United States Department of Agriculture

Santa Fe National Forest 

Geothermal Leasing

Draft Environmental Impact Statement

Forest Service Santa Fe Coyote, Cuba, Espanola June 2016

National Forest Jemez Ranger Districts MB-R3-10-23
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Santa Fe National Forest

Draft Environmental Impact Statement

Sandoval and Rio Arriba Counties, New Mexico

Lead Agency: USDA Forest Service

Cooperating Agencies: Bureau of Land Management 

National Park Service

Responsible Official: Maria Garcia

11 Forest Lane, Santa Fe, New Mexico 87508

For information, contact: Larry Gore

04B County Road 11, Cuba, New Mexico

(575) 289-3264 x2149

Abstract: In accordance with the Energy Policy Act of 2005 (Public Law 109-58, August 8, 2005), 

Secretarial Order 3285A1 (amended February 22, 2010), and the Forest Service obligations under Section 

225 of the Energy Policy Act, the Forest Service is required to facilitate the development and production 

of geothermal energy. This draft environmental impact statement (DEIS) documents the National 

Environmental Policy Act analysis for determining which lands would be available for geothermal leasing 

in the project area and under what stipulations. The DEIS analyzes four alternatives in detail: Alternative 

1 (No Action), Alternative 2 (the Proposed Action), Alternative 3 (No Leasing), and Alternative 4 

(Development Alternative). The proposed action would amend the 1987 Santa Fe National Forest Plan.

This DEIS tiers to and incorporates by reference those elements of the 2008 Geothermal Programmatic 

Environmental Impact Statement that are appropriate for such use, such as resource impact analysis, 

stipulations, leasing procedures, and best management practices. 

It is important that reviewers provide their comments at such times and in such a way that they are useful 

to the Forest Service’s preparation of the EIS. Therefore, comments should be provided before the close 

of the comment period and should clearly state the reviewer’s concerns and contentions. Submitting

timely and specific comments can affect a reviewer’s ability to participate in subsequent administrative 

review or judicial review. Comments received in response to this solicitation, including names and 

addresses of commenters, will be part of the public record for this proposed action. Comments submitted 

anonymously will be accepted and considered; however, anonymous comments will not provide the 

commenter with the opportunity to participate in subsequent administrative or judicial reviews.

Send written comments to: Geothermal EIS Project, Santa Fe National Forest

11 Forest Lane 

Santa Fe, NM 87508

Comments may also be sent via e-mail to comments-southwestern-santafe@fs.fed.us, or via 

facsimile to (505) 438-5390.

Comments must be received within 45 days of the Notice of Availability publication
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Summary

Santa Fe National Forest Geothermal Leasing EIS i

Summary

The Santa Fe National Forest (SFNF) proposes to identify lands in the project area administered 

by the Forest Service as closed to geothermal leasing under either nondiscretionary or 

discretionary authorities or open to geothermal leasing, subject to stipulations. The project area 

encompasses 194,910 acres in the Coyote, Cuba, Espanola, and Jemez Ranger Districts, of which 

168,650 acres are National Forest System (NFS) lands. 

This action is needed to allow the Forest Service to satisfy its statutory and policy mandates in 

responding to requests for the environmentally responsible development of energy resources and 

to respond to other policy directives calling for clean and renewable energy.

In 2008, the US Department of the Interior, Bureau of Land Management (BLM) recommended 

and the Assistant Secretary of Land and Minerals Management approved the Record of Decision 

(ROD) associated with the Programmatic Environmental Impact Statement (PEIS) for 

Geothermal Leasing in the Western United States. This led to a decision to amend BLM resource 

area management plans and provided certain National Forests with analysis to make decisions on

existing lease applications. Decisions in the 2008 Geothermal ROD identified those lands that are 

legally open or closed to consideration for geothermal leasing on affected NFS lands; it provided 

stipulations, best management practices (BMPs), and procedures for geothermal leasing and 

development. The Forest Service has determined that additional site-specific environmental 

analysis is needed to supplement the 2008 Geothermal PEIS. This is so the Forest Service can 

make a decision about providing concurrence and consent to the BLM to lease lands in the SFNF

for developing geothermal resources.

The Proposed Action

Under Alternative 2, the Proposed Action, the SFNF would implement discretionary and 

nondiscretionary leasing closures for geothermal resources. Approximately 32,000 acres would be 

closed (by law, regulations, or other authority) to geothermal leasing in the project area. 

Approximately 136,650 acres of NFS lands in the project area would be allocated as open to 

geothermal leasing. This would be subject to existing laws, regulations, formal orders, and 

stipulations attached to the lease form, and the terms and conditions of the standard lease form. 

Controlled surface use (CSU), no surface occupancy (NSO), and timing limitation (TL)

stipulations would be implemented.

Public Involvement

The formal public scoping comment period, as required by the National Environmental Policy 

Act (NEPA; 40 Code of Federal Regulations [CFR], Subpart 1501.7), began on May 13, 2015, 

and ended on June 26, 2015. Scoping included the following:

• Notice of Intent (NOI) published in the Federal Register on May 13, 2015

• Media outreach, including press releases and a project website (http://www.fs.usda.gov/

projects/santafe/landmanagement/projects)

• Scoping letter mailed to those on the project mailing list, including federal, state, and local 

agencies, Native American tribes, special interest groups, and landowners

• Public scoping meetings
Summary

ii Santa Fe National Forest Geothermal Leasing EIS

Results of the public scoping are discussed in detail in the scoping report posted on the project 

website.

Alternatives Considered

Following the close of the public scoping period on June 26, 2015, the SFNF began developing 

alternatives. Based on public input, the interdisciplinary team’s analysis of the current 

management situation and resource data and on the defined purpose and need for the project, the 

Forest Service developed four alternatives. 

Under Alternative 1, the No Action Alternative, the SFNF would not make an availability 

determination for geothermal leasing on lands in the project area. It would continue processing 

geothermal lease applications and nominations but would evaluate them on a case-by-case basis 

under separate NEPA analyses, in accordance with the Forest Plan and existing laws and 

regulations. This alternative does not meet the purpose and need.

Under Alternative 2, the proposed action, land in the project area administered by the Forest 

Service would be identified as being closed to geothermal leasing under either nondiscretionary 

or discretionary authorities or open to geothermal leasing with possible moderate constraints (TL 

and CSU stipulations) to major constraints (NSO stipulations).

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. The SFNF 

developed this alternative in response to comments received from the public and tribes during 

scoping. Although this alternative is contrary to program direction and mandates to make mineral

and energy resources available, it is supportable, due to resource concerns and the level of 

protection needed. Alternative 3 may prevent geothermal development on private land in and 

adjoining the project area due to drainage of federal resource issues.

Under Alternative 4, land in the project area administered by the Forest Service would be closed 

to geothermal leasing under either non-discretionary or discretionary authorities, or would be 

open to geothermal leasing, with possible moderate constraints (TLs and CSU stipulations) to 

major constraints (NSO stipulations). There would be fewer areas identified as closed to 

geothermal leasing, and the stipulations would be less restrictive, compared with Alternative 2.

Decision to be Made

The SFNF supervisor is the Forest Service responsible official. Based on the environmental 

analysis and supporting documents in the project record, the forest supervisor will decide whether 

the proposed action should be implemented as proposed, modified by another action alternative, 

or not implemented at all. This decision is subject to the pre-decision administrative review 

process (objection process) under 36 CFR, Part 218, Subparts A and B.

Major Conclusions

Under Alternative 1, geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA 

analyses, in accordance with the Forest Plan and existing laws and regulations. The Jemez 

National Recreation Area would remain closed to geothermal leasing; however, no other 

geothermal-specific leasing closures or stipulations would be implemented to protect resource or 

resource uses in the project area outside of the Jemez National Recreation Area. 
Summary

Santa Fe National Forest Geothermal Leasing EIS iii

Potential indirect impacts from future geothermal leasing are as follows:

• Increased risk of seismic activity and ground subsidence

• Soil disturbance, compaction, and erosion

• Changes in groundwater flow paths, pressurization, and temperature

• Increased sediment and turbidity in surface water

• Vegetation removal

• Fish and wildlife habitat alteration and noise disturbance

• Increased short-term fugitive dust and vehicle emissions

• Disturbance to livestock and livestock grazing operations

• Reduced livestock grazing forage

• Disturbance to landscapes and locations associated with religious beliefs or cultural uses

• Temporary and long-term job creation

Alternative 1 would not meet the purpose and need of the project. This is because it would not 

identify reasonable and necessary conditions to protect surface and subsurface resources.

Indirect impacts under Alternative 2, the Proposed Action, would generally be similar to those 

under Alternative 1; however, discretionary closures and stipulations could reduce or mitigate

impacts on some resource or resource uses. For example, soil disturbance, compaction, and 

erosion would occur, but soil stipulations would reduce erosion in areas with severe erosion 

hazards and steep slopes. Stipulations for streams and rivers would limit sediment transport and 

turbidity. 

Fish and wildlife could be impacted through habitat alteration, removal, reduction, or 

fragmentation; however, implementation of stipulations would protect seasonally important 

wildlife habitat. Also, impacts would not lead to a substantial population change or trend toward 

federal listing for any species. Stipulations and closures for traditional cultural properties and 

Native American sacred sites, as identified though consultation, may reduce impacts, compared 

with Alternative 1; nevertheless, tribes consider the disturbance of the land or use of geothermal 

resources as an adverse impact that could not be avoided or minimized. The risk of seismic 

activity and ground subsidence would still occur under the proposed action.

Under Alternative 3, all Forest Service lands in the project area would be closed to geothermal 

leasing, and there would be no direct or indirect impacts. 

Indirect Impacts under Alternative 4 would be similar to those described under Alternative 2, the

Proposed Action. However, because fewer discretionary closures and stipulations would be 

implemented, the intensity or severity of impacts could be greater in certain areas. For example, 

soil erosion and runoff would be more likely to occur, and riparian areas would be more likely to 

experience disturbance or habitat alteration impacts. 
Summary

iv Santa Fe National Forest Geothermal Leasing EIS

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Contents

Santa Fe National Forest Geothermal Leasing EIS v 

Contents

Summary........................................................................................................................................... i

The Proposed Action .................................................................................................................... i

Public Involvement....................................................................................................................... i

Alternatives Considered ..............................................................................................................ii

Decision to be Made....................................................................................................................ii

Major Conclusions.......................................................................................................................ii

Acronym or Abbreviation...............................................................................................................ix

Chapter 1. Purpose of and Need for Action.................................................................................. 1-1

1.1 Introduction ................................................................................................................. 1-1

1.2 Purpose and Need for Action ...................................................................................... 1-2

1.3 Description of the Project Area and Decision Area .................................................... 1-3

1.4 Background for Geothermal Resources....................................................................... 1-3

1.5 Leasing and Development Process of Geothermal Resources on National 

Forest System Lands ................................................................................................... 1-7

1.6 New Mexico Geothermal Potential ............................................................................. 1-9

1.7 Relationship to Forest Service Plans, Policies, and Programs .................................. 1-13

1.8 Scope of Analysis...................................................................................................... 1-15

1.9 Decision Framework ................................................................................................. 1-16

1.10 Public Involvement and Scoping............................................................................... 1-16

1.11 Tribal Coordination ................................................................................................... 1-17

1.12 Issues......................................................................................................................... 1-18

1.13 Proposed Action ........................................................................................................ 1-21

Chapter 2. Alternatives, Including the Proposed Action............................................................... 2-1

2.1 Introduction ................................................................................................................. 2-1

2.2 Stipulations, Best Management Practices, and Procedures......................................... 2-1

2.3 Alternatives Considered in Detail ............................................................................... 2-5

2.4 Alternatives Considered but Eliminated from Detailed Study .................................. 2-12

2.5 Reasonably Foreseeable Development Scenario....................................................... 2-13

2.6 Comparison of Alternatives....................................................................................... 2-15

Chapter 3. Affected Environment and Environmental Consequences.......................................... 3-1

3.1 Introduction ................................................................................................................. 3-1

3.2 Methods and Assumptions Common to the Analysis of Impacts................................ 3-1

3.3 Cumulative Actions for Cumulative Impacts Analysis............................................... 3-3

3.4 Land Use, Recreation, and Special Designations........................................................ 3-5

3.5 Geologic Resources................................................................................................... 3-16

3.6 Energy and Mineral Resources.................................................................................. 3-22

3.7 Paleontological Resources......................................................................................... 3-27

3.8 Soil Resources........................................................................................................... 3-31

3.9 Water Resources........................................................................................................ 3-36

3.10 Air Quality and Air Quality-Related Values............................................................. 3-53

3.11 Vegetation ................................................................................................................. 3-71

3.12 Fish and Wildlife ....................................................................................................... 3-77

3.13 Threatened and Endangered Species and Special Status Species.............................. 3-89

3.14 Livestock Grazing ................................................................................................... 3-112

3.15 Cultural Resources .................................................................................................. 3-117

3.16 Tribal Interests and Traditional Cultural Resources................................................ 3-124

3.17 Visual Resources..................................................................................................... 3-131

3.18 Social Interests, Economics and Environmental Justice ......................................... 3-140
Contents

vi Santa Fe National Forest Geothermal Leasing EIS

3.19 Health and Safety .................................................................................................... 3-153

3.20 Noise ....................................................................................................................... 3-156

3.21 Transportation and Access...................................................................................... 3-158

3.22 Climate Change....................................................................................................... 3-163

3.23 Short-Term Uses and Long-Term Productivity....................................................... 3-171

3.24 Unavoidable Adverse Impacts ................................................................................ 3-172

3.25 Irreversible and Irretrievable Commitments of Resources...................................... 3-172

Chapter 4. Consultation and Coordination ................................................................................... 4-1

4.1 Preparers and Contributors.......................................................................................... 4-1

4.2 List of Agencies, Organizations and Persons Who Were Sent Copies of 

the DEIS...................................................................................................................... 4-4

Chapter 5. Glossary ...................................................................................................................... 5-1

Chapter 6. References................................................................................................................... 6-1

Chapter 7. Index............................................................................................................................ 7-1

List of Tables

Table 2-1. Summary of Acres Open and Closed to Geothermal Leasing, by Alternative............ 2-5

Table 2-2. Summary of Surface Disturbance from Exploration Activities................................. 2-14

Table 2-3. Summary of Surface Disturbance from Drilling and Utilization .............................. 2-14

Table 2-4. Comparison of Alternatives....................................................................................... 2-15

Table 3-1. Reasonably Foreseeable Future Actions ..................................................................... 3-4

Table 3-2. PRRAS Classification for Project Area..................................................................... 3-28

Table 3-3. Soil Characteristics of the Project Area..................................................................... 3-32

Table 3-4. Watershed Erodibility Index ..................................................................................... 3-43

Table 3-5. National and New Mexico Ambient Air Quality Standards...................................... 3-54

Table 3-6. Air Quality Monitoring Values in Rio Arriba and Sandoval Counties, 

New Mexico........................................................................................................................ 3-58

Table 3-7. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 

2011 (Tons)......................................................................................................................... 3-59

Table 3-8. Summary of Geothermal Exploration Activities and Surface Disturbance............... 3-64

Table 3-9. Geothermal Exploration Well Drilling Emissions .................................................... 3-65

Table 3-10. Summary of Geothermal Development Drilling and Surface Disturbance............. 3-67

Table 3-11. Geothermal Development Drilling Emissions......................................................... 3-68

Table 3-12. Major Vegetation Communities in the Project Area ............................................... 3-71

Table 3-13. Southwestern Region Regional Forester’s MIS on the SFNF................................. 3-78

Table 3-14. Federally Listed and Region 3 Regional Forester’s Sensitive Species on 

the SFNF............................................................................................................................. 3-90

Table 3-15. Northern Goshawk Post-Fledgling Family Areas in the Project Area .................... 3-96

Table 3-16. Livestock Grazing Allotments in the Santa Fe National Forest Geothermal 

Decision Area ................................................................................................................... 3-113

Table 3-17. Livestock Grazing Allotments in the Jemez National Recreation Area................ 3-115

Table 3-18. Scenic Integrity ..................................................................................................... 3-131

Table 3-19. Examples of Lux Measurements on a Given Surface............................................ 3-133

Table 3-20. Stipulations and Closures within a 1- and 2-mile Buffer of NPS Lands for 

Action Alternatives........................................................................................................... 3-139

Table 3-21. Viewshed Acres from the Caldera Rim and Redondo Peak by Action 

Alternative ........................................................................................................................ 3-140

Table 3-22. Population by County, State, and Country ............................................................ 3-141

Table 3-23. Housing Units by County, State and Country ....................................................... 3-142
Contents

Santa Fe National Forest Geothermal Leasing EIS vii

Table 3-24. Housing Vacancy Status 2010............................................................................... 3-142

Table 3-25. Median Home Values and Median Gross Rent 2014 ............................................ 3-143

Table 3-26. Santa Fe Geothermal Leasing Study Area - Property Tax Assessed Values 

and Obligations................................................................................................................. 3-143

Table 3-27. Santa Fe Geothermal Leasing Study Area - Average Yearly Unadjusted 

Unemployment Rate by County from 2010-2015............................................................. 3-144

Table 3-28. Median Household Income.................................................................................... 3-144

Table 3-29. Per Capita Income ................................................................................................. 3-144

Table 3-30. Populations in Poverty 2014.................................................................................. 3-146

Table 3-31. Study Populations by Race/Ethnicity 2014 ........................................................... 3-147

Table 3-32. Economic Impacts of Geothermal Electricity Generation..................................... 3-150

Table 3-33. Observed and Calculated Noise Levels for Geothermal Power Plants, 

Production Wells, and Drill Rigs...................................................................................... 3-157

Table 3-34. Average Temperatures and Precipitation in the Project Area (1981-2010)........... 3-163

Table 3-35. Geothermal Development Exploration Well Carbon Dioxide Emissions............. 3-167

Table 3-36. Geothermal Development Well Drilling Carbon Dioxide Emissions ................... 3-168

Table 3-37. Comparison of Geothermal and Fossil Fuel Carbon Dioxide Emissions.............. 3-169

List of Figures

Figure 1-1. Geothermal Leasing Project Surface Administration................................................. 1-4

Figure 1-2. Uses of Geothermal Energy (from 2008 PEIS; BLM and Forest Service 2008) ....... 1-5

Figure 1-3. Geothermal Leasing and Development Process....................................................... 1-10

Figure 1-4. Geothermal Potential Areas ..................................................................................... 1-12

Figure 3-1. Watersheds............................................................................................................... 3-37

Figure 3-2. Grazing Allotments................................................................................................ 3-114

Figure 3-3. Scenic Integrity ...................................................................................................... 3-132

Figure 3-4. Redondo Peak and Caldera Rim Viewsheds.......................................................... 3-134

Appendix B Figures 

Figure 2-1. Alternative 2 – The Proposed Action Closed to Leasing

Figure 2-2. Alternative 2 – The Proposed Action Available for Leasing Subject to 

No Surface Occupancy

Figure 2-3. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Controlled Surface Use

Figure 2-4. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Timing Limitations

Figure 2-5. Alternative 4 – The Development Alternative Closed to Leasing

Figure 2-6. Alternative 4 – The Development Alternative Available for Leasing Subject to 

No Surface Occupancy

Figure 2-7. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Controlled Surface Use

Figure 2-8. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Timing Limitations
Contents

viii Santa Fe National Forest Geothermal Leasing EIS

List of Appendices

Appendix A. Management Areas and Prescriptions from Forest Plan

Appendix B. Stipulations and Closures by Alternative

Appendix C. Best Management Practices and Mitigation Measures
Contents

Santa Fe National Forest Geothermal Leasing EIS ix

Acronym or Abbreviation Full Term

μg/m3 micrograms per cubic meter

AADT annual average daily traffic

ACEC Area of Critical Environmental Concern

AMZ aquatic management zone

AQRV air quality related value

AUM animal unit month

BLM United States Department of the Interior, Bureau of Land Management

BLS Bureau of Labor Statistics

BMP best management practice

°C degree Celsius

CAA Clean Air Act

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CWA Clean Water Act

CO2 carbon dioxide

CO2e carbon dioxide equivalent

COA condition of approval

CRMP Cultural Resource Management Plan 

CSU controlled surface use

CWE cumulative watershed effects

dBA a-weighted decibel

DOE United States Department of Energy

EIA Energy Information Administration

EIS environmental impact statement

EPA United States Environmental Protection Agency

ESA Endangered Species Act of 1973

°F degree Fahrenheit

FLPMA Federal Land Policy and Management Act of 1976

Forest Plan Santa Fe National Forest Plan 

GHG greenhouse gas

GIS geographic information system

IPCC Intergovernmental Panel on Climate Change

IRA inventoried roadless area

JNRA Jemez National Recreation Area

KGRA known geothermal resource area

LANL Los Alamos National Laboratory

MBTA Migratory Bird Treaty Act

MIS management indicator species

MOU memorandum of understanding
Contents

x Santa Fe National Forest Geothermal Leasing EIS

MSO Mexican spotted owl

MW megawatt 

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NFS National Forest System 

NHD National Hydrography Dataset

NHPA National Historic Preservation Act

NMDGF New Mexico Department of Game and Fish

NMDOT New Mexico Department of Transportation

NMED New Mexico Environment Department

NMOSE New Mexico Office of the State Engineer

NMWQCC New Mexico Water Quality Control Commission

NOI notice of intent

NORM naturally occurring radioactive materials

NPS United States Department of the Interior, National Park Service

NRA National Recreation Area

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NSO no surface occupancy

PAC protected activity center

PEIS programmatic environmental impact statement

PM2.5 particulate matter with an aerodynamic diameter of 2.5 microns or less

PM10 particulate matter with an aerodynamic diameter of 10 microns or less

ppb parts per billion

ppm parts per million

PRRAS Paleontological Resources Rapid Assessment System

PSD prevention of significant deterioration

RFDS reasonably foreseeable development scenario

RGCT Rio Grande cutthroat trout

ROD record of decision

ROI region of interest

ROS recreation opportunity spectrum

ROW right-of-way

SHPO State Historic Preservation Office

SFNF Santa Fe National Forest

TL timing limitation

TMDL Total Maximum Daily Load

USC United States Code

USDA United States Department of Agriculture

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VCNP Valles Caldera National Preserve

WEG wind erodibility group
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-1

Chapter 1. Purpose of and Need for Action

1.1 Introduction

In 2008, the US Department of the Interior, Bureau of Land Management (BLM) recommended 

and the Assistant Secretary of Land and Minerals Management approved the Record of Decision

(ROD) associated with the Programmatic Environmental Impact Statement (PEIS) for 

Geothermal Leasing in the Western United States. This led to a decision to amend BLM resource 

area management plans and provided analysis to allow certain National Forests to make 

decisions on existing lease applications. 

Decisions in the 2008 Geothermal ROD identified those lands that are legally open or closed to 

consideration for geothermal leasing on affected National Forest System (NFS) lands; it 

provided stipulations, best management practices (BMPs), and procedures for geothermal leasing 

and development. The Forest Service has determined that additional site-specific environmental 

analysis is needed to supplement the 2008 Geothermal PEIS. This is so the Forest Service can 

make a decision about providing concurrence and consent to the BLM to lease lands in the Santa 

Fe National Forest (SFNF) for developing geothermal resources. The regulations governing the 

relationship between the BLM and Forest Service (43 CFR, Subpart 3201.10[a][2]) use the term 

“concurrence.” Throughout this document “concurrence” and “consent” are used 

interchangeably. 

The 2008 Geothermal PEIS and ROD was prepared in accordance with the planning 

requirements of the Federal Land Policy and Management Act of 1976, as amended (FLPMA) 

and its implementing regulations at 43 CFR, Part 1600, as well as with the National 

Environmental Policy Act (NEPA) and its implementing regulations at 40 CFR, Parts 1500 

through 1508.

The Forest Service’s proposed action is to determine which lands in the SFNF on the Coyote, 

Cuba, Espanola, and Jemez Ranger Districts would be available for geothermal leasing and 

under what stipulations. As appropriate, this proposed action would amend the 1987 Santa Fe 

National Forest Plan, or the results of this environmental impact statement (EIS) would be 

incorporated into the revised Forest Plan.

The Forest Service has prepared this EIS in compliance with NEPA and other relevant federal 

and state laws and regulations. This EIS identities the direct, indirect, and cumulative 

environmental impacts that would result from the proposed action and alternatives. 

Additional documentation, including more detailed analyses of project area resources, may be 

found in the project planning record located at the SFNF.

This chapter details the purpose and need for the proposed action, the action’s objective, the 

planning and decision areas. It also provides the following:

 Provides a brief background on geothermal resources and the leasing and development 

process

 Details the relationship of the proposed action to existing policies and plans

 Outlines the scope of the analysis for the proposed action, the decisions to be made after 

analysis, and issues to be addressed based on internal and external scoping
Chapter 1. Purpose of and Need for Action

1-2 Santa Fe National Forest Geothermal Leasing EIS

Secretarial Order 3285A1, amended February 22, 2010, establishes the development of 

environmentally responsible renewable energy as a United States Department of Interior priority. 

The US Department of Agriculture, Forest Service (Forest Service) has obligations under Section 

225 of the Energy Policy Act to facilitate the development and production of geothermal energy.

The State of New Mexico, through the Renewable Portfolio Standard, has mandated that 

investor-owned utilities procure renewable energy and renewable energy certificates from New 

Mexico renewable generation facilities. In 2007 legislative changes to the Renewable Energy Act 

(SB418, signed by Governor Bill Richardson) mandated that investor-owned utilities must have 

in their portfolio as a percentage of total retail sales to New Mexico customers, renewable energy 

of no less than 15 percent by 2015 and 20 percent by 2020. 

Geothermal resources, along with oil and gas, fall under the Forest Service Leasable Minerals 

Program. The Geothermal Steam Act of 1970 gives the Secretary of the Interior authority to 

issue geothermal leases on NFS lands and regulates subsurface geothermal activities through the 

BLM (BLM; 30 United States Code [USC] 1002, Section 3).

In response to lease nominations and inquiries from industry, the BLM has requested the 

concurrence of the Forest Service to lease NFS lands in the SFNF for future geothermal 

exploration, development, and production (see Section 1.5, Leasing and Development Process of 

Geothermal Resources on NFS Lands, for more information about the leasing process). The 

BLM may only lease nominated NFS lands with Forest Service consent (43 CFR, Part

3201.10[a][2]). Before providing concurrence to the BLM for leasing, the Forest Service is 

responsible for conducting a NEPA analysis for leasing, for developing appropriate terms and 

conditions under which leases may be issued, and for ensuring decisions are consistent with the

SFNF Plan. 

1.2 Purpose and Need for Action

The purpose of the action is to refine the analysis available in the PEIS in order to determine if 

certain lands in the SFNF may be made available for geothermal leasing and, if so, to provide 

consent to leasing of lands and to identify reasonable and necessary conditions to protect 

resources. 

The need for the action is twofold: (1) to allow the Forest Service to satisfy its respective 

statutory and policy mandates in responding to requests for the environmentally responsible 

development of energy resources and (2) to respond to other policy directives calling for clean 

and renewable energy.

Specifically, the United States Geological Survey (USGS) has identified approximately 194,000 

acres of SFNF lands with significant geothermal potential; the BLM has received expressions of 

interest in leasing approximately 46,000 acres of this land for geothermal energy production. 

This action is needed because the SFNF Plan, as amended (Forest Service 1987) does not 

allocate areas as open or closed to geothermal leasing, does not have adequate stipulations or 

BMPs to apply to geothermal leases to protect sensitive resources, and does not assess the 

reasonably foreseeable development scenario (RFDS), as required in the 2008 PEIS. 

While the current expressed interest in geothermal leasing does not constitute all 194,000 acres, 

the entire area plus an additional approximately 900 acres for power transmission will be 

considered in the analysis in the event that the SFNF needs to address future interest. By 

incorporating all lands identified as containing significant geothermal potential under one EIS, 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-3

the SFNF can address future nominations and applications and provide consent or non-consent in 

a timely manner. 

1.3 Description of the Project Area and Decision Area

The project area encompasses approximately 194,910 acres, as follows:

 Approximately 26,212 acres are privately owned

 Approximately 48 acres are owned by state or other government entities

 Approximately 168,650 acres are NFS lands (lands on the Coyote, Cuba, Espanola, and 

Jemez Ranger Districts of the SFNF [Figure 1-1, Geothermal Leasing Project Surface 

Administration]). These lands comprise the decision area for the project; non-federal lands 

are not included in this decision.

The project area is in Sandoval and Rio Arriba Counties, New Mexico. The SFNF defined spatial 

boundaries for five units in the project area, for the purpose of future planning and characterizing 

existing conditions. These units, on lands managed by the SFNF, are listed below:

 Lease Interest Unit (39,200 acres)

 North Unit (48,200 acres)

 Middle Unit (10,800 acres)

 Jemez National Recreation Area (JNRA) Unit (39,200 acres)

 South Unit (34,400 acres)

1.4 Background for Geothermal Resources

As described in the 2008 PEIS, the term geothermal comes from the Greek words gé, meaning 

earth, and thermé, meaning heat, as geothermal energy is derived from the natural heat of the 

earth. Geothermal resources are typically underground reservoirs of hot water or steam created 

by heat from the earth, but geothermal resources also include subsurface areas of dry hot rock. In 

cases where the reservoir is dry hot rock, the energy is captured by injecting cool water from the 

surface, which is then heated by the hot rock and extracted as fluid or steam. 

Geothermal steam and hot water can naturally reach the earth’s surface in the form of hot 

springs, geysers, mud pots, or steam vents. Geothermal reservoirs of hot water are also found at 

various depths beneath the Earth’s surface. In the United States, geothermal resources are most 

ubiquitous in the western states, Alaska, and Hawaii (Tester et al. 2006; NREL 2015a). 

Geothermal resources can be accessed by wells and used to provide heat directly. This is called 

the direct use of geothermal energy. The heat energy can also be used to commercially generate 

electricity, a process called indirect use. As shown in Figure 1-2, Uses of Geothermal Energy, 

there are a wide range of uses for geothermal resources.

1.4.1 Direct Use

Humans have been using geothermal resources in the form of hot springs for thousands of years, 

and direct heat use is one of the most versatile forms of geothermal energy use (Dickson and 

Fanelli 2003, p. 16). Today, geothermal reservoirs with waters of 68 degrees Fahrenheit (oF) to 

302oF (20 degrees Celsius [oC] to 150oC) temperature water provide numerous opportunities for 

direct use. Direct use means using geothermal resources for commercial, residential, agricultural, 

Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-5

Figure 1-2. Uses of Geothermal Energy (from 2008 PEIS; BLM and Forest Service 2008)
Chapter 1. Purpose of and Need for Action

1-6 Santa Fe National Forest Geothermal Leasing EIS

or public facilities or for energy needs other than the commercial production of electricity (43 

CFR, Part 3200.1). The direct use of geothermal energy includes heating pools and spas, 

greenhouses and aquaculture facilities, and melting snow, and drying agricultural products. 

Direct use also has industrial applications and can be used for ground-source heat pumps (Lund 

and Boyd 2015). 

Direct uses in the United States have been growing at about 7 percent per year. The largest 

applications of direct heat uses in the United States are ground-source heat pumps, accounting 

for 88 percent of the annual energy use for all geothermal direct uses (Lund and Boyd 2015).

1.4.2 Commercial Electrical Generation

Commercial electrical generation from geothermal resources is also called indirect use. Electrical 

generation uses geothermally heated fluid to turn a turbine connected to a generator. As 

discussed below, the fluid may be the naturally occurring steam or water in the geothermal 

reservoir or another fluid that has the geothermal heat transferred through a heat exchange 

system.

Geothermal energy has been a small but consistent source of electricity in the United States since 

1971, providing 0.4 percent of total US generation in 2013 (EIA 2015a). As of 2013, there were 

64 operating conventional geothermal power plants in the United States, accounting for nearly 

2,700 megawatts (MW) of total capacity (EIA 2015a).

Geothermal power plants can be small (generating 300 kilowatts), medium (generating 10 to 50 

MW), and large (generating 50 MW and higher; Nemzer et al. 2007). Generation capacity is 

guided by the number of turbines in a plant. To extract thermal energy economically, one must 

drill to depths where temperatures are sufficiently high to justify investment in the heat-mining 

project. For commercial electricity generation, this generally means drilling to rock temperatures 

in excess of 300oF (149oC) (Tester et al. 2006). However, new technologies have proven that 

lower-temperature water (below 300oF [149oC]) can also be used for electrical generation 

(Aneke et al. 2011; BLM and Forest Service 2008; DOE 2015).

The following three types of geothermal power plant systems are commonly used to generate 

electricity, depending on temperature, depth, and quality of the water and steam in the area 

(NREL 2015b):

 Flash steam

 Binary-cycle

 Dry stream power plants

These plants can also be hybridized by including elements of the different technologies at a 

single location. In all three methods the remaining geothermal fluid is injected back into the 

ground to replenish the reservoir and recycle the residual hot water. Geothermal power plant

systems are described in detail in the 2008 Geothermal PEIS (BLM and Forest Service 2008).
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-7

1.5 Leasing and Development Process of Geothermal 

Resources on National Forest System Lands

1.5.1 Federal Geothermal Leasing Laws and Regulations

A federal geothermal lease grants “the exclusive right to drill for, extract, produce, remove, 

utilize, sell, and dispose of all the geothermal resources” in the lands described within the lease 

form. According to 43 CFR, Part 3200.1, geothermal steam and associated geothermal resources 

are defined as follows:

 All products of geothermal processes, including indigenous steam, hot water, and brines

 Steam and other gases, hot water, and hot brines resulting from water, gas, or other fluids 

artificially introduced into geothermal formations

 Other associated energy found in geothermal formations

 Any byproducts

The BLM has the delegated authority to issue geothermal leases on federal lands. It is the policy 

of the federal government, consistent with Section 2 of the Mining and Mineral Policy Act of 

1970 and Sections 102(a)(7), (8), and (12) of the FLPMA (43 USC, Section 1701 et seq.), to 

encourage the development of mineral resources, including geothermal resources, on federal 

lands. The Geothermal Steam Act of 1970 (30 USC, Section 1001 et seq.), which was amended 

and supplemented by the Energy Policy Act of 2005, provides statutory guidance for geothermal 

leasing by the BLM. Federal geothermal development regulations (43 CFR, Parts 3000, 3200, 

and 3280—Geothermal Resource Leasing and Geothermal Resources Unit Agreements) were 

made effective June 1, 2007 (72 Federal Register 24358, May 2, 2007), as a result of a directive 

provided in the Energy Policy Act of 2005. These statutes and regulations delineate lands that are 

available and unavailable for leasing.

1.5.2 Leasing and Development Process, Rights, and Limitations

The BLM grants access to geothermal resources through a formalized leasing process based on 

the end use. For direct uses, an applicant can apply noncompetitively for a lease; for indirect use, 

such as commercial electrical generation, the BLM awards leases through a competitive bidding 

process. Historically, certain lands were designated as known geothermal resource areas

(KGRAs). All lands designated within KGRAs were leased through a competitive bidding 

process. Before the passage of the Energy Policy Act of 2005, lands outside of known 

geothermal resource areas could be leased noncompetitively. Section 222 of the Energy Policy 

Act of 2005 modified the Geothermal Steam Act of 1970 to allow only competitive lease sales 

for all federal geothermal resources and their associated lands; however, there were the following 

exceptions:

 Parcels of land that did not receive bids in a competitive sale

 Lands available exclusively for direct use

 Lands with a mining claim and a current approved plan of operations

 Lands for which a lease application was pending on August 8, 2005, if the applicant so 

chooses

Lease areas are nominated by the public for a lease sale, whereas the public is defined as

follows: 
Chapter 1. Purpose of and Need for Action

1-8 Santa Fe National Forest Geothermal Leasing EIS

 A US citizen at least 18 years old

 An association of US citizens, including a partnership

 A corporation organized under the laws of the United States

 Any state or the District of Columbia

 A domestic government unit

When the BLM receives a nomination, it is adjudicated and configured into lease parcels by the 

respective BLM state office. Lease parcels are then forwarded to the appropriate Forest Service

office, where the appropriate environmental analysis and review is conducted. Environmental 

analysis and review yields a consent or non-consent decision for geothermal leasing. With the 

Forest Service’s consent, and once lease parcels are configured, the BLM is responsible for 

conducting geothermal lease sales and issuing competitive and noncompetitive leases. 

The BLM holds a competitive lease sale at least once every two years for lands available for 

leasing in a state that has nominations pending. Although the BLM cannot issue a lease without 

the consent of the Forest Service, it can add any additional terms, conditions, or stipulations that 

it deems necessary and appropriate. Also, the BLM must make an independent decision on 

whether to issue the lease after reviewing the decision and documentation presented by the 

Forest Service. 

The four stages of geothermal resource development within a lease area are exploration, drilling 

operations, utilization, and reclamation and abandonment. Each stage requires a permit from the 

BLM and is described in detail in Chapter 2 of the 2008 Geothermal PEIS (BLM and Forest 

Service 2008). Leasing geothermal resources from the BLM vests with the lessee a nonexclusive 

right to future exploration (non-production) and an exclusive right to produce and use the 

geothermal resources in the lease area. This is subject to existing laws, regulations, and formal 

orders. The lease is also subject to the terms, conditions, and stipulations in or attached to the 

lease form or included as conditions of approval to permits. 

Lease issuance alone does not authorize any ground-disturbing activities to explore for or 

develop geothermal resources without site-specific approval for the intended operation. Such 

approval could include additional environmental reviews and permits. Also at each stage, the 

BLM can issue site-specific conditions of approval (COAs) to protect resource values. For both 

exploration and production or utilization operations on leased lands, the BLM determines if the 

permit application should be approved. It coordinates NEPA review with the Forest Service, 

which may propose permit conditions of approval involving surface issues. The level of 

environmental analysis to be required under NEPA for subsequent individual exploration, 

development, and production permits is determined at the BLM field office and Forest Service 

unit level. 

A lease is issued for a primary term of 10 years and may be extended for two five-year periods. 

The BLM will extend the primary term for five years under one of the following circumstances:

 The lessee has satisfied the minimum work requirement or made a payment to the BLM 

equivalent to the required work; in such a case, the total of the payment and the value of the 

work performed must equal $40 per acre (43 CFR, Parts 3207.10 and 3207.11).

 The lessee submits documentation to the BLM that geothermal resources are produced or 

used in commercial quantities (43 CFR, Parts 3207.10 and 3207.11).
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Santa Fe National Forest Geothermal Leasing EIS 1-9

Once commercial production is established, the lease may receive a production extension of up 

to 35 years and a renewal period of up to 55 years. The lease must continue to produce to remain 

in effect. The BLM may grant a suspension of operations and production on a lease when 

justified by the operator (43 CFR, Part 3207). A diagram outlining the leasing and development 

process, including what stages provide opportunities for public involvement, is shown in Figure 

1-3, Geothermal Leasing and Development Process.

Geothermal exploration and production on federal land conducted through leases is subject to 

lease terms and stipulations and must also comply with all applicable federal and state laws 

pertaining to various considerations for tribal interests, sanitation, air quality, solid waste, scenic 

values, roads, water quality, wildlife, safety, cultural resources, and reclamation.

New Mexico classifies geothermal resources as mineral if the fluid produced has a temperature 

greater than 250°F and as water if the fluid produced has a temperature less than or equal to 

250°F. If the fluid produced is considered mineral, the resource is under the primary jurisdiction 

of the New Mexico Department of Energy, Minerals, and Natural Resources. This agency 

coordinates with the US Environmental Protection Agency (EPA), Region 6, which has authority 

over wastewater discharge to surface waters in the state. Both of these agencies, in addition to 

the New Mexico Environment Department (NMED), have regulatory authority over geothermal

discharge permits.

Geothermal fluid less than 250°F is considered water and is under the primary responsibility of 

the New Mexico Office of the State Engineer (NMOSE) for drilling and permitting. The EPA 

also has authority over wastewater discharge to surface waters in the state for fluids less than 

250°F. State permitting is beyond the scope of this project.

1.6 New Mexico Geothermal Potential

At the broad level, the 2008 PEIS (BLM and Forest Service 2008) estimated the potential for 

geothermal energy. However, since that time, changes in technology and more specific studies 

were conducted so that these areas may be more closely designated. In order to assess where 

geothermal development could occur, the SFNF conducted a detailed review of literature 

pertaining to existing geothermal potential studies on lands covering the SFNF.

The US Geological Survey (USGS 2010) reviewed geographic information system (GIS) data 

for lands with highly favorable geothermal development potential. This study analyzed 12 

models that correlate different geological and geophysical factors to the known presence of 

moderate (90 to 150°C) to high (greater than 150°C) temperature geothermal systems (Williams 

and DeAngelo 2008; Williams et al. 2008; Williams et al. 2009). The SFNF also evaluated the 

location of KGRAs that the USGS identified as containing geothermal resources (Forest Service

1977). Although KGRAs no longer guide the geothermal leasing process, they do show areas of 

potential geothermal resources. Additionally, the SFNF evaluated data published in a US 

Department of Energy (DOE) commissioned study: Opportunities for Near-Term Geothermal 

Development on Public Lands in the Western United States (DOE and BLM 2003). Based on the 

information contained in these studies, the SFNF identified lands most likely to receive 

geothermal lease nominations and applications. This area was defined as the project area for the 

EIS.
Chapter 1. Purpose of and Need for Action

1-10 Santa Fe National Forest Geothermal Leasing EIS

Figure 1-3. Geothermal Leasing and Development Process
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-11

1.6.1 Resource Geography

New Mexico contains abundant geothermal resources throughout a large temperature gradients. 

Temperature gradients refer to the rate of increasing temperature with respect to increasing 

depth. High temperature gradients can indicate the location and depth of potential underground 

geothermal reservoirs capable of supporting commercial uses. Resources suitable for most 

development are concentrated in the west and north-central regions of the state, with high

temperature gradients ranging from 1.6°F to 2.5°F per 100 feet of depth (BLM and Forest 

Service 2008).

Within the project area, highly favorable geothermal resources are concentrated on lands next to 

the Valles Caldera National Preserve (VCNP), as shown on Figure 1-4, Geothermal Potential 

Areas (USGS 2010). KGRAs cover most lands in the project area south of Highway 96. 

Similarly, most lands identified as having geothermal development potential in the project area

in the 2003 US DOE study are south of Highway 96 (DOE and BLM 2003).

1.6.2 Utilization

New Mexico’s first utility-scale geothermal power plant was completed at the Lightning Dock 

geothermal field in Hidalgo County in 2013, producing 4 MW of electricity (Geothermal Energy 

Association 2014). No other utility-scale production plants are in operation in New Mexico. 

Direct use applications of geothermal in New Mexico include greenhouses, heat pumps, and 

aquaculture operations.

1.6.3 Technical Capabilities

New Mexico universities, national laboratories, state agencies, local working groups, and private 

companies contribute technical capabilities to the local and national geothermal communities. 

Research conducted through Sandia National Laboratories has investigated drilling concepts and 

new technology and processes, including tools to make geothermal energy drilling more cost 

efficient. The concept of hot dry rock1geothermal technology originated at Los Alamos National 

Laboratory (LANL) in the early 1970s (Brown 2009). Numerous research and collaboration 

studies from the University of New Mexico have contributed to the understanding of geothermal 

and hydrothermal conditions in the state, including SFNF lands. New Mexico State University at 

Las Cruces has conducted geothermal research that resulted in the development of a geothermal 

space-heating system that at one point heated up to 30 campus buildings, such as dorms and 

athletic facilities (BLM and Forest Service 2008).

1.6.4 Electrical Power Generation and Capacity

In the near term, geothermal development in New Mexico is likely for small-scale power (BLM 

and Forest Service 2008). The USGS report titled Assessment of Moderate- and High-Temperature 

Geothermal Resources of the United States estimates a mean probability 170 MW of electrical 

power generation for identified geothermal resources on all lands in New Mexico during the next 

30 years; it predicts a total low-high range of between 53 MW and 343 MW (Williams et al. 2008).

 

1 Hot dry rock technology refers to the formation of a fully engineered geothermal reservoir in hot, 

crystalline rock by the application of hydro-shearing techniques and the subsequent circulation of water 

through that engineered reservoir to mine the thermal energy from the hot rock (Duchane and Brown 

1995).

Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-13

Lopez et al. (2012) investigated technical potential for hydrothermal and enhanced geothermal 

systems by state, given system performance, topographic limitations, environmental, and landuse constraints to estimate the upper boundary of development potential. In New Mexico, total 

estimated technical potential for hydrothermal is 2 gigawatts (GW), and enhanced geothermal 

systems is 180 GW (Lopez et al. 2012).

1.7 Relationship to Forest Service Plans, Policies, and 

Programs

1.7.1 Santa Fe National Forest Plan

The SFNF operates under the direction of the Santa Fe National Forest Plan, as amended (Forest 

Service 1987). The 1987 Forest Plan does not allocate lands as available or unavailable to 

geothermal leasing. 

Goals and forest-wide standards and guidelines relevant to fluid mineral leasing and 

development (i.e., lands and minerals) are summarized below. Standards and guidelines specific 

to management areas in the project area are found in Appendix A, Management Areas and 

Prescriptions from Forest Plan. This list is not comprehensive but instead includes only 

management that is relevant to geothermal leasing. In 2015, the SFNF began the process of 

revising the Forest Plan. The results of this EIS will amend the 1987 Forest Plan.

1.7.1.1 Goals—Minerals

 Support sound energy and minerals exploration and development, where appropriate. 

Administer the mineral laws and regulations to minimize adverse surface resource impacts.

1.7.1.2 Goals—Lands

 Minimize the number of electronic sites and utility corridors by allowing only those that are 

most appropriately located on Forest lands. Use existing corridors, whenever possible from a 

need and resource management standpoint. 

1.7.1.3 Forest-Wide Standards and Guidelines—Minerals 

 G01—Review with the BLM existing withdrawals to ensure compliance with FLPMA. 

Consider release for exploration and development while adequately protecting surface 

resources. (Note: Forest Service Manual 2561.25 provides direction on managing 

groundwater resources in addition to surface resources).

 G04—Respond in a timely manner to oil and gas, geothermal, and other mineral lease 

applications. Response will normally be within 30 days of receipt of application, but 

extensive public involvement or environmental analysis needs may require more time. Such 

needs will be fully coordinated with the BLM. 

 G05—Control surface uses in mineral operations through plans of operation and permits that 

provide for the following:

 Meeting visual quality objectives

 Preserving water quality

 Protecting watershed values

 Reclaiming the surface to original or characteristic contours or adapting it to serve 

further surface resource uses
Chapter 1. Purpose of and Need for Action

1-14 Santa Fe National Forest Geothermal Leasing EIS

 Revegetating or reforesting the surface with appropriate plant species to attain soil 

stability

 Protecting cultural resources

 Protecting threatened and endangered species and other wildlife habitats

 G06—Ensure mineral areas are restored to repair resource damage and remove public safety 

hazards, as needed. Reclamation will be managed for progressive development and 

rehabilitation. Operating plans, including appropriate bonding, will be the means for 

accomplishing this. Backlog work will be programmed and accomplished as opportunities 

arise and funding is made available.

1.7.1.4 Forest-Wide Standards and Guidelines—Lands and Utility Corridors

 Provide for joint use in corridors and combine uses to the extent possible in light of technical 

and environmental constraints. All requests for utility corridors will require a comprehensive 

NEPA environmental analysis. Each management area has been evaluated as to suitability 

for corridor location. The suitability classifications are as follows:

 Exclusion area—No utility corridors are allowed.

 Avoidance area—Utility corridors are not consistent with management area emphasis 

and may require extensive mitigation measures.

 Unclassified area—Utility corridors are permitted after normal environmental analysis.

1.7.2 Memorandum of Understanding Between Forest Service and 

BLM: Implementation of Section 225 of the Energy Policy Act 

of 2005 Regarding Geothermal Leasing and Permitting

In 2006, the BLM and Forest Service signed a Memorandum of Understanding (MOU) to 

facilitate interagency coordination between the Forest Service and BLM, and establish policies 

and procedures to implement Section 225 of the Energy Policy Act of 2005, Public Law 109-58. 

Section 225 requires the coordination of geothermal leasing and permitting on public lands and 

NFS lands between the Secretary of the Interior and Secretary of Agriculture.

The MOU establishes that the Forest Service will take the lead for completing pre-lease NEPA

documents and is responsible for providing the official Forest Service consent or non-consent to 

leasing on NFS lands. The Forest Service and BLM will also identify, through the analysis, 

reasonable and justifiable stipulations needed to protect or minimize impacts on specific 

resources or land uses. 

1.7.3 Programmatic Environmental Impact Statement for 

Geothermal Leasing Exploration and Development

The BLM and Forest Service prepared the 2008 Geothermal PEIS to assess the environmental 

impacts from developing and implementing the geothermal program. It facilitated

environmentally responsible utility-scale geothermal energy development in the following 

Western states: Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, Nevada, 

Oregon, Utah, Washington, and Wyoming. Additionally, the 2008 Geothermal PEIS allocated 

NFS lands as open or closed to being considered for geothermal leasing. It also adopted 

stipulations and BMPs and explained the procedures for geothermal leasing and development 

(BLM and Forest Service 2008).
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-15

The Forest Service determinations resulting from the 2008 Geothermal PEIS and ROD are as 

follows:

 Identified those NFS lands legally open or closed to leasing

 Developed an RFDS for a potential for 12,210 MW of electrical generating capacity from 

244 power plants in the 12 western states by 2025, plus additional direct uses of geothermal 

resources

 Included stipulations, BMPs, and procedures for geothermal leasing and development

 Recognized that, before making a leasing decision on lands near an National Park Service

(NPS) unit, the BLM or other surface management agency must determine if there would be 

any impacts on thermal or hydrological features in the unit, in accordance with the 

Geothermal Steam Act Amendments (30 USC, Section 1026)

The 2008 Geothermal PEIS noted that designating lands for geothermal leasing potential and 

amending a land use plan, in and of itself, does not cause any direct impacts, as defined by the 

Council on Environmental Quality (CEQ) regulations (40 CFR, Part 1508.8[a]). However, it is 

reasonable to foresee that on-the-ground impacts would occur if the BLM were to issue 

geothermal leases but that the impacts would not occur until the future. Therefore, the 2008 

Geothermal PEIS addressed both direct and indirect impacts based on the foreseeable on-theground actions, including exploration, drilling, and utilization.

In Volume I, these impacts were not analyzed site specifically but generically and 

programmatically for the 2008 Geothermal PEIS project area, based on the RFDS. The 2008 

Geothermal PEIS analyzed the broad impacts associated with allocation of geothermal resources

for leasing. It also analyzed the adoption of stipulations and BMPs, based on the assumptions 

presented in the RFDS, in assessing the likely impacts from development following leasing in 

the project area. 

Volume II of the PEIS provided lease-specific analysis to decision-makers to aid them in 

deciding on whether to issue or deny 19 geothermal lease applications that were pending as of 

January 1, 2005. Pending lease applications did not include lands on the SFNF, and no sitespecific analysis for issues associated with on-the-ground actions of geothermal exploration, 

drilling, utilization, or reclamation and abandonment was conducted. Additionally, the 2008 

Geothermal PEIS did not result in a consent determination on NFS lands. Before conducting 

lease sales, the Forest Service must provide the BLM with a consent determination (including 

terms and conditions or stipulations). As such, this document alone is insufficient to proceed 

with geothermal lease sales and issuance of competitive and noncompetitive leases. The 2008 

Programmatic EIS provides the basis for consent decisions covered in this EIS. 

1.8 Scope of Analysis

The 2008 Geothermal PEIS included an analysis of the potential effects of utility-scale 

geothermal energy development on public lands. That analysis was designed to provide 

environmental consequences, in accordance with NEPA, to support the decision, which 

identified lands legally open to leasing. The SFNF Geothermal Leasing EIS is a separate analysis 

process, with the following purposes:

 Determines if lands in the project area are available for the BLM to lease and, if so, under 

what stipulations for protection of surface resources

 Describes the RFDS for the project area
Chapter 1. Purpose of and Need for Action

1-16 Santa Fe National Forest Geothermal Leasing EIS

 Examines the existing environmental setting

 Describes the potential direct, indirect, and cumulative impacts on the human and natural 

environment associated with implementing a range of alternatives

Because the planning and decision area for the SFNF Geothermal Leasing EIS is in the study 

area covered by the 2008 Geothermal PEIS analysis, this EIS will “tier” to the PEIS. Tiering 

refers to the coverage of general matters in a broader EIS; subsequent narrower EISs or 

environmental assessments, such as this one, incorporate by reference the general discussions 

and concentrate solely on the issues specific to the EIS or environmental assessment 

subsequently prepared (40 CFR, Part 1508.28). Tiering typically results in a more efficient 

environmental analysis process for future development proposals. The determination of the 

necessary level of additional NEPA analysis is made on a case-by-case basis at the time a project 

is proposed. 

This EIS will tier to those elements of the 2008 Geothermal PEIS that are appropriate for such 

use (e.g., resource impact analysis, stipulations, leasing procedures, and BMPs). Because the 

SFNF Geothermal Leasing EIS presents different site-specific issues than those addressed in the 

2008 Geothermal PEIS, the analysis for this EIS has been refined and may include other 

protective provisions specific to the project area.

The scope of this analysis does not evaluate surface-disturbing geothermal exploration or 

development proposals. Subsequent site-specific projects would require future environmental 

analysis, which could tier to this EIS and the 2008 Geothermal PEIS. The appropriate level of 

environmental analysis would be determined by the authorizing officer. 

1.9 Decision Framework

Given the purpose and need, the deciding official reviews the proposed action, the other 

alternatives, and the environmental consequences in order to make the following decisions:

 What lands would be made available for leasing through a consent determination and any 

stipulations that would be included in future leases the BLM may issue

 What lands would not be available for leasing 

This decision would not authorize lease sale or development of parcels. 

1.10 Public Involvement and Scoping

The formal public scoping comment period, as required by NEPA (40 CFR, Subpart 1501.7), 

began on May 13, 2015, and ended on June 26, 2015. Scoping included the following:

 Notice of intent (NOI) published in the Federal Register on May 13, 2015;

 Media outreach, including press releases and project website 

(http://www.fs.usda.gov/project/?project=46886)

 Scoping letter mailing to those on the project mailing list, including federal, state, and local 

agencies, Native American tribes, special interest groups, and landowners

 Public scoping meetings

The NOI published was entitled Santa Fe National Forest; New Mexico; Geothermal Leasing. It

noted that comments concerning the scope of the analysis must be received by June 12, 2015 (on 

June 8, 2015, the SFNF issued a news release indicating the scoping period was extended to June 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-17

26). The NOI also provided an overview of the proposed action, purpose and need for the 

project, and instructions for submitting comments.

The SFNF issued a press release on May 13, 2015, announcing its intent to prepare an EIS. The 

press release included a link to the NOI, which was published that day. On May 26, 2015, the 

SFNF issued a second press release that included dates, times, and locations for the two 

scheduled public scoping meetings, as well as information on how written comments could be 

submitted. On June 8, 2015, a third press release was issued indicating the SFNF had extended 

the deadline for public comments on the scope of the environmental analysis from June 12 to 

June 26, 2015, to give the public more time to submit comments on the proposed project.

On May 22, 2015, the SFNF e-mailed a scoping letter and scoping document to federal, state, 

and local agencies, special interest groups, landowners, and other interested individuals. Hard 

copies of the scoping letter were also mailed to individuals with no e-mail address on file. The

scoping letter provided a brief overview of the project and included dates and locations of the 

two public meetings and instructions for submitting written comments. The scoping document 

provided a more detailed description of the project: leasing background information, purpose and 

need for action, decision to be made, preliminary issues, scoping process, analysis process, and 

figures showing the project area and proposed closures.

Public scoping meetings were held on June 1, in Cuba, New Mexico and on June 2 in Santa Fe. 

Forest Service staff were available at the meetings to answer questions from attendees, who were 

encouraged to submit written comments so that their concerns could be accurately conveyed and 

formally addressed in the EIS. Comment forms were available at the meetings for attendees to 

fill out and either submit at the meeting or mail in later. 

Results of the public scoping are discussed in detail in the scoping report posted on the project 

website.

1.11 Tribal Coordination

The Forest Service consults on a government-to-government basis with Native American tribes. 

Consultation and coordination with Native American tribal governments have begun and are 

ongoing. 

The SFNF consulted with the following federally recognized tribes in the region: Pueblo of 

Acoma; Pueblo of Isleta; Kewa Pueblo (Pueblo of Santa Domingo); Pueblo of Nambé; Pueblo of 

Cochiti; Pueblo of Jemez; Pueblo of Laguna; Ohkay Owingeh; Pueblo of Picuris; Pueblo of San 

Ildefonso; Pueblo of Santa Clara; Pueblo of Pojoaque; Pueblo of San Felipe; Pueblo of Santa 

Ana; Pueblo of Taos; Pueblo of Tesuque; Pueblo of Zia; Pueblo of Zuni; Jicarilla Apache Nation; 

Ojo Encino Navajo Chapter House; Pueblo Pintado Navajo Chapter House; Canoncito Navajo 

Chapter House; Ramah Navajo Chapter House; Counselor Navajo Chapter House; Crownpoint 

Navajo Chapter House; Torreon Navajo Chapter House; Whitehorse Lake Navajo Chapter 

House; Mescalero Apache Tribe; The Hopi Tribe; The Navajo Nation; Southern Ute Tribe; Ute 

Mountain Ute Tribe.

The SFNF began consultation before the formal scoping period by mailing a briefing paper to 

tribes on October 14, 2014, which provided an overview of the project, and current status. 

Additionally, meetings were held with tribes in October, 2014, to present information related to 

the project and answer questions. The SFNF held meetings with the following tribes: Pueblo of 

Jemez; Pueblo of Zia; Pueblo of Cochiti; Pueblo of Santa Domingo; Pueblo of San Ildefonso; 
Chapter 1. Purpose of and Need for Action

1-18 Santa Fe National Forest Geothermal Leasing EIS

Ohkay Owingeh; Pueblo of Santa Clara; Jicarilla Apache Nation; Counselor Navajo Chapter 

House; and Torreon Navajo Chapter House. Scoping letters were sent to the list of consulted 

tribes describing the project, date, and times of the public meetings and requesting consultation. 

The letters requested information on issues or concerns with historic properties in the project 

area under Section 106 of the National Historic Preservation Act. The SFNF held meetings with 

the San Felipe and Santa Clara Pueblo in July and September 2015.

1.12 Issues 

The Forest Service separated the issues into two groups: significant and non-significant. 

Significant issues were defined as those directly or indirectly caused by implementing the 

proposed action. Non-significant issues were identified as the following:

 Those outside the scope of the proposed action

 Those already decided by law, regulation, Forest Plan, or other higher level decision

 Those irrelevant to the decision to be made

 Those conjectural and not supported by scientific or factual evidence

NEPA regulations explain this delineation in Sec. 1501.7, “...identify and eliminate from 

detailed study the issues which are not significant or which have been covered by prior 

environmental review (Sec. 1506.3)....” A list of non-significant issues and reasons regarding 

their categorization as such can be found in the project record.

As for significant issues, the Forest Service identified the following issues during scoping:

1.12.1 Timing and Scope of the Proposal

 Issue—Is the timing and scope of the proposal appropriate, considering the size of the 

project area relative to expression of interest area and the ongoing Forest Plan revision 

process?

 Issue—Considering previous geothermal exploration in the region, how viable is commercial 

geothermal development in the project area?

 Issue—Are there other agencies besides the BLM and NPS that should serve as cooperating 

agencies on this project?

1.12.2 Land Use, Recreation, and Special Designations (Including 

Inventoried Roadless Areas)

 Issue—How would geothermal leasing impact inventoried roadless areas (IRAs) and 

sensitive resources in IRAs?

 Issue—How would geothermal leasing impact adjacent wilderness areas, lands with 

wilderness characteristics, IRAs, and Areas of Critical Environmental Concern (ACECs) or 

other special designations?

 Issue—How would geothermal leasing affect recreation in the project area? How would 

geothermal leasing affect the JNRA and other nearby recreation areas managed by other 

federal or state agencies?

1.12.3 Geologic Resources

 Issue—What are the impacts on geologic resources from geothermal developments? Could 

there be increased risk for induced seismicity or other geologic hazards as a result of 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-19

geothermal leasing? If so, what are the indirect effects of geologic hazards, considering the 

proximity of the Abiquiu Dam and LANL?

 Issue—Is baseline seismic monitoring or additional fault mapping required to determine the 

risks of induced seismicity or other geologic hazards associated with geothermal exploration

or development?

1.12.4 Water Resources and Quality

 Issue—How would geothermal leasing affect surface and subsurface water quantity? Would 

geothermal leasing change or reduce water allocations for other uses? What are the shortand long-term effects on the regional aquifer?

 Issue—How would geothermal leasing affect water quality, and what size buffers are 

necessary to protect surface waters? How might these effects differ, depending on the type of 

geothermal system?

 Issue—How would geothermal leasing affect the Abiquiu Reservoir and Dam and the New 

Mexico Department of Game and Fish (NMDGF) Habitat Stamp Program water projects?

1.12.5 Air Quality and Air Quality-Related Values

 Issue—How would gases and emissions from geothermal leasing be monitored and 

controlled, and how would residual waste accumulations from air emission management be 

disposed of?

 What are the effects of odors from geothermal leasing, and how would these affect receptors 

in the project area?

1.12.6 Vegetation

 Issue—How would vegetation loss from geothermal leasing affect soil erosion?

 Issue—How would noxious and invasive weeds be managed in geothermal leasing areas?

1.12.7 Wildlife

 Issue—What are the short- and long-term effects of geothermal leasing on cold water 

fisheries, wildlife corridors, critical wildlife habitat areas, fish hatcheries, and other 

important or sensitive fish and wildlife habitats in the project area?

1.12.8 Threatened and Endangered Species and Special Status 

Species

 Issue—What are the effects of geothermal leasing on the Mexican spotted owl, Jemez 

Mountain salamander, New Mexico meadow jumping mouse, Jemez woodland snail, Rio 

Grande cutthroat trout (RGCT), and other threatened and endangered or special status 

species in the project area? What stipulations and mitigation measures are necessary to 

protect these species?

 Issue—Would geothermal leasing displace other resource uses on the forest, such as 

recreation and livestock grazing, into or near threatened and endangered species or special 

status species’ habitats?

1.12.9 Livestock Grazing

 Issue—How would geothermal leasing affect grazing allotments and grazing forage?
Chapter 1. Purpose of and Need for Action

1-20 Santa Fe National Forest Geothermal Leasing EIS

1.12.10 Cultural Resources

 Issue—How would cultural resources be affected by geothermal leasing, and how would

these effects be managed?

1.12.11 Tribal Interests and Traditional Cultural Properties

 Issue—How would traditional cultural properties and tribal interests be affected by 

geothermal leasing, including those in confidential locations, and how would those effects be 

managed? What are the direct, indirect, and cumulative impacts of other resource impacts on 

tribal interests?

1.12.12 Visual Resources

 Issue—What are the visual impacts associated with geothermal leasing, including 

construction of transmission lines and water vapor from geothermal plants?

1.12.13 Social Interests, Economics, and Environmental Justice

 Issue—How would geothermal leasing affect tourism, local businesses, property values, and 

community services?

 Issue—Would geothermal leasing result in disparate impacts on communities, tribes, or other 

populations?

1.12.14 Health and Safety

 Issue—What are the health and safety risks of geothermal leasing? How would geothermal 

leasing affect drinking water, considering the regional geology?

1.12.15 Noise

 Issue—What are the impacts of increased noise in the project area?

1.12.16 Transportation and Access

 Issue—How would increased traffic affect residents, visitors, and other forest users? What 

would be the impacts on road conditions and adjacent buildings as a result of increased 

traffic?

 Issue—How would geothermal leasing affect public access to the SFNF?

1.12.17 Climate Change

 Issue—How would the SFNF address climate change and greenhouse gas (GHG) emissions 

from geothermal leasing?

 Issue—Would geothermal leasing affect regional weather conditions?

1.12.18 Fire

 Issue—What stipulations and mitigation measures are necessary to reduce the risk of 

wildfire associated with geothermal energy transmission?
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-21

1.12.19 National Park Service Values2

 Issue—How would geothermal leasing affect the natural, cultural, and sensory resource 

values of the Bandelier National Monument and Valles Caldera National Preserve, and what 

stipulations and mitigation measures are necessary to protect these values?

1.13 Proposed Action

The Forest Service’s proposed action is to determine which lands in the SFNF on the Coyote, 

Cuba, Espanola, and Jemez Ranger Districts would be available for geothermal leasing and 

under what stipulations. This would be implemented by amending the SFNF Forest Plan or by 

incorporating the decisions into the revised Forest Plan.

Under the proposed action, certain lands in the project area are excluded from geothermal 

leasing on the basis of existing laws, regulations (43 CFR, Part 3201.11), and executive orders. 

Non-discretionary closures are for the JNRA (28,900 acres).

In addition to non-discretionary closures, the Forest Service has the administrative authority to 

issue discretionary closures to protect special resource values. The following areas are proposed 

Forest Service discretionary closures for geothermal leasing:

 Administrative site withdrawals

 Seven Springs (7 acres)

 Encino (184 acres)

 Encino Point (120 acres)

 Cerro Pelado Lookout (160 acres)

About 29,321 acres of NFS lands would be closed by law, regulations, or other authority to 

geothermal leasing in the project area. This represents about 17 percent of the NFS lands in the 

project area. 

All other lands in the project area would be allocated as open to leasing, subject to existing laws, 

regulations, formal orders, stipulations attached to the lease form, and terms and conditions of 

the standard lease form.

No surface occupancy (NSO), controlled surface use (CSU), and timing limitation (TL)

stipulations would be implemented on lands allocated as open to leasing, in accordance with the 

guidance provided in the Geothermal PEIS. These allocations are described in detail in 

Chapter 2. 

The lessee and the appropriate federal agency would monitor lease stipulations, conditions of 

approval, and the general operation of geothermal developments to ensure their continued 

effectiveness through all phases of development. Using adaptive management strategies, where 

mitigation measures are determined to be ineffective at meeting the desired resource conditions, 

the BLM and Forest Service would take steps to determine the cause and would require the 

 

2

Issues specific to National Park Service values are discussed under Section 3.17, Visual Resources; 

Section 3.20, Noise; Section 3.15, Cultural Resources; Section 3.16, Tribal Interests and Traditional 

Cultural Resources; Section 3.11, Vegetation; Section 3.12, Fish and Wildlife; and Section 3.13, 

Threatened and Endangered Species and Special Status Species. 
Chapter 1. Purpose of and Need for Action

1-22 Santa Fe National Forest Geothermal Leasing EIS

operator to take corrective action. This information would also be used to inform future 

geothermal leasing and development.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-1

Chapter 2. Alternatives, Including the Proposed 

Action

2.1 Introduction

This chapter provides the details of the proposed action, the alternatives to the proposed action, a 

discussion of alternatives considered but eliminated from detailed analysis, and an overview of 

the RFDS for geothermal resources in the SFNF. Also in this section is a comparison of the 

alternatives, sharply defining the differences between each alternative and providing a clear basis 

for choice among options by the decision-maker and the public.

After the public scoping period closed on June 26, 2015, the SFNF began developing 

alternatives. Based on public input, the interdisciplinary team’s analysis of the current 

management situation and resource data, and the defined purpose and need for the project, the 

Forest Service developed four alternatives, including a no action alternative. Each of the 

alternatives denotes whether the SFNF would consent to leasing land in the decision area and 

which lease stipulations would apply. Differences between alternatives are expressed by whether 

the SFNF would consent to leasing land and the degree of stipulation constraints applied to those 

areas. 

2.1.1 Identified Lands Available for Geothermal Leasing

The geothermal leasing regulations (43 CFR, Part 3201) describe the types of lands available and 

unavailable for geothermal leasing. The BLM may issue geothermal leases on Forest Service

lands that are available for leasing in the land use planning process. Exceptions to this are 

identified as lands closed to geothermal leasing; this denotes an area that is not available for 

geothermal leasing, exploration, or development for nondiscretionary or discretionary reasons. 

The 2008 Geothermal PEIS identified certain classifications of lands as excluded from 

geothermal leasing, based on a nondiscretionary or discretionary basis. Nondiscretionary 

closures would be for lands that are excluded based on existing laws, regulations (43 CFR, 

Subpart 3201.11), and executive orders. For both the action and no action alternatives, 

nondiscretionary closed lands or lands where consent would not be granted for leasing are 

approximately 28,900 acres of NFS lands in the JNRA (of the 32,900 total acres—including nonNFS lands—in the JNRA). 

2.2 Stipulations, Best Management Practices, and 

Procedures

This section describes the types of constraints that would be applied as appropriate to any new 

leases for lands that are available for geothermal leasing. The SFNF developed stipulations, 

BMPs, and procedures based on the 2008 Geothermal PEIS and through the assessment process 

for this EIS. These stipulations were selected for inclusion based on a comprehensive review of 

the SFNF Forest Plan, program guidance, geothermal development activities, published data on 

geothermal development impacts, industry standards, and best professional judgment. Other 

reports on fluid mineral leasing and development (e.g., oil and gas) were consulted because of 

the similarity of most of the activities and impacts, such as from exploration, drilling, and site 

development. Where the agency determines that particular stipulations may be inappropriate for 

a planning area, the procedures for waivers, exceptions, and modifications would be followed.
Chapter 2. Alternatives, Including the Proposed Action

2-2 Santa Fe National Forest Geothermal Leasing EIS

A detailed description of stipulations by alternative is provided in Appendix B, Geothermal 

Leasing Stipulations by Alternative. A list of BMPs is provided in Appendix C, Best 

Management Practices and Mitigation Measures. 

2.2.1 Lease Stipulations

Lease stipulations are major or moderate constraints applied to a new geothermal lease. A lease 

stipulation is a condition of lease issuance that provides a level of protection for other resource 

values or land uses by restricting lease operations during certain times or at certain locations or 

by mitigating unacceptable impacts, to an extent greater than standard lease terms or conditions. 

A stipulation is an enforceable term of the lease contract; it supersedes any inconsistent 

provisions of the standard lease form and is attached to and made a part of the lease. Lease 

stipulations further implement the Forest Service’s and BLM’s regulatory authority to protect 

resources or resource values.

Stipulations provided in this EIS would serve as the minimal level of protection and would be 

adopted into the Forest Plan when the ROD is signed. It may be necessary to add, delete, or 

modify lease stipulations in the Forest Plan. This would happen as a result of pre-lease issuance 

parcel reviews, statewide lease stipulation consistency reviews, plan amendments, changed 

circumstances on the ground, or changed resource protection priorities. This is accomplished and 

documented either through the plan maintenance process (for minor changes consistent with an 

approved plan) or the plan amendment process (for changes resulting in modification of terms, 

conditions, or decisions in an approved plan).

More than one stipulation may apply to a parcel of land. For example, a parcel may have an NSO

stipulation to protect a property listed on the National Register of Historic Places (NRHP), a

CSU stipulation to protect a recreation area, and a TL for big game winter range.

2.2.2 Lease Exceptions, Waivers, and Modifications

To ensure leasing decisions remain appropriate in light of continually changing circumstances 

and new information, the Forest Service and BLM develop and apply lease stipulation 

exceptions, waivers, and modification criteria. An exception, waiver, or modification (defined 

below) may not be approved unless the BLM Authorized Officer determines that the factors 

leading to the stipulation’s inclusion in the lease have changed sufficiently to make the 

protection provided by the stipulation no longer justified, or the proposed operations would not 

cause unacceptable impacts (43 CFR, Subpart 3101.1-4).

• An exception is a one-time exemption for a particular site within the leasehold and is

determined on a case-by-case basis; the stipulation continues to apply to all other sites within 

the leasehold. An exception is a limited type of waiver.

• A waiver is a permanent exemption from a lease stipulation. The stipulation no longer 

applies anywhere within the leasehold. 

• A modification is a change to the provisions of a lease stipulation, either temporarily or for 

the term of the lease. Depending on the specific modification, the stipulation may or may not 

apply to all sites within the leasehold to which the restrictive criteria are applied.

Requests from the operator should contain, at a minimum, a plan with the following information:

• Related on-site or off-site mitigation efforts, to adequately protect affected resources

• Data collection and monitoring efforts
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-3

• Time frames for beginning and completing the proposed project

The BLM Authorized Officer will require the operator to submit a written request for an 

exception, waiver, or modification and information demonstrating one of the following:

• The factors leading to the inclusion of the stipulation in the lease have changed sufficiently 

to make the protection provided by the lease stipulation no longer justified.

• The proposed operation would not cause unacceptable impacts. 

The SFNF must analyze and document how the exception, waiver, or modification conforms

with the Forest Plan. It must identify the plan decision (including goals, objectives, or desired 

outcomes) supported by the proposed exception, waiver, or modification. If existing NEPA

analysis does not support the exception, waiver, or modification, the Forest Service must conduct 

the appropriate environmental review and NEPA analysis. If the proposed exception, waiver, or 

modification is not in conformance with the Forest Plan or that document does not disclose the 

conditions under which such proposed change would be allowed, the Forest Service must either 

amend the plan or deny the request for exception, waiver, or modification.

During the review process, the BLM Authorized Officer will coordinate with other state or 

federal agencies, as appropriate, and will document the outcome. For example, it may be 

appropriate to coordinate the review of wildlife exceptions, waivers, and modifications with 

NMDGF staff; review and recommendations will be documented, along with any necessary 

mitigation, and provided to the BLM Authorized Officer for approval or disapproval. The 

applicant will then be provided with a written notification of the decision.

Public notification (30-day public review), if required, should both identify the modified lease 

terms and describe the affected lands on a map. When public notification is required, the 

following procedures may apply:

• Approval of an exception, waiver, or modification at the same time the grounddisturbing activity is approved—A notice describing the modified lease terms, when 

required, may be posted for 30 days in the SFNF offices, on the SFNF website, or in a local 

paper as a legal notice or incorporated into a newspaper article. Or the notice may be 

included as part of the NEPA document’s public review, if the document is offered for 

review.

• Approval of an exception, waiver, or modification after the ground-disturbing activity 

is approved—Public notice, if required, may take the form of a 30-day posting on the SFNF 

website, a legal notice or article in the newspaper, or a notice and associated public review 

conducted as part of the NEPA analysis process.

2.2.3 No Surface Occupancy Lease Stipulation

NSO stipulations are considered a major constraint, because they do not allow for surface 

development. For example, a lessee of an NSO area must develop any surface infrastructure 

outside the NSO area. The lessee would need to use advanced technology, such as directional 

drilling, to access the geothermal resource under the NSO area. An NSO is appropriate when the 

standard terms and conditions, CSU stipulations, TLs, and BMPs for permit approval are 

determined to be insufficient to achieve the resource protection objectives.
Chapter 2. Alternatives, Including the Proposed Action

2-4 Santa Fe National Forest Geothermal Leasing EIS

2.2.4 Timing Limitations and Controlled Surface Use Lease 

Stipulations

Where standard lease terms and permit-level decisions are deemed insufficient to protect 

sensitive resources but where an NSO is deemed overly restrictive, the Forest Service would 

apply seasonal or TL or CSU stipulations to leases.

In general, TLs are used to protect resources that are sensitive to disturbance during certain 

periods. Such stipulations are generally applicable to specific areas, seasons, and resources. They 

are commonly applied to wildlife activities and habitat, such as winter range for deer and elk, 

nesting habitat for raptors and migratory birds, and wildlife breeding areas. The SFNF 

Authorized Officer would apply TLs as appropriate for the specific lease areas. 

A CSU allows the Forest Service to require that any future activity or development be modified 

or relocated from the proposed location if necessary to protect resources. The project applicant 

would be required to submit a plan to meet the resource management objectives through special 

design, construction, operation, mitigation, or reclamation measures or relocation. Unless the 

plan is approved, surface occupancy would not be allowed in the CSU stipulation area.

2.2.5 Best Management Practices

In addition to lease stipulations, during any subsequent exploration, drilling, utilization, or 

reclamation and abandonment of geothermal resources, the SFNF may require project-specific 

mitigation measures to permits. A list of BMPs, provided in Appendix C, was developed based 

on the following:

• Programmatic EIS for Geothermal Leasing in the Western United States (BLM and Forest 

Service 2008)

• Forest Service National Best Management Practices for Water Quality Management on 

National Forest System Lands 

• Forest Service Handbook (Southwestern Region) FSH 2509.22 – Soil and Water 

Conservation Handbook

• Santa Fe National Forest Plan, as amended (Forest Service 1987)

The BMPs detailed in Appendix C would be incorporated as appropriate into the permit 

application or would be included in the approved use authorization by the BLM as COAs. When 

implementing the BMPs, the BLM and Forest Service would work with an affected lessee early 

in the process to explain how BMPs may fit into its development proposals and how BMPs can 

be implemented with the least economic impact on the lessee. 

The BLM and Forest Service would discuss potential resource impacts with the lessee and would 

seek the operator’s recommended solutions. The BLM and Forest Service would also encourage 

the lessee to incorporate necessary and effective BMPs into its project proposals, as determined 

to be appropriate during site-specific, project-level environmental analysis. BMPs not 

incorporated into the lessee’s permit applications may be considered and evaluated through the 

environmental review process and incorporated into the use authorization as COAs or right-ofway (ROW) stipulations.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-5

2.2.6 Monitoring

The lessee and the appropriate federal agency would monitor such measures as lease stipulations 

and COAs, as well as the general operation of geothermal developments. This would be done to 

ensure the continued effectiveness of the stipulations and COAs through all phases of 

development, as described in the 2008 Geothermal PEIS (BLM and Forest Service 2008). Using 

adaptive management strategies, where mitigation measures are determined to be ineffective at 

meeting the desired resource conditions, the BLM and SFNF would determine the cause and 

would require the operator to take corrective action. The two agencies would also use this 

information to inform future geothermal leasing and development.

2.2.7 Procedures Prior to Leasing

Pre-lease procedures would follow guidance identified in the 2008 Geothermal PEIS (BLM and 

Forest Service 2008). The stipulations listed above would also be used to help achieve resource 

protection, in accordance with laws and regulations. 

The SFNF would provide a consent determination (including terms and conditions or 

stipulations) to the BLM prior to any parcels on NFS lands being offered for lease sale. 

2.3 Alternatives Considered in Detail

After the public scoping period closed, on June 26, 2015, the SFNF began developing 

alternatives. The Forest Service developed four alternatives, including the No Action Alternative. 

This was based on public input, the interdisciplinary team’s analysis of the current management 

situation and resource data, and the defined purpose and need for the project. Much of the 

geographic information system (GIS) data used in developing the alternatives is based on remote 

sensing, and has not been field verified. 

A summary of lands closed and available to leasing for the action alternatives is provided in 

Table 2-1. For figures showing the locations of closures and stipulations, see Appendix B, 

Stipulations and Closures by Alternative.

Table 2-1. Summary of Acres Open and Closed to Geothermal Leasing, by Alternative1, 2, 3

Allocation Alternative

Alternative 2

Acres/percent of 

decision area

Alternative 3

Acres/percent of 

decision area

Alternative 4

Acres/percent of 

decision area

Closed to geothermal 

leasing

32,000

19

168,600

100

28,900

17

Open to geothermal 

leasing, subject to NSO

stipulations

132,900

79

0

0

122,500

73

Open to geothermal 

leasing, subject to CSU

stipulations

80,300

48

0

0

122,600

73

Open to geothermal 

leasing, subject to TLs

39,500

23

0

0

42,200

25
Chapter 2. Alternatives, Including the Proposed Action

2-6 Santa Fe National Forest Geothermal Leasing EIS

Table 2-1. Summary of Acres Open and Closed to Geothermal Leasing, by Alternative1, 2, 3

Allocation Alternative

Alternative 2

Acres/percent of 

decision area

Alternative 3

Acres/percent of 

decision area

Alternative 4

Acres/percent of 

decision area

Open to geothermal 

leasing, subject to 

standard lease terms 

and conditions

1,400

1

0

0

3,800

2

Available for surface 

occupancy4 3,700

2

(largest parcel = 300 

acres)

0

0

17,200

10

(largest parcel = 1,900 

acres)

Source: Forest Service GIS 2015 1 NSO, CSU, and TLs do not overlap areas closed to leasing 2 NSO, CSU, and TLs overlap each other, as exceptions, modifications, or waivers may be applied to some 

stipulations, and the lesser stipulation would still be applied

3 Acres identified as closed or open to geothermal leasing, subject to stipulations, are not provided for in Alternative 1, 

as the SFNF would not make an availability determination for geothermal leasing under this alternative.

4 Lands that are neither closed to leasing nor subject to NSO stipulations are considered available for surface 

occupancy 

2.3.1 Alternative 1—No Action

2.3.1.1 No Action 

NEPA regulations require an agency conducting an EIS to “include the alternative of no action” 

(40 CFR, Subpart 1502.14). Under the no action alternative, the present course of management,

based on the current forest plan, would continue.

Under the no action alternative, the SFNF would not make an availability determination for 

geothermal leasing on lands in the project area. Geothermal lease applications and nominations 

would continue to be processed; however, they would be evaluated on a case-by-case basis under 

separate NEPA analyses, in accordance with the Forest Plan and existing laws and regulations. 

The JNRA (approximately 28,900 acres) would remain closed to geothermal leasing. This 

alternative does not meet the purpose and need. 

2.3.2 Alternative 2—The Proposed Action

Under the proposed action, land in the project area administered by the Forest Service would be 

identified as being closed to geothermal leasing, under either nondiscretionary or discretionary 

authorities, or would be identified as open to geothermal leasing, with possible moderate 

constraints (TLs and CSU stipulations) or major constraints (NSO stipulations). 

2.3.2.1 Lands Closed to Leasing

The Forest Service has determined that certain lands in the project area are excluded from 

geothermal leasing on the basis of existing laws, regulations (see 43 CFR, Subpart 3201.11), and 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-7

executive orders. This would be the case for NFS lands in the JNRA; approximately 28,900 

acres.

1

In addition to making nondiscretionary closures, the Forest Service has the administrative 

authority to issue discretionary closures to protect special resource values. 

The following areas are proposed Forest Service discretionary closures for geothermal leasing:

2

• Natural geothermal features, such as hot springs or other surface expressions of geothermal 

activity, and a 1-mile radius protection zone around them

• Administrative site withdrawals3

♦ Seven Springs (7 acres)

♦ Encino (184 acres)

♦ Encino Point (120 acres)

♦ Cerro Pelado Lookout (160 acres)

Approximately 32,000 acres of Forest Service lands would be closed (by law, regulations, or 

other authority) to geothermal leasing within the project area. 

2.3.2.2 Lands Available for Leasing

Under the proposed action approximately 136,650 acres of the Forest Service lands in the project

area would be available for geothermal leasing. This would be subject to existing laws,

regulations, formal orders, and stipulations attached to the lease form and its terms and 

conditions.

No Surface Occupancy

NSO stipulations would apply to the following:4

• Designated or proposed critical habitat for listed species under the Endangered Species Act

of 1973 (as amended) if it would adversely modify the habitat. For listed or proposed species

without designated habitat, NSO would be implemented to the extent necessary to avoid 

jeopardy.

• Areas with important cultural and archaeological resources, such as

 1 Wilderness areas and the segment of the East Fork of the Jemez River designated as wild under the Wild 

and Scenic Rivers Act were listed in the alternatives presented during the public scoping period. They are 

deleted because there are no wilderness areas within the project area, and the Wild segment of the East 

Fork of the Jemez River is within the JNRA. 2 This list originally included National Historic Trails, but there are no designated National Historic Trails 

in the project area, the Jemez Mountain National Scenic Byway, Jemez Historic Site National Landmark, 

and Monument Canyon Research Natural Area, all of which are in the JNRA. 3 This list originally included La Cueva, Sulphur Flat, and Las Conchas, all of which are in the JNRA. 4 NSO stipulations were originally proposed for the segments of the East Fork of the Jemez River

designated as Scenic or Recreational; however, these segments are within the JNRA, which is closed to 

geothermal leasing. In addition, NSO stipulations were originally proposed for segments of rivers 

determined to be potentially eligible for status under the Wild and Scenic Rivers Act which have not been 

listed, but there are none within this category at present. Natural Geothermal Features were inadvertently 

listed as NSO; however, they are classified as not available for leasing.
Chapter 2. Alternatives, Including the Proposed Action

2-8 Santa Fe National Forest Geothermal Leasing EIS

♦ Traditional cultural properties and Native American sacred sites, as identified through 

consultation

♦ Properties listed on or eligible for listing on the NRHP, including National Landmarks 

and National Register Districts and Sites

♦ Additional lands outside the designated boundaries, to the extent necessary to protect 

values where the setting and integrity are critical to their designation or eligibility

♦ Areas that qualify for cultural resource protection, based on Forest Plan criteria

• Water bodies; perennial and intermittent rivers and streams;

5 wetlands, springs, and playas 

(mapped in the USGS National Hydrography Dataset [NHD]); riparian areas; 100-year 

floodplains surrounding some features are protected by a 500-foot-wide protection zone. 

• Acequias6 are not included in the NHD and will need to be delineated on-site. Acequias with 

water rights recognized by the NMOSE would be protected by a protection zone of 50 feet, 

measured horizontally from the outer edge of the ditch.

• Water sources recognized by the NMOSE are drinking water sources, wells, springs, and a 

one-mile protection zone around them.

• Slopes in excess of 40 percent. 

• Soils with severe erosion potential.

• Developed recreation facilities, special-use permit recreation sites, and areas with significant 

recreational use with which geothermal development is deemed incompatible7

♦ San Antonio Creek Recreation Area

♦ Seven Springs Recreation Area

♦ Paliza Recreation Area

• Forest Service lands with a Scenery Management System integrity level of very high.

• Inventoried roadless areas.

Approximately 132,900 acres of Forest Service lands would be available to leasing under 

Alternative 2, subject to NSO stipulations. 

Controlled Surface Use

CSU stipulations would apply to the following areas and site conditions:

• Protection of slopes between 30 and 40 percent—This stipulation would be applied to 

minimize the potential for soil erosion on these slopes.

8

• Protection of important dispersed recreational areas—This stipulation would be applied to 

minimize the potential for adverse impacts on recreational values, both motorized and 

nonmotorized, and the natural settings associated with the recreation.

• Protection of viewsheds with a Scenery Management System integrity level of high.

 5 Perennial and intermittent rivers and streams were added to this listing for clarity. Ephemeral streams 

were removed, and acequias were moved to their own NSO stipulation. 6 Man-made ditches to bring irrigation water from the highlands to privately owned agricultural lands. A 

new NSO stipulation was created to address acequias. 7 This list originally included Jemez Falls, East Jemez, Horseshoe Springs, Las Conchas, Jemez Canyon, 

Redondo, San Antonio Creek, Battleship Rock, La Cueva, Laughing Water, and Sulphur Flat Summer 

Home Area, all of which are in the JNRA. 8 This CSU stipulation was added, because it had been inadvertently left off the original list.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-9

Under Alternative 2, approximately 80,300 acres of Forest Service lands would be available to 

leasing, subject to CSU stipulations. Of these lands, approximately 78,200 acres are also subject 

to NSO stipulations. 

Timing Limitation Stipulations

TLs would apply to the following areas:

9

• Mexican spotted owl designated protected activity centers (PACs)—Drilling and 

construction would be prohibited between March 1 and August 31.

• Northern goshawk designated post-fledging areas—Drilling and construction would be

prohibited between March 1 and September 30.

• Peregrine falcon eyrie nesting areas—Drilling and construction would be prohibited between 

March 1 and August 15.

• Elk Calving Areas—Drilling and construction would be prohibited between June 1 and July 

31.10

Approximately 39,500 acres would be available to leasing under Alternative 2, subject to TL

stipulations. Of these lands, approximately 23,800 acres are also subject to CSU stipulations, and 

approximately 39,400 acres are also subject to NSO stipulations.

Standard Lease Terms and Conditions

Under Alternative 2, approximately 1,400 acres would be open to leasing, subject to standard 

lease terms and conditions; that is, they would not be subject to closures or NSO, CSU, or TL

stipulations, as described above. 

Notice to Lessee

The notice to lessee of no vegetation clearing between May 15 and July 31 would be applied in 

migratory bird nesting areas.

2.3.3 Alternative 3—No Leasing

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. This 

alternative was developed in response to comments received from the public and tribes during 

scoping. Alternative 3 is contrary to program direction and mandate to make mineral and energy 

resources available, but it is supportable due to resource concerns and level of protection needed.

This alternative may prevent geothermal development on private land in and adjoining the 

project area due to federal resource drainage issues.

2.3.3.1 Lands Closed to Leasing

Under Alternative 3, 194,900 acres would be closed to leasing, including nondiscretionary closed 

lands in the JNRA.

 9 This list originally included deer and elk winter range, but that was removed because none is identified in 

the project area. Migratory bird nesting areas were removed from the TLs and will be included as a notice 

to lessee.

10 No deer fawning areas were identified, so that designation was removed.
Chapter 2. Alternatives, Including the Proposed Action

2-10 Santa Fe National Forest Geothermal Leasing EIS

2.3.3.2 Lands Available for Leasing

There would be no lands available for leasing in the project area under Alternative 3.

2.3.4 Alternative 4—Development Alternative

Developed to complete the range of alternatives, Alternative 4 incorporates the BLM’s 

information on the RFDS of geothermal resources; therefore, it focuses on the Leasing Interest 

Unit (i.e., Pending Lease Unit) and the Northern Unit. 

2.3.4.1 Lands Closed to Leasing

The Forest Service has determined that certain lands in the project area are excluded from 

geothermal leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and 

executive orders. These non-discretionary closures include approximately 28,900 acres in the 

JNRA. There would be no discretionary closures under Alternative 4. In total, 28,900 acres 

would be closed to geothermal leasing.

2.3.4.2 Lands Available for Leasing

Under the proposed action, approximately 139,800 acres of Forest Service lands in the project

area would be available for geothermal leasing. This would be subject to existing laws,

regulations, formal orders, and stipulations attached to the lease form and to the terms and 

conditions of the standard lease form.

No Surface Occupancy

NSO stipulations would apply to the following:

• Natural geothermal features, such as hot springs or other surface expressions of geothermal 

activity, and a one-mile protection zone around them.

• Designated or proposed critical habitat for listed species under the Endangered Species Act

(ESA) of 1973 (as amended) if it would adversely modify the habitat. For listed or proposed 

species without designated habitat, NSO would be implemented to the extent necessary to 

avoid jeopardy.

• Areas with important cultural and archaeological resources, such as

♦ Traditional cultural properties and Native American sacred sites, as identified through 

consultation

♦ Properties listed on or eligible for listing on the NRHP, including National Landmarks 

and National Register Districts and Sites

♦ Additional lands outside the designated boundaries, to the extent necessary to protect 

values where the setting and integrity are critical to their designation or eligibility

♦ Areas that qualify for cultural resource protection, based on Forest Plan criteria

• Water bodies; perennial rivers and streams; riparian areas, wetlands, and playas; 100-year 

floodplains; and a 500-foot-wide protection zone around them

• Acequias, which are not included in the NHD and will need to be delineated on-site;

acequias with OSE-recognized water rights would have a protection zone of 50 feet, 

measured horizontally from the outer edge of the ditch

• Drinking water sources that are NMOSE recognized and a one-mile protection zone around 

them
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-11

• Developed recreation facilities, special-use permit recreation sites, areas with significant 

recreation where geothermal development is deemed incompatible, and the following 

administrative sites

♦ San Antonio Creek Recreational Area

♦ Seven Springs Recreation Area

♦ Paliza Recreation Area

♦ Seven Springs Administrative Site

♦ Encino Administrative Site

♦ Encino Point Administrative Site

♦ Cerro Pelado Lookout Administrative Site

• Inventoried roadless areas

• Slopes in excess of 40 percent

Approximately 122,500 acres of Forest Service lands would be available to leasing under 

Alternative 4, subject to NSO stipulations.

Controlled Surface Use

CSU stipulations would apply to the following areas and site conditions:

• Intermittent streams listed in the NHD and ephemeral drainages delineated by site-specific 

mapping

• NMOSE-recognized springs and all NMOSE-permitted wells

• Protection of slopes between 30 and 40 percent; this stipulation would be applied to 

minimize the potential for soil erosion on these slopes

• Soils with severe erosion potential

• Protection of important dispersed recreational areas; this stipulation would be applied to 

minimize the potential for adverse impacts on recreational values, both motorized and 

nonmotorized, and the natural settings associated with the recreation

• Viewsheds with a Scenery Management System integrity level of very high and high

Approximately 122,600 acres of Forest Service lands would be available for leasing under 

Alternative 4, subject to CSU stipulations. Of these lands, approximately 78,200 acres are 

subject to NSO stipulations. 

Timing Limitations

TLs would apply as appropriate to the following areas:

• Mexican spotted owl designated PACs—Drilling and construction would be prohibited 

between March 1 and August 31.

• Northern goshawk designated post-fledging areas—Drilling and construction would be

prohibited between March 1 and September 30.

• Peregrine falcon eyrie nesting areas—Drilling and construction would be prohibited between 

March 1 and August 15.

• Elk calving areas—Drilling and construction would be prohibited between June 1 and July 

31.
Chapter 2. Alternatives, Including the Proposed Action

2-12 Santa Fe National Forest Geothermal Leasing EIS

Approximately 42,200 acres of Forest Service lands would be available to leasing under 

Alternative 4, subject to TL stipulations. Of these lands, approximately 36,900 acres are also 

subject to CSU stipulations, and approximately 41,800 acres are also subject to NSO

stipulations.

Standard Lease Terms and Conditions

Under Alternative 4, approximately 3,800 acres would be open to leasing, subject to standard 

lease terms and conditions; that is, they would not be subject to closures or NSO, CSU, or TL

stipulations, as described above. 

Notice to Lessee

The notice to lessee of no vegetation clearing between May 15 and July 31 would be applied in 

migratory bird nesting areas.

2.4 Alternatives Considered but Eliminated from Detailed 

Study

NEPA requires federal agencies to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any that were not developed in 

detail (40 CFR, Subpart 1502.14). Through their comments on the proposed action, the public 

suggested alternative methods for achieving the purpose and need. Some of these alternatives 

may have been outside the scope of identifying lands as being open or closed to leasing, were 

duplicative of the alternatives considered in detail, or were determined to be components that 

would cause unnecessary environmental harm. These suggested alternatives were considered but 

dismissed from detailed consideration for the reasons summarized below.

2.4.1 Reduced Project Area

Under a reduced project area alternative, the SFNF would evaluate future geothermal leasing

only in the 46,000 acres where the BLM has received expressions of interest in leasing. This 

alternative was considered but eliminated from detailed analysis because it fails to address the

potential for future lease nominations on other lands with significant geothermal potential on the 

SFNF. In these areas, geothermal lease applications and nominations would be evaluated on a 

case-by-case basis under separate NEPA analyses. This could yield delays and inefficient 

consideration of future project planning.

2.4.2 Enlarged Project Area

Under an enlarged project area alternative, the SFNF would evaluate future geothermal leasing

on additional lands within the SFNF (beyond the currently defined project area boundary of 

194,000 acres). This would include lands east of the project area boundary. This alternative was 

considered but eliminated from detailed analysis due to limited geothermal potential and existing 

constraints on geothermal development potential.

2.4.3 Alternative with Stipulations and No Exceptions, Waivers, or 

Modifications

Under this alternative, geothermal stipulations would be applied, as described under the 

proposed action alternative; however, no lease exceptions, waivers, or modifications would be 

granted. This alternative was considered but eliminated from detailed analysis because some 

stipulations are based on resources that are not permanent, fixed geographic points, or polygons 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-13

and may change over time. For example, an NSO stipulation would be applied to designated 

critical habitat for species listed under the ESA, and a TL stipulation would be applied to elk

calving areas. Species may become delisted over time, or elk calving areas may change, based on 

forage availability. Non-consent for resources that are dynamic, such as those examples provided 

above, would not allow for adaptive management when circumstances change.

2.4.4 Compensatory Off-Site Mitigation

Under this alternative, the Forest Service would require compensatory off-site mitigation for 

unavoidable impacts that may result from geothermal leasing. This alternative was considered 

but eliminated from detailed analysis because the extent and level of detail regarding adverse or 

unavoidable impacts for specific geothermal land use authorizations is unknown at this time.

2.4.5 Wilderness Protection

Under the wilderness protection alternative, the SFNF would apply the stipulations described 

under the proposed action; however, IRAs and lands meeting wilderness planning criteria (FSH 

1909.12, Land Management Planning Handbook, Chapter 70 – Wilderness Evaluation), would 

be closed to leasing. This alternative was considered but eliminated from detailed analysis 

because evaluating lands with wilderness characteristics is beyond the scope of this project.

2.5 Reasonably Foreseeable Development Scenario

In 2015, the BLM prepared an RFDS for the SFNF geothermal leasing project (BLM 2015) for 

the time frame of 2016 through 2031. The RFDS is a best professional estimate of what may 

occur if lands in the project area were leased. It is based on the assumption that all potentially 

productive areas can be open under standard lease terms and conditions, except those areas 

designated as closed to leasing by law, regulation, or executive order. It is not intended to be a 

maximum development scenario; however, it is biased toward the higher end of expected 

development. The RFDS for geothermal resource use involves three sequential phases: (1) 

exploration, (2) development drilling and utilization, and (3) final plugging and reclamation. 

Activities and acres of surface disturbance associated with each phase are summarized below. 

2.5.1 Exploration

As described in detail within the RFDS, activities associated with exploration are geochemical 

surveys, geologic mapping, geophysical surveys, exploration drilling, and temperature-gradient 

drilling. Table 2-2, below, provides a description of expected disturbance in the project area

from the exploration phase of geothermal development. 

2.5.2 Development Drilling and Utilization

Drilling and utilization involves full-diameter well drilling, power plant construction, power 

plant utilization, and repairs and maintenance. Table 2-3, below, provides a description of the 

expected disturbance in the project area from the development drilling and utilization phase of 

geothermal energy use.
Chapter 2. Alternatives, Including the Proposed Action

2-14 Santa Fe National Forest Geothermal Leasing EIS

Table 2-2. Summary of Surface Disturbance from Exploration Activities

Activity Amount Expected Over 

Life of Plan

Amount of Disturbance 

per Unit (Acres)

Disturbance over Project 

Area for Life of Plan (15 

Years) (Acres)

Temperaturegradient wells11 15 0.25 3.75

Slim wells12, 0.2 

wells per lease

5 2.8 14

Exploration roads 10 miles of road widened 

by 8 feet

N/A 9.7

Total 27.45

Source: BLM 2015

Table 2-3. Summary of Surface Disturbance from Drilling and Utilization

Activity Amount Expected 

over Life of Plan

Amount of 

Disturbance (Acres)

Disturbance over Project 

Area for Life of Plan (15 

Years) (Acres)

Production and/or 

injection wells

30 5 per well 150

Transmission lines A maximum of 14 

miles, at a width of 

200 feet

N/A 339 

Pipelines A maximum of 7 

miles per plant, with 

a width of 25 feet

21.2 per plant 106

Roads 10 miles of road 

widened 2 feet

N/A 2.42

Power plant and 

ancillary facilities

5 power plants 10 per power plant 50

Total 647.42

Source: BLM 2015

2.5.3 Plugging and Final Reclamation

The final stage of geothermal operations is abandonment when exploration is unsuccessful or 

after production ceases. Certain facilities may be abandoned before all operations are ready for 

closure, and interim reclamation, such as revegetating the shoulders and ditches of access roads,

may occur immediately following construction. The RFDS expects that 40 percent of the well 

pad area would be subject to interim reclamation. The physical footprint of the well pads would 

not undergo interim reclamation; however, interim reclamation would occur in the area 

surrounding the well pads.

 11 Temperature-gradient wells enable the investigation of temperatures at shallow depths in and around a 

geothermal system. Initial well diameters are typically 8 to 10 inches (BLM 2015). 12 Slim wells are 3 to 6 inches in diameter and are used to recover core, take water samples, and measure 

thermal and fluid flow properties (BLM 2015).
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-15

2.6 Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where 

different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives. 

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Land use, recreation, and 

special designations 

The JNRA (approximately 

28,900 acres) would remain 

closed to geothermal leasing.

No direct impacts would occur 

in this area. Geothermal lease 

applications and nominations 

would continue to be 

processed; however, they 

would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. 

Impacts would be minimized 

by implementing CSUs, 

NSOs, and TLs. These would 

be designed to protect 

existing land uses, recreation

areas, and special 

designation areas. Compared 

with the Alternative 1, 

Alternative 2 provides specific 

guidance to ensure an SFNFwide approach is adopted and 

that land use, recreation, and 

special designation areas are 

considered across all users of 

the SFNF.

There would be no direct or 

indirect impacts on land use 

on 168,600 acres of the SFNF 

project area.

Of the alternatives that 

include geothermal leasing, 

Alternative 4 would have 

fewer closed acres, fewer 

acres under NSO, more acres 

under CSU, fewer TLs, fewer 

stipulations, and more 

waivers and modifications. 

Because of the greater 

access to SFNF lands and 

fewer restrictions, Alternative 

4 would have a greater impact 

on the broad spectrum of land 

uses, recreation areas, and 

special designation areas on 

the SFNF.

Geologic resources The SFNF would process 

leases on a case-by-case 

basis. Geothermal 

development projected under 

this alternative could slightly 

increase the likelihood of 

seismic activity in and around 

the project area, particularly if 

enhanced geothermal systems

are used. This would require 

further analysis, if proposed as 

part of a geothermal 

development project. 

Impacts would be the same 

as those described under 

Alternative 1. 

There would be no direct or 

indirect impacts on geologic 

resources in the project area.

Impacts would be the same 

as those under Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-16 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Geothermal development may 

also slightly increase the risk 

of subsidence in the project 

area. Impacts on volcanic 

activity or release of 

radioactive material are not 

expected to result from the 

projected geothermal 

development.

Energy and mineral resources Impacts on energy and mineral 

resources would be evaluated 

on a case-by-case basis under 

separate NEPA analyses. 

While additional roads and 

transmission lines could 

encourage additional energy 

and mineral development, 

other limitations associated 

with those resources would still 

prevent their development.

Impacts would be the same 

as those described under 

Alternative 1. 

All Forest Service lands in the 

project area would be closed 

to geothermal leasing. There 

would be no construction of 

transmission lines or 

development of roads 

specifically for geothermal 

energy development. There 

would be no impacts on nongeothermal energy and 

mineral resources. 

Impacts would be the same 

as those described under 

Alternative 1.

Paleontological resources Geothermal lease stipulations 

and closures would not be 

specifically implemented on 

paleontological resources 

outside of the JNRA; 

however, all geothermal lease 

applications and nominations 

would be subject to the 

standards and guidelines 

outlined in the Forest Plan 

and subsequent 

environmental analysis. 

Surface disturbance related to 

geothermal development

could impact an unknown 

quantity of fossils that may 

Impacts would be similar to 

those described under 

Alternative 1. Closures and 

stipulations would not be 

specifically implemented for 

paleontological resources; 

however, closures and 

stipulations for other resources 

would inadvertently protect 

geologic units with likely fossil 

occurrences. The potential for 

geothermal development to 

impact sensitive geologic units 

is low, considering geothermal 

leasing closures, stipulations, 

and BMPs.

There would be no direct or 

indirect impacts on

paleontological resources 

under Alternative 3. 

Impacts under Alternative 4 

on paleontological resources 

would be similar to those 

described under Alternative 2; 

however, fewer acres in areas 

with likely fossil occurrence 

would be subject to NSO

stipulations and closures, and 

more acres would be subject 

to CSU stipulations. The 

potential for geothermal 

development to impact 

sensitive geologic units is low, 

considering geothermal 

leasing closures, stipulations, 

and BMPs.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-17

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

occur on or underneath the 

surface in areas containing 

paleontologically sensitive 

geologic units.

Soil resources Impacts would be assessed 

on a case-by-case basis. 

Geothermal development

could result in physical 

disturbance, compaction, 

changes to erosion patterns, 

and loss of soil productivity. 

Impacts could result from the 

development of roads and 

facilities and geothermal 

projects, including 

construction and operation.

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 1; 

however, they would be 

restricted in location by 

administrative withdrawals

and stipulations.

NSO stipulations would limit 

erosion on soils with severe 

erosion hazards and steep 

slopes, but they would 

exclude potential impacts 

from powerline and road 

construction and road use. 

There would be no direct 

impacts on soils under 

Alternative 3. However, there 

would be indirect impacts on 

soil resources because the 

project area would be closed 

to geothermal leasing for the 

foreseeable future. Over time, 

there would be less soil 

disturbance than expected 

under the current Forest Plan.

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 2; 

however, they would have 

more potential for impacts on 

slopes between 30 and 40 

percent and in areas with 

moderately high to high runoff 

potential, due to a reduction in 

stipulations.

Water resources Impacts would be assessed 

on a case-by-case basis. 

Geothermal development

could result in contamination, 

altered groundwater flow 

paths or pressurization, and 

changes in water 

temperature. 

Exploration, development, 

and operation could result in 

increased sediment and 

turbidity in surface water and

contamination of surface 

water or groundwater by 

accidental release of 

chemicals or waste. Water 

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 1; 

however, they would be 

restricted in location by 

administrative withdrawals

and stipulations.

NSO stipulations would 

reduce the potential for direct 

impacts on many hydrologic 

features. They would also 

limit erosion on soils with 

severe erosion hazard and 

steep slopes. This would 

reduce the potential for

There would be no impacts on 

watersheds or groundwater

resources under Alternative 3.

However, there would be 

indirect impacts on water 

resources. Because the 

project area would be closed 

to geothermal leasing for the 

foreseeable future, over time, 

there would be less surface 

disturbance than expected 

under the current Forest Plan, 

and less potential for changes 

to surface or subsurface 

water resources.

Impacts under Alternative 4

would be similar to those 

described under Alternative 2. 

However, there would be no 

discretionary closures under 

Alternative 4, and there would 

be reduced protection of 

specific areas from 

implementing less restrictive 

lease stipulations. Water and 

geothermal fluids may be lost 

when reinjected into the 

formation or through 

accidental spills or releases.
Chapter 2. Alternatives, Including the Proposed Action

2-18 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

and geothermal fluids may be 

lost when reinjected into the 

formation or through 

accidental spills or releases.

sedimentation into streams 

but would exclude potential 

impacts from road and 

powerline construction, and 

road use. Water and 

geothermal fluids may be lost 

when reinjected into the 

formation or through 

accidental spills or releases.

Air quality and air qualityrelated valuesThere would be temporary 

and short-term impacts on air 

quality during exploration, 

development, and utilization 

from fugitive dust and 

equipment and vehicle 

exhaust. Impacts would be 

minimized through BMPs

applied at the permit level. 

Impacts from hydrogen sulfide 

release, if present in the 

geothermal resource, would 

be avoided with blowout 

prevention equipment and 

through monitoring and 

abatement, if required by New 

Mexico Environment 

Department (NMED) during 

air permitting.

Long-term emissions from 

operating the binary-cycle 

plants would be low because 

they are closed-loop systems 

that are designed to not emit 

pollutants. Because the plants 

would be air cooled, they 

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of emissions would be 

the same.

The constraints in areas open 

to leasing may alter the 

locations where geothermal 

development would occur. 

More areas would be 

constrained than under 

Alternative 1, so activities 

under Alternative 2 could 

occur within a smaller area. 

Because geothermal plants 

would be spaced by 1 mile or 

more, the overall direct and 

indirect impacts would be the 

same as under Alternative 1.

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on air quality or air 

quality related values 

(AQRVs) would occur.

Direct and indirect impacts on 

air quality and AQRVs would 

be the same as described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-19

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

would not emit steam plumes 

and, therefore, would not 

affect visibility in Class I 

areas. The plants would not 

emit hydrogen sulfide, if 

present in the resource, 

during normal operations; 

therefore, operations would 

not emit nuisance odors.

All activities must comply with 

the Clean Air Act and 

applicable state air quality

regulations.

Vegetation The JNRA would remain 

closed to geothermal leasing. 

No direct impacts on

vegetation would occur in this 

area. Elsewhere, geothermal 

lease applications and 

nominations would continue 

to be processed; however, 

they would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. Direct impacts 

(vegetation removal and 

vegetation communities

alteration) and indirect 

impacts (introduction or 

spread of invasive species) 

may occur. Up to 765 acres 

may be disturbed in 

vegetation communities by 

developing well pads, 

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. Compared to 

Alternative 1, an additional 

3,100 acres would be closed 

to geothermal leasing. 

Impacts would be minimized 

by implementing CSUs,

NSOs, and TLs. These would 

be designed to protect 

vulnerable and important 

vegetation communities. Up 

to 765 acres may be 

disturbed in vegetation 

communities by developing 

well pads, roadways, 

transmission corridors, and 

other geothermal facilities.

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on vegetation would 

occur.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. Impacts would be 

similar to Alternative 2, except 

that fewer acres would be 

closed to geothermal leasing

and fewer acres would be 

subject to NSO stipulations. 

Intermittent streams and

slopes with severe erosion 

potential would be subject to 

CSU stipulations. Impacts on

riparian vegetation 

communities may be more 

severe than under Alternative 

2, because there would be 

less restrictive geothermal 

leasing stipulations in these 

areas, compared with 

Alternative 2.
Chapter 2. Alternatives, Including the Proposed Action

2-20 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

roadways, transmission 

corridors, and other 

geothermal facilities. 

Fish and wildlife The JNRA would remain 

closed to geothermal leasing, 

and no direct impacts on fish 

and wildlife would occur in 

this area. Elsewhere,

geothermal lease applications 

and nominations would 

continue to be processed; 

however, they would be 

evaluated on a case-by-case 

basis under separate NEPA

analyses, in accordance with 

the Forest Plan and existing 

laws and regulations. 

Geothermal leasing 

stipulations and closures 

specific to fish and wildlife 

would not be implemented 

under this alternative; 

however, any geothermal 

lease applications and

nominations would be subject 

to standards and guidelines 

outlined in the forest plan and 

environmental analysis.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. 

Impacts on fisheries and 

aquatic biota could occur from 

erosion and sedimentation 

into rivers and streams; 

however, geothermal leasing

stipulations on steep slopes 

and erosive soils would 

mitigate these effects, and 

impacts are unlikely to result 

in a substantial population 

change.

Impacts on wildlife could 

occur though habitat 

alteration, removal, reduction, 

or fragmentation. 

Implementing TLs would limit 

impacts on seasonally 

important wildlife habitat. 

Impacts would not lead to a 

substantial population change 

for any wildlife species.

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on fish and wildlife

would occur.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts from the overall 

levels of disturbance would be 

the same.

Direct and indirect impacts on 

fish and wildlife would be 

similar to those described 

under Alternative 2; however, 

there would be a greater 

likelihood of increased 

sedimentation flowing into 

perennial streams, which 

reduce the quality of habitat 

for sediment intolerant aquatic 

species.

Threatened and endangered 

species and special status 

species

The JNRA would remain 

closed to geothermal leasing, 

and no direct impacts on

threatened or endangered 

species or special status 

The RFDS would be the same 

as described under Alternative 

1; therefore, impacts from the 

overall levels of disturbance 

would be the same. 

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on threatened and 

endangered species and 

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-21

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

species would occur in this 

area. Elsewhere, geothermal 

lease applications and 

nominations would continue 

to be processed; however, 

they would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. The types of 

effects could include habitat 

disturbance or alteration, 

noise disturbance, injury or 

mortality, exposure to 

contaminants, and 

interference with behavioral 

activities. All actions must 

comply with the ESA.

Alternative 2 would not result 

in adverse impacts on

threatened or endangered 

species, and would not lead 

to a trend toward federal 

listing of non-federally listed 

special status species. All 

actions must comply with the 

ESA.

special status species would 

occur.

the same. Impacts would be 

similar to Alternative 2; 

however, the potential 

disturbance on intermittent 

streams could lead to 

increased sedimentation 

flowing into perennial streams 

and could have an impact on 

species that are sediment 

intolerant, such as Rio 

Grande sucker, Rio Grande 

chub, RGCT, and other cold 

water fish species. All actions 

must comply with the ESA.

Livestock grazing The JNRA would remain 

closed to geothermal leasing.

Within those 28,900 acres,

there would be no disturbance 

to livestock or livestock 

management. Impacts 

identified in the 2008 

geothermal PEIS could occur 

on allotments outside of the 

JNRA on a case-by-case 

basis.

In addition to portions of 

allotments closed to 

geothermal development that 

fall within the JNRA, 

Alternative 2 closes other 

areas based on special 

circumstances, and impacts 

would be less than under 

Alternative 1. Indirect impacts 

on grazing allotments outside 

of the JNRA and other closure 

areas would be a reduction in 

forage, a possible reduction in 

animal unit months (AUMs), 

and harassment of livestock.

There would be no direct or 

indirect impacts on livestock 

or livestock operations from 

geothermal leasing.

Indirect impacts would be the 

same as those described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-22 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Cultural resources Because there would be sitespecific analysis, potential 

impacts on cultural resources 

and their settings could be 

avoided or reduced, but there 

would be no additional 

established stipulations for 

surface use that may 

incidentally reduce impact 

potential on cultural 

resources. Current closures to 

leasing in the JNRA would 

continue.

The potential for impacts on 

cultural resources would be 

reduced by additional 

closures and stipulations. 

Stipulations for other surface 

uses may also incidentally 

reduce the impact potential on 

cultural resources. 

NSO stipulations would be 

implemented for areas with 

important cultural resources 

and their settings, including 

archaeological resources, 

traditional cultural properties, 

sacred sites, and NRHPeligible and listed properties. 

There are 1,567 known sites 

that would be included in land 

with NSO stipulations under

this alternative. 

Implementing discretionary 

closures to geothermal 

leasing on all lands in the

project area not already 

closed to leasing would result 

in no leasing and no 

subsequent development.

There would be no impacts on 

cultural resources and their 

settings.

The potential for impacts on 

cultural resources would be 

reduced by stipulations, but 

there would be no new 

closures. Stipulations for 

other surface uses may also 

incidentally reduce the impact 

potential on cultural 

resources. 

NSO stipulations would be 

implemented for areas with 

important cultural resources 

and their settings, including 

archaeological resources, 

traditional cultural properties, 

sacred sites, and NRHPeligible and listed properties. 

There are 1,522 known sites 

that would be included in land 

with NSO stipulations under 

this alternative. 

Tribal interests and traditional 

cultural resources

Potential direct and indirect 

impacts from subsequent 

geothermal development

could disturb landscapes and 

locations associated with 

religious beliefs or cultural 

uses. 

Because there would be sitespecific analysis and 

consultation, potential impacts 

could be avoided or reduced, 

but there would be no 

additional established 

stipulations for surface use 

There would be new closures 

and NSO stipulations for 

traditional cultural properties 

and Native American sacred 

sites, as identified through 

consultation and site-specific 

consideration of impacts on 

tribal interests and traditional 

cultural resources and uses 

and their settings for each 

phase of geothermal 

development.

The potential for impact from 

subsequent geothermal 

The SFNF would amend the 

forest plan to implement 

discretionary closures to 

geothermal leasing on all 

lands in the project area not 

already closed to leasing. 

Because there would be no 

leasing and no subsequent 

development, no new impacts 

are anticipated.

There would be NSO

stipulations for traditional 

cultural properties and Native 

American sacred sites, as 

identified through consultation

and site-specific consideration 

of impacts and consultation 

for each phase of geothermal 

development. 

The potential for impact from 

subsequent geothermal 

development would be 

reduced; however, tribes may 

consider the disturbance of 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-23

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

that may incidentally reduce 

impact potential on tribal 

interests and traditional 

cultural resources and uses.

Tribes may consider the 

disturbance of the land or use 

of geothermal resources as 

an adverse impact that could 

not be avoided or minimized. 

development would be 

reduced; however, tribes may 

consider the disturbance of 

the land or use of geothermal 

resources as an adverse 

impact that could not be 

avoided or minimized. 

Additional habitat and visual 

protections may incidentally 

reduce the impact potential on 

traditional cultural resources

and resource uses, cultural 

landscapes, and their 

settings.

the land or use of geothermal 

resources as an adverse 

impact that could not be 

avoided or minimized.

Additional habitat and visual 

protections may incidentally 

reduce the impact potential on 

traditional cultural resources

and resource uses, cultural 

landscapes, and their 

settings.

Visual resources The JNRA would remain 

closed to geothermal leasing. 

Visual resources would be 

protected in this area.

Elsewhere, visual resources 

could be impacted because of 

the lack of stipulations. The 

visual variety of the landscape 

in areas with very high or high 

scenic integrity would make 

hiding geothermal 

development activities easier 

than in areas with moderate, 

low, or very low scenic 

integrity. However, areas with 

existing development may be 

able to absorb new 

development without much 

change in the overall 

landscape.

The JNRA would remain 

closed to geothermal leasing,

and an additional 10,400 

acres would also be closed; 

impacts would be the same 

as under Alternative 1 but 

over a larger area. In areas 

restricted by NSO

stipulations, visual resources

would be preserved in the 

same way that areas closed 

to leasing would be protected. 

Areas restricted by CSU

stipulations would see 

reduced impacts on visual 

resources. These landscapes 

generally have diverse 

topography, colors, and 

vegetation, which can be 

used to screen development 

from casual observers. 

Finally, areas not subject to 

NSO or CSU stipulations 

There would be no leasing, so 

no impacts on visual 

resources from geothermal 

exploration or development.

Impacts would be similar to 

Alternative 2, except that 

fewer acres would be closed 

to geothermal leasing and 

fewer acres would be subject 

to NSO stipulations. 

Therefore, more acres would 

be subject to possible impacts 

on visual resources. CSU

stipulations on most of the 

area not closed to leasing 

would offer some protection, 

but any development could

impact visual resources. More 

acres would be open to 

leasing not subject to NSO or 

CSU stipulations than under 

Alternative 2. Impacts would 

be the same but would occur 

over a larger area. 
Chapter 2. Alternatives, Including the Proposed Action

2-24 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

have the greatest risk of 

impacts. These areas have 

either moderate or low scenic 

integrity. 

Social interests, economics, 

and environmental justice

Impacts would occur on a 

case-by-case basis but would 

include temporary and longterm job creation, new federal 

royalty payments and taxable 

incomes, and retained 

recreation and tourism 

revenues in the long term. 

Overall impacts are the same 

as Alternative 1, but economic 

impacts could be less 

regionally dispersed due to 

NSO, CSU, and TL

stipulations.

There would be no lands 

available for leasing in the 

project area and no impacts 

on socioeconomics from 

geothermal development.

Overall impacts are the same 

as Alternative 1, but economic 

impacts could be less 

regionally dispersed due to 

NSO, CSU, and TL

stipulations.

Health and safety Impacts would continue to 

occur on a case-by-case 

basis, and measures to 

minimize impacts on health 

and safety would be 

considered in separate NEPA

analyses. There would be a 

risk of human-caused fire from 

geothermal development.

However, because power line 

rights-of-way would be cleared 

of trees, the risk of wildfire 

associated with trees causing 

downed power lines would be 

minor.

The nature and character of 

impacts would be similar to 

those described for Common 

Impacts Associated with 

Geothermal Development. 

BMPs included in approved 

use authorizations would 

protect public health and 

safety by minimizing risks to 

workers and the public. The 

risk of wildfire associated with 

downed power lines would be 

the same as under Alternative 

1.

There would be no lands 

available for leasing in the 

project area and no impacts 

on health and safety from 

geothermal activities.

Impacts would be the same 

as those described under 

Alternative 2, because the 

same level of disturbance, the 

same number of wells, and 

the same number of power 

plants are expected.

Noise Impacts would continue to 

occur on a case-by-case 

basis, and measures to 

minimize noise impacts would 

be considered in separate 

NEPA analyses.

Due to the highly rural and 

unpopulated nature of lands in 

the project area, it is unlikely 

that any sensitive receptors 

would experience noise levels 

approaching the 65 Aweighted decibels (dBA) limit 

specified in BLM regulations.

There would be no lands 

available for leasing in the 

project area and no noise 

impacts from geothermal 

activities.

Impacts would be the same 

as those described under 

Alternative 2, because the 

same level of disturbance, the 

same number of wells, and 

the same number of power 

plants are expected.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-25

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Transportation and access Geothermal lease applications 

and nominations would 

continue to be processed; 

however, they would be 

evaluated on a case-by-case 

basis under separate NEPA

analyses, in accordance with 

the Forest Plan and existing 

laws and regulations.

Alternative 2 would result in 

greater limitations for siting 

geothermal infrastructure. This 

could result in more 

concentrated areas of 

development, resulting in 

fewer impacts on 

transportation and access 

within an NSO boundary, but a 

potentially higher 

concentration of visual and 

noise impacts for travelers in 

areas outside of an NSO 

boundary. It may also 

concentrate traffic issues, 

although any future action 

would have to comply with the 

Forest Plan and the Travel 

Management Plan and be 

studied under a site-specific 

NEPA analysis.

There would be no direct or 

indirect impacts on the 

transportation network or 

access over the 168,600 

acres of the SFNF project 

area.

Of the alternatives that 

include geothermal leasing, 

Alternative 4 would have 

fewer closed acres, fewer 

acres under NSO, more acres 

under CSU, fewer TLs, fewer 

stipulations, and more 

waivers and modifications. 

Because of the greater 

access to SFNF lands and 

fewer overall restrictions, 

Alternative 4 may have a 

greater impact on 

transportation and access on 

the SFNF.

Climate change There would be no direct 

impacts. Indirect impacts are 

from GHG emissions during 

all project phases from the 

following: fuels combustion by 

equipment and vehicles, the

release of carbon dioxide in 

the geothermal resource, and 

the removal of vegetation and 

disturbance of soils on 760 

total acres. BMPs that reduce 

equipment and vehicle 

exhaust emissions to 

minimize impacts on air 

quality would also reduce 

Impacts would be the same 

as those described for 

Alternative 1.

There would be no 

geothermal development and 

no emissions of GHGs. If 

there is no geothermal power 

plant development, there 

could be an indirect negative 

impact on climate change if 

power from conventional 

fossil fuel sources of 

electricity were developed in 

place of geothermal 

development.

Impacts would be the same 

as those described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-26 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

GHG emissions.

GHGs emissions from plant 

operation are from commute 

traffic, maintenance traffic, 

truck deliveries, and potential 

releases of carbon dioxide 

during well maintenance. 

GHG emissions would be 

below the 25,000 metric tons 

per year reporting limit under 

the Greenhouse Gas 

Monitoring Rule. Geothermal 

power plant development 

could have an indirect 

beneficial impact if power 

produced by the geothermal 

plant were to displace 

electricity generated by 

conventional fossil fuel 

sources of electricity.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-1

Chapter 3. Affected Environment and 

Environmental Consequences

3.1 Introduction

This chapter describes the affected environment and environmental consequences for resources 

and resource uses. The affected environment discussion includes a description of the biological, 

physical, and socioeconomic characteristics, including human uses, that could be affected by any 

future actions. Information from broad-scale assessments was used to help set the context for the 

project area. The information and direction for NFS lands has been further broken down into 

fine-scale assessments and information, where possible.

The environmental consequences discussion analyzes direct, indirect, and cumulative impacts 

expected to occur by implementing any future actions (including any decisions to lease or 

develop geothermal resources) that may be taken, consistent with the four alternatives: 

Alternative 1, the No Action Alternative; Alternative 2, the Proposed Action; Alternative 3, No 

Leasing; and Alternative 4, the Development Alternative. The scope of the analysis is 

commensurate with the detail of the alternatives and the availability of data. Current conditions 

of the project area, as described under the affected environment sections, provide the baseline for 

assessing impacts. 

3.2 Methods and Assumptions Common to the Analysis of 

Impacts

Consenting to issue a geothermal lease has no direct impact on the environment; however, it is a 

commitment of the resource for potential future exploration, drilling operations and development, 

utilization, and reclamation and abandonment, which are subject to environmental review and 

permits. Therefore, this EIS analyzes the potential impacts of the various stages that may follow a 

leasing decision, along with the potential cumulative impacts throughout the entire project area.

The method for the following impact assessment conforms to the guidance found in the 

following sections of the CEQ regulations for implementing NEPA: 

 40 CFR, Subpart 1502.24 (Methodology and Scientific Accuracy)

 40 CFR, Subpart 1508.7 (Cumulative Impact)

 40 CFR, Subpart 1508.8 (Impacts)

CEQ regulations require that agencies “rigorously explore and objectively evaluate” the impact 

of all alternatives.

The alternatives described in Chapter 2 do not specifically propose developing a geothermal 

resource. For this reason, the analysis relies on the RFDS, which projects future geothermal 

leasing and development on NFS lands in the SFNF geothermal leasing project area from 2016 

through 2031 (15 years) based on best professional judgment. The RFDS is based on the 

assumption that all potentially productive areas can be open under standard lease terms and 

conditions, except those designated as closed to leasing by law, regulation, or executive order. 

Therefore, it does not consider any allocations (e.g., NSO, CSU, or TL stipulations) prescribed 

under any of the alternatives when projecting future geothermal leasing and development. The 
Chapter 3. Affected Environment and Environmental Consequences

3-2 Santa Fe National Forest Geothermal Leasing EIS

RFDS is not intended to be a “maximum-development” scenario; however, it is biased toward 

the higher end of expected development. 

It is important to note that the magnitude and extent of impacts on any resource or resource use 

will vary, depending on the amount of land apportioned for each lease. A lease can range in size 

from 640 acres up to 5,120 acres.

A consent to lease lands, in and of itself, does not cause any direct impacts, as defined by the 

CEQ regulations, which state that such impacts “are caused by the action and occur at the same 

time and place” (40 CFR, Subpart 1508.8[a]). Before any ground disturbance or other future 

actions that would occur consistent with implementing the plan, further decision-making would 

be required. This decision-making must take place before any future actions. It would take into 

consideration a wide variety of factors, including policy initiatives about timing of actions, 

whether any applications are submitted, whether funding is available, and compliance with other 

authorities and policies.

The regulations governing geothermal leasing and development provide for several decision 

stages before any ground-disturbing activities take place and may include further compliance 

with applicable authorities during these decision stages. Prior to ground disturbance, additional 

site-specific analysis would be required as described in Chapter 1. Under this regulatory scheme, 

the BLM receives and approves an application for a permit to drill or other authorization with 

specific information about a particular project. Until then, the impacts of actual development that 

might follow lease issuance are speculative. This is because so much is unknown as to location, 

scope, scale, and timing of that development. At each decision stage, the BLM retains the 

authority to approve, deny, or approve subject to conditions any permit, based on compliance 

with applicable authorities and policies. Therefore, the analysis of the impacts of development in 

this EIS reflects a more general, programmatic approach.

Any future development of geothermal resources would result in impacts. It is reasonable, 

therefore, to foresee what on-the-ground impacts would occur if the Forest Service were to 

consent to leasing and the BLM were to issue geothermal leases. However, those impacts would 

not occur until some point in the future and following several decision stages. Because of this, 

the following analysis focuses primarily on both direct and indirect impacts of future 

development of geothermal resources. It is based on the foreseeable on-the ground actions, 

taking into consideration the stipulations, BMPs, and procedures outlined in the 2008 

Geothermal PEIS. These impacts cannot be analyzed site specifically, but they can be analyzed 

in general terms for the leasing area, based on the RFDS outlined in Chapter 2. 

The following assumptions from the RFDS were applied for the analysis in Chapter 3:

 A total of 25 leases would be issued during the 15-year RFDS time frame.

 Five 25-megawatt binary power plants would be developed on leases in the project area, 

with separations of a mile or more between plants.

 The total acres of surface disturbance associated with geothermal exploration is anticipated 

to be 27.

 The total acres of surface disturbance associated with development drilling and utilization is 

647. This includes disturbance associated with developing wells, transmission lines, 

pipelines, roads, power plants, and ancillary facilities.

 Based on existing temperature gradient data, binary cycle power plants are most likely to be 

constructed in the project area. These plants operate at lower temperatures than flash steam 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-3

plants or dry steam plants. Therefore, this analysis does not analyze the potential impacts of 

flash steam or dry steam geothermal power plants. 

3.3 Cumulative Actions for Cumulative Impacts Analysis

The CEQ regulations state that the cumulative impact analysis should include the anticipated 

impacts on the environment resulting from “the incremental impact of [an] action when added to 

other past, present, and reasonably foreseeable future actions, regardless of what agency (federal 

or non-federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions taking place over time” (40 CFR, Subpart

1508.7).

Sections 3.3.1 through 3.3.4 describe the processes for assessing cumulative impacts, the time 

frame of the cumulative projects, and reasonably foreseeable future actions for the cumulative 

impact assessment. Each resource or resource use section includes a cumulative impact 

assessment.

3.3.1 Process for Assessing Cumulative Impacts

The cumulative impact analysis for each resource or resource use builds on the analyses of the 

direct and indirect impacts of anticipated future actions to be taken, consistent with the project 

alternatives. In addition, the cumulative impact analysis considers other past, present, and 

reasonably foreseeable future actions and their impacts on natural resources, ecosystems, and 

human uses in the project area.

3.3.2 Regions of Influence

To determine which other actions should be included in a cumulative impacts analysis, the 

region of influence for each resource must first be defined. These regions should not be limited 

to only the geographic areas of resources addressed by the project, but they should also take into 

account the distances that cumulative impacts may travel and the regional characteristics of the 

affected resources.

Because this EIS addresses the consent to lease NFS lands at a programmatic level, the region of 

influence for each resource evaluated by the cumulative impacts analysis is the project area, 

unless otherwise noted.

3.3.3 Time Frame of the Cumulative Projects

The time frame of the cumulative impact analysis incorporates the sum of the impacts of 

anticipated future actions consistent with implementing an alternative, in combination with other 

past, present, and future actions. This is because impacts may accumulate or develop over time. 

The future actions described in this analysis are those that are “reasonably foreseeable”; that is, 

they are ongoing (and will continue into the future), are funded for future implementation, or are 

included in firm near-term plans. The reasonably foreseeable time frame for future actions 

evaluated in this cumulative analysis is 20 years from the consent to geothermal leasing. While it 

is difficult to project reasonably foreseeable future actions (or trends) beyond a 20-year time 

frame, the impacts identified in the cumulative impacts analysis will likely continue beyond the 

20-year horizon.
Chapter 3. Affected Environment and Environmental Consequences

3-4 Santa Fe National Forest Geothermal Leasing EIS

3.3.4 Reasonably Foreseeable Future Actions

Reasonably foreseeable future actions are projects, activities, or trends that could impact human 

and environmental receptors in the defined regions of influence (Section 3.3.2) and in the 

defined time frames (Section 3.3.3). 

Table 3-1. Reasonably Foreseeable Future Actions

Project Name General Location Project Description

Vegetation Management

Southwest Jemez 

Mountains Landscape 

Restoration Project

Middle Jemez River

Watershed

Ecological restoration of up to 110,000 acres in 

the greater Southwest Jemez Mountains over 

10 years.

Supplement to the Final 

EIS for Invasive Plant 

Control Project EIS

Carson and Santa Fe 

National Forests 

Updates information contained in the Forest 

Service’s Final Environmental Impact Statement 

for the Invasive Plant Control Project, published 

September 2005.

Cerro Pelon Timber Stand 

and Wildlife Habitat 

Improvement Project

Santa Fe National Forest, 

Espanola Ranger District

Thinning in a stand of pinyon-juniper of 165 

acres to improve the health and fire resilience of 

the stand. This should result in increased pinyon 

nut production for birds and other wildlife. This 

project has been postponed.

Water Resources

Pueblo of Jemez Red 

Rocks Dam Repair

Pueblo of Jemez The project area is on the east side of New 

Mexico State Highway 4 (NM 4), in an unnamed 

ephemeral stream channel and arroyo. This 

arroyo flows west into the Jemez River, which is 

less than 0.4 mile downstream. During the 

federal disaster declared by the president and 

designated as Federal Emergency Management 

Agency (FEMA) Number 4152-DR-NM, a major 

storm and subsequent high water flows eroded 

the containment berm at Red Rocks Dam. This

caused a breach and failure of the stormwater 

detention facility. This facility provides flood 

protection for downstream road and irrigation 

infrastructure at the Pueblo of Jemez. As such, 

the purpose of the proposed project is to repair 

the stormwater detention facility and protect 

downstream infrastructure.

Pueblo of Jemez Owl 

Springs Bridge Sediment 

Removal Project

Pueblo of Jemez The Natural Resources Department of Jemez 

Pueblo is proposing to use a track hoe for 

removing the sedimentation; it will be operated 

from the banks of the Jemez River.

Valle Seco Wetland

Restoration Project

Valles Caldera The proposal is to restore severely eroded 

emergent wetlands in the watershed of Sulphur 

Creek in the Valles Caldera National Preserve 

(VCNP), Jemez Springs. The project will 

construct 54 rock and earthen structures along 

five headwater tributaries (19,580 feet) and 

3,600 feet of the main channel. The project 

proponent will build 25 plug and pond 

structures, sod dams, one-rock dams, a worm 

ditch, and contour swales.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-5

Table 3-1. Reasonably Foreseeable Future Actions

Project Name General Location Project Description

Abiquiu Land Grant 

Waterline Replacement 

Project

Santa Fe National Forest, 

Espanola Ranger District

In 1967, the Merced de Abiquiu (Land Grant) 

installed a water collection gallery and water line 

on NFS lands in order to provide water for 

livestock. This facility is at the end of its life, and 

the proposal is to replace it.

McKinney County Dam Santa Fe National Forest, 

Jemez Ranger District

Remove McKinney Dam and replace it with a 

fish barrier. This project is on hold.

Energy and Mineral Resources

Valles Caldera: 

Nomination under the 

Geothermal Steam Act

Valles Caldera National 

Preserve

The NPS is in the process of listing the Valles 

Caldera as a significant geothermal feature 

under the Geothermal Steam Act of 1970 (30 

USC, Section 1019). If it were determined by the 

BLM, in consultation with the NPS, that 

geothermal operations were reasonably likely to

result in a significant adverse impact on such a 

feature, then the BLM would decline to issue the 

lease. The BLM or Forest Service, in 

consultation with the NPS, would include 

stipulations to protect any significant thermal 

features of a National Park System unit that 

could be adversely affected by geothermal 

development. These stipulations would be 

added, if necessary, if the lease or permit were

issued, extended, renewed, or modified (43 

CFR, Subpart 3201.10[b]).

South Pit Pumice Mine 

Expansion

Santa Fe National Forest, 

Jemez Ranger District

Approval of a 10-year-plan of operations for a 

pumice mine of approximately 48 acres next to 

a recently reclaimed 9-acre pumice mine.

Duran 2010 Pumice Mine South of Cerro del Pino, 

Jemez Ranger District, 

SFNF

Develop an open-pit pumice mine south of 

Cerro del Pino.

Threatened, Endangered, and Special Status Species

New Mexico Meadow 

Jumping Mouse Critical 

Habitat Protection Project 

(EA)

Jemez Ranger District, 

SFNF

Protection and improvement of habitat 

conditions for the New Mexico Meadow Jumping 

Mouse.

Source: Forest Service GIS 2015

3.4 Land Use, Recreation, and Special Designations

3.4.1 Affected Environment

This section focuses on the current management and use in project area for the SFNF. 

Three resource classes are described and analyzed below: land use, recreation, and special 

designations. National Scenic and Historic Trails are covered as a subsection under special 

designations.
Chapter 3. Affected Environment and Environmental Consequences

3-6 Santa Fe National Forest Geothermal Leasing EIS

3.4.1.1 Land Use

The National Forest Management Act of 1976 requires the Secretary of Agriculture to assess 

NFS lands, to develop a management program based on multiple-use and sustained-yield 

principles, and to implement a resource management plan for each unit of the NFS. The primary 

statutes that authorize the disposal of renewable resources on NFS lands are the Organic 

Administration Act, Multiple-Use Sustained-Yield Act, and the Bankhead-Jones Farm Tenant 

Act. 

The SFNF operates under the direction of the Forest Plan (Forest Service 1987). In accordance 

with the Geothermal Steam Act of 1970 (30 USC, Section 1019), the BLM administers 

geothermal leasing on NFS lands. It does this with the concurrence of the Forest Service, which 

is mandated by national policies to administer lands under the concept of multiple uses, while 

protecting the long-term health of the land. 

Land Use Authorizations

Land use authorizations include various agreements to use Forest Service land, such as ROW

grants, road use agreements, and associated temporary use permits. Land use authorizations are 

issued for a variety of purposes, both short term and long term. Short-term uses include 

agricultural leases and other uses involving minimal land improvements or disturbances. Longterm uses include right-of-way grants for power lines, highways, roads, pipelines, fiber-optic 

cables, communication sites, electric power generation sites, and irrigation canals or acequias.

Rights-of-way and Utility Corridors

A ROW grant is an authorization to use a specific piece of public land for a certain project, such 

as roads, pipelines, transmission lines, and fiber-optic lines. The grant authorizes rights and 

privileges for a specific use of the land for a specific period of time. Generally, a Forest Service

ROW is granted for the life of the project and remains in impact unless terminated by mutual 

agreement or one agency giving the other 90 days prior written notice. 

Special Use Permits and Leases

A lease is an authorization to possess and use public land for a fixed period. A lease is issued 

when there is going to be substantial construction, development, and improvement, and there is 

an investment of large amounts of capital that would be amortized over time. Special use permits 

are authorized when uses of public lands would be short term and involve little or no land 

improvement, construction, or investment. Special use permits and leases are subject to process 

and monitoring fees and a fair-market rental value.

Withdrawals

A land withdrawal is a real estate management tool to implement resource management planning 

prescriptions or to transfer administrative jurisdiction from one federal agency to another. A 

withdrawal creates a title encumbrance on the land, thereby restricting an agency’s ability to 

manage its lands under multiple use management principles. The restrictions generally segregate 

the lands from some or all the public land laws and some or all of the mining and mineral leasing 

laws for a specific period, generally 20 years for post-FLPMA withdrawals. Withdrawn land can 

be closed to mining, mineral leasing, or mineral material disposal.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-7

SFNF Project Area: Land Use

The SFNF project area covers approximately 194,900 acres and is in the northwest-central 

portion of New Mexico, including Rio Arriba and Sandoval Counties. Property adjacent to the

project area is as follows:

 Lands administered by the Taos Field Office of the BLM, LANL, and DOE

 Bandelier National Monument and Valles Caldera National Preserve (VCNP) administered 

by the NPS

 State and municipal lands

 Jemez Pueblo lands administered by the Pueblo and Bureau of Indian Affairs

 Private lands

There are no major population centers in the project area. Nearby towns are Jemez Springs, 

Jemez Pueblo, Ponderosa, Cuba, Los Alamos, and other small towns and villages. Ranger 

Districts on the SFNF are Coyote, Cuba, Espanola, Jemez, and Pecos/Las Vegas, although the 

project area does not include the Pecos/Las Vegas Ranger District. 

The SFNF manages lands for multiple uses, including recreation, grazing, wildlife habitat, 

fisheries, watersheds, and heritage resource protection and interpretation. Lands surrounding the 

SFNF are undeveloped areas (open grasslands and low-, mid-, and high-elevation forest 

ecosystems), dispersed residential developments, small towns, villages, and Pueblos, a national 

research center (LANL), ski areas, reservoirs, and agricultural areas, including both ranches and 

small irrigated farms. 

Existing ROWs on the SFNF are those for transmission lines, water lines, fiber-optic cables, 

communication facilities, roads and highways, pipelines, and other infrastructure that support 

local, regional, and national interests. 

3.4.1.2 Recreation

Recreation planning on NFS lands is an integral part of land and resource management planning, 

as required by the Forest and Rangeland Renewable Resources Planning Act of 1974, as 

amended by the National Forest Management Act of 1976, and described in 36 CFR, Part 219, 

and Forest Service Manual 1920. 

Recreation opportunities in the project area range from dispersed uses, such as hiking and 

wildlife viewing, to developed recreation, such as that for campgrounds and interpretive sites. 

Recreation is an important component of the multiple use management practices of the SFNF. 

Surveys cited in the PEIS (2008) demonstrate that recreation on Forest Service lands is 

increasing annually (BLM and Forest Service 2008). Steady population growth continues to 

increase the recreation demand on undeveloped public lands as visitors and nearby residents seek 

a diversity of recreation.

The Recreation Opportunity Spectrum (ROS) is both a classification system and a prescriptive 

tool for recreation planning, management, and research (Clark and Stankey 1979). The Forest 

Service uses ROS to illustrate the recreation setting by describing a combination of the physical, 

biological, social, and managerial conditions that give value to a place. 

The ROS embodies six land classes, as follows, along with the number of acres in the project 

area on lands managed by the SFNF (Forest Service GIS 2015): 
Chapter 3. Affected Environment and Environmental Consequences

3-8 Santa Fe National Forest Geothermal Leasing EIS

 Primitive—0 acres

 Semi-primitive non-motorized—9,415 acres

 Semi-primitive motorized—85,973 acres

 Roaded natural—74,309 acres

 Rural—398 acres

 Urban—0 acres

Each setting provides experiences that range from a sense of isolation and closeness to nature (at 

the primitive end of the spectrum) to social experiences in highly structured environments (at the 

urban end of the spectrum). 

The SFNF includes a diversity of landscapes, offering visitors a variety of recreation settings and 

opportunities. Providing these outdoor recreation opportunities is a primary goal identified in the 

Forest Service’s Strategic Plan for Fiscal Years 2015 to 2020 (Forest Service 2015a). In the plan, 

the Forest Service has identified the following key aspects for managing recreation resources on 

system lands:

 Maintain recreation settings, hiking trails, and other sustainable recreation opportunities on 

National Forests and Grasslands for public use

 Improve recreation facility accessibility

 Help meet public needs and expectations for outdoor recreation on National Forests and 

Grasslands through public and private partnerships

 Improve our communication of outdoor recreation information about the National Forests 

and Grasslands on the Internet, social media, and other outlets to reach more people, serve 

them better, and receive their feedback

 Encourage community planning for sustainable tourism and recreation, providing private 

landowners with economic incentives to maintain open space

 Use tools such as the ROS and the Scenery Management System to help identify, prioritize, 

protect, and enhance open spaces

 Maintain water of sufficient quantity and quality to sustain aquatic life and support terrestrial 

habitats, domestic uses, recreation opportunities, and scenic character

 Develop sustainable recreation settings and opportunities along with programs that 

complement national, state, and community tourism strategies

In addition to planning documents, the aspects of the regulatory framework for recreation are 

provided in the 2008 Geothermal PEIS (BLM and Forest Service 2008). Since publication of the 

2008 PEIS, the SFNF completed updates to its Forest Plan (Forest Service 1987), including 

identifying management areas for recreation, providing management rules for special designations 

areas, and restricting motor vehicles to the route network displayed on motor vehicle use maps.

SFNF Recreation Areas

The SFNF previously administered the VCNP, formerly the Baca Ranch, but it is now a preserve 

under the NPS. Bandelier National Monument, also administered by the NPS, is east of the 

project area, near LANL, on the Pajarito Plateau.

An estimated 591,000 to 676,000 people visited the Jemez Ranger District in 2012. Holiday 

weekend visitation can increase dramatically. For example, on Memorial Day weekend in 2003, 

visitation was 163 percent above the average weekday (MRCOG 2006). Most SFNF recreation 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-9

users travel NM 4 from the Albuquerque area. Almost all of the Jemez Ranger District developed 

recreation sites are found along NM 4 and NM 126. The notable exception is Paliza Family and 

Group campgrounds, which are located off Forest Road 10 (Forest Service 2015b).

Recreation use is generally light to moderate throughout the broader project area, except along 

major routes, such as NM 4, and around campgrounds, hot springs, rivers, and population 

centers, such as Jemez Springs, where peak-season visitation during the summer can be high. In 

April and May there is a dramatic increase in day-use hikers. Trailhead parking is full during 

weekends and mostly full during the weekdays. Forest roads are opened to the public in midApril and visitors begin to use the dispersed camping areas. By early May the developed sites are 

open to the public and are busy throughout the summer. Campgrounds and dispersed camping 

areas continue to be used during the fall big game hunting seasons. As winter approaches the 

most developed sites are winterized and closed. Forest roads typically close in early January and 

are used as cross-country ski and snowmobile trails (Forest Service 2015b).

There are 1,089 miles of motorized routes that crisscross the SFNF project area (Forest Service

GIS 2015). The Travel Management Rule (36 CFR, Part 212) establishes requirements for 

National Forest transportation systems. It also describes the requirements for designating roads, 

trails, and areas for motor vehicle use on a motor vehicle use map.

In addition, there are a number of designated recreation areas on the SFNF, such as the San 

Antonio, Jemez Falls, Jemez Canyon, Laughing Water, Redondo, Las Conchas, Horseshoe 

Springs, and Paliza, which total to over 5,000 acres (Forest Service GIS 2015). 

Within the project area, there are six campgrounds (all on the Jemez Ranger District) and four 

picnic sites (three on the Jemez Ranger District and one on the Coyote Ranger District; Forest 

Service GIS 2015). Primitive camping is allowed throughout, unless otherwise posted and not 

within 100 feet of a riparian area.

NMDGF Hunt Units 5B, 6A, 6B, 51A, and 51B are partially or entirely in the project area. 

Permitted hunting is through the NMDGF, although an additional habitat stamp is required to hunt 

on federal lands. Typical hunted species are mule deer, elk, turkey, and other small game animals.

3.4.1.3 Special Designations

The following section describes special management designations on the project area, including 

IRAs, National Recreation Areas (NRAs), National Historic and Scenic Trails, Wilderness Areas, 

and Wild and Scenic Rivers. These areas have been designated to protect unique characteristics 

and contain resources that have been identified as scientifically, educationally, or recreationally 

important. Special area designations on NFS lands can be established by Congress or 

Presidential Proclamation or administratively by USDA. The Forest Service has the authority to 

adopt many, but not all, special management designations through Forest Plan amendments or 

revisions, such as the management designations detailed in the SFNF Plan (Forest Service 1987).

Inventoried Roadless Areas

IRAs are a Forest Service administrative designation representing some of the nation’s most 

highly valued expanses of open space.

There are seven IRAs in the SFNF project area covering approximately 15,800 acres. IRAs can 

be characterized by nine values or features, which are described below. The 2001 Roadless Rule 
Chapter 3. Affected Environment and Environmental Consequences

3-10 Santa Fe National Forest Geothermal Leasing EIS

(36 CFR, Subpart 294.43) places restrictions on resource extraction and road 

construction/reconstruction in IRAs.

The 2001 Roadless Rule lists the following nine values or features that often characterize IRAs:

 High-quality or undisturbed soil, water, and air

 Sources of public drinking water

 Diversity of plant and animal communities

 Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those 

species that depend on large, undisturbed areas

 Primitive, semi-primitive non-motorized, and semi-primitive motorized recreation 

opportunities

 Reference landscapes

 Natural-appearing landscapes with high scenic quality

 Traditional cultural properties and sacred sites

 Other locally identified unique characteristics

Seven IRAs are distributed in the northern and southern portions of the project area. Youngsville 

(6,000 acres), Pueblo Mesa (1,100 acres), Canones Creek (3,900 acres), and Polvadera (1,200 

acres) are all in this northern area; Virgin Canyon (600 acres), Peralta Ridge (800 acres), and 

Alamo Canyon (2,200 acres) are in the far south (Forest Service 2016a). 

National Recreation Areas

The Forest Service establishes NRAs primarily to protect important recreation, scenic, scientific, 

and natural values for the enjoyment of current and future generations. The highlighted activities 

center on water- and land-based pursuits associated with the natural environment.

The JNRA is in the project area. It was established in 1993 and consists of over 28,000 acres,

managed by the Jemez Ranger District, and abuts portions of the VCNP. The SFNF administers 

the lands to promote the area for fishing, camping, rock climbing, hunting and hiking. Mining in 

this NRA is prohibited, except on preexisting claims, and the JNRA Act withdrew the area from 

geothermal development. The JNRA (Public Law 103-104, Stat. 1025) requires the SFNF to 

protect, conserve, and restore natural resource values in the JNRA. 

National Historic, Scenic, and Recreational Trails

The National Trails System is made up of National Scenic Trails, National Historic Trails, and 

National Recreation Trails. National Scenic Trails and National Historic Trails are congressional 

designations given to protected areas in the United States that contain trails and surrounding 

areas of particular natural beauty and historic significance. National Recreational Trails are 

designated based on applications from diverse partnerships, and include more than 1,200 trails 

on federal, state, local, and privately owned land throughout the country. National Trails are 

officially established under the authorities of the National Trails System Act (16 USC, 

Subsection 1241-51). 

National Scenic Trails are 100 miles or longer, continuous, primarily non-motorized routes of 

outstanding recreation opportunity. National Historic Trails commemorate historic and 

prehistoric routes of travel that are of significance to the entire nation. National Historic Trails 

have as their purpose the identification and protection of the historic route and its historic 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-11

remnants and artifacts for public use and enjoyment (NPS 2006a). They must meet three criteria 

listed in Section 5(b)(11) of the National Trails System Act:

 They must follow actual documented route of historic use

 They must be of national significance

 They must possess significant potential for public recreation and interpretation

Within the SFNF, there is one federally designated National Scenic Trail: the Continental Divide 

Trail. It runs along the Continental Divide of North America and crosses the SFNF for a total of 

25.7 miles on the Cuba and Coyote Ranger Districts1, but not within the project area (Forest 

Service 2016b). There are no National Historic Trails within the project area; however, the Old 

Spanish National Historic Trail is located north of the project area. The Canones Creek National 

Recreational Trail is the only National Recreational Trail in the project area, extending 6.2 miles 

from the Cerro Pavo trailhead through Canones Canyon near Coyote.

National Scenic Byways 

The National Scenic Byways Program (NSBP; 23 USC 162) was authorized in 1991 and is 

administered by the Federal Highway Administration (FHWA). The FHWA designates National 

Scenic Byways when roads have outstanding scenic, historic, cultural, natural, recreational, and 

archaeological qualities. NSBP funding supports projects that manage and protect these intrinsic 

qualities, interpret these qualities for visitors, and improve visitor facilities along byways. The 

National Scenic Byway in the project area is the Jemez Mountain Trail National Scenic Byway. 

It is approximately 65 miles long, 21.8 miles of which fall within the project area. It provides 

scenic opportunities for viewing geological formations, ancient Native American ruins, Jemez 

Pueblo, and an area rich in historic logging, mining, and ranching (Forest Service GIS 2015). 

The portion of the Jemez Mountain Trail National Scenic Byway within the project areas is 

within the JNRA.

Wilderness Areas 

The National Wilderness Preservation System was created to ensure the preservation and 

protection of natural conditions in areas designated as wilderness. On the SFNF, there are of four 

wilderness areas (Pecos, San Pedro Parks, Chama River Canyon, and Dome), although none are 

in the project area. 

Wild and Scenic Rivers

Congress established the National Wild and Scenic Rivers System to effectively manage special 

river segments. Rivers, or segments of rivers, must be free flowing and possess at least one 

outstandingly remarkable value, such as scenic, recreational, geologic, fish, wildlife, historic, 

cultural, or other features. The outstandingly remarkable values of eligible rivers must be 

protected until superseded by Congress. Within the National Wild and Scenic Rivers System, 

three classifications define the general character of designated rivers: wild, scenic, or 

recreational. Classifications reflect levels of development and natural conditions along a stretch 

of river. These classifications are used to help develop management goals for the river.

 

1 Mathew Chavez and Anne Bishop, Forest Service, personal communication with Holly Prohaska, 

EMPSi. March 2, 2016.
Chapter 3. Affected Environment and Environmental Consequences

3-12 Santa Fe National Forest Geothermal Leasing EIS

The SFNF has three Wild and Scenic Rivers: The Rio Chama, Pecos, and the East Fork of the 

Jemez River. However, only 9 miles of the East Fork of the Jemez River fall within the current 

project area, all of which is in the JNRA (Forest Service GIS 2015).

3.4.2 Environmental Consequences

3.4.2.1 Scoping Comments on Land Use, Recreation, and Special 

Designations

The following issues specific to land use, recreation, and special designations were identified 

during the public scoping period:

 How would geothermal leasing impact IRAs and their sensitive resources?

 How would geothermal leasing impact adjacent wilderness areas, lands with wilderness 

characteristics, IRAs, and ACECs or other special designations?

 How would geothermal leasing affect recreation in the project area? How would geothermal 

leasing affect the JNRA and other nearby recreation areas managed by other federal or state 

agencies?

3.4.2.2 How Resource Impacts Were Evaluated

Methods

Land status baseline information, recreation data, and special designation areas in Section 3.4

were reviewed for an understanding of SFNF management practices, designations, and land use 

in the project area. The SFNF GIS data (Forest Service GIS 2015) were overlain with the actions 

found under each alternative in Chapter 2. Conclusions were drawn based on an understanding 

that these types of actions may affect NFS lands and adjacent landowners.

Indicators

The following indicators have been identified in order to evaluate potential impacts on land use, 

recreation, and special designation areas:

 Conflict with management goals and objectives set forth by the Forest Service to sustain the 

health, productivity, and diversity of federal lands

 Result in proposed uses that are incompatible with existing or adjacent land uses

 Result in a change of recreation access

 Conflict with existing recreation uses of the area

 Diminish existing recreation experiences and opportunities by altering the recreation setting

 Conflict with management goals and objectives set forth by the Forest Service in order to 

categorize, protect, and manage special designation areas

 Conflict with conservation goals for the area

 Result in proposed land uses that are incompatible with adjacent special designation areas

Assumptions

This analysis assumes the following: 

 The SFNF’s consent or denial of NFS lands for geothermal leasing and its issuance of 

geothermal leases would not impact land use and access. Existing ROWs and 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-13

communication sites would be managed to protect valid existing rights. However, impacts 

could result from future construction and operation of geothermal energy projects in the 

project area, based on future leases.

 Congressionally designated wilderness areas would be closed to leasing. 

 Current land use could change once site-specific geothermal operations begin. Under travel 

management, new roads created for a specific project would probably not be open to 

recreational use.

 Demand for recreation opportunities would increase over time.

3.4.2.3 Common Impacts Associated with Geothermal Development

Due to the inability to predict the location, scope, scale, and timing of future development, the 

following impact analysis provides a general description of common impacts on land use from 

geothermal development. The information presented in the Common Impacts on Land Use with 

Geothermal Development section of the 2008 Geothermal PEIS is incorporated by reference and 

summarized here (BLM and Forest Service 2008). Chapter 2 summarizes the alternativespecific data.

Lands converted to geothermal use during the drilling and utilization phases (well pad, power 

plant, pipeline, and transmission line construction and uses) could result in long-term indirect 

impacts on other uses, such as grazing, recreation, hunting, and mining, because geothermal use 

could displace these activities and uses. Short-term (lasting only the duration of the actual 

activity) impacts could include maneuvering construction and maintenance equipment and 

vehicles associated with the drilling and utilization activities. Further, reclamation and 

abandonment would likely return the landscape to its pre-construction condition, and the 

previous uses and activities could resume.

The development of geothermal resources could also alter the physical, social, and operational 

character of the recreation setting, thereby changing an individual’s experiences. All phases of 

development, including surveying, drilling, utilization, operation, and maintenance, could restrict 

recreation areas, temporarily reducing the amount of land available for recreation and accessible 

trails. This could displace some recreationists and could limit recreation. Recreationists could 

experience an increase in noise, vibration, and dust. Additionally, exploration could shift the 

ROS setting. Under travel management, new roads created for a specific project would probably 

not be open to recreational use. However, this would also alter the experience for people seeking 

a more remote experience in those same areas. 

Increased traffic from reclamation and abandonment could affect timely public access, as 

described above. All disturbed lands would be reclaimed in accordance with Forest Service

standards, and recreation activities could resume, improving recreation opportunities.

3.4.2.4 Impacts Under Alternative 1—No Action

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. The JNRA would 

remain closed to geothermal leasing, and no direct impacts would occur in this area. Geothermal 

lease stipulations and closures would not be specifically implemented on recreation areas or 

special designations outside of the JNRA; however, any geothermal lease applications and 
Chapter 3. Affected Environment and Environmental Consequences

3-14 Santa Fe National Forest Geothermal Leasing EIS

nominations would be subject to the standards and guidelines outlined in the Forest Plan and 

subsequent environmental analysis.

3.4.2.5 Impacts Under Alternative 2—Proposed Action

Relevant stipulations detailed in Chapter 2 and designed to protect existing land uses are CSU

stipulations in and around popular recreation areas, TLs to benefit wildlife, and NSOs to ensure 

sensitive and special designation areas are protected. These measures are expected to effectively 

avoid or minimize direct and indirect impacts identified in Section 3.4.2.3 on land uses, 

recreation and special designation areas by identifying conflicts early in the process and 

requiring specific measures to maintain public uses and values. Implementing lease stipulations 

under Alternative 2 would minimize impacts. 

More trucks, possible road improvements, and more people could diminish the overall recreation 

experience on the SFNF. Further, traffic noise may disrupt the experience of people staying in 

campgrounds and picnic areas along NM 4 and NM 126. Evening and night traffic from trucks 

and project equipment would be light, but traffic noise from evening and night travel could 

indirectly impact campers’ experience. Daytime traffic may have fewer impacts because many 

campers are elsewhere during the day, in contrast to users of picnic areas that are open only 

during the daytime. 

Special designations in the project area, including the Wild and Scenic segment of the East Fork 

of the Jemez River, the JNRA, Canones Creek National Recreation Trail, and the seven IRAs, 

are either closed to leasing or are subject to NSO under Alternative 2. No direct impacts would 

occur in these areas. The Jemez Mountain Trail National Scenic Byway, 21.8 miles of which fall 

within the project area, could include minor, temporary impacts from congestion resulting from 

large, long-wheelbase construction vehicle traffic during geothermal exploration and 

development phases. 

Overall, this alternative would result in greater limitations for the siting of geothermal 

infrastructure, compared to Alternative 1, which could result in more concentrated areas of 

development. Recreation experiences and opportunities may be diminished by increased visual 

and noise impacts. These impacts would occur in areas not subject to leasing closures or NSO

stipulations.

Compared with Alternative 1, Alternative 2 provides specific guidance to ensure that a National 

Forest-wide approach is adopted and that land use issues are considered across all users of the 

SFNF.

3.4.2.6 Impacts Under Alternative 3—No Leasing

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Under the no 

lease alternative, there would be no direct or indirect impacts on land use, recreation, or special 

designations in the project area.

3.4.2.7 Impacts Under Alternative 4—Development 

Relevant stipulations and closures detailed in Chapter 2 would be designed to protect special 

designation areas, such as IRAs, the JNRA, Scenic Trails, recreation areas, and land uses. 

Impacts would be similar to those described under Alternative 2. However, because of the 

greater access to SFNF lands and fewer overall restrictions, Alternative 4 may have greater 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-15

indirect impacts—such as noise, fugitive dust, and visual intrusions—on special designation 

areas, recreation opportunities, and land uses on the SFNF. 

The JNRA is closed to leasing under Alternative 4. However, there could be impacts on other 

types of recreation areas, including remote portions of the SFNF and areas currently valued for 

solitude and low-density visitation. More trucks, possible road improvements, and more people 

could reduce the overall recreation experience on the SFNF, compared to Alternative 3. Traffic 

noise may disrupt the experience of people staying in campgrounds and picnic areas along NM 4 

and NM 126. Evening and night traffic from trucks and project equipment would be light, but 

traffic noise from evening and night travel could indirectly impact campers’ experience. Daytime 

traffic may have fewer impacts because many campers are elsewhere during the day, in contrast 

to users of picnic areas that are open only during the daytime. 

Other special designations in the project area, including the wild and scenic segment of the East 

Fork of the River, Canones Creek National Recreation Trail, and the seven IRAs are either 

closed to leasing or subject to NSO under Alternative 4. No direct impacts would occur in these 

areas. The Jemez Mountain Trail National Scenic Byway, 21.8 miles of which fall within the 

project area, could include minor, temporary impacts from congestion, resulting from large, 

long-wheelbase construction vehicle traffic during geothermal exploration and development.

3.4.2.8 Cumulative Impacts, Land Use, Recreation, and Special Designations

Consent to the issuance of a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any future development of geothermal resources, if and when it does 

take place, may result in impacts, whether deemed significant or not. It is reasonable, therefore, 

to foresee that on-the-ground impacts on land use, recreation, and special designation areas may 

occur if the Forest Service consents to leasing and the BLM issues geothermal leases. Those 

impacts would not occur, however, until some point in the future, following several decision 

stages. 

Past and present activities that have had cumulative impacts on land uses, recreation, and special 

designation areas are wildfire, mining, ranching, timber cutting, road building, off-road vehicle 

riding, and dispersed camping, including in sensitive riparian areas, such as along the wild and 

scenic portion of the East Fork of the Jemez River near Las Conchas. 

Reasonably foreseeable future actions are the proposed South Pit Pumice Mine Expansion, the 

Duran 2010 Pumice Mine, and the VCNP designation as a significant geothermal feature under 

the Geothermal Steam Act of 1970 (30 USC, Section 1019). The two pumice mines are on the 

Jemez Ranger District and could have a cumulative impact on recreation and land uses. 

Specifically they could have indirect impacts related to noise, traffic, fugitive dust, and visual 

intrusions. Further, if the NPS successfully nominates the VCNP as a significant thermal feature 

under the Geothermal Steam Act, areas next to the caldera, or those with hydrological 

connections, may not be leased; this could reduce potential indirect impacts on land uses, 

recreation, and special designations. Other reasonably foreseeable actions could include potential 

fire management activities, timber sales, mineral leases, and transmission lines 

Incremental cumulative impacts are not anticipated under Alternative 3, because the project area 

would be closed to geothermal leasing. Under Alternatives 2 and 4, there would be incremental 
Chapter 3. Affected Environment and Environmental Consequences

3-16 Santa Fe National Forest Geothermal Leasing EIS

cumulative impacts on recreation, including noise, fugitive dust, increased traffic, and visual 

intrusions that may diminish recreation experiences. However, special designation areas would 

not be affected, due to NSO stipulations. Further, any ground disturbance or other future actions 

that would occur under Alternatives 2 and 4, would require further decision-making under 

NEPA. This would involve a wide variety of factors; examples are policy initiatives about timing 

of actions, whether any applications are submitted or any funding is available, and compliance 

with other authorities and policies. The use of TLs, CSUs, and NSOs should minimize conflicts 

with land use, recreation, and special designation areas, as should individual analyses under 

NEPA that would determine project-specific direct, indirect, and cumulative impacts. Alternative 

1 would also follow this action-specific NEPA process. 

3.5 Geologic Resources

3.5.1 Affected Environment

3.5.1.1 Geologic Setting

The project area is in the Jemez Mountain region of northern New Mexico, to the west of the Rio 

Grande Valley. It sits at the southern margin of the Rocky Mountain ecoregion on the west side 

of the Rio Grande Rift Zone. The Jemez Mountains are part of the Jemez Lineament, which is a 

chain of volcanic centers extending from Arizona to Colorado. The Rio Grande Rift is a feature 

where the crustal plate is separating that stretches from the Colorado Rockies to Mexico. The 

project area lies above the intersection of the Jemez Lineament and the Rio Grande Rift. A 

dormant super-volcano beneath the project area has erupted numerous times due to tectonic 

movements (Muldavin and Tonne 2003). The last eruption occurred 40,000 to 50,000 years ago. 

The Valles Caldera crater was created by a massive eruption 1.25 million years ago and is now a 

13-mile-wide crater-shaped landscape and contains the 89,000-acre ranch that is now the VCNP. 

This is bordered on three sides by the project area (Forest Service 2016c).

The Jemez Mountains and Valles Caldera are composed of Quaternary Period alluvial and 

landslide deposits, welded Bandelier tuff, Tertiary basalt, basaltic-andesite, or rhyolite and 

breccias. These are clastic sedimentary rocks, which originated from volcanic activity in the 

region 13 million years ago. These rocks overlie Tertiary, Mesozoic, and Paleozoic sedimentary 

rocks, which in turn overlie Precambrian granitic basement rock. More specifically, the 

Paleozoic Madera limestone underlies the redstones, siltstones, and shale of the Abo Formation, 

with the Mesozoic Chinle formation and the Tertiary Santa Fe Group and Abiquiu tuff 

superseding. The more permeable layers of volcanic tuff allow for groundwater to occur in 

perched aquifers above the relatively impermeable Abo Formation (Forest Service 2016c).

The rocks are down-faulted to the east into the Rio Grande Rift. Unconsolidated Tertiary 

sediments of the Santa Fe Formation thicken eastward toward the axis of the rift. The Jemez 

Mountains volcanics occur at the intersection of the rift with the northeast-trending Jemez 

Lineament, a line of Miocene to Quaternary volcanic fields extending across the northwest 

portion of New Mexico (Aldrich and Laughlin 1984; Shevenell et al. 1987).

The Chama River cuts through the southeastern Colorado Plateau and southern Rocky 

Mountains, which consists of high mesas dissected by tributaries of the Rio Chama and its main 

stem. Rock units exposed in the lower reach of the river are the Ojo Caliente sandstone, Abiquiu 

tuff, and Lobato basalt (Wells 2009).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-17

Downstream of the Abiquiu Reservoir, to the confluence of the Rio Chama with the Rio Grande,

and following the Rio Grande downstream to its confluence with the Jemez River, the valley 

floors also consist of Tertiary Period partly compacted sands and gravels of the Santa Fe group

or Quaternary Period alluvium. The Santa Fe Group consists of alluvial fans, river channel 

deposits, and interbedded volcanic rocks. Several of the mesas are capped by Triassic Period 

basaltic to andesitic lava flows (NRCS 2011a).

3.5.1.2 Geologic Hazards

Seismic Activity

The project area lies above several faults. There were 54 earthquakes in the vicinity of the SFNF 

between 1962 and 2014, with the largest having a magnitude 3.5. The probability of an 

earthquake exceeding magnitude 5.0 in the project area in the next 20 years ranges from 3 

percent to 15 percent (USGS 1999). A magnitude 5.0 earthquake may damage poorly constructed 

structures but have little to no damage on well-constructed structures. Small earthquakes are 

expected to continue to occur in the vicinity of the project area (Forest Service 2015c). 

Seismic activity can be caused by human activity in areas with certain types of faults and a 

critical state of stress in the rocks. Changes in pore pressure, or stress, on a fault may occur when 

fluids are injected into or extracted from a well. This change may lead to movement along that 

fault, resulting in a seismic event. Increased seismicity in the central United States in recent 

years has been linked to injection of wastewater or other fluids in high volumes over an extended 

period in deep disposal wells (Petersen et al. 2015). Geothermal development has been 

associated with induced seismicity but only in cases of Enhanced Geothermal Systems (i.e., 

injecting and withdrawing fluids from rock formations to enhance rock permeability and recover 

heat from the rock; Majer et al. 2012). The seismic events believed to have resulted from this 

activity have almost all been of relatively small magnitude. Most of these events are rarely felt 

by the time the seismic energy reaches the surface (Majer et al. 2007). 

The USGS is working to create a seismic hazard model that incorporates induced seismicity into 

predictions of probability of future seismic events. A 2014 report prepared by the USGS states 

that forecasting the seismic hazard from induced seismicity is fundamentally different from 

forecasting the seismic hazard for natural seismic activity. This is due to the economic and policy 

factors that affect where fluid extraction and injection occurs. The report concludes that the rates 

of induced earthquakes are inherently variable and non-stationary and therefore are extremely 

difficult to predict on a multi-year basis (Petersen et al. 2015). As a result, the risk of induced 

seismicity in the project area cannot be accurately predicted at this time.

The USGS has identified 17 areas in the central and eastern United States that contained 

seismicity suspected to have been induced by fluid injection or removal. These areas are called 

induced seismicity zones. New Mexico contains two such zones—the Raton Basin near the New 

Mexico-Colorado border and Dagger Draw in southeastern New Mexico. While earthquakes 

recorded in these zones could be natural, the USGS believes they may be induced seismicity. 

This is because the earthquakes are all located near deep fluid injection wells or other industrial 

activities capable of inducing earthquakes (Petersen et al. 2015). Neither of the induced 

seismicity zones in New Mexico are in or near the project area.

Volcanic Activity

There is a long history of volcanic activity in northern New Mexico, including the SFNF 

(Schwab et al. 2008). All of the volcanoes on or near the SFNF are considered extinct, except for 
Chapter 3. Affected Environment and Environmental Consequences

3-18 Santa Fe National Forest Geothermal Leasing EIS

those in the Valles Caldera. As discussed in Geologic Setting, above, the project area surrounds 

three sides of the Valles Caldera and sits above a dormant super-volcano. The volcano has not 

erupted in the past 40,000 to 50,000 years. However, new magma has been seen in the volcanic 

deposits beneath the project area, suggesting that “the Jemez Mountains volcanics field may be 

entering a new phase of activity” (Dunbar 2010). Those studying the area conclude that the 

volcanic features beneath the project area are likely to erupt again but that the next eruption may 

not occur for thousands, or even tens of thousands, of years (Dunbar 2010). Studies of magma 

bodies in New Mexico indicate that magma deposits may occur as little as 2.5 miles below the 

earth’s surface; however, most of the deposits are believed to occur between 3.7 and 11.8 miles 

below the surface (Sanford 1983; Fialko and Simons 2001). 

Naturally Occurring Radioactive Material

Some geologic formations, including the Mancos Formation in northwestern New Mexico, 

contain low levels of radioactive materials, such as uranium and thorium, and their decay 

elements, radium 226 and radium 228 (USGS 1999). These elements emit the same levels of 

radiation that humans are generally exposed to on a daily basis (BLM 2014). These naturally 

occurring radioactive materials (NORM) can be brought to the surface during drilling operations 

that remove fluids from the radioactive formation (Sumi 2008). 

Pipes and other equipment that handle large volumes of water flowing out of formations over the 

long term can become coated with scale deposits that contain radium (USGS 1999). Radiation 

levels on these pipes may increase above background levels over time to a level that can be 

dangerous to those who handle the equipment (USGS 1999). However, the radiation is weak 

enough that it cannot penetrate dense materials, such as the steel used in pipes and tanks, to 

contaminate the surrounding environment (BLM 2014).

3.5.2 Environmental Consequences

3.5.2.1 Scoping Comments on Resource

The following issues specific to geologic resources were identified during the public scoping 

period:

 What are the impacts on geologic resources from geothermal developments? Could there be 

increased risk for induced seismicity or other geologic hazards as a result of geothermal 

leasing? If so, what are the indirect impacts of geologic hazards, considering the proximity 

of the Abiquiu Dam and LANL?

 Is baseline seismic monitoring or additional fault mapping required to determine the risk of 

induced seismicity or other geologic hazards associated with geothermal exploration or 

development?

3.5.2.2 How Resource Impacts Were Evaluated

Method

The potential impacts of geothermal development were evaluated by assessing the impacts that 

anticipated future actions under the alternatives would have on the geologic resources of the 

project area. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-19

Indicators

The following indicators have been identified in order to evaluate potential impacts on geology 

and seismicity: 

 Changes in seismic activity, including both natural and induced seismicity

 Changes in volcanic activity

 Release of NORM into the environment

 Ground subsidence

Assumption

This analysis assumes that further environmental analysis would be completed before enhanced 

geothermal systems are authorized in the project area.

3.5.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Geology Resources and Seismic Setting 

Associated with Geothermal Development section of the 2008 Geothermal PEIS is incorporated 

by reference and summarized here. 

Although the concerns identified above in the Indicators are discussed here and in the 2008 

Geothermal PEIS, due to the inability to predict future types of development, the timing, and 

locations, the potential for these impacts to occur can only be fully evaluated once a site-specific 

proposal is submitted. Any subsequent, site-specific projects that might occur in the project area 

would undergo NEPA review, during which geotechnical investigations may be conducted, if 

deemed necessary. 

Seismic risk could increase if geothermal resource development includes high pressure 

reinjection along any faults intersected by the injection well. However, the risk is reduced where 

geothermal fluid withdrawn from the resources is used and then re-injected into the system for a 

near zero net change.

While the project area has had historic volcanic activity and has the potential for future volcanic 

activity, geothermal development in the project area is not expected to affect the risk of this 

activity. As discussed under Affected Environment, studies of magma bodies in New Mexico 

indicate that magma deposits may occur between 2.5 and 11.8 miles below the earth’s surface, 

though most deposits occur at least 3.7 miles below the surface (Sanford 1983; Fialko and 

Simons 2001). The deepest geothermal wells are drilled to approximately 2.2 miles below the 

surface, and most are shallower than that (Finger and Blankenship 2010; Brown 2009 [Fenton 

Hill]). Therefore, the potential for a geothermal well to encounter a magma deposit is low.

NORM can be released from subsurface formations during withdrawal of groundwater

associated with geothermal development. However, as discussed under Affected Environment, 

the radioactivity cannot penetrate the materials used in geothermal development equipment. 

Therefore, the potential for release of these materials into the environment is low.

Subsidence can occur where groundwater is pumped from underground aquifers at a rate 

exceeding the rate at which it is replenished. Most geothermal development techniques include 

re-injecting the geothermal fluid after the heat is used and maintaining static pressure of the 

geothermal reservoir. Therefore, the potential for subsidence is low.
Chapter 3. Affected Environment and Environmental Consequences

3-20 Santa Fe National Forest Geothermal Leasing EIS

Enhanced Geothermal Systems 

The process of stimulating production and injection wells by injecting water under pressure, and 

often at a much cooler temperature than the receiving rock, results in the expansion of existing 

fractures and sometimes the creation of new fractures through the movements of masses of rock 

at depth. This fracturing method is commonly referred to as hydro-shearing or shearing. These 

movements result in seismic activity. Since the seismic activity is created by the reservoir 

stimulation, it is distinguished from natural seismicity by the term induced seismicity. Whether 

or not the induced seismicity can be felt at the surface depends on the depth of the reservoir, the 

degree to which the rock masses are shifted from the stimulation, and the nature of the overlying 

geology and its ability to transfer the shock waves to the surface. 

Typically, natural fractures vary in length on a scale of 1 to 10 meters. Seismic energy radiated 

during the shearing process depends on the length of the fracture or the stress release from the 

constraining natural forces. Most of the observed data from existing Enhanced Geothermal 

Systems projects suggest that the higher energy radiated from the shearing is caused by a high 

stress release from relatively small joint lengths (Michelet et al. 2004). This would suggest that if 

there were some perceived seismicity on the surface, the frequency content would be too high to 

generate any seismic risk, but minor events may still raise concern among local inhabitants. As 

part of the NEPA process for any specific Enhanced Geothermal Systems proposal, mitigation 

measures, such as seismic monitoring requirements, would be developed to address the potential 

for seismic-related risks.

Protocols 

The International Energy Agency developed a peer-reviewed and accepted protocol for 

addressing induced seismicity during geothermal projects, and the DOE has adopted it (Majer et 

al. 2012). Such protocols may be made a requirement of any enhanced geothermal systems

project. The protocol calls for the following steps to be taken for a site-specific project:

 Perform a preliminary screening evaluation

 Implement an outreach and communication program

 Review and select criteria for ground vibration and noise

 Establish seismic monitoring

 Quantify the hazard from natural and induced seismic events

 Characterize the risk of induced seismic events

 Develop risk-based mitigation plan

Induced Seismicity Hazards Risk Analysis 

If desired by the operator or required by the Forest Service, an independent consultant can be 

contracted to prepare an induced seismicity and seismic risk hazards analysis. Such analyses 

identify and quantify the risk associated with induced seismicity and can focus its content on 

potential impacts on nearest communities and homeowners.

Prediction of Event Number and Magnitude 

Recent advances have been made in predicting the number and magnitude of induced seismicity 

that can be expected during hydro-shearing operations. If desired by the operator or required by 

the Forest Service, mechanisms of induced seismicity can be quantified and a “seismogenic 

index” can be developed for a specific area. Such an index would characterize the potential 

number of induced seismicity events greater than a particular magnitude as a function of the 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-21

injected volume. Changes to injection rates and total fluid volumes can be used during 

operations to manage seismic impacts. The maximum allowable magnitude is determined by the 

induced seismicity and seismic hazard risk analysis. Evaluation of the seismogenic index will 

allow project geologists to place initial bounds on the hydro-shearing operational and mitigation 

limits for a given project. 

Control of Rate and Bleeding Pressure after Injection 

Mitigation measures can be implemented if induced seismic events approach defined limits. The 

primary mitigation method may be reducing the rate of water injection to a level where an 

induced seismicity rate and magnitude are within an acceptable range. A secondary method can 

be to backflow the well to reduce reservoir pressure. 

The utilization phase of Enhanced Geothermal Systems projects could produce micro-seismic 

events. Seismic data collection arrays may be set up before any well stimulation so that induced 

seismicity can be monitored in real time. This monitoring allows supervising geologists to track 

where the reservoir is opening up and allows operations to be modified, as needed. The ongoing 

monitoring of micro-seismicity with multi-station sensor arrays would allow regulators to 

continuously review the project and halt or modify operations if the risk to properties is 

considered to be too great.

3.5.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. 

Projected geothermal development under Alternative 1 may increase the impacts on geologic 

resources, described under Common Impacts Associated with Geothermal Development. As 

noted under Common Impacts Associated with Geothermal Development, these impacts of 

increased seismic risk, volcanic activity, release of NORM, and subsidence are all low. While the 

risk of increased seismicity cannot be quantified at this stage, development using enhanced 

geothermal systems would not be authorized without further analysis of the risks of induced 

seismicity associated with a proposed project.

3.5.2.5 Impacts Under Alternative 2

Impacts under Alternative 2 on geologic resources would be the similar as those described under 

Alternative 1. BMPs identified in Appendix C include monitoring during all phases of 

development and adaptive management strategies developed at the project level. These measures 

would reduce the risk of geologic hazard impacts.

3.5.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts described under Common Impacts Associated with Geothermal Development would not 

occur.

3.5.2.7 Impacts Under Alternative 4

Impacts under Alternative 4 on geologic resources would be the same as those described under 

Alternative 2.
Chapter 3. Affected Environment and Environmental Consequences

3-22 Santa Fe National Forest Geothermal Leasing EIS

3.5.2.8 Cumulative Impacts

Cumulative impacts on geologic resources from geothermal exploration, drilling, and 

development are expected to be minor. BMPs identified in Appendix C—such as geotechnical 

investigations and monitoring, and mitigation of impacts from future drilling activities—would 

be implemented. Any impacts from development that might occur would be minimal and largely 

limited to the project site. Seismic events related to geothermal reservoir injection could 

cumulatively contribute to seismic events triggered by multiple operations; however, the risk of 

seismic events triggered by specific geothermal development activities cannot be assessed at this 

time.

3.6 Energy and Mineral Resources

3.6.1 Affected Environment

In this section, energy and mineral resources are discussed, along with their association with 

geothermal resources. This section addresses the Forest Service’s general regulatory framework 

for energy and mineral resource development, regulations particular to the project area, energy 

resources and activity in New Mexico and the project area, and mineral resources and activity in 

New Mexico and the project area.

Wind, solar, biomass, and geothermal energy are considered renewable energy resources. The 

Forest Service manages these activities under 36 CFR, Part 251, Subpart B. These resources all 

have different factors influencing the feasibility of their development. However, some issues are 

common to all, including distance to existing power transmission facilities and compatibility 

with existing federal land use.

On federal lands, mineral resources are governed by the General Mining Law of 1872, as 

amended; those portions of the FLPMA that affect the General Mining Law; the Mineral Leasing 

Act of 1920; the Surface Resources Act of 1955; and the Mining and Minerals Policy Act of 

1970. Oil and gas leasing is guided by the Energy Policy Act of 2005, and geothermal leasing is 

guided by the Geothermal Steam Act of 1970 (30 USC 1004), as amended by the Energy Policy 

Act of 2005.

The Forest Service manages oil and gas operations on NFS lands under 36 CFR, Part 228, 

Subpart E. Mineral leasing operations are guided by Forest Service Manual 2820; mineral 

prospecting, including geophysical activities, is guided by Forest Service Manual 2860. 

Locatable minerals and surface management regulations fall under 36 CFR, Part 228, Subpart A, 

and Forest Service Manual 2810. Mineral materials are regulated under 36 CFR, Part 228, 

Subpart C, and Forest Service Manual 2850. Within the SFNF, the right to occupy and use 

surface lands as reasonably necessary to carry on prospecting mining is guided by 16 USC, 

Subsection 482(j). 

A portion of the project area overlaps the JNRA. Subject to valid existing rights, lands in the 

recreation area are withdrawn from locatable mineral entry under the General Mining Law of 

1872 and the Mineral Leasing Act of 1920, 16 USC, Subsection 460jjj-2(b). Locatable mineral 

development is similarly prohibited with 0.25 mile of the high water mark on either side of the 

East Fork of the Wild and Scenic Jemez River. As a result, nearly one-quarter of the project area 

is withdrawn from locatable mineral entry.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-23

3.6.1.1 Energy Resources in New Mexico

New Mexico is an energy exporter, producing 2.4 times as much energy as it consumes (New 

Mexico Energy, Minerals & Natural Resources Annual Report 2015). In 2014, New Mexico 

exported 13 million megawatt hours of electricity (EIA 2014). Coal, crude oil, natural gas, 

uranium, hydroelectric, solar, wind, and geothermal resources are all being developed in the 

state.

The state ranks sixth nationally in crude oil production, seventh in dry natural gas production, 

twelfth in coal production, 38th in electricity production. It is home to over a quarter of proven 

US coal-bed methane reserves, second only to Colorado. These resources are produced largely 

on federal lands, but approximately 25 percent is produced on state lands, with fractional 

amounts produced on private and tribal lands (EIA 2015b).

Electric utilities must meet the State’s renewable portfolio standard by including a State policydetermined proportion of renewable energies in their total generating capacity. Investor-owned 

utilities must have no less than 20 percent of their generation come from renewable energies by 

2020, while rural electrical cooperatives, like the Central New Mexico Electric Cooperative,

must have no less than 10 percent by 2020. In 2007, the New Mexico Public Regulation 

Commission issued an order requiring renewable generation used to meet the standard to include 

no less than 30 percent wind, 20 percent solar, 5 percent other renewable technologies, and 1.5

percent distributed generation (New Mexico Public Regulation Commission 2016).

Historically, coal and natural gas have been the major fuel sources for electrical generation in 

New Mexico. Since 1990, these fuels have accounted for over 90 percent of the state’s 

generation. Wind and solar accounted for 7 percent of that capacity, while hydro-electric and 

petroleum combined contributed less than 0.5 percent. In 2013, geothermal energy sources 

generated 0.0002 percent (or 69 megawatt hours) in the state (EIA 2016).

From 1870 to 1890, the US Army Corps of Engineers surveyed much of New Mexico and 

identified the following as geothermal waters: the San Ysidro Spring, Ojo Caliente, Ponce de 

Leon Warm Springs, San Antonio Hot Springs, San Antonio Warm Springs, Jemez Hot Springs, 

Montezuma Hot Springs, Apache Tejo Warm Springs, Faywood Hot Springs, and the Mimbres 

Hot Springs (Summers 1976).

In the mid-1960s, the State of New Mexico took on its own effort to inventory geothermal waters 

in the state. It identified sources in Gila River Basin, Rio Grande Basin, Pecos River Basin, 

Tularosa Basin, and San Juan River Basin, to varying extents (Summers 1976).

In the early 1980s, the New Mexico Energy and Minerals Department funded two projects to use 

geothermal energy, both outside of the project area. The first, at Carrie Tingley Hospital, used 

geothermal waters to heat a pool used for physical therapy treatments. The second used 

geothermal water as a low-temperature space heating system at a senior citizens center (Lund 

and Witcher 2002).

3.6.1.2 Energy Resources in the Santa Fe National Forest Project Area

The project area is in the Albuquerque-Santa Fe Rift province identified in the USGS National 

Oil and Gas Assessment (Molenaar 1995). There has been no oil or gas production in the project 

area, and none is expected during the next 20 years. There are no active or pending coal leases in 

the project area, and coal resources have not been identified there (Hoffman 1996). 
Chapter 3. Affected Environment and Environmental Consequences

3-24 Santa Fe National Forest Geothermal Leasing EIS

As discussed in Chapter 1, Purpose of and Need for Action, the project area contains the lands 

identified by SFNF as most likely to receive geothermal lease nominations and applications, 

based on the favorability of its geothermal resources (see Figure 1-3, Geothermal Potential 

Areas). However, no geothermal development has occurred in the project area to date, largely 

due to the lack of transmission lines there.

The RFDS prepared by SFNF (BLM 2015) projects development of 15 temperature gradient 

wells and 5 slim wells over the expected life of the plan. Development of five 25-MW binary 

power plants containing six wells each is also predicted. See BLM (2015) for detailed 

explanation of the different types of geothermal wells.

There are no active or pending proposals for wind energy in the project area, and there is little 

potential for wind energy development. There is no known potential for hydroelectric power in 

the project area.

3.6.1.3 Mineral Resources in New Mexico

The earliest mining in the region started around 1870 with the production of sheet mica (Bingler 

1968). This mineral is now used primarily in the electronic industry due to its unique electrical, 

insulating, and mechanical properties (Dolley 2008). As demand for sheet mica declined, a 

market for electrical mica grew through World War II. Since then, most of the mica mined in 

New Mexico has been processed for scrap mica (Dolley 2008). In the early twentieth century, 

mineral production was primarily for sand and gravel. However, some commercial development 

occurred for gold, silver, copper, lead, zinc, molybdenum, fluorite, and crushed and ornamental 

stones (Bingler 1968).

3.6.1.4 Mineral Resources in the SFNF Project Area

For many centuries, local populations in the SFNF used clay for ceramics and stones for 

buildings. Turquoise was commercially developed and transported from the area. High-grade 

copper deposits were also mined by the Spanish and Indians (Gillio 1979; Bingler 1968). Some 

lead was also mined for bullets.

There are no active mineral operations in the project area. The SFNF is offering portions of the 

project area for pumice mining through a competitive sale. Pumice deposits are common in and 

around the project area, due to ancient volcanic eruptions (Schwab et al. 2008).

While other minerals exist in the project area, known occurrences are too small and low grade to 

be economically mined and transported to processing plants. Therefore, development of other 

minerals in the project area is not expected during the life of the Forest Plan.

3.6.2 Environmental Consequences

3.6.2.1 Scoping Comments on Resource

There were no issues specific to energy and mineral resources identified during the public 

scoping period. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-25

3.6.2.2 How Resource Impacts Were Evaluated

Method

Impacts of energy and minerals were evaluated by examining whether leasing areas for 

geothermal resources would have the potential to impact mining, oil and gas leasing, and 

electricity generation or transmission or the subsequent development of those resources.

Indicators

The potential impacts of geothermal development were evaluated by assessing the impacts that 

anticipated future actions consistent with implementation of the alternatives described in 

Chapter 2 would have on energy and mineral resources. Geothermal leasing would have no 

direct impacts on energy and mineral resources. Impacts would occur from subsequent 

development. Potential impacts on energy and mineral resources could occur if reasonably 

foreseeable future actions were to have any of the following impacts: 

 Result in the construction of transmission lines that would affect the feasibility of other 

energy development along the transmission corridor

 Develop roads that would encourage other energy and mineral exploration in otherwise 

undeveloped areas

 Occupy portions of the project area in a manner that precludes extraction of other minerals 

or development of energy infrastructure

Assumptions

This analysis assumes the following: 

 If the prescription for an administrative designation, as described in the applicable land use 

plans, allows for geothermal leasing, then these areas could remain open to geothermal 

leasing, at the discretion of the Forest Supervisor. 

3.6.2.3 Common Impacts Associated with Geothermal Development 

Improving existing roads and constructing new roads for geothermal resource exploration, 

production, operation and reclamation and abandonment of geothermal resources would have a 

negligible to minor impact on the exploration for other energy and mineral resources in the 

immediate area. The degree of impact would depend on the existing limits to access in the area 

and the distance of the roads to the other mineral resources. Introducing new transmission lines 

would encourage developing other energy resources along the transmission line. Mineral 

resource developments would be encouraged due to the new availability of power for their 

operations. These impacts would be reduced with increased distance from mineral resources to 

the power plant, roads, and transmission lines. 

Drilling operations would hinder the development of other energy or mineral resources on the 

same land; however, after reclamation and abandonment of geothermal operations, developers of 

other energy sources could use the property. Any other ongoing operations in the area that use 

these facilities would have to take over maintenance of shared facilities, such as roads and

transmission lines, or they would also be reclaimed.

The extent of all of these impacts in the project area would be limited due to the low amount of 

current and expected energy and mineral development in the project area. While additional roads 

and transmission lines would encourage additional energy and mineral development, other 
Chapter 3. Affected Environment and Environmental Consequences

3-26 Santa Fe National Forest Geothermal Leasing EIS

limitations associated with those resources in the project area may still prevent their 

development.

3.6.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations.

The Forest Plan calls for sound energy and minerals exploration and development administered 

“to minimize adverse surface resource impacts.” It directs Forest supervisors to respond to 

geothermal lease applications in a timely manner; however, the availability of roads and utility 

corridors is subject to certain restrictions. For example, reconstruction and rehabilitation of 

existing roads is emphasized over new road construction. Roads constructed for mineral 

activities would be built and maintained by the permittee to minimum standards for the intended 

use. Similarly, utility corridors are prohibited in some management areas while placement in 

others would require extensive mitigation measures.

Under Alternative 1, the RFDS prepared by the SFNF (BLM 2015) predicts that fifteen 

temperature gradient wells, five slim wells, and five 25-MW binary power plants (with six wells 

each) would be developed in the project area over the life of the plan. Developing these facilities

could increase accessibility to otherwise undeveloped areas and result in the construction of 

transmission lines. However, there would be a negligible impact on other non-geothermal 

mineral and energy resources, due to the low amount of projected development.

3.6.2.5 Impacts Under Alternative 2

Under Alternative 2, the SFNF would manage approximately 17 percent of the project area as 

closed to geothermal leasing. Another 79 percent would be open, subject to NSOs, 48 percent 

would be open subject to CSUs, and 23 percent would be open subject to TLs.

2 Approximately 1 

percent of the project area would be open to geothermal leasing, subject to standard stipulations. 

In accordance with the RFDS (BLM 2015), the amount of expected geothermal development

would be the same as Alternative 1. Therefore, the impacts of that development on other energy 

and minerals resources would be the same as those described under Alternative 1.

3.6.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts described under Common Impacts Associated with Geothermal Development would not 

occur. There would continue to be a reliance on other forms of energy production and electrical 

generation in the region, the majority of which come from fossil fuels.

3.6.2.7 Impacts Under Alternative 4

Under Alternative 4, the SFNF would manage approximately 17 percent of the project area as 

closed to geothermal leasing. Another 73 percent would be open subject to NSOs, 73 percent 

would be open subject to CSUs, and 25 percent would be open subject to TLs. Approximately 2 

percent of the project area would be open to geothermal leasing, subject to standard stipulations.

 

2 The percentages add up to greater than 100 percent because some stipulations overlap.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-27

In accordance with the RFDS (BLM 2015), the amount of expected geothermal development

would be the same as Alternative 1. Therefore, the impacts of that development on other energy 

and minerals resources would be the same as those described under Alternative 1.

3.6.2.8 Cumulative Impacts

Geothermal development in the project area could change the electricity generation mix in New 

Mexico by increasing the proportion of geothermal energy used to provide electricity and 

decreasing the proportion associated with other energy sources. This would occur only where 

geothermal resources are developed to produce electricity, and not where they are developed for 

direct use. Under Alternatives 1, 2, and 4, the development of five 25-MW geothermal power 

plants in the project area would add up to 1.1 million megawatt hours per year of geothermalproduced electricity to New Mexico’s energy mix. The additional geothermal electricity 

generated would make up less than 1 percent of the total electricity produced in New Mexico; 

however, it would contribute to the state’s renewable energy standard mandate, calling for 5 

percent of an investor-owned utility’s electrical generation to come from renewable energies 

other than wind, solar, and distributed generation (EIA 2015b [Supply and Disposition of 

Electricity]; NMAC 17.9.572). 

Alternatively, Alternative 3, at a minimum, would maintain reliance on other forms of energy 

production and electrical generation – the majority of which are generated by burning fossil fuels 

like coal and natural gas.

3.7 Paleontological Resources

3.7.1 Affected Environment

Paleontological resources, or fossils, are the remains, imprints, or traces of once living organisms 

preserved in rocks, sediments, and caves. These include mineralized, partially mineralized, or 

unmineralized bones and teeth, soft tissues, shells, wood, leaf impressions, footprints, burrows, 

and microscopic remains. The fossil record is the only evidence that life on earth has existed for 

more than 3.6 billion years. Fossils are considered nonrenewable resources because the 

organisms they represent no longer exist (BLM and Forest Service 2008). 

Fossils are managed for scientific, educational, and recreational values, such as collecting 

invertebrate fossils and petrified wood for a hobby, and to protect these resources from any 

impacts. Primary regulations governing the protection and conservation of paleontological 

resources on federally administered lands includes the Antiquities Act of 1906 and the 

Paleontological Resource Preservation Act (Sections 6301-6312 of the Omnibus Public Lands 

Act of 2009, 16 USC, Section 470[aaa]). The Antiquities Act protects both historic and 

prehistoric resources on federal lands, and the Paleontological Resource Preservation Act 

provides specific protections for paleontological resources, mandating the management and 

preservation of those resources on public lands, using scientific principles and expertise. In 

addition, FLPMA (Public Law 94-579) requires that public lands be managed in a manner that 

protects the “quality of scientific” and other values, and NEPA requires protections for 

“important historic, cultural and natural aspects of our national heritage.” 

The SFNF issued nine reconnaissance/collecting permits for paleontological resources between

1997 and 2014. Seasonal interns researched, documented, and published paleontological work on 

northern New Mexico NFS lands in 2004. They identified 1,335 fossil localities in Rio Arriba, 

Sandoval, Santa Fe, Los Alamos, San Miguel, and Mora Counties. Of these sites, 240 are within 
Chapter 3. Affected Environment and Environmental Consequences

3-28 Santa Fe National Forest Geothermal Leasing EIS

the SFNF boundary or within a 2-mile buffer around the SFNF. The site data were used to 

determine the formations’ potential for vertebrate fossil occurrence (Forest Service 2015c). 

As required by Forest Service Manual 2882.6, the SFNF classified its NFS lands for fossil 

potential using the Paleontological Resources Rapid Assessment System (PRRAS), the results of 

the 2004 project, and more recent work. SFNF is using this information and PRRAS rankings to 

manage activities on NFS lands with the potential to disturb or degrade the scientific value of the 

paleontological resources. The PRRAS classification has the following categories: fossil 

occurrence likely (2), fossil occurrence likelihood unknown (1), and fossil occurrence unlikely 

(0). The project area includes geologic units classified as PRRAS 2, 1, and 0, as shown below

(Table 3-2).

Table 3-2. PRRAS Classification for Project Area

PRRAS 

Classification Geologic Units Acreage

Fossil occurrence 

likely (2)

Abo Formation, alluvium, Chinle Group, Cutler 

Formation, Dakota sandstone, Lower and Middle Santa 

Fe Group, Madera Formation, Mancos shale, Morrison 

Formation, piedmont alluvial deposits, San Andres 

limestone, Glorieta sandstone, Santa Fe Group, 

Paleogene sedimentary units, and Yesa Formation

68,800

Fossil occurrence 

likelihood 

unknown (1)

Landslide deposits and colluvium, basaltic volcanics, 

and Bandelier tuff

69,300

Fossil occurrence

unlikely (0)

Neogene basalt and andesite flows, Neogene volcanic 

rocks, silicic volcanic rocks, silicic to intermediate 

volcanic rocks, and Valles rhyolite

56,700

Sources: Forest Service 2015c; Forest Service GIS 2015

The project area includes 68,830 acres with geologic units classified as PRRAS 2 (likely fossil 

occurrence) (Forest Service 2015c). These geologic units mostly range in age from the Jurassic 

Era to the Early Pleistocene. Of particular importance are the deposits of Early Paleocene 

mammals that are extremely well preserved in these units. These deposits represent an excellent 

record of the rapid mammalian diversification, following the extinction of the dinosaurs at the 

end of the Cretaceous (BLM and Forest Service 2008). By the late Eocene, all the modern orders 

of mammals had evolved and were represented by species that were ancestral to the modern 

forms known today. As climates cooled, the tropical and subtropical forests of the Paleocene and 

early Eocene gave way to more open woodlands; continued global cooling and drying led to the 

evolution of grassland ecosystems during the Miocene. General adaptive strategies for 

mammalian groups at this time included an increase in body size, the ability to digest grasses, 

and a trend toward a greater emphasis on running. 

Decades of scientific investigation have recovered various fossil remains from these geologic 

units, including early reptiles, eohippus (the first horse), camelids, rhinoceroses, gomphotheres 

(ancestors of modern elephants), oreodonts, dogbears, large cats that could be considered sabertoothed, and many other extinct orders, families, and genera (Kues and Lucas 1979; SFNF 

2015). 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-29

3.7.2 Environmental Consequences

3.7.2.1 Scoping Comments on Resource

There were no issues specific to paleontological resources identified during the public scoping 

period.

3.7.2.2 How Resource Impacts Were Evaluated

Method

The PRRAS classification, described above in Table 3-2, describes the potential for 

paleontological resources within a given geological unit and the potential sensitivity that should 

be considered in project planning; however, it does not mean that paleontological resources are 

actually present within those specific units. 

The analysis area for paleontological resources is the project area. The potential impacts of 

geothermal development were evaluated by assessing the impacts that anticipated future actions 

under the alternatives would have on the paleontological resources.

Indicators

Potential impacts on paleontological resources could occur if anticipated actions consistent with 

implementing the alternatives described in Chapter 2 were to involve the following:

 Surface disturbance, such as building roads or preparing drill sites or plant sites, that could 

directly impact paleontological resources

 Surface disturbance that could expose geologic units with potentially important 

paleontological resources, leading to impacts from vandalism or unsupervised and 

unpermitted fossil collection

 Surface disturbance that could cause indirect impacts from increased erosion of important 

fossil resources

General indicators were evaluated, along with those considered in the Geothermal PEIS (BLM 

and Forest Service 2008).

Assumptions

This analysis assumes that leasing land for potential geothermal development does not involve 

ground-disturbing activities or any type of construction, so there would be no direct impact on 

paleontological resources. Any impacts would result from activities pursued after leasing.

3.7.2.3 Common Impacts Associated with Geothermal Development

The Geothermal PEIS (BLM and Forest Service 2008) provides a general description of 

common impacts on paleontological resources from geothermal resource development, although 

it is not possible to predict specific future development scenarios, including types of 

development, timing, and location. 

Impacts on nonrenewable surface or subsurface paleontological resources, particularly those 

involving PRRAS 2 classifications (fossil occurrence likely), could result from destruction by 

breakage and crushing during surface-disturbing actions. Surface disturbance related to 

geothermal development has the potential to impact an unknown quantity of fossils that may 
Chapter 3. Affected Environment and Environmental Consequences

3-30 Santa Fe National Forest Geothermal Leasing EIS

occur on or underneath the surface in areas containing paleontologically sensitive geologic units 

classified as PRRAS 2 (fossil occurrence likely). 

Without mitigation, these fossils, as well as the paleontological data they could provide if 

properly salvaged and documented, could be destroyed, rendering them permanently 

unavailable. Impacts can typically be mitigated to below a level of significance by implementing 

CSU or NSO stipulations, such as avoiding or minimizing work in areas with PRRAS 2

classifications (fossil occurrence likely). Mitigation also results in the salvage of fossils that may 

never have been unearthed as the result of natural processes. With mitigation, these newly 

exposed fossils become available for scientific research, education, display, and preservation into 

perpetuity at a public museum. 

Impacts also result from the continuing implementation of management decisions and associated 

activities. For paleontological resources, impacts most commonly occur as the result of 

management actions that increase the accessibility of public lands, increasing the potential for 

loss of paleontological resources by vandalism or unsupervised and unpermitted collecting 

(poaching). These impacts are difficult to mitigate to below the level of significance, but they 

can be greatly reduced by increasing public awareness about the scientific importance of 

paleontological resources through education, community partnerships, and interpretive displays 

and by informing the public about penalties for unlawfully destroying or collecting these 

resources. 

3.7.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analyses, in accordance with the Forest Plan (Forest Service 1987) and existing laws and 

regulations. There would be no impacts on paleontological resources in the JNRA.

Geothermal lease stipulations and closures would not be specifically implemented on 

paleontological resources outside of the JNRA; however, any geothermal lease applications and 

nominations would be subject to the standards and guidelines outlined in the Forest Plan and 

subsequent environmental analysis. The types of impacts that could occur would be the same as 

those described under Common Impacts Associated with Geothermal Development.

3.7.2.5 Impacts Under Alternative 2

Impacts under Alternative 2 on paleontological resources would be similar to those described 

under Alternative 1. However, additional lands would be identified as closed to leasing or subject 

to NSO, CSU, and TL stipulations. Closures and stipulations would not be specifically 

implemented for paleontological resources; however, closures and stipulations for other 

resources would also protect geologic units with likely fossil occurrences. In PRRAS 2, 8,400 

acres would be closed to geothermal leasing, 39,400 acres would be subject to NSO stipulations, 

and 25,700 acres would be subject to CSU stipulations (Forest Service GIS 2015). 

In accordance with BMPs identified in Appendix C, if paleontological resources are present at a 

site, or areas with a high potential to contain paleontological material have been identified, a 

paleontological resource management plan would be developed. The potential is low for 

geothermal development to impact sensitive geologic units (those classified PRRAS 2 [fossil 

occurrence likely]), considering geothermal leasing closures, stipulations, and BMPs. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-31

3.7.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts on paleontological resources described under Common Impacts Associated with 

Geothermal Development would not occur.

3.7.2.7 Impacts Under Alternative 4

Impacts under Alternative 4 on paleontological resources would be similar to those described 

under Alternative 2; however, fewer acres of PRRAS would be subject to NSO stipulations and 

closures, and more acres would be subject to CSU stipulations. In PRRAS 2, 7,800 acres would 

be closed to geothermal leasing, 35,900 acres would be subject to NSO stipulations, and 35,800 

acres would be subject to CSU stipulations. The potential is low for geothermal development to 

impact sensitive geologic units (those classified PRRAS 2 [fossil occurrence likely]), 

considering geothermal leasing closures, stipulations, and BMPs.

3.7.2.8 Cumulative Impacts

Consenting to issue a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any potential future development of geothermal resources may result in 

impacts, whether deemed significant or not. It is reasonable, therefore, to foresee that cumulative 

impacts on sensitive geologic units (those classified PRRAS 2 [fossil occurrence likely]) could 

occur if the Forest Service were to consent to leasing and the BLM were to issue geothermal 

leases under Alternatives 1, 2, and 4. Those impacts would not occur, however, until some point 

in the future, following further decision-making under NEPA. Moreover, the use of CSU or NSO

stipulations would likely minimize or avoid impacts on paleontological resources. 

Alternative 3 would have no cumulative impacts on paleontological resources.

3.8 Soil Resources

3.8.1 Affected Environment

The soils of the project area are primarily characterized by those typical of the region. The 

primary soil classifications in the project area are inceptisols, alfisols, entisols, and mossisols. 

Specific soil types and distributions by unit can be found in the Soils and Water Specialist Report 

(Forest Service 2016c). 

3.8.1.1 Soil Erosion

The soil erosion hazard is a measure of the susceptibility of the soil to erode when its surface is 

exposed to water. A rating of severe indicates that predicted potential soil loss rates have a high 

probability of reducing site productivity due to erosion. Table 3-3, below, summarizes the area 

of severe erosion hazard by unit. The project area includes 107,775 acres of severe erosion 

hazard, making up 55 percent of the entire project area. Over 82 percent of the area in the Lease 

Interest Unit and Middle Unit is rated as severe. Locations of areas with severe soil erosion 

hazard are depicted in the Soils and Water Specialist Report (Forest Service 2016c).
Chapter 3. Affected Environment and Environmental Consequences

3-32 Santa Fe National Forest Geothermal Leasing EIS

Table 3-3. Soil Characteristics of the Project Area

Unit

JNRA

Unit

Lease 

Interest 

Unit

Middle 

Unit

North 

Unit

South 

Unit Totals

Area of Severe Erosion Hazard per Unit in Project Area

Area of severe erosion hazard 

in unit (acres)

18,880 32,561 11,528 29,460 15,346 107,775

Percent of unit with severe 

erosion hazard

48 83 82 43 45 55

Percent of Each Wind Erodibility Group per Unit in the Project Area

WEG 1 0 0 0 0 1 0

WEG 2 0 0 0 23 0 8

WEG 3 0 0 0 14 0 5

WEG 4L 12 29 33 5 12 14

WEG 5 21 12 61 10 6 16

WEG 7 35 59 0 42 65 45

WEG 8 33 0 6 7 15 12

Percent of Each Hydrologic Soil Group per Unit in the Project Area

A: Low runoff potential/high 

infiltration rate

0 0 0 0 0 0

B: Moderately low runoff 

potential

68 21 67 56 45 50

C: Moderately high runoff 

potential

0 41 0 19 0 15

D: High runoff potential/very 

slow infiltration rate

32 38 33 25 55 35

Sources: Forest Service 2016c

3.8.1.2 Wind Erodibility

The wind erodibility group (WEG) is a Natural Resources Conservation Service (NRCS) 

designation for a grouping of soils that have similar properties affecting their susceptibility to 

wind erosion. The ranking ranges from 1 to 8, with 1 being the most susceptible to wind erosion. 

Data group 1 is fine sand, sand, and coarse sand. A data group of WEG 8 would indicate soils 

that are not susceptible to wind erosion due to rock and pararock3fragments at the surface. Table 

3-3, Soil Characteristics of the Project Area, summarizes the percent of land in each WEG by 

project area unit. 

The soils of the project area are not particularly susceptible to wind erosion, with the exception 

being some of the soils in the North Unit. Across the project area, 73 percent is covered by soils 

that are categorized as WEG 5 or higher, with large tracts of land (57 percent of the project area) 

categorized as WEG 7 or 8. Locations of WEG designations are depicted in the Soils and Water 

Specialist Report (Forest Service 2016c).

 

3

Soft rock fragments
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-33

3.8.1.3 Soil Runoff Potential

A hydrologic soil group is soils that have similar runoff potential under similar storm and cover 

conditions. The classification reflects the soil’s runoff potential from rainfall. The rankings range 

from A to D, with A being the lowest runoff potential and highest infiltration rates and D having 

the highest runoff potential and lowest infiltration rates. Table 3-3, Soil Characteristics of the 

Project Area, summarizes the percent of area covered by each hydrologic soil group by project 

unit. 

The soils in the project area tend to have a moderate to high runoff potential. Seventy-nine 

percent of the Lease Interest Unit area has either a moderately high or high runoff potential. The 

locations of hydrologic soil group designation in the project area are depicted in the Soils and 

Water Specialist Report (Forest Service 2016c).

3.8.1.4 Shrink/Swell Potential

Shrink/swell potential is the relative change in volume to be expected with changes in moisture 

content. The change in volume can exert enough force on a building or structures to cause 

structural damage to buildings, other structures, and roads. Most of the project area has a low 

shrink/swell potential, but the Lease Interest Unit has a few larger areas of moderate shrink/swell 

potential. Shrink/swell potential is further described in the Soils and Water Specialist Report 

(Forest Service 2016c).

3.8.2 Environmental Consequences

3.8.2.1 Scoping Comments on Resource

There were no issues specific to soil resources identified during the public scoping period. 

3.8.2.2 How Resource Impacts Were Evaluated

Method

Available soils data for the project area was analyzed to determine the susceptibility of the soils 

to erosion and potential transport by surface flow. The analysis also examines areas of expansive 

soils where construction may be difficult. 

The soil erosion hazard data are from the Terrestrial Ecological Unit Inventory, which classifies 

ecological types and maps terrestrial ecological units to a consistent standard throughout NFS 

lands (Forest Service 2005). 

The WEG is soils that have similar properties affecting their resistance to soil blowing. These 

data were adopted from the NRCS.

The Digital General Soil Map of the United States, or STATSGO2, is a broad-based inventory of 

soils and non-soil areas that occur in a repeatable pattern on the landscape and that can be 

mapped at the scale of 1:250,000 in the continental United States. The United States General Soil 

Map is composed of general soil association units and is maintained and distributed as a spatial 

and tabular dataset from the NRCS. This level of soils data was used for the existing condition of 

soils in the project area. 
Chapter 3. Affected Environment and Environmental Consequences

3-34 Santa Fe National Forest Geothermal Leasing EIS

Indicators

The consent or denial of NFS lands for geothermal leasing and the issuance of geothermal leases 

would not directly impact soils. However, indirect impacts would result from future construction 

and operation of geothermal energy projects in the project area, based on future leases. Indicators 

of impacts of the proposed action and alternatives are as follows:

 Susceptibility of soils in the project area to water erosion, as measured by the soil erosion 

hazard

 Susceptibility of soils in the project area to wind erosion, as measured by the WEG

 Potential for runoff and sediment transport in the project area, as measured by the hydrologic 

soil condition

 Area of expansive soils (shrink/swell potential)

Assumptions

 The potential impacts of the alternatives were evaluated on the basis of extent of area that 

would be open for exploration and development and the general presence of easily eroded 

soils.

3.8.2.3 Common Impacts Associated with Geothermal Development

A detailed description of geothermal development operations relative to soil resources is in the 

2008 Geothermal PEIS (BLM and Forest Service 2008) and is summarized in this section. 

Common impacts on soil resources from geothermal development are physical disturbance (such 

as movement or removal), compaction, and changes to erosion patterns. 

Impacts on soils could include direct disturbance due to development of roads and facilities 

associated with exploration and development of geothermal production sites. Development could 

lead to erosion and sedimentation of soils. There would be some loss of soil productivity. 

Exposed soil surfaces would be vulnerable to the impacts of wind and surface water runoff 

during construction and operations.

Surface water erosion could remove some soils from the disturbed sites, potentially carrying 

them into streams and other water resources. In addition, some areas may be subject to 

deposition of wind-blown material outside the footprint of construction areas or the loss of soil 

due to wind erosion. 

Soils would be directly impacted by grading activities during construction. The degree of risk of 

erosion and transport due to water and wind depends on the eventual location of disturbances, 

such as roads and facilities.

There would be a long-term commitment of soil resources in areas that are converted to non-soil 

surfaces (such as geothermal structures and ancillary facilities) and therefore removed from 

productive use. This loss may be temporary, as in disturbance surrounding sites or along edges of 

roads, or long term, due to construction of impermeable surfaces, such as drilling pads and 

power plants. The loss is not permanent, because all surfaces would be reclaimed if exploration 

is unsuccessful or after production ceases. 

3.8.2.4 Impacts Under Alternative 1—No Action

Alternative 1 would have the same general impacts on soil resources associated with the RFDS

as described under Common Impacts Associated with Geothermal Development, above. Although 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-35

the SFNF would not make an availability determination for geothermal leasing in the project 

area, geothermal lease applications and nominations would continue to be processed on a caseby-case basis under separate NEPA analysis, in accordance with the Forest Plan (Forest Service

1987) and existing laws and regulations. 

Geothermal leasing stipulations and closures would not be specifically implemented related to 

soil resources; however, any future geothermal lease applications and nominations would be 

subject to standards and guidelines outlined in the Forest Plan and environmental analysis. 

3.8.2.5 Impacts Under Alternative 2—Proposed Action

Under Alternative 2, impacts from anticipated geothermal exploration and development would 

generally be the same as those described under Alternative 1; however, the location of potential 

sites would be restricted by administrative withdrawals and stipulations. Approximately 32,000 

acres, or 17 percent of the NFS lands in the project area, would be closed to geothermal leasing; 

approximately 136,650 acres would be allocated as open to geothermal leasing, subject to 

existing laws, regulations, formal orders, and stipulations.

Implementing NSO stipulations on soils with severe erosion hazard would limit the amount of 

potential erosion from soil disturbance. Preventing facility development on slopes in excess of 

40 percent would further limit both erosion and sediment transport potential. This would 

minimize the potential impacts, particularly in areas that do not have a severe erosion hazard 

(and therefore are subject to NSO) but do have a high runoff potential. However, roads and 

powerlines could still likely cross areas of severe erosion hazard and potentially areas of steep 

slopes; therefore, there would still be a risk of erosion and transport due to road construction, 

reconstruction, use, eventual reclamation, and powerline construction. In all units, BMPs

identified in Appendix C could be implemented to minimize any potential impacts.

3.8.2.6 Impacts Under Alternative 3

There would be no direct impacts on soils under Alternative 3. No surface areas would be 

disturbed by geothermal developments. However, there would be indirect impacts on soil 

resources. Because the area would be closed to leasing for the foreseeable future, over time, 

there would be less soil disturbance than expected under the implementation of the current Forest 

Plan.

3.8.2.7 Impacts Under Alternative 4

Impacts on soils would be similar to those described under Alternative 2. However, allowing 

surface occupancy on areas of severe erosion hazard by implementing only CSU stipulations on 

these soils would increase the risk of erosion and sediment transport in areas disturbed for 

exploration and development of geothermal sites under Alternative 4. This would be a particular 

concern on steeper slopes of between 30 and 40 percent and areas with moderately high to high 

runoff potential. Implementing BMPs identified in Appendix C to minimize and contain any 

erosion could reduce the impacts on soil productivity.

3.8.2.8 Cumulative Impacts

Cumulative impacts for soil resources are analyzed at the sixth-level watersheds that overlap or 

encompass the project area. Past, present, and reasonably foreseeable future actions are 

discussed in Section 3.3.4. 
Chapter 3. Affected Environment and Environmental Consequences

3-36 Santa Fe National Forest Geothermal Leasing EIS

Water resource repair and replacement projects—the Pueblo of Jemez Red Rocks Dam Repair, 

the Abiquiu Land Grant Waterline Replacement, and the McKinney County Dam—will initially 

directly impact soil resources through digging and removing soil resources. These surfacedisturbing activities could cause additional erosion and sedimentation into waterways. Mineral 

development projects—the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine—would involve significant soil disturbance for expansion and operation. These activities 

could increase erosion and reduce soil productivity.

Restoration projects, such as the Southwest Jemez Mountains Restoration Project, Pueblo of 

Jemez Owl Springs Bridge Sediment Removal Project, and Valle Seco Wetland Restoration 

Project, would maintain or improve soil conditions in their respective project areas by removing 

sedimentation and reducing erosion.

Sedimentation and erosion would likely occur from geothermal development, combined with 

natural processes, such as fires in project area watersheds. The intensity of the combined impacts 

of fires and geothermal development will depend on the size and severity of the fire, as well as 

local soil conditions.

There would be the fewest cumulative impacts under Alternative 3, due to the restriction of 

leasing in the entire project area. Cumulative impacts over the remaining alternatives would be 

similar, due to the RFDS; however, Alternatives 1 and 4 would likely have the greatest intensity, 

due to a lack of or reduction of restrictive stipulations on geothermal development. 

3.9 Water Resources

3.9.1 Affected Environment

3.9.1.1 Watersheds and Surface Water

The project area lies in the Rio Grande River Basin. The Rio Grande flows from its headwaters

in southern Colorado through New Mexico to the border with Mexico, where it turns eastward 

and marks the border between Mexico and Texas before emptying into the Gulf of Mexico.

Tectonic rifting has defined the route of the Rio Grande through New Mexico over millions of 

years and has resulted in intense volcanism in the basin. Valles Caldera, surrounded by the 

project area boundary on three sides, is one of the world’s largest and youngest calderas. Magma 

underlying the caldera is the source of the geothermal heat in the region.

The project area includes parts of three fourth-level watersheds4of the Rio Grande system: 

Jemez River, Rio Chama, and Rio-Grande-Santa Fe. The three four-level watersheds are further 

defined as sixth-level watersheds. Parts of 22 nested sixth-level sub-watersheds are included in 

the project area. Figure 3-1 shows a map of the sixth-level watersheds within the project area 

(Watershed Boundary Dataset GIS 2016).

 

4 The United States is divided and subdivided into successively smaller hydrologic units. The fourth-level 

of classification is the cataloging unit. It is a geographic area representing part or all of a surface drainage 

basin, a combination of drainage basins, or district hydrologic features. The fourth-level watersheds are 

further divided into fifth and sixth levels, where the sixth-level watershed is the smallest subdivision, 

normally encompassing between 10,000 and 40,000 acres. Each hydrologic unit is assigned a name 

corresponding to its principal hydrologic feature or to a cultural or political feature in the unit. 

Chapter 3. Affected Environment and Environmental Consequences

3-38 Santa Fe National Forest Geothermal Leasing EIS

Some of the sixth-level watersheds overlap the project area to a very minimal extent. However, 

should activities in these overlapped areas be proposed, the activities could affect watershed 

conditions, both in the project area and in the larger watershed that extends outside of the project 

area. Therefore, the watershed analysis takes into account all sixth-level watersheds that overlap 

part of the project area. Fourth and sixth-level watersheds and their relation to the project area 

are shown in the Soils and Water Specialist Report (Forest Service 2016c).

Surface water flows in the Rio Grande Basin originate primarily in the high mountain elevations 

as snow melt during the spring and as monsoonal rainfall during the late summer. Typically, the 

river reaches its highest discharge between April and June, with its peak levels in May. Natural 

flows also show variation from year to year due to drought and climate variability (New Mexico 

Office of the State Engineer 2006). The northern extent of the leasing area, north of the VCNP is 

part of the Upper Rio Grande Basin and includes the Rio Chama watershed. The Jemez 

Watershed is in the southern part of the leasing area and includes the Jemez River, the only 

perennial tributary to the Middle Rio Grande Basin.

The annual flow of the Rio Grande is quite variable. One-third of the approximately 1.1 million 

acre-feet (long-term average) of native Rio Grande surface water that leaves the Upper Rio 

Grande comes from Colorado, one-third comes from the Sangre de Cristo Mountains, and 

another third comes from the Rio Chama watershed. Water storage on the Upper Rio Grande 

includes waters stored in reservoirs on the Rio Chama, including storage of San Juan Chama 

Project water. The reservoirs are Heron, El Vado, and Abiquiu (New Mexico Office of the State 

Engineer 2006). The Abiquiu Reservoir is just north of the project area. (Flow is measured at the 

Otowi stream flow gage.)

The project area is in the Jemez Mountains, where warm springs originating from subsurface 

geothermal activity have long been used for bathing and therapy. The Jemez Mountains are 

relatively wet in comparison to the dryer and lower surrounding country. Part of this 

precipitation, in the form of rain or snow melt, runs off or is lost to evapotranspiration, but the 

rest infiltrates and is stored as groundwater. The water supports a dense forest in the high 

country. The Valles Caldera, surrounded by the project area on three sides, is a defining terrain 

unit. The Jemez River drains the caldera on the west and then flows south through the project 

area. The Rio Chama drains the caldera on the north.

Jemez River Watershed

The Jemez Watershed is a fourth-level watershed that covers 44 percent of the project area, 

primarily in the southwest and south-central portions, and along the east edge of the VCNP. All 

of the Middle Unit, the southernmost spur of the Leasing Unit, and approximately the western 

two-thirds of the JNRA Unit and the South Unit are in this watershed. The surface waters 

draining the Valles Caldera are collected by this watershed’s streams, including the Jemez River

and San Antonio Creek. 

There are six hot springs located in this watershed. There are also two drinking water sources, 

one in the JNRA Unit and the other in the southern end of the South Unit.

Ongoing processes and existing conditions in the Jemez Watershed include high sediment 

erosion and water runoff as the result of forest fires. In addition, the lowering of valleys by river 

incision is a continuing process. Many valleys are flanked by terraces. Rivers respond by 

aggrading during climates that promote large sediment yield and large, stable discharges, and 

incising during climates that produce flash flows and reduce the sediment supply (NRCS 2011c).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-39

There are 10 sixth-level watersheds in the Jemez fourth-level watershed that are partially within 

the project area, as follows: 

 Cañon de la Canada

 Church Canyon-Jemez River

 East Fork Jemez River

 Headwaters Rio Cebolla

 Headwaters San Antonio Creek

 Outlet Rio Cebolla

 Outlet San Antonio Creek

 Sulphur Creek

 Vallecita Creek

 Virgin Canyon

Rio Chama Watershed

The Rio Chama Watershed is a fourth-level watershed that covers approximately 49 percent of 

the project area, including all of the North Unit and most of the northern portion of the Proposed 

Leasing Unit. Waters draining the north-facing sides of the Valles Caldera and the northern 

Nacimiento Mountains, as well as adjacent mountains and valleys, are channeled to the Rio 

Chama and the Abiquiu Reservoir. Eventually these waters lead to the Rio Grande, north of the 

project area. There are three drinking water wells along the northern edge of the project area in 

this watershed. There are no natural thermal features in the portion of this watershed that covers 

the project area.

The western boundary of the larger Rio Chama Watershed is formed by the Continental Divide 

and the northeastern edge of the Jemez Mountains. In the east, the watershed is hemmed in by 

the Tusas Mountains and Black Mesa. The Rio Chama headwaters drain the southern San Juan 

Mountains, and the river ends at its confluence with the Rio Grande, near Espanola, New 

Mexico. The upland areas of the drainage basin are significant contributors to Rio Chama flows, 

resulting in snowmelt-dominated hydrology. 

Mean annual precipitation in the basin ranges from 9 to 53 inches, with values dependent on 

elevation (NRCS 2011a). Ongoing processes and existing conditions in the Rio Chama

Watershed include high sedimentation rates caused by landslides in the Mancos shale and high 

sediment erosion and water runoff as the result of forest fires. In addition, the lowering of valleys 

by river incision is a continuing process. 

There are seven sixth-level watersheds of the larger Rio Chama Watershed that occupy portions 

of the project area, as follows:

 Cañones Creek

 Cañones Creek-Abiquiu Reservoir

 Coyote Creek

 Headwaters Rio Puerco

 Outlet Rio Puerco

 Poleo Creek

 Polvadero Creek
Chapter 3. Affected Environment and Environmental Consequences

3-40 Santa Fe National Forest Geothermal Leasing EIS

Many of these sub-watersheds have impairments, due to bank instability and lack of a healthy 

riparian zone. These impairments have resulted in excess sediment and higher stream 

temperatures (Levine et al. 2015). 

The greatest land use in the Rio Chama Watershed by area is rangeland. Impairments are typical 

of streams impacted by improper grazing management, which can cause a loss of riparian

vegetation, increase habitat and seed source for invasive species that compete with native 

species, and degrade banks, leading to erosion and sedimentation.

Rio Grande-Santa Fe Watershed

The Rio Grande-Santa Fe Watershed is a fourth-level watershed that covers just 7 percent of the 

project area. It is in the southeastern extent, on the eastern side of the JNRA Unit, and the eastern 

side and southern edge of the South Unit. Waters drain into this watershed from the southeastfacing slopes of the Valles Caldera, joining several streams and canyons leading to the Cochiti 

Reservoir and eventually the Rio Grande. This watershed contains the headwaters of Capulin 

Creek, which is one of only two perennial steams in Bandelier National Monument. There are no 

drinking water wells or natural geothermal features in the portion of this watershed that is in the 

project area.

Outside of the project area, portions of the Rio Grande-Santa Fe Watershed extend into 

Bernalillo, Los Alamos, San Miguel, Sandoval, and Santa Fe Counties. Elevations range from 

5,000 to 13,153 feet and precipitation ranges from 9 to 43 inches annually, depending on 

elevation.

The hydrologic unit begins at Otowi, west of Pojoaque, New Mexico, in the Upper Rio Grande

Valley. Farther downstream, the river enters Cochiti Lake, which marks the northern boundary of 

the Middle Rio Grande Valley. The hydrologic unit continues downstream to the confluence with 

the Jemez River. 

Ongoing processes and existing conditions in the Rio-Grande Santa Fe Watershed are high 

sediment erosion and water runoff as the result of forest fires. In addition, the lowering of valleys 

by river incision is a continuing process. This can be exacerbated by mining sand and gravel 

from the river channels.

There are five sixth-level watersheds in the Rio Grande-Santa Fe watershed in the project area, 

as follows: 

 Alamo Canyon-Rio Grande

 Capulin Canyon-Rio Grande

 Headwaters Borrego Canyon

 Peralta Canyon

 Rio Chiquito

100-Year Floodplains

One hundred-year floodplains in the project area are delineated in accordance with the Federal 

Emergency Management Act and are shown in the Soils and Water Specialist Report (Forest 

Service 2016c). Most of the delineated areas are in the JNRA Unit, along the Jemez River, 

including the Cañon de San Diego, and extending slightly into San Antonio and Sulphur Creeks. 

There is also a small section of the East Fork of the Jemez River that crosses into the JNRA Unit 

that is delineated as a 100-year floodplain. There is also a 100-year floodplain in the portion of 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-41

the Middle Unit that is crossed by the Rio Cebolla. The delineation of this floodplain extends 

into the southwestern corner of the Lease Interest Unit. There are also several small sections of 

tributaries to the Rio Puerco, along the northern edge of the North Unit, that include 100-year 

floodplains.

Beneficial Uses

The basic authority for water quality management in New Mexico is provided through the State 

Water Quality Act. It establishes the New Mexico Water Quality Control Commission 

(NMWQCC), which is the state water pollution control agency for purposes of the federal Clean 

Water Act. New Mexico’s water quality standards define water quality goals by designating uses 

for rivers, streams, lakes, and other surface waters. The waters are classified by the uses for 

which they are presently suitable or intended to become suitable. The standards set criteria to 

protect these uses and establish anti-degradation provisions to preserve water quality. The 

standards are adopted by the NMWQCC, then approved by the EPA under the federal Clean 

Water Act. 

The New Mexico Environment Department (NMED) is responsible for implementing the federal 

Clean Water Act in New Mexico and ensuring that surface waters meet their designated

beneficial uses and New Mexico state water quality standards. The beneficial uses of the sixthlevel project area watersheds are presented in the Soils and Water Specialist Report (Forest 

Service 2016c). All of the watersheds have the beneficial use of livestock watering/wildlife 

habitat. 

Clean Water Act, Section 303(d), Impaired Surface Waters and Total Maximum Daily 

Loads

Under the Clean Water Act, Section 303(d), states, territories, and federally recognized tribes that 

have obtained treatment in a similar manner as states are required to develop lists of impaired 

waters. These are waters that are too polluted or otherwise degraded to meet the water quality

standards set by the states, territories, or tribes. The law requires that these jurisdictions establish 

priority rankings for waters on the lists and develop a Total Maximum Daily Load (TMDL) for 

these waters (see the Soils and Water Specialist Report [Forest Service 2016c]). TMDL is a 

calculation of the maximum amount of a pollutant that a water body can receive and still safely 

meet water quality standards. The NMWQCC is the issuing agency of water quality standards for 

interstate and intrastate waters in New Mexico.

In the Jemez Watershed there is one body of water, the 23.81-acre Fenton Lake, with a maximum 

volume estimated at 264 acre-feet, that is listed as impaired as of the 2010 to 2012 listing cycle. 

Fifteen reaches of the Jemez Watershed are in the sixth-level watersheds that overlap the project 

area and are listed as Section 303(d) impaired surface water. Natural conditions contribute to 

high aluminum concentrations throughout the Jemez Watershed, and impacts on aquatic life are 

unclear. Many sixth-level watersheds in the Jemez Watershed have aluminum listings, but no 

TMDLs have been identified yet. 

In the Rio Chama Watershed there are seven reaches in the sixth-level watersheds that overlap 

the project area and are listed as Section 303(d) impaired surface waters. 

The Rio Grande-Santa Fe Watershed contains one reach in the sixth-level watersheds that 

overlap the project area and is listed as a Section 303(d) impaired surface water. 
Chapter 3. Affected Environment and Environmental Consequences

3-42 Santa Fe National Forest Geothermal Leasing EIS

The Soils and Water Specialist Report identifies specific reaches that have been listed as Section 

303(d) impaired surface waters.

Watershed Condition Class

The watershed condition framework is a comprehensive approach for restoring priority 

watersheds on national forests and grasslands (Forest Service 2011). It also provides a consistent 

way to evaluate watershed conditions at both the national and forest levels. Further explanation 

of this metric can be found in the Soils and Water Specialist Report (Forest Service 2016c).

The Forest Service completed an assessment of all sixth-level Watersheds on National Forests in 

2011. It rated the condition of each watershed as properly functioning, functioning at risk, or 

functionally impaired. The watersheds were also given ratings for twelve condition indicators.

None of the sixth-level watersheds in the analysis are considered to be properly functioning. Two 

of the watersheds, Headwaters Rio Cebolla and Outlet San Antonio Creek, are functionally 

impaired. Both are sub-watersheds of the fourth-level Jemez Watershed and together cover most 

of the Middle Unit.

Throughout all of the sixth-level watersheds, the categories that are consistently of concern are 

riparian and wetland vegetation, roads and trails, soil condition, and fire impacts. None of the 

watersheds scored “good” in these categories. For both roads and trails and soil condition, only 

two watersheds scored “fair”: Cañones Creek-Abiquiu Reservoir for soil condition and Outlet 

Rio Puerco for road and trails. All the other watersheds were classified as “poor” for these 

categories. 

These categories are indicators of the following concerns:

 Riparian and wetland vegetation—Vegetation condition

 Roads and trails—Open road density, road maintenance, proximity to wear, and mass 

wasting

 Soil Conditions—Soil productivity, soil erosion, and soil contamination

 Fire impacts—Fire condition class or wildfire impacts

Watershed Erodibility Index and Road Density

The watershed erodibility index is an indicator of the vulnerability of a watershed to erosion and 

sedimentation from disturbances determined by evaluating the risk of both erosion and transport 

to streams. This index weights the area in each watershed covered by each erodibility-transport 

risk (slight, moderate, severe, or very severe). This provides an overall watershed index number 

that allows watersheds to be compared to each other and illustrates relative risk across the 

watershed. The index ranges from 1 to 4, with 1 indicating the entire watershed has only a slight 

erodibility-transport risk, and 4 indicating that the entire watershed would have a very severe 

erodibility-transport risk. More information on the method for creating this index number can be 

found in the Soil and Water Specialist Report (Forest Service 2016c). The watershed erodibility 

index rating across all of the sixth-level watersheds that overlap portions of the project area 

ranges from 1.2 to 1.9, with an average of 1.5 (see Table 3-4, below).

Problems with road density and poor maintenance can also manifest in soil erosion by resulting 

in deficiency of drainage, modification of water runoff, and excessive loading of slopes resulting 

in mass movement such as landslides. Additionally, roads can convert subsurface runoff to 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-43

Table 3-4. Watershed Erodibility Index

Watershed Name Percent of Watershed

in Project Area

Road Density (Miles of 

Road per Square Mile)

Watershed Erodibility 

Index Rating

Fourth-Level Watershed: Jemez 

Cañon de la Cañada 72.1 5.6 1.2

Church Canyon-Jemez 

River

77.6 6.1 1.3

East Fork Jemez River 15.1 3.9 1.6

Headwaters Rio Cebolla 70.1 10.5 1.3

Headwaters San 

Antonio Creek

1.6 5.5 1.5

Outlet Rio Cebolla 16.3 6.5 1.3

Outlet San Antonio 

Creek

69.5 7.1 1.6

Sulphur Creek 11.0 3.0 1.9

Vallecita Creek 50.0 6.1 1.3

Virgin Creek 22.1 5.0 1.3

Fourth-Level Watershed: Rio Chama

Cañones Creek 82.0 12.3 1.5

Cañones Creek-Abiquiu 

Reservoir

21.1 2.5 1.2

Coyote Creek 99.6 6.8 1.6

Headwaters Rio Puerco 21.1 5.7 1.8

Outlet Rio Puerco 47.5 3.3 1.4

Poleo Creek 1.3 7.9 1.7

Polvadero Creek 21.2 5.1 1.7

Fourth-Level Watershed: Rio Grande-Santa Fe 

Alamo Canyon-Rio 

Grande

6.0 2.9 1.5

Capulin Canyon-Rio 

Grande

2.1 2.0 1.3

Headwaters Borrego 

Canyon

0.9 3.1 1.2

Peralta Canyon 9.1 1.4 1.5

Rio Chiquito 28.8 5.3 1.5

Source: Forest Service 2016c

surface runoff and then route the surface runoff to stream channels, increasing peak flows 

(Megan and Kidd 1972; Ice 1985; Swanson et al. 1987). Roads can also divert stream channels 

to adjacent channels through surface runoff, increasing discharge and peak flow to the receiving 

channel and decreasing discharge and peak flows to the diverted channel. Therefore, watersheds

with higher road densities have a higher risk of sedimentation of stream channels when there are 

disturbances in the watershed. The average road density for all sixth-level watersheds that 

overlap the project area is 5.3 miles of road per square mile.
Chapter 3. Affected Environment and Environmental Consequences

3-44 Santa Fe National Forest Geothermal Leasing EIS

3.9.1.2 Groundwater

The Rio Grande Aquifer System

The groundwater in the project area is in the Rio Grande aquifer system, which is the principal 

aquifer in a 70,000-square-mile area of southern Colorado, central New Mexico, and western 

Texas. The Rio Grande Aquifer is an unconsolidated sand and gravel system, consisting of a 

network of hydraulically interconnected aquifers in basin-fill deposits along the Rio Grande 

Valley and nearby valleys. Although some volcanic rocks (like those that make up the majority 

of the bedrock in the project area), solution-altered carbonate rocks, or extensively fractured 

beds can yield water in specific areas, the bedrock underlying the Rio Grande Valley and aquifer 

is relatively impermeable. However, the bedrock in the surrounding mountains is somewhat 

permeable and acts to collect precipitation for recharge.

Recharge to the Rio Grande aquifer system primarily comes from precipitation in the 

mountainous areas that surround the basins. Runoff from snowmelt or rainfall spreads across 

permeable alluvial fans and percolates downward into the aquifer. If the volume of runoff is 

large or becomes part of a perennial stream, groundwater recharge can be distributed over a 

much longer reach of stream channel. 

Runoff produces most mountain-front recharge to the aquifer system and water from the bedrock 

aquifers is discharged into the basin fill where the mountains front the Rio Grande Valley (Goff 

2002). In some mountainous areas, such as the project area, thick and extensive layers of 

volcanic rocks are sufficiently permeable to enable large volumes of water to flow through the 

rocks and directly recharge the basin-fill aquifers. Precipitation falling in the valleys does not 

contribute to aquifer recharge, because most of it is lost to evaporation and transpiration.

Project Area Hydrogeology

The project area lies in the Jemez Mountains in north-central New Mexico. The most dominant 

feature of the Jemez Mountains is the large central caldera, or area of collapse, known as the 

Valles Caldera. It contains a geothermal system that is a classic, liquid-dominated reservoir, 

overlain by a low-pressure vapor cap and recharged by local water derived from precipitation or 

condensation (Goff et al. 1985; Trainer et al. 2000). The Valles geothermal system is in the 

central and western parts of the Valles Caldera but does not extend under the entire caldera 

(Hulen and Nielson 1986; Wilt and Vender Harr 1986). 

The caldera contains both thermal and non-thermal groundwater. Like the local surface water

drainage patterns, groundwater flows radially outward from the rim of the caldera. The most 

extensive and productive aquifer in the region underlies the Pajarito Plateau on the east side of 

the mountain mass. On the west side, thermal and non-thermal waters discharge from the caldera 

to the southwest, down Cañon de San Diego, which follows the trace of the Jemez Fault Zone. 

The principal geothermal reservoir, or aquifer, in the region is under the central and western parts 

of the caldera (Trainer et al. 2000).

Non-thermal water in Valles Caldera occurs in diverse perched aquifers and deeper valley-fill 

aquifers. The non-thermal groundwater is derived from precipitation or condensation (Vuataz 

and Goff 1986). Discharge of non-thermal water from Valles Caldera takes several paths, some 

of which are not well understood. Some of the non-thermal groundwater discharges from 

springs, particularly from higher, smaller perched aquifers. Water from the more extensive 

valley-fill aquifers discharges as spring flow and seepage to the principal streams. Some deeper 

discharge from the valley-fill aquifers recharges the underlying geothermal reservoir by slow 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-45

leakage through relatively impermeable rocks and along fractures and faults (Faust et al. 1984, in 

Trainer et al. 2000; Vuataz and Goff 1986, in Trainer et al. 2000). The water that recharges the 

geothermal reservoir moves downward from the aquifers in the caldera fill to depths of 6,500 

feet or more, reaching temperatures of approximately 330 degrees Celsius (°C). This now heated 

geothermal water then rises convectively to depths of 2,000 feet or less and mixes with other 

groundwater as it flows away from the geothermal reservoir. 

The principal reservoir of geothermal fluids is at depth under the central and western parts of the 

caldera. The heated water of the geothermal system flows out the caldera to the west and 

southwest under the Jemez Plateau and along the Jemez Fault Zone. This geothermal water 

mixes with other groundwater as it flows along the fault zone, and some of this mixed or 

derivative water issues as hot springs in Cañon de San Diego (Trainer 1974). Outflowing mineral 

water appears to be limited to the western and southwestern parts of the Jemez Mountains. 

The geothermal system at Valles Caldera is subdivided into the Redondo, Sulphur Springs, and 

Jemez Springs geothermal areas, based on the distribution of springs and fumaroles,5past 

geothermal exploration projects, and scientific drilling programs. Surface discharges at Redondo 

and Sulphur Springs are fed by upwelling fluids from chemically distinct, isolated reservoirs 

beneath the caldera floor (OpenEI 2016). Free gas issues at Sulphur Springs and from smaller 

springs and fumaroles in the resurgent dome of the caldera (Goff et al. 1988). The Jemez Springs 

system lies outside the caldera walls, to the southwest in Cañon de San Diego. Hydrothermal 

features outside Valles Caldera are restricted largely to this canyon; geothermal waters reach the 

springs primarily by structurally controlled lateral outflow and by more minor flow through 

Paleozoic strata. 

Subsurface escape of reservoir fluid from near and beneath Valles Caldera has formed a 

discharge plume of reservoir water, mixed with dilute groundwater, which extends down Cañon 

de San Diego (Trainer 1974; Goff et al. 1988). The Jemez Fault Zone transports a relatively large 

portion of this flow. Soda Dam and Jemez Springs are derivatives of geothermal outflow from 

the reservoir. Near Jemez Pueblo, subsurface mineral water merges with the regional aquifer in 

fill deposits of the Albuquerque Basin (Trainer 1974). Free gas also emerges from several 

thermal features along the Jemez fault zone, southwest of the caldera.

Natural Geothermal Features

Hot springs are found both inside and outside of the Valles Caldera, a result of deep groundwater

circulating over the very hot rocks of the magma chamber that underlies the caldera (New 

Mexico Natural History 2015). Numerous natural mineral hot springs are located throughout the 

Jemez valley. Some are on public land, others are on private land and are open to the public for a 

fee. All of these features are found in the Jemez Watershed and are associated with the collapsed 

caldera. The five natural hot or warm springs in the project area are Jemez, Soda Dam, San 

Antonio, Spence, and McCauley. An additional hot spring, Sulphur Spring, is just outside of the 

project area boundaries, in the Valles Caldera. More information on the individual hot springs 

can be found in the Soils and Water Specialist Report (Forest Service 2016c).

Non-Thermal Groundwater Sources

Little information is available on groundwater hydrology in the region. However, groundwater is 

critically important because most of the region’s residents depend on it for their domestic water 

 

5 An opening in or near a volcano that emits hot sulfurous gases
Chapter 3. Affected Environment and Environmental Consequences

3-46 Santa Fe National Forest Geothermal Leasing EIS

supplies, and periodic shortages occur. Aquifer characteristics in much of the region severely 

limit groundwater availability. 

Groundwater beneath the Rio Chama Watershed

Groundwater in the Mancos shale, an aquiclude,6has a low yield, and usually is fair to poor 

quality for livestock or crops. Groundwater in the igneous rocks and volcanics is usually along 

fracture zones that are hard to intercept with water wells (NRCS 2011a). 

The Rio Chama watershed consists of three different geologic provinces, each containing distinct 

aquifer systems. The Española Basin province, in the southern part of the watershed and 

overlapping the project area, consists of Tertiary Period sediments, primarily the Santa Fe Group. 

These deposits are moderately permeable, contain large amounts of sand and gravel, transmit a 

fair amount of water, and have a relatively large recharge potential, meaning that the 

groundwater is easily renewed by percolating surface water. Española Basin aquifers usually 

yield relatively ample supplies of good quality water (New Mexico Office of the State Engineer 

2006). 

Shallow alluvial aquifers are found throughout the watershed, in all three geologic provinces, 

and many wells in the region draw water from these aquifers. Alluvial aquifers, composed 

largely of gravel and sand, can be a good source of water if the deposits are deep and extensive. 

However, in the Rio Chama region, the alluvial deposits are shallow and generally not extensive. 

Wells drawing water from these aquifers often run short of water in dry years. 

Additional groundwater production may be possible on a limited scale in certain areas. However, 

in the Rio Chama watershed as a whole, there do not appear to be significant untapped 

groundwater sources that could replace any large fraction of surface water use or provide major 

new water supplies in or outside of the region.

Groundwater beneath the Jemez Watershed

The bedrock geology in the western portion of the watershed is characterized by Precambrian 

metamorphic and Permian sedimentary rocks, while the central and eastern portions of the 

watershed are composed of volcanic rocks associated with the Valles Caldera. Groundwater

occurs in bedrock and in surficial deposits overlying it. Groundwater in the igneous rocks and 

volcanics is usually along fracture zones that are hard to intercept with water wells. Groundwater 

quality ranges from fair to poor for livestock or crops (NRCS 2011c).

Groundwater beneath the Rio Grande-Santa Fe Watershed

The most significant aquifer in the Rio Grande-Santa Fe Watershed is the Santa Fe Group, 

particularly its lower member, the Tesuque Formation. The upper member, the Ancha, is 

typically more conductive than the Tesuque but occurs above the water table in much of the Rio 

Grande-Santa Fe Watershed (NRCS 2011b). Deeper groundwater is nearly continuous in the 

Tesuque Formation throughout the watershed area, to depths of 2,000 feet or greater in some 

areas. This deep groundwater dates from the Ice Age and is recharged little if at all by presentday rainfall and snowmelt. 

Precipitation in the high mountains and flow in the Santa Fe River and its tributary arroyos seeps 

into and recharges shallow groundwater, which, in some areas, may be continuous with deeper 

 

6 A subsurface rock, soil, or sediment unit that does not yield useful quantities of water
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-47

groundwater (NRCS 2011b). Volcanics often serve as a “floor” or channel to concentrate 

percolating groundwater and cause it to emerge as spring flow. 

3.9.2 Environmental Consequences

3.9.2.1 Scoping Comments on Resource

The following issues specific to water resources were identified during the public scoping 

period:

 How would geothermal leasing affect surface and subsurface water quantity? Would

geothermal leasing change or reduce water allocations for other uses? What are the shortand long-term impacts on the regional aquifer?

 How would geothermal leasing affect water quality, and what size buffers are necessary to 

protect surface waters? How might these impacts differ, depending on the type of geothermal 

system?

 How would geothermal leasing affect the Abiquiu Reservoir and Dam and the NMDGF 

Habitat Stamp Program water projects?

3.9.2.2 How Resource Impacts Were Evaluated

Method

This section analyzes water resource data for the project area to determine the current conditions 

of watersheds and their susceptibility to impacts from erosion. Water quality, flow pattern, water 

temperature, and groundwater supply impacts are discussed.

The surface water layers were taken from the NHD Stream and Water Body GIS layers. This 

dataset represents the drainage network, with such features as rivers, streams, canals, lakes, 

ponds, coastlines, dams, and stream gages. This dataset has a scale of 1:24,000. These data are 

designed to be used in general mapping and in analyzing surface water systems.

The watershed boundaries were delineated by the NRCS Geospatial Data Gateway. Both fourthand sixth-level watershed boundaries from this dataset are used. The watershed erodibility index 

analysis uses the Kw factor from the State Soil Geographic spatial database and land slope 

derived from USGS 30-meter digital elevation models. The Watershed Condition Class 

Framework is from the Forest Service GIS Layer. The 100-year floodplains are from the Federal 

Emergency Management Act GIS layer. The well data is from the NMOSE Enterprise GIS. 

The NMOSE Enterprise GIS offers an open data site, which is set up for agency transparency for 

allowing the public and other agencies access to downloadable data from the NMOSE. The point 

of diversions layer includes well locations, surface declarations, and surface permits. These data 

were extracted from the NMOSE Water Administration Technical Engineering Resource System 

database. These data are current as of March 2016, have varying degrees of accuracy, and have 

not been validated. 

Indicators

Indicators of the impacts of the proposed action and alternatives are as follows:

 Erosion and sedimentation that could alter or impair perennial or intermittent streams; the 

analysis includes a combined erosion and transport potential for each watershed in the 
Chapter 3. Affected Environment and Environmental Consequences

3-48 Santa Fe National Forest Geothermal Leasing EIS

project area, as measured by the soil erosion water factor (Kw) and slope to form the 

watershed erodibility index

 Possible impacts on beneficial uses and sensitive watersheds as measured by combining 

factors including the watershed erodibility index, watershed condition class, impaired 

streams, density of roads and beneficial uses

 Potential for contamination of fresh surface water or groundwater supplies, as indicated by 

risk of leaks and spills

 Possibility for depletion of groundwater supplies or interferences with groundwater recharge, 

such that the local groundwater table would be lowered to a level that would not support 

existing land uses

 Potential for groundwater “mounding” due to injection that does not result in groundwater 

being returned to the aquifer that it was extracted from

 Potential for changes to natural thermal features

 Potential for changes in flow from springs and in surface water drainages

 Potential for changes in groundwater or surface water temperatures

 Potential for changes in groundwater or surface water quality

 Potential for changes in source water and vegetation at wetland areas

 Possible flash flooding impacts on proposed facilities, as indicated by location of 100-year 

floodplains

Assumptions

This analysis assumes the following: 

 Leasing land does not involve ground-disturbing activities or any type of construction, so 

there would be no direct impact on water resources. Impacts would result from activities 

pursued after leasing.

3.9.2.3 Common Impacts Associated with Geothermal Development

The following impact analysis provides a general description of common impacts on water 

resources from geothermal development, as well as specific impacts based on the RFDS. 

Because the RFDS is the same under all alternatives, except the No Leasing Alternative 

(Alternative 3), general impacts under those alternatives would be the same. 

The information presented in the Common Impacts on Water Resources and Quality Associated 

with Geothermal Development section of the 2008 Geothermal PEIS is incorporated by 

reference and summarized here. As described in the 2008 Geothermal PEIS, common impacts 

from geothermal development could include water contamination, lowered groundwater tables, 

and changes in water temperature. 

Impacts on water quantity are directly related to water use. Water use would occur for drilling 

wells, constructing infrastructure, stimulating injection wells, operating the power plant, and dust 

control. Water would not be used for cooling because the air temperature is sufficiently low to 

allow for air cooling of water to be reinjected. The applicant would be responsible for obtaining 

water rights in accordance with state and federal regulations. Fresh water used in the drilling 

operations would be trucked in or would come from local springs and wells at depths less than 

1,000 feet (BLM 2015). Water is used during the well construction as drilling fluids, and for 

cementing the casing in place. Well depth, total number of wells, volume of the borehole, and the 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-49

physical and chemical properties of the formation would affect water volume requirements 

during drilling operations. 

For enhanced geothermal systems, water is also required for stimulating the reservoir7. 

Stimulation volume is dependent on the desired water volume flow rate (Clark et al. 2011). The 

vast majority of water use would occur during the operations phase. Although extracted water 

would be reinjected after use, water may be lost to the geologic formation. To maintain pressure 

and operation, water that is lost must be made up from alternative water sources. Water 

consumption (i.e., water that is withdrawn from a resource such as a river, lake, or nongeothermal aquifer that is not returned to that resource), varies between 0.29 and 0.72 gallon per 

kilowatt-hour for enhanced geothermal scenarios (Clark et al. 2011). 

Potential impacts on surface water quality due to ground disturbance during road, powerline, and 

facility development could occur from erosion and subsequent transport of eroded materials into 

surface waters in areas where vegetation has been removed and soils disturbed. This could 

increase suspended sediment and turbidity in surface water following periods of runoff. There 

could also be impacts on sensitive riparian zones due to road construction and any activities that 

are proposed near stream courses. This would be of particular concern in areas of highly erodible 

soils, near impaired stream reaches, or in sensitive watersheds.

Potential short-term impacts on water quality could also occur from accidental releases of 

chemical compounds, such as fuels, solvents for removing buildup on pipes, and working fluids 

required for drilling and operation activities, or wastewater, which could contaminate surface 

water and shallow groundwater. Impacts from accidental releases of wastewater, such as 

stormwater or sanitation water, could include increased concentrations of nitrate, phosphate, total 

dissolved solids, and fecal coliform in shallow groundwater or surface water. The risk of 

occurrence of spills, or impacts if a spill occurs, would be reduced by incorporating in the 

development plan BMPs and environmental protection measures. Extracted geothermal fluids 

containing high concentrations of dissolved constituents and leaking into the shallow aquifer 

could contaminate freshwater supplies through faulty reinjection practices, geothermal well 

casing failure, and uncontrolled discharge of waste geothermal fluids. Protecting groundwater 

from contamination by geothermal fluids is facilitated by the use of multiple casing strings, 

whose depths are specified partly on the basis of the depths of groundwater aquifers. In addition, 

redundant blow-out prevention equipment is used. 

Impacts would vary relative to the area that is disturbed and location of the disturbance in 

relation to permeable soils and local aquifers.

Binary power plant systems would return most of the extracted groundwater to the geothermal 

source aquifer through injection wells. During pumping, some groundwater flow paths in the 

deeper aquifers could be modified due to reductions in temperature of reinjected waters, which 

reduces pressure in the deeper geothermal system and could therefore change flow paths. 

Upward vertical hydraulic gradients could be reduced due to this depressurization, altering flow 

paths. It is also possible that the reinjection site would not return the geothermal fluid to the 

exact hydraulic connection that it was withdrawn from, and water may be lost to the formation. 

This could also locally alter pressurization in the system and flow paths. Monitoring plans could 

be implemented to track changes occurring from the pumping. 

 

7

Stimulation opens existing spaces within the formation and enables or enhances the circulation of fluids.
Chapter 3. Affected Environment and Environmental Consequences

3-50 Santa Fe National Forest Geothermal Leasing EIS

Flows at non-thermal springs and seeps are not likely to be affected by geothermal groundwater

development. Most of these springs are recharged by shallow groundwater with short flow paths, 

which is recharged primarily from precipitation, irrigation, and runoff. For most of the project 

area, geothermal fluids would be extracted at much greater depths than the shallow aquifer and 

would be reinjected once the heat is extracted. However, there are numerous faults extending 

from the caldera, and where there is an interconnection between deeper groundwater and faults, 

pumping could change flow paths. There also could be some slight changes in flow paths from 

pressure differences due to small differences in the extraction and reinjection zones. 

Deeper groundwater is nearly continuous in the Tesuque Formation throughout the Santa Fe-Rio 

Grande Watershed area, to depths of 2,000 feet or greater in some areas. This deep groundwater 

dates from the Ice Age, approximately 10,000 years ago, and is recharged little if at all by 

present-day rainfall and snowmelt. Should geothermal extraction occur in this area, there could 

be more risk of changes to flow paths, and mixing of geothermal fluids with other groundwater. 

However, as geothermal waters are reinjected, any changes in groundwater level would be minor 

and would result from changes in flow paths, rather than reductions in groundwater quantity. 

Where there is interconnected flow to springs and seeps in thermal areas, this could alter the 

mixing of weather-related non-thermal waters with the deeper geothermal waters and alter flow 

paths to geothermal features. Additionally, temperatures could be lowered if interconnected flow 

from deeper zones is reduced by returning the cooled geothermal water to the reservoir. 

3.9.2.4 Impacts Under Alternative 1

Alternative 1 would have the same general impacts on water resources associated with the RFDS

described under Common Impacts Associated with Geothermal Development, above. Although 

the SFNF would not make an availability determination for geothermal leasing in the project 

area, geothermal lease applications and nominations would continue to be processed on a caseby-case basis under separate NEPA analysis, in accordance with the Forest Plan (Forest Service

1987) and existing laws and regulations. 

Geothermal leasing stipulations and closures would not be specifically implemented related to 

watershed, surface water, or groundwater resources; however, any future geothermal lease 

applications and nominations would be subject to standards and guidelines outlined in the Forest 

Plan and environmental analysis. 

It has been established that there is a geothermal plume that extends from the caldera southwest 

to Jemez Springs and Soda Dam. The delineation of that plume is not exact. Most of it likely 

runs through the JNRA Unit, which is not available for leasing. However, the plume may also 

extend into the Middle Unit and South Unit, west of the edge of the caldera. Any pumping, 

including outside of the geothermal system, could affect pressurization, temperature, and 

possible flow paths.

The hot springs in Valles Caldera and southwest of the caldera in San Diego Canyon could be 

impacted by extracting and reinjecting geothermal waters from these systems. Both flow rates 

and water quality could be impacted. Extracting groundwater could have short-term impacts in 

reducing shallow groundwater levels and altering pressures of geothermal sources and fractures. 

Because the applicant would be required to obtain water rights, and the source of makeup water 

is unknown, the amount of water consumption occurring within the project area is unknown.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-51

3.9.2.5 Impacts Under Alternative 2

Under Alternative 2, indirect impacts from anticipated geothermal exploration and development 

would generally be the same as those described under Alternative 1, although the location of 

potential sites would be restricted by administrative withdrawals and stipulations. Approximately 

32,000 acres, or 17 percent of the NFS lands in the project area, would be closed to geothermal 

leasing, while approximately 136,650 acres in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. 

NSO stipulations for drinking water sources, points of surface water diversions, developed 

springs and wells, rivers, streams, wetlands, springs, playas, riparian areas, 100-year floodplains, 

and other water bodies would reduce the potential for direct impacts on these resources from 

erosion caused by development and contamination from accidental spills. Implementing a 1-mile 

no leasing protection zone around geothermal features should reduce the potential for direct 

pumping of geothermal fluids around these features. However, in this fractured and 

interconnected system, pumping some distance from the geothermal features could change 

temperature and chemical composition and flow rates. 

NSO stipulations on slopes greater than 40 percent and soils with severe erosion potential, as 

well as CSU stipulations for slopes between 30 and 40 percent, would reduce the potential for 

direct impacts on water resources connected with these sites from erosion caused by 

development and contamination from accidental spills. However, road and power line 

development could still impact all of these areas, as described under Common Impacts 

Associated with Geothermal Development. 

Because the applicant would be required to obtain water rights, and the source of makeup water 

is unknown, the amount of water consumption occurring within the project area is unknown. 

However, BMPs—such as evaluating the consumptive use of water in the operation and its effect 

on water dependent ecosystems, and identifying areas of groundwater discharge and recharge 

and their potential relationship with surface water bodies—could be applied into the permit 

application or included as approved use authorizations by the BLM as COAs. These measures 

would reduce the likelihood of lowering the groundwater table to a level that would not support 

existing land uses.

There would be no indirect impacts on surface water in the Valles Caldera National Preserve or 

Bandier National Monument. This is because surface water drainage from the caldera generally 

flows into the project area. While headwaters to perennial streams in the South Unit of Bandelier 

National Monument occur in the south unit of the project area, no impacts on these headwaters 

are anticipated. This is because NSO stipulations would apply to 33,200 acres in the south unit 

(or 97 percent of the south unit), including 500 feet from the outer edge of perennial and 

intermittent rivers and streams.

3.9.2.6 Impacts Under Alternative 3

There would be no direct impacts on watersheds or groundwater resources under Alternative 3. 

No surface areas would be disturbed by geothermal developments; however, there would be 

indirect impacts on water resources. Because the area would be closed to leasing for the 

foreseeable future, over time, there would be less potential impacts on surface or subsurface 

water resources than expected under implementation of the current Forest Plan.
Chapter 3. Affected Environment and Environmental Consequences

3-52 Santa Fe National Forest Geothermal Leasing EIS

3.9.2.7 Impacts Under Alternative 4

Impacts from Alternative 4 would be similar to those described under Alternative 2. However, 

there would be no discretionary closures under Alternative 4, and there would be reduced 

protection of specific areas from implementing less restrictive lease stipulations. 

Although there would be no discretionary closures, approximately 17 percent of the NFS lands 

in the project area would still be closed to geothermal leasing. NSO would still be stipulated for 

slopes in excess of 40 percent, and slopes between 30 and 40 percent would still be subject to 

CSU. However, implementing CSU rather than NSO stipulations on areas with severe erosion 

hazard would increase the risk of erosion in areas disturbed by exploration and development of 

geothermal sites. This would increase sedimentation and turbidity into streams and rivers, 

particularly near steeper slopes between 30 and 40 percent and areas with moderately high to 

high runoff potential. 

Runoff from development on steep slopes in areas of severe erosion hazard would be a concern 

for watersheds and water quality if runoff were to reach streams and impact water quality. BMPs

identified in Appendix C could be implemented to minimize and contain erosion.

CSU rather than NSO stipulations in intermittent streams (the NSO still holds for perennial 

streams) would increase the risk of erosion and transport to water sources. This would be the 

case particularly in areas of severe erosion hazard and where the runoff potential is moderate to 

high. Implementing an additional CSU stipulation for ephemeral drainages would reduce the risk 

of erosion and sediment transport in these areas. BMPs identified in Appendix C could be 

implemented to help reduce impacts on these stream reaches. 

Impacts from road development and water use under Alternative 4 would be the same as those 

described under Alternative 2.

Under Alternative 4, NSO stipulations apply to natural geothermal features, and a 1-mile buffer 

around them. NSO stipulations would protect these resources from accidental spills or leaks from 

the pumping site and would increase the difficulty of accessing geothermal waters close to the 

geothermal features. However, this stipulation does not prevent withdrawals from waters near 

the geothermal features using advanced technology. A lessee of a NSO area must develop any 

surface infrastructure outside the NSO area and would need to use advanced technology, such as 

directional drilling, to access the geothermal resource under the NSO area; nevertheless, those 

resources could still be accessed. Therefore, this alternative is more likely to impact natural 

geothermal features, potentially affecting temperatures and flow rates. BMPs identified in 

Appendix C include a monitoring plan, which could be implemented to identify impacts on these 

resources.

There would be no indirect impacts on surface water in the Valles Caldera National Preserve or 

Bandier National Monument because surface water drainage from the caldera generally flows 

into the project area. While headwaters to perennial streams in the South Unit of Bandelier 

National Monument occur in the south unit of the project area, no impacts on these headwaters 

are anticipated. This is because NSO stipulations would apply to 33,200 acres in the south unit 

(or 97 percent of the south unit).

3.9.2.8 Cumulative Impacts

Cumulative impacts for water resources are analyzed at the level of the sixth-level watersheds. 

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-53

Water resource repair and replacement projects—the Pueblo of Jemez Red Rocks Dam Repair, 

the Abiquiu Land Grant Waterline Replacement, and the McKinney County Dam—in 

combination with Alternatives 1, 2, and 4, would likely initially directly impact water resources 

through increased erosion and sedimentation into waterways. However, long-term impacts would 

be improved protection from flooding and erosion and reduced potential for loss of water 

resources through leakage.

Restoration projects, such as the Southwest Jemez Mountains Restoration Project, Pueblo of 

Jemez Owl Springs Bridge Sediment Removal Project, and Valle Seco Wetland Restoration 

Project, would maintain or improve water resource conditions in their respective project areas by 

removing sedimentation and reducing erosion, or by maintaining streambank stability.

Under Alternatives 1, 2, or 4, sedimentation and erosion would likely occur from geothermal 

development. Natural processes, such as fire, could accelerate or amplify the impacts of 

sedimentation and erosion. The magnitude and intensity of these impacts would depend on the 

size and severity of the fire, as well as local soil conditions. Water quality impacts from 

accidental spills related to geothermal development are possible and could be combined with 

impacts from sediment transport and erosion or other accidental spills outside of the project area 

that travel downstream through the sixth-level watersheds. 

Although extracted water would be reinjected after use, water may be lost to the geologic 

formation. To maintain pressure and operation, water that is lost must be made up from 

alternative water sources, which may contribute to the cumulative demand for water resources in 

the fourth-level watersheds under Alternatives 1, 2, and 4. While the source of makeup water is 

unknown, BMPs identified in Appendix C—such as evaluating the consumptive use of water in 

the operation and its effect on water dependent ecosystems, and identifying areas of groundwater

discharge and recharge and their potential relationship with surface water bodies—could be 

applied into the permit application or included as approved use authorizations by the BLM as 

COAs. These measures would reduce the likelihood of lowering the groundwater table to a level 

that would not support existing land uses.

3.10 Air Quality and Air Quality-Related Values

3.10.1 Affected Environment

Ambient air quality is affected by the type and amount of air pollutants emitted into the 

atmosphere, the size and topography of the air basin, prevailing meteorological conditions, and 

the conversion of air pollutants and other species by a complex series of chemical and 

photochemical reactions in the atmosphere. The levels of air pollutants are generally expressed 

in terms of concentration, either in units of parts per million (ppm), parts per billion (ppb), or 

micrograms per cubic meter (μg/m).

3.10.1.1 Regulatory Framework

Clean Air Act

The Clean Air Act (CAA; 42 USC, Sections 7401-7642), as amended, is the primary authority 

for regulating and protecting air quality in the United States. The EPA has the primary 

responsibility for regulating atmospheric emissions. This includes six nationally regulated air 

pollutants, known as criteria pollutants, that are believed to be key indicators of air quality:

carbon monoxide, nitrogen dioxide, ozone, sulfur dioxide, lead, and two categories of particulate 
Chapter 3. Affected Environment and Environmental Consequences

3-54 Santa Fe National Forest Geothermal Leasing EIS

matter (particulate matter with an aerodynamic diameter of 10 microns or less [PM10] and 

particulate matter with an aerodynamic diameter of 2.5 microns or less [PM2.5]). 

Under the authority of the CAA, the EPA has set time-averaged national ambient air quality

standards (NAAQS) for these criteria pollutants. The two-tiered standards may be primary or 

secondary. Primary standards set limits to protect public health, including the health of sensitive 

populations, such as asthmatics, children, and the elderly. Secondary standards set limits to 

protect public welfare, including protection against decreased visibility and damage to animals, 

crops, vegetation, and buildings. Averaging periods vary by pollutant, based on the potential 

health and welfare impacts of each pollutant. States may set their own ambient air quality 

standards, but they must be at least as stringent as the national standards. National and state 

ambient air quality standards are shown in Table 3-5, below.

Table 3-5. National and New Mexico Ambient Air Quality Standards

Pollutant Averaging 

Time

National Standards New 

Mexico

Primary Secondary Standard Form

Ozone 8-hour 0.070 

ppm1

Same as 

primary

Annual 4th-highest daily 

maximum 8-hour 

concentration, averaged 

over 3 years

—

Carbon 

monoxide

8-hour 9 ppm — Not to be exceeded more 

than once per year

8.7 ppm

1-hour 35 ppm — 13.1 ppm

Nitrogen 

dioxide

Annual 

(arithmetic 

mean)

0.053 

ppm

Same as 

primary

Annual mean 0.05 ppm

24-hour — — — 0.10 ppm

1-hour 100 ppb — 98th percentile, averaged 

over 3 years

—

Sulfur dioxide Annual mean — — — 0.02 ppm

24-hour — — — 0.10 ppm

3-hour — 0.5 ppm Not to be exceeded more 

than once per year

—

1-hour 75 ppb2 — 99th percentile of 1-hour 

daily maximum 

concentrations, averaged 

over 3 years

—

PM10 24-hour 150 

μg/m3

Same as 

primary

Not to be exceeded more 

than once per year on 

average over 3 years

—

PM2.5 Annual 

(arithmetic 

mean)

15 μg/m3 Same as 

primary

Annual mean, averaged 

over 3 years

—

24-hour 35 μg/m3 Same as 

primary

98th percentile, averaged 

over 3 years

—

Lead3 Rolling 3-month 

average

0.15 

μg/m3

Same as 

primary

Not to be exceeded —
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-55

Table 3-5. National and New Mexico Ambient Air Quality Standards

Pollutant Averaging 

Time

National Standards New 

Mexico

Primary Secondary Standard Form

Total 

suspended 

particulates

Annual 

(geometric 

mean)

— — — 60 μg/m3

30-day average — — — 90 μg/m3

7-day — — — 110 μg/m3

24-hour — — — 150 μg/m3

Total reduced 

sulfur

0.5-hour — — — 0.003 ppm

Hydrogen 

sulfide

1-hour 

(statewide)

— — — 0.010 ppm

0.5-hour (within 

5 miles of 

municipalities 

greater than 

20,000 people)

— — — 0.003 ppm

Total reduced 

sulfur

0.5-hour — — — 0.003 ppm

Sources: EPA 2016a; New Mexico Commission of Public Records 2002

1

Final rule signed October 1, 2015, and effective December 28, 2015. The 2008 ozone standards additionally remain in 

impact in some areas. Revocation of the 2008 ozone standards and transitioning to the 2015 standards will be 

addressed in the implementation rule for the current standards.

2

Final rule signed June 2, 2010. The 1971 annual and 24-hour sulfur dioxide standards (0.03 ppm annual and 0.14 ppm 

24-hour) were revoked in that same rule making. However, these standards remain in impact until one year after an area 

is designated for the 2010 standard. One exception is in areas designated nonattainment for the 1971 standards; here, 

the 1971 standards remain in impact until implementation plans to attain or maintain the 2010 standard are approved.

3

Final rule signed October 15, 2008. The 1978 lead standard (1.5 μg/m3) remains in impact until one year after an area is 

designated for the 2008 standard. The one exception is in areas designated nonattainment for the 1978 standard; here,

the 1978 standard remains in impact until implementation plans to attain or maintain the 2008 standard are approved.

Hazardous Air Pollutants

Congress amended the CAA in 1990 to address a large number of air pollutants that are known to 

cause or may reasonably be anticipated to cause impacts on human health or the environment. 

Congress initially identified 188 specific pollutants and chemical groups as hazardous air 

pollutants and has modified the list over time. 

The CAA requires control measures for hazardous air pollutants. The EPA issues national 

emissions standards for hazardous air pollutants to limit the release of specified hazardous air 

pollutants from specific industrial sectors. These standards are technology based, meaning that 

they represent the maximum achievable control technology that is economically feasible for an 

industrial sector. The CAA defines a major source for hazardous air pollutants to be one that 

emits 10 tons per year of any single hazardous air pollutant or 25 tons per year of any 

combination of hazardous air pollutants. Under state regulations, a construction or operating 

permit may be required for any major source, though some exceptions apply. In New Mexico, 

these regulations are Sections 20.2.70 and 20.2.73 of the New Mexico Administrative Code. 
Chapter 3. Affected Environment and Environmental Consequences

3-56 Santa Fe National Forest Geothermal Leasing EIS

Clean Air Act Conformity Requirements

Section 176(c) of the CAA requires that federal actions conform to the appropriate state 

implementation plan. This is a plan developed at the state level that provides for the 

implementation, maintenance, and enforcement of NAAQS and is enforceable by the EPA. The 

EPA has promulgated rules establishing conformity analysis procedures for transportation-related 

actions and for other general federal agency actions (40 CFR, Parts 6, 51, and 93). 

The EPA general conformity rule requires preparation of a formal conformity determination 

document for federal agency actions that are undertaken, approved, or funded in federal 

nonattainment or maintenance areas, when the total net change in direct and indirect emissions 

of nonattainment pollutants (or their precursors) exceeds specified thresholds. Because the SFNF 

Ranger Districts in the project area are not in a nonattainment or maintenance area, the proposed 

action is exempt from the CAA general conformity rule (discussed further under Air Quality

Conditions, below).

Prevention of Significant Deterioration

In addition to the NAAQS, the Prevention of Significant Deterioration (PSD) regulations set 

forth a permit process that applies to new major sources or major modifications of existing 

sources for pollutants. It is applicable where the emission source is inside an attainment or 

unclassifiable area, as defined by the NAAQS. Furthermore, the PSD program requires the use 

of best available control technologies and provides for an air quality impact analysis and public 

involvement. The purpose of the PSD program is to protect public health and welfare. It also 

preserves, protects, and enhances the air quality of national parks and wilderness areas, national 

monuments, seashores, and other areas of recreation, scenic, or historic value.

The PSD regulations prevent areas that are in attainment of the NAAQS from being polluted up 

to the level of the standards. The CAA directs the EPA to classify areas of the United States as 

Class I, II, or III. Class I areas are national parks and wilderness areas of a certain size that 

existed before 1977 or additional areas that have since been designated by federal regulation. 

The PSD regulations place limits on the total increase in ambient pollution levels above 

established baseline levels for sulfur dioxide, nitrogen dioxide, and PM10 that are allowed in 

these areas. Class II areas are the remaining areas in the United States (outside of nonattainment 

and maintenance areas). No Class III areas have been designated.

The SFNF is not a PSD Class I area. There are four Class I areas within 62 miles of the SFNF 

boundary: Bandelier Wilderness, Pecos Wilderness, San Pedro Parks Wilderness, and Wheeler 

Peak Wilderness. 

The PSD regulations require operators of major sources or major modification of sources to 

obtain permits for attainment pollutants. Geothermal plants are not a rule-listed emissions 

source; therefore, the PSD trigger levels are 250 tons per year for each criteria pollutant emitted 

during individual plant operations.

Regional Haze Rule

On July 1, 1999, the EPA issued regional haze rules to comply with the requirements of the 

CAA. Under 40 CFR, Subpart 51.308, the rule requires the State of New Mexico to develop state 

implementation plans. The plans must include visibility progress goals for each of the nine Class 

I areas in New Mexico, as well as provisions requiring continuing consultation between the state 

and federal land managers to address and coordinate implementation of visibility protection 

programs. Under 40 CFR, Subpart 51.309, the rule also provides an optional approach to New 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-57

Mexico and eight other western states to incorporate emission-reduction strategies issued by the 

Grand Canyon Visibility Transport Commission. These are designed primarily to improve 

visibility in 16 Class I areas on the Colorado Plateau, including the San Pedro Parks Wilderness 

Area (Forest Service 2015d). New Mexico has been implementing an approved state 

implementation plan since 2006. The goal of the regional haze rule is, by 2064, to return 

visibility in Class I areas to visibility conditions before man-made impacts.

State Law

In New Mexico, the Environmental Improvement Board is the state air pollution control agency 

(except in Bernalillo County), and air quality programs are administered under the authority of 

the NMED. Air quality is regulated under the New Mexico Air Quality Control Act (Sections 74-

2-1 to 74-2-17, New Mexico Statutes, Annotated 1978) and the New Mexico Ambient Air 

Quality Standards and Air Quality Control Regulations. 

The state ambient air quality standards are described in Table 3-5. One of the state-regulated 

pollutants, hydrogen sulfide, is a naturally occurring byproduct of oil, gas, and geothermal 

development in some areas. It is a colorless flammable gas with a rotten egg smell. It is both an 

irritant and a chemical asphyxiant, with impacts on both oxygen utilization and the central 

nervous system. Its health impacts can vary, depending on the level and duration of exposure. 

While there is no NAAQS for hydrogen sulfide, and it is not regulated as a hazardous air 

pollutant under the CAA, a number of states, including New Mexico, have set standards for 

hydrogen sulfide at the state level. No information was found on whether hydrogen sulfide is 

present, or at what levels, in geothermal fluids in the project area.

3.10.1.2 Air Quality Conditions

The CAA requires each state to identify areas that have ambient air quality in violation of federal 

standards using monitoring data collected through state monitoring networks, as follows:

 Areas that violate air quality standards are designated as nonattainment for the relevant 

criteria air pollutants.

 Areas that comply with air quality standards are designated as attainment for the relevant 

criteria air pollutants.

 Areas that have been re-designated from nonattainment to attainment are considered 

maintenance areas.

 Areas of uncertain status are generally designated as unclassifiable but are treated as 

attainment areas for regulatory purposes. 

The project area is in attainment or unclassified for all NAAQS (EPA 2016b). The only 

nonattainment and maintenance areas are in southwestern New Mexico, over 200 miles south of

the project area. Given the distance between these nonattainment and maintenance areas and the 

weather patterns in New Mexico, the proposed action would have no potential to affect air 

quality in these areas; thus, these areas would have no potential to affect air quality in the project 

area.

The NMED, Air Quality Bureau, is responsible for operating a network of air monitoring stations 

in most of New Mexico. Table 3-6, below, shows the locations, the pollutants monitored, and the 

last three years of monitoring data for each station in Rio Arriba and Sandoval Counties. 
Chapter 3. Affected Environment and Environmental Consequences

3-58 Santa Fe National Forest Geothermal Leasing EIS

Table 3-6. Air Quality Monitoring Values in Rio Arriba and Sandoval Counties, New Mexico

Pollutant Averaging 

Time 2012 2013 2014 3-Year Average NAAQS

Percent 

of 

NAAQS

Coyote Ranger District (21 New Mexico 96, Coyote, NM 87012; Rio Arriba County)1

Ozone (ppm) 8-hour N/A20.066 ppm 0.065 ppm N/A20.070 ppm N/C

3

Highway Department Yard Near Bernalillo (E Avenida Bernalillo, Bernalillo, NM; Sandoval County)4

Ozone (ppm) 8-hour 0.062 ppm 0.067 ppm 0.062 ppm 0.064 ppm 0.070 ppm 91

Bernalillo City Hall (829 S Camino Del Pueblo, Bernalillo, NM 87004; Sandoval County)5

PM10 (μg/m3) 24-hour 23 μg/m325 μg/m321 μg/m323 μg/m3150 μg/m315

Source: EPA 2016c

1

Approximately 2 miles northwest of the project area boundary

2Not available

3Not calculated since there are not three consecutive years of data

4

Approximately 25 miles south of the project area boundary

5

Approximately 30 miles south of the project area boundary

As shown in Table 3-6, ambient air concentrations of monitored pollutants are below the 

NAAQS for stations with three consecutive years of data. However, monitored levels of ozone

are nearing the NAAQS. These ozone levels generally are attributed to oil and gas operations 

and power plants, including the San Juan Generating Station and the Four Corners Power Plant, 

in the region (Four Corners Air Quality Task Force 2007).

Actions to address emissions from oil and gas operations and fossil fuel-fired power plant 

operations have included the following:

 In October 2012, the EPA promulgated New Source Performance Standards under 40 CFR, 

Part 60, Subpart OOOO, that requires air pollution controls for volatile organic compounds 

at natural gas production wells and other facilities associated with the oil and gas industry.

 In 2013, the NMED, the Public Service Company of New Mexico, and the EPA agreed to 

meet the requirements of the federal regional haze rule by closing two units at the San Juan 

Generating Station by the end of 2017. 

 In December 2013, three coal-fired generators were closed at the Four Corners Power Plant 

as part of a plan to meet the requirements of the federal regional haze rule. The remaining 

two coal-fired generators will have selective catalytic reduction technology installed by 

2018. These changes satisfy the EPA’s best available retrofit technology requirements.

It is uncertain whether the Four Corners area will be redesignated as an ozone nonattainment 

area over the 15-year life of the RFDS (2016 to 2031), or if the SFNF will be included in the 

nonattainment boundary if redesignation occurs. While federal, state, local, and tribal 

jurisdictions continue to seek ways to reduce emissions from the oil and gas sector and 

electricity generating plants through voluntary and regulatory mechanisms, sources of ozoneprecursor emissions from these industrial sectors continue to be proposed west of the project 

area. 

Existing Emissions

The EPA prepares a national emissions inventory every three years to provide a comprehensive 

and detailed estimate of emissions from all air emission sources in the United States. Emissions 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-59

in the inventory are presented by county. The inventories are based on emission estimates and 

model inputs provided by state, local, and tribal air agencies for sources in their jurisdictions, 

supplemented by data developed by the EPA.

Table 3-7, below, summarizes the mobile and stationary source emissions in Rio Arriba and 

Sandoval Counties in 2011, the most recent inventory year available (EPA 2013). This baseline 

emissions summary is a conservative overestimate of project area emissions. This is because it 

includes emissions from all of Rio Arriba and Sandoval Counties, and the project area 

encompasses only approximately 3 percent of those counties together. However, the baseline 

emissions summary provides a scale against which to compare projected emissions from 

geothermal exploration, development, and production under the proposed action.

Table 3-7. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 2011 (Tons)

Source Category 

County

Volatile 

Organic 

Compounds

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Dioxide PM10 PM2.5

Agricultural

Rio Arriba — — — — 34 7

Sandoval — — — — 36 7

Subtotal — — — — 70 14

Bulk Gasoline Terminals and Gas Stations

Rio Arriba 303 — — — — —

Sandoval 591 — — — — —

Subtotal 894 — — — — —

Commercial Cooking

Rio Arriba 1 3 — — 7 7

Sandoval 4 11 — — 29 26

Subtotal 5 14 — — 36 33

Dust

Rio Arriba — — — — 32,819 308

Sandoval — — — — 38,616 3,949

Subtotal — — — — 71,435 4,257

Fuel Combustion

Rio Arriba 811 2,542 1,811 13 109 106

Sandoval 214 1,296 416 75 209 180

Subtotal 1,025 3,838 2,227 88 318 286

Industrial Processes

Rio Arriba 15,498 12,411 9,016 4 124 109

Sandoval 525 338 300 0 35 9

Subtotal 16,020 12,749 9,316 4 159 118

Miscellaneous Nonindustrial 

Rio Arriba 19 0 0 0 0 0

Sandoval 36 0 0 0 0 0

Subtotal 55 0 0 0 0 0
Chapter 3. Affected Environment and Environmental Consequences

3-60 Santa Fe National Forest Geothermal Leasing EIS

Table 3-7. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 2011 (Tons)

Source Category 

County

Volatile 

Organic 

Compounds

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Dioxide PM10 PM2.5

Mobile Sources

Rio Arriba 920 6,608 1,108 6 62 49

Sandoval 1,513 15,487 3,397 16 169 129

Subtotal 2,433 22,095 4,505 22 231 178

Solvents

Rio Arriba 295 — — — — —

Sandoval 929 — — — — —

Subtotal 1,224 — — — — —

Waste Disposal

Rio Arriba 30 366 14 1 67 57

Sandoval 3 4 1 1 11 7

Subtotal 33 370 15 2 78 64

Total source 

emissions1

21,689 39,066 16,063 116 72,327 4,950

Total source 

emissions (without 

fugitive dust)

21,689 39,066 16,063 116 892 693

Source: EPA 2013

3.10.1.3 Air Quality-Related Values

AQRVs are resources that may be affected by a change in air quality, including visibility, aquatic 

and terrestrial impacts of wet and dry pollutant deposition, and terrestrial impacts of ozone. The 

only AQRV discussed in this report is visibility, which is the primary AQRV concern in the 

project area and the AQRV with the most potential to be impacted by the proposed action.

In 1985, the EPA initiated a network of monitoring stations to measure impacts on visibility in

Class I areas. These are known as the Interagency Monitoring for the Protection of Visual 

Environments monitors and exist in some, but not all, Class I areas. There are monitors at three 

of the four Class I areas within 62 miles of the project area; however, one of the monitors 

represents conditions at both the Pecos Wilderness and Wheeler Peak Wilderness. 

The visibility trends for the Interagency Monitoring for the Protection of Visual Environments 

monitors in Bandelier Wilderness, Pecos Wilderness/Wheeler Peak Wilderness, and San Pedro 

Parks Wilderness are shown in the Air Technical Report (Forest Service 2016d). The top line on 

each graph is for the 20 percent worst days, and the bottom line is for the 20 percent best days. A 

down-sloping line means less reduction of visibility and therefore an improvement. In most 

cases, visibility trends have been flat or improving. Implementation of best available retrofit 

technology strategies, as required under the federal Regional Haze Rule, may result in further 

improvements. The peak in the Bandelier Wilderness 20 percent worst days line is likely due to 

the occurrence of large wildfires in 2000.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-61

3.10.2 Environmental Consequences

3.10.2.1 Scoping Comments on Resource

The following issues specific to air quality and air quality related values were identified during 

the public scoping period:

 How would gases and emissions from geothermal leasing be monitored and controlled, and 

how would residual waste accumulations from air emission management be disposed of?

 What are the impacts of odors from geothermal leasing, and how would these affect 

receptors in the project area?

3.10.2.2 How Resource Impacts Were Evaluated

Method

The method for air quality impact analysis is incorporated by reference from the 2008 

Geothermal PEIS (BLM and Forest Service 2008). There would be no direct impacts on air 

quality and AQRVs from leasing actions. However, it is reasonable to foresee that on-the-ground 

impacts would occur if the Forest Service were to consent to leasing and the BLM were to issue 

geothermal leases. 

The potential impacts of geothermal development on air quality and AQRVs were evaluated by 

examining the typical air emissions associated with the various stages of geothermal 

development. The emissions from potential geothermal well development were compared against 

the PSD construction permit threshold. There are no federally designated nonattainment areas in 

the project area, so CAA conformity guidelines do not apply.

Indicators

The indicators of impacts on air quality are as follows:

 Emissions in tons per year for regulated pollutants

 Comparison to PSD permitting thresholds

 Amount and time frame of steam and water vapor emitted from potential project operations

Assumptions

 BMPs, such as those identified in Appendix C, would be applied, as applicable, at the BLM 

permitting level to minimize impacts on air quality from exploration, drilling operations, 

utilization, and reclamation and abandonment.

 State air permitting requirements would depend on the timing, scope, and size of sitespecific geothermal exploration, development, and utilization proposals and would be 

determined during project-level analysis prior to approval.

 Based on existing temperature gradient data, binary cycle power plants (which operate at 

lower temperatures than flash steam or dry steam plants) are the most likely technology that 

would be developed in the project area. Therefore, this analysis does not assess the potential 

impacts of flash steam or dry steam geothermal power plants. Binary plants are closed-loop 

systems and do not emit air pollutants during their operation. For this reason, only emissions 

from exploration and development are evaluated. 

 Binary plants would use air cooling rather than wet cooling.

 A total of 25 leases would be issued during the 15-year RFDS time frame (2016 to 2031).
Chapter 3. Affected Environment and Environmental Consequences

3-62 Santa Fe National Forest Geothermal Leasing EIS

 Five 25-megawatt binary power plants would be developed on leases in the project area. 

 Total surface disturbance associated with geothermal exploration would be 27 acres.

 Total surface disturbance associated with development drilling and utilization would be 647

acres, including disturbance associated with developing wells, transmission lines, pipelines, 

roads, power plants, and ancillary facilities.

Geothermal leasing would have no direct impacts on air quality and AQRVs; any impacts would 

occur from subsequent development activities.

3.10.2.3 Common Impacts Associated with Geothermal Development

This section addresses the general air quality and AQRV impacts associated with each phase of 

geothermal development. The common impacts associated with exploration, drilling, utilization, 

and reclamation and abandonment presented in the 2008 Geothermal Programmatic EIS (BLM 

and Forest Service 2008; Section 4.8.3, Common Impacts on Air Quality and Atmospheric 

Values Associated with Geothermal Development) are summarized below. 

Some activities resulting in air quality emissions are common to all phases of a geothermal 

project life cycle, while others are specific to certain phases. Table 4-1 in the Geothermal 

Programmatic EIS (BLM and Forest Service 2008) summarizes the activities and the criteria 

pollutants of concern related to those activities and are incorporated here by reference.

General Geothermal-Related Air Quality Impacts Associated with Each Phase of 

Geothermal Development

Exploration

Air quality and AQRV impacts associated with exploration are short term and are generally 

limited to the release of fugitive dust from surface disturbance and emissions from vehicles and 

construction and drilling equipment. Initial exploration activities, such as surveying and 

sampling, would have minimal impacts on air quality and AQRVs. These impacts would be from 

accessing exploration sites in areas without roads and from disturbing small land areas while 

placing surveying equipment. Secondary exploration activities, specifically site clearing, 

exploration well pad development, and drilling temperature gradient wells and slim wells, would 

have more intensive fugitive dust and exhaust-related emissions and would last longer. The total 

time for exploration activities typically ranges from one to five years.

Drilling Operations

Air emissions during the drilling operations phase of a geothermal project are fugitive dust and 

emissions from combustion engines. The following specific activities during the drilling 

operations phase would result in emissions of fugitive dust and exhaust from combustion 

engines:

 Driving vehicles, such as worker vehicles, watering trucks, and materials delivery trucks, on 

access roads

 Removing vegetation cover 

 Constructing roads and well pads

 Drilling production and injection wells

 Constructing fluid sump pits
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-63

As successful wells are drilled, geothermal fluids venting to the atmosphere are an additional 

source of air pollutant emissions. Well venting introduces the potential release of hydrogen 

sulfide, carbon dioxide, mercury, arsenic, and boron when these compounds are present in the 

geothermal resource. Hydrogen sulfide is generally the primary pollutant of concern if present in 

the geothermal resource. The NMED may require a project proponent to establish an air 

monitoring program for hydrogen sulfide emissions. 

Utilization

Constructing a geothermal power plant and its associated infrastructure—roads, pipelines, and 

transmission lines—during the onset of the utilization phase would create fugitive dust and 

exhaust from combustion engines. Fugitive dust and exhaust from combustion engines during 

operations in the utilization phase would be generally limited to worker and maintenance vehicle 

traffic.

A binary cycle geothermal power plant does not emit air pollutants, except from well venting 

during maintenance or leaks in the heat exchangers, which could result in the release of volatile 

organic compounds. The working fluid in a binary power plant may be condensed through air or 

water cooling. Water cooling produces condensed water vapor plumes. While these plumes do 

not have a large impact in terms of pollutant emissions, they are a concern in areas of high visual 

sensitivity, including in the four Class I areas near the project area. Air cooling does not produce 

steam plumes.

Reclamation and Abandonment

Air quality and AQRV impacts during reclamation and abandonment would be limited to 

emissions from vehicles, trucks, and construction equipment and to fugitive dust from the 

movement of vehicles and reclamation of disturbed areas. Depending on the flow and 

temperature of the geothermal fluids or steam at the well heads at the time of abandonment, well 

capping could release the range of pollutants listed above under General Impacts by Geothermal 

Development Phase—Drilling Operations.

Emissions by Geothermal Development Phase for the Reasonably Foreseeable 

Development Scenario

This section describes the air pollutant emissions from each stage of geothermal exploration and 

development, as described in the RFDS, which also describes the phases as exploration, 

development drilling and utilization, and final plugging and reclamation. Because the RFDS is

the same under all alternatives except Alternative 3, emissions under each of the other 

alternatives would be the same. 

Exploration

Exploration would have temporary impacts on air quality and AQRVs from construction and 

drilling. Sources of temporary and localized fugitive dust emissions are the following:

 Surface disturbance for temperature gradient wells, slim wells, and exploration roads

 Travel on unpaved roads and surfaces by commute vehicles, delivery trucks, water trucks, 

and tractor trailers

 Travel on paved roads by commute vehicles, delivery trucks, water trucks, and tractor 

trailers
Chapter 3. Affected Environment and Environmental Consequences

3-64 Santa Fe National Forest Geothermal Leasing EIS

Sources of temporary exhaust-related criteria pollutant emissions are the following:

 Gas- and diesel-powered construction equipment for exploration road development

 Drill rigs and auxiliary equipment to develop temperature gradient wells and slim wells

 Tractor trailers to bring in and move out construction and drilling equipment

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for road construction and drill rig personnel 

Diesel-fired equipment and trucks would also emit small quantities of diesel particulate matter, 

acetaldehyde, benzene, and formaldehyde. 

Temperature gradient wells do not typically come in contact with the geothermal resource; 

therefore, no release of naturally occurring non-condensable gases, such as carbon dioxide or 

hydrogen sulfide, or trace amounts of boron, mercury, or arsenic would occur. Slim wells do 

encounter the geothermal resource and thus have the potential to release these gases; blowoutprevention equipment and monitoring devices for hydrogen sulfide may be required for slim well 

development and would be determined at the project-level planning stage.

Under the RFDS, the geothermal exploration time frame is one to five years of the 15-year 

RFDS time frame. Table 3-8, below, summarizes the number and type of wells and the area of 

surface disturbance associated with exploration under the RFDS.

Table 3-8. Summary of Geothermal Exploration Activities and Surface Disturbance

Activity

Amount Expected 

over 15-Year RFDS

Time Frame (2016 to 

2031)

Amount of 

Disturbance 

(Acres)

Disturbance over Project 

Area over 15-Year RFDS

Time Frame (Acres)

Temperature gradient wells 15 wells 0.25 3.75

Slim wells 5 wells 2.80 14.00

Exploration roads 10 miles of road 

widened by 8 feet

N/A 9.7

Total 27.45

Source: BLM 2015

Table 3-9, below, depicts potential emissions for exploration associated with geothermal 

exploration drilling, based on the parameters described in Table 3-8, above. Emissions are 

presented to develop a single exploration well and include the following categories:

 Emissions from on-road vehicles and trucks 

 Fugitive dust from vehicle travel on unpaved roadways

 Fugitive dust from vehicle travel on paved roadways

 Emissions from drill rigs and auxiliary equipment 

Emissions from developing a single well are multiplied by the total number of wells to estimate 

the total well drilling emissions that would be associated with the RFDS.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-65

In addition to the drilling-related emissions shown in Table 3-9, the following construction 

activities would produce emissions:

 Construction equipment not used for road development

 Fugitive dust during road development

Table 3-9. Geothermal Exploration Well Drilling Emissions

Activity1 Carbon 

Monoxide

Nitrogen 

Oxides

Volatile 

Organic 

Compounds

Sulfur 

Oxides PM10 PM2.5

On-road vehicle exhaust (tons 

per well)

0.0281 0.0279 0.0042 0.0001 0.0015 0.0012

Unpaved road dust2(tons per well) - - - - 0.6855 0.0685

Paved road dust (tons per well) - - - - 0.0260 0.0033

Drill rig and auxiliary equipment 

(tons per well)

0.1484 0.5419 0.0417 0.0157 0.0339 0.0329

Total (tons per well) 0.1484 0.5419 0.0417 0.0157 0.7469 0.1059

Total3(tons per RFDS [20 

wells])

3.53 11.40 0.92 0.32 14.94 2.12

Source: Forest Service GIS 2015

1

Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2

Assumes dust control using watering and speed limits; dust could be further controlled with chemical dust suppressants 

or by covering roads with aggregate.

3

Emissions from vehicle travel (on-road exhaust and paved and unpaved road dust) would likely be less under the full 

RFDS, as drill rig equipment and other construction equipment would likely be moved from well site to well site, resulting 

in fewer miles traveled than calculated for a single well development. 

The primary pollutants of concern relative to construction emissions are fugitive dust from 

surface disturbance, wind erosion, and travel on unpaved surfaces and criteria pollutant, 

primarily nitrogen oxide, emissions from the operation of diesel-fired construction equipment,

and heavy truck traffic. Because emissions from construction would be temporary and localized 

and would occur intermittently over one to five years, construction-related emissions from road 

development have not been quantified for this analysis.

BMPs, such as those identified in Appendix C, would be applied at the permit level to minimize 

impacts on air quality and AQRVs from construction and surface disturbance. These include 

measures to mitigate equipment exhaust emissions and measures to control fugitive dust. BMPs 

would be incorporated into the permit application or may be included in the approved use 

authorization as conditions of approval. 

Development Drilling and Utilization

Development drilling and utilization would have temporary impacts on air quality and AQRVs

from construction and drilling. Sources of temporary and localized fugitive dust emissions would 

be the following:

 Surface disturbance for well pads, transmission lines, pipelines, roads, and power plant 

construction

 Travel on unpaved roads and surfaces by commute vehicles, delivery trucks, water trucks, 

and tractor trailers
Chapter 3. Affected Environment and Environmental Consequences

3-66 Santa Fe National Forest Geothermal Leasing EIS

 Travel on paved surfaces by commute vehicles, delivery trucks, water trucks, and tractor 

trailers

Sources of temporary exhaust-related criteria pollutant emissions would be the following:

 Gas- and diesel-powered construction equipment for well pad, transmission line, pipeline, 

road, and power plant construction

 Drill rigs and auxiliary equipment to develop production and injection wells

 Tractor trailers to bring in and move out construction and drilling equipment and materials to 

construct the power plants

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for construction and drill rig personnel 

As described above under Exploration, diesel-fired equipment and trucks would also emit small 

quantities of diesel particulate matter, acetaldehyde, benzene, and formaldehyde. 

In addition to diesel equipment and vehicle emissions, well drilling has the potential to release 

non-condensable gases, such as carbon dioxide, hydrogen sulfide, methane, and ammonia, as 

well as trace amounts of mercury, boron, and arsenic when these compounds are contained in the 

geothermal resource. The amount and ratio of these constituents varies by geothermal resource, 

with carbon dioxide generally comprising over 95 percent of the non-condensable gases. Noncondensable gases would be emitted during flow testing, but this would be temporary, lasting 

until the well is shut in or connected to the pipeline.

While the exact characterization of the geothermal resource that would be developed is not yet 

known, there is potential for hydrogen sulfide to be present in the resource. Hydrogen sulfide is 

the non-condensable gas of greatest concern because it can pose a threat to human health at high 

concentrations (BLM and Forest Service 2008). It also can result in nuisance odor conditions, 

even at levels below the state standard for hydrogen sulfide. Hydrogen sulfide releases are of 

greatest concern in the event of a well blowout. Blowout prevention equipment may be required 

for well development, so large releases of hydrogen sulfide during well development would be 

unlikely. Some minor releases of hydrogen sulfide could occur during well drilling and flow 

testing. 

The NMED may require that monitoring devices be installed and operated during drilling and 

testing and that a hydrogen sulfide abatement plan be developed. Any necessary mitigation 

measures and BMPs would be determined during project-specific NEPA analysis and NMED air 

permitting at the project-level stage. Such measures as monitoring and abatement would ensure 

that hydrogen sulfide emissions would not result in unsafe levels and would prevent potential 

nuisance odors if hydrogen sulfide is present in the geothermal resource.

Under the RFDS, the development drilling and utilization time frame is two to ten years of the 

15-year RFDS time frame. Table 3-10, below, summarizes the number of wells and the area of 

surface disturbance associated with development drilling under the RFDS.

Production well development requires much larger drill rigs and auxiliary equipment and longer 

drilling times than exploration well development. As such, emissions from development drilling 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-67

Table 3-10. Summary of Geothermal Development Drilling and Surface Disturbance 

Component

Amount Expected over 

the 15-Year RFDS Time 

Frame (2016 to 2031)

Amount of 

Disturbance (Acres)

Disturbance in the Project 

Area over 15-Year RFDS

Time Frame (Acres)

Wells 30 wells 5.0 acres per well 150.00

Transmission lines Maximum of 14 miles at a 

width of 200 feet

N/A 339.00 

Pipelines Maximum of 7 miles per 

power plant with a width of 

25 feet

21.2 acres per power 

plant

106.00

Roads 10 miles of road widened 

by 2 feet

N/A 2.42

Power plants and 

ancillary facilities

5 power plants 10.0 acres per power 

plant

50.00

Total 647.42

Source: BLM 2015

operations are much greater than from exploration well operations. For comparison purposes, on a 

per-well basis, emissions from development drilling operations would not exceed Pre-Construction 

and New Source Review permit rates of 25 tons per year of criteria pollutants, or PSD construction 

permit limits for major stationary sources of 250 tons per year of any regulated pollutant. However, 

production well development associated with a single proposed geothermal power plant (six wells) 

could exceed the Pre-Construction and New Source Review permit rate. Development of the 30 

wells together would not exceed the PSD construction permit limit of 250 tons per year for any 

regulated pollutant. The RFDS indicates that exhaust emission and dust would be controlled to 

meet applicable air quality standards for the duration of the drilling operation.

In addition to the development drilling-related emissions shown in Table 3-11, the following 

construction activities would produce air pollutant emissions:

 Non-road construction equipment emissions for well pad, transmission line, pipeline, road, 

and power plant construction

 On-road vehicle equipment emissions from material and equipment deliveries, water trucks, 

concrete trucks, and construction personnel commute vehicles

 Fugitive dust emissions from well pad, transmission line, pipeline, road, and power plant 

development

As described above under Exploration, the primary pollutants of concern relative to construction 

emissions are fugitive dust from surface disturbance, wind erosion, travel on unpaved surfaces, 

and criteria pollutant emissions, primarily nitrogen oxide, from the operation of diesel-fired 

construction equipment and heavy truck traffic. Because emissions from construction would be 

temporary and would occur over two to ten years, construction-related emissions from these 

activities have not been quantified for this analysis. 

Construction for development and utilization would occur at a scale requiring air permits from 

NMED, as well as implementation of measures to mitigate fugitive dust emissions and 

equipment exhaust emissions. BMPs, such as those identified in Appendix C, would be applied, 

as needed, at the BLM permitting level to minimize impacts on air quality from construction and 

surface disturbance. BMPs would be incorporated into the permit application or may be included 

in the approved use authorization as conditions of approval. 
Chapter 3. Affected Environment and Environmental Consequences

3-68 Santa Fe National Forest Geothermal Leasing EIS

Table 3-11. Geothermal Development Drilling Emissions

Activity1 Carbon 

Monoxide

Nitrogen 

Oxides

Volatile 

Organic 

Compounds

Sulfur 

Oxides PM10 PM2.5

On-road vehicle exhaust 

(tons per well)

0.0959 0.0765 0.0139 0.0004 0.0047 0.0036

Unpaved road dust2(tons 

per well)

- - - - 2.96 0.30

Paved road dust (tons per 

well)

- - - - 0.1091 0.0138

Drill rig and auxiliary 

equipment1(tons per well)

1.85 7.15 0.52 0.15 0.38 0.36

Total (tons per well) 1.85 7.15 0.52 0.15 3.4538 0.6774

Total3(tons per 6 wells) 11.68 43.36 3.20 0.90 20.72 4.06

Total (tons per RFDS [30 

wells])

58.38 216.80 16.02 4.51 103.61 20.32

Source: Forest Service GIS 2015

1

Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2

Assumes dust control using watering and speed limits; dust could be further controlled with chemical dust suppressants 

or by covering roads with aggregate.

3

Emissions from vehicle travel (on-road exhaust and paved and unpaved road dust) would likely be less under the full 

RFDS. This is because drill rig equipment and other construction equipment would likely be moved from well site to well 

site, resulting in fewer miles traveled than calculated for a single well development. In addition, commute-related 

emissions may be less if on-site worker camps were developed for drill rig personnel.

Under the RFDS, five 25-MW geothermal binary cycle power plants would operate for 30 to 50 

years. Operating a binary cycle geothermal power plant does not emit air pollutants, except from 

well venting during maintenance or from leaks in the heat exchangers, which could result in the 

release of volatile organic compounds.

Binary cycle power plants operate on water at temperatures of approximately 225oF to 360oF. 

Binary cycle plants use the heat from the hot water to boil a working fluid, usually an organic 

compound with a low boiling point. The working fluid is vaporized in a heat exchanger and is 

used to turn a turbine. The water is then injected back into the ground to be reheated. Under 

normal operations, binary power plants operate in a closed environment, where the geothermal 

fluid and the working fluid do not contact the atmosphere. The working fluid is a substance with 

a low boiling point, typically a butane or pentane hydrocarbon. 

Because the power plant would be a closed system with the working fluid rarely exposed to the 

atmosphere, little impact on air quality is expected from the operation of the power plant. During 

maintenance or if there are leaks in the system, there may be emissions of nitrogen, carbon 

dioxide, and oxygen from the working fluid. Mitigation measures, such as those identified in 

Appendix C, may be applied at the permit level to monitor for emissions from plant operations.

In addition, the RFDS indicates that because of the cool air temperatures and the scarcity of 

water in the project area, the binary plants would likely be air cooled instead of water cooled. 

Air-cooled plants do not produce steam plumes; therefore, plant operations would not affect 

visibility in any of the four Class I areas within 62 miles of the project area. Operation of a 

binary power plant would likely have emissions below the level that constitutes a major source 

of new emissions in the federal PSD program.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-69

The RFDS estimates that each plant would employ 9 shift workers and up to 12 additional 

workers per day. Emissions would be limited primarily to vehicle and maintenance equipment, 

including vehicle commute traffic, delivery traffic, and on-site maintenance truck and equipment 

use. These emissions would be low. 

Reclamation and Abandonment

Air quality and AQRV impacts during reclamation and abandonment would include emissions 

from vehicles, construction equipment, and truck traffic, from dismantling the power plant and 

other unnecessary infrastructure, and fugitive dust from the movement of vehicles and 

reclamation of disturbed areas. Depending on the flow and temperature of the geothermal fluids 

or steam at the well heads at the time of abandonment, well capping could result in the potential 

release of the range of pollutants listed above under Development Drilling and Utilization. 

Because reclamation and abandonment would occur 30 to 50 years in the future, no emissions 

have been calculated for this action. However, these activities would be subject to NEPA analysis 

and BLM permitting, at which time mitigation measures and BMPs would be determined to 

minimize or mitigate impacts on air quality.

3.10.2.4 Impacts Under Alternative 1

Alternative 1 would have the same impacts on air quality as described under Emissions by 

Geothermal Development Phase for the RFDS, above. Well drilling emissions, as quantified in 

Table 3-9 and Table 3-11, would emit criteria air pollutants, hazardous air pollutants, and GHGs

in the project area. Exploration drilling emissions for all 20 wells would be far below the PSD 

permitting threshold of 250 tons per year (presented for comparison purposes only). These 

emissions would also be less than 1 percent of county emission levels described in Table 3-7 for 

all criteria pollutants.

Development drilling would produce a greater level of emissions. Emissions to develop and 

complete all 30 wells would still be below the PSD permitting threshold of 250 tons per year. 

These emissions would also be less than 1 percent of county emission levels described in Table 

3-7 for volatile organic compounds, carbon monoxide, PM10, and PM2.5 (when fugitive dust is 

included), 1.35 percent of county emissions for nitrogen oxides, and 4.05 percent of county 

emissions for sulfur dioxide. Thus, development drilling would contribute to county emissions 

but not to a substantial degree, relative to overall emissions. Drilling emissions would be a 

temporary and short-term source of emissions.

Construction activities would emit similar pollutants, as described for drilling. However, they 

would be at lower levels for exploration and at similar or lower levels for development and 

utilization, given the amount of surface disturbance described in Table 3-10 and the diesel-fired 

heavy construction equipment that would be necessary to construct the power plants and 

associated infrastructure. As described under Emissions by Geothermal Development Phase for 

the Reasonably Foreseeable Development Scenario, construction would be temporary and would 

occur over a one- to five-year exploration time frame and a two- to ten-year development time 

frame.

Both drilling and construction emissions would be minimized or mitigated through BMPs

applied at the permit level to minimize impacts on air quality from well drilling, facility and 

infrastructure construction, and surface disturbance. BMPs would be incorporated into the permit

applications or may be included in the approved use authorizations as conditions of approval. 

BMPs identified in Appendix C include measures to mitigate equipment exhaust emissions and 

control fugitive dust. State air permitting would impose additional limits on allowable emissions 
Chapter 3. Affected Environment and Environmental Consequences

3-70 Santa Fe National Forest Geothermal Leasing EIS

from future development activities. The permits required and the conditions imposed in these 

permits would be determined during project-specific permitting processes.

Long-term emissions from operating the binary cycle geothermal power plants would be low. 

Binary cycle power plants are closed-loop systems and generally do not emit pollutants under 

normal operating conditions. Because the plants would be air cooled, they would not emit steam 

plumes and, therefore, would not affect visibility in the four Class I areas within 62 miles of the 

project area. They also would not emit hydrogen sulfide; therefore, plant operations would not 

cause nuisance odor conditions.

3.10.2.5 Impacts Under Alternative 2

The RFDS under Alternative 2 would be the same as described under Alternative 1; therefore, 

impacts related to the overall levels of emissions would be the same. Impacts on AQRVs would 

also be the same. 

While the moderate to major constraints in areas open to geothermal leasing would not affect the 

overall level of emissions that would result from geothermal development in the project area, it 

may alter the locations where geothermal development would occur. More areas would be 

constrained under Alternative 2 than under Alternative 1; therefore, geothermal exploration and 

development under Alternative 2 could occur in a smaller area in the project area than under 

Alternative 1. As the RFDS indicates that geothermal plants would be spaced by one mile or 

more, the overall direct and indirect impacts would be the same as described under Alternative 1.

3.10.2.6 Impacts Under Alternative 3

Under Alternative 3, there would be no geothermal development; therefore, no direct or indirect 

impacts on air quality or AQRVs would occur.

3.10.2.7 Impacts Under Alternative 4

Direct and indirect impacts on air quality and AQRVs under Alternative 4 would be the same as 

described for Alternative 1.

3.10.2.8 Cumulative Impacts

Cumulative air quality impacts occur when multiple projects affect the same geographic area at 

the same time, or when sequential projects extend the duration of air quality impacts on a given 

area over a longer period. Air quality monitoring data trends can predict future air quality 

conditions in the cumulative impacts area. Past and present actions in the project area have 

affected air quality such that monitored levels of ozone are nearing the NAAQS. Ozone levels 

generally are attributed to oil and gas operations and power plants, including the San Juan 

Generating Station and the Four Corners Power Plant, in the region (Four Corners Air Quality 

Task Force 2007).

Past and present actions on SFNF lands that have affected air quality are those related to 

development, including timber harvest, road development, and mineral development. 

Reasonably foreseeable actions would also affect air quality, including pumice mine expansion 

and development and actions related to vegetation management. These actions would have 

temporary and intermittent air quality impacts from vehicle and equipment use and surface 

disturbance. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-71

The contribution of Alternatives 1, 2, and 4 to cumulative air pollutant emissions would be 

minor, and such impacts would be minimized by implementing BMPs identified in Appendix C. 

Air quality impacts from these alternatives would consist of temporary impacts during well 

exploration and development. As a result, the potential for cumulative impacts from this 

alternative would be short term and minimal, as binary cycle power plants are closed-loop 

systems and do not emit pollutants under normal operating conditions. Alternative 3 would not 

emit air pollutants; therefore, there would be no cumulative impacts associated with this 

alternative.

3.11 Vegetation

3.11.1 Affected Environment

There are twelve major vegetation communities in the 194,900-acre project area (Table 3-12, 

Major Vegetation Communities in the Project Area, and Figure 2 in the SFNF Geothermal 

Leasing EIS, Wildlife, Fisheries, and Plants Report [Forest Service 2016e]). 

Table 3-12. Major Vegetation Communities in the Project Area

Vegetation Community Acres Percent of Project Area

Blue grama grassland 3,200 1.6

Perennial grass mix 7,400 3.8

Big sagebrush 4,100 2.1

Deciduous shrub mix 5,500 2.8

Aspen 4,900 2.5

Juniper 11,100 5.7

Pinyon/pinyon-juniper 20,800 10.7

Ponderosa pine 65,200 33.4

Spruce and fir 9,600 4.9

Upper deciduous evergreen mix 63,200 32.4

Sparsely vegetated Less than 100 0.0

Total 194,900 100.00

Source: Forest Service GIS 2015

The dominant vegetation communities are ponderosa pine (Pinus ponderosa), upper deciduous 

evergreen mix, and pinyon-juniper. The ponderosa pine forest vegetation community is 

dominated by ponderosa pine but includes other species, such as oak (Quercus spp.), juniper

(Juniperus spp.), and pinyon (Pinus edulis). Such species as aspen (Populus tremuloides), 

Douglas-fir (Pseudotsuga menziesii), white fir (Abies concolor), and blue spruce (Picea 

pungens) may also be present but occur infrequently as small groups or individual trees. This 

forest vegetation community typically occurs with an understory of grasses and forbs and 

sometimes includes shrubs. There are 65,200 acres of ponderosa pine forest, covering 

approximately 33 percent of the project area.

Suitable mature ponderosa pine habitat is abundant in the project area; however, much of this 

forest type has become crowded and overstocked with relatively young trees. Open areas are

gradually filling in with trees. These systems have moved from open forests, dominated by 

groups and clumps of trees of different ages and sizes, to a dense, continuous blanket of even-
Chapter 3. Affected Environment and Environmental Consequences

3-72 Santa Fe National Forest Geothermal Leasing EIS

aged (80- to 90-year-old), pole-sized (5- to 12-inch-diameter) trees. Tree densities in the 

southwest Jemez Mountains have increased 10-fold, from an average of 15 to 56 trees per acre to 

500 trees per acre (Forest Service 2010). There are fewer large (over 18-inch-diameter) trees, old

growth trees, snags, and down wood. 

Openings and understory plants are scarce. The common, open park-like characteristic of 

reference conditions for ponderosa pine forests (Swetnam and Baisan 1996) promoted greater 

faunal diversity and were better adapted to fire than the dense stands of today. Ponderosa pine 

forests in the project area are generally denser and more continuous than in pre-settlement 

reference conditions, and accumulations of forest litter and woody debris are much higher than 

would have occurred under the historic disturbance regime. The dense tree canopy also inhibits 

the growth of understory grasses, forbs, and shrubs. Instead, there is a carpet of pine needles.

The lack of fire disturbance has led to fuel loads that increase the risk of uncharacteristically 

severe wildfire and drought-related mortality. This means there is more competition for light, 

water, and nutrients. On average, the trees are now smaller and grow more slowly. There is a 

moderate risk of insect and disease outbreak, which is also a function of increased tree density.

The spruce/fir community occurs in high elevation areas in the project area. This community is 

dominated by blue spruce, Douglas-fir, and white fir. Mature and old growth spruce/fir forests on 

the SFNF provide valuable habitat for various special status wildlife species. There are 9,600 

acres of spruce/fir, covering approximately 5 percent of the project area.

Upper deciduous evergreen mix is present throughout the project area between the ponderosa 

pine and the spruce/fir vegetation communities. This community contains a mix of ponderosa 

pine, blue spruce, Douglas-fir, white fir, and aspen. The canopy cover for this community is 

composed of less than 75 percent deciduous trees (Brohman and Bryant 2005). There are 63,200 

acres of upper deciduous evergreen mix, covering approximately 32 percent of the project area.

Aspen-dominated stands are currently a minor part of New Mexico forests and forests in the 

project area, though they are considered important for providing diversity of wildlife habitat, 

forage, and watershed values in the conifer-dominated forests. There are approximately 4,900 

acres of aspen covering approximately 3 percent of the project area. Aspen forests are unusual 

because they reproduce primarily by suckering from the parent root system. Often a disturbance 

or dieback is necessary to stimulate stand regeneration.

The pinyon/pinyon-juniper cover type is collectively composed of the pinyon woodland, pinyonjuniper grassland, pinyon-juniper sagebrush, pinyon-juniper evergreen shrub, and pinyon-juniper 

persistent woodland communities. Two-needle pinyon pine (Pinus edulis) is common, as is oneseed (Juniperus monosperma), Utah (J. osteosperma), Rocky Mountain (J. scopulorum), and 

alligator (J. deppeana) juniper. Species composition and stand structure vary by location,

primarily due to precipitation, elevation, temperature, and soil type. There are 20,800 acres of 

pinyon-juniper habitat, comprising approximately 11 percent of the project area.

Most of the pinyon-juniper vegetation communities are younger and denser than they were 

historically because of changes in wildfire occurrence and past livestock and wildlife grazing. 

Greater tree density has increased competition for water and nutrients. This, in turn, has caused a 

reduction in understory plant cover and diversity, a loss of ground cover, and subsequent 

increases in soil erosion. Pinyon-juniper woodland supports a wider array of birds and mammals 

than ponderosa pine forest. Several species of birds are directly associated with pinyon-juniper 

habitats, including pinyon jays (Gymnorhinus cyanocephalus) and juniper titmice (Baeolophus 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-73

ridgwayi). Woodlands provide key winter habitat for a range of species, including ungulates and 

raptors. 

The pinyon-juniper communities produce hard mast that supports high densities of small 

mammals, making these areas important for foraging carnivorous species, including black bear

(Ursus americanus), birds, and snakes. Many wildlife species select large trees for foraging and 

large snags for nesting. Current conditions slow the growth rates of trees, prolonging the time 

required to develop old and large trees. Slowed growth rates can also leave large and old trees 

more vulnerable to short- and long-term weather and climate trends (Kane and Kolb 2014). The 

delay in replacing this component of woodland habitat also delays future large-diameter snag 

recruitment.

Riparian areas occupy a small percent of the landscape of the project area; however, their 

importance far outweighs their representation on the landscape. Riparian areas provide valuable 

habitat for fish, wildlife, migratory birds, and special status species. Riparian areas are found as 

narrow bands of shrubs or trees lining stream banks, seeps, and springs. Often riparian areas are 

composed of a mosaic of multiple communities and are found throughout the project area. 

Riparian habitat in the project area occurs along the Jemez River, Redondo Creek, San Antonio 

Creek, Rio Cebolla, Coyote Creek, and other perennial and intermittent streams, seeps, and 

springs. Common species include alder (Alnus spp.), willow (Salix spp.), aspen, maple (Acer 

spp.), dogwood (Cornus spp.), cottonwood (Populus spp.), and ash (Fraxinus spp.; Dreesen et al. 

2002).

Nonnative and invasive plants (also known as noxious weeds) are aggressive and displace native 

plant species. The National Invasive Species Council defines invasive species as “those (species) 

that are not native to the ecosystem under consideration and that cause or are likely to cause 

economic or environmental harm or harm to human, animal, or plant health.” Noxious and 

invasive weeds that have the potential to occur in the project area are bull thistle (Cirsium 

vulgare), Canada thistle (C. canadensis), field bindweed (Convolvulus arvensis), nodding thistle 

(Carduus nutans), poison hemlock (Conium maculatum), cheatgrass (Bromus tectorum), oxeye 

daisy (Leucanthemum vulgare), spotted knapweed (Centaurea stoebe), dalmation toadflax 

(Linaria dalmatica), Russian olive (Elaeagnus angustifolia), saltcedar (Tamarix spp.), Siberian 

elm (Ulmus pumila), hoary cress (Cardaria draba), scotch thistle (Onopordum acanthium), and 

Russian knapweed (Rhaponticum repens; Forest Service 2013).

The natural fire regime has been interrupted since the late 1800s. High numbers of sheep and 

cattle that grazed in the Jemez Mountains reduced the native grasses that carried surface fires. 

The Forest Service suppressed wildfires, even those that would have benefited the landscape. 

Without fire to control their numbers, seedlings and saplings thrived. As a result, the forests in 

the project area are dominated by dense thickets of pole-sized trees (5 to 16 inches in diameter). 

Understory plants and grasses, large, thick-barked pine trees, and old growth are lacking. The 

species composition has shifted, and ponderosa pine forests now resemble mixed conifer forests 

with more Douglas-fir, white fir, and limber pine (Forest Service 2015b). 

3.11.2 Environmental Consequences

3.11.2.1 Scoping Comments on Resource

The following issues specific to vegetation were identified during the public scoping period:

 How would vegetation loss from geothermal leasing affect soil erosion?
Chapter 3. Affected Environment and Environmental Consequences

3-74 Santa Fe National Forest Geothermal Leasing EIS

 How would noxious and invasive weeds be managed in geothermal leasing areas?

3.11.2.2 How Resource Impacts Were Evaluated

Method

Leasing geothermal resources would not affect vegetation or important habitats and 

communities. These resources would be affected only by development of specific geothermal 

projects that occurred after the leasing action. Potential impacts of geothermal development were 

evaluated based on the typical disturbance of geothermal projects for the various stages of 

development and then were assessed based on projected intensity, as described in the RFDS

(BLM 2015). The types of vegetation and important habitats and communities that could be 

affected by geothermal development depend on the specific location of the proposed projects, 

which are unknown at this time. In general, the vegetation communities described in Section 

3.11 could be affected by geothermal development, as described below.

Indicators

Potential impacts on vegetation could occur if anticipated future actions, consistent with 

implementing the alternatives described in Chapter 2, were to result in the following:

 Affect a plant species, habitat, or natural community recognized for ecological, scientific, 

recreational, or commercial importance

 Affect a species, habitat, or natural community that is specifically recognized as biologically 

significant in local, state, or federal policies, statutes, or regulations

 Establish or increase noxious weed populations

 Destroy or extensively alter habitats or vegetation communities in such a way that would 

render them unfavorable to native species

 Conflict with Forest Service management strategies

Assumptions

This analysis assumes the following:

 NSO stipulations would generally prevent direct disturbance to vegetation by restricting 

surface-disturbing activities where they are applied, except when exceptions, waivers, or 

modifications are met.

 CSU stipulations could be used to avoid impacts on sensitive vegetation in certain areas.

 The degree of impact attributed to any one disturbance or series of disturbances would be 

influenced by several factors, including location in the watershed; the type, time, and degree 

of disturbance; existing vegetation; the amount, type, and timing of precipitation; and 

mitigating actions applied to the disturbance.

 The Forest Service would comply with its own weed control plans.

3.11.2.3 Common Impacts Associated with Geothermal Development

Common impacts on vegetation associated with geothermal development are described in the 

2008 Geothermal PEIS (BLM and Forest Service 2008) and are incorporated into this document 

by reference.

Regardless of the location of geothermal development projects, the nature of impacts from 

exploration and development on vegetation would be similar in all vegetation communities. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-75

Vegetation would be affected by direct destruction and removal, erosion, and fugitive dust. In 

addition, potential direct and indirect impacts could occur from exposure to such contaminants as 

oil and fuel leaks from heavy equipment, accidental fire caused by on-site workers or heavy 

equipment, and the introduction of invasive species. However, BMPs identified in Appendix C

would minimize these risks.

The extent of the impacts is typically associated with the size of the area that is disturbed and the 

types of vegetation habitats and communities present. In general, localized impacts from 

geothermal development on the scale anticipated by the RFDS on vegetation communities that 

are common in the project area, such as ponderosa pine and upper deciduous evergreen mix 

forests, would be unlikely to change the composition or health of most vegetation communities.

3.11.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Vegetation 

communities may be impacted by habitat alteration, removal, reduction, or fragmentation. Up to 

674 acres may be disturbed in vegetation communities in the project area. The Forest Service has 

determined that the JNRA (approximately 28,900 acres) is excluded from geothermal leasing on 

the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and executive orders. There 

would be no direct disturbance to vegetation within the JNRA under Alternative 1.

3.11.2.5 Impacts Under Alternative 2

Under Alternative 2 approximately 32,000 acres would be closed to geothermal leasing, while 

approximately 136,650 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations.

Vegetation communities may be impacted by habitat alteration, removal, reduction, or 

fragmentation. Up to 674 acres of disturbance may occur in vegetation communities in the 

project area; however, the location of disturbance is unknown. Vegetation at drilling pads, 

facilities, roadways, and transmission corridors may be affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. Impacts on wetland and riparian areas would be minimized by 

the leasing stipulations described in Chapter 2.

Fragmentation can facilitate the spread and introduction of invasive plant species. Roads and 

other corridors can facilitate the dispersal of invasive species by altering existing habitat 

conditions, stressing or removing native species, and allowing easier movement by wild or 

human vectors (Trombulak and Frissell 2000). Sensitive plants can be affected by invasive 

vegetation through competition for resources and available habitat. BMPs for noxious weeds

include measures such as weed monitoring, education of personnel on weed identification, use of 

certified weed-free mulch, a controlled inspection and cleaning area for vehicles arriving from 

locations with known weed infestations, and developing a plan for control of noxious weeds and 

invasive species.

Geothermal development under Alternative 2 could increase the risk of wildland fire in the 

project area. Equipment operations, increased vehicular and human traffic, use of drilling muds, 

and extraction of geothermal fluids can increase the risk of fires. Vehicles, electrical lines, and 

smoking can all result in accidental fires. High severity wildfires destroy vegetation and seed

banks for native plants. In addition, fire can result in indirect impacts, such as helping establish
Chapter 3. Affected Environment and Environmental Consequences

3-76 Santa Fe National Forest Geothermal Leasing EIS

and spread invasive species by increasing plant resource availability, reducing competition, or 

altering sediment transport of an affected watershed (USGS 2002; Brooks and Lusk 2008). Low 

severity wildfires are important ecologically and help maintain variable tree densities. BMPs

would be followed, and operators would develop a fire management strategy to implement 

measures to minimize the potential for a human-caused fire.

3.11.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3; there would 

be no direct or indirect impacts on vegetation from geothermal activities.

3.11.2.7 Impacts Under Alternative 4

Under Alternative 4 approximately 28,900 acres would be closed to geothermal leasing, while 

approximately 139,800 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. Direct 

and indirect impacts on vegetation would be similar to those under Alternative 2. However, the 

intensity of disturbance could be more severe and certain areas may be more likely to be 

disturbed (specifically intermittent streams and viewsheds with a Scenery Management System 

integrity level of very high). Therefore, impacts on vegetation communities in these areas (direct 

vegetation removal, or indirect spread and establishment of noxious weeds) would be more 

likely.

3.11.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for vegetation is the three level 4 

watersheds that intersect the project area: the Rio Grande-Santa Fe, Rio Chama, and Jemez 

watersheds. Past, present, and reasonably foreseeable future actions within these watersheds are 

the Pueblo of Jemez Red Rocks Dam Repair, the Abiquiu Land Grant Waterline Replacement, 

and the McKinney County Dam; mineral development in the South Pit Pumice Mine Expansion 

and the Duran 2010 Pumice Mine; and habitat improvement projects, such as the Southwest 

Jemez Mountains Restoration Project, the Cerro Pelon Timber Stand and Wildlife Habitat 

Improvement Project, the Pueblo of Jemez Owl Springs Bridge Sediment Removal Project, the 

New Mexico Meadow Jumping Mouse Critical Habitat Protection Project, and the Supplement 

to the Final EIS for Invasive Plant Control Project. 

Implementation of Alternatives 1, 2, or 4 would increase the number of acres of disturbance in 

the region of influence (i.e., the three level 4 watersheds) over the long term, when combined 

with other surface-disturbing projects. However, under Alternatives 2 and 4, NSO and CSU

stipulations would mitigate impacts on vegetation by restricting where development could occur. 

Habitat improvement projects could help to restore vegetation conditions within the cumulative 

impacts analysis area to a more fire-adapted ecosystem. 

As a result of exploration, drilling, and utilization disturbance, there is the potential for 

nonnative and invasive species to colonize and dominate sites. The facilitation of seed dispersal 

could result from construction equipment transporting invasive species from the construction 

areas to adjacent lands along access roads and main roads. However, BMPs identified in 

Appendix C (such as weed monitoring, education of personnel on weed identification, use of 

certified weed-free mulch, a controlled inspection and cleaning area for vehicles arriving from 

locations with known weed infestations, and weed control plans) and other weed control efforts 

on the Coyote, Cuba, Espanola, and Jemez Ranger Districts would reduce this risk. This impact 

could occur under Alternatives 1, 2, and 4.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-77

Geothermal development within the project area could increase the risk of wildland fire in the 

project area, which could spread to adjacent land such as the Valles Caldera. Wildfires that 

spread beyond the project area could further impact vegetation communities affected by recent 

fires, such as the Thompson Ridge fire (2013), Las Conchas fire (2011), Tres Lagunas fire 

(2013), and South Fork fire (2010). The Las Conchas and Thompson Ridge fires in particular 

burned much of the upper deciduous evergreen mix forest type on the Valles Caldera. 

Disturbance in this vegetation type could further alter or remove upper deciduous evergreen mix 

forest communities. However, of the 60,600 acres of upper deciduous-evergreen mix forest type 

in the decision area, the majority would be closed to geothermal leasing or NSO under 

Alternatives 2 and 4. Under Alternative 2, 400 acres would be open subject to standard lease 

terms and conditions, while 1,500 acres would be open subject to standard lease terms and 

conditions under Alternative 4 (Forest Service GIS 2015). BMPs would minimize the potential 

for a human-caused fire.

Combined with other reasonably foreseeable future actions, no significant cumulative impacts on 

vegetation are expected from Alternatives 1, 2, and 4. Alternative 3 would have no cumulative 

impacts on vegetation.

3.12 Fish and Wildlife

3.12.1 Affected Environment

This section discusses management indicator species (MIS) and migratory birds. The detailed 

description and analysis of MIS in the SFNF Geothermal Leasing EIS Fish, Wildlife, and Plant 

Report (Forest Service 2016e) is incorporated by reference and summarized here. In this 

analysis, these species are used as a proxy for all fish and wildlife in the project area. MIS are 

identified as representing a group of species having similar habitat requirements. MIS in the 

SFNF are shown below in Table 3-13.

3.12.1.1 Rocky Mountain Bighorn Sheep

Bighorn sheep serve as a management indicator for alpine meadow habitat. On the SFNF, Rocky 

Mountain bighorn sheep inhabit the highest alpine areas of the Sangre de Cristo Mountains in the 

Pecos Wilderness, outside the project area. Bighorn sheep were reintroduced into the Cochiti 

Canyon, approximately 10 miles southeast of the project area, and may use the project area as 

transition habitat. Habitat conditions in the Pecos Wilderness are generally fair to good, but the

limiting factor is severe winter conditions, where quality and quantity of forage can fluctuate

significantly. The habitat trend for bighorn sheep on the SFNF is stable.

Species Status and Population Trend

In 2011 the number of bighorn sheep in the SFNF was 110 to 125 adults. The Rocky Mountain 

Bighorn Sheep population ranks as uncommon for the SFNF. This means that the estimated 

number of breeding females ranges between 100 and 1,000 individuals. The population trend for 

Rocky Mountain bighorn sheep is declining on the SFNF. There is no suitable or occupied 

habitat for bighorn sheep within the project area. 
Chapter 3. Affected Environment and Environmental Consequences

3-78 Santa Fe National Forest Geothermal Leasing EIS

Table 3-13. Southwestern Region Regional Forester’s MIS on the SFNF

Common 

Name Species Species Status1

Species or 

Habitat in 

the Project 

Area

Habitat 

Association

Acres in 

the 

Project 

Area

Acres in 

SFNF

Rocky 

Mountain 

bighorn 

sheep

Ovis 

canadensis 

canadensis 

MIS No Alpine 

meadow

0 7,900

Rocky 

Mountain elk

Cervus elaphus MIS Yes Mid-elevation 

grasslands 

(generally less 

than 9,000 

feet), 

meadows and 

forest

157,800 1,424,900

Merriam’s 

turkey

Meleagris 

gallopavo 

merriami

MIS Yes Mature 

ponderosa 

pine forest

59,400 633,700

Mourning 

dove

Zenaida

macroura

MIS Yes Mid- and lowelevation 

grasslands, 

woodlands, 

and ponderosa 

pine

48,900 647,300

Hairy 

woodpecker

Pica villosa MIS Yes Mature forest 

and woodland

10,200 84,100

Pinyon jay Gymnorhinus 

cyanocephalus

MIS Yes Pinyon-juniper 

woodlands

12,600 250,100

Mexican 

spotted owl

(MSO)

Strix 

occidentalis 

lucida

T/MIS Yes Late-seral 

stage mixedconifer

72,500 667,600

Rio Grande

cutthroat 

trout (RGCT)

Oncorhynchus 

clarki virginalis

SS/MIS Yes Riparian and 

stream habitat; 

good water 

quality

23 miles 135 miles

Migratory 

birds

— — Yes All 194,900 1,558,500

Source: Forest Service GIS 2015, Forest Service 1987

1

T = Threatened under the Endangered Species Act of 1973 (ESA)

SS = Forest Service Region 3 Forester’s sensitive species

MIS = Forest Service Region 3 Forester’s MIS

2D = Documented, reliable, recorded observation in appropriate habitat within the SFNF boundary 

3.12.1.2 Rocky Mountain Elk

Rocky Mountain elk are primarily grazers and inhabit most forest types with good forage and 

cover. However, they were selected to represent mid-elevation grasslands (generally less than 

9,000 feet), meadows, and forested areas, which are present in the project area (Amy and Cook 

2012). Overall, elk habitat is rated as stable. 

Species Status and Population Trend

The total number of elk on the SFNF is estimated at between 7,500 and 11,000 (Amy and Cook

2012). The Rocky Mountain elk population ranks as common for the SFNF. This means that the 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-79

estimated number of breeding females ranges between 1,000 and 10,000. The population may 

fluctuate from year to year based on hunting pressure and a variety of environmental factors. The 

population trend for the Rocky Mountain elk is ranked as increasing on the SFNF. The objective, 

however, is to maintain the herd at about its current level. In recent years, the NMDGF has 

increased the number of elk hunting licenses, including late-season cow permits, in an attempt to 

maintain current elk populations.

3.12.1.3 Merriam’s Turkey

Merriam’s turkeys use a wide range of vegetation communities, but they were selected to serve 

as a management indicator of healthy, mature ponderosa pine habitat, which is present in the 

project area (Amy and Cook 2012). The estimated habitat trend for turkey is relatively stable,

based on disturbed acres providing additional feeding habitat and undisturbed areas declining in 

quality due to forest-encroachment issues. 

Species Status and Population Trend

Merriam’s turkey has the widest distribution and is known to reside on all the ranger districts on 

the SFNF. They are ranked as common on the SFNF, which means that the estimated number of 

breeding female birds ranges between 1,000 and 10,000. The NMDGF estimates between 35,000 

and 40,000 wild turkeys throughout the state. The population trend for Merriam’s turkey on the 

SFNF is rated as stable. This estimate is based on the amount of habitat available, breeding bird 

surveys, and professional opinion of local biologists. Statewide, population numbers are 

expected to increase. The NMDGF has not conducted hunter success surveys over the past few 

years and currently does not conduct population surveys for Merriam’s turkey (Amy and Cook 

2012).

3.12.1.4 Mourning Dove

Mourning dove serves as a management indicator of healthy mid- and low-elevation grasslands, 

woodlands, and ponderosa pine habitats, which are present in the project area (Amy and Cook 

2012). The habitat trend for the mourning dove is stable to increasing across the SFNF. Emphasis 

in healthy forest restoration should result in an upward trend.

Species Status and Population Trend

Mourning doves are common throughout the state. They are ranked as common on the SFNF,

meaning that the estimated number of breeding pairs ranges between 1,000 and 10,000. The 

mourning dove is listed as secure in New Mexico (NatureServe 2011a). The population trend for 

the mourning dove on the SFNF is stable, based on the statewide trend and breeding bird surveys 

on and next to the SFNF.

3.12.1.5 Hairy Woodpecker

Hairy woodpeckers serve as a management indicator for mature forest and woodland habitats—

ponderosa pine, mixed-conifer, spruce/fir, aspen, and oak woodland—which are present in the 

project area (Amy and Cook 2012). The SFNF supports adequate numbers of snags and downed

logs for hairy woodpecker habitat. 

Species Status and Population Trend

This species is widespread across the SFNF and can be found in any of the suitable habitat types.

The hairy woodpecker population is ranked as abundant on the SFNF. This means that the 

estimated number of breeding pairs ranges between 10,000 and 100,000. Breeding bird survey 
Chapter 3. Affected Environment and Environmental Consequences

3-80 Santa Fe National Forest Geothermal Leasing EIS

routes on or near the SFNF reported to the USGS between 1987 and 2010 indicate a stable to 

increasing trend for hairy woodpecker on the SFNF. The hairy woodpecker is listed as secure in 

New Mexico (NatureServe 2011b). The population trend for the hairy woodpecker on the SFNF 

is stable, based on the statewide trend and breeding bird surveys in and next to the SFNF.

3.12.1.6 Rio Grande Cutthroat Trout

RGCT serve as a management indicator of healthy riparian and stream habitat and good water 

quality. Since development of the Forest Plan (Forest Service 1987), stream habitat conditions 

for RGCT have varied from slightly declining to slightly improving. However, large catastrophic 

wildfires (e.g., Thompson Ridge fire [2013], Tres Laguna fire [2013], Las Conchas fire [2011], 

and South Fork fire [2010]) have severely impacted important RGCT streams in the SFNF, 

causing the habitat quality to decline.

Species Status and Population Trend

RGCT is also a Forest Service Region 3 sensitive species and was a candidate for federal 

protection under the ESA, from 2008 to 2014; then it was removed from candidacy when it was 

determined that listing was not warranted (79 Federal Register 59140-59150, October 1, 2014; 

NMDGF 2014). The SFNF manages approximately 1,072 miles of perennial streams. 

Approximately 965 miles were thought to be historically occupied before nonnative trout were 

stocked, and all are considered potential habitat in the State-Wide Conservation Agreement.

RGCT currently live on 135 miles of perennial streams in the SFNF (NMDGF 2014). The 

population trend for RGCT on the SFNF is stable to declining.

3.12.1.7 Pinyon Jay

Pinyon jays can be found in a wide variety of vegetation communities, but they were selected to 

serve as a management indicator of healthy pinyon-juniper habitat. Their greatest threat is the 

continued loss of cone-producing pinyon due to drought and insect infestation. Because of this 

wide-scale loss of pinyon, the habitat trend for pinyon jay is ranked as declining on the SFNF.

Species Status and Population Trend

Survey results for routes on or near the SFNF reported to the USGS, between 1987 and 2010, 

indicate a stable population trend for pinyon jay on the SFNF, although the USGS data indicate a 

downward trend throughout New Mexico and the West (Amy and Cook 2012). NatureServe 

(2011c) lists the pinyon jay as vulnerable in New Mexico.

3.12.1.8 Mexican Spotted Owl

Mexican spotted owl (MSO) serves as a management indicator for late seral stage mixed-conifer 

habitat. MSO are discussed in detail in Section 3.13, Threatened and Endangered Species and 

Special Status Species.

3.12.1.9 Migratory Birds

The Migratory Bird Treaty Act of 1918 (MBTA) implements a series of international treaties that 

provide for migratory bird protection. Under the MBTA, it is unlawful, except as permitted by 

regulations, “to pursue, take, or kill any migratory bird, or any part, nest or egg of any such bird” 

(16 USC, Section 703); however, the MBTA does not regulate habitat. The list of species 

protected by the MBTA was revised in March 2010 and includes almost all 1,007 bird species 

that are native to the United States. The Forest Service Southwestern Region currently analyzes 

the following impacts on migratory birds:
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-81

 Impacts on highest priority species listed by New Mexico Avian Conservation Partners 

 Impacts on United States Fish and Wildlife Service (USFWS) priority species in the 

Southern Rockies/Colorado Plateau bird conservation region 

 Impacts on Important Bird Areas

 Impacts on important overwintering areas

Highest Priority Species Listed by New Mexico Avian Conservation Partners

New Mexico Avian Conservation Partners considers eight risk factors in identifying conservation 

priority species: global abundance, New Mexico breeding abundance, global breeding 

distribution, New Mexico breeding distribution, threats to breeding in New Mexico, importance 

of New Mexico to breeding, global winter distribution, and threats on wintering grounds. Species 

with the highest risk factors are classified as “highest priority” for conservation action. This 

evaluation addresses general impacts on migratory birds and impacts on highest priority species 

for the main habitat types found in the project area (New Mexico Partners in Flight 2013). 

New Mexico Partners in Flight Bird Conservation Plan (New Mexico Partners in Flight 2013) 

lists priority species of concern by vegetation type. All highest priority species were reviewed for 

vegetation types found in the project area for spruce/fir, mixed-conifer, ponderosa pine, pinyonjuniper, montane riparian, wet meadows/montane grasslands, middle-elevation riparian, and 

cliffs and caves (New Mexico Partners in Flight 2013). These include aspen, juniper, pinyon, 

pinyon-juniper, ponderosa pine mix, spruce/fir, and upper deciduous evergreen forest.

USFWS Priority Species in the Southern Rockies/Colorado Plateau Bird Conservation 

Region

The following criteria are used to select species for consideration and inclusion on bird 

conservation region lists: 

 Begin with a list from appropriate bird conservation initiative

 Follow criteria for appropriate bird groups

 Add nonbreeding species, if they occur at significant relative density scores or have 

moderate or high threat levels in nonbreeding season, if not already included due to breeding 

population

 Consider subspecies and populations, where appropriate, and where information on their 

status is available

 Remove sport-hunted species and federally listed threatened or endangered populations 

(retaining non-listed populations with notation)

 Add recently ESA de-listed, candidate, or proposed species not already included

 In very limited circumstances, add or remove species and document the rationale when 

USFWS expertise, supplemental information, or local data indicate a much greater or lesser 

degree of concern than that reflected by bird conservation initiative scoring

There are 27 species of birds on the list for the Southern Rockies/Colorado Plateau bird 

conservation region.

Important Bird Areas

There are no designated Important Bird Areas in the project area; however, the 89,000-acre 

Valles Caldera/Jemez Mountains Important Bird Area is next to the project area. 
Chapter 3. Affected Environment and Environmental Consequences

3-82 Santa Fe National Forest Geothermal Leasing EIS

Overwintering Areas

Many important overwintering areas are large wetlands. Important overwintering areas 

recognized on the SFNF are Rio Chama, Rio Grande corridor, and Pecos Canyon. The project 

area is not recognized as an important overwintering area, because significant concentrations of 

birds do not occur there, nor do a unique or a high diversity of birds winter there.

3.12.2 Environmental Consequences

3.12.2.1 Scoping Comments on Resource

The following issue specific to fish and wildlife was identified during the public scoping period:

 What are the short- and long-term impacts of geothermal leasing on cold-water fisheries, 

wildlife corridors, critical wildlife habitat areas, fish hatcheries, and other important or 

sensitive fish and wildlife habitat in the project area?

3.12.2.2 How Resource Impacts Were Evaluated

Method

Leasing geothermal resources does not affect fish and wildlife. These resources would be 

affected only by subsequent development of specific geothermal projects. Potential impacts of 

geothermal development were evaluated based on the typical disturbance of geothermal projects 

for the various stages of development and then assessed based on projected intensity, as 

described in the RFDS. The types of fish and wildlife that could be affected by geothermal 

development depend on the specific location of the proposed project, the time of year, the project 

design, and its environmental setting. The analysis uses Forest Service MIS as a proxy for 

general impacts on non-sensitive fish and wildlife. Impacts on federally listed Forest Service 

sensitive species are discussed in Section 3.13. Since most fish and wildlife species rely to some 

extent on the vegetation in the project area, impacts on vegetation, as described in Section 3.11, 

would also likely impact fish and wildlife habitat.

Indicators

Indicators of impacts on fish and wildlife are as follows:

 Disturbance and changes in habitat, food supplies, cover, breeding sites, and other habitat 

components necessary for population maintenance used by any species to a degree that 

would lead to substantial population change

 Disturbance and change of seasonally important habitat (e.g., critical for overwintering or 

successful breeding) to a degree that would lead to substantial population change

 Interference with a species’ movement pattern that affects its ability to breed or overwinter 

successfully to a degree that would lead to substantial population change

Assumptions

This analysis assumes the following:

 NSO stipulations would prevent direct disturbance to habitats and species by restricting 

surface-disturbing activities where they are applied.

 TL stipulations would help to prevent direct disturbance to species during sensitive periods, 

such as during winter, when forage is sparse, and during breeding and birthing.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-83

 Disturbance of a key or critical component of a species habitat would be detrimental, with 

the degree dependent on the importance of the habitat component to the maintenance of the 

population.

 Habitat conditions and quality are directly linked to the health, vigor, and cover of vegetation 

communities, as well as to soil conditions and water quality and quantity.

 Habitat disturbance from damaged vegetation, noise, human presence, and increased dust 

would often displace wildlife beyond the actual disturbance footprint, although some 

wildlife may adapt over time, depending on the nature of the disturbance and the species 

being impacted.

3.12.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Fish and Wildlife Associated with 

Geothermal Development section of the 2008 Geothermal PEIS (BLM and Forest Service 2008) 

is incorporated by reference here. Additional information specific to this EIS includes 

consideration of the particular fish and wildlife species in the project area per alternative below.

3.12.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Impacts under 

Alternative 1 would be similar to those described in the 2008 Geothermal PEIS (BLM and Forest 

Service 2008), although specific impacts would be evaluated on a case-by case basis. 

Geothermal leasing stipulations and closures specific to fish and wildlife would not be 

implemented under this alternative; however, any geothermal lease applications and nominations 

would be subject to standards and guidelines outlined in the Forest Plan and environmental 

analysis. The Forest Service has determined that the JNRA (approximately 28,900 acres) is 

excluded from geothermal leasing on the basis of existing laws, regulations (see 43 CFR, 

Subpart 3201.11), and executive orders. There would be no direct impacts on wildlife in the 

JNRA under Alternative 1.

3.12.2.5 Impacts Under Alternative 2

Fisheries and Aquatic Biota

Impacts on fisheries from geothermal projects are directly linked to impacts on streams and 

aquatic habitat, in most cases. Impacts would result primarily from activities occurring near or in 

water bodies. NSO stipulations described in Chapter 2 would apply to water bodies, rivers and 

streams (perennial and intermittent), wetlands, springs, playas, riparian areas, 100-year 

floodplains, and a 500-foot-wide protection zone surrounding these features. Adjacent ground 

and streams would not be disturbed directly. The NSO stipulations would reduce or eliminate 

impacts associated with direct habitat disturbance, such as removal of streamside vegetation.

Indirect impacts on aquatic habitat could occur from groundwater withdrawal from geothermal 

activities. However, the amount of water to be used during geothermal development is not 

identified in the RFDS and is not known at this time. Changes in flows of surface waters due to 

geothermal pumping would be unlikely, because the extracted geothermal groundwater would be 

returned to the source aquifer via injection wells. Therefore, the volume of groundwater in the 

source aquifer would not be substantially reduced over the life of the project. 
Chapter 3. Affected Environment and Environmental Consequences

3-84 Santa Fe National Forest Geothermal Leasing EIS

Indirect impacts on aquatic habitat from groundwater withdrawal during geothermal activities 

are unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage, with USFWS consultation, once more information is known.

Stream flow rates are affected by the upland vegetation and adjacent terrain; therefore, 

geothermal development could alter stream flows and affect aquatic species and habitat. NSO

stipulations would apply to slopes in excess of 40 percent and soils with severe erosion potential. 

These stipulations would reduce the impacts on aquatic habitat from runoff and sedimentation of 

streams due to geothermal activity. Surface disturbance and use of heavy machinery and 

equipment could result in erosion and sedimentation into cold water aquatic habitats; however, 

these impacts are unlikely to result in a substantial population change.

Wildlife

Wildlife species may be affected by habitat alteration, removal, reduction, or fragmentation. Up 

to 674 acres of disturbance may occur in wildlife habitat in the project area; however, the 

location of surface disturbance is unknown at this time. Habitat at drilling pads, facilities, 

roadways, and transmission corridors would be directly affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. Geothermal development would have the greatest impact on 

wildlife if it were to affect specialty habitats, such as riparian areas, wetlands, alpine talus, caves, 

or wintering and breeding areas. NSO stipulations would apply to several specialty habitats, such 

as riparian areas, wetlands, and slopes in excess of 40 percent, reducing the likelihood of direct 

or indirect impacts on wildlife in these areas. 

Fragmentation would affect wildlife by altering how wildlife species use the habitat. 

Fragmentation can separate wildlife populations into smaller populations, making them more 

vulnerable to predation, drought, and disease and limiting genetic diversity within breeding 

groups. Movement between habitat tracts is more difficult after fragmentation. Roads have been 

shown to impede the movements of invertebrates, reptiles, and small and large mammals 

(Jackson 2000). Habitat fragmentation can create increased edges for access by predators and 

invasive species and can facilitate access by hunters, reducing the density and diversity of 

wildlife species found in the original habitat (Andren 1994). 

Animals displaced by fragmentation would occupy nearby habitats, which could lead to an 

increase in competition for resources and result in decreased health and, potentially, death for 

individuals that are less fit. The impacts resulting from displacement after habitat removal and 

fragmentation depend on many factors, including the sensitivity of a species to edge and area 

impacts, the duration and rate of habitat loss and fragmentation, and the proximity of a chosen 

habitat to the disturbed area (Hagan et al. 1996). 

Wildlife would generally avoid areas next to disturbance resulting from geothermal 

development; therefore, the amount of habitat actually affected by disturbance and fragmentation 

extends beyond the habitat disturbed. The effective habitat loss (amount of habitat actually used 

by wildlife) due to new roadways was reported to be 2.5 to 3.5 times as great as actual habitat 

loss (Reed et al. 1996). During the exploration phase of development, approximately 10 miles of 

local road, with a width of 12 feet, would need to be widened to about 20 feet to accommodate 

larger truck traffic. Roads used during exploration would be widened an additional two feet 

during the development phase. Wildlife habitat fragmentation and disturbance impacts described 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-85

above could occur along these roadways; however, the exact location and magnitude of impacts

are unknown at this time.

Fragmentation can facilitate the spread and introduction of invasive plant species. Roads and 

other corridors can facilitate the dispersal of invasive species by altering existing habitat 

conditions, stressing or removing native species, and allowing easier movement by wild or 

human vectors (Trombulak and Frissell 2000). 

Wildlife can be affected by invasive vegetation. Invasive plant species may be unpalatable for 

native animal species, making it difficult for them to forage. This can alter the population 

structure of entire habitats. Invasive plants often disperse native vegetation, reducing the quality 

of the habitat for most wildlife. Birds are most directly affected by invasive plants, as their food 

source is often seeds from native grasses and shrubs. 

Noise from geothermal activities can have impacts on wildlife. Principal sources of noise from 

geothermal activities include trucks and the operation of drilling rigs and heavy machinery. On 

the basis of the types of equipment that would likely be used, such as drill rigs and graders, noise 

levels above 65 dBA would be present at distances of less than 400 feet from binary power 

plants. Noise levels from production wells would exceed the 65 dBA limit only at a distance of 

less than 69 feet. Most impacts associated with noise could occur if critical life cycle activities 

were disrupted, such as mating and nesting. Disturbance during mating, nesting, or rearing can 

cause wildlife to abandon mating and nesting activities and can strand young, leaving them 

susceptible to predation and starvation. However, implementing TLs, as described in Chapter 2, 

would limit noise disturbance nesting and breeding periods (March 1 to August 15) and would 

reduce the likelihood of impacts on seasonally important wildlife habitat.

The location and timing of geothermal activities (especially exploration and development) may 

affect the migratory and other behavioral activities of some species. Construction activities could 

affect local wildlife by disturbing normal behavior, such as foraging, mating, and nesting. 

Wildlife may cease foraging, mating, or nesting or may vacate active nest sites in areas where 

geothermal activities are occurring; some species may permanently abandon the disturbed areas 

and adjacent habitats. In addition, exploration and development may affect the movements of

some birds and mammals; for example, they may avoid a migratory route because of ongoing 

construction. 

Increased human activity also increases the potential for fires. Fire may affect wildlife through 

direct mortality, reduced habitat, or reduced habitat quality including reduced forage and cover. 

BMPs (such as development of a fire management strategy) would minimize the potential for a 

human-caused fire.

Rocky Mountain Bighorn Sheep 

Because all Rocky Mountain bighorn sheep habitat is in the Pecos Wilderness and Cochiti 

Canyon, and the proposed action would not impact alpine meadow habitat, there would be no 

impacts on Rocky Mountain bighorn sheep. 

Rocky Mountain Elk

Direct and indirect impacts on Rocky Mountain elk would be the same as the impacts described 

above for wildlife. Up to 674 acres of the approximately 1,424,900 acres of Rocky Mountain elk

habitat in the SFNF could be directly impacted by Alternative 2. Constructing access roads could 

result in indirect impacts on Rocky Mountain elk, including temporal and spatial habitat 
Chapter 3. Affected Environment and Environmental Consequences

3-86 Santa Fe National Forest Geothermal Leasing EIS

avoidance. These impacts could occur on approximately 14,320 acres of habitat surrounding 

roads during times that roads are utilized (Wisdom et al. 2004; Rowland et al. 2000). However, 

the exact amount of habitat directly or indirectly affected is unknown, because the location of 

surface-disturbing geothermal development is not known at this time. At most, expected surface 

disturbance would remove less than 0.05 percent of the available Rocky Mountain elk habitat in 

the SFNF, and, because population trends are stable, changes in vegetation would have 

negligible impacts on Rocky Mountain elk habitat and would not lead to a substantial population 

change. 

Merriam’s Turkey

Direct and indirect impacts on Merriam’s turkey would be the same as the impacts described 

above for wildlife. Up to 674 acres of the approximately 633,700 acres of Merriam’s turkey 

habitat in the SFNF could be directly impacted by Alternative 2. Indirectly, some habitat could 

be reduced in quality due to noise or other disturbance. However, the exact extent of habitat 

directly or indirectly affected is unknown, as the location of surface-disturbing geothermal 

development activities is not known at this time. At most, expected surface disturbance would 

remove less than 0.1 percent of the available Merriam’s turkey habitat on the SFNF. Because 

population trends are stable, changes in vegetation would have negligible impacts on Merriam’s 

turkey habitat and would not lead to a substantial population change.

Mourning Dove

Direct and indirect impacts on mourning dove would be the same as the impacts described above 

for wildlife. Up to 674 acres of the approximately 647,300 acres of mourning dove habitat in the 

SFNF could be directly impacted by Alternative 2. Indirectly some habitat would be reduced in 

quality due to noise or other disturbance. However, the exact amount of habitat directly or 

indirectly affected is unknown, as the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.1 percent of the available mourning dove habitat on the SFNF. Because population trends 

are stable, changes in vegetation would have negligible impacts on mourning dove habitat and 

would not lead to a substantial population change.

Hairy Woodpecker

Direct and indirect impacts on hairy woodpecker would be the same as the impacts described 

above for wildlife. Up to 674 acres of the up to 84,100 acres of hairy woodpecker habitat in the 

SFNF could be directly impacted by Alternative 2. Indirectly, some habitat could be reduced in 

quality due to noise or other disturbance. However, the exact amount of habitat directly or 

indirectly affected is unknown, as the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.8 percent of the available hairy woodpecker habitat on the SFNF. Because population 

trends are stable, changes in vegetation would have negligible impacts on hairy woodpecker 

habitat and would not lead to a substantial population change.

Rio Grande Cutthroat Trout

In most cases, impacts on RGCT and its habitat from geothermal projects are directly linked to 

impacts on riparian and wetland habitats. Sediment inputs may affect habitat suitability 

(particularly spawning habitat, which consists of clean gravel, with little or no fine sediment).

NSO stipulations would apply to water bodies, rivers and streams (perennial and intermittent), 

wetlands, springs, playas, riparian areas, 100-year floodplains, and a 500-foot-wide protection 

zone surrounding these features. Implementing these measures would protect and maintain 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-87

streamside vegetation and bank stability in RGCT habitat. In addition, in combination with NSO 

stipulations for steep slopes and soils with severe erosion potential, the stipulations would reduce 

the likelihood of sedimentation into occupied RGCT streams. However, indirect impacts

associated with sedimentation could still occur.

Indirect impacts on RGCT habitat from groundwater withdrawal during geothermal activities are 

unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage once more information is known.

There would be no direct impacts on RGCT. Alternative 2 could indirectly impact RGCT habitat 

but would not reduce available habitat. The impacts on RGCT habitat would not lead to a 

substantial population change.

Pinyon Jay

Direct and indirect impacts on pinyon jay would be the same as the impacts described above for 

wildlife. Up to 674 acres of the approximately 250,100 acres of pinyon jay habitat in the SFNF 

could be directly impacted by Alternative 2. Indirectly, some habitat could be reduced in quality 

due to noise or other disturbance. However, the exact extent of habitat directly or indirectly 

affected is unknown, because the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.3 percent of the available pinyon jay habitat on the SFNF. Because population trends are 

stable, changes in vegetation would have negligible impacts on pinyon jay habitat and would not 

lead to a substantial population change.

Mexican Spotted Owl

The types of direct and indirect impacts on MSO would be the similar as the impacts described 

above for wildlife. However, surface occupancy and use would be prohibited on designated 

habitat. In these areas, no direct impacts on MSO are anticipated. Indirectly, some habitat could 

be reduced in quality due to noise or other disturbance; however, the extent and magnitude of 

these impacts is unknown, as the locations of surface-disturbing geothermal development

activities is not known at this time. 

Direct and indirect impacts could also occur on potential MSO habitat not designated as critical 

habitat (late-seral stage mixed conifer vegetation, which constitutes 72,500 acres in the project 

area). These types of impacts could include direct removal, fragmentation, habitat avoidance, 

and noise disturbance. Implementing TLs from March 1 to August 31 would protect and limit 

disturbance from drilling and construction in protected activity centers (PACs) during the critical 

nesting and breeding period. At most, expected surface disturbance would remove less than 0.9

percent of late-seral stage mixed conifer habitat on the SFNF. Because population trends are 

stable on the SFNF, the changes in vegetation would have a negligible impact on MSO habitat 

and would not lead to a substantial population change.

Migratory Birds

Direct and indirect impacts on migratory birds would be the same as the impacts described above 

for wildlife. Up to 674 acres of the approximately 1,558,500 acres of migratory bird habitat in 

the SFNF could be impacted by Alternative 2. Expected surface disturbance would remove less 

than 0.04 percent of the available migratory bird habitat on the SFNF; therefore, changes in 

vegetation would have negligible impacts on migratory bird habitat.
Chapter 3. Affected Environment and Environmental Consequences

3-88 Santa Fe National Forest Geothermal Leasing EIS

3.12.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3. There 

would be no direct or indirect impacts on fish and wildlife species from geothermal activities 

under this alternative.

3.12.2.7 Impacts Under Alternative 4

Under Alternative 4, approximately 28,900 acres would be closed to geothermal leasing, while 

approximately 139,800 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. As with 

Alternative 2, 674 acres could be disturbed in the project area. Direct and indirect impacts on 

fish and wildlife would be similar to those described under Alternative 2; however, the level of 

intensity of disturbance could be more severe, specifically for fish and riparian species. This is 

because stipulations for water bodies and rivers or streams are less restrictive. The potential 

disturbance on intermittent streams could lead to increased sedimentation flowing into perennial 

streams and could reduce the quality of habitat for species that are sediment intolerant, such as 

RGCT and other cold water fish species. 

3.12.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for fish and wildlife is the three level 4 

watersheds that intersect the project area: the Rio Grande-Santa Fe, Rio Chama, and Jemez 

watersheds. Impacts on fish and wildlife do not end at the project area boundary but would 

encompass migration corridors, large home ranges, and cross boundary landscapes that extend 

beyond SFNF land. 

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4. They are 

the following projects, which would increase the amount of disturbance in the cumulative 

impacts analysis area:

 Building hiking trails for the Continental Divide National Scenic Trail

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney Dam

 Mineral development, including the South Pit Pumice Mine Expansion and the Duran 2010 

Pumice Mine

Other projects that would likely restore habitat conditions in the cumulative impacts analysis 

area are as follows:

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project

 Supplement to the Final EIS for Invasive Plant Control Project

The response of individual species to past, present, and reasonably foreseeable future actions 

would vary, depending on the life history and habitat needs of the species. However, in general, 

projects that increase the amount of disturbance could reduce habitat or cover where those 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-89

projects occur. In addition, ongoing recreation use could result in wildlife habitat avoidance in 

some areas. 

Alternatives 1, 2, and 4 would increase the number of acres of disturbance in the cumulative 

impacts analysis area, when combined with other past, present, and reasonably foreseeable future 

actions. However, NSO, CSU, and TL stipulations under Alternatives 2 and 4 would limit 

impacts in seasonally important habitats (such as perennial and intermittent rivers and streams, 

and elk calving areas). Timing limitations for special status raptors may also minimize risk to 

reproductive and post-fledgling success for other migratory birds nesting in those areas. 

Geothermal development activities, in combination with other surface-disturbing activities, may 

increase the potential for nonnative and invasive species to colonize and dominate sites, thus 

reducing the quality of habitat for some species. However, BMPs identified in Appendix C—and 

other weed control efforts on the Coyote, Cuba, Espanola, and Jemez Ranger Districts—would 

reduce or mitigate this impact.

Cumulative impacts on fish and aquatic habitats could include sediment influx in some areas as a 

result of geothermal development in combination with natural wildfire or flooding. However, 

stipulations for rivers, streams, and erosive soils under Alternatives 2 and 4 would restrict 

geothermal development in these areas and limit the amount of sedimentation entering 

waterways from geothermal specific activities.

Combined with other reasonably foreseeable future actions, no significant cumulative impacts on 

wildlife and fisheries or their habitat are expected from Alternatives 1, 2, and 4. Alternative 3 

would have no cumulative impacts on wildlife and fisheries or their habitat.

3.13 Threatened and Endangered Species and Special 

Status Species

3.13.1 Affected Environment

This section addresses only federally listed or proposed species and Forest Service sensitive 

species. No special status species surveys were conducted for this project.

Species listed as endangered under the ESA are those that are “in danger of extinction 

throughout all or a significant portion of its range” (16 USC, Subsection 1532[6]). A species 

listed as threatened under the ESA is considered “likely to become an endangered species within 

the foreseeable future throughout all or a significant portion of its range” (16 USC, Subsection 

1532[20]). Proposed species for ESA listing are those that were found to warrant listing as either 

threatened or endangered and were officially proposed as such in a Federal Register notice after 

the completion of a status review and consideration of other protective conservation measures.

Forest Service sensitive species are defined in Forest Service Manual 2670.5 as “those plant and 

animal species identified by a Regional Forester for which population viability is a concern, as 

evidenced by 1) significant current or predicted downward trends in population numbers or 

density, or 2) significant current or predicted downward trends in habitat capability that would 

reduce a species’ existing distribution.” Table 3-14, below, shows threatened, endangered, or 

Forest Service sensitive species on the SFNF and whether each is known to occur in the project 

area.
Chapter 3. Affected Environment and Environmental Consequences

3-90 Santa Fe National Forest Geothermal Leasing EIS

Table 3-14. Federally Listed and Region 3 Regional Forester’s Sensitive Species on the SFNF

Common Name Taxon Species 

Status1

Known to Occur 

in the Project 

Area

Occurrence in 

SFNF2

Amphibians

Northern leopard frog Lithobates pipiens SS Yes D

Jemez Mountain 

salamander

Plethodon 

neomexicanus

E Yes D

Birds

Northern goshawk Accipiter gentilis SS Yes D

Boreal owl Aegolius funereus SS No D

Burrowing owl Athene cunicularia 

hypugaea

SS No ND

American peregrine 

falcon

Falco peregrinus 

anatum

SS Yes D

White-tailed 

ptarmigan

Lagopus leucura SS No D

Mexican spotted owl Strix occidentalis lucida T/MIS Yes D

Gray vireo Vireo vicinior SS Yes D

Fish

Rio Grande sucker Catostomus plebeius SS Yes D

Rio Grande chub Gila pandora SS Yes D

Rio Grande cutthroat 

trout (RGCT)

Oncorhynchus clarki 

virginalis

SS/MIS Yes D

Mammals

Pale Townsend’s 

big-eared bat

Corynorhinus townsendii 

pallescens

SS Yes D

Gunnison’s prairie 

dog

Cynomys gunnisoni SS Yes D

Spotted bat Euderma maculatum SS Yes D

American marten Martes americana 

origenes

SS No D

Goat Peak pika Ochotona princeps 

nigrescens

SS Yes3 D

American pika O. princeps saxatilis SS Yes D

Cinereus (masked) 

shrew

Sorex cinereus cinereus SS Yes D

Water shrew S. palustris navigator SS Yes4 D

Preble’s shrew S. preblei SS Yes D

New Mexico 

meadow jumping 

mouse

Zapus hudsonium luteus E Yes D

Clams

Lilljeborg’s pea-clam Pisidium lilljeborg SS No D
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-91

Table 3-14. Federally Listed and Region 3 Regional Forester’s Sensitive Species on the SFNF

Common Name Taxon Species 

Status1

Known to Occur 

in the Project 

Area

Occurrence in 

SFNF2

Plants

Tufted sand verbena Abronia bigelovii SS No S

Greene milkweed Asclepias uncialis 

uncialis

SS No D

Chaco milkvetch Astragalus micromerius SS No S

Pecos mariposa lily Calochortus gunnisonii 

var. perpulcher

SS No D

Yellow lady’s-slipper Cypripedium 

parviflorum pubescens

SS No D

Robust larkspur Delphinium robustum SS No ND

Heil’s alpine 

whitlowgrass

Draba heilii SS No D

Pecos fleabane Erigeron subglaber SS No D

Wood lily Lilium philadelphicum SS No D

Chama blazingstar Mentzelia conspicua SS No D

Santa Fe (Springer’s) 

blazingstar

Mentzelia springeri SS Yes S

Arizona willow Salix arizonica SS No D

Source: Forest Service GIS 2015

1

E = Endangered under the ESA

T = Threatened under the ESA

SS = Forest Service Region 3 Forester’s sensitive species

MIS = Forest Service Region 3 Forester’s MIS

2D = Documented, reliable, recorded observation in appropriate habitat within the SFNF boundary 

S = Suspected, likely to occur based on habitat availability to support individuals/breeding pairs/groups within the SFNF

boundary

ND = Not documented or suspected within the SFNF boundary

3

Biota Information System of New Mexico 2016

4

Forest Service 2014a

Species known to occur in the project area are discussed in more detail below. Federally listed 

species observed there are the Jemez Mountain salamander, New Mexico meadow jumping 

mouse, and MSO. Forest Service sensitive species analyzed below are the Rio Grande sucker, 

Rio Grande chub, northern leopard frog, northern goshawk, American peregrine falcon, gray 

vireo, pale Townsend’s big-eared bat, spotted bat, Gunnison’s prairie dog, Goat Peak pika, 

American pika, cinereus (masked) shrew, water shrew, Preble’s shrew, woodlily, Santa Fe 

(Springer’s) blazingstar, and Arizona willow.

3.13.1.1 Forest Service Species Excluded from Analysis and Rationale

A list of potential occurrence in the project area and within 0.5 mile of it was used for the species 

exclusion from analysis. Sensitive species that may be affected by the proposed action were

identified by evaluating the habitat needs of the listed species against the habitat in the project

area. Known occupancy or use by sensitive species was also considered.
Chapter 3. Affected Environment and Environmental Consequences

3-92 Santa Fe National Forest Geothermal Leasing EIS

The following Forest Service Region 3 sensitive species were excluded from further analysis in 

this report because the project area is outside the species’ range, there is lack of essential habitat 

in the project area, or the species is not known to occur in the project area.

During the impacts analysis for this report, the proposed action was determined to have no 

impact on the following species: boreal owl, burrowing owl, bald eagle, white-tailed ptarmigan, 

American marten, Lilljeborg’s pea-clam, tufted sand verbena, Greene milkweed, Chaco 

milkvetch, Pecos mariposa lily, robust larkspur, Pecos fleabane, and Chama blazing star. The 

rationale for this no impact determination is included in the SFNF Geothermal Leasing EIS Fish, 

Wildlife, and Plant Report (Forest Service 2016e).

3.13.1.2 Federally Listed Species

Jemez Mountain Salamander

This salamander can be found in moss-covered talus and under bark and beneath logs and rocks 

in and near mixed forests of spruce/fir and aspen (Biota Information System of New Mexico

2015). This species occurs underground except during periods of warm seasonal rains. In New 

Mexico, it is found from 6,990 to 11,270 feet in elevation. It lays its eggs underground. 

The Jemez Mountain salamander is restricted to the Jemez Mountains in Sandoval, Los Alamos, 

and Rio Arriba Counties. More than 90 percent of the recorded observations are on lands 

administered by the SFNF, with additional populations on Santa Clara Pueblo, in Bandelier 

National Monument, and in the VCNP. Habitat on the SFNF consists of spruce/fir and aspen 

between 6,990 and 11,270 feet in elevation. Critical habitat for the Jemez Mountain salamander 

covering 34,400 acres has been designated in the project area; the Forest Service has recorded

573 observations there (Forest Service GIS 2015). 

New Mexico Meadow Jumping Mouse

New Mexico meadow jumping mouse can be found on the ground surface in grassy or weedy 

meadows in the riparian, mixed-conifer, and spruce/fir vegetation communities. This species 

appears to use two specific riparian community types: persistent emergent herbaceous wetlands

(i.e., beaked sedge and reed canarygrass alliances) and scrub-shrub wetlands (i.e., riparian areas 

along perennial streams that are composed of willows and alders). This jumping mouse 

especially uses microhabitats of patches or stringers of tall dense sedges on moist soil, along the 

edge of permanent water (USFWS 2016). This species has been recorded on the SFNF, including 

three observations in the project area (Forest Service GIS 2015). Due to the low number of 

observations, it is uncertain how much potential habitat it occupies. Approximately 800 acres of 

critical habitat for the New Mexico meadow jumping mouse has been designated in the project 

area, in the San Antonio Creek and Rio Cebolla areas.

Mexican Spotted Owl

The MSO is federally listed as threatened. It is found from parts of central Colorado and Utah, 

south through Arizona, New Mexico, and west Texas, then south again through northwestern 

Mexico to the Mexican state of Michoacán. It has the largest geographic range of the three 

spotted owl subspecies. Its range extends from the southern Rocky Mountains in Colorado and 

the Colorado Plateau in southern Utah, southward through Arizona and New Mexico and, 

discontinuously, through the Sierra Madre Occidental and Oriental to the mountains at the south 

end of the Mexican Plateau (USFWS 1993). Twenty-one years has passed since the first recovery 

plan, and total population size is not reliably known (USFWS 2012).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-93

MSO is resident in the mountains of New Mexico, being most regular in the south. It can be

found in the San Juan, Jemez, Sangre de Cristo, Mount Taylor, Sandia, Manzano, San Francisco, 

Tularosa, Mogollon, San Mateo, Pinos Altos, Black, White, Sacramento, Guadalupe, and Animas 

Mountains (Hubbard 1978). The MSO is threatened by destruction and modification of habitat 

caused by timber harvest and fires. Fuel accumulation and forests overstocked with trees place 

MSO habitat at risk to stand-replacing fires. Lack of small-scale, low-intensity ground fires has 

increased this risk.

MSO has limited distribution across the SFNF. There are historical records from all Ranger 

Districts, mostly in the Jemez and Pecos/Las Vegas Ranger Districts, where it is found in very 

specific habitat types.

MSO is most common in mature and old-growth forests throughout much of its range. The most

highly sought habitat characteristics are high canopy closure, high stand density, a multi-layered

canopy, uneven-aged stands, numerous snags, and downed woody matter. Dominant and codominant trees in the main canopy are often 18-inch-diameter breast height or larger, with 18-

inch-diameter breast height or greater in the mature and old forest types, best expressed in oldgrowth mixed-conifer forests (usually more than 200 years old). These characteristics may also 

develop in younger stands that are unmanaged or minimally managed, especially when the 

stands contain remnant large trees or patches of large trees from earlier stands (USFWS 1993). 

MSO may be found in other vegetation communities, but on the SFNF, they are closely linked to 

the mixed-conifer and riparian vegetation types, which occur throughout the project area.

In addition to the forested areas, MSO in the Jemez Mountains also occupy canyon habitats, 

where they are cliff nesters. These canyon habitats range from those with a high degree of forest 

structure on at least one of the slopes above the canyon wall, to little or no tree cover present; 

however, typically mixed-conifer habitat is close by.

Since 1988, the SFNF has been surveying for MSO. As new areas were surveyed, the number of 

PACs also increased as owls were located. PACs are areas measuring 600 acres and are 

designated to conserve the core use areas of MSO. PACs are designed to protect the nest site, 

several roost sites, and the closest and highly used foraging sites (Ganey et al. 2014). The 

number of PACs identified in the SFNF has increased from 19 in 1989 to 50 in 2009; 14 PACs 

have been identified in the project area. Monitoring of existing PACs to determine occupancy 

has been sporadic; 17 MSO observations have been recorded in the project area (Forest Service

GIS 2015).

3.13.1.3 Fisheries

Rio Grande Sucker

Rio Grande suckers typically occur in middle elevation streams (6,600 to 8,600 feet) of small to 

large size (Sublette et al. 1990). On the SFNF, Rio Grande sucker are found in low gradient (less 

than 3.2 percent) stream reaches at elevations from 5,600 to 9,600 feet. Juveniles and adults both 

prefer glides and pools with mean water column velocities less than 706 cubic feet per second. 

They favor low- to moderate-gradient riffles and pools below riffles in low-velocity stream 

reaches. They are usually found over gravel or cobble but can also be in backwater habitats 
Chapter 3. Affected Environment and Environmental Consequences

3-94 Santa Fe National Forest Geothermal Leasing EIS

(USFWS 2013). Rio Grande suckers prefer clear-water streams where periphyton8food is 

common, and they are rarely found in waters with heavy loads of silt and organic detritus 

(Sublette et al. 1990). In the project area, Rio Grande suckers are found in the Rio Cebolla, Rio 

Guadalupe, San Antonio Creek, East Fork of the Jemez River, and in the main stem Jemez River.

The East Fork of the Jemez River, its the main stem, and half of San Antonio Creek are in the 

JNRA.

Rio Grande Chub

Rio Grande chub spawn in riffle habitat in the spring and early summer, with peak spawning

occurring as water levels are declining from peak flow in the spring. Rio Grande chubs feed on 

mid-water insects, zooplankton, and small fish. They are generally found in streams less than 2 

percent gradient in low-velocity habitats, such as pools, runs, and glides, and are often associated 

with in-stream woody debris or aquatic vegetation (USFWS 2013). In the project area, Rio 

Grande chubs are found in the Rio Cebolla, Rio Guadalupe, and in the East Fork and main stem 

of the Jemez River, both of which are in the JNRA.

Rio Grande Cutthroat Trout

RGCT is a Forest Service Region 3 sensitive species. It was a candidate for federal protection 

under the ESA from 2008 to 2014, when it was removed from candidacy because listing was 

determined to be not warranted (79 Federal Register 59140-59150, October 1, 2014; NMDGF 

2014). 

RGCT is one of 14 subspecies of cutthroat trout native to the western United States (Behnke 

2002). It is found primarily in clear, cold mountain lakes and streams in Colorado and New 

Mexico, within the Rio Grande Basin (Sublette et al. 1990). In New Mexico, RGCT exist in 

mountain streams, primarily in the Sangre de Cristo and Jemez Mountains in the Carson

National Forest and SFNF. Isolated populations persist in southern New Mexico on the Gila 

National Forest in the Black Range (Sublette et al. 1990) and on the Mescalero Apache Indian 

Reservation in the Tularosa Basin. Conservation populations (those with 10 percent or less 

hybridization with nonnative trout genes) of RGCT occupy approximately 10 percent of their 

historical habitat (Alves et al. 2008). In 2013, there were 127 conservation populations rangewide, with four conservation populations in the project area, including Canones Creek, Medio 

Dia Creek, Rio Cebolla, and Rio Puerco (USFWS 2013).

Streams capable of supporting RGCT are at elevations of 6,000 feet and higher. Historically 

(circa 1800), 43 percent of RGCT populations occupied streams 8,000 feet or less in elevation 

(Alves et al. 2008). Currently, only approximately 1.6 percent of the populations are in streams 

with elevation less than 8,000 feet (Alves et al. 2008). Conservation populations are concentrated 

in streams with elevations from 9,000 to 10,000 feet. Because RGCT are now restricted to firstand second-order headwater streams that are narrow and small, compared to the larger third- and 

fourth-order streams they once occupied, the absolute loss of habitat is much greater than stream 

miles might indicate.

Quality of habitat conditions is generally less than moderate across the SFNF. In high-elevation 

locations where access is limited by topography and wilderness regulations, stream habitat 

 

8 A complex mixture of algae, blue-green bacteria, microbes that live off nutrients they scavenge from 

living hosts or find in dead organic matter, and waste or debris that is attached to submerged surfaces in 

most aquatic ecosystems. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-95

quality is moderate to excellent. Where poor habitat and water quality conditions occur, the size 

of RGCT populations is affected. Decreased water quality can be attributed to, but is not limited 

to, soil compaction, road runoff, bank instability, and pollutant delivery from nonpoint sources. 

Poor habitat conditions can be attributed to, but are not limited to, a lack of in-stream large 

woody debris, sediment-filled pools, loss of undercut banks, depletion of beaver populations, 

lack of side channel development, and poor riparian health.

At the conclusion of 2010, the SFNF had surveyed over 299 miles of stream using the Forest 

Service Region 3 Stream Habitat Inventory protocol. An analysis of the habitat data collected 

between 2001 and 2005 shows that streams in the wilderness average 33 pieces of large wood 

per mile. In similar stream types outside of the wilderness, streams had only 11 pieces per mile, 

in many cases going several miles without one piece of wood. Other habitat indicators often 

below standard are as follows:

 Excessive sediment and fines in riffle habitat (greater than 20 percent)

 Stream widening that has led to high water temperatures

 Unstable stream banks

 Too few and small pools with low pool volume

 Lack of side channel development

Since development of the Forest Plan (Forest Service 1987), stream habitat conditions for RGCT

have varied from slightly declining to slightly improving. However, three large catastrophic 

wildfires have severely impacted six important RGCT streams in the SFNF between 2010 and 

2011, causing the habitat quality to decline. 

The SFNF manages approximately 1,072 miles of perennial stream. Approximately 965 miles 

were thought to be historically occupied before being stocked with nonnative trout, and all are 

considered potential habitat in the State-Wide Conservation Agreement. RGCT currently live on 

135 miles of perennial stream in the SFNF (NMDGF 2014). In the project area, RGCT are 

present in 23 miles of stream reaches, including Rio Cebolla, Rio Puerco, Medio Dia Creek, and

Canones Creek (Forest Service GIS 2015). All of these creeks are outside of the JNRA.

3.13.1.4 Wildlife

Northern Leopard Frog

This leopard frog ranges in a wide variety of habitats (springs, marshes, wet meadows, riparian

areas, vegetated irrigation canals, ponds, and reservoirs) but requires a high degree of vegetation

cover for concealment (NatureServe 2009a; Biota Information System of New Mexico 2006). In 

New Mexico, it is known from approximately 3,600 to 10,000 feet and breeds in ponds or lake 

edges with fairly dense aquatic emergent vegetation, from April to July and September to 

October (Degenhardt et al. 1996). The leopard frog attaches its eggs to submerged vegetation 

well below the surface, in water 1.5 feet deep or more (NatureServe 2009a). 

Over-wintering habitats are larger lakes and streams that do not freeze completely during winter 

(NatureServe 2009a). Suitable habitat is present in the project area.

The northern leopard frog has been documented on the SFNF Cuba, Jemez, Española, and 

Pecos/Las Vegas Ranger Districts. The species is also suspected to be on the SFNF Coyote 

District. There are approximately 7,400 acres of potential habitat for northern leopard frog in the 

project area. This habitat was modeled using the SFNF riparian geospatial information below 
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3-96 Santa Fe National Forest Geothermal Leasing EIS

10,000 feet in elevation. A total of 28 observations have been recorded in the project area. Due to 

the low number of observations, it is uncertain how much potential habitat is currently occupied. 

In 2013, the species was reintroduced as tadpoles on the VCNP (outside of the project area) in 

two isolated pond locations. 

Northern Goshawk

Preferred habitat for the northern goshawk consists of coniferous forests, with a variety of

structural stages for nesting and foraging. Forest types occupied by the goshawk in the 

Southwest are ponderosa pine (74 percent), mixed species (23 percent), and spruce-fir (3 

percent; Reynolds et al. 1992). At the nest tree/stand level, nests typically occur in mature to oldgrowth forests, composed primarily of large trees with high canopy closure, near the bottom of 

moderate hill slopes, with sparse ground cover (Squires and Reynolds 1997; Squires and 

Kennedy 2006). Goshawks nested 2.5 times more often than expected in stands with 70 to 79 

percent canopy coverage and 5.8 times more often than expected in stands with 80 percent or 

greater canopy coverage (Squires and Reynolds 1997). The nest site is generally situated within 

0.25 mile of a stream or other water source (Squires and Reynolds 1997). 

Northern goshawks prey on small- to medium-size birds and mammals, from robins and 

chipmunks to grouse and rabbit (Reynolds et al. 1992). The best foraging habitat occurs in a 

mosaic of structural stages scattered across the landscape (Reynolds et al. 1992). In New 

Mexico, average home range size during the breeding season is 1,400 acres for females and 

5,200 acres for males (Squires and Reynolds 1997).

Suitable nesting and foraging habitat for northern goshawk is found in the ponderosa pine and 

spruce/fir vegetation communities in the project area. Post-fledgling family areas are 

surrounding a nest area that is defended by a goshawk pair. The project area contains 14 known 

post-fledgling family areas, covering a total of 7,900 acres (Table 3-15). Nineteen observations 

have been recorded in the project area.

Table 3-15. Northern Goshawk Post-Fledgling Family Areas in the Project Area

Post-Fledgling Family Area Name Year of Occupancy Acres

Barley 1992 500

Calaveras 1993 400

Cerro Pavo 1992 700

Cerro Pelado 1992 600

Cerro Pelon 1989 4,100

El Cajete 1991 600

Horseshoe 1984 600

Las Conchas 1992 600

Monument 1991 600

Pony Canyon 1991 600

Redondo 1989 500

Rio Cebolla 1995 600

San Juan Canyon 1991 600

San Juan Mesa 1991 600

Source: Forest Service GIS 2015
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Santa Fe National Forest Geothermal Leasing EIS 3-97

Boreal Owl

The boreal owl occurs mainly above 9,500 feet in spruce/fir forests. Surveys through 1996 

showed this species to be resident in very small numbers in spruce/fir habitat in the Jemez 

Mountains. As of 1996 no boreal owls have been observed south of the Valles Caldera, but 

individuals have been observed in the Valles Caldera, next to the project area (Forest Service

2014a).

Approximately 9,600 acres of spruce/fir forest are present in the project area, some of which are 

above 9,500 feet in elevation. These forests may provide suitable habitat for the boreal owl in the 

project area, and this species may be present but not recorded by the Forest Service.

American Peregrine Falcon

There are approximately 237,600 acres of designated peregrine falcon suitable breeding habitat 

zones on the SFNF, 3,100 acres of which are in the project area. There are four designated 

suitable breeding habitat zones completely within the boundaries of the project area: R26, R29, 

R39, and R44. A peregrine falcon territory is an area surrounding a nest that is defended by a 

falcon pair. Statewide surveys conducted from 2008 to 2010 found that 84 percent of the 174 

peregrine falcon territories were occupied. Populations increased dramatically from 1980 to 

2007, then remained stable or declined slightly by 2010 (Biota Information System of New 

Mexico 2016). 

Suitable habitat for American peregrine falcon includes various open habitats, from grassland to

forested areas, in association with suitable nesting cliffs (NatureServe 2009b). In New Mexico, 

the breeding territories of peregrine falcon center on cliffs that are in wooded/forest habitats, 

next to large expanses of foraging areas (Biota Information System of New Mexico 2008). The 

falcon often nests on ledges or potholes on the face of rocky cliffs or crags (Biota Information 

System of New Mexico 2008). Ideal locations include undisturbed areas with a wide view, near 

water, and close to plentiful prey. Foraging habitats of woodlands, open grasslands, and water 

bodies are generally associated with the nesting territory (NatureServe 2009b). Suitable nesting 

and foraging habitat is in the project area. 

Prey consists almost entirely of birds, ranging in size from swallows to large shorebirds. In New 

Mexico, jay, woodpecker, swift, mourning dove (Zenaida macroura), and pigeon (Columbo 

livia) are commonly taken as prey species (Biota Information System of New Mexico 2008). 

Falcons are known to forage over large areas, often 10 to 15 miles from the nest.

Gray Vireo

The gray vireo is a scrub-foraging inhabitant of some of the hottest, most arid regions of the

southwestern United States and adjacent parts of northwestern Mexico. The vireo is a shortdistant migrant, withdrawing from breeding habitat by August (early fall) and returning in late 

April to early May (NMDGF 2006). Breeding habitat in northern and northwestern parts of New 

Mexico is found at elevations from 5,500 to 7,200 feet, in broad-bottomed canyons (flat or 

gently sloped valleys), below or near ridgetop/rock outcrop/cliff head wall of canyon, or gently 

sloped bowls in pinyon-juniper woodlands (NatureServe 2006; NMDGF 2006). The vireo is 

most often associated with juniper, pinyon pine, or oak trees, with a wide variety of shrubs and 

grasses (NMDGF 2006, 2007). Habitat usually contains a mixture of open savannas and slightly 

more closed-canopy woodland areas (NatureServe 2006; NMDGF 2006). Trees in habitat areas 

are generally mature, ranging from 12 to 25 feet in height (NatureServe 2006).
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3-98 Santa Fe National Forest Geothermal Leasing EIS

Gray vireos are insectivorous, taking grasshopper, stinkbug (Eleodes spp.), treehopper, cricket, 

moth, damselfly, cicada, and caterpillar. The vireo is a thicket forager, taking most prey from 

leaves, twigs, branches, and trunks of small trees or twigs and branches of shrubby vegetation. 

Territory size varies in part with population density, ranging from 5 to 17 acres (NMDGF 2007).

The gray vireo is found throughout New Mexico west of the Great Plains, but with an extremely

patchy distribution often composed of small sites (NMDGF 2006, 2007a). Breeding Bird Survey 

data showed a significantly increasing trend for gray vireos range-wide during the 1980s and 

1990s; however, this may, in part, reflect increased ability by survey personnel to detect this 

easily overlooked species (New Mexico Partners in Flight 2007). Current range-wide Breeding

Bird Survey data still show an increasing trend, but there is insufficient sample size and data 

quality for a reliable estimate to be made. Breeding Bird Survey coverage of this species in New 

Mexico is minimal. The highly negative trend shown for New Mexico reflects a drop in 

detections on a small number of routes in the northwest part of the state. On the SFNF, the gray 

vireo is documented on the Jemez and Española Ranger Districts and is suspected on the Coyote, 

Cuba, and Pecos/Las Vegas Ranger Districts. Individuals and a pair of birds were detected during 

surveys on the SFNF in 2010.

There are approximately 192,600 acres of potential habitat for the gray vireo on the SFNF, 9,200

acres of which are in the project area. This habitat was modeled using pinyon-juniper vegetation 

communities between 5,500 and 7,200 feet in elevation. Due to a low number of observations, it 

is uncertain how much potential habitat it currently occupies.

Pale Townsend’s Big-Eared Bat

Although pale Townsend’s big-eared bat occurs in a wide variety of habitats, its distribution

tends to be geomorphically9determined and is strongly correlated with the availability of caves 

or cave-like roosting habitat, such as old mines. Population concentrations occur in areas with

substantial surface exposures of cavity-forming rock, such as limestone, sandstone, gypsum, or

volcanic (Pierson et al. 1999). Individuals or small groups of three to five bats may day roost in 

hollow and creviced trees and snags for a limited time. 

Populations appear to be quite sedentary, with marked animals (all females) not known to move 

more than a few miles from their birth roost. Studies suggest that movement in the nursery 

season, whether for foraging or shifting to an alternate roost, are confined to within 9.3 miles of 

the primary roost (Pierson and Rainey 1998). The most significant roosts are those with large 

congregations of bats, summer maternity roosts, and winter hibernacula (Pierson et al. 1999). 

These sites are highly sensitive to disturbance and human interference. 

Foraging occurs after dark in a variety of habitats, including open and forested areas. The bat 

forages in tree canopies and gleans insects from vegetation. It can forage up to 8 miles from day 

roosts but tends to forage within a few miles of colonial roosts (Pierson et al. 1999). Suitable 

roosting and foraging habitat is in the project area.

Threats are habitat loss, cave vandalism disturbance by cave explorers at maternity and

hibernation roosts (Pierson et al. 1999; Biota Information System of New Mexico 2006), and the 

spread of white-nose syndrome, which affects hibernating bats. Named for the white fungus that 

appears on the muzzle and other body parts of hibernating bats, white-nose syndrome is 

associated with extensive mortality of bats in eastern North America. First documented in New 

 

9 Related to or resembling the earth’s surface
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Santa Fe National Forest Geothermal Leasing EIS 3-99

York in the winter of 2006/2007, white-nose syndrome has spread rapidly across the eastern 

United States and Canada, and the fungus associated with white-nose syndrome has been 

detected as far west as Oklahoma. White-nose syndrome has not been documented in New 

Mexico.

There are approximately 302,600 acres of potential habitat for the pale Townsend’s big-eared bat 

on the SFNF, 6,200 acres of which are in the project area. This habitat was modeled using 

information on geologic formations that are known for producing cave and rock crevice habitat. 

While mines provide artificial habitat for the pale Townsend’s big-eared bat, there is insufficient 

information on bat use of abandoned mines on the SFNF; therefore, mines were not used for this 

analysis. An individual was captured during studies in 1998 in the vicinity of the project area, 

indicating a low density in the Jemez Mountains (Bogan et al. 1998). It is uncertain how much 

potential habitat it currently occupies.

Spotted Bat

Spotted bats have been recorded in a variety of habitats, including riparian, pinyon-juniper, 

ponderosa pine, mixed-conifer, and spruce-fir forest. Most records are from forested areas. This 

bat occurs between 3,900 and 10,600 feet in New Mexico. It is suggested that it is a resident of 

the ponderosa pine area in June and July and moves to lower elevations in late summer and 

autumn. Those captured in the Jemez Mountains were netted over streams or water holes in 

ponderosa or mixed-coniferous forest (Bogan et al. 1998). They are cliff dwellers that roost in 

cracks and crevices in rock. The bat’s diet consists predominantly of moths but also includes 

katydids, grasshoppers, and flies (Biota Information System of New Mexico 2006; NMDGF 

2006). 

This species is fairly rare throughout its range, indicating that its scarcity in New Mexico may be 

due to biology rather than other impacts (NMDGF 2006). There are approximately 76,900 acres 

of potential habitat for the spotted bat on the SFNF, 7,500 acres of which are in the project area. 

Due to the species rarity and low number of observations, it is uncertain how much potential 

habitat it currently occupies. Suitable roosting and foraging habitat is in the project area.

Gunnison’s Prairie Dog

Gunnison’s prairie dog is found in grassland and shrub-steppe habitat, at elevations ranging from 

semi-desert to montane (NMDGF 2008). In New Mexico, Gunnison's prairie dog may occur 

from approximately 4,500 to 10,000 feet in elevation. The species is found in montane grassland, 

juniper savanna, plains-mesa grassland, Great Basin desert scrub, plains-mesa sand scrub, and 

desert grassland vegetation in New Mexico, as well as in urban and cultivated areas (NMDGF 

2008). A large complex of Gunnison’s prairie dog in the VCNP, next to the project area,

constitutes a focal area for the species. Approximately 8,000 acres of potentially suitable habitat 

is in the project area, and six incidental observations were recorded there. Due to a low number 

of observations, it is uncertain how much potential habitat it currently occupies.

American Marten

American marten prefers late successional stands of mesic, conifer-dominated forest. It occurs 

between 7,000 to 13,000 feet, mostly above 9,000 feet. Optimum habitat appears to be mature 

old-growth spruce/fir, with more than 30 percent canopy cover, abundant fallen logs and stumps, 

and lush shrub and forb vegetation to support prey species. These are mice, voles, insects, red 

squirrels, and snowshoe hare. It also feeds on carrion, birds, and bird eggs. It is sensitive to 
Chapter 3. Affected Environment and Environmental Consequences

3-100 Santa Fe National Forest Geothermal Leasing EIS

changes in habitat, including timber harvest, snag removal, and firewood collection. Martens den 

in tree cavities, logs, rock piles, and burrows (Forest Service 2014a).

American marten have been documented on the Espanola and Pecos/Las Vegas Ranger Districts 

and suspected on the Jemez District of the SFNF. There have been no recorded observations in 

the project area, but there have been sightings on the northwestern corner of the VCNP, next to 

the project area. American marten home ranges from these sightings would most likely overlap 

with the project area. Due to no recorded observations, it is uncertain how much potential habitat 

it currently occupies.

Goat Peak Pika

Goat Peak pika is confined to talus slides and boulder fields in alpine and subalpine areas. 

Optimal habitat for the pika is the talus/meadowland ecotone, with grass growing between the 

rock slabs. Temperature is a limiting factor for Goat Peak pika. The temperature within 

representative talus habitat ranges from -10 to 53°F, with temperatures 2 feet above the ground 

ranging from -13 to 72°F. Pikas cannot tolerate an ambient air temperature in their immediate 

environment of 82°F for more than two hours.

In the Jemez Mountains, Goat Peak pikas have been observed on Goat, Santa Clara, and Pelado

Peaks, where they live in lava rocks as low as 9,000 feet (Biota Information System of New 

Mexico 2016). Goat Peak pikas occupy virtually every patch of appropriate talus in the Jemez 

Mountains. Specimens have been collected from Chicoma Mountain, Pajorito Mountain, Cerro 

Grande, Rabbit Mountain, the head of Frijoles Creek, Redondo Peak, and Cerros del Abrigo. 

Additional sightings have been made on Cerro Toledo and Shell Mountain (Biota Information 

System of New Mexico 2016). There are approximately 7,400 acres of potential habitat for the 

Goat Peak pika on the SFNF, 200 acres of which are in the project area. This habitat was 

modeled using alpine and subalpine communities above 9,000 feet in elevation. Goat Peak pikas 

have been recorded at Pelado Peak, Rabbit Mountain, and Frijoles Creek in the project area. 

American Pika

American pika is rather narrowly restricted to mountainous areas, where talus slopes provide 

suitable cover. In New Mexico, American pikas live from above the timberline, down into 

subalpine forest. Occasional exceptional animals are found living under piles of boards or 

timbers or in burrows (probably made by other mammals), but broken rock (including mine 

tailings) is the usual habitat. The rock must be sufficiently large that the spaces between provide 

corridors for movement; the slide must be of sufficiently recent origin that the spaces have not 

filled with debris from higher ground. In the best habitat the talus is interspersed with meadow 

vegetation (Biota Information System of New Mexico 2016). 

In New Mexico, American pikas are confined to talus slides and boulder fields in alpine and 

subalpine areas. They are common in the alpine area of the Sangre de Cristo Range, descending 

as low as 11,000 feet. There are approximately 86,400 acres of potential habitat for the American 

pika on the SFNF, less than 100 acres of which are in the project area. One occurrence of 

American pika has been recorded in the project area.

Cinereus (Masked) Shrew

In New Mexico, this shrew is confined primarily to riparian habitats in subalpine coniferous

forest in the Sangre de Cristo, Jemez, and San Juan Mountains, usually above 9,500 feet. This 

species has been found along the banks of cold streams, in springy meadows, or under logs in the 

cold spruce woods.
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Santa Fe National Forest Geothermal Leasing EIS 3-101

There are approximately 268,500 acres of potential habitat for cinereus shrew on the SFNF, 

23,100 acres of which are in the project area. This habitat was modeled by including highelevation areas (above 9,000 feet in elevation), including ponderosa pine and white fir vegetation 

communities on the west side of the SFNF. Five observations have been recorded in the project 

area (Forest Service GIS 2015). Due to the large area modeled and the fact that more than 75 

percent of the observations fell within the modeled habitat, most of the modeled habitat is 

assumed to be sparsely occupied. 

Water Shrew

According to current records in New Mexico, water shrews are confined to the Sangre de Cristo,

San Juan, and Jemez Mountains. It occurs near permanent streams, seldom descending below 

8,000 feet in elevation. The water shrew can swim with great facility, diving under water to 

pursue aquatic organisms, and can run across the surface of the water for a short distance 

(Findley 1987). It eats large quantities of invertebrates daily, such as earthworms and spiders.

On the SFNF, the water shrew has been documented on all Ranger Districts. It is widespread in 

the Jemez Mountains, although it is not common (Frey 2004). Known capture sites on the Jemez 

Ranger District are near Fenton Lake, Rio Cebolla, and San Antonio Creek. There are 

approximately 76,900 acres of potential habitat for water shrew on the SFNF, 7,500 acres of 

which are in the project area. It is uncertain how much potential habitat it currently occupies,

though approximately a third of the observations fell within the modeled habitat. Water shrews 

have been observed along San Antonio Creek in the project area. 

Preble’s Shrew

The species can be found near permanent or intermittent streams, in arid to semiarid shrub or

grasslands, and to a lesser extent in dense high-elevation coniferous forests. In general, its

habitats are confined to riparian or riparian-like (e.g., springs and seeps) conditions (Cornely et 

al. 1992). Little is known about its food sources, but it probably forages on small, soft-bodied 

invertebrates found in riparian areas. There are approximately 76,900 acres of potential habitat 

for Preble’s shrew on the SFNF, 7,500 acres of which are in the project area. Six incidental 

observations have been recorded there. Due to a low number of observations, how much

potential habitat it currently occupies is uncertain.

3.13.1.5 Plants

Yellow Lady’s Slipper

The yellow lady’s slipper is a perennial deciduous herb that grows as a single plant or in a 

colony. It grows in moderate shade to nearly full sun in fir, pine, and aspen forests from 6,000 to 

9,500 feet in elevation. It most often grows just above the banks of streams, usually 150 to 300 

feet from water. This species grows on mesic slopes up to 60 degrees, facing east to northeast, 

and covered with lush growth less than a foot tall (Forest Service 2014a). 

This species is known from San Miguel, Los Alamos, San Juan, and Santa Fe Counties (Forest 

Service 2014a). There is no modeled habitat for it in the project area, and there are no recorded 

observations there, but yellow lady’s slipper has been observed in the Valle Caldera National 

Preserve, next to the project area. Due to a low number of observations, it is uncertain how much 

potential habitat it currently occupies and if suitable habitat is in the project area.
Chapter 3. Affected Environment and Environmental Consequences

3-102 Santa Fe National Forest Geothermal Leasing EIS

Heil’s Alpine Whitlowgrass

Heil’s alpine whitlowgrass is a perennial herb found scattered in small populations in northern 

New Mexico. This species is found in alpine tundra growing in association with other low

growing, cushion-shaped alpine plants. This species occurs at elevations from 12,100 feet and 

higher. It is known from Rio Arriba and Mora Counties (NMRPTC 1999). It has not been 

recorded in the project area but has been recorded on the Bandelier National Monument next to 

the project area, and there may be suitable habitat in the project area. Due to a low number of 

observations, it is uncertain how much potential habitat it currently occupies.

Woodlily

The woodlily is a perennial herb found scattered in small populations in northern New Mexico. It

prefers wetter sites, in mixed conifer forests with a lush understory, often associated with large 

aspen, Douglas-fir, or ponderosa pine. Less frequently this species can be found along streams or 

in meadows (Forest Service 1990). It prefers soils that are rich and well drained. This species is 

known from San Miguel, Los Alamos, Sandoval, Otero, Rio Arriba, and Santa Fe Counties 

(Forest Service 2014a). It has not been recorded in the project area, but it contains approximately 

4,700 acres of potentially suitable habitat. Potentially suitable habitat both within the project area 

and surrounding areas has undergone significant reductions due to wildfires. Due to a low 

number of observations, it is uncertain how much potential habitat it currently occupies.

Santa Fe Blazingstar

Santa Fe blazingstar is a perennial herb, with numerous branches 1.0 to 1.5 feet long. Its yellow

flowers open in late afternoon in July through August. This species occurs in volcanic pumice 

and unconsolidated pyroclastic ash in pinyon-juniper woodland and lower montane coniferous 

forests, from 7,000 to 8,000 feet in elevation (NMRPTC 1999). This species is narrowly endemic 

to loose, volcanic substrate of the Jemez Mountains and is often seen where roads cut through 

pumice.

The Santa Fe blazingstar is known in Los Alamos, Sandoval, and Santa Fe Counties, New 

Mexico. Modeled habitat was taken from the SFNF’s Terrestrial Ecological Unit Inventory 

geospatial information for volcanic soils between 7,000 and 8,000 feet in elevation 

(approximately 15,500 acres of potential habitat on the SFNF, 5,600 acres of which are in the 

project area). The Santa Fe blazingstar has been documented in three locations in the project 

area, with a total of 0.49 acre of occupied habitat recorded. Due to a low number of observations, 

it is uncertain how much potential habitat it currently occupies.

Arizona Willow

Arizona willow is a perennial shrub forming a prostrate mat, large hedge, or thicket up to 9 feet 

tall. The plant’s flowers open in late May through June. This species occurs in sedge meadows 

and wet drainage ways in subalpine coniferous forests, from 10,000 to 11,200 feet in elevation 

(NMRPTC 1999). Habitat often occurs as a narrow, linear strip associated with perennial water 

in seeps, springs, stream sides, and wet meadows. This species is known from locations in New 

Mexico, Arizona, and Utah. Arizona willow is known in Rio Arriba, Taos, and Mora Counties, 

New Mexico. The Forest Service has not documented it in the project area, where there is

approximately 100 acres of potentially suitable habitat. Due to a low number of observations, it 

is uncertain how much potential habitat it currently occupies.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-103

3.13.2 Environmental Consequences

3.13.2.1 Scoping Comments on Resource

The following issues specific to threatened and endangered species and special status species 

were identified during the public scoping period:

 What are the impacts of geothermal leasing on the Mexican spotted owl, Jemez Mountain 

salamander, New Mexico meadow jumping mouse, Jemez woodland snail, RGCT, and other 

threatened and endangered or special status species in the project area? What stipulations 

and mitigation measures are necessary to protect these species?

 Would geothermal leasing displace other resource uses on the forest, such as recreation and 

livestock grazing, into or near threatened and endangered species or special status species’ 

habitats?

3.13.2.2 How Resource Impacts Were Evaluated

Method

The method for determining special status species impact is incorporated by reference from the 

2008 Geothermal PEIS (BLM and Forest Service 2008). The analysis presented is largely 

qualitative, due to the lack of data or uncertainty in existing data on special status species in the 

project area. Since most special status species are associated with specific vegetation 

communities, the impacts on vegetation described in Section 3.11 would also likely impact 

special status species. In addition, many of the impacts on fish and wildlife associated with 

geothermal development described in Section 3.12 would also apply to special status species.

Indicators

Indicators of impacts on special status species are as follows:

 Change in acres of habitat potentially suitable for threatened and endangered and special 

status species

 Change in acres of habitat occupied by threatened and endangered and special status species

 Change in number of threatened and endangered and special status species populations

 Change in acres of rare plant associations

 Change in number of special status wildlife detections

Assumptions

This analysis assumes the following:

 NSO stipulations would minimize direct disturbance to habitats and species by restricting 

surface-disturbing activities where they are applied.

 TL stipulations would help to prevent direct disturbance to species during sensitive periods, 

such as winter, when forage is sparse, and during breeding and birthing.

 Disturbance of a key or critical component of a species habitat would be detrimental, with 

the degree dependent on the importance of the habitat component to the maintenance of the 

population.

 Impacts on special status species would be more significant than impacts on common species 

because population viability is already uncertain for special status species.
Chapter 3. Affected Environment and Environmental Consequences

3-104 Santa Fe National Forest Geothermal Leasing EIS

 The Forest Service would consult with the USFWS for any actions that could affect any 

federally listed endangered, threatened, or proposed species.

3.13.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Special Status Species Associated with 

Geothermal Development section of the 2008 Geothermal PEIS (BLM and Forest Service 2008) 

is incorporated by reference. Additional information specific to this EIS includes consideration 

of the particular special status species and habitats found in the project area.

Due to the inability to predict the location, scope, scale, and timing of future development, the 

impact analysis below provides a general description of common indirect impacts on threatened 

and endangered and special status species from geothermal resource development. Geothermal 

exploration, drilling operations, utilization, and reclamation and abandonment could affect 

threatened, endangered, and sensitive species in the same manner that vegetation, wildlife, and 

aquatic resources could be affected (see Section 3.12, Fish and Wildlife).

Special status species could be affected as a result of 

 Habitat disturbance

 Introduction of invasive vegetation

 Injury or mortality

 Erosion and runoff

 Fugitive dust

 Noise

 Exposure to contaminants

 Interference with behavioral activities

Which species may be at risk to construction-related impacts would depend on the project 

location and specific habitat at or near the site.

An important distinction about impacts on special status species is that those on small localized 

areas or those affecting only a few individuals can have impacts on special status species. Many 

special status species depend on unique habitats or have small remaining populations. Impacts 

that directly affect these unique habitats or individuals, even when small, can have significant 

impacts on special status species.

3.13.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analyses, in accordance with the Forest Plan and existing laws and regulations. 

Geothermal leasing stipulations and closures specific to threatened and endangered species or 

other special status species would not be implemented; however, any geothermal lease 

applications and nominations would be subject to standards and guidelines outlined in the Forest 

Plan and environmental analysis. The Forest Service has determined that the JNRA

(approximately 28,900 acres) is excluded from geothermal leasing on the basis of existing laws, 

regulations (see 43 CFR, Subpart 3201.11), and executive orders. There would be no direct 

disturbance to threatened, endangered, or sensitive species in the JNRA under Alternative 1.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-105

Elsewhere, the types of impacts that could occur on threatened and endangered and special status 

species are those described under Common Impacts Associated with Geothermal Development. 

3.13.2.5 Impacts Under Alternative 2

Federally Listed Species

Jemez Mountain Salamander

Jemez Mountain salamander may be affected by habitat alteration, removal, reduction, or 

fragmentation. No surface occupancy stipulations would apply to any designated critical habitat 

for this species. There are approximately 34,400 acres of critical habitat for Jemez Mountain 

salamander in the project area, and it may also be present outside of designated critical habitat in 

the aspen and spruce/fir vegetation communities. 

NSO stipulations would be in place outside of critical habitat as well, as outlined in Chapter 2. 

Under Alternative 2, NSO stipulations would apply to approximately 132,900 acres in the project 

area. Up to 674 acres of disturbance is anticipated in the RFDS in the project area; any

disturbance that occurs in Jemez Mountain salamander habitat outside of designated critical 

habitat would reduce the number of acres of suitable habitat available. Habitat at drilling pads, 

facilities, roadways, and transmission corridors would be affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. 

Fragmentation would affect Jemez Mountain salamander by altering how it uses the habitat. 

Fragmentation can separate populations into smaller populations, making them more vulnerable 

to predation, drought, and disease and limiting genetic diversity within breeding groups. 

Movement between habitat tracts is more difficult after fragmentation. Roads have been shown 

to impede the movements of invertebrates, reptiles, and small and large mammals (Jackson 

2000). Habitat fragmentation can create increased edges for access by predators and invasive 

species (Biota Information System of New Mexico 2015). 

Disturbance in occupied habitat could lead individuals to move into adjacent habitat that may be 

at or near carrying capacity. Increased concentrations in adjacent habitat could lead to an 

increase in the spread of diseases transmitted from humans, such as Batrachochytrium 

dendrobatidis, a fungal disease in northern New Mexico.

Direct injury and mortality could occur as a result of geothermal development associated with 

the RFDS. Equipment used for clearing vegetation, roadways, well pads, and facility sites and 

vehicles used during operation and closeout would affect wildlife, such as the Jemez Mountain 

salamander, which are not mobile enough to avoid construction operations. 

New Mexico Meadow Jumping Mouse

Impacts on New Mexico meadow jumping mouse from geothermal projects are directly linked to 

impacts on riparian and wetland habitats, in most cases. Impacts would result primarily from 

activities occurring near or in water bodies. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies
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3-106 Santa Fe National Forest Geothermal Leasing EIS

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas 

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for New Mexico meadow jumping mouse. NSO 

stipulations would apply to any designated critical habitat for New Mexico meadow jumping 

mouse. Approximately 800 acres of critical habitat have been designated in the San Antonio 

Creek and Rio Cebolla areas in the project area. Potential habitat occurs beyond designated 

critical habitat (such as along the upper Rio Cebolla); however, development in these areas 

would be restricted due to the riparian area stipulations. Direct and indirect impacts on New 

Mexico meadow jumping mouse would not occur as a result of Alternative 2.

Mexican Spotted Owl

MSO may be impacted by habitat alteration, removal, reduction, or fragmentation. NSO

stipulations would apply to any MSO-designated critical habitat. Approximately 12,998 acres of 

MSO critical habitat have been designated in the project area. Up to approximately 674 acres of 

disturbance is anticipated in the RFDS in the project area, and any disturbance that occurs in 

MSO habitat outside of designated critical habitat would reduce the number of acres of suitable 

habitat available. Habitat at drilling pads, facilities, roadways, and transmission corridors would 

be affected. The magnitude of the disturbance would be a function of the level of preexisting 

disturbance and the size, scale, and phase of geothermal development. 

Noise from geothermal activities can have impacts on MSO. Principal sources of noise from 

geothermal activities would be trucks, drilling rigs, and heavy machinery. The most impacts 

associated with noise could occur if critical life cycle activities (e.g., mating and nesting) were 

disrupted. Disturbance during mating, nesting, or rearing of young can cause MSO to abandon 

mating and nesting activities and can strand young, leaving them susceptible to predation and 

starvation. 

On the basis of the types of equipment that would likely be used, such as drilling rigs and 

graders, the noise levels at distances of less than 400 feet from binary power plants would be 

above 65 dBA. Noise levels from production wells would exceed the 65 dBA limit only at a 

distance of less than 69 feet.

The location and timing of geothermal activities (especially exploration and development) may 

affect the migratory and other behavioral activities of MSO. They may cease foraging, mating, or 

nesting or may vacate active nest sites in areas where geothermal activities are occurring; MSO 

may permanently abandon the disturbed areas and adjacent habitats. In addition, exploration and 

development may affect movements; for example, they may avoid a localized migratory route 

because of ongoing construction. However, drilling and construction would be prohibited 

between March 1 and August 31 in MSO-designated PACs. Implementing TLs in designated 

PACs would minimize impacts on MSO during critical nesting and breeding periods.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-107

Fisheries and Aquatic Biota

Impacts on Rio Grande sucker, Rio Grande chub, RGCT, and northern leopard frog from 

geothermal projects are directly linked to impacts on riparian and wetland habitats, in most 

cases. Impacts would result primarily from activities near or in water bodies. The East Fork and 

main stem of the Jemez River and San Antonio Creek are in the JNRA, which is closed to 

geothermal development, so direct impacts from geothermal development in these streams would 

not occur. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for aquatic species. 

Indirect impacts on aquatic habitat from groundwater withdrawal during geothermal activities

are unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage, with USFWS consultation, once more information is known. 

Stream flow rates are affected by the upland vegetation and adjacent terrain; therefore, 

geothermal development could alter stream flows and affect aquatic species and habitat. NSO

stipulations would apply to slopes in excess of 40 percent and soils with severe erosion potential. 

These stipulations would reduce the impacts on aquatic habitat from runoff and sedimentation of 

streams due to geothermal activity.

Alternative 2 may impact individual Rio Grande sucker, Rio Grande chub, RGCT, and northern 

leopard frog; however it is not likely to result in a trend toward federal listing of these species or 

loss of species viability.

Riparian Mammals

In most cases, impacts on water shrew and Preble’s shrew from geothermal projects are directly 

linked to impacts on riparian and wetland habitats. Impacts would result primarily from activities 

occurring near or in water bodies. The East Fork and main stem of the Jemez River and San 

Antonio Creek are in the JNRA, which is closed to geothermal development, so direct impacts

from geothermal development in these streams would not occur. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies
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3-108 Santa Fe National Forest Geothermal Leasing EIS

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for riparian species. 

Alternative 2 may impact individual water shrew and Preble’s shrew, but it is not likely to result 

in a trend toward federal listing of these species or loss of species viability.

Raptors and Migratory Birds

Northern goshawk, boreal owl, American peregrine falcon, and gray vireo may be affected by 

habitat alteration, removal, reduction, or fragmentation. Up to 674 acres may be disturbed in

raptor and migratory bird habitat in the project area and may reduce the number of acres of 

suitable habitat available. Habitat at drilling pads, facilities, roadways, and transmission 

corridors would be affected. The magnitude of the disturbance would be a function of the level 

of preexisting disturbance and the size, scale, and phase of geothermal development. 

Geothermal development would have the greatest impact on raptors and migratory birds if it 

were to affect specialty habitats, such as riparian areas, wetlands, cliffs, tall trees, or nesting 

areas. NSO stipulations would apply to several specialty habitats, such as riparian areas and 

wetlands. 

The direct injury and mortality of raptors and migratory birds may occur as a result of 

geothermal development associated with the RFDS. Equipment used for clearing vegetation and 

roadways, well pads, and facility sites and vehicles used during operation and closeout would 

affect migratory birds nesting in the areas of proposed disturbance. Wildfire could remove acres 

of suitable habitat for raptors and migratory birds and could reduce the quality of remaining 

habitat.

Noise from geothermal activities can have impacts on raptors and migratory birds. The principal 

sources of noise are trucks, drilling rigs, and heavy machinery. The most impacts associated with 

noise could occur if critical life cycle activities were disrupted (e.g., mating and nesting). All 

birds could be disturbed by noise. Disturbance during mating, nesting, or rearing of young can 

cause birds to abandon mating and nesting activities and can strand young, leaving them 

susceptible to predation and starvation. 

However, TLs are proposed in northern goshawk post-fledgling areas, with drilling and 

construction prohibited between March 1 and September 30, and in peregrine falcon nesting 

areas, with drilling and construction prohibited between March 1 and August 15. These measures 

would minimize risks to northern goshawk and peregrine falcon reproductive and post-fledgling 

success during the critical nesting and breeding period. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-109

Raptors and migratory birds could also be affected by light pollution. Increased illumination may 

extend diurnal10 or crepuscular11 behaviors into the nighttime environment by improving an 

animal’s ability to orient itself. However, constant artificial night lighting may also disorient or 

entrap birds accustomed to navigating in a dark environment, which may affect foraging, 

reproduction, communication, and other behaviors (Longcore and Rich 2004). The BMPs

identified in Appendix C include efficient facility light design, such that upward light scattering 

is minimized. These measures would minimize potential impacts on migratory birds associated 

with light pollution.

Alternative 2 may impact individual northern goshawk, boreal owl, American peregrine falcon, 

and gray vireo, but it is not likely to result in a trend toward federal listing or loss of species 

viability.

Bats

Pale Townsend’s big-eared bat and spotted bat may be affected by habitat alteration, removal, 

reduction, or fragmentation. Up to 674 acres may be disturbed in bat habitat in the project area, 

which may reduce the number of acres of suitable habitat available. Habitat at drilling pads, 

facilities, roadways, and transmission corridors would be affected. Geothermal development

would have the greatest impact on bats if it were to affect specialty habitats, such as riparian

areas, wetlands, rock outcrops, caves, and tree roosting areas. NSO stipulations would apply to 

several specialty habitats, such as riparian areas, wetlands, and slopes in excess of 40 percent 

(accounting for rock outcrops and cliffs). 

The direct injury and mortality of bats may occur as a result of geothermal development

associated with the RFDS. Bat mortalities could occur by colliding with vehicles or structures 

associated with geothermal development. Shining lights downward can reduce the risk of 

impacts on bat species; implementing such BMPs as installing shrouds, properly directing light 

to illuminate only necessary areas, and installing motion sensors to illuminate areas only when 

necessary, would minimize upward light scattering.

Noise from geothermal activities can have impacts on bats. The principal sources of noise would

be trucks, drilling rigs, and heavy machinery. The most impacts associated with noise could 

occur if critical life cycle activities were disrupted (e.g., mating and foraging). Bats use sound in 

order to forage, and increased noise can affect their ability to find food through echolocation. 

On the basis of the types of equipment that would likely be used, such as drill rigs and graders, 

the noise levels associated with the equipment would be elevated to levels that could potentially 

disturb bat species, which are known to avoid areas of elevated noise while foraging (Schaub et 

al. 2008).

Alternative 2 may impact individual pale Townsend’s big-eared bat and spotted bat, but it is not 

likely to result in a trend toward federal listing or loss of species viability.

Small Mammals

Gunnison’s prairie dog, American marten, Goat Peak pika, American pika, and cinereus shrew 

may be affected by habitat alteration, removal, reduction, or fragmentation. Up to 674 acres may 

be disturbed within potential small mammal habitat in the project area and may reduce the 

 

10 Appearing or active during the day

11 Appearing or active in twilight
Chapter 3. Affected Environment and Environmental Consequences

3-110 Santa Fe National Forest Geothermal Leasing EIS

number of acres of suitable habitat available. Habitat at drilling pads, facilities, roadways, and 

transmission corridors would be affected. Geothermal development would have the greatest 

impact on small mammals if it were to affect specialty habitats, such as riparian areas, wetlands, 

alpine talus, caves, or wintering and breeding areas. NSO stipulations would apply to several 

specialty habitats, such as riparian areas, wetlands, and slopes in excess of 40 percent. 

The direct injury and mortality of small mammals may occur as a result of geothermal 

development associated with the RFDS. Equipment used for clearing vegetation and roadways, 

well pads, and facility sites and vehicles used during operation and closeout would affect special 

status wildlife that are not mobile enough to avoid them. Of the small mammal species with 

habitat in the project area, Gunnison’s prairie dog and cinereus shrew would be most susceptible. 

American pika and Goat Peak pika have habitat in high elevation alpine talus, where geothermal 

development is unlikely.

Noise from geothermal activities can have impacts on small mammals. Principal sources of noise 

are trucks, drilling rigs, and heavy machinery. The most impacts associated with noise could 

occur if critical life cycle activities, such as mating, were disrupted. All small mammals could be 

disturbed by noise. Disturbance during mating or rearing of young can cause wildlife to abandon 

mating activities and can strand young, leaving them susceptible to predation and starvation. 

Alternative 2 may impact individual Gunnison’s prairie dog, American marten, Goat Peak pika, 

American pika, and cinereus shrew, but it is not likely to result in a trend toward federal listing

or loss of species viability.

Plants

Yellow lady’s slipper, Heil’s alpine whitlowgrass, woodlily, Santa Fe blazingstar, and Arizona 

willow may be impacted by habitat alteration, removal, reduction, or fragmentation. Up to 674

acres may be disturbed in potential sensitive plant habitat in the project area, and acres of 

suitable habitat available may be reduced. Habitat at drilling pads, facilities, roadways, and 

transmission corridors may be affected. The magnitude of the disturbance would be a function of 

the level of preexisting disturbance and the size, scale, and phase of geothermal development. 

Fragmentation can separate sensitive plant populations into smaller populations, making them 

more vulnerable to drought, surface disturbance, and disease. Fragmentation can facilitate the 

spread and introduction of invasive plant species. Roads and other corridors can facilitate the 

dispersal of invasive species by altering existing habitat conditions, stressing or removing native 

species, and allowing easier movement of wild or human vectors (Trombulak and Frissell 2000). 

Sensitive plants can be affected by invasive vegetation through competition for resources and 

available habitat. However, BMPs for noxious weeds identified in Appendix C, including 

development of a weed control plan and use of a controlled inspection and cleaning for 

construction equipment, would reduce the potential for noxious weed invasion. Wildfire could 

remove acres of suitable habitat for special status plants and could reduce the quality of 

remaining habitat.

The direct removal and mortality of sensitive plants would likely not occur as a result of 

geothermal development associated with the RFDS. Before geothermal activity begins, BMPs

such as clearance surveys could be incorporated as appropriate into permit applications, or 

included in the approved use authorizations. These measures would allow for detection and 

avoidance of sensitive plant populations prior to disturbance. NSO stipulations for riparian areas 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-111

and wetlands would reduce the potential to impact yellow lady’s slipper, woodlily, and Arizona 

willow.

Alternative 2 may impact individual yellow lady’s slipper, Heil’s alpine whitlowgrass, woodlily, 

Santa Fe blazingstar, and Arizona willow, but it is not likely to result in a trend toward federal 

listing or loss of species viability.

3.13.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3. There 

would be no direct or indirect impacts on threatened, endangered, and sensitive species from 

geothermal activities under Alternative 3.

3.13.2.7 Impacts Under Alternative 4

Direct and indirect impacts on federally listed species, raptors and migratory birds, bats, small 

mammals, and plants would be the same as those described under Alternative 2; however, the 

level of intensity of disturbance could be more severe under Alternative 4 for fish, aquatic 

communities, and other species that use or depend on riparian environments. This is because the 

NSO stipulations under Alternative 2 are more restrictive for intermittent streams and soils with 

severe erosion potential.

Intermittent streams, along with a 500-foot protection zone, are subject to NSO stipulations 

under Alternative 2, compared to CSU stipulations under Alternative 4. The potential disturbance 

on intermittent streams could lead to increased sedimentation flowing into perennial streams and 

could have an impact on species that are sediment intolerant, such as Rio Grande sucker, Rio 

Grande chub, RGCT, and other cold water fish species. 

3.13.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for threatened and endangered species and 

special status species is the three level 4 watersheds that intersect the project area: the Rio 

Grande-Santa Fe, Rio Chama, and Jemez watersheds. Impacts on threatened, endangered, and 

sensitive species do not end at the project area boundary but would encompass migration 

corridors, large home ranges, and cross-boundary landscapes that extend beyond SFNF land.

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4. The 

following projects would increase the amount of disturbance in the cumulative impacts analysis 

area:

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam

 Mineral development in the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine

Projects that should improve habitat conditions in the cumulative impacts analysis area are as 

follows:

 Southwest Jemez Mountains Restoration Project,

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project
Chapter 3. Affected Environment and Environmental Consequences

3-112 Santa Fe National Forest Geothermal Leasing EIS

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project

 Supplement to the Final EIS for Invasive Plant Control Project

The response of individual species to past, present, and reasonably foreseeable future actions 

would vary, depending on the life history and habitat needs of the species. However, in general, 

projects that increase the amount of disturbance could reduce habitat or cover where those 

projects occur. 

Alternatives 1, 2, and 4 would increase the number of acres of disturbance in the cumulative 

impacts analysis area, when combined with other past, present, and reasonably foreseeable future 

actions. An expanded road network within the project area could increase fragmentation and 

reduce the habitat quality for special status species in the cumulative impact analysis area. 

However, NSO, CSU, and TL stipulations under Alternatives 2 and 4 would limit wildlife 

impacts in seasonally important habitats (such as goshawk PFAs, peregrine falcon eyrie nesting 

areas, and MSO PACs), designated or proposed critical habitats, and riparian areas. 

For fish and other aquatic special status species, stipulations for rivers, streams, and erosive soils 

under Alternatives 2 and 4 would restrict geothermal development in these areas, thereby 

maintaining acres of occupied and potentially suitable habitat. 

Geothermal development, in combination with other surface-disturbing projects or wildfire, 

could reduce the number of acres of potentially suitable habitat for special status wildlife and 

plants in the cumulative impacts analysis area; however, clearance surveys would be required in 

advance of surface-disturbing geothermal activities.

Combined with other reasonably foreseeable future actions, no significant cumulative impacts on 

threatened, endangered, and sensitive species or their habitat is expected from Alternatives 1, 2, 

and 4. Alternative 3 would have no cumulative impacts on threatened, endangered, and sensitive 

species or their habitat.

3.14 Livestock Grazing

3.14.1 Affected Environment

The primary law governing grazing on NFS lands is the Public Rangelands Improvement Act of 

1978. The three enabling statutes that govern grazing on NFS lands are the Organic Administration 

Act, the Bankhead-Jones Farm Tenant Act, and the Multiple-Use Sustained-Yield Act.

The Forest Service primarily manages grazing and management on NFS lands under 36 CFR, 

Part 222, Forest Service Manual 2200 – Range Management, and Forest Service Handbook 2200 

– Range Management (Forest Service 2016f). Under this management, ranchers may obtain a 

grazing permit for an allotment of public or NFS land on which a specified number of livestock 

may graze. An allotment is an area of land designated and managed for livestock grazing. The 

number of permitted livestock on a particular allotment on public land is determined by how 

many animal unit months12 (AUMs) that land will support. Upper and special limits governing 

the total number of livestock for which a person is entitled to hold a grazing permit on NFS lands 

is determined by the Chief of the Forest Service (36 CFR, Part 222).

 

12 The quantity of forage required by one mature cow and her calf (or the equivalent in sheep or horses) for 

one month. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-113

There are 17 grazing allotments on NFS lands in the SFNF Geothermal Decision Area (see Figure 

3-2). Table 3-16, below, outlines the active grazing allotments that occur in the SFNF Geothermal 

Decision Area, as well as the total acres and AUMs designated for each. 

Table 3-16. Livestock Grazing Allotments in the Santa Fe National Forest Geothermal Decision 

Area

Allotment Name Acres in the Decision 

Area1 AUMs

Alamo 5,100 332

Bland Canyon 100 15

Cebolla/San Antonio 19,700 1544

Chicoma 3,800 152

Coyote 19,900 2457

Del Norte 4,900 337

Jarosa 8,200 3022

Las Conchas 1,400 337

Mesa Del Medio 14,200 1085

Penas Negras 3,800 1387

Peralta 3,700 267

Polvadera 4,800 186

Recreation 3,500 0

San Diego 17,200 2522

Vallecitos 15,800 671

V-Double Slash 12,400 1908

Youngsville 30,300 5640

Sources13: Forest Service GIS 2015 

1Rounded to the nearest 100

3.14.2 Environmental Consequences

3.14.2.1 Scoping Comments on Resource

The following issue specific to livestock grazing was identified during the public scoping period:

 How would geothermal leasing affect grazing allotments and grazing forage?

3.14.2.2 How Resource Impacts Were Evaluated

Method

The method used to determine potential impacts on livestock grazing included a review of 

available allotment information and GIS data for the geothermal decision area.

 

13 Mathew Chavez and Anne Bishop, Forest Service, personal communication with Holly Prohaska, 

EMPSi. March 2, 2016.

Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-115

Indicators

Potential impacts on livestock grazing could occur if reasonably foreseeable future actions were 

to result in the following:

 Decrease acreages available to grazing

 Decrease AUM number or forage

 Cause harassment or death of livestock

3.14.2.3 Common Impacts Associated with Geothermal Development

Issuing a geothermal lease does not involve ground-disturbing activities or any type of 

construction, so there would be no direct impact on livestock grazing. Impacts would result from 

activities pursued after leasing. Due to the inability to predict the location, scope, scale, and 

timing of future development, the following impact analysis provides a general description of 

common impacts on livestock grazing from geothermal resource development. 

A detailed description of geothermal development operations relative to livestock grazing

resources are described in detail in the 2008 Geothermal PEIS; the phases of geothermal 

development, including exploration, drilling operations, utilization, and reclamation and 

abandonment, are also discussed in detailed in the PEIS. Indirect impacts on livestock grazing 

from the future phases of geothermal exploration or development would occur from ground 

disturbance on allotments in a lease area. Indirect impacts are temporary or permanent reduction 

in forage and AUMs, harassment of livestock, shifts in grazing distribution, or changes in season 

of use.

3.14.2.4 Impacts Under Alternative 1

Under Alternative 1, the JNRA (approximately 28,900 acres) is excluded from geothermal 

leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and executive 

orders. Within those 28,900 acres there would be no disturbance to livestock or livestock 

management on the allotments in the JNRA from geothermal development (see Table 3-17, 

below). Indirect impacts identified above and in the 2008 geothermal PEIS could occur on 

allotments outside of the JNRA on a case-by-case basis.

Table 3-17. Livestock Grazing Allotments in the Jemez National Recreation Area

Allotment Name Acres in the Jemez 

National Recreation 

Area

Percentage of 

Allotment

Cebolla San Antonio 1,600 8

Del Norte 3,300 67

Las Conchas 1,400 100

Peralta 2,100 57

Recreation 3,400 97

San Diego 7,500 44

Vallecitos 3,800 24

V-Double Slash 5,700 46

Total 28,900

Source: Forest Service GIS 2015
Chapter 3. Affected Environment and Environmental Consequences

3-116 Santa Fe National Forest Geothermal Leasing EIS

Based on the RFDS for the decision area and an estimated disturbance of 27 acres from 

exploration or 647 acres of development, there is potential for indirect impacts on grazing 

allotments outside of the JNRA and other closure areas. These impacts would be a reduction in 

forage, possible reductions in AUMs, and harassment of livestock. However, because the size 

and location of each geothermal project is not known, the disturbance of approximately 674

acres could be spread across all of the grazing allotments, minimizing overall impacts per 

allotment.

3.14.2.5 Impacts Under Alternative 2

In addition to portions of allotments closed to geothermal development that fall within the 

JNRA, Alternative 2 closes other areas based on special circumstances. As such, the Cebollo San 

Antonio allotment would have an additional 2,600 acres closed to geothermal development, the 

Vallecitos and V-Double Slash allotments would have an additional 100 acres closed to 

geothermal development, and the Youngsville would have 300 acres closed to geothermal 

development. The closures, along with the addition of NSO stipulations, would slightly decrease 

disturbance of livestock grazing and livestock forage over Alternative 1. 

3.14.2.6 Impacts Under Alternative 3

Under Alternative 3, all 194,900 acres of grazing allotments in the project area would be closed 

to leasing. Therefore, there would be no direct or indirect impacts on livestock or livestock 

operations from geothermal leasing and development.

3.14.2.7 Impacts Under Alternative 4

Indirect impacts under Alternative 4 would be the same as those described for the No Action 

Alternative; however, CSU stipulations may decrease harassment of livestock or disturbance of 

forage where these area overlap. 

3.14.2.8 Cumulative Impacts

Cumulative impacts on livestock grazing would occur from the loss of forage for grazing, loss of 

AUM capacity, and the disruption of livestock grazing practices where geothermal development

and other projects create disturbance on grazing allotments in and next to the project area. Past, 

present, and reasonably foreseeable future actions are discussed in Section 3.3.4 and include the 

following projects, which would increase the amount of disturbance in the project area:

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam

 Mineral development in the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine

However, cumulative projects that would also promote healthy forage and clean water in the 

project area are as follows:

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-117

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project (while this project 

would promote clean water, forage would be protected for jumping mouse habitat and not 

available to livestock)

 Supplement to the Final EIS for Invasive Plant Control Project

3.15 Cultural Resources

Cultural resources are the present expressions of human culture and the physical remains of past 

activities, such as buildings, structures, districts, landscapes, archaeological sites, and objects. 

They can also include locations that can be significant in national, regional, or local history, 

architecture, archaeology, engineering, or culture. They include sacred sites and natural features 

significant to contemporary communities or peoples. Section 3.16 provides an additional 

discussion of ethnographic resources and the potential for impacts on these resources.

The Cultural Resource Specialist Report (PaleoWest 2016) is incorporated by reference. See the 

report for a detailed cultural history of the project area and information on regulatory 

background, data sources, methods, assumptions, and data limitations.

3.15.1 Affected Environment

NEPA requires a consideration of “important historic, cultural, and natural aspects of our natural 

heritage.” This includes the necessity of independent compliance with the applicable procedures 

and requirements of other federal and state laws, regulations, and executive orders. The principal 

federal law addressing cultural resources is the National Historic Preservation Act (NHPA) of 

1966, as amended (54 USC, Section 300101 et seq.) and its implementing regulations found at 

36 CFR, Part 800.3. These regulations, commonly referred to as the Section 106 process, 

describe the procedures for identifying and evaluating historic properties, for assessing the 

impacts of federal actions on historic properties, and for project proponents consulting with 

appropriate agencies to avoid, reduce, or minimize adverse impacts. Historic properties are 

cultural resources that meet specific criteria for listing on the NRHP.

Among other mandates, Section 110a of the NHPA (54 USC, Sections 306101[a] and 306102) 

requires federal agencies to develop a program that ensures that historic properties under the 

jurisdiction or control of the agency are identified, evaluated, and nominated to the NRHP. It also 

requires that they be maintained in a way that considers the preservation of their historic, 

archaeological, architectural, and cultural values. Although leasing consent has no direct impact 

on cultural resources, it is a commitment of resources that may result in potential impacts in the 

future. Thus, in support of this EIS, the Forest Service has prepared a cultural resource specialist 

report examining the entire geothermal potential area, rather than simply considering reasonably 

foreseeable development or past lease interest areas. The goal of the report is to compile 

information on previously recorded cultural resources and cultural resource inventories in the 

project area. Cultural resource GIS data for sites and projects provided by the Forest Service is 

current and accurate as of fall 2015 (PaleoWest 2016).

3.15.1.1 Inventory

Archaeologists have surveyed approximately 102,002 acres, or 52 percent, of the project area, 

including all levels of pedestrian survey on SFNF, private, and state lands. Many previous 

surveys are overlapping, and therefore cultural resource surveys have covered 233,643 acres in 

965 survey projects. Most of the higher density of survey coverage is in the central and southern 

portion of the project area. Based on reported field methods, inventories are categorized as valid 
Chapter 3. Affected Environment and Environmental Consequences

3-118 Santa Fe National Forest Geothermal Leasing EIS

and complete (consistent with current Forest Service standards), less than complete, or unknown 

by the Forest Service. These assessments of survey validity are not absolute but are considered 

when determining cultural resource identification for specific undertakings. Valid and complete 

survey coverage is estimated at approximately 28 percent of the project area, or 54,558 acres.

The Forest Service has identified 1,962 cultural resource sites on the 102,002 surveyed acres in 

the project area. These consist of a wide variety of prehistoric and historic era resources. 

Human occupation of the Jemez Mountains spans from the earliest identified culture in the 

United States (Paleo-Indian) to the present. Most cultural resource sites identified in the project 

area are prehistoric (1,054, or 54 percent); 143 sites (7 percent) are historic; 368 sites (19 

percent) have both prehistoric and historic components; 388 sites (20 percent) are unknown; and 

the cultural affiliation of 9 sites (less than 1 percent) was not reported. Eight sites are linear, such 

as roads and trails. 

Contemporary pueblo, tribal, and Hispanic groups have traditional ties to ancestral sites, 

landscapes, and resources in the project area. These are not necessarily enumerated or recorded 

in these inventories, but they are of concern from a cultural resource management perspective. 

The Forest Service is responsible for considering the impacts of its actions on traditional cultural 

properties and traditional cultural practices. Section 3.16 provides additional discussion of 

ethnographic resources and the potential for impacts on these resources. 

Prehistoric resources are field houses, agricultural terraces, grid gardens, pueblo villages, 

roomblocks, pithouses, rock art panels, rock shelters, rubble mounds/habitations, campsites, 

activity areas, hearths, hunting features, storage features, cairns, shrines, trails, lithic quarries, 

lithic and pottery scatters, and burials. Historic era resources are ranching and livestock sites, 

railroad and logging sites, cabins ruins, refuse scatters and roads, and erosion control features. 

More than half of the sites in the project area (1,152) are situated between 7,000 and 8,000 feet 

above mean sea level. One site occurs at an elevation of less than 6,000 feet, 201 sites are 

between 6,000 and 7,000 feet, 494 sites are between 8,000 and 9,000 feet, and 113 sites are at 

elevations over 9,000 feet. Only 11 sites have been located above 10,000 feet in elevation.

The GIS data included 405 site records where NRHP eligibility was reported. Eligibility 

recommendations of 1,557 sites were not reported and should be treated as “unevaluated.” Of the 

sites with eligibility recommendations, 6 are listed on the NRHP, 288 are recommended as 

eligible for listing, 21 are ineligible for listing, and 90 are unevaluated (PaleoWest 2016).

Six properties in the project area are listed on the NRHP: one in the JNRA (LA56557 [Virgin 

Logging Camp #2]) and five in the southern part of the project area (LA303 [Sayshukua], LA475 

[Totaskwina], LA478 [Wabakwa], LA386, and LA5920). LA675, known as Gíusewa Pueblo 

(Jemez State Monument), is listed on the NRHP and is National Historic Landmark #12001007. 

Gíusewa is in the project area but is on land owned by the State of New Mexico. 

All of the above sites, aside from the logging camp (LA56557), were listed under a National 

Register Multiple Property nomination, Jemez Cultural Developments in North-Central New 

Mexico (NPS 1990).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-119

3.15.2 Environmental Consequences

3.15.2.1 Scoping Comments on Resource

The following issues specific to cultural resources were identified during the public scoping 

period:

 How would cultural resources be affected by geothermal leasing? 

 How would these impacts be managed?

3.15.2.2 How Resource Impacts Were Evaluated

A consent to leasing and leasing decisions do not grant any rights or authorize any activities 

affecting cultural resources. The impact analysis focuses on the potential future actions and 

disturbance estimates, based on the RFDS, and the implementation of the alternatives described

in Chapter 2. In all cases, before any ground disturbance or other future actions, further 

decision-making would be required, including cultural resource compliance.

Methods

PaleoWest (2016) reviewed cultural resource baseline information for an understanding of 

known resources and to determine the condition of the resources. Also, it considered all laws 

pertinent to determining the impacts on cultural resources and included them in criteria for 

determining impacts. Known resources and an informed estimation of site density in unsurveyed 

areas was overlain with the actions found under each alternative in Chapter 2. Conclusions were 

drawn, based on an understanding of how these types of actions may affect the known and 

potentially discoverable resources (PaleoWest 2016). 

Based on ongoing consultation with contemporary pueblo, tribal, and Hispanic groups, the SFNF 

used a qualitative assessment of the potential for impacts on sites, landscapes, and other 

resources that may be important to those groups for traditional or religious uses (Forest Service

2016g). 

Indicators

Potential impacts on cultural resources could occur if anticipated future actions, consistent with 

implementing the alternatives described in Chapter 2, were to have any of the following 

impacts: 

 Conflict with Forest Service goals and objectives to inventory, protect, evaluate, nominate to 

the NRHP, interpret, and enhance cultural resources

 Result in uses that are incompatible or that interfere with maintaining cultural resources and 

their qualities or traditional cultural properties, practices, and uses

 Result in an adverse impact on historic properties under Section 106 of the NHPA

Impacts on cultural resources occur when there is damage or loss of cultural resources or their 

settings. Impacts on cultural resources are assessed by applying the NHPA criteria of adverse 

impact, as defined in the implementing regulations for Section 106 of the NHPA (36 CFR, Part 

800). 

An adverse impact is found when an action may alter the characteristics of a historic property 

that qualify it for inclusion on the NRHP, in a manner that would diminish the integrity of the 

property’s location, design, setting, workmanship, feeling, or association. Adverse impacts may 
Chapter 3. Affected Environment and Environmental Consequences

3-120 Santa Fe National Forest Geothermal Leasing EIS

include reasonably foreseeable impacts caused by the action that may occur later in time, be 

farther removed in distance, or be cumulative (36 CFR, Subpart 800.5). 

Additionally, focused consultation with the affected group is required to assess impacts involving 

contemporary pueblo, tribal, or other traditional community’s cultural or religious practices, 

resources, or areas. Impact analysis would be informed by ongoing consultation with groups 

with interests in the SFNF and focused consultation for subsequent actions and decisions (Forest 

Service 2016g). 

For the purposes of this analysis, indicators for determining impacts on cultural resources are to 

ask if the action would have any of the following impacts:

 Cause physical destruction or damage to all or part of the property

 Alter a property in a manner that is not consistent with the Secretary of the Interior’s 

standards for the treatment of historic properties (36 CFR, Part 68) and applicable guidelines

 Remove the property from its historic location

 Change the character of the property’s use or physical features in its setting that contribute to 

its historic significance, such as isolating the property from its setting

 Introduce visual, atmospheric, or audible elements that diminish the integrity of the 

property’s significant historic features

 Neglect a property, which causes its deterioration, except where such neglect and 

deterioration are recognized qualities of a property of religious and cultural significance to 

an Indian tribe

 Disturb any human remains, including those interred outside of formal cemeteries

Under the NHPA, any of the above indicators would contribute to an adverse impact on a 

cultural resource if it were listed on or eligible for listing on the NRHP, or if it were an area of 

importance to Native American tribes, pueblos, or other traditional communities.

Impacts can be direct or indirect. In practice, a direct impact would be limited to the direct 

physical disturbance of a historic property, such as destroying the property for facility or access 

construction. Indirect impacts would be visual or audible intrusion as a result of the project being 

built or the increased risk of looting as a result of better access and increased visitation to the 

area.

Impacts on cultural resources are typically considered permanent, as they are finite, and any 

disturbance, particularly of archaeological sites, cannot be reversed. However, impacts on the 

historic landscape or the viewsheds of historic or other culturally significant areas can be 

temporary, if projects do not permanently impact associated resources and are removed at a 

future date.

Adverse impacts can be resolved or reduced through avoidance and other measures that the 

applicant would implement, in coordination with the Forest Service and the BLM. 

Assumptions

This analysis assumes the following:

 There would be no findings of adverse impact from any of the alternatives, because consent 

to leasing would not disturb the ground. Future geothermal development phases would be 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-121

subject to additional analyses under NEPA and the NHPA, and adverse impacts from such 

actions would be identified at that time.

 Cultural resource protection and avoidance measures apply to all proposed federal or 

federally assisted undertakings by the Forest Service and to leases granted by the BLM. 

 Several decision stages would occur before any ground-disturbing activities and would 

include further compliance with applicable authorities. If leasing were approved, the Forest 

Service and the BLM would complete steps to meet cultural resource legal and procedural 

requirements before development begins, as outlined in the Section 106 process and the 

Region 3 Programmatic Agreement (Forest Service 2003). These include consultation with 

the New Mexico State Historic Preservation Office (SHPO) and Native American tribes, 

pueblos, or other traditional communities. 

 The number of sites that could be affected by actions correlates with the degree, nature, 

depth, and quantity of surface-disturbing activities in the project area and the cultural 

sensitivity of the area.

 The information on cultural resources in the project area is based on the results of industry 

and Forest Service inventory projects and depicts the relative potential for cultural resource 

sites. However, these data are geographically biased toward past project-oriented 

undertakings and cannot accurately predict where and how many resources may exist in

unsurveyed areas. 

 Likewise the presence and significance of sites, landscapes, and other resources that may be 

important to contemporary pueblo, tribal, and Hispanic groups for traditional or religious 

uses may not be readily identifiable outside of those communities. 

 Cultural resource inventories, either federal undertakings or related programs, would result 

in the continued identification of cultural resources. The cultural resource data acquired 

through these inventories and evaluations would increase overall knowledge and 

understanding of the distribution of cultural resources in the region.

3.15.2.3 Common Impacts Associated with Geothermal Development

The nature and characteristics of the direct and indirect impacts on cultural resources from 

geothermal development under the decisions common to Alternatives 2, 3, and 4 would be the 

same as those described in the 2008 Geothermal PEIS (BLM and Forest Service 2008, pp. 4-106 

to 4-108) is incorporated by reference and summarized here. The PEIS describes common 

impacts on cultural resources associated with exploration, drilling, utilization, reclamation, and 

abandonment. 

Any activities that would involve surface-disturbing activities would have direct and indirect 

impacts on cultural resources, including damaging, destroying, or displacing artifacts and 

features and building modern features out of character with a historic setting. Damaging, 

displacing, or destroying cultural resources could include removing artifacts from their 

situational context, breaking artifacts, or shifting, obliterating, or excavating features without 

appropriately recording them. 

Indirect impacts on cultural resources would include changing the character of a property’s use 

or physical features in its setting that contribute to its historic significance (such as isolating the 

property from its setting) and introducing visual, atmospheric, or audible elements that diminish 

the integrity of its historic features. The geothermal plants, well pads, and associated facilities 

would be modern features in a landscape that did not have them previously, thereby juxtaposing 

modern industrial features onto a historic landscape. Additionally, with the increased human 
Chapter 3. Affected Environment and Environmental Consequences

3-122 Santa Fe National Forest Geothermal Leasing EIS

presence of site workers during all phases of geothermal development, there is the risk of illicit 

collection of surface artifacts, resulting in a loss of scientific information.

The potential for undiscovered buried cultural resources and human remains exists, despite 

previous archaeological surveys and investigations. Surface-disturbing activities would directly 

impact undiscovered cultural resources and human remains by exposing buried material, 

resulting in inadvertent artifact destruction or loss of scientific context. Indirect impacts could 

result from the increased presence of site workers, leading to possible illicit collection of newly 

exposed materials.

Final reclamation of geothermal developments would eliminate the indirect viewshed or setting 

impacts for cultural resources. With reclamation, the natural and historic setting would be 

restored. Similar to impacts during earlier phases, the potential for undiscovered buried cultural 

materials or human remains continues to exist through reclamation and abandonment. 

Abandonment may expose buried materials, resulting in inadvertent artifact destruction or loss of 

scientific context; additionally, the increased presence of site employees may lead to illicit 

collection of exposed materials.

3.15.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. The level of anticipated geothermal leasing and development is 

assumed to be consistent with the RFDS. If geothermal lease applications and nominations are 

received, they would be processed and evaluated on a case-by-case basis under separate NEPA

and NHPA analyses, in accordance with the Forest Plan and existing laws and regulations. 

Potential direct and indirect impacts from subsequent geothermal development phases would be 

the same as those described for Common Impacts Associated with Geothermal Development.

Because there would be site-specific analysis, potential impacts on cultural resources and their 

settings could be avoided or reduced, but there would be no additional established stipulations 

for surface use that may incidentally reduce impact potential on cultural resources. The JNRA is 

excluded from geothermal leasing on the basis of existing laws, regulations, and executive 

orders. There would continue to be no leasing in the JNRA and thus no impacts on cultural 

resources from subsequent geothermal development phases. 

3.15.2.5 Impacts Under Alternative 2

Under Alternative 2, the SFNF would identify lands as being closed to geothermal leasing under 

either nondiscretionary or discretionary authorities, or open to geothermal leasing, with TL, 

CSU, and NSO stipulations. Compared with Alternative 1, Alternative 2 provides standard 

stipulations and consideration for resource protection and other uses for the project area for 

geothermal leasing, consistent with forest goals and objectives. There would still be site-specific 

consideration of impacts on cultural resources and their settings for each phase of geothermal 

development. 

Alternative 2 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, traditional cultural properties, sacred sites, and 

NRHP-eligible and listed properties. Because of this, the potential for impact on cultural 

resources from subsequent geothermal development would be reduced. Additional established 

stipulations for other surface uses may incidentally reduce the impact potential on cultural 

resources. There are 1,567 known sites that would be included in land with NSO stipulations 

under Alternative 2. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-123

3.15.2.6 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Because there 

would be no leasing and no subsequent development, there would be no impacts on cultural 

resources and their settings. 

3.15.2.7 Impacts Under Alternative 4

Under Alternative 4, the SFNF would not identify lands as being closed to geothermal leasing

under discretionary authorities. Lands would be identified as open to geothermal leasing with 

TL, CSU, and NSO stipulations. Compared with Alternative 1, Alternative 4 provides standard 

stipulations and consideration for resource protection and other uses for the project area for 

geothermal leasing, consistent with forest goals and objectives. There would still be site-specific 

consideration of impacts on cultural resources and their settings for each phase of geothermal 

development. 

Alternative 4 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, traditional cultural properties, sacred sites, NRHPeligible and listed properties. Because of this, the potential for impacts on cultural resources 

from geothermal development would be reduced. Additional established stipulations for other 

surface uses may incidentally reduce the impact potential on cultural resources. There are 1,522 

known sites that would be included in land with NSO stipulations under Alternative 4.

3.15.2.8 Cumulative Impacts

Cumulative impacts on cultural resource are analyzed at the landscape scale for the project area. 

Past, present, and reasonably foreseeable future actions are those that would increase surface 

disturbance in the project area, potentially affecting cultural resources. These are the following:

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam

 South Pit Pumice Mine Expansion

 Duran 2010 Pumice Mine

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project

 New Mexico Meadow Jumping Mouse Critical Habitat Protection Project

Those that are in the project area have now or will have cultural resource compliance actions 

through the Section 106 process and the Region 3 Programmatic Agreement. These would seek 

to avoid or reduce the potential for adverse impacts on cultural resources. The full RFDS under 

Alternatives 1, 2, and 4 may impact cultural resources and their settings, but impacts would be 

reduced through the Section 106 process and the stipulations that would be implemented. The 

contributions to direct cumulative impacts would be minor, relative to the project area, although, 

depending on siting, the indirect impacts on setting and cultural landscapes may be moderate. 

There would be no contributions to cumulative impacts under Alternative 3.
Chapter 3. Affected Environment and Environmental Consequences

3-124 Santa Fe National Forest Geothermal Leasing EIS

3.16 Tribal Interests and Traditional Cultural Resources

Tribal interests include economic rights, such as Indian trust assets, and resource uses and access 

guaranteed by treaty, agreements, or legislation. Traditional cultural resources include areas of 

cultural importance to contemporary communities, such as sacred sites or resource gathering 

areas. 

As discussed in Section 3.15, Cultural Resources, places that are important in maintaining 

community traditions or culturally important activities can also be recognized as eligible for 

listing on the NRHP as traditional cultural properties. 

While most commonly considered in the context of Native American tribes and pueblos, there 

are traditional cultural resources associated with other ethnic or socially linked groups in the 

Jemez Mountains and project area, such as Hispanic land grants and communities. Although the 

SFNF does not have decision concurrence authority over leasing on Indian reservations, there are 

tribal and other traditional uses of Forest Service lands that could be impacted from subsequent 

phases of geothermal exploration, drilling operations, utilization, and reclamation and 

abandonment. Adjacent or nearby reservation land and land grants may also be impacted by 

these actions. When planning any proposed project or action, the agencies must ensure that all 

anticipated impacts on Indian lands, trust resources, and treaty rights are addressed in the 

planning, decision, and operational documents prepared for each project. Federal agencies must 

ensure that meaningful consultation and coordination are conducted on a government-togovernment basis with federally recognized tribes.

The trust responsibility is the US government’s permanent legal obligation to exercise statutory 

and other legal authorities to protect tribal lands, assets, resources, and treaty rights, as well as a 

duty to carry out the mandates of federal law with respect to Native American tribes. Treaties are 

negotiated contracts made pursuant to the US Constitution and take precedence over any 

conflicting state laws because of the Constitution’s supremacy clause (Article 6, Clause 2). 

Other sources of defined reciprocal rights and obligations assumed by the federal government 

and Indian tribes are congressional and executive branch actions to acquire or repatriate Indian 

lands, establish reservations, provide federal recognition of tribes, and remove Indian peoples to 

reservations. 

Communities often view these rights and resource uses as interconnected with culture, tradition, 

and spiritual practice. Among many groups, land, water, geologic features, landscapes, and other 

seemingly inanimate objects are considered sacred. Examples of traditional cultural resources are

natural landscape features, ceremonial and worship places, plant gathering locations, traditional 

hunting and fishing locations, ancestral archaeological sites, artisan material locations, rock art,

and communal resources, such as community-maintained irrigation systems. 

While many traditional cultural resources are known, many locations or resources may be 

privileged information that is restricted to specific practitioners or clans. For tribes, maintaining 

confidentiality and customs regarding traditional knowledge may take precedence over 

identifying and evaluating these resources, unless they are in imminent danger of damage or 

destruction. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-125

3.16.1 Affected Environment

3.16.1.1 Overview

Native American occupation and use of the lands of the Jemez Mountains for thousands of years 

is well documented in the archaeological record and by oral traditions. Patterns of occupation 

and use changed through time, ranging from small, highly mobile bands following the seasons 

and resources to small and large permanent and semipermanent communities, defensive sites,

and agricultural fields (PaleoWest 2016). During the Spanish contact and early colonization 

period (1540-1610), the vast majority of puebloan villages were located near the junction of the 

Rio Grande and Rio Chama, along the Rio Grande, and along the Jemez River. Still, artifacts and 

faunal and botanical data clearly show that the mountains continued to be visited for hunting, 

gathering, raw material procurement, and field house-based high altitude farming. 

Spanish colonization of New Mexico brought the alien concept of landownership to the pueblo 

world that was in conflict with native concepts of movement across the land, seasonal lowlandupland migrations, and religious associations with landscape and water features. 

From 1609 to 1680, the Spaniards developed New Mexico through a system of religious 

missions, military presidios, the feudal system of encomiendas, and agricultural land grants. In 

theory, the Spanish Crown issued patents or grants for lands to native communities, which 

colonial officials were then charged with protecting from adverse activities by Hispano settlers. 

The problem of settler encroachment on Indian fields, disenfranchisement of native lands, and 

abuse by colonists was a universal one under Spanish and later Mexican rule. Mexico honored 

the land grants already established by the Spanish Crown for both pueblo people and Hispanic 

settlers, but it also created a system for establishing new immigrant settlements of Europeans and 

Americans who would become Mexican citizens. Those outside influences and new trade 

through the Santa Fe Trail caused more American occupation of Mexican territory, leading to the 

US-Mexican War of 1846-1848.

The war ended with the Treaty of Guadalupe Hidalgo. The treaty also affirmed established land 

grants, but in practice it failed in most cases to protect them. Some land grants have been 

incorporated into the SFNF. There is a long subsequent history of congressional and Executive 

Branch actions and litigation regarding land grants, reservation boundaries, sovereignty, and 

tribal rights that continue to the present (Forest Service 2016g). 

3.16.1.2 Resources

The SFNF regularly consults on a government-to-government basis with federally recognized 

tribes and engages with communities on the impacts of their actions and programs. In support of 

this EIS and Southwest Jemez Mountains Landscape Restoration Project, the SFNF consulted 

with descendants of Native American and Hispanic land grant recipients, who had occupied 

portions of the Jemez Mountains and adjacent areas prehistorically and historically and 

maintained traditional cultural resources and practices associated with those resources. 

The Forest Service contracted an ethnographic overview and assessment of traditional and 

current land uses by Native American and other communities. The intent is to identify traditional 

uses across the Jemez Mountains at the landscape level, but not to single out specific locations or 

traditional cultural resources, unless their significance to landscape-scale planning is appropriate 

and necessary. A general review of this outreach and results is provided in a public summary 

(Forest Service 2016g).
Chapter 3. Affected Environment and Environmental Consequences

3-126 Santa Fe National Forest Geothermal Leasing EIS

The SFNF determined the following Native American communities could be directly affected by 

future projects either because they are adjacent to Forest lands or have long-term documented 

intensive use of the Jemez Mountains: Pueblo of Jemez, Pueblo of Zia, Pueblo of Santo 

Domingo (Kewa), Pueblo of Santa Ana, Pueblo of Cochití, Pueblo of Ohkay Owingeh, Pueblo of 

Santa Clara, Pueblo de San Ildefonso, Pueblo of Nambé, Pueblo of Pojoaque, Pueblo of Tesuque, 

Pueblo of San Felipe, Jicarilla Apache Tribe, and the Navajo Nation. It is understood that many

other tribes have had associations with the Jemez Mountains, either through inter-tribal 

relationships or more sporadic occupation of lands or resource use. 

Land grants recognized as units of government include the Abiquiu Land Grant and the San 

Joaquin del Rio de Chama Grant. Land grants incorporated into the SFNF include the Polvadera 

Grant, Juan Jose Lobato Grant, Ojo de San Jose Grant, Cañon de San Diego Grant, and Baca 

Location No. 1 Grant. The ethnographic studies, interviews and consultation with these 

communities broadly identified traditional use areas, significant plant and animal resources, 

mineral resources, visual resources, and traditional community perspectives on direct and 

indirect impacts of geothermal leasing and landscape restoration on those resources. 

Ongoing consultation with representatives of pueblo and tribal groups indicated that the Jemez 

Mountains are important as a sacred place, as a sacred landscape, or as a historic landscape. 

Within the Jemez Mountains are subregions (based primarily on topography) that were discussed 

regarding specific concerns. Many landforms and locations have defined place names and are 

described in the oral traditions of the pueblo and Hispanic people. Areas of concern relate to high 

peaks that may contain shrines and campsites near the shrines, trails for access and ceremonies 

that extend variously through the Jemez Mountains or within these sub-regions, high areas, such 

as alpine meadows for plant collecting, ancestral sites and cultural resources, and springs that 

provide water for ceremonies, consumption, and supply water for grazing allotments and 

farming. General areas of concern as traditional use areas are known, but specific locations of 

traditional cultural resources, plant gathering areas, and other important locations are not 

revealed. 

Continued forest management practices were encouraged to attain healthy, stable forest 

environments, but practices should include sensitive consideration of the cultural heritage 

associations and traditional uses of the areas by those who were consulted and those who choose 

to not discuss their particular interests or resources. Groups fear that geothermal energy 

development will have devastating impacts on the area, including impacting the availability of 

water resources and the quality of water and effects on other resources that are important for

their heritage and ceremonies. 

In general, the representatives of the groups interviewed were not in favor of geothermal energy 

development, or they expressed concerns about the impacts on water quality and availability. 

Native American and Hispanic groups are also interested in recovering ownership of lands that 

were part of their original land base and, therefore, would be concerned about committing lands 

to other uses. 

The All Pueblos Council of Governors adopted a resolution on August 10, 2015, unanimously

supporting closing the forest to geothermal leasing. The resolution called on the SFNF to restrict 

all access in the Jemez Mountains and Santa Fe National Forest to proposals from the 

geothermal and energy and minerals industry and expressed the Council’s support for the 

designation of the Jemez Mountains as a traditional cultural property. The resolution requests 

that meetings be held to inform and consult with pueblo leadership regarding this proposal (All 

Pueblo Council of Governors 2015). 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-127

3.16.2 Environmental Consequences

3.16.2.1 Scoping Comments on Resource

The following issues specific to tribal interests and traditional cultural resources were identified 

during the public scoping period:

 How would traditional cultural properties and tribal interests be affected by geothermal 

leasing, including those in confidential locations, and how would those impacts be managed? 

What are the direct, indirect, and cumulative impacts of other resource impacts on tribal 

interests?

Method

Consent to leasing and leasing decisions do not grant any rights or authorize any activities that 

would directly affect tribal interests and traditional cultural resources. However, issuing 

geothermal leases confers on the lessee a right to future exploration and development of 

geothermal resources in the lease area. Thus, it is a conditional commitment or granting of a 

right that may interfere with other uses or interests, such as land-into-trust applications by tribes 

or acquisition of ancestral land base or resources. 

The impact analysis focuses on the potential future actions and potential for direct impacts or 

disturbances, based on the RFDS and the implementation of the alternatives described in Chapter 

2. In all cases, before any ground disturbance or other future actions, further decision-making 

would be required. Examples are NEPA, NHPA compliance, and meaningful consultation and 

coordination with affected communities, on a government-to-government basis, with federally 

recognized tribes and pueblos.

As described above, the SFNF regularly consults with Native American groups and other 

traditional communities on its activities and is conducting a landscape-scale study of past and 

present uses of the Jemez Mountains in support of this EIS and other actions. This work for each 

of the tribal groups and land grants includes ethnographic archival research and interviews to 

define and provide a more holistic understanding of tribal interests and the range and variety of 

traditional cultural resources and uses of the Jemez Mountains. The identification is at an 

appropriate level for determining the impacts of leasing consent. Laws, regulations, and policies 

pertinent to determining impacts on tribal interests and resources were considered and included 

in the impact criteria. 

A qualitative assessment is used to assess the potential for impacts on sites, landscapes, and other 

resources that may be important to contemporary pueblo, tribal, and Hispanic groups for 

traditional or religious uses, based on ongoing consultation with these groups. Locally sensitive 

areas and resources may be known from previous consultation and resource identification efforts. 

However, affected groups may not wish to enter into direct consultation or may prefer not to 

discuss specific traditional use areas or sacred sites until development plans are proposed and 

there is a perception that interests or resources would be threatened.

Indicators

Potential impacts on tribal interests or traditional and heritage resources could occur if 

anticipated future actions consistent with implementing the alternatives were to result in the 

following:
Chapter 3. Affected Environment and Environmental Consequences

3-128 Santa Fe National Forest Geothermal Leasing EIS

 Conflict with land uses, management, and economic well being of adjacent or nearby 

reservations, trust lands, restricted Indian allotments, and tribal-dependent Indian 

communities

 Conflict with the exercising of off-reservation treaty and reserved rights and agreements,

including grazing rights, hunting and fishing rights, gathering rights and interests, and water 

rights

 Conflict with federal trust responsibilities to tribes and pueblos regarding real property, 

physical assets, or intangible property rights

 Conflict with existing court decisions, laws, policies, executive orders, and agency 

agreements with tribes and land grant communities regarding land and resource use

 Result in proposed uses that are incompatible with maintaining and identifying cultural 

resources and their qualities

 Have an adverse impact on traditional cultural properties and cultural landscapes under 

Section 106 of the NHPA (36 CFR, Part 800)

 Impact or restrict access to traditionally used hunting, fishing, and gathering areas and 

species

 Change or reduce access to traditionally used or culturally important water sources and hot 

springs

 Impact culturally important trails or trail systems

 Impact sacred sites or their settings, access, or use

Assumptions

This analysis assumes the following:

 Areas proposed for leasing would likely include lands and specific locations where there are 

tribal interests and traditional cultural resources that are not currently identified.

 The SFNF would continue to coordinate and consult with pueblo, tribal, and affected 

communities to identify issues and concerns during all phases of geothermal leasing and 

development.

 Some Native American groups and land grant communities may be interested in recovering 

ownership of lands or specific resource locations that were part of their original land base 

and, therefore, would be concerned about committing lands to other uses.

 The Jemez Mountains has been characterized as a sacred place, as a sacred landscape, or as a 

historic landscape. Disturbing the land or using geothermal resources may be considered an 

adverse impact that could not be avoided or minimized.

 There may be unidentified conflicts with existing rights or claims of ownership related to hot 

springs and water sources.

3.16.2.2 Common Impacts Associated with Geothermal Development

The nature and characteristics of the impacts on tribal interests and traditional cultural resources 

and uses associated with geothermal development as a result of the decisions common to all 

action alternatives would be the similar to those described in the 2008 Geothermal PEIS (BLM 

and Forest Service 2008, pp. 4-114 to 4-117). This is incorporated by reference and summarized 

here. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-129

The PEIS describes common impacts on tribal interests and traditional cultural resources and 

uses associated with exploration, drilling operations, utilization, and reclamation and 

abandonment.

Types of impacts that could occur from exploration, drilling operations, utilization, and 

reclamation and abandonment are direct disturbance of locations or landscapes associated with 

traditional beliefs, resource gathering areas, hunting and fishing areas, water sources, hot 

springs, ancestral sites, human remains, and trails. Other impacts could result from alterations of 

visual and aural aspects of the cultural landscape’s setting, both on the lease site and in adjacent 

areas; increased access and site workers, which could lead to increased incidents of vandalism

and unauthorized collection of ancestral sites; decreased tribal member access or interference 

with the exercise of rights or cultural uses and practices, such as resource gathering or hunting; 

and the potential for erosion, pollution, habitat loss, and less tangible changes to natural features

and resources that tribal members may consider sacred. 

Exploration, drilling operations, and utilization in or around hot spring sources may impact 

traditional resources and could impact other tribal interests. Impacts could include loss of access, 

interference with use, and changes to hot springs. Since the thermal water in these springs may 

be considered sacred, there is a potential for loss of sacred sites and the healing energy and 

power they provide to the tribal users who value them. 

While visual and aural settings and some habitats may be restored, it is unlikely that some 

cultural or sacred uses could be restored. 

3.16.2.3 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. The level of anticipated geothermal leasing and development is 

assumed to be consistent with the RFDS. If geothermal lease applications and nominations are 

received, they would be processed and evaluated on a case-by-case basis under separate NEPA

and NHPA analyses, in accordance with the Forest Plan and existing laws and regulations. 

Potential direct and indirect impacts from subsequent geothermal development phases would be 

the same as those described for common impacts associated with geothermal development.

Because there would be site-specific analysis and consultation, potential impacts could be 

avoided or reduced, but there would be no additional established stipulations for surface use that 

may incidentally reduce impact potential on tribal interests and traditional cultural resources and 

uses. 

Tribes may consider disturbance of the land or use of geothermal resources as an adverse impact

that could not be avoided or minimized. The JNRA is excluded from geothermal leasing on the 

basis of existing laws, regulations, and executive orders. There would continue to be no leasing 

in the JNRA and thus no impacts anticipated from subsequent geothermal development phases.

3.16.2.4 Impacts Under Alternative 2

Under Alternative 2, the SFNF would identify lands as being closed to geothermal leasing under 

either nondiscretionary or discretionary authorities or open to geothermal leasing with TLs and 

CSU stipulations and NSO stipulations. Compared with Alternative 1, Alternative 2 provides 

standard stipulations and consideration for resource protection and other uses for the project area 

for geothermal leasing, consistent with forest goals and objectives. There would be NSO 

stipulations for traditional cultural properties and Native American sacred sites, as identified 

through consultation. There would still be site-specific consideration of impacts on tribal 
Chapter 3. Affected Environment and Environmental Consequences

3-130 Santa Fe National Forest Geothermal Leasing EIS

interests and traditional cultural resources and uses and their settings for each phase of 

geothermal development. 

Because Alternative 2 includes NSO stipulations for areas with important cultural resources and 

their settings (archaeological resources, traditional cultural properties, sacred sites, and NRHPeligible and listed properties), the potential for impact from subsequent geothermal development

would be reduced. Tribes may consider disturbance of the land or use of geothermal resources as 

an adverse impact that could not be avoided or minimized. Additional established stipulations for 

other surface uses (i.e., habitat and visual protections) may incidentally reduce the impact 

potential on traditional cultural resources, cultural landscapes, and their settings.

3.16.2.5 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Because there 

would be no leasing and no subsequent development, no new impacts are anticipated. 

3.16.2.6 Impacts Under Alternative 4

Under Alternative 4, the SFNF would not identify lands as being closed to geothermal leasing

under discretionary authorities. Lands would be identified as open to geothermal leasing with 

TLs and CSU stipulations and NSO stipulations. Compared with Alternative 1, Alternative 4 

provides standard stipulations and consideration for resource protection and other uses for the 

project area for geothermal leasing, consistent with forest goals and objectives. There would be 

NSO stipulations for traditional cultural properties and Native American sacred sites, as 

identified through consultation. There would still be site-specific consideration of impacts and 

consultation for each phase of geothermal development. 

Alternative 4 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, traditional cultural properties, sacred sites, NRHPeligible and listed properties. Because of this, the potential for impact on cultural resources from 

subsequent geothermal development would be reduced. Tribes may consider disturbance of the 

land or use of geothermal resources as an adverse impact that could not be avoided or 

minimized. Additional established stipulations for other surface uses (i.e., habitat and visual 

protections) may incidentally reduce the impact potential on traditional cultural resources, 

cultural landscapes, and their settings. 

3.16.2.7 Cumulative Impacts

Cumulative impacts on tribal interests and traditional cultural resources and uses are analyzed at 

the landscape scale for the project area. Past, present, and reasonably foreseeable future actions 

include those that would increase surface disturbance in the project area, potentially affecting 

cultural resources. These include Pueblo of Jemez Red Rocks Dam Repair, the Abiquiu Land 

Grant Waterline Replacement, the McKinney County Dam, South Pit Pumice Mine Expansion, 

the Duran 2010 Pumice Mine, the Southwest Jemez Mountains Restoration Project, the Cerro 

Pelon Timber Stand and Wildlife Habitat Improvement Project, Pueblo of Jemez Owl Springs 

Bridge Sediment Removal Project, and the New Mexico Meadow Jumping Mouse Critical 

Habitat Protection Project. 

Each of these that is in the project area has or will have cultural resource compliance actions and 

site-specific consultation, which would seek to identify tribal interests and traditional cultural 

resources and avoid or reduce the potential for adverse impacts. Tribes may consider disturbance 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-131

of the land or use of geothermal resources as an adverse impact that could not be avoided or 

minimized. The full RFDS under Alternatives 1, 2, and 4 may impact traditional cultural 

resources and their settings, but impacts would be reduced through the Section 106 process and 

the stipulations that would be implemented. The contributions to direct cumulative impacts 

would be minor to major, relative to the project area. This would depend on the perspective of 

consulting parties on the impacts on tribal interests and traditional cultural resources. There 

would be no contributions to cumulative impacts from Alternative 3.

3.17 Visual Resources

3.17.1 Affected Environment

The landscape in the decision area is characterized primarily by montane woodlands and 

meadows, but also includes canyons and rock outcrops in the southwest portion of the decision 

area near Jemez Springs and surrounding areas. Elevation ranges from about 6,300 feet to 10,000 

feet.

The Forest Service manages visual resources according to the Scenery Management System. The 

Scenery Management System is described in the IRAs report for this project (Forest Service 

2016a).

Table 3-18 and Figure 3-3, Scenic Integrity, shows the acres of lands in the decision area by 

each scenic integrity degree.

Table 3-18. Scenic Integrity

Scenic Integrity Acres

Very High 3,700

High 93,000

Moderate 67,800

Low 3,800

Very Low 300

Source: Forest Service GIS 2015

3.17.1.1 Night Skies

The Forest Service does not manage lands specifically for preserving dark night skies. However, 

lands adjacent to the project area are managed by the NPS, and the NPS is mandated to preserve, 

to the greatest extent possible, the natural lightscapes of the parks, which are natural resources 

and values that exist in the absence of human-caused light (NPS 2006b). Therefore, the affected 

environment for night skies adjacent to the project area is discussed below in order to provide a 

comprehensive cumulative analysis.

The natural lightscape plays a role in natural resource processes and affects biological behavior, 

as well as being a feature that contributes to visitor experience. The VCNP’s high elevation, 

excellent air quality, low population density, and frequent cloud-free weather afford world-class 

viewing and enjoyment of naturally dark, star-filled skies. The unfettered view of the Milky Way, 

planets, meteors, and galaxies is increasingly becoming a major reason for many to visit the 

park. 

Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-133

Although night sky measurements have not yet been made at VCNP, they have been made at a 

nearby Bandelier National Monument fire tower, located approximately 6 miles east of the 

project area boundary. Light is evaluated through Lux. Lux is the unit of light measurement 

taking area into consideration (i.e., light intensity). Table 3-19, Examples of Lux Measurements 

on a Given Surface, provides examples of lux pertaining to different origins of light illuminated 

on a surface. Measurements at the Bandelier National Monument fire tower in 2005 identified a 

maximum vertical illuminance of 1.11 millilux with an estimated artificial contribution of 0.44 

millilux. Measurements in 2006 identified a maximum vertical illuminance of 1.24 millilux with 

an estimated artificial contribution of 0.73 millilux (NPS 2005; 2006c). 

Table 3-19. Examples of Lux Measurements on a Given Surface

Illuminance Surfaces illuminated by:

0.0001 lux Moonless, overcast night sky (starlight)

0.0014 lux Venus at brightest

0.002 lux Moonless clear night sky with airglow

0.1 lux Quarter moon

0.27–1.0 lux Full moon on a clear night

3.4 lux Dark limit of civil twilight under a clear sky

Source: Schlyter 2006; Bunning and Ilse 1968

Dark sky conditions in the project area and the adjacent VCNP are likely to be similar to those 

recorded at the Bandelier National Monument fire tower. However, because factors that 

influence dark skies (e.g., distance populated areas, elevation, topography, and other sources of 

human-caused light), vary between the location of recorded measurements and the project area, 

overall maximum vertical illuminance and estimate artificial illuminance values may not be 

identical.

3.17.1.2 Adjacent Landscapes

Landscapes adjacent to the project area include undisturbed natural settings consisting of forest 

cover, volcanic landforms, and other geologic features. The VCNP is located adjacent to the 

project area, and important visitor use areas in the VCNP include the caldera rim and Redondo 

Peak. The viewshed from the caldera rim and Redondo Peak (for objects up to 35 meters in 

height) is shown in Figure 3-4, Redondo Peak and Caldera Rim Viewsheds. This viewshed 

covers approximately 119,300 acres (61 percent) in the project area, including lands not 

managed by the Forest Service. 

3.17.2 Environmental Consequences

3.17.2.1 Scoping Comments on Resource

The following issues specific to visual resources were identified during the public scoping 

period:

 What are the visual impacts associated with geothermal leasing, including construction of 

transmission lines and water vapor from geothermal plants?

Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-135

3.17.2.2 How Resource Impacts Were Evaluated

Method

The impact analysis for visual resources was based on review of existing baseline data for the 

project area as described under Affected Environment and information gathered through scoping. 

To the extent practical, spatial data were used to compare environmental conditions with the 

alternatives. Various actions that might create changes to the basic landscape elements were 

considered in identifying potential impacts. The region of influence for direct and indirect 

impacts is the decision area.

Indicators

Potential impacts on visual resources could occur if reasonably foreseeable future actions were 

to:

 Have impacts on a scenic vista;

 Degrade the existing visual character or quality of the site and its surroundings;

 Create a new source of light or glare; or

 Be incompatible with the scenic integrity.

Assumptions

Receptors sensitive to disturbances of visual resources are varied and depend on the landscape’s 

visual resources; the project’s location; the view distance, angle, and duration; the location of 

travel routes; public areas of interest; the season; the topography; recreation activities; and the 

number of viewers. Because of this, it is important to note that site-specific impact assessment is 

needed to thoroughly assess impacts on visual resources from a particular project. Without 

precise information about a specific project, it is not possible to detail the visual impacts. 

However, by using the RFDS as a general description of expected geothermal resource

development activities, a generalized assessment of the possible impacts on visual resources can 

be made by describing the range of expected visual changes.

The assumptions for this analysis are:

 Other visual impact mitigation measures would likely be required at the project-specific 

phase of analysis and permitting; 

 Scenic resources will remain in demand on public lands;

 Any new surface-disturbing geothermal activities would be subject to further NEPA analysis, 

which would include an analysis to determine consistency with applicable visual resource

objectives.

3.17.2.3 Common Impacts Associated with Geothermal Development

The common impacts associated with geothermal development are described in the Final 

Programmatic EIS for Geothermal Leasing in the Western United States (BLM and Forest 

Service 2008). Additional impacts associated with light pollution and dark skies are discussed 

below. 

Light pollution, defined as stray unwanted light outside the range and timing of natural variation, 

is not only an ecological disrupter, but also may affect the natural scenery of the night. 
Chapter 3. Affected Environment and Environmental Consequences

3-136 Santa Fe National Forest Geothermal Leasing EIS

Light pollution has been documented over 200 miles from the light source (Chespesiuk 2009). 

The cumulative effect of multiple artificial light sources at varying distance brightens the sky 

background, drowning out stars and astronomical objects by contrast reduction, and increasing 

the luminance of the ground surface. Particularly dark night skies are most prone to a 

degradation of their scenic potential, showing a large reduction in the number of visible stars 

with a small amount of light pollution. Night skies already brightened by artificial light show a 

lessening degradation with each incremental increase in light pollution. Within this response 

function may be embedded thresholds whereupon certain species, ecological processes, or key 

scenic resources would be affected (Longcore and Rich 2004).

The degree of impact of artificial light is highly dependent on the distance and the type and 

brightness of the light fixture. Atmospheric characteristics such as humidity and particulates 

further influence the apparent effect of artificial light. Whether the light fixture is fully shielded 

is also important; fully shielded fixtures can greatly decrease the creation of both point and 

diffuse source light pollution (Falchi et al. 2011). The perception of light pollution would vary 

from one location to another caused by differences in vegetation cover, sight lines and horizon 

visibility, and even the color of the ground. Atmosphere of greater clarity tends to amplify distant 

light sources and attenuate nearby light sources, while more humid and polluted air tends to 

amplify close light sources.

While there is a canopy layer of vegetation in most of the project area and adjacent NPS lands, 

subsequent geothermal development could increase the amount of artificial lighting and could 

increase the potential for skyglow into adjacent landscapes such as the VCNP. This is especially 

true for the horizon, the part of the sky in which lightscape impacts are first noted. Air quality

considerations can play a role in the context of lightscape impacts, because the presence of air 

pollution can increase light scattering. 

Distance is the most influential factor in determining skyglow, because the brightness of skyglow 

from a given light source decreases six times for every doubling of distance (point light sources 

decrease four times for every doubling of distance). The distance for lighting on a drill rig to 

diminish to the level equivalent to a clear moonless night with airglow on a surface—or 0.002 

lux—is approximately 10,000 feet, or two miles14. 

Light measurement data collected in April 2016 from a drilling rig near Big Thicket National 

Preserve, Texas, provided the basis for the extrapolation of collected data to define the distance 

of the affected environment. This survey data is representative of a typical drilling rig. Using this 

information, the strongest direction that light shined from the source was south with 1.3 lux at 

300 feet. Since this was the strongest light direction and the variability of the drill rig orientation 

can change on future well drilling projects, this direction was used to produce a radius that 

would show the largest distance light would travel from the source in any direction. The final 

distance light would need to travel to reach 0.002 lux is 10,000 feet in all directions, providing 

no obstructions. This distance does not take anthropogenic and natural barriers, such as walls and 

vegetation, which would drastically reduce this distance15.

 

14 Randy Stanley, Natural Sounds and Night Skies Coordinator, NPS, letter to Forest Service regarding 

night skies. April 28, 2016.

15 Randy Stanley, Natural Sounds and Night Skies Coordinator, NPS, letter to Forest Service regarding 

night skies. April 28, 2016.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-137

3.17.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area, except for nondiscretionary closures (i.e., the JNRA). Geothermal 

lease applications and nominations would continue to be processed; however, they would be 

evaluated on a case-by-case basis under separate NEPA analysis, in accordance with the Forest 

Plan and existing laws and regulations. 

The JNRA would remain closed to geothermal leasing. Visual resources would be protected in 

this area.

In the remainder of the decision area, visual resources could be impacted from subsequent 

geothermal exploration and development. It is likely that some form of mitigation would be 

required in areas of very high or high scenic integrity. In addition, due to the generally greater 

visual variety of the landscape in these areas, some development can be more easily hidden from 

view of the casual observer. In moderate, low, and very low scenic integrity areas, new 

development may not be as easily hidden. However, areas with existing development may be 

able to absorb new development without much change in the overall landscape. 

3.17.2.5 Impacts Under Alternative 2

The JNRA would remain closed to geothermal leasing. An additional 10,400 acres would also be 

closed to geothermal leasing. Visual resources would be protected in these areas.

In addition to areas closed to leasing, 132,900 acres would be subject to NSO stipulations. This 

would preclude surface occupancy in these areas and visual resources would be preserved in the 

same way that areas closed to leasing would be protected. This includes all lands of very high 

scenic integrity.

The remaining 3,700 acres not either closed or subject to NSO stipulations are in the Lease 

Interest Unit and North Unit. High scenic integrity landscapes in this area would be subject to 

CSU stipulations. This stipulation would not prohibit development in the area, but development 

would need to take into consideration scenic values. The CSU stipulation would require that 

visual quality objectives be met within 5 years from project startup, reducing impacts on visual 

resources in the long term. While few existing modifications are in high scenic integrity 

landscapes, these landscapes generally have diverse topography, colors, and vegetation features 

that can be used to screen development from sight of the casual observer. 

Few areas (1,400 acres) are not subject to any stipulations. Where this occurs, the scenic 

integrity is either moderate or low. This means that the landscape character is slightly or 

moderately altered. Often times these landscapes have less visual variety than areas with very 

high or high scenic integrity, making it more difficult to blend disturbances with the landscape, 

particularly where few are currently present. However, some level of disturbance that is 

noticeable to the casual observer is allowed in these areas.

3.17.2.6 Impacts Under Alternative 3

Under Alternative 3, no leasing would be permitted. There would be no impacts associated with 

geothermal development and the characteristic landscape would be retained.

3.17.2.7 Impacts Under Alternative 4

The JNRA would remain closed to geothermal leasing. Visual resources would be protected in 

this area.
Chapter 3. Affected Environment and Environmental Consequences

3-138 Santa Fe National Forest Geothermal Leasing EIS

In addition to the JNRA, 122,500 acres would be subject to NSO stipulations. None of the NSO 

is specifically to protect visual resources. However, visual resources would be incidentally 

protected. The impacts would be the same as described under Alternative 2.

The remaining 17,200 acres not either closed or subject to NSO stipulations are in the Lease 

Interest Unit and North Unit. Very high and high scenic integrity landscapes in this area would 

be subject to CSU stipulations. Impacts would be the same as described under Alternative 2.

Few areas are not subject to any stipulations. Where this occurs, the scenic integrity is either 

moderate or low. Impacts would be the same as under Alternative 2, but over a slightly larger 

area as there would be more acres not subject to stipulations under this alternative.

3.17.2.8 Cumulative Impacts

The region of influence for cumulative impacts is the viewshed of the decision area and adjacent 

landscapes.

Development of geothermal resources could result in cumulative impacts on visual resources

across the project area when combined with other projects. The heights, type, and color of 

drilling equipment and power plants, together with their placement with respect to local 

topography, are factors that would contribute to determining the extent of visual intrusion on the 

landscape. Also, the development of transmission lines to connect new electrical production 

facilities to the regional power grid could contribute to cumulative impacts. Stipulations for the 

protection of visual resources including areas with very high and high scenic integrity would 

minimize impacts on visual resources. 

Cumulative impacts on night skies and adjacent landscapes may occur. These impacts are 

described by alternative below.

Alternative 1

Night Skies

Under Alternative 1, geothermal exploration, drilling, and utilization as described in the RFDS

(BLM 2015) would result in new artificial light sources in the project area. These light sources 

would likely increase the artificial contribution of skyglow in the project area, and potentially 

adjacent landscapes such as the VCNP, as described under Common Impacts Associated with 

Geothermal Development. The quantitative increase in artificial illuminance for adjacent 

lightscapes would ultimately depend on factors such as topography, the distance to VCNP, and 

vegetation cover. Wells within 2 miles of the VCNP boundary would be most likely to increase 

the artificial contribution of skyglow in the VCNP.

Adjacent Landscapes

Geothermal development under Alternative 1 may occur in the Redondo Peak and caldera rim 

viewsheds. In general, visual impacts from well rigs would be short term, while visual impacts 

from powerplants, powerlines, and other utilization infrastructure would be long term. Impacts 

on adjacent landscapes would be evaluated on a case-by-case basis. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-139

Alternative 2

Night Skies

Cumulative impacts on night skies would be similar to those described under Alternative 1. 

However, discretionary leasing closures and stipulations would limit areas of potential 

development near the VCNP boundary, as shown in Table 3-20, below.

Table 3-20. Stipulations and Closures within a 1- and 2-mile Buffer of NPS Lands for Action 

Alternatives

Alternative 2 Alternative 3 Alternative 4

1 mile from NPS Lands

Decision Area Lands 23,700 23,700 23,700

Closed 9,500 23,700 8,300

NSO 14,200 0 13,800

CSU 8,900 0 13,700

TL 5,000 0 6,100

Open Subject to Standard 

Lease Terms and Conditions

0 0 100

2 miles from NPS Lands

Decision Area Lands 49,200 49,200 49,200

Closed 17,900 49,200 15,500

NSO 27,200 0 26,000

CSU 14,600 0 26,500

TL 9,300 0 11,600

Open Subject to Standard 

Lease Terms and Conditions

0 0 400

Source: Forest Service GIS 2015

Under Alternative 2, there would be no lands open to geothermal leasing, subject to standard 

lease terms and conditions, within a 2-mile buffer of NPS lands. Geothermal development could 

potentially occur within 2 miles of NPS lands, resulting in increased artificial lighting. However, 

implementing BMPs as described in Appendix C (such as topography and vegetation screening, 

and minimum lighting design) would reduce the likelihood of increasing skyglow in the project 

area and adjacent NPS lands. 

Adjacent Landscapes

Geothermal development under Alternative 2 could potentially occur in the viewshed of the 

caldera rim and Redondo Peak. However, geothermal leasing closures and stipulations would 

restrict where development could occur, as shown in Table 3-21, below.

Under Alternative 2, the majority of decision area lands in the viewshed would be closed to leasing 

or NSO. Approximately 1,100 acres in the viewshed would be open to leasing, subject to standard 

lease terms and conditions. Geothermal developments such as wells, power plants, and powerlines 

may be visible from the caldera rim, Redondo Peak, and other landscapes adjacent to the project 

area, which may detract from the visual character of these areas. However, implementing BMPs

described in Appendix C would minimize the potential impacts on adjacent landscapes.
Chapter 3. Affected Environment and Environmental Consequences

3-140 Santa Fe National Forest Geothermal Leasing EIS

Table 3-21. Viewshed Acres from the Caldera Rim and Redondo Peak by Action Alternative1

Alternative 2 Alternative 3 Alternative 4

Decision Area Lands 111,300 111,300 111,300

Closed 28,800 111,300 25,900

NSO 80,000 0 73,200

CSU 48,000 0 74,000

TL 26,900 0 29,500

Open Subject to 

Standard Lease Terms 

and Conditions

1,100 0 3,100

Source: Forest Service GIS 2015; NPS GIS 2016

1

for objects up to 35 meters in height

Alternative 3

There would be no cumulative impacts on visual resources under Alternative 3

Alternative 4

Night Skies

Cumulative impacts on night skies would be similar to those described under Alternative 2. 

However, because there would be more acres open to leasing, subject to standard terms and 

conditions (approximately 400 acres) within a 2-mile buffer of NPS lands, there would be a 

greater potential for development near the NPS boundary and, therefore, a greater potential for 

increased skyglow in these areas. Because the location of geothermal developments is unknown, 

the magnitude of impacts is unknown. 

Adjacent Landscapes

Impacts on adjacent landscapes would be similar to those described under Alternative 2. 

However, because there would be more acres open to leasing subject to standard lease terms and 

conditions (approximately 3,100 acres) within the viewshed of the Redondo Peak and the caldera 

rim, there would be an increased likelihood for development in this area and greater impacts. 

3.18 Social Interests, Economics and Environmental Justice

3.18.1 Affected Environment

The construction and operation of geothermal power plants contributes to local, state, and 

national economies by creating jobs, generating property taxes, paying revenues, and making 

voluntary contributions to communities. The use of NFS lands in the project area for geothermal 

energy development affects the demographic characteristics and economies of the project area. 

Additionally, social structure and values in the project area shape the demand and opportunities 

created by NFS lands.

For these reasons, demographic, economic, and social data for the project area are presented in 

this section. Counties that fall within the project area were selected as the region of interest 

(ROI) for socioeconomic and environmental justice analysis because the impacts of leasing are 

likely to occur within this region. The ROI is Rio Arriba and Sandoval Counties. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-141

A summary of the population, housing, and low-income and minority populations for each county 

is provided, based primarily on data from US Census 2010 and 2014 population estimates, 

demographic and housing information from the US 2010 Census, and employment and industry 

information from the Bureau of Labor Statistics (BLS) and the Bureau of Economic Analysis.

3.18.1.1 Population

The project area is in Rio Arriba and Sandoval Counties. Rio Arriba is in north-central New 

Mexico, bordering Colorado to the north, Taos and Mora Counties to the east, Santa Fe, Los 

Alamos, and Sandoval Counties to the south, and San Juan County to the west. 

Rio Arriba County has a land area of 5,860.84 square miles and a population density of 6.9 persons 

per square mile, with a total population of 40,155 (US Census Bureau 2014). Population growth is 

expected to be slow for Rio Arriba County over the next 20 years. Estimates conclude that by 

2035, the county will have a population of approximately 47,000 people (Alcantara 2008). 

Sandoval County is directly south of Rio Arriba and is part of the Albuquerque metropolitan 

statistical area. Sandoval County borders Los Alamos and Santa Fe Counties to the east, 

Bernalillo County to the south, and Cibola, McKinley, and San Juan Counties to the west. 

Sandoval County has a land area of 3,710.65 square miles and a population density of 35.5 

persons per square mile, with a total population of 135,191 (US Census Bureau 2014). Unlike

Rio Arriba County, the Sandoval County population is projected to grow quickly and will exceed 

200,000 people by 2035; this will result in a 68 percent growth in population over the next 20 

years. New Mexico as a whole is also estimated to experience quick population growth, by 

nearly 70 percent between 2014 and 2035. This growth will be concentrated in and around the 

metropolitan centers of Albuquerque, Santa Fe, and Las Cruces (Alcantara 2008).

Table 3-22, below, describes population data for 2010 and 2014. Rio Arriba’s total population 

decreased by 1 percent between 2010 and 2014; Sandoval’s population increased by 

approximately 1 percent during the same period, narrowly outpacing average population growth

in both New Mexico and the United States (US Census Bureau 2014). 

Table 3-22. Population by County, State, and Country

Location 2010 2014 2010-2014 Percent 

Change

United States 303,965,272 314,107,084 +1.03

New Mexico 2,013,122 2,080,085 +1.03

Rio Arriba County 40,195 40,155 -0.99

Sandoval County 124,263 135,191 +1.09

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

*Percent change rounded to the nearest hundredth. 

3.18.1.2 Housing

Table 3-23, below, provides data on the number of housing units for 2010 and 2014 for Rio 

Arriba and Sandoval Counties. The total housing supply for both counties grew between 2010 

and 2014. 
Chapter 3. Affected Environment and Environmental Consequences

3-142 Santa Fe National Forest Geothermal Leasing EIS

Table 3-23. Housing Units by County, State and Country

Location 2010 2014 2010-2014 Percent 

Change

United States 130,038,080 132,741,033 +1.02

New Mexico 887,890 907,233 +1.02

Rio Arriba County 19,385 19,601 +1.01

Sandoval County 50,314 53,289 +1.06

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

*Percent change rounded to the nearest hundredth.

Table 3-24, below, shows the vacancy rate for Rio Arriba and Sandoval Counties as 23 percent 

and 10.8 percent. Vacancy rates can be indicators of rental property income, property values, 

unemployment rates, disposable income, and overall economic conditions in a region (US 

Census Bureau 2010). A significant portion of vacant housing in both counties is classified for 

seasonal or recreation use. 

Table 3-24. Housing Vacancy Status 2010

United States New Mexico Rio Arriba 

County Sandoval County

Vacancy rate 12.2% 14.8% 23.0% 10.8%

Vacant housing 

units

14,988,438 109,993 3,870 4,685

For rent 4,137,567 22,150 373 594

Rented, not 

occupied

206,825 1,303 38 51

For sale only 1,896,796 11,050 179 894

Sold, not occupied 421,032 2,143 45 170

For seasonal, 

recreational, or 

occasional use

4,649,298 36,612 1,709 1,532

For migratory 

workers

24,161 229 8 4

Other vacant 3,652,759 36,506 1,518 1,440

Source: US Census Bureau 2010

In 2014, as shown in Table 3-25, below, the Rio Arriba County median home value was 

$140,900. This was below the New Mexico and national median home value. The median home 

value in Sandoval County was $175,800, well above the New Mexico median home value and 

nearly equivalent to the national median home value. Median gross rent for Rio Arriba County 

was $644, also below New Mexico and national median gross rent. Sandoval County median 

gross rent was $997, which was higher than the New Mexico and national median gross rents. 

Sandoval County is part of the Albuquerque metropolitan area, which accounts for its higher 

median home values and median gross rent.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-143

Table 3-25. Median Home Values and Median Gross Rent 2014

Location Median Home Value Median Gross Rent

United States $175,700 $920

New Mexico $159,300 $774

Rio Arriba County $140,900 $644

Sandoval County $175,800 $997

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

Property taxes are a substantial source of revenue for Rio Arriba and Sandoval Counties. The 

weighted average property tax rate, or mill levy, is calculated by weighing tax rates in proportion 

to the taxable value of the tax district in which the rates appear. The property tax rate for Rio

Arriba County in 2015 was $18.643 per $1,000 of net taxable value for residential property and 

$28.231 per $1,000 for nonresidential property. The property tax rate for Sandoval County in 

2015 was $33.241 per $1,000 of net taxable value for residential property and $36.194 per 

$1,000 for nonresidential property (NMDFA 2015). In comparison, the mean residential property 

tax rate for New Mexico was $29.751 per $1,000 of net taxable value and the mean 

nonresidential property tax rate for New Mexico was $31.252 per $1,000 of net taxable value 

(NMDFA 2015). Property tax obligations (revenue, assuming 100 percent collection) and 

assessed values are shown in Table 3-26, below.

Table 3-26. Santa Fe Geothermal Leasing Study Area - Property Tax Assessed Values and 

Obligations

Location

Residential Nonresidential

Total Assessed 

Value Tax Obligation Total Assessed Value Tax Obligation

Rio Arriba County

2014

2015

Percent change

$497,972,317

$503,272,606

1.01

$8,857,470

$9,382,526

1.06

$304,893,136

$289,642,902

-0.95

$7,943,607

$8,176,899

1.02

Sandoval County

2014

2015

Percent change

$2,427,832,009

$2,459,906,995

1.01

$79,541,120

$81,769,053

1.02

$751,460,176

$738,900,559

-0.98

$26,774,991

$26,743,586

-1.00

State of New Mexico

2014

2015

Percent change

$31,574,705,479

$32,283,583,025

1.02

$929,779,057

$960,480,174

1.03

$17,003,242,702

$17,454,632,250

1.02

$528,806,372

$545,494,747

1.03

Source: NMDFA 2014, 2015

3.18.1.3 Employment

Table 3-27, below, provides the average unadjusted unemployment rate for each year by county. 

Both Rio Arriba and Sandoval Counties saw an overall decrease in unemployment over this 

period, by 1.2 percent and 1.8 percent, following state and national trends (BLS 2015). 
Chapter 3. Affected Environment and Environmental Consequences

3-144 Santa Fe National Forest Geothermal Leasing EIS

Table 3-27. Santa Fe Geothermal Leasing Study Area - Average Yearly Unadjusted Unemployment 

Rate by County from 2010-2015

Percent Unemployed

Location 2010 2011 2012 2013 2014 2015

United States 9.6 9.0 8.1 7.4 6.2 5.3

New Mexico 8.1 7.6 7.1 6.9 6.5 6.5

Rio Arriba County 9.1 9.2 9.1 9.2 8.3 7.9

Sandoval County 8.4 8.1 7.8 7.5 7.1 6.6

Source: BLS 2015

Unemployment rates remained consistently higher than the New Mexico rate in Rio Arriba 

County and slightly above the state rate in Sandoval County over the period examined.

In December 2014, the labor force of Rio Arriba County consisted of 16,356 people; 14,995 were 

employed and 1,361 were unemployed (BLS 2015). Sandoval County had a labor force of 59,968 

people; 55,711 were employed and 4,257 were unemployed as of December 2014 (BLS 2015). 

3.18.1.4 Income

Table 3-28, below, shows median household incomes for years 2010 and 2014. The median 

household income for Rio Arriba County was $38,635 in 2014; this is a decrease in median 

household income by $2,802 from 2010 and falls below the New Mexico and United States 

median household incomes (US Census Bureau 2014). Sandoval County’s median household 

income decreased less significantly from 2010 to 2014; at $57,092 in 2014, it is above both the 

New Mexico and United States median household incomes (US Census Bureau 2014).

Table 3-28. Median Household Income

Location 2010 2014

United States $51,914 $53,482

New Mexico $43,820 $44,968

Rio Arriba County $41,437 $38,635

Sandoval County $57,158 $57,092

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

Table 3-29, below, shows average income across the total population for Rio Arriba and 

Sandoval Counties in 2010 and 2014. 

Table 3-29. Per Capita Income

Location 2010 2014

United States $27,334 $28,555

New Mexico $22,966 $23,948

Rio Arriba County $19,913 $19,483

Sandoval County $25,979 $26,916

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-145

3.18.1.5 Key Economic Sectors Related to Forest Service Management

Tourism

Revenues and employment opportunities associated with travel and tourism are important 

sources of income in Rio Arriba and Sandoval Counties. Based on data from a 2014 National 

Forest Service Visitor Use and Monitoring report, the average total trip spending on a visit to the 

Santa Fe region of the SFNF was $230, while the median was $25 (Forest Service 2014b). 

Visitors planned overnight stays within 50 miles of the National Forest 21 percent of the time 

and stayed an average of 4.9 nights per trip within 50 miles of SFNF (Forest Service 2014b). In 

2009, an estimated 1,496,000 people visited the SFNF (Harris 2014). In 2014, the travel and 

tourism sector accounted for 11.7 percent of total employment in Rio Arriba County and 14.3 

percent in Sandoval County (Headwaters Institute 2016b). A significant majority of these 

employment opportunities come from the accommodations and food services industries. 

Mineral Development

For fiscal year 2014, neither Rio Arriba nor Sandoval County received any royalty payments 

from the federal government for geothermal leases on federal lands or royalty payments from 

any fluid mineral development on federal land (Headwaters Institute 2016a).

Grazing

Royalties from grazing leases on federal lands can be significant sources of revenue for local 

county governments. Rio Arriba County received $32,043 in federal lands payments from 

grazing districts in fiscal year 2014; Sandoval County received $46,641 in federal lands 

payments from grazing districts in the same year (Headwaters Institute 2016a). 

Community Services

Rio Arriba County has two sheriff’s office locations, one in Tierra Amarilla, the county seat, and 

one in Espanola. There are 18 fire districts in Rio Arriba County; it is serviced by 12 emergency 

management stations and a county public works office (Rio Arriba County 2016). Sandoval 

County is serviced by 8 fire districts and 20 fire stations, with nearly 300 volunteer and full-time 

firefighters (Sandoval County 2016). Its sheriff’s office is in San Bernalillo. Both counties are 

also serviced by New Mexico state police districts (New Mexico State Police 2016). 

3.18.1.6 Environmental Justice

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority

Populations and Low-Income Populations, requires that federal agencies identify and address any

disproportionately high and adverse human health or environmental impacts of their programs,

policies, and activities on minority, low-income populations and Native Americans. Guidance on

environmental justice terminology developed by the President’s Council on Environmental

Quality provides the following definitions:

A low-income population is determined based on annual statistical poverty thresholds developed 

by the US Census Bureau. In 2014, the poverty level is based on a total income of $12,316 for an 

individual under age 65 and $24,418 for a family of four (DeNavas-Walt and Proctor 2015)

 A low-income community may include either a group of individuals living in geographic 

proximity to one another or dispersed individuals, such as migrant workers or Native 

Americans.
Chapter 3. Affected Environment and Environmental Consequences

3-146 Santa Fe National Forest Geothermal Leasing EIS

 Minorities are individuals who are members of the following population groups: American 

Indian, Alaska Native, Asian, Pacific Islander, Black, or Hispanic.

 A minority population area is so defined if either the aggregate population of all minority 

groups combined exceeds 50 percent of the total population in the area, or if the percentage 

of the population in the area comprising all minority groups is meaningfully greater than the 

minority population percentage in the comparison population. Like a low-income 

population, a minority population may include either individuals living in geographic 

proximity to one another or dispersed individuals.

 For the purpose of identifying a minority population or a low-income population 

concentration, the comparison population used in this study is the state of New Mexico as a 

whole.

To analyze low-income and minority populations in the project area, study area counties and 

relevant census tract data was examined. Rio Arriba Census Tract 4, Rio Arriba Census Tract 5, 

Sandoval Census Tract 110, and Sandoval Census Tract 112 all overlap the project area and are 

more representative of populations in the project area than data taken from Rio Arriba or 

Sandoval Counties as a whole. 

3.18.1.7 Low-Income Populations

Rio Arriba Census Tract 5, Sandoval Census Tract 110, and Sandoval Census Tract 112 all had 

percent of populations in poverty lower than that of the State of New Mexico (see Table 

3-30).Only Rio Arriba County and Rio Arriba Census Tract 4, with 22.5 percent of individuals 

below the poverty level, had a percentage of the population in poverty greater than New Mexico 

(US Census Bureau 2014). 

Table 3-30. Populations in Poverty 2014

Location

Percent of Individuals Whose Income 

in the Past 12 Months Was below the 

Poverty Level

Percent of Families Whose Income in 

the Past 12 Months Was below the 

Poverty Level

United States 15.6 11.5

New Mexico 20.9 16.1

Rio Arriba County 22.5 15.8

Rio Arriba County,

Census Tract 4

22.5 12.8

Rio Arriba County,

Census Tract 5

15.4 12.2

Sandoval County 14.7 10.7

Sandoval County,

Census Tract 110

19.2 14.4

Sandoval County,

Census Tract 112

14.2 12.1

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-147

3.18.1.8 Minority Populations

As shown in Table 3-31, all study area populations were above 50 percent minority. Rio Arriba 

Census Tract 4, Rio Arriba Census Tract 5, and Sandoval Census Tract 110 had aggregate 

minority populations that were greater than the New Mexico aggregate minority population. 

Minority populations were also identified in Sandoval Census Tract 112, with 57 percent of the 

population identifying as a minority, although this was less than the New Mexico aggregate 

minority population (US Census Bureau 2014). 

Table 3-31. Study Populations by Race/Ethnicity 2014

Population

Tract 

4, Rio 

Arriba 

County

Tract 5, 

Rio 

Arriba 

County

Tract 

110, 

Sandoval 

County

Tract 

112, 

Sandoval 

County

Rio 

Arriba 

County

Sandoval 

County

New 

Mexico

United 

States

Total 

population

4,504 3,548 1,859 2,676 40,155 135,191 2,080,085 314,107,084

Hispanic or 

Latino 

ethnicity of 

any race

77.5% 65.2% 32.7% 17.1% 71.4% 36.4% 47.0% 16.9%

White alone 21.6% 31.3% 25.4% 42.9% 13.1% 46.1% 39.6 % 62.8%

Black or 

African 

American 

alone

0.4% 0.3% 1.0% 0.0% 0.4% 2.0% 2.0% 12.6%

American 

Indian or 

Alaskan 

Native alone

1.5% 3.4% 36.5% 39.8% 14.0% 11.9% 9.2% 0.8%

Asian alone 0.0% 0.1% 0.7% 0.8% 0.5% 1.3% 1.4% 5.0%

Native 

Hawaiian 

and Other 

Pacific 

Islander 

alone

0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.2%

Some other 

race

11.9% 4.9% 9.8% 5.0% 0.1% 0.4% 11.1% 4.7%

Two or 

more races

0.2% 1.0% 4.0% 0.4% 0.5% 1.9% 3.1% 2.9%

Aggregate 

Minority 

population

78.4% 68.7% 74.6% 57.1% 86.9% 53.9% 60.4% 36.2%

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over five years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

Aggregate minority population is calculated by total population, minus those reporting as white of non-Hispanic.
Chapter 3. Affected Environment and Environmental Consequences

3-148 Santa Fe National Forest Geothermal Leasing EIS

3.18.1.9 Native Americans

In Sandoval Census Tract 110, 678 persons identify as American Indian alone, out of a total 

population of 1,859. In Sandoval Census Tract 112, 1,065 persons identify as American Indian 

alone, out of a total population of 2,676 (US Census Bureau 2014). 

As identified in Table 3-31, Study Populations by Race/Ethnicity 2014, all populations in the 

area have more than 50 percent aggregate minority populations, and therefore qualify as minority 

populations under CEQ guidance. The Forest Service will address environmental justice

populations in the project area in the EIS to mitigate any disproportionate environmental impacts 

on these populations, following guidelines set forth in Executive Order 12898. 

3.18.2 Environmental Consequences

3.18.2.1 Scoping Comments on Resource

The following issues specific to social interests, economics, and environmental justice were 

identified during the public scoping period:

 How would geothermal leasing affect tourism, local businesses, property value, and 

community services? 

 Would geothermal leasing result in disparate impacts on communities, tribes, or other 

populations?

3.18.2.2 How Resource Impacts Were Evaluated

Method

Impacts were analyzed in terms of the predicted increase in geothermal energy activities and the 

associated changes expected in employment, income, tax revenue, royalties, property value, 

public infrastructure needs, impacts on other land uses, and other socioeconomic factors. The 

location of such development could occur anywhere in the project area where consent to leasing 

has been granted. Components of geothermal plant construction and operation, including the 

number of temporary and permanent workers required, are partially determined by plant 

production potential.

The analysis of socioeconomic and environmental justice issues associated with the development 

of geothermal facilities considers impacts within the counties of the project area: Rio Arriba and 

Sandoval. 

Indicators

Impacts would result from the lease revenues and future construction and operation of 

geothermal energy projects in the project area, based on future leases. Consenting to geothermal 

leasing and issuing geothermal leases would not impact environmental justice. Potential impacts 

on socioeconomics and environmental justice could occur if reasonably foreseeable future 

actions were to result in any of the following:

 Impact other land uses that currently create revenue

 Change residential property value and property taxes collected

 Induce growth or otherwise change population concentrations and cause additional demands 

on housing or social services that could not be met by the local communities
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-149

 Cause a change in local or project area employment

 Have a disproportionately high and adverse impact on minority populations or a 

disproportionately high and adverse impact on low-income populations

Assumptions

 NSO stipulations would prevent direct disturbance to recreation, wildlife, visual resources, 

habitats, and species by restricting surface-disturbing activities where they are applied.

 Geothermal projects in the project area would be developed in accordance with the RFDS, 

suggesting a maximum of five geothermal plants of 25 MW each during the 15-year time 

frame, for a total of 125 MW. 

 Jobs and economic activity generated are based on RFDS MW estimates and economic 

impact estimates from the Geothermal Leasing PEIS (BLM and Forest Service 2008).

 Any new surface-disturbing geothermal activities would be subject to further NEPA analysis, 

which would include a site-specific analysis to determine consistency with applicable 

environmental justice guidelines.

3.18.2.3 Common Impacts Associated with Geothermal Development

The issuance of geothermal leases would impact socioeconomics through lease revenues, with 

50 percent of revenues going to the state, 25 percent going to the county, and the remainder 

going to the US Treasury (BLM and Forest Service 2008).

Impacts on area socioeconomics and environmental justice from developing the geothermal 

resource would vary, depending on the types, timing, and location of development. The largest 

impact on socioeconomics would result from employment and income directly and indirectly 

associated with geothermal electricity plant construction and operation. In addition, geothermal 

power plants may generate additional revenue streams for local government, including property 

taxes and royalties. Information and impacts for these factors are discussed at length in the 2008 

Geothermal PEIS (BLM and Forest Service 2008), and this information is incorporated by 

reference and summarized here.

Activities associated with exploration and drilling provide temporary jobs for the local 

community near geothermal resources, as well as expenditures for fuel, lodging, food, and other 

needs, providing stimulus to the local economy. 

The level of impact resulting from utilization phase activities (construction, operations, and 

maintenance) generally varies, depending on resource potential for the area. Based on the 2008 

Geothermal PEIS (BLM and Forest Service 2008), construction income is estimated to be 

roughly $4.5 million per 25-MW power plant and associated activities. In summary, construction 

of a 25-MW power plant and the associated transmission lines would require 935 person-months, 

or 77.5 person-years, with a variable number of employees required at any given time during 

construction. Operations and maintenance income is estimated to be $1.6 million annually for a 

25-MW plan. 

Generally, employment would provide positive impacts on the surrounding area in the form of 

opportunities and secondary impacts from money spent in the local economy. Additionally, 

geothermal resource development may provide an opportunity to broaden the economic base of 

the communities in and around the project area and would provide taxes and possible royalties to 

the county. 
Chapter 3. Affected Environment and Environmental Consequences

3-150 Santa Fe National Forest Geothermal Leasing EIS

3.18.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Excluded from 

leasing would be the 28,900-acre JNRA. The social and economic impacts from geothermal 

development, should a lease application be approved, are described here. 

Alternative 1 would result in impacts similar to those described in Section 3.18.2.3. The direct 

economic impacts from the construction and operation of the five 25-MW geothermal plants also 

include employment opportunities and federal royalties paid to the State of New Mexico and Rio 

Arriba and Sandoval Counties. Indirect impacts, such as increased economic activity and tax 

contributions, would also impact the area.

The creation of approximately 388 temporary construction jobs, only some of which would come 

from the local labor force, would have temporary impacts on the local economy (BLM and 

Forest Service 2008). The degree to which employment would be filled by area residents would 

depend on the level of skill required for particular jobs and the availability of qualified 

candidates, among other factors. While these jobs would be temporary, indirect impacts on local 

economies would be spending by these job holders on housing, goods, and services. 

A short-term increased demand for housing might also occur. Such an increase is not anticipated 

to create a significant burden on local housing or social services markets or induce a level of 

growth that the local communities do not have a capacity for. This is because the number of 

construction workers needed at any given time would vary throughout the completion of the 

project. 

Table 3-32, below, further details the direct economic impacts associated with geothermal 

electricity plant development. It is in accordance with expected development scenarios 

established in the RFDS (BLM 2015) and economic impacts from those scenarios from the 

Geothermal Programmatic EIS (BLM and Forest Service 2008).

Table 3-32. Economic Impacts of Geothermal Electricity Generation

Estimated geothermal MW Five 25-MW geothermal plants = 125 MW 

Total temporary construction jobs1388

Construction income (million $)2$22.5 million

Operations and maintenance jobs (permanent, full-time jobs)3212

Annual operations and maintenance income4$8 million

Federal royalty estimate (30-year total)

5

$1.75 million

State royalty estimate (30-year total)5$3.5 million

County royalty estimate (30-year total)5$1.75 million

1

Assuming an average of 3.1 total construction jobs per MW (BLM and Forest Service 2008)

2 Assuming a rate of $4.5 million for a 25-MW power plant (BLM and Forest Service 2008)

3

Assuming a rate of 1.7 permanent full time jobs/MW, in accordance with the Reasonably Foreseeable Design (BLM 

2015)

4 Assuming a rate of $1.6 million annually for a 25-MW power plant, as discussed in BLM and Forest Service (2008)

5 With average electricity price of 6 cents/kilowatt hour and 95 percent capacity factor, following Kagel (2006)
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-151

Long-term employment projections from geothermal operations and maintenance could include 

up to 212 new jobs (BLM 2015). Geothermal projects employ people with a variety of skills and 

education levels in diverse careers, from geologists and hydrologists to plumbers, machinists, 

electricians, and structural engineers (Kagel 2006). Some of these jobs would employ members 

of the region’s current labor force, while some specialized positions may require hiring workers 

new to the region. 

Short-term direct impacts for local area residents’ quality of life may occur as a result of project 

construction, due to increased traffic, noise, and dust from construction equipment (see 

Transportation and Access, Noise, and Air Quality and Air Quality Related Values sections). 

Impacts would be focused on those who live in the vicinity of development projects, and specific 

intensity and location of impacts would be variable, depending on the location of wells and 

plants, which are currently unknown. Because there is low housing density in the project area, 

these impacts would occur only in localized areas. 

In addition to direct impacts, indirect impacts on social interests and economics might occur as a 

result of geothermal development under Alternative 1. Property tax values of lands near or next 

to the geothermal power plant could be impacted by the perceived decrease in scenic value from 

the development. However, because geothermal plants are of small footprint and must be located 

near existing power lines, these affects would be minimal and short-term. This is because much 

of the disturbed area would be reclaimed within a few years after the completion of construction.

Although some long-term employment opportunities may be created though geothermal 

development, the population, labor force, or employment sector of the region would not be 

greatly altered. The RFDS reports that 1.7 potential long-term jobs are created for every MW of 

a geothermal plant. Assuming geothermal development reaches its full potential of five 25-MW

plants in the project area, 212 long-term jobs could result from development. Assuming the 

maximum long-term employment rate, that each person who receives a job must relocate to the 

project region, and that each person has an average size family of three persons, the total 

maximum increase in population would equal 636 people. This unlikely potential impact would 

result in a negligible 1.5 percent maximum population increase to Rio Arriba County or a 

negligible 0.5 percent maximum population increase to Sandoval County. 

Recreation and tourism revenues might be reduced, but this would be limited to the construction 

phase of geothermal development. Hiking, hunting, wildlife viewing, sport climbing, and 

camping are all popular recreation activities in the area. Currently developed recreation facilities, 

special-use permit recreation sites, and areas with significant recreation use deemed 

incompatible with geothermal development would be closed to geothermal leasing. This would 

minimize impacts on current recreation and tourism revenues. Due to these stipulations and the 

dispersed nature of the popular activities, there would be minimal long-term impacts on revenues 

that come from recreation and tourism in the project area.

Alternative 1 is not site specific, and leasing would be approved on a case-by-case basis; 

therefore, uniform guidance, stipulations, closures, and consistent BMPs for leasing have not 

been identified under this alternative. This type of planning does not provide the best protections 

for natural resources, socioeconomics, or environmental justice populations. By designating 

specific areas as open or closed to leasing and imposing stipulations on direct and indirect landuse by geothermal development, impacts on natural resources, socioeconomics, and 

environmental justice populations can be minimized or negated. Without site-specific plans for 

geothermal development, impacts on environmental justice populations in the project area cannot 

be determined at this time. 
Chapter 3. Affected Environment and Environmental Consequences

3-152 Santa Fe National Forest Geothermal Leasing EIS

3.18.2.5 Impacts Under Alternative 2

The overall economic impacts of geothermal development under Alternative 2 are the same as 

Alternative 1, but certain restrictions to leasing would apply. Under this alternative, 29,321 acres 

would be closed by law, regulation, or authority to geothermal leasing. Also, under this 

alternative, 139,329 acres would be open to leasing, but 132,900 of them would be subject to 

NSO stipulations, 80,300 would be subject to CSU stipulations, and 39,500 would be subject to 

TL stipulations (Forest Service GIS 2015). 

The overall potential development of five 25-MW geothermal plants and the overall net 

economic impacts from such development would be the same as under Alternative 1, but 

Alternative 2 includes greater limitations for the siting of geothermal plants and infrastructure

than Alternative 1. Site limitations may cause net economic impacts to be more dispersed 

throughout the ROI than under Alternative 1. NSO, CSU, and TL stipulations would limit

potential development sites but would minimize the direct impacts on natural resources, such as 

wildlife, soil, and water. This reduced impact on natural resources indirectly impacts 

socioeconomics by improving the quality of life for residents of the surrounding project area and 

reducing impacts on recreation and other land uses that generate revenue for the local economy. 

The programmatic nature of this EIS does not allow for analyzing specific environmental justice

populations in the project area at this time. Site-specific considerations for environmental justice 

populations must occur to mitigate any disproportionately high and adverse impacts from 

geothermal development, in compliance with Executive Order 12898. 

3.18.2.6 Impacts Under Alternative 3

Under Alternative 3, no leasing would be permitted, and no new employment opportunities, 

federal royalty payments, or new taxable income would be generated. There would be no 

impacts associated with geothermal development, and the current social and economic profile of 

the surrounding area would be retained.

3.18.2.7 Impacts Under Alternative 4

The overall economic impacts of geothermal development under Alternative 4 are the same as 

under Alternative 1, but certain restrictions to leasing would apply. Under this alternative, 28,900 

acres would be closed by law, regulation, or authority to geothermal leasing. Also, under this 

alternative, 139,329 acres would be open to leasing, but 122,500 of them would be subject to 

NSO stipulations, 122,600 would be subject to CSU stipulations, and 42,200 would be subject to 

TL stipulations (Forest Service GIS 2015). 

The overall potential development of five 25-MW geothermal plants and the overall net 

economic impacts from such development would be the same as under Alternative 1, but 

Alternative 4 includes greater limitations for the siting of geothermal plants and infrastructure

than Alternative 1. Site limitations may cause net economic impacts to be more dispersed 

throughout the ROI than under Alternative 1. NSO, CSU, and TL stipulations would limit

potential development sites but would minimize the direct impacts on natural resources, such as 

wildlife, soil, water, and air quality. This reduced impact on natural resources indirectly impacts 

socioeconomics by improving the quality of life for residents of the surrounding project area and 

reducing impacts on recreation and other land uses that generate revenue for the local economy. 

The programmatic nature of this EIS does not allow for analyzing specific environmental justice

populations in the project area at this time. Site-specific considerations for environmental justice 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-153

populations must occur to mitigate any disproportionately high and adverse impacts from 

geothermal development, in compliance with Executive Order 12898. 

3.18.2.8 Cumulative Impacts

Overall cumulative net impacts from geothermal development and other industrial projects also 

slated to occur in the ROI would generally result in increased economic activity in the region. 

Projects are the Pueblo of Jemez Red Rocks Dam Repair, the Pueblo of Jemez Owl Springs 

Bridge Sediment Removal, and the Abiquiu Land Grant Waterline Replacement. Impacts include 

the creation of jobs, increased royalties for local municipalities, increased tax revenue, and the 

securement of reliable utilities, such as clean potable water and electricity for the population. 

However, a cumulative increased demand for housing and social services from temporary 

construction employment, should these development projects overlap with geothermal 

development, could impact the local economy’s ability to provide such services. The level of 

impacts would depend on the exact timing of development projects and the level of employment 

needs, which cannot be determined at this time. 

Contribution to cumulative impacts would vary by Alternative. Following direct and indirect 

impacts discussed above, geothermal leasing under Alternatives 1, 2, and 4 would result in 

contributions to cumulative impacts, while no contributions to cumulative impacts would occur 

under Alternative 3 due to no geothermal leasing and development. 

Geothermal development projects when combined with other industrial projects could 

cumulatively impact environmental justice populations in the project area identified in Section 

3.18.1.6. Compliance with the environmental justice guidelines set forth in Executive Order 

12898 would be necessary to ensure no disproportionately high and adverse impacts affect these 

identified populations. 

3.19 Health and Safety

3.19.1 Affected Environment

The 2008 Geothermal PEIS describes health and safety concerns associated with geothermal 

energy development, as well as the regulatory framework around the health and safety of 

workers involved in such development. In the future, when NEPA analysis is conducted for 

specific geothermal exploration and development projects in the project area, site-specific health 

and safety risks would be documented. Existing health and safety risks in the project area relate 

to existing and ongoing mining and exploration, vegetation treatments, recreation, hunting, and 

transportation. In addition, there have been several major wildfires on the SFNF in recent years 

caused by trees or branches falling on small service lines.

3.19.2 Environmental Consequences

3.19.2.1 Scoping Comments on Resource

The issues specific to health and safety identified during the public scoping period are 

 What are the health and safety risks of geothermal leasing? How would geothermal 

leasing affect drinking water, considering the regional geology?
Chapter 3. Affected Environment and Environmental Consequences

3-154 Santa Fe National Forest Geothermal Leasing EIS

3.19.2.2 How Resource Impacts Were Evaluated

Method

The method for the public health and safety impact analysis is incorporated by reference from 

the health and safety section of the 2008 Geothermal PEIS (BLM and Forest Service 2008).

Indicators

Impact criteria for public health and safety are also incorporated by reference from the health 

and safety section of the 2008 Geothermal PEIS (BLM and Forest Service 2008). More 

specifically, the analysis discusses the potential for the exposure of construction workers, 

personnel, or the public to hazards related to the exploration, development, or operational phases 

of a geothermal project. This section does not discuss hazards related to hazardous materials, 

because they were discussed separately under Hazardous Materials.

Assumptions

This analysis assumes the following: 

 The risk of exposure to hazardous situations would be highest among geothermal project 

staff; the general public would have a lower risk of exposure due to the reduced likelihood of 

being on the project site during exploration, development, operations, and abandonment. 

 All construction workers and operational personnel would work according to Occupational 

Health and Safety Administration standards to prevent or minimize health and safety risks.

3.19.2.3 Common Impacts Associated with Geothermal Development

The nature and characteristics of the impacts on public health and safety associated with 

geothermal development as a result of the decisions common to all action alternatives would be 

the same as those described in the 2008 Geothermal PEIS (BLM and Forest Service 2008), 

which is incorporated by reference and summarized here.

Due to the inability to predict the location, scope, scale, and timing of future development, what 

follows is a general description of common impacts on public health and safety from geothermal 

resource development. Potential impacts are as follows: 

 Exposure of individuals to geothermal steam during exploration and development drilling 

 Exposure of individuals to electrical fires or wildfires caused by project activities

 Exposure of individuals to electric shock from maintenance of transmission lines and 

substations

 Vehicular accidents due to increased traffic on local roads

 A variety of potential accidents inherent to exploration, development, operations, 

maintenance, and reclamation and abandonment, as listed in the Geothermal PEIS

 A variety of potential accidents inherent to industrial facilities

Potential public health and safety impacts would last for the duration of exploration, estimated at 

between one and five years for an individual project, development phase, estimated at two to ten 

years for an individual project, and operations and maintenance phase, estimated at 10 to 30 

years for an individual project.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-155

Impacts from drilling activities on drinking water quality are discussed in Section 3.9, Water 

Resources.

3.19.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis and in accordance with the Forest Plan and existing laws and regulations. Impacts 

would be similar to those identified in Section 3.19.2.3, Common Impacts Associated with 

Geothermal Development, above. Measures to minimize impacts on health and safety would be 

considered in these separate NEPA analyses.

There would be a risk of human-caused fire from geothermal development. However, because 

power line rights-of-way would be cleared of trees, the risk of wildfire associated with trees 

causing downed power lines would be minor. This is in contrast to smaller service lines 

associated with residences, where the right-of-way owner may not clear trees at a long enough 

distance to prevent them from falling on the line. 

3.19.2.5 Impacts Under Alternative 2

The nature and character of impacts under Alternative 2 would be similar to those described in 

Common Impacts Associated with Geothermal Development. Under this alternative, the 

recommended BMPs detailed in Appendix C would be incorporated as appropriate into the 

permit application by the lessee or would be included in the approved use authorization as 

conditions of approval. Depending on which BMPs are identified as necessary for each lease, 

operators may be required to implement actions that would protect public health and safety. For 

example, operators would be required to minimize air quality impacts, develop hazardous 

materials and waste management plans, establish safety zones, and develop fire management

strategies. These measures would effectively minimize impacts on health and safety from 

geothermal-related actions. 

Impacts from wildfire and power lines would be the same as described under Alternative 1.

3.19.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area and no impacts on health and 

safety from geothermal activities.

3.19.2.7 Impacts Under Alternative 4

Impacts would be the same as those described under Alternative 2, because the same level of 

disturbance, the same number of wells, and the same number of power plants are expected.

3.19.2.8 Cumulative Impacts

Health and safety risks associated with geothermal energy activities, in conjunction with other 

reasonably foreseeable projects across the project area, are expected to be negligible. This is 

because all project proponents would have to comply with state and federal requirements 

pertaining to worker safety and the use, storage, transport, and disposal of debris and hazardous 

materials and wastes. The potential for spills of hazardous waste, such as fuel and drilling muds, 

would be minimized by applying BMPs included in lease terms. Any spills would not be at a 

large enough scale to cumulatively affect human health and safety, either at the local level, when 

combined with other local projects, or across the project area, when combined with all other 
Chapter 3. Affected Environment and Environmental Consequences

3-156 Santa Fe National Forest Geothermal Leasing EIS

projects with similar individual impacts. There would be no cumulative impact on wildfire from 

downed power lines, because power line rights-of-way associated with geothermal development

would be maintained free of trees or other vegetation that could fall onto the line.

3.20 Noise

3.20.1 Affected Environment

The federal law that directly affects noise control is the Noise Control Act of 1972, as amended 

by the Quiet Communities Act of 1978 (42 USC, Sections 4901-4918). This act delegates to the 

states the authority to regulate environmental noise. It also directs government agencies to 

comply with local community noise statutes and regulations and to conduct their programs to 

promote an environment free of any noise that could jeopardize public health or welfare.

Geothermal developers on NFS lands are subject to BLM leasing regulations. These mandate 

that noise at one-half mile—or at the lease boundary, if closer—from a major geothermal 

operation shall not exceed 65 A-weighted decibels (dBA; Federal Geothermal Resources 

Operational Order Number 4).

An understanding of current noise conditions in the project area is derived from a mix of noise 

measurements and modeled calculations. For example, geospatial models of the ambient sound 

level in the VCNP predict summer daytime median (L50) sound levels ranging from 

approximately 30 to 32 dBA16. Noise measurements were taken at the El Cajete Pumice Mine in 

the JNRA south of the VCNP; normal background noise levels were measured at less than 40 

dBA and up to 70 dBA, with a strong breeze in the surrounding pine forest. Vehicle noise on NM 

4 was measured at 50 to 60 dBA from a distance of approximately 200 feet. Noise levels at oil 

and gas wells operating in the SFNF have also been measured. Gas-fueled pump-jacks registered 

at 55 to 60 dBA, at a distance of 20 feet from their spark arresters, and gas compressors 

registered at 55 to 70 dBA, at a distance of approximately 80 feet.17

3.20.2 Environmental Consequences

3.20.2.1 Scoping Comments on Resource

The following issue specific to noise was identified during the public scoping period:

 What are the impacts of increased noise in the project area?

3.20.2.2 How Resource Impacts Were Evaluated

Method

The method for the noise impact analysis is incorporated by reference from the noise section of 

the 2008 Geothermal PEIS.

 

16 Randy Stanley, Natural Sounds and Night Skies Coordinator, National Park Service, personal 

communication with Forest Service. April 28, 2016.

17 Larry Gore, Geologist, Forest Service, personal communication with Drew Vankat, EMPSi. February 

10, 2016.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-157

Indicators

Impact criteria for noise are incorporated by reference from the noise section of the 2008 

Geothermal PEIS. More specifically, the analysis discusses potential noise levels and compares 

them to those set by the Federal Geothermal Resources Operational Order Number 4. This 

mandates that noise levels must be 65 dBA or less at the geothermal lease boundary, or 0.5 mile 

from the source, whichever is greater.

Assumptions

This analysis assumes the following: 

 Future analysis for site-specific projects would identify the presence of sensitive noise 

receptors, such as residences or schools, in the vicinity of the proposed well drilling or 

geothermal plant activities. 

 Noise levels for the specific activities would be assessed to determine their compliance with 

applicable noise guidelines, and measures to reduce noise impacts would be identified, if 

necessary.

3.20.2.3 Common Impacts Associated with Geothermal Development

Noise levels measured at geothermal power plants and wells can provide insight into the type 

and severity of impacts expected in the project area. In support of an EIS for the proposed Casa 

Diablo IV project near Bishop, California, Leiken (2011) measured average noise levels at the 

Galena-3 binary power plant near Reno, Nevada (Table 3-33). 

Table 3-33. Observed and Calculated Noise Levels for Geothermal Power Plants, Production 

Wells, and Drill Rigs

Distance Binary Power Plant Production Well Drill Rig

150 feet 71.5 dBA154.8 dBA269.1 dBA2

400 feet 64.5 dBA1 46.3 dBA260.6 dBA1

1,320 feet 54.0 dBA135.6 dBA150.2 dBA2

Source: Leiken 2011; Sengpielaudio 2016

1 Observed or calculated average noise levels from Leiken 2011

2 Calculated noise levels from Sengpielaudio 2016

Doubling the distance from the source of a sound decreases sound levels by 6 dBA. Using this 

formula, estimated sound levels at different distances can be calculated. Based on field 

measurements and calculated estimates, noise levels from binary power plants would only 

exceed the limit of 65 dBA established in Federal Geothermal Resources Operational Order 

Number 4 at distances of less than 400 feet. Production wells would exceed this limit at 

distances of less than 69 feet, and drill rigs would exceed this limit at distances of less than 241 

feet. These distances are estimates, as vegetation, topography, and other site-specific factors 

could affect sound levels.

Noise impacts could also occur during the exploration stage of development; however, these 

impacts would generally be less than noise levels generated during drilling operations and 

utilization.
Chapter 3. Affected Environment and Environmental Consequences

3-158 Santa Fe National Forest Geothermal Leasing EIS

3.20.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Measures to 

minimize noise related impacts (as identified above under Common Impacts Associated with 

Geothermal Development) would be considered in these separate NEPA analyses.

3.20.2.5 Impacts Under Alternative 2

Since leases are not issued on lands that also contain sensitive receptors, such as residences, 

schools, or hospitals, the maximum noise potentially experienced by such a receptor would be 65 

dBA. This indirect impact from subsequent development would occur only if the receptor is next 

to the lease boundary or within 400 feet of a power plant. Due to the highly rural and 

unpopulated nature of lands in the decision area, it is unlikely that any sensitive receptors would 

be this close to noise-emitting geothermal equipment or activities.

3.20.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area and no noise impacts from 

subsequent geothermal exploration and drilling.

3.20.2.7 Impacts Under Alternative 4

Impacts would be similar to those described under Alternative 2, because the same level of 

disturbance, the same number of wells, and the same number of power plants are expected.

3.20.2.8 Cumulative Impacts

The region of influence for noise is the project area and adjacent landscapes. Past, present, and 

reasonably foreseeable future noise-producing projects are pumice mine operation and expansion 

and mechanical vegetation treatments. Cumulative impacts on noise could occur if these 

activities were close to geothermal development activities and sensitive receptors. 

Geothermal development could potentially affect adjacent landscapes, including the VCNP,

under Alternatives 1, 2, and 4. As shown in Table 3-X, Stipulations and Closures within a 1- and 

2-mile Buffer of NPS Lands for Action Alternatives, under Alternative 2 there would be no lands 

open to geothermal leasing, subject to standard lease terms and conditions, within a 2-mile buffer 

of NPS lands. Under Alternative 4, approximately 400 acres would be open to leasing subject to 

standard lease terms and conditions within 2 miles of NPS lands. Under both alternatives, 

geothermal development could potentially occur within 2 miles of NPS lands, resulting in 

increased noise levels. There would be a greater potential for development near NPS lands under 

Alternative 4, as more acres would be open subject to standard lease terms and conditions near 

the VCNP boundary. However, implementing BMPs as described in Appendix C (such as sound 

control devices, adequate mufflers, and adequate equipment maintenance) would reduce these 

impacts from increased noise levels on NPS lands.

3.21 Transportation and Access

3.21.1 Affected Environment

A network of state highways and Forest Service roads serve the broader project area. Throughout 

the project area there are a range of single-lane and two-lane roads, with varying degrees of 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-159

improvements and a broad range of users. The 2012 Record of Decision for the SFNF Travel 

Management Plan EIS provides a comprehensive summary of travel management issues and 

decisions on the SFNF (Forest Service 2012).

3.21.1.1 State Highways

There are three main state highways in the project area: NM 4, NM 126, and NM 96. For NM 4 

the 2014 annual average daily traffic (AADT) was 3,198 vehicles (New Mexico Department of 

Transportation [NMDOT] 2014). For NM 126, the 2014 AADT was 2,700 vehicles (NMDOT 

2014), and for NM 96, the 2014 AADT was 1,238 vehicles (NMDOT 2014). These state 

highways are two-lane roads with narrow shoulders, and they traverse the forested and 

mountainous terrain typical of this part of northern New Mexico.

The Jemez Mountain Trail National Scenic Byway follows NM 4 for 21.8 miles in the project 

area (Forest Service GIS 2015). NM 4 is a popular one-day loop drive, connecting Albuquerque 

with Los Alamos and Santa Fe, and is the main access to the developed campgrounds, picnic 

areas, and trailheads. NM 4 also travels directly through Jemez Pueblo and is often highly 

congested during the summer and fall, with tourists, recreation vehicles, and day visitors. NM 

126 is also in the project area, for a total of 6.2 miles (Forest Service GIS 2015). NM 126 

provides access to Fenton Lake and Cuba, located west of the project area. NM 96, along the 

northern project boundary for 10.4 miles, connects Abiquiu with Coyote, Gallina, Regina, and 

other towns and villages to the west of the project area (Forest Service GIS 2015). It is less 

popular with tourists.

3.21.1.2 SFNF Roads and Trails

The SFNF has implemented the Travel Management Rule that requires all National Forests and 

Grasslands to designate a system of roads, trails, and areas for motorized use and to prohibit all 

motor vehicle use off the designated system. 

To address concerns about the impacts of unmanaged off-highway vehicles, the Forest Service

published final travel management regulations for motor vehicle use on National Forests and 

Grasslands on November 9, 2005. The Travel Management Rule “provides for a system of NFS

roads, NFS trails, and areas on NFS lands that are designated for motor vehicle use. After these 

roads, trails, and areas are designated, motor vehicle use, including the class of vehicle and time 

of year, not in accordance with these designations is prohibited.”

On the SFNF, complying with the Travel Management Rule means the following: 

 No cross-country motorized travel except in designated areas

 Identification of roads and trails that are open for motorized use

 Designation of the limited use of motor vehicles within a specified distance of certain 

designated routes and, such as within specified periods, solely for the purposes of dispersed 

camping or retrieval of a big game animal by an individual who has legally killed that 

animal

 A Forest Plan that reflects these management classifications and is consistent with the Travel 

Management Rule (Forest Service 2012)

The 2015 SFNF Motor Vehicle Use Maps provide a comprehensive overview of system roads 

and trails on the SFNF. These maps show which roads and trails are open to motor vehicle travel, 
Chapter 3. Affected Environment and Environmental Consequences

3-160 Santa Fe National Forest Geothermal Leasing EIS

what type of vehicle they are open to, and what season they are open. Within the project area, 

roads and trails are as follows (Forest Service GIS 2015):

 Miles of paved main roads—19

 Miles of dirt main roads—125

 Miles of dirt roads—908

 Miles of motorized trails—74

Forest Road 376 travels through the most used motor vehicle-dispersed recreation area on the 

SFNF. An estimated 97,000 to 110,000 people travel on this road every year. Forest Road 10 is 

another highly used motor vehicle recreation corridor; 93,000 to 107,000 people travel through 

and recreate along this road every year. Forest Road 10 provides primary access to other 

dispersed recreation areas along Forest Roads 266, 270, and 269. The dispersed camping 

corridor along Forest Road 144 serves as an overflow area for the Forest Road 376 recreation 

area when it is full (Forest Service 2015b). Other Forest roads in the project area also experience 

high-volume visitation during the peak summer season.

3.21.2 Environmental Consequences

3.21.2.1 Scoping Comments on Resource

The following issues specific to transportation and access were identified during the public 

scoping period:

 How would increased traffic affect residents, visitors, and other Forest users?

 What would the impacts be on road conditions and adjacent buildings as a result of increased

traffic?

3.21.2.2 How Resource Impacts Were Evaluated

Method

Information from the National Visitor Use Monitoring surveys (NVUM 2013), the SFNF Travel 

Management EIS and Record of Decision (Forest Service 2012), SFNF GIS (Forest Service GIS 

2015), and traffic counts from the NMDOT (2014) were used to estimate the number of visitors 

to the area, the travel management issues on the Forest, areas of greatest use in the project area, 

and the overall issues that would be encountered under the analyzed alternatives. 

Indicators

Potential impacts on transportation and access could occur if reasonably foreseeable future 

actions were to have the following impacts:

 Change traffic patterns or volume

 Change access to public or private roads

Assumptions

This analysis assumes the following:

 Making land potentially available to geothermal leasing, as included under Alternatives 1, 2, 

and 4, would not impact transportation or access; however, impacts could occur if applicants 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-161

propose exploration or production. These impacts would be considered in future site-specific 

analyses under NEPA.

 Potential future geothermal activities could improve motorized access, with a possible 

increase in traffic and congestion from large construction vehicles operating during 

exploration and development.

3.21.2.3 Common Impacts Associated with Geothermal Development

Due to the inability to predict the location, scope, scale, and timing of future development, the 

following impact analysis provides a general description of common impacts on transportation 

and access from geothermal development. The information presented in the Development section 

of the 2008 Geothermal PEIS may also be referenced (BLM and Forest Service 2008).

If the geothermal resources in the project area are explored or used, there could be impacts on 

traffic and access along the primary routes in the project area (NM 4, NM 96, and NM 126). This 

would be due to additional vehicles, such as large trucks, drilling rigs, cranes, construction 

trailers, or other long-wheelbase vehicles. 

Impacts could include increased congestion. This is because the use of these large vehicles with 

limited turning radii and potentially heavy loads that make acceleration difficult would likely 

slow other traffic in the steep, narrow roads with limited sight distance that are typical of the 

project area. These potential increases in congestion and traffic would mostly be temporary and 

limited to exploration and development, in contrast to the operational phase of geothermal 

development; this requires fewer large vehicles and would result in minor or negligible impacts 

on transportation or access. Such measures as traffic control plans, signage, and TLs could help 

to mitigate the temporary impacts on traffic and access during exploration and development (see 

Appendix C). 

If the geothermal resources in the project area were explored or used, there could be impacts 

from the development of new roads or improvements to existing roads. The RFDS (BLM 2015) 

estimates that under the exploration phase, approximately 10 miles of current 12-foot-wide roads 

may be widened by up to 8 feet—for a total road width of 20 feet—to accommodate large drill 

rigs and tractor-trailers. These existing two-track roads vary in condition, but generally would 

require the aforementioned widening, along with grading and other minor improvements to 

accommodate seismic activities or exploratory drilling. Fewer vehicles and trips would be 

involved with exploratory activities, compared with development and utilization (BLM 2015).

During the development and utilization phases, the BLM (2015) estimates that the 10 miles of 

roads used during exploration may be widened by an additional 2 feet—for a total road width of 

22 feet. This is because access roads would have to be at a higher standard than for gradient-well 

drilling: the drill rig for a full-diameter well is transported to the site by tractor-trailer. The 

number of trips for both heavy and light vehicles would be significantly greater than under the 

exploration phase. Transporting the drill rig and ancillary equipment to the site may require 

approximately 15 to 20 trips by full-sized tractor-trailers; the same number would be required to 

demobilize the rig. The size of the material-supply trucks and water trucks would necessarily be 

larger than for a temperature-gradient well, and the number of trips would be proportionally 

greater, given the greater well depth. A full-diameter drilling operation typically has from 10 to 

15 people on-site at all times, with more coming and going periodically with equipment and 

supplies, which may increase traffic and congestion (BLM 2015).
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3-162 Santa Fe National Forest Geothermal Leasing EIS

In addition, there would be impacts from the construction of new temporary roads associated 

with development and utilization phases in the project area. The temporary roads would be 

adequate for exploration and development equipment and trucks to get from geothermal sites to a 

landing or main road and could be decommissioned after use. A temporary road is one that is 

authorized by contract, special use permit, lease, or other written authorization that is not an NFS

road and that is not included in an NFS transportation atlas. Any temporary roads would not 

require an amendment to the Travel Management Plan.

3.21.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Impacts would be 

similar to those identified under Common Impacts Associate with Geothermal Development, 

such as temporary increases in congestion and traffic limited to the use of large, long-wheelbase 

construction vehicles in the exploration and development phases. Under Alternative 1, there 

would be no amendment to the Travel Management Plan.

3.21.2.5 Impacts Under Alternative 2

Direct and indirect impacts would be the same as those described under Alternative 1. However, 

implementing closures and stipulations may limit the volume of traffic in those areas. TLs

imposed on drilling operations and construction would reduce the volume of traffic between 

March 1 to September 30, compared to Alternative 1.

3.21.2.6 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. There would 

be no direct or indirect impacts on transportation or access, compared to Alternative 1.

3.21.2.7 Impacts Under Alternative 4

Direct and indirect impacts would be the same as those described under Alternative 2.

3.21.2.8 Cumulative Impacts

Consenting to the issue a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any future development of geothermal resources may result in impacts, 

whether significant or not. It is reasonable, therefore, to foresee that on-the-ground impacts on

transportation and access may occur if the Forest Service consents to leasing and the BLM issues 

geothermal leases. Those impacts would not occur, however, until some point in the future, 

following several decision stages. 

Past and present activities that have had cumulative impacts on transportation and access are 

mining, ranching, timber cutting, road building, road decommissioning, off-road vehicle riding, 

developing the LANL, and implementing the travel management plan. In addition, the 2014

transfer of Valles Caldera to a National Preserve under the management of the NPS has increased 

access, visitor days, and overall traffic on NM 4 and portions of the project area next to the 

caldera.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-163

Reasonably foreseeable future actions are the proposed South Pit Pumice Mine Expansion, the 

Duran 2010 Pumice Mine, and the Valles Caldera nomination under the Geothermal Steam Act 

of 1970 (30 USC, Section 1019). The two pumice mines on the Jemez Ranger District could 

have a minor cumulative impact on transportation and access. Further, if the VCNP is designated 

as a significant thermal feature under the Geothermal Steam Act, development in areas near to 

the caldera, or those with hydrological connections, may not be leased; this would reduce

potential indirect impacts on transportation and access, such as increased congestion. Other 

reasonably foreseeable actions could include potential fire management activities, timber sales, 

mineral leases, and transmission lines. 

Incremental cumulative impacts would not be anticipated under Alternative 3, because the 

project area would be closed to geothermal leasing. Under Alternatives 1, 2, and 4, incremental 

cumulative impacts on transportation and access would increase traffic and congestion. 

However, these would be temporary impacts associated with exploration and development. 

3.22 Climate Change

3.22.1 Affected Environment

Climate

Climate is defined as the generally prevailing weather conditions of a particular region 

throughout the year, averaged over a series of years. Climate is both a driving force and a 

limiting factor for biological, ecological, and hydrologic processes, as well as for resource 

management of public lands. 

The climate of the project area is generally mild. The summer and fall are characterized by warm 

daytime temperatures and cold nights. While the winter is relatively mild, snow depths may 

average eight to ten feet. In the summer, the climate is abundant in sunshine, with large 

variations between daytime and nighttime temperatures. Peak precipitation occurs in late 

summer and early fall, when moisture from the Gulf of Mexico moves into the region. 

Table 3-34, below, shows monthly climate normal data from 1981 to 2010 for select towns 

within the buffer zones of the project area. Climate normals are three-decade averages of 

climatological variables produced by the National Oceanic and Atmospheric Administration, 

National Climatic Data Center, every ten years. Monthly summary tables of these data, along 

with average annual snowfall, were obtained from the Western Regional Climate Center. 

Table 3-34. Average Temperatures and Precipitation in the Project Area (1981-2010)

Location

Average Maximum 

Temperature (°F)

Average Minimum 

Temperature (°F)

Average Precipitation 

(in inches)

Average 

Snow in 

Jan Jul Annual Jan Aug Annual June Aug Annual Inches

Los 

Alamos

39.6 81.1 60.4 18.6 53.3 36.3 1.56 3.42 19.03 53.2

Santa Fe 43.8 86.2 65.4 18.3 54.0 36.0 1.25 2.23 14.19 21.0

Source: WRCC 2014
Chapter 3. Affected Environment and Environmental Consequences

3-164 Santa Fe National Forest Geothermal Leasing EIS

Climate Change

Climate change is an identifiable change in climate over time due to natural internal processes 

and variability or as a result of human activity (IPCC 2014). The United Nations Framework 

Convention on Climate Change further defines climate change as attributed directly or indirectly 

to human activity that alters the composition of the global atmosphere and that is natural climate 

variability observed over comparable periods (United Nations 1992).

According to the most recent assessment from the Intergovernmental Panel on Climate Change 

(IPCC), humans are the primary cause of climate change through emissions of GHGs. The earth 

has a natural greenhouse impact, wherein naturally occurring gases, such as water vapor, carbon 

dioxide, methane, and nitrous oxide, absorb and retain heat. Without the natural greenhouse 

impact, the earth would be approximately 60°F cooler. Climate change is caused in part by the 

increase in GHGs in the atmosphere beyond naturally occurring levels. Over time the amount of 

energy sent from the sun to the earth’s surface should be approximately the same as the amount 

of energy radiated back into space, leaving the temperature of the earth’s surface roughly 

constant. Increased levels of GHGs trap more heat in the atmosphere and result in average 

overall warming of temperatures over time.

From 1983 to 2012, the northern hemisphere experienced what is likely the warmest 30-year 

period in the last 1,400 years, and global temperatures have increased 1.53oF since 1880 (IPCC 

2014). A climate change vulnerability assessment for biodiversity in New Mexico identified the 

following climate trends (Enquist and Gori 2008):

 Mean annual temperatures have risen across New Mexico and the southwestern United 

States since the early twentieth century. Relative to a 1961 to 1990 baseline, both the 1991 to 

2005 and 2000 to 2005 periods show temperature increases in over 95 percent of the 

geographical area of New Mexico. The magnitude of warming varied across the state, with 

the greatest warming in northwestern, central, and southwestern New Mexico.

 In New Mexico, mean annual temperatures increased 0.6°F per decade, with a 1.8°F overall 

change since 1976, when averaged across the state’s eight climate divisions. Mean winter 

temperatures are most responsible for this rise, yet springtime temperatures have also risen.

 Precipitation changes vary across New Mexico, with 54 percent of the state tending toward 

wetter conditions, 41 percent toward drier conditions, and 5 percent showing no change 

during the 1991 to 2005 period, compared to 1961 to 1990 baseline conditions.

Climate change has potentially disruptive consequences for agriculture, water supply, 

transportation, coastal communities, the economy, energy, ecosystems, and national security. 

Observed climate change has impacted natural and human systems, regardless of its cause, 

underscoring the sensitivity of natural and human systems to changing climate (IPCC 2014). In 

New Mexico, climate change is likely to exacerbate the impacts of natural and altered 

disturbance regimes, including wildfire, insect outbreaks, flooding, and erosion, across all habitat 

types and may prompt abrupt ecological changes. This is particularly true in such ecosystems as 

grasslands, riparian areas, and forests, where the impacts of past management and land use 

change are substantial (Enquist and Gori 2008). 

Mid- to high-elevation forests and woodlands have experienced the highest levels of climate 

change effects since the late twentieth century, particularly in terms of mean temperature 

increases. The forests and woodlands in northwestern New Mexico have been subjected to 

consistently warmer and drier conditions. Elevated moisture stress in forests and woodlands of 

the southwestern United States has been shown to amplify the impacts of ecological disturbance 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-165

regimes, such as insect outbreaks and fire, in addition to increasing the risk of large-scale forest 

diebacks. These disturbances are expected to increase under the warmer and drier conditions that 

most climate models predict for twenty-first century climate in the region (Enquist and Gori 

2008).

Greenhouse Gases

GHGs are compounds that contribute to climate change by trapping heat in the atmosphere. They

absorb infrared radiation and radiate a portion of that radiation back to the earth’s surface, thus 

trapping heat and warming the atmosphere. The most important naturally occurring GHG 

compounds are carbon dioxide (CO2), methane, nitrous oxide, ozone, and water vapor. CO2, 

methane, and nitrous oxide are produced naturally by the following processes:

 Respiration and other physiological processes of plants, animals, and microorganisms 

 Decomposition of organic matter

 Volcanic and geothermal activity

 Naturally occurring wildfires

 Natural chemical reactions in soil and water

Ozone is not released directly by natural sources but forms during complex chemical reactions in 

the atmosphere among organic compounds and nitrogen oxides in the presence of ultraviolet 

radiation. While water vapor is a strong GHG, its concentration in the atmosphere is primarily a 

result and not a cause of changes in surface and lower atmospheric temperature conditions. 

Although naturally present in the atmosphere, concentrations of CO2, methane, and nitrous oxide 

are also produced by industrial processes, transportation technology, urban development, 

agriculture, and other human activity. Globally, atmospheric CO2 concentrations have increased 

from an estimated 277 parts per million before 1750 to approximately 395 parts per million in 

2013 (Global Carbon Project 2014). 

In the United States, GHG emissions come mostly from energy use. Such emissions result from 

combustion of fossil fuels used for electricity generation, transportation, industry, heating, and 

other needs. In 2009, the electric power sector was the largest source, accounting for 40 percent 

of all energy-related CO2 emissions; the transportation sector was the second-largest source, at 

34 percent of total emissions (EIA 2011). 

The EPA estimated that national GHG emissions in 2014 (the most recent year for which 

national data has been tabulated) totaled 6,873 million metric tons of carbon dioxide equivalents 

(CO2e; a measure that accounts for the global warming potential of the different GHGs; EPA 

2015). 

The most recently available comprehensive inventory of statewide GHG emissions for New 

Mexico occurred in 2007. It showed gross GHG emissions of 76.2 million metric tons of CO2e 

(NMED 2010). This state-wide inventory was 1.02 percent of total US emissions for that same 

year (7,480 million metric tons of CO2e). 

Large emitters are required to report their GHG emissions to the EPA annually. Reported sources 

in Rio Arriba County were nine petroleum and natural gas systems, which emitted 405,735 

metric tons of CO2e. Reported sources in Sandoval County include two landfills, a wallboard 

plant, and an electronics manufacturing facility that emitted 206,035 metric tons of CO2e (EPA 

2014).
Chapter 3. Affected Environment and Environmental Consequences

3-166 Santa Fe National Forest Geothermal Leasing EIS

3.22.2 Environmental Consequences

3.22.2.1 Scoping Comments on Resource

The following issues specific to climate change were identified during the public scoping period:

 How would the SFNF address climate change and GHG emissions from geothermal leasing?

 Would geothermal leasing affect regional weather conditions?

3.22.2.2 How Resource Impacts Were Evaluated

Method

The method for climate change compares estimated GHG emissions from well drilling, the 

primary source of temporary emissions from geothermal development, against national and state 

GHG emission levels and against the indicator described below. The analysis also compares 

GHG emissions associated with geothermal power production against GHG emissions from 

other sources of energy generation.

Indicators

On September 22, 2009, the EPA released final regulations for a Greenhouse Gas Monitoring 

Rule (see 74 Federal Register 56260). The reporting rule requires suppliers of fossil fuels or 

industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric 

tons or more per year of GHG emissions to submit annual reports to the EPA. As there are no 

Clean Air Act significance thresholds for evaluating GHGs, this analysis compares likely GHG

emissions from each alternative against the Greenhouse Gas Monitoring Rule.

Assumptions

The analysis makes the following assumption:

 BMPs, such as those identified in Appendix C, would be applied at the BLM permitting level 

to minimize impacts on air quality from exploration, drilling operations, utilization, and 

reclamation and abandonment. Minimization of equipment-related air quality impacts also 

would minimize GHG emissions from this equipment.

 Based on existing temperature gradient data, binary cycle power plants (which operate at 

lower temperatures than flash steam plants or dry steam plants) are the most likely 

technology that would be developed in the project area. Therefore, this analysis does not 

assess the potential impacts of flash steam or dry steam geothermal power plants. Binary

plants are closed-loop systems and do not emit GHGs during their operation. For this reason, 

only GHG emissions from exploration and development are evaluated. 

 Binary plants would use air cooling rather than wet cooling.

 There is a correlation between global concentrations of GHGs and climate change. However, 

it is not currently possible to link projected GHG emissions associated with any particular 

activity to specific environmental impacts at a specific site or location.

3.22.2.3 Common Impacts Associated with Geothermal Development

The information on climate change presented in the Common Impacts on Air Quality and 

Atmospheric Values Associated with Geothermal Development section of the PEIS is 

incorporated here by reference (this section of the PEIS also addresses climate change and 

GHGs). Leasing would have no direct impacts related to climate change or emissions of GHGs.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-167

Temporary emissions of CO2 and methane from equipment use would occur during all phases of 

geothermal development. Sources of these temporary GHG emissions are vehicles, truck traffic, 

and construction equipment required for exploration, well drilling, and power plant construction. 

Exploration

Exploration would result in exhaust-related CO2 emissions and much smaller amounts of 

methane from vehicles and construction and drilling equipment. Sources of emissions are the 

following:

 Gas- and diesel-powered construction equipment for exploration road development

 Drill rigs and auxiliary equipment to develop temperature gradient wells and slim wells

 Tractor trailers to bring in and move out construction and drilling equipment

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for road construction and drill rig personnel

Table 3-35 provides estimated CO2 emissions from geothermal development under the RFDS. 

The time frame for geothermal exploration is one to five years.

Table 3-35. Geothermal Development Exploration Well Carbon Dioxide Emissions

Activity CO2 (tons) 1

On-road vehicle exhaust (tons per well) 10

Unpaved road dust (tons per well) 0

Paved road dust (tons/well) 0

Drill rig and auxiliary equipment (tons per well) 82

Total (tons per well) 92

Total2(tons per RFDS [20 wells]) 1,840

Source: Forest Service 2016d

1

Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2

Emissions from vehicle travel would likely be less under the full RFDS, as drill rig equipment and other 

construction equipment would likely be moved from well site to well site, resulting in fewer miles traveled than 

calculated for a single well development.

In addition to the drilling-related CO2 emissions shown in Table 3-35, on-road construction 

equipment for road development would produce CO2 emissions and much smaller amounts of 

methane. BMPs, such as those identified in Appendix C, would be applied at the permit level. 

Measures to mitigate equipment exhaust emissions, if applied, would also reduce CO2 emissions.

Temperature gradient wells do not typically encounter the geothermal resource; therefore, no 

release of naturally occurring non-condensable gases, comprised mostly of carbon dioxide, 

would occur. Slim wells do encounter the geothermal resource and thus have the potential to 

release CO2 during development.

Exploration would disturb approximately 27 acres, primarily for exploration road development. 

Removing vegetation and disturbing soil releases the soil organic carbon and the carbon stored in 

the vegetation. 
Chapter 3. Affected Environment and Environmental Consequences

3-168 Santa Fe National Forest Geothermal Leasing EIS

Development Drilling and Utilization

Development drilling and utilization would result in exhaust-related CO2 emissions and much 

smaller amounts of methane from vehicles and construction and drilling equipment. Sources of 

emissions are the following:

 Gas- and diesel-powered construction equipment for well pad, transmission line, pipeline, 

road, and power plant construction

 Drill rigs and auxiliary equipment to develop production and injection wells

 Tractor trailers to bring in and move out construction and drilling equipment and materials to 

construct the power plants

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for construction and drill rig personnel 

Well drilling has the potential to release non-condensable gases, primarily CO2. Noncondensable gases would be emitted during flow testing and would last until the well is shut in 

or connected to the pipeline.

Table 3-36 depicts potential CO2 emissions associated with geothermal development. The time 

frame for geothermal exploration is two to ten years.

Table 3-36. Geothermal Development Well Drilling Carbon Dioxide Emissions

Activity CO2 (tons) 1

On-road vehicle exhaust (tons per well) 38

Unpaved road dust (tons per well) 0

Paved road dust (tons per well) 0

Drill rig and auxiliary equipment (tons per well) 802

Total (tons per well) 840

Total (tons per 6 wells, or 1 power plant) 5,040

Total2(tons per RFDS [30 wells]) 25,200

Source: Forest Service 2016d

1

Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report.

2

Emissions from vehicle travel would likely be less under the full RFDS, as drill rig equipment and other 

construction equipment would likely be moved from well site to well site, resulting in fewer miles traveled than 

calculated for a single well development.

In addition to the development drilling-related emissions shown in Table 3-36, the following 

construction activities would produce CO2 emissions and much smaller amounts of methane:

 Non-road construction equipment emissions for well pad, transmission line, pipeline, road, 

and power plant construction

 On-road vehicle equipment emissions from material and equipment deliveries, water trucks, 

concrete trucks, and construction personnel commute vehicles
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-169

As described under Exploration, BMPs, such as those identified in Appendix C, would be 

applied at the permit level. Measures to mitigate equipment exhaust emissions, if applied, would 

also reduce CO2 emissions.

In addition to equipment and vehicle emissions, well drilling has the potential to release noncondensable gases. The amount and ratio of the constituents in the geothermal resource varies by 

geology, with carbon dioxide generally comprising over 95 percent of the non-condensable 

gases. Emissions of non-condensable gases would occur during flow testing and would continue 

until the well is shut in or connected to the pipeline.

Development and utilization would disturb approximately 647 acres for well pads, transmission 

lines, pipelines, roads, and power plant facilities. Removing vegetation and disturbing soil 

releases the soil organic carbon and the carbon stored in the vegetation. 

Power Plant Operation

Under the RFDS, five 25-megawatt geothermal binary cycle power plants would operate for a 

period of 30 to 50 years. The RFDS estimates that each plant would employ 9 shift workers and 

up to 12 additional workers per day. CO2 emissions would be limited primarily to vehicle and 

maintenance equipment emissions, including vehicle commute traffic, delivery traffic, and onsite maintenance truck and equipment use.

Operating a closed binary cycle geothermal power plant does not emit CO2, except from well 

venting during maintenance and potentially if there are leaks. The plants would use air cooling 

and therefore would not emit steam into the environment. Development of the power plants 

would have an indirect impact on GHG emissions if the power produced by the plants were to 

displace electricity generated by conventional sources of electricity. Geothermal power 

production creates less CO2 per kilowatt-hour of electricity produced than burning fossil fuels. It 

would have a positive net impact on CO2 emissions if used in place of fossil fuel extraction. 

Compared to coal and natural gas, geothermal energy has a smaller carbon footprint and lower 

gaseous emissions (Matek 2013). 

Table 3-37, below, compares CO2 emissions for a composite of geothermal power plant

technology versus fossil fuel plants. As shown, geothermal plants emit significantly less CO2

(Bloomfield et al. 2003). Because the geothermal technology used in the project area would be 

air-cooled binary plants, no CO2 would be emitted from operation of the plants. 

Table 3-37. Comparison of Geothermal and Fossil Fuel Carbon Dioxide Emissions

Geothermal Coal Petroleum Natural Gas

Emissions (pounds of CO2 per kilowatt-hour) 0.2 2.095 1.969 1.321

Source: Bloomfield et al. 2003

3.22.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. 

Alternative 1 would have no direct climate change impacts. 
Chapter 3. Affected Environment and Environmental Consequences

3-170 Santa Fe National Forest Geothermal Leasing EIS

Indirect impacts would include the production of GHG emissions during all phases of 

geothermal development, including construction and well drilling. GHGs would be produced 

through the combustion of fuels used by construction equipment and construction-related 

vehicles. GHGs would also be emitted during well drilling as the CO2 is released from the 

geothermal resource itself. Carbon would be released from the removal of vegetation and 

disturbance of soils on approximately 760 total acres. Any BMPs or measures designed to reduce 

equipment and vehicle exhaust emissions to minimize impacts on air quality would also reduce 

GHG emissions.

As shown under Common Impacts Associated with Geothermal Development, well drilling 

during exploration would emit an estimated 1,840 tons of CO2 under the RFDS (20 temperature 

gradient and slim wells), while well drilling under exploration would emit an estimated 25,200 

tons of CO2 under the RFDS (30 production wells). These emissions would occur over the life of 

the exploration phase (one to five years) and development phase (two to ten years); thus these 

activities would emit less than the referenced 25,000 metric tons of GHG per year under the 

EPA’s GHG Monitoring Rule, which is used as an indicator in this analysis. They would also 

represent less than 1 percent of national and state emission levels.

GHG emissions associated with the operation of geothermal power plants would include 

commute traffic, maintenance traffic, and truck deliveries and potential releases of CO2 during 

maintenance. GHG emissions from each power plant would be expected to be well below the 

25,000 metric tons per year reporting limit under the Greenhouse Gas Monitoring Rule.

As described under Common Impacts Associated with Geothermal Development, geothermal 

power plant development could have an indirect impact, if power produced by the geothermal 

plant were to displace electricity generated by conventional fossil fuel sources of electricity and 

thus offset CO2 emissions that would otherwise be provided by fossil fuel-produced electricity. 

3.22.2.5 Impacts Under Alternative 2

Indirect impacts would be the same as those described for Alternative 1.

3.22.2.6 Impacts Under Alternative 3

Under Alternative 3, there would be no geothermal development and no emissions of GHGs. 

3.22.2.7 Impacts Under Alternative 4

Indirect impacts would be similar to those described for Alternative 1.

3.22.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for GHG emissions is northern New 

Mexico. Past and present actions and events in this analysis area have directly emitted GHGs and 

caused carbon to be released from soils and vegetation. Past and present actions and conditions 

that have contributed GHGs to the atmosphere are urban development (population increases 

spurring development), mineral development, energy production, fossil fuel burning (primarily 

transportation-related use), and wildfire. These sources will continue to emit GHGs in the future. 

Reasonably foreseeable future actions in the immediate project area from vegetation and water 

resources management, described in Section 3.3.4, would temporarily emit GHGs from vehicles

and equipment; surface disturbance also would release carbon during vegetation removal and 

soil disturbance.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-171

Current scientific technology makes it difficult to link a specific action to a specific climate 

change-related impact. Emissions of GHGs from construction under Alternatives 1, 2, and 4 

would be small in the context of broader emissions. However, over the long term, these actions, 

in combination with other GHG-emitting actions, do contribute to total global emission levels. 

These, in turn, could contribute to future long-term, anticipated climate changes to a small

degree. Overall, the contribution of geothermal development under Alternatives 1, 2, and 4 

would be a very small portion of the total from other sources of a regional and global nature. In 

addition, GHG production would be temporary, because the plants would not emit GHGs. 

Therefore, GHG emissions under Alternatives 1, 2, and 4 would not be cumulatively significant.

Alternatives 1, 2, and 4 would result in five 25-MW binary geothermal plants being brought 

online, which would have the potential to reduce GHG emissions from other sources of 

nonrenewable energy.

3.23 Short-Term Uses and Long-Term Productivity

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR, Subpart 1502.16). 

As declared by Congress, this includes using all practicable means and measures, such as 

financial and technical assistance, in a manner calculated to foster and promote the general 

welfare, to create and maintain conditions under which humans and nature can exist in 

productive harmony, and fulfill the social, economic, and other requirements of present and 

future generations of Americans (NEPA Section 101).

For this EIS, short term refers to the steps needed to develop a geothermal resource (exploration, 

drilling, testing, and construction). Long term refers primarily to the 15-year time frame 

described within the RFDS.

The exploration and testing phase of a geothermal project is designed to determine the nature 

and extent of the geothermal resource, including boundaries, controls on permeability, 

temperature distribution, and fluid flow paths. Generally, this phase lasts one to five years. 

Where such exploration proves unsuccessful, these lands would not be used for subsequent 

development and production; instead they would be restored as much as possible to their original 

condition on completion of exploration and testing.

If geothermal activities progress beyond the exploration and testing phase into the development 

and production phases, the lands could be affected to a greater extent. The short-term uses of the 

environment associated with anticipated future actions—exploration, drilling, land clearing, 

plant construction, operation, maintenance, and plugging and final reclamation, as detailed in the 

RFDS—consistent with implementation of Alternatives 1, 2, and 4, include impacts on the 

natural and human environment, as detailed in each resource section of this chapter. These shortterm impacts can be compared to the long-term productivity associated with long-term 

renewable energy production. Under Alternative 3, all lands in the project area would be closed 

to leasing, and there would be short-term uses or long-term productivity associated with 

geothermal development.

Over the long term, while geothermal plants are in production, low-cost and renewable energy

would be generated. Geothermal power production creates less CO2 per kilowatt-hour of 

electricity produced than burning fossil fuels. Compared to coal and natural gas, geothermal 

energy has a smaller carbon footprint and lower gaseous emissions (Matek 2013). Therefore, 
Chapter 3. Affected Environment and Environmental Consequences

3-172 Santa Fe National Forest Geothermal Leasing EIS

geothermal energy development would offset the use of irretrievable resources, such as coal and 

oil, which would reduce GHG emissions.

In addition, while in production, each plant would provide employment opportunities for citizens 

of surrounding communities, and energy sales would generate revenue for Rio Arriba and 

Sandoval Counties. 

3.24 Unavoidable Adverse Impacts

Consenting to geothermal leasing and the subsequent issuing of leases would not result in any 

unavoidable adverse impacts. These impacts would be assessed during the permitting process 

and on a site-specific basis. If geothermal leases were developed, adverse impacts would be 

expected. Because the RFDS anticipates development of leases under Alternatives 1, 2, and 4, 

the following impacts would be applicable to these alternatives:

 Long-term loss of vegetation, wildlife habitat, soil, and soil quality. The stipulations in the 

EIS would reduce these impacts as described under Section 3.8, Soil Resources, Section 

3.11, Vegetation, Section 3.12, Fish and Wildlife, and Section 3.13, Threatened and 

Endangered Species and Special Status Species.

 Short-term and intermittent noise impacts from construction and maintenance as described 

under Section 3.20, Noise.

 Possible loss of recreation opportunities from energy infrastructure, although new roads 

could provide access for additional recreation opportunities, as described under Section 3.4, 

Land Use, Recreation, and Special Designations.

 Long-term visual impacts from power plants and infrastructure. The degree to which visual 

impacts would occur would vary by alternative, as described in Section 3.17, Visual 

Resources.

There would be no unavoidable adverse impacts under Alternative 3, as all lands in the project 

area would be closed to geothermal leasing.

3.25 Irreversible and Irretrievable Commitments of 

Resources

This section describes the irreversible and irretrievable commitments of resources associated 

with implementing the alternatives. Resources irreversibly or irretrievably committed by a 

proposed action are those used on a long-term or permanent basis. Irreversible resource 

commitments occur when there is unavoidable destruction of natural resources that could limit 

the range of potential uses of that particular environment. Irreversible commitments apply 

primarily to nonrenewable resources, such as cultural resources, and also to those resources that 

are renewable only over long periods, such as soil productivity or forest health. Irretrievable 

resource commitments occur when an action causes the use or consumption of a resource that is 

neither renewable nor recoverable for future use. Irretrievable commitments apply to loss of 

production, harvest, or use of natural resources. These include the use of nonrenewable resources 

such as metal, fuel, and other natural or cultural resources considered irretrievable, in that they 

would be used for the proposed action when they could have been conserved or used for other 

purposes.

No irreversible commitments of resources would result from the Forest Service providing 

consent to geothermal leasing. In addition, stipulations outlined under the action alternatives 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-173

would be applicable to future phases of leasing and development, and lessees would be required 

to complete a site-specific NEPA analysis outlining their proposed action and alternatives and the 

direct and indirect impacts associated with their proposed action, before any occupancy and 

surface disturbance. Nevertheless, anticipated future development actions that may follow 

leasing consistent with implementation of any of the alternatives discussed in Chapter 2 could 

result in a variety of irreversible and irretrievable commitments of resources, below.

3.25.1 Geologic Resources and Energy and Mineral Resources

The principal commitment of resources in implementing the proposed action would be the 

depletion of thermal energy and water from the geothermal reservoirs tapped for energy use. To 

minimize this impact, the super-hot water extracted from the subterranean geothermal reservoirs 

through production wells would be injected back into the reservoir for reheating and reuse. Over 

time, these resources (heat and water) could be depleted to the point that the power generating 

plant would no longer be economically productive.

3.25.2 Water Resources

Because of the large volume and long duration of geothermal fluid production, the production 

stage of resource development is likely to have the greatest potential for impact on hydrologic 

resources. These impacts could occur in terms of changes to the hydraulics of the geothermal and 

groundwater reservoirs and spent geothermal fluid disposal. The result could include a reduction 

in spring discharge rates and lowering of water levels in wells. Re-injecting spent geothermal 

fluids could also introduce low-quality fluids to groundwater pathways that discharge at springs 

or wells. This could also affect the quality of available water. Disposal of spent geothermal fluids 

on the surface could create large pools of low-quality water. Changes in spring flow and 

development of spent fluid-holding ponds could impact wetlands-supported ecosystems and 

habitats. As a result, hydrologic impacts associated with geothermal development could have 

secondary impacts in the plant and animal community supported by natural or created wetlands

3.25.3 Vegetation

Introduction of noxious weeds by construction and support vehicles into previously clean areas 

would be probable during all phases of geothermal development. The drilling and utilization 

phases would present the greatest opportunity for noxious weed introduction and proliferation. 

Once introduced, control or eradication of noxious weeds could be difficult.

3.25.4 Threatened and Endangered Species

Loss of any species is irretrievable. Protection of threatened, endangered, and special status 

species is governed by federal and state statute. To minimize the impacts on threatened, 

endangered, and special status species, lessees would be required to complete a site-specific 

NEPA analysis, outlining their proposed actions and alternatives, and the direct and indirect 

impacts of their proposed actions, on any threatened, endangered, and special status species 

before any occupancy and surface disturbance. Site-specific compliance with the ESA would 

occur at the time of development.

3.25.5 Visual Resources

Any changes in the characteristic landscape of the affected areas due to geothermal energy 

development could be visible for many years. Succession (change in habitat type over time, 

including the return of an area to its pre-development state after site reclamation/rehabilitation) 

in the project area is slow, due to generally low annual precipitation. Rehabilitation techniques 
Chapter 3. Affected Environment and Environmental Consequences

3-174 Santa Fe National Forest Geothermal Leasing EIS

could use nonindigenous plant species, thus changing the character of the area. The degree of 

contrast between a reclaimed project site and its untouched surroundings would vary by area, 

rehabilitation techniques, and the success of those techniques. All landscapes are unique in their 

own right, and any change or loss of scenic values is irretrievable. Those losses become more 

significant in areas of unique or outstanding scenic quality.

3.25.6 Hazardous Materials and Waste and Solid Waste

If handled improperly, hazardous materials and waste and solid waste have the potential to create 

irretrievable consequences. The transportation, storage, use, and disposal of hazardous materials 

and waste and solid waste are governed by federal and state statutes. To minimize the impacts of 

hazardous materials and waste and solid waste, lessees would be required to complete sitespecific NEPA analyses, outlining their proposed actions and alternatives and the direct and 

indirect impacts of hazardous materials and waste and solid waste associated with their proposed 

actions before any occupancy and surface disturbance.
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-1

Chapter 4. Consultation and Coordination

4.1 Preparers and Contributors

The Forest Service consulted the individuals, federal, state, and local agencies, tribes, and other 

organizations below during the development of this environmental impact statement.

4.1.1 Interdisciplinary Team Members

Santa Fe National Forest Interdisciplinary Team Members

Team Member Responsibility Education Years of Relevant 

Experience

Will Amy Wildlife Program Manager BS Natural Resource 

Sciences

17

Anne Baldwin Supervisory Archeologist BA Anthropology MA 

Cultural Anthropology

40

Christine Bishop Rangeland Program Manager BS Wildlife Biology

MS Rangeland Ecology

12

Michael Bremer Forest Archaeologist BA Anthropology MA 

Anthropology

40

Mathew Chavez Range Management 

Specialist

BS in Wildlife Science

BS in Range Science

6

Jennifer Cramer Social Interest, Economics, 

and Environmental Justice

BA Biology

PhD Plant Biology

6

Michael Frazier R/H/L/M/E Staff Officer BA Liberal Arts 

BS Forestry

44

Larry Gore Project Manager, Geologist BS Geology

MS Geology

26

Cliff Gibbons Safety and Occupational 

Health Specialist

BS Biology 17

Joshua Hall Air Quality Specialist MS Environmental 

Science 

MA Environmental 

Policy and Natural 

Resource Management

11

Lee Harrelson Forest Engineer BS Civil Engineering 31

Sandy Hurlocker NEPA Specialist BS Science Ed.

MS Journalism

25

Heidi Klingel Soils and Hydrology 

Specialist 

BS Earth Science

MS Geosciences

11

Julie Luetzelschwab Forest Resource Information 

Coordinator

BA, MA Environmental 

Geography

19

Steve Miranda Fire Management Specialist BS Rangeland 

Management

22

Cecil Rich Fish Biologist BS Biology

MS Fish Ecology

PhD Fisheries and 

Aquatic Science

20
Chapter 4. Consultation and Coordination

4-2 Santa Fe National Forest Geothermal Leasing EIS

EMPSi – Environmental Management and Planning Solutions, Inc. (Contractor)

Team Member Resource/Resource Program Education Years of 

Experience

David Batts Principal-in-Charge MS Natural Resource 

Planning

23

Kevin Rice Project Management, Biological 

Resources

BS Environmental 

Science

6 

Kevin Doyle Cultural Resources BA Sociology 30 

Nick Parker Land Use, Recreation, Special 

Designations, and 

Transportation and Access

MA Archaeology

BA Earth Science and 

Cultural Geography

16 

Katie Patterson Geologic Resources JD Environmental Law 7 

Alex Finch Geologic Resources JD Natural Resources 

Law and Policy

4 

Melissa Estep Soil and Water Resources BS Industrial & Systems 

Engineering

4 

Laura Patten Air Quality, Climate Change MS Environmental Law 

and Policy

5

Amy Cordle Air Quality, Climate Change BS Civil Engineering 18 

Daniel Robinson Biological Resources BS Wildlife Ecology and 

Conservation

10 

Kate Krebs Visual Resources BA Environmental 

Studies, Spanish

10 

Drew Vankat Health and Safety, Noise, MS Environmental Policy 

and Planning

11 

Zoe Ghali Social Interests, Economics, and 

Environmental Justice

MS Integrative Physiology 

(Environmental 

Physiology)

8 

Sarah Crump Social Interests, Economics, and 

Environmental Justice

BA Environmental 

Studies, Political Science

3 

Holly Prohaska Livestock Grazing/QA MS Environmental 

Management

15 

Marcia Rickey GIS MS Biology, Conservation 

Biology Sequence

15 

Jacob Accola GIS BA Environmental Design 2 

Cooperating Agency Team Members and Other Contributors 

Team Member Resource/Resource Program Education Years of 

Experience

Linda Dansby Energy and Minerals 

Coordinator, Intermountain 

Region, NPS

BS Biology 38

Fraser Goff Geothermal Consultant to the 

NPS

BS Chemistry

PhD Earth Sciences

41
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-3

Cooperating Agency Team Members and Other Contributors 

Team Member Resource/Resource Program Education Years of 

Experience

Ross Klein Natural Resource Specialist –

Minerals, BLM

BS Renewable Natural 

Resources

MS Rangeland Ecology 

and Management

8

Sheila Mallory Deputy State Director, BLM BS Geology

MS Economic Geology

15

Mark Meyer Renewable Energy Visual 

Resource Specialist, Air 

Resources Division, NPS

BS Design Landscape 

Architecture 

MS Natural Science

34

Robert Parmenter Biological Scientist/Division 

Chief, Science and Resource 

Stewardship, Valles Caldera, 

NPS

BA Biology

MS Zoology

PhD Biology/Ecology

42

Mark Peyton Wildlife Biologist/Technician, 

Valles Caldera National 

Preserve, NPS

MS Forestry

MS Wildlife Science

12

Ana Steffen Archaeologist, Valles Caldera 

National Preserve, NPS

BA Biology

MS Zoology

PhD Biology/Ecology

25

Randy Stanley Natural Sounds & Night Skies 

Coordinator, Intermountain 

Region, NPS

BSE Acoustical 

Engineering

M.Eng Acoustics

18

Martina Suazo Plant Ecologist/Technician, 

Valles Caldera National 

Preserve, NPS

BS Biology 5

John Swigart Cartographer, Valles Caldera 

National Preserve, NPS

BA Anthropology

MA Anthropology

20

4.1.2 Federal, State, and Local Agencies

• Bureau of Land Management

• National Park Service

4.1.3 Tribes

• Canoncito Navajo Chapter House

• Counselor Navajo Chapter House

• Crownpoint Navajo Chapter House

• Jicarilla Apache Nation

• Kewa Pueblo (Pueblo of Santo Domingo)

• Mescalero Apache Tribe

• Ohkay Owingeh

• Ojo Encino Navajo Chapter House

• Pueblo of Acoma
Chapter 4. Consultation and Coordination

4-4 Santa Fe National Forest Geothermal Leasing EIS

• Pueblo of Cochiti

• Pueblo of Isleta

• Pueblo of Jemez

• Pueblo of Laguna

• Pueblo of Nambé

• Pueblo of Picuris

• Pueblo of Pojoaque

• Pueblo of San Felipe

• Pueblo of San Ildefonso

• Pueblo of Santa Ana

• Pueblo of Santa Clara

• Pueblo of Taos

• Pueblo of Tesuque

• Pueblo of Zia

• Pueblo of Zuni

• Pueblo Pintado Navajo Chapter House

• Ramah Navajo Chapter House

• Southern Ute Tribe

• The Hopi Tribe

• The Navajo Nation

• Torreon Navajo Chapter House

• Ute Mountain Ute Tribe

• Whitehorse Lake Navajo Chapter House

4.1.4 Others

• Los Alamos National Laboratory 

4.2 List of Agencies, Organizations and Persons Who Were 

Sent Copies of the DEIS

4.2.1 Federal

• Advisory Council on Historic Preservation

• USDA, Animal and Plant Health Inspection Service

• USDA, Natural Resources Conservation Service

• USDA, National Agriculture Library

• National Oceanic and Atmospheric Administration

• US Army Corps of Engineers

• US Environmental Protection Agency 

• Department of Energy

• Department of Interior, Office of Environmental Policy and Compliance
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-5

• Federal Aviation Administration

• US Department of Transportation, Federal Highway Administration

In addition, all individual, organizations, and agencies on the project mailing list received

notification of the availability of the DEIS.
Chapter 4. Consultation and Coordination

4-6 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-1

Chapter 5. Glossary

Allotment: An area of land where one or more operators graze their livestock. It generally 

consists of public lands but may include parcels of private or state-owned lands. The number of 

livestock and period of use are stipulated for each allotment.

Animal unit month (AUM): The amount of forage necessary for the sustenance of one cow or 

its equivalent for a period of one month (approximately 800 pounds of air-dried material per 

AUM). A full AUM’s fee is charged for each month of grazing by adult animals if the grazing 

animal 1) is weaned, 2) is six months or older when entering public land, or 3) will become 12 

months old during the period of use. For fee purposes, an AUM is the amount of forage used by 

five weaned or adult sheep or goats or one cow, bull, steer, heifer, horse, or mule. The term AUM 

is commonly used in three ways: 1) stocking rate, as in X acres per AUM, 2) forage allocation, 

as in X AUMs in allotment A, and 3) utilization, as in X AUMs consumed from Unit B.

Assessment: The act of evaluating and interpreting data and information for a defined purpose.

Best management practices (BMPs): A suite of techniques that guide, or may be applied to, 

management actions to aid in achieving desired outcomes. 

Buffer: An area of specified width where certain activities may not occur. Buffers are usually 

defined around special sensitive resources, such as archaeological sites, or along each side of a 

stream, or near other features to be protected from human disturbance. 

Controlled surface use (CSU): The CSU stipulation is intended for application where standard 

lease terms and permit-level decisions are deemed insufficient to achieve the level of resource 

protection necessary to protect the public interest, but where an NSO is deemed overly 

restrictive. A CSU stipulation requires that a proposed facility or activity be relocated by more 

than 200 meters from the proposed location if necessary to achieve the desired level of 

protection. A CSU is not required if relocating a proposed facility or activity by up to 200 meters 

would be sufficient to protect the specified resources.

Condition of approval: A site-specific and enforceable requirement included in an approved 

application for permit to drill or sundry notice that may limit or amend the specific actions 

proposed by the operator. Conditions of approval minimize, mitigate, or prevent impacts on

resource values or other uses of public lands.

Direct use: Use of geothermal resources for commercial, residential, agricultural, or public 

facilities or for energy needs other than the commercial production of electricity.

Endangered species: As defined in the federal Endangered Species Act, any species that is in 

danger of extinction throughout all or a significant portion of its range. For terrestrial species, the 

US Fish and Wildlife Service determines endangered status.

Environmental impact statement (EIS): A written analysis of the impacts on the natural, 

social, and economic environment of a proposed project or resource management plan.

Erosion: The wearing away of the land surface by rain or irrigation water, wind, ice, or other 

natural or human agents that abrade, detach, and remove geologic parent material or soil from 

one point on the earth’s surface and deposit it elsewhere.
Chapter 5. Glossary

5-2 Santa Fe National Forest Geothermal Leasing EIS

Exception: A one-time exemption for a particular site in a leasehold. Exceptions are determined 

on a case-by-case basis, and the stipulation continues to apply to all other sites in the leasehold. 

An exception is a limited type of waiver.

Federal land: Land owned by the United States without reference to how the land was acquired 

or which federal agency administers it, including mineral and coal estates underlying private 

surface.

Geographic information system (GIS): A computer system capable of storing, analyzing, and 

displaying data and describing places on the earth’s surface.

Geothermal energy: Natural heat from within the earth, captured for production of electric 

power, space heating, or industrial steam.

Geothermal plant: A plant powered by a steam turbine. The turbine is driven either by steam 

produced from hot water or by natural steam that derives its energy from heat found in rocks or 

fluids at various depths beneath the surface of the earth. The energy is extracted by drilling or 

pumping.

Hot dry rock: A type of geothermal technology that refers to the formation of a fully engineered 

geothermal reservoir in hot crystalline rock by the application of hydraulic fracturing and 

subsequent circulation of water through that engineered reservoir to mine the thermal energy 

from the hot rock.

Indirect use: Commercial electrical generation from geothermal resources.

Invertebrates: Animals without back bones.

Known geothermal resource area (KGRA): A region identified by the US Geological Survey 

as containing geothermal resources. New leasing regulations no longer use KGRAs as a basis for 

the leasing process.

Lease stipulation: A condition of lease issuance that provides a level of protection for other 

resource values or land uses by restricting lease operations during certain times or locations or to 

avoid unacceptable impacts, to an extent greater than standard lease terms or regulations. A 

stipulation is an enforceable term of the lease contract, supersedes any inconsistent provisions of 

the standard lease form, and is attached to and made a part of the lease. Lease stipulations further 

implement the Forest Service’s regulatory authority to protect resources or resource values. 

Lease stipulations are developed through the land use planning process.

Locatable mineral: A mineral subject to location under the 1872 Mining Laws. Examples of 

such minerals are gold, silver, copper, and lead, as compared to oil and natural gas, which are 

leasable minerals.

Modification: A change to the provisions of a lease stipulation, either temporarily or for the 

term of the lease. Depending on the specific modification, the stipulation may or may not apply 

to all sites within the leasehold to which the restrictive criteria are applied.

National Environmental Policy Act (NEPA) of 1969: A law enacted on January 1, 1970, that 

established a national policy to maintain conditions under which humans and nature can exist in 

productive harmony and fulfill the social, economic, and other requirements of present and 

future generations of Americans. It established the Council on Environmental Quality for 
Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-3

coordinating environmental matters at the federal level and to serve as the advisor to the 

president on such matters. The law made all federal actions and proposals that could have 

significant impact on the environment subject to review by federal, state, and local 

environmental authorities.

Native (indigenous) species: A species of plant or animal that naturally occurs in an area and 

that was not introduced by humans.

National Forest System lands: Forests and grasslands that the Forest Service manages. Includes 

both lands reserved from the federal estate and acquired lands. 

No surface occupancy (NSO): A fluid minerals leasing constraint that prohibits occupancy or 

disturbance on all or part of the lease surface to protect special values or uses. Lessees may 

exploit the fluid mineral resources under the leases restricted by this constraint through the use 

of directional drilling from sites outside the NSO area.

Open: Generally denotes that an area is available for a particular use or uses. Refers to specific 

program definitions found in law, regulations, or policy guidance for application to individual 

programs. For example, 43 CFR, Subpart 8340.0-5, defines the specific meaning of open as it 

relates to off-highway vehicle use.

Permitted use: The forage allocated by, or under the guidance of, an applicable land use plan for 

livestock grazing in an allotment under a permit or lease, expressed in AUMs (43 CFR, Subpart

4100.0-5).

Project area: Potential geothermal leasing areas on National Forest Service lands that were 

identified for the analysis to determine consent to leasing.

Renewable energy: Resources that constantly renew themselves or that are regarded as 

practically inexhaustible. Examples are solar, wind, geothermal, hydro, and wood. Although 

particular geothermal formations can be depleted, the natural heat in the earth is a virtually 

inexhaustible reserve of potential energy. Renewable resources also include some experimental 

or less developed sources, such as tidal power, sea currents, and ocean thermal gradients.

Right-of-way: An easement or permit that authorizes public land to be used for a specified 

purpose that generally requires a long narrow strip of land. Examples are roads, power lines, and 

pipelines.

Seismic exploration: This remains the most common way to locate subsurface resources. The 

process involves sending sound waves into the earth at one point and recording them at other

points after they have passed through different geological strata. There are two common methods 

used today. The first involves the detonation of small explosive charges; the other consists of a 

truck that drops a huge weight at various intervals. The data collected is used to show probable 

subsurface resource deposits.

Site visit: The entry of one person on a site or area to participate in recreation for an unspecified 

period.

Special status species: Includes proposed species, listed species, and candidate species under 

the ESA and Forest Service sensitive species, as defined in Forest Service Manual 2670.5 as 

“those plant and animal species identified by a Regional Forester for which population viability 

is a concern, as evidenced by 1) significant current or predicted downward trends in population 
Chapter 5. Glossary

5-4 Santa Fe National Forest Geothermal Leasing EIS

numbers or density, or 2) significant current or predicted downward trends in habitat capability 

that would reduce a species’ existing distribution”

Standard lease terms and conditions: Areas may be open to leasing with no specific 

management decisions; however, these areas are subject to lease terms and conditions, as defined 

on the lease form (Form 3100-11, Offer to Lease and Lease for Oil and Gas; and Form 3200-24, 

Offer to Lease and Lease for Geothermal Resources).

State implementation plan: A strategic document, prepared by a state or other authorized air 

quality regulatory agency and approved by the US Environmental Protection Agency, which 

thoroughly describes how requirements of the Clean Air Act will be implemented, including 

standards to be achieved, control measures to be applied, and enforcement actions in case of 

violation.

Stipulation: A condition of lease issuance that provides protection for other resource values or 

land uses by establishing authority for substantial delay or site changes or the denial of 

operations within the terms of the lease contract.

Stipulation standards: The physical and temporal conditions, resources, or resource values that 

must be present and met for application of a specific stipulation to a specific lease.

Tectonic: A field of study in geology concerned generally with the structure of the crust of the 

earth and particularly with the forces and movements that have operated in a region to create 

geomorphic features. 

Timing limitation (TL): This stipulation limits activity during a specified period of the year. A 

TL stipulation is intended for application where standard lease terms are deemed insufficient to 

achieve the level of resource protection necessary to protect the public interest, but where an 

NSO is deemed overly restrictive. The scope of the TL stipulation goes beyond grounddisturbing activities to encompass any source of protracted or high-intensity disturbance that 

could interfere with normal wildlife behavior and adversely affect habitat use. The limitation is 

applied annually for a specified period lasting more than 60 days. Under the proposed plan, TLs 

may also be applied to land uses and activities other than oil and gas development.

Transmission: The movement or transfer of electric energy over an interconnected group of 

lines and associated equipment between points of supply and points where it is transformed for 

delivery to consumers or is delivered to other electric systems. Transmission is considered to end 

when the energy is transformed for distribution to the consumer.

Threatened species: 1) Any species that is likely to become endangered within the foreseeable 

future throughout all or a significant portion of its range, and 2) as further defined by the 

Endangered Species Act of 1973.

Tribal interests: Native American or Native Alaskan economic rights, such as Indian trust 

assets, resource uses and access guaranteed by treaty rights, and subsistence uses. 

Traditional cultural resources or properties: Areas of cultural importance to contemporary 

communities, such as sacred sites or resource gathering areas. 

Utility: A regulated entity that exhibits the characteristics of a natural monopoly. For the 

purposes of electric industry restructuring, it refers to a regulated, vertically integrated electric 

company. Transmission utility refers to the regulated owner or operator of the transmission 
Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-5

system only. Distribution utility refers to the regulated owner or operator of the distribution 

system that serves retail customers.

Vertebrate: Animals with back bones, including fish, amphibians, reptiles, birds, and mammals.

Waiver: A permanent exemption from a lease stipulation that no longer applies anywhere within 

the leasehold.

Watershed:

• First Level: The first level of classification divides the nation into 21 major geographic 

areas, or regions. These geographic areas contain either the drainage area of a major river, or 

the combined drainage areas of a series of rivers.

• Second Level: The second level of classification divides the 21 regions into 221 subregions. 

A subregion includes the area drained by a river system, a reach of a river and its tributaries 

in that reach, a closed basin(s), or a group of streams forming a coastal drainage area. 

• Third Level: The third level of classification subdivides may of the subregions into 

accounting units. These 378 hydrologic accounting units are nested within, or can be 

equivalent to the subregions.

• Fourth Level: The four level of classification is the cataloging unit. A cataloging unit is a 

geographic area representing part of or all of a surface drainage basin, a combination of 

drainage basins, or distinct hydrologic feature. These units subdivide the subregions and 

accounting units into smaller areas. There are 2,264 cataloging units in the Nation.

Watt: The electrical unit of power. The rate of energy transfer equivalent to 1 ampere flowing 

under a pressure of 1 volt at unity power factor.

Watt-hour: An electrical energy unit of measure equal to 1 watt of power supplied to, or taken 

from, an electric circuit steadily for 1 hour.

Wilderness area: An area of public land designated by an act of Congress to be protected in its 

natural condition according to the requirements of the Wilderness Act of 1964.
Chapter 5. Glossary

5-6 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 6. References

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Chapter 7. Index

Santa Fe National Forest Geothermal Leasing EIS 7-1

Chapter 7. Index

Adaptive management, 1-21, 2-5, 2-13, 3-21

Air quality, 1-9, 1-19, 2-18, 2-19, 2-18, 

2-25, 3-53, 3-54, 3-56, 3-57, 3-58, 3-60, 

3-61, 3-62, 3-63, 3-65, 3-67, 3-68, 3-69, 

3-70, 3-71, 3-131, 3-136, 3-151, 3-152, 

3-155, 3-166, 3-167, 3-168, 3-170, 4-1, 

4-2, 5-4

Air Quality-Related Values, 1-19, 2-18, 

3-53, 3-60, 3-61, 3-62, 3-63, 3-65, 3-70

Area of Critical Environmental Concern 

(ACEC), 1-18, 3-12

Best management practice (BMP), 1-1, 1-2, 

1-14, 1-15, 1-16, 2-1, 2-2, 2-3, 2-4, 2-16, 

2-18, 2-24, 2-25, 3-2, 3-21, 3-22, 3-30, 

3-31, 3-35, 3-49, 3-51, 3-52, 3-53, 3-61, 

3-65, 3-66, 3-67, 3-69, 3-71, 3-75, 3-76, 

3-77, 3-85, 3-89, 3-109, 3-110, 3-139, 

3-151, 3-155, 3-158, 3-166, 3-167, 3-169, 

3-170, 5-1

Bighorn sheep, Rocky Mountain, 3-77, 3-78, 

3-85

Birds, migratory, 2-4, 3-73, 3-77, 3-78, 

3-80, 3-81, 3-87, 3-89, 3-108, 3-109, 

3-111

Candidate species, 5-3

Canones Creek, 3-10, 3-11, 3-14, 3-15, 3-94, 

3-95

Cheatgrass, 3-73

Clean Water Act, 3-41

Council on Environmental Quality (CEQ), 

1-15, 3-1, 3-2, 3-3, 3-145, 3-148, 5-2

County, Rio Arriba, 1-3, 3-58, 3-92, 3-141, 

3-142, 3-143, 3-144, 3-145, 3-146, 3-147, 

3-151, 3-165

County, Sandoval, 3-7, 3-57, 3-58, 3-59, 

3-140, 3-141, 3-142, 3-143, 3-144, 3-145, 

3-146, 3-147, 3-150, 3-151, 3-165, 3-172

Coyote Creek, 3-39, 3-43, 3-73

Deer, mule, 3-9

Eagle, bald, 3-92

Elk, 2-4, 2-9, 2-11, 2-13, 3-9, 3-78, 3-85, 

3-89

Endangered species, 2-20, 2-21, 3-89, 3-103, 

3-104, 3-111, 5-1

Endangered Species Act (ESA), 2-7, 2-10, 

2-13, 2-21, 3-78, 3-80, 3-81, 3-89, 3-91, 

3-94, 3-173, 5-1, 5-3, 5-4

Environmental justice, 2-24, 3-140, 3-145, 

3-148, 3-149, 3-151, 3-152, 3-153

Exploration wells, 3-62, 3-64, 3-66, 3-67

Federal Land Policy and Management Act 

(FLPMA), 1-1, 1-7, 1-13, 3-6, 3-22, 3-27

Fire management, 3-15, 3-76, 3-85, 3-155, 

3-163

Fire regime, 3-73

Forest Service, 1-1, 1-2, 1-5, 1-6, 1-8, 1-9, 

1-11, 1-13, 1-14, 1-15, 1-17, 1-18, 1-21, 

2-1, 2-2, 2-3, 2-4, 2-5, 2-6, 2-7, 2-8, 2-9, 

2-10, 2-11, 2-12, 2-13, 2-16, 3-2, 3-4, 3-5, 

3-6, 3-7, 3-8, 3-9, 3-10, 3-11, 3-12, 3-13, 

3-15, 3-16, 3-17, 3-20, 3-22, 3-27, 3-28, 

3-29, 3-30, 3-31, 3-32, 3-33, 3-34, 3-35, 

3-38, 3-40, 3-41, 3-42, 3-43, 3-45, 3-47, 

3-50, 3-57, 3-60, 3-61, 3-62, 3-65, 3-66, 

3-68, 3-71, 3-72, 3-73, 3-74, 3-75, 3-77, 

3-78, 3-80, 3-82, 3-83, 3-89, 3-91, 3-92, 

3-93, 3-94, 3-95, 3-96, 3-97, 3-100, 

3-101, 3-102, 3-103, 3-104, 3-112, 3-113, 

3-115, 3-117, 3-118, 3-119, 3-120, 3-121, 

3-124, 3-125, 3-128, 3-131, 3-133, 3-135, 

3-136, 3-139, 3-140, 3-145, 3-148, 3-149, 

3-150, 3-152, 3-154, 3-156, 3-158, 3-159, 

3-160, 3-161, 3-162, 3-167, 3-168, 3-172, 

4-1, 5-2, 5-3

Fuel load, 3-72

Fugitive dust, 2-18, 3-15, 3-16, 3-60, 3-62, 

3-63, 3-64, 3-65, 3-67, 3-69, 3-75, 3-104

Geothermal development, 1-7, 1-9, 1-11, 

1-18, 1-21, 2-1, 2-5, 2-8, 2-9, 2-11, 2-12, 

2-13, 2-15, 2-16, 2-16, 2-17, 2-18, 2-19, 

2-20, 2-21, 2-22, 2-23, 2-22, 2-23, 2-24, 

2-25, 3-5, 3-10, 3-13, 3-17, 3-18, 3-19, 

3-21, 3-22, 3-24, 3-25, 3-26, 3-27, 3-29, 

3-30, 3-31, 3-34, 3-35, 3-36, 3-48, 3-51, 

3-53, 3-57, 3-61, 3-62, 3-70, 3-74, 3-75, 

3-77, 3-82, 3-83, 3-84, 3-86, 3-87, 3-89, 

3-103, 3-105, 3-106, 3-107, 3-108, 3-109, 

3-110, 3-112, 3-115, 3-116, 3-120, 3-121, 

3-122, 3-123, 3-128, 3-129, 3-130, 3-135, 

3-136, 3-137, 3-138, 3-139, 3-140, 3-150, 

3-151, 3-152, 3-153, 3-154, 3-155, 3-156, 

3-158, 3-161, 3-166, 3-167, 3-168, 3-170, 

3-171, 3-173
Chapter 7. Index

7-2 Santa Fe National Forest Geothermal Leasing EIS

Geothermal exploration, 1-2, 1-9, 1-15, 

1-16, 1-18, 1-19, 2-17, 2-23, 3-2, 3-14, 

3-15, 3-18, 3-22, 3-35, 3-45, 3-51, 3-59, 

3-61, 3-62, 3-63, 3-64, 3-70, 3-104, 

3-115, 3-124, 3-137, 3-138, 3-153, 3-158, 

3-167, 3-168

Geothermal power plant, 1-6, 1-11, 2-26, 

2-25, 3-3, 3-27, 3-61, 3-63, 3-67, 3-68, 

3-70, 3-140, 3-149, 3-151, 3-157, 3-166, 

3-169, 3-170

Geothermal Programmatic EIS, 1-1, 1-2, 

1-3, 1-5, 1-6, 1-8, 1-9, 1-14, 1-15, 1-16, 

1-21, 2-1, 2-4, 2-5, 2-21, 3-2, 3-7, 3-8, 

3-13, 3-19, 3-29, 3-34, 3-48, 3-61, 3-62, 

3-74, 3-83, 3-103, 3-104, 3-115, 3-121, 

3-128, 3-129, 3-135, 3-149, 3-150, 3-153, 

3-154, 3-156, 3-157, 3-161, 3-166

Geothermal reservoir, 1-3, 1-6, 1-11, 3-19, 

3-22, 3-44, 3-173, 5-2

Geothermal resource, 1-1, 1-2, 1-3, 1-6, 1-7, 

1-8, 1-9, 1-11, 1-15, 2-1, 2-3, 2-4, 2-10, 

2-13, 2-18, 2-23, 2-25, 3-1, 3-2, 3-13, 

3-15, 3-19, 3-22, 3-23, 3-24, 3-25, 3-27, 

3-29, 3-31, 3-52, 3-63, 3-64, 3-66, 3-74, 

3-82, 3-104, 3-115, 3-127, 3-128, 3-129, 

3-130, 3-131, 3-135, 3-138, 3-149, 3-154, 

3-161, 3-162, 3-167, 3-169, 3-170, 3-171, 

5-1, 5-2

Geothermal system, 1-9, 1-13, 1-19, 2-14, 

2-15, 3-19, 3-20, 3-21, 3-44, 3-45, 3-47, 

3-49, 3-50

Grazing, allotment, 1-19, 2-21, 3-112, 

3-113, 3-116, 3-126, 5-1, 5-3

Greenhouse Gases, 1-20, 2-25, 2-26, 2-25, 

3-69, 3-164, 3-165, 3-166, 3-167, 3-169, 

3-170, 3-171, 3-172

Ground disturbance, 3-2, 3-16, 3-49, 3-106, 

3-107, 3-108, 3-115, 3-119, 3-127

Inventoried Roadless Areas, 1-18, 2-8, 2-11, 

3-9

Jemez National Recreation Area, 1-3, 1-18, 

1-21, 2-1, 2-6, 2-7, 2-8, 2-9, 2-10, 2-15, 

2-16, 2-19, 2-20, 2-21, 2-22, 2-23, 3-10, 

3-11, 3-12, 3-13, 3-14, 3-15, 3-22, 3-30, 

3-32, 3-38, 3-40, 3-50, 3-75, 3-83, 3-94, 

3-95, 3-104, 3-107, 3-115, 3-116, 3-118, 

3-122, 3-129, 3-137, 3-138, 3-150, 3-156

Jemez River, 2-7, 3-4, 3-12, 3-14, 3-15, 

3-17, 3-22, 3-36, 3-38, 3-39, 3-40, 3-43, 

3-73, 3-94, 3-107, 3-125

Leasing, geothermal, 1-1, 1-2, 1-7, 1-8, 1-9, 

1-13, 1-14, 1-15, 1-18, 1-19, 1-20, 1-21, 

1-22, 2-1, 2-5, 2-6, 2-7, 2-9, 2-10, 2-12, 

2-13, 2-15, 2-16, 2-17, 2-19, 2-20, 2-21, 

2-22, 2-23, 2-25, 3-1, 3-2, 3-3, 3-6, 3-12, 

3-13, 3-14, 3-15, 3-18, 3-21, 3-22, 3-25, 

3-26, 3-30, 3-31, 3-34, 3-35, 3-47, 3-50, 

3-51, 3-52, 3-61, 3-62, 3-70, 3-73, 3-74, 

3-75, 3-76, 3-77, 3-82, 3-83, 3-88, 3-103, 

3-104, 3-113, 3-115, 3-116, 3-119, 3-122, 

3-123, 3-126, 3-127, 3-128, 3-129, 3-130, 

3-133, 3-137, 3-139, 3-148, 3-150, 3-151, 

3-152, 3-153, 3-155, 3-158, 3-160, 3-162, 

3-163, 3-166, 3-169, 3-172, 5-3

Leasing, oil and gas, 3-22, 3-25

Leasing, terms and stipulations, 1-9

Listed species, see Threatened and 

endangered species, 2-7, 2-10, 3-91, 

3-111, 5-3

Mexican Spotted Owl, 1-19, 2-9, 2-11, 3-78, 

3-80, 3-87, 3-90, 3-91, 3-92, 3-93, 3-103, 

3-106, 3-112

Minerals, entry, 3-22

Minerals, fluid, 5-3

Minerals, locatable, 3-22

Mining Law of 1872, 3-22

National Ambient Air Quality Standards, 

3-54, 3-56, 3-57, 3-58, 3-70

National Environmental Policy Act of 1969 

(NEPA), 1-1, 1-2, 1-8, 1-14, 1-15, 1-16, 

1-18, 2-3, 2-6, 2-12, 2-15, 2-16, 2-19, 

2-20, 2-21, 2-24, 2-25, 3-1, 3-13, 3-15, 

3-16, 3-19, 3-20, 3-21, 3-26, 3-27, 3-30, 

3-31, 3-35, 3-50, 3-66, 3-69, 3-75, 3-83, 

3-104, 3-117, 3-121, 3-122, 3-127, 3-129, 

3-135, 3-137, 3-149, 3-150, 3-153, 3-155, 

3-158, 3-161, 3-162, 3-169, 3-171, 3-173, 

3-174, 4-1, 5-2

National Park Service (NPS), 1-15, 1-18, 

1-21, 3-5, 3-7, 3-8, 3-11, 3-15, 3-118, 

3-131, 3-133, 3-136, 3-139, 3-140, 3-156, 

3-158, 3-162, 4-2, 4-3

National Register of Historic Places 

(NRHP), 2-2, 2-8, 2-10, 2-22, 3-117, 

3-118, 3-119, 3-120, 3-122, 3-123, 3-124, 

3-130

National Wild and Scenic Rivers System 

(NWSRS), 3-11

Nonattainment area, 3-58, 3-61

Off-highway vehicle (OHV), 3-159, 5-3

Old growth, 3-72, 3-73
Chapter 7. Index

Santa Fe National Forest Geothermal Leasing EIS 7-3

Old Spanish National Historic Trail, 3-11

Ozone (O3), 3-53, 3-54, 3-55, 3-58, 3-60, 

3-70, 3-165

Particulate matter (PM2.5, PM10), 3-54, 3-56, 

3-58, 3-59, 3-64, 3-65, 3-66, 3-68, 3-69

Phosphate, 3-49

Plants, invasive, 3-73, 3-85

Proposed species, 2-7, 2-10, 3-81, 3-89, 

3-104, 5-3

Public access, 1-20, 3-13

Raptor, 2-4, 3-73, 3-89, 3-108, 3-109, 3-111

Reasonably Foreseeable Development 

Scenario (RFDS), 1-2, 1-15, 2-1, 2-10, 

2-13, 2-14, 2-18, 2-19, 2-20, 3-1, 3-2, 

3-24, 3-26, 3-27, 3-34, 3-36, 3-48, 3-50, 

3-58, 3-61, 3-63, 3-64, 3-65, 3-66, 3-67, 

3-68, 3-69, 3-70, 3-74, 3-75, 3-82, 3-83, 

3-105, 3-106, 3-108, 3-109, 3-110, 3-116, 

3-119, 3-122, 3-123, 3-127, 3-129, 3-131, 

3-135, 3-138, 3-149, 3-150, 3-151, 3-161, 

3-167, 3-168, 3-169, 3-170, 3-171, 3-172

Record of Decision (ROD), 1-1, 1-15, 2-2, 

3-159, 3-160

Redondo Creek, 3-73

Renewable energy, 1-2, 3-22, 3-27, 3-171, 

5-3

Rights-of-way (ROW), 2-4, 2-24, 3-6, 3-7, 

3-12, 3-155, 3-156, 5-3

Rio Cebolla, 3-39, 3-41, 3-42, 3-43, 3-73, 

3-92, 3-94, 3-95, 3-96, 3-101, 3-106

Rio Chama, 3-12, 3-16, 3-17, 3-36, 3-38, 

3-39, 3-40, 3-41, 3-43, 3-46, 3-76, 3-82, 

3-88, 3-111, 3-125

Rio Grande, 1-19, 2-21, 3-16, 3-17, 3-23, 

3-36, 3-38, 3-39, 3-40, 3-41, 3-43, 3-44, 

3-46, 3-50, 3-76, 3-78, 3-80, 3-82, 3-86, 

3-88, 3-90, 3-91, 3-93, 3-94, 3-107, 

3-111, 3-125

Rio Grande Cutthroat Trout, 1-19, 2-21, 

3-78, 3-80, 3-86, 3-87, 3-88, 3-90, 3-94, 

3-95, 3-103, 3-107, 3-111

Rio Guadalupe, 3-94

Rio Puerco, 3-39, 3-41, 3-42, 3-43, 3-94, 

3-95

San Antonio Creek, 2-8, 2-11, 3-38, 3-39, 

3-42, 3-43, 3-73, 3-92, 3-94, 3-101, 

3-106, 3-107

Sensitive species, 3-10, 3-78, 3-80, 3-82, 

3-89, 3-91, 3-92, 3-94, 3-104, 3-111, 

3-112, 5-3

Snowmobile, 3-9

Socioeconomics, 2-24, 3-1, 3-140, 3-148, 

3-149, 3-151, 3-152

Soils, erodible, 3-34, 3-49

Stipulation, Controlled surface use (CSU), 

1-21, 2-2, 2-3, 2-4, 2-5, 2-6, 2-8, 2-9, 

2-11, 2-12, 2-15, 2-16, 2-19, 2-23, 2-24, 

2-25, 3-1, 3-14, 3-16, 3-26, 3-30, 3-31, 

3-35, 3-51, 3-52, 3-74, 3-76, 3-89, 3-111, 

3-112, 3-116, 3-122, 3-123, 3-129, 3-130, 

3-137, 3-138, 3-139, 3-140, 3-152, 5-1

Stipulation, No surface occupancy (NSO), 

1-21, 2-2, 2-3, 2-4, 2-5, 2-6, 2-7, 2-8, 2-9, 

2-10, 2-11, 2-12, 2-13, 2-15, 2-16, 2-17, 

2-19, 2-22, 2-23, 2-24, 2-25, 3-1, 3-14, 

3-15, 3-16, 3-26, 3-30, 3-31, 3-35, 3-51, 

3-52, 3-74, 3-76, 3-77, 3-82, 3-83, 3-84, 

3-86, 3-89, 3-103, 3-105, 3-106, 3-107, 

3-108, 3-109, 3-110, 3-111, 3-112, 3-116, 

3-122, 3-123, 3-129, 3-130, 3-137, 3-138, 

3-139, 3-140, 3-149, 3-152, 5-1, 5-3, 5-4

Stipulation, Timing limitation (TL), 1-21, 

2-2, 2-3, 2-4, 2-5, 2-6, 2-9, 2-11, 2-12, 

2-13, 2-15, 2-19, 2-20, 2-24, 2-25, 3-1, 

3-14, 3-16, 3-26, 3-30, 3-82, 3-85, 3-87, 

3-89, 3-103, 3-106, 3-108, 3-112, 3-122, 

3-123, 3-129, 3-130, 3-139, 3-140, 3-152, 

3-161, 3-162, 5-4

Surface disturbance, 2-13, 2-16, 2-17, 3-2, 

3-29, 3-62, 3-63, 3-64, 3-65, 3-66, 3-67, 

3-69, 3-70, 3-84, 3-86, 3-87, 3-110, 

3-123, 3-130, 3-170, 3-173, 3-174

Surface water, 1-9, 1-19, 2-17, 3-34, 3-38, 

3-41, 3-42, 3-44, 3-46, 3-47, 3-48, 3-49, 

3-50, 3-51, 3-52, 3-53, 3-83

Threatened and endangered species, 1-14, 

1-19, 2-20, 3-103, 3-104, 3-111

Threatened species, 5-4

Timber harvest, 3-70, 3-93, 3-100

Travel management, 3-13, 3-159, 3-160, 

3-162

Travel, motorized, 3-159

Utility corridor, 1-13, 1-14, 3-26

Vegetation, invasive species/noxious weed, 

3-73, 3-74, 3-75, 3-76, 3-110, 3-173

Vegetation, Riparian, 2-8, 2-10, 2-19, 3-9, 

3-15, 3-40, 3-42, 3-49, 3-51, 3-73, 3-75, 

3-78, 3-80, 3-81, 3-83, 3-84, 3-86, 3-88, 

3-92, 3-93, 3-95, 3-99, 3-100, 3-101, 

3-105, 3-106, 3-107, 3-108, 3-109, 3-110, 

3-111, 3-112, 3-164
Chapter 7. Index

7-4 Santa Fe National Forest Geothermal Leasing EIS

Vegetation, wetlands, 2-8, 2-10, 3-4, 3-36, 

3-42, 3-48, 3-51, 3-53, 3-75, 3-82, 3-83, 

3-84, 3-86, 3-92, 3-105, 3-106, 3-107, 

3-108, 3-109, 3-110, 3-111, 3-173

Visual resources, 1-20, 1-21, 2-23, 3-126, 

3-131, 3-133, 3-135, 3-137, 3-138, 3-140, 

3-149, 3-172, 3-173, 4-2, 4-3

Water quality, 1-9, 1-13, 1-19, 3-41, 3-47, 

3-48, 3-49, 3-50, 3-52, 3-53, 3-78, 3-80, 

3-83, 3-95, 3-126, 3-155

Water, groundwater, 1-13, 2-17, 3-16, 3-19, 

3-38, 3-44, 3-45, 3-46, 3-47, 3-48, 3-49, 

3-50, 3-51, 3-53, 3-83, 3-84, 3-87, 3-107, 

3-173

Water, rights, 2-8, 2-10, 3-48, 3-50, 3-51, 

3-84, 3-87, 3-107, 3-128

Water, surface water, 1-9, 1-19, 2-17, 3-34, 

3-38, 3-41, 3-42, 3-44, 3-46, 3-47, 3-48, 

3-49, 3-50, 3-51, 3-52, 3-53, 3-83

Watershed, 1-13, 2-17, 3-4, 3-7, 3-35, 3-36, 

3-37, 3-38, 3-39, 3-40, 3-41, 3-42, 3-43, 

3-45, 3-46, 3-47, 3-48, 3-49, 3-50, 3-51, 

3-52, 3-53, 3-72, 3-74, 3-76, 3-88, 3-111, 

5-5

Wilderness Characteristics, 1-18, 2-13, 3-12

Wildland fire, 3-60, 3-73, 3-75, 3-77, 3-80, 

3-95, 3-102, 3-108, 3-110, 3-153, 3-154, 

3-165

Withdrawal, 1-13, 1-21, 2-7, 2-17, 3-6, 3-19, 

3-35, 3-51, 3-52, 3-83, 3-84, 3-87, 3-107
Appendix A

Management Areas and Prescriptions 

from Forest Plan
This page intentionally left blank.
Appendix A. Management Areas and Prescriptions from Forest Plan

Santa Fe National Forest Geothermal Leasing EIS A-1

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

A 52,500 Emphasis is on timber production 

and enhancement of wildlife habitat 

diversity, consistent with other 

resource integration. Grazing 

capacity is generally transitory in 

nature, but there are allotments in 

intermingled grasslands. Roaded 

dispersed recreation experiences 

are emphasized. Firewood is 

provided as a by-product of timber 

harvesting.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

B 14,100 The emphasis in this area is on 

wildlife habitat improvement and 

key species habitat protection. 

Grazing and timber harvesting

occur where they are compatible 

with the primary emphasis of this 

area. Recreation is mostly of a 

dispersed roaded nature. Timber 

harvesting slash will be provided for 

wildlife and firewood.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

C 1,200 Emphasis is on enhancing visual 

quality and developed recreation 

opportunities, while protecting 

essential wildlife habitat and riparian 

zones. Grazing and timber 

harvesting occur where consistent 

with the primary emphasis of this 

area.

G04 –

mineral

leasing 

category: 

Limited Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

D <100 Emphasis is on enhancing visual 

quality and developed recreation 

opportunity. Grazing and timber 

harvesting occur where they are 

consistent with the primary 

emphasis of this area.

G04 –

mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

E 17,700 Emphasis is on providing dispersed 

recreation opportunities, 

maintaining visual quality, and 

harvesting timber and firewood. 

Grazing activities vary in intensity 

over this area. Emphasis is on 

maintaining or enhancing wildlife 

habitat diversity.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

F 3,300 Management area F is specific to 

the Jemez Wild and Scenic River.

Emphasis is on prohibiting road 

construction and motorized use, 

managing for high scenic integrity 

objective, and managing for semiprimitive nonmotorized recreation 

opportunity spectrum setting.

Closed to 

new mineral 

leasing

Prohibit new road 

construction 
Appendix A. Management Areas and Prescriptions from Forest Plan

A-2 Santa Fe National Forest Geothermal Leasing EIS

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

G 8,600 Emphasis in this area is on 

protecting key wildlife habitats, 

improving habitats, and producing 

forage and firewood. Recreational 

opportunities are dispersed and 

consist of firewood and pinyon nut 

gathering, hunting, and recreational 

driving.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

L 4,300 Emphasis is on providing semiprimitive nonmotorized recreation 

opportunities. Wildlife, range, and 

fuels may be managed where it is 

consistent with this emphasis. 

Timber harvesting and road building 

are not consistent with this 

emphasis, and neither is scheduled 

in this planning period. These areas 

will receive priority in dispersed 

recreation management, trail and 

trailhead development, and trail 

maintenance.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

M 600 These areas will be managed to 

provide opportunities for nondisruptive research and education. 

This management includes allowing 

natural processes to occur and 

protecting natural features. Use 

restrictions will be imposed as 

necessary to keep areas in their 

natural or unmodified condition. No 

timber or firewood will be harvested, 

nor will this area be assigned any 

grazing capacity.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use 

– No 

Surface 

Occupancy

J01 – Utility 

corridors are 

excluded

N 6,700 The emphasis here will be on 

management that protects and 

enhances essential wildlife habitat. 

This land area will not be included 

in the suitable timber base. 

However, certain timber 

management activities—as well as 

grazing, firewood collection, and fire 

management—may occur, when 

they are consistent with the 

emphasis on protecting this area.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance
Appendix A. Management Areas and Prescriptions from Forest Plan

Santa Fe National Forest Geothermal Leasing EIS A-3

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

P 9,800 Cultural resource location, 

inventory, nomination, and 

protection are emphasized here. 

Emphasis is also on timber 

production and enhancement of 

wildlife habitat diversity, consistent 

with other resource integration. 

Grazing capacity is generally 

transitory in nature, but there are 

allotments in intermingled 

grasslands. Roaded, dispersed 

recreation experiences are 

emphasized. Firewood is provided 

as a by-product of timber 

harvesting.

G04 –

Mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

Q 3,200 Cultural resource site location, 

inventory, nomination, and 

protection in these areas are 

emphasized. The emphasis is also 

on providing dispersed recreation 

opportunities, while maintaining 

visual quality, timber harvesting, 

and firewood production. Grazing 

activities vary in intensity over this 

area. The emphasis is on 

maintaining or enhancing wildlife 

habitat diversity. Cultural resource 

site location, inventory, nomination, 

and protection in these areas are

emphasized.

Source: Forest Service 1987

1 Excludes Forest-Wide Standards and Guidelines
Appendix A. Management Areas and Prescriptions from Forest Plan

A-4 Santa Fe National Forest Geothermal Leasing EIS

This page intentionally left blank.
Appendix B

Stipulations and Closures by Alternative
This page intentionally left blank.
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-1

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

Fish and Wildlife

Designated or 

proposed critical 

habitat

Surface occupancy and use is 

prohibited on designated or proposed

critical habitat for listed species under 

the Endangered Species Act of 1973 

(as amended), as following: 

• New Mexico meadow jumping 

mouse

• Mexican spotted owl 

• Jemez mountain salamander

Purpose: To avoid surface disturbance activities that would 

result in loss of critical habitat within these distinct localized 

areas

Changes: An exception, modification, or waiver may be 

granted if an operator could demonstrate in a site-specific 

surface use plan of operations that adverse impacts on habitat 

could be completely avoided and clearance is obtained from the 

agency biologist and the US Fish and Wildlife Service.

• •

Cultural Resources

Areas with important 

cultural resources

Surface occupancy and is prohibited at

the following:

• Traditional cultural properties and 

Native American sacred sites, as 

identified through consultation

• Properties listed on or eligible for 

listing on the National Register of 

Historic Places, including National 

Landmarks and National Register 

Districts and Sites; also, additional 

lands outside the designated 

boundaries, to the extent 

necessary to protect values where 

the setting and integrity is critical 

to their designation or eligibility

• Areas that qualify for cultural 

resource protection based on 

Forest Plan criteria (Planning 

Areas P, Q, and R)

Purpose: To avoid surface disturbance activities that would 

result in irreversible loss of cultural resources within these 

areas where cultural resource avoidance or data recovery are 

not viable options

Changes: An exception, modification, or waiver may be 

granted if an operator’s site-specific surface use plan of 

operations were to demonstrate that adverse impacts on the 

cultural resources could be completely avoided, and clearance 

is recommended, in accordance with the requirements of

Section 106 of the National Historical Preservation Act, and 

approved by the Forest Supervisor.

• •

Water Resources and Water Quality

Water bodies, rivers

and streams

(perennial and 

intermittent), riparian 

areas, wetlands, 

playas, 100-year 

floodplains, and a 

Surface occupancy and use is 

prohibited within a 500-foot-wide 

protection zone, measured horizontally 

from the outer edge of each feature for

the following:

• Water bodies, rivers and streams 

(perennial and intermittent), 

Purpose: To avoid adverse impacts on riparian and wetland 

resources, to prevent development in floodplains, and to remain 

consistent with law (Clean Water Act), regulation, and policy 

(National BMPs)

Changes: An exception or modification may be granted if 

surveys show that the area of a proposed activity is not a water 

•
Appendix B. Stipulations and Closures by Alternative

B-2 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

500-foot-wide 

protection zone 

around them

wetlands, and playas (mapped in 

the USGS National Hydrography 

Dataset [NHD]) 

• Riparian areas are protected by a 

500-foot-wide buffer. They are 

approximately mapped within the 

terrestrial ecosystem survey and 

vegetation data sets (includes 

Terrestrial Ecosystem Units 3-8, 

10, 11, 13, 31, 33, 34, 38, 234, 

320, and 334), but they may also 

need site-specific field delineation. 

• The 100-year floodplain 

(surrounding some features) 

needs to be delineated through 

field geomorphology surveys, 

stream gage data, and hydrologic 

modelling.

feature and that impacts on a water feature are not likely to 

occur. 

Roads and power lines may cross these areas if the operator 

can show that crossing the water feature and protection zone 

will have less environmental impact than other routes and that 

adverse effects can be minimized.

Water bodies, 

perennial rivers and 

streams, riparian 

areas, wetlands, 

playas, 100-year 

floodplains, and a 

500-foot-wide 

protection zone 

around them.

Surface occupancy and use is 

prohibited within a 500-foot wide 

protection zone measured horizontally 

from the outer edge of each feature for

the following:

• Water bodies, perennial rivers and 

streams, wetlands, and playas 

(mapped in the USGS NHD) 

• Riparian areas are protected by a 

500 foot-wide buffer. They are 

approximately mapped within the 

terrestrial ecosystem survey and 

vegetation data sets (includes 

Terrestrial Ecosystem Units 3-8, 

10, 11, 13, 31, 33, 34, 38, 234, 

320, and 334), but they may also 

need site specific field delineation. 

• The 100-year floodplain 

(surrounding some features) 

needs to be delineated through 

field geomorphology surveys, 

Purpose: To avoid adverse impacts on riparian and wetland 

resources, to prevent development in floodplains, and to remain 

consistent with law (Clean Water Act), regulation, and policy 

(National BMPs).

Changes: An exception or modification may be granted if 

surveys show that the area of a proposed activity is not a water 

feature and that impacts on a water feature are not likely to 

occur. 

Roads and power lines may cross these areas if the operator 

can show that crossing the water feature and protection zone 

will have less environmental impact than other routes and that 

adverse effects can be minimized. 

•
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-3

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

stream gage data and hydrologic 

modelling.

Acequias and a 50-

foot protection zone

Surface occupancy and use is 

prohibited within a 50-foot protection 

zone, as measured horizontally from 

the outer edge of the ditch for acequias 

with the Office of the State Engineer 

(OSE) recognized water rights.

Purpose: To avoid adverse impacts on riparian and wetland 

resources and impairment of existing water rights

Changes: An exception or modification may be granted if 

surveys show that impacts on the acequia are not likely to occur 

and the New Mexico Acequia Commission agrees. 

Roads and power lines may cross these areas if the operator 

can show that crossing the acequia and protection zone would 

have less environmental impact than other routes and that 

adverse effects could be minimized. 

• •

New Mexico Office of 

the State Engineer 

Recognized Water 

Sources and a 1-mile 

protection zone 

around them

Surface occupancy and use is 

prohibited within a 1-mile protection 

zone for New Mexico OSE-recognized 

water sources. In the project boundary, 

these are as follows: 

• Known drinking water sources 

• Known wells 

• Known springs 

Purpose: To protect the water quality and quantity of water 

sources. Protecting water sources will help the Forest Service 

comply with its own management direction, such as the Santa 

Fe National Forest Plan (1987) and FSM 2500; laws, such as 

the Clean Water Act (1972) and the Safe Drinking Water Act 

(1974); and regulations, such as New Mexico water quality 

standards, water rights. and permits.

Changes: An exception or modification may be granted if the 

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show there is no reasonable risk to the 

quality or quantity at a water source.

Roads and power lines may cross a water source protection 

zone if the operator can demonstrate that it would have less 

environmental impact than other routes and that adverse effects 

could be minimized.

•

New Mexico OSErecognized drinking 

water sources and a 

1-mile protection 

zone around them

Surface occupancy and use is 

prohibited within a 1-mile protection 

zone for OSE-recognized drinking 

water sources, such as that within the 

project boundary.

Purpose: To protect the water quality and quantity of water 

sources. Protecting water sources will help the Forest Service 

comply with its own management direction, such as the Santa 

Fe National Forest Plan (1987) and FSM 2500; law, such as the 

Clean Water Act (1972) and the Safe Drinking Water Act 

(1974); and regulation, such as the New Mexico water quality 

standards, water rights, and permits.

Changes: An exception or modification may be granted if the 

•
Appendix B. Stipulations and Closures by Alternative

B-4 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show that there is no reasonable risk to 

the quality or quantity at a water source. 

Roads and power lines may cross a water source protection 

zone if the operator can demonstrate that it would have less 

environmental impact than other routes and that adverse effects 

could be minimized.

Geologic Resources

Natural geothermal 

features and a 1-mile 

protection zone 

around them

Surface occupancy and use is 

prohibited on thermal features. These

are defined broadly as places on the 

earth’s surface with natural discharges 

of elevated temperature groundwater. 

Within the project area boundary there 

are two known hot springs outside of 

the Jemez NRA: San Antonio Hot 

Springs and Sulphur Springs, which is 

on private land, but the protection zone 

extends onto Forest Service lands. A 1-

mile (radius) protection zone would 

surround any known or currently 

unknown thermal feature, within which 

the area would be closed to all surface 

occupancy.

Purpose: To protect the water quality, water quantity, unique 

ecosystems, and cultural values these features hold.

Changes: An exception or modification may be granted if the 

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show that there is no reasonable risk to 

the quality or quantity of water creating the feature.

Roads and power lines may cross these areas if the operator 

can demonstrate there are no practicable alternatives and that 

adverse effects could be minimized. Detailed plans for 

mitigations to adverse effects would be required with the 

application for exception or modification.

•

Soils

Slopes in excess of 

40 percent

Surface occupancy and use is 

prohibited on slopes equal to or in 

excess of a 40 percent grade. These 

areas are extremely susceptible to 

erosion and mass wasting.

Purpose: To preclude surface-disturbing activities on steep 

slopes, because these areas tend to have high erosion and a 

mass wasting hazard. Additionally, water quality is more likely 

to be impaired where steep slopes have been developed. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that unstable or steep slopes do 

not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-5

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

be minimized and activities safely conducted without a loss of 

long-term site productivity. 

Power lines and roads may cross slopes equal to or exceeding 

a 40 percent gradient. Where this occurs, any vegetation or 

ground disturbance must have a minimal impact on the 

hydrologic network. This can be achieved through proper 

implementation of best management practices (BMPs) and by 

designing for sufficient and appropriate water control.

Soils with severe 

erosion potential

Surface occupancy and use is 

prohibited on all soils with severe 

erosion potential, as defined by the 

Forest Service Terrestrial Ecological 

Unit geographical information system 

(GIS) layers.

Purpose: To preclude surface-disturbing activities on severely 

erosive soils, because these areas are likely to erode. Without 

this protection there would be a high risk of impairing long-term 

soil productivity and watershed conditions. Additionally, these 

precautions must be taken to remain consistent with Forest 

Service policy.

Changes: An exception or modification may be granted if 

onsite inspection were to show that soils with severe erosion 

potential do not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

be minimized and activities safely conducted without the loss of 

long-term site productivity.

Power lines and roads may cross areas with severely erosive 

soils. Where this occurs, any vegetation or ground disturbance 

must incorporate BMPs to minimize erosion potential.

•

Land Use, Recreation, and Special Designations

Developed recreation 

facilities 

Surface occupancy and use is 

prohibited on the following developed 

recreation facilities:

• San Antonio Creek Recreation 

Area

• Seven Springs Recreation Area

• Paliza Recreation Area

Purpose: To avoid incompatible development that would 

impact developed recreation facilities and sites.

Changes: No exceptions, waivers, or modifications would be 

considered.

•
Appendix B. Stipulations and Closures by Alternative

B-6 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

Developed recreation 

facilities and Forest 

Service 

administrative sites

Surface occupancy and use is 

prohibited on the following developed 

recreation facilities and Forest Service 

administrative sites:

• San Antonio Creek Recreational 

Area

• Seven Springs Recreation Area

• Paliza Recreation Area

• Seven Springs Administrative Site

• Encino Administrative Site

• Encino Point Administrative Site

• Cerro Pelado Lookout 

Administrative Site

Purpose: To avoid incompatible development that would 

impact developed recreation facilities and administrative sites.

Changes: No exceptions, waivers, or modifications would be 

considered.

•

Inventoried roadless 

areas

Surface occupancy and use is 

prohibited on inventoried roadless 

areas.

Purpose: To keep surface disturbance activities outside the 

inventoried roadless area. This stipulation is needed to protect 

and maintain the roadless, semiprimitive, and nonmotorized 

character of these special areas. Examples are such elements 

as natural integrity, natural appearance, opportunity for quiet 

and solitude, manageability of boundaries, and special features, 

such as ecological, geological, scenic, cultural features.

Changes: No exceptions, waivers, or modifications would be 

considered.

• •

Visual Resources

National Forest 

System lands with a 

Scenery Management 

System integrity level 

of very high

Surface occupancy and use is 

prohibited on National Forest System 

lands with a Scenery Management 

System integrity level of very high. This 

is Management Area L in the SFNF 

Forest Plan.

Purpose: To protect important viewsheds.

Changes: An exception, modification, or waiver may be 

granted if an operator’s site-specific surface use plan of 

operations were to demonstrate that adverse impacts on the 

viewshed would not occur.

•
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-7

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Soils

Slopes between 30 

and 40 percent

Design and locate all surface-disturbing 

activities to minimize soil erosion. 

Erosion factors include fugitive dust, 

wind, and stormwater runoff. BMPs 

would be applied to all sites containing 

these soils, and additional measures 

may be required.

Purpose: To preclude surface-disturbing activities on slopes 

that tend to have high erosion and a mass wasting hazard. 

Additionally, water quality is more likely to be impaired where 

slopes have been developed. Without this protection there 

would be a risk of impairing long-term soil productivity and 

watershed conditions. Additionally, these precautions must be 

taken to remain consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that unstable or steep slopes do 

not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

be minimized and activities safely conducted without loss of 

long-term site productivity. 

Power lines and roads may cross these slopes. Where this 

occurs, any vegetation or ground disturbance must have a 

minimal impact on the hydrologic network. This could be 

achieved through proper implementation of BMPs and 

designing for sufficient and appropriate water control.

• •

Soils with severe 

erosion potential

Design and locate all surface-disturbing 

activities to minimize soil erosion. 

Erosion factors are fugitive dust, wind, 

and stormwater runoff. BMPs would be 

applied to all sites containing these 

soils, and additional measures may be 

required.

Purpose: To limit and modify surface-disturbing activities on 

severely erosive soils, because these areas are likely to erode. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that soils with severe erosion 

potential do not exist on the specific site.

Power lines and roads may cross areas with severely erosive 

soils. Where this occurs, any vegetation or ground disturbance 

must incorporate BMPs to minimize erosion potential.

•
Appendix B. Stipulations and Closures by Alternative

B-8 Santa Fe National Forest Geothermal Leasing EIS

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Water Resources and Water Quality

Intermittent streams 

listed in the NHD and 

ephemeral drainages 

delineated by sitespecific mapping

Design and locate all surface-disturbing 

activities to minimize or avoid impacts 

on intermittent and ephemeral 

drainages. BMPs would be applied to 

all sites containing these features, and 

additional measures may be required.

Purpose: To limit and modify surface-disturbing activities on 

severely erosive soils, because these areas are likely to erode. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that intermittent streams or 

ephemeral drainages do not exist on the specific site.

Power lines and roads may cross intermittent streams or 

ephemeral drainages. Where this occurs, any vegetation or 

ground disturbance must incorporate BMPs to minimize erosion 

potential.

•

New Mexico OSErecognized wells and 

springs

Design and locate all surface-disturbing 

activities to minimize soil erosion.

BMPs will be applied to all sites, and 

additional measures may be required. 

Proper drilling and casing processes 

will be required to protect groundwater 

quality.

Purpose: To limit and modify surface-disturbing activities near 

springs and wells that might impact water quality. Without this 

protection there would be a high risk of impairing water quality. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

To limit activities that would impact groundwater quantity or 

quality. Without this protection, the owner’s water right could be 

impaired.

Changes: An exception or modification may be granted if onsite inspection were to show that the spring does not exist on 

the specified site.

•

Land Use, Recreation, and Special Designations

Dispersed 

recreational areas

Locate and design surface disturbance 

activities to be compatible with 

dispersed recreational use. Also,

reclaim disturbed areas to be 

substantially unnoticeable to dispersed 

recreational users within 1 to 3 years of 

project startup. Generally, this can be 

met by following BMPs.

Purpose: To minimize the potential for adverse impacts on

recreational values, both motorized and nonmotorized, and the 

natural settings associated with the recreation.

Changes: An exception, modification, or waiver may be 

granted if the operator could demonstrate that the proposed 

surface disturbance would have less environmental impact than 

placing the surface-disturbing activity elsewhere and that 

adverse effects could be minimized.

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-9

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Visual Resources

Viewsheds with a 

Scenery Management 

System integrity level

of high

Locate and design surface disturbance 

activities to be consistent with the 

scenic integrity of high or to reclaim 

disturbed areas to meet the visual 

quality objective within 5 years of 

project startup. Generally, this can be 

met by following BMPs for minimizing 

impacts on visual quality, along with 

visual quality guidelines in the Forest 

Plan and Forest Service Scenery 

Management System Handbook 

(Agriculture Handbook 701).

Purpose: To protect the long-term scenic values in areas of 

high scenic integrity, consistent with Forest Service directives 

and the Forest Plan.

Changes: An exception, modification, or waiver may be 

granted if the operator were to demonstrate in a site-specific 

surface use plan of operations that adverse impacts on the 

viewshed would not occur.

•

Viewsheds with a 

Scenery Management 

System integrity level

of very high and high

Locate and design surface disturbance 

activities to be consistent with the 

scenic integrity or to reclaim disturbed 

areas to meet the visual quality 

objective within 5 years of project 

startup. Generally, this can be met by 

following BMPs for minimizing impacts 

on visual quality, along with visual 

quality guidelines in the Forest Plan 

and Forest Service Scenery 

Management System Handbook 

(Agriculture Handbook 701).

Purpose: To protect the long-term scenic values in areas of 

high scenic integrity, consistent with Forest Service directives 

and the Forest Plan.

Changes: An exception, modification, or waiver may be 

granted if the operator were to demonstrate in a site-specific 

surface use plan of operations that adverse impacts on the 

viewshed would not occur.

•
Appendix B. Stipulations and Closures by Alternative

B-10 Santa Fe National Forest Geothermal Leasing EIS

Table B-3. Timing Limitation Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Threatened and Endangered Species and Special Status Species

Mexican spotted owl 

designated protected 

activity centers 

(PACs)

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to August 31.

Purpose: To protect and limit disturbance from drilling and 

construction within Mexican spotted owl PACs (nesting/fledging 

areas). This would be to minimize risks to the owl’s reproductive 

and post-fledging success during the critical nesting/breeding 

period. This is defined in the recovery plan for this federally 

listed threatened species, as well as in the Forest Plan 

(Appendix D, p. 2). This stipulation would not apply to daily 

operations and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if an operator’s site-specific surface 

use plan of operations were to demonstrate that adverse 

impacts on threatened and endangered species could be 

avoided, effects were documented in a biological assessment, 

and concurrence from the US Fish and Wildlife Service were 

obtained.

• •

Northern goshawk 

designated Postfledging areas (PFAs)

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to September 

30.

Purpose: To protect and limit disturbance from drilling and 

construction within northern goshawk nesting PFAs. This would 

be to minimize risks to reproductive and post-fledging success 

of northern goshawks during the critical nesting/breeding period,

defined in interagency goshawk guidelines and the Forest Plan 

(Appendix D, pp. 6, 10). This stipulation would not apply to daily 

operations and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if goshawk surveys were to show that 

the area is not used for nesting.

• •

Peregrine falcon eyrie 

nesting areas

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to August 15.

Purpose: To protect and limit disturbance from drilling and 

construction in peregrine falcon habitat. This would be to 

minimize risks to reproductive and post-fledging success of 

peregrine falcons during the critical nesting/breeding period, 

consistent with the Forest Plan (p. 63) and Forest Service 

directives. This stipulation would not apply to daily operations

and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if surveys were to show that the area 

is not used for nesting.

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-11

Table B-3. Timing Limitation Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Elk calving areas Timing limitation would be imposed on 

drilling operations and construction 

activities from June 1 to July 31.

Purpose: To protect and limit disturbance from drilling and 

construction in important elk calving areas. This would be to 

minimize risks to herd reproduction during a critical period. This 

stipulation would not apply to daily operations and maintenance.

Changes: An exception or modification to the timing limitation 

may be granted if the operator were to demonstrate that the 

drilling/construction location would not disrupt deer fawning and 

elk calving.

• •
B-12 Santa Fe National Forest Geothermal Leasing EIS

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List of Figures – Appendix B

Figure 2-1. Alternative 2 – The Proposed Action Closed to Leasing

Figure 2-2. Alternative 2 – The Proposed Action Available for Leasing Subject to 

No Surface Occupancy

Figure 2-3. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Controlled Surface Use

Figure 2-4. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Timing Limitations

Figure 2-5. Alternative 4 – The Development Alternative Closed to Leasing

Figure 2-6. Alternative 4 – The Development Alternative Available for Leasing Subject to 

No Surface Occupancy

Figure 2-7. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Controlled Surface Use

Figure 2-8. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Timing Limitations
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Appendix C

Best Management Practices and Mitigation 

Measures
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Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-1

Appendix C. Best Management Practices and 

Mitigation Measures

Best Management Practices (BMPs) are state-of-the-art mitigation measures applied on a sitespecific basis to avoid, minimize, reduce, rectify, or compensate for adverse environmental or 

social impacts. They are applied to management actions to aid in achieving desired outcomes for 

safe, environmentally responsible resource development by preventing, minimizing, or mitigating 

adverse impacts and reducing conflicts.

The following BMPs provide the BLM, Forest Service, industry, and stakeholders a menu of 

practices for developing geothermal energy and minimizing impacts to the environment and 

landscape. The list is not meant to be all inclusive given the constant development of improved 

practices, diversity of the area, and potential for unique site-specific conditions. Practices which 

are not included in this appendix may be implemented as needed.

Some BMPs are more suitable for consideration on a case-by-case basis depending on:

• Their effectiveness

• The balancing of increased operating costs vs. the benefit to the public and resource values

• The availability of less restrictive mitigation alternatives that accomplish the same objective

• Other site-specific factors 

Guidelines for applying and selecting project-specific requirements include determining whether 

the measure would:

• Ensure compliance with relevant statutory or administrative requirements

• Minimize local impacts associated with siting and design decisions

• Promote post-construction stabilization of impacts

• Maximize restoration of previous habitat conditions

• Minimize cumulative impacts

• Promote economically feasible development of geothermal energy on Forest Service land 

Only those BMPs reasonably necessary to ensure environmentally responsible geothermal 

development should be selected from the list below. Not all of the individual mitigation measures 

below will apply to most situations, and selection of appropriated BMPs and mitigation measures 

should be dependent on factors such as the project size, location, site-specific characteristics, and 

potential resource impacts. Prior to inclusion, the measures may be further modified to meet sitespecific situations and agency requirements.

This list was compiled from several sources, primarily:

• Programmatic EIS for Geothermal Leasing in the Western United States (2008)

• Forest Service National Best Management Practices for Water Quality Management on 

National Forest System Lands (2012) available at: http://www.fs.fed.us/biology/resources/

pubs/watershed/FS_National_Core_BMPs_April2012.pdf

• Forest Service Handbook (Southwestern Region) FSH 2509.22 – Soil and Water 

Conservation Handbook
Appendix C. Best Management Practices and Mitigation Measures

C-2 Santa Fe National Forest Geothermal Leasing EIS

• Santa Fe National Forest Plan (2007 as amended)

In the event that the BMPs listed here are not effective, or do not address a particular resource 

concern, there are numerous other sources which will be consulted. Some of these are:

• Forest Service Low-Volume Roads Engineering Best Management Practices Field Guide 

(2003)

• The Gold Book, Surface Operating Standards and Guidelines for Oil and Gas Exploration and 

Development (current edition)

• BLM Washington Office Fluid Minerals website 

• US DOE Protocol for Addressing Induced Seismicity Associated with Enhanced Geothermal 

Systems (2012)

• US EPA

• New Mexico Game and Fish

• New Mexico Environment Department

In keeping with the PEIS, the BMPs are listed according to the phase of operations they apply to 

the most.

C.1 Information Collection & Monitoring

C.1.1 General

• Prior to geothermal exploration and development, a subsurface geotechnical investigation 

will be conducted to analyze the soil and geologic conditions of each site with proposed 

surface disturbance. The investigation will evaluate and identify potential geologic hazards 

and will provide remedial grading recommendations, foundation and slab design criteria, and 

soil parameters for the design of geothermal power infrastructure.

• The operator will collect available information describing the environmental and sociocultural conditions in the vicinity of the proposed project and will provide the information to 

the agency.

• The agency will require suitable geotechnical or stability analyses to ensure that facilities are 

constructed to acceptable factors of safety using standard engineering practices and 

considering foundation conditions and material, construction materials and techniques, the 

seismicity of the area, and the water-related resources at risk.

• A monitoring program will be developed by the operator to ensure that environmental 

conditions are monitored during the exploration and well drilling, testing, construction, and 

utilization and reclamation phases. The monitoring program requirements, including adaptive 

management strategies, will be established at the project level to ensure that potential adverse 

impacts of geothermal development are mitigated. The monitoring program will identify the 

monitoring requirements for each major environmental resource present at the site, establish 

metrics against which monitoring observations can be measured, identify potential mitigation 

measures, and establish protocols for incorporating monitoring observations and additional 

mitigation measures into ongoing activities. The operator will provide results of the 

monitoring program to the agency in an annual report.

• The operator will comply with the Secretary of Agriculture’s rules and regulations:

♦ For all use and occupancy of the NFS lands prior to approval of an exploration plan by 

the Secretary of the Interior
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-3

♦ For uses of all existing improvements, such as forest development roads, within and 

outside the area permitted by the Secretary of the Interior

♦ For use and occupancy of the NFS lands not authorized by an exploration plan approved 

by the Secretary of the Interior

C.1.2 Paleontological and Cultural Resources

• Before any specific permits are issued under leases, treatment of cultural resources will 

follow the procedures established by the Advisory Council on Historic Preservation for 

compliance with Section 106 of the National Historic Preservation Act. A pedestrian 

inventory will be undertaken of all portions that have not been previously surveyed or are 

identified by the Forest Service or BLM as requiring inventory to identify properties that are 

eligible for the NRHP. Those sites not already evaluated for NRHP eligibility will be 

evaluated based on surface remains, subsurface testing, archival, and/or ethnographic sources. 

Subsurface testing will be kept to a minimum whenever possible if sufficient information is 

available to evaluate the site or if avoidance is an expected mitigation outcome. 

Recommendations regarding the eligibility of sites will be submitted to the Forest Service, 

and a treatment plan will be prepared to detail methods for avoidance of impacts or mitigation 

of effects. The Forest Service will make determinations of eligibility and effect and consult 

with SHPO as necessary based on each proposed lease application and project plans. In 

consultation with the Forest Service, the BLM may require modification to exploration or 

development proposals to protect such properties, or disapprove any activity that is likely to 

result in adverse effects that cannot be successfully avoided, minimized, or mitigated. 

Avoidance of impacts through project design will be given priority over data recovery as the 

preferred mitigation measure. Avoidance measures include moving project elements away 

from site locations or to areas of previous impacts, restricting travel to existing roads, and 

maintaining barriers and signs in areas of cultural sensitivity. Any data recovery will be 

preceded by approval of a detailed research design, Native American Consultation, and other 

requirements for Forest Service issuance of a permit under the Archaeological Resources 

Protection Act.

• If cultural resources are present at the site, or if areas with a high potential to contain cultural 

material have been identified, a cultural resources management plan (CRMP) will be 

developed. This plan will address mitigation activities to be taken for cultural resources found 

at the site. Avoidance of the area is always the preferred mitigation option. Other mitigation 

options include archaeological survey and excavation (as warranted) and monitoring. If an 

area exhibits a high potential, but no artifacts were observed during an archaeological survey, 

monitoring by a qualified archaeologist could be required during all excavation and 

earthmoving in the high potential area. A report will be prepared documenting these activities. 

The CRMP also will:

♦ Establish a monitoring program

♦ Identify measures to prevent potential looting/vandalism or erosion impacts

♦ Address the education of workers and the public to make them aware of the consequences 

of unauthorized collection of artifacts and destruction of property on public land 

• The operator will determine whether paleontological resources exist in a project area on the 

basis of the sedimentary context of the area, a records search for past paleontological finds in 

the area, and/or, depending on the extent of existing information, a paleontological survey.

• If paleontological resources are present at the site, or if areas with a high potential to contain 

paleontological material have been identified, a paleontological resources management plan 
Appendix C. Best Management Practices and Mitigation Measures

C-4 Santa Fe National Forest Geothermal Leasing EIS

will be developed. This plan will include a mitigation plan for avoidance, removal of fossils, 

or monitoring. If an area exhibits a high potential but no fossils were observed during survey, 

monitoring by a qualified paleontologist may be required during excavation and earthmoving 

in the sensitive area. The operator will submit a report to the agency documenting these 

activities. The paleontological resources management plan also will:

♦ Establish a monitoring program

♦ Identify measures to prevent potential looting/vandalism or erosion impacts

♦ Address the education of workers and the public to make them aware of the consequences 

of unauthorized collection of fossils on public land

C.1.3 Water Resources

The BMPs require suitable characterization of site hydrology commensurate with the potential for 

impacts to surface water and groundwater resources, to include physical and chemical 

characteristics of surface and groundwater systems, as needed, for the range of expected seasonal 

variation in precipitation and potential stormflow events likely to occur at the site for the duration 

of the minerals activities.

The operator will: 

• Evaluate the consumptive use of water in the operation and its effect on water-dependent 

ecosystems.

• Evaluate the potential for direct and indirect impacts to morphology, stability, and function of 

waterbodies, riparian areas, and wetland habitats.

• Develop a storm water management plan for the site to ensure compliance with applicable 

regulations and to prevent offsite migration of contaminated storm water or increased soil 

erosion.

• Gain a clear understanding of the local hydrogeology. Areas of groundwater discharge and 

recharge and their potential relationships with surface water bodies will be identified.

• Avoid creating hydrologic conduits between two aquifers during foundation excavation and 

other activities.

• Identify federal, state, and local permits or requirements needed to implement the project.

Examples include water quality standards, CWA 401 certification, CWA 402 permits 

(including stormwater permits), CWA 404 permits, and Coastal Zone Management Act 

requirements.

• Plan to limit surface disturbance to the extent practicable while still achieving project 

objectives.

• Provide adequate buffers and setbacks from waterbodies to avoid or minimize impacts to 

water quality and aquatic ecosystems.

• Designate specific aquatic management zones (AMZs) around water features in the project 

area.

• Design activities on or near unstable areas and sensitive soils to minimize management 

induced impacts. 

• Use local direction and requirements for prevention and control of terrestrial and aquatic 

invasive species.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-5

• Use suitable tools to analyze the potential for cumulative watershed effects (CWE) to occur 

from the additive impacts of the proposed project and past, present, and reasonably 

foreseeable future activities on NFS and neighboring lands within the project watersheds.

• Consider the natural sensitivity or tolerance of the watershed based on geology, climate, and 

other relevant factors.

• Consider the existing condition of the watershed and water quality as a reflection of past land 

management activities and natural disturbances.

• Estimate the potential for adverse effects to soil, water quality, and riparian resources from 

current and reasonably foreseeable future activities on all lands within the watershed relative 

to existing watershed conditions.

• Use land management plan direction; federal, state, or local water quality standards; and other 

regulations to determine acceptable limits for CWE.

• Modify the proposed project or activity as necessary by changing project design, location, 

and timing to reduce the potential for CWE to occur.

• Consider including additional mitigation measures to reduce project effects. 

• Identify and implement opportunities for restoration activities to speed recovery of watershed 

condition before initiating additional anthropogenic disturbance in the watershed.

• Coordinate and cooperate with other federal, state, and private landowners in assessing and 

preventing CWE in multiple ownership watersheds.

• Integrate restoration and rehabilitation needs into the project plan.

• Consider water-quality improvement actions identified in a TMDL or other watershed 

restoration plan to restore impaired waterbodies within the project area.

• Identify project-specific monitoring needs.

• Document site-specific BMP prescriptions, design criteria, mitigation measures, and 

restoration, rehabilitation, and monitoring needs in the applicable NEPA documents, design 

plans, contracts, permits, authorizations, and operation and maintenance plans.

• Delineate all protected or excluded areas, including, for example, AMZs and waterbodies,

• Include 303(d) listed and TMDL waterbodies, and municipal supply watersheds, on the 

project map.

• Evaluate the condition of aquatic habitat, riparian habitat, and beneficial riparian zone 

functions and their estimated response to the proposed activity in determining the need for 

and width of the AMZ.

• Use stream class and type, channel condition, aspect, side slope steepness, precipitation and 

climate characteristics, soil erodibility, slope stability, groundwater features, and aquatic and 

riparian conditions and functions to determine appropriate AMZ widths to achieve desired 

conditions in the AMZ.

• Include riparian vegetation within the designated AMZ and extend the AMZ to include steep 

slopes, highly erodible soils, or other sensitive or unstable areas. 

• Establish wider AMZ areas for waters with high resource value and quality.

• Design and implement project activities within the AMZ to:

♦ Avoid or minimize unacceptable impacts to riparian vegetation, groundwater recharge 

areas, steep slopes, highly erodible soils, or unstable areas.

♦ Maintain or provide sufficient ground cover to encourage infiltration, avoid or minimize 

erosion, and filter pollutants.
Appendix C. Best Management Practices and Mitigation Measures

C-6 Santa Fe National Forest Geothermal Leasing EIS

♦ Avoid, minimize, or restore detrimental soil compaction.

♦ Retain trees necessary for shading and bank stabilization, and as a future source of large 

woody debris.

♦ Retain floodplain function.

♦ Restore existing disturbed areas that are eroding and contributing sediment to the 

waterbody.

• Mark the boundaries of the AMZ and sensitive areas—like riparian areas, wetlands, and 

unstable areas—on the ground before land-disturbing activities.

C.1.4 Vegetation and Fish and Wildlife

• The operator will conduct surveys for plant and animal species that are listed or proposed for 

listing as threatened or endangered and their habitats in areas proposed for development 

where these species could potentially occur, following accepted protocols and in consultation 

with the USFWS, as appropriate. Particular care should be taken to avoid disturbing listed 

species during surveys in any designated critical habitat. The operator will monitor activities 

and their effects on ESA-listed species throughout the duration of the project.

• The operator will identify important, sensitive, or unique habitat and biota in the project 

vicinity and site and should design the project to avoid (if possible), minimize, or mitigate 

potential impacts on these resources. The design and siting of the facilities will follow 

appropriate guidance and requirements from the Forest Service and other resource agencies, 

as available and applicable.

C.1.5 National Scenic and Historic Trails

• When any ROW application includes remnants of a National Historic Trail, is located within 

the viewshed of a National Historic Trail’s designated centerline, or includes or is within the 

viewshed of a trail eligible for listing on the NRHP, the operator will evaluate the potential 

visual impacts to the trail associated with the proposed project and identify appropriate 

mitigation measures for inclusion in the operation plan.

C.1.6 Air Quality and Climate

• The operator will coordinate with the New Mexico Environment Department Air Quality 

Bureau to develop and implement an air-quality monitoring plan.

C.2 Planning, Location, and Design

C.2.1 Bonding

• As outlined in the Forest Service Training Guide for Reclamation Bond Estimation and 

Administration for Minerals Plans of Operation, the Forest Service must consider the direct 

and indirect costs of stabilizing, rehabilitating, and reclaiming the area of mineral operations 

to the appropriate standards for water quality and watershed condition as determined from the 

land management plan, state and federal laws, regulations, plans, or permits when 

determining the reclamation bond amount. The bond amount determined by the Forest 

Service must include costs for:

♦ Operation and maintenance of facilities designed to divert, convey, store, or treat water. 

♦ Decontaminating, neutralizing, disposing, treating, or isolating hazardous materials at the 

site to minimize potential for contamination of soil, surface water, and groundwater.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-7

♦ Water treatment needs predicted during planning and discovered during operations to 

achieve applicable water-quality standards.

♦ Earthwork to reclaim roads, backfilling water features (diversions, ditches, and sediment 

ponds), and construction of diversion channels and drains, stream channels, and wetlands.

♦ Revegetation to stabilize the site and minimize soil erosion.

♦ Mitigation to restore natural function and value of streams, wetlands, and floodplains.

♦ Long-term operations, monitoring, and maintenance of mineral production-related 

facilities that must perform as designed to avoid or minimize contamination of surface or 

groundwater resources, including roads, diversion ditches, dams, and water treatment 

systems.

♦ Protection of the reclaimed area until long-term stability, erosion control, and revegetation has been established.

• The Forest Service coordinates with the BLM to ensure the reclamation bond required for 

operations will be sufficient to guarantee reclamation work on NFS lands to the appropriate 

standards for water quality and watershed condition as determined from the land management 

plan, state and federal laws, regulations, plans, or permits.

C.2.2 Traffic Planning

• The operator will consult with local planning authorities regarding increased traffic prior to 

the construction phase, including an assessment of the number of vehicles per day, their size, 

and type. Specific issues of concern (e.g., location of school bus routes and stops) will be 

identified and addressed in the traffic management plan.

C.2.3 Roads & Pads

• To plan for efficient use of the land, necessary infrastructure will be consolidated wherever 

possible.

• The operator will limit roads to the minimum practicable number, width, and total length 

consistent with the purpose of specific operations, local topography, geology, and climate to 

achieve land management plan desired conditions, goals, and objectives for access and waterquality management.

• The operator will use existing roads when practicable.

• The operator will plan road networks to have the minimum number of waterbody crossings as 

is practicable and necessary to achieve transportation system desired conditions, goals, and 

objectives.

• The operator will design the roads to maintain stable road prism, cut, and fill slopes.

• The operator will design cut and fill slope ratios to reduce soil loss from mass failures.

• The operator will use structural or nonstructural measures as necessary to stabilize cut and fill 

slopes.

• The operator will use brush mulches or filter fences when necessary to mitigate impacts of 

roads near water courses. 

• The operator will design the road surface drainage system to intercept, collect, and remove 

water from the road surface and surrounding slopes in a manner that minimizes concentrated 

flow in ditches, culverts, and over fill slopes and road surfaces.
Appendix C. Best Management Practices and Mitigation Measures

C-8 Santa Fe National Forest Geothermal Leasing EIS

• The operator will use structural or nonstructural measures suitable to the road materials, road 

gradient, and expected traffic levels. The operator will use an interval between drainage 

features that is suitable for the road gradient, surface material, and climate.

• The operator will use suitable measures to avoid or minimize erosion of ditches. 

• The operator will design and construct all new roads and drilling pads to a safe and 

appropriate standard, no higher than necessary to accommodate their intended use.

• Existing roads and pad sites will be used to the maximum extent feasible, but only if located 

in a safe and environmentally sound location. No new roads and pad sites will be constructed 

without agency authorization. If new roads and pad sites have been authorized, they will be 

designed and constructed by the operator to the appropriate agency standard, no higher than 

necessary to accommodate their intended function. Roads and pad sites will be routinely 

maintained by the operator to maintain public safety and to minimize impacts to the 

environment, such as erosion, sedimentation, fugitive dust, and loss of vegetation.

• An access road siting and management plan will be prepared incorporating existing agency 

standards regarding road design, construction, and maintenance, such as those described in 

the Forest Service handbook 7709.56 and the Surface Operating Standards for Oil and Gas 

Exploration and Development (i.e., the Gold Book, current edition).

• A traffic management plan will be prepared for the site access roads to ensure that no hazards 

would result from the increased truck traffic and that traffic flow would not be adversely 

impacted. This plan will incorporate measures such as informational signs, flaggers when 

equipment may result in blocked throughways, and traffic cones to identify any necessary 

changes in temporary lane configuration.

• Where possible, access roads will be located to follow natural contours and to minimize side 

hill cuts and fills. Excessive grades on roads, road embankments, ditches, and drainages shall 

be avoided, especially in areas with erodible soils.

• Roads will be designed so that changes to surface water runoff are minimized and new 

erosion is not initiated.

• Access roads will be located to minimize stream crossings. All structures crossing streams 

will be located and constructed so that they do not decrease channel stability or increase 

water velocity. The operator will obtain all applicable federal and state water crossing 

permits.

• Roads will be located away from drainage bottoms and will avoid wetlands, if practicable.

• The operator will minimize the period that disturbed areas are not vegetated by revegetating 

and/or mulching cuts and fill slopes. 

• Clearing of vegetation along rights-of-way, facilities, and special use sites will be limited to 

that which poses a hazard to the facility and operational efficiency.

C.2.4 Geotechnical Analysis

• The operator will perform a detailed geotechnical analysis prior to the construction of any 

structures, so they will be sited to avoid any hazards from subsidence or liquefaction (i.e., the 

changing of a saturated soil from a relatively stable solid state to a liquid during earthquakes 

or nearby blasting).
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-9

C.2.5 Well Pads

The operator will:

• Locate well sites on level locations that will accommodate the intended use to reduce the 

need for vertical cuts and steep fill slopes.

• Use suitable measures to stabilize fill slopes and to minimize potential of slope failures.

• Use suitable measures to provide surface drainage and to manage runoff from the work areas 

used for mud tanks, generators, mud storage, and fuel tanks in a manner that avoids or 

minimizes pollutant contamination of surface waters or groundwater.

• Use nontoxic, nonhazardous drilling fluids whenever practicable.

• Construct suitable impervious containment structures with sufficient volume and freeboard to 

avoid or minimize spills or leakages of oil, gas, salt water, toxic liquids, or waste materials 

from reaching surface waters or groundwater.

• Avoid mixing of geothermal fluids with surface water or groundwater where the chemical and 

thermal properties of the geothermal fluids would damage aquatic ecosystems and 

contaminate drinking water supplies.

• Minimize production of byproducts and wastes to the extent practicable.

• Plan space to properly handle, store, and contain byproducts and wastes.

• Recycle or properly dispose of wastes (e.g., used petroleum products, site garbage, septic 

effluent, decommissioned equipment, and used barrels or containers).

• Use applicable practices for sanitation systems and solid waste management to avoid 

contaminating surface water or groundwater from sanitation or solid waste facilities.

• Manage all chemicals, reagents, fuels, and other hazardous or toxic materials used for 

construction and operations to avoid or minimize contaminating surface water or 

groundwater.

• Require a transportation spill response plan, where applicable, that describes the petroleum 

products or other hazardous materials or chemicals that will be used in the operations, 

including the routes, amount, and frequency of shipments, and the containers and vehicles 

that are to be used. Describe in this plan the procedures, equipment, and personnel that would 

be used to respond to a spill.

C.2.6 Visual Mitigation

• The operator will incorporate visual design considerations into the planning and design of the 

project to minimize potential visual impacts of the proposal and to meet the visual resource 

management objectives of the area and the agency.

C.2.6.1 Visual Design Considerations

• Construct low-profile structures whenever possible to reduce structure visibility.

• Select and design materials and surface treatments to repeat or blend with landscape 

elements.

• Site projects outside of the viewsheds of publically accessible vantage points, or if this cannot 

be avoided, as far away as possible.

• Site projects to take advantage of both topography and vegetation as screening devices to 

restrict views of projects from visually sensitive areas.
Appendix C. Best Management Practices and Mitigation Measures

C-10 Santa Fe National Forest Geothermal Leasing EIS

• Site facilities away from and not adjacent to prominent landscape features (e.g., knobs and 

water features).

• Avoid placing facilities on ridgelines, summits, or other locations such that they will be 

silhouetted against the sky from important viewing locations.

• Collocate facilities to the extent possible to use existing and shared rights-of-way, existing 

and shared access and maintenance roads, and other infrastructure, so they do not bisect ridge 

tops or run down the center of valley bottoms.

• Site linear features (aboveground pipelines, rights-of-way, and roads) to follow natural land 

contours rather than straight lines (particularly up slopes) when possible. Fall-line cuts should 

be avoided.

• Site facilities, especially linear facilities, to take advantage of natural topographic breaks (i.e., 

pronounced changes in slope) to avoid siting facilities on steep side slopes. 

• Where available, site linear features—such as rights-of-ways and roads—to follow the edges 

of clearings (where they will be less conspicuous) rather than passing through the centers of 

clearings.

• Site facilities to take advantage of existing clearings to reduce vegetation clearing and ground 

disturbance, where possible.

• Site linear features (e.g., trails, roads, and rivers) to cross other linear features at right angles 

whenever possible to minimize viewing area and duration.

• Site and design structures and roads to minimize and balance cuts and fills and to preserve 

existing rocks, vegetation, and drainage patterns to the maximum extent possible.

• Use appropriately colored materials for structures or appropriate stains and coatings to blend 

with the project’s backdrop. Refer to the Standard Environmental Colors chart available from 

the BLM.

• Use non-reflective or low-reflectivity materials, coatings, or paints whenever possible.

• Paint grouped structures the same color to reduce visual complexity and color contrast.

• Design and install efficient facility lighting so that the minimum amount of lighting required 

for safety and security is provided but not exceeded and so that upward light scattering (light 

pollution) is minimized. This may include, for example, installing shrouds to minimize light 

from straying off-site, properly directing light to only illuminate necessary areas, and 

installing motion sensors to only illuminate areas when necessary.

• Site construction staging areas and laydown areas outside of the viewsheds of publically 

accessible vantage points and visually sensitive areas, where possible, including siting in 

swales, around bends, and behind ridges and vegetative screens.

• Discuss visual impact mitigation objectives and activities with equipment operators prior to 

commencement of construction activities.

• Mulch or scatter slash from vegetation removal and spread it to cover fresh soil disturbances 

or, if not possible, bury or compost slash.

• If slash piles are necessary, stage them out of sight of sensitive viewing areas.

• Avoid installing gravel and pavement where possible to reduce color and texture contrasts 

with existing landscape.

• Use excess fill-to–fill, uphill-side swales resulting from road construction in order to reduce 

unnatural-appearing slope interruption and to reduce fill piles.

• Avoid downslope wasting of excess fill material.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-11

• Round road-cut slopes, vary cut and fill pitch to reduce contrasts in form and line, and vary 

slope to preserve specimen trees and nonhazardous rock outcroppings.

• Leave planting pockets on slopes where feasible.

• Combine methods of reestablishing native vegetation through seeding, planting of nursery 

stock, transplanting of local vegetation within the proposed disturbance areas, and staging of 

construction-enabling direct transplanting.

• Revegetate with native vegetation establishing a composition consistent with the form, line, 

color, and texture of the surrounding undisturbed landscape.

• Provide benches in rock cuts to accent natural strata.

• Use split-face rock blasting to minimize unnatural form and texture resulting from blasting.

• Segregate topsoil from cut and fill activities and spread it on freshly disturbed areas to reduce 

color contrast and to aid rapid revegetation.

• Bury utility cables in or adjacent to the road where feasible. 

• Minimize signage and paint or coat reverse sides of signs and mounts to reduce color contrast 

with existing landscape.

• Prohibit trash burning; store trash in containers to be hauled off-site for disposal.

• Undertake interim restoration during the operating life of the project as soon as possible after 

disturbances. During road maintenance activities, avoid blading existing forbs and grasses in 

ditches and along roads.

• Randomly scarify cut slopes to reduce texture contrast with existing landscape and to aid in 

revegetation.

• Cover disturbed areas with stockpiled topsoil or mulch, and revegetate with a mix of native 

species selected for visual compatibility with existing vegetation.

• Restore rocks, brush, and natural debris whenever possible to approximate preexisting visual 

conditions.

C.2.7 Air Quality and Climate

• The operator will prepare and submit to the agency an Equipment Emissions Mitigation Plan 

for managing diesel exhaust. The Equipment Emissions Mitigation Plan will identify actions 

to reduce diesel particulate, carbon monoxide, hydrocarbons, and nitrogen oxides associated 

with construction and drilling activities. The Equipment Emissions Mitigation Plan will 

require that all drilling/construction-related engines are maintained and operated as follows:

♦ They are tuned to the engine manufacturer’s specification in accordance with an 

appropriate time frame.

♦ They do not idle for more than 5 minutes (unless, in the case of certain drilling engines, it 

is necessary for the operating scope).

♦ They are not tampered with in order to increase engine horsepower.

♦ Particulate traps, oxidation catalysts, and other suitable control devices are included on 

all drilling/construction equipment used at the project site.

♦ They use diesel fuel having a sulfur content of 15 parts per million or less, or other 

suitable alternative diesel fuel, unless such fuel cannot be reasonably procured in the 

market area.

♦ They include control devices to reduce air emissions. The determination of which 

equipment is suitable for control devices should be made by an independent Licensed 

Mechanical Engineer. Equipment suitable for control devices may include drilling 
Appendix C. Best Management Practices and Mitigation Measures

C-12 Santa Fe National Forest Geothermal Leasing EIS

equipment, work over and service rigs, mud pumps, generators, compressors, graders, 

bulldozers, and dump trucks.

C.2.8 Health and Safety

• The operator will use applicable practices for sanitation systems and solid waste management 

to avoid contaminating surface water or groundwater from sanitation or solid waste facilities.

• The operator will develop a hazardous materials management plan addressing storage, use, 

transportation, and disposal of each hazardous material anticipated to be used at the site. The 

plan will identify all hazardous materials that would be used, stored, or transported at the site. 

It will establish inspection procedures, storage requirements, storage quantity limits, 

inventory control, nonhazardous product substitutes, and disposition of excess materials. The 

plan will also identify requirements for notices to federal and local emergency response 

authorities and include emergency response plans.

• The operator will develop a waste management plan identifying the waste streams that are 

expected to be generated at the site and addressing hazardous waste determination 

procedures, waste storage locations, waste-specific management and disposal requirements, 

inspection procedures, and waste minimization procedures. This plan will address all solid 

and liquid wastes that may be generated at the site.

• The operator will develop a spill prevention and response plan identifying where hazardous 

materials and wastes are stored on-site, spill prevention measures to be implemented, training 

requirements, appropriate spill response actions for each material or waste, the locations of 

spill response kits on-site, a procedure for ensuring that the spill response kits are adequately 

stocked at all times, and procedures for making timely notifications to authorities.

• The operator will develop a transportation spill response plan that describes the petroleum 

products or other hazardous materials or chemicals that will be used in the operations, 

including the routes, amount and frequency of shipments, and containers and vehicles used.

This plan will describe the procedures, equipment, and personnel that would be used to 

respond to a spill.

• A safety assessment will be conducted to describe potential safety issues and the means that 

would be taken to mitigate them, including issues such as site access, construction, safe work 

practices, security, heavy equipment transportation, traffic management, emergency 

procedures, and fire control.

• A health and safety program will be developed to protect both workers and the general public 

during construction and operation of geothermal projects. The program will:

♦ Identify all applicable federal and state occupational safety standards 

♦ Establish safe work practices for each task (e.g., requirements for personal protective 

equipment and safety harnesses)

♦ Include Occupational Safety and Health Administration standard practices for safe use of 

explosives and blasting agents, and measures for reducing occupational electric and 

magnetic fields exposures 

♦ Establish fire safety evacuation procedures 

♦ Define safety performance standards (e.g., electrical system standards and lightning 

protection standards) 

♦ Include a training program to identify hazard training requirements for workers for each 

task and establish procedures for providing required training to all workers. 
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-13

Documentation of training and a mechanism for reporting serious accidents to 

appropriate agencies will be established.

♦ Establish a safety zone or setback for generators from residences and occupied buildings, 

roads, ROWs, and other public access areas that is sufficient to prevent accidents 

resulting from the operation of generators 

♦ Identify requirements for temporary fencing around staging areas, storage yards, and 

excavations during construction or rehabilitation activities. It will also identify measures 

to be taken during the operation phase to limit public access to hazardous facilities (e.g., 

permanent fencing would be installed only around electrical substations, and facility 

access doors would be locked).

• The operator will consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and 

type. Specific issues of concern (e.g., location of school bus routes and stops) will be 

identified and addressed in the traffic management plan.

• The operator will develop a fire management strategy to implement measures to minimize the 

potential for a human-caused fire.

C.2.9 Livestock Grazing

• The operator will coordinate with the Forest and livestock operators to minimize impacts to 

livestock operations.

C.2.10 Noxious Weeds and Pesticides

• The operator will develop a plan for control of noxious weeds and invasive species, which 

could occur as a result of new surface disturbance activities at the site. The most recent 

recommendations at the state and local level should be incorporated into any operating plan 

for the geothermal exploration and development. The plan will address monitoring, education 

of personnel on weed identification, the manner in which weeds spread, and methods for 

treating infestations. The use of certified weed-free mulching will be required. If trucks and 

construction equipment are arriving from locations with known invasive vegetation problems, 

a controlled inspection and cleaning area will be established to visually inspect construction 

equipment arriving at the project area and to remove and collect seeds that may be adhering 

to tires and other equipment surfaces.

• If pesticides are used on the site, an integrated pest management plan will be developed to 

ensure that applications would be conducted within the framework of all federal, state, and 

local laws and regulations and entail only the use of EPA-registered pesticides.

C.2.11 Vegetation and Fish and Wildlife

• The operator shall prepare a habitat restoration plan to avoid (if possible), minimize, or 

mitigate negative impacts on vulnerable wildlife while maintaining or enhancing habitat 

values for other species. The plan will identify revegetation, soil stabilization, and erosion 

reduction measures that will be implemented to ensure that all temporary use areas are 

restored. The plan will require that restoration occur as soon as possible after completion of 

activities to reduce the amount of habitat converted at any one time and to speed up the 

recovery to natural habitats.
Appendix C. Best Management Practices and Mitigation Measures

C-14 Santa Fe National Forest Geothermal Leasing EIS

C.2.12 Water Rights and Usage

The operator will:

• Obtain surface water (e.g., instream flow rights) and groundwater under appropriate federal 

and state legal and regulatory authorities to avoid, minimize, or mitigate adverse effects to 

stream processes, aquatic and riparian habitats and communities, groundwater-dependent 

ecosystems, and recreation and aesthetic values.

• Locate monitoring wells according to a monitoring plan to minimize the number of wells 

needed to achieve monitoring objectives.

• Construct and complete wells consistent with applicable federal and state regulations.

• Use licensed well drilling contractors.

• Use suitable measures to avoid or minimize well contamination, inter-aquifer exchange of 

water, floodwaters from contaminating the aquifer, and infiltration of surface water.

• Operate wells in such a manner as to avoid excessive withdrawals, maintain suitable 

groundwater levels, and minimize effects to groundwater-dependent ecosystems.

• Permanently seal abandoned wells consistent with applicable federal, state, and local 

regulations and requirements.

• Locate the spring box to allow water to flow by gravity from the spring to the spring box to 

eliminate disturbance from pumps and auxiliary equipment.

• Design the collection system to avoid, minimize, or mitigate adverse effects to the spring 

development and downstream waters from excessive water withdrawal, freezing, flooding, 

sedimentation, contamination, vehicular traffic, and livestock as needed.

• Collect no more water than is sufficient to meet the intended purpose of the spring 

development.

• Ensure that enough water remains in the spring to support the source groundwater-dependent 

ecosystem and downstream aquatic ecosystems.

• Trap and remove sediment that does enter the system.

• Intercept the spring flow below the ground surface upslope of where the water surfaces.

C.3 Construction

C.3.1 General

The operator will:

• Make adjustments in the plans, authorizations, and bonds if conditions develop that are 

outside the design criteria and conduct adequate notification, emergency stabilization, or 

other activities to avoid effects before proceeding with additional operations.

• Establish and maintain construction area limits to the minimum area necessary for completing 

the project and confine disturbance to within this area.

• Develop and implement an erosion control and sediment plan that covers all disturbed areas, 

including borrow, stockpile, fueling, and staging areas used during construction activities.

• Limit operation of equipment when ground conditions could result in excessive rutting, soil 

puddling, or runoff of sediments directly into waterbodies.

• Prepare a certified Spill Prevention Control and Countermeasure (SPCC) Plan for each 

facility as required by 40 CFR, Part 112.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-15

• Install or construct the containment features or countermeasures called for in the SPCC Plan 

to ensure that spilled hazardous materials are contained and do not reach groundwater or 

surface water.

• Ensure that cleanup of spills and leaking tanks is completed in compliance with federal, state, 

and local regulations and requirements.

• Ensure that hazardous spill kits are adequately stocked with necessary supplies and are 

maintained in accessible locations.

• Stockpile and protect topsoil for reuse in site revegetation.

• Minimize bank and riparian area excavation during construction to the extent practicable.

• Keep excavated materials out of the waterbody.

• Use only clean, suitable materials that are free of toxins and invasive species for fill.

• Properly compact fills to avoid or minimize erosion.

C.3.2 Traffic Management

• Traffic will be restricted to the roads developed for the project. Use of other unimproved 

roads will be restricted to emergency situations.

• Signs will be placed along roads to identify speed limits, travel restrictions, and other 

standard traffic control information. Signs directing vehicles to alternative park access and 

parking will be posted in the event construction temporarily obstructs recreational parking 

areas near trailheads. Whenever active work is being performed, the area will be posted with 

“construction ahead” signs on any adjacent access roads or trails that might be affected.

• Project personnel and contractors will be instructed and required to adhere to speed limits 

commensurate with road types, traffic volumes, vehicle types, and site-specific conditions; to 

ensure safe and efficient traffic flow; and to reduce wildlife collisions and disturbance and 

fugitive dust.

• When practical, construction activities will be avoided during high recreational use periods.

C.3.3 Roads & Pads

• The operator will plan and construct, to the extent practicable, exploration roads to be 

recontoured when operations are complete.

• The operator will limit the extent of open exploratory areas at one time and restore one site 

before moving on to the next one, to the extent practicable.

• The operator will obtain agency authorization prior to borrowing soil or rock material from 

agency lands.

• Road use will be restricted during the wet season if road surfacing is not adequate to prevent 

soil displacement, rutting, and resultant stream sedimentation.

• The operator will implement suitable measures to close and physically block the road 

entrance so that unauthorized motorized vehicles cannot access the road. 

• Access roads and on-site roads will be surfaced with aggregate materials where necessary to 

provide a stable road surface, support anticipated traffic, reduce fugitive dust, and prevent 

erosion.

• Dust abatement techniques will be used before and during surface clearing, excavation, or 

blasting activities. Dust abatement techniques will be used on unpaved, unvegetated surfaces 

to minimize fugitive dust. Speed limits (e.g., 25 mph [40 kph]) will be posted and enforced to 
Appendix C. Best Management Practices and Mitigation Measures

C-16 Santa Fe National Forest Geothermal Leasing EIS

reduce fugitive dust. Construction materials and stockpiled soils will be covered if they are a 

source of fugitive dust.

• Culvert outlets will be rip-rapped to dissipate water energy at the outlet and to reduce erosion. 

Catch basins, roadway ditches, and culverts will be cleaned and maintained regularly.

• The operator will report all label violations that occur during the application of dust 

suppressants or other surface stabilizers to the appropriate enforcement agency.

• The operator will respond to and report spills and other accidents during the application of 

dust suppressants or other surface stabilizers.

• The operator will design and locate stream crossings to minimize disturbance to the 

waterbody.

• The operator will locate stream crossings where the channel is narrow, straight, and uniform, 

and has stable soils and relatively flat terrain to the extent practicable.

• The operator will select a site where erosion potential is low.

• The operator will orient the stream crossing perpendicular to the channel to the extent 

practicable.

• The operator will keep approaches to stream crossings to as gentle a slope as practicable.

C.3.4 Well Pads

The operator will:

• Locate reserve pits in stable areas on the drill pad to the extent practicable.

• Locate pits away from natural watercourses, riparian areas, wetlands, floodplains, and areas 

of shallow groundwater wherever practicable.

• Use suitable measures to ensure full containment of drilling fluids where the reserve pit must 

be placed in a sensitive location or in porous material.

• Design the reserve pit to contain all anticipated drilling muds, cuttings, fracture fluids, and 

precipitation while maintaining a suitable amount of freeboard to avoid or minimize 

overtopping.

• Use suitable measures to avoid or minimize seepage from the reserve pit contaminating 

groundwater.

• Remove any visible or measurable layer of oil from the surface of the reserve pit after 

cessation of drilling and completion of operations, and continue to keep the pit free of oil.

• Use suitable measures to avoid or minimize surface waters and groundwater from entering 

open pits.

C.3.5 Pipelines

• Pipelines constructed aboveground due to thermal gradient-induced expansion and 

contraction will rest on cradles above ground level, allowing small animals to pass 

underneath. Projects should be analyzed to ensure adequate passage for all wildlife species. 

The pipeline will be raised higher to allow wildlife passage where needed. Because pipeline 

corridors through certain habitat types can alter local predator/prey dynamics by providing 

predators with lines of sight and travel corridors, large projects should be analyzed to ensure 

there will be no significant changes to predator/prey balance.

• The operator will collocate pipelines and transmission lines with roads or their rights-of-way 

where practicable.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-17

• The operator will limit corridor disturbance, particularly in or near AMZs, surface waters, 

shallow groundwater, unstable areas, hydric soils, or wetlands.

• The operator will aggressively address unauthorized uses of the corridor, such as motorized 

vehicle use, that are exposing soils, increasing erosion, or damaging the facilities.

C.3.6 Utilities

• Underground utilities will be installed to minimize the amount of open trenches at any given 

time, keeping trenching and backfilling crews close together. Avoid leaving trenches open 

overnight. Where trenches cannot be backfilled immediately, escape ramps should be 

constructed at least every 100 feet.

C.3.7 Facilities

• The BLM will request a copy of operator’s Clean Water Act (CWA) 401 Certification from 

designated federal, state, or local entities before approving a plan of operations that may 

result in any discharge into waters of the United States.

• The operator will consider the following design criteria in facility planning:

♦ Locate the facility away from the immediate vicinity of surface waters, AMZs, wetlands, 

sandy soils, shallow water tables, groundwater recharge areas, floodplains, and other 

sensitive areas to the extent practicable.

♦ Avoid unstable slopes and soils.

♦ Minimize the disturbance footprint.

• The operator will use and maintain proper erosion and sediment control practices during and 

immediately after construction.

• The operator will incorporate suitable stormwater controls in the project design.

• The operator will incorporate requirements from applicable federal, state, and local permits 

into facility construction and operation plans.

• The operator will develop a contingency plan for implementing appropriate pre-storm or 

winterization BMPs before the grading permit expires.

• The operator will conform to all applicable federal, state, and local regulations and permits 

governing water supply, sanitation, and septic systems.

• The operator will determine instream flow needs to minimize damage to scenic and aesthetic 

values; native plant, fish, and wildlife habitat; and to otherwise protect the environment 

where the operation of the facility would modify existing streamflow.

• The operator will install and seasonally monitor groundwater quality monitoring wells if a 

risk of groundwater pollution exists.

• The operator will establish a suitable inspection schedule to ensure that water diversion 

structures, conveyances, and storage facilities are performing as designed and appropriately 

maintained.

• The operator will maintain erosion and stormwater controls as necessary to ensure proper and 

effective functioning.

• The operator will prepare for unexpected failures of erosion control measures.

• The operator will implement corrective actions without delay when failures are discovered to 

prevent pollutant discharge to nearby waterbodies.

• The operator will routinely inspect construction sites to verify that erosion and stormwater 

controls are implemented and functioning as designed and are appropriately maintained.
Appendix C. Best Management Practices and Mitigation Measures

C-18 Santa Fe National Forest Geothermal Leasing EIS

• The operator will use suitable measures in compliance with local direction to prevent and 

control invasive species.

C.4 Specific Resources

C.4.1 Cultural and Paleontological Resources

• Unexpected discovery of cultural or paleontological resources during construction will be 

brought to the attention of the responsible BLM Authorized Officer immediately. Work will 

be halted in the vicinity of the find to avoid further disturbance to the resources while they are 

being evaluated and appropriate mitigation measures are being developed.

C.4.2 Noise

• The operator will take measurements to assess the existing background noise levels at a given 

site and compare them with the anticipated noise levels associated with the proposed project.

• Within 2 miles of existing, occupied residences, geothermal well drilling or major facility 

construction operations will be restricted to non-sleeping hours (7:00 am to 10:00 pm).

• All equipment will have sound-control devices no less effective than those provided on the 

original equipment. All construction equipment used will be adequately muffled and 

maintained.

• All stationary construction equipment (e.g., compressors and generators) will be located as 

far as practicable from nearby residences.

• If blasting or other noisy activities are required during the construction period, nearby 

residents will be notified by the operator at least 1 hour in advance.

• Explosives will be used only within specified times and at specified distances from sensitive 

wildlife or streams and lakes, as established by the federal and state agencies.

C.4.3 Noxious Weeds and Pesticides

• The use of certified, weed-free mulch will be required when stabilizing areas of disturbed 

soil.

• If trucks and construction equipment are arriving from locations with known invasive 

vegetation problems, a controlled inspection and cleaning area will be established to visually 

inspect construction equipment arriving at the project area and to remove and collect seeds 

that may be adhering to tires and other equipment surfaces.

• Fill materials and road surfacing materials that originate from areas with known invasive 

vegetation problems will not be used.

• Revegetation, habitat restoration, and weed control activities will be initiated as soon as 

possible after construction activities are completed.

• Use of pesticides must be approved by the agency. Pesticide use will be limited to agencyapproved pesticides and will only be applied in accordance with label and application permit 

directions and stipulations for terrestrial and aquatic applications.

C.4.4 Waste Management

• The operator will plan for suitable equipment refueling and servicing sites during project 

design.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-19

• All refueling will occur in a designated fueling area that includes a temporary berm to limit 

the spread of any spill. 

• Drip pans will be used during refueling to contain accidental releases.

• Drip pans will be used under fuel pump and valve mechanisms of any bulk fueling vehicles 

parked at the construction site.

• Any containers used to collect liquids will be enclosed or screened to prevent access to 

contaminants by wildlife, livestock, and migratory birds.

• Spills will be immediately addressed per the spill management plan, and soil cleanup and 

removal will be initiated as soon as feasible.

• The operator will use nontoxic, nonhazardous drilling fluids whenever practicable.

• The operator will construct suitable impervious containment structures with sufficient volume 

and freeboard to avoid or minimize spills or leakages of oil, gas, salt water, toxic liquids, or 

waste materials from reaching surface waters or groundwater.

C.4.5 Wildlife

• The operator will ensure that employees, contractors, and site visitors avoid harassment and 

disturbance of wildlife, especially during reproductive (i.e., courtship and nesting) seasons. In 

addition, pets will be controlled or excluded to avoid harassment and disturbance of wildlife.

• Ponds, tanks, and impoundments (including but not limited to drill pits) containing liquids 

can present hazards to wildlife. Any liquids contaminated by substances which may be 

harmful due to toxicity, or fouling of the fur or feathers (detergents and oils), should be 

excluded from wildlife access by fencing, netting, or covering at all times when not in active 

use. Liquids at excessive temperature should likewise be excluded. If exclusion is not 

feasible, such as a large pond, a hazing program based on radar or visual detection, in 

conjunction with formal monitoring, should be implemented. Clean water impoundments can 

also present a trapping hazard if they are steep-sided or lined with smooth material. All pits, 

ponds, and tanks should have escape ramps functional at any reasonably anticipated water 

level, down to almost empty. Escape ramps can take various forms depending on the 

configuration of the impoundment. Earthen pits may be constructed with one side sloped 3:1 

or greater lined ponds can use textured material; straight-sided tanks can be fitted with 

expanded metal escape ladders.

C.4.6 Air Quality

• Use of any dust suppressant must be specifically authorized by the Forest Service. The 

operator must consider the following when requesting the authorization to use dust 

suppressants:

♦ Select chemical products suitable for use on the target species or that meet project 

objectives.

♦ Use chemicals that are registered for the intended uses.

♦ Consult the Materials Safety Data Sheet and product label for information on use, 

hazards, and safe handling procedures for chemical products under consideration for use.

♦ Consider chemical solubility, absorption, breakdown rate properties, and site factors 

when determining which chemical products to use.

♦ Use chemicals with properties such that soil residual activity will persist only as long as 

needed to achieve treatment objectives.
Appendix C. Best Management Practices and Mitigation Measures

C-20 Santa Fe National Forest Geothermal Leasing EIS

♦ Consider soil type, chemical mobility, distance to surface water, and depth to 

groundwater to avoid or minimize surface water and groundwater contamination.

♦ Use a suitable pressure, nozzle size, and nozzle type combination to minimize off-target 

drift or droplet splatter.

♦ Specify management direction and appropriate site-specific response measures in project 

plans and safety plans (FSH 2109.14, chapter 60).

♦ Ensure that planned chemical use projects conform to all applicable local, state, federal, 

and agency laws, regulations, and policies.

♦ Obtain necessary permits, including CWA 402 permit coverage.

♦ Develop spill contingency plans.

♦ Obtain or provide training and licensing as required by the label and state regulations.

♦ Incorporate constraints identified on the label and other legal requirements of application 

into project plans and contracts.

♦ Be aware that states may have more restrictive requirements than the label instructions.

C.5 Operations/Utilization

C.5.1 General

• “Good housekeeping” procedures will be developed by the operator to ensure that during all 

phases of exploration and operation the site will be kept clean of noxious weeds, debris, litter, 

garbage, fugitive trash or waste, and graffiti. Scrap heaps and dumps are prohibited. Storage 

yards are to be minimized to that which is absolutely necessary.

• The operator will make adjustments in the plans, authorizations, and bonds if conditions 

develop that are outside the design criteria and conduct adequate notification, emergency 

stabilization, or other activities to avoid effects before proceeding with additional operations.

• The operator will inspect drainage structures and road surfaces after major storm events and 

perform any necessary maintenance.

C.6 Roads

The operator will:

• Maintain the road surface drainage system to intercept, collect, and remove water from the 

road surface and surrounding slopes in a manner that reduces concentrated flow in ditches, 

culverts, and over fill slopes and road surfaces.

• Conduct frequent inspections to ensure road drainage is not adversely affecting soil or water 

resources.

• Clean ditches and catch basins only as needed to keep them functioning.

• Move snow in a manner that will avoid or minimize disturbance of or damage to road 

surfaces and drainage structures.

• Mark drainage structures to avoid damage during plowing.

• Discontinue road use and snow removal when use would likely damage the roadway surface 

or road drainage features.

• Modify snow removal procedures as necessary to meet water quality concerns.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-21

• Replace lost road surface materials with similar quality material and repair structures 

damaged in snow removal operations as soon as practicable.

C.6.1 Chemical Transport and Storage

The operator will:

• Transport and handle chemical containers in a manner that minimizes the potential for leaks 

and spills.

• Inspect containers for leaks or loose caps or plugs before loading.

• Secure containers properly to avoid or minimize shifting in transport.

• Check containers periodically en route. 

• Ensure arrangements for proper storage are in place before transporting chemicals.

• Manage and store chemicals in accordance with all applicable federal, state, or local 

regulations, including label directions.

• Store chemicals in their original containers with labels intact.

• Locate chemical storage facilities at sites that minimize the possibility of impacts to surface 

water or groundwater in case accidents or fires occur.

• At a minimum, ensure that containment of a complete spill from the largest container being 

stored is possible with the spill-kit materials at the storage site.

• Check containers before storage and periodically during storage to ensure that they are 

properly sealed and not leaking.

C.6.2 Produced Water

The operator will:

• Discharge or otherwise dispose of produced water in compliance with the CWA and Safe 

Drinking Water Act, with appropriate approvals from the State and EPA.

• Reinject produced water of suitable quality into acceptable underground reservoirs when 

authorized and appropriate.

• Avoid, minimize, or mitigate surface-discharge effects including headcuts, stream crossing 

washouts, impoundments, channel stability, and flooding.

C.7 Reclamation

• A reclamation plan meeting the following objectives and standards will be submitted prior to 

site development:

Reclamation Objectives

♦ The objective of interim reclamation is to restore vegetative cover and a portion of the 

landform sufficient to maintain healthy, biologically active topsoil; control erosion; and 

minimize habitat, visual, and forage loss during the life of the well or facilities. 

♦ The long-term objective of final reclamation is to return the land to a condition 

approximating that which existed prior to disturbance. This includes restoration of the 

landform and natural vegetative community, hydrologic systems, visual resources, and 

wildlife habitats. To ensure that the long-term objective will be reached through human 

and natural processes, actions will be taken to ensure standards are met for site stability, 

visual quality, hydrological functioning, and vegetative productivity.
Appendix C. Best Management Practices and Mitigation Measures

C-22 Santa Fe National Forest Geothermal Leasing EIS

Reclamation Performance Standards

Interim Reclamation – Includes disturbed areas that may be redisturbed during operations and 

will be redisturbed at final reclamation to achieve restoration of the original landform and a 

natural vegetative community. It will be judged successful when the authorized officer 

determines that disturbed areas not needed for active, long-term production operations or 

vehicle travel have been recontoured, protected from erosion, and revegetated with a selfsustaining, vigorous, diverse, native (or as otherwise approved) plant community sufficient to 

minimize visual impacts, provide forage, stabilize soils, and impede the invasion of noxious, 

invasive, and non-native weeds.

Final Reclamation – Includes disturbed areas where the original landform and a natural 

vegetative community have been restored. It will be judged successful when the authorized 

officer determines that the original landform has been restored for all disturbed areas 

including well pads, production facilities, roads, pipelines, and utility corridors.

♦ A self-sustaining, vigorous, diverse, native (or otherwise approved) plant community is 

established on the site, with a density sufficient to control erosion and invasion by nonnative plants and to reestablish wildlife habitat or forage production. At a minimum, the 

established plant community will consist of species included in the seed mix and/or 

desirable species occurring in the surrounding natural vegetation.

♦ No single species will account for more than [to be determined by site-specific survey]

percent of the total vegetative composition unless it is evident at higher levels in the 

adjacent landscape. 

♦ Permanent vegetative cover will be determined successful when the basal cover of 

desirable perennial species is at least [to be determined by site-specific survey] percent of 

the basal cover on adjacent or nearby undisturbed areas where vegetation is in a healthy 

condition. 

♦ Plants must be resilient as evidenced by well-developed root systems and flowers. Shrubs

will be well established and in a “young” age class at a minimum; therefore, they will not 

be comprised mainly of seedlings that may not survive until the following year.

♦ Erosion features are equal to or less than the surrounding area, and erosion control is 

sufficient so that water naturally infiltrates into the soil and gullying, headcutting, 

slumping, and deep or excessive rills (greater than 3 inches) are not observed.

♦ The site is free of state- or county-listed noxious weeds, oil field debris and equipment, 

and contaminated soil. Invasive and nonnative weeds are controlled.

C.7.1 Reclamation Actions

• During initial well pad, production facility, road, pipeline, and utility corridor construction 

and prior to completion of the final well on the well pad, pre-interim reclamation stormwater 

management actions will be taken to ensure disturbed areas are quickly stabilized to control 

surface water flow and to protect both the disturbed and adjacent areas from erosion and 

siltation. This may involve construction and maintenance of temporary silt ponds, silt fences, 

berms, ditches, and mulching.

• When the last well on the pad has been completed, some portions of the well location will 

undergo interim reclamation and some portions of the well pad will usually undergo final 

reclamation. Most well locations will have limited areas of bare ground, such as a small area 

around production facilities or the surface of a rocked road. Other areas will have interim 

reclamation where workover rigs and tanks may need a level area to set up in the future. 
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-23

Some areas will undergo final reclamation where portions of the well pad will no longer be 

needed for production operations and can be recontoured to restore the original landform.

The following minimum reclamation actions will be taken to ensure that the reclamation 

objectives and standards are met. It may be necessary to take additional reclamation actions 

beyond the minimum in order to achieve the Reclamation Standards.

C.7.2 Reclamation – General

• The agency will be notified 24 hours prior to commencement of any reclamation operations.

• The operator will sample and test the site to identify hazardous materials and associated areas 

that may be contaminated by petroleum products, reactive materials, or other chemicals.

• The operator will use suitable measures to isolate, neutralize, remove, or treat hazardous or 

contaminated materials—including chemicals, reactive materials, acidic wastes, fuels, pit 

fluids, sediment, and human waste—consistent with applicable federal, state, and local 

regulations to achieve applicable standards.

• The operator will properly abandon, plug, and cap all drill holes, cores, and wells per 

applicable state or federal requirements.

• The operator will reconstruct, maintain, or decommission roads, trails, and staging areas 

consistent with the land management plan’s desired conditions, goals, and objectives for the 

area.

• The operator will use suitable measures to limit human, vehicle, and livestock access to the 

site as needed to allow for recovery of vegetation.

C.7.2.1 Housekeeping

• Immediately upon well completion, the well location and surrounding areas(s) will be cleared 

of, and maintained free of, all debris, materials, trash, and equipment not required for 

production.

• No hazardous substances, trash, or litter will be buried or placed in pits. Upon well 

completion, any hydrocarbons in the pit will be remediated or removed.

C.7.2.2 Vegetation Clearing

• Vegetation removal and the degree of surface disturbance will be minimized wherever 

possible.

• During vegetation-clearing activities, trees and woody vegetation removed from the well pad 

and access road will be moved aside prior to any soil-disturbing activities. Care will be taken 

to avoid mixing soil with the trees and woody vegetation. 

• Trees left for wood gathering will be cut and delimbed. Trunks 6 inches or more in diameter 

will be removed and placed either by the uphill side of the access road, moved to the end of 

the road, or moved to a road junction for easy access for wood gatherers and to reduce 

vehicle traffic on the well pad. Trees with a trunk diameter less than 6 inches and woody 

vegetation will be used to trap sediment or slow runoff, or they will be scattered on reclaimed 

areas to stabilize slopes, control erosion, and improve visual resources.

C.7.2.3 Topsoil Management

• Operations will disturb the minimum amount of surface area necessary to conduct safe and 

efficient operations. When possible, equipment will be stored and operated on top of 

vegetated ground to minimize surface disturbance.
Appendix C. Best Management Practices and Mitigation Measures

C-24 Santa Fe National Forest Geothermal Leasing EIS

• In areas to be heavily disturbed, the top (to be determined by a site-specific survey) inches of 

soil material will be stripped and stockpiled around the perimeter of the well location to 

control run-on and run-off, and to make redistribution of topsoil more efficient during interim 

reclamation. Stockpiled topsoil may include vegetative material. Topsoil will be clearly 

segregated and stored separately from subsoils.

• Earthwork for interim and final reclamation will be completed within 6 months of well 

completion or plugging unless a delay is approved in writing by the BLM Authorized Officer.

• Salvaging and spreading topsoil will not be performed when the ground or topsoil is frozen or 

too wet to adequately support construction equipment. If such equipment creates ruts in 

excess of 4 inches deep, the soil will be deemed too wet.

• No major depressions will be left that would trap water and cause ponding.

C.7.2.4 Seeding

• Initial seedbed preparation will consist of recontouring to the appropriate interim or final 

reclamation standard. All compacted areas to be seeded will be ripped to a minimum depth of 

18 inches with a minimum furrow spacing of 2 feet, followed by recontouring the surface and 

then evenly spreading the stockpiled topsoil. Prior to seeding, the seedbed will be scarified 

and left with a rough surface.

• If broadcast seeding is to be used and is delayed, final seedbed preparation will consist of 

contour cultivating to a depth of 4 to 6 inches within 24 hours prior to seeding, dozer 

tracking, or other imprinting in order to loosen up the soil and create seed germination microsites.

• Seed application will be conducted no more than 24 hours following completion of final 

seedbed preparation. 

• A certified weed-free seed mix designed by the Forest Service and BLM to meet reclamation 

standards will be used on all disturbed surfaces, including pipelines and road cut and fill 

slopes.

• The application rate (to be determined by site-specific survey) is based on drill-seeded to a 

depth of 0.25 to 0.5 inches, which is the method that will be used where feasible. 

• Shrub species will be seeded during the winter on the ground surface or preferably on top of 

snow.

• In areas that will not be drill-seeded, the seed mix will be broadcast-seeded at twice the 

application rate shown in the table and covered no more than 0.25 inch deep with a harrow, 

drag bar, or roller or will be broadcast-seeded into imprints, such as fresh dozer cleat marks.

• Seeding will be done in (season to be determined by site-specific survey).

C.7.2.5 Erosion Control and Mulching

• Mulch, silt fencing, wattles, hay bales, and other erosion control devices will be used on areas 

at risk of soil movement from wind and water erosion.

• Mulch will be used if necessary to control erosion, create vegetation micro-sites, and retain 

soil moisture and may include hay, small-grain straw, wood fiber, live mulch, cotton, jute, or 

synthetic netting. Mulch will be free from mold, fungi, and certified free of noxious or 

invasive weed seeds.

• If straw mulch is used, it will contain fibers long enough to facilitate crimping and to provide 

the greatest cover.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-25

C.7.2.6 Pit Closure

• Reserve pits will be closed and backfilled within 60 days of release of the rig. All reserve pits 

remaining open after 60 days will require written authorization of the authorized officer.

Immediately upon well completion, any hydrocarbons or trash in the pit will be removed. Pits 

will be allowed to dry, be pumped dry, or solidified in-situ prior to backfilling.

• Following completion activities, pit liners will be completely removed or removed down to 

the solids level and disposed of at an approved landfill, or treated to prevent their 

reemergence to the surface and interference with long-term successful revegetation. If it was 

necessary to line the pit with a synthetic liner, the pit will not be trenched (cut) or filled 

(squeezed) while containing fluids. When dry, the pit will be backfilled with a minimum of 5 

feet of soil material. In relatively flat areas, the pit area will be slightly mounded above the 

surrounding grade to allow for settling and to promote surface drainage away from the 

backfilled pit.

C.7.2.7 Management of Invasive, Noxious, and Non-Native Species

• All reclamation equipment will be cleaned prior to use to reduce the potential for introduction 

of noxious weeds or other undesirable non-native species.

• An intensive weed monitoring and control program will be implemented prior to site 

preparation for planting and will continue until interim or final reclamation is approved by 

the authorized officer.

• Monitoring will be conducted at least annually during the growing season to determine the 

presence of any invasive, noxious, and non-native species. Invasive, noxious, and non-native 

species that have been identified during monitoring will be promptly treated and controlled. 

C.7.3 Interim Reclamation Procedures – Additional

C.7.3.1 Recontouring

• Interim reclamation actions will be completed no later than 6 months from when the final 

well on the location has been completed, weather permitting. The portions of the cleared well 

site not needed for active operational and safety purposes will be recontoured to the original 

contour if feasible, or if not feasible, to an interim contour that blends with the surrounding 

topography as much as possible. Sufficient semi-level area will remain for setup of a 

workover rig and to park equipment. In some cases, rig anchors may need to be pulled and 

reset after recontouring to allow for maximum interim reclamation.

• If the well is a producer, the interim cut and fill slopes prior to reseeding will not be steeper 

than a 3:1 ratio, unless the adjacent native topography is steeper. Note: Constructed slopes 

may be much steeper during drilling but will be recontoured to the above ratios during 

interim reclamation.

• Roads and well production equipment will be placed on location so as to permit maximum 

interim reclamation of disturbed areas. If equipment is found to interfere with the proper 

interim reclamation of disturbed areas, the equipment will be moved so proper recontouring 

and revegetation can occur.

C.7.3.2 Application of Topsoil & Revegetation

• Topsoil will be evenly respread and aggressively revegetated over the entire disturbed area 

not needed for all-weather operations, including road cuts and fills and to within a few feet of 
Appendix C. Best Management Practices and Mitigation Measures

C-26 Santa Fe National Forest Geothermal Leasing EIS

the production facilities, unless an all-weather, surfaced, access route or small “teardrop” 

turnaround is needed on the well pad.

• In order to inspect and operate the well or complete workover operations, it may be necessary 

to drive, park, and operate equipment on restored, interim vegetation within the previously 

disturbed area. Damage to soils and interim vegetation will be repaired and reclaimed 

following use. To prevent soil compaction, under some situations, such as the presence of 

moist, clay soils, the vegetation and topsoil will be removed prior to workover operations and 

restored and reclaimed following workover operations.

C.7.3.3 Visual Resources Mitigation for Reclamation

• Trees, if present, and vegetation will be left along the edges of the pads whenever feasible to 

provide screening. 

• To help mitigate the contrast of recontoured slopes, reclamation will include measures to 

feather cleared lines of vegetation and to save and redistribute cleared trees, debris, and rock 

over recontoured cut and fill slopes.

• To reduce the view of production facilities from visibility corridors and private residences, 

facilities will not be placed in visually exposed locations (such as ridgelines and hilltops).

• Production facilities will be clustered and placed away from cut slopes and fill slopes to allow 

the maximum recontouring of the cut and fill slopes.

• All long-term, aboveground structures will be painted (color to be determined by site-specific 

survey; from the “Standard Environmental Colors” chart) to blend with the natural color of 

the late-summer landscape background.

C.7.4 Final Reclamation Procedures – Additional

• Final reclamation actions will be completed within 6 months of well plugging, weather 

permitting.

• All disturbed areas, including roads, pipelines, pads, facilities, and interim reclaimed areas 

will be recontoured to the contour existing prior to initial construction or a contour that 

blends indistinguishably with the surrounding landscape. Resalvaged topsoil will be respread 

evenly over the entire disturbed site to ensure successful revegetation. To help mitigate the 

contrast of recontoured slopes, reclamation will include measures to feather cleared lines of 

vegetation and to save and redistribute cleared trees, woody debris, and large rocks over 

recontoured cut and fill slopes.

• Water breaks and terracing will only be installed when absolutely necessary to prevent 

erosion of fill material. Water breaks and terracing are not permanent features and will be 

removed and reseeded when the rest of the site is successfully revegetated and stabilized.

• If necessary to ensure timely revegetation, the pad will be fenced to exclude livestock grazing 

for the first two growing seasons or until seeded species become firmly established, 

whichever comes later. 

• Final abandonment of pipelines and flowlines will involve flushing and properly disposing of 

any fluids in the lines. All surface lines and any lines that are buried close to the surface that 

may become exposed in the foreseeable future due to water or wind erosion, soil movement, 

or anticipated subsequent use, must be removed. Deeply buried lines may remain in place 

unless otherwise directed by the authorized officer.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-27

C.7.4.1 Road Closure

The operator will:

• Remove drainage structures.

• Recontour and stabilize cut slopes and fill material.

• Reshape the channel and streambanks at crossing sites to pass expected flows without 

scouring or ponding, minimize potential for undercutting or slumping of streambanks, and 

maintain continuation of channel dimensions and the longitudinal profile through the crossing 

site.

• Restore or replace streambed materials to a particle-size distribution suitable for the site.

• Restore floodplain function.

• Implement suitable measures to promote infiltration of runoff and intercepted flow and 

desired vegetation growth on the road prism and other compacted areas.

• Use suitable measures in compliance with local direction to prevent and control invasive 

species.

C.7.4.2 Reclamation Monitoring and Final Abandonment Approval

• Reclaimed areas will be monitored annually. Actions will be taken to ensure that reclamation 

standards are met as quickly as reasonably practical.

• Reclamation monitoring will be documented in an annual reclamation report submitted to the 

authorized officer by (date to be determined). The report will document compliance with all 

aspects of the reclamation objectives and standards, identify whether the reclamation 

objectives and standards are likely to be achieved in the near future without additional 

actions, and identify actions that have been or will be taken to meet the objectives and 

standards. The report will also include acreage figures for: 

♦ Initial Disturbed Acres

♦ Successful Interim Reclaimed Acres

♦ Successful Final Reclaimed Acres 

Annual reports will not be submitted for sites approved by the authorized officer in writing as 

having met interim or final reclamation standards. Monitoring and reporting continues annually 

until interim or final reclamation is approved. Any time 30 percent or more of a reclaimed area is 

redisturbed, monitoring will be reinitiated.

• The authorized officer will be informed when reclamation has been completed, appears to be 

successful, and the site is ready for final inspection.
Appendix C. Best Management Practices and Mitigation Measures

C-28 Santa Fe National Forest Geothermal Leasing EIS

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