Alternatives 2 and 3 in 

order to treat the most acres and affect the most change in the potential for severe wildfire effects. 

The Mormon Mountain portion of this decision is the Alternative 3 version, which includes 2,320

acres of traditional ground based equipment, 73 acres of steep slope equipment harvesting, 180

acres of hand thinning, and 402 acres of burn only. 

The decision takes into account comments and concerns brought forth on the Draft 

Environmental Impact Statement, published July 3, 2014 for the 45-day comment period, 

including concerns involving cable logging within MSO habitat and within the viewshed of 

Flagstaff, and the removal of large and old trees as a result of that harvesting method. The 

Modified Large Tree Retention Strategy from Alternative 4 is incorporated into this decision, as 

are the design features and mitigation measures related to all three of the action alternatives (see 

Appendix B for the full list of design features). 

This decision does not incorporate or adopt any new recreation trails, nor does it include the 

protection of non-forest system trails (e.g. user-created trails) during implementation activities. 

While I understand the concern of many local recreationists on this subject, such activities are 

outside the scope of FWPP and are more appropriate for consideration under the Mount Elden –
6 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Dry Lake Hills Recreation Planning Project, which overlaps the Dry Lake Hills portion of FWPP

and included in the cumulative effects analysis discussed in Chapter 3 of the FEIS. I fully commit 

to an intensive public awareness effort throughout the FWPP implementation process, including 

working with our partners to ensure the location and need for temporary closures are 

communicated early and often. 

There is a need for a comprehensive recreation analysis of the Mount Elden/Dry Lake Hills area, 

especially after FWPP is implemented and more fire resilient ecosystems are established. I 

acknowledge and support the need to take that step toward a more sustainable recreation system 

within the Dry Lake Hills through the National Environmental Policy Act to continue 

improvement of recreational access and opportunities and the protection of forest resources for 

current and future generations.

The decision reflects the public responses to the DEIS, consultation with agencies, and further 

environmental analysis. My decision incorporates components analyzed and described in each of 

the action alternatives (2, 3, and 4). These components are within the range of those described in 

the FEIS (see “Alternatives Considered in Detail” in the FEIS) and the effects of the decision are 

within the range of effects described in the FEIS.

The following sections provide more detail on the different components of the decision.
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 7

Figure 2: Decision Treatment Map, Dry Lake Hills
8 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Figure 3: Decision Treatment Map, Mormon Mountain

Treatment of Steep Slopes

Helicopter logging will be utilized for removing cut material on approximately 556 acres within 

the Dry Lake Hills portion. This includes steep slopes within Mexican spotted owl protected 

activity centers (MSO PACs) and those areas visible from the City of Flagstaff. No helicopter 

logging will occur on Mormon Mountain. 

Cable logging will be utilized to remove cut material on approximately 414 acres within the Dry 

Lake Hills, the majority of which will be by excaline (300 acres) and the rest will be skyline (114 

acres). Excaline corridors will be shorter (typically less than 300 feet in length) than skyline 

corridors and a machine known as a jammer could also be used, which will remove the need for 

corridors that would require the removal of all trees within them. No cable logging will occur on 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 9

Mormon Mountain. Descriptions of the harvesting methods are provided in Chapter 2 of the 

FEIS. 

Approximately 323 acres will be harvested using specialized steep-slope equipment; 

approximately 250 acres within the Dry Lake Hills and 73 acres on Mormon Mountain. Hand 

thinning will occur on a total of 678 acres, and an additional 270 acres of steep sloped areas are 

deferred from treatment. These areas were proposed for hand thinning and/or burn only under 

Alternatives 2 and 3, but because of the steepness they are unlikely to be successfully treated due 

to safety concerns related to felling trees and building piles by hand, and then burning the piles 

during the winter with snow on the ground. 

Table 2 below details the total acres that will be treated and the acres broken down by harvesting 

method. Prescribed burning will be included across all treated areas (approximately 8,668 acres). 

Table 3 contains more specific information about the treatment description/objective (e.g. what 

the cutting prescription will include). 

Adaptive Harvesting Matrix

To address concerns with the potential of finding a contractor for these specialized harvesting 

systems, I am including this Adaptive Harvesting Matrix, which will allow the latitude to 

substitute harvesting methods that result in less impact to meet the approved forest management 

goals identified for the treatment area. For example, the analysis of effects in the FEIS show that 

helicopter logging can result in less impact overall than cable logging, but is often more 

expensive. If, during project implementation, it is found to be more advantageous to treat an area 

identified in this decision to be treated with “cable logging” with helicopter logging or hand 

thinning instead, this will be acceptable and within the scope and range of environmental effects 

considered in the environmental analysis. This adaptive approach provides flexibility to substitute 

a less invasive treatment type rather than deferral from treatment in the event a qualified 

contractor cannot be acquired or other problems are identified. Decisions to modify treatment 

types shall follow a hierarchy of impacts, moving from the harvesting method with the most 

effects on resources to those with less. Additional analysis or a revision to the decision will not be 

required as the fallback harvesting method would have less impact than the original harvesting 

method and all the harvesting methods were included in the analysis performed for the FWPP 

EIS. This decision does not authorize a change from a secondary harvesting method to one with 

more impacts (e.g. from helicopter logging to cable logging). There will be a letter to FWS, for 

the record, stating what method was chosen/used and the Forest will coordinate with the FWS as 

we proceed with the action.

Table 1: Adaptive Harvesting Matrix

Original Harvesting Method Secondary Harvesting Method Third Harvesting Method

Cable Logging Helicopter Logging Hand Thinning

Helicopter Logging Hand Thinning

Specialized Steep Slope 

Equipment

Hand Thinning
10 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Treatment of MSO Habitat

My decision includes approximately 2,689 acres of treatment within MSO Recovery Habitat, 

3,951 acres of treatment within MSO PACs, 120 acres of hand thinning and prescribed burning 

within the Schultz Creek nest core, and 785 acres of burn only treatment within the remaining 

seven nest cores. Table 3 includes more information about those treatments, including desired 

condition ranges. These treatments require an amendment to the Forest Plan, which is 

summarized below and detailed in Appendix A of the FEIS.

As part of this decision, I also commit to the MSO monitoring plan proposed in the DEIS and 

finalized through formal consultation with the Fish and Wildlife Service (FWS). Monitoring of 

these treatments will help inform and guide future management within MSO habitat, and is an 

important component of FWPP. 

Monitoring

This decision also incorporates the monitoring identified within the Final EIS (FEIS) to be either 

preformed internally (by the USFS) or as in the case of red squirrel monitoring plan, by our 

federal, state and/or local partners (FWS, Ecological Restoration Institute of Northern Arizona 

University, Arizona Game and Fish Department, Rocky Mountain Research Station, etc.). I 

recognize the importance of our partners and volunteers in our monitoring efforts and look 

forward to continuing these important relationships and efforts. 

Design Features tied to protection of Mexican spotted owls and other wildlife, as well as soils and 

hydrology, scenic resources, recreation, and the retention of old trees and large pre-settlement 

trees are incorporated into this decision. See Appendix B of this document and Chapter 2 of the 

FEIS.

Forest Plan Amendments

The Coconino National Forest is currently operating under the 1987 Coconino Land Management 

Plan, as amended; the Forest is in the process of revising the Forest Plan, with the Record of 

Decision (ROD) for the revised plan anticipated for release in 2016. The following two projectspecific Forest Plan amendments are required as this decision is being signed prior to 

implementation of the revised Forest Plan. This project is amending the Forest Plan under the 

2012 Planning Rule (36 CFR 219.13); the two amendments below are significant per (36 CFR 

219.13(b)(3). 

A site (project) specific plan amendment is a one-time variance in Forest Plan direction for the 

project; Forest Plan direction reverts back to its original language/direction upon completion of 

the specified project. The language proposed does not apply to any other forest project. The 

following are summaries of the amendments; more information can be found in Appendix A of 

this document. The effects of the significant amendments are the same as those analyzed from 

treating on steep slopes and treating within MSO habitat as disclosed in the EIS.

Amendment 1: The purpose of this amendment will be to facilitate treatment in high-priority 

locations such as Mexican spotted owl occupied habitat to prevent high-severity wildfire. This is 

based on language in the Mexican Spotted Owl Recovery Plan (2012), which states, “[wildfires] 

result in the most significant alteration of owl habitat and hence, have the greatest potential for 

loss of habitat” (USDI 2012). The current Forest Plan adopted language from the previous MSO 

Recovery Plan (USDI 1995). For this project, the Forest Plan amendment utilizes some of the 

more updated management direction in the revised recovery plan where it is different than what is 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 11

currently included in the Forest Plan. More information about this amendment can be found in 

Appendix A. 

Amendment 2: The current Forest Plan restricts the use of mechanical equipment to slopes less 

than 40 percent. Amendment 2 removes the restrictive language related to 40 percent slopes and 

also the language identifying slopes above 40 percent as inoperable in order to allow mechanical 

harvesting on slopes greater than 40 percent within the project area. 
12 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Table 2: Summary of treated acres and harvesting methods across the project area

Project 

Area

Treated 

Acres*

Harvesting

by 

Helicopter

Harvesting by 

Cable Logging

Specialized 

Steep 

Slope 

Equipment

Traditional 

Ground 

Based

Hand 

Thinning

Burn 

Only

No 

Treatment

Total 

Project 

Acres

Dry Lake 

Hills

5,692

acres

566 acres 414 acres 

114 acres 

skyline 

300 acres 

excaline

250 acres 3,497 acres 498 acres 468 acres 1,876

acres

7,569 acres

Mormon 

Mountain

2,975

acres

0 acres 0 acres 73 acres 2,320 acres 180 acres 402 acres 0 acres 2,975 acres

Total 8,668

acres

556 acres 414 acres 323 acres 5,817 acres 678

acres

870 acres 1,876

acres

10,544

acres

*Totals may differ slightly due to rounding errors
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 13

Table 3: Treatment Descriptions, Objectives, Acres and Harvesting Systems for 

the Decision

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk 

LOPFA2 Areas)

These treatments areas are outside of 

MSO PACs and northern goshawk 

PFAs and nest cores. Mechanical 

treatment designed to develop 

uneven-aged structure and a mosaic of 

openings and tree groups of varying 

sizes. Openings will occupy 

approximately 20 percent of the 

treatment area. Tree groups will vary 

in shape, size, density, and number: 

generally from 0.05 – 0.7 acres in size 

with residual group basal areas of 20-

80 ft2 per acre and 2-40 trees per 

group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

Ponderosa Pine Fuels 

Reduction – Hand 

Thinning

(Northern Goshawk 

LOPFA Areas)

This treatment includes steep areas 

that have low tree density and/or are 

dominated by smaller diameter trees 

where the purpose and need can be 

met through hand felling treatments. 

Where practical and feasible, 

treatments will be designed to develop 

uneven-aged structure and a mosaic of 

tree groups of varying sizes similar to 

the treatment described above.

81 - DLH

Mixed Conifer Fuels 

Reduction

(MSO Recovery Areas)

These treatment areas include dry 

mixed conifer areas outside of MSO 

PACs, replacement nest/roost habitat,

and northern goshawk PFAs and nest 

cores, but include MSO recovery

habitat. Mechanical treatment 

designed to develop uneven-aged 

structure and a mosaic of openings 

and tree groups of varying sizes. Trees 

above 24” dbh will not be cut. 

Openings will occupy about 10-20 

percent of the treatment area. Tree 

1141 - DLH

 2 LOPFA – Landscapes outside of goshawk post-fledging family areas (as referenced in the Forest 

Plan)
14 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Treatment Type Treatment Description/Objective Acres

groups will vary in shape, size, 

density, and number: generally less 

than one acre in size with residual 

group basal areas of 30-90 ft2 per acre 

and 2-50 trees per group

MSO PAC Fuels 

Reduction - Wet Mixed 

Conifer 

In this treatment, dead and down 

material will be piled for burning to 

reduce the heavy fuel loading and 

allow for lower-intensity prescribed 

burning. Piles will be placed in 

openings to the extent possible to 

reduce fire damage to large trees. In 

addition, mechanical treatment will 

create small openings within aspen 

stands to promote regeneration. 

180 - MM

MSO PAC Fuels 

Reduction 

Mechanical treatment to create a 

diversity of patch sizes with minimum 

patch size of 2.5 acres. Provide for 10 

percent openings across treatment 

areas from 0.1 – 2.5 acres in size. 

Maintain a minimum of 40 percent 

canopy cover in pine/pine-oak and 60 

percent in mixed conifer. Posttreatment, trees greater than 16” dbh 

will contribute at least 50 percent of 

the stand basal area per MSO 

Recovery Plan Desired Conditions 

(2012). Trees above 18” dbh will not 

be cut except if necessary for cable 

corridor locations.

1195 – DLH

1592 - MM

MSO PAC Fuels 

Reduction – Hand 

Thinning

This treatment includes steep areas 

which have low density and 

dominated by smaller trees or are in 

areas not conducive to specialized 

steep slope equipment or cable or 

helicopter yarding operations. 

Treatments where feasible will treat 

stand similar to the MSO PAC 

treatment described from above. 

Otherwise treatments will be thin 

from below to reduce density and fuel 

ladders.

202 – DLH 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 15

Treatment Type Treatment Description/Objective Acres

MSO Nest Fuels 

Reduction -Hand 

Thinning

Hand thinning up to 5” dbh will occur 

within 80 % of the Schultz Creek nest 

core in coordination with the US Fish 

and Wildlife Service (122 acres, 

DLH). Approximately 20% of the nest 

core will be deferred from treatment 

in order to maintain denser patches for 

habitat. Residual basal area will be a 

minimum of 110 ft2, and treatment 

will maintain a minimum of 60% 

canopy cover in mixed conifer. This 

nest core will also receive the 

prescribed burning treatment 

described below.

122 – DLH

MSO Nest Fuels 

Reduction - Burn Only

In all nest cores other than the Schultz 

Creek nest core, treatment will consist 

of low-intensity burning only. Dead 

and down material in MSO nest cores 

will be piled by hand and burned.

261 – DLH

402 – MM

MSO Recovery 

Nest/Roost -Hand 

Thinning

Hand thinning up to 9” dbh will occur 

on 72 acres in DLH under this 

treatment, and dead trees less than 12”

dbh and down material will be cut and 

piled by hand for prescribed burning. 

72 - DLH

MSO Recovery 

Nest/Roost - Burn Only

Thirty-seven acres of Nest/Roost 

Replacement Recovery habitat will be 

prescribed burned only (no hand 

thinning). Snag retention guidelines 

identified in the Forest Plan will still 

be followed (see Design Features –

Snags). Treatments will be designed 

to move the stands towards minimum 

desired conditions: Residual basal 

area of 110 ft2 in ponderosa pine, and 

120 ft2 in mixed conifer; canopy 

cover of 40 percent in pine/pine-oak 

and 60 percent in mixed conifer; 12 

trees per acre greater than 18” 

diameter; trees from 12-18” dbh will 

comprise over 30 percent of stand BA, 

and trees greater than 18” dbh will 

comprise an additional 30% of BA.

37 - DLH

MSO Recovery 

Nest/Roost– Mechanical 

Thinning

Mechanical treatment will remove 

ponderosa pine in a variety of size

classes; however, no trees greater than 

18” dbh will be cut. Treatments will

22 - MM
16 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Treatment Type Treatment Description/Objective Acres

be designed to maintain a minimum 

residual basal area of 110 ft2; canopy 

cover of 40 percent with 12 trees per 

acre greater than 18” diameter; trees 

from 12-18” dbh will comprise over 

30 percent of stand BA, and trees 

greater than 18 inches will comprise 

an additional 30% of BA. No oak will

be cut.

Northern Goshawk Post 

Fledging Areas (PFA) 

Fuels Reduction

Uneven-age mechanical treatment 

designed to develop uneven-aged 

structure and a mosaic of tree groups 

of varying sizes. Openings will 

occupy 20 percent of the treatment 

area. Tree groups will vary in shape, 

size, density, and number: generally 

from 0.05 – 0.7 acres in size with 

residual group basal areas of up to 30-

90 ft2 per acre and 2-40 trees per 

group

359 - DLH

Northern Goshawk Nest 

Fuels Reduction

Mechanical treatment designed to 

develop northern goshawk nest stand 

conditions consisting of a contiguous 

over-story of large trees. Forest Plan 

guidelines for canopy cover will be 

met: canopy cover will vary from 50 

to 70 percent.

100 - DLH

Aspen Treatment A variety of different treatments will 

be used to promote and protect aspen 

health and regeneration, including the 

removal of post settlement conifers 

within 100 feet of aspen clones, 

prescribed fire, ripping, planting, 

fencing and/or cutting of aspen to 

stimulate root suckering.

22 – DLH

Grassland Restoration Mechanical treatment to remove 

encroaching post-settlement conifers 

and restore the pre-settlement tree 

density and patterns.

60 – DLH

Burn Only Burn only treatment will remove 

excessive fuel loading in areas which 

were previously burned by the Radio 

Fire.

171 - DLH
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 17

Treatment Type Treatment Description/Objective Acres

Electronic Site –

Structure Protection

These sites are occupied by 

telecommunication facilities, and will 

be treated to provide a sufficient 

defensible space around these 

structures from a wildland fire. 

Individual trees that are determined to 

contribute to wildfire hazard or pose a 

hazard to the electronic sites will be 

removed. The remainder of the sites 

will receive a thin from below to 

approximately 20 – 40 ft2 basal area 

with the purpose of raising the crown 

base height and leaving the largest 

and most fire resistant trees.

6 – DLH

12 - MM

No Treatment (No New 

Analysis)

These acres include non-treatable 

areas, including rock faces and 

boulder fields, and the Orion Timber 

Sale (approximately 837 acres). 

Though the Timber Sale is within the 

project boundary, the treatments for 

that area were analyzed and 

authorized under the Jack Smith 

Schultz Fuels Reduction and Forest 

Health Restoration Project Decision 

Notice/Finding of No Significant 

Impact (2008). No additional 

treatments within the Timber Sale 

area are proposed under this decision. 

1876 - DLH

Table 4: Harvesting Methods for Dry Lake Hills

Treatment 

Type

GroundbasedHand 

Cut/Piled

Helicopter Cable 

Logging

Burn 

Only

Steep 

Slope 

Equipment

TOTAL

Ponderosa 

Pine Fuels 

Reduction

1613 242 10 1865

Ponderosa 

Pine Fuels 

Reduction –

Hand 

Thinning

81 81

Mixed 

Conifer Fuels 

Reduction

626 299 126 90 1141

MSO PAC 793 267 135 1195
18 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Treatment 

Type

GroundbasedHand 

Cut/Piled

Helicopter Cable 

Logging

Burn 

Only

Steep 

Slope 

Equipment

TOTAL

Fuels 

Reduction

MSO PAC 

Fuels 

Reduction –

Hand 

Thinning

202 202

MSO Nest 

Fuels 

Reduction

122 261 383

MSO 

Nest/Roost 

Recovery

72 37 109

Goshawk 

PFA Fuels 

Reduction

299 45 15 359

Goshawk 

Nest Fuels 

Reduction

100 100

Aspen 

Treatment 22 22

Grassland 

Restoration 60 60

Burn Only 171 171

Electronic 

Site-Structure 

Protection

6 6

No 

Treatment/No 

New 

Analysis

- - - - - 1876

TOTAL 3497 499 566 413 469 250 7570

Table 5: Harvesting Methods for Mormon Mountain

Treatment Type GroundbasedHand 

Cut/Piled

Burn 

Only

Steep 

Slope 

Machinery

TOTAL

Ponderosa Pine Fuels Reduction 766 767

MSO PAC Fuels Reduction 1519 73 1592

MSO PAC Fuels Reduction –

Wet Mixed Conifer

180 180

MSO Nest Fuels Reduction 402 402

MSO Nest/Roost Recovery 22 22
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 19

Treatment Type GroundbasedHand 

Cut/Piled

Burn 

Only

Steep 

Slope 

Machinery

TOTAL

Electronic Site-Structure 

Protection

12 12

TOTAL 2321 180 402 73 2,975

Required Transportation System

Forest Service contractors have the right to legally use public roads within and outside of the 

project area, subject to regulation by the public entity charged with jurisdiction of that roadway. 

In order to move timber from the project area to processing facilities, it will be necessary for 

heavy trucks to use public roads through a portion of the city of Flagstaff. The Forest Service 

may only restrict haul routes or timing of routes used by contractors on the National Forest in 

order to provide for public safety. The Forest Service cannot dictate the routes the contractor uses 

once they leave the forest. The routes here are only potential options that could be used.

Truck volume will increase throughout the FWPP treatment period. Approximately 14,000 total 

(including treatments in DLH and MM areas) truck trips are expected to result from activities 

authorized by this decision, which equals roughly 2,800 truck trips per year (see following section 

on Haul Routes for more information). 

Dry Lake Hills

System haul roads within the project area 18.07 miles

System haul roads outside the project area 14.33 miles

New temporary haul roads constructed 11.67 miles

Temporary roads on existing road prisms 2.75 miles

Temporary roads rehabilitated post-treatment 14.43 miles

Relocated system road used as haul road 1.58 miles

System roads decommissioned 4.19 miles

Mormon Mountain

System haul roads within the project area 16.46 miles

System haul roads outside the project area 18.13 miles

New temporary haul roads constructed 0.0 miles

Temporary roads on existing road prisms 2.52 miles

Temporary roads rehabilitated post-treatment 2.52 miles

Relocated system road used for hauling 0.53 miles

System roads decommissioned 0.19 miles

Haul Routes -Dry Lake Hills

This project will utilize several primary haul routes for log trucks and chip vans (Figure 4). The 

following roads will be utilized as haul routes to remove material cut in the Dry Lake Hills 

portion of the project:

• FR 557 (Elden Lookout Road)

• FR 420 (Schultz Pass Road) 

• FR 556 (Elden Springs Road) 

• FR 522 (Freidlein Prairie Road)
20 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

• FR 516 (Snowbowl Road) 

Figure 4: Required Transportation System for the Dry Lake Hills
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 21

Figure 5: Required Transportation System for Mormon Mountain
22 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

All of the timber removed from Mount Elden and the timber from the lower, flatter slopes to the 

west of Mount Elden will use FR 557 to its junction with FR 420 and then enter State Highway 

180. Approximately 3,800 truckloads will use this route.

Nearly all of the area between FR 557 and FR 420 as well as a portion of the project north of FR 

420 will either be hauled on FR 420 to Highway 180 or on FR 556 to Highway 89. 

Approximately 5,200 truckloads will use these routes. 

The very northern portion of the Dry Lake Hills area will be hauled on FR 522 to FR 516 and 

then onto Highway 180. Approximately 200 truckloads will use this route. 

Trucks that haul onto Highway 180 will most likely use N. Switzer Canyon Road to reach east 

Route 66. These loads will use Ponderosa Parkway and E. Butler Ave to enter Interstate 40 at the 

east Butler Ave interchange, exit 198. Trucks hauling to Highway 89 will likely use East Route 

66 to Country Club Drive and enter Interstate 40 at the Country Club interchange, exit 201. 

However, as mentioned previously, these are potential route options; the Forest Service cannot 

dictate where the contractor(s) go once they leave the National Forest. 

Haul Routes - Mormon Mountain

Timber hauled from the Mormon Mountain portion of the project area could be either hauled to 

Interstate 17 at Munds Park via FR 240 or onto Highway 3 (Lake Mary Road) via County Road 

90. Both of these routes will utilize FR 132, 132A, 648 and 240 as well as County Road 90. See 

Figure 5. Approximately 4,700 truckloads will use these routes.

Campfire Closure Order

This decision establishes a permanent campfire restriction order in the DLH portion of the project 

area to limit the potential for human-caused wildfire. 

Temporary Closure Orders

There may be a need to temporarily close portions of the project area to the public during 

implementation due to safety concerns related to heavy machinery on steep slopes and log 

hauling and equipment on and/or adjacent to roads and trails, as well as prescribed burning 

activities. The closures could apply to the area being treated as well as the truck haul routes in use 

and any trails within or immediately adjacent to the treatment area. The closures will likely be 

short in duration and specific to the area where machines are operating. For harvesting units, area 

closures may last up to approximately one year; for prescribed burning areas, closures may last 

from one to five days. After timber cutting and removal are competed, the closure order will be 

lifted and the public will be able to access the area again. The closures will be communicated 

with the public prior to their taking affect, and reroutes of affected trails (where possible) will be 

identified and communicated as well.

Large Tree Retention Strategy

This decision incorporates a modified Large Tree Retention Strategy (LTRS) based on that which 

was included in Alternative 4. The design features to protect old and large trees are included (see 

Appendix B), and the Forest Service will retain all decision-making authority regarding treatment 

prescriptions within the project area. Large post-settlement trees will be retained throughout the 

project area except: 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 23

1. As necessary to meet community protection and public safety goals (e.g. in WUI areas 

adjacent to communities)

2. When best available science identifies sites where ecological restoration and biodiversity 

objectives cannot otherwise be met; specifically in the case of FWPP, within stand 

openings and in heavily-stocked stands with high basal area generated by a 

preponderance of large, young trees. 

The modified LTRS applies to a small portion of the project area – approximately 766 acres of 

ponderosa pine in the MM portion—as the DLH portion will fall under the first point noted 

above. The original LTRS was developed specifically for ponderosa pine and so does not apply to 

mixed conifer areas; however, large and old trees will also be retained where possible within 

mixed conifer areas (see Design Features). As the MM portion does not fit within Number 1 

above because of its distance from the City of Flagstaff, the LTRS will only pertain to the 

ponderosa pine Gambel oak forests outside of MSO PACs on MM. 

Most of the other “exception” categories listed in the LTRS are not relevant for the MM portion 

of FWPP discussed above, including: 

• Seeps and Springs

• Riparian

• Wet Meadows

• Encroached Grasslands 

• Aspen Forest and Woodland

As not every acre of the relevant MM portion was surveyed (see Methodology section of Forest 

Structure and Health in Chapter 3 of the FEIS), it is possible that the 766 acres of ponderosa pine 

might contain primarily small-diameter (less than 16 inches dbh) trees, which will not fit within 

an exception category under the original LTRS. As stated in the Forest Structure and Health 

methodology section:

The modeling assumptions attempt to meet the spirit of the Large Tree Retention 

Strategy (LTRS) within the limitations of a non-spatially explicit model. On the 

ground cutting prescriptions for Alternatives 2 and 3 would follow components 

of the LTRS that have been incorporated into the design features of this EIS. 

Alternative 4 would include more specific limitations on large tree removal per 

the modified LTRS and related Design Features discussed in this FEIS (p. 198)

Because of this, as long as the purpose and need of fire hazard reduction can still be met, the 

decision incorporates the following additional Design Features for the Northern Goshawk habitat 

within LOPFA on MM:

• To meet the desired condition of increasing the more fire-resilient VSS 5 and 6 age 

class, tree retention within groups will focus on existing large trees (generally, trees 

within the dominate and codominant crown position). 

• Tree groups, on average, will range in size from 0.1 to 1 acre; sites with a preponderance 

of large trees and highly productive microsites will have larger average group sizes (0.25 

to 1 acre). Overall, average group size will vary within this range depending on fuel 

loading, site quality and topography, existing stand structure, and pre-settlement tree 

evidence.
24 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

• Stands with a preponderance of large trees will be managed for greater residual canopy 

cover and density of large young trees while still meeting the purpose and need of 

reduced wildfire hazard. Residual stand structure will be managed toward the higher end 

of the natural range of variability for ponderosa pine in the stands that meet these 

conditions (see Table 6). This will be accomplished by focusing treatments towards the 

higher end of the natural range of variability, managing for larger group sizes (see 

below), and/or retaining additional large trees.

• Regeneration openings (group selection) will account for 10 to 20 percent of tree groups. 

The percentage will vary within this range depending on current VSS distribution. They 

will average 0.25 to 2 acres with an average of approximately 1 acre and be no wider than 

200 feet. Where stand structure dictates, establish regeneration openings by removing 

groups of trees of VSS3 and smaller diameter VSS4.

Table 6: Ranges of reference conditions for ponderosa pine forests in the 

Southwestern United States from studies detailed in RMRS-GTR-310 (2013).

Forest attribute Ponderosa pine

Trees / acre 11.7-124

Basal area (ft2 / acre) 22.1-89.3

Spatial patterns Grouped or random

Number of trees / group 2-72

Size of groups (acres) 0.003-0.72

Number of groups / acre 6-7

Economics

This decision will cost approximately $8,011,548 to implement; a comparison of costs between 

alternatives and this decision is provided in Table 7 below. This estimation includes the following 

costs: surveying and marking cultural sites, marking and cruising timber, road construction, road 

rehabilitation, road maintenance, preparing contracts, project administration, harvesting trees, 

hand thinning and prescribed burning. This estimate does not include the cost of preparing the 

Environmental Impact Statement for the project. The gross value of timber is subtracted from the 

gross cost of implementation to provide the net implementation cost (below). More details about 

the analysis, including methodology and assumptions, are included in the Economics section of 

Chapter 3 in the FEIS. 

Table 7: Comparison of costs per alternative

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Decision

Cultural 

Resource Survey 

Cost

$102,0003 $104,160 $103,820 $103,780 $104,160

Sale Preparation 

Cost

$0 $871,080 $874,440 $640,680 $872,160

Sale $0 $355,450 $356,850 $263,200 $355,900

 3 Cost of archaegological surveys already completed for the project.
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 25

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Decision

Administration 

Cost

Temp Road 

Construction 

and 

Rehabilitation

$0 $220,903 $149,532 $138,819 $176,089

Construction of 

Relocated 

System Roads 

Cost

$0 $18,659 $18,659 $18,659 $18,659

Road 

Rehabilitation 

Cost 

$0 $56,194 $56,194 $56,194 $56,194

Hand Thinning $0 $719,100 $707,200 $372,300 $739,500

Prescribed 

Burning

$0 $5,251,296 $5,251,296 $3,027,250 $5,251,296

Costs of 

Implementation, 

(not including 

net timber value)

$102,000 $7,596,842.00 $7,517,991.00 $4,620,882.00 $7,573,958

Net Timber 

Value

$0 +$274,908 -$992,747 +$539,823 -$437,590

Total 

Implementation 

Cost 

(Net Timber 

Value minus 

Cost of 

Implementation)

$102,000 $7,319,774 $8,508,918 $4,079,279 $8,011,548

Rationale for the Decision

I make this decision to meet the purpose and need of FWPP while achieving the best balance of 

the social, economic, and environmental interests and effects. This decision is based on 

compliance with law, regulation and policy; consultation with regulatory agencies; consultation 

with interested tribes; and a review of the project record. I have thoroughly examined relevant 

scientific information and I will explain my rationale for the decision in the following sections.

The Flagstaff Watershed Protection Project FEIS documents the analysis and conclusions upon 

which this decision is based.

Meets the Purpose and Need

This decision meets the purpose and need for the project by reducing the potential for high 

severity fire and subsequent flooding on approximately 57 percent of the project area under the 

No Action Alternative to approximately 7 percent. Modeling indicates that after treatment, 

approximately two percent of the Dry Lake Hills and 18 percent of the Mormon Mountain area 
26 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

would be at risk for extreme fire hazard, compared to 67 and 75 percent (respectively) under the 

No Action Alternative (see Table 8 and Table 9). Under Schultz Fire conditions, modeling shows 

that after treatment, the Dry Lake Hills would likely experience active crown fire on 745 acres, 

passive crown fire on 99acres, and surface fire on 6,591 acres (see Table 10). On Mormon 

Mountain, crown fire potential modeling shows active crown fire on 63 acres, passive crown fire 

on 329 acres, and surface fire on 2,577 acres (Table 11). Table 10 and Table 11compare these 

modeled outputs with those modeled for existing conditions (the No Action Alternative). 

Table 8: Fire Hazard Post-Treatment, Dry Lake Hills

Existing Fire 

Hazard (No 

Action)

Acres Percent Post 

Treatment 

Fire Hazard

Acres Percent

Extreme 2,582 67% Extreme 91 2%

Very High 72 4% Very High 268 8%

High 613 15% High 510 13%

Moderate 470 12% Moderate 1,930 50%

Low 100 2% Low 1,036 27%

Table 9: Fire Hazard Post-Treatment, Mormon Mountain

Existing Fire 

Hazard

Acres Percent Post 

Treatment 

Fire Hazard

Acres Percent

Extreme 2,089 75% Extreme 526 18%

Very High 197 8% Very High 10 1%

High 273 10% High 273 9%

Moderate 174 6% Moderate 736 26%

Low 51 1% Low 1,284 46%

Table 10: Crown Fire Potential under Schultz Fire Weather Conditions, Dry Lake 

Hills

Crown Fire Type Existing Crown Fire 

Potential 

(Schultz conditions)

Decision, 

Dry Lake Hills

(Schultz conditions)

Active 3,832 acres 745 acres

Passive 749 acres 99 acres

Surface 2,881acres 6,591 acres
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 27

Table 11: Crown Fire Potential under Schultz Fire Weather Conditions, Mormon 

Mountain

Crown Fire Type Existing Crown 

Fire Potential 

(Schultz

Conditions)

Decision, 

Mormon Mountain 

(Schultz conditions)

Active 2,068 acres 63 acres

Passive 725 acres 329 acres

Surface 176 acres 2,577 acres

This decision will also result in reducing the post-fire predicted peak discharge associated with a 

100-year storm event by approximately 60 percent as compared to the No Action Alternative. 

The projected soil burn severity of a wildfire burning under Schultz Fire weather conditions will 

also be reduced after implementation of this decision, so that only eight percent of the DLH and 

one percent of MM are predicted to experience high soil burn severity; under the No Action, 

those numbers are 39 percent for DLH and 62 percent for MM. See the soil burn severity maps on 

the following pages (Figure 6 and Figure 7) and Table 13 to compare modeled outcomes for each 

of the alternatives analyzed in the FEIS as well as this decision.

This decision meets the purpose and need; incorporates public input on the selection of harvesting 

methods, protection of large and old trees, and deferment of certain areas on steep slopes; and 

includes the Large Tree Retention Strategy as modified in the FEIS.
28 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Figure 6: Predicted Soil Burn Severity for the Dry Lake Hills under the Decision
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 29

Figure 7: Predicted Soil Burn Severity for Mormon Mountain under the Decision
30 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Table 12: Comparison of Alternatives4

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Total Treatment Acres Jack Smith 

Schultz/Eastside5

8,669 acres

5,694 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

5,802 acres

3,459 acres DLH

2,343 acres MM

Percentage of Total 

Project Area to be 

Treated

0% 82%

75% DLH

100% MM

85%

79% DLH

100% MM

85%

79% DLH

100% MM

55%

46% DLH

79% MM

Acres to be Helicopter 

Logged

0 acres 566 acres

566 acres DLH

0 acres MM

0 acres 973 acres

973 acres DLH

0 acres MM

0 acres

Acres to be Cable 

Logged

0 acres 414 acres

414 acres DLH

0 acres MM

1,291 acres

1,185 acres DLH

106 acres MM

0 acres 0 acres

Acres to be treated by 

Specialized Steep 

Slope Equipment

0 acres 323 acres

250 acres DLH

73 acres MM

0 acres 346 acres

273 acres DLH

73 acres MM

0 acres

Acres to be Hand 

Thinned

0 acres 678 acres

498 acres DLH

180 acres MM

846 acres

699 acres DLH

147 acres MM

832 acres

652 acres DLH

180 acres MM

438 acres

438 acres DLH

0 acres MM

Acres to be Prescribed 

Burned

0 acres 8,669 acres

5,694 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

5,802 acres

3,459 acres DLH

2,343 acres MM

Campfire Closure 

Order

No Yes Yes Yes Yes

 4 Acres are approximate and may vary slightly from other tables and discussions due to rounding

5 Past projects with acreages within the FWPP boundary that could be implemented
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 31

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Forest Plan 

Amendments

No Yes

1. Related to MSO

2. Mechanical 

Treatment on slopes 

>40%

Yes

1. Related to MSO

2. Mechanical 

Treatment on slopes 

>40%

Yes

1. Related to MSO

2. Mechanical Treatment on 

slopes >40%

Yes

1. Related to MSO

2. Mechanical 

Treatment on slopes 

>40%

Treatments in MSO 

Nest Cores

No Yes, hand thinning 

122 acres and 

prescribed burning all 

(785 acres total)

Yes, hand thinning 122 

acres and prescribed 

burning all (785 acres 

total)

Yes, hand thinning 122 acres 

and prescribed burning all 

(785 acres total)

Yes, hand thinning 

and prescribed 

burning of 122 acres 

total.

Acres Treated by 

Cable Logging within 

MSO PACs6

0 0 acres 465 acres 0 acres 0 acres

Acres Treated by 

Helicopter Logging 

within MSO PACs7

0 267 acres 0 acres 267 acres 0 acres

Total Temp Roads 

Mileage

0 miles 16.95 miles

14.43 DLH

2.52 MM

21.20 miles

17.61 DLH

3.59 MM

15.39 miles

12.87 DLH

2.52 MM

12.92 miles

10.40 DLH

2.52 MM

Temp Road Mileage 

within MSO PACs

0 miles 4.7 miles 4.7 miles 3.1 miles 3.1 miles

System Road 

Decommissioning

0 miles 4.38 Miles 4.38 Miles 4.38 Miles 4.38 Miles

 6 Indicates acres where all snags would have to be removed for safety purposes.

7 Indicates acres where all snags would have to be removed for safety purposes
32 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Table 13: Comparison of Effects between Alternatives

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Percentage of Project 

Area predicted to have 

active crown fire posttreatment

57% Total

51% DLH

70% MM

8% Total

10% DLH

2% MM

7% Total

9% DLH

2% MM

7% Total

9% DLH

2% MM

28% Total

32% DLH

19% MM

Percentage of MSO 

PAC acreage predicted 

to have active crown 

fire post-treatment

65% of PACs

65% DLH

66% MM

9% of PACs

18% DLH

1% MM

9% of PACs

17% DLH

1% MM

9% of PACs

17% DLH

1% MM

31% of PACs

37% DLH

25% MM

Percentage of project 

area predicted to have 

high soil burn severity 

in simulated wildfire 

post-treatment

39% DLH

62% MM

8% DLH

1% MM

8% DLH

1% MM

8% DLH

1% MM

30% DLH

17% MM

Anticipated discharge 

(cfs) within DLH after 

a simulated wildfire, 

during Schultz Rain 

Event8

2,014 cfs 804 cfs 804 cfs 804 cfs 1,409 cfs

Total sediment 

delivery (tons) after 

simulated wildfire9

14,912 tons 

DLH

2,445 tons MM

8,277 tons DLH

1,432 tons MM

8,277 tons DLH

1,432 tons MM

8,277 tons DLH

1,432 MM

12,977 tons DLH

1,551 MM

 8 Schultz rain event equates to the rain event on July 20, 2010, which produced approximately 1.78 inches in 45 minutes over the area impacted by the Schultz fire. Estimate 

is only for DLH as there no flow data for MM to inform modeling .

9 In first year after simulated wildfire
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 33

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Projected length of 

treatment 

effectiveness10

n/a The silviculture analysis 

documents that after 40 

years, the majority of 

the areas that would be 

mechanically treated or 

hand thinned would 

have Basal Areas, 

Canopy covers, and 

trees per acres that are 

lower than the current 

conditions. 

In area of burn only 

treatment effectiveness 

last between 20 and 40 

years before Basal 

Areas and Canopy 

Cover return to or 

exceed pre-treatment 

conditions.

The silviculture analysis 

documents that after 40 

years, the majority of 

the areas that would be 

mechanically treated or 

hand thinned would 

have Basal Areas, 

Canopy covers, and 

trees per acres that are 

lower than the current 

conditions. 

In area of burn only 

treatment effectiveness 

last between 20 and 40 

years before Basal 

Areas and Canopy 

Cover return to or 

exceed pre-treatment 

conditions.

The silviculture analysis 

documents that after 40 

years, the majority of the 

areas that would be 

mechanically treated or hand 

thinned would have Basal 

Areas, Canopy covers, and 

trees per acres that are lower 

than the current conditions. 

In area of burn only 

treatment effectiveness last 

between 20 and 40 years 

before Basal Areas and 

Canopy Cover return to or 

exceed pre-treatment 

conditions.

The silviculture 

analysis documents 

that after 40 years, 

the majority of the 

areas that would be 

mechanically treated 

or hand thinned 

would have Basal 

Areas, Canopy 

covers, and trees per 

acres that are lower 

than the current 

conditions. 

In area of burn only 

treatment 

effectiveness last 

between 20 and 40 

years before Basal 

Areas and Canopy 

Cover return to or 

exceed pre-treatment 

conditions.

 10 Refers to the duration of time before additional mechanical thinning would be needed to restore post-treatment conditions. This does not include maintenance burning, 

which is anticipated to extend the effectiveness of treatments. 
34 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Total number of trees 

>18” dbh within cable 

logging corridors to be 

removed in MSO 

PACs

0 0 132 Total

108 DLH

24 MM

0 0

Number of Trees >24” 

dbh within cable 

logging corridors to be 

removed in MSO 

Recovery Habitat

0 0 206 Total

206 DLH

0 MM

0 0

Acres of treatment 

where all snags have 

to be removed for 

safety within MSO 

PACs

0 267 acres 391 acres 267 acres 0 acres 

Temp Road Mileage 

within MSO PACs

0 miles 4.7 miles 4.7 miles 3.1 miles 3.1 miles

Road 

Decommissioning

0 miles 4.38 miles 4.38 miles 4.38 miles 4.38 miles
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 35

Actions Alternative 1 –

No Treatment

Decision Alternative 2 – Proposed 

Action with Cable 

Logging

Alternative 3 – Proposed 

Action without Cable Logging

Alternative 4 –

Minimal Treatment

Overall effects to 

MSO

No Impact May have impacts to

breeding owls as 

treatments could occur 

within PACs during the 

breeding season for up 

to two years; areas 

treated by helicopter 

would affect quality of 

critical habitat in the 

short-term through the 

removal of snags. Longterm benefits would 

include reduction in the 

potential for highseverity wildfire. 

May have impacts to

breeding owls as 

treatments could occur 

within PACs during the 

breeding season for up 

to two years. Areas 

treated by cable logging

would affect quality of 

critical habitat in the 

short-term through the 

removal of snags. Longterm benefits would 

include reduction in the 

potential for highseverity wildfire. 

 

May have impacts to

breeding owls as treatments 

could occur within PACs 

during the breeding season 

for up to two years; areas 

treated by helicopter would 

affect quality of critical 

habitat in the short-term 

through the removal of 

snags. Long-term benefits 

would include reduction in 

the potential for highseverity wildfire. 

May have impacts to

breeding owls as 

treatments could 

occur within PACs 

during the breeding 

season for up to two 

years. The project 

activities may affect, 

but are not likely to 

adversely affect 

MSO critical habitat 

due to the lack of 

having to remove 

habitat components 

(such as snags) for 

safety requirements 

or harvesting 

operations (e.g. cable 

corridors). 

Total 

Implementation Cost 

(Net Timber Value 

minus Cost of 

Implementation)

$102,000

(cost of 

archaeological 

surveys 

completed)

$8,011,548 $7,323,094 $8,512,238 $4,082,599
36 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Best Available Science 

My decision is based on consideration of the best available science. The record contains a 

thorough review of relevant scientific information and relevant opposing views and, where 

appropriate, acknowledges incomplete or unavailable information, scientific uncertainty and risk.

Specifically, the extensive literature cited by specialists, listed in the FEIS, shows that relevant 

literature has been reviewed and considered in preparing the EIS. The record shows that literature 

cited by the public during the comment period has been reviewed and considered as appropriate. 

Consideration of Unavoidable Adverse Effects

Overall, this decision considers the trade-offs between short-term adverse effects (i.e., 

environmental harm) and long-term benefits. Implementation of this decision will result in some 

unavoidable short-term adverse effects on a threatened species and its critical habitat, scenery 

values (short term, related to viewshed), soil and water resources (short term, related to 

compaction during treatment), recreation access, and air quality (short term, during prescribed 

fire activities). However, the selected alternative includes design features (Appendix B) that will 

reduce these adverse effects to the extent practicable while still achieving project objectives. In 

addition, the potential effects of not doing anything outweigh the short term effects to forest 

resources. 

My decision considered all comments received during scoping periods, workshops, public 

meetings, field trips, and the formal notice and comment period. This decision considers the input 

received from the public and our partners throughout the process. We recognize that there is a 

range of public opinion regarding the harvesting methods analyzed, particularly in the Dry Lake 

Hills. However, I have concluded that this decision is an informed one that best meets the 

project’s purpose and need while balancing the diversity of public input. This decision will move 

the project area toward desired conditions and considers and discloses the environmental 

consequences (both positive and negative) of the selected actions. Monitoring of the effects on 

not only the Mexican spotted owl and its habitat components, but also other mixed conifer species 

(including the red squirrel) will help inform other future projects. As stated by the USFWS in the 

final Biological Opinion, “FWPP gives us a unique opportunity to learn about treatment effects to 

the Mexican spotted owl and its habitat” (USFWS 2015). 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 37

Public Involvement

FWPP has been listed on the Coconino National Forest Schedule of Proposed Actions (SOPA) 

since January, 2013. Throughout the project’s proposed action development and the scoping 

period, the FWPP interdisciplinary team (IDT) met with interested parties, agencies and Tribes, 

including the Arizona Department of Game and Fish, the United States Fish and Wildlife Service, 

the Ecological Restoration Institute of Northern Arizona University, and environmental groups to 

discuss the proposed action. 

Scoping

The formal 30-day public scoping period began with the publication of the Notice of Intent (NOI) 

to prepare an Environmental Impact Statement in the Federal Register on April 11, 2013, and 

ended May 13, 2013. The NOI referenced the public open house for May 1, 2013 hosted by the 

Forest Service and noted that the Greater Flagstaff Forests Partnership (GFFP) would be hosting 

meetings on behalf of the City of Flagstaff, and provided information about the external project 

website (www.flagstaffwatershedprotection.org). 

Scoping letters, including a link to the proposed action on the Coconino National Forest website, 

were sent as hard copies to 606 individuals, including permittees, property owners, and state and 

local agencies. Thirteen personalized letters to tribal contacts were mailed simultaneously, and 

included hard copies of maps and the proposed action. An additional 157 cover letters with links 

to more detailed project information were sent to email contacts. Chapter 4 of the EIS lists the 

agencies, organizations, and tribes who received copies. The project record contains the 

comprehensive list of all those listed above and the individuals who were contacted.

A press release was issued from the Coconino National Forest on April 10, 2013 and a public 

open house on the proposed action was held on May 1 to provide more information on potential 

activities, funding sources, and collaboration with the city. Notices regarding the meetings were 

posted on the Coconino National Forest website and the Flagstaff Watershed Protection Project 

external website. 

Approximately 19 people attended the public meeting. Throughout April 2013, the City of 

Flagstaff hosted three outreach meetings targeted at specific interest groups, including recreation 

user groups, adjacent land owners in the Mount Elden area, and other interest groups. The Forest 

Service hosted an additional public meeting on August 24, 2013 geared toward the primarilyseasonal residents of Mormon Lake. Twenty residents attended the meeting, held at the Mormon 

Lake Fire Station, and primarily voiced concerns about dust abatement and ensuring Best 

Management Practices are followed during implementation. 

In response to scoping, 25 submissions were received from the public, which contained a total of 

144 comments (see the Scoping Summary document in the project record). The following issues 

were identified in scoping comments and were used to determine the scope of the analysis and 

develop alternatives to the proposed action:

1. Restoration versus Fire Hazard Reduction Issue: A common public concern voiced 

during scoping was the importance and sustainability of restoring ecosystems versus a 

purely fire-hazard reduction approach to treatment. There is concern that a fire-hazard

reduction approach would result in unnecessarily departing from historical conditions that 

could be more sustainable long term. 
38 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

2. Mixed Conifer Issue: Several comments included concerns about different aspects of 

treatments in mixed conifer including what was perceived to be a proposal to change the 

Fire Regime of mixed conifer areas, the potential for vegetation conversion, and the 

differences between wet and dry mixed conifer vegetation types and treatments. 

Several comments also voiced concerns over treatments proposed in mixed conifer 

vegetation types due to its relative rarity and importance to wildlife. 

3. Conservation of Large (16” dbh+) Trees Issue: some comments indicated that the Forest 

Service should adopt project-level restrictions to minimize the cutting of trees greater 

than 16 inches dbh. 

4. Monitoring Issue: Several comments included concerns over the lack of monitoring for 

anything other than the Mexican spotted owl and thus the potential to not know the 

effects of treatments on other wildlife and habitats. 

5. Snag Retention and Creation Issue: There is some concern over the loss of snags due to 

cable logging and also the effectiveness and viability of snags created through girdling 

and topping healthy trees compared to snags created through natural processes.

6. Prescribed Burning/Maintenance Issue: Public comments showed concern over proposed 

exclusion of prescribed burning in areas with mixed conifer on steep slopes due to the 

effectiveness and importance of prescribed fire. Concerns over whether maintenance 

burning would be included and what the intervals would be for the different fire regimes 

also arose during the scoping period. 

7. Significance of Forest Plan Amendments Issue: The public voiced a concern about the 

significance of the proposed Forest Plan amendments included in one more of the 

alternatives due to the impact of these amendments on wildlife species including the 

northern goshawk and the Mexican spotted owl. 

8. Visual Effects Issue: The IDT identified a concern about potential effects on scenic 

resources as a result of implementation due to the highly-valued view sheds contained 

within the project area.

In addition to the issues identified above, a number of issues identified from public scoping were 

addressed through Design Features incorporated into one or more of the alternatives. Chapter 2 of 

the FEIS contains more information about Design Features. A description of issues relevant to the 

proposed action and how they were each addressed appears in the FEIS in Chapter 1. 

Publication of the Draft Environmental Impact Statement

On July 3, 2014 we published a draft environmental impact statement (DEIS) and the Federal 

Register published a notice of availability. This date began the 45-day comment period for public 

input. The DEIS included three action alternatives and the no action alternative. The DEIS 

summarized information from specialist reports on the potential effects of each alternative to fire 

and fuels, air quality, forest structure and health, soil and water resources, wildlife, scenery, 

economics, invasive plant species, sensitive plants, recreation and heritage. In anticipation of 

most people not having the time to read the entire DEIS, various shortened versions were 

provided, including a Reader’s Guide and a Summary with Comparison Tables, pulled from 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 39

Chapters 1 and 2 of the DEIS. Numerous outreach events were also held during the comment 

period, including two open houses (held July 17 and 22), two presentations and field visits with 

neighborhoods abutting the project area, a meeting with the Mormon Lake community, and 

meetings with special interest groups including Flagstaff Biking Organization and the Ecological 

Restoration Institute. In addition, information was disseminated through local media outlets, 

including KNAU and the Arizona Daily Sun. The FS Project Manager was also available for 

questions throughout the comment period, and offered to meet with interested individuals at their 

convenience (see email from August 11, 2014 in the Project Record). A Map Packet was made 

available on the Forest Service project website, along with copies of individual specialist reports, 

and an external website was developed in order for the public to more easily access information 

about the project (www.flagstaffwatershedprotection.org). Interactive Google Earth project maps 

were posted on the external website to allow the public to more easily determine locations of 

proposed treatments, temporary roads, and harvesting systems. 

Response to DEIS, and Changes from Draft to Final

We received 107 submissions during the comment period with 530 individual comments within 

those submissions. I appreciate the time, energy, and passion expressed by all who shared their 

interests, views, and concerns. Three main themes emerged from the comments received on the 

DEIS:

1. Impacts from cable logging

a. Erosion

b. Unknown since it’s not common in southwest

c. Visual

2. Implementation/Monitoring

a. Forest Service oversight of contractor(s) (including marking, tree selection, and 

during harvesting)

b. Monitoring tied to wildlife, treatment effectiveness, noxious weeds and soil 

impacts

c. Maintenance (and how to finance)

3. Recreation

a. Effects on trails (system and non-system)

b. Overlap with the Mount Elden/Dry Lake Hills Recreation Planning Project

c. Area closures/safety concerns/duration during implementation

d. Temp road to trail conversions 

e. Public outreach

Many of the comments (and additional information provided after the release of the DEIS) 

resulted in modifications to the alternatives and changes to the analysis of potential effects. The 

comments provided a framework for further analysis the interdisciplinary team included in the 

FEIS, and, ultimately, contributed to my decision. Responses were provided for each of those 

comments or concern areas. The extensive response to comments (available online and

summarized in the EIS) describes how each comment was addressed in the EIS analysis.

In addition to responding to comments in the EIS, the IDT made a number of changes to the FEIS 

based on comments and meetings with the public and partners. The main changes between the 

draft and final EIS include:
40 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

• Inclusion of a Socio-Economics section to address public comments related to project 

impacts on local economies and communities.

• Change in location of the temporary road proposed south of Mount Elden and north of 

the private property boundary. 

• More detailed information in the Scenery section about cable logging examples both in 

the southwest and in other areas with similar ecosystems, such as eastern Montana.

• Modifications to Design Features, including: 

o Adding a monitoring component to the snag creation design feature to aid in 

determining the effectiveness.

o Adding a design feature to protect caves and karst, and sink holes

o Clarification on the protection of existing forest system trails during 

implementation

o Addition of design features related to protection of MSO

In addition, an Implementation Plan has been developed to assist in communicating the steps 

necessary to implement a forest thinning project (e.g. timber preparation, contracting, contract 

oversight); how design features will be executed; and how the treatments will likely be phased.

Coordination with Federal, State, and County Organizations

In addition to the formal public involvement process; my staff met with federal and state agencies 

and county officials on a number of occasions to solicit input and inform the alternatives. As 

mentioned previously, the City of Flagstaff had a representative on the IDT, and we routinely 

provided updates and briefings on the status of not only the planning effort, but also the 

implementation of road maintenance, hand thinning and prescribed burning within the FWPP 

boundary (covered under previous NEPA – see the General Location section for more 

information). 

For example, my staff met with and worked side-by-side with the Fish and Wildlife Service 

(FWS) on a number of occasions to discuss treatments within MSO habitat and to develop design 

features and mitigation measures to reduce potential impacts. We also worked very closely with 

FWS to draft a MSO Monitoring Plan, which was finalized during the formal consultation 

process (AESO/SE 02EAAZ00-2013-F-0190). .

My staff also met with Arizona Game and Fish Department (AZGFD) to discuss concerns and 

options for treatments within mixed conifer habitat and the potential effects on non-listed species, 

such as the red squirrel.
41

Alternatives Analyzed in Detail

Alternative 1: No Action

National Environmental Policy Act (NEPA) regulations require the no action alternative to be 

included as a baseline for comparison to all action alternatives. Under this alternative, no new 

areas would be treated in the FWPP area. Implementation of previous NEPA decisions, including 

Jack Smith Schultz and the Eastside Fuels Reduction and Forest Health Restoration projects 

could continue. For the Environmental Impact Statement, specialists analyzed the impacts of a 

modeled wildfire occurring under existing conditions as a basis of comparison between effects. 

Alternative 2: Proposed Action with Cable Logging Emphasis on 

Steep Slopes

Alternative 2 emphasizes the use of cable logging wherever plausible to remove cut material on 

steep slopes. Under this alternative, treatments would include mechanical and hand thinning as 

well as prescribed fire on the remaining acres (approximately 8,938 acres). Both Forest Plan 

amendments would be necessary for this alternative. 

Mechanical tree thinning up to 18 inches dbh would occur within Mexican spotted owl protected 

activity centers (MSO PACs) with a desired condition of trees greater than 16 inches dbh 

contributing more than 50 percent of the stand basal area and maintaining a minimum of 40 

percent canopy cover in pine-oak and 60 percent in mixed conifer per the MSO Recovery Plan 

(2012, pp. 276-277), followed by prescribed burning. Hand thinning up to 5 inches dbh in 

approximately 80 percent of the Schultz Creek Nest Core and prescribed burning in all nest cores 

would occur. In addition, hand thinning up to 9 inches dbh in the DLH, mechanical thinning up to 

24 inches dbh on MM, and prescribed burning at both areas would also occur within MSO 

nest/roost habitat in coordination with the US Fish and Wildlife Service (FWS) to reduce the 

potential for high severity wildfire. No cable logging would occur within MSO nest cores and no 

temporary roads would be located within MSO nest cores. Some treatments proposed within 

occupied PACs may need to occur during the breeding season (March 1-August 31) and would be 

coordinated with FWS. Treatments in nest cores would not occur during the breeding season. 

Prescribed fire would include initial pile burning to remove slash accumulated through 

harvesting, followed by broadcast burning. In areas where fuel loading allows, broadcast burning 

may occur prior to thinning. Maintenance burning may occur every five to seven years following 

implementation in order to maintain lower fuel loading levels and to restore a frequent, lowseverity fire regime. Mixed conifer on steep slopes may only receive one broadcast burn through 

the life of the project due to the difficulty of implementation in these fuel types and terrain, and 

also because the historic Fire Return Interval in some vegetation types is historically longer than 

the life of this project. Prescribed burning techniques in wet mixed conifer would target 

accumulated dead and down material rather than using broadcast burning ignition patterns. Other 

slash removal options as described in the Implementation Methods section of the FEIS could also 

be used in lieu of burning, including biomass removal.

Alternative 3: Proposed Action without Cable Logging

Alternative 3 would be similar to Alternative 2 in that the described treatments would be the 

same; however this alternative addresses visual concerns and distribution of snags and large trees 

due to the absence of proposed cable corridors. Under Alternative 3, treatments would utilize 

ground-based harvesting across the majority of the project area, with helicopter logging for 
42 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

critical areas that are too steep, rocky, or inaccessible to be treated by steep slope ground-based 

equipment. No cable logging would occur under this alternative, which would reduce the need to 

remove some large trees and snags on steep slopes and also the need to create corridors. The 

enclosed cabs of steep-slope machinery precludes the need to remove hazard trees, and though 

areas proposed for treatment by helicopter would still need to have hazard trees removed, the 

distribution of snags and large trees could be factored into treatment placement more easily. Both 

Forest Plan amendments would be necessary for this alternative. 

Alternative 4: Minimal Treatment Approach

This alternative would be similar to Alternatives 2 and 3; however the purpose of Alternative 4 is 

to implement the minimum amount of treatment necessary to meet the purpose and need. 

Treatments are proposed for those areas with dense fuel loading where topography aligns with 

dominant winds and the probability of severe effects to soil resources from a wildfire is greater, 

based on FLAM MAP 5.0 modeling of both fire behavior and fire spread under Schultz fire 

weather conditions. Specifically, factors considered include: fire hazard rating, potential damage 

to soils (from high severity fire and also harvesting methods), MSO habitat, and the type of 

harvesting methods necessary to affect change. 

Under Alternative 4, approximately 3,459 acres along the base of Dry Lake Hills and Mount 

Elden and the upper, flatter tops would receive basically the same treatments proposed in 

Alternatives 2 and 3, though under this alternative more areas are proposed for hand thinning and 

prescribed burning instead of cable or helicopter logging in order to reduce the potential impacts 

from temporary road network associated with those harvesting methods (roughly 46 percent of 

the DLH project area). Both Forest Plan amendments would be necessary for this alternative. 

Additionally, treatments are focused on the area south and east of FR420; the portion of the 

project area between FR420 and the Kachina Peaks Wilderness would still be treated but under 

the constraints of the analysis and decision for the Jack Smith Schultz Fuels Reduction and Forest 

Health Restoration Project. Thus, no new analysis would be performed for those areas under this 

alternative. 

The Spruce Avenue Wash was identified as a high priority area due to the fuel loading, 

topography, size and also its location relative to the City of Flagstaff and MSO PACs. The 

portion of the Mount Elden MSO PAC within the Spruce Avenue Wash would also be treated 

under the same parameters described in Alternatives 2 and 3. The Schultz Creek MSO PAC and 

nest core were identified in conjunction with the FWS as high priority areas, and would also 

receive the same treatment described for Alternatives 2 and 3.

For MM, treatments would occur on 2,343 acres. The same methodology used for treatment 

placements in the DLH area was applied to MM to determine where to focus treatments. Under 

Alternative 4, the wet mixed conifer belt and MSO nest cores would not be treated, (roughly 21 

percent of the MM area); however treatments would occur below and above that belt. 

Areas not included in this alternative would be designated as No Treatment. All treated acres 

would include prescribed burning in the manner described under Alternative 2: initially pile 

burning to remove slash accumulated through harvesting, followed by broadcast burning. 

Maintenance burning in ponderosa pine may occur every five to seven years following 

implementation in order to maintain lower fuel loading levels and to restore a frequent, lowseverity fire regime. Mixed conifer on steep slopes may only receive one broadcast burn through 

the life of the project due to the difficulty of implementation in these fuel types and terrain, and 

also because the historic Fire Return Interval may be longer than the life of this project. Other 

slash removal options as described in the Implementation Methods section of the FEIS could also 

be used in lieu of burning, including biomass removal.
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 43

Alternative 4 incorporates the goal of retaining large young trees and old trees within the project 

area through a modified the Large Tree Retention Strategy (LTRS), which is detailed in Chapter 2 

of the FEIS.

Alternatives Considered But Eliminated from 

Detailed Study

The National Environmental Policy Act requires Federal agencies to rigorously explore and 

objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating 

any alternatives that were not developed in detail (40 CFR §1502.14). Public comments received 

in response to the proposed action provided suggestions for alternative methods for achieving the 

purpose and need. The following two alternatives identified through scoping comments were 

discussed by the IDT and determined to not meet the purpose and need for the project. 

Alternative 5: No Temporary Road Use or Forest Plan 

Amendments & Hand Thinning Only

This alternative would involve hand thinning only with no amendments to the Forest Plan, and 

would utilize existing, open roads only. No new temporary roads would be constructed and no 

existing, closed roads would be utilized. Under this alternative achieving the desired conditions of 

reduced high-severity wildfire and achieving a sustainable forest structure would not be possible 

due to: the preponderance of trees greater than 9 inches dbh, (the standard limit for hand thinning 

treatments), the safety concerns and feasibility of hand felling and piling larger trees on steep 

rocky slopes, the inability to remove cut material which would leave an overabundance of fuels 

on the ground, and the subsequent need for extensive hand piling and burning on steep slopes.

Alternative 6: Kachina Peaks Wilderness 

This alternative would include expanding the DLH portion of the project area to include treating 

in the Kachina Peaks Wilderness. While portion of the wilderness could potentially benefit from 

treatments that reduce the potential for uncharacteristically large, high-severity wildfire, the 

inaccessibility, high fuel loadings, and rough terrain of the area would require road development 

and treatment of an extent that would clearly be in conflict with the objectives of a designated 

Wilderness area. Namely, that of maintaining wilderness in such a manner that “ecosystems are 

unaffected by human manipulation and influences so that plants and animals develop and respond 

to natural forces” (FSM 2320.2(2)). 

Environmentally Preferred Alternative

The NEPA implementing regulations (Section 1505.2) require that the alternative(s) that best 

promotes national environmental policy as expressed in NEPA, Section 101, be identified in the 

decision as the “environmentally preferable alternative” or alternatives. This is ordinarily “the 

alternative that causes the least damage to the biological and physical environment and best 

protects, preserves, and enhances historical, cultural, and natural resources” (FSH 1909.15, 05).
44 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

The environmentally preferable alternative is not necessarily the alternative that would be

implemented, and it does not have to meet the underlying need for the project. It does, however, 

have to cause the least damage to the biological and physical environment and best protect, 

preserve, and enhance historical, cultural, and natural resources.

For this plan, I believe the decision is the environmentally preferable alternative. In comparison 

with the other alternatives, this alternative represents the greatest reduction in severe wildfire 

hazard while also protecting valuable ecosystem service components through the targeted use of 

helicopter logging within MSO protected habitat and within the viewshed of Flagstaff rather than 

cable logging or no treatment. This alternative will also result in the increased retention and 

protection of large trees through incorporation of the Large Tree Retention Strategy and the use of 

helicopter logging on a greater acreage than under Alternative 2. The decision defers cable 

logging within MSO protected activity centers, which results in fewer temporary roads within that 

habitat and thus fewer acres of disturbance than under Alternative 2. While Alternative 4 would 

have the least direct impact to forest resources, it would also leave large areas vulnerable to 

uncharacteristic wildfire.

Findings Required by Law and Regulation

The EIS has been prepared in accordance with the following laws and regulations:

Clean Air Act of 1970

The Clean Air Act of 1970 and its amendments provide for protecting and enhancing the nation’s 

air resources. The Federal and State ambient air quality standards are not expected to be exceeded 

as a result of implementing this decision. This action is consistent with the Clean Air Act.

Clean Water Act

The Clean Water Act, as amended, regulates dredging and filling freshwater and coastal wetlands. 

Section 404 (33 USC 1344) of the Clean Water Act prohibits discharging dredged or fill material 

into waters (including wetlands) of the United States without first obtaining a permit from the 

U.S. Army Corps of Engineers. Wetlands are regulated in accordance with federal Non‐Tidal 

Wetlands Regulations (Sections 401 and 404). No dredging or filling is part of this action and no 

permits are required. In addition, my decision will improve conditions with respect to 

sedimentation of State‐listed impaired streams (FEIS, Chapter 3, Soil and Water Resources

section). This project is consistent with the Clean Water Act.

Endangered Species Act of 1973

The Endangered Species Act (ESA) (16 USC 1531 et seq.) requires that any action authorized by 

a Federal agency does not jeopardize the continued existence of a threatened or endangered 

species, or result in the destruction or adverse modification of the critical habitat of such species.

The Mexican spotted owl (Strix occidentalis lucida) is the only threatened species within the 

FWPP analysis area. Formal consultation with the US Fish and Wildlife Service (USFWS) under 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 45

Section 7 of the Endangered Species Act of 1973, as amended (16 USC 1531 et seq.), was

requested by the Forest Service on January 12, 2015 for project effects on the Mexican spotted 

owl. The analysis for Mexican spotted owl and its critical habitat concluded there is potential for 

short-term adverse effects to owls. Long-term effects of the project should be beneficial to 

Mexican spotted owls by enhancing key habitat components for Mexican spotted owl and their 

prey. The selected alternative may effect, and is likely to adversely affect Mexican spotted owl 

and its critical habitat (Thompson 2014).

On June 5, 2015, the USFWS issued the final Biological Opinion (BO) (AESO/SE O2EAAZ00-

2013-F-0190), which stated that while implementation of the FWPP has the potential to 

negatively affect the owl and its habitat, the project will not jeopardize the continued existence of 

the Mexican spotted owl, and will not destroy or adversely modify its designated critical habitat. 

Incidental take for Mexican spotted owl (per section 9 of the Endangered Species Act) was 

attributed at the PAC level. The majority of incidental take for actions implemented under the 

FWPP will be in the form of short-term harassment. The amount of take tiers to (is included 

within) the amount of take anticipated under the 2012 biological opinion for the Forest Plan, 

according to the Biological Opinion for FWPP (USDI FWS 2015, pp. 37-39).Conservation 

recommendations associated with the incidental take were included in the BO. The full Biological 

Opinion is located within the project record. 

Bald and Golden Eagle Protection Act 

All golden and bald eagles, regardless of status, are protected under the Bald and Golden Eagle 

Protection Act. We requested technical assistance from the USFWS to ensure the intent of the 

Bald and Golden Eagle Protection Act was met while implementing the actions associated this 

decision. With the incorporated design features (Appendix B) this decision will not result in take 

for either species (Thompson 2014). This decision aligns with the direction recommended by the 

U.S. Fish and Wildlife Service including “Conservation Assessment and Strategy for Bald eagles 

in Arizona” (Driscoll et. al. 2006) in conjunction with “Bald Eagle National Guidelines” (USDI 

FWS 2007). This decision aligns with the USFWS-issued “Interim Golden Eagle Technical 

Guidance: Inventory and Monitoring Protocols and Other Recommendations in Support of 

Golden Eagle Management and Permit Issuance” (Pagel et al. 2010).

Forest Service Sensitive Species

Forest Service Sensitive Species within the FWPP action area (project boundary plus 0.5 mile 

buffer) include the Bald Eagle, Northern goshawk, American peregrine falcon, Navajo Mogollon 

vole, Allen’s lappet-browed bat, Pale Townsend’s big-eared bat, spotted bat, and the Northern

leopard frog. As disclosed in Chapter 3 of the FEIS, project activities associated with this 

decision may impact individual but are not likely to cause a trend toward listing or loss of

viability.

Management Indicator Species

The wildlife section of Chapter 3 in the FEIS contains descriptions of each of the management 

indicator species (MIS) identified for management areas (MAs) within the analysis area and a

discussion of the relationship of the effects of each project alternative on forest-level population

and habitat trends for each of these species. MSO protected habitat treatments may include both 

mixed conifer and ponderosa pine cover types. The MIS analyzed for FWPP include Abert 
46 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

squirrel, red squirrel, Mexican spotted owl, elk, northern goshawk, pygmy nuthatch, turkey, hairy 

woodpecker, Red-naped sapsucker, mule deer, Juniper (plain) titmouse, and pronghorn antelope. Actions 

associated with this decision will not result in changes to MIS forest-wide population or habitat 

trends.

Migratory Bird Treaty Act and Executive Order 13186 

The selected alternative with the design features described in Chapter 2 of the FEIS provides for 

adequate conservation measures for migratory birds. The migratory bird analysis discloses that 

thinning and broadcast burning operations activities may lead to loss of egg viability or injury or 

death to nestlings. Overall, unintentional take of some individual birds may occur. However, no 

measurable negative effect to any of the bird populations is associated with the selected 

alternative (FEIS Chapter 3, “Migratory Birds” section).

National Environmental Policy Act

The National Environmental Policy Act (NEPA) requires Federal agencies to complete detailed 

analyses of proposed actions that significantly affect the quality of the human environment. The 

Act’s requirement to prepare an environmental analysis is designed to provide decision‐makers 

with a detailed accounting of the likely environmental effects of a proposed action prior to 

adoption and to inform the public of (and encourage comments on) such effects. The Final EIS 

analyzes the alternatives and displays the environmental effects in conformance with NEPA

standards. The procedural requirements of the NEPA have been followed.

National Forest Management Act

The National Forest Management Act (NFMA) amends the Forest and Rangeland Renewable 

Resources Planning Act of 1974 (RPA) and sets forth the requirements for Land and Resource 

Management Plans (Forest Plans) for the National Forest System. The project was reviewed 

against the direction in the current Coconino National Forest Land Management Plan (Forest 

Plan), as amended (USDA 1987) and 36 CFR 219.17(b)(3). Consistency evaluations are included 

in each resource report and in Appendix C of the FEIS. 

There is a need to amend the Forest Plan to allow implementation of this decision. I have 

determined that the two amendments are appropriate and project-specific. The amendments are

summarized in the “Decision” section of this document under the heading Forest Plan 

Amendments, with further details and all changes shown in Appendix A.

I have determined that Amendment 1 and 2 are authorized changes to the Forest Plan being made 

pursuant to 36 CFR 219.13. These plan amendments were included as part of the proposed action 

to be consistent with the Forest Service NEPA procedures. These amendments include the same 

scope and scale of the specific activities which they were included to allow exception to in the 

Forest Plan. The effects of the decision, which includes the same effects of these plan 

amendments, are fully disclosed in the Final EIS.

This decision does not change any other management requirement in the Forest Plan designed to 

protect resources. Further, I have determined that the amendments will have no effects on the 

long-term relationship of goods and services projected by the current Forest Plan nor will they

affect the long-term relationship of goods and services projected under the revised Forest Plan, 
Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 47

which is currently in the NEPA process. This amendment does not substantially change desired 

land conditions as stated in either plan, but provides more specific treatment for the area. 

The public was notified at scoping that amendments would be part of this analysis and the 

decision. The public was advised of the need for the amendments, and their components were 

described in the DEIS that was issued for public comment. Documentation of the NFMA 

significance review of amendment components is contained in the project file.

My decision is consistent with Forest Plan goals and objectives, standards and guidelines, as 

documented in the resource sections in Chapter 3 of the FEIS and in “Rationale for My 

Decision.” Forest Plan standards are inflexible and require that decisions comply with the 

standards or the Plan must be amended accordingly.

National Historic Preservation Act of 1966

Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to 

consider the potential effects of a preferred alternative on historic, architectural, or archaeological 

resources that are eligible for inclusion on the National Register of Historic Places (NRHP) and to 

afford the President’s Advisory Council on Historic Preservation an opportunity to comment. 

Section 110 of the Act requires Federal agencies to identify, evaluate, inventory, and protect 

NRHP resources on properties they control. Potential effects on archaeological and historic 

resources have been evaluated in compliance with Section 106 of the NHPA. 

The NHPA provides comprehensive direction to Federal agencies to identify, evaluate, treat, 

protect, and manage historic properties. The NHPA expands the NRHP and it establishes the 

Advisory Council on Historic Preservation (ACHP) and SHPOs. Section 106 of the NHPA 

directs all Federal agencies to take into account effects of their undertakings (actions, financial 

support, and authorizations) on properties included in or eligible for the National Register. The 

ACHP’s regulations (36 CFR §800) implement Section 106 of the NHPA. Section 110 of the Act 

sets inventory, nomination, protection, and preservation responsibilities for federally owned and 

administered historic properties.

The Southwestern Region of the Forest Service developed a programmatic agreement with the 

State Historic Preservation Office in which the Forest outlined a plan to complete NRHP 

evaluations prior to project implementation for all unevaluated cultural sites located in the area of 

potential effect.The Arizona State Historic Preservation Officer (SHPO) has been consulted and 

on March 5, 2014 concurred with the project’s determination of No Adverse Effect to historic 

properties (SHPO-2013-1161(118074)).

This commitment under the programmatic agreement satisfies legal requirements for this decision

Other Laws and Executive Orders

Executive Order 11593

Executive Order 11593, entitled Protection and Enhancement of the Cultural Environment, also 

includes direction about the identification and consideration of historic properties in Federal land 

management decisions. The order, issued May 13, 1971, directs Federal agencies to inventory 

cultural resources under their jurisdiction, to nominate to the NRHP all federally owned 
48 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

properties that meet the criteria, to use due caution until the inventory and nomination processes 

are completed, and to assure that Federal plans and programs contribute to preservation and 

enhancement of properties not federally owned. This project considered effects on historic 

properties as part of the National Historic Preservation Act compliance and thus satisfies the 

requirements of E.O. 11593.

Executive Order 12898 – Environmental Justice

A specific consideration of equity and fairness in resource decision-making is encompassed in the 

issue of environmental justice. Executive Order 12898 provides that, “each Federal agency shall 

make achieving environmental justice part of its mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or environmental effects of its 

programs, policies, and activities on minority populations and low-income populations.” This 

analysis was performed and no adverse impacts are anticipated as a result of any of the 

alternatives; therefore the decision is also not anticipated to result in any disproportionately high 

and adverse human health or environmental effects. See the Environmental Justice section of 

Chapter 3 in the FEIS for a more detailed explanation.

Predecisional Administrative Review Process

This project is subject to the Predecisional Administrative Review Process (Objection Process)

pursuant to 36 CFR 218, subparts A and B. The FEIS and draft ROD are available on-line at:

www.fs.usda.gov/goto/FWPP. These documents are also available for review at the Flagstaff 

Ranger District Office at 5075 N Hwy 89, Flagstaff, AZ 86004.

Objections will only be accepted from those who have previously submitted specific written 

comments regarding the project during scoping or other designated opportunity for public 

comment in accordance with §218.5(a). Issues raised in objections must be based on previously 

submitted timely, specific written comments regarding the proposed project unless based on new 

information arising after the designated comment opportunities.

Objections, including attachments, must be filed via mail, fax, email, hand-delivery, express 

delivery, or messenger service (Monday through Friday, 8:00 a.m. to 4:30 p.m., excluding 

holidays) to: Cal Joyner, Regional Forester, 333 Broadway SE, Albuquerque, NM FAX: (505) 

842-3292, email to: objections-southwestern-regional-office@fs.fed.us. Electronically filed 

objections may be submitted by email in word (.doc), rich text format (.rtf), text (.txt), and 

hypertext markup language (.html). 

Objections must be submitted within 45 calendar days following the publication of a legal notice 

in the Arizona Daily Sun. The publication date in the newspaper of record is the exclusive means 

for calculating the time to file an objection. Those wishing to object should not rely upon dates or 

timeframe information provided by any other source. The regulations prohibit extending the time 

to file an objection. 

At a minimum, an objection must include the following (36 CFR 218.8(d)): 

1. The objector’s name and address, with a telephone number, if available; 

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 50

Appendix A: Forest Plan Amendments

The following Forest Plan amendments are being done under the 2012 Planning Rule per 36 CFR 

219.17 (b)(2), which requires all Forest Plan amendments initiated after May 9, 2012 to utilize the 

2012 Planning Rule.

Amendment 1

Amendment 1 is a specific, one-time variance for managing MSO habitat in the FWPP project 

area. Once the project is complete, current Forest Plan direction will apply to the project area. 

The language proposed does not apply to any other forest project. 

Amendment 1 Description

Amendment 1 will update the terminology referring to MSO habitat types to reflect that of the 

2012 MSO Recovery Plan. Specifically, this amendment will update the definition of protected 

habitat to exclude pine-oak and mixed conifer forests with slopes greater than 40 percent where 

timber harvest has not occurred in the last 20 years and instead including these areas as recovery 

habitat, and change “restricted” habitat to “recovery” habitat. 

This amendment will allow mechanical thinning within 10 PACs and recovery habitat to reduce 

the potential for high-severity wildfire. Amendment 1 will change the treatment diameter limit of 

9 inches dbh to 18 inches dbh in ten MSO PACs11, and will allow the removal of larger trees 

(greater than 18 inches dbh in PACs and 24 inches dbh in recovery habitat).

Amendment 1 will also allow hand thinning in the Schultz Creek nest core up to 5 inches dbh, 

and prescribed burning treatments within all MSO nest cores. The amendment will remove 

language referencing monitoring (pre- and post-treatment, population, and habitat); replacement 

language will defer to a monitoring plan developed specifically for this project by the Forest 

Service, U.S. Fish and Wildlife Service (FWS), and the Ecological Restoration Institute of 

Northern Arizona University and finalized through the formal consultation process. The 

monitoring plan pairs treated and untreated (reference) PACs within and adjacent to the Dry Lake 

Hills and Mormon Mountain portions of the project, and compares occupancy rates, reproduction 

rates, and habitat changes. Reference PACs match the environmental conditions in PACs where 

treatments are proposed, as closely as possible. The monitoring plan will be finalized in 

conjunction with FWS consultation and so is incorporated by reference here. 

The amendment will allow the MSO nest roost recovery area identified within the project area to 

be treated to meet the minimum habitat requirements for MSO nest roost recovery habitat under 

the 2012 revised MSO Recovery Plan. 

Amendment 1 will also remove timing restrictions on treatments within ten MSO PACs for two 

breeding seasons in order to more quickly accomplish implementation and to limit the duration of 

effects on MSO. Treatments will be prioritized to be accomplished within one to two breeding 

seasons, and will be coordinated with FWS. No one PAC will be treated for more than two 

breeding seasons. If treatments within a PAC extend beyond the two year timeframe, timing 

restrictions will apply for the subsequent years (March 1 – August 31). 

Timing restrictions will still apply for activities in nest cores, including hand thinning within the 

Schultz Creek nest core and prescribed burning within all nest cores. 

 11 Ten PACs within the FWPP boundary: De Toro’s, Lockwood, Moore Well, Mormon Mountain, Mormon Mountain 

North, Weimer Springs, Schultz Creek, Mount Elden, Orion Spring, and Weatherford 2
Appendix A – Forest Plan Amendments

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 51

Need for Plan Amendment

MSO PAC field reviews, data evaluation, and vegetation simulation modeling indicate that there 

is a need to mechanically thin trees greater than 9 inches dbh in ten PACs and greater than 24 

inches dbh in recovery habitat within the project boundary in order to facilitate treatments to 

achieve the purpose and need of the FWPP project: to reduce the potential for high-intensity 

wildfire and subsequent flooding. 

There is a need to treat within MSO nest/cores to remove fuels and reduce the potential for

ecologically-damaging wildfire as leaving these areas untreated would not meet the purpose and 

need, and could also hinder the feasibility of prescribed burning in PACs. Lining the core areas 

would be expensive in terms of time, money, and other resource commitments, and would still 

leave these areas vulnerable to high-intensity wildfire. There is a need to treat MSO recovery 

nest/roost replacement habitat to meet the minimum habitat parameters identified in Table C.3 of 

the 2012 MSO Recovery Plan due to the existing forest structure and to put that habitat on a 

trajectory toward desired conditions.

There is a need to replace the monitoring language specified in the Forest Plan in order to better 

incorporate a monitoring plan tiered to the revised MSO Recovery Plan (USFWS 2012) that was

developed by the Forest Service and the Fish and Wildlife Service. Monitoring assesses the 

effectiveness of management actions and provides the adaptive framework needed to develop 

successful management by assisting in determining the short-term effects of thinning and burning 

on Mexican spotted owl occupancy and reproduction, and their habitat. The monitoring plan was

reviewed as part of the consultation process for treatments planned to occur within PACs.

Edited or added/new text is bolded in Table 14. Current Forest Plan direction related to MSO that 

will not be changed under this amendment is not included below. 

Table 14: Amendment 1: Current and Proposed MSO Forest Plan Language

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

MSO Standards

No corresponding direction currently exists. The Flagstaff Watershed Protection Project 

will comply with the biological opinion and 

monitoring protocol developed in 

coordination and consultation with the 

FWS.

Provide three levels of habitat management –

protected, restricted, and other forest and 

woodland types to achieve a diversity of habitat 

conditions across the landscape (p. 65).

Provide three levels of habitat management –

protected, recovery, and other forest and 

woodland types to achieve a diversity of habitat 

conditions across the landscape (p. 65).

Protected areas include delineated protected 

activity centers; mixed conifer and pine-oak 

forests with slopes greater than 40% where 

timber harvest has not occurred in the last 20 

years; and reserved lands which include 

wilderness, research natural areas, wild and 

scenic rivers, and congressionally recognized 

wilderness study areas (Coconino NF Forest 

Plan, p. 65).

Within the Flagstaff Watershed Protection 

Project boundary, protected areas include 

delineated protected activity centers; and 

reserved lands which include wilderness, 

research natural areas, wild and scenic 

rivers, and congressionally recognized 

wilderness study areas. Recovery habitat 

includes pine-oak and mixed conifer forests 

on all slopes (Coconino NF Forest Plan, p. 

65).
Appendix A – Forest Plan Amendments

52 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

Limit human activity in protected activity 

centers during the breeding season (Coconino 

NF Forest Plan, p. 65). 

Limit human activity in protected activity centers 

during the breeding season, except for the 

following PACs where implementation of 

treatments may occur the Flagstaff 

Watershed Protection Project boundary for 

no more than two breeding seasons: De 

Toro’s, Lockwood, Moore Well, Mormon 

Mountain, Mormon Mountain North, 

Weimer Springs, Schultz Creek, Mount 

Elden, Orion Spring, and Weatherford 2.

In protected and restricted areas, when 

activities conducted in conformance with these 

standards and guidelines may adversely affect 

other threatened, endangered, or sensitive 

species or may conflict with other established 

recovery plans or conservation agreements; 

consult with US Fish and Wildlife Service to 

resolve the conflict (Coconino NF Forest Plan, 

p. 65-1). 

In protected and recovery areas, when 

activities conducted in conformance with these 

standards and guidelines may adversely affect 

other threatened, endangered, or sensitive 

species or may conflict with other established 

recovery plans or conservation agreements; 

consult with US Fish and Wildlife Service to 

resolve the conflict (Coconino NF Forest Plan, 

p. 65-1). 

Monitor changes in owl populations and habitat 

needed for delisting (Coconino National Forest 

Plan, page 65-1). 

Monitoring of owl populations and habitat 

within the Flagstaff Watershed Protection 

Project boundary will follow the monitoring 

protocol developed and finalized through 

that project’s consultation with the US Fish 

and Wildlife Service.

MSO Guidelines

Harvest fuelwood when it can be done in such 

a way that effects on the owl are minimized. 

Manage within the following limitations to 

minimize effects on the owl (Coconino NF 

Forest Plan, p. 65-2). 

Retain key forest species such as oak. 

Retain key habitat components such as snags 

and large downed logs. 

Harvest conifers less than 9 inches in diameter 

only within those protected activity centers 

treated to abate fire risk as described below, 

except for the Clark PAC where trees less than 

16 inches diameter will be harvested. 

Harvest fuelwood when it can be done in such 

a way that effects on the owl are minimized. 

Manage within the following limitations to 

minimize effects on the owl (Coconino NF 

Forest Plan, p. 65-2). 

Retain key forest species such as oak. 

Retain key habitat components such as snags 

and large downed logs. 

Harvest conifers less than 9 inches in diameter 

only within those protected activity centers 

treated to abate fire risk as described below, 

except for the Clark PAC where trees less than 

16 inches diameter will be harvested and the 

following PACs within the Flagstaff 

Watershed Protection Project boundary, 

where trees up to 18 inches dbh will be 

harvested: De Toro’s, Lockwood, Moore 

Well, Mormon Mountain, Mormon 

Mountain North, Weimer Springs, Schultz 
Appendix A – Forest Plan Amendments

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 53

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

Creek, Mount Elden, Orion Spring, and 

Weatherford 2 PACS. Where cable logging 

occurs, all trees may be removed within 

cable logging corridors, including those 

above 18 inches in PACs and above 24 

inches in recovery habitat. 

Treat fuel accumulations to abate fire risk. 

–Select for treatment 10% of the protected 

activity centers where nest sites are known in 

each recovery unit having high fire risk 

conditions. Also select another 10% of the 

protected activity centers where nest sites are 

known as a paired sample to serve as control 

areas (Coconino National Forest Plan, page 65-

2). 

–Designate a 100 acre "no treatment" area 

around the known nest site of each selected 

protected activity center. Habitat in the no 

treatment area should be as similar as possible 

in structure and composition as that found in 

the activity center. 

–Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the 

Clark PAC), mechanical fuel treatment and 

prescribed fire to abate fire risk in the 

remainder of the selected protected activity 

center outside the 100 acre "no treatment" area. 

Treat fuel accumulations to abate fire risk. 

–Select for treatment 10% of the protected 

activity centers where nest sites are known in 

each recovery unit having high fire risk 

conditions. Also select another 10% of the 

protected activity centers where nest sites are 

known as a paired sample to serve as control 

areas (Coconino National Forest Plan, page 65-

2). 

–Designate a 100 acre "no treatment" area 

around the known nest site of each selected 

protected activity center. Habitat in the no 

treatment area should be as similar as possible 

in structure and composition as that found in 

the activity center. Within the Flagstaff 

Watershed Protection Project boundary, 

allow prescribed hand thinning of trees less 

than 5 inches dbh in 80% of the Schultz 

Creek nest core and prescribed burning in 

the following nest cores within the project 

boundary outside of the MSO breeding 

season: De Toro’s, Lockwood, Moore Well, 

Mormon Mountain, Mormon Mountain 

North, Weimer Springs, Schultz Creek, 

Mount Elden, Orion Spring, and 

Weatherford 2.

–Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the 

Clark PAC), mechanical fuel treatment and 

prescribed fire to abate fire risk in the 

remainder of the selected protected activity 

center outside the 100 acre "no treatment" area 

except as follows:

Use combinations of thinning trees up to 18 

inches dbh within : De Toro’s, Lockwood, 

Moore Well, Mormon Mountain, Mormon 

Mountain North, Weimer Springs, Schultz 

Creek, Mount Elden, Orion Spring, and 

Weatherford 2 PACs, mechanical fuel 

treatment and prescribed fire to abate fire in the 

remainder of the selected protected activity 
Appendix A – Forest Plan Amendments

54 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

center outside the 100-acre nest core area. 

Treat fuel accumulations to abate fire risk. Pre 

and post treatment monitoring should be 

conducted in all protected activity centers 

treated for fire risk abatement. (See monitoring 

guidelines) (Coconino National Forest Plan, 

page 65-2). 

Monitoring of owl populations and habitat 

within the Flagstaff Watershed Protection 

Project boundary will follow the monitoring 

protocol developed and finalized through 

that project’s consultation with the US Fish 

and Wildlife Service.

Mixed Conifer and Pine-oak Forests (See 

glossary definition): Manage to ensure a 

sustained level of owl nest/roost habitat well 

distributed across the landscape. Create 

replacement owl nest/roost habitat where 

appropriate while providing a diversity of stand 

conditions across the landscape to ensure 

habitat for a diversity of prey species. The 

following table displays the minimum 

percentage of restricted area which should be 

managed to have nest/roost characteristics. The 

minimum mixed conifer restricted area 

includes 10% at 170 basal area and an 

additional amount of area at 150 basal area. 

The additional area of 150 basal area is +10% 

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

The variables are for stand averages and are 

minimum threshold values and must be met 

simultaneously. In project design, no stands 

simultaneously meeting or exceeding the 

minimum threshold values should be reduced 

below the threshold values unless a districtwide or larger landscape analysis of restricted 

areas shows that there is a surplus of restricted 

area acres simultaneously meeting the 

threshold values. Management should be 

designed to create minimum threshold 

conditions on project areas where there is a 

deficit of stands simultaneously meeting 

minimum threshold conditions unless the 

district-wide or larger landscape analysis shows 

there is a surplus. This table has been modified 

to contain only information pertinent to the 

Coconino NF. (Coconino NF Forest Plan, 

pp.65-3 to 65-5). 

Mixed Conifer and Pine-oak Forests (See 

glossary definition): Manage to ensure a 

sustained level of owl nest/roost habitat well 

distributed across the landscape. Create 

replacement owl nest/roost habitat where 

appropriate while providing a diversity of stand 

conditions across the landscape to ensure 

habitat for a diversity of prey species. 

Recovery nest/roost replacement habitat in 

the Flagstaff Watershed Protection Project 

will be treated to meet or exceed the 

minimum habitat desired conditions for 

MSO recovery nest roost replacement 

habitat under table C3 in the 2012 revised 

MSO Recovery Plan. The parameter values 

are based on stand averages among plots 

sampled within forest stands. Values in 

Table C3 are minimums, not targets, with 

the goal to meet them all simultaneously. . In 

project design, no stands simultaneously 

meeting or exceeding the minimum recovery

nest roost replacement habitat values should 

be reduced below these values unless a districtwide or larger landscape analysis of recovery 

habitat shows that there is a surplus of acres 

simultaneously meeting these values. 

Management should be designed to create 

desired conditions on project areas where there 

is a deficit of stands simultaneously meeting 

these desired conditions unless the districtwide or larger landscape analysis shows there 

is a surplus of recovery habitat acres 

simultaneously meeting these desired 

conditions. Management should be designed to 

create minimum desired conditions on project 

areas where there is a deficit of stands 

simultaneously meeting minimum desired

conditions unless the district-wide or larger 

landscape analysis shows there is a surplus. 

This table has been modified to contain only 
Appendix A – Forest Plan Amendments

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 55

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

information pertinent to the Coconino NF. 

(Coconino NF Forest Plan, pp.65-3 to 65-5).

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline

Amendment 2

Amendment 2 Description

Amendment 2 will remove language restricting mechanical equipment to slopes less than 40 

percent and language identifying slopes above 40 percent as inoperable. This amendment will

allow mechanical harvesting on slopes greater than 40 percent within the project area.

Need for Plan Amendment

It will be necessary to allow for use of specialized mechanical equipment to cut and remove trees 

on steep slopes to reduce the potential for high-severity wildfire in this project area due to the 

preponderance of areas with greater than 40 percent slope in the project area. Furthermore, since 

the Forest Plan was written and amended, mechanized ground-based equipment has progressed to 

be able to operate on steep slopes more effectively. While this specialized equipment is not 

commonplace in this region due to the high cost of its use, the approval of the City bond makes 

the use of such equipment a possibility for this project. In order to be able to utilize such 

equipment to treat slopes above 40 percent in the project area and meet the purpose and need, this 

Forest Plan amendment is needed.

Edited or added/new text is bolded in Table 15.

Table 15: Amendment 2: Current and Proposed Steep Slope Forest Plan Language

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

Inoperable Lands: Timber lands, usually 

greater than 40 percent slope, not meeting the 

Forest cable logging criteria. See Operable 

Lands for criteria definition (p. 252).

Inoperable Lands: Timber lands, usually 

greater than 40 percent slope, not meeting the 

Forest cable logging criteria and outside of the 

Flagstaff Watershed Protection Project 

boundary. See Operable Lands for criteria 

definition.

Operable Lands: Timbered lands, usually 40 

percent slope and greater, meeting the forest 

cable logging criteria. The cable logging 

criteria are: cut per acre must be 3 MMBF12 or 

greater; maximum yarding distance not to 

exceed 1,300 feet (slope distance); volume 

from contiguous cable logging area must be at 

least 1 MMBF; sale area must also contain a 

minimum of 1 MMBF of conventional logging 

volume, or no less than a 50-50 mix; multispan yarding is not required, and cable yarding 

areas must be 300 to 400 acres in size to meet 

Operable Lands: Timbered lands, usually 40 

percent slope and greater, meeting the forest 

cable logging criteria or within the Flagstaff 

Watershed Protection Project boundary. 

The cable logging criteria for areas outside of 

the Flagstaff Watershed Protection Project 

are: cut per acre must be 3 MMBF or greater; 

maximum yarding distance not to exceed 1,300 

feet (slope distance); volume from contiguous 

cable logging area must be at least 1 MMBF; 

sale area must also contain a minimum of 1 

MMBF of conventional logging volume, or no 

 12 MMBF (million board feet): A symbol to indicate one million board feet of wood fiber volume either in log form or 

after conversion to lumber (Forest Plan, p. 256)
Appendix A – Forest Plan Amendments

56 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

the cut per acre and 1 MMBF requirement (p. 

258). 

less than a 50-50 mix; multi-span yarding is not 

required, and cable yarding areas must be 300 

to 400 acres in size to meet the cut per acre and 

1 MMBF requirement. Within the Flagstaff 

Watershed Protection Project area, 

harvesting activities are not confined by the 

cable logging criteria above, but rather are 

defined by that project’s NEPA analysis and 

decision. 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 57

Appendix B: Design Features

Design features are required measures or procedures designed to avoid, minimize, and/or mitigate 

potential adverse impacts from proposed activities. The design features in Table 16 and Table 17

below will be incorporated into project implementation. 

Table 16: Design Features Specific to Helicopter and Cable Logging Areas

Specialist Area Related 

Resource Design Feature

Soils/Watershed Timber 

Operations

Skid trails and cable yarding corridors will be 

restored after use by a combination of any or all 

of the following practices in order to prevent the 

concentration of runoff in skid trails and to 

protect exposed soil: reshaping the surface to 

promote dispersed drainage (i.e., create convex 

vs. concave cross-section), installation of 

drainage features such as water bars to shed 

water, and spreading slash across skid trails and 

cable yarding corridors to protect areas where 

mineral soil is exposed. Where skid trails and or 

cable yarding corridors intersect existing roads or 

trails, native materials such as logs, slash, and/or 

boulders will be placed along skid trail or cable 

corridor to line-of-sight or first 300’, whichever is 

greater. 

Mexican Spotted 

Owl

• No cable logging will occur within MSO 

PACs. No helicopter logging will occur 

within MSO nest/cores. 

• An implementation guide will be developed 

in coordination with FWS to minimize the 

impacts of helicopter operations (i.e. 

helilanding locations, flight patterns) on 

nesting MSO and other bird species 

(peregrines, eagles, northern goshawks, etc.).

Northern Goshawk

Helicopter paths will be reviewed to exclude 

flights over occupied nest locations during the 

northern goshawk breeding season.

Wildlife Red Squirrels

• Retain all trees within a 26-foot radius from 

cache (1/20th acre). Within cable and 

helicopter units, snags may be felled within 

the 26-foot radius for safety reasons. Caches 

will still be protected and live trees will be 

retained except where cable corridors overlap 

with that buffer. Additional caches will be 

protected outside of cable logging units to 

compensate.

• Leave snag patch placement will be 
Appendix B – Design Features

58 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

coordinated with existing red squirrel caches.

Snags

• In areas where large snags are cut for safety 

purposes, fallen trees will be left on site as 

needed for wildlife habitat while still 

lowering overall fuel loadings to meet desired 

conditions.

• Biologists will identify patches of snags up to 

10 acres in size in advance of treatment unit 

layout in cable and helicopter logging areas. 

This will allow for the protection of patches 

of snags at the ecosystem management area 

level that could serve as a reserve area for 

areas/acres where we are unable to maintain 

snags during operations. Patch locations will

be identified with consideration for red 

squirrel caches (see Red Squirrel Design 

Features above).

• Where helicopter logging is used, consider 

using patch cuts in order to break up 

fuels. This will allow for the maintenance of 

snags outside the patches, but will allow for 

greater removal of trees (live and dead) and 

operational safety within the patches. 

• Use logging systems when feasible in 

sensitive habitats that can meet project 

objectives and maintain important structural 

components (e.g., snags, etc.). 

Table 17: General Project Design Features 

Specialist Area Related 

Resource Design Feature

Silviculture Old Trees

Emphasize retaining old, pre-settlement trees 

where possible, particularly within MSO 

recovery nest/roost habitat. Old trees, as defined 

by Thomson (1940) for ponderosa pine, and 

mixed conifer species with fire scars will not be 

targeted for cutting. However, exceptions may 

be necessary. An example of this will be 

removing an old tree to address human health 

and safety concerns and OSHA regulations 

where treatments are occurring if these trees are 

considered to be dangerous. Another instance 

will be to cut an old tree in order to 

accommodate the turning radius of a logging 

truck, rather than relocating an entire road, or if 

they are located within a cable yarding corridor 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 59

Specialist Area Related 

Resource Design Feature

or temporary road location.

Large Trees

Post-settlement ponderosa pine trees > 16 inches 

dbh will be prioritized for protection, but may 

be removed to restore forest health and to 

emulate natural vegetation patterns based on 

current stand conditions, pre-settlement 

evidences, desired future conditions, or other 

restoration objectives. Instances where this will

occur include: in conifer-encroached aspen 

stands, encroached grasslands, in heavily 

stocked stands of large, young trees when the 

presence of such trees will prevent the reestablishment of sufficient stand openings, when 

necessary to develop or maintain uneven-aged 

forest conditions (where desired), and if they are 

located within a cable yarding corridor or 

temporary road location. 

Mixed Conifer

Treatments within both dry and wet mixed 

conifer vegetation types will be site-specific in 

nature and vary according to the diversity of tree 

species compositions and locations. 

Juniper & 

Gambel Oak

• Gambel oak will only be cut as necessary to 

facilitate logging operations (skid trail and 

landings). 

• Large mature juniper (“alligator juniper”) 

and pinyon species will not be cut as part of 

treatments. Young and mid-aged juniper 

and pinyon may be cut to reduce fire hazard

to surrounding larger trees.

• Placement of roads, skid trails and landings 

will avoid cutting or damaging large 

alligator junipers and gambel oak where 

possible. 

Forest Health

Log decks will not be left at the landings or in 

the treatment areas for such a period that will

contribute to an increase in bark beetle 

populations; typically no longer than 4 weeks if 

bark beetles are present. Logs and log decks 

could be left for longer than 4 weeks if no bark 

beetle activity is detected. Entomologists from 

the Forest Health Group will be consulted as 

needed.

Operations Operational 

Safety

Danger trees that are present within two treelengths of areas where contractors are not 

enclosed within a Falling Object Protective 

Structure (FOPS) cab may be removed or felled. 
Appendix B – Design Features

60 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

These areas include cutting units that require 

manual falling, cable or helicopter logging units 

and landings. A danger tree is any tree that 

presents a hazard to employees due to 

conditions such as deterioration or damage to 

the root system, trunk, stem or limbs 

Coordination

Use of haul routes designated either within or 

adjacent to utility corridors will be coordinated 

with El Paso Natural Gas Company and/or other 

appropriate utility companies. 

Fire/Fuels

Slash Mats

In areas where slash mats are used to protect 

soils during harvesting activities, Forest Service 

fire/fuels personnel will work with the 

appropriate contract authority to determine if 

material should be piled and burned postimplementation where slash exceeds 4 inches in 

depth.

Fuelwood 

Gathering 

Areas of project-generated slash suitable for 

fuelwood gathering (outside of MSO PACs, 

recovery habitat and northern goshawk PFAs) 

could be identified for public use. Those areas 

will be identified on the Forest website and on 

the map accompanying each fuelwood 

gathering permit. 

Slash Treatment

• Limit machine piling of slash within 300 

feet of private property boundaries.

• Limit hand piling within 50 feet of private 

property boundaries. 

• If a market for biomass exists during the 

time of implementation, biomass removal 

methods may be utilized in place of pile 

burning in areas identified for potential 

ground based harvesting, particularly in 

areas adjacent to residential property. 

Heritage

Site Protection

• All fire intolerant sites will be marked for 

avoidance from prescribed burning and all 

National Register of Historic Places 

(NRHP) eligible or unevaluated sites will be 

protected from ground disturbing activities.

• No mechanized thinning will occur within 

NRHP eligible sites; however hand thinning 

could occur. These efforts will be 

coordinated by the District Archaeologist.

Survey

Temporary roads will be surveyed prior to their 

construction per the sampling plan submitted 

and approved by the State Historic Preservation 

Office (SHPO). 
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Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 61

Specialist Area Related 

Resource Design Feature

Wildlife Mexican Spotted 

Owl

• MSO surveys will be coordinated with the 

Fish and Wildlife Service the year of 

implementation or one year prior to 

determine occupancy of owls. Surveys 

include the project area plus 1⁄2 mile beyond 

the perimeter of the project boundary. 

• The FWPP project boundary lies within the 

project boundary for 4FRI as well as other 

forest thinning and burning 

projects. Flagstaff Ranger District staff will

ensure that all proposed treatments are 

coordinated to ensure that there are not 

multiple entries into sensitive habitats (such 

as MSO PACs) that are split between 

different project boundaries. In doing so, 

habitat and noise disturbance to these areas 

will be minimized.

• The Forest Service will monitor effects to 

MSO from the proposed action and report 

their findings to the FWS. Implementation 

monitoring will include information such as 

when or if the project was implemented, 

whether the project was implemented as 

analyzed in the site specific BO (including 

conservation measures, and best 

management practices), breeding season(s) 

over which the project occurred, relevant 

MSO survey information, and any other 

pertinent information about the project’s 

effects on the species. Treatment activities 

within PACs will be assessed through 

implementation of the monitoring plan 

designed with FWS.

• Treatments will be designed so that thinning 

activities within each PAC will be 

completed in one to two breeding seasons. 

Treatments within MSO PACs may occur 

during the breeding season for no more than 

two years; if implementation is not 

completed at the end of two years, timing 

restrictions will apply (March 1 – August 

31). The Thicket northern goshawk PFA on 

Mormon Mountain will be treated in 

conjunction with the PACs it overlaps with 

the same parameters. 

• Activities will not occur within MSO 

occupied nest cores during the breeding 
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62 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

season (March 1 – August 31). 

• Initial entry burning and pile burning will

primarily occur in PACs during the 

fall/winter to minimize impacts from smoke 

on MSO. Maintenance burning within PACs 

but outside of nest cores could occur during 

the breeding season.

• Prescribed fire will be allowed to enter cores 

only if it is expected to burn with low fire 

severity and intensity. Firelines, check-lines, 

backfiring, and similar fire management 

tactics will be used to reduce fire effects and 

to maintain key habitat elements (e.g. 

hardwoods, large downed logs, snags, and 

large trees).

• In MSO recovery habitat, manage for large 

oaks by removing conifers up to 18 inches 

dbh that do not meet the “old tree” 

definition within 30 feet of oak 10 inches 

drc or larger

• Coordinate burning spatially and temporally 

to limit smoke effects on nesting owls 

(March 1 to August 31).

• The Forest Service, in coordination with the 

FWS, shall develop contingency plans in the 

event of new PACs being established or 

PAC boundary modifications due to owl 

movement or habitat changes. Flexibility 

shall be built into the project (including task 

orders) so that as owls move or new sites are 

located, project activities can be modified to 

accommodate these situations. Minor 

modifications will be coordinated with 

FWS. 

• The Forest Service shall ensure that all 

contractors associated with thinning and 

burning activities, transportation of 

equipment and forest products, research, or 

restoration activities are briefed on the 

Mexican spotted owl, know to report 

sightings and to whom, avoid harassment of 

the owl, and are informed as to who to 

contact and what to do if a Mexican spotted 

owl is incidentally injured, killed, or found 

injured or dead on the Coconino NF. If an 

owl fatality is discovered, the FWS Mexican 

spotted owl lead will be contacted as soon 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 63

Specialist Area Related 

Resource Design Feature

as possible.

• The Forest Service shall meet annually with 

the FWS to discuss the upcoming year’s 

thinning and burning plans in Mexican 

spotted owl habitat and review the past 

year’s thinning and burning activities in owl 

habitats.

Northern Goshawk

• Thinning treatments within PFAs may occur 

during the northern goshawk breeding 

season for no more than two years; if 

implementation is not completed at the end 

of two years, timing restrictions will apply 

(March 1 – September 30). The Thicket 

northern goshawk PFA on Mormon 

Mountain will be treated in conjunction with 

the PACs it overlaps with the same 

parameters as those PACs.

• Prescribed burn plans in northern goshawk 

PFAs will be designed and implemented to 

minimize smoke effects on nesting birds and 

minimize loss of nest trees.

Wildlife Other Wildlife

• No thinning activities will occur within onequarter mile of the Devil’s Head peregrine 

eyrie if occupied during the breeding season 

(March 1 – August 15).

• If any of the three bald eagle nests near 

Mormon Mountain are occupied during the 

eagle breeding season (March 1- August 1), 

prescribed burning will only be permitted in 

the Mormon Mountain project area when 

ventilation is favorable and in coordination 

with the wildlife biologist and FWS. 

Typically nesting status can be confirmed 

by May.

• Burn plans within 1/2 mile of golden eagle 

nest and peregrine falcon eyries will be 

coordinated with the district wildlife 

biologist to insure nesting falcons and 

golden eagles will not be adversely 

impacted from smoke.

• Hiding cover will be maintained near 

dependable waters by not targeting 

drainages for openings, and through 

implementation of watershed BMPs.

• Tanks within 1⁄4 mile of known northern 

leopard frog sites will be surveyed prior to 

implementation. If northern leopard frogs 
Appendix B – Design Features

64 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

are detected, a buffer for no treatments (no 

thinning, no direct ignition) will be 

identified to protect occupied tanks.

• Aquatic Management Zones (AMZs) will be 

established around designated streamcourses 

and will provide protection for northern 

leopard frogs by limiting the type of 

disturbance which could occur within the 

AMZ. 

• Primary red squirrel caches will generally 

be protected at a density of one cache per 

two acres where current cache numbers 

allow. 

Snags

• Use logging systems when feasible in 

sensitive habitats that can meet project 

objectives and maintain important structural 

components (e.g., snags, etc.). 

• Protect snags and logs wherever possible 

through site prep, implementation planning, 

and ignition techniques to retain within the 

project area an average of approximately ≥ 

2 snags per acre >18 inches dbh and ≥30 ft 

in height and ≥3 logs with > 12 inches midpoint diameter and ≥ 8 ft in length in 

ponderosa pine and ≥ 3 snags per acre >18 

inches dbh and ≥30 ft in height and ≥5 logs 

with >12 inches mid-point diameter and ≥ 8 

ft in length in mixed conifer and spruce-fir

• Within the project area, retain an average of 

approximately ≥ 2 trees per acre ≥18 inches 

dbh with dead tops, cavities, and lightning 

strikes wherever possible to provide for 

replacement snags and cavity 

nesting/foraging habitat

• Emphasize retention of snags exhibiting 

loose bark to provide habitat for roosting 

bats.

• Create snags in key areas (i.e. PACs, 

recovery nest roost habitat) where 

monitoring determines a deficit. Trees will

be chosen on a case-by-case basis in order 

to ensure successful recruitment as snags. 

Created snags, or a subset of, will be 

monitored over time to determine if the 

action was successful (i.e. trees decayed but 

remained standing, etc.).

Wildlife (cont) Caves, Karst and Treatment buffers will be designated around 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 65

Specialist Area Related 

Resource Design Feature

Sink Holes cave entrances, sink hole rims, and drainages 

leading to these features to protect cave 

ecosystems (including microclimate, hydrology, 

and entrance vegetation) and reduce potential 

disturbance to roosting bats. No direct ignition 

of fire within buffer.

Botany Noxious/Invasive 

Weeds

Best Management Practices as outlined in 

Appendix B of the “Final Environmental Impact 

Statement for Integrated Treatment of Noxious 

or Invasive Weeds” (USDA Forest Service 

2005) will be followed to incorporate weed 

prevention and control into the project. The 

following features will be incorporated into 

project implementation and monitoring:

• Prevent the spread of potential and existing 

noxious or invasive weeds by vehicles used 

in management activities by incorporating 

weed prevention and control into project 

layout, design, and implementation.

• Prior to ground-disturbing activities, survey 

for and prioritize and implement treatments 

of noxious or invasive weeds in project 

operating areas including landings , 

permanent and temporary roads and roads to 

be closed or decommissioned.

• Avoid existing noxious or invasive weeds 

during soil disturbing activities when 

possible.

• Clean all off road vehicles, machinery and 

tools of seeds, soil, vegetative matter, and 

other debris that could contain or hold seeds 

prior to entering the project area, when 

moving from one potentially-infested area to 

another area, and when leaving the project if 

the area the equipment was previously 

operating in has identified noxious weeds, 

or it is unknown if the area has weeds (e.g.

private or other ownership, or areas we have 

not surveyed). 

• Fully incorporate the equipment cleaning 

provisions of the timber sale and/or 

stewardships contracts into the 

implementation contract(s) to prevent the 

introduction or spread of noxious or 

invasive weeds. 

• When in areas where known noxious weeds 

exist, designate turnaround sites for log 
Appendix B – Design Features

66 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

trucks and other large equipment that are 

weed free. 

• Manage prescribed fires to promote native 

species, aid in control of existing weed 

infestations and prevent spread of existing 

weeds through coordination with the District 

Weeds Coordinator. 

• Place slash piles on previously used 

locations such as old piling sites, old log 

deck sites, or other disturbed sites to avoid 

severe disturbance to additional locations 

where possible.

• Monitor slash pile sites after burning and if 

found, control noxious or invasive weeds.

• Avoid acquiring water for dust abatement 

from weed-infested areas.

• Minimize period from end of project 

activities to site preparation, revegetation, 

and contract closure.

Sensitive Plants

• Determine potential occurrences and habitat 

of Region 3 sensitive plants in potential 

activity areas when planning for 

implementation. Identify potential species 

and survey the area to be treated before 

implementation.

• Mitigate loss of individuals and groups of 

Rusby milkvetch during management 

activities by avoiding known population 

locations.

• Construct slash piles at least 10-20 feet 

away from known populations of Rusby 

milkvetch where possible.

• Avoid constructing mechanical slash piles 

within known populations of Rusby 

milkvetch.

• Minimize temporary road construction or 

reconstruction within known populations of 

Rusby milkvetch. 

• Minimize construction, reconstruction or log 

landings within known populations of 

Rusby milkvetch

• Leave tree groups may include Rusby 

milkvetch populations where practical, 

using areas not occupied by the plants as 

openings. 

• Manage prescribed burns at low to moderate 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 67

Specialist Area Related 

Resource Design Feature

intensity to promote native species and to 

hinder weed species germination.

• Monitor the effects of treatment on Region 3 

sensitive plants after treatments are 

completed in areas with known populations. 

Soil/Watershed

General

• In order to avoid negative effects on soils 

and water resources, best management 

practices (BMPs) will be implemented for 

prescribed fire and mechanical vegetation 

treatment measures. These resource 

protection measures are derived mainly from 

the Soil and Watershed Conservation 

Practices Handbook (USDA, 1990) and the 

National Best Management Practices for 

Water Quality Management on National 

Forest System Lands, Volume 1: National 

Core BMP Technical Guide (USDA, 2012). 

Resource protection measures are 

implemented to protect soils and minimize 

nonpoint source pollution as outlined in the 

intergovernmental agreement between the 

Arizona Department of Environmental 

Quality and the Southwest Region (Region 

3) of the Forest Service (ADEQ, 2008). 

BMPs will be incorporated in prescribed fire 

burn plans and timber harvesting or 

stewardship contracts. 

Prescribed Fire

• Incorporate prescription elements into the 

prescribed fire plan including such factors as 

weather, slope, aspect, soils, fuel type and 

amount, and fuel moisture in order to 

minimize high soil burn severity. 

• Consider the spatial distribution and 

contiguous size of the planned burn area in a 

watershed during prescription development 

to reduce the effects of peak flow change on 

channels. 

Timber Harvesting

At a minimum, all perennial water bodies, 

wetlands, and areas with riparian ecosystems 

will be designated as Aquatic Management 

Zones (AMZs), also called filter strips in the 

1987 Coconino National Forest Plan. Those 

stream channels that support seasonal flow in 

response to snowmelt and/or seasonal 

fluctuations in the water table will also be 

evaluated for potential designation as AMZs. 

AMZ widths will be adjusted based on the 
Appendix B – Design Features

68 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

steepness of upgradient hillslopes with the 

following general guidelines: 

• AMZ width is the distance measured 

perpendicularly from the outer edges of 

the streamcourse (i.e., channel bank) or 

wetland. For stream courses or wetlands 

with upgradient hillslopes of 35 percent 

or less, the AMZ width will be 50’. For 

those with upgradient hillslopes greater 

than 35 percent, AMZ width will be 

100’. As an example, the total width of 

an AMZ for a streamcourse with an 

upgradient hillslope exceeding 35 

percent will be 200’ plus the width of 

the streamcourse. 

Equipment/vehicle staging areas, and fuel used 

for ignition devices will be located outside of 

AMZs. Ignition of fuels will not be initiated 

within AMZs. Hand piling and burning of slash 

within AMZs will be avoided to the extent 

practicable. 

Containment lines will be sited and constructed 

in a manner that minimizes erosion and prevents 

runoff from directly entering water bodies by 

consideration of placement relative to the water 

body(ies) and lay-of-the-land and through 

construction and maintenance of suitable 

drainage features such as water bars. To the 

extent possible, wetlands and riparian areas will

be avoided. Where applicable, natural fire 

breaks such as outcrops will be used in lieu of 

ground-disturbing containment lines. In 

general, spacing of water bars will be such that 

water bars are located at eye level when viewed 

starting at the bottom of a slope and traversing 

upward. 

Staging areas will be kept as small as possible 

while allowing for safe and efficient operation. 

Prior to conducting harvesting activities, all 

AMZs, staging areas (including areas where 

vehicles are serviced, equipment/chemicals are 

stored, and/or fuel is dispensed), primary skid 

trails, cable yarding corridors, temporary roads, 

and landings will be designated on a map and 

visibly marked by means of flagging or other 

suitable measures for approval by the timber 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 69

Specialist Area Related 

Resource Design Feature

sale administrator. Temporary fuel storage 

tanks will be permitted and installed in 

accordance with the Office of the State Fire 

Marshall requirements. If the total oil or oil 

products storage exceeds 1,320 gallons in 

containers of 55 gallons or greater, Purchaser 

shall prepare a Spill Prevention Control and 

Countermeasures Plan. Such plan shall meet 

applicable EPA requirements (40 CFR 112), 

including certification by a registered 

professional engineer.

To the extent possible, skid trail design will not 

include long, straight downhill segments which 

will concentrate runoff. If it is not operational 

feasible to avoid a long straight downhill 

segment, skid trail rehabilitation measures will

be applied as soon as skidding is completed on 

that trail. Cable yarding corridors will be 

located to efficiently yard materials with the 

least soil damage. Skidding or cable yarding up 

or down drainage courses will not be 

permissible unless, in the case of cable yarding, 

logs are fully suspended.

Insofar as safety permits, trees will be felled to 

angle in the direction of skidding.

Drainage of roads will be controlled by a variety 

of methods including but not limited to 

insloping of the road bed toward an interior 

drainage ditch with periodic cross drains, 

outsloping of the road bed, crowning of the road 

bed, and construction of rolling dips and water 

lead-off ditches. Drainage from landings and 

skid trails will be controlled to prevent 

concentration of runoff. 

Equipment will not be operated when ground 

conditions are such that excessive damage will

result as visually monitored through such 

indicators as soil rutting. 

Machine piling of logging slash will be done in 

such a manner as to minimize the construction 

of new clearings for slash piles through use of 

natural openings, temporary roads, and landings. 

Skid trails and cable yarding corridors will be 

restored after use by a combination of any or all 

of the following practices in order to prevent the 

concentration of runoff in skid trails and to 
Appendix B – Design Features

70 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

protect exposed soil: reshaping the surface to 

promote dispersed drainage (i.e., create convex 

vs. concave cross-section), installation of 

drainage features such as water bars to shed 

water, and spreading slash across skid trails and 

cable yarding corridors to protect areas where 

mineral soil is exposed. Where skid trails and or 

cable yarding corridors intersect existing roads 

or trails, native materials such as logs, slash,

and/or boulders will be placed along skid trail or 

cable corridor to line-of-sight or first 300’, 

whichever is greater. 

Temporary roads and landings will be restored 

after use by a combination of any or all of the 

following practices in order restore original 

topography, protect soils, and prevent 

concentrated runoff: roll berms created during 

temporary road and/or landing construction 

back across the disturbed surface to restore 

original surface topography to the extent 

practicable, install drainage features such as 

water bars where needed to prevent runoff from 

concentrating, and spread slash on areas with 

exposed mineral soil. Where temporary roads 

intersect existing roads or trails, native materials 

such as logs, slash, and/or boulders will be 

placed along temporary road to line-of-sight or 

first 300’, whichever is greater. 

Where visual observation indicates that the 

above methods of erosion protection are 

inadequate, a certified weed-free mix of native 

or naturalized grasses will be broadcast evenly 

over the inadequately protected surface at the 

rate of 5 pounds per acre after surface 

scarification.

Recreation Public Awareness

• Inform forest visitors about activities within 

the project area and make them aware of 

potential impacts when visiting this part of 

the forest. Provide information about 

implementation activities on the Forest 

website. 

• Issue news release(s) as appropriate when 

forest restoration activities are scheduled to 

occur and how it may affect forest 

visitation.

• If it is necessary to close forest roads during 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 71

Specialist Area Related 

Resource Design Feature

harvesting operations for public safety, 

notices and signs will be posted at key 

locations adjacent to and within the project 

area to inform the public of these closures, 

in conjunction with issuing news releases as 

stated above. This may include major FS 

roads accessing the area, kiosks at 

trailheads, bulletin boards, electronic sign 

boards, etc.

• Utilize dust abatement methods during haul 

of logs on unpaved roads near private land 

residences during the season when dust is 

likely and funding is available

Forest Service Trails

• Harvesting activities will avoid existing 

forest system trails13, if possible. If it is 

determined necessary that an existing forest 

system trail must be used as a temporary 

road or skid trail, then the trail will be 

restored to USFS standards post-treatment. 

• It is acceptable to make perpendicular trail 

crossings. Trail crossing locations will be 

designated and flagged with input from the 

District Trails Coordinator or assigned 

personnel. Crossings of existing forest 

system trails will be restored to pre-project 

condition after use.

• Forest restoration treatments within close 

proximity (i.e. 100’-200’) of existing forest 

system trails will consider “feathering” the 

treatment so the visual impacts are more

transitional than abrupt and as to not 

significantly change the character or 

experience of the trail.

• Existing forest system trails originally 

designated for “single track” use (motorized 

and non-motorized) will be avoided for use 

as skid trails or temporary roads. 

• Public outreach efforts (e.g. additional 

signage, postings at trailhead kiosks, maps 

on the website) will occur prior to treatment 

to increase public understanding of what 

trails are within the forest system (and thus 

will be protected and/or restored) and which 

are not. 

 13 Existing forest system trails are identified in Chapter 3 of the EIS.
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72 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

Special-Use Events

Coordinated efforts will be made with sponsors 

of recreational special-use events (i.e. running 

or mountain biking races) to minimize the 

impacts on such events within the project area 

during implementation. Alternative locations 

will be identified to meet the needs of the 

special-use event if forest management activities 

conflict with preferred locations and cannot be 

resolved through timing.

High-Use 

Weekends and 

Holidays

Efforts will be taken to limit forest treatment 

activities within the project area during high-use 

weekends and holidays (i.e. Memorial Day, 4th

of July, Labor Day, etc.); especially in locations 

where recreation based activities (i.e. trails, 

trailheads, etc.) occur.

Hunting Access

Temporary closures of forest roads and/or 

portions of the project area during 

implementation will be coordinated with 

AZGFD during hunting seasons to reduce 

impacts on hunter and angler access.

Mt. Elden 

Environmental Study 

Area

Measures will be taken to safeguard the trails 

and interpretive signs/markers within the Mt. 

Elden Environmental Study Area from forest 

restoration activities.

Wilderness

Improve the wilderness boundary marking 

where forest restoration operations are planned 

within close proximity (i.e. 1⁄4 mi.) of a 

wilderness area.

Forest restoration treatments within close 

proximity (i.e. 1⁄4 - 1⁄2 mile) to a wilderness area 

will consider “feathering” the treatment so the 

visual impacts are more transitional than abrupt.

Edges of Individual 

Units

Thinning forest vegetation geometric shapes 

(such as linear corridors from cable yarding) 

will be avoided when it does not interfere with 

implementation feasibility or safety, and high 

contrast will be avoided between treatment 

locations. Use the following techniques:

• Shape and/or feather the edges of treatment 

areas to avoid abrupt changes between 

treated and untreated areas.

• Where the treatment unit is adjacent to 

denser forest (treated or untreated), the 

percent of thinning within the transition 

zone (150-250 feet) will be progressively 

reduced toward the denser edges of the unit.
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 73

Specialist Area Related 

Resource Design Feature

• Similarly, where the treatment unit 

interfaces with an opening (including 

savannah and grassland treatments, and 

natural openings) the transition zone will

progressively increase toward the open 

edges of the unit.

• Soften edges by thinning adjacent to the 

existing unit boundaries. Treat up to the 

edges; do not leave a screen of trees. Favor 

groups of trees complying with the 

prescribed treatment that visually connect 

with the unit’s edge to avoid an abrupt and 

noticeable change.

• Treatment boundaries should extend up and 

over ridgelines to avoid the “Mohawk” look. 

• Avoid widely spaced individual trees that 

are silhouetted along the skylines.

Scenery

Unit Marking

• Avoid using trails as boundaries especially 

for different prescribed treatments.

• Avoid abrupt changes between treatment 

units. Use the techniques suggested for 

edges of treatment units (above). 

• Where possible, mark trees on the side 

facing away from roads, trails and 

developed recreation sites.

Road, Skid Trail 

& Landing 

Construction

• Utilize dust abatement methods during haul 

of logs during the season when dust is likely 

and funding is available. Priorities will

include residential areas, private land and 

adjacent to recreation sites. Coordinate with 

Coconino County on the application and 

timing of application of dust abatement on 

road segments that have County 

Maintenance responsibilities.

• Utilize existing skid roads and landings to 

the extent possible.

• Log landings, temporary roads, and skid 

trails should be minimized within sensitive 

viewsheds such as those next to developed 

recreation sites, private homes or 

communities, paved and passenger car level 

roads and trails.

• To hasten recovery and help eliminate 

unauthorized motorized and non-motorized 

use of skid trails and temporary roads, use 

physical measures such as re-contouring, 
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74 Draft Record of Decision for the Flagstaff Watershed Protection Project EIS

Specialist Area Related 

Resource Design Feature

pulling slash and rocks across the line, 

placing cull logs perpendicular to the route, 

and disguising entrances. 

• If areas where piles were burned are not 

naturally restored, it may be necessary to 

scratch in seed and soil from unburned areas 

in order to assure vegetative cover

Cull Logs, 

Stump Heights & 

Slash Treatments

• Cull logs will not be abandoned on landings.

• Use cull logs for closing temporary roads 

and decommissioning roads, and for closed, 

undesignated roads if appropriate.

• Cull logs may also be suitable to use as 

down woody material, but must be scattered 

away from the landings.

• Stump heights should be cut as low as 

possible.

• Unless used for erosion control or 

maintenance of soil productivity, slash on 

log landings must be treated or removed.

• In the seen area immediate foreground of 

sensitive places (within 300 feet of the 

centerline of paved or passenger car level 

roads or trails, or 300 feet from the 

boundary of a recreation site or private 

land/communities):

o Where whole tree logging occurs, 

machine piling may occur to the 

middle/back of log landings. 

Prioritize slash burning in these 

locations within one year or as soon 

as possible after treatment.

• Root wads and other debris in sensitive 

foreground areas will be removed, buried, 

burned, or chipped. If materials are buried, 

locate in previously disturbed areas where 

possible, such as areas for road obliteration. 

Beyond sensitive immediate foreground 

areas, it is acceptable to scatter these or use 

them to help decommission temporary roads 

or skid trails.

• Place project-generated slash outside of 

permitted utility line and pipeline rights-ofway; do not interfere with utility corridor 

management.

Fire Control 

Lines

• Wherever possible, construct fire lines to 

reduce the contrast so that they are not 
Appendix B – Design Features

Draft Record of Decision for the Flagstaff Watershed Protection Project EIS 75

Specialist Area Related 

Resource Design Feature

noticeable in the middle and background 

views. 

• Generally restore control lines to a near 

undisturbed condition in the foregrounds 

(within 300 feet) of roads, trails, and 

developed recreation sites with high scenic 

integrity objectives.

• To hasten recovery and help eliminate 

unauthorized motorized and non-motorized 

use of control lines, use measures such as 

re-contouring, pulling slash and rocks across 

the line, and disguising entrances to nonsystem roads and trails.

Range

Infrastructure • Protect range infrastructure from prescribed 

fire (e.g. by lining fence stays).

• Upon completion of implementation, cattle 

guards will be cleaned to preimplementation condition.

Implementation • Coordinate implementation activities with 

range specialists when implementation will

impact an active grazing allotment.

• Vehicles passing through grazing pastures 

will close gates upon entering and exiting 

the area to ensure livestock remain in the 

correct pasture.