BLM
BLM MISSION. . .

To sustain the health, diversity, and 

productivity of the public land for the use 

and enjoyment of present and future 

generations.

NLCS MISSION. . .

The PTNM is a unit of the BLM National 

Landscape Conservation System (NLCS). 

The mission of the NLCS is to conserve, 

protect, and restore Nationally-significant 

landscapes that are recognized for their 

outstanding cultural, ecological, and 

scientific values. The PTNM was 

designated in order to conserve, protect, 

and enhance the unique and Nationally-

important paleontological, scientific, 

educational, scenic, and recreational 

resources and values of the public land.

OUR VISION. . .

The Prehistoric Trackways National 

Monument preserves a moment in time 

when the world was poised on the brink of 

cataclysmic change that would usher in the 

era of the dinosaurs. Our vision is to tell 

this story to the Nation through education 

and interpretation, and through scientific 

research. The BLM will maintain the 

rugged and scenic setting while providing 

opportunities for recreationists to enjoy 

these lands now, and for future 

generations, while ensuring the 

sustainability and protection of the 

paleontological resources. We will work 

collaboratively with partners to optimize 

Monument management which will 

enhance our ability to serve the public and 

meet the needs of the Monument resources, 

objects, and values.

BLM/NM/PL-15-01-1610
United States Department of the Interior

BUREAU OF LAND MANAGEMENT

Las Cruces District Office

1800 Marquess Street

 Las Cruces, NM 88005

In reply refer to:

1610-5.G.1.4 (L00000)

December 2014

Dear Reader:

Enclosed are the Proposed Resource Management Plan (RMP) and Final Environmental Impact 

Statement (EIS) for the Prehistoric Trackways National Monument. The Bureau of Land 

Management (BLM) prepared the Proposed RMP/Final EIS in consultation with cooperating 

agencies, taking into account public comments received during this planning effort. The 

Proposed RMP provides a framework for the future management direction and appropriate use of 

the Prehistoric Trackways National Monument, located in Doña Ana County, New Mexico. The 

document contains both land use planning decisions and implementation decisions to guide the 

BLM’s management of the Prehistoric Trackways National Monument.

This Proposed RMP and Final EIS have been developed in accordance with the National 

Environmental Policy Act of 1969, as amended, and the Federal Land Policy and Management 

Act of 1976, as amended. The Proposed RMP is largely based on Alternative C, the preferred 

alternative in the Draft RMP/EIS, which was released on July 20, 2012. The Proposed 

RMP/Final EIS contains the Proposed Plan, a summary of changes made between the Draft 

RMP/EIS and Proposed RMP/Final EIS, impacts of the Proposed Plan, documentation of the all 

the comments received during the public review period for the Draft RMP/EIS, and responses to 

the substantive comments.

Pursuant to BLM’s planning regulations at 43 CFR 1610.5-2, any person who participated in the 

planning process for this Proposed RMP and has an interest which is or may be adversely 

affected by the planning decisions may protest approval of the planning decisions within 30 days 

from date the Environmental Protection Agency (EPA) publishes the Notice of Availability in 

the Federal Register. For further information on filing a protest, please see the accompanying 

protest regulations in the pages that follow (labeled as Attachment # 1). The regulations specify 

the required elements of your protest. Take care to document all relevant facts. As much as 

possible, reference or cite the planning documents or available planning records (e.g., meeting 

minutes or summaries, correspondence, etc.).

Emailed protests will not be accepted as valid protests unless the protesting party also provides 

the original letter by either regular mail or overnight delivery postmarked by the close of the 

protest period. Under these conditions, the BLM will consider the emailed protest as an advance 

copy and will afford it full consideration. If you wish to provide the BLM with such advance 

notification, please direct emailed protests to: protest@blm.gov.

Attachment 1

Protest Regulations

[CITE: 43CFR1610.5-2]

TITLE 43--PUBLIC LANDS: INTERIOR

CHAPTER II--BUREAU OF LAND MANAGEMENT, DEPARTMENT OF THE INTERIOR

PART 1600--PLANNING, PROGRAMMING, BUDGETING--Table of Contents

Subpart 1610--Resource Management Planning

Sec. 1610.5-2 Protest procedures.

(a) Any person who participated in the planning process and has an interest which is or may be 

adversely affected by the approval or amendment of a resource management plan may protest 

such approval or amendment. A protest may raise only those issues which were submitted for 

the record during the planning process.

(1) The protest shall be in writing and shall be filed with the Director. The protest shall be 

filed within 30 days of the date the Environmental Protection Agency published the 

notice of receipt of the final environmental impact statement containing the plan or 

amendment in the Federal Register. For an amendment not requiring the preparation of an 

environmental impact statement, the protest shall be filed within 30 days of the 

publication of the notice of its effective date.

(2) The protest shall contain:

(i) The name, mailing address, telephone number and interest of the person filing 

the protest;

(ii) A statement of the issue or issues being protested;

(iii) A statement of the part or parts of the plan or amendment being protested;

(iv) A copy of all documents addressing the issue or issues that were submitted 

during the planning process by the protesting party or an indication of the date 

the issue or issues were discussed for the record; and

(v) A concise statement explaining why the State Director's decision is believed to 

be wrong.

(3) The Director shall promptly render a decision on the protest.

(b) The decision shall be in writing and shall set forth the reasons for the decision. The decision 

shall be sent to the protesting party by certified mail, return receipt requested. The decision 

of the Director shall be the final decision of the Department of the Interior.

RG-1

PTNM READER’S GUIDE

The following is a brief overview of the organization and content of the Prehistoric Trackways National 

Monument Proposed Resource Management Plan (RMP) and Final Environmental Impact Statement 

(EIS) to aid in your review and understanding of the proposed decisions and actions. All the chapters are 

arranged in the same order or arrangement within the various sections.

The document begins with a Dear Reader Letter explaining 

what BLM is doing, why, a brief overview of the Proposed 

RMP/Final EIS and relevant protest information. This is 

followed by a Table of Contents. The Table of Contents is 

comprehensive and most helpful to locate discussions of 

particular resource programs such as special designations, 

recreation and visitor services, livestock grazing, wildlife 

habitat management and so forth. Next is an Executive 

Summary of the document which gives the reader an 

overview of what is covered in this Proposed RMP/Final 

EIS. The Executive Summary goes over the main topics of 

the Proposed RMP/Final EIS, highlights the key issues 

brought forth in the planning process, and summarizes the 

impacts from the proposed management alternatives.

CHAPTER 1

Chapter 1 identifies the purpose and need for the plan, 

defines the Planning and Analysis Areas, and explains public

participation in the planning process. This chapter identifies 

the planning criteria used as guidelines influencing all 

aspects of the process. These guidelines are based on law, 

regulation, policy, and the designating Legislation. The 

issues developed through public participation and the 

planning processes are described therein.

CHAPTER 2

Chapter 2 presents the various management alternatives for 

achieving the purpose and need. The Proposed RMP/Final 

EIS includes a detailed description of the goals, objectives, 

and management actions for each resource or program that 

could impact the Monument resources, objects, and values. 

The actions in this Proposed RMP/Final EIS are designed to 

provide general management guidance in most cases. The 

resources and uses are organized with the first four topics as 

Paleontological Resources, Education and Interpretation, 

Recreation and Visitor Services, and Trails and Travel 

Management. Subsequent to these four topics, resources or 

uses are in alphabetical order for ease to the reader. It is 

organized in this manner to highlight the major issues within 

the Monument.
RG-2

Specific implementation plans for certain resources/uses, such as a Trails and Travel Management, were 

also developed as part of this interdisciplinary plan. These plans and processes address more precisely 

how a resource or use is to be managed.

There are two different types of decisions within Chapter 2; planning (broad overarching) decisions or 

implementation (on-the-ground) decisions. The implementation decisions are denoted with an asterisk 

(*).

A Summary Comparison Impacts Table is included at the end of Chapter 2. This table provides the reader 

a comparison summary of the main impacts that would result from implementing each of four alternatives 

that were developed for the Prehistoric Trackways National Monument RMP.

CHAPTER 3

Chapter 3 (Affected Environment) provides an overview of the Planning Area and describes the existing 

condition for each of the resources and resource programs. It describes the various components that may 

be affected by the proposed management alternatives. The resources and uses are organized similar to 

Chapter 2 with the first four topics as Paleontological Resources, Education and Interpretation, Recreation 

and Visitor Services, and Trails and Travel Management. Subsequent to these four topics, resources or 

uses are in alphabetical order for ease of the reader.

CHAPTER 4

Chapter 4 (Environmental Consequences) analyzes the beneficial and adverse effects of each alternative. 

Assumptions used in the analysis are specified at the beginning of the Chapter and under certain resource

discussions to help guide the reader through the assessment process. At the end of the analysis of all the 

resources, a discussion of the cumulative effects is provided. The resources and uses are organized in the 

same order as Chapter 2 and 3.

CHAPTER 5

Chapter 5 summarizes key events in the consultation and coordination process prior to and during

preparation of the Prehistoric Trackways National Monument Proposed RMP/Final EIS. It lists those 

agencies and organizations that were contacted or provided input into the planning process. Also listed 

are the BLM team members who prepared or contributed to this RMP/EIS.

GLOSSARY

The Glossary contains the definitions of the terms and technical language used in the text.

REFERENCES

The section contains the bibliography of the references cited in the 

document to assist the reader in the review process.

APPENDICES

The appendices include additional supporting or background material 

referenced in the Proposed RMP/Final EIS.
i

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ....................................................................................................ES-1

CHAPTER 1 PURPOSE AND NEED

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

1.2 Description of the Monument and Analysis Area............................................................... 1-2

1.3 Purpose and Need for the Action ........................................................................................ 1-4

1.4 Scoping and Planning Issues............................................................................................... 1-4

1.4.1 Issues Addressed................................................................................................. 1-6

1.4.2 Issues Considered but not Further Analyzed ...................................................... 1-8

1.5 Planning Criteria/Legislative Constraints........................................................................... 1-8

1.6 Planning Process............................................................................................................... 1-10

1.7 Collaboration..................................................................................................................... 1-14

1.8 Relationship to Other Plans .............................................................................................. 1-14

1.9 Monument Resources, Objects, and Values ..................................................................... 1-15

1.10 Mission Statement and Overall Vision ........................................................................... 1-16

1.11 Changes from the Draft RMP/EIS .................................................................................. 1-17

CHAPTER 2 ALTERNATIVES

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

2.2 Alternative Development.................................................................................................... 2-1

2.2.1 Alternative Themes............................................................................................. 2-2

2.2.2 Alternatives Considered but Not Analyzed in Detail ......................................... 2-4

2.3 PTNM Legislative Directives............................................................................................. 2-4

2.4 Management Alternatives................................................................................................... 2-6

2.4.1 Paleontological Resources................................................................................... 2-6

2.4.2 Education and Interpretation................................................................................ 2-9

2.4.3 Recreation and Visitor Services......................................................................... 2-11

2.4.4 Trails and Travel Management .......................................................................... 2-15

2.4.5 Air Resources..................................................................................................... 2-22

2.4.6 Cultural Resources............................................................................................. 2-23

2.4.7 Lands and Realty................................................................................................ 2-24

2.4.8 Lands with Wilderness Characteristics.............................................................. 2-27

2.4.9 Livestock Grazing.............................................................................................. 2-30

2.4.10 Soils.................................................................................................................. 2-32

2.4.11Special Designation-Robledo Mountains ACEC.............................................. 2-34

2.4.12 Special Designation-Robledo Mountains WSA............................................... 2-34

2.4.13 Special Designation-Paleozoic Trackways Research Natural Area (RNA) .... 2-35

2.4.14 Special Status Species...................................................................................... 2-36

2.4.15 Vegetation ........................................................................................................ 2-37

2.4.16 Visual and Scenic Resources........................................................................... 2-39

2.4.17 Water Resources .............................................................................................. 2-44

2.4.18 Wildland Fire Management ............................................................................. 2-45
ii

Page

2.4.19 Wildlife ............................................................................................................ 2-46

2.5 Summary Comparison of Impacts .................................................................................... 2-47

CHAPTER 3 AFFECTED ENVIRONMENT

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

3.2 Resources and Uses............................................................................................................. 3-1

3.2.1 Paleontological Resources................................................................................... 3-1

3.2.2 Education and Interpretation................................................................................ 3-7

3.2.3 Recreation and Visitor Services........................................................................... 3-8

3.2.4 Trails and Travel Management ............................................................................ 3-9

3.2.5 Air Resources....................................................................................................... 3-9

3.2.6 Cultural Resources............................................................................................. 3-12

3.2.7 Geology/Minerals .............................................................................................. 3-14

3.2.8 Lands and Realty................................................................................................ 3-16

3.2.9 Lands with Wilderness Characteristics.............................................................. 3-16

3.2.10 Livestock Grazing............................................................................................ 3-16

3.2.11 Science and Research Management................................................................. 3-21

3.2.12 Socio-Economic Conditions............................................................................ 3-21

3.2.13 Soils.................................................................................................................. 3-32

3.2.14 Special Designations........................................................................................ 3-34

3.2.15 Special Status Species...................................................................................... 3-39

3.2.16 Vegetation ........................................................................................................ 3-41

3.2.17 Visual and Scenic Resources........................................................................... 3-49

3.2.18 Water Resources .............................................................................................. 3-52

3.2.19 Wildland Fire Management ............................................................................. 3-54

3.2.20 Wildlife ............................................................................................................ 3-58

CHAPTER 4 ENVIRONMENTAL CONSEQUENCES

4.1 Introduction......................................................................................................................... 4-1

4.2 Analytical Methodology ..................................................................................................... 4-1

4.3 Chapter Organization.......................................................................................................... 4-3

4.4 Resource or Resource Use .................................................................................................. 4-4

4.4.1 Paleontological Resources................................................................................... 4-4

4.4.2 Education and Interpretation................................................................................ 4-9

4.4.3 Recreation and Visitor Services......................................................................... 4-15

4.4.4 Trails and Travel Management .......................................................................... 4-26

4.4.5 Air Resources..................................................................................................... 4-29

4.4.6 Cultural Resources............................................................................................. 4-33

4.4.7 Lands and Realty................................................................................................ 4-36

4.4.8 Lands with Wilderness Characteristics.............................................................. 4-39

4.4.9 Livestock Grazing.............................................................................................. 4-41

4.4.10 Socio-Economic Conditions............................................................................ 4-45

4.4.11 Soils.................................................................................................................. 4-52

4.4.12 Special Designations........................................................................................ 4-56
iii

Page

4.4.13 Special Status Species...................................................................................... 4-57

4.4.14 Vegetation ........................................................................................................ 4-61

4.4.15 Visual and Scenic Resources........................................................................... 4-67

4.4.16 Water Resources .............................................................................................. 4-73

4.4.17 Wildland Fire Management ............................................................................. 4-74

4.4.18 Wildlife ............................................................................................................ 4-76

4.5 Cumulative Impacts.......................................................................................................... 4-79

4.5.1 Methodology...................................................................................................... 4-79

4.5.2 Cumulative Impacts........................................................................................... 4-81

4.6 Irreversible and Irretrievable Commitment of Resources................................................. 4-84

4.7 Unavoidable Adverse Impacts.......................................................................................... 4-85

CHAPTER 5 CONSULTATION AND COORDINATION

5.1 Introduction......................................................................................................................... 5-1

5.2 Public Scoping .................................................................................................................... 5-1

5.3 Consultation and Coordination Efforts............................................................................... 5-2

5.4 Additional Collaboration .................................................................................................... 5-3

5.5 Comments on the Draft RMP/EIS ...................................................................................... 5-5

5.6 Proposed RMP/Final EIS Distribution List ........................................................................ 5-5

5.7 List of Preparers and Reviewers......................................................................................... 5-7

GLOSSARY ..........................................................................................................................GL-1

Acronyms.................................................................................................................GL-17

REFERENCES .........................................................................................................................R-1

APPENDICES

Appendix A The Omnibus Public Lands Management Act 2009 .......................................... A-1

Appendix B Acts of Authority and Mandates for the BLM ....................................................B-1

Appendix C Prehistoric Trackways National Monument Comprehensive Trails and Travel 

 Management Plan................................................................................................C-1

Appendix D Paleontology....................................................................................................... D-1

Appendix E Best Management Practices.................................................................................E-1

Appendix F Public Scoping Report .........................................................................................F-1

Appendix G Safety Zones for Recreational Target Shooting Analysis.................................. G-1

Appendix H Public Comments on Draft RMP/EIS and Responses........................................ H-1

MAPS

Map 1-1 Regional Map ............................................................................................................. 1-3

Map 1-2 Prehistoric Trackways National Monument............................................................... 1-5
iv

Page

Map 2-1 Trails and Travel Management, Alternative A......................................................... 2-18

Map 2-2 Trails and Travel Management, Alternative B......................................................... 2-19

Map 2-3 Recreation, Trails and Travel Management, Alternative C ..................................... 2-20

Map 2-4 Recreation Trails and Travel Management, Alternative D ...................................... 2-21

Map 2-5 Minerals Acquisition, Alternatives B, C, & D ......................................................... 2-26

Map 2-6 Lands Managed to Maintain Wilderness Characteristics, Alt B.............................. 2-28

Map 2-7 Lands Managed to Maintain Wilderness Characteristics, Alt C.............................. 2-29

Map 2-8 Visual Resource Management, Alt A....................................................................... 2-40

Map 2-9 Visual Resource Management, Alt B....................................................................... 2-41

Map 2-10 Visual Resource Management, Alt C..................................................................... 2-42

Map 2-11 Visual Resource Management, Alt D..................................................................... 2-43

Map 3-1 Potential Fossil Yield Classification System ............................................................. 3-3

Map 3-2 Lands with Wilderness Characteristics.................................................................... 3-17

Map 3-3 Livestock Grazing Allotments ................................................................................. 3-19

Map 3-4 Soils.......................................................................................................................... 3-33

Map 3-5 Robledo Mountains ACEC....................................................................................... 3-36

Map 3-6 Paleozoic Trackways Research Natural Area .......................................................... 3-37

Map 3-7 Robledo Mountains WSA ........................................................................................ 3-38

Map 3-8 Vegetation ................................................................................................................ 3-42

Map 3-9 Ecological Sites ....................................................................................................... 3-44

Map 3-10 Visual Resource Management ............................................................................... 3-51

Map 3-11 Watersheds............................................................................................................. 3-53

Map 3-12 Fire Regime Condition Classes.............................................................................. 3-55

Map 3-13 Fire Management Unit Categories ......................................................................... 3-57

Map 3-14 Standard Habitat Sites............................................................................................ 3-59

Map 4-1 Recreation and Visitor Services Paleontological Resources with 1⁄2-Mile Safety

 Zone ................................................................................................................... 4-18

Map 4-2 Recreation and Visitor Services Routes and Trails with 1⁄2-Mile Safety Zone ........ 4-19

Map 4-3 Recreation and Visitor Services Combined Criteria 1⁄2-Mile Safety Zones ............. 4-20

FIGURES

Figure 1-1 Planning Process ................................................................................................... 1-11

Figure 3-1 Amphibian Trace..................................................................................................... 3-1

Figure 3-2 Horseshoe Crab Trace ............................................................................................. 3-1

Figure 3-3 Permian Tidal Flat................................................................................................... 3-2

Figure 3-4 Leaf Fossils ............................................................................................................. 3-4

Figure 3-5 Petrified Wood ........................................................................................................ 3-4

Figure 3-6 Walchia Fossils ....................................................................................................... 3-5

Figure 3-7 Dromopus................................................................................................................ 3-6

Figure 3-8 Marine Fossils......................................................................................................... 3-6

Figure 3-9 The Trackways Display at the Las Cruces Museum of Nature and Science .......... 3-7
v

Page

Figure 3-10 The “red beds” of the Abo Formation found in the Prehistoric

 Trackways National Monument.......................................................................... 3-15

Figure 3-11 Race and Ethnicity .............................................................................................. 3-26

Figure 3-12 Employment by Industry in the Study Area........................................................ 3-28

Figure 3-13 Annual Unemployment Rate, 2001-2010 ........................................................... 3-29

TABLES

S-1 Summary of Impacts by Resource by Alternative............................................................ES-6

2-1 Summary of Impacts by Resource by Alternative............................................................ 2-48

3-1 2010-2012 Design Values for Las Cruces, NM ............................................................... 3-10

3-2 Average Temperature and Precipitation for Las Cruces, 1981-2010 ............................... 3-11

3-3 Land Status of Grazing Allotments within the PTNM..................................................... 3-18

3-4 Range Improvements within the Prehistoric Trackways National Monument................. 3-20

3-5 Populations 1990, 2000, 2010 .......................................................................................... 3-22

3-6 Population Density ........................................................................................................... 3-23

3-7 Median Age ...................................................................................................................... 3-23

3-8 Educational Attainment, Percent of Persons Age 25+ ..................................................... 3-24

3-9 Percent of Persons Living in Poverty ............................................................................... 3-25

3-10 Trends in Per Capita Income and Average Earnings Per Job......................................... 3-27

3-11 Contribution of Labor and Non-Labor Income to Total Personal Income ..................... 3-27

3-12 Median Value of Owner-Occupied Homes ................................................................... 3-30

3-13 Payments In Lieu of Taxes, Fiscal Year 2011................................................................ 3-31

3-14 Special Status Species .................................................................................................... 3-39

3-15 Visual Resource Management Acreages within the PTNM........................................... 3-50

3-16 Fire Regime Condition Classes ...................................................................................... 3-56

3-17 Fire Management Units within the PTNM..................................................................... 3-58

4-1 Definition of Impact Terms................................................................................................ 4-1

4-2 VRM Objectives Compared to Visual Resource Inventory Class Ratings,

 Alternative A..................................................................................................... 4-68

4-3 VRM Objectives Compared to Visual Resource Inventory Class Ratings,

 Alternative B..................................................................................................... 4-69

4-4 VRM Objectives Compared to Visual Resource Inventory Class Ratings,

 Alternative C..................................................................................................... 4-70

4-5 VRM Objectives Compared to Visual Resource Inventory Class Ratings,

 Alternative D..................................................................................................... 4-71

4-6 Reasonably Foreseeable Future Actions in Doña Ana County (2010 to 2030)................ 4-80

5-1 List of Preparers and Reviewers......................................................................................... 5-8
EXECUTIVE SUMMARY

tHE 
ES-1

EXECUTIVE SUMMARY

INTRODUCTION

Located in the Robledo Mountains of southern New Mexico lies a major deposit of Paleozoic Era 

fossilized footprints, plants, and wood dating back approximately 280 million years ago. Approximately 

5,255 acres of these fossils located 10 miles northwest of Las Cruces, New Mexico are designated as the 

Prehistoric Trackways National Monument (PTNM) by the Omnibus Public Land Management Act of 

2009.

The Bureau of Land Management (BLM) has prepared this Resource Management Plan (RMP) and 

Environmental Impact Statement (EIS) to provide management guidance for the Federal land within the 

PTNM. These 5,255 acres are considered the Planning Area, while Doña Ana County, where the PTNM 

resides, is considered the Analysis Area.

BACKGROUND

In 1987, a major deposit of Paleozoic Era fossilized footprint megatrackways was discovered in the 

Robledo Mountains by a local Las Crucen, Jerry MacDonald. The area is located in the BLM New 

Mexico Las Cruces District Office and covered by management outlined in the Mimbres RMP (1993). In 

1990, Senator Jeff Bingaman and Congressman Joe Skeen introduced the Prehistoric Trackways Study 

Legislation (S. 2684 and H.R. 4945). In 1993, the legislation was passed which allowed the BLM to 

contract with the Smithsonian Institution and the New Mexico Museum of Natural History and Science to 

conduct a study and prepare a report on the significance of the trackways discovery. The report states:

“. . . evaluation indicates the Robledo Mountains tracksites are the most scientifically 

significant Early Permian tracksites known. The diversity, abundance and quality of the 

tracks in the Robledo Mountains is far greater than at any other known tracksites or 

aggregation of tracksites. Because of this, the Robledo tracks allow a wide range of 

scientific problems regarding late Paleozoic tracks to be solved that could not be solved 

before.” (Lucas, Hunt, and Hotton III 1994)

Senator Bingaman introduced legislation in 2008 to designate the trackways area as a National Monument

“. . . in order to conserve, protect, and enhance the unique and nationally important paleontological, 

scientific, educational, scenic, and recreational resources and values of the public land. . . .” The

Legislation was passed as part of the Omnibus Public Land Management Act of 2009 (the Act or 

Legislation) and designated 5,280 acres as the Prehistoric Trackways National Monument (PTNM or 

Monument) administered by the Bureau of Land Management.

PURPOSE AND NEED

The need for the PTNM Draft RMP/EIS is established by the enabling Legislation which requires that:

“Not later than 3 years after the date of enactment of this Act, the Secretary shall develop 

a comprehensive management plan for the long-term protection and management of the 

Monument... The management plan shall describe the appropriate uses and management

of the Monument, consistent with the provisions of the legislation . . . . “
ES-2

The existing Mimbres RMP (1993) covering the Monument is inadequate to address the mandates of the 

enabling legislation. The purpose of the Monument RMP is to address resource management and public 

uses within the Monument as prescribed by Congressional legislation. The EIS will disclose to the public 

and BLM managers any impacts to the environment that would likely result from implementing the 

agency’s Proposed Action or possible alternatives.

Proposed within Chapter 2 are two different types of decisions. Those decisions are either planning 

(broad overarching) decisions or implementation (on-the-ground) decisions. The BLM Land Use 

Planning Handbook H-1601-1 separates Planning (land use) Decisions for public land into two 

categories: desired outcomes (goals and objectives) and allowable (including restricted or prohibited) uses 

and actions anticipated to achieve desired outcomes. Implementation decisions are the BLM’s final 

approval, allowing on-the-ground actions to proceed. Implementation decisions will always be denoted 

with an asterisk (*).

Legislative Provisions (see Appendix A for the full text of Prehistoric Trackways National 

Monument section of the Omnibus Public Lands Management Act of 2009)

 Conserve, protect, and enhance the following resources and values: Paleontological, Scientific, 

Educational, Scenic, and Recreational.

 Shall only allow uses of the Monument that the Secretary determines would further the purposes 

for which the Monument has been established.

 Provide for public interpretation of, and education and scientific research on, the paleontological 

resources of the Monument, with priority given to exhibiting and curating the resources in Doña 

Ana County, New Mexico.

 Enter into cooperative management agreements or other instruments with interested parties or 

agencies, as appropriate, to coordinate and collaborate management of the Monument.

 Continue to manage that portion of the Robledo Mountains Area of Critical Environmental 

Concern (ACEC) within the Monument.

 Except as needed for administrative purposes or to respond to an emergency, the use of motorized 

vehicles in the Monument shall be allowed only on roads and trails designated in this 

management plan for use by motorized vehicles.

 Subject to valid existing rights, any Federal land within the Monument and any land or interest in 

land that is acquired by the United States for inclusion in the Monument after the date of 

enactment of this Act are withdrawn from - (1) entry, appropriation, or disposal under the public 

land laws; (2) location, entry, and patent under the 1872 mining law as amended; and (3) 

operation of the mineral leasing laws, geothermal leasing laws, and mineral material disposal 

laws.

 Manage any land or interest in land that is acquired by the United States for inclusion in the 

Monument after the date of enactment of this Act in the same manner and degree as herein 

described for the rest of the Monument.
ES-3

 The Secretary may allow grazing to continue in any area of the Monument in which grazing is 

allowed before the date of enactment of this Act, subject to applicable laws (including 

regulations).

ISSUES

The process for developing an RMP begins with identification of planning issues. Issues are areas of 

conflict or controversy between uses and management activities for a given area of public land that must 

be resolved in the RMP. The agency also addresses other basic environmental and management concerns 

to provide comprehensive management guidance for all resources within the Monument and to satisfy 

legal requirements.

The following are issues or areas of concern for the Monument. These were identified through internal 

scoping by resource specialists and/or raised by the public during scoping.

Issues Addressed

Paleontological Research and Protection

1. How will management actions address the legislative mandate of providing for resource 

protection and research of paleontological resources?

2. How will the management prescriptions address site protection and resource mitigation?

Education and Interpretation

1. How will the management actions address the legislative mandate of providing for public 

interpretation of, and education and scientific research on, the paleontological resources of the 

Monument, with priority given to exhibiting and curating the resources in Doña Ana County?

2. What types of education and interpretation are best suited to protection of the fossils? Onsite? 

Off-site?

Travel and Access

1. How can the BLM manage access to the Monument while protecting the resources?

Recreation

1. How will the BLM manage conflicts between motorized use and protection of Monument

objects?

2. How will the BLM manage requests for special recreation permits?

3. How will the management actions address other various recreation opportunities such as 

camping, shooting, and fossil hunting while protecting Monument objects?

4. What opportunities will be available for visitor services and facilities?
ES-4

Management Concerns

Wildlife, Livestock, and Vegetation

1. What management actions will protect wildlife and wildlife habitat?

2. How will livestock grazing be addressed within the Monument?

3. How will management of vegetative communities be addressed in the Monument?

Visual Resources

1. How will the BLM manage threats to scenic quality within the boundaries of the Monument?

Socio-economics

1. How will management actions impact economic and social opportunities in the community?

SUMMARY OF MANAGEMENT ALTERNATIVES

Alternative A

Alternative A or the “No Action Alternative” represents the continuation of existing management, which 

is defined by the Mimbres RMP (1993) and the legislation designating the Monument, the Omnibus 

Public Land Management Act of 2009.

Alternative B

Alternative B represents a more restrictive public use approach of the Monument. This approach is more 

passive; human interventions with the resources are minimal and natural processes would continue at the 

current rate.

 All paleontological resources would be conserved for scientific research.

 Casual collecting of common invertebrate and plant paleontological resources would not be allowed.

 Trails and roads would be restricted to those already developed, and the Monument would be closed 

to all mechanized or motorized vehicles except those permitted for authorized use.

 A majority of the education and interpretation program would be off-site.

 The PTNM would be CLOSED to Special Recreation Permits (SRPs).

 Livestock grazing would not be allowed within the Monument.

Alternative C

Alternative C represents a moderate public use and resource management method of the Monument. 

This alternative allows for protection of the resources while allowing compatible public uses.

 Fossil localities deemed suitable for scientific research may be reserved for scientific research only. 

Localities appropriate for interpretation, educational, and recreational use may be developed.

 Closed to casual collecting of common invertebrate and plant paleontological resources.

 Collecting of common invertebrate fossils would only be allowed while in conjunction with BLM 

authorized interpretive or educational activities or programs.

 Interpretation and education would be enhanced on-site and off-site including a visitor contact station.
ES-5

 Facilitated tours and self-guided interpretive activities would be developed.

 Motorized and mechanized travel within the Monument would be limited to designated routes and 

trails with a permit.

 Approximately 5.4 miles of designated routes would be closed.

 New routes or trails may be developed by the BLM to enhance visitor experiences and research 

opportunities.

 Commercial, competitive, and organized group activities would be managed through the SRP process.

 Grazing would be excluded at specific locations such as exclosures around campsites or in areas to 

protect paleontological resources if determined necessary.

Alternative D

Alternative D represents a maximum use approach to management of the Monument and the widest 

range of public uses of the resources while still following the constraints of the designating Legislation.

 Fossil localities deemed suitable for scientific research would be preserved and reserved for scientific 

research only. Localities appropriate for interpretation, educational, and recreational use would be 

developed for that use.

 Closed to casual collecting of common invertebrate and plant paleontological resources.

 Collecting of common invertebrate fossils would only be allowed while in conjunction with BLM 

authorized interpretive or educational activities or programs.

 Interpretation and education would be developed for the Monument both on-site and off-site as would 

a visitor center.

 Facilitated tours and self-guided interpretive activities would be developed along with an interpretive 

motor tour route.

 Motorized and mechanized travel within the Monument would be limited to designated routes.

 Approximately 4.0 miles of designated routes would be closed.

 New routes and trails may be developed to enhance visitor experiences and research opportunities.

 Competitive, commercial, and organized group activities would be managed through the SRP process.

 Current livestock management would continue in the Monument.

ENVIRONMENTAL IMPACTS

Table S-1 summarizes the impacts by resource by alternative for the PTNM. These impacts are fully 

discussed in Chapter 4.

The following resources have been found to have negligible or no impacts from any of the management 

alternatives proposed:

 American Indian Uses and Traditional Cultural Practices

 Riparian Areas

 Woodland Management

 Floodplains and Wetlands

 Geology

 Minerals

 Hazardous and Solid Wastes

 Prime or Unique Farmlands

 Wild and Scenic Rivers
ES-6

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

PALEONTOLOGICAL RESOURCES

Casual collecting of common 

invertebrate and plant 

paleontological resources 

would lead to depletion of the 

resources.

Off-site interpretation would 

increase protection through 

enhancing awareness, and 

leaving sites conserved in-situ 

for future research.

Vehicles would continue to 

damage fossils through 

crushing, fracturing, or 

staining.

Closing the PTNM to the 

casual collection of fossils 

would reduce the loss of 

scientific-worthy vertebrate 

fossils, but would also 

reduce educational and 

recreational opportunities. 

Off-site interpretation would 

protect resources by 

increasing awareness and 

leaving paleontological sites 

conserved in-situ for future

research.

Closure to motorized and 

mechanized travel would 

eliminate damage to fossils 

from this use.

Restricting the casual collecting 

of common invertebrate and 

plant fossils would reduce the 

loss of scientific-worthy 

vertebrate fossils.

On-site education and 

interpretation would increase 

awareness of the resource but 

could increase the potential for 

looting.

Closing certain routes would 

protect important exposed 

fossils from OHV activity. 

Development of visitor facilities 

could increase visitation and 

thereby result in increased 

stewardship, but vandalism and 

looting could also increase.

Same as Alternative C except, 

both the beneficial and 

adverse impacts from on-site 

interpretation and facilities 

would be increased due to 

more development.

EDUCATION AND INTEPRETATION

Scientific research would 

enhance education and 

interpretation through the 

discovery of new sites.

Casual collecting of common 

invertebrate and plant 

paleontological resources

would enhance the educational 

experience in the Monument.

Limited facility and trail 

development would constrain 

the interpretive experience onsite.

Same as Alternative A.

The closure to casual 

collection of fossils would 

limit the on-site interpretive 

experience.

Same as Alternative A.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities such as 

interpretative trails and signs 

in those areas (576 acres).

Same as Alternative A.

Same as Alternative B.

On-site interpretation, trails and 

facilities would be developed to 

enhance educational 

opportunities.

Same as Alternative B except 

surface disturbing activities may 

be limited to 253 acres. The 

remaining 323 acres found to 

have wilderness characteristics, 

but not managed for those 

characteristics, may be impacted 

from potential surface 

disturbing activities. 

Same as Alternative A. 

Collecting common fossils in 

conjunction with a BLM 

activity would enhance the 

educational experience.

The development of a 

motorized interpretive tour or 

a visitor center would enhance 

the experience of many 

visitors.

Lands found to have 

wilderness characteristics 

would not be managed for 

those characteristics, therefore 

development may occur and 

may impact the wilderness 

characteristics in those areas 

(576 acres).
ES-7

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

RECREATION AND VISITOR SERVICES

Annual visitation to the 

Monument area is 25,000.

Casual collecting of common 

invertebrate and plant fossils 

provides a recreational 

opportunity. 

The lack of on-site visitor 

facilities limits the visitor 

experience and may reduce 

visitation from some groups. 

Target shooting could cause 

conflict between users.

No planned improvement or 

maintenance of trails would 

limit recreation.

Annual visitation may be 

reduced by 5,625 visitors. 

Casual collection of fossils, 

Special Recreation 

Permits, and motorized and 

mechanized vehicle use 

would not be allowed, thus 

reducing the number of 

recreation opportunities.

Same as Alternative A.

Same as Alternative A.

Annual visitation would increase 

to 37,500 people.

Same as Alternative B.

On-site visitor facilities would 

enhance the visitor experience 

and may increase visitation.

Closure to target shooting would 

reduce a recreational opportunity.

Closure of a portion of the OHV 

trails would impact the extreme 

OHV users. Maintaining and 

developing trails and routes 

would enhance recreational 

opportunities.

Annual visitation would 

increase to 75,000 people.

Collecting common fossils 

while in conjunction with a 

BLM activity would provide a 

recreational opportunity.

A visitor center and a 

campground would create 

recreational opportunities.

Same as Alternative C.

A 1.4-mile portion of trail 

route would remain open 

providing an opportunity to 

access an extreme route. 

TRAILS AND TRAVEL MANAGEMENT

Continued use of the existing 

37.6 miles of designated trails 

provides an extensive route 

network with a variety of 

opportunities for motorized, 

mechanized, and pedestrian 

use and travel. 

Improvement or maintenance 

of existing routes has not been 

planned for, reducing the ease 

of access for educational and 

some recreational uses.

Closing the Monument to 

motorized and mechanized 

travel would reduce access 

to most visitors.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities, such as 

trails and roads and routes in 

those areas (576 acres).

Lack of improvement or 

maintenance of routes would 

reduce the ease of access and 

recreational experience for 

many visitors.

Limiting motorized and 

mechanized travel to 32.2 miles 

of designated routes would 

provide an extensive route 

network with a variety of 

opportunities for use.

Lands found to have wilderness 

characteristics, managed for 

those characteristics, may limit 

the new development of 

facilities, additional roads and 

routes and maintenance in those 

areas (253 acres). The 323 

acres found to have wilderness 

characteristics, but not managed 

for those characteristics, may be 

impacted from potential surface 

disturbing activities

Improved and maintained routes 

would enhance the visitor 

experience.

Same as Alternative C, except 

33.6 miles of routes would be 

designated.

Lands found to have 

wilderness characteristics 

would not be managed for 

those characteristics, therefore 

new trails, roads, and route 

construction may occur and 

may impact the wilderness 

characteristics in those areas 

(576 acres).

Same as Alternative C.
ES-8

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

AIR RESOURCES-- AIR QUALITY

Vehicle travel on designated 

trails has the potential to emit 

pollutants and cause dust.

Surface disturbance from 

potential authorized rights-ofway could cause dust 

emissions.

Mineral extraction could cause 

dust emissions.

Closure to motorized and 

mechanized use would 

reduce dust and emissions 

compared to Alternative A.

Rights-of-way would not be 

allowed. Emissions would 

be less than Alternative A.

No mineral extraction would 

take place. Emissions would 

be less than Alternative A.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities, and 

potentially reduce dust 

emissions in those areas (576 

acres), compared to 

Alternative A. 

Same as Alternative A. 

Same as Alternative A.

Same as Alternative B.

The 323 acres of lands with 

wilderness characteristics, but 

not managed for them, may be 

subject to disturbing activities 

that increase dust emissions.

Construction of facilities could 

cause emissions. 

Same as Alternative A.

Same as Alternative A.

Same as Alternative B.

Lands found to have 

wilderness characteristics 

would not be managed for 

them. Dust emissions may 

potentially increase due to 

surface disturbing activities in 

those areas (576 acres).

Same as Alternative C.

AIR RESOURCES -- CLIMATE

It is not possible to predict with certainty the potential emissions of greenhouse gases (GHG) associated with the four alternatives, 

their potential impacts on temperature within the Planning Area, or related impacts on resources due to climate change. In general, 

trails and travel management, livestock grazing, and wildland fire generate GHG emissions that contribute to climate change and, in 

turn, may impact resources.

CULTURAL RESOURCES

The BLM would comply with 

Section 106 of the National 

Historic Preservation Act 

thereby minimizing impacts to 

cultural resources.

Closure of the Monument to 

rights-of way, vehicular 

travel and other surface 

disturbing activities would 

greatly reduce the potential 

impacts to cultural resources.

Same as Alternative A Same as Alternative A
ES-9

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

LANDS AND REALTY

Surface disturbing land use 

authorizations could take 

place.

Commercial-scale renewable 

energy would be excluded. 

Authorizations would meet 

Visual Resource Management 

(VRM) Classes I to IV.

Surface disturbing land use 

authorizations would be 

excluded from the PTNM.

Same as Alternative A.

There would be no VRM 

impacts.

Obtaining non-Federal 

minerals would eliminate 

split-estate issues.

Surface disturbing land use 

authorizations would be 

considered with the exception of 

lands managed for their 

wilderness characteristics.

Same as Alternative A.

VRM I and II could limit land 

use authorizations.

Same as Alternative B.

Same as Alternative C

Same as Alternative A.

Same as Alternative C.

Same as Alternative B.

LANDS WITH WILDERNESS CHARACTERISTICS

Lands found to have 

wilderness characteristics but 

not managed for those 

characteristics may be 

impacted (576 acres).

Managing for lands with 

wilderness characteristics 

would protect the wilderness 

characteristics in those areas 

(576 acres).

Lands found to have wilderness 

characteristics and managed for 

them may limit disturbance 

activities (253 acres). The 

remaining 323 acres found to 

have wilderness characteristics, 

but not managed for them, may 

be impacted from potential 

surface disturbing activities.

Designation of the Monument 

as VRM I and II would help 

retain wilderness characteristics.

Same as Alternative A. 

VRM I and II designations 

may help to retain some of the 

wilderness characteristics 

found in the PTNM.

LIVESTOCK GRAZING

Increased visitation could 

cause increased conflicts with 

livestock and recreational 

users.

Vegetation treatments could 

improve forage and reduce 

competition.

There would be no direct 

impacts from livestock 

grazing in the Monument.

Exclusion from grazing 

would require fencing and 

management adjustments in 

the Picacho Peak and 

Altamira allotments. 

Animal unit months (AUMs) 

would be reduced by a 

minimum of 456 for the two 

allotments.

Same as Alternative A.

Fences would be constructed to 

protect significant fossils as 

needed. Forage reductions 

would be based on the specific 

acres excluded.

Same as Alternative A but using 

more effective techniques.

Excluding improvements from 

253 acres managed for 

wilderness characteristics may 

reduce the use of forage.

Same as Alternatives C with 

more anticipated interactions 

between visitors and livestock 

as visitor facilities and routes 

increase.

Same as Alternatives A and C, 

but with more forage possibly 

improved.
ES-10

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

SOCIO-ECONOMIC CONDITIONS

Visitation to the PTNM would 

support 16 jobs and $417,000 

in labor income annually.

Visitor facilities would not be 

constructed.

Alternative A has the lowest 

levels of non-market economic 

values and the least support for 

social values related to 

preservation of ecological 

health and wilderness.

Similar levels of employment 

and income would be 

supported.

None of the decisions are 

expected to disproportionately 

or adversely affect 

environmental justice 

communities.

Designation of 37.6 miles of 

roads and trails open to 

motorized and mechanized 

uses supports social values 

related to public land access 

and OHV recreation.

Visitation to the PTNM 

would support 4 jobs and 

$94,000 in labor income 

annually.

Economic benefits from 

facility construction would 

not be realized.

Alternative B would support 

the highest levels of nonmarket economic values and 

social values related to 

protection of natural and 

cultural resources.

Elimination of grazing 

would reduce labor income 

to ranchers.

Same as Alternative A

Closure to motorized and 

mechanized uses would 

reduce the quality of life for 

those who primarily value 

OHV recreation, but would 

make PTNM more of an 

attraction for others.

Visitation to the PTNM would 

support 24 jobs and $626,000 in 

labor income annually.

Development of visitor facilities 

would temporarily increase 

local employment and labor 

income during construction.

Alternative C balances social 

values of access and motorized 

recreation with values related to 

ecological health and 

wilderness.

Social and economic 

consequences of grazing are the 

same under Alternatives A.

Same as Alternative A.

Same as Alternative A but with 

a reduction in available routes 

for extreme OHV opportunities.

Visitation to the PTNM would 

support 47 jobs and annual 

labor income of $1,251,000.

Same as Alternative C.

Alternative D would support 

lower levels of non-market 

economic values and social 

values related to protection of 

natural and cultural resources.

Same as Alternatives A.

Same as Alternative A.

Same as Alternative C.

SOILS

Excavations could cause 

highly disturbed areas. Casual 

collecting of fossils would 

have a minor disturbance. 

Soil disturbance would be 

caused by recreation, research, 

interpretation tours, camping, 

Special Recreation Permits, 

vehicular travel, right-of-way 

development, and range 

improvements. 

Spills of petroleum products 

could contaminate soils.

Surface disturbance would 

be reduced because casual 

collecting would be 

prohibited.

Closure to vehicular travel 

and camping, no issuance of 

Special Recreation Permits, 

removal of grazing, and 

exclusion of surface 

disturbing land use 

authorizations would all 

benefit soils.

Same as Alternative B.

Visitor facilities would displace 

and compact soils, increasing 

runoff and erosion rates.

Same as Alternative A.

Same as Alternative C.
ES-11

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

SPECIAL DESIGNATION -- AREA OF CRITICAL ENVIRONMENTAL CONCERN (ACEC)

Manage as the Robledo 

Mountains ACEC.

Same as Alternative A. Same as Alternative A. Same as Alternative A.

SPECIAL DESIGNATION-- RESEARCH NATURAL AREA (RNA)

Management prescriptions of 

the RNA would be duplicated 

by the PTNM Legislation.

The RNA designation would

be removed and replaced by 

the PTNM RMP decisions.

Same as Alternative B. Same as Alternative B.

SPECIAL DESIGNATION -- WILDERNESS STUDY AREA (WSA)

The Robledo Mountains WSA 

would be managed to meet the 

non-impairment standard. 

Same as Alternative A. Same as Alternative A. Same as Alternative A.

SPECIAL STATUS SPECIES

Vehicle travel and dispersed 

recreation has the potential to 

temporarily displace special 

status species or injure slow 

moving species.

Livestock watering sources 

would benefit special status 

species such as bats.

Vegetation management would 

improve habitat for species 

associated with grasslands.

Closure to motorized and 

mechanized travel would 

reduce potential for injury of 

some species such as Texas 

horned lizard.

Elimination of livestock 

grazing could reduce forage 

competition and improve 

habitat for species such as 

burrowing owl and northern 

shrike.

Same as Alternative A.

Same as Alternative A except 

development could increase 

temporary displacement of 

special status species or injure 

slow moving species.

Same as Alternative A. 

Same as Alternative A.

Same as Alternative C.

Same as Alternative A.

Same as Alternative A.

VEGETATION

Special designations would 

protect 789 acres from surface 

disturbing activities.

Use of trails and routes has the 

potential to remove or damage 

vegetation and spread noxious 

weeds.

Livestock grazing may remove 

30 to 50 percent of key forage 

species and has the potential to 

introduce or spread weeds.

Vegetation treatments have the 

potential to shift species 

dominance and control weeds.

Same as Alternative A, but 

with an additional 576 acres 

managed as lands with 

wilderness characteristics.

Surface disturbing activities, 

e.g., Special Recreation 

Permits, OHV use, and 

rights-of-way, would be 

restricted to reduce the 

potential for damage to 

vegetation. 

Elimination of livestock 

grazing decreases utilization 

of forage species favored by 

cattle.

Treatment options would be 

limited for noxious weed 

control.

Same as Alternative A except an 

additional 253 acres would be 

managed as lands with 

wilderness characteristics.

Development of new trails, 

routes, or facilities could 

remove vegetative cover in 

other areas.

Same as Alternative A

Same as Alternative A.

Same as Alternative A.

Same as Alternative C except 

additional surface disturbance 

and vegetation removal is 

possible from facilities 

development.

Same as Alternative A.

Same as Alternative A.
ES-12

TABLE S-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

VISUAL RESOURCES

VRM Class I designation 

would preserve the character 

of the landscape on 789 acres 

of the most scenic, natural 

appearing, and visually 

sensitive areas.

VRM Class II would retain the 

existing character of the 

landscape on 907 acres.

The remaining lands would be 

designated as VRM Class III 

and IV, which allow more 

change in the visual character 

of the land.

Development of 368 acres of 

non-Federal minerals may 

impact the existing character 

of the landscape.

1,365 acres would be 

designated as VRM Class I 

as described in Alternative 

A.

3,912 acres would be 

designated VRM Class II as 

described in Alternative A. 

Exclusion of livestock from 

the Monument could cause 

short-term visual impacts 

from fence construction.

1,042 acres would be designated 

VRM Class I as described in 

Alternative A.

4,213 acres would be designated 

VRM Class II as described in 

Alternative A. 

Same as Alternative A.

789 acres would be designated 

VRM Class I as described in 

Alternative A.

4,465 acres would be VRM 

Class II as described in 

Alternative A.

Same as Alternative A.

WATER RESOURCES

Surface disturbing activities 

may create nonpoint source 

pollutants that could transport 

to the Rio Grande, decrease 

infiltration, increase runoff, 

and alter water flow patterns.

Restrictions in surface 

disturbing activities would 

help soil stability and 

productivity, hinder erosion, 

and reduce nonpoint source 

pollution.

Same as Alternative A. Same as Alternative A.

WILDLAND FIRE MANAGEMENT

Visitation and associated 

recreation activities could 

increase potential for humancaused wildfires. 

Vegetation treatments could 

cause an increase in fuel 

loading resulting in unwanted 

fire behavior.

Same as Alternative A 

except the reduction of some 

recreation activities would 

reduce the potential of 

human-caused wildfires.

Reduction in livestock 

grazing would increase fuels 

and the likelihood that a 

wildfire would carry.

Same as Alternative A. Same as Alternative A.

WILDLIFE

Increase in visitation and 

recreation activities could 

temporarily displace wildlife.

Vehicular travel has the 

potential to injure slow 

moving wildlife.

Closure to travel would 

decrease potential injury and 

displacement of wildlife.

Removal of livestock would 

increase forage and cover for 

wildlife.

Same as Alternative A except 

increased displacement could 

occur around developed 

interpretation sites and facilities

Same as Alternative C, except 

prescribed fire could displace, 

kill or render habitat 

unsuitable but would have 

long-term benefits to habitat.
PURPOSE AND NEED

CHAPTER 1

tHE 
1-1

CHAPTER 1 PURPOSE AND NEED

1.1 INTRODUCTION

In 1987, a major deposit of Paleozoic Era fossil footprints and trace fossils trackways were discovered in 

the Robledo Mountains in southern New Mexico. The deposit contains imprints of tracks, tail drags, 

burrows, and body impressions of numerous amphibians, reptiles, and insects (including previously 

unknown species), as well as impressions of plants and petrified wood that date to approximately 280

million years ago. Together, these types of fossils are known as ichnofossils. Ichnofossils are fossilized 

traces of actions and behaviors; they may include footprints, burrow casts, and body impressions. These 

paleontological resources collectively provide new opportunities to understand animal behaviors and 

environments from a time predating the dinosaurs. The area is located in the Bureau of Land 

Management (BLM) New Mexico Las Cruces District Office and covered by management outlined in the 

Mimbres Resource Management Plan (RMP) (BLM 1993). In 1990, Senator Jeff Bingaman and 

Congressman Joe Skeen introduced the Prehistoric Trackways Study Legislation (S. 2684 and H.R. 

4945). In 1993, the legislation passed which led the BLM to contract with the Smithsonian Institution 

and the New Mexico Museum of Natural History and Science to conduct a study and prepare a report on 

the significance of the trackways discovery. The report states:

...evaluation indicates the Robledo Mountains tracksites are the most scientifically 

significant Early Permian tracksites known. The diversity, abundance and quality 

of the tracks in the Robledo Mountains is far greater than at any other known 

tracksites or aggregation of tracksites. Because of this, the Robledo tracks allow a 

wide range of scientific problems regarding late Paleozoic tracks to be solved that 

could not be solved before. (Lucas, Hunt, and Hotton III 1994)

In 2008, Senator Bingaman introduced legislation to designate an area of public land in the southern 

Robledo Mountains as a National Monument . . . “in order to conserve, protect, and enhance the unique 

and nationally important paleontological, scientific, educational, scenic, and recreational resources and 

values of the public land....” The legislation was passed as part of the Omnibus Public Land 

Management Act of 2009 (the Act or Legislation) and designated 5,280 acres as the Prehistoric 

Trackways National Monument (PTNM or Monument) administered by the BLM. The Act as it pertains 

to PTNM is reprinted in Appendix A. This Legislation directs the BLM to develop a comprehensive

management plan specifically for the Monument.

This land use plan provides direction for the Prehistoric Trackways National Monument consistent with 

the designating legislation and manages its resources using scientific principles and expertise. The BLM 

developed a Draft Resource Management Plan and Environmental Impact statement (RMP/EIS) to 

analyze and consider measures to ensure that resources, objects and values are conserved, protected, and 

restored. This Proposed RMP/Final EIS will become the basis for every on-the-ground action the BLM 

undertakes in the Monument.

This Proposed RMP/Final EIS describes four alternative management strategies, identifies the potential 

impacts of implementation of the alternatives, and outlines the appropriate measures to mitigate those 

impacts. The EIS analyzes and documents the direct, indirect, and cumulative impacts of the reasonably 

foreseeable future actions resulting from the BLM’s management decisions. These impacts must be 

analyzed before BLM allocates public land resources and the RMP/EIS satisfies the requirements of the 

National Environmental Policy Act of 1969 (NEPA), Council on Environmental Quality (CEQ) 

regulations implementing NEPA (40 CFR 1500-1508), Federal Land Policy and Management Act 

(FLPMA), the Paleontological Resources Preservation Act (PRPA) and other associated regulations.
1-2

1.2 DESCRIPTION OF THE MONUMENT AND ANALYSIS AREA

The Monument is located in the southern third of the Robledo Mountains and is approximately 10 miles 

northwest of the City of Las Cruces in Doña Ana County, New Mexico (see Map 1-1). The Robledo 

Mountains are a north-south trending fault-block located northwest of Las Cruces. Elevation varies from 

5,876 feet on Robledo Mountain to about 4,100 feet at the southern end. The area is characterized by an 

arid, continental climate with mild winters and warm-to-hot summers. Summer daytime temperatures 

often exceed 100 o F. Average annual precipitation is slightly less than 9 inches; however wide variations 

in both temperature and precipitation are not uncommon. 

Vegetation in the Monument is sparse, dominated by grasses and Chihuahuan Desert shrub species. A 

few juniper trees are scattered, primarily along north slopes and arroyos. Shrubs include mesquite, yucca, 

whitethorn acacia, creosote, and mimosa, with scattered agaves and various cacti.

Wildlife of the Monument is typical of the Chihuahuan Desert, but also includes species that may be 

found along the Rio Grande and the nearby farming areas in the Mesilla Valley. Species that may be 

found within the Monument include side-blotched lizards and marbled whiptail lizards, mule deer, blacktailed jackrabbits, desert cottontails, and spotted ground squirrels. Common birds include mourning dove, 

Northern Harrier, Swainson’s hawk, red-tailed hawk, Chihuahuan raven, greater roadrunner, 

mockingbird, scaled quail, and Gambel’s quail.

Prior to designation, a portion of the Monument was managed by the BLM as the Paleozoic Trackways 

Research Natural Area (RNA), as designated by the Mimbres RMP (BLM 1993). The management goals 

of the Paleozoic Trackways RNA were to protect, research, and interpret paleontological resources (Map 

1-2). The Robledo Mountains Area of Critical Environmental Concern (ACEC) was designated to protect 

paleontological and scenic resources in the Mimbres RMP as well. A portion of the ACEC (789 acres) is 

within the Monument. The ACEC boundary and the Robledo Mountains Wilderness Study Area (WSA) 

boundary overlap (Map 1-2). The Robledo Mountains WSA was recommended in 1980 and since that 

time, the BLM has managed the area to preserve its wilderness character (BLM 1980).

The Robledo Mountains are used for many types of recreation, including hiking, mountain biking, fossil 

and rock collecting, hunting, horseback riding, camping, target shooting and off-highway vehicle (OHV)

use. A system of designated OHV trails was authorized in 1997. The Robledo Mountains Off-Highway 

Vehicle Trails are used almost daily by casual OHV enthusiasts. The annual Chile Challenge OHV event 

has been permitted through the BLM Special Recreation Program for the past 16 years. This is a 

Nationally-recognized “rock-crawling” activity that attracts both regional and international participants.

In the Omnibus Lands Act, the acreage of the Monument is stated as 5,280. However, the acreage 

calculated using the BLM’s Geographic Information System (GIS), which allows production of maps and 

analysis based on digitized satellite imagery shows a smaller acreage area of 5,255 acres. Because the 

acreage difference is relatively insignificant in comparison to the level of effort required to reconcile the 

data precisely, the BLM Planning Team has elected to use the GIS figures throughout the analysis. These 

differences are not large enough to change the outcome of the analysis.

The designating Legislation states: “If additional paleontological resources are discovered on public 

land adjacent to the Monument after the date of enactment of this Act, the Secretary may make minor 

boundary adjustments to the Monument to include the resources in the Monument.” If public land is 

added to the Monument, it will be administered following the same management decisions resulting from 

this document.
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The Planning Area is the area for which decisions made in this RMP will apply. The Planning Area 

consists of 5,255 acres of Federal surface estate and 4,886 acres of Federal subsurface estate, designated 

as the PTNM (see Map 1-2).

The term Analysis Area is used for some resources and resource use discussions outside the Planning 

Area. The Analysis Area, Doña Ana County, includes public, private, and other government lands, and 

consists of 2,436,595 acres.

1.3 PURPOSE AND NEED FOR THE ACTION

The enabling Legislation established the need for the PTNM RMP/EIS, which requires that “Not later 

than 3 years after the date of enactment of this Act, the Secretary shall develop a comprehensive 

management plan for the long-term protection and management of the Monument... The management 

plan shall describe the appropriate uses and management of the Monument, consistent with the 

provisions of the legislation.” The purpose of the Monument RMP is to address resource management 

and public uses within the Monument as prescribed by the Legislation, including:

 Manage the Monument in a manner that conserves, protects, and enhances the paleontological, 

scientific, educational, scenic, and recreational resources and values of the Monument.

 The Secretary shall provide for public interpretation of, and education and scientific research on, 

the paleontological resources of the Monument, (with priority given to exhibiting and curating the 

resources in Doña Ana County, New Mexico).

 The use of motorized vehicles in the Monument shall be allowed only on roads and trails 

designated for use by motorized vehicles under the RMP.

 The Secretary may issue permits for special recreation events involving motorized vehicles within 

the boundaries of the Monument to the extent the events do not harm paleontological resources, 

and subject to any terms and conditions that the Secretary determines to be necessary.

1.4 SCOPING AND PLANNING ISSUES

The process for developing an RMP begins with the identification of planning issues (40 CFR 1502.7 and 

43 CFR 1610.4-1). Issues are areas of conflict or controversy between uses and management activities 

for a given area of public land that must be resolved in the RMP. The agency also addresses 

environmental and management concerns in order to provide comprehensive management guidance for all 

resources within the Monument and to satisfy legal requirements.

BLM specialists and the public identified planning issues during internal and public scoping. The BLM 

then refined the preliminary planning issues and determined which issues would be carried forward.
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1.4.1 Issues Addressed

Paleontological Research and Protection

How will management actions address the legislative mandate of providing for resource 

protection and research of paleontological resources?

How will the management prescriptions address site protection and resource mitigation?

The paleontological resources of the Monument provide information and insight into the Permian Era. 

Research of the paleontological resources has increased the knowledge of the Permian Era environment 

and life forms that existed during this interval of geologic history. This research has also provided the 

BLM with information for public educational and interpretive materials.

The BLM has entered into a partnership with the New Mexico Museum of Natural History & Science 

(NMMNHS) to collect, record locality data, curate, research, publish, and provide educational materials 

relating to the paleontological resources discovered in what is now the PTNM. The NMMNHS continues 

to publish scientific information regarding the fossils of the Robledo Mountains through scientific 

journals. The NMMNHS is in the process of finalizing a report for the BLM that provides 

recommendations for the management of paleontological resources within the PTNM. The NMMNHS

has also provided several trackways specimens through a long-term loan that are currently on exhibit at 

the Las Cruces Museum of Nature and Science.

Interpretation and Education

How will the management actions address the legislative mandate of providing for public 

interpretation of, and education and scientific research on, the paleontological resources of the 

Monument, with priority given to exhibiting and curating the resources in Doña Ana County?

What types of education and interpretation are best suited to protection of fossils? Onsite?

Off-site?

Since the designation of the Monument in 2009, the BLM has initiated education and interpretation 

activities. Park rangers regularly give programs for community groups and partnering agencies, host an 

annual K-5 paleontology day camp, visit classrooms, host field trips, and give guided hikes to the public. 

The PTNM is a BLM Hands on the Land Site – a National network of outdoor classrooms on public land.

The Monument has a K-8 curriculum and school kit for in-classroom and field trip activities. There are 

two traveling trunk exhibits that are stationed in visitor centers around Las Cruces. In 2009, the BLM 

partnered with the NMMNHS, the Smithsonian’s National Museum of Natural History and New Mexico 

State University’s Creative Media Institute to make 10 podcasts in which scientists explain the scientific 

significance of the Trackways. As the on-site educational and interpretive programs expand, facilities 

such as trails with wayside interpretive exhibits may be needed.

The BLM has entered into a partnership with the City of Las Cruces Museums and assisted in developing 

the trackways exhibits for their new Museum of Nature and Science. The theme of the new museum is 

“Trackways to Space” and the centerpiece exhibit is a large sandstone trackway segment that includes 

ichnofossils from a number of Permian species. There are several other exhibits that also interpret 

various aspects of the trackways and the Monument. This museum now serves as the primary gateway to 

educating the public on the resources of the Monument; future plans may include educational 

presentations and guided tours of the Monument.
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Travel and Access

How can the BLM manage access to the Monument while protecting the resources?

Within the Monument are 37.6 miles of primitive roads. Most of these primitive roads were created in 

conjunction with the Robledo Off-Highway Vehicle Trails, and they usually follow drainage bottoms. 

There are portions of some primitive roads that follow along prominent ridge lines. As primitive roads,

these are not maintained and do not adhere to any BLM prescription for construction. Although these 

routes function as the primary vehicle access to the majority of the Monument, travel is limited to high 

clearance, 4-wheel drive vehicles. Technically, there are a variety of access points to the Monument. 

Many of these “casual use” access routes cross private or State trust lands.

Appendix C includes a Comprehensive Trails and Travel Management Plan that identified public land 

within the Monument as Open, Limited, or Closed to Off-Highway Vehicle Use. The Comprehensive 

Trails and Travel Management Plan also includes implementation decisions of designating routes and 

allowable uses in areas identified as limited to designated routes.

Recreation

How will the BLM manage conflicts between motorized use and protection of Monument 

resources, objects, and values?

How will the BLM manage requests for special recreation permits?

How will the management actions address other various recreation opportunities such as 

camping, shooting, and fossil hunting while protecting Monument resources, objects, and values?

What opportunities will be available for visitor services and facilities?

The Monument is currently used for a wide variety of recreation. Mountain biking, hiking, OHV 

(including all-terrain vehicles, motorcycles, and full size 4-wheel drive vehicles), hunters, and visitors in 

search of a rugged, scenic experience, and naturalists hoping to glimpse evidence of a prehistoric 

environment all find a destination in the Monument. Some activities are no longer compatible with the 

legislative mandate for Monument management. Casual collection of fossilized material may disturb 

geologic formations that host significant Permian Age ichnofossil, and motorized activities may adversely 

affect fossils that are exposed within the vehicle footprint. These types of recreational opportunities may 

need to be monitored, restricted, or prohibited in order to adequately ensure the integrity of the fossil 

resources.

Wildlife, Livestock, and Vegetation

What management actions will protect wildlife and wildlife habitat?

How will livestock grazing be addressed within the Monument?

How will management of vegetative communities be addressed in the Monument?

Management must consider the potential impacts to wildlife and vegetation. Livestock grazing may 

continue (see Appendix A, page A-4), but the BLM must consider its potential impacts on the important 

paleontological resources.
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Visual Resources

How will the BLM manage threats to scenic quality within the boundaries of the Monument?

The visual resources within the Monument must be considered while making management decisions.

Socio-economics

How will management actions impact economic and social opportunities in the community?

The Monument designation and management can impact economic and social opportunities for the local 

community through tourism, recreational opportunities, and livestock grazing. These impacts must be 

considered when analyzing the management alternatives.

1.4.2 Issues Considered but Not Further Analyzed

During public scoping, the BLM received comments that referred to implementation decisions made 

through administrative or resource program guidance and do not require land use planning decisions in 

order to be resolved:

 Comments urging the BLM to organize or support a volunteer or advisory group for the 

Monument are documented in the Scoping Report, but will not be addressed in the RMP/EIS. 

Such actions can be resolved through administration or policy action. The BLM is committed to 

coordinating and collaborating with local groups, clubs, educational institutions, and agencies to 

protect and promote the resources of the Monument.

 A management concern for the BLM is the possibility of new legislation that would change the 

Monument boundary. The existing Legislation allows the Secretary of the Interior to make minor 

boundary adjustments to the Monument if additional paleontological resources are discovered on 

public land adjacent to the Monument. The Secretary of the Interior has the authority to make 

these adjustments independent of the RMP/EIS process. If additional lands are added to the 

Monument at a later date, these lands will be managed in accordance with the management 

decisions made in this RMP/EIS.

 Actions regarding the adjacent Community Pit #1 are beyond the scope of the RMP because the 

Community Pit #1 is outside the RMP Planning Area (Map 1-2). However, cumulative impacts 

from the actions taken in Community Pit #1 will be addressed in the RMP/EIS.

1.5 PLANNING CRITERIA/LEGISLATIVE CONSTRAINTS

The BLM’s land use planning guidance (Handbook H-1601-1) states that planning criteria are the 

constraints or ground rules that guide and direct the development of the RMP. The RMP planning criteria 

tailor the document to the identified issues and ensure that unnecessary data collection and analyses are 

avoided. Planning criteria for the PTNM RMP/EIS are as follows:

 The RMP will be consistent with the FLPMA, NEPA, New Mexico Standards and Guidelines for 

Livestock Grazing Management (2001), the Omnibus Public Land Management Act of 2009-

Paleontological Resources Preservation (16 USC 470aaa et seq.), and all other applicable laws, 

regulations, and policies (Appendix B).
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 The RMP will be consistent with the Omnibus Public Land Management Act of 2009

(Appendix A), FLPMA, NEPA, and all other applicable laws, regulations, and policies.

 The RMP will be in compliance with the BLM National Monuments, National Conservation 

Areas, and Similar Designations Manual 6220.

 The RMP will comply with the BLM Management of Paleontological Resources 8270 Manual 

and Handbook and all applicable Instruction Memorandums (IMs):

o 2012-140 Collecting Paleontological Resources Under the Paleontological Resources 

Preservation Act of 2009

o 2012-141 Confidentiality of Paleontological Locality Information Under the Omnibus 

Public Lands Act of 2009, Title VI, Subtitle D on Paleontological Resources Preservation

o 2009-011 Assessment and Mitigation of Potential Impacts to Paleontological Resources

o 2009-113 Casual Collecting of Common Invertebrate and Plant Paleontological 

Resources under the Paleontological Resources Preservation Act of 2009

o 2009-138 Confidentiality of Paleontological Locality Information under the Omnibus 

Public Lands Act of 2009

o 2008-009 Potential Fossil Yield Classification System for Paleontological Resources on 

Public Lands

 Land use decisions will apply to the surface and subsurface estate managed by the BLM.

 For program-specific guidance for decisions at the land use planning level, the process will 

follow the BLM’s policies in the Land Use Planning Handbook, H-1601.

 BLM staff will strive to make decisions in the RMP compatible with the existing plans and 

policies of adjacent local, state, and Federal agencies and local American Indian tribes, as long as 

the decisions are consistent with the Legislation.

 BLM staff will work cooperatively and collaboratively with cooperating agencies and all other 

interested groups, agencies, local governments, tribes, and individuals.

 The planning process will provide for ongoing consultation with American Indian tribal 

governments and the public regarding strategies for protecting recognized traditional uses and 

heritage resources if such are subsequently identified within the Monument.

 Broad-based public participation and collaboration will be an integral part of the RMP process.

 In the RMP, the BLM will recognize the State’s responsibility and authority to manage wildlife. 

The BLM will coordinate with the New Mexico Department of Game and Fish.

 The RMP will recognize valid existing rights.

 The RMP will incorporate, where applicable, management decisions brought forward from 

existing planning documents.

 The BLM will consider public welfare and safety when addressing recreational target shooting, 

hazardous materials, and fire management.
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 The Wilderness Study Area (WSA) will continue to be managed pursuant to FLPMA Section 

603(c) and the BLM Management of Wilderness Study Areas, Manual 6330, until Congress either 

designates all or portions of the WSA as wilderness or releases the lands from further wilderness 

consideration. 

 Where practical and timely for the planning effort, the best available scientific information, 

research, and new technologies will be used.

 Geographic Information System and metadata information will meet Federal Geographic Data 

Committee standards, as required by Executive Order 12906. All other applicable BLM data 

standards will also be followed.

 Local Fire Management Plan(s) will provide specific implementation strategies, evaluation 

criteria and accomplishment reporting as referenced in the fire management portion of the RMP.

 Planning and management direction will focus on the relative values of resources and not the 

combination of uses that will give the greatest economic return or economic output.

 Actions must comply with all applicable laws and regulations and must be reasonable, 

achievable, and allow for flexibility while supporting adaptive management principles.

 The RMP will identify specific goals, objectives, and actions for the use, conservation, protection, 

interpretation and possible restoration of the Monument’s resources.

 The RMP will identify Best Management Practices (BMPs) or mitigation measures to be applied 

to existing uses and planned uses to ensure protection of the Monument’s resources, objects, and 

values.

As stated in the BLM Instruction Memorandum No. 2009-215:

. . .“according to Section 302(a) of FLPMA, the National System of Public Lands is to be managed under 

the principles of multiple use and sustained yield except that where a tract of such public land has been 

dedicated to specific uses according to any other provisions of law it shall be managed in accordance 

with such law.”

When an area of public land is set aside by an Act of Congress, the designating language is the controlling 

law. Therefore, as a general rule, if the management direction of the designating Legislation conflicts 

with FLPMA’s multiple-use mandate, the designating Legislation supersedes that portion of FLPMA.

1.6 PLANNING PROCESS

The RMP process follows ten steps according to the BLM Land Use Planning Handbook, H-1601 (see 

Figure 1-1). These steps allow the BLM to act in accordance with NEPA and FLPMA.

NEPA requires that those actions whose effects are expected to be significant and are not fully covered by 

an existing EIS be analyzed in a new EIS. Approval of an RMP is considered a Federal action that 

normally requires the preparation of an EIS. The public is encouraged to participate throughout the RMP
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Figure 1-1 Planning Process
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process, and the BLM is mandated to support and allow for public participation and review. This process 

also requires the expertise of an interdisciplinary team of resource specialists to complete each step.

FLPMA mandates the BLM to prepare and maintain a current inventory of public land and its resources

and values. It also mandates the BLM to develop, maintain, and where appropriate revise land use plans 

for the public land. Section 202 of FLPMA states that land use plans must observe and use the principles 

of multiple-use and sustained yield, use a systematic interdisciplinary approach, give priority to Areas of 

Critical Environmental Concern (ACECs), rely on the available inventory of public land, consider present 

and potential uses, consider the scarcity of the values involved, weigh the long- and short-term benefits, 

comply with applicable laws and regulations, and coordinate with state and local governments.

The designating Legislation also states that a comprehensive management plan for the long-term 

protection and management of the Monument shall be developed.

Development of the PTNM RMP followed the BLM land use planning process as outlined in the BLM 

Land Use Planning Handbook (H-1601-1). Below is a description of the steps of the process and how 

those steps were taken with respect to the PTNM RMP.

Step 1: Prepare to Plan

In January 2010, the BLM finalized the PTNM Preparation Plan. This Preparation Plan was developed to 

identify the preliminary planning issues and management concerns, identify data needs, identify potential 

cooperating agencies and public scoping opportunities, and create a schedule and budget.

Step 2: Issue Notice of Intent

On January 5, 2010, a Notice of Intent (NOI) was published in the Federal Register (Volume 75, Number 

2, Pages 431-432), which notified the public of the BLM’s intent to prepare the RMP/EIS and to begin 

public scoping.

Step 3: Scoping

The BLM held one formal scoping meeting in Las Cruces on January 26, 2010 to share information about 

the Monument, preliminary issues, and the planning process. The BLM asked the public for comments 

and suggestions regarding the management and interpretation of the natural, cultural, recreational, and 

scientific resources within the Monument. The initial formal scoping period closed on February 10, 2010. 

The results of the public scoping are found in the Scoping Report, Appendix F.

Step 4: Analysis of Management Situation

The BLM analyzed available inventory data, portrayed the existing management situation, and identified 

management opportunities to respond to identified issues, which are presented in the Analysis of 

Management Situation (AMS). The AMS is the basis for formulating reasonable alternatives, and 

identifying the resources suitable for development or protection. This analysis also results in 

identification of the “No Action Alternative” - the baseline (current) management condition, which 

includes the Monument Legislation.

Step 5: Formulate Alternatives

The BLM planning regulations (43 CFR 1610.4-2) require development of planning criteria to guide 

preparation of an RMP. Planning criteria are the standards, rules, and other guidelines developed by 
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managers and interdisciplinary teams, with public input, for use in forming judgments about plan-level 

decision making, analysis and data collection. These criteria are used to establish the parameters or 

ground rules for making planning decisions and simplifying RMP actions. The criteria may be adjusted 

during RMP development based on management concerns and the results of public scoping.

Four alternatives are presented and analyzed in the RMP/EIS. These alternatives address planning issues 

identified by the Legislation and during both internal and external scoping and they meet the goals and 

objectives developed by the interdisciplinary team. In compliance with NEPA, CEQ regulations, and 

BLM planning policy and guidance, the alternatives are reasonable and can be implemented. These 

alternatives are described in detail in Chapter 2.

Step 6: Analyze Effects of Alternatives and Select a Preferred Alternative

The resulting physical, biological, economic, and social impacts from implementation of each of the 

alternatives have been predicted and assessed in Chapter 4. The District Manager evaluated the 

alternatives and estimated impacts. The District Manager then identified Alternative C as the preferred 

alternative and made this recommendation to the State Director.

Step 7: Preparation of the Draft RMP/EIS

The resulting Draft RMP/EIS was distributed for a 90-day public review and comment period. In addition 

to the public comment period, a public meeting was held by the Las Cruces District Office in Las Cruces, 

New Mexico on August 7, 2012.

Step 8: Preparation of the Proposed RMP/Final EIS

After the comment period, the BLM evaluated comments and updated the RMP/EIS. The District 

Manager has recommended a proposal to the State Director, who has selected an alternative or a mixture 

of alternatives, which is published in this Proposed RMP/Final EIS. Publication of this Proposed 

RMP/Final EIS will start a 60-day Governor’s Consistency Review and a 30-day protest period.

Step 9: Approval of the Record of Decision and Approved RMP

Following resolution of any protests on the Proposed RMP/Final EIS, the BLM New Mexico State 

Director will make a final decision regarding the selection of an alternative. The Approved RMP and 

Record of Decision (ROD) will be published.

Unlike land use planning decisions, implementation decisions included in this Proposed RMP/Final EIS

are not subject to protest under the BLM planning regulations, but are subject to an administrative review 

process, through appeals to the Office of Hearings and Appeals, Interior Board of Land Appeals pursuant 

to 43 CFR, Part 4 Subpart E. Implementation decisions generally constitute the BLM’s final approval 

allowing on-the-ground actions to proceed. Where implementation decisions are made as part of the land 

use planning process, they are still subject to the appeals process or other administrative review as 

prescribed by specific resource program regulations once the BLM resolves the protests to land use 

planning decisions and issues an Approved RMP and ROD. The Approved RMP and ROD will therefore 

identify the implementation decisions made in the plan that may be appealed to the Office of Hearing and 

Appeals.
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Step 10: Implementation and Monitoring of Planning Decisions

The BLM will formulate an implementation and monitoring plan after the RMP is finalized. This will 

provide for periodic evaluations (minimum every 5 years) to determine if management and mitigation 

measures are satisfactory for the resources. This will allow the BLM to detect any issues early on or to 

ensure that management goals are being met.

1.7 COLLABORATION

Tribal Consultation

American Indian tribes have a long history of collaboration with BLM in planning and managing cultural 

resources. Letters inviting participation in the planning process as cooperating agencies were sent in 

February 2010 to the following seven tribes: Fort Sill Apache Tribe of Oklahoma, Comanche Indian 

Tribe, White Mountain Apache, Pueblo of Ysleta del Sur, Pueblo of Isleta, Mescalero Apache Tribe, and 

Navajo Nation. In September 2011, three additional tribes were invited to participate as cooperating 

agencies: Pueblo of Acoma, the Pueblo of Laguna and the Pueblo of Tesuque. No tribe has accepted the 

invitation to be a cooperating agency.

Cooperating Agencies

By definition, a cooperating agency is any Federal, state, or local government agency or Indian tribe that 

has either jurisdiction by law or special expertise regarding environmental impacts of a proposal. A 

Cooperating Agency Agreement is a formal framework for governmental units to engage in active 

collaboration with the lead Federal agency during the NEPA process. In January and February 2010 and 

September 2011, letters were sent to the following agencies inviting recipients to become a cooperating 

agency for this project: City of Las Cruces, Doña Ana County, New Mexico State Parks, New Mexico 

Museum of Natural History and Science, and the New Mexico Department of Game and Fish. Formal 

status for cooperating agency was not been requested by any invited party. The State Historic 

Preservation Office was notified of the planning process, as required by section 106 of the National 

Historic Preservation Act.

Other Stakeholder Relationships

Various groups not defined as cooperating agencies have worked with the BLM and provided valuable 

information: Las Cruces Museum of Nature and Science, Las Cruces Four-Wheel Drive Club, New 

Mexico State University, Paleozoic Trackways Foundation, Smithsonian Institution, and New Mexico 

Museum of Natural History & Science

1.8 RELATIONSHIP TO OTHER PLANS

The BLM must ensure that land use plans are as consistent as possible with existing officially adopted 

related plans, policies or programs of other Federal and state agencies, Indian tribes, and local

governments that may be affected (43 CFR 1610.3-1(d)(1)). These plans were reviewed as required to 

determine whether they were relevant to the development of the Monument RMP. A summary of those 

plans that affect the same land as the Monument are as follows:
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Federal

The Mimbres RMP, as amended, approved in April 1993, currently provides general guidance on a 

landscape level for management in Doña Ana, Grant, Hidalgo, and Luna Counties. The PTNM RMP will 

supersede the Mimbres RMP for the Monument and provide the framework and prescriptions to 

implement Legislative directives. The document identifies the current management situation, the desired 

future conditions to maintain or achieve, and the management actions needed to achieve these objectives. 

Following completion of the PTNM RMP, the BLM Las Cruces District Office staff will develop an 

implementation plan. The Mimbres RMP for Doña Ana County is currently under revision and will be 

known as the TriCounty RMP. The TriCounty RMP does not analyze the PTNM nor will it modify 

decisions made in the PTNM RMP.

The Las Cruces District Fire Management Plan provides specific implementation strategies as referenced 

in the fire management portion of the RMP. Standards for Public Land Health and Guidelines for 

Livestock Grazing Management (BLM 2001) amends the Mimbres RMP and is the underlying guidance 

for livestock grazing decisions on BLM land in the Monument and throughout BLM land in New Mexico. 

Decisions from these plans are specifically addressed in the existing management guidance and 

alternatives.

State and Local Government Plans

This RMP is consistent with the following resource related plans of State and local governments:

 Doña Ana County, New Mexico Natural Events Action Plan Reevaluation 2005

 Statewide Comprehensive Outdoor Recreation Plan (SCORP)

 New Mexico Historic Preservation Plan

 The 2006 Comprehensive Wildlife Conservation Strategy

 2000 City of Las Cruces Extraterritorial Zoning Comprehensive Plan 2000-2020

 2005 Las Cruces Metropolitan Planning Organization Transportation Plan

 2004 Rio Grande Riparian Ecological Corridor Project Report

 Vision 2040 Regional Planning Project- City of Las Cruces and Doña Ana County

A summary description of the relevancy and consistency of these plans is found in Chapter 5.

1.9 MONUMENT RESOURCES, OBJECTS, AND VALUES

The BLM refers to the values described in the PTNM designating Legislation as Monument Resources, 

Objects, and Values (ROVs). The BLM’s management approach must reflect the direction from 

Congress to conserve, protect, and enhance the Monument ROVs in accordance with FLPMA and other 

appropriate laws as a component of the National Landscape Conservation System. The PTNM was 

designated to “protect the unique fossil resources for present and future generations” and Congress 

directed the BLM to “conserve, protect, and enhance the unique and nationally important 

paleontological, scientific, educational, scenic, and recreational resources and values.” Where ROVs

are described in the designating legislation in broad categories, BLM identifies the specific resources that 

fall into those categories. The BLM has interpreted the Prehistoric Trackways National Monument ROVs 

to be the following:
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Paleontological: Fossil resources are predominantly Permian Age fossil material, but may be expanded 

to encompass subsequent discoveries. 

Scientific: Science-based research conducted on paleontological and geologic resources, especially 

Permian Age fossils and their geologic context.

Educational: Educational and interpretive opportunities on the Permian fossils.

Recreation: Recreational uses related to the enjoyment, appreciation, and protection of the fossil 

resources and their geologic context.

Scenic: The distinct geologic exposures of the Robledo Mountains in the context of the Permian fossils.

Alternatives and management decisions proposed in the PTNM RMP/EIS reflect direction from Congress 

in the Prehistoric Trackways National Monument designation within the Omnibus Public Lands 

Management Act of 2009. The BLM RMP process is influenced by administrative directives found in the 

Act (Sec. 2104) (See Appendix A). The directives provide important parameters for selecting and 

framing Alternatives in Chapter 2.

Prehistoric Trackways National Monument Directives

 Provide for public interpretation of, and education and scientific research on, the paleontological 

resources of the Monument.

 Enter into cooperative management agreements or other instruments with interested parties or 

agencies, as appropriate, to coordinate and collaborate management of the Monument.

 Continue to manage that portion of the Robledo Mountains WSA within the Monument.

 Continue to manage that portion of the Robledo Mountains ACEC within the Monument.

 The use of motorized vehicles in the Monument shall be allowed only on roads and trails 

designated in this plan for use by motorized vehicles.

 Subject to valid existing rights, close the Monument to entry, appropriation, or disposal under the 

public land laws.

 Subject to valid existing rights, close the Monument to location, entry, and patent under the 

mining laws; and the operation of the mineral leasing laws, geothermal leasing laws, and mineral 

materials laws.

1.10 MISSION STATEMENT AND OVERALL VISION

The PTNM is a unit of the BLM National Landscape Conservation System (NLCS). The mission of the 

NLCS is to conserve, protect, and restore Nationally-significant landscapes that are recognized for their 

outstanding cultural, ecological, and scientific values. The PTNM was designated in order to conserve, 

protect, and enhance the unique and Nationally-important paleontological, scientific, educational, scenic, 

and recreational resources and values of the public land.
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The Prehistoric Trackways National Monument preserves a moment in time when the world was poised 

on the brink of cataclysmic change that would usher in the era of the dinosaurs. Our vision is to tell this 

story to the Nation through education and interpretation, and through scientific research. The BLM will

maintain the rugged and scenic setting while providing opportunities for recreationists to enjoy these 

lands now, and for future generations, while ensuring the sustainability and protection of the 

paleontological resources. We will work collaboratively with partners to optimize Monument 

management which will enhance our ability to serve the public and meet the needs of the Monument 

resources, objects, and values.

1.11 CHANGES FROM THE DRAFT RMP/EIS 

Changes in the Proposed RMP/Final EIS were prompted primarily by public comment. Public comments 

are reproduced in Appendix H. In Appendix H, the response to substantive comments will direct the 

reader to changes throughout the document. Extensive internal reviews of the Final EIS have also led to 

corrections, revisions, updates, and other improvements to the document. Acreage figures and associated 

quantifications have also been revised throughout the document to reflect public input and staff review.

The BLM also considered whether the Draft RMP/EIS warranted supplementation (see BLM National 

Environmental Policy Act Handbook 1790-1 Section 5.3 for details on supplementing an EIS). The 

Prehistoric Trackways National Monument Draft RMP/EIS does not require the issuance of a 

supplemental EIS because no substantial changes were made to the proposed action, no new alternatives 

outside the spectrum of alternatives already analyzed were proposed, no significant new circumstances 

arose, and no new significant information was provided.

Since the Draft PTNM RMP/EIS was published, the BLM has issued new guidance for land use planning 

in National Monuments -- Manual 6220-National Monuments, National Conservation Areas, and Similar 

Designations (USDOI BLM 2012). This guidance directs the BLM to identify management actions, 

allowable uses, restrictions, management actions regarding any valid existing rights, and mitigation 

measures to ensure that the resources, objects, and values are protected. This Proposed Final RMP/EIS

adopts the new guidance. The BLM has refined the list of Monument Objects, re-phrased goals and 

objectives to better match the new guidance, and re-analyzed impacts to resources and resource uses 

under the new framework.

 The Alternatives were not changed from the Draft RMP to the Proposed Final RMP. In many 

cases, wording may be slightly different but the concepts were left intact.

 Research Management did not vary through the Alternatives. It was decided by BLM staff that 

the Goals, Objectives, and Management Common to All Alternatives would better describe and 

support Paleontological Resources. These sections of Research Management are now found 

under Paleontological Resources in Chapter 2.

 After the Draft RMP was published, the BLM obtained legal access to PTNM. Most references 

to obtain legal access have been removed, but the BLM will continue to seek other means of 

access if needed.
ALTERNATIVES

CHAPTER 2

tHE 
2-1

CHAPTER 2 ALTERNATIVES

2.1 INTRODUCTION

This chapter identifies a range of goals and objectives for the Prehistoric Trackways National Monument

(PTNM). Since the Draft PTNM RMP/EIS was published, the BLM has issued new guidance for land use 

planning in National Monuments (Manual 6220-National Monuments, National Conservation Areas, and 

Similar Designations (USDI BLM 2012). This guidance directs the BLM to identify management 

actions, allowable uses, restrictions, management actions regarding any valid existing rights, and 

mitigation measures to ensure that the Monument resources, objects and values are protected. This 

Proposed Final RMP/EIS adopts the new guidance.

The National Environmental Policy Act (NEPA) requires Federal agencies to consider a reasonable range 

of alternative approaches when proposing and analyzing Federal actions. The different alternatives within 

this Chapter are developed with guidance from professional resource specialists, Monument LegislationPublic Law 111-11 (located in Appendix A), NEPA, the Federal Land Policy and Management Act

(FLPMA), BLM regulations and policies (Appendix B), and public input.

Three management alternatives have been developed and analyzed for the PTNM along with the No 

Action Alternative. The No Action Alternative is a description of the current management, which is a 

combination of management decisions, goals, and objectives from the Mimbres RMP (1993), Monument 

Legislation, and current policies and regulations. The No Action Alternative allows for a point of 

reference for the other three developed management alternatives.

Proposed within this Chapter are two different types of decisions. Those decisions are either planning 

(broad overarching) decisions or implementation (on-the-ground) decisions. The implementation 

decisions are denoted with an asterisk (*). Planning decisions may be protested, while implementation 

decisions can be appealed at the time of their implementation, and this is described in the Dear Reader 

letter at the front of this document.

Chapter 2 Sections

 Section 2.2 describes the alternative development process for the PTNM RMP/EIS and 

provides an overview of the focus of each of the three action alternatives considered.

 Section 2.3 lists directives from the Omnibus Public Lands Management Act of 2009, Subtitle 

B-The Prehistoric Trackways National Monument.

 Section 2.4 describes the management alternatives in detail. Goals, Objectives, Management 

Common to All Alternatives, and the Proposed Management Actions are described in this 

section. Management Common to All Alternatives lists management guidance that will follow 

through all of the proposed alternatives.

 Section 2.5 is a summary of the impact analyses from Chapter 4, depicted in a table.

2.2 ALTERNATIVE DEVELOPMENT

RMPs are broad-scale land management plans that establish desired outcomes (goals and objectives) for 

management of the public land and identify the management actions and allowable public uses that will 
2-2

reach those outcomes. An Approved RMP and Record of Decision (ROD) provide the framework for 

future site-specific management decisions and actions.

Implementation-level decisions are typically made after the RMP is adopted, but in this RMP some 

implementation-level decisions are identified and incorporated into the alternatives. An example of an 

implementation-level decision within this RMP is the Trails and Travel Management Plan, which 

includes decisions designating routes as motorized or non-motorized (Appendix C).

Goals and objectives were developed through the planning process for every applicable resource. Goals 

describe broad direction and desired conditions for each resource or resource use, as interpreted through 

the Monument resources, objects, and values identified in Chapter 1, BLM policy guidance, and public 

scoping input.

Objectives describe more detailed outcomes or desired future conditions for different components of the 

resource or resource use that meet the overall goals. Objectives are usually quantifiable and measurable 

and may have established timeframes for achievement (as appropriate). Some objectives are common to 

all alternatives while others vary by alternative. Alternatives must: 

 Meet the purpose and need for the RMP (see Chapter 1). 

 Be reasonable. 

 Be responsive to issues identified in scoping. 

 Meet the established planning criteria (see Chapter 1), Federal laws and regulations, and 

BLM planning policy. 

2.2.1 ALTERNATIVE THEMES

Alternative A or the “No Action Alternative” represents the continuation of existing management, which 

is defined by the Mimbres RMP (1993) and the legislation designating the Monument, the Omnibus 

Public Land Management Act of 2009. Two RMP amendments also affect management of the Planning

Area: New Mexico Standards for Public Land Health and Guidelines for Livestock Grazing Management

(2001) (NM Standards and Guidelines) and the Resource Management Plan Amendment for Fire and 

Fuels Management on Public Land in New Mexico and Texas (2004).

Alternative B represents a more restrictive approach to use of the Monument that emphasizes resource 

protection; BLM would invest less in the Monument and would limit changes and involvement as 

compared to Alternatives C and D.

 All paleontological resources would be conserved for future scientific research.

 The Monument would be closed to casual collection of common invertebrate fossils.

 The Monument would be closed to livestock grazing.

 The Monument would be closed to all mechanized and motorized vehicles - exceptions may be 

authorized for any military, fire, emergency, or law enforcement vehicles or any vehicle in 

official use or expressly authorized in writing by the authorized officer.

 There would be no prohibitions on recreational target shooting.

 Special Recreation Permits (SRPs) would not be issued.

 The education and interpretation program would be primarily off-site.

Alternative C (Preferred Alternative) protects resources while allowing compatible public uses. The 

BLM has determined that this is the best combination of management approaches to protect the resources, 

objects and values in the Monument.
2-3

 Paleontological resources deemed suitable for scientific research would be conserved and used

for scientific research only. Paleontological resources appropriate for interpretation, educational 

and recreational use would be developed for that use. 

 The Monument would be closed to casual collecting of petrified wood, common invertebrate and 

plant paleontological resources.

 Allotment management plans would be adjusted to exclude grazing at specific locations such as 

campsites or fossil sites based on the Monument Monitoring Plan results.

 Motorized and mechanized travel within the Monument would be limited to designated routes 

and require a no-fee day-use permit.

 Approximately 5.4 miles of previously designated routes would be closed to motorized and 

mechanized travel.

 Recreational target shooting would be prohibited.

 New routes or trails may be developed by the BLM to enhance visitor experiences and research 

opportunities. 

 Commercial, competitive, and organized group activities would be managed through the SRP 

process.

 Education and interpretation would be enhanced on-site and off-site including an on-site visitor 

contact station.

 Organized tours and self-guided interpretive activities would be developed.

Alternative D represents a maximum use approach to management of the Monument and the widest 

range of public uses of the resources while still following the constraints of the Monument Legislation.

 Localities deemed suitable for scientific research would be preserved and used for scientific 

research only.

 Localities appropriate for interpretation, educational and recreational use would be developed.

 The Monument would be closed to casual collecting of common invertebrate and plant 

paleontological resources.

 Limited collecting of common invertebrates would be allowed when in conjunction with a BLMauthorized educational or interpretive activity.

 Current livestock management would continue in the Monument.

 Approximately 4.0 miles of designated routes would be closed to motorized and mechanized use.

 New motorized and non-motorized routes may be developed by the BLM to enhance visitor 

experiences and research opportunities.

 Competitive, commercial, and organized group activities would be managed through the SRP 

process.

 Recreational target shooting would be prohibited.

 Education and interpretation would be developed for the Monument both on-site and off-site, 

including an on-site visitor center.

 Organized tours and self-guided interpretive activities would be developed along with an 

interpretive motorized tour route.

Slight changes, wording, acreages, and format were made to the Proposed RMP. These are described in 

more detail in Section 1.11, and in Appendix H.
2-4

2.2.2 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL

2.2.2.1 Community Pit #1

During scoping, the BLM received a comment to consider including the adjacent Community Pit #1 into 

the Monument. Community Pit #1 is not within the Monument boundary and is therefore outside the 

Planning Area for this RMP, and this RMP cannot make decisions for land outside the Planning Area. 

Only the Secretary of the Interior or President may alter the Monument boundary. This action cannot be 

accomplished through the RMP process.

2.2.2.2 Target Shooting Allowed Within a Designated Area of Monument

In Alternatives C and D, the BLM proposes to close the Monument to recreational target shooting. No 

restrictions are proposed in Alternatives A and B. A proposal to allow target shooting within a designated 

area was evaluated in a map-based exercise in GIS using a 1⁄2-mile safety buffer (described further in 

Appendix G) overlain on documented paleontological localities in the Monument (areas where 

researchers and visitors were likely to congregate). This GIS analysis determined that only 356 acres, or 

7 percent, of the Monument lies outside the Safety Zone. This area is near the southern boundary. There 

are no access roads on this side of the Monument and no distinct physical boundaries for the 356 acres. 

From a management perspective, allowing recreational target shooting within these 356 acres would be 

difficult since it would be hard to sign the area and enforce the boundary; therefore, it is not feasible to 

carry this alternative forward for further analysis. Approximately 10 miles southwest of the PTNM is the 

Butterfield Range, which is a City of Las Cruces facility that is free for public use and open 7 days a 

week. The shooting range accommodates a full range of target shooting, including pistol, rifle and 

shotgun, and has multiple shooting bays ranging from 25 yards to 1000 yards.

2.3 PTNM LEGISLATIVE DIRECTIVES

The four alternatives were developed by considering the PTNM legislative directives. Each alternative 

must incorporate the elements of the Legislation presented below:

 The Secretary shall manage the Monument in a manner that conserves, protects, and enhances the 

resources and values of the Monument.

 Provide for public interpretation of, and education and scientific research on, the paleontological 

resources of the Monument, with priority given to exhibiting and curating the resources in Doña 

Ana County, New Mexico.

 Enter into cooperative management agreements or other instruments with interested parties or 

agencies, as appropriate, to coordinate and collaborate management of the Monument.

 Continue to manage that portion of the Robledo Mountains Wilderness Study Area (WSA) within 

the Monument until such time that Congress designates it as a Wilderness Area or releases it from 

further consideration.

 Continue to manage that portion of the Robledo Mountains Area of Critical Environmental 

Concern (ACEC) within the Monument as an ACEC.
2-5

 Land use authorizations may be permitted to facilitate the management of the Monument and to 

meet the intent of the enabling Legislation. The Secretary shall only allow uses of the Monument 

that the Secretary determines would further the purposes for which the Monument has been 

established.

 Subject to valid existing rights, close the Monument to location, entry, and patent under the 

mining laws; and the operation of the mineral leasing laws, geothermal leasing laws, and minerals 

materials laws.

 Manage any land or interest in land that is acquired by the United States for inclusion in the 

Monument after the date of enactment of this Act in the same manner and degree as herein 

described for the rest of the Monument.

 Except as needed for administrative purposes or to respond to an emergency, the use of motorized 

vehicles in the Monument shall be allowed only on roads and trails designated in this plan for use 

by motorized vehicles.

The broad categories of Monument resources, objects, and values found within the PTNM Legislation can 

be furthered defined based on scoping issues and BLM experience with the area.

 Paleontological

Fossil resources are predominantly Permian Age fossil material, but may be expanded to 

encompass subsequent discoveries.

 Scientific

Science-based research conducted on paleontological and geologic resources, especially Permian

Age fossils and their geologic context.

 Educational

Educational and interpretive opportunities on the Permian fossils.

 Recreation

Recreational uses related to the enjoyment, appreciation, and protection of the fossil resources 

and their geologic context.

 Scenic

The distinct geologic exposures of the Robledo Mountains in the context of the Permian fossils.
2-6

2.4 MANAGEMENT ALTERNATIVES

2.4.1 PALEONTOLOGICAL RESOURCES

GOAL 1: Conserve, protect and enhance unique and important paleontological resources and values in 

the PTNM.

GOAL 2: Manage the Monument to provide for and allow scientific research while taking into 

consideration conservation and preservation of the paleontological resources.

OBJECTIVE 1: Protect and enhance paleontological resources by ongoing research and documentation, 

which establishes the scientific, educational, or recreational merit of the localities.

OBJECTIVE 2: Facilitate research that increases our knowledge and understanding of the 

paleontological resources.

OBJECTIVE 3: Make all ensuing scientific material/data available to the public except locality data and 

certain details which are considered restricted for the preservation and protection of the resource. Ensure 

materials are properly curated.

OBJECTIVE 4: Actively work with organizations, schools, and the scientific community to provide for 

scientific research on the fossil resources.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 The BLM would develop a Monument Monitoring Plan within 2 years of the signing of the PTNM 

RMP Record of Decision that would establish baseline conditions of fossil resources and track 

changes to those resources based on management, research, and other factors (such as weathering).

 Unauthorized collection of vertebrate fossils is not allowed under 43 CFR 8365.1-5 and PRPA 

PL 111-01 Section 6034.a.1. Permits are required for the collection of vertebrate fossils, including 

their trace fossils, such as trackways and coprolites.

 The PTNM legislation withdraws the Monument from operation under the mineral materials laws. 

The PTNM is closed to free-use or casual collection of petrified wood without a permit (43 CFR, 

3622; BLM Manual 8270 .09 B. 1; and PRPA PL 111-01 Section 6304.e.).

 The BLM would continue to use information collected from work performed under existing and new 

paleontological permits to evaluate the importance of specific sites in the Monument and to allow for 

focused permitted research or collecting in response to approved research proposals or management 

needs.

 Paleontological resources collected under a research permit would be stored in Federally-approved 

repositories as government property for research and used in exhibits. Paleontological collection 

permits would be issued with consideration of protecting the integrity of the site from which it is 

being collected, the protection of the resources, and the value of the scientific research or educational 

aspect for which it would be collected.
2-7

PALEONTOLOGICAL RESOURCES (Continued)

(MANAGEMENT COMMON TO ALL ALTERNATIVES, Concluded)

 The BLM would use the criteria for determining which localities are suitable for scientific research or 

interpretation, education, and recreation in accordance with the Omnibus Public Land Management 

Act of 2009-Paleontological Resources Preservation (16 USC 470aaa et seq.):

o Furthers paleontological knowledge or public education 

o Provides additional information about the history of life on earth

o Increases public awareness about the significance of paleontological resources 

o Promotes the scientific and educational use of paleontological resources

o Will not threaten significant natural or cultural resources

o Will not create risk of harm to, or theft or destruction of, the paleontological resources or 

the locality

 All proposed research projects would be evaluated by the BLM staff, including the Regional 

Paleontologist, for all proposed paleontological research projects. The following items would be 

considered prior to authorization: 

o An assessment of whether the proposed research is the appropriate current use of the 

resource

o An assessment of its priority level if there are multiple proposals

o An appropriate level of environmental analysis (NEPA)

o Incorporating project-specific stipulations for resource protection

o A final written determination, which would be in the form of an authorization

 All contractors, cooperators, partners, volunteers, and permittees conducting or assisting with 

scientific activities in the Monument must comply with the requirements of the Department of the 

Interior and the BLM policies on Scientific Integrity, including professional conduct.

 The BLM would identify research priorities and update or revise on an as-needed-basis.

 The BLM would obtain copies of research projects and published research articles based on work 

conducted in the Monument and establish an in-house reference collection for primary research.

 The BLM would maintain, encourage, and enter into partnerships or cooperative agreements with 

appropriate entities and individuals to conduct research within the Monument.

 The BLM would provide existing GIS, or other data as available and appropriate, to qualified 

researchers when requested. 
2-8

PALEONTOLOGICAL RESOURCES (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Casual collecting of 

common invertebrates 

and plant fossils is 

allowed throughout 

the Monument.

Closed to casual 

collecting of common 

invertebrate and plant 

fossils and ichnofossils. 

A permit would be 

required for any 

collecting [16 USC 

470aaa-3(e) at 123 Stat. 

1174].

Collection of petrified 

wood would be allowed 

only with a permit 

(BLM Manual 8270.09 

B. 1.).

Closed to casual 

collecting of common 

invertebrate and plant 

fossils and ichnofossils. 

A permit would be 

required for any 

collecting [16 USC 

470aaa-3(e) at 123 Stat. 

1174].

Collection of petrified 

wood would be allowed 

only with a permit (BLM 

Manual 8270.09 B. 1.).

Closed to casual 

collecting of common 

invertebrate and plant 

fossils and ichnofossils. 

A permit would be 

required for any 

collecting [16 USC 

470aaa-3(e) at 123 Stat. 

1174].

Collection of petrified 

wood would be allowed 

only with a permit (BLM 

Manual 8270.09 B. 1.).

Limited collecting of 

common invertebrate 

fossils without a permit 

may be allowed only in 

conjunction with BLM 

approved interpretive or 

educational activities at 

specified locations. 

Amounts collected would 

not exceed 5 of any one 

variety of invertebrate 

fossil or 2 pounds per 

person. Use of small 

hand tools would not be 

allowed.

Management is 

directed by FLPMA, 

other legislative acts 

and instruction 

memoranda.

Conserve all 

paleontological resources 

localities for on-going 

and future scientific 

research.

Localities deemed suitable for scientific research 

would be preserved and used for scientific research 

only. Localities appropriate for interpretation, 

educational and recreational use would be developed 

for that use.
2-9

2.4.2 EDUCATION AND INTERPRETATION*

GOAL 1: Provide interpretive and educational opportunities supporting and protective of the fossil 

resources.

OBJECTIVE 1: Partner with organizations (e.g. museums, research and academic institutions) on local 

and National levels to assist the BLM in providing educational and interpretive opportunities to the public 

within the Monument.

OBJECTIVE 2: Develop interpretive trails and visitor facilities.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Continue BLM and partner-led interpretive tours to the Discovery Site and other appropriate sites.

 Develop interpretative materials for programs and events.

 Develop a K-12 paleontological curriculum, in partnership with local school districts, in accordance 

with State/National standards.

 Develop paleontological and other natural resources interpretive materials for websites.

 Develop and deliver paleontological interpretive and educational programs to school and civic groups.

 Support the development of paleontological exhibits for venues in Doña Ana County and beyond.
2-10

EDUCATION AND INTERPRETATION (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Activities 

implemented on a 

case-by-case basis

Develop interpretive materials on paleontological resources such as wayside 

exhibits, brochures and smart phone applications to support self-guided 

interpretive activities.*

Develop interpretive programs on paleontological resources for ranger or docentled field tours of the PTNM for school groups and for public and civic groups.*

Minimal directional 

and informational 

signs would be 

installed at 

established routes.*

Develop pedestrian trails with orientation kiosks (with or 

without brochures) and wayside exhibits interpreting 

PTNM resources in place, based on an activity level plan 

in Recreation and Visitor Services.*

Develop exhibits for onsite interpretation at a 

visitor contact station(s) 

and other destinations. A 

Visitor Contact Station is a 

minimal facility that is a 

point of contact for BLM 

staff or volunteers to be 

present and available to 

interact with the public. It 

does not necessarily 

provide a range of 

amenities such as indoor 

restrooms, or exhibits. It 

is a building, or possibly a 

shade shelter, where 

public can expect to find 

information about 

PTNM.*

Develop interpretive and 

educational materials and 

programs for an on-site 

visitor center, and other 

destinations. A Visitor 

Center is a larger facility that 

provides a location for the 

visiting public to enjoy the 

full range of opportunities 

not possible in a Visitor 

Contact Station. It would 

potentially provide the full 

range of amenities such as 

indoor restrooms, 

educational exhibits, and 

specimen displays.*

No management action 

planned.

Prepare an activity plan for a 

motorized tour route with 

interpretive materials 

designed for fossil resources. 

The route would be selfguided or led by partner 

groups.*

*All Education and Interpretation Alternatives are Implementation Level Decisions to be carried out in 

the future after subsequent implementation planning and analysis.
2-11

2.4.3 RECREATION AND VISITOR SERVICES

GOAL 1: Plan recreational opportunities that protect unique and Nationally-important paleontological 

values of the PTNM.

OBJECTIVE 1: Manage approximately 4,480 acres for front-country public visitation. Manage 

approximately 800 acres of the Robledo Mountains WSA for primitive visitation classification.

OBJECTIVE 2: Manage recreation in a safe and reasonable manner while protecting and enhancing the 

Monument’s paleontological resources, with emphasis on Leave No Trace principles.

OBJECTIVE 3: Designate the Monument as an Extensive Recreation Management Area (ERMA) to 

support and sustain paleontological resources.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

The Monument Monitoring Plan would track changes to fossil resources based on Recreation and Visitor 

Services management actions.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Carry forward 5,255

acres as dispersed 

recreation as managed 

under the Mimbres RMP

(See Map 2-1).

Designate 5,255 acres as 

ERMA (see Map 2-2).

Objective- Self-directed 

recreation, manage to 

provide visitor safety 

and minimize user 

conflicts. Install 

minimal directional and 

informational signs for 

fossil resources.

Activities- Hiking, 

horseback riding, 

picnicking, hunting, 

sightseeing.

Experiences- Develop 

outdoor recreational 

skills, spend time with 

one’s self or in small;

groups, enjoy nature, 

fossil resources, 

landscapes, physical 

rest, escape 

personal/social 

pressures.

Designate 5,255 acres as 

ERMA (see Map 2-3).

Objective- More 

directed. In addition to 

Alternative B 

objectives, install basic 

improvements to reduce 

impacts from recreation 

activities and to assist in 

the visitor experience.

Activities- Permitted

OHV use, mountain 

biking, hiking, 

horseback riding, 

picnicking, camping, 

hunting, and 

sightseeing. 

Experiences- Same as 

B.

Designate 5,255 acres 

as ERMA (see Map 2-

4).

Objective- Directed 

recreation. In addition 

to Alternative C 

Objectives, guide the 

visitor experience.

Activities- Same as C

but OHV use would be 

allowed without a 

permit.

Experiences- Same as 

B.
2-12

RECREATION AND VISITOR SERVICES (Continued)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

BenefitsPersonal- Improved 

physical and mental 

health, improved skill 

for outdoor enjoyment, 

improved awareness of 

public and private lands, 

more outdoor oriented.

Community/SocialPride in one’s 

community and heritage, 

self-renewal leading to 

healthier relations and 

sense of community.

EnvironmentalIncreased awareness and 

protection of distinctive 

natural, paleontological 

and landscape features, 

reduce negative impacts 

such as litter, vegetative 

trampling.

BenefitsPersonal- Improved 

physical and mental 

health, improved skill 

for outdoor enjoyment, 

improved relationships 

with family and friends, 

improved awareness of 

public and private lands, 

more outdoor oriented.

Community/Social- Self 

renewal, pride in one’s 

community and 

heritage, greater family 

bonding.

Environmental- Same as 

B.

BenefitsPersonal- Same as C.

Community/SocialSame as C.

Environmental- Same as 

B.

Dispersed camping 

would be allowed.

Camping and campfires 

would not be allowed.

Dispersed camping 

would be allowed. If 

resource damage is 

demonstrated, primitive 

campsites would be 

developed.

1

Primitive camping 

would be allowed in 

designated areas.

2

 If 

resource damage is 

documented, developed 

campsites would be 

made.

No management actions

planned.

Minimal directional and 

informational signs 

would be installed at 

established routes.**

BLM would prepare an activity and site 

development plan to explore opportunities in 

locating appropriate sites to develop visitor 

facilities. This plan would include possibilities to 

install, develop, and maintain toilets, shade 

shelters, information kiosks, trail markers, and 

picnic sites.**
2-13

RECREATION AND VISITOR SERVICES (Continued)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

No management actions planned. BLM would prepare an 

activity and site 

development plan to 

explore opportunities in 

locating an appropriate 

site to install, staff, and 

maintain a Visitor 

Contact Station within or 

adjacent to PTNM to 

house interpretive 

exhibits and to use for 

interpretive programs 

(multi-purpose use).*

BLM would prepare an 

activity and site 

development plan to 

explore opportunities in 

locating an appropriate 

site to build, staff, and 

maintain a visitor center 

within or adjacent to 

PTNM housing 

specimens and 

interpretive exhibits.*

No management actions planned. BLM would prepare an activity plan to identify 

opportunities for a trail system for recreational 

opportunities (bike, OHV, hiking, etc.). *

Except as provided under current law, regulation 

and policy, there would be no restrictions on the 

discharge of firearms (see Map 2-1 and 2-2).

Recreational target shooting would be prohibited 

(see Maps 2-3 and 2-4).

Commercial, 

competitive and 

organized group 

activities would be

authorized per 43 CFR 

Part 2930, Special 

Recreation Permits.

The PTNM would be 

CLOSED to Special 

Recreation Permits.

The BLM would authorize commercial, 

competitive, and organized group activities on a 

discretionary, case-by-case basis per 43 CFR Part 

2930, Special Recreation Permits, and in 

compliance with NEPA.

SRPs for OHV events would be limited by the 

following requirements, or other restrictions that 

provide for the protection of fossil resources:

 Would not degrade fossil resources;

 No more than 3 permitted OHV events per year 

(first-come, first-served, no multiple year events 

permits would be considered); 

 No permits would be issued for OHV events 

lasting for more than 4 consecutive days.

 No more frequently than 1 every 3 months;

 No more than 250 vehicles per event; 

 No more than 20 vehicles per “run”; 

 No more than 2 “runs” per trail route would be 

authorized during each event; 

 Only Registered Event vehicles (including 

event support and BLM staff vehicles) would be 

allowed on the routes, during the event.
2-14

RECREATION AND VISITOR SERVICES (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Continue to allow casual 

collecting of rock and 

mineral resources 

throughout the 

Monument.

Closed to casual 

collecting of rock and 

mineral resources.

Closed to casual collecting

of rock and mineral 

resources.

Limited collecting of rock 

and mineral resources would 

be allowed only in 

conjunction with BLM 

authorized education and 

interpretation activities. Use 

of small hand tools would 

not be allowed.

Allow casual 

collecting of rock 

and mineral 

resources 

throughout the 

Monument.

NOTES:

1

To deter resource damage, the BLM would sign sensitive areas as “no camping,” reduce evidence of inappropriate camping and 

educate visitors to use Leave No Trace principles. However, if the Monument Monitoring Plan demonstrates impacts to 

Monument resources, objects, and values from dispersed camping, a primitive campground and designated camping areas would 

be established within, or on lands adjacent to, the Monument. Monitoring criteria that would establish the need for a primitive 

campground include: campsites and fires near or on sensitive paleontological sites, large campsites damaging vegetation and/or 

game trails, and camping on routes. If a primitive campground is established, campfires would be limited to designated campsites 

with campfire rings.

2

If the Monument Monitoring Plan demonstrates that Primitive Campsites are impacting Monument resources, objects, and 

values, a more developed campground would be established, along with designated primitive camping areas that would be 

established within, or on lands adjacent to, the Monument. Factors monitored to determine the need for a developed campground 

include: the need to manage human waste and trash, reduce impacts from high use camping areas, or the need to manage and 

provide for visitor parking. If a campground is established, campfires would be limited to designated campsites with campfire 

rings.

* These are Implementation Level Decisions to be carried out in the future after subsequent 

implementation planning and analysis.

**These are Implementation Level Decisions that are being made concurrent with this planning effort,

and are appealable to the Interior Board of Land Appeals.
2-15

2.4.4 TRAILS AND TRAVEL MANAGEMENT

GOAL 1: Designate and manage areas in the Monument to the appropriate level of motorized and 

mechanized vehicle use so that fossils are protected. Areas must be classified as open, limited, or closed 

for motorized travel activities.

OBJECTIVE 1: Develop a Comprehensive Trails and Travel Management (CTTM) Plan to identify and 

designate routes within the Monument according to type and condition of use (Appendix C).

OBJECTIVE 2: Determine appropriate level of maintenance for mechanized or motorized access to the 

Monument.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 The portion of the Robledo Mountains WSA located within the Monument would be CLOSED to 

motorized and mechanized use.

 Exceptions to OHV travel restrictions or closures may be authorized for any military, fire, emergency, 

or law enforcement vehicle while being used for emergency purposes, and any vehicle in official use 

or expressly authorized in writing by the authorized officer.

 Where off-road vehicles are causing or would cause considerable adverse effects upon soil, 

vegetation, wildlife, wildlife habitat, cultural resources, historical resources, threatened or endangered

species, wilderness suitability, other authorized uses, or other resources, the affected areas shall be 

immediately closed to the type(s) of vehicle causing the adverse effect until they are eliminated and 

measures implemented to prevent recurrence (43 CFR §8341.2). The Monument Monitoring Plan 

would track changes to fossil resources based on trails and travel management actions. Based on the 

findings of the CTTM (Appendix C), implementation-level closures to certain routes are proposed 

across the various alternatives. Any future closures would be additional implementation-level 

decisions.**

 Dispersed pedestrian recreation would be allowed.

 The Monument would be open to equestrian use.

 As defined by BLM Manual 1626, OPEN areas are permitted year-long to motorized vehicle travel; 

LMITED areas are subject to restrictions and travel is within specified areas or on designated routes, 

roads, vehicle ways, or trails. CLOSED areas are those where motorized vehicle travel is prohibited.
2-16

TRAILS AND TRAVEL MANAGEMENT (Continued)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Motorized and 

mechanized travel is 

LIMITED (5,255 acres) 

to those routes 

designated by the 

Mimbres RMP, Robledo 

Mountains Off-Highway 

Vehicle Trails Plan, and 

the Doña Ana County 

Mountain Bike Trails 

(SST Trail).

A total of 37.6 miles of 

routes would be 

available for motorized 

or mechanized use.**

Approximately 32.3

miles of OHV 

recreational opportunity 

within the PTNM are 

open year-round for 

motorized use (see 

Map 2-1).**

The PTNM would be 

CLOSED (5,255 

acres) to recreational 

use by motorized and 

mechanized vehicles.

The BLM would 

issue supplementary 

rules for enforcement 

purposes in the future 

following the 

requirements in 43 

CFR 8365.1-6.

A total of 0 miles of 

routes would be 

available for 

motorized or 

mechanized use.**

All routes would be 

CLOSED to 

recreational 

motorized and 

mechanized use to 

protect fossil 

resources from the 

impacts of motorized 

or mechanized 

vehicles (see 

Map 2-2).**

Motorized and mechanized 

travel would be LIMITED 

(5,255 acres) to designated 

routes (Appendix C). 

Recreational use by 

motorized and mechanized 

vehicles (not associated with 

a permitted event) would 

require a no-fee Day Use 

Pass. These passes, along 

with maps and resource 

protection information, 

would be available online 

and at the local BLM office.

A total of 33.2 miles of 

current routes would be 

available for motorized or 

mechanized use.**

A total of 4.9 miles of 

previously designated OHV 

routes would be closed to 

motorized and mechanized 

vehicle use to protect fossil 

resources from their impacts

(see Map 2-3):**

 Tabasco Twister OHV 

Route- 2.7 miles 

 Patzcuaro’s Revenge 

OHV Route- 1.8 miles 

 Cayenne Crawler- 0.4 

miles 

Motorized and 

mechanized travel 

would be LIMITED 

(5,255 acres) to 

designated routes 

(Appendix C).

A total of 33.6 miles 

of current routes 

would be available for 

motorized or 

mechanized use.**

A total of 3.5 miles of 

previously designated 

routes would be 

closed to motorized 

and mechanized 

vehicle use to protect 

fossil resources from 

their impacts(see 

Map 2-4):**

 Tabasco Twister 

OHV Route- 2.7 

miles

 Patzcuaro’s 

Revenge OHV 

Route- 0.8 miles
2-17

TRAILS AND TRAVEL MANAGEMENT (Continued)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

The following route would 

also be closed to any 

designated use:

 Un-named Route- 0.5 

miles 

Cayenne Crawler 

would remain open, 

but would be 

modified from an 

uphill only route to a 

downhill only route. 

This would allow 

OHV use on Cayenne 

Crawler that leads 

into the remaining 

open portion of 

Patzcuaro’s Revenge 

OHV Route.

 Un-named Route 

Same as 

Alternative C.

The PTNM would be 

LIMITED to designated 

routes for recreational 

use by mechanized 

vehicles. The SST 

Mountain Bike Trail is 

open for year-round

mechanized and nonmotorized use (see

Map 2-1).

The PTNM would be 

CLOSED to 

recreational use by 

mechanized vehicles

(See Map 2-2).

Same as Alternative A (see 

Map 2-3).

Same as Alternative A

(see Map 2-4).

No management action 

planned.

Routes would not be 

maintained or 

improved.**

Designated routes that do not damage sensitive 

resources could be maintained or improved as 

necessary to facilitate designated visitor use.*

* These are Implementation Level Decisions to be carried out in the future after subsequent 

implementation planning and analysis.

**These are Implementation Level Decisions that are being made concurrent with this planning effort,

and are appealable to the Interior Board of Land Appeals.
2-18
2-19
2-20
2-21
2-22

2.4.5 AIR RESOURCES

GOAL 1: Manage uses to maintain Federal, State and local air quality standards.

OBJECTIVE 1: Manage activities on public land to maintain air quality consistent with the Clean Air 

Act and FLPMA.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

Prevent and reduce air quality impacts from authorized activities on public land by implementing 

mitigation measures developed on a case-by-case basis, described in Appendix E. These processes would 

be applicable to all BLM authorized activities.
2-23

2.4.6 CULTURAL RESOURCES

GOAL 1: Identify, preserve, and protect significant cultural resources and ensure they are available for 

use by present and future generations consistent with the BLM cultural resources program and appropriate 

to the goals of the PTNM.

GOAL 2: Reduce imminent threats and resolve potential conflicts from natural or human caused 

deterioration, or potential conflict with other resource uses consistent with the BLM cultural resources 

program and appropriate to the goals of the PTNM.

OBJECTIVE 1: Recognize potential public and scientific uses of cultural resources within the 

Monument, managing them in such a manner that these values and uses are appropriately protected.

OBJECTIVE 2: Protect and preserve in place representative examples of the full complement of 

cultural resources that may exist within the Monument.

OBJECTIVE 3: Ensure that proposed land uses avoid inadvertent damage to cultural resources on 

Federal, State, and non-Federal lands.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Cultural resource inventories would be done in response to specific land-use proposals in accordance 

with Section 106 of the National Historic Preservation Act (NHPA).

 Should at a later time a Native American entity express concern about a specific place or resource, the 

BLM will consult accordingly.

 The BLM would comply with Section 106 of the NHPA through the National Programmatic 

Agreement and the Protocol Agreement between New Mexico BLM and the State Historic 

Preservation Officer.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Historic properties, i.e., 

sites determined eligible for 

or included on the National 

Register of Historic Places

(NRHP), are allocated to 

uses subject to management 

actions. The six use 

allocations include: (1) 

scientific use, (2) 

conservation for future use; 

(3) traditional use; (4) 

public use; (5) experimental 

use; and (6) discharged 

from management.

Allocate historic properties to either scientific use or discharge from 

management. The latter are sites that have been determined to be not 

eligible or no longer eligible for the NRHP; therefore no longer 

constituting a historic property requiring a management action.
2-24

2.4.7 LANDS AND REALTY

GOAL 1: Manage the acquisition of lands or interests therein to meet the mandates of the Monument 

Legislation.

GOAL 2: Manage rights-of-way and land use authorizations within the Monument to meet the needs of 

the BLM and Monument Legislation.

OBJECTIVE 1: Retain all public land within the PTNM in Federal ownership.

OBJECTIVE 2: Acquire the mineral estate within the boundaries of the Monument to further protect the 

overall purposes of the Monument.

OBJECTIVE 3: Maintain a right-of-way and land use authorization system to meet resource 

management needs.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Federal land within the PTNM is withdrawn from entry, appropriation, or disposal under the public 

land laws. Federal land is not open to disposal through land exchange, land sales, State grants, 

Recreation and Public Purpose Act leases or sales, desert land entries, Indian allotments or 

commercial or agricultural leases (Appendix A).

 Public land within the PTNM would continue to be classified for retention under Section 7 of the 

Taylor Grazing Act, as amended (43 U.S.C. 315f).

 If additional lands and minerals are added to the Monument at a later date, these lands would be 

managed in accordance with the management decisions made in this RMP/EIS.

 The BLM would attempt to acquire access easements for public use from private landowners. 

Easements would be acquired only from willing sellers and would be in accordance with the 

provisions of Section 205 of FLPMA.

 Non-Federal mineral estate would be acquired only from a willing seller. Acquisition of the mineral 

estate would be in accordance with the provisions of Section 205 of FLPMA.

 The PTNM would be excluded from commercial communication site, transmission line, solar, and 

wind energy rights-of-way (ROWs).

 Realty actions such as rights-of-way or land use authorizations would be allowed within the 

Monument that are compatible with the values identified in the PTNM, while respecting existing 

uses. New uses will be in accordance with the provisions of TITLE III and TITLE V of FLPMA.

 Retain all public land.
2-25

LANDS AND REALTY (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

No existing acquisition 

management decisions.

Retain all public land.

Acquire approximately 640 acres of all non-Federal mineral estate within and 

adjacent to the Monument in sec. 36, T. 23 S., R. 1 W. (See Map 2-5).

Retain all public land.

Exclude authorizations 

for new ROWs, except 

when mandated by law. 

Access routes can be 

considered on a caseby-case basis. 

Existing ROWs within 

exclusion areas are 

recognized as 

grandfathered and 

operation, maintenance, 

and renewal of these 

facilities would be 

allowed to continue 

within the scope of the 

ROW grant.

Surface disturbing land 

use activities would not 

be authorized except for

scientific research.

Non-surface disturbing 

activities (for examplenon-surface disturbing 

film permits) could be 

authorized on a case-bycase.

Exclude new ROW authorizations, except when 

uses of the ROWs would further the purposes for 

which the Monument was established or when 

mandated by law.

Access routes can be considered on a case-by-case 

basis.

Existing ROWs within exclusion areas are 

recognized as grandfathered and operation, 

maintenance, and renewal of these facilities would 

be allowed to continue within the scope of the 

ROW grant.

Surface and non-surface disturbing activities would 

be authorized on a case-by-case basis.
2-26
2-27

2.4.8 LANDS WITH WILDERNESS CHARACTERISTICS

GOAL 1: For lands with wilderness characteristics identified for protection in the RMP, maintain 

wilderness characteristics by preventing incompatible activities.

GOAL 2: For lands with wilderness characteristics not identified for protection in the RMP, allow for 

activities that do not conform to the maintenance of wilderness characteristics while minimizing the 

impacts of the activity to the extent possible.

OBJECTIVE 1: Manage surface disturbing activities such that the natural quality of lands with 

wilderness characteristics identified for protection is maintained.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

No similar action. Manage the 576 acres 

(located in sec. 19, T. 22 S., 

R. 1 E. and sec. 24, T. 22

S., R. 1 W, see Map 2-6) 

that is contiguous with the 

Robledo Mountains WSA 

to maintain wilderness 

characteristics.

Management will follow 

these prescriptions:

 Prohibit all surface 

disturbing activities 

except those associated 

with permitted 

scientific exploration

and emergencies.

 Manage as an exclusion 

area for rights-of-way.

 Manage as a Visual 

Resource Management 

(VRM) Class I.

 Close to motorized and 

mechanized vehicles.

 No new trails or 

interpretation signage 

will be constructed 

within the area.

Manage the 253 acres 

(located in sec. 19, T. 

22 S., R. 1 E., see Map 

2-7) that is contiguous 

with the Robledo 

Mountains WSA to 

maintain wilderness 

characteristics.

Management 

prescriptions are the 

same as Alternative B.

Do not manage for the 

576 acres found to have 

wilderness 

characteristics (located 

in sec. 19, T. 22 S., R. 1 

E. and sec. 24, T. 22 S., 

R. 1 W.).
2-28
2-29
2-30

2.4.9 LIVESTOCK GRAZING

GOAL 1: Manage livestock grazing on public land in a manner that ensures progress toward achieving 

the New Mexico Standards for Public Land Health and Guidelines for Livestock Grazing Management

(BLM 2001). The Standards for Public Land Health are consistent with protecting the resources, objects 

and values for which the Monument was designated.

OBJECTIVE 1: Maintain quality and quantity of key forage and browse species for use by livestock 

and wildlife through continued implementation of appropriate grazing systems and management practices.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Continue monitoring range health and productivity within the National Monument to ensure standards 

for public land health are being achieved.

 Existing range improvements would continue to be maintained.

 New range improvements would not be authorized in the Robledo Mountains WSA.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Grazing for the Picacho 

Peak Allotment would 

continue under a 

deferred rotation system 

in accordance with the 

allotment management 

plan, as amended May 

1997.

Grazing use would 

continue to be 

authorized on the 

Altamira Allotment.

Grazing would be 

excluded from the 

PTNM.

Livestock grazing would 

be allowed when 

consistent with applicable 

laws and regulations and 

with protection of the 

Monument objects.

Develop a Monument 

Monitoring Plan within 2 

years of the signing of 

the PTNM RMP Record 

of Decision. If montoring 

indicates fossil resources 

or other Monument 

objects require protection 

from livestock, adjust the 

allotment management 

plan to exclude grazing 

from specific sites.* 

Adjustments could be 

made to the allotment 

management plan, in 

consultation with the 

permittee, to change 

grazing systems, number 

of livestock and season of 

use as needed.*

Same as Alternative A.

Develop a Monument 

Monitoring Plan within 

2 years of the signing of 

the PTNM RMP 

Record of Decision that 

would track changes to 

fossil resources based 

on livestock 

management actions.

*These are Implementation Level Decisions.
2-31

LIVESTOCK GRAZING (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Existing rangeland

improvements would 

continue to be maintained 

by the entity assigned 

maintenance responsibility

for livestock and wildlife 

use.

A benefit-cost analysis 

would be used to help set 

improvement priorities on 

all new rangeland 

improvements.

Rangeland improvements 

and vegetation treatments 

would be implemented to 

improve or maintain forage 

production and range 

condition.

Existing rangeland

improvements would be 

maintained by the BLM 

based on need and would 

be dependent on water 

availability.

No new rangeland

improvements would be 

authorized on public land 

within the PTNM.

Existing rangeland improvements would continue to be 

maintained by the assigned entity for livestock and wildlife 

use.

Implement new rangeland improvements as needed within 

the Monument to facilitate livestock management and 

minimize conflicts with other uses and management 

objectives.

Grazing treatments would 

be incorporated into 

activity plans to meet 

management objectives and 

goals established for each 

individual allotment.

Forage increases as a 

result of grassland 

restoration treatments 

would be reserved for 

watershed function.

Forage increases as a 

result of grassland 

restoration treatments 

would first be reserved to 

meet the needs for 

watershed function. 

Forage in excess of those 

needs would be allocated 

to wildlife and livestock 

with wildlife receiving 

priority over livestock.

All forage increases as a result 

of grassland restoration 

treatments would be allocated 

to wildlife and livestock, with 

neither having priority over 

the other.

* These are Implementation Level Decisions to be carried out in the future after subsequent

implementation planning and analysis.
2-32

2.4.10 SOILS

GOAL 1: Meet or move toward upland health standards consistent with the New Mexico Standards for 

Public Land Health and Guidelines for Livestock Grazing Management (BLM 2001) to protect and 

restore natural ecosystems and the fossil resources.

OBJECTIVE 1: Maintain and restore watersheds through enhanced soil stability and productivity, 

increased soil moisture, decreased erosion, and thriving desired vegetation communities.

OBJECTIVE 2: Stabilize soils and hydrologic processes by maintaining appropriate amounts of 

standing live vegetation and protective litter or rock cover, and minimize surface disturbances.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Soils would be managed to meet the New Mexico Standards for Public Land Health and Guidelines 

for Livestock Grazing Management (BLM 2001).

 Develop a Monument Monitoring Plan within 2 years of the signing of the PTNM RMP Record of 

Decision that would track changes to fossil resources based on soil management actions.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Control soil erosion, 

sediment movement, 

and salt contamination 

as a priority 

management goal. 

Minimize surface 

disturbance from 

construction projects.

Close and rehabilitate

unneeded roads. 

Control off-road 

vehicle use in critical 

areas.

Nonpoint source 

pollutants in 

watersheds and areas 

with critical to severe 

erosion would to be a 

major focus.

Project level planning 

would consider the 

sensitivity of 

watershed resources in 

the affected area on a 

site-specific basis.

Manage soil resources 

and areas needing 

restoration using only 

passive methods to meet 

the soil and hydrologic 

functions of the potential 

natural community or 

capability of the 

ecological site.

Passive methods would 

focus on prohibiting 

surface disturbing 

activities that would 

result in unnatural 

degradation of soil 

resources and allow soil 

recovery and production 

to occur through natural 

processes. Passive 

methods could include, 

but not be limited to, 

removing grazing, 

closing roads and trails, 

and prohibiting actions 

requiring heavy 

machinery.

Manage soil resources and 

areas needing restoration 

using both passive and 

active methods, with an 

emphasis on non-structural 

approaches whenever 

possible, to increase the 

site stability and the 

hydrologic function to the 

capability of the ecological 

site. 

Passive methods identified 

in Alternative B would be 

the same under this 

alternative. Active 

methods would include 

maintenance and 

rehabilitation of soil 

resources through actions

such as construction of 

water-bars, dikes, dropstructures, re-contouring, 

and seeding.

Manage soil resources 

and areas needing 

restoration using any 

acceptable 

management practices 

to meet the ecological 

site capability for soil 

and site stability and 

the hydrologic 

function to the 

capability of the 

ecological site. 
2-33

SOILS (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Critical soils on 0-10 

percent slopes would 

be the priority for 

treatments and grazing 

management to reduce 

erosion and improve 

water quality

No management action 

planned.

Stabilize and rehabilitate 

areas where accelerated 

erosion, runoff, and 

physical or chemical 

degradation have resulted 

in unacceptable soil 

conditions through the use 

of non-structural 

approaches whenever 

possible.

Stabilize and 

rehabilitate areas 

where accelerated 

erosion, runoff, and 

physical or chemical 

degradation have 

resulted in 

unacceptable soil 

conditions through the 

use of any acceptable 

practice.

No management action 

planned.

Prohibit surface 

disturbing activities and 

uses in areas containing 

high potential for soil 

erosion and storm water 

runoff.

Prohibit new surface 

disturbing activities for 

areas that contain a high 

potential for soil erosion 

and storm water runoff, 

except for activities 

required to meet resource 

goals and objectives,

provided impacts could be 

fully mitigated.

Allow surface 

disturbing activities 

and uses with proper 

mitigation in areas 

containing high 

potential for soil 

erosion and storm 

water runoff.
2-34

2.4.11 SPECIAL DESIGNATION- ROBLEDO MOUNTAINS ACEC

GOAL 1: Designate and manage areas that have special values, meet the relevance and importance 

criteria, and require special management to prevent risk of loss of or damage to those values.

OBJECTIVE 1: Manage ACECs where relevance and importance criteria are met and special 

management is required to protect the identified values.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Carry forward the Robledo Mountains ACEC designation in order to protect biological, cultural, and 

scenic values and to protect, research, and interpret paleontological values, consistent with Section 

2014(d)(1)(B) of the Omnibus Public Land Management Act of 2009, which states that “[t]he 

establishment of the Monument shall not change the management status of any area within the 

boundary of the Monument that is...managed as an area of critical environmental concern.”

Management will follow these prescriptions:

o Retain all public land.

o Limit vehicle use to designated roads and trails.

o Exclude authorizations for new rights-of-way.

o Withdraw from location, entry, and patent under the mining laws.

o Withdraw from the mineral leasing laws, geothermal leasing laws, and mineral materials laws.

o Acquire legal public access.

o Maintain current livestock grazing practices.

o Allow natural fires to burn under prescribed conditions.

o Manage for primitive and semi-primitive recreation opportunities (no developed facilities).

o Manage as VRM Class I.

2.4.12 SPECIAL DESIGNATION- ROBLEDO MOUNTAINS WSA

GOAL 1: Manage areas that have special values to prevent risk of loss or damage to those characteristics 

and values.

OBJECTIVE 1: Protect naturalness; outstanding opportunities for primitive, unconfined recreation; and 

outstanding opportunities for solitude.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Recreation opportunities within the Robledo Mountains WSA portion of the Monument would remain 

primitive with no motorized or mechanized vehicle traffic in order to preserve the wilderness 

characteristics. The WSA would be managed in accordance with the Management of Wilderness 

Study Areas Manual 6330 and Guidelines for Lands under Wilderness Review.
2-35

2.4.13 SPECIAL DESIGNATION-PALEOZOIC TRACKWAYS

RESEARCH NATURAL AREA (RNA)

GOAL 1: Manage the fossil resources within the Paleozoic Trackways RNA to prevent loss or damage.

OBJECTIVE 1: Manage the resources according to the Legislation designating the Monument, The 

Omnibus Public Land Management Act of 2009, which is to protect, research, and interpret 

paleontological resources.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Manage the Paleozoic 

Trackways RNA to protect 

and allow research and 

interpretation of the fossils

(see Map 3-6):

 Retain public land; 

acquire State land 

inholdings through 

exchange or purchase.

 Limit vehicle use to 

designated roads and 

trails.

 Exclude new rights-ofway.

 Access routes will be 

limited and considered 

on a case-by-case 

basis.

 Withdraw from 

location, entry, and 

patent under the 

mining laws.

 Withdraw from 

operation of the 

mineral leasing laws, 

geothermal leasing 

laws, and mineral 

materials laws.

 Manage and interpret 

in accordance with 

Trackways study 

legislation.

 Manage as VRM Class 

II

The Paleozoic Trackways RNA designation would be discontinued for all 

land within the Monument boundary. The resources would be managed 

according to the Legislation and the management actions determined in the 

Prehistoric Trackways RMP.
2-36

2.4.14 SPECIAL STATUS SPECIES

Texas Horned Lizard

GOAL 1: Manage public land to maintain, restore, improve or enhance habitats that lead to the recovery 

of Federally-listed species populations and preclude the need for listing proposed, candidate, State 

protected or sensitive species.

OBJECTIVE 1: Over the life of this RMP, achieve “no net loss” of special status species habitats by 

maintaining, restoring, and improving special status species habitat.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

The BLM would ensure that appropriate management, protections, and mitigations would be developed 

and applied by continuing to monitor and inventory special status species and their habitats throughout 

the Monument. Any future proposed surface disturbing activities would require surveys for special status 

species and appropriate mitigation.
2-37

2.4.15 VEGETATION

GOAL 1: Manage vegetation resources to produce healthy and vigorous native plant communities with 

an abundance and distribution of vegetative density and diversity within the PTNM.

OBJECTIVE 1: Provide a mosaic of vegetative communities through protection and restoration of 

vegetation resources to protect soils, watersheds, air quality, wildlife and scenic views.

OBJECTIVE 2: Monitor for the potential introduction and spread of noxious weeds within the 

Monument and manage any noxious weeds and native invasive species.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 The Monument would be closed to commercial and recreational plant collecting. The BLM would 

retain plant/seed collecting authority for administrative purposes (e.g., Seeds of Success).

 Vegetation treatments would be in compliance with the 2007 Record of Decision for the Vegetation 

Treatments on Bureau of Land Management Lands in 17 Western States Programmatic 

Environmental Impact Statement.

 The BLM would develop a Monument Monitoring Plan that would track changes to fossil resources 

based on vegetation management actions.

 Where restoration, rehabilitation, or reclamation efforts require reseeding activities, or use of other 

plant materials (such as potted plants, poles, etc.), non-native plant species would be used only if 

native species are not readily available in sufficient quantities. Care would be taken in selecting nonnative species that are not likely to become invasive. If non-native plant species are used or identified 

for use in restoration, rehabilitation, or reclamation projects, the BLM would identify and develop 

native replacements for the non-native species. Additionally, seed mixes used in these actions would 

use the closest locally adapted selections, varieties, or cultivars of native species available to improve 

success of the seeding effort (Executive Order 13112, BLM Manual 1745, and subject to future 

revisions to Bureau policy and guidance).
2-38

VEGETATION (Concluded)

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Creosotebush, 

mesquite, and other 

desert shrubs (<10% 

slope) would be 

treated almost 

entirely by the use of 

herbicides. Areas 

over 10% slope, 

within 1⁄2-mile of a 

perennial stream, or 

within a 1⁄4-mile of a 

dwelling and 

vegetation 

containing vacant or 

occupied raptor nests 

would not be treated 

with herbicide.

Manage vegetation 

communities and areas needing 

restoration using passive 

methods to meet the ecological 

site potential, natural 

community, or capability 

(degree to-which the kind, 

proportions, and amounts of 

plants in the ecological 

community resemble the 

potential natural community 

based on the area’s disturbance 

history).

Passive methods allow the 

vegetation resource to naturally 

regenerate over time without 

taking direct action.

Manage vegetation 

communities and areas 

needing restoration 

using passive and 

active treatments to 

increase native 

vegetation to the 

capability of the site. 

Active methods include 

activities designed to 

enhance or improve the 

vegetation resource, 

including mechanical, 

cultural, biological or 

chemical restoration 

practices.

Manage vegetation 

communities and 

areas needing 

restoration using 

passive and active 

restoration to meet 

the ecological site 

capability.

No management 

action planned.

Manage transitioning areas and 

other stable-state areas for a 

desired state and condition to 

meet ecological site potential.

An emphasis would be on 

enhancing habitat for special 

status species.

Same as Alternative B.

Manage for multipleuse values while 

maintaining or 

enhancing habitat for 

special status species.

Same as Alternative 

B.

Emphasize

commodity uses 

while maintaining or 

enhancing habitat for 

special status 

species.

Chemical herbicides 

would be used to 

control noxious 

weeds.

Use integrated management 

techniques including passive, 

manual, and biological 

treatment methods to manage 

noxious weeds and non-native 

invasive species.

Same as Alternative B

but with the additional 

use of chemical and 

mechanical treatments.

Same as Alternative 

C but with the 

additional use of 

fire.
2-39

2.4.16 VISUAL AND SCENIC RESOURCES

GOAL 1: To manage Federal land in a manner that maintains the scenic values.

OBJECTIVE 1: Ensure that activities and land uses are consistent with, and meet, VRM Class 

objectives.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

WSAs, until such time as these areas are designated as wilderness or released for other uses by Congress,

will be managed as VRM Class I (BLM IM 2000-096).

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

PTNM has four VRM 

Classes:

VRM Class I: 789 acres 

VRM Class II: 907 acres

VRM Class III: 2,627 acres

VRM Class IV: 932 acres

See Map 2-8.

PTNM would be 

classified in the

following VRM 

Classes:

Class I: 1,365 acres 

Class II: 3,912 acres

See Map 2-9.

PTNM would be 

classified in the

following VRM 

Classes:

Class I: 1,042 acres 

Class II: 4,213 acres

See Map 2-10.

PTNM would be 

classified in the 

following VRM 

Classes:

Class I: 789 acres 

Class II: 4,465 acres

See Map 2-11.

ADD A PHOTO
2-40
2-41
2-42
2-43
2-44

2.4.17 WATER RESOURCES

GOAL 1: Ensure surface and ground water influenced by BLM activities comply with or are making 

significant progress toward achieving New Mexico water quality standards consistent with the New 

Mexico Environment Department and the U.S. Environmental Protection Agency.

OBJECTIVE 1: Fully mitigate any action which may contribute nonpoint source pollutants into the Rio 

Grande and to protect the State’s water resources.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Enter into cooperative management agreements or other instruments with interested parties or 

agencies, as appropriate, to coordinate and collaborate watershed management of the Monument.

 Consult and coordinate with other Federal, State, and local agencies, as directed by the Watershed 

Protection and Flood Prevention Act (16 U.S.C. 1001-1009), and the Clean Water Act (33 U.S.C. 

1251).

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Erosion control would 

continue to be 

incorporated into all 

surface disturbing 

actions.

Prohibit surface 

disturbing activities on 

public land within the 

Rio Grande watershed 

and areas susceptible to 

high amounts of erosion, 

except activities 

specifically designed for 

enhancing water quality.

Fully mitigate 

surface disturbing 

activities on public 

land within the Rio 

Grande watershed 

and use nonstructural approaches 

whenever possible.

All surface disturbing 

activities would be allowed 

provided they do not 

contribute to the Rio Grande 

becoming impaired from 

nonpoint source pollutants. 

Site-specific mitigation 

would apply to activities 

near 303d streams.
2-45

2.4.18 WILDLAND FIRE MANAGEMENT

GOAL 1: Reduce the risk to human life and property from wildland fire; reduce the risk and cost of fire 

suppression in areas of hazardous fuels buildup; and improve landscape health through returning fire to its 

natural role in the ecosystem.

OBJECTIVE 1: Reduce the potential for escaped fire or loss of life or property in surrounding areas.

OBJECTIVE 2: Improve landscape health through treating lands in Fire Regime Condition Classes 2 

and 3 to achieve the desired future condition of the landscape of Fire Regime Condition Class 1. 

Maintain Condition Class 1 where it occurs (see Map 3-11).

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Incorporate current management as outlined in the Resource Management Plan Amendment for Fire 

and Fuels Management on Public Lands in New Mexico and Texas (BLM 2004a).

 Fires would be suppressed and hazardous fuels would be treated in wildland urban interface areas.

 A cultural and paleontological resource advisor would be consulted during a pre-fire season meeting. 

Aerial drops of fire retardant would avoid Monument resources, objects and values, and water would 

be the preferred method of suppression.

 Any improvements would be protected from all fire by preplanned defendable space and fire 

suppression tactics as needed.

 Resources and fire management would be integrated as potential new issues arise or objectives 

change.

 In Fire Management Units categorized as C or D, natural ignitions (lightning started fires) could be 

managed for resource benefit (see Map 3-12).

 The BLM would develop a Monument Monitoring Plan within 2 years of the signing of the PTNM 

RMP Record of Decision that would track changes to fossil resources based on fire management.

ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Management tools such as prescribed fire and mechanical thinning 

would not be considered for use in the Monument.

The use of prescribed fire and 

mechanical thinning as 

management tools based on 

future needs and future 

vegetation analysis would be 

considered for the Monument.
2-46

2.4.19 WILDLIFE

GOAL 1: In cooperation with the New Mexico Department of Game and Fish (NMDGF), manage the 

PTNM to provide sufficient quantity and quality of wildlife habitat and to maintain or enhance wildlife 

populations and biological diversity.

OBJECTIVE 1: Protect, enhance, and restore native wildlife and wildlife habitats by the following:

 Manage public land to attain the biotic and other standards for public land health in conjunction with 

the Standards for Public Land Health and Guidelines for Livestock Grazing Management (BLM 

2001).

 Manage for Species of Greatest Conservation Need and Key Habitats identified in the NMDGF’s 

Comprehensive Wildlife Conservation Strategy (CWCS).

 Implement BLM activity plans or other Federal, or State plans and wildlife habitat projects consistent 

with habitat management goals and objectives.

 Manage public land to allow for reintroductions, transplants, and augmentations of native wildlife 

populations in coordination with the NMDGF or the U.S. Fish and Wildlife Service and consistent 

with applicable agency policies and habitat and population management plan goals.

 Maintain and restore habitat connectivity in and between public land including breeding, foraging, 

dispersal, and seasonal use habitats.

MANAGEMENT COMMON TO ALL ALTERNATIVES:

 Implement the Robledo Mountains Habitat Management Plan for deer, antelope, and upland game 

species, which includes the installation of water developments as needed.

 Animal Damage Control actions would be conducted in accordance with their annual plans.
2-47

2.5. SUMMARY COMPARISON OF IMPACTS

Table 2-1 summarizes the impacts by resource by alternative for the PTNM. These impacts are fully 

discussed in Chapter 4. The dark gray shaded boxes list the resource or use, and the boxes with no 

shading are the estimated impacts per alternative.

The following resources have been found to have negligible or no impacts from any of the management 

alternatives proposed:

 Riparian Areas

 Woodland Management

 Floodplains and Wetlands

 Geology

 Minerals

 Hazardous and Solid Wastes

 Prime or Unique Farmlands

 Wild and Scenic Rivers

The BLM reached out to American Indian tribes but were not made aware of any tribal concerns from the 

management alternatives.
2-48

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

PALEONTOLOGICAL RESOURCES

Casual collecting of common 

invertebrate and plant 

paleontological resources 

would lead to depletion of the 

resources.

Off-site interpretation would 

increase protection through 

enhancing awareness, and 

leaving sites conserved in-situ 

for future research.

Vehicles would continue to 

damage fossils through 

crushing, fracturing, or 

staining.

Closing the PTNM to the 

casual collection of fossils 

would reduce the loss of 

scientific-worthy vertebrate 

fossils, but would also 

reduce educational and 

recreational opportunities. 

Off-site interpretation would 

protect resources by 

increasing awareness and 

leaving paleontological sites 

conserved in-situ for future 

research.

Closure to motorized and 

mechanized travel would 

eliminate damage to fossils 

from this use.

Restricting the casual collecting 

of common invertebrate and 

plant fossils would reduce the 

loss of scientific-worthy 

vertebrate fossils.

On-site education and 

interpretation would increase 

awareness of the resource but 

could increase the potential for 

looting.

Closing certain routes would 

protect important exposed 

fossils from OHV activity. 

Development of visitor facilities 

could increase visitation and 

thereby result in increased 

stewardship, but vandalism and 

looting could also increase.

Same as Alternative C except, 

both the beneficial and 

adverse impacts from on-site 

interpretation and facilities 

would be increased due to 

more development.

EDUCATION AND INTEPRETATION

Scientific research would 

enhance education and 

interpretation through the 

discovery of new sites.

Casual collecting of common 

invertebrate and plant 

paleontological resources

would enhance the educational 

experience in the Monument.

Limited facility and trail 

development would constrain 

the interpretive experience onsite.

Same as Alternative A.

The closure to casual 

collection of fossils would 

limit the on-site interpretive 

experience.

Same as Alternative A.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities such as 

interpretative trails and signs 

in those areas (576 acres).

Same as Alternative A.

Same as Alternative B.

On-site interpretation, trails and 

facilities would be developed to 

enhance educational 

opportunities.

Same as Alternative B except 

surface disturbing activities may 

be limited to 253 acres. The 

remaining 323 acres found to 

have wilderness characteristics, 

but not managed for those 

characteristics, may be impacted 

from potential surface 

disturbing activities. 

Same as Alternative A. 

Collecting common fossils in 

conjunction with a BLM 

activity would enhance the 

educational experience.

The development of a 

motorized interpretive tour or 

a visitor center would enhance 

the experience of many 

visitors.

Lands found to have 

wilderness characteristics 

would not be managed for 

those characteristics, therefore 

development may occur and 

may impact the wilderness 

characteristics in those areas 

(576 acres).
2-49

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

RECREATION AND VISITOR SERVICES

Annual visitation to the 

Monument area is 25,000.

Casual collecting of common 

invertebrate and plant fossils 

provides a recreational 

opportunity. 

The lack of on-site visitor 

facilities limits the visitor 

experience and may reduce 

visitation from some groups. 

Target shooting could cause 

conflict between users.

No planned improvement or 

maintenance of trails would 

limit recreation.

Annual visitation may be 

reduced by 5,625 visitors. 

Casual collection of fossils, 

Special Recreation 

Permits, and motorized and 

mechanized vehicle use 

would not be allowed, thus 

reducing the number of 

recreation opportunities.

Same as Alternative A.

Same as Alternative A.

Annual visitation would increase 

to 37,500 people.

Same as Alternative B.

On-site visitor facilities would 

enhance the visitor experience 

and may increase visitation.

Closure to target shooting would 

reduce a recreational opportunity.

Closure of a portion of the OHV 

trails would impact the extreme 

OHV users. Maintaining and 

developing trails and routes 

would enhance recreational 

opportunities.

Annual visitation would 

increase to 75,000 people.

Collecting common fossils 

while in conjunction with a 

BLM activity would provide a 

recreational opportunity.

A visitor center and a 

campground would create 

recreational opportunities.

Same as Alternative C.

A 1.4-mile portion of trail 

route would remain open 

providing an opportunity to 

access an extreme route. 

TRAILS AND TRAVEL MANAGEMENT

Continued use of the existing 

37.6 miles of designated trails 

provides an extensive route 

network with a variety of 

opportunities for motorized, 

mechanized, and pedestrian 

use and travel. 

Improvement or maintenance 

of existing routes has not been 

planned for, reducing the ease 

of access for educational and 

some recreational uses.

Closing the Monument to 

motorized and mechanized 

travel would reduce access 

to most visitors.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities, such as 

trails and roads and routes in 

those areas (576 acres).

Lack of improvement or 

maintenance of routes would 

reduce the ease of access and 

recreational experience for 

many visitors.

Limiting motorized and 

mechanized travel to 32.2 miles 

of designated routes would

provide an extensive route 

network with a variety of 

opportunities for use.

Lands found to have wilderness 

characteristics, managed for 

those characteristics, may limit 

the new development of 

facilities, additional roads and 

routes and maintenance in those 

areas (253 acres). The 323 

acres found to have wilderness 

characteristics, but not managed 

for those characteristics, may be 

impacted from potential surface 

disturbing activities

Improved and maintained routes 

would enhance the visitor 

experience.

Same as Alternative C, except 

33.6 miles of routes would be 

designated.

Lands found to have 

wilderness characteristics 

would not be managed for 

those characteristics, therefore 

new trails, roads, and route 

construction may occur and 

may impact the wilderness 

characteristics in those areas 

(576 acres).

Same as Alternative C.
2-50

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

AIR RESOURCES-- AIR QUALITY

Vehicle travel on designated 

trails has the potential to emit 

pollutants and cause dust.

Surface disturbance from 

potential authorized rights-ofway could cause dust 

emissions.

Mineral extraction could cause 

dust emissions.

Closure to motorized and 

mechanized use would 

reduce dust and emissions 

compared to Alternative A.

Rights-of-way would not be 

allowed. Emissions would 

be less than Alternative A.

No mineral extraction would 

take place. Emissions would 

be less than Alternative A.

Managing for lands with 

wilderness characteristics 

may limit new surface 

disturbing activities, and 

potentially reduce dust 

emissions in those areas (576 

acres), compared to 

Alternative A. 

Same as Alternative A. 

Same as Alternative A.

Same as Alternative B.

The 323 acres of lands with 

wilderness characteristics, but 

not managed for them, may be 

subject to disturbing activities 

that increase dust emissions.

Construction of facilities could 

cause emissions. 

Same as Alternative A.

Same as Alternative A.

Same as Alternative B.

Lands found to have 

wilderness characteristics 

would not be managed for 

them. Dust emissions may 

potentially increase due to 

surface disturbing activities in 

those areas (576 acres).

Same as Alternative C.

AIR RESOURCES -- CLIMATE

It is not possible to predict with certainty the potential emissions of greenhouse gases (GHG) associated with the four alternatives, 

their potential impacts on temperature within the Planning Area, or related impacts on resources due to climate change. In general, 

trails and travel management, livestock grazing, and wildland fire generate GHG emissions that contribute to climate change and, in 

turn, may impact resources.

CULTURAL RESOURCES

The BLM would comply with 

Section 106 of the National 

Historic Preservation Act 

thereby minimizing impacts to 

cultural resources.

Closure of the Monument to 

rights-of way, vehicular 

travel and other surface 

disturbing activities would 

greatly reduce the potential 

impacts to cultural resources.

Same as Alternative A Same as Alternative A
2-51

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

LANDS AND REALTY

Surface disturbing land use 

authorizations could take 

place.

Commercial-scale renewable 

energy would be excluded. 

Authorizations would meet 

Visual Resource Management 

(VRM) Classes I to IV.

Surface disturbing land use 

authorizations would be 

excluded from the PTNM.

Same as Alternative A.

There would be no VRM 

impacts.

Obtaining non-Federal 

minerals would eliminate 

split-estate issues.

Surface disturbing land use 

authorizations would be 

considered with the exception of 

lands managed for their 

wilderness characteristics.

Same as Alternative A.

VRM I and II could limit land 

use authorizations.

Same as Alternative B.

Same as Alternative C

Same as Alternative A.

Same as Alternative C.

Same as Alternative B.

LANDS WITH WILDERNESS CHARACTERISTICS

Lands found to have 

wilderness characteristics but 

not managed for those 

characteristics may be 

impacted (576 acres).

Managing for lands with 

wilderness characteristics 

would protect the wilderness 

characteristics in those areas 

(576 acres).

Lands found to have wilderness 

characteristics and managed for 

them may limit disturbance 

activities (253 acres). The 

remaining 323 acres found to 

have wilderness characteristics, 

but not managed for them, may 

be impacted from potential 

surface disturbing activities.

Designation of the Monument 

as VRM I and II would help 

retain wilderness characteristics.

Same as Alternative A. 

VRM I and II designations 

may help to retain some of the 

wilderness characteristics 

found in the PTNM.

LIVESTOCK GRAZING

Increased visitation could 

cause increased conflicts with 

livestock and recreational 

users.

Vegetation treatments could 

improve forage and reduce 

competition.

There would be no direct 

impacts from livestock 

grazing in the Monument.

Exclusion from grazing 

would require fencing and 

management adjustments in 

the Picacho Peak and 

Altamira allotments. 

Animal unit months (AUMs) 

would be reduced by a 

minimum of 456 for the two 

allotments.

Same as Alternative A.

Fences would be constructed to 

protect significant fossils as 

needed. Forage reductions 

would be based on the specific 

acres excluded.

Same as Alternative A but using 

more effective techniques.

Excluding improvements from 

253 acres managed for 

wilderness characteristics may 

reduce the use of forage.

Same as Alternatives C with 

more anticipated interactions 

between visitors and livestock 

as visitor facilities and routes 

increase.

Same as Alternatives A and C, 

but with more forage possibly 

improved.
2-52

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

SOCIO-ECONOMIC CONDITIONS

Visitation to the PTNM would 

support 16 jobs and $417,000 

in labor income annually.

Visitor facilities would not be 

constructed.

Alternative A has the lowest 

levels of non-market economic 

values and the least support for 

social values related to 

preservation of ecological 

health and wilderness.

Similar levels of employment 

and income would be 

supported.

None of the decisions are 

expected to disproportionately 

or adversely affect 

environmental justice 

communities.

Designation of 37.6 miles of 

roads and trails open to 

motorized and mechanized 

uses supports social values 

related to public land access 

and OHV recreation.

Visitation to the PTNM 

would support 4 jobs and 

$94,000 in labor income 

annually.

Economic benefits from 

facility construction would 

not be realized.

Alternative B would support 

the highest levels of nonmarket economic values and 

social values related to 

protection of natural and 

cultural resources.

Elimination of grazing 

would reduce labor income 

to ranchers.

Same as Alternative A

Closure to motorized and 

mechanized uses would 

reduce the quality of life for 

those who primarily value 

OHV recreation, but would 

make PTNM more of an 

attraction for others.

Visitation to the PTNM would 

support 24 jobs and $626,000 in 

labor income annually.

Development of visitor facilities 

would temporarily increase 

local employment and labor 

income during construction.

Alternative C balances social 

values of access and motorized 

recreation with values related to 

ecological health and 

wilderness.

Social and economic 

consequences of grazing are the 

same under Alternatives A.

Same as Alternative A.

Same as Alternative A but with 

a reduction in available routes 

for extreme OHV opportunities.

Visitation to the PTNM would 

support 47 jobs and annual 

labor income of $1,251,000.

Same as Alternative C.

Alternative D would support 

lower levels of non-market 

economic values and social 

values related to protection of 

natural and cultural resources.

Same as Alternatives A.

Same as Alternative A.

Same as Alternative C.

SOILS

Excavations could cause 

highly disturbed areas. Casual 

collecting of fossils would 

have a minor disturbance. 

Soil disturbance would be 

caused by recreation, research, 

interpretation tours, camping, 

Special Recreation Permits, 

vehicular travel, right-of-way 

development, and range 

improvements. 

Spills of petroleum products 

could contaminate soils.

Surface disturbance would 

be reduced because casual 

collecting would be 

prohibited.

Closure to vehicular travel 

and camping, no issuance of 

Special Recreation Permits, 

removal of grazing, and 

exclusion of surface 

disturbing land use 

authorizations would all 

benefit soils.

Same as Alternative B.

Visitor facilities would displace 

and compact soils, increasing 

runoff and erosion rates.

Same as Alternative A.

Same as Alternative C.
2-53

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

SPECIAL DESIGNATION -- AREA OF CRITICAL ENVIRONMENTAL CONCERN (ACEC)

Manage as the Robledo 

Mountains ACEC.

Same as Alternative A. Same as Alternative A. Same as Alternative A.

SPECIAL DESIGNATION-- RESEARCH NATURAL AREA (RNA)

Management prescriptions of 

the RNA would be duplicated 

by the PTNM Legislation.

The RNA designation would 

be removed and replaced by 

the PTNM RMP decisions.

Same as Alternative B. Same as Alternative B.

SPECIAL DESIGNATION -- WILDERNESS STUDY AREA (WSA)

The Robledo Mountains WSA 

would be managed to meet the 

non-impairment standard. 

Same as Alternative A. Same as Alternative A. Same as Alternative A.

SPECIAL STATUS SPECIES

Vehicle travel and dispersed 

recreation has the potential to 

temporarily displace special 

status species or injure slow 

moving species.

Livestock watering sources 

would benefit special status 

species such as bats.

Vegetation management would 

improve habitat for species 

associated with grasslands.

Closure to motorized and 

mechanized travel would 

reduce potential for injury of 

some species such as Texas 

horned lizard.

Elimination of livestock 

grazing could reduce forage 

competition and improve 

habitat for species such as 

burrowing owl and northern 

shrike.

Same as Alternative A.

Same as Alternative A except 

development could increase 

temporary displacement of 

special status species or injure 

slow moving species.

Same as Alternative A. 

Same as Alternative A.

Same as Alternative C.

Same as Alternative A.

Same as Alternative A.

VEGETATION

Special designations would 

protect 789 acres from surface 

disturbing activities.

Use of trails and routes has the 

potential to remove or damage 

vegetation and spread noxious 

weeds.

Livestock grazing may remove 

30 to 50 percent of key forage 

species and has the potential to 

introduce or spread weeds.

Vegetation treatments have the 

potential to shift species 

dominance and control weeds.

Same as Alternative A, but 

with an additional 576 acres 

managed as lands with 

wilderness characteristics.

Surface disturbing activities, 

e.g., Special Recreation 

Permits, OHV use, and 

rights-of-way, would be 

restricted to reduce the 

potential for damage to 

vegetation. 

Elimination of livestock 

grazing decreases utilization 

of forage species favored by 

cattle.

Treatment options would be 

limited for noxious weed 

control.

Same as Alternative A except an 

additional 253 acres would be 

managed as lands with 

wilderness characteristics.

Development of new trails, 

routes, or facilities could 

remove vegetative cover in 

other areas.

Same as Alternative A

Same as Alternative A.

Same as Alternative A.

Same as Alternative C except 

additional surface disturbance 

and vegetation removal is 

possible from facilities 

development.

Same as Alternative A.

Same as Alternative A.
2-54

TABLE 2-1

SUMMARY OF IMPACTS BY RESOURCE BY ALTERNATIVE

ALTERNATIVE A ALTERNATIVE B

ALTERNATIVE C 

(PREFERRED) ALTERNATIVE D

VISUAL RESOURCES

VRM Class I designation 

would preserve the character 

of the landscape on 789 acres 

of the most scenic, natural 

appearing, and visually 

sensitive areas.

VRM Class II would retain the 

existing character of the 

landscape on 907 acres.

The remaining lands would be 

designated as VRM Class III 

and IV, which allow more 

change in the visual character 

of the land.

Development of 368 acres of 

non-Federal minerals may 

impact the existing character 

of the landscape.

1,365 acres would be 

designated as VRM Class I 

as described in Alternative 

A.

3,912 acres would be 

designated VRM Class II as 

described in Alternative A. 

Exclusion of livestock from 

the Monument could cause 

short-term visual impacts 

from fence construction.

1,042 acres would be designated 

VRM Class I as described in 

Alternative A. 

4,213 acres would be designated 

VRM Class II as described in 

Alternative A. 

Same as Alternative A.

789 acres would be designated 

VRM Class I as described in 

Alternative A.

4,465 acres would be VRM 

Class II as described in 

Alternative A.

Same as Alternative A.

WATER RESOURCES

Surface disturbing activities 

may create nonpoint source 

pollutants that could transport 

to the Rio Grande, decrease 

infiltration, increase runoff, 

and alter water flow patterns.

Restrictions in surface 

disturbing activities would 

help soil stability and 

productivity, hinder erosion, 

and reduce nonpoint source 

pollution.

Same as Alternative A. Same as Alternative A.

WILDLAND FIRE MANAGEMENT

Visitation and associated 

recreation activities could 

increase potential for humancaused wildfires. 

Vegetation treatments could 

cause an increase in fuel 

loading resulting in unwanted 

fire behavior.

Same as Alternative A 

except the reduction of some 

recreation activities would 

reduce the potential of 

human-caused wildfires.

Reduction in livestock 

grazing would increase fuels 

and the likelihood that a 

wildfire would carry.

Same as Alternative A. Same as Alternative A.

WILDLIFE

Increase in visitation and 

recreation activities could 

temporarily displace wildlife.

Vehicular travel has the 

potential to injure slow 

moving wildlife.

Closure to travel would 

decrease potential injury and 

displacement of wildlife.

Removal of livestock would 

increase forage and cover for 

wildlife.

Same as Alternative A except 

increased displacement could 

occur around developed 

interpretation sites and facilities

Same as Alternative C, except 

prescribed fire could displace, 

kill or render habitat 

unsuitable but would have 

long-term benefits to habitat.
AFFECTED ENVIRONMENT

CHAPTER 

3

tHE 
3-1

Figure 3-1

Amphibian Trace. 

Illustration by 

Matt Celeskey, NM 

Museum of 

Natural History & 

Science

CHAPTER 3 AFFECTED ENVIRONMENT

3.1 INTRODUCTION

This Chapter describes the current environment within the Prehistoric Trackways National Monument

(PTNM). Many, though not all, of the sections within this Chapter correlate with programs for which the 

Bureau of Land Management (BLM) intends to make management decisions through the planning 

process. These resources and uses may be affected by the implementation of any of the management 

alternatives, but the current environment gives a baseline to which to compare the impacts from the 

different alternatives.

3.2 RESOURCES AND USES

3.2.1 Paleontological Resources

Within the Monument, evidence of life that once existed along an ancient tidal flat is contained in red 

stained layers of sandstone, siltstone, and mudstone that are referred to as the Robledo Mountain 

Formation (some call this the Abo Formation). These red layers are interbedded with grayish-yellow 

limestone layers that were laid near shore and in deeper waters of a regressive-transgressive Permian-aged 

sea. Together, these rocks comprise what is known as the Hueco Group. The limestones of the Hueco 

Group contain a number of marine invertebrate fossils that include brachiopods, snails, and crinoids. 

Paleontological resources may also be found in sedimentary rocks that were deposited 

during the Oligocene Epoch through the Pleistocene Epoch. These sediments constitute the 

filling of the Rio Grande Rift and are collectively known as the Santa Fe Group. Fossils 

found in the Santa Fe Group are typified by terrestrial vertebrates. 

In the sedimentary rocks, the movements of animals have been preserved in the sands, silts,

and mud of the tidal flat for almost 300 million years. Jumping trails of wingless insects 

have been preserved. Activities of amphibians (see Figure 3-1), reptiles, a variety of 

arthropods including horse shoe crabs (see Figure 3-2), and insects are recorded in the red 

beds. Even impressions of the animals themselves have been documented by recent 

discoveries of sea anemones and jelly fish.

These impressions in rock are called trace fossils (ichnofossils) and they can be used to 

develop a picture of what life was like on the coast of an inland 

Permian sea 280 million years ago (see Figures 3-2 and 3-3), 

before the age of dinosaurs. Leaf impressions and petrified 

wood (see Figures 3-4, 3-5, and 3-6,) tell what was growing on 

the landscape. When the sea level rose, the tidal flats were 

inundated by marine waters, and the limestone was deposited. 

This marine limestone contains a variety of invertebrate body 

fossils such as shells of brachiopods, clams, and gastropods

(see Figure 3-8).

Sedimentary structures such as ripple laminations and mud 

cracks, along with various trace fossils, can be used to define 

life zones on the tidal flat, shallow water zones, and tidal Figure 3-2. Horseshoe Crab Trace. 

Illustration by Mary Sundstrom.
3-2

channels, allowing paleontologists and sedimentologists to refine models of Permian ecosystems. Animal 

tracks reveal how an animal lived and what its life was like and, perhaps, who was food for whom.

The BLM is directed by Section 2103 of Public Law 111-11 to conserve, protect, and enhance the 

resources and values of the Monument. Paleontological resources collected under a research permit 

would be stored in a Federally-approved repository for research and use in exhibits in order to meet the 

law’s requirement to conserve these resources. This allows research on specimens stored away from 

forces of nature. These specimens can be, and are, exhibited to a wide range of people across the U.S.

The BLM policy for identifying paleontological sensitive geological formations is based on the Potential 

Fossil Yield Classification System (PFYC). Under the PFYC System, geologic units are classified based 

on the potential abundance of vertebrate fossils or uncommon invertebrate or plant fossils. It is not 

intended to be an assessment of whether important fossils are known to occur in these units, nor is it 

intended to be applied to specific sites or areas. In many situations, the classification should be an 

intermediate step in the analysis, and should be used to assess additional mitigation needs. Current BLM 

policy provides for a specific course of action depending on the paleontological resource potential ranked 

1 through 5 (see Appendix D). The PFYC classes are depicted on Map 3-1 and defined as follows:

Class 1: Is composed of geologic units unlikely to contain recognizable fossil remains. This includes 

units that are igneous or metamorphic in origin (but excludes tuffs), as well as units that are Precambrian 

in age or older. Management concern for paleontological resources in Class 1 units is negligible or not 

applicable. No assessment or mitigation is needed except in very rare circumstances. The occurrence of 

significant fossils in Class 1 units is non-existent or extremely rare.

Class 2: Is composed of sedimentary geologic units that are not likely to contain vertebrate fossils or 

scientifically significant invertebrate fossils. This includes units in which vertebrate or significant 

invertebrate fossils are unknown or very rare, units that are younger than 10,000 years before present, 

units that are aeolian in origin and units which exhibit significant physical changes in rock (i.e., 

compaction, cementation, mineral replacement). The potential for affecting vertebrate fossils or 

uncommon invertebrate or plant fossils is low. Management concern for paleontological resources is low, 

and management actions are not likely to be needed. Localities containing important resources may exist, 

but would be rare and would not influence the classification.

Class 3: Is composed of fossiliferous sedimentary geologic units where fossil content varies in 

significance, abundance, and predictable occurrence; or sedimentary units of unknown fossil potential. 

These units are often marine in origin with sporadic known occurrences of vertebrate fossils. Vertebrate 

fossils and uncommon invertebrate fossils are known to occur inconsistently, and predictability is known 

to be low. Surface-disturbing activities will require sufficient assessment to determine whether 

significant fossil resources occur in the area of a proposed action, and whether the action could affect the 

paleontological resources.

Figure 3-3. Permian Tidal Flat. Illustration by Mary Sundstrom.
3-3

Class 4: These are Class 5 geologic units (see below) that have lowered risks of human-caused adverse 

impacts or lowered risk of natural degradation. They include bedrock units with extensive soil or 

vegetative cover, bedrock exposures that are limited or not expected to be impacted, units with areas of 

exposed outcrop that are smaller than two contiguous acres, units in which outcrops form cliffs of 

sufficient height and slope so that impacts are minimized by topographic effects, and units where other 

characteristics are present that lower the vulnerability of both known and unidentified fossil localities.

Class 5: 

Highly fossiliferous geologic units that regularly and predictably produce vertebrate fossils or uncommon 

invertebrate or plant fossils, and that are at risk of human-caused adverse impacts or natural degradation. 

These include units in which vertebrate fossils or uncommon invertebrate or plant fossils are known and 

documented to occur consistently, predictably, or abundantly. Class 5 pertains to highly sensitive units 

that are well exposed with little or no soil or vegetative cover, units in which outcrop areas are extensive, 

and exposed bedrock areas that are larger than two contiguous acres.
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PHOTOS COURTESY OF:

JERRY MACDONALD

Figure 3-4 Leaf Fossils

Figure 3-5 Petrified Wood
3-5

Figure 3-6 Walchia Fossils

Illustration by Mary Sundstrom

Photo by Spencer Lucas, New Mexico Museum of Natural 

History and Science

3.2.1.1 Non-Marine Fossils

3.2.1.1.1 Plant Fossils

The Robledo Mountains contain several important Lower Permian plant localities.

“Plants from the Robledo Mountains are primarily representatives of groups that 

we believe to have grown in seasonally dry habitats - commonly including 

conifers and an extinct group known as peltasperms, as well as other less 

abundant forms. Most of the plants grew along the margins of stream channels or 

in swampy lowlands, which is what permitted their leaves and branches to be 

buried quickly and in environments where they were removed from the effects of 

decay.”

Bill DiMichele, PhD., Curator of Fossil Plants, Smithsonian Institution

3.2.1.1.2 Vertebrate Tracks

The most common ichnotaxon in the Robledo samples is the amphibian track type Anthichnium 

salamdroide. A large amphibian, ichnogenus Limnopus is represented and the diminutive amphibian 

ichnogenus Erpetopus is present. A few specimens suggest the presence of a larger amphibian track 

maker such as Parabarpus.

The most common small reptilian track type is Dromopus lacertoides, which occurs in large numbers on 

some layers at New Mexico Museum of Natural History (NMMNH) locality 846 (also termed the 

Discovery Site in the Jerry MacDonald Collection, see Figure 3-7).
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3.2.1.1.3 Invertebrate Trackways

The invertebrate ichnofauna is particularly diverse and evidently includes many more than the 17 

ichnotaxa described by Demathieu et al. (1992) from the Lower Permian of Southern France. Several 

described genera are present, whereas other morphologies probably represent new taxa. Minter and 

Braddy (2009) describe 18 types of invertebrate trace fossils from the Jerry MacDonald Collection.

3.2.1.2 Marine Fossils

Kues and Giles (2004) described and illustrated examples of the marine fauna represented in the Hueco 

Group in the Monument. More than 70 of the characteristic taxa are illustrated in the article and include 

brachiopods, bivalves and gastropods (see Figure 3-8) which are the most diverse elements of the fauna.

Additionally, remains 

of sponges, corals, 

bryozoans, 

scaphopods, 

nautiloids, 

ammonoids, 

echinoids, crinoids, 

trilobites and sharks 

were found by Kues 

in the marine 

sequences. Ostracods 

are the most common 

microfossils in the 

Hueco Group in the 

Robledo Mountains. 

Some replacement of 

original minerals in 

the fossil shells has 

occurred and can 

obscure the original 

structure in some of 

the marine fauna.

Figure 3-7. Dromopus. Photo by Sebastian Voigt.

Illustration by Matt Celeskey, New Mexico Museum of Natural History and Science

Figure 3-8. Marine Fossils. Photo by Scott Elrick.
3-7

3.2.2 Education and Interpretation

Currently, there are no formal on-site interpretive facilities such as exhibits, kiosks or signs within the 

PTNM. There are no signed trails to lead visitors to any location within the PTNM. There is an informal 

trail to the Discovery Site which is marked with a sign that offers little in the way of interpretation. An 

information kiosk was installed on BLM land adjacent to the Monument in the winter of 2011 that offers 

orientation and interpretation of the Trackways. Within the Monument, guided hikes, tours, and school 

programs have been held for the past few years by the BLM and other educational entities from Las 

Cruces, such as the Museum of Nature and Science. Self-guided activities are taking place as well, but it 

is unknown how informative such excursions are for visitors.

Off-site programs have been on-going at various venues since the initial discovery of the Trackways.

Originally, these programs were conducted by Jerry MacDonald. Since the designation of the Monument, 

the BLM and additional partners have carried on this practice. One of the local partners for interpretative 

and educational programs is the Las Cruces Museum of Nature and Science (MoNas). The Museum has 

been active in public education since the 1980’s, and recently moved to a new and larger facility where 

they have expanded areas for the display of fossil specimens.

In 2011, the BLM formalized this partnership by entering into an Assistance Agreement with the City of 

Las Cruces to assist in the development of trackway exhibits for the new Museum which was in the 

planning stages. Today, the Museum displays a 30-foot long continuous Trackway specimen containing

hundreds of tracks from several different animals from the Permian Era (Figure 3-9). This specimen is 

the centerpiece of the Museum whose theme is “Trackways to Space.” In addition, there are several other 

displays interpreting the resources of the Monument including interactive videos of Jerry MacDonald 

discussing various aspects of his discoveries at the PTNM.

The MoNas is the in-town 

visitor center for the PTNM, 

offering formal educational and 

interpretive programs at the 

Museum. To continue and 

expand this partnership and in 

the interest of providing a link 

to the Monument itself, the 

BLM entered into a second 

Assistance Agreement with the 

City. The purpose of this 

Agreement is to continue 

supporting the MoNas in

developing interpretative 

opportunities and providing 

information for informal (selfguided) and formal (Ranger or 

docent-led) touring 

opportunities. 

Another partner that has been instrumental in providing educational and interpretive services and products 

is the New Mexico Museum of Natural History and Science (NMMNHS) in Albuquerque. This museum 

is currently the main curatorial facility housing most of the PTNM Trackway slabs. In 2012, an 

interpretive booklet was published by the NMMNHS through an Assistance Agreement with the BLM. 

The booklet, Traces of a Permian Seacoast, has been very popular with the public and is provided by the 

Figure 3-9 The Trackways display at the Las Cruces Museum of Nature and Science.
3-8

BLM at no cost upon request. Through the same Agreement, the NMMNHS produced educational 

“travelling trunks” which have been located at several off-site venues since 2011. School kits are being 

developed in partnership with the BLM, NMMNHS and New Mexico State University. These items have 

enhanced the off-site programs that are supported by the BLM.

Another key partner for the PTNM is the Paleozoic Trackways Foundation of Las Cruces. This group has 

assisted in raising funds in support of educational programs concerning the PTNM including funding for 

school buses for field trips to the Monument for Ranger-led tours. They provide outreach and 

information at many local public venues. Also, the PTNM is a BLM Hands-on-the-Land site which is a 

National network of outdoor classrooms on public land. These classrooms provide field-based 

opportunities that address the Science, Technology, Engineering and Mathematics (STEM) programs and 

curriculum.

3.2.3 Recreation and Visitor Services

The Monument is near Las Cruces, New Mexico. It has been recognized for decades as an easily 

accessible area to enjoy a variety of outdoor activities. Visitors use the area to hike, mountain bike, drive 

on OHV trails, horseback ride and more. Since Jerry MacDonald began excavating in the late 1980s, his

“Discovery Site” has been a popular attraction for people to hike to and view fossil tracks. New Mexico 

State University has been taking geology classes out to the Robledo Mountains for decades to explore the 

unique geological features. There are currently no facilities within the Monument to support these uses. 

As the Monument becomes more widely known, it is reasonable to anticipate an increasing demand for 

on-site facilities.

Visitation numbers to the Monument and its immediate environs are estimated at 25,000. From August 

2011 to August 2012, TRAFx vehicle counters were placed at three strategic locations to estimate the 

number of visitors entering the Monument. One counter was placed at the cattle guard on Permian Tracks 

Road (see Map 2-1) and over 10,000 vehicles were counted. This cattle guard is outside the Monument at 

a juncture where cars may continue into the Monument or park outside the Monument and enter it by 

foot, bike, OHV, or horse. This spot is also a popular area for target shooting during the day, and parties 

during the night. It is certain that many of the vehicles that crossed over the vehicle counter on Permian 

Tracks Road were not destined for the Monument proper.

Placement of the two other counters allows the BLM to estimate that from 40 to 60 percent of vehicles 

that crossed the cattle guard entered the Monument on OHV routes. The standard conversion for 

recreational visits per vehicle is 2.5 meaning that perhaps 25,000 visitors crossed the vehicle counter and 

anywhere from 10,000 to 15,000 people came into the Monument. Various other unimproved routes 

access the Monument so there may be an even higher number of visits into the Monument that are 

unaccounted.

The Monument offers a variety of informal hiking trails, paths, and canyon bottoms that appeal to outdoor 

enthusiasts. Hikers, horse riders, recreational firearms users, OHV enthusiasts, amateur fossil and rock 

collectors, geologists, paleontologists, photographers, cyclists, and dirt bike riders are all attracted to the 

rustic, yet convenient foothills of the southern Robledo Mountains. Hikers and bicyclists usually follow 

the arroyos and ridgelines and often use the same trails as the OHV drivers.

Recreational target shooting and hunting is allowed in the Monument. Target shooting is popular 

adjacent to the Monument, in the vicinity of the cattle guard on Permian Tracks Road (see Map 2-1). 

Visitors, educational groups, and staff members have reported safety risks from target shooters. Hunting 

occurs during deer hunting season and year-round for non-game species such as jackrabbits, squirrels, and 

coyotes.
3-9

Campfire remains and large amounts of debris associated with partying around the Monument are 

frequently noted and cleaned up by BLM staff and concerned public.

3.2.4 Trails and Travel Management

In 1997, in order to reduce motorized vehicle incursions into the Robledo Mountains Wilderness Study 

Area (WSA) and to provide a convenient venue for OHV enthusiasts, the BLM prepared the Robledo 

Mountains Off-Highway Vehicle Implementation Plan (NM-036-97-083). This trail system is open yeararound and has been popularized by the annual Chile Challenge Extreme Off-Road Event. About 32 

miles of the Robledo Mountains OHV trails are within the boundaries of the Monument. The variety of 

extreme “rock crawling” trails coupled with a network of unmaintained two-track routes has made the 

Robledo Mountains a favorite destination for OHV use.

The Monument is characterized by rugged, challenging terrain that incorporates approximately 32 miles 

of OHV trails. All of the routes within the Monument require high clearance, four-wheel drive vehicles. 

Nearly half of these trails are rated as extreme or difficult, and require modified vehicles, knowledge, and 

skills. The rest of the trails are rated as easy or moderate but still require a certain degree of skill and 

four-wheel drive vehicles. Low clearance, two-wheel drive vehicles cannot safely negotiate these trails.

In 1998, the BLM completed an environmental assessment (NM-036-98-29) to identify and authorize 

mountain bike trails in Doña Ana County. Among the trails that were approved for development through 

this analysis was the 4-mile (round trip) route in the southern Robledo Mountains that is popularly known 

as the SST Trail. Since 1998, the SST has evolved to incorporate a portion of a designated OHV trail 

bringing the total round trip distance to 6.5 miles, of which 5.5 miles are within the Monument.

The PTNM is currently open for casual equestrian use and hiking, although no formal trails are 

designated for those uses.

3.2.5 Air Resources

3.2.5.1 Air Quality

The Clean Air Act, as amended, requires the Environmental Protection Agency (EPA) to establish 

National Ambient Air Quality Standards (NAAQS) for six “criteria” pollutants including Carbon 

Monoxide, Lead, Nitrogen Dioxide, Sulfur Dioxide, Ozone, and Particulate Matter (PM). Of these six, 

only one – PM – is substantially affected by natural resource management activities proposed in the 

Analysis Area. PM is a complex mixture of extremely small particles and liquid droplets. Particle 

pollution is made up of a number of components, including acids (such as nitrates and sulfates), organic 

chemicals, metals, and soil or dust particles. Vehicle exhaust emissions, such as NOx, CO, Volatile 

Organic Compounds and Hazardous Air Pollutants, may result from natural resource management 

activities proposed in the Analysis Area as well. NOx and VOC emissions may combine in the presence 

of sunlight to form ozone.

The size of particles is directly linked to their potential for causing health problems. EPA is concerned 

about particles that are 10 micrometers in diameter or smaller (PM10) because those are the particles that 

generally pass through the throat and nose and enter the lungs. A separate standard has been set for 

PM2.5, those particles with diameter of 2.5 micrometers or less, because they have been found to cause the 

most serious health impacts. Once inhaled, these particles can affect the heart and lungs and cause 

serious health effects. Units of measure for the PM are micrograms per cubic meter of air (μg/m3). 

(http://www.epa.gov/air/criteria.html)
3-10

Air quality monitoring stations measure concentrations of PM throughout the country; Doña Ana County 

currently has several. Two monitoring stations for PM10 can be considered representative of the Analysis 

Area. The West Mesa site is located approximately 6 miles south of the Planning Area and the Holman 

Road Site is approximately 12 miles to the east-northeast. In addition, PM2.5 is monitored in Las Cruces 

approximately7 miles to the southeast. A review of 2010-2012 data indicates that the PM2.5 levels have 

remained well within the standards set by the New Mexico Environment Department, as shown in Table 

3.1. There are no CO and NO2 monitors in the Las Cruces area.

Table 3-1 2010-2012 Design Values for Las Cruces, NM

TABLE 3-1

2010-2012 DESIGN VALUES FOR LAS CRUCES, NM

POLLUTANT DESIGN VALUE AVERAGING PERIOD NAAQS NMAAQS

PM2.5 5.7 μg/m3 Annual 12.0 μg/m3,1

PM2.5 12.0 μg/m324-hour 35 μg/m3,2

O3 0.065 ppm 8-hour 0.075 ppm3

Source: http://www.epa.gov/airtrends/values.html

Notes: 13-year average of the annual mean 

 2

3-year average of the 98th percentile

 3

3-year average of the 4th highest daily maximum 8-hour ozone concentration

A review of PM10 monitoring data for Dona Ana County (http://www.epa.gov/airtrends/values.html) 

shows that several monitoring sites in the county recorded exceedances of the 24-hour NAAQS. The 

New Mexico Environment Department recently published a study showing that 2008 exceedances of the 

PM10 standards were associated with regional dust storms and not human activities in Doña Ana County 

(NMED 2011). Southern Doña Ana County is also impacted by industrial sources in Mexico and Texas 

as well as in the Sunland Park and Anthony areas south of Las Cruces. A small area around the 

community of Anthony, approximately 30 miles southeast of the Planning Area, is designated as 

nonattainment for the PM10 standard. In addition, an area in the corridor from Anthony south to Sunland 

Park is currently considered a maintenance area for ozone.

According to the 2011 National Emissions Inventory, the emissions of criteria pollutants, Volatile 

Organic Compounds (VOCs) and Hazardous Air Pollutants (HAPs) in Doña Ana County are primarily 

from biogenic sources, fire, mobile sources and dust. Annual emissions of criteria pollutants and HAPs 

for 2011 in Doña Ana County are: 

 51,899.4 tons CO; 

 10,541.94 tons NO2; 

 66,038.36 tons PM10; 

 8,340.40 tons PM2.5, 

 209.4 tons So2 

 65,772.4 tons VOC

Data were taken from the following website: http://www.epa.gov/ttn/chief/net/2011inventory.html. The 

state of New Mexico is in the midst of a multi-year drought, which means soils in the State are 

particularly dry. This condition may lead to more wind-blown dust events where PM concentrations are 

elevated because dry soils are more susceptible to becoming airborne. It is not possible to predict when 

the current drought will end.
3-11

The EPA conducts a periodic National Air Toxics Assessment (NATA) that quantifies HAP emissions by 

county in the U.S. The purpose of the NATA is to identify areas where HAP emissions result in high 

health risks and further emissions reduction strategies are necessary. According to the 2005 NATA 

(http://www.epa.gov/ttn/atw/nata2005/05pdf/sum_results.pdf), Doña Ana County has a cancer risk of

25-50 in a million and 0-1 respiratory hazard index. These levels are considerably lower than 

metropolitan areas in the region.

The closest Class I area, as defined by the Clean Air Act, is the Gila Wilderness Area, which is 75 air 

miles distant from the Monument.

3.2.5.2 Climate

The PTNM has an arid continental climate with hot summers and mild winters. Summers are known for 

hot weather, with extended periods of over 100°F (38°C) and the latter half of the summer seeing

increased humidity and frequent afternoon thunderstorms. Autumn brings cooler temperatures, although 

still warm and with decreased precipitation. Winter conditions fluctuate between warm and sunny to cool 

and windy. Average winter temperatures range from minimums in the upper 20s to maximums in the 

mid- to upper 50s. Spring is known for its high winds in the afternoons and warmer weather. Average 

annual precipitation ranges from 8 to 14 inches. Precipitation mainly comes in the form of thunderstorms 

associated with the Southwest monsoon in the summer, with showers throughout the year as Pacific 

weather systems dip south. An average freeze-free period from 200 to 240 days occurs in most of the 

area. Light snowfall occurs most winters but is usually short-lived. Table 3-2 shows average monthly 

temperature and precipitation for 1981-2010 measured at New Mexico State University in Las Cruces.

Table 3-2 Average Temperature and Precipitation for Las Cruces 1981-2010

TABLE 3-2

AVERAGE TEMPERATURE AND PRECIPITATION FOR LAS CRUCES 1981-2010

LAS CRUCES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Average Temperature (oF) 43.8 48.1 54.1 61.4 70.2 78.6 81.4 79.4 73.8 63.0 51.5 43.5

Average Max Temperature (oF) 58.6 63.5 70.1 77.8 86.8 94.8 94.9 92.1 87.7 78.6 67.3 57.8

Average Min Temperature (oF) 29.1 32.7 38.2 44.9 53.7 62.4 68.0 66.8 59.9 47.4 35.7 29.1

Precipitation (inches) 0.51 0.41 0.22 0.29 0.40 0.66 1.53 2.22 1.33 0.94 0.46 0.77

Source: NOAA, 2011.

In addition to the air quality information cited above, new information about greenhouse gases (GHGs) 

and their effects on national and global climate conditions has emerged. Global mean surface 

temperatures increased nearly 1.0°C (1.8°F) from 1890 to 2006 (Goddard Institute for Space Studies, 

2007). However, observations and predictive models indicate that average temperature changes are likely 

to be greater in the Northern Hemisphere. Without additional meteorological monitoring and modeling 

systems, it is difficult to determine the spatial and temporal variability and change of climatic conditions; 

what is known is that increasing concentrations of GHGs are likely to accelerate the rate of climate 

change. 

Greenhouse gases that are included in the US Greenhouse Gas Inventory are: carbon dioxide (CO2), 

methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur 

hexafluoride (SF6), CO2 and methane (CH4) are typically emitted from combustion activities or are 

directly emitted into the atmosphere. On-going scientific research has identified the potential impacts of 
3-12

greenhouse gas emissions (including CO2; CH4; nitrous oxide (N2O), and several trace gasses) on global 

climate. Through complex interactions on regional and global scales, these greenhouse gas emissions 

cause a net warming effect of the atmosphere (which makes surface temperatures suitable for life on 

Earth), primarily by decreasing the amount of heat energy radiated by the Earth back into space. Although 

greenhouse gas levels have varied for millennia (along with corresponding variations in climatic 

conditions), recent industrialization and burning of fossil carbon sources have caused CO2 concentrations 

to increase dramatically, and are likely to contribute to overall climatic changes. Increasing CO2

concentrations may also lead to preferential fertilization and growth of specific plant species.

In 2007, the Intergovernmental Panel on Climate Change (IPCC) predicted that by the year 2100, global 

average surface temperatures would increase 1.4 to 5.8°C (2.5 to 10.4°F) above 1990 levels. The National 

Academy of Sciences (2006) supports these predictions, but has acknowledged that there are uncertainties 

regarding how climate change may affect different regions. Computer model predictions indicate that 

increases in temperature will not be equally distributed, but are likely to be accentuated at higher 

latitudes. Warming during the winter months is expected to be greater than during the summer, and 

increases in daily minimum temperatures are more likely than increases in daily maximum temperatures. 

It is not, however, possible at this time to predict with any certainty the causal connection of site specific 

emissions from sources to impacts on the global/regional climate relative to the proposed lease parcels 

and subsequent actions of oil and gas development.

Mean annual temperatures have risen across New Mexico and the southwestern U.S. since the early 20th 

century. When compared to baseline information, periods between 1991 and 2005 show temperature 

increases in over 95 percent of the geographical area of New Mexico. Warming is greatest in the 

northwestern, central, and southwestern parts of the State. Recurrent research has indicated that 

predicting the future effects of climate change and subsequent challenges of managing resources in the 

Southwest is not feasible at this time (IPCC, 2007; CCSP, 2008). However, it has been noted that forests 

at higher elevations in New Mexico, for example, have been exposed to warmer and drier conditions over 

a ten year period. Should the trend continue, the habitats and identified drought sensitive species in these 

forested areas and higher elevations may also be affected by climate change (Enquist and Gori, 2008).

A number of activities contribute to the phenomenon of climate change, including emissions of GHGs 

(especially carbon dioxide and methane) from fossil fuel development, large wildfires, activities using 

combustion engines, changes to the natural carbon cycle, and changes to radiative forces and reflectivity 

(albedo). It is important to note that GHGs will have a sustained climatic impact over different temporal 

scales due to their differences in global warming potential (described above) and lifespans in the 

atmosphere. 

Climate change is expected to result in increasingly frequent and intense extreme heat events, which will 

worsen drought and increase wildfire risks in New Mexico. As well, increasing and more intense heat 

events are projected to increase ozone concentrations by 1-10 ppb this century according to the draft 

Third National Climate Assessment and Development Advisory Committee report 

(http://ncadac.globalchange.gov/). Increased drought and areas where wildfire has resulted in a loss of 

vegetation will be further susceptible to wind events where soils easily become airborne and measured 

PM concentrations are elevated. 

3.2.6 Cultural Resources

The cultural resources of the Monument are not well known; less than one percent of the Monument has 

been inventoried. Four linear inventories have been conducted for a bike trail and for grazing 

improvements. Only one archaeological site was identified during these inventories. This site,

LA 53790, is described as a lithic scatter of less than 10 artifacts with an unknown time period.
3-13

Socio-cultural properties, also known as traditional cultural use areas, are those places of traditional 

cultural significance to American Indians and others. Such properties may exist within the boundaries of 

the PTNM, but no specific place or resource has yet to be identified during formal consultation.

Cultural resources include archaeological, historic, and socio-cultural properties. Archaeological 

resources generally refer to prehistoric sites while historic resources refer to those for which some form of 

written record exists. Socio-cultural properties refer to areas of concern to Americans Indians, and other 

cultural groups, that are significant to heritage or spiritual and cultural practices.

There are several distinct periods or traditions that are discernible in the archaeological records for the 

Analysis Area generally. The earliest occupation occurred from about 9,500 BC to approximately 6,000 

BC. This period is known as the Paleo-Indian period. The period is divided into three traditions: Clovis, 

Folsom, and Plano. Each tradition is associated with distinctive projectile points and lithic tool kits. 

Isolated project points from these traditions have been found within the larger region. Paleo-Indian 

people are thought to have been mobile hunters and gatherers who focused on migratory big game.

The second prehistoric period is referred to as the Archaic or Desert Archaic. The Archaic cultures are 

believed to have occupied the larger area from around 6,000 BC to about 100 AD. Archaic cultures are 

believed to have been non-sedentary, pre-pottery hunters and gatherers with a growing emphasis on 

territoriality and home bases and plant gathering leading to plant cultivation. The origins of agriculture in 

the Southwest United States begin during this period. The Archaic cultures are known for a suite of 

projectile points that define sites as well as other lithic tools and organic remains in the form of basketry, 

sandals, and other textiles that have survived owing to the dry conditions of this area.

The third period or tradition has been identified as the Mogollon. The Mogollon cultural region has been 

divided into the Western Mogollon and eastern or Jornada Branch of the Mogollon. This period is also 

known as the Formative Period. This tradition begins at approximately 200 AD and extends to 

approximately 1450 AD. Within this time period, several distinct changes begin to occur in the 

archaeological record:

1. Agriculture becomes the basic element of the economy although supplemented by hunting and 

gathering in varying degrees;

2. Pottery is introduced and soon divides into technological and distinctive artistic/stylistic 

traditions;

3. Pithouse hamlets aggregate into sedentary pithouse villages;

4. These communities in turn begin to construct above ground residences known as pueblos of either 

masonry or adobe; and

5. Interregional contact and trade are more evident, at least in the archaeological record, than 

heretofore.

The Mogollon Period ends at 1450 to 1500 AD. There appears to be a complete break in occupation 

although this may be more apparent than real. This period is succeeded by the Protohistoric Period or that 

period just before and phasing into the Historic Period. The Protohistoric occurs between 1540 and 1680 

AD for this area. Several named Protohistoric groups are recorded for the area and appear to have 

practiced a hunting and gathering economy. During this period, various peoples that would become the 

historic Apaches move into the Analysis Area from the west and northwest displacing or absorbing the 

peoples in their path. The Chiricahua Apache occupation of the area continued into the Historic Period 

until 1890. The Apache were mobile hunters and gatherers and, increasingly during the Historic Period, 

depended on raiding to supplement their economy.
3-14

Following its initial population by Native Americans, the Mesilla Valley was inhabited by the Spanish 

party of Friar Agustin Rodríguez in 1581. After the 1848 Treaty of Guadalupe Hidalgo, which signaled 

the end of the Mexican War, a colony of individuals not desiring American citizenship moved across the 

Rio Grande and established the town of Mesilla.

The Mesilla Valley has experienced the broad trends of the Historic Period but permanent settlement and 

development only occurred in the 1850s. Fierce Apache resistance to European encroachment inhibited 

any permanent settlement. However, all broad historic trends are represented in the historical record and 

include the establishment and use of El Camino Real de Tierra Adentro, the founding of towns and 

agriculture, military forts and the Apache wars, the Civil War, and mining and ranching, into the events of 

the 20th century. The primary historic use of the PTNM was grazing.

The Mesilla area was seen as an ideal location for a railroad route to the Pacific, which would connect the 

rest of the United States to California. The Gadsden Treaty was signed on December 30, 1853, resulting 

in the addition of Mesilla to Doña Ana County. The railroad was routed through Las Cruces instead, and 

that city eventually replaced Mesilla as the County seat. This has brought settlement and human 

influence and use to Doña Ana County, which includes the Robledo Mountains.

One historic feature within the Monument is Apache Dam. Apache Dam was constructed by the Civilian 

Conservation Corps from Camp BR-39, Las Cruces, New Mexico, in 1936 and was constructed to control 

arroyo flooding that threatened the Picacho Canal and farmland in the Mesilla Valley. Two other 

unnamed dams in support of Apache Dam were constructed as well.

3.2.7 Geology/Minerals

This section discusses the physiography, rock units, geologic structure and tectonic history of the region.

The Monument is situated within the North American Basin and Range Province and the dominant 

tectonic feature is the Rio Grande Rift. The Rio Grande Rift is a geographically extensive extensional 

basin associated with the most recent phase (spanning ~ 30 million years ago to present) of crustal 

thinning in the Southwest Basin and Range Province. The closely-spaced normal faulting and dominostyle block tilting along the north-south rift axis is caused by extension of the upper crust, which is being 

driven by the plastic flow of hotter rocks at depth (New Mexico Bureau of Geology and Mineral 

Resources 2003). The rift system is superimposed on a weakened crustal region of faults that were active 

during Pennsylvanian-age Tectonism (318 to 299 million years ago). Block-faulted, uplifted mountains 

including the Robledo Mountains are located on both sides of the Rio Grande Rift.

The Trackways Discovery Site and other tracksite locations in the Robledo Mountains are red-colored 

sandstones referred to as the Abo Formation of the Hueco Group (see Figure 3-10). In the Robledo 

Mountains, the Hueco Group consists primarily of limestone and fine-grained clastics (sandstones and 

shales) deposited in a shallow marine environment. Rocks of the Abo Formation contain both 

fossiliferous marine limestone and shale and red silty-sandstone deposited in a tidal flat environment. 

It is this sandstone which hosts the fossil trackways (Kues and Giles 2004). These strata along with an 

overlying upper member of the Hueco Group represent a regional transition zone between marine 

limestone of the Hueco Group to the south and non-marine red beds of the Abo Formation to the north 

(Lucas et al. 1994).
3-15

The Abo Formation and Hueco 

Group were deposited during the 

early Permian Period at the end of 

the Paleozoic Era, over 250 

million years ago. Younger rocks 

are also found in the Robledo 

Mountains. In the southern part 

of the Range, conglomerates, 

gypsiferous sandstones and 

mudstones occur in association 

with the Love Ranch Formation 

and the Palm Park Formation. 

These rocks were probably 

deposited during the Eocene 

Period between 55 and 51 million 

years ago. Volcanic rocks were 

emplaced in the northern part of 

the Robledo Mountains during at 

least two episodes around 35 

million years ago and 7 million 

years ago. The youngest rocks in the Monument consist of landslide deposits, valley-fill deposits and 

stream-channel gravels in boulders generally deposited less than 5 million years ago (Seager et al. 2008).

The historical record of earthquakes in the Rio Grande Rift system from 1962 through 1998 lists only four 

earthquakes of magnitude 3.0 or greater. Those earthquakes were located north and east of Las Cruces

(Sanford et al. 2002). Although New Mexico is in a seismically active area, the average earthquake 

intensity is a moderate 4.5 on the Richter scale. As such, a strong, damaging earthquake is not likely to 

occur in the Monument. In parts of the Monument, steep slopes and the presence of the friable, easily 

weathered Abo Formation may create local concerns with slope stability and landslide potential.

Sedimentary-hosted iron deposits were discovered in the southwestern Robledo Mountains (Iron Hill 

District) in the early 1930s (McLemore 1998; McLemore et al. 2005). Iron deposits consist 

predominately of iron-oxide minerals and occur in Hueco Formation Group limestone. Inferred ore 

reserves are estimated at approximately 15,000 short tons, but future development of these deposits is 

unlikely due to small tonnages, low grade and inaccessibility. Travertine was also mined sporadically 

from the southwest Robledo Mountains, and gypsum deposits have been found but have not been 

exploited (McLemore 1998).

Chemical analysis suggests that the Hueco Formation in Apache Canyon may have potential as a source 

of high-calcium limestone (McLemore 1998). Historically, the most important mineral resource in the 

Robledo Mountains has been building stone from the south central portions of the Range. A rock quarry 

outside the eastern boundary of the Monument, known as Community Pit #1, was the source for 

sandstone and siltstone used in retaining walls, decorative walls, and in general landscaping.

Community Pit #1 was in production for approximately 40 years (beginning in 1969) and, according to 

the quarry operators, most of the rock produced (probably less than 1 million tons) was used locally. Past 

mining practices at the quarry have left it with unsafe vertical high walls, which pose a safety concern. 

Significant fossil trackways have been found in siltstone and sandstone at and near the quarry. Although 

excavation at the quarry has led to additional findings, there are concerns in the academic community that 

continued mining could harm undiscovered specimens. The Community Pit #1 is now closed to public 

Figure 3-10 The “red beds” of the Abo Formation found in the Prehistoric 

Trackways National Monument.
3-16

access due to safety concerns. An environmental assessment analyzing reclamation of the Community Pit 

was completed in 2010.

Small volumes of landscape rock have also been mined in Apache Canyon, just south of the Monument. 

The BLM authorized extraction of building stone material at the quarry, known as Apache Canyon, prior 

to 2000. This quarry was active until the BLM did not renew the permit in February 2011. The 

proximity to the Monument and regular discovery of fossils at the quarry’s edge was the logic for its 

closure. The excavations and use of this area has exposed fossils and created parking areas that in the 

future may potentially be an interpretation and educational resource, even though this area is outside of 

the Monument boundary.

Other than for building stone, there has not been much interest in the minerals of the Robledo Mountains. 

There are no existing mining claims within the Monument boundary. The designating Legislation 

withdrew all Federal minerals within the Monument from mineral entry, which means that mineral 

exploration or removal is not allowed. In the southern portion of the Monument, there are 368 acres of 

non-Federal minerals to which the mineral withdrawal does not apply unless acquired by the Federal 

government and included into the Monument.

3.2.8 Lands and Realty

Public land within the National Monument is withdrawn from entry, appropriation, or disposal under the 

public land laws as directed by the Legislation. There are no rights-of-way (ROWs) within PTNM.

BLM establishes right-of-way exclusion and avoidance areas to guide decisions about where ROWs may 

be granted. In exclusion areas, no ROWs are allowed unless mandated by law; in avoidance areas, ROWs 

may be granted only when no feasible alternative route (or designated ROW corridor) is available (BLM 

1993). ROW exclusion areas within the Monument include the Robledo Mountains ACEC and Paleozoic 

Trackways RNA. ROW avoidance areas include Visual Resource Management Class II areas.

Acquisition of an easement across private land for access to public land leading into the Robledo 

Mountains (PTNM) is a specific management decision (Mimbres RMP, p.2-20).

3.2.9 Lands with Wilderness Characteristics

FLPMA requires the BLM to maintain a current inventory of land under its jurisdiction and identify 

within that inventory lands with wilderness characteristics outside of areas designated WSAs. Through 

the land use planning process, the BLM can make a decision to protect lands with wilderness 

characteristics or to allocate those lands for other uses.

Within the Monument, there are no areas outside of the Robledo Mountains WSA being managed for 

wilderness characteristics; however, the values of naturalness, opportunities for outstanding solitude, or 

opportunities for primitive and unconfined recreation, as defined by BLM Instruction Memorandum

2011-154, are present. The BLM conducted a wilderness inventory of the Monument in January 2011, 

which identified 576 acres that are contiguous to the Robledo Mountains WSA as having wilderness 

characteristics (Map 3-2). The rest of the Monument was determined not to be of sufficient size to meet 

the criteria for wilderness characteristics (4,311 acres).
3-17

3.2.10 Livestock Grazing

Ranching and livestock grazing have been predominant in the area since the 1880s, when railroads arrived 

in the territory. Grazing on public land has been authorized and numerous range improvements such as 

fencing and watering sources have been developed. Most of the land administered by the BLM in the 

Analysis Area is grazed by livestock. The Monument is permitted to two different livestock operators in 

two separate allotments. Portions of the Picacho Peak Allotment (03008) and the Altamira Ranch 

(03040) are within the National Monument (see Map 3-3). Both grazing allotments are administered 

under Section 3 of the Taylor Grazing Act, as they are within the boundaries of the established grazing 

district. Land status of the allotments is shown in Table 3-3.

Approximately 748 acres of public land in the National Monument are within the Altamira Ranch 

Allotment and 4,505 acres of public land in the Monument are within the Picacho Peak Allotment. Range 

improvements such as water developments and fences are associated with the allotments (Table 3-4).

The current grazing permit for the Picacho Peak Allotment allows 89 cattle to graze the allotment 

yearlong for a total of 822 active animal unit months (AUMs) at 77 percent public land use. An 

additional 152 AUMs have previously been put into suspended use as a result of changes to allotment 

boundaries from land exchanges and other land use changes on private land. The Altamira Ranch 

Allotment is permitted to run 54 cattle yearlong for a total of 635 active AUMs at 98 percent public land 

use.

Table 3-3 Land Status of Grazing Allotments within the PTNM

TABLE 3-3

LAND STATUS OF GRAZING ALLOTMENTS WITHIN THE PTNM

Land Status Picacho Peak (acres) Altamira (acres)

Federal Range 11,235 8,988

Deeded Private Land 55 74

State Trust Lands Leased by Permittee 1,047 -

State Trust Land Not Leased by Permittee 180 1,028

Private Land Not Leased by Permittee 1,492 375

Total Surface Acres 14,009 10,090

Federal range inside PTNM 4,505 748

At current carrying capacity, a total of 143 cattle are authorized to graze on the two allotments. A total of 

456 AUMs of forage are available for livestock grazing on an annual basis on public land within the 

Monument. Approximately 395 AUMs within the Monument boundary are associated with acreage on 

the Picacho Peak Allotment, and the remaining 61 AUMs are allotted to Altamira. However, actual use 

on the Monument is much less than what is authorized under the current grazing permits. Since the 

revision of the allotment management plan in 1997, the Picacho Peak Allotment has been conservatively 

stocked up to approximately 58 percent of the authorized carrying capacity on a voluntary basis.

Under the current rotation system, cattle typically graze the Monument from the beginning of April to the 

beginning of November annually. Quantification of livestock use on the Monument from the Altamira 

Ranch Allotment is difficult due to the lack of actual use data for the allotment; however, conversations 

with the grazing permittee have confirmed that cattle spend most of the year on the northern part of the 

allotment, and the southern part where the Monument is located is seldom used. The main reasons that 

cattle do not typically use this part of the allotment are the lack of water developments and reliable water 

sources and the rugged terrain.
3-18
3-19
3-20

Table 3-4 Range Improvements within the Prehistoric Trackways National Monument

The northern portion of the Picacho Peak Allotment contains a network of pipelines, a water storage tank, 

and troughs constructed in order to improve cattle distribution to attain proper forage utilization. The 

water source for these improvements is a well on private land outside of the Monument. Watering 

facilities have not been developed in the southern end of Altamira Ranch Allotment.

The Picacho Peak Allotment is divided into two main pastures, with the pasture division fence running in 

an east/west direction close to the southern Monument boundary. The majority of the Monument is 

located in the northern pasture of the Picacho Peak Allotment, with two small areas to the south separated 

by the main pasture fence. The allotments have some boundary fencing which lies close to the 

Monument; however, the majority of the allotment boundary between the Picacho Peak and Altamira 

Ranch Allotments is not fenced. In addition, the terrain in this location is typically too rough for cattle to 

move freely between the allotments.

Based on the most recent monitoring data and confirmed by subsequent allotment inspections, the 

majority of this northern pasture of the Picacho Peak Allotment is lightly utilized. The southern part of 

the Altamira Allotment is not routinely utilized by cattle due to the rough terrain and lack of water, and 

may only see slight use from occasional cattle that could drift into the area. Therefore, livestock use of 

the Monument is light; grazing intensity may occur at a more moderate level near watering points, but 

most places see slight to light use by livestock due to terrain. This is based on both historic utilization 

data and more recent observations during range health assessments and allotment inspections.

TABLE 3-4

RANGE IMPROVEMENTS WITHIN THE PREHISTORIC TRACKWAYS NATIONAL MONUMENT

ALLOTMENT PROJECT UNITS LOCATION AUTHORIZATION DATE CONDITION

PICACHO 

PEAK

Baker Reservoir 1 1 each T. 22 S., R. 1 W., 

Sec. 25

Range Improvement 

Permit 1943 Good

Robledo Interior 

Fence

3 miles T. 22 S., R. 1 E., 

Sec. 31

T. 22 S., R. 1 W., 

Secs. 35, 36

Cooperative 

Agreement

1987 Good

Burke Tanks 2 each T. 22 S., R. 1 W., 

Secs. 23 and 24

Range Improvement 

Permit

1972 Good

Robledo Pipeline 2.3 miles

1 storage

3 troughs

T. 22 S., R. 1 E., 

Secs. 19, 20, 29, 30

T 22 S, R 1,

Sec. 24

Range Improvement 

Permit

1984 Good

Robledo Pipeline 

Extension 2

0.25 mile

2 troughs

T. 22 S., R. 1 W., 

Secs. 23, 24

Range Improvement 

Permit

1991 Trough 

Maintenance 

Needed

Robledo Pipeline 

Extension 1

4.5 miles

5 Troughs

T. 22 S., R. 1 W., 

Secs. 24, 25, 26, 

35, 36

T. 22 S., R. 1 E., 

Secs. 30, 31

Cooperative 

Agreement

1989 Good

ALTAMIRA 

RANCH

NO PROJECTS
3-21

3.2.11 Science and Research Management

Research proposals are approved by the BLM Regional Paleontologist and are authorized on a case-bycase basis. Several research projects within the Monument have increased the scientific information 

about Permian Age animal and plant life. Approximately 140 paleontological sites have been 

documented within the Monument and over 3,000 acres of the Monument have been surveyed for 

paleontological resources as of Fall 2010. The BLM has partnerships with natural history museums and 

institutions to increase research and to educate the public about the scientific findings. Currently,

partnerships have been established with the New Mexico Museum of Natural History and Science

(NMMNHS), the Smithsonian Institution, the Carnegie Museum of Natural History, the Los Angeles 

County Museum, and the City of Las Cruces Museum of Nature and Science. The NMMNHS is the 

approved repository where the majority of the PTNM specimens are currently stored.

There are three types of paleontological resource use permits issued by the BLM: (1) the Survey and 

Limited Collection, (2) Excavation, or (3) Consulting. The BLM issues these permits under the authority 

of 16 USC 470aaa et seq. (Omnibus Public Land Management Act-Paleontological Resources 

Preservation Act [OPLMA-PRPA]). Prior to authorization, a research proposal must be submitted to the 

BLM Regional Paleontologist by a qualified paleontologist. The proposal must detail the project and 

describe any collection strategies. A Survey and Limited Collection permit (Reconnaissance and Survey 

permit) allows for limited surface collection with ground disturbance of up to 1 meter square. An 

Excavation permit is required for surface disturbances of over 1 meter square. An environmental 

evaluation under NEPA is required for all Excavation permits due to surface disturbance. A Consulting 

permit is normally issued to consulting paleontologists for projects that are proposed by outside 

proponent such as pipelines, gravel pits, or road construction. Consulting paleontologists perform preground disturbing surveys for fossil resources and can monitor ground moving activities as they are 

happening to ensure fossil resources are protected to the greatest extent possible. The BLM can also 

contract with consulting paleontologists as needed.

In order to receive a paleontological resource use permit, applicants must be able to demonstrate the 

following (BLM Handbook 8270- Paleontological Resource Management):

(a) Professional instruction in a field of paleontology relevant to the work proposed (vertebrate, 

invertebrate, trace, paleobotany, etc.), obtained through:

(1) Formal education resulting in a graduate degree from an accredited institution in 

paleontology, or in geology, biology, botany, zoology or anthropology if the major 

emphasis is in paleontology; OR

(2) Equivalent paleontological training and experience including at least 24 months under the 

guidance of a professional paleontologist who meets qualification (1), that provided 

increased responsibility leading to professional duties similar to those in qualification (1) 

above; and

(b) Demonstrated experience in collecting, analyzing, and reporting paleontological data

For excavation and limited collection permits, the permittee must also identify and verify that they have 

an approved repository willing to curate the paleontological resources that are collected.

3.2.12 Socio-Economic Conditions

Existing social and economic conditions are necessary to establish the baseline from which to estimate 

potential consequences of management actions. The proceeding section analyzes the current conditions 
3-22

and trends related to the social and economic environment of the Analysis Area, including population and 

demographic changes, potential environmental justice populations, and local economic conditions.

3.2.12.1 Population and Demographics

This section highlights population and demographic trends in the Analysis Area. Population is an 

important consideration in managing natural resources. In particular, population structure (size, 

composition, density, etc.) and population dynamics (how the structure changes over time) are essential to 

describing the consequences of land management and planning on a social environment (Seesholtz et al.

2004). Population increases may lead to conflicts over land use, travel management, recreation activities, 

and values. These are conflicts that BLM managers attempt to balance when making management 

decisions.

3.2.12.1.1 Population Growth

The Analysis Area is home to 209,233 people (U.S. Census Bureau 2010). Table 3-5 displays U.S. 

Census Bureau population data for the county, state, and nation in 1990, 2000, and 2010.

Since 1990, population growth in Doña Ana County has occurred at more than double the pace of 

National population growth. Rapid population growth may signal expanding economic opportunities or 

desirable amenities. Much of southern New Mexico is occupied Federal land. Department of the Interior 

(DOI) and National Forest System (NFS) lands provide natural amenities, which may attract new 

residents to the region.

Table 3-5 Populations 1990, 2000, 2010

TABLE 3-5

POPULATIONS 1990, 2000, 2010

LOCATIONS POPULATIONS PERCENTAGE (%) GROWTH

1990 2000 2010 1990-2000 2000-2010

Doña Ana County 135,510 174,682 209,233 29 20

New Mexico 1,515,069 1,819,046 2,059,179 20 13

United States 248,709,873 281,421,906 308,745,538 13 10

SOURCE: U.S. Census Bureau, 1990, 2000, and 2010

3.2.12.1.2 Population Density

Population density can serve as an indicator of a number of socioeconomic factors of interest –

urbanization, availability of open space, socioeconomic diversity, and civic infrastructure (Horne and 

Hayes 1999). More densely populated areas are generally urban and diverse, and offer better access to 

infrastructure. In contrast, less densely populated areas provide open space offering more natural amenity 

values to residents and visitors. Table 3-6 displays the number of people per square mile in the Analysis 

Area.

Despite substantial gains in population since 1990, both Doña Ana County and New Mexico continue to 

have low population density relative to the nation. However, Doña Ana County is several times more 

densely populated than the State – largely due to the presence of Las Cruces, the second-largest city in the
3-23

State, with a 2009 population of 93,680 people. Outside of Las Cruces, most of Doña Ana County is 

quite rural. Only 16 percent of Doña Ana County is private land. Department of Defense, Department of 

the Interior, Department of Agriculture, and New Mexico State lands account for over 80 percent of land 

ownership, which accounts for the low population density.

Table 3-6 Population Density

3.2.12.1.3 Median Age

Table 3-7 lists the median age in the Analysis Area. A high median age generally indicates that a 

relatively large number of retirees reside in the area. An area with a large percentage of retirees will earn 

income primarily from investments and transfer payments (e.g., dividends and Social Security), rather 

than salaries and wages. In contrast, a low median age suggests a large number of families with young 

children or a concentration of industries that employ large numbers of young workers.

The median age in Doña Ana County is below the State and National medians. The presence of New 

Mexico State University, with an enrollment of more than 20,000 students, contributes to the relatively 

low median age in the county (NMSU 2010).

Table 3-7 Median Age

TABLE 3-7

MEDIAN AGE

Area MEDIAN AGE

Doña Ana County 32.4

New Mexico 36.7

United States 37.2

SOURCE: U.S. Census Bureau, 2010.

Age data may be relevant for land management decisions. A population’s age may affect community 

values and uses associated with public land. For example, older populations may have a greater need for 

easily accessible recreation opportunities.

3.2.12.1.4 Educational Attainment

Educational attainment, the measure of people with at least a high school diploma or bachelor’s degree, is 

an indicator of an area’s social and economic opportunities and its ability to adapt to change. Table 3-8 

lists the percentage of the adult population with at least a high school diploma and a bachelor’s degree.

TABLE 3-6

POPULATION DENSITY

AREA PEOPLE/SQ. MILE

Doña Ana County 55

New Mexico 17

United States 87

SOURCE: U.S. Census Bureau 2010
3-24

Table 3-8 Educational Attainment, Percent of Persons Age 25+

TABLE 3-8

EDUCATIONAL ATTAINMENT, PERCENT OF PERSONS AGE 25+

HIGH SCHOOL 

GRADUATES (%)

BACHELOR’S DEGREE OR 

HIGHER (%)

Doña Ana County 74.4 25.0

New Mexico 82.1 25.1

United States 84.6 27.5

Source: U.S. Census Bureau, 2009.

Approximately three-quarters of adult residents in the Analysis Area are high school graduates. A quarter 

of study area residents have a bachelor’s degree or higher. Although Doña Ana County has a lower 

percentage of high school graduates than either the State or Nation, the County has a similar percentage of 

residents with a bachelor’s degree or higher. These findings suggest that the Analysis Area is split in 

terms of educational attainment – it has a relatively high proportion of individuals with low educational 

attainment as well as a relatively high proportion of individuals with high educational attainment (and 

relatively fewer individuals with moderate educational attainment). Opportunities exist for working-age 

adults with high levels of education. The three largest employers in Doña Ana County – Las Cruces 

Public Schools, New Mexico State University, and White Sands Missile Range – employ large numbers 

of highly skilled individuals (Peter J. Smith and Company 2009). The presence of highly educated adults 

may be self-reinforcing: a highly educated population is a signal that an area provides economic and 

cultural opportunities, which attracts additional college educated adults to the area. This process leads to 

further economic development and job creation. In contrast, areas with low levels of educational 

attainment have lower levels of human capital, which reduces an area’s ability to capitalize on economic 

change (Florida 2002).

The presence of New Mexico State University in Las Cruces may improve the County’s ability to retain 

and attract young residents. In areas without higher educational opportunities, young people who wish to 

continue their education migrate out of the area – a process known as the “brain drain.”

3.2.12.2 Environmental Justice

Executive Order 12898 mandates that all Federal agencies analyze the potential for their actions to affect 

minority and low-income populations disproportionately. The Council on Environmental Quality (CEQ) 

suggests the following criteria for identifying potential Environmental Justice populations (CEQ 1997):

 “Minority population: Minority populations should be identified where either: (a) the 

minority population of the affected area exceeds 50 percent or (b) the minority 

population percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of 

geographic analysis...”

 “Low-income population: Low-income populations in an affected area should be 

identified with the annual statistical poverty thresholds from the Bureau of the Census' 

Current Population Reports, Series P-60 on Income and Poverty. In identifying lowincome populations, agencies may consider as a community either a group of 

individuals living in geographic proximity to one another, or a set of individuals (such 

as migrant workers or Native Americans), where either type of group experiences 

common conditions of environmental exposure or effect.”
3-25

The emphasis of environmental justice is on health effects. The CEQ has interpreted health effects with a 

broad definition: “Such effects may include ecological, cultural, human health, economic or social 

impacts on minority communities, low-income communities or Indian Tribes when those impacts are 

interrelated to impacts on the natural or physical environment” (CEQ 1997).

Doña Ana County has a higher concentration of Hispanic and Latino residents than either the State or 

Nation. Approximately two-thirds of Doña Ana County residents self-identify as Hispanic or Latino. 

This finding highlights the need to analyze potential environmental justice issues in the Analysis Area. 

U.S. Census Bureau data (2010) on race and ethnicity is reported in Figure 3-11. Table 3-9 reports the 

percentage of residents living in poverty. Nearly one-quarter of Doña Ana County residents live in

poverty.

Table 3-9 Percent of Persons Living in Poverty

TABLE 3-9

PERCENT OF PERSONS LIVING IN POVERTY

AREA POVERTY RATE (%)

Doña Ana County 24.6

New Mexico 18.1

United States 13.5

Source: U.S. Census Bureau, 2009

The incidence of poverty in Doña Ana County is not evenly distributed among racial and ethnic groups. 

Approximately one-third of Hispanic residents in Doña Ana County live in poverty (U.S. Census Bureau 

2000). Based on the minority status and poverty data presented above, Doña Ana County appears at risk 

for environmental justice issues. The largest minority group in the County – Hispanic and Latino 

residents – also experiences a very high poverty rate.

3.2.12.3 Employment and Income

The previous section assessed demographic trends in the Analysis Area relative to State and National 

trends. This section will focus on economic conditions and trends. This discussion provides additional 

information on the social and economic environment in the Analysis Area.

3.2.12.3.1 Income and Earnings

Per capita income is a key indicator of the economic well-being of a county. High per capita income may 

be a signal of greater job opportunities, highly skilled residents, greater economic resiliency, and welldeveloped infrastructure. However, per capita income offers an incomplete picture of the economic wellbeing of an area. Average earnings per job provide insight into local labor market conditions. Whereas 

per capita income considers all sources of income (wage and salary payments, transfer payments, 

investment earnings, dividends, and rents), median earnings considers only wage and salary earnings. 

Table 3-10 provides data on per capita income and average earnings per job in 2000 and 2008 for the 

Analysis Area, State, and Nation.
3-26

Figure 3-11 Race and Ethnicity

0.0% 40.0% 80.0% 120.0% 160.0% 200.0%

Doña Ana County

New Mexico

United States

Doña Ana County New Mexico United States

White 74.1% 68.4% 72.4%

Black or African American 1.7% 2.1% 12.6%

American Indian and Alaska Native 1.5% 9.4% 0.9%

Asian 1.1% 1.4% 4.8%

Native Hawaiian and Other Pacific

Islander 0.1% 0.1% 0.2%

Some Other Race 18.5% 15.0% 6.2%

Two or More Races 3.0% 3.7% 2.9%

Hispanic or Latino (of any race) 65.7% 46.3% 16.3%

FIGURE 3-11 RACE AND ETHNICITY

SOURCE: U.S. Census Bureau 2010

NOTE: Totals sum to greater than 100 percent because Hispanic and Latino individuals may be of any race.
3-27

Table 3-10 Trends in Per Capita Income and Average Earning Per Job

TABLE 3-10

TRENDS IN PER CAPITA INCOME AND AVERAGE EARNINGS PER JOB

AREA

PER CAPITA INCOME AVERAGE EARNINGS PER JOB

2000 2008

PERCENT 

CHANGE

2000 2008

PERCENT 

CHANGE

2000-2008 2000-2008

Doña Ana 

County

$22,633 $27,848 +23 $29,614 $33,242 +13

New Mexico $28,446 $33,609 +18 $35,122 $38,680 +10

United States $37,907 $40,674 +7 $43,828 $45,807 +5

SOURCE: U.S. Department of Commerce, Bureau of Economic Analysis 2010 (http://www.bea.gov/regional/reis/action.cfm)

NOTE: Figures are inflation-adjusted to 2008 US Dollars using the Bureau of Labor Statistics CPI Inflation Calculator 

(http://www.bls.gov/data/inflation_calculator.htm)

Doña Ana County residents have lower per capita income and average earnings per job than other 

residents of the State and Nation. However, the County experienced more rapid income and earnings 

growth between 2000 and 2008 than either the State or Nation.

Several factors may be contributing to the relatively lower average earnings per job in the Analysis Area. 

Most job growth in Doña Ana County has occurred in retail and services employment since 1970 (U.S. 

Department of Commerce, Bureau of Economic Analysis 2002). Current figures indicate that health care, 

retail trade, and accommodation and food services are among the largest sectors (see Figure 3-12), and 

these jobs typically pay less than other service jobs, such as those in finance and insurance.

3.2.12.3.2 Non-Labor Income

Table 3-11 displays the role of labor and non-labor income in total personal income for 2000 and 2009. 

Non-labor income is any income derived from investments, dividends, rents, or transfer payments. In 

contrast, labor income is salary and wage disbursements from employment. During the past decade, the 

percentage of total income derived from non-labor sources increased in all considered areas.

Table 3-11 Contribution of Labor and Non-Labor Income to Total Personal Income

TABLE 3-11

CONTRIBUTION OF LABOR AND NON-LABOR INCOME TO TOTAL PERSONAL INCOME

AREA 2000 2009

LABOR NON-LABOR LABOR NON-LABOR 

Doña Ana County 64% 36% 61% 39%

New Mexico 66% 34% 62% 38%

United States 69% 31% 65% 35%

SOURCE: U.S. Bureau of Economic Analysis, 2011.

Non-labor income is not directly tied to employment; therefore, it can be more resistant to economic 

downturns. However, as the most recent recession demonstrated, asset markets can be quite volatile, and 

non-labor income that depends on investment returns may be unstable.

An increase in non-labor income may reflect changing demographic characteristics. Older populations 

rely largely on non-labor income, including rents, dividends, and transfer payments (e.g., Social Security). 

High percentages of non-labor income likely indicate higher concentrations of retirees.
3-28

Figure 3-12 Employment by Industry in the Study Area

Ag, Forestry, Fish 

& Hunting

5%

Mining

0%

Utilities

0%

Construction

6%

Manufacturing

3%

Wholesale Trade

2%

Retail Trade

10%

Transportation & 

Warehousing

3%

Information

1%

Finance & 

Insurance

2%

Real Estate & 

Rental

3%

Prof, Sci & Tech 

Services

7%

Management of 

Companies

0%

Admin & Waste 

Services

5%

Educational Services

1%

Health & Social 

Services

15%

Arts, Entertainment 

& Recreation

2%

Accommodation & 

Food Services

7%

Other Services

5%

Government

24%

FIGURE 3-12 EMPLOYMENT BY INDUSTRY IN THE STUDY AREA

Source: MIG 2009
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A slightly higher proportion of total personal income in Doña Ana County derives from non-labor sources 

compared to the State and Nation. This suggests that Doña Ana County has a somewhat higher 

concentration of retirees than the State and Nation.

3.2.12.3.3 Unemployment

The unemployment rate provides insight into the correspondence between residents’ skills and 

employment opportunities. The “natural” rate of unemployment is said to be around 5 percent. This is 

the so-called “natural” rate because this is a level that allows for movement between jobs and industries, 

but does not signal broad economic distress. Recently, the National unemployment rate has hovered 

between 9 percent and 10 percent. Figure 3-13 provides the annual unemployment rates for counties, the 

State, and the Nation from 2001 to 2010.

In recent years, the unemployment rates in both Doña Ana County and New Mexico have been 

consistently below the National unemployment rate. This suggests that labor market conditions in the 

Analysis Area are more stable than National labor market conditions.

Figure 3-13 Annual Unemployment Rate, 2001-2010

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Doña Ana County 6.1% 6.3% 6.5% 6.4% 5.7% 4.6% 3.8% 4.7% 6.8% 8.2%

New Mexico 4.9% 5.5% 5.9% 5.8% 5.2% 4.1% 3.4% 4.5% 7.0% 8.4%

United States 4.7% 5.8% 6.0% 5.5% 5.1% 4.6% 4.6% 5.8% 9.3% 9.6%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

FIGURE 3-13 ANNUAL UNEMPLOYMENT RATE, 2001-2010

SOURCE: U.S. BUREAU OF LABOR STATISTICS 2011B
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3.2.12.4 Housing

The above comparisons of per capita income and average earnings per job between the Analysis Area, the 

State, and the Nation are incomplete. Data on local cost of living offer additional context. Of the 

contributions to cost of living, housing costs are among the most substantial. Table 3-12 presents median 

home values in 2009.

Table 3-12 Median Value of Owner-Occupied Homes

TABLE 3-12

MEDIAN VALUE OF OWNER-OCCUPIED HOMES

AREA MEDIAN HOME VALUE

Doña Ana County $128,500

New Mexico $150,500

United States $185,400

SOURCE: U.S. Census Bureau 2009

Doña Ana County has lower per capita income and average earnings per job than the State and the Nation 

(Table 3-10); however, the home values in the County are correspondingly lower than the State and the 

Nation. This finding suggests that Analysis Area residents spend a comparable share of their income on 

housing.

3.2.12.5 Economic Diversity

Economic diversity generally promotes stability and greater employment opportunities. Highly 

specialized economies (i.e., those that depend on very few industries for the bulk of employment and 

income) are prone to cyclical fluctuations and offer more limited job opportunities. Determining the 

degree of specialization in an economy is important for decision makers, particularly when the dominant 

industry can be affected by changes in policy. For the BLM, this is likely to be the case where natural 

resource-related industries or the tourism and recreation industries, for instance, are reliant on public land.

Figure 3-12 provides a breakdown of employment by industry in the study area. The study area economy 

is somewhat diverse, with a wide range of employing sectors in the local economy. Nevertheless, 

government employment accounts for approximately one-quarter of Analysis Area employment. 

Government, retail trade, and the health and social services sectors are the largest employment sectors in 

the local economy. These industries are consistent with findings discussed in the demographic section –

namely a substantial government presence due to public education institutions and the White Sands 

Missile Range, a large retiree population that consumes health and social services, and amenities that 

attract tourists who contribute to the retail trade sector.

3.2.12.5.1 Payments to States and Counties

The BLM makes payments to states and counties that contain public land. Federal agencies do not pay 

property taxes; therefore, payments-in-lieu-of-taxes (PILT) are distributed to counties to compensate for 

the local services that support activities on Federal land. These services include law enforcement, road 

maintenance, and fire departments.

Table 3-13 lists the PILT from the PTNM and the payments attributable to all BLM-administered public 

land in New Mexico.
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Table 3-13 Payments in Lieu of Taxes, Fiscal Year 2011

TABLE 3-13

PAYMENTS IN LIEU OF TAXES, FISCAL YEAR 2011

PILT

Prehistoric Trackways National Monument $12,712

BLM New Mexico $21,596,643

Source: DOI 2011

3.2.12.6 Key Industries Related to BLM Management in the Analysis Area

3.2.12.6.1 Energy and Mineral Development

Mining provides 73 jobs in Doña Ana County – approximately 0.08 percent of total County employment 

(MIG 2009). Mining-related employment and income, therefore, play a minor role in the Analysis Area

economy. The Monument designation withdrew the PTNM from mineral entry, which means that 

minerals exploration and removal are not allowed. Therefore, energy and mineral development is not 

discussed further as it relates to the social and economic environment.

3.2.12.6.2 Agriculture and Grazing

Agriculture, forestry, fishing, and hunting sector jobs account for approximately 5 percent total 

employment in the Analysis Area. About 258 of the 4,128 jobs in the agriculture sector relate to cattle 

ranching.

In 2011, Doña Ana County was home to approximately 7.5 percent of all cattle and calves in

New Mexico – placing the County behind only Chaves, Curry, and Roosevelt Counties in terms of the 

total cattle and calf count (USDA NASS 2011).

The PTNM provides opportunities for grazing at the Picacho Peak Allotment and Altamira Ranch 

Allotment. The current stocking rate provides 272 AUMs to grazing permittees, although 456 AUMs are 

authorized. The Las Cruces District Office had 388,143 authorized AUMs in Fiscal Year 2011 (BLM 

2011). Grazing on the PTNM, therefore, accounts for less than one percent of total public land grazing in 

the District. Public land ranchers pay a $1.35 grazing fee per AUM. Given the small amount of grazing 

that occurs on the PTNM, total annual grazing fees amount to approximately $615.

3.2.12.6.3 Recreation

Recreation opportunities provided on BLM-administered land provide an attraction for visitors to the 

Planning Area. Visitation to PTNM and its immediate environs is estimated at 25,000 people (10,000 

party trips) annually, including use related to Special Recreation Permits (SRPs). Across BLMadministered land in New Mexico, visitation is estimated to be approximately 2.4 million people annually 

(BLM 2010). Recreational visitors to the Planning Area support employment and income in local 

economies. Recreation expenditures include outfitting, retail, food, and lodging services that support 

local economies. Visitor expenditure data specific to the PTNM are unavailable. 

Recreation-related employment may be seasonal, and can be irregular. Since employment is distributed 

across a number of economic sectors, the precise number of recreation-related jobs in Doña Ana County 

is unknown, however; jobs in recreation-related sectors - retail trade, arts, entertainment and recreation, 

and food services and accommodation - are growing.
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3.2.12.7 Non-Market Values

Public land has both market and non-market values. Market values include commodity uses of public 

land resources, such as timber or minerals. Market values are relatively easy to measure. The economic 

impact of marketed goods and services are captured in the economic input-output analysis. Non-market 

values, however, are more difficult to assess. Non-market values may arise from direct use of the 

resources (e.g., hunting for personal use and subsistence gathering) or from passive use (sometimes called 

non-use). Passive use captures the value of knowing that the resource(s) exist, whether or not future 

direct use is intended. Public land provides numerous values that are often of direct use to humans, even 

if they are not recognized. Clean water, climate regulation, and the research and educational 

opportunities that unique ecosystems afford are a few of the many ecosystem goods and services whose 

values are not addressed in traditional economic impact analysis.

3.2.13 Soils

The soil resources of the Monument are categorized according to soil associations or in the recent 

terminology of the Natural Resource Conservation Service (NRCS) surveys, general soil map units. Soils 

in the Monument are primarily the product of climate, geologic parent material, landscape, and time.

Soils in the Monument are semiarid, young, and poorly developed. Physical, chemical, and biological 

soil development processes, such as rock weathering, decomposition of plant materials, accumulation of 

organic matter, and nutrient cycling proceed slowly in this environment. Likewise, soil recovery 

processes from soil disturbances are slow and can lead to long-term changes in ecology and productivity. 

The most extensive soil degradation and erosion occurs in the very southern portion of the Monument 

where erosion of gypsiferous sandstones and mudstones on steeper slopes form a “badlands” type of 

topography. While localized anthropogenic caused erosion is present, the erosional features present are 

typical when these rock and soil types are exposed to weathering.

Five separate soil classifications exist within the Monument boundaries (see Map 3-4). The most 

dominant soil type is the Rock outcrop-Lozier association. These soils extend the entire length of the 

Monument from north to south and cover 4,180 acres (79 percent) primarily in the central and northern 

portions of the Monument. These soils are typically very shallow stony loam with high rock fragment 

content up to cobble size, overlying bedrock on steep slopes and tops of ridges. Soils on steeper slopes 

have a higher potential for water erosion. Where rock content and vegetation is locally decreased, some 

soil movement is apparent by occasional soil lines on rock fragments and pedestalled plant bases usually 

less than 2 inches in height. However, the large percentage of bedrock outcrops (approximately 45

percent) and high rock fragment content is adequate at slowing water flow velocities, hindering wind 

erosion, and stabilizing the shallow soils over most of the area. Drainage bottoms are generally composed 

of large cobbles, boulders, and bedrock with very little soil, soil accumulation, and soil production 

potential due to channelized high water flows.

The Rock outcrop-Torriorthents association is located in the southwestern portion of the Monument and 

covers approximately 860 acres (16 percent) within the Monument. These soils are shallow to moderately 

deep gravelly loam and gravelly sandy loam, found on hills and hill slopes with moderate to steep 

gradient and contain approximately 40 percent rock outcrop. Where rock content is locally decreased, 

these soils can be susceptible to moderate amounts of soil loss from water erosion and surface disturbance 

and to a lesser amount wind erosion. The Torriorthents soils in the Monument may occasionally have 

short discontinuous rills, soil lines on rock fragments, localized weak gravel lag, and a few short 

pedestaled plant bases. Where large percentages of bedrock outcrops and high rock fragment are present, 

the rock content in these soils is generally adequate at slowing water flow velocities, hindering wind 

erosion, and stabilizing the soils over most of the area.
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3-34

Nickel-Badland complex soils forming on alluvial fans and escarpments are present in the southeastern 

portion of the Monument and cover approximately 100 acres (2 percent). Typically, very gravelly sandy 

loam, interbeds of fine silt and clay may be present in the soil profile. High surface gravel content often 

forms a weak gravel lag, which hinders soil movement. Soil surface erosion rates are generally low for 

these soils, but may vary with changes in particle size, gravel abundance, and slope gradient. However, 

underlying stratigraphic beds of poorly cemented gypsiferous sandstones and mudstones tend to weather 

more easily, creating a “badlands” type of topography.

Comprising approximately 3 percent of the Monument is the Bluepoint-Caliza-Yturbide complex (60 

acres) and Tencee-Upton association (80 acres) soils formed on alluvial fans along the eastern flank of the 

Robledo Mountains. Slope gradients range from 5-15 percent in the loamy sand of the Bluepoint, 15-40 

percent in the Caliza gravelly sandy loam, and 1-8 percent for the gravelly loamy sand in the Yturbide 

soils. Slopes for the Tencee-Upton association range from 3-15 percent in gravelly sandy loam and a 

petrocalcic layer may be present between 7-20 inches in the subsurface. Wind and water erosion is 

approximated from moderate to high in the Bluepoint soils and low to moderate for the Tencee-Upton 

soils, respectively.

Areas in which the topography is primarily controlled by underlying rock and relatively resistant to 

erosion such as the Rock outcrop-Lozier and Rock outcrop-Torriorthents association soils, soil loss could

result from decreased vegetation and water infiltration as well as increased surface water runoff. 

However, with resistant bedrock shallow in the profile, dramatic changes in topography and channel 

form, as well as excessive erosion such as rills and gullies, would not be expected. For deeper soils, finer 

grained soils, and soils that have formed on poorly consolidated and poorly cemented sedimentary layers, 

such as the remaining four soil types in the Monument, the effects of soil loss is greater. Soils with these 

characteristics are more susceptible to erosion and impacts from surface disturbances and experience 

higher erosion rates, accelerated down-cutting, changes in topography, increased sedimentation 

downstream, and drainage degradation and alteration.

3.2.14 Special Designations

3.2.14.1 Area of Critical Environmental Concern

The Robledo Mountains ACEC consists of 8,695 acres, which includes much of the Robledo Mountains 

WSA and part of the Monument. The Robledo Mountains ACEC was evaluated for Relevance and 

Importance in the Mimbres RMP and meets the relevance criteria of having significant paleontological, 

cultural, and scenic values and endangered plant species. It meets the importance criteria of more than 

locally significant resources in terms of scenic quality, which is enjoyed by hundreds of thousands of 

travelers on I-25 annually, and for preservation of biodiversity, which is distinctive (Mimbres RMP, page 

5-43). The Robledo Mountains support a high diversity of cacti including Scheer’s pincushion cactus and 

night-blooming cereus. They also provide important habitat for uncommon reptiles such as the Madrean 

alligator lizard and Trans-Pecos rat snake. The Monument encompasses 789 acres of the ACEC (same 

area as the WSA in the Monument). See Map 3-5. Planned management actions in the Mimbres RMP

(BLM 1993) for the ACEC that apply to the land within the Monument are:

 Retain all public land

 Limit vehicle use to designated roads and trails

 Exclude authorization for new rights-of-way

 Close to mineral material sales and to fluid mineral leasing

 Acquire legal public access

 Maintain current livestock grazing practices
3-35

 Allow natural fires to burn under prescribed conditions

 Manage for primitive and semi-primitive recreation opportunities (no developed facilities)

 Manage as VRM Class I

 Manage for recreation opportunity spectrum (ROS) primitive and semi-primitive non-motorized 

and semi-primitive motorized classes

3.2.14.2 Research Natural Area

The Paleozoic Trackways Research Natural Area (RNA) designation was established in the Mimbres

RMP (BLM 1993). It establishes 720 acres on the southeast portion of the Robledo Mountains as the

RNA (see Map 3-6). It was designated in order to protect, research, and interpret paleontological values. 

Within the 720 acres, footprints and trackways of vertebrate and invertebrate animals from Permian Age

are preserved in the rock. The potential for this site to produce scientific information and specimens is 

considered high. Planned management actions are as follows:

 Retain all public land

 Limit vehicle use to designated routes

 Exclude new ROWs

 Withdraw from locatable mineral entry

 Close to mineral material sales

 Close to fluid mineral leasing

 Acquire legal public access

 Manage according to recommendations in the Trackways Study Legislation (Lucas et al. 1994)

 Manage as VRM Class II

 Manage for ROS semi-primitive, non-motorized class

3.2.14.3 Wilderness Study Area

Designated in 1980, the Robledo Mountains WSA consists of 13,033 acres. The southern tip of the WSA, 

approximately 789 acres, extends into the Monument (see Map 3-7). This area has been managed 

according to BLM Handbook 8550-01: Interim Management Policy and Guidelines for Lands under 

Wilderness Review so the suitability of such an area for preservation as wilderness would not be impaired 

until designated wilderness or released by Congress.

In the mid-90s, the BLM discovered that unauthorized OHV use was occurring which was degrading the 

values of the fossil resources. This use was curtailed and directed south, outside of the WSA. As a result, 

the scars created by the use are slowly healing.
3-36
3-37
3-38
3-39

3.2.15 Special Status Species

BLM special status species are: (1) species listed or proposed for listing under the Endangered Species 

Act (ESA), and (2) species requiring special management consideration to promote their conservation and 

reduce the likelihood and need for future listing under the ESA, which are designated as BLM sensitive 

by the BLM State Director. The Robledo Mountains contain habitat that is associated with several 

species of animals and one plant species that are considered special status. These species have been 

identified in accordance with procedures set forth in BLM Manual 6840: Special Status Species 

Management. All Federal candidate species, proposed species, and delisted species in the 5 years 

following delisting will be conserved as BLM sensitive species. The presence of special status plant 

species and their habitats in the Planning Area were considered using Las Cruces District species 

occurrence/habitat records and New Mexico Natural Heritage Program species records. Species 

descriptions and distributions were derived from Las Cruces District office records and New Mexico Rare 

Plant Technical Council [NMRPTC 1999: New Mexico Rare Plants. Albuquerque, NM: New Mexico 

Rare Plants Home Page. http://nmrareplants.unm.edu (Latest update: 11 July 2011)]. Table 3-14 lists the 

special status species that may potentially be associated with habitat located in the Robledo Mountains.

Although BLM does not have a record of specific occurrences and locations of any special status species

within PTNM, suitable habitat does occur throughout the Monument for each special status species.

Table 3-14 Special Status Species

TABLE 3-14

SPECIAL STATUS SPECIES

COMMON NAME SCIENTIFIC NAME STATUS*

Texas horned lizard Phryonsoma cornutum BLMS 

Burrowing owl Athene cunicularia hypugaea BLMS, FWSS 

Loggerhead shrike Lanius ludovicianus BLMS 

Cave myotis bat Myotis velifer BLMS 

Long-legged myotis bat Myotis volans interior BLMS 

Fringed myotis bat Myotis thysanodes thysanodes BLMS

Spotted bat Euderma maculatum BLMS 

Pale Townsend’s big-eared bat Corynorhinus townsendii pallescens BLMS, FWSS

Night-blooming cereus Peniocereus greggii var greggii BLMS, FWSS

NOTE: * CONSERVATION STATUS: FWSS=USFWS Species of Concern, BLMS=BLM SENSITIVE

Habitat descriptions for the special status species that have habitat in the Robledo Mountains are as 

follows:

Texas horned lizard (Phrynosoma cornutum). This species is ubiquitous over southern New Mexico, 

occurring in a variety of open desert grassland and shrubland habitats. They are common in a range of 

seral communities. There is insufficient population trends data on this species in the Robledo Mountains.

Burrowing owl (Athene cunicularia hypugaea). Burrowing owls are year-round residents of southern 

New Mexico. Preferred habitat includes open shrubland and grassland. These owls occur in a variety of 

seral communities ranging from disturbed areas to climax grassland and are tolerant of human activity. 

They occur in desert scrub dominated by mesquite, yucca and cactus. They use abandoned prairie dog, 

ground squirrel, fox, badger and similar burrows as well as ground holes in road cuts for nesting.

Population trends for the Robledo Mountains are not known.
3-40

Loggerhead shrike (Lanius ludovicianus). Loggerhead shrikes are a year-round resident of southern 

New Mexico in open shrub and grasslands. Riparian habitat is an essential environmental component. 

Nest habitat includes small trees and shrubs. Population trends for the Robledo Mountains are not 

known.

Cave myotis (Myotis velifer). Both subspecies occur in southern New Mexico. These bats are migratory 

over much of their range, but occur in southern New Mexico year-round. They occur in arid habitats, 

preferring desert floodplains and rocky canyon lands. Dense arroyo and riparian vegetation may be 

important foraging habitat. This species hibernate in caves and roost primarily in caves and mines 

forming large colonies. Population trends for the Robledo Mountains are not known.

Long-legged myotis (Myotis volans). The subspecies for New Mexico is M. v. interior. This species is 

most common in coniferous forest, but is known from high grassland and woodland habitats. They use 

mines and caves as hibernacula and night roosts. Cracks and crevices in rocks, buildings, tunnels, hollow 

trees and loose tree bark are utilized for day roosts. Summer nursery colonies form in tree hollows, rock 

crevices, and buildings. Population trends for the Robledo Mountains are not known.

Fringed myotis (Myotis thysanodes). The subspecies in New Mexico is M. t. thysanodes. This summer 

resident myotis occurs over most of the western two-thirds of New Mexico, most commonly in grasslands 

and oak-piñon woodlands. It is also known to occur from desert scrub to coniferous forest. They forage 

close to the vegetation canopy for moths and beetles primarily, but do take other insects. Maternity and 

day roost habitat includes rock crevices, caves, mines, snags and buildings. Population trends for the 

Robledo Mountains are not known.

Spotted bat (Euderma maculatum). Spotted bats are year-round residents, ranging widely in New 

Mexico, but are very rare in occurrence. They are found in a variety of habitats from low desert to conifer 

forest. Spotted bats forage in habitats such as forests, woodlands, riparian/riverine, as well as, old fields. 

The most important habitat component is rock and cliff features. They are strongly associated with 

broken canyon terrain and cliff habitat where day roosts are normally located, most in association with or 

near open water. Spotted bats are thought to be a non-colony forming species. Population trends for the 

Robledo Mountains are not known.

Big free-tailed bat (Nyctinomops macrotis). This uncommon yet wide-ranging bat occurs in arid, rocky 

habitats of New Mexico. They have been known to occur in desert shrub, woodlands and as high as 

evergreen forests near 2.5 km in elevation. They are believed to be seasonal migrants, though it is 

thought that some may hibernate in southern New Mexico. These bats roost and form maternity colonies 

in cracks and crevices of rock outcrops and cliff faces. There is insufficient data to determine population 

trends of this species in the Robledo Mountains.

Pale Townsend’s big-eared bat (Corynorhinus townsendii pallescens). The Pale or western Townsend’s 

big-eared bat occurs year-round in most areas of New Mexico. They inhabit a variety of vegetation 

habitats with proximity to rocky, broken expanses as a likely prerequisite. Caves and mines are crucial 

habitat components and may contain high concentrations of bats during hibernation and while rearing 

young. This species is highly intolerant of roost site disturbance, which can result in roost abandonment 

and substantial mortality. Population trends for the Robledo Mountains are not known.

There are no known special status species that are specific to the Robledo Mountains nor are the standard

habitat sites which occur in the Robledo Mountains habitat obligates for any special status species.

Night-blooming cereus (Peniocereus greggii var. greggii), which is considered a species of concern by 

the U.S. Fish and Wildlife Service, a sensitive species by the BLM, and endangered by the State of New 
3-41

Mexico, may also occur here, but it is widespread in southern New Mexico though not abundant at any 

location. Night-blooming cereus is usually associated with creosotebush and honey mesquite both that 

occur in and around the Robledo Mountains. Night-blooming cereus occurs mostly in sandy to silty 

gravelly soils in the Chihuahuan Desert, shrubland and desert grassland. Night-blooming cereus grows 

up through and is supported by shrubs like creosotebush and honey mesquite.

3.2.16 Vegetation

The National Vegetation Classification (NVC) was developed to standardize information about vegetation 

in the United States. This classification helps align vegetation data collection across different agencies 

and vegetation management programs, helping provide a greater understanding of vegetation 

communities.

The dominant vegetation type found within the Monument is Apacherian-Chihuahuan Semi-Desert 

Grassland and Steppe. Within this vegetation type, five ecological systems are present within the 

Monument. The dominant system in the PTNM is Chihuahuan Creosotebush, Mixed Desert and Thorn 

Scrub. The other main ecological systems are Chihuahuan Mixed Salt Desert Scrub, Chihuahuan Mixed 

Desert and Thorn Scrub, Apacherian-Chihuahuan Semi-Desert Grassland and Steppe, and ApacherianChihuahuan Mesquite Upland Scrubland (See Map 3-8).

The plant species found in the Monument are characteristic of these vegetation types, and plant 

communities found within the Chihuahuan Desert in general. Common grass species within the 

Monument include: black grama (Bouteloua eriopoda), blue grama (Bouteloua gracilis), sideoats grama 

(Bouteloua curtipendula), bush muhly (Muhlenbergia porteri), threeawn grasses (Aristida spp.), tobosa 

(Pluraphis mutica), Arizona cotton top (Digitaria californica), cane bluestem (Bothriochloa barbinodis), 

slim tridens (Tridens muticus), mesa dropseed (Sporobolus flexuosus), sand dropseed (Sporobolus 

cryptandrus), fluffgrass (Dasyochloa pulchella), plains bristlegrass (Setaria leucopila), six-weeks grama 

(Bouteloua barbata), and burrograss (Scleropogon brevifolius). Common shrubs and trees include agave 

(Agave spp.), sotol (Dasylirion spp.), ocotillo (Fouquieria splendens), feather peabush (Dalea formosa), 

broom snakeweed (Gutierrezia sarothrae), yucca (Yucca spp.), creosotebush (Larrea tridentata), longleaf 

ephedra (Ephedra trifurca), mariola (Parthenium incanum), Apacheplume (Fallugia paradoxa), range 

ratany (Krameria parvifolia), broom dalea (Psorothamnus scoparius), tarbush (Flourensia cernua) , 

littleleaf sumac (Rhus microphylla), white thorn (Acacia constricta.), prickly pear (Opuntia spp.), barrel 

cactus (Ferocactus wislizenii), hedgehog cactus (Echinocereus spp.), mesquite (Prosopis glandulosa), 

juniper (Juniperus monosperma), skunkbush (Rhus aromatica), and shrub live-oak (Quercus turbinella). 

Forbs found in the area commonly are wooly plantain (Plantago patagonica), globemallow (Sphaeralcea 

spp.), wild buckwheat (Eriogonum spp.),California bricklebush (Brickellia californica), tansey mustard 

(Descurainia pinnata), Russian thistle (Salsola kali), desert holly (Perezia nana), woolly paperflower 

(Psilostrophe tagetina), croton (Croton spp.), scorpion weed (Phacelia spp.), blanket flower (Gallardia 

pinnatafida), bladder pod (Lesquerella spp.), filaree (Erodium cicutarium), and spectacle pod 

(Dimorphocarpa wislizenii). Vegetation along the ephemeral drainages includes desert willow (Chilopsis 

linearis), littleleaf sumac, and cutleaf bricklebush (Brickellia laciniata). 

Determinations of rangeland health and condition, and vegetation management decisions utilize 

information found in ecological site descriptions that have been developed and are maintained by the 

Natural Resources Conservation Service (NRCS). The NRCS identifies large geographically associated 

land resource units called major land resource areas (MLRAs), which delineate areas with common 

topography, geology, climate, water resources, soils, biological resources including plant, fish, and 

wildlife species, and common land uses. The Planning Area is within the Southern Desert Basins, Plains 

and Mountains MLRA number 42, land resource unit SD-2. Elevations within MLRA-42 range from 

2,600 to 5,000 feet in basins and valleys, and more than 7,800 feet in the tallest mountains. Broad desert 
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basins and valleys are bordered by gently sloping to strongly sloping fans and terraces. Steep north-south 

trending mountain ranges and many small mesas occur in the MLRA. Average annual precipitation

ranges from 8-14 inches. Most precipitation occurs from mid-spring to mid-autumn. Average annual 

temperature is between 55-65° F. An average freeze-free period from 200 to 240 days occurs in most of 

the area.

MLRAs are divided into distinct ecological sites, which more specifically describe climate, soils, and 

expected vegetation on a more localized scale. More information on MLRAs and ecological site 

descriptions can be found at http://efotg.sc.egov.usda.gov/treemenuFS.aspx . Ecological site descriptions 

describe in detail the historic climax vegetation that is expected on a particular site, and contain state and 

transition models which discuss different plant community phases and the mechanisms by which plant 

communities can shift from one state to another through disturbances or restoration activities.

Generally speaking, vegetation communities within the Monument exist in a stable state. Minor shifts 

within the current state are generally attributable to precipitation patterns. Based on recent observations, 

ongoing drought conditions have limited plant vigor and productivity throughout much of the Monument 

during dry years; however, adequate monsoonal rains help plant communities rebound during wetter 

years. The majority of the Robledo Mountains consists of limestone hills, while the gravelly sites occur 

mainly on the southern and the eastern edge of the mountain range. Public land in the PTNM are 

primarily within the hills and limestone hills ecological sites with only a small portion of the area (south 

and east part of the PTNM) located in gravelly and gravelly sand ecological sites. See Map 3-9. 

Ephemeral drainages cross through portions of the Monument, and were classified as belonging to the

draw ecological site based on recent mapping of ecological sites; however these drainages do not 

resemble the typical draw ecological site. Theses drainages are predominately seasonal arroyos

dominated by upland vegetation, which occasionally run large amounts of water for brief durations during 

intense thunderstorms characteristic of the monsoon in the desert Southwest. The limestone hills 

ecological sites within the Monument are in a grassland/succulent state. The hills ecological sites within 

the Monument also generally occur in a grassland/succulent state with a fair amount of invasion by 

creosotebush evident. The gravelly and gravelly sand ecological sites within the Monument occur in a 

shrub-dominated state where creosotebush is dominant on the landscape with an understory present 

consisting of grama grasses, bush muhly, and fluff grass.

The changes made to grazing management on the Picacho Peak Allotment over time have resulted in 

improvement to rangeland condition from mid-poor to low-fair on limestone hills sites and from mid-fair 

to low-good on gravelly sites according to data obtained during the revision of the allotment management 

plan in 1997.

3.2.16.1 Noxious Weeds or Invasive Species

A noxious weed is defined as a plant species designated by federal or state law as generally possessing 

one or more of the following characteristics: aggressive, and difficult to manage; parasitic; a carrier or 

host of serious insects or diseases, or non-native, new, or not common in the United States (USDI 2007). 

Invasive plants include not only noxious weeds, but also other plants that are not native to the ecosystem 

into which they have been introduced, and exhibit characteristics that give them a competitive advantage 

over the desirable native species, often causing economic or environmental harm. As a result, they 

usually have no natural enemies to limit their reproduction and spread (Masters and Sheley 2001; 

Westbrooks 1998). The establishment and spread of invasive species can directly affect vegetation by 
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increasing the overall competition with native species for limited resources including water and nutrients. 

Over time, invasive species also can alter the structural and functional components of an ecosystem, i.e., 

soil structure/function, hydrologic function, fire return intervals, and energy flow (DiTomaso 2000) 

severely enough that reestablishment of native or desirable species is not feasible (Masters and Sheley 

2001). Common locations for noxious or invasive weed infestations include roadsides, recreation areas 

frequented by hikers, mountain bikers, ATVs/UTVs, and four-wheel drive vehicles, livestock 

concentration areas, recreational dumping spots and areas that are highly disturbed or degraded from 

miscellaneous land uses.

Noxious weeds in New Mexico have been classified based on their relative distribution within the State 

and the management strategies by which these weeds should be managed. New Mexico State University 

has published a guide book containing additional information on New Mexico’s noxious weed species of 

concern, their distribution, identification and strategies for management (Jamshid et. al. 2010). Classes of 

New Mexico’s listed noxious weeds are described below:

 Class A weeds - Weeds that are not native to an ecosystem and have a limited distribution within 

the State are placed in this class. Preventing new infestations and eliminating infestations have 

the highest priorities in the management plan. Species not presently found in the State but 

threatening to invade are placed in this class.

 Class B weeds - Weeds that are not native to the ecosystem and are presently limited to a 

particular area of the State are listed within this class. The management priority is to contain 

them within their current areas. Preventing infestations in new areas also has a high priority.

 Class C weeds - Weeds that are not native to the ecosystem yet are widespread throughout the 

State. Long-term programs of management and suppression are encouraged.

There are no known populations of Class A or Class B noxious weeds that have been identified within the 

Monument as a result of weed surveys. Class C weeds present within and nearby the Monument are 

individual plants and isolated populations of saltcedar (Tamarix rammosissima). Saltcedar is a deciduous 

or evergreen shrub or small tree that typically grows from 5 to 20 feet tall. “Saltcedar was introduced 

from Eurasia and is now widespread in the United States” Whitson (et al. 2006). The Tamarisk family, 

which includes saltcedar, has been used as ornamentals and has also been cultivated for use in erosion 

control and windbreaks (Vallentine 1989), but this plant has proliferated and has “become naturalized 

along streams, canals, and reservoirs in much of the west” (Whitson et al. 2006). Stands form 

monocultures, which limit native plant and wildlife biodiversity. Large plants of saltcedar can transpire at 

least 200 gallons of water per plant each day (Whitson et al. 2006). Saltcedar has been found to have low 

water use efficiencies and exhibit salt tolerance (Glenn et al. 1998), and actually tends to increase soil 

salinity through salts excreted from the leaves (Smith et al. 1998; Ladenburger et al. 2006), which would

give them a competitive advantage over less tolerant native plants. Saltcedar within the Monument is 

primarily located within Apache Canyon. This noxious weed tends to grow where water troughs may be 

leaking onto the ground, where manmade earthen reservoirs or flood control dams have been constructed,

or where moist soils may exist at some point in the year just long enough to support individual plants. No 

other riparian obligate plant species persist near this saltcedar, and no other habitat that is conducive to a 

riparian area exists at these sites. The areas where saltcedar may be found on the Monument are not 

considered riparian areas and would not be managed as such. Isolated individuals and smaller 

populations can also be found in smaller ephemeral side drainages on Federal, State trust and private 

lands adjacent to the Monument.

Common weed species occur within and around the PTNM. Some of the more common weeds 

encountered include Russian thistle, silverleaf nightshade (Solanum elaeagnifolium Cav.), various 
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pigweeds species (Amaranthus spp.), puncturevine (Tribulus terrestris L.), spotted and prostrate spurge 

(Chamaesyce maculate L.), and common cocklebur (Xanthium strumarium L.). These common weeds 

are typically found in disturbed areas and near livestock watering points. Cocklebur tends to occur 

mainly along drainages and in earthen reservoirs.

3.2.16.2 Rangeland Health and Standards for Livestock Grazing

The grazing regulations (43 CFR 4180.1) require that the authorized officer ensure that the following four 

conditions for rangeland health exist on the grazing allotments:

 Ecological processes are to be maintained, or there is to be significant progress toward attainment 

of these processes, that would support a healthy biotic community.

 Habitats are, or are to be making significant progress toward, being maintained or restored for 

Federal threatened and endangered, proposed threatened, Federal candidate, Federal species of 

concern or other species with special status.

 Water quality complies with the water quality standards of the State, and is to achieve, or to make 

significant progress toward achieving, any management objectives established by the BLM.

 Watersheds are to be in, or to be making significant progress toward achieving a properly 

functioning condition.

In January 2001, the BLM completed a Statewide Resource Management Plan Amendment and 

Environmental Impact Statement in which three Public Land Health Standards were adopted to address 

uplands, biotic communities, and riparian areas. The authorized officer would make a determination for 

each public land health standard as follows:

 Is the standard being met?

 If the standard is not being met, is livestock a causal factor?

 Does existing management conform to the Guidelines for Livestock Grazing Management?

Historic monitoring studies on the Picacho Peak Allotment were completed between 1983 and 1995. 

During that time period, gravelly ecological sites improved from fair to good condition, and the limestone 

hills ecological site improved from poor to fair condition as a result of changes in grazing management. 

The Picacho Peak Allotment is managed under an allotment management plan, which was updated and 

amended in 1997. Monitoring data collected in 1982 indicated that the Altamira Ranch Allotment was 

also in fair to good condition.

In 2010, Range Health Assessments were conducted on the public land within the Prehistoric Trackways 

National Monument by an interdisciplinary team of specialists with expertise in rangeland, soils, 

hydrology, and wildlife resources. Assessments were conducted at two sites within the limestone hills

ecological site, and one site was evaluated in the hills ecological site within the Monument. One gravelly 

ecological site was evaluated outside of the Monument boundary; however, this site was within a quarter 

of a mile from the Monument, and was considered to be representative of gravelly sites in the Planning 

Area.

Twenty-one public land health indicators were used to assess soil and site stability, hydrologic function, 

and biotic integrity in accordance with methodology described in Interpreting Indicators of Rangeland 

Health, Version 4, Technical Reference 1734-6 (Pellant et al., 2005). The indicators were evaluated 

according to departure from the reference conditions based on expected historical climax communities 

and on ecological site descriptions maintained by the Natural Resources Conservation Service. 

Rangeland health assessment worksheets are on file at the Las Cruces District Office.
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Determination/Rationale

1. Standard 1 (Upland Sites)

Upland ecological sites are in productive and sustainable condition within the capability of their

sites. Upland soils are stabilized and exhibit infiltration and permeability rates that are 

appropriate for the soil type, climate, and landform. The kind, amount, and/or pattern of 

vegetation provide protection on a given site to minimize erosion and assist in meeting state water 

quality standards.

Determination: It has been determined that Standard 1 (Upland Sites) is not currently being met, 

but current livestock management practices are not significant factors. Grazing management on 

the allotments within the Monument conforms to the Guidelines for Livestock Grazing 

Management.

Rationale: Standard 1 (Upland Sites) was analyzed using 10 indicators relating to soil stability. 

These indicators include rills, water flow patterns, pedestals and/or terracettes, bare ground, 

gullies, wind-scoured, blowouts, and/or deposition areas, litter movement, soil surface resistance 

to erosion, soil surface loss or degradation, and compaction layer.

Overall, soils matched the reference condition across all sites for several of the indicators, 

including water flow patterns, gullies, wind-scoured blowouts and/or deposition areas, litter 

movement, and compaction layer. The hills ecological site had the greatest degree of departure 

from reference condition, and as such, influenced the determination for not meeting the Upland 

Site standard. The hills site had a moderate degree of departure for rills, pedestals, and soil 

surface loss or degradation. The hills site had a slight to moderate departure from reference 

condition with regard to bare ground and soil surface resistance to erosion. While the 

preponderance of evidence indicates that, overall, the hills site is only slightly to moderately 

departed from the reference, the indicators show that soil erosion has occurred and soils could 

continue to be susceptible to losses in the future.

Generally speaking, the gravelly ecological site closely matched reference; however, the soil

surface loss or degradation indicator showed a moderate degree of departure from the reference 

condition expected for the site. Thus, it is likely that there has been some historic soil loss that 

has occurred on this site, but the remaining indicators suggest that soils are currently stable due to 

a high degree of rock cover that helps protect the soil.

The limestone hills ecological sites were in the best condition overall, with all soil stability 

indicators matching reference at one site. The other limestone hills site had a few pedestals 

present, mainly on individual tarbush shrubs and there was some soil loss evident.

In consideration of the data obtained from rangeland health assessments, there has been some soil 

erosion that has occurred on the Monument. While many areas are not experiencing active 

erosion, susceptibility to erosion varies throughout the Monument. One of the main contributing 

factors to not meeting the standard for upland sites is directly related to vegetation communities 

present on the Monument. Some areas have good vegetation cover and diversity or high amounts 

of rock that help protect the soil from erosion. Other areas, especially where shrub encroachment

by creosotebush is more pronounced, continue to be susceptible to accelerated soil erosion.
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2. Standard 2 (Biotic Communities)

Including Native, Threatened, Endangered, and Special Status Species

Ecological processes such as the hydrologic cycle, nutrient cycle, and energy flow support 

productive and diverse native biotic communities, including special status, threatened, and 

endangered species appropriate to the site.

Determination: It has been determined that Standard 2 (Biotic Communities) is not currently 

being met, but current livestock management practices are not significant factors. Grazing 

management on the allotments within the Monument conforms to the Guidelines for Livestock 

Grazing Management.

Rationale: Standard 2 was analyzed using 11 indicators relating to hydrology and 13 indicators 

that describe biotic integrity. These indicators include rills, water flow patterns, pedestals and/or 

terracettes, bare ground, gullies, soil surface resistance to erosion, soil surface loss or degradation, 

plant community composition and distribution relative to infiltration and runoff, compaction 

layer, functional structural groups, plant mortality and decadence, litter amount, annual 

production, invasive plants, reproductive capability of perennial plants, wildlife habitat, wildlife 

populations, special status species habitat, and special status species populations.

Hydrologic function indicators matched the reference across all sites for water flow patterns, 

gullies, and compaction layer. As with soils, the hills site had the greatest degree of departure 

from reference, and was rated as having a moderate change overall. Indicators rated as 

moderately departed from reference were rills, pedestals and/or terracettes, soil surface loss or 

degradation, plant community composition and distribution relative to infiltration, and the amount 

of litter present. There was a slight to moderate departure for bare ground and soil surface 

resistance to erosion. For the gravelly site, most of the indicators closely matched reference, 

except for litter amount, soil surface loss or degradation, and plant community composition and 

distribution relative to infiltration. The hydrologic function at one of the limestone hills sites very 

closely matched the reference condition, while the other site showed a slight departure from 

reference with regard to pedestals, soil surface loss, plant community composition and litter.

Biotic integrity indicators closely matched the reference across all sites for compaction layer, 

wildlife habitat, wildlife populations, special status species habitat, and special status species 

populations. Biotic integrity was rated as moderately departed from the reference on both the 

hills and gravelly sites. The indicators that were most influential in causing this shift were soil 

surface loss or degradation, functional structural groups, annual production and invasive plants. 

For the hills site, there was a also a moderate departure from reference conditions with regard to 

litter amount, but only a slight departure was observed for soil surface resistance to erosion. For 

the gravelly site, the indicators for litter and reproductive capability of perennial plants were 

slightly departed from the reference. Consistent with the other indicator groupings, biotic 

integrity within the limestone hills ecological site closely matched reference at one site, while the 

other site was rated as having a slight to moderate departure from the reference condition. The 

main factors contributing to the shifts on limestone hills sites were changes to functional 

structural groups and litter amount, and to a lesser degree soil surface loss, plant mortality and 

decadence, annual production, and invasive plants at one of the sites.

When considering these groupings of rangeland health indicators, the major factor contributing to 

not meeting the standard for biotic communities is directly related to the plant community present 

across much of the Monument. The main cause for any departure from the standards was the 

increase of creosotebush density, which was observed at high enough levels to consider this to be 
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an invader of hills and limestone hills ecological sites within the Monument. While creosotebush 

is native to the hot desert regions of the southwest, including the Chihuahuan desert, this shrub 

can increase to the point where it becomes out of balance with the desired plant community 

composition. Increasing densities of creosotebush often lead to increased competition with 

grasses and forbs for limiting water and nutrients. Currently, plant communities within the 

Monument are in a stable state, which would require active vegetation treatments in order to shift 

communities back toward a more productive grassland state. Some areas have the potential to 

respond favorably to treatment with the presence of a good perennial grass understory, but the 

area is characterized by rugged topography, which would preclude herbicide treatments in many 

areas due to concerns of herbicide drift on slopes steeper than 10 percent.

3. Standard 3 (Riparian Sites)

Riparian areas are in a productive, properly functioning, and sustainable condition, within the 

capability of that site.

There are no riparian sites within the PTNM, thus this standard is not applicable to the Planning 

Area. Several ephemeral drainages and canyons cut through the Monument; however they do not 

support riparian obligate vegetation thus they are not considered to be riparian areas.

3.2.17 Visual and Scenic Resources

The PTNM is a very expressive example of the Chihuahuan Desert with its variety of native plant and 

animal species along with the rugged terrain captured in the Robledo Mountains. A high diversity of cacti 

provide habitat for many reptiles within the Monument. During the spring and monsoon seasons, flowers 

abound on the desert plants and cacti. Thousands of residents and travelers on Interstate 25 and Interstate 

10 view the Robledo Mountains every day. The adjacent closed Community Pit #1 is a major visual 

impact and landscape modification. Areas showing major impacts to the line, form, color and texture are 

clearly evident even from several miles away. These impacts in Community Pit #1 include areas of 

vegetation removal, roads, rock piles and landings for stockpiling and loading the excavated rock.

Visual resources include natural and manmade physical features that give landscapes scenic quality and 

provide scenic views. Visual resources are interrelated with social and economic values, beliefs, and 

attitudes, lifestyle, quality of life, well-being, and place-based values, which all influence a viewer’s 

perception of the scenic quality and importance of scenic resources.

The BLM uses a systematic approach of visual resource inventory (VRI) to measure visual resource 

values. The results of this inventory provide the basis for considering visual values in the RMP process 

and assigning visual resource management objectives.

There are three components of a VRI Classification process:

1. Scenic Quality Evaluation – This is a measurement of the visual appeal of a landscape and is 

based on seven key factors: landform, vegetation, water, color, influence of adjacent scenery, 

scarcity, and cultural modification. The Scenic Quality Rating of the Robledo Mountains is 

“Class B”, which indicates a Medium rating based on observed characteristics such as highly 

eroded features with good color and mountain views, sparse vegetation, and cultural modification 

(the Community Pit quarry site).
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2. The Sensitivity Level Analysis – This is a measure of public concern for scenic quality. The 

Robledo Mountains overall rating of High is based on a combination of public sensitivity for the 

WSA, the ACEC, and the PTNM. The Monument is rated High for its level of public interest and 

amount of recreational use.

3. Delineation of Distance Zones - Viewsheds across public land are divided into three distance 

zones based on relative visibility from various travel routes or observation points, they are: (1) the 

foreground-middleground zone which occurs at 3-5 miles, (2) the background zone which occurs 

5 miles and beyond, and (3) the seldom seen zone which occurs in those areas not otherwise

visible from commonly travel routes or observation points. The entire PTNM was inventoried 

within the Foreground/Middleground Distance Zone.

As indicated in the Mimbres RMP (1993), the Monument is designated into all four VRM Classes (See 

Map 3-10). Table 3-15 displays the total acreage of public land within the Monument per VRM Class.

Table 3-15 Visual Resource Management Acreages within the PTNM

TABLE 3-15

VISUAL RESOURCE MANAGEMENT ACREAGES WITHIN THE PTNM

VRM CLASS ACRES

Class I 789

Class II 907

Class III 2,627

Class IV 932

TOTAL 5,255

SOURCE: Mimbres RMP, 1993.

With the VRI (defined above) serving as a baseline to quantify visual values, the BLM then considers 

other RMP decisions and resource allocations that may affect these values to arrive at appropriate visual 

resource management objectives. These objectives, or classes, are divided into four categories:

1. Class I Objective - to preserve the existing character of the landscape. This class provides for 

natural ecological changes but does not preclude very limited management activity.

2. Class II Objective - to retain the existing character of the landscape. The level of change to the 

characteristic landscape should be low. Management activities may be seen, but should not 

attract the attention of the casual observer.

3. Class III Objective - to partially retain the existing character of the landscape. The level of 

change to the characteristic landscape should be moderate. Management activities may attract 

attention but should not dominate the view of the casual observer. 

4. Class IV Objective - to provide for management activities, which require major modifications of 

the existing character of the landscape. The level of change to the characteristic landscape can be 

high.

Based on the components of VRI identified above and management considerations for other land uses, 

public land is placed into one of four VRI classes. These inventory classes represent the relative value of 

the visual resources. Classes I and II being the most valued, Class III representing a moderate value, and 

Class IV being of least value. Based upon the most recent VRI of the Planning Area that was undertaken 

in 2009, the entire PTNM Planning Area was rated as a VRI Class II.
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3.2.18 Water Resources

3.2.18.1 Groundwater

All water rights in New Mexico are acquired in accordance with the State’s substantive and procedural 

law, except where Congress or the Executive Branch has created a Federal reservation with a reserved 

water right.

The New Mexico Office of the State Engineer (NMOSE), as designated by statute and judicial decision, 

has divided the State into declared groundwater basins to assess and adjudicate water resources. The 

Monument and surrounding area lie within the Mesilla Basin, which is a sub-basin of the Lower Rio 

Grande Basin. According to NMOSE records, depths to the water table can vary widely throughout the 

Mesilla Basin. Variations can be from a few tens of feet along the Rio Grande to over 1,000 feet at 

various locations within the Valley. There are no records of wells or groundwater monitoring sites known 

to be present within the Monument boundaries.

The Santa Fe Group (Oligocene-Pleistocene) forms the major aquifer in this region and consists of a thick 

sequences of alluvial, fluvial, aeolian, and lacustrine sediments deposited in the intermountain basins of 

the Rio Grande Rift valley. Although the Santa Fe Group is present along the eastern boundary of the 

Monument, it comprises a very small percentage of the geologic formations located within the 

Monument. This equates to a very small percentage of the Monument containing prime aquifer 

characteristics. Some beds such as sandstones, conglomerates, or dissolved limestone beds within the 

Hueco Group, may contain water storage capabilities; however, these beds are relatively thin and can be 

laterally discontinuous. Additionally, tectonic uplift, volcanism, and intrusive events related to 

continental rifting have resulted in a structurally complex mountain range. Given the geologic history 

from deposition, deformation, and alteration of the Hueco Group in the Robledo Mountains, it is unlikely 

that any significant groundwater or potential aquifers exist in the Hueco Group within the Monument. 

Should small quantities of groundwater be present in selective beds of the Hueco Group, it would not be 

expected to have a significant nexus to groundwater in the Mesilla Basin aquifer. Given the history of the 

Robledo Mountains, the inferred lack of aquifer potential, and the absence of groundwater data within the 

Monument, there is a high degree of uncertainty regarding groundwater throughout the Monument.

3.2.18.2 Surface Water

There are no perennial surface waters located within the Monument. Surface water is limited to 

ephemeral and intermittent overland and in-channel flows during rainfall events. Water flows within 

arroyos primarily flow southeast and east and terminate at the Rio Grande (See Map 3-11). This water is 

both seasonally common and an essential component of the public land. Desert washes primarily function 

as areas of overland flow collection and recharge areas for the surrounding watershed. Ephemeral pools, 

either in-channel or in the uplands, are watering sites for wildlife and livestock. 
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Water quality analysis in New Mexico is designed to satisfy the statutory requirements of Section 303(d), 

the reporting requirements of Sections 305(b) and 314 of the Federal Water Pollution Control Act [33 

U.S.C. 1251 et seq.], commonly known as the Clean Water Act. The New Mexico Environment 

Department (NMED) Surface Water Quality Bureau’s 2010-2012 State of New Mexico Clean Water Act 

303(d)/305(b) Integrated List and Report found that the Rio Grande, from the International Mexico 

Boundary to 1 mile below Percha Dam, exceeds the allowable concentrations of Escherichia coli (E. 

coli). Additionally, the report lists probable sources for E. coli as avian sources (e.g., waterfowl), 

concentrated animal feeding operations, impervious surfaces/parking lot runoff, municipal point source 

discharges, on-site treatment systems (e.g., septic systems), rangeland grazing, wastes from pets, and 

wildlife. Even though the Rio Grande is located adjacent to and not within the Monument boundary, 

watersheds within the Monument drain into the Rio Grande. This provides the BLM with the 

responsibility to mitigate any action that may contribute contaminants into the Rio Grande and to protect 

the State’s water resources. Contaminants not only include E. coli that may further degrade water quality, 

but rather any contaminants that may lead to an additional impairment(s) of water quality.

Ongoing studies to identify E. coli concentrations and its sources are being conducted along the Rio 

Grande within the Lower Rio Grande Watershed. Key partners for these studies include the NMED 

Surface Water Quality Bureau, Elephant Butte Irrigation District, and Dr. Phil King and Dr. Geoff Smith 

with New Mexico State University. Results of E. coli studies revealed high levels in the Rio Grande 

during fall rainstorms and high levels in the lower portion of the watershed. Birds were the most 

abundant source identified followed by livestock, wildlife, pets and sewage, and E.coli concentrations 

were higher downstream of Picacho Bridge (Smith 2012). The Lower Rio Grande Watershed 

encompasses the Rio Grande Basin from Percha Dam (south of Caballo Reservoir, approximately 70 

miles north of Las Cruces, New Mexico), downstream to the Texas-Mexico boundary adjacent to the 

cities of El Paso, Texas and Ciudad Juarez, Mexico, (approximately 30 miles south of Las Cruces) and 

comprises approximately 1.5 million acres. This stretch is in the U.S. Geologic Survey (USGS) 

Hydrologic Unit Code (HUC 13030102) located in Sierra and Doña Ana counties. The Monument 

comprises approximately 0.3 percent of the Lower Rio Grande Watershed. While it is likely that nonpoint source pollutants such as E. coli are transported to the Rio Grande from the Monument during large 

storm events, it is inferred that the small size of the Monument watershed does not contribute a significant 

quantity of pollutants when compared to other sources located outside of the Monument.

The Planning Area receives approximately 9 inches of rainfall annually. Most of this occurs in July and 

August in the form of thunderstorms. Localized heavy rainfall often results in flash flooding in the 

arroyos carrying large quantities of sediment and debris.

3.2.19 Wildland Fire Management

The existing vegetation within the Monument is not conducive to carrying a fire. As stated earlier in the 

Vegetation section, the combination of the existing soils and climate lead to a desert grass-shrub 

vegetation community. The sparse understory does not lend itself to large wildland fires. Historically, 

there has not been any known wildland fire event within the Planning Area.

A natural fire regime is the pattern, frequency, and intensity of the wildfires that prevails across a 

landscape without the intervention of humans. A fire regime condition class (FRCC) is a classification of 

the amount of departure from the natural fire regime (see Table 3-16). Historical fire regimes provide a 

baseline against the current condition of an area and the effects of the change to the ecosystem. Fire is a 

natural part of a healthy ecosystem and the FRCC helps land managers plan the response to wildfires 

across the landscape (see Map 3-12). Fire Management Plans (FMPs) develop management responses to 

wildfire for all Fire Management Units (FMU). 
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Table 3-16 Fire Regime Condition Classes

These wildfire management strategies take into account: safety, cost, and resource objectives, in that 

order of prioritization. FMUs are created based on geographic, social, and political characteristics. The 

FMUs are assigned a fire management category(s) that dictate a management approach for each unit. 

Public land is assigned to one of the following fire management categories (See Map 3-13): 

 Category A: Areas where fire is not desired at all. 

 Category B: Areas where unplanned wildfire is not desired because of current conditions. 

 Category C: Areas where fire is desired, but there are significant constraints on its use. 

 Category D: Areas where wildland fire is desired, and there are few or no constraints on its use.

TABLE 3-16

FIRE REGIME CONDITION CLASSES

CONDITION CLASS ATTRIBUTES

EXAMPLE MANAGEMENT 

OPTIONS

Condition Class 1 Fire regimes are within or near a historical range. 

The risk of losing ecosystem components is low. 

Fire frequencies have departed from historical 

frequencies by no more than one return interval. 

Vegetation attributes (species composition and 

structure) are intact and functioning within a 

historical range.

Where appropriate, these areas can be 

maintained within the historical fire 

regime by treatments such as prescribed 

fire and allowing lightning fires to 

burn.

Condition Class 2 Fire regimes have been moderately altered from 

their historical range. 

The risk of losing key ecosystem components has 

increased to moderate. 

Fire frequencies have departed (either increased or 

decreased) from historical frequencies by more than 

one return interval. Results are moderate changes 

to one or more of the following: fire size, 

frequency, and intensity, severity, or landscape 

patterns. 

Vegetation attributes have been moderately altered 

from their historical range.

Where appropriate, these areas may 

need moderate levels of restoration 

treatments, such as prescribed fire and 

hand or mechanical treatments.

Condition Class 3 Fire regimes have been significantly altered from 

their historical range. 

The risk of losing ecosystem components is high.

Fire frequencies have departed from historical 

frequencies by multiple return intervals and results 

in dramatic changes to one or more of the 

following: fire size, frequency, intensity, or 

severity, and landscape patterns.

Vegetation attributes have been significantly altered 

from their historical range.

Where appropriate, these areas may 

need high levels of restoration 

treatments, such as hand or mechanical 

treatments. These treatments may be 

necessary before prescriptive fire 

treatments are used to restore the 

historical fire regime.

SOURCE: Bureau of Land Management, 2004a.
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3-58

Three FMUs are found within the Monument (see Table 3-17). The FMU categories are shown on Map 

3-13. These categories allow management to prioritize resources if there are multiple wildfires occurring 

at the same time.

Table 3-17 Fire Management Units within the PTNM

TABLE 3-17

FIRE MANAGEMENT UNITS WITHIN THE PTNM

FIRE MANAGEMENT UNIT ACRES

FIRE MANAGEMENT 

CATEGORY

Rio Grande Valley Uplands 4,469 C

Robledo Mountains WSA/ACEC 782 D

Rio Grande Corridor 4 B

Where necessary, emergency stabilization treatments would be implemented and completed within one 

calendar year from the date of the control of wildland fire. Rehabilitation of non-emergency actions due 

to wildland fires must be completed within 3 years of the date of the control of fire with funding for 

rehabilitation prioritized using common criteria (BLM 2005). Wildland and prescribed fires are 

monitored according to variables described in the Resource Management Plan Amendment for Fire and 

Fuels Management on Public Lands in New Mexico and Texas (BLM 2004a). Fuel treatment and fire 

suppression activities would be consistent with the New Mexico Standards and Guidelines for Livestock 

Grazing Management (2001).

3.2.20 Wildlife

In terms of habitat quality for wildlife, the PTNM has steep slopes dominated by rocky soils, with sparse 

vegetative cover dominated by creosote. Arroyos dissecting the hillsides have sandy bottoms and support 

a slightly more diverse overstory, such as Apache plume and little-leaf sumac. Compared to other 

habitats in the Chihuahuan Desert, the site has low productivity and diversity. The BLM has classified 

wildlife habitat referred to as Standard Habitat Sites (SHSs). SHSs are the primary indicators for wildlife 

and habitat to assess habitat quality. This also allows for identification of and monitoring of specific 

issues at the landscape level in the Planning Area. The BLM-based SHSs are used as indicators because 

they provide the best available data on current condition, trends, and forecasts of wildlife and habitat. 

The SHSs were designed at a large scale and do not break the habitats down by vegetative communities 

that may occur on different soil types. To gain an understanding of which habitat types occur in an SHS, 

the ecological site descriptions discussed in the Vegetation section of this document are utilized 

(limestone hills, hills, draws, gravelly, and gravelly sand). The Planning Area is comprised primarily of 

the Mixed Shrub Mountain SHS with a small area of Creosote Breaks SHS along the eastern edge (See 

Map 3-14).

3.2.20.1 Mixed Shrub Mountain

Shrub species dominate the vegetation composition of this SHS along with an understory of grama 

grasses (Bouteloua spp.), bush muhly (Muhlenbergia poteri), slim tridens (Tridens muticus), and threeawn (Aristida spp.). Characteristic shrubs are broom snakeweed (Gutierrezia sarothrae), whitethorn 

acacia (Acacia constricta), catclaw mimosa (Mimosa aculeaticarpa), Apacheplume (Fallugia paradoxa), 

skunkbush sumac (Rhus trilobata), and mountain mahogany (Cercocarpus montanus). This SHS is 

located between surrounding uplands and below the piñon-juniper vegetative community. Species 

diversity is high for mammals, moderate for herptiles, and low for birds (BLM 1983).
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3-60

Typical wildlife species of the mixed shrub mountain habitat type include tree lizards, Chihuahuan 

whiptails, Great Plains skinks, rock rattlesnakes, canyon wrens, white-throated swifts, rock squirrels, 

javelina, and mule deer.

On the Monument, the mixed shrub mountain SHS is primarily made up of the limestone hills and hills 

ecological sites with several drainages throughout (See Map 3-9). Over time, the vegetative composition 

of the Monument has become shrub dominated (See Section: 3.2.16-Vegetation). Overall, the wildlife 

habitat on the Monument more closely resembles the Creosote Breaks SHS and does not have great 

species diversity.

3.2.20.3 Creosote Breaks

Vegetation in this SHS is dominated by creosotebush (Larrea tridentata) found on steep slopes and gravel 

ridges. This SHS experiences a high degree of soil erosion. Ecological condition and species diversity 

has not been identified for this SHS. 

Typical wildlife species of creosote breaks include Couch’s spadefoots, western whiptails, side-blotched 

lizards, western diamondback rattlesnakes, cactus wrens, Merriam’s kangaroo rats, and black-tailed 

jackrabbits. Because of proximity to the Rio Grande, this is an important wildlife habitat.
ENVIRONMENTAL CONSEQUENCES

CHAPTER 

4

tHE 
4-1

CHAPTER 4 ENVIRONMENTAL CONSEQUENCES

4.1 INTRODUCTION

Chapter 4 analyzes the potential environmental impacts or effects of the proposed management actions 

explained in the four alternatives described in Chapter 2-Alternatives. The four alternatives describe

different ways to manage the Federal land and resources within the Monument to achieve the goals and 

objectives and to meet the purpose and need for overall management of the Monument. The baseline 

used for the analysis is the current environment is described in Chapter 3-Affected Environment. Impacts 

are defined as changes that may occur to the existing environment as a result of the actions described in 

the alternatives. The impacts can be beneficial or adverse and can be projected for short-term or longterm. Short-term impacts are defined as impacts that may range from 0-5 years and long-term impacts 

may be permanent and may remain for the life of this planning document and beyond. Direct and indirect 

effects will be discussed together in the following sections followed by a cumulative effects section.

Table 4-1 Definition of Impact Terms

TABLE 4-1

DEFINITION OF IMPACT TERMS

Direct effects “...which are caused by the action and occur at the same time and place” 

(40CFR 1508.8(a)).

Indirect effects “...which are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable. Indirect effects may include growth 

inducing effects and other effects related to induced changes in the pattern of land 

use, population density, or growth, and related effects on water and air and other 

natural systems, including ecosystems” (40 CFR 1508.8 (b)).

Cumulative “...the impact on the environment which results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency (Federal or non-Federal) or person undertakes such 

actions” (40CFR 1508.7).

Reasonable 

Foreseeable 

Development 

Consist of actions that can be projected, with a reasonable degree of confidence, 

within a range of time that will impact a resource.

The BLM’s decisions about resource use and allocation within the Monument will be formed by the 

impact analysis in this Chapter. A comparison of these impacts is shown at the end of Chapter 2.

4.2 ANALYTICAL METHODOLOGY

The BLM interdisciplinary team members used their professional judgment, existing and current data, and 

current models and methodology for the analysis. 

4.2.1 Analytical Assumptions

Several general assumptions were made to help guide the analysis by the resource specialists and also to 

inform the public. The assumptions listed below are Common to All Alternatives. Specific assumptions 

to individual resources or uses are detailed in the discussion of that resource.

 Management actions proposed in the alternatives apply to public land within the Monument. 

However, cumulative effects analyses consider potential actions by individuals, entities other than 

the BLM, the BLM, and actions in Doña Ana County or as further defined.
4-2

 Generally speaking, proposed actions that would increase visitor use, public access, and 

information regarding the Monument’s paleontological resources would result in an increase in 

the opportunity to locate, loot, and vandalize these resources. On the other hand, actions that 

would increase BLM presence at the Monument and inform and educate the public about the 

value of the Monument’s unique resources would serve to deter looting and vandalism.

 The alternatives would be implemented in accordance with all laws, regulations, and best 

management practices (BMPs). BMPs are located in Appendix E.

 Funding and staff will be available to implement any of the alternatives proposed in this Plan.

 Acreages were calculated using GIS technology; there may be slight variations in total acres 

between disciplines. These variations are negligible and will not affect analysis.

 All PTNM legislative directives are analyzed such as:

 Continue to manage that portion of the Robledo Mountains Wilderness Study Area 

(WSA) within the Monument pursuant to FLPMA Section 603(c) and the BLM

Management of Wilderness Study Areas Manual 6330 until such time that Congress 

designates it as a Wilderness Area or releases it from further consideration.

 Continue to manage that portion of the Robledo Mountains Area of Critical 

Environmental Concern (ACEC) within the Monument as an ACEC.

 Subject to valid existing rights, any Federal land within the Monument and any land or 

interest in land that is acquired by the United States for inclusion in the Monument are 

withdrawn from, entry, appropriation, or disposal under the public land laws, location, 

entry and patent under the mining laws and operation of the mineral leasing laws, 

geothermal leasing laws and minerals materials laws.

 The RMP decisions would remain in effect throughout the life of the Plan. A plan amendment 

“shall be initiated by the need to consider monitoring and evaluation findings, new data, new or 

revised policy, a change in circumstances or a proposed action that may result in a change in the 

scope of resources uses or a change in the terms, conditions, and decisions of the approved plan” 

(43 CFR 1610.5).

 Current visitation to the Monument is estimated to be 10,000 to 15,000 people. Methodology for 

this is described in Recreation and Visitor Services in section 4.4.3 below.

4.2.2 Incomplete Information

Where possible, site-specific data are used, but not all resources or uses have complete data to the extent 

needed for this plan. The best available data is used in developing this RMP. For resources with 

incomplete information, the impacts are estimated to the best of our knowledge. The data available was 

considered adequate to make reasoned choices among alternatives. 

4.2.3 Resources or Programs Where No or Negligible Impacts Would Occur

Resources and uses that are either not present or not likely to be impacted within the Analysis Area:

American Indian Uses and Traditional Cultural Practices, Riparian Areas, Woodlands, Floodplains and 

Wetlands, Geology, Minerals, Hazardous Wastes, Prime or Unique Farmlands, Wild and Scenic Rivers.
4-3

Actions that are often associated with ongoing management are not addressed in this Chapter and include 

but are not limited to: Identification of fossil locations, research management actions, and maintaining

and updating baseline data. These actions would be analyzed under the appropriate level of NEPA.

4.3 CHAPTER ORGANIZATION

Effects from different management alternatives that could be implemented under this RMP are considered 

on all resources/uses that are affected by that management action. Where applicable, the analysis 

addresses the Planning Issues that were brought forward from internal discussions and public scoping. 

These issues are: Paleontological Research, Recreation, Trails and Travel Management, Wildlife, 

Vegetation, Livestock Grazing, and Education and Interpretation. 

The following impact discussions are organized alphabetically after the first four resources/uses, which 

are Paleontological Resources, Education and Interpretation, Recreation and Visitor Services, and Trails 

and Travel Management. Impact discussions are arranged as follows:

RESOURCE OR RESOURCE USE

Assumptions and Incomplete Information: In this section criteria used to consider the impacts are 

described, as are limitations or incomplete information.

Management Decisions with No Impacts to Resource: Here we describe the resource decisions that 

do no impact the analyzed resource.

Effects Common to All Alternatives: These sections address impacts from actions to be carried out, for 

that resource, under all alternatives (the impact is common to Alternatives A, B, C, and D).

IMPACTS OF THE ALTERNATIVES

ALTERNATIVE A Alternative A is the No Action Alternative. Impacts of implementing current 

management decisions, including those in the Omnibus Public Lands Bill and the existing Mimbres RMP,

are analyzed here.

ALTERNATIVE B

ALTERNATIVE C

ALTERNATIVE D

Alternatives B, C, and D are the action alternatives and the impacts of implementing the actions under 

these alternatives are discussed here.

Chapter 4 concludes with a discussion of cumulative impacts. Cumulative impacts analyze the direct and 

indirect effects of the proposed action and alternatives together with the effects of the other actions that 

have a cumulative effect. The section considers other BLM actions, other Federal actions, and nonFederal (including private) actions (40 CFR 1508.7).
PALEONTOLOGICAL RESOURCES

4-4

4.4 RESOURCE OR RESOURCE USE

4.4.1 PALEONTOLOGICAL RESOURCES

Assumptions and Incomplete Information: Since 1997, the BLM has issued Special Recreation 

Permits (SRPs) for commercial off-highway vehicle (OHV) related events in the Robledo Mountains. On 

average, the OHV events have 150 to 300 participants that utilize approximately 150 miles of routes

within Doña Ana County. Beginning in 2008, the BLM established special stipulations to mitigate 

damage to exposed fossils and to monitor permitted events for comprehensive resource impacts.

Fossils have been collected from the Robledo Mountains for decades. This includes everything from 

trackway slabs for decorative construction to invertebrate fossils collected by school children on field 

trips. What effect this has had on the integrity of the paleontological resources or the information that 

may have been lost can never be known. Impacts on this resource can only be determined based on what 

is currently known and the proposed management actions for the future.

Paleontological Resources are identified as one of the resources, objects, and values for which the 

Monument was established and are defined as fossil resources that are predominantly Permian Age fossil 

material, but may be expanded to encompass subsequent discoveries. The scientific values are sciencebased research conducted on paleontological and geologic resources, especially Permian Age fossils and 

their geologic context.

Management Decisions with No Impacts to Paleontological Resources: Under all Alternatives, the 

following programs would have little or no impact to Paleontological Resources: Air Resources, Cultural 

Resources, Socio-Economic Conditions, Soils, Special Status Species, Vegetation, Visual Resources, 

Wildland Fire Management, and Wildlife.

Effects Common to All Alternatives:

Impacts from Paleontological Resources – Increased protection for fossil resources may lead to 

collectors searching for these specimens elsewhere. Stricter controls on science and research may 

discourage some paleontologists from studying the PTNM.

Research permits for collecting paleontological resources would continue to be evaluated and issued to 

qualified researchers. Continuing the research program could increase the amount of data and specimens 

available to researchers and our understanding of the geologic past, and this knowledge could change our 

way of thinking about the Permian Era. Specimens found by researchers may be exhibited and 

interpreted for the public allowing more people to see and understand these resources.

Impacts from Education and Interpretation – There would be opportunities to learn from the 

educational material on websites, educational talks, and at the local museum. Guided interpretive tours to 

the Discovery Site and other sites within the Monument would continue. This would allow for the public 

to experience and learn about the paleontological resources, which serves not only the objectives of 

education. It also serves to involve the community, which tends to increase support for the Monument.
PALEONTOLOGICAL RESOURCES

4-5

IMPACTS OF THE ALTERNATIVES

4.4.1.1 ALTERNATIVE A

Impacts from Paleontological Resources – Casual collecting of common invertebrates occurs 

throughout the Monument. Since this activity is not monitored through a permit system or confined

within a designated area, it is unknown to what extent these activities are impacting the paleontological 

resources, but paleontologists familiar with the Monument have expressed the opinion that casual 

collecting of common invertebrate fossils would not be detrimental to that paleontological resource. 

Casual and illegal collecting of scientifically significant ichnofossils or vertebrate fossils may be 

occurring as well, and this activity would impact research. Permitted scientific research and collecting

would continue, so additional specimens would leave the Monument to be curated and/or exhibited in a 

repository or museum. Additional scientific information would be collected as scientists research the 

resources within the PTNM.

Impacts from Education and Interpretation – The lack of interpretation on-site in Alternative A 

limits what visitors can learn and view on their own at the Monument without a guided tour or 

interpretive talk.

Impacts from Recreation and Visitor Services – Under Alternative A, both non-permitted OHV use 

and special recreation permitted OHV events would occur within the Monument. Petroleum-based fluids

(e.g., transmission fluid, power steering fluid, differential oil, etc.) sometimes leak during the course of a 

trail tour. Even though stipulations for OHV SRPs require mitigation to reduce the impacts from such 

fluid spills, there are no provisions to address similar fluid releases during non-permitted use. Petroleumbased fluid stains alter the appearance of trace fossils and plant carbon impressions contained in the red 

beds along the routes.

Impacts from Trails and Travel Management – Non-permitted and permitted use of motorized and 

mechanized vehicles would continue on 37.6 miles of trails and routes previously designated. Fossil

resources are exposed on portions of the Tabasco Twister (Apache Canyon) and Patzcuaro’s Revenge 

Trail (Branson Canyon) and documented in a 1994 monitoring report (Spencer L.; Hunt, A.; and Hotton 

II, N. 1994). These localities were confirmed again in an updated inventory during 2010.

The paleontological resources exposed on parts of the Tabasco Twister and Patzcuaro’s Revenge Trails 

would continue to be subjected to the impacts of motorized vehicle use. Monitoring of these impacts has 

taken place yearly since 2007. Field reports, observations by BLM specialists, and data points document 

a gradual degradation of significant fossils and fossil beds. Fossils have been destroyed, marred, and 

displaced by the heavy weights of vehicles; forces exerted by tires; undercarriages scraping along fossil 

beds when crawling from one level to another; and dislodging equipment with crowbars. Other results 

are crushing, fracturing, tire scuff marks, and petroleum product staining of the red beds. The Robledo 

Member (Abo Tongue) sandstones hosting fossil specimens are usually fine-bedded and friable. The 

impact from the weight of an OHV is often sufficient to fracture or exacerbate the natural exfoliation of 

these thin compositional layers. Degradation of the exposed surface destroys visible fossil specimens, 

and compromises the integrity of the entire formation segment.

In addition to the direct impacts of OHV use on the exposed fossil beds, the indirect impacts of vehicles 

by-passing difficult features such as outcrops leads to disturbance of areas not previously driven on and 

subsequent damage to vegetation and the loosening of soils. This increases erosion and also can cause 

large rock slides that have been known to displace fossil layers. These landslides remove the fossils from 

their original context and reduce their value to scientific research.
PALEONTOLOGICAL RESOURCES

4-6

Although the limestone block layers are generally more resistant to natural erosion, their natural bedding 

planes make them susceptible to fracturing along exposed seams from excessive pressure or weight. 

These are exactly the kind of forces imparted by OHV activity during climbing maneuvers. The results of 

these impact fractures are evident at the vertical obstacles located in the arroyos.

Impacts from Livestock Grazing – Under Alternative A, livestock grazing would continue. There is 

potential for livestock to trample paleontological resources, although unlikely, due to the location of the 

paleontological resources. A majority of the paleontological resources are located on the sides of steep 

hills or arroyos. Those resources on level ground would have the potential to be stepped on and possibly 

cracked or scuffed by livestock.

Impacts from Special Designations – Under Alternative A, 720 acres of the Monument were previously 

designated as the Paleozoic Trackways RNA. The RNA was designated for protection, research, and 

interpretation of paleontological values. The impact from continuing the designation of the Paleozoic 

Trackways RNA is a duplication of most management prescriptions from the Monument Legislation. 

Management prescriptions such as retain all public land, limit vehicle use to designated roads and trails, 

and withdrawal from mineral entry are also stated in the designating Legislation. These duplicated 

management prescriptions protect fossil resources by limiting actions that would have physical impacts on 

them.

The PTNM boundary also overlaps 789 acres of the Robledo Mountains ACEC. The ACEC is 9,190 

acres and extends from its southern boundary within the PTNM north into the Robledo Mountains. The 

ACEC meets the relevance criteria of having significant paleontological values. Management 

prescriptions to protect and conserve fossils are similar to those in the RNA. The ACEC designation 

reinforces the need to protect and maintain the paleontological resources.

4.4.1.2 ALTERNATIVE B

Impacts from Paleontological Resources – Under Alternative B, casual collecting of common

invertebrate and plant paleontological resources would not be allowed. Only BLM permitted collecting in 

association with scientific research would be allowed. This reduces the likelihood of scientifically 

significant fossils being removed illegally from the Monument and scientific information from those 

fossils being lost to the public and to science.

Impacts from Education and Interpretation – Under Alternative B, education and interpretation of 

paleontological resources would occur mostly offsite except for some self-guided interpretive activities 

and on-site interpretive programs. The fossils resources would remain in-situ for ongoing and future 

scientific research and would not be available for on-site public education and interpretation.

Impacts from Recreation and Visitor Services – Under Alternative B, SRPs would not be authorized 

within the Monument. This would eliminate any organized group activities other than those sponsored by 

the BLM. This would eliminate the impacts on the fossils from SRPs as described in Alternative A.

Impacts from Trails and Travel Management – Under Alternative B, the Monument would be closed 

to all motorized and mechanized use except administrative and emergency motorized use. Closing the 

PTNM to motorized and mechanized recreational activity would eliminate damage to fossils, as described 

in Alternative A, and would conserve the paleontological resources in-situ. This would contribute to the 

stabilization of both the fossils and their associated geological contexts. Closure of the PTNM to 

motorized and mechanized recreational use would remove access to PTNM resources by these 

recreational user groups, reduce public access, and would reduce, but not eliminate the possibility for 

unauthorized collecting of paleontological resources. Closure of trails to vehicle use would eliminate a 
PALEONTOLOGICAL RESOURCES

4-7

convenient, but not unique, source of recreational opportunities for the OHV and mountain bike user 

groups. Similar recreational venues may be found in the local Doña Ana Mountains, the Caballo 

Mountains, and the Las Uvas Mountains. Currently, there are no designated trail systems for either OHV 

or mountain bikes in these other ranges, but it is conceivable that challenging rock crawling opportunities 

for both motorized and mechanized vehicles could be authorized in these adjacent areas.

Trail use on foot or horseback would still allow the public to access paleontological resources.

Impacts from Livestock Grazing – Under Alternative B, livestock grazing would not be allowed;

therefore, the risk of paleontological resources being damaged by livestock would be eliminated.

Impacts from Special Designations- Research Natural Area – The designation of the Paleozoic 

Trackways RNA would be removed, and the land would be managed under the prescriptions from the 

PTNM RMP. Conservation of the fossil resources would be achieved and a redundant management 

designation would be eliminated.

4.4.1.3 ALTERNATIVE C

Impacts from Paleontological Resources – Under Alternative C, fossil localities would be assessed to 

determine the best management of those sites. Such assessments would consider the importance, value,

and quality of documented localities and would be used to determine the most suitable use for these 

localities. Some localities would be developed for interpretation and education while others would be 

preserved for research.

Impacts from Education and Interpretation – Under Alternative C, in addition to the off-site 

programs mentioned under Alternative A, pedestrian trails with kiosks and wayside exhibits and a visitor 

contact station would be developed, which would provide an education focusing on the paleontological 

resources in an outdoor setting. These developments would increase the public’s understanding and 

appreciation of these resources. Interpretation provides the public with information that could raise their 

awareness of the sensitivity and importance of the resource, thereby increasing stewardship and 

appreciation. While this enhanced appreciation should deter theft and vandalism of the resources, 

increased visitor use could also increase the opportunity and occurrence of such activities. However, 

directing the public to appropriate locations for interpretation which are not as scientifically sensitive may 

keep them from seeking out scientifically-sensitive locations because their curiosity is fulfilled by the 

experience of being in the actual location of the resource and having the extra benefit of interpretation.

Impacts from Recreation and Visitor Services – Under Alternative C, on-site visitor facilities such as a 

visitor contact station, toilets, shade shelters, information kiosks, trail markers, and picnic sites would be 

developed. This would probably attract more visitors to the Monument. With increased visitation, more 

people would be able to experience the resources in a natural setting within the Monument. Increased 

visitation would increase the risk of theft and vandalism of the paleontological specimens by exposing 

fossil-bearing locations to the visiting public. The impacts from allowing SRPs would be the same as 

mentioned under Alternative A.

Impacts from Trails and Travel Management – Under Alternative C, within the Monument 

boundaries, 100 percent of the Tabasco Twister Trail (2.7 miles), and 100 percent (1.8 miles) of

Patzcuaro’s Revenge Trail would be closed to motorized and mechanized vehicle use (see Map 2-3). In 

addition, 100 percent (0.4 miles) of the Cayenne Crawler Trail would be closed to motorized and 

mechanized use to eliminate access from the south to Patzcuaro’s Revenge Trail. Fossils located within 

these arroyos would be protected from these types of impacts as described in Alternative A.
PALEONTOLOGICAL RESOURCES

4-8

For activities which do not require an SRP, a non-fee day-pass system would be established for motorized 

and mechanized use of designated routes. These passes would include educational information about the

paleontological resources and maps of routes that are open or closed to motorized and mechanized travel.

Routes would be maintained or improved as long as sensitive resources are not impacted. Route

improvement and maintenance would allow greater numbers of visitors to enjoy the interior portions of 

the Monument. This enhanced access would, presumably, lead to a commensurate heightened sense of 

public ownership and responsibility for the resources. Conversely, the easier access could lead to 

increases in inappropriate behavior such as littering, vandalism, and theft of fossil resources.

Impacts from Livestock Grazing – Under Alternative C, livestock grazing would continue within the 

Monument. If, through the Monument Monitoring Plan, it is determined that livestock are impacting the 

fossil resources, those areas would be fenced off from livestock to remove the direct impact. Grazing in 

areas not enclosed by a fence would have the same impacts on the resources as Alternative A.

Impacts from Special Designations – Impacts are the same as described under Alternative B.

4.4.1.4 ALTERNATIVE D

Impacts from Paleontological Resources – Impacts would be the same as described in Alternative C, 

except that limiting collection of common invertebrate fossils to BLM authorized programs would allow

opportunities for discovery of fossils in an educational and recreational setting.

Impacts from Education and Interpretation – Under Alternative D, the impacts from all off-site 

activities would be the same as described in Alternative C except that an on-site visitor center would 

replace the visitor contact station and a motorized interpretive tour would be created. The visitor center 

and the motorized interpretive tour may appeal to a larger audience, so more people would learn about the 

resources located within the Monument. Education programs would lead to improved stewardship of the 

site through an increased appreciation of the resources. An on-site visitor center would present a greater 

agency presence which could help to deter vandalism and theft of fossils.

Impacts from Recreation and Visitor Services – Under Alternative D, development of recreational 

facilities such as a campground, primitive camping areas, toilets, shade shelters, information kiosks, trail 

markers, picnic sites, trails, and a visitor center would probably increase the number of visitors to the 

PTNM. This increase in facilities and visitors may increase the potential for looting and destruction of 

paleontological resources. The impacts from allowing SRPs would be the same as those discussed for

Alternative A except that under Alternative D, locations allowed for OHV SRPs would be limited. The 

routes that are known currently to have exposed fossils would not be available for motorized or 

mechanized use under a SRP, eliminating damage to the exposed fossils.

Impacts from Trails and Travel Management – Impacts would be the same as under Alternative C 

except that the Cayenne Crawler Trail would be open for motorized and mechanized use and modified to 

allow access to the western portion of Patzcuaro’s Revenge Trail (Map 2-4). This additional mileage

would not impact the fossils in the closed portion of Patzcuaro’s Revenge Trail. The absence of a pass

system could result in reduced public awareness of the rules and regulations.

Impacts from Livestock Grazing – Impacts would be the same as under Alternative A.

Impacts from Special Designations – Impacts would be the same as under Alternative B.
EDUCATION AND INTERPRETATION

4-9

4.4.2 EDUCATION AND INTERPRETATION 

Assumptions and Incomplete Information: Off-site interpretation and educational opportunities 

already exist and would be expected to continue under all Alternatives. These include classroom and 

civic group talks and programs given by BLM staff and partners, the exhibits and programs offered at the 

City of Las Cruces Museum of Nature and Science (MoNaS), which opened in November 2012. The 

BLM has partnered with the City of Las Cruces in the development of the museum exhibits concerning 

the Trackways through an Assistance Agreement. Another Assistance Agreement with the City involves 

the development of additional exhibits and facilities at the MoNaS to encourage and facilitate visitation to

the PTNM and other public land. Programs and educational materials will be coordinated between the 

BLM and the MoNaS, and a shared docent program will be developed.

It is assumed that in all Alternatives, except Alternative B in which access is limited to pedestrian traffic, 

visitation to the Monument would increase annually (USDI BLM 2013).

Two travelling trunk exhibits have been developed by the New Mexico Museum of Natural History and 

Science. They are available for use by other museums and educational facilities around the State. Both 

are currently in use at local venues. Travelling suitcase/school kits and curricula have been developed for 

outreach to the public schools and will be used for training staff and volunteers in conducting tours.

Education is identified as one of the resources, objects, and values for which the Monument was 

established and is defined as educational and interpretive opportunities on the Permian fossils.

Management Decisions with No Impacts to Education and Interpretation: Under all Alternatives, 

the following programs would have little or no impact to Education and Interpretation: Air Resources 

including Air Quality and Climate Change, Cultural Resources, Livestock Grazing, Socio-Economic

Conditions, Soils, Special Designations, Special Status Species, Vegetation Management, Visual 

Resources, Water Resources, Wildland Fire Management, and Wildlife.

Effects Common to All Alternatives:

Impacts from Education and Interpretation – The off-site interpretation and education management 

actions are the same for all Alternatives. Interpretive material would be created via multiple media and so

education could occur off-site. The public can learn about the Monument’s resources at presentations, 

talks, museum exhibits, websites, and videos but this type of interpretation would not have the backdrop 

of the Monument to support educational messages. The number of visitors to the Monument, the MoNaS,

and to presentations on the Monument may increase over time.

Guided tours to specific sites would offer an excellent interpretive opportunity to participants. Interaction 

with an interpretive tour guide usually enriches the experience because a wealth of detail can be conveyed 

verbally while the resources are visually available. Participants can ask questions to further their 

knowledge and awareness of the subject matter against a natural background that provides further subject 

matter for interpretation. The personal interaction provided by a live tour is probably more effective in 

promoting stewardship from participants. Self-guided touring and exploring is also available under all 

Alternatives, but under Alternatives A and B, it would be very limited in terms of interpretation and 

education because the experience would be unassisted by directional signs and interpretive exhibits.

Impacts from Lands and Realty – Under all Alternatives, acquisition of public access easements from 

willing sellers would be beneficial to Education and Interpretation. Easements would provide the agency

and the public legal access, which would facilitate activities such as walking and motor tours.
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IMPACTS OF THE ALTERNATIVES

4.4.2.1 ALTERNATIVE A

Impacts from Paleontological Resources – Under Alternative A, the Paleontology program would 

continue to permit and support research. Scientific research provides baseline information which is used 

to develop meaningful interpretive and educational products and programs. The continuation of 

paleontological research would enhance and benefit the interpretive materials already available and could 

lead to the discovery of new specimens that could be used for exhibits (either authentic or cast replica),

and the resulting information obtained from the study of such fossils would enhance existing programs. 

In interpreting the fossil resources of the Monument, great care would be taken to interpret and educate 

without causing any loss of scientific information or undue degradation of the resource. Interpreters 

would work closely with the paleontologists to choose appropriate specimens for off-site museum 

exhibits, to possibly develop exhibits located adjacent to the PTNM, and to choose appropriate 

interpretive destinations within the Monument. Other sites would be protected from visitation due to 

concerns over theft and vandalism.

Casual collecting of common invertebrates and plant paleontological resources in the PTNM has been 

occurring for years and is still occurring today. This is a legal activity, unlike collecting archaeological 

artifacts. Families and school groups have enjoyed finding and collecting small fossils and, at least in the 

case of the school groups, this activity is educational. Even in an unstructured context, children’s 

imaginations are sparked by the remains of life from long ago and many of them pursue this interest on 

their own. However, a more structured approach (signing, making information readily available) to 

casual collecting would be preferable and would possibly result in fewer impacts to resources.

Impacts from Education and Interpretation – Under Alternative A, the plans for Education and 

Interpretation are primarily off-site. It is assumed that off-site venues within the local community would 

include museums, the BLM and other agency facilities, and public schools. These off-site venues would 

accommodate information and interpretive talks/presentations, and classroom presentations. For people 

not capable of accessing the resources in an outdoor setting, interpretive and educational programs in a 

museum or classroom setting could increase appreciation and understanding. Museum and educational 

experiences could lead to an enhanced visit for those people capable of visiting the PTNM. BLM-led 

tours to the Discovery Site and other sites would continue. Currently, there are no on-site interpretive 

facilities or opportunities within the PTNM such as exhibits or kiosks, except for a sign at the Discovery 

Site. There are no formal trails with signs to lead visitors to any location within the PTNM that has 

interpretable resources. This situation does not allow for any interpretation or education to occur in the 

Monument unless one is on a guided hike. This limits the opportunities for the public to learn on their 

own about the resources available in the Monument.

Impacts from Recreation and Visitor Services – Under Alternative A, there are no plans to build 

visitor facilities, and SRPs are allowed. On-site, self-guided interpretation and education would be 

limited to the Discovery Site which only offers an informal trail with minimal signage. Guided pedestrian 

tours would require hiking overland (not on a trail) to bring visitors to potential interpretive destinations.

Impacts from Trails and Travel Management – The existing routes (approximately 37.6 miles) are 

available for use, but no management actions are planned to improve the existing routes or add new trails 

and routes under Alternative A. Therefore, public education and interpretation would have to be 

accomplished off-site at museums, on areas adjacent to the PTNM or on-site through guided tours using 

informal trails and designated routes for access. Opportunities for expanding the MoNaS experience to 

the Monument itself, via organized tours (motorized or pedestrian), would be limited by the lack of trails 
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and interpretive exhibits. This would limit the on-site interpretation and educational use of the 

Monument.

Impacts from Lands and Realty – If non-Federal minerals were extracted, the BLM would lose the 

opportunity to interpret the resources located on that Federal surface.

Impacts from Lands with Wilderness Characteristics – Under this Alternative, 576 acres are 

identified as having wilderness characteristics. This does not impact Education and Interpretation

because Alternative A does not include plans for construction of new trails or interpretive exhibits within 

the Monument. Guided tours in this area would still be possible under this Alternative.

4.4.2.2 ALTERNATIVE B

Impacts from Paleontological Resources – Under Alternative B, all paleontological resources would be 

conserved for scientific research which would have the same impacts as Alternative A. Casual collecting 

of common invertebrates and plant fossils would not be allowed. This would be a minor impact to 

Education and Interpretation because although collecting invertebrates may enhance interpretation, it is 

not essential for a meaningful experience.

Impacts from Education and Interpretation – Under Alternative B, the BLM would develop 

interpretive materials for self-guided activities and programs for guided tours. This could increase the 

number of visitors to the Monument and could increase stewardship towards the Monument and would 

increase visitor’s knowledge about the PTNM.

Impacts from Recreation and Visitor Services – Impacts would be very similar to those described 

under Alternative A, however; there would be no on-site interpretive facilities or opportunities within the 

PTNM such as exhibits, kiosks or signs. Without formal trails and visitor facilities, public education and 

interpretation would have to be accomplished off-site at museums, on areas adjacent to the PTNM, or onsite through guided tours using informal non-motorized routes and self-guided activities. Self-guided 

interpretive activities would lead visitors to locations within the PTNM that have fossil resources. 

Improving access to the Discovery Site would not be possible under Alternative B thus visitors would not 

receive enhanced interpretation and education. Restricting casual collecting would lessen opportunities 

for the public to gain knowledge and hands-on opportunities with paleontological resources.

Impacts from Trails and Travel Management – Under Alternative B, the current system of routes 

would be closed to motorized and mechanized vehicle use. As a consequence, those routes would be 

unavailable for motorized interpretive tours, which could reduce both educational and interpretive 

opportunities. Opportunities for expanding MoNaS led tours, would be limited to pedestrian tours only 

and would be further limited by the lack of trails and interpretive exhibits. Hiking tours could be 

conducted along the existing routes; however, most of those routes do not lead to sites suitable for 

interpretation. Hikes across rugged terrain could reduce visitor participation in educational and 

interpretive activities.

Impacts from Lands and Realty – Under Alternative B, acquiring the non-Federal mineral estate would 

further protect the Monument from incompatible uses, thus protecting the values which the Education and 

Interpretation program would be founded upon.

Impacts from Lands with Wilderness Characteristics – Under this alternative, the 576 acres 

identified as Lands with Wilderness Characteristics would not be available for new trail construction or 
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exhibit installation; however, in Alternative B, there would be no plans for trails or exhibits. Guided and 

self-guided tours would still be possible.

4.4.2.3 ALTERNATIVE C

Impacts from Paleontological Resources – Under Alternative C, identified paleontological localities 

would be assessed for their educational, scientific, or interpretive values. This would facilitate the 

appropriate selection of sites for interpretive development and public viewing, and designate areas more 

appropriate for scientific research. Through assessment and data recovery processes, sites which have 

been determined to be non-sensitive or low-sensitive by a professional paleontologist, but having 

interpretive value, would be chosen for public interpretation. These sites may contain resources which 

are redundant, damaged or otherwise do not offer scientifically important data, or data that has already

been recovered.

Impacts from Education and Interpretation – Under Alternative C, pedestrian trails with kiosks and 

exhibits would be developed. Increased amounts of interpretive material and opportunities would bring 

complicated, complex, and often obscure aspects of life on this planet to the public in a way that is easily 

understood. Effective interpretation enhances understanding and imparts the wonder and joy that the 

natural and cultural worlds contain, but is firmly based on the details of life that are often discovered only 

by careful scientific research and analysis. These programs are usually beneficial because they can help 

foster the public’s appreciation and understanding, which leads them to want to protect and conserve 

these valuable resources. Children especially begin to develop deeper understandings of biology, 

geology, and other sciences and carry this into adulthood which leads to enhanced feelings of 

responsibility as a citizen and member of society.

Under Alternative C, exhibits for a visitor contact station and other sites would be developed to provide 

the opportunity for greater understanding of the paleontological resources through on-site venues. With 

on-site development of interpretive sites, visitors to the area would experience the resources in an outdoor 

setting, which provides context and could possibly increase the understanding of the resources. Through 

increased understanding, a greater appreciation for the tracks and trace fossils in the Monument might be 

developed by those visiting the PTNM. Increased understanding of the resources could lead to less trash

dumping, vandalism and theft of paleontological resources.

Impacts from Recreation and Visitor Services – Under Alternative C, on-site facilities such as shade 

shelters, information kiosks, a trail systems with trail markers and interpretive exhibits, and a visitor 

contact station would be developed. Interpretive exhibits would inform the visitor about a variety of 

interpretive themes including the Permian environment, the existence and behavior of extinct animals, 

how the trackways inform scientists and the evolutionary development of reptiles and amphibians, to 

name only a few. Interpretive facilities would draw more visitors to the Monument, which increases the 

interpretive audience. A visitor contact station would serve the public by offering a sheltered location in 

which to hold interpretive and educational programs, possibly replica specimens, interpretive exhibits, 

printed materials, and possibly a sign-in kiosk. This would be very beneficial to interpretation and 

education because such a facility would greatly enhance the visitor’s experience by offering exhibits and 

printed material that inform about the resources of the Monument, furthering the BLM’s educational and 

interpretive goals. Kiosks and signing establish a management presence and this serves both the agency 

and the members of the public in various ways. Visitors feel more secure about an area when trails are 

marked and safety information is readily available. Visitors may better appreciate the public land when 

they are provided information. Establishing a sense of ownership in the visiting public serves to protect 

the public land from vandalism and theft. The agency presence also is a deterrent to these destructive
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activities especially when incidences of vandalism are quickly addressed, showing that an area is not 

being ignored or neglected.

Impacts from Trails and Travel Management – Under Alternative C, designated trails could be 

developed to guide the visitor to geological and paleontological localities that illustrate interpretive 

concepts. Eighty-nine percent of the existing routes in which motorized or mechanized vehicle use is 

allowed would remain open to this use. Educational material could be included in the no-fee day-use pass 

that would be required for motorized and mechanized vehicle use. Formal trails and an effective 

interpretive/education program would assist in protecting sensitive resources by offering suitable 

locations that are fairly easy to access. This would satisfy the visitor’s interest in viewing and 

experiencing exciting resources, and may also keep those visitors from seeking out locations that merit 

protection from the possible abuses associated with public visitation. The routes that are open under 

Alternative C could be used for motorized or non-motorized self-guided and guided tours by the BLM, 

docents, or BLM’s partners.

Impacts from Lands and Realty – Public access easements would be acquired from willing sellers

which would provide additional legal access points for portals to interpretive trails leading to exhibits or 

destinations. Acquiring the non-Federal mineral estate on lands within and adjacent to the Monument 

would be advantageous since the acquisition would further protect the Monument from incompatible uses, 

thus protecting the values which the Education and Interpretation Program would be founded upon.

Impacts from Lands with Wilderness Characteristics – Under Alternative C, 253 acres would be 

managed as Lands with Wilderness Characteristics (see Map 2-7). These lands would be limited from 

development as described under Alternative B. However, the lands outside of those managed for 

wilderness characteristics, such as the Discovery Site, would be available for the development of 

interpretive trails and exhibits, which would greatly increase the interpretive opportunities. Guided tours 

in this area would also be possible.

4.4.2.4 ALTERNATIVE D

Impacts from Paleontological Resources – Under Alternative D, the effects from the Paleontology

management actions would be similar to those described under Alternative C, except that limited

collecting of common invertebrate fossils without a permit would be allowed only in conjunction with 

BLM-approved interpretive or educational programs or activities. This would be an effective teaching

tool for school-age children that could have far-reaching impacts for their educational development. 

Finding a fossil is an exciting event and being able to keep it provides a physical reminder of the 

experience.

Impacts from Education and Interpretation – The effects from the Education and Interpretation

management actions would be similar to those described under Alternative C. Under D, a visitor center 

(effects described below) and a motorized interpretive tour would be developed. These additions would 

probably increase the number of visitors to the Monument since a visitor center would be universally 

accessible and the motorized vehicle tour would not be dependent on one’s physical ability or vehicle’s 

ability. A visitor center presents many additional and expanded opportunities and would be very 

beneficial to interpretation and education. Programs involving both the indoor exhibits and the outdoor 

exhibits could be crafted to provide a cohesive and consistent interpretive message. Visitors of all 

capabilities could experience the Monument within the visitor center which would be placed within the 

Monument and possibly close to outdoor exhibits; this would increase visitation. A motorized tour would 

bring the backcountry experience to more people and would bring more people to interpretive 

destinations, significantly increasing the educational value of the tour.
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Impacts from Recreation and Visitor Services – The effects are the same as described under 

Alternative C with the additional actions of enhanced recreational opportunities. A visitor center would 

offer exhibits and activities devoted entirely to interpreting the resources of the PTNM, which would be a 

unique museum experience. This facility would offer the opportunity for educational programs to be 

conducted on-site and would assist in accommodating school and public groups visiting the PTNM. It 

also would serve as the launching point for many of the front-country activities such as accessing the 

formal trails that bring the visitor to interpretive destinations, such as in-situ fossil exhibits developed for 

public visitation. This would increase the number of visitors and possibly increase the stewardship of the 

Monument.

Impacts from Trails and Travel Management – Under Alternative D, despite the closure of certain 

roads used for rock-crawling, pedestrian interpretive and educational activities on these routes would still 

occur. New routes could be developed to enhance the visitor’s interpretive and educational opportunities. 

For instance, if a paleontological location is selected for interpretive development but is inaccessible, this 

alternative allows the development of a non-motorized or motorized route to facilitate access. This would 

allow for more visitors to access in-situ interpretive sites.

Impacts from Lands and Realty – The impacts from Lands and Realty would be the same as discussed 

under Alternative C.

Impacts from Lands with Wilderness Characteristics – Under Alternative D, since no lands outside 

the WSA would be managed to maintain wilderness characteristics, lands with wilderness characteristics 

would present no restraints to developing interpretive trails and exhibits.
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4.4.3 RECREATION AND VISITOR SERVICES

Assumptions and Incomplete Information: Under Alternatives C and D, a visitor contact station and a 

visitor center were analyzed; however, there is no one obvious location for these facilities and the analysis 

is based on the opportunity to explore several locations inside and bordering the Monument. Any future

BLM decisions for these facilities would consider legal and physical access, ecological impacts, and 

proximity to paleontological sites, and recreational trails.

Under Alternative C, a visitor contact station is analyzed. The visitor contact station would be a minimal 

facility that is ABA (Architectural Barriers Act of 1968) accessible. It could be a large shade structure

(approximately 50 feet by 50 feet) with a set of wayside exhibits and panels. A parking area for 15 cars 

would cover about 20,000 square feet of surface. Pit toilets would be installed. The footprint for the 

contact station, parking lot, wayside exhibits and toilets would be about 1 to 11⁄2 acres. The estimated 

range of cost for this type of infrastructure would be approximately $240,000.

The visitor contact station may or may not be staffed by BLM employees at regular times and could be 

used to hold interpretive programs. It would be a place where visitors can learn about the Monument, feel 

like they have had contact with the resources, and learn why it was made into a National Monument.

Under Alternative D, a visitor center is analyzed. A visitor center would be an ABA accessible building 

that would be staffed with regular hours of operation. It would have paleontological and geological 

specimen exhibits and interpretive displays. The facility would have indoor bathroom facilities, 

electricity, and plumbing. The footprint of this building and parking lot would take up about 11⁄2 to 2 

acres. Cost estimate for a 2,500 to 3,000 square foot building, a paved park area for 30 cars, and a 

maintained gravel road, is approximately $2,000,000.

A visitor center would require a greater number of staff members to maintain the facilities and manage

the visitor center with regular hours of operation.

Under the authority of the Federal Lands Recreation Enhancement Act (REA), the BLM uses the Special 

Recreation Permitting system to satisfy recreational demands within allowable use levels in an equitable, 

safe, and enjoyable manner while minimizing adverse resource impacts and user conflicts for all public 

land. All SRP applications will be analyzed with an elevated consideration of protecting the Monument 

Objects. Environmental Assessments (EAs) have been completed for previous SRPs and events held 

within the Monument. As a part of the SRP process, BLM monitors SRP events, completes post-event 

assessments, and evaluates whether the events adhered to the Legislation. Further studies have not been 

completed to assess the number of OHV SRPs that could be issued annually while still protecting the 

Monument’s fossil resources.

Vehicle counters have been placed at three major access points into the Trackways. One of the counters 

placed at a major access point to the Monument, near the eastern boundary, counted over 10,000 vehicle 

crossing it in a year. However, the exact number of visitors then crossing into the Monument is difficult 

to determine, because there are several other routes for vehicles to enter and leave the Monument. The 

accepted conversion for visitor trips based on vehicle counts is 2.5 visitors per car. The BLM estimates

that somewhere between 40 to 60 percent of the vehicles that crossed the vehicle counter actually entered 

into the Monument proper, or 10,000 to 15,000 people. Visitors entering the Monument as hikers or on 

mountain bikes were not counted.

It is assumed that in all Alternatives, except Alternative B in which access is limited to pedestrian traffic, 

visitation to the Monument would increase annually (USDI BLM 2013). Under Alternative B, with the 
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elimination of motorized and mechanized use, the number would probably drop to less than current 

visitation. If under Alternative C a visitor contact station, interpretive facilities, and recreational trails

were put in, it is assumed visitation would increase substantially annually. If under Alternative D, a 

visitor center is put in along with interpretive facilities and recreational trails, it is assumed visitation 

would increase more than in the other alternatives.

Recreation is identified as one of the resources, objects, and values for which the Monument was 

established. The specific recreational resources managed under this category are those which relate to the 

enjoyment, appreciation, and protection of the fossil resources and their geologic context. Other types of 

recreational uses (for example, OHV use, camping, and mountain biking) are allowed to the extent that 

they do not conflict with management of Paleontological Resources.

Management Decisions with No Impacts to Recreation and Visitor Services: The following 

resources or uses have no or little impact on Recreation and Visitor Services: Cultural Resources, 

Livestock Grazing, Special Designations, Special Status Species, Vegetation Management, Visual 

Resources, and Wildlife.

Effects Common to All Alternatives:

Impacts from Lands and Realty – Under all Alternatives, the BLM would continue with the current 

management prescription for acquiring legal public access.

IMPACTS OF THE ALTERNATIVES

4.4.3.1 ALTERNATIVE A

Impacts from Paleontological Resources – Under Alternative A, casual collecting of common 

invertebrates and plant paleontological resources would be allowed to continue. Paleontologists familiar 

with the Monument have expressed the opinion that casual collecting of common invertebrates would not 

be detrimental to the resources. Under the Paleontological Resource Protection Act, this type of 

collecting is allowed.

Impacts from Education and Interpretation – Under Alternative A, the BLM would continue 

interpretation partnerships with museums and other entities to develop interpretive materials for programs 

and events and have tours led to the fossil sites. The Monument’s paleontological resources are very 

subtle and challenging to detect. On-site tours and interpretive programs would facilitate the visitor

experience and increase their understanding of the resources within the Monument. The lack of on-site 

interpretive and educational exhibits and facilities would limit visitors’ abilities to intellectually and 

emotionally connect with the fossil resources of the Monument.

Impacts from Recreation and Visitor Services – Under Alternative A, there are no plans to develop

visitor facilities within the Monument. The Monument’s desert environment is prone to extreme heat in 

the late spring, summer and early fall. This environment combined with the lack of comfort facilities in 

and around the Monument would likely deter or limit family groups, school groups and other visitors who 

might be in need of bathrooms and shade shelters. Lack of development and facilities would increase the 

opportunity for visitors seeking a recreation experience in a less crowded and more natural setting. Under 

this Alternative, visitor use is expected to decrease. Lack of facilities and developed access under this 

Alternative may deter visitors with certain kinds of disabilities or limit their recreation opportunities. 

Over time, the absence of toilet facilities may create challenges associated with managing human waste.
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Discharge of firearms is allowed under Alternative A. Hunters would continue to use the Planning Area

in accordance with New Mexico Department of Game and Fish regulations. Target shooters would 

continue to use the Monument for their activities. However, the BLM acknowledges that there is a safety 

risk of inviting the public and researchers to the Monument and continuing to allow recreational target 

shooting throughout the same area within Alternative A. Target shooting is a safety concern for 

recreationists, tourists, researchers, BLM staff and volunteers. The issue arises when recreational 

shooters utilize the area for the discharge of firearms concurrent with public visitation to the Monument, 

as well as BLM-sponsored educational events. The BLM events include guided educational programs for 

local elementary, middle-school and high schools, as well as other guided hikes by the BLM and other 

entities. The events may take place adjacent to areas being used for target shooting, and the BLM has 

documented near misses as well as an unwillingness by target shooters to cease while school busses are 

unloading or other visitors are beginning their hikes. Students, law enforcement officers, and other 

visitors have been in close proximity to bullets shooting by.

The BLM evaluated target shooting in certain areas of the PTNM in terms of public safety. The Las 

Cruces District Office analyzed industry standards for predictable projectile safety areas (Appendix G). 

From this data, the BLM concluded that a 1⁄2-mile safety zone (no target shooting) around areas where 

people congregate within the Monument is appropriate. Consistent with this analysis, the BLM applied 

the same 1⁄2-mile safety buffer zone around those locations within the Monument where people congregate

such as paleontological resources (researchers, BLM staff, and tourists, etc.) and routes.

Within the Monument, visitors and researchers often congregate near the paleontological resources. 

Further, the BLM authorizes scientific exploration and academic research in the PTNM and surrounding 

areas. The researchers are working throughout the day, often crouched in a low-visibility position at the 

many paleontological sites located within winding arroyos. This can leave the researchers and other 

members of the public screened from above, or within, the arroyos. Unintentional bullet ricochets or 

misfires would present an unnecessary risk to public safety in the area.

This mapping exercise reveals that the safety buffer zones associated with protection of public access to 

paleontological sites incorporates 93 percent of the Monument. Approximately 356 acres, or 7 percent, of 

the Monument near the southern boundary lies outside the 1⁄2-mile buffer zones associated with 

paleontological sites. (In conformance with the Paleontological Resources Protection Act, 

paleontological sites are not displayed on the associated maps.) 

Another set of locations in the Monument where people congregate are designated recreational routes. 

The area within the Monument includes 32 miles of designated off-highway vehicle (OHV) trails having 

National recognition as prime and challenging trails for extreme off-roading and rock crawling 

enthusiasts. These trails are the destination for recreation activity rather than access routes to recreation 

destinations beyond. The OHVs move slowly over extended periods of time, with people often 

congregating and walking alongside the vehicles. Recreational target shooting would put these visitors at 

unnecessary risk. The BLM applied a 1⁄2-mile buffer around designated recreational routes in Alternative 

A. Map 4-2 shows 67 acres, or approximately 1 percent of the Monument lies outside of the 1⁄2-mile 

safety zones associated with designated recreational routes.

The 1⁄2-mile buffer zones associated with paleontological resources (Map 4-1) and designated routes (Map 

4-2) were merged to determine where recreational shooting could be considered safer in the Monument. 

However, these two sets of safety zones cover the entire Monument (Map 4-3), indicating that there are 

no areas in the Monument that are more than 1⁄2-mile from areas of high public use where recreational 

target shooting could take place safely. In addition to areas where the public congregate, the soil surface 

throughout the Monument has a high rock content (see Soils section in Chapter 3) which would further 

increase unnecessary risk to visitors from the potentially increased number of ricochets.
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Under Alternative A, SRPs would continue to be authorized on a discretionary basis. Continuing to 

authorize SRP events and related activities would provide a means to manage visitor use, enhance the 

recreation experience, and promote land stewardship. Permitted activities would also result in short-term 

impacts such as increased noise, crowds, and associated visitor use conflicts.

Impacts from Trails and Travel Management – Alternative A would continue to provide OHV access 

over approximately 32 miles of the Robledo Mountain OHV Trails (commonly known as the Chile 

Challenge Trails). These routes primarily benefit specialized, high-clearance off highway vehicles. This 

Alternative would maximize OHV access and related recreation opportunities.

The 6.2-mile SST Mountain Bike Trail would remain and continue to provide an opportunity for both 

individual and group biking activities (5.5 miles are within the Monument boundary).

Alternative A does not specifically plan for additional development of separate hiking, pedestrian, and 

horse trails. However, portions of vehicle routes or most arroyo and canyon bottoms could be used by 

those who want to explore the Monument on foot or horseback. Dispersed hiking and equestrian activity 

would continue throughout the Monument and allow visitors the opportunity to discover and explore. 

Access along the trail to the original Discovery Site that hugs the base of the north side Community Pit 

spoils pile would remain closed due to safety concerns resulting from the proximity of the trail to unstable 

spoils piles and debris. The absence of well designed, convenient trails impacts visitor interest and ability 

to reach the desired destination.

Impacts from Lands with Wilderness Characteristics – Under this Alternative, the 576 acres 

identified as lands with wilderness characteristics would be available for recreational development.

4.4.3.2 ALTERNATIVE B

Impacts from Paleontological Resources – Under Alternative B, casual collecting of common 

invertebrates and plant paleontological resources would not be allowed. This would disappoint visitors

and school students collecting common invertebrate fossils. This may reduce the number of visitors and 

students that would want to visit the Monument.

Impacts from Education and Interpretation – Under Alternative B, interpretation and education 

allows for continued partnerships with museums, BLM and partner-led interpretive tours to fossil sites, 

and development of interpretive materials for programs and events. On-site tours and interpretive 

programs would help facilitate the visitor experience and help the visitor relate to and understand the 

resources of the Monument. Only minimal directional and informational signs would be installed. 

Visitors (not a part of guided tours) would have a challenging time finding paleontological sites and 

connecting with the resources on self-guided visits to the Monument.

Impacts from Recreation and Visitor Services – Installation of minimal directional and informational 

signs would facilitate exploration and discovery, and increase visitor safety by reducing the opportunity 

for visitors to lose their way. The effects of forgoing development of additional recreation and visitor 

facilities are the same as under Alternative A. Due to the lack of motorized and mechanical recreational 

use in this Alternative, it is assumed that visitation would drop.

Under Alternative B, hunting would continue in accordance with New Mexico Department of Game and 

Fish regulations and recreational target shooting would continue. The analysis of recreational target 

shooting in Alternative A and Map 4-1 applies as well to Alternative B. Because Alternative B would 

close the PTNM to motorized and mechanized vehicle use, the analyses found in Maps 4-2 and 4-3 do not 
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apply to Alternative B. In the southern portion of the Monument, approximately 356 acres (or 7 percent 

of the Monument) lie outside the 1⁄2-mile buffer zone around fossil sites. This area does not have access. 

In addition, because Alternative B does not include increased access to the PTNM, the 356 acres 

identified outside the buffer zone cannot be reached by vehicle. Reaching this area would be a challenge 

for both target shooters and BLM rangers. If target shooters reached this area by foot or horseback, 

researchers, BLM staff, and the visiting public in the same area remain at risk from stray bullets.

The BLM acknowledges that there is a safety risk of inviting the public and researchers to the Monument 

and continuing to allow recreational target shooting throughout the same area. With no motorized or 

mechanized access with this Alternative, there would be fewer people within the Monument and probably 

less risk to public safety than with Alternative A.

The effects from lack of recreation and visitor facilities under this Alternative is the same as under 

Alternative A.

Impacts from Trails and Travel Management – Under Alternative B, the Monument would be closed 

to motorized and mechanized vehicle use. This would close the 32 miles of the Robledo Mountains OHV

Trails (Chile Challenge Trails) and 5.5 miles of the SST Mountain Bike Trail. Eliminating the use of 

motorized and mechanized vehicles would essentially close the Monument to a large portion of its 

recreational user groups. OHV enthusiasts and mountain bikers would likely continue to pursue their 

recreational interest in other areas.

Closing the Monument to motorized and mechanized use would increase and enhance the recreational 

opportunity for those seeking a quiet and natural recreation setting (e.g., fewer signs of vehicle activity 

such as tire tracks, oil spills, broken rocks, etc.)

Under Alternative B, there are no plans to develop hiking or horse trails. With the exception of portions 

of the existing vehicle trail system, hiking and equestrian opportunities would be limited primarily to 

cross-country use. Access along the trail to the original Discovery Site tracksite that hugs the base of the 

north side Community Pit spoils pile would remain closed due to safety concerns resulting from the 

proximity of the trail to unstable spoils piles and debris. As in Alternative A, the absence of developed 

hiking trails to points of interest in the Monument, discourages casual investigation by the public.

Impacts from Lands and Realty – The BLM would acquire the non-Federal minerals within the 

Monument. This would eliminate the possibility of disturbance to the surface from extraction of the 

subsurface minerals and a subsequent reduction in recreational opportunities on those lands.

Impacts from Lands with Wilderness Characteristics – Under this alternative, the 576 acres identified 

as Lands with Wilderness Characteristics would not be available for recreational development. Instead, 

recreational development such as trails and recreational facilities would occur in other areas of the 

Monument, minimally impacting the lands identified as having wilderness characteristics.

4.4.3.3 ALTERNATIVE C

Impacts from Paleontological Resources – Under Alterntive C, the effects would be the same as those 

discussed in Alternative B.

Impacts from Education and Interpretation – As in Alternatives A and B, interpretation and education 

allows for continued partnerships with museums, BLM and partner-led interpretive tours to fossil sites, 

and development of interpretive materials for programs and events. This would have the same beneficial 

effects discussed under the previous alternatives.
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Under Alternative C, there would be pedestrian trails developed with orientation kiosks and wayside 

exhibits, along with developed exhibits for on-site interpretation and a visitor contact station. These 

would benefit those visitors trying to understand and relate to the resources of the Monument. On the 

other hand, such facilities might detract from the natural and wild settings of the Monument if these 

interpretive developments are too frequent or too conspicuous.

Impacts from Recreation and Visitor Services – Alternative C, provides for the possibility to develop, 

install, and maintain a variety of visitor facilities (i.e., a visitor contact station, toilets, shade shelter, 

information kiosks, and picnic sites). This level of development would increase visitor comfort, visitor 

use, and overall opportunities for those seeking a more developed, safe and controlled recreation setting 

(e.g., school and tour groups). Due to the development of facilities and the opportunities for education 

and interpretation, visitation would be expected to increase dramatically (BLM 2013). This level of 

development would also reduce the opportunity for those seeking a less crowded and more natural

recreation setting.

Under Alternative C, motorized and mechanized vehicle users would be required to obtain a no-fee dayuse permit. Registering online or driving to the BLM office for a permit would result in an inconvenience 

and require additional planning. In the short-term, vehicle users who are unaware of the permit 

requirement would either have to cancel their trip or return to the Las Cruces BLM office to obtain a 

permit. When obtaining the permit, maps and safety information would direct visitors to trails and the 

location of interpretive and educational sites. A permit system would also provide the BLM accurate 

visitor use data to better plan and manage future vehicle-use.

Under Alternative C, recreational target shooting would be prohibited. The Las Cruces District Office 

analyzed industry standards for predictable projectile safety areas and these results are found in 

Alternative A and in Appendix G. The analysis demonstrates that there are no areas in the Monument 

that are more than 1⁄2-mile from areas of high public use where recreational target shooting could take 

place safely.

Closing the Monument to recreational target shooting would slightly decrease the number of opportunities 

for this activity in the Analysis Area. However, the public land in Doña Ana County outside of the 

Monument is available for recreational target shooting (unless closed under Supplemental Rules at 

developed recreation areas). There are approximately 1,069,757 acres, or 44 percent, of Doña Ana 

County that are available for recreational target shooting. In addition, there is a public shooting range 12 

miles to the west of the PTNM on BLM land that is operated by the City of Las Cruces, which is free to 

the public for target shooting. The BLM currently permits this shooting range, the Butterfield Range, to 

the City of Las Cruces under a Recreation and Public Purposes Act lease. This is an excellent shooting 

facility and readily accommodates a wide variety of safe shooting venues for the public.

Prohibiting target shooting would increase visitor and BLM staff safety by reducing risks associated with 

stray bullets. It would also eliminate the litter left by target shooters, and reduce the opportunity for user 

conflicts. As Monument visitation increases over time, the conflict between target shooters and other 

visitors would increase if the Monument was not closed to recreational target shooting. Closing the 

Monument to target practice shooting would create a safer environment for researchers, visitors and BLM 

staff and volunteers.

Impacts from Trails and Travel Management – Under Alternative C, approximately 26.9 miles of the 

Robledo Mountains OHV Trail routes would remain open to motorized and mechanized vehicle use and 

5.4 miles would be closed. Open vehicle routes would provide recreational opportunities for those who 

are unable to hike cross-country and through rugged terrain, taking visitors closer to various fossils and 

interpretive sites. The closure of 5.4 miles of trail used by OHV rock crawling enthusiasts would 
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inconvenience and disappoint this user group. While other challenging routes would remain open with a 

day-use pass, these segments are highly valued because of their level of extreme difficulty. Closure of the 

5.4 miles might discourage some OHV owners from using the Monument and overall rock crawling 

would decrease. Closing the segments of trail would increase and enhance the recreational opportunity 

for non-motorized users seeking a quieter and more natural recreation setting.

Under Alternative C, the 5.5 miles of SST Mountain Bike Trail would remain open for mountain biking 

with a no-fee day permit. This Trail would continue to provide a quality recreation opportunity.

Alternative C provides an opportunity to identify, construct and maintain new routes for biking, hiking, 

and equestrian and OHV activity. An expanded trail system would increase access and associated 

recreational opportunities for both motorized and non-motorized travelers. Additional trails would 

enhance the recreation experience by increasing access to fossil sites, scenic views, geological formations, 

and other values for which the Monument was designated. An expanded trail system and related activity 

may deter those seeking a recreation experience in a less crowded and more natural setting.

Impacts from Lands and Realty – Under Alternative C, the BLM also would acquire access easements 

for public use. The increase of legal access points would allow multiple entry points and open the 

Monument up to more people. This could lead to several impacts such as increased vandalism and trash 

throughout the Monument and increased recreational destinations and opportunities.

Impacts from Lands with Wilderness Characteristics – Under Alternative C, 253 acres would be 

managed as Lands with Wilderness Characteristics. Management of these lands would limit man-made 

intrusions as described under Alternative B. However, the remaining lands would be available for the 

development of recreational facilities which could greatly increase the recreational opportunities within 

the Monument. The Discovery Site is within those remaining lands (not to be managed as Lands with 

Wilderness Characteristics); therefore it would allow greater interpretation of that site and the ability to 

build trails for better access to it.

4.4.3.4 ALTERNATIVE D

Impacts from Paleontological Resources – Under Alternative D, collecting of common invertebrate

fossils would only be allowed in conjunction with BLM authorized interpretive or educational activities 

and programs in areas of the Monument identified by BLM Paleontologists for this use. Designating 

areas for collection of common invertebrates would significantly reduce the likelihood of the removal of a 

fossil important for scientific research.

Impacts from Education and Interpretation – Interpretation and education allows for continued 

partnerships with museums, BLM and partner-led interpretive tours to fossil sites, and development of 

interpretive materials for programs and events. This would have the same effects as discussed under 

Alternatives A and B.

Under Alternative D, there would be pedestrian trails developed with orientation kiosks and wayside 

exhibits, along with developed exhibits for on-site interpretation. These would have the same impacts as 

discussed under Alternative C.

Under Alternative D, BLM may create an on-site visitor center. This would provide an avenue for strong 

interpretation and BLM presence in the Monument. However, a visitor center requires regular staff hours, 

maintenance, and a significant financial obligation. It would also detract from the experience of those 

seeking a wilder, more natural setting. The impact to the natural setting from any facilities proposed 
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(kiosks, exhibits, visitor center) would be minor considering how few acres these facilities would take up 

compared to the number of acres that would be without facilities.

Impacts from Recreation and Visitor Services – Impacts under Alternative D are the same as under 

Alternative C. Installation of a campground and visitor center would increase visitor use and significantly 

increase BLM’s financial obligation with regard to capital investments, staffing, and facility maintenance.

Installation of a visitor center would provide the BLM an on-site opportunity to offer exhibits and 

activities devoted entirely to interpreting the unique paleontological resources of the PTNM. A visitor 

center would also provide a venue to conduct on-site educational programs that would better 

accommodate larger groups (e.g., schools, tours, family, etc.). Overall, this level of development would 

benefit those seeking a more comfortable, social, and controlled recreation setting. This level of 

development would also reduce the opportunity for those seeking a recreation experience in a less 

crowded and more natural setting.

Under Alternative D, recreational target shooting would not be allowed. This would have the same 

impacts as described under Alternative C.

Impacts from Trails and Travel Management – Under Alternative D, approximately 28.3 miles of the 

Robledo Mountains OHV Trails would remain open to motorized and mechanized use and 4.0 miles 

would be closed. This closure would affect the extreme OHV recreationists as these routes are considered 

to be some of the most challenging for rock crawling. Under this Alternative, 0.9 miles of Branson 

Canyon would remain open for rock crawling by re-configuring Cayenne Crawler from an “up only” to a 

“down only” direction, thus allowing OHV access to the upper portion of Branson Canyon (Patzcuaro’s

Revenge Trail) which would allow a desirable rock crawling opportunity not offered in Alternative C. 

The rest of the impacts would be the same as described under Alternative C.

Under Alternative D, the 5.5 miles of SST Mountain Bike Trail would remain open for mountain biking,

and impacts would be the same as those described in Alternative A.

Alternative D provides an opportunity to identify, construct, and maintain new trails for biking, hiking, 

and equestrian and OHV activity. An expanded trail system could lead recreationists and visitors to fossil 

sites, scenic views, geological formations and other qualities and values for which the Monument was 

designated. This would provide greater opportunities for a quality recreation experience for hikers, 

horseback riders, OHV users, bicyclists, and sightseers.

Impacts from Lands and Realty – Under Alternative D, the impacts are the same as discussed under

Alternative C.

Impacts from Lands with Wilderness Characteristics – Under Alternative D, no land outside the

WSA would be managed to maintain wilderness characteristics; therefore, recreational facilities may 

impact those characteristics.
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4.4.4 TRAILS AND TRAVEL MANAGEMENT

Assumptions and Incomplete Information: Public interest in both recreational and 

scientific/educational access to the Monument is assumed to increase with advertisements of its unique 

and significant characteristics.

Management Decisions with No Impacts to Trails and Travel Management: The following 

resources or uses have little or no impact on Trails and Travel Management: Air Resources, Cultural 

Resources, Livestock Grazing, Socio-Economic Conditions, Special Status Species, Vegetation

Management, Visual Resource Management, Wildland Fire Management, and Wildlife.

Effects Common to All Alternatives:

Impacts from Paleontological Resource – Under all Alternatives, if the PTNM Authorizing Officer 

determines that OHV use would cause or have the potential to cause adverse impacts to specific

paleontological resource sites, then an area could be closed to travel or travel restrictions may be imposed.

Impacts from Trails and Travel Management – Under all Alternatives, casual, dispersed pedestrian 

and equestrian use are allowed. This allows for hikers and equestrian users to traverse the Monument as 

they please. They are not bound to any route.

Impacts from Lands and Realty – Under all Alternatives, the BLM would attempt to acquire public

access easements for public use from willing sellers. This would allow for legal access for the public and 

administrative use into the Monument.

Impacts from Special Designations-Area of Critical Environmental Concern (ACEC) – The 

Robledo Mountains ACEC limits all vehicle use to designated roads and trails. For the portion of the 

ACEC within the Monument, there are no roads or trails; therefore there would be no vehicle use within 

the ACEC portion of the Monument. All travel within the ACEC would have to be on foot or on 

horseback, which reduces the number of people who would visit this part of the monument.

IMPACTS OF THE ALTERNATIVES

4.4.4.1 ALTERNATIVE A

Impacts from Paleontological Resources – Under Alternative A, casual collecting of common 

invertebrates and plant paleontological resources would be allowed to continue. This may encourage the 

public to drive on undesignated roads to get to invertebrate fossils, thus creating illegal routes within the 

Monument. Due to rough routes, the traffic to find invertebrate fossils would be primarily pedestrian.

Impacts from Education and Interpretation – Under Alternative A, off-site interpretation and 

education would continue as would BLM-led tours to the Discovery Site and other sites. The off-site 

education program does not cause an impact on travel management, but there are requests for tours within 

the Monument. Construction of new routes and maintenance of existing routes would not be planned. 

This Alternative allows for tours on the existing routes or arroyos, but they are not the most accessible or 

easy to hike. As interpretive tour requests increase, the need for maintained trails would increase. Lack 

of scheduled route or trail maintenance or construction would hinder access to the Monument for those 

interested in learning about the resources and enjoying an easy stroll.
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Impacts from Recreation and Visitor Services – SRPs would continue to be authorized. This would 

allow commercial, competitive, and organized groups to continue to conduct various events. Most of the 

SRPs are for OHV events on the designated routes. This Alternative continues to allow for OHV SRPs, 

which provides a highly sought after OHV experience.

Impacts from Trails and Travel Management – Under Alternative A, motorized and mechanized use 

is limited to approximately 37.6 miles of designated routes. These routes provide excellent opportunities 

to experience the Monument on a daily basis with minimal restrictions. Those that have high clearance

vehicles capable of negotiating the challenges of these routes can experience a first class OHV or 

mountain bike experience. However, the lack of scheduled improvement or maintenance of routes and

trails reduces the ease of access for educational and some recreational uses. There is little or no 

opportunity for low-clearance vehicles to access the Monument.

Impacts from Lands and Realty – Under Alternative A, the impacts are the same as those stated in 

Effects Common to All Alternatives.

Impacts from Lands with Wilderness Characteristics – Under Alternative A, there would be no 

impacts to trails and travel management from Lands with Wilderness Characteristics.

Impacts from Special Designations-Research Natural Area (RNA) – Under Alternative A, the RNA 

designation would remain, which has the following prescriptions that impact trails and travel 

management: limit vehicle use to designated roads and trails and manage for Recreation Opportunity 

Spectrum (ROS) semi-primitive non-motorized class. This designation allows motorized recreation on

designated routes and non-motorized use in the RNA. These management prescriptions still allow access 

to the Monument for recreation, research, and administrative use.

4.4.4.2 ALTERNATIVE B

Under Alternative B, motorized and mechanized use of the routes would not be allowed within the 

Monument, except for administrative, permitted, and emergency use. There would be no impacts from 

other resources to trails and travel management.

4.4.4.3 ALTERNATIVE C

Impacts from Paleontological Resources – Under Alternative C, route use may decrease from some 

members of the public that use the area for casual collection of fossils. The use of routes for permitted 

collection would increase.

Impacts from Education and Interpretation – Under Alternative C, a hiking trail system with kiosks 

would be developed. A visitor contact station could be developed, thus access to the station would be 

necessary. These may add routes to the Comprehensive Trails and Travel Management (CTTM) Plan 

(Appendix C) and workload to a maintenance schedule. Through the interpretive hiking trails, the public 

could access and understand the fossils more easily.

Impacts from Recreation and Visitor Services – Under Alternative C, the BLM could prepare an 

activity plan to identify, construct and maintain new trails for biking, hiking, equestrian, and OHV 

activity. An expanded trail system would increase access for both motorized and non-motorized travelers. 

An activity plan would locate sites to develop visitor facilities. Routes changes would be incorporated 

into the CTTM Plan for the Monument (see Appendix C). All developments would be done in 

compliance to the NEPA process.
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Impacts from Lands and Realty – Under Alternative C, acquisition of access easements would trigger a

revision of the CTTM Plan (Appendix C). More access points into the Monument would improve the 

visitor experience. The CTTM Plan would have to balance the need for access and the need for resource 

protection. As access opportunities increase, the BLM would undertake more administrative 

responsibility for maintaining and managing the use of these easements.

Impacts from Lands with Wilderness Characteristics – Under Alternative C, approximately 253 acres 

within the Monument would be managed for protection of the wilderness characteristics. Since there are 

no trails, roads or interpretive exhibits planned within this area, there would be no impacts to trails and 

travel management. The area would remain open for dispersed non-motorized, non-mechanized travel, so 

hiking and horseback use would continue.

Impacts from Visual Resources – Under Alternative C, VRM Class objectives I and II would influence

the location and degree of any proposed trail construction. Construction of new trails would have to meet 

the objective to either preserve (VRM Class I) or retain (VRM Class II) the existing character of the 

landscape. Any newly created visual contrasts would have to be low (Class II) or very low (Class I). 

These constraints would require careful trail design and location and may prohibit trail construction 

altogether in some locations.

4.4.4.4 ALTERNATIVE D

Impacts from Paleontological Resources – Under Alternative D, casual collection of common 

invertebrates and plant fossils would not be allowed. Collecting of common invertebrate fossils would 

only be allowed in conjunction with BLM authorized interpretive or educational activities and programs. 

This would direct groups to specific locations, which may result in the need for improved access, and may 

cause additional wear on the routes.

Impacts from Education and Interpretation – Under Alternative D, in addition to the actions and 

impacts stated in Alternative C, an on-site visitor center (instead of a visitor contact station) and a 

motorized interpretive tour route may be developed. These actions create a more developed Monument

triggering a revision to the CTTM Plan to include more or improved travel facilities. Alternative D would 

allow easier access to portions of the Monument, benefitting those that have low-clearance vehicles.

Those that enjoy the more challenging OHV routes would not see the improvements as an enhancement. 

Impacts from Recreation and Visitor Services – Impacts are the same as under Alternative C.

Impacts from Lands and Realty – Impacts are the same as under Alternative C.

Impacts from Lands with Wilderness Characteristics – Impacts are the same as under Alternative A.

Impacts from Visual Resources – Impacts are the same as under Alternative C.
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4.4.5 AIR RESOURCES

4.4.5.1 AIR QUALITY

Assumptions and Incomplete Information: Air quality data is limited within the Analysis Area and 

even more limited within the Planning Area. The New Mexico Environment Department has several air 

quality monitoring stations within Doña Ana County. Specific air quality data for specific events within 

the Monument are not available.

Management Decisions with No Impacts to Air Quality: The following resources or uses have no or 

little impact on Air Quality: Paleontological Resources, Education and Interpretation, Soils, Cultural 

Resources, Lands with Wilderness Characteristics, Socio-Economic Conditions, Soils, Special Status

Species, Special Designations, Visual Resources, Water Resources, and Wildlife.

Effects Common to All Alternatives:

Impacts from Vegetation – Managing and restoring the vegetation within the Monument could reduce 

soil erosion and thus reduce dust. However, using only passive means of vegetation restoration, as 

Alternative B states, would in most cases, take a much longer time to achieve the same or similar results 

as would active restoration projects.

IMPACTS OF THE ALTERNATIVES

4.4.5.1.1 ALTERNATIVE A

Impacts from Recreation and Visitor Services and Trails and Travel Management – Under 

Alternative A, motorized and mechanized vehicle use along approximately 37.6 miles of existing routes 

would result in localized dust and vehicle emissions. Most vehicle use would occur at low speeds in 

rough terrain along scoured canyon bottoms or across bedrock outcrops, which would not create 

measurable dust. Overall, air quality impacts from vehicle use would be minimal and short-term.

Impacts from Lands and Realty – Under Alternative A, land use authorizations that benefit the 

Monument would be considered, which may create ground disturbance and temporary impacts to air 

quality. Actions such as surface disturbing right-of-way construction could potentially impact air quality 

with short-term, localized degradation. Best management practices such as controlling erosion, 

minimizing surface disturbance, and using dust control measures would be implemented to reduce 

impacts to air quality. Under Alternative A, it is not proposed to acquire the 640 acres of subsurface acres 

that are not Federally-owned. This could potentially lead to development of the private minerals within 

the Monument, thus creating the possibility of air quality degradation from these mineral activities.

Impacts from Livestock Grazing – Under Alternative A, movement of the livestock across the 5,255

acres and use of the two-track routes by the livestock permittees may create dust when traversed, however 

the high rock content of the soil diminishes the opportunities for dust creation and this activity would 

have an adverse, but likely negligible impact on air quality.

Impacts from Wildland Fire Management – Although there are no fire management actions planned

under Alternative A, in the case of an unplanned fire there would be short-term and temporary 

degradation to air quality during the fire. The extent of the emissions would depend on the fuel source 

and amount of area burning.
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4.4.5.1.2 ALTERNATIVE B

Impacts from Recreation and Visitor Services – Under Alternative B, little or no measureable impacts 

to air quality are anticipated resulting from recreational visitor use. Prohibiting campfires would 

eliminate campfire smoke.

Impacts from Trails and Travel Management – Alternative B closes the Monument to all vehicle use 

and eliminates the opportunity for impacts on air quality resulting from vehicle emissions and localized 

dust.

Impacts from Lands and Realty – Under Alternative B, ground disturbing land use authorizations 

would not be permitted. Proposed in Alternative B is acquisition of the non-Federal, subsurface minerals 

totaling approximately 640 acres. By acquiring the subsurface minerals, it would remove the possibility 

of development of the private minerals within the Monument, thus eliminating the possibility of air 

quality degradation from these mineral activities.

Impacts from Livestock Grazing – Livestock use under Alternative B would not be allowed. This 

would reduce air quality impacts as compared to Alternative A. Cattle would not be disturbing the soil 

surface and vegetation quantities would be expected to increase; this would reduce dust emissions over 

the other alternatives.

Impacts from Wildland Fire Management – Under Alternative B, air quality impacts from possible 

wildland fire are the same as under Alternative A.

4.4.5.1.3 ALTERNATIVE C

Impacts from Recreation and Visitor Services – Under Alternative C, campfires would contribute to

air pollutant emissions in the region. Dust would occur during construction of a visitor center or visitor 

facilities; however, the impacts would be temporary and limited to the time of construction.

Impacts from Trails and Travel Management – Under Alternative C, permitted motorized vehicle use 

along approximately 26.9 miles of existing routes would result in localized dust and vehicle emissions. 

Most vehicle use would occur at low speeds in rough terrain and along arroyos. Overall, air quality 

impacts from vehicle use would be minimal and short-term.

Impacts from Lands and Realty – Under Alternative C, limited land use authorizations that benefit the 

Monument would be considered, which may create ground disturbance and temporary impacts to air 

quality. This would be comparable to the air quality impacts discussed in Alternative A. Impacts from 

acquisition of the non-Federal minerals are the same as for Alternative B.

Impacts from Livestock Grazing – Livestock use under Alternative C is similar to Alternative A except 

that grazing is excluded from specific locations such as proposed campsites and certain areas to protect 

paleontological resources. This would likely move the minimal air quality impacts to other areas within 

the Monument, which would create the same impacts as Alternative A.

Impacts from Wildland Fire Management – Under Alternative C, air quality impacts from possible 

wildland fire are the same as Alternative A.
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4.4.5.1.4 ALTERNATIVE D

Impacts from Recreation and Visitor Services – Under Alternative D, impacts from recreation and 

visitor services would be similar to Alternative C. Visitors to a visitor center would create more daily 

motorized traffic within the Monument. Emissions and dust from motorized traffic would increase with 

this Alternative as compared to Alternative A.

Impacts from Trails and Travel Management – Under Alternative D, impacts from trails and travel 

management would be similar to Alternative C. Motorized tour routes would create more daily motorized 

traffic within the Monument. Emissions and dust from motorized traffic would increase with this 

Alternative as compared to Alternative A.

Impacts from Lands and Realty – Under Alternative D, land use authorizations that benefit the 

Monument would be considered, which may create ground disturbance and temporary impacts to air 

quality. This would be comparable to the air quality impacts discussed under Alternatives A and C. 

Impacts from acquisition of the non-Federal minerals are the same as for Alternatives B and C.

Impacts from Livestock Grazing – Under Alternative D, impacts from livestock grazing on air quality 

would be similar to Alternative A.

Impacts from Wildland Fire Management – Under Alternative D, prescribed fire can be used as a 

management tool. Prescribed fire would impact air quality during the prescribed fire and after the 

prescribed fire until re-vegetation occurs that reduces windblown dust. The extent of the emissions would 

depend on the type and amount of fuel and size of fire. Air quality impacts would be minimized by using 

smoke management techniques.

4.4.5.2 CLIMATE

Assumptions and Incomplete Information: The assessment of greenhouse gas (GHG) emissions, their 

relationship to global climatic patterns, and the resulting impacts is an ongoing scientific process. The 

inconsistency in results of scientific models used to predict climate change at the global scale and the lack 

of scientific models capable of predicting climate change on regional or local scales, limit the ability to 

quantify potential future impacts of decisions made at this level. Determining the significance of any 

discrete amount of GHG emissions is beyond the limits of existing science. However, scientists are 

increasingly able to isolate likely scenarios for climate change and its impacts on a regional scale. The 

U.S. Global Change Research Program Report on Impacts of Climate Change in the United States (2009) 

focuses on broad areas of the country and greatest points of vulnerability as well as looking at Climate 

Change Impacts in different sectors of the economy. In the Southwest, a particular concern is the 

uncertainty around precipitation and the potential for extended periods of drought stressing already 

uncertain water supplies.

When further information on the impacts to climate change is known, such information would be 

incorporated into the BLM’s planning and NEPA documents as appropriate.

Management Decisions with No Impacts to Climate: The following resources or uses have no or 

little impact on Climate: Paleontological Resources, Education and Interpretation, Cultural Resources, 

Lands and Realty, Lands with Wilderness Characteristics, Soils, Special Status Species, Special 

Designations, Visual Resources, Water Resources, and Wildlife.
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Effects Common to All Alternatives: 

The impacts of each of the alternatives would be the same as related to climate.

Impacts from Trails and Travel Management and Livestock Grazing – Livestock, humans, and 

vehicle emissions may contribute to climate change through the increase or decrease of greenhouse gas 

emissions, but it is uncertain as to what degree these activities can make a discernible impact on climate 

change within the 5,255 acres.

Impacts from Wildland Fire Management – If a wildfire or prescribed fire occurred, it would result in 

greenhouse gas emissions, but the subsequent new vegetation may make up for this in carbon 

sequestration over time.
CULTURAL RESOURCES

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4.4.6 CULTURAL RESOURCES

Assumptions and Incomplete Information: The BLM cultural resource management program has been 

developed to comply with Federal law, implementing regulations, and other policies which address 

cultural resources and historic preservation. Impact analysis assumes that the program would be

implemented in accordance with BLM policy. The program consists of four elements: (1) inventory and 

evaluation, (2) protection and preservation, (3) cultural resource use allocation, and (4) planning.

The analysis assumes that BLM will continue the compliance aspect of the program by reviewing specific 

projects in accordance with Section 106 of the National Historic Preservation Act (NHPA). The BLM 

takes into account the potential effects on cultural resources that are eligible for the National Register of 

Historic Places (NRHP) and modifies proposed activities to avoid adverse effects to significant cultural 

resources, or reduces or mitigates adverse effects should avoidance not be possible.

Information about cultural resources within the PTNM is incomplete. No systematic, block inventory has 

been undertaken to identify and evaluate cultural resources. Class III inventory will be conducted in 

compliance with Section 106 of the NHPA as projects with the potential to adversely affect significant 

cultural resources are proposed.

Management Decisions with No Impacts to Cultural Resources: The following resources or uses 

have no or little impact on Cultural Resources: Education and Interpretation, Air Resources-Air Quality

and Climate, Geology/Minerals, Lands with Wilderness Characteristics, Socio-Economic Conditions, 

Soils, Special Designations-Area of Critical Environmental Concern, Wilderness Study Area, Research 

Natural Area, Special Status Species, Visual Resources, and Wildlife.

Effects Common to All Alternatives: Where new ground disturbance is proposed, the BLM will 

comply with Section 106 of the NHPA to inventory and evaluate cultural resources, and either modify the 

project to avoid adverse effects to significant cultural resources eligible for the NRHP or reduce or 

mitigate adverse effects where avoidance is not possible.

IMPACTS OF THE ALTERNATIVES

4.4.6.1 ALTERNATIVE A

Impacts from Paleontological Resources – Casual collecting of fossils is allowed. While collecting 

fossils, there is potential for cultural resources to be inadvertently or intentionally vandalized or stolen.

Impacts from Recreation and Visitor Services – Under Alternative A, dispersed camping is allowed. 

The location of any dispersed camping site with the Monument could impact cultural resources when the 

surface is disturbed to create a camp, which could displace artifacts. Dispersed camp sites could be 

subject to compliance with Section 106 of the NHPA if these sites become popular and heavily used.

Casual collecting of rock and mineral resources is allowed which may lead to cultural resources being

inadvertently or intentionally vandalized or stolen.

Impacts from Trails and Travel Management – Under Alternative A, the location of any existing or

new routes that could be maintained, improved, or developed would be subject to compliance under 

Section 106 of the NHPA in order to avoid adverse effects to cultural resources.
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Impacts from Lands and Realty – Under Alternative A, any proposed land use authorizations that 

allow surface disturbing activities would be subject to compliance with Section 106 of the NHPA. 

Projects proposed where cultural properties are found would be adjusted by means of mitigating the 

effects such as redesigning the project or changing the location.

Impacts from Livestock Grazing – The location for any proposed range improvements with the 

potential for ground disturbance would be subject to compliance with Section 106 of the NHPA. 

Building, maintaining, or removing fences, water systems, or other range improvements would potentially 

impact cultural resources. However, projects proposed where cultural properties are found would be 

adjusted by means of mitigating the effects such as redesigning the project or changing the location.

4.4.6.2 ALTERNATIVE B

Impacts from Paleontological Resources – No collecting of common invertebrate fossils would be 

allowed, which would nearly eliminate inadvertent collection of artifacts.

Impacts from Recreation and Visitor Services – Visitation to the Monument would probably decrease 

under this Alternative. The opportunity to encounter cultural resources would be limited and impacts to 

cultural resources would probably be minor.

Impacts from Trails and Travel Management – Closing the Monument to motorized and mechanized 

travel would reduce the number of visitors to the Monument so opportunities for encountering cultural 

resources would be limited. Vandalism and theft of cultural resources would be reduced substantially 

compared to the other Alternatives.

Impacts from Lands and Realty – Under Alternative C, surface-disturbing land use authorizations 

would be approved, therefore minimizing impacts to cultural resources from these activities.

Impacts from Livestock Grazing – The Monument would be closed to livestock grazing in Alternative 

B, therefore there would be no impacts to cultural resources expected from this activity.

Impacts from Vegetation – The passive methods of vegetation management proposed in Alternative B 

would not disturb soils and are not expected to impact cultural resources.

4.4.6.3 ALTERNATIVE C

Impacts from Paleontological Resources – Impacts of Alternative C would be the same as those 

described in Alternative B.

Impacts from Recreation and Visitor Services – Under Alternative C, designated camping areas, a 

visitor contact station, and visitor facilities are proposed. In conjunction with BLM authorized 

interpretive or educational activities and programs, limited collecting of rock and mineral resources would 

be allowed, which would limit the potential for vandalism or looting of cultural resources. These 

activities would be conducted under the supervision of staff or trained docents and volunteers who can 

discern rocks and minerals from artifacts. The location of any proposed primitive campground,

designated camping area, visitor contact station, or visitor facilities would be subject to compliance with 

Section 106 of the NHPA. The surface disturbance created by these proposed actions could potentially 

impact cultural resources. However, proposed projects where cultural properties are found would be 

adjusted by means of mitigating the effects such as redesigning the project or the changing the location.
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Impacts from Trails and Travel Management – The location of any existing or new routes that could 

be maintained, improved, or developed would be subject to compliance under Section 106 of the NHPA

in order to avoid adverse effects to cultural resources. Proposed projects where cultural properties are 

found would be adjusted to mitigate the effects such as redesigning the project or changing the location.

Impacts from Lands and Realty – Under Alternative C, impacts to cultural resources would be similar 

to those described under Alternative A and impacts stated in Effects Common to All Alternatives.

Impacts from Livestock Grazing – Impacts would be similar to those in Alternative A.

Impacts from Vegetation – Under Alternative C, manual removal of noxious weeds would be allowed, 

if necessary. The location for any proposed manual removal of noxious weeds and invasive species 

would be subject to compliance with Section 106 of the NHPA. The action that would allow the manual 

removal of noxious weeds and invasive species would be adjusted by means of mitigating the effects such 

as redesigning the project, so as to not create surface disturbance if cultural resources are found at the 

project site.

4.4.6.4 ALTERNATIVE D

Impacts from Paleontological Resources – Under Alternative D, collecting of common invertebrates in 

conjunction with a BLM authorized activity or program would be allowed but there is potential for 

cultural resources to be inadvertently or intentionally vandalized or stolen during this activity. This risk is 

less than Alternative A due to the activity being authorized and the collecting directed in a specific 

location supervised by individuals trained to discern fossils and minerals from artifacts.

Impacts from Recreation and Visitor Services – Pedestrian trails, kiosks and wayside exhibits,

campgrounds, and a full service visitor center are proposed. Casual collecting of rock and mineral 

resources is allowed also. While collecting these resources, there is potential for cultural resources to be 

inadvertently or intentionally vandalized or stolen from the Monument. The location of any proposed 

visitor facility would be subject to compliance under Section 106 of the NHPA. The actions that would 

allow new pedestrian trails, kiosks, wayside exhibits, campgrounds, and a full visitor center could 

potentially impact cultural resources. However, the project proposed where cultural properties are found 

would be adjusted by means of mitigating the effects such as redesigning the project or changing location.

Impacts from Trails and Travel Management – Impacts to cultural resources would be the same as 

those described in Alternative C.

Impacts from Land and Realty – Under Alternative D, impacts to cultural resources would be similar 

to those described under Alternative A and impacts stated in Effects Common to All Alternatives.

Impacts from Livestock Grazing – Impacts to cultural resources would be the same to those described 

in Alternative A and Alternative C.

Impacts from Vegetation – Impacts would be the same to those in Alternative C.

Impacts from Wildland Fire Management – The location of any proposed prescribed fire and 

mechanical thinning would be subject to compliance under Section 106 of the NHPA. The action that 

would allow prescribed fire and mechanical thinning could potentially impact cultural resources. 

However, the proposed projects where cultural properties are found would be adjusted by means of 

mitigating the effects such as redesigning the project or changing the location.
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4.4.7 LANDS AND REALTY

Assumptions and Incomplete Information: Any and all land use authorizations would include 

stipulations to avoid introducing noxious weeds into the Monument.

Management Decisions with No Impacts to Lands and Realty: The following resources or uses have 

no or little impact on Lands and Realty: Education and Interpretation, Trails and Travel Management, Air 

Resources, Cultural Resources, Livestock Grazing, Special Designations- Research Natural Area, Special 

Status Species, Vegetation Management, Wildland Fire Management, Wildlife.

Effects Common to All Alternatives: 

Impacts from Lands and Realty – Under all Alternatives, BLM would continue to acquire legal public

access easements for the PTNM. This would allow the BLM and public to have legal access into the 

PTNM.

Impacts from Special Designations -Area of Critical Environmental Concern – Under all 

Alternatives, rights-of-way are not authorized in the ACEC. These limitations on rights-of-way would 

reduce the number of acres available for rights-of-way in the Monument by about 789 acres.

IMPACTS OF THE ALTERNATIVES

4.4.7.1 ALTERNATIVE A

Impacts from Lands and Realty – Under Alternative A, the Monument legislation states that only those 

uses that benefit the Monument would be allowed. The private mineral estate located in the southern 

portion of the Monument would not be acquired, which could result in split-estate issues. This would be 

incompatible with management of the public land within the PTNM. Land use authorizations (both 

surface disturbing and non-surface disturbing) would be authorized on a case-by-case basis following 

NEPA analysis consistent with Monument goals and objectives.

4.4.7.2 ALTERNATIVE B

Impacts from Recreation and Visitor Services – Under Alternative B, there would be no management 

actions that would impact lands and realty.

Impacts from Lands and Realty – Under Alternative B, surface disturbing authorizations would not be 

authorized. Non-surface disturbing activities could be authorized. This would allow authorizations such 

as film permits in the Monument, which could be a benefit to the promotion of the resources and 

scientific research.

The BLM would attempt to acquire non-Federal minerals located in section 36, T. 23 S., R. 1 W., to 

reduce possible surface disturbance associated with mineral development which would be incompatible 

with management of the PTNM. As a result of acquiring the non-Federal minerals, the BLM would have 

jurisdiction over both the surface and subsurface.

Impacts from Lands with Wilderness Characteristics – Under Alternative B, approximately 576 acres 

of land within the Monument would be managed for wilderness characteristics. One of the management 

prescriptions is to manage this area as an exclusion area for rights-of-ways. This would eliminate those 
LANDS AND REALTY

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576 acres from being available for rights-of-ways, but does not eliminate them from all land use 

authorizations. For example, film permits proposing no surface disturbance could be permitted under

Alternative B. Although this limits the type of land use authorizations permitted within these 576 acres, it 

allows management of the area to be consistent with the goals and objectives of lands with wilderness 

characteristics. 

Impacts from Soils – Under Alternative B, surface disturbing activities would not be authorized. Soil 

resources would not be altered or impaired.

Impacts from Visual Resources – Under Alternative B, the portion of the Monument outside of the 

special designation areas would be managed as VRM Class I (1,365 acres). The rest of the Monument 

would be managed as VRM Class II. In Alternative B, surface disturbing land use authorizations are not 

allowed, so there would be no impacts from visual resources on the Lands and Realty program.

4.4.7.3 ALTERNATIVE C

Impacts from Recreation and Visitor Services – Under Alternative C, impacts from the Recreation and 

Visitor Services program could include the need for authorizing rights-of-way (electricity, water, roads) 

to service the proposed visitor facilities.

Impacts from Lands and Realty – Under Alternative C, land use authorizations (both surface 

disturbing and non-surface disturbing) would be considered if consistent with Monument goals and 

objectives. Acquisition of access easements for public use would facilitate public and administrative 

access.

Impacts from acquiring the 640 acres of non-Federal mineral estate within and adjacent to the Monument 

in section 36, T. 23 S., R. 1 W., are the same as Alternative B.

Impacts from Lands with Wilderness Characteristics – Under Alternative C, approximately 253 acres 

of land within the Monument would be managed for wilderness characteristics and rights-of-way would 

be excluded. Film permits proposing no surface disturbance would be considered as would other nonsurface disturbing activities. Although this limits the types of land use authorizations permitted within 

these 253 acres, it allows management of the area to be consistent with the goals and objectives of lands 

with wilderness characteristics.

Impacts from Visual Resources – Under Alternative C, the area designated as the Robledo Mountains 

WSA and ACEC, and the lands with wilderness characteristics would be managed as VRM Class I (1,042 

acres) by preserving the existing character of the landscape and allowing impacts to the landscape to have 

little or no change to the visual environment. The rest of the Monument would be managed as VRM 

Class II by retaining the existing character of the landscape and allowing the level of change to the 

landscape to be low and not attract attention of the casual observer. Prior to construction of any visitor 

facilities, an activity and site development would be completed, which would explore opportunities of

appropriate locations for facilities and would follow the Visual Resource Management Objectives. 

Therefore, authorizations would be designed as to not impair these visual qualities.

Impacts from Soils – Under Alternative C, realty actions such as right-of-way or land use authorization 

would be allowed. Rights-of-way could cause adverse impacts to soils from surface disturbances. Each 

lands and realty action would require mitigation on a case-by-case basis due to varying impacts associated 

with action type, size, and location.
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4.4.7.4 ALTERNATIVE D

Impacts from Recreation and Visitor Services – The impacts are the same as under Alternative C.

Impacts from Lands and Realty – The impacts are the same as under Alternative C.

Impacts from Lands with Wilderness Characteristics – Under Alternative D, lands found to have 

wilderness characteristics would not be managed for their wilderness characteristics. Rights-of-way, 

access, and other land use authorizations would not be constrained by managing for wilderness 

characteristics.

Impacts from Visual Resources – Under Alternative D, the area designated as the Robledo Mountains 

WSA and ACEC would be managed as VRM Class I (789 acres). The rest of the Monument would be 

managed as VRM Class II. These impacts are the same as for Alternative C.

Impacts from Soils – Under Alternative D, the impacts are the same as those stated in Alternatives A 

and C.
LANDS WITH WILDERNESS CHARACTERISTICS

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4.4.8 LANDS WITH WILDERNESS CHARACTERISTICS

Assumptions and Incomplete Information: Wilderness characteristic values include the area’s size, its 

naturalness, and outstanding opportunities for solitude or a primitive and unconfined recreation. They 

may also include supplemental values. Lands with wilderness characteristics are those lands that have 

been inventoried and determined by the BLM to contain wilderness characteristics as defined in section 

2(c) of the Wilderness Act (Public Law 88-577). In 2011, the wilderness inventory was updated for the 

Monument. This inventory identified 576 acres of land contiguous to the Robledo Mountains WSA 

within the Monument as having wilderness characteristics.

Management Decisions with No Impacts to Lands with Wilderness Characteristics: The 

following resources or uses have little or no impact on those Lands with Wilderness Characteristics: Air 

Resources, Cultural Resources, Grazing, Special Status Species, Visual Resources, Vegetation, Water 

Resources, and Wildlife.

IMPACTS OF THE ALTERNATIVES

4.4.8.1 ALTERNATIVE A

Under Alternative A, 576 acres are identified as having wilderness characteristics, but are not protected 

from actions that would diminish those characteristics. However, there are no activities planned under 

Alternative A for those 576 acres that would impact the wilderness characteristics of these lands.

4.4.8.2 ALTERNATIVE B

Under Alternative B, approximately 576 acres would be protected for wilderness characteristics. There 

are no resource management actions that would cause impacts that would detract from the wilderness 

characteristics of these 576 acres. All resource management actions stated under Alternative B would be 

complementary to protecting wilderness characteristics.

4.4.8.3 ALTERNATIVE C

Under Alternative C, approximately 253 acres would be identified and protected as lands with wilderness 

characteristics. Approximately 323 acres of land identified during the 2011 inventory would not be 

managed to protect wilderness characteristics. There are no planned resource management actions that 

would cause impacts that would detract from the wilderness characteristics of the 253 acres.

Impacts from Paleontological Resources - Under Alternative C, approximately 323 acres of lands with 

wilderness characteristics would not be managed for wilderness characteristics and could be utilized for 

paleontology studies and excavations.

Impacts from Education and Interpretation – Under Alternative C, development of a hiking trail 

system with kiosks would occur. In order to interpret the Discovery Site properly, a trail and signage 

would be necessary on the land not protected for its wilderness characteristics. The human impacts on the 

323 acres may be noticeable.

Impacts from Recreation and Visitor Services – Under Alternative C, designated camping areas, 

hiking trails, visitor contact station, and visitor facilities are proposed. These recreational trails and 
LANDS WITH WILDERNESS CHARACTERISTICS

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facilities could be placed on the 323 acres outside of the protected lands with wilderness characteristics.

However, doing so may potentially impact wilderness characteristics in those areas.

Impacts from Trails and Travel Management – Under Alternative C, new routes and trails could be 

constructed and existing routes could be maintained or improved. This alternative would allow for a trail 

to be constructed or maintained to the Discovery Site, which is the boundary for those acres managed as

lands with wilderness characteristics. Alternative C allows for man-made intrusions on the area outside 

of the protected 253 acres.

Impacts from Lands and Realty – Under Alternative C, surface disturbing land use would be 

authorized on those lands not protected for wilderness characteristics following NEPA analysis. Surface 

disturbing land use authorizations may impact the wilderness characteristics

4.4.8.4 ALTERNATIVE D

Under Alternative D, lands with wilderness characteristics would not be managed to protect those 

wilderness characteristics, and therefore the wilderness characteristics may be impacted.

Impacts from Paleontological Resources – The 576 acres not protected for wilderness characteristics 

could be utilized as appropriate areas for paleontological research, interpretation and other activities.

Impacts from Education and Interpretation – Under Alternative D, the impacts are the same as

Alternative C except the proposed actions may impact 576 acres not protected for wilderness 

characteristics.

Impacts from Recreation and Visitor Services – Under Alternative D, the impacts are the same as 

Alternative C except the proposed actions may impact 576 acres not protected for wilderness 

characteristics. 

Impacts from Trails and Travel Management – Under Alternative D, the impacts are the same as 

Alternative C except the impacts may occur on 576 acres not protected for wilderness characteristics.

Impacts from Lands and Realty – Under Alternative D, the impacts are the same as Alternative C 

except surface disturbing activities may occur and impact 576 acres not protected for wilderness 

characteristics.
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4.4.9 LIVESTOCK GRAZING

Assumptions and Incomplete Information: It is assumed that visitation to the PTNM would increase 

over time.

Management Decisions with No Impacts to Livestock Grazing: The following resources or uses 

have no or little impact on Livestock Grazing: Paleontological Resources, Education and Interpretation, 

Air Resources, Cultural Resources, Lands and Realty, Soils, Special Designations- Research Natural 

Area, Special Status Species, Visual Resources, Water Resources, and Wildlife.

Effects Common to All Alternatives:

Impacts from Special Designations-WSA – Under all Alternatives, the continued management of the 

ACEC designation would limit the construction of new range improvements such as fences, watering 

facilities, pipelines, and erosion control structures. This could limit the ability to change the management 

of the area such as creating new pastures for rest-rotation grazing.

Impacts from Wildland Fire Management – Under all Alternatives, improvements would be protected 

from all fire by preplanned defendable space and fire suppression tactics as needed. Even though, these 

precautions would be taken, wildfires could damage or destroy range improvements such as watering 

facilities and fences, and could result in injury or death of livestock. In the event of a wildland fire, 

grazing deferment would potentially occur, which would impact livestock operations. Livestock would 

have to be removed from the burned area; the grazing permittees would then have to find another location 

for the livestock or reduce their number of livestock until the grazing deferment is complete.

IMPACTS OF THE ALTERNATIVES

4.4.9.1 ALTERNATIVE A

Impacts from Recreation and Visitor Services – Under Alternative A, visitor facilities would be 

minimal. With the designation of the Monument, it is assumed that the number of visitors would increase

and increased recreational use by visitors could result in conflicts with livestock and allotment 

management goals. Visitors congregating around livestock waters would directly conflict with livestock 

watering needs. Vandalism, carelessness or abuse by visitors could result in damage to range 

improvements including fences, watering facilities, and pipelines, which would in turn interfere with the 

proper management of livestock.

Impacts from Trails and Travel Management – The designated routes would continue to exist for 

motorized, mechanized, and pedestrian travel and their use is expected to increase. This may lead to a

potential increase in collisions with vehicles resulting in associated property damage and injury to visitors 

or livestock. Livestock operators would be permitted to use motorized vehicles on designated routes. 

This would allow for the operators to maintain range improvements and care for livestock with motorized 

vehicles, on foot, or horseback.

Impacts from Livestock Grazing – Under Alternative A, grazing would continue on both the Picacho 

Peak and Altamira Ranch Allotments. Range improvements would continue to exist on the Picacho Peak 

Allotment, which are authorized under Section 4 range improvement permits and cooperative agreements. 

Range improvement permits grant title and maintenance responsibility to the grazing permittee, while 

cooperative agreements provide shared title between the permittee and BLM. The goal of improvements 
LIVESTOCK GRAZING

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to the range infrastructure would be to improve distribution of cattle, promote rangeland health, and 

maintain or enhance forage production. The authorization of future range improvements would be 

prioritized based on a cost-benefit analysis. The continued maintenance and functionality of these 

improvements is important to maintain an even distribution of the grazing pressure associated with cattle 

grazing and provide water sources for wildlife.

Impacts from Lands with Wilderness Characteristics – Under Alternative A, there are no designated 

lands with wilderness characteristics, so there are no impacts to livestock grazing.

Impacts from Vegetation – Under Alternative A, chemical herbicides could be used to control noxious 

weeds. Introduced exotic and native weeds would compete with desired native plant species for water 

and nutrients if not controlled. It is probable that continued shrub encroachment would result in further 

competition for water and nutrients with perennial forage species. Increased competition for resources 

could ultimately lead to reductions in grass cover and forage available for livestock use.

4.4.9.2 ALTERNATIVE B

Impacts from Livestock Grazing – Under Alternative B, The BLM would not authorize livestock to 

graze in the PTNM. This alternative would require that the grazing permittees for the Picacho Peak and 

Altamira allotments control their cattle so that they do not graze within the Monument. In the absence of 

fence, this would entail active herding by the permittees in addition to shutting off the water that is piped 

to the troughs located within the PTNM. If the BLM in conjunction with grazing permittees constructed a 

Monument boundary fence in lieu of active herding and water control, this would exclude livestock from 

the Monument and leave the surrounding public lands available to livestock. Management guidelines for 

the Robledo Mountains WSA would create challenges for fencing the Monument boundary for those 

areas inside the WSA. If fence construction was selected as the tool to exclude livestock from the 

Monument, minor fence reroutes of the pasture fence dividing the north and south pastures of the Picacho 

Peak Allotment would be necessary to fully exclude approximately 150 acres in the southern part of the 

Monument from the remainder of the allotment. Additional fence might also be needed to define the 

Monument boundary. The perimeter of the PTNM is approximately 14.5 miles in length. Of this length, 

approximately 0.75 miles of existing fence parallels the Monument boundary. Approximately 1.3 miles 

of pasture fence would need removal or need to be rerouted. In total, approximately 13.75 miles of fence 

would need to be constructed to define the entire Monument boundary, and ensure grazing from the 

surrounding allotments would be excluded. Assuming an estimate of $3.20 per foot on construction of a 

wire fence in rough terrain (from the 2011 practice cost data from the Natural Resources Conservation 

Service [NRCS 2011]), excluding livestock grazing from the Monument through use of fencing would 

cost approximately $232,320 to be incurred by the BLM or the BLM and permittee(s).

Overall, exclusion of grazing in the Monument would result in the need to adjust allotment boundaries of 

the two allotments within the Monument. Removing livestock grazing from the Monument would 

eliminate approximately 4,505 acres from the north pasture on the Picacho Peak Allotment; without 

changes to allotment infrastructure, this would make the north pasture virtually unusable since the 

remaining parcels would be very small and would be separated by the Monument. Ultimately, since there 

is only one other pasture that is actively used on the allotment, this would result in decreased flexibility 

for the grazing permittee, removing the ability to defer areas from grazing without additional changes to 

the allotment infrastructure. Also, reductions to the number of cattle that could responsibly graze on the

allotment would need to be made from the reduced acreage on the allotment, having a direct economic 

impact on the livestock operations for the grazing permittee. There would be a decrease in carrying 

capacity of 395 AUMs or 33 cattle yearlong for the Picacho Peak Allotment. In addition, nearly all of the

livestock watering points and pipelines in the north pasture of the Picacho Peak Allotment are within the 
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Monument boundary. The majority of range improvement projects in the Monument are currently 

authorized under range improvement permits that grant title and maintenance responsibility to the grazing 

permittee. The Robledo Interior Fence and the Robledo Pipeline are authorized under cooperative 

agreements, where title is shared between the contributing grazing permittee and the BLM, and 

maintenance responsibility belongs to the grazing permittee. If grazing were discontinued within the 

Monument, the United States would be required to compensate the permittee for their share of the value 

of the range improvements in accordance with the grazing regulations (43 CFR 4120.3-6). The permittee 

may be allowed to remove the range improvements authorized under a range improvement permit, which 

would include salvaging materials and performing site rehabilitation where needed as a result of ground 

disturbance from removing these improvements.

Exclusion of livestock from the Monument would have less impact on current management trends for the 

Altamira Allotment. There would be a loss of approximately 748 acres available to grazing, which would 

result in reductions to the allotment carrying capacity. The loss of these acres would equate to a decrease 

in carrying capacity of approximately 61 AUMs or 5 cattle yearlong on the Altamira Allotment. This 

would result in direct financial impacts to the grazing permittee from the loss of forage.

No range improvement projects are authorized on the Altamira Allotment within the Monument 

boundary. Much of the Altamira Allotment lies within the Robledo Mountains WSA, where ground 

disturbing activities are largely prohibited. Should the permittee decide to plan livestock water to 

increase the ability of livestock to make use of forage in the southern part of this allotment, the 

Wilderness Study Area would reduce the amount of land available for construction of new improvements 

in the Monument approximately by half.

4.4.9.3 ALTERNATIVE C

Impacts from Recreation and Visitor Services – Visitor facilities would expand and grazing may be

excluded from these sites resulting in minor decreases in acreage available for forage. Projects that 

involve reducing the acreage available to grazing would be individually analyzed for site-specific impacts 

to livestock grazing and if applicable, changes to carrying capacity.

Impacts from Trails and Travel Management – Under Alternative C, improvement of designated 

routes or construction of new routes could increase motorized use of the Monument, which would result 

in the increase for potential conflicts between livestock and motorized vehicle users. More interaction 

between livestock and humans or vehicles increases the chances of livestock and visitors getting hurt or 

livestock improvements getting damaged. Livestock operators would be permitted to use motorized 

vehicles on designated routes. This would allow for the operators to maintain range improvements and 

care for livestock with motorized vehicles, on foot, or horseback.

Impacts from Livestock Grazing – Under Alternative C, adjustments could be made to the allotment 

management plan in consultation with the grazing permittee to aid in management of the Monument. 

Adjustments to allotment management would be necessary if exclusion areas were created in order to 

minimize contact between livestock and recreational areas that would see heavy use by Monument 

visitors; these adjustments to the allotment management plan would be needed if changes were warranted 

in season of use, prescribed grazing systems, or livestock numbers as a result of creating exclusion areas 

that alter grazing patterns. Range improvements would be authorized in a manner consistent with 

Alternative A in order to promote rangeland health and maintain or enhance forage production. 

Improvements would be designed to enhance Monument management objectives and minimize potential 

conflicts with other resources and uses.
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Impacts from Lands with Wilderness Characteristics – Under Alternative C, approximately 253 acres

would be managed for wilderness characteristics. Within these 253 acres, surface disturbing range 

improvements and motorized and mechanized vehicle use would not be allowed.

Impacts from Vegetation – Under Alternative C, integrated management techniques including passive, 

manual, biological, chemical, and mechanical treatment methods to manage noxious weeds and nonnative invasive species would be used. This would limit the competition between noxious weeds or nonnative invasive species with desired forage thus increasing desired forage for livestock. Particular sites 

within the Monument would be managed for multiple-use values while maintaining or enhancing habitat 

for special status species.

4.4.9.4 ALTERNATIVE D

Impacts from Recreation and Visitor Services – Impacts to livestock grazing from Recreation and 

Visitor Services under this Alternative would be the same as those described under Alternative C.

Impacts from Trails and Travel Management – Impacts to livestock grazing from Trails and Travel 

Management under this Alternative would be the same as those described under Alternative C.

Impacts from Livestock Grazing – Under Alternative D, effects of livestock management would be the 

same as those described in Alternative A.

Impacts from Lands with Wilderness Characteristics – Under Alternative D, impacts to livestock 

grazing from lands with wilderness characteristics are the same as described under Alternative A.

Impacts from Vegetation – Under Alternative D, integrated management techniques including passive, 

manual, fire, biological, chemical, and mechanical treatment methods to manage noxious weeds and nonnative invasive species would be used. This would limit the competition between noxious weeds or nonnative invasive species with desired forage thus increasing desired forage for livestock. Particular sites 

within the Monument would be managed for emphasizing commodity uses while maintaining or 

enhancing habitat for special status species.

Impacts from Wildland Fire Management – Under Alternative D, fire could be used as a vegetation 

management tool. Grazing deferments would be necessary to accumulate fine fuels in preparation of a 

prescribed fire, and also following a fire to help protect vegetation and soil stability afterward. Grazing 

deferments would impact typical livestock operations on the Picacho Peak Allotment by reducing 

flexibility in pasture rotation since there are only two active pastures on the Allotment. Any deferments 

in the north pasture for fire treatments to manage the Monument would either result in rotating livestock 

into the south pasture or moving them to privately-owned or leased lands elsewhere for the duration of the 

required deferment period. Any additional livestock use in the south pasture would result in increases to

grazing pressure on vegetation, particularly around water sources.
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4.4.10 SOCIO-ECONOMIC CONDITIONS

Data Sources:

Economic effects were modeled using IMPLAN Professional Version 3.0 and the Forest Economic 

Analysis Spreadsheet Tool (FEAST), with 2009 data. Data on use levels under each alternative were 

collected from the PTNM’s resource specialists. In most instances, the precise change is unknown. 

Therefore, the changes are based on the professional expertise of the resource specialists.

A financial efficiency analysis is conducted for the Livestock Grazing and Recreation and Visitor 

Services programs. A financial efficiency analysis compares costs (expenditures) and benefits (revenues) 

over time. Costs and benefits that accrue in future years are adjusted using a 4 percent discount rate. This 

analysis does not account for all costs and benefits associated with public land management. The public 

value of recreating at a fee-free site, for instance, is not captured in this analysis. Non-monetary costs and 

benefits are described qualitatively in the social analysis.

Social effects use the baseline social conditions presented in the Affected Environment Section, visitor 

information from the Recreation Section of this analysis, and information from the Community 

Socioeconomic Workshops (Preister 2003) to discern the primary values that the Monument provides to 

area residents and visitors. Social effects are based on the interaction of the identified values with 

estimated changes to resource availability and uses. The social analysis addresses effects to non-market 

values, consistent with IM 2013-131 (BLM 2013).

Assumptions and Incomplete Information: 

1. The economic impact of grazing was estimated using authorized levels. However, actual 

livestock use occurring within the Monument varies annually based on a number of factors, such 

as current forage and market conditions. The impact of recent management trends are reported.

2. Changes in use levels were estimated using professional judgment. However, precise changes in 

use are not possible to predict.

3. Some of the value of public land management is not captured in market transactions. Non-market 

goods and services, such as clean air and scenic vistas, have economic values. However, the 

monetary values of such goods and services are generally unknown. As a result, it is difficult to 

analyze potential tradeoffs between market and non-market values.

4. Data on the distribution of visitors among expenditure segment shares (i.e., local and non-local; 

overnight and day) is unavailable for the Monument. Therefore, segment shares from the Lincoln 

National Forest are applied to the total Monument visitation estimates. The economic impact 

analysis uses National data on average visitor spending by segment share on National Forests, 

since no equivalent data exist for BLM-managed land.

5. Organized OHV events affected by route closures would continue to take place on adjacent or 

nearby public lands.

6. It is assumed that visitors to the Monument for the purpose of recreation and scientific research 

would steadily increase over the life of the Plan, regardless of the chosen alternative.

7. The Community Socioeconomic Workshop report (Preister 2003) identifies a number of values 

related to public land in Doña Ana County, including: (a) public land access, (b) diverse and 

plentiful recreation opportunities, (c) ecological health, (d) preservation of traditional and cultural 

uses of public land, (e) community and economic development. These are assumed to be the key 

social values related to public land management in the Analysis Area.
SOCIO-ECONOMIC CONDITIONS

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Management Decisions with No Impacts to Social and Economic Conditions: Under all 

Alternatives, the following programs would have little or no impact to Socio-Economic Conditions: Air 

Resources, Cultural Resources, Lands and Realty, Soils, Special Status Species, Vegetation Management, 

Water Resources, and Wildlife.

Effects Common to All Alternatives:

Impacts to Environmental Justice – The majority (65.7 percent) of residents in Doña Ana County 

identify as Hispanic or Latino (U.S. Census Bureau 2010). The County also has a high incidence of 

poverty, with approximately one-quarter of residents living in poverty. However, an analysis of the 

decisions to be made under the Alternatives did not identify environmental justice consequences. None of 

the decisions are expected to disproportionately or adversely affect environmental justice communities.

Consequences to social values are analyzed within the Alternatives. Although quality of life associated 

with Monument uses may vary between Alternatives, none of these changes are expected to 

disproportionately affect Hispanic and Latino residents.

American Indian uses and traditional cultural practices will not be affected by any planning decisions.

IMPACTS OF THE ALTERNATIVES

4.4.10.1 ALTERNATIVE A

Impacts from Paleontological Resources and Scientific Values – The unique paleontological 

resources of the Monument drive much of the visitation. The economic impact of visitor spending is 

captured in the impacts from the Recreation and Visitor Services discussion, below. In addition to the 

contribution of paleontological resources to local economic activity, these resources provide social and 

non-market values. Degradation of fossils is expected to occur under Alternative A due to motorized use 

and casual collection. This loss of resources would reduce non-market values related to education and 

scientific discovery. 

Impacts from Education and Interpretation – Under Alternative A, most of the interpretation and 

education related to the Monument would continue to occur off-site. Minimal signage and on-site 

interpretive opportunities are less likely to support values related to education. As a result, non-market 

values related to the preservation and dissemination of scientific knowledge are expected to be lower 

under Alternative A, relative to the other Alternatives. 

Impacts from Recreation and Visitor Services – An estimated 25,000 people (10,000 party-trips) 

would visit the Monument each year under Alternative A. Visitor spending would support approximately 

16 jobs and $417,000 in labor income in the local economy on an average annual basis. Most of the 

employment and income would occur in the accommodation and food services sector. 

Management of the recreation program in the Monument costs approximately $135,000 annually. The 

Monument collects no visitor fees and recreation-related revenue is limited to cost-recovery of 

approximately $4,500 associated with one special recreation permit, which is issued annually. Over the 

20-year life of the Plan, using a 4 percent discount rate, the present net value of the recreation program on 

the Monument is -$1,843,760. This analysis only considers financial costs and benefits accruing to the 

agency. The employment and income associated with these expenditures is captured in the impacts from 

the BLM expenditures analysis, below. 
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Impacts from Trails and Travel Management – Under Alternative A, non-permitted and permitted use 

by motorized and mechanized vehicles would continue on approximately 37.6 miles of trails and routes 

previously designated. Alternative A offers the most miles of trails and routes among the considered 

Alternatives. Residents and visitors who hold social values related to public land access and OHV 

recreation would benefit from Alternative A. However, a number of comments in the Preister (2003) 

report expressed concern that motorized and mechanized recreation on public land disturbs ecological 

health and reduces the quality of the recreation experience for non-motorized users.

More opportunities for motorized and mechanized recreation may make the Monument more attractive to 

some individuals and less attractive to others. Visitation to the Monument from all types of recreation 

users contributes to economic activity in the local area. The economic consequences of trail and travel 

management are captured in the impacts from the Recreation and Visitor Services analysis, above. 

Impacts from Livestock Grazing – Alternative A would continue current livestock grazing 

management, with 456 permitted AUMs within the Monument boundary. However, the current stocking 

rate is considerably less. With over 1.5 million cattle and calves in New Mexico, the AUMs on the 

PTNM account for a very small portion of the livestock farming and ranching sector in the State (NASS 

2011). As a result, less than one job and between $6,000 and $11,000 (depending on stocking rate) in 

labor income would be supported by grazing on the Monument, annually.

Management of the grazing program in the Monument costs approximately $18,000 annually. Fees for 

the grazing that occur on the Monument total approximately $615 annually. Over the 20-year life of the 

Plan, using a 4 percent discount rate, the present net value of the grazing program on the Monument is

-$245,180. This analysis only considers financial costs and benefits accruing to the agency. The 

employment and income associated with these expenditures is captured in the impacts from the BLM 

expenditures analysis, below.

Impacts from Lands with Wilderness Characteristics – Under Alternative A, no lands with wilderness 

characteristics are being managed within the Monument. As described in the Trails and Travel 

Management section above, Alternative A is expected to provide the highest value for individuals who 

prefer to maximize access to the public land and minimize restrictions on use. However, individuals who 

value the protection of cultural and paleontological resources, outstanding opportunities for solitude, and 

the protection of ecological integrity would be less likely to benefit from management under 

Alternative A.

Impacts from BLM Expenditures – Salary and non-salary (e.g., equipment) expenditures related to 

Monument management support approximately 5 jobs and $287,000 in labor income in the local 

economy, annually.

Payments from the Monument to states and counties (e.g., PILT) total approximately $13,000. These 

payments contribute to State and local budgets. Due to the relatively small size of these payments, less 

than one job and approximately $8,000 in labor income would be supported in the local economy, 

annually.

4.4.10.2 ALTERNATIVE B

Impacts from Paleontological Resources and Scientific Values -- Alternative B would only permit the 

collection of paleontological resources in connection with authorized scientific research on the 

Monument. As a result, Alternative B is expected to reduce the loss of scientific information associated 

with fossils. The elimination of motorized and mechanized recreation and grazing on the Monument 

would also reduce fossil degradation. While these limits would promote non-market values related to 
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protection of sensitive resources and promotion of scientific inquiry, they may reduce other non-market 

values. For instance, the elimination of motorized and mechanized access may reduce the number of 

individuals who are able to observe and enjoy the paleontological resources of the Monument.

Impacts from Education and Interpretation—Similar to Alternative A, most of the education and 

interpretive activities related to the Monument would occur off-site. The elimination of casual fossil 

collection may reduce the quality of the experience for some individuals who value a tangible reminder of 

their experience. However, this decrease in value is expected to be more than offset by the educational 

and enjoyment value of protecting the Monument’s resources for present and future generations. 

Impacts from Recreation and Visitor Services—Due to the elimination of motorized and mechanized 

recreation opportunities under Alternative B, visitation is expected to be reduced to 5,625 annual visitors 

(2,250 party-trips). Visitor spending would support approximately 4 jobs and $94,000 in labor income in 

the local economy on an average annual basis. Most of the employment and income would occur in the 

accommodation and food services sector. 

Recreation-related program expenditures would continue to be approximately $135,000 annually. The 

elimination of motorized recreation would eliminate recreation-related revenue. Therefore, over the 

20-year life of the Plan, using a 4 percent discount rate, the present net value of the recreation program on 

the Monument is -$1,908,080. This analysis only considers financial costs and benefits accruing to the 

agency. The employment and income associated with these expenditures is captured in the impacts from 

the BLM expenditures analysis below.

Impacts from Trails and Travel Management – Under Alternative B, the Monument would be closed 

to all motorized and mechanized use except administrative and emergency motorized use. Alternative B 

offers the fewest miles of roads and trails open to motorized and mechanized use. The closure of the 

Monument to all recreational motorized and mechanized uses would reduce quality of life for individuals 

who primarily value public land access and OHV recreation opportunities. The selection of Alternative B 

would make the Monument a less attractive recreation destination for motorized and mechanized 

recreationists. As a result, some individuals would likely choose to recreate elsewhere or stay home. 

This would reduce the economic impact of recreation on the public land in the local economy. However, 

since a number of individuals stated that motorized recreation reduced the quality of their experiences of 

public land (Preister 2003), the elimination of motorized and mechanized recreation on the Monument 

may make it a more attractive destination for non-motorized uses. The net economic impact of recreation 

is described in the impacts from recreation and visitor services analysis, above.

Impacts from Livestock Grazing – Alternative B would eliminate livestock grazing on the Monument. 

No grazing-related employment or labor income would be supported by activities on the Monument. The 

economic effect of this change would be very minor in the context of the local economy; there would be 

social consequences. The ranchers who use the Picacho Peak and Altamira Ranch Allotments would need 

to replace the lost forage. Since private forage is more costly than public land forage, the ranchers’ 

operating costs would increase (NASS 2011). In addition, some individuals associate public land grazing 

with cultural and heritage values. The loss of grazing opportunities on public land, therefore, would 

reduce the quality of life for individuals who hold such values. Some individuals prefer the elimination of 

grazing and other commercial activities on public land. Individuals with these values would prefer 

Alternative B.

Impacts from Lands with Wilderness Characteristics – Alternative B would manage 576 acres (11

percent) of the Monument for wilderness characteristics. Alternative B would manage the highest 

proportion of the Monument for wilderness characteristics among the considered Alternatives. Therefore, 

Alternative B would be most likely to increase non-market economic values. Alternative B would appeal 
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to individuals who are primarily concerned with protecting wilderness characteristics and having 

outstanding opportunities for solitude and/or primitive and confined recreation.

Impacts from BLM Expenditures – Salary and non-salary (e.g., equipment) expenditures related to 

Monument management support approximately 5 jobs and $287,000 in labor income in the local 

economy, annually.

Payments from the Monument to states and counties (e.g., PILT) total approximately $13,000. These 

payments contribute to State and local budgets. Due to the relatively small size of these payments, less 

than one job and approximately $8,000 in labor income would be supported in the local economy, 

annually.

4.4.10.3 ALTERNATIVE C

Impacts from Paleontological Resources and Scientific Values – The development of a visitor contact 

station under Alternative C would increase public understanding and appreciation of the paleontological 

resources of the Monument. This is expected to increase non-market values related to education, as more 

people are exposed to the Monument’s unique resources. However, increased visitation may also increase 

the risk of theft and vandalism, which would reduce values related to the protection of sensitive resources 

and opportunities for scientific inquiry. 

Impacts from Education and Interpretation – Alternative C would develop more educational and 

interpretive opportunities on-site, relative to Alternatives A and B. The economic effect of these actions, 

along with other management actions meant to improve the quality of the visitor experience, is captured 

in the impacts from Recreation and Visitor Services analysis below. Increased educational opportunities 

may also promote non-market values related to the dissemination of production of scientific knowledge. 

Furthermore, more interpretive opportunities may increase appreciation of the resources, and therefore, 

both increase social values related to the unique resources of the Monument and limit the risk of theft and 

vandalism, discussed above.

Impacts from Recreation and Visitor Services – A visitor contact station would be developed under 

Alternative C. Annual visitation is expected to increase to 37,500 people (15,000 party-trips) under 

Alternative C. Visitor spending would support approximately 24 jobs and $626,000 in labor income in 

the local economy on an average annual basis. Most of the employment and income would occur in the 

accommodation and food services sector.

The expected cost for the station is outlined in the Recreation and Visitor Services Section (Section 

4.4.3). During site construction, approximately 2.4 jobs and $91,750 in labor income would be 

contributed to the local economy. The visitor contact station would not require additional staffing, 

therefore, no additional jobs would be supported during the operations and maintenance phase. Periodic 

road and site maintenance would contribute to the local economy; however, expected expenditures are 

minimal.

Recreation-related program expenditures would increase during the construction of the visitor contact 

station. Therefore, over the 20-year life of the Plan, using a 4 percent discount rate, the present net value 

of the recreation program on the Monument is -$2,061,260. This analysis only considers financial costs 

and benefits accruing to the agency. The employment and income associated with these expenditures is 

captured in the impacts from BLM expenditures analysis, below and the construction impacts, above. 
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Impacts from Trails and Travel Management – Under Alternative C, Tabasco Twister Trail (2.7

miles) and Patzcuaro’s Revenge Trail (1.8 miles) would be closed to motorized and mechanized vehicle 

use. One un-named route from the intersection of Cayenne Crawler and Pasado to Sandia Gulch would 

be closed (0.5 mile). Cayenne Crawler Trail (0.4 mile) would be closed to motorized and mechanized use 

to eliminate access from the south to Patzcuaro’s Revenge Trail Alternative C would leave the majority 

of the designated routes and trails available under Alternative A open to motorized and mechanized uses. 

The popularity of Tabasco Twister and Patzcuaro’s Revenge trails may discourage some visitation to the 

Monument from off-highway vehicle users However, the reduction in visitor spending associated with 

this change is expected to be more than offset by increased visitation due to the development of a visitor 

contact station, as described in the impacts from Recreation and Visitor Services analysis. The economic 

consequences of visitor spending associated with trails and travel management are captured in the impacts 

from Recreation and Visitor Services portion of this analysis, above.

In social terms, Alternative C would balance some of the conflicting interests related to public land 

management. Specifically, Alternative C would continue to support public land access and diverse 

recreation opportunities while also reducing damage to natural and cultural resources. Nevertheless, 

individuals who use the Monument chiefly for motorized and mechanized use may have their values 

compromised, relative to current conditions.

Impacts from Livestock Grazing – Alternative C would continue to permit cattle grazing. Although, as 

with Alternative A, actual use may be expected to be lower depending on forage and market conditions. 

With over 1.5 million cattle and calves in New Mexico, the AUMs on the PTNM make up a very small 

portion of the livestock farming and ranching sector in the State (NASS 2011). As a result, less than one 

job and between $6,000 and $11,000 (depending on stocking rate) in labor income would be supported, 

annually.

The present net value of the grazing program would be the same as described under Alternative A.

Impacts from Lands with Wilderness Characteristics – Alternative C would manage 253 acres (5

percent) of the Monument for wilderness characteristics. Alternative C would manage the second-highest 

proportion of the Monument for wilderness characteristics among the considered Alternatives. This 

Alternative would balance the interests of individuals who value ecological preservation of the public 

land with the interests of individuals who primarily value access and motorized recreation opportunities. 

Alternative C would increase non-market economic values related to ecological health relative to 

Alternatives A and D.

Impacts from BLM Expenditures – Salary and non-salary (e.g., equipment) expenditures related to 

Monument management support approximately 5 jobs and $287,000 in labor income in the local 

economy, annually. The construction and maintenance of the visitor contact station is excluded from 

these estimates, since these effects are captured in the impacts from the Recreation and Visitor Services 

analysis, above.

Payments from the Monument to states and counties (e.g., PILT) total approximately $13,000. These 

payments contribute to State and local budgets. Due to the relatively small size of these payments, less 

than one job and approximately $8,000 in labor income would be supported in the local economy, 

annually.

4.4.10.4 ALTERNATIVE D

Impacts from Paleontological Resources and Scientific Values – The social and economic 

consequences of paleontological resources are expected to be similar to those described under Alternative 
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C. The development of a visitor center would drive additional use to the Monument, which is analyzed in 

the impacts from the Recreation and Visitor Services section, below.

Impacts from Education and Interpretation – The social and economic consequences of interpretation 

and education are expected to be similar to those described under Alternative C. The development of a 

visitor center would provide more opportunities for education and interpretation on-site, which may 

increase social and non-market values as more people are exposed to the unique resources of the 

Monument. 

Impacts from Recreation and Visitor Services – A visitor center would be developed under 

Alternative D. Annual visitation is expected to increase to 75,000 people (30,000 party-trips) under 

Alternative D. Visitor spending would support approximately 47 jobs and $1,251,000 in labor income in 

the local economy on an average annual basis. Most of the employment and income would occur in the 

accommodation and food services sector. The expected cost for the center is outlined in the Recreation 

and Visitor Services Section (Section 4.4.3).

The expected cost for the center is outlined in the Recreation and Visitor Services Section (Section 4.4.3). 

During the construction phase, approximately 22 jobs and $830,300 in labor income would be contributed 

to the local economy. Throughout operations and maintenance of the facility, additional staff would be 

required to manage the visitor center. Staffing of the visitor center would support slightly more than one 

job and $33,000 in labor income in the local economy, annually.

Recreation-related program expenditures would increase due to the construction of the visitor center and 

the need for staff. Over the 20-year life of the Plan, using a 4 percent discount rate, the present net value 

of the recreation program on the Monument is -$4,224,120. This analysis only considers financial costs 

and benefits accruing to the agency. The employment and income associated with these expenses is 

captured in the impacts from the BLM expenditures analysis, below, and the construction impacts, above. 

Impacts from Trails and Travel Management – Impacts would be the same as under Alternative C 

except that the Cayenne Crawler Trail (0.4 miles) would be left open for motorized and mechanized use 

and modified to allow motorized and mechanized use on 0.9 miles of Patzcuaro’s Revenge Trail. The 

difference between Alternative C and Alternative D is small in terms of the total available routes that the 

social and economic impacts are not expected to differ measurably between these alternatives. The 

difference in expected recreation use between Alternatives C and D is driven by the development of a 

visitor center, as opposed to a contact station, under Alternative D.

Impacts from Livestock Grazing – Impacts would be the same as Alternative A.

Impacts from Lands with Wilderness Characteristics – Alternative D would manage 0 acres (0

percent) of the Monument for wilderness characteristics. Alternative D would manage the same number 

of acres for wilderness characteristics as Alternative A; therefore, the social and economic impacts 

discussed under Alternative A also apply to Alternative D.

Impacts from BLM Expenditures – Salary and non-salary (e.g., equipment) expenditures related to 

PTNM management support approximately 5 jobs and $287,000 in labor income in the local economy, 

annually. The construction and maintenance of the visitor center is excluded from these estimates.

Payments from the Monument to states and counties (e.g., PILT) total approximately $13,000. These 

payments contribute to State and local budgets. Less than one job and approximately $8,000 in labor 

income would be supported in the local economy, annually.
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4.4.11 SOILS

Assumptions and Incomplete Information: 

Soil resources would be managed to meet New Mexico Standards for Public Land Health and Guidelines 

for Livestock Grazing Management (New Mexico Standards and Guidelines).

Soils would be managed to minimize erosion and maintain soil productivity.

Surface disturbance of soil, including compaction of soil or loss of vegetation cover, might increase water 

runoff and downstream sediment loads and lower soil productivity, which may degrade water quality, 

alter channel structure, and affect overall watershed health.

The degree of impact attributed to any one disturbance or series of disturbances would be influenced by 

several factors, including location within the watershed, soil characteristics, time and type and degree of 

disturbance, existing vegetation type and quantities, and climatic conditions.

The greatest anticipated impacts on soil resources would occur from surface disturbance associated with 

paleontological resources, trails and travel management, livestock grazing, and recreation and visitor 

services. Management actions would be designed to minimize impacts by implementing BMPs and other 

site-specific protection measures. These measures often cause localized, short-term, site-specific impacts 

on soil resources, but are designed to maintain soil productivity and stability in the long-term. Restricting

or prohibiting surface disturbance would often help maintain or improve soil conditions.

Management Decisions with No Impacts to Soils: The following resources or uses have little or no

impact on Soil Resources for all Alternatives: Air Resources – Air Quality and Climate Change, Cultural 

Resources, Geology/Minerals, Lands with Wilderness Characteristics, Special Designations, Special 

Status Species, Visual Resources, Water Resources, and Wildlife.

Effects Common to All Alternatives:

Impacts from Vegetation Management – Under all Alternatives, the impacts from Vegetation would 

have very similar effects on soil resources. All of the Alternatives would have positive impacts to the 

soils by reducing and managing noxious weeds and non-native invasive plant species and promoting 

healthy native plant communities. This would enhance infiltration, increase soil moisture and organic 

content, and promote soil productivity and stabilization.

IMPACTS OF THE ALTERNATIVES

4.4.11.1 ALTERNATIVE A

Impacts from Paleontological Resources and Scientific Values – The Paleontology Program would 

continue to permit and support the on-going research within the PTNM, including excavation of fossils. 

Excavations may cause localized highly disturbed areas. Many of the past excavations within the PTNM 

have been on relatively steep slopes where erosion potentials are the highest. Mitigation measures are 

generally adequate for stabilizing these soils after excavation, but soil loss on steep slopes, void of 

vegetation, is inevitable. However, these activities are typically small in scale and have had little impact 

to the watershed as a whole. Casual collecting of paleontological resources would result in minor surface 

disturbance at infrequent intervals from foot traffic and hand tools.
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Impacts from Education and Interpretation – Under Alternative A, minor soil disturbance would 

occur along designated trails at infrequent intervals associated with BLM or partner-led interpretive tours. 

Disturbances would primarily be in the form of foot traffic from small groups of people.

Impacts from Recreation and Visitor Services – Under Alternative A, dispersed camping could cause 

localized removal of vegetation and compaction of the soil leading to increased runoff and erosion. 

Although impacts from camp sites are generally isolated and small, no restrictions on camping locations 

could result in multiple camp sites cumulatively adversely impacting a greater area. Commercial, 

competitive and organized group activities would be administered through the SRP program. Each event 

permitted through the SRP would require mitigation on a case-by-case basis due to varying impacts 

associated with event type, size, and location.

Impacts from Trails and Travel Management – Under Alternative A, designated routes would be 

available for motorized or mechanized use. Many of these routes are in the bottom of arroyos. Colluvial 

deposits along the slopes of the canyons are easily eroded and could be damaged by impacts from both 

vehicles and spectators. This degradation is caused by both non-permitted use and permitted events. 

BLM monitoring of the 2008 and 2009 Chile Challenge Trails Tour confirmed that visitor and spectator 

use of canyon slopes for event viewing resulted in creation of new trails, dislocation and displacement of 

soils and large cobbles and damage to vegetation. OHV trails are primarily located along canyon bottoms 

and ridge tops that are relatively resistant to erosion. These areas have essentially been compacted, 

devoid of vegetation and soil, and have very low potential for natural recovery. Petroleum product spill 

would contaminate soils in various locations along OHV routes reducing soil productivity and potentially 

lower vegetation densities in the long-term. However, the volume of fluid spilled at any given location is 

typically small (less than 1 gallon). Where “braided” routes (i.e., routes that are used to get around an 

inoperative vehicle or obstacle) are created, vegetation is crushed and soils are disturbed or compressed. 

These impacts contribute to increased susceptibility to erosion and sediment load during water runoff. 

Localized site mitigation measures would be employed to reduce or stop slope and channel erosion and 

degradation of site-specific important fossil bearing formations from OHV activities. Proper mitigation 

measures could reduce localized sediment movement from slopes and channels caused by OHV activities.

Impacts from Lands and Realty – Under Alternative A, realty actions such as right-of-way or land use 

authorization would be allowed. Authorizations of rights-of-way could cause adverse impacts to soils 

from surface disturbances. Each lands and realty action would require mitigation on a case-by-case basis 

due to varying impacts associated with action type, size, and location.

Impacts from Livestock Grazing – Under Alternative A, grazing would continue within the Monument. 

High impact areas around livestock watering facilities would continue to have less vegetation cover,

which reduces water infiltration and increases water runoff. Soils would be more compacted around 

watering points and water infiltration rates would be reduced decreasing soil moisture contents. This 

would cause localized soil erosion from alluvial and eolian processes. Maintenance of existing structural 

improvements (e. g., pipeline and troughs) and potential new improvements could result in surface 

disturbance. These disturbances would likely cause localized short-term soil loss and degradation. 

Utilization of vegetation from cattle would reduce plant cover; increasing bare ground and decreasing soil 

moisture. This would increase the likelihood of soil movement. However, the high surface rock content 

is the primary soil stabilization factor and overall erosion associated with livestock should be slight.

Impacts from Wildland Fire Management – Under Alternative A, management tools such as 

prescribed fire and mechanical thinning would not be considered for use in the Monument. Fire 

suppression tactics that cause surface disturbance could cause localized short-term impacts to soil in 

wildland urban interface areas.
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4.4.11.2 ALTERNATIVE B

Impacts from Paleontological Resources and Scientific Values – Under Alternative B, the impacts are 

similar as described under Alternative A. However, under this Alternative, soil disturbance would be 

slightly less with the closure of the PTNM to casual collecting of common invertebrates and plant fossil 

resources. These actions would cause less surface disturbance relative to Alternative A.

Impacts from Education and Interpretation – Under Alternative B, impacts to soils from Education 

and Interpretation are the same as described under Alternative A.

Impacts from Recreation and Visitor Services – Under Alternative B, camping would not be allowed 

within the Monument. Current camp sites would be rehabilitated and allowed to recover to the natural 

surroundings over time, which would reduce impacts to soils such as compaction and erosion. SRPs

would not be permitted, so there would be no impacts from such events as previously permitted.

Impacts from Trails and Travel Management – Under Alternative B, closing the PTNM to motorized 

and mechanized vehicles would have fewer impacts on soil resources than Alternative A. Recreational 

OHVs would not be traveling on trails, and no new trails would be created. This would decrease soil 

disturbances. However, these routes, which mostly are in arroyos, have little potential for recovery due to 

natural flash floods and the overall slow nature of soil formation processes in semi-arid climates. Natural 

rehabilitation of the trails would be a very long process.

Impacts from Lands and Realty – Under Alternative B, surface disturbing activities would not be 

authorized. Soil resources would not be altered or impaired.

Impacts from Livestock Grazing – Under Alternative B, removal of grazing from these allotments

would provide less impact to soils, such as less compaction around waters and trails. Additionally, 

removal of grazing from the Monument would decrease the utilization of vegetation; this would result in 

greater amounts of biomass remaining, potentially resulting in higher infiltration rates and increased soil 

moisture. The degree to which vegetation maintains or improves infiltration and soil moisture, with 

respect to potential vegetation increases, would depend on factors such as precipitation, the current 

location, density and type(s) of vegetation present, future growth rates, potential increases of ground 

cover, and types of vegetation that become established.

Impacts from Wildland Fire Management – Under Alternative B, impacts to soils from wildland fire 

management are the same as described under Alternative A.

4.4.11.3 ALTERNATIVE C

Impacts from Paleontological Resources and Scientific Values – Under Alternative C, impacts to soils 

from paleontological resources are the same as described under Alternative A.

Impacts from Education and Interpretation – Under Alternative C, impacts to soils from 

interpretation and education are the same as described under Alternative A.

Impacts from Recreation and Visitor Services – Under Alternative C, designated primitive campsites 

would be established. Impacts from camping would be similar to Alternative A; however, primitive 

campsites would reduce the impacts to soil compared to dispersed camping. Designating specific 

campsites would control the locations resulting in better managed and maintained camping facilities. 

Visitor facilities such as toilets, shade shelters, kiosks, picnic sites, and parking lots would result in 
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ground clearing and compaction activities. This would remove vegetation, compact soil, alter the natural 

topography, decrease infiltration and increase surface water runoff and erosion rates. The magnitude of 

these effects from a specific action would greatly depend upon the size, location, current climatic 

conditions and soil type for any given surface disturbing activities. 

Impacts from activities through the SRP program would be the same as Alternative A.

Impacts from Trails and Travel Management – Under Alternative C, impacts to soil resources would 

be similar to, but slightly less than Alternative A. The nature of impacts to soils would be the same, but 

the length of designated trails would be less. In total, 5.4 miles of routes would be closed to motorized 

and mechanized vehicles and the same long-term impacts would occur to soils as identified in Alternative 

B. Increased visitation and foot traffic could lead to accelerated erosion and slope destabilization in the 

areas that are heavily visited. With well-placed, properly engineered and marked trails, impacts would be 

monitored and stabilizing mitigation measures would be used before damage occurs.

Impacts from Lands and Realty – Under Alternative C, impacts to soils from lands and realty are the 

same as described under Alternative A.

Impacts from Livestock Grazing – Under Alternative C, impacts to soils from livestock grazing are the 

same as described under Alternative A.

Impacts from Wildland Fire Management – Under Alternative C, impacts to soils from wildland fire 

management are the same as described under Alternative A.

4.4.11.4 ALTERNATIVE D

Impacts from Paleontological Resources and Scientific Values – Under Alternative D, impacts to soils 

from paleontological resources are the same as described under Alternative B.

Impacts from Education and Interpretation – Under Alternative D, impacts to soils from 

interpretation and education are the same as described under Alternative A.

Impacts from Recreation and Visitor Services – Under Alternative D, developed campgrounds along 

with designated primitive camping sites would have greater impacts than Alternatives A, B, and C due to 

larger areas of surface disturbance and compaction. All other impacts from actions initiated by recreation 

and visitor services would be the same as Alternative C.

Impacts from Trails and Travel Management – Under Alternative D, the nature of the impacts to soils 

from trails and travel management are the same as described under Alternative A. However, 4.0 miles of 

existing designated routes would be closed to motorized and mechanized vehicles. Along these closed 

routes, the same long-term impacts would occur to soils, as those identified in Alternative B.

Impacts from Lands and Realty – Impacts to soils are the same as described under Alternative A.

Impacts from Livestock Grazing – Impacts to soils are the same as described under Alternative A.

Impacts from Wildland Fire Management – Under Alternative D, prescribed fire and mechanical 

thinning are allowed as management tools if deemed necessary in the future. Fire suppression tactics and 

mechanical thinning that cause surface disturbance would cause localized short-term impacts to soil.
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4.4.12 SPECIAL DESIGNATIONS

4.4.12.1 AREA OF CRITICAL ENVIRONMENTAL CONCERN

Assumptions and Incomplete Information: The PTNM legislation states “The establishment of the 

Monument shall not change the management status of any area within the boundary of the Monument that 

is –(B) managed as an area of critical environment concern.”

Management Decisions with No Impacts to Special Designations – ACEC: The proposed BLM 

management decisions in the Alternatives would not result in impacts that would alter the characteristics 

for which the ACEC was designated (significant paleontological, cultural, and scenic values, and high 

diversity of cacti species).

4.4.12.2 RESEARCH NATURAL AREA

Management Decisions with No Impacts to Special Designations-RNA: See discussion below in 

“Effects Common to All Alternatives.”

Effects Common to All Alternatives: Management actions for all resources and uses would be similar 

on the land within the Monument whether it has the Paleozoic Trackways RNA designation (Alternative 

A) or the RNA designation removed (Alternatives B, C, and D). The Monument designation duplicates 

the management goals of the RNA; protect, research, and interpret paleontological values to the entire 

Monument. Therefore, the RNA designation and management actions are redundant and not necessary.

4.4.12.3 WILDERNESS STUDY AREA

Assumptions and Incomplete Information: The PTNM legislation “The establishment of the 

Monument shall not change the management status of any area within the boundary of the Monument that 

is – (A) designated as a wilderness study area and managed in accordance with section 603(c) of the 

Federal Land Policy and Management Act of 1976 (43 U.S.C. 1782(c).” 

The Robledo Mountains WSA would be managed to preserve its wilderness characteristics so as not to 

impair the area’s suitability for wilderness designation. All proposed actions within the WSA must 

follow the Management of Wilderness Study Areas Manual 6330.

Management Decisions with No Impacts to Special Designations-WSA: The following resources or 

Monument uses have little or no impact on the Robledo Mountains WSA: Paleontological Resources, Air 

Resources, Cultural Resources, Special Management Areas- Area of Critical Environmental Concern and 

Research Natural Area, Special Status Species, Visual Resources, Water Resources, and Wildlife.

Effects Common to All Alternatives: No alternatives considered would result in impairment to the 

WSA.
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4.4.13 SPECIAL STATUS SPECIES

Assumptions and Incomplete Information: There is only one recorded occurrence of a special status 

plant (night-blooming cereus) near the Monument and a substantial amount of habitat for this plant occurs 

throughout the Monument. If there were losses, they would be at an individual level rather than the entire 

population.

Prior to any construction, a field survey would be completed and any special status species found within 

the construction site would be avoided or mitigated.

If additional special status species are designated or discovered, or critical habitat is designated on the 

Monument, the BLM would adopt subsequent recovery plans or species specific guidance. 

Management Decisions with No Impacts to Special Status Species: The following resources or uses 

have little or no impact on Special Status Species: Paleontology, Air Quality and Climate Change, 

Cultural Resources, Lands and Realty, Socio-Economic Conditions, Soils, Special Designations- Area of 

Critical Environmental Concern and Research Natural Area, Visual Resources, and Water Resources.

IMPACTS OF THE ALTERNATIVES

4.4.13.1 ALTERNATIVE A

Impacts from Education and Interpretation – Under Alternative A, there would be no management 

actions for interpretation and education that would impact special status species.

Impacts from Trails and Travel Management – Under Alternative A, there are approximately 37.6

miles of motorized and mechanized routes and 5.3 miles of trail for mechanized vehicle use only open 

year-round. Authorized use of those routes could potentially cause injury or mortality of slow moving 

special status animals such as Texas horned lizards that may inhabit areas near these routes. Special status 

bat species would not be impacted as there are no suitable roosting habitat near routes. Burrowing owls 

and loggerhead shrikes may temporarily vacate areas near routes that are being used. Traffic that may be 

present on these routes would not be occur regularly and would not permanently displace special status 

species that would potentially inhabit areas adjacent to the routes. No impacts would be expected on 

night-blooming cereus plants as they do not occur in disturbed areas such as trails and routes that would 

be open under Alternative A.

Impacts from Livestock Grazing – Under Alternative A, livestock grazing would continue within the 

Monument and livestock grazing improvements would continue to function. Grazing improvements such 

as water facilities would benefit special status animals due to continued availability of water in an area in 

which water would not naturally occur. Trampling of night-blooming cereus may occur, but it is unlikely 

as livestock do not congregate in creosote shrublands which is primarily where night-blooming cereus is 

likely to occur. If any mortality of night-blooming cereus takes place, it would be at an individual level 

and not at a population wide scale. Special status bats that may occur in the Monument would potentially 

utilize the earthen reservoirs during times when water would be present. Bats would potentially forage 

for flying insects that may be present around the tanks during the summer months. Troughs would be 

utilized more throughout the year as they would hold water in times when earthen reservoirs or dirt tanks 

may be dry. Troughs would be fitted with wildlife escape ramps to prevent drowning of bats that may fall 

into troughs. Impacts to special status birds and reptiles would be minimal as they currently coexist with 

livestock and typically avoid areas of high concentrations of livestock such as troughs.
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Impacts from Vegetation – Chemical herbicides would be used to control noxious weeds within the 

Monument, including existing populations and those that may be introduced over time. Herbicides would 

also be used to treat areas where mesquite or creosotebush have become out of balance with the desired 

plant community and are competing with desirable native plant species. Any vegetation treatments that 

may occur would benefit special status animals by increasing forage and improving grassland habitat.

Due to its association with creosote and mesquite, night-blooming cereus may be affected by large scale 

vegetation treatments. Although some individual plants may suffer mortality, the entire local population 

would not be harmed. Surveys of the treatment areas would also take place and any special status plants 

identified would be buffered from treatment. Bats would not be impacted by chemical treatments as they 

do not use the habitats that contain large amounts of shrubs that would be treated. Over time as grasses 

are expected to move into treatment areas, more insects would be expected to be present during wet 

periods during the late summer and early fall. These insects would be a valuable food source for 

burrowing owls, loggerhead shrikes, and Texas horned lizards.

Impacts from Wildland Fire Management – Under Alternative A, there would be no management 

actions for wildland fire management that would impact special status species.

4.4.13.2 ALTERNATIVE B

Impacts from Education and Interpretation – Under Alternative B, there would be no management 

actions for interpretation and education that would impact special status species.

Impacts from Recreation and Visitor Services – Under Alternative B, recreational use of the 

Monument under Alternative B would be limited to hunting, hiking, and sightseeing. This use would 

temporarily disturb special status species such as burrowing owls, loggerhead shrikes, and Texas horned 

lizards in general. Increased human presence would also potentially bring about harassment and potential 

illegal collection of Texas horned lizards. No camping would be allowed; therefore, displacement would 

be limited to day-use associated with dispersed recreation. This temporarily displaces special status 

species in areas where the recreation is occurring. There is only one recorded occurrence of a special 

status plant (night-blooming cereus) near the Monument and a substantial amount of habitat for this plant 

occurs throughout the Monument that if there were losses, they would be at an individual level rather than 

the entire population. SRP events would not be allowed, thus the impacts from those events would not 

occur. Special status bats would not be impacted because they are primarily active at night when 

recreation impacts would not be occurring. 

Impacts from Trails and Travel Management – Motorized and mechanized use would be prohibited 

thus minimizing the chance of slow moving special status species such as Texas horned lizards to be 

injured on and near travel routes. No impacts would occur to other special status species.

Impacts from Livestock Grazing – Under Alternative B, livestock grazing would not continue within 

the Monument. Availability of forage for species such as burrowing owls, loggerhead shrikes, and Texas 

horned lizards and cover would increase as grasses and forbs would be expected to increase in certain 

areas. This would be beneficial to these special status species. Artificial water sources and earthen 

reservoirs would be maintained by the BLM primarily for wildlife use. Should pipelines and troughs be 

retained for use by wildlife, modifications to the facilities may be needed, or a new water source would 

need to be found to supply water to these facilities, as the existing source is a well on private land not 

under the jurisdiction or control of the BLM. These water sources would continue to be available for bats 

to forage over and drink out of. Troughs would be fitted with wildlife escape ramps to prevent drowning 

of bats that may fall into these troughs. Night-blooming cereus plants that may occur in areas frequented 

by livestock would be under no threat of trampling by cattle.
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Impacts from Vegetation – Impacts to special status species from vegetation management under this 

Alternative would be similar to those outlined under Alternative A. Passive treatment methods would 

allow for finer scaled treatment of target species such as creosote and mesquite, and impacts to night 

blooming cereus that would occur with chemical treatments would be avoided. If biological methods of 

controlling the brush were used, impacts to night-blooming cereus would be the same as in Alternative A. 

No impacts to other special status species would occur. 

Impacts from Wildland Fire Management – Under Alternative B, there would be no management 

actions for wildland fire management that would impact special status species.

4.4.13.3 ALTERNATIVE C

Impacts from Education and Interpretation – Under Alternative C, pedestrian trails and interpretation 

kiosks would be developed. This would potentially bring an increase in human traffic causing special 

status animal species such as burrowing owls, loggerhead shrikes, and Texas horned lizards to

temporarily vacate the area near the trails and kiosks. No impacts on bats or night-blooming cereus 

would occur as the interpretive kiosks and pedestrian trails would not be constructed where habitat is 

present.

Impacts from Recreation and Visitor Services – Visitor facilities such as toilets, shade shelters, 

information kiosks, trail markers, and picnic sites would be developed and maintained. This could 

displace special status species such as burrowing owls, loggerhead shrikes, and Texas horned lizards that 

may inhabit the area where these facilities would be built and used. Dispersed recreation would continue 

and also continue to temporarily displace these special status species in areas where the recreation is 

occurring. The establishment of a primitive campground would displace any special status species that 

inhabits the area where the campground would be built. An increase in human activity would temporarily 

cause some special status species to vacate areas frequented by humans. Increased human presence 

would also potentially bring about harassment and potential illegal collection of Texas horned lizards. 

Special status bats may roost in newly-constructed facilities and may become a nuisance, but as bats are 

mostly active at night, these impacts would be minimal. 

Impacts from Trails and Travel Management – Under Alternative C, there are approximately 26.9

miles of motorized and mechanized routes and 5.3 miles of trails for mechanized vehicles only (such as 

bikes) open for use. Due to the use allowed on certain routes, there would be potential for slow moving 

special status species to be injured on and near travel routes. This risk would increase during SRP events 

where a greater number of vehicles or people would be on the routes. Impacts to special status species 

would be similar to impacts discussed in Alternative A.

Impacts from Livestock Grazing – Under Alternative C, grazing would continue except where 

excluded to protect paleontological resources, campsites, or other specified locations where other 

unresolved resource conflicts arise. Grazing improvements such as water facilities would benefit special 

status species due to continued availability of water in an area in which water would not naturally occur.

Trampling of night-blooming cereus may occur, but it is unlikely as livestock do not congregate in 

creosote shrublands which is primarily where night-blooming cereus is likely to occur. If any mortality of 

night-blooming cereus takes place, it would be at an individual level and not at a population wide scale. 

Impacts would be similar to those discussed in Alternative A, however if areas are excluded from grazing, 

impacts at those locations would be the same as Alternative B. 

Impacts from Vegetation – Impacts to special status species from vegetation management under this 

Alternative would be similar to those outlined under Alternative A.
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Impacts from Wildland Fire Management – Under Alternative C, there would be no management 

actions for wildland fire management that would impact special status species.

4.4.13.4 ALTERNATIVE D

Impacts from Education and Interpretation – Development of kiosks would bring an increase in 

human traffic causing special status species to temporarily vacate the area near the trails and kiosks.

Impacts would be similar to Alternative C.

Impacts from Recreation and Visitor Services – Under Alternative D, development of pedestrian trails 

would potentially bring an increase in human traffic causing special status species to temporarily vacate 

the area near the trails. Impacts would be similar to Alternative C. The establishment of an on-site visitor 

center would displace special status species from the site chosen for the visitor center. Activities 

associated with the construction of the visitor center could potentially lead to mortality of slow moving 

special status species such as Texas horned lizards which are unable to quickly vacate the area. 

Recreational use of the Monument under Alternative D would lead to a possibility of the establishment of 

a developed campground which would displace any special status species that inhabits the area where the 

campground would be built.

Impacts from Trails and Travel Management – Under Alternative D, new routes or trails could be 

constructed and maintained. There are approximately 28.3 miles of motorized and mechanized routes and 

5.3 miles of trails for mechanized use only proposed for use. The establishment of new routes or trails 

would create a potential for slow moving special status species to be injured or killed on and near travel 

routes. Vehicular use of the Monument would not be prohibited therefore there would be potential for 

slow moving special status species to be injured on and near travel routes. This risk would increase 

during special events where a greater number of vehicles would be utilizing the routes. Impacts would be 

similar to Alternative A.

Impacts from Livestock Grazing – Under Alternative D, impacts to special status species from 

livestock grazing are the same as described under Alternative A.

Impacts from Vegetation – Under Alternative D, impacts to special status species from vegetation 

management would be the same as those outlined under Alternative A.

Impacts from Wildland Fire Management – Under Alternative D, prescribed fire is allowed as a 

management tool. Prescribed fire could displace, kill, and render habitat unsuitable for special status 

species for longer durations of time than a one-time event, road construction, or some other short duration 

disturbing activity. The long-term positive benefits of prescribed fire to the overall ecosystem would be 

substantial.
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4.4.14 VEGETATION

Assumptions and Incomplete Information: It is assumed that under Alternatives A, C, and D, visitation 

would steadily increase over the life of the Plan.

Management Decisions with No Impacts to Vegetation: The following resources or uses have little or 

no impact on Vegetation: Paleontological Resources, Education and Interpretation, Air Resources, 

Cultural Resources, Lands and Realty, Special Designations, Visual Resources, and Water Resources.

Effects Common to All Alternatives

Impacts from Vegetation – Under all Alternatives, plant collecting without a permit is not allowed 

within the Monument. By not allowing plant collecting, this would help to protect native vegetation 

diversity and abundance directly benefiting wildlife, and helping protect the soil from erosion.

Impacts from Special Designations – The ACEC and WSA designations limit surface disturbance.

Impacts from Education and Interpretation – Under all Alternatives, impacts to vegetation would be 

impacted by tours to fossil sites. Inadvertent trampling of vegetation by groups would occur along

designated trails and at interpretive sites.

Impacts from Wildland Fire Management – Under all Alternatives, fires would be suppressed and 

hazardous fuels would be treated in wildland urban interface areas. Under the current fire management 

direction for the Robledo Mountains, vegetation would be disturbed by wildfires and fire suppression 

activities.

IMPACTS OF THE ALTERNATIVES

4.4.14.1 ALTERNATIVE A

Impacts from Education and Interpretation– Under Alternative A, interpretive facilities would not be 

developed so there would be no loss of vegetation that would result from the installation of structures, 

signs, exhibits and trails. Self-guided interpretive activities could result in the trampling of vegetation 

since visitor access routes would be limited and more cross-country access could occur.

Impacts from Recreation and Visitor Services – Under Alternative A, increased visitor use would 

likely result in disturbance to vegetation through hiking cross-country, and could result in the introduction 

and spread of noxious and invasive weeds through vehicles or clothes contaminated by weed seeds.

Impacts from Trails and Travel Management – Under Alternative A, the existing routes would 

continue to be used for motorized, mechanized, and pedestrian travel. Designated routes within the 

Monument are also used by the grazing permittee for managing cattle and maintaining range 

improvements. Activities associated with the use of these trails and roads would have the potential to 

remove or damage vegetation within and adjacent to these routes. The potential exists for vehicles and 

hikers to introduce and contribute to the spread of noxious and invasive weeds. Typically this can occur 

when people and vehicles travel through weed infested areas, and seeds are picked up and become stuck 

to vehicles and clothing. Subsequently, seeds can then drop in areas free of weed infestations. Soil 

disturbance from vehicles traveling off of existing roads can create areas more susceptible to invasion by 

noxious weeds.
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Impacts from Lands and Realty – Under Alternative A, vegetation disturbance including damage or 

removal would occur within or adjacent to surface disturbing authorizations. Development of nonFederal minerals would result in further vegetation disturbance.

Impact from Lands with Wilderness Characteristics – Under Alternative A, no lands with wilderness 

characteristics within the Monument would be managed for those characteristics. Surface disturbing 

activities are allowed and may potentially impact vegetation.

Impacts from Livestock Grazing – Under Alternative A, livestock would continue to graze public land 

forage. A total of 456 AUMs of forage have been allotted to livestock on the public land within the 

Monument on an annual basis. Due to the rugged terrain, and the location of water and supplements, 

cattle distribution and forage utilization would not be uniform across the entire Monument. Areas where 

livestock congregate, particularly in the vicinity of livestock waters, typically experience a higher impact 

to vegetation than other areas that are further from these water sources. Research in the Chihuahuan 

Desert indicates that biomass of perennial grasses can be reduced up to 1,000 meters from water (Fusco et 

al. 1995). As the distance from water increases, these impacts are reduced as livestock become more 

dispersed throughout the landscape.

Currently, livestock that graze in the majority of the Monument are managed under a deferred-rotation 

grazing system as prescribed in the Picacho Peak Allotment Management Plan. Under this Plan, forage 

utilization targets have been established, where use would not exceed 50 percent of the current year’s

growth for most perennial grass species. For black grama, maximum forage utilization allowed is more 

restrictive at 40 percent use for the north pasture and 35 percent in the south pasture. Since the revision 

of the management plan in 1997, the allotment has been stocked at a maximum of 58 percent of the 

permitted carrying capacity, thus actual forage removed has been substantially lower than the maximum 

allowed. Reductions in actual numbers of livestock on the allotment have been made voluntarily to allow 

for conservation of forage resources when possible and to respond to decreased production as a result of 

periodic drought conditions.

The southern part of the Altamira Allotment is not typically stocked with cattle resulting in very minimal 

use by livestock due to the terrain and the lack of developed water. Any new water developments in the 

southern part of the Altamira Allotment would alter grazing use in this area, and would result in increased

forage use. In addition to changes in grazing use, vegetation would also be disturbed in order to construct 

future range improvements, such as watering facilities, fences, erosion control structures and pipelines.

Livestock grazing has the potential to introduce Class A, B, or C noxious weeds into an area through 

consumption of feed contaminated with weed seed; however, this is unlikely since maintenance feeding 

of livestock is not authorized. It is more likely that cattle could introduce weed species through the 

introduction of seeds that are stuck to animal hair, or when seeds are consumed and then later excreted.

Subsequently seeds can then be transported and dropped in areas free of weed infestations. This 

mechanism can also contribute to the spread of noxious weeds by cattle from populations that may 

become established within or adjacent to the Monument by other means. Introduction of noxious weeds 

by cattle would most likely occur when replacement animals are brought in from other ranches or 

auctions and added to the herd on the allotment. Ground disturbances from livestock tend to be more 

pronounced in areas of livestock concentration, which can increase susceptibility of these areas to 

invasion by noxious weeds. Livestock grazing is not anticipated to influence the spread or vigor of salt 

cedar populations.

Impacts from Soils – Under Alternative A, critical soils on slopes over 10 percent would be a priority 

for altering grazing management to reduce erosion and improve water quality. Loss of soil due to erosion 

would impact soil fertility, and could result in shifts in the type of vegetation and species that can grow in 
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a particular area. Research indicates that black grama dominated ecosystems in southern New Mexico are 

at risk from nutrient imbalances as a result of wind erosion, which can also shift the competitive 

advantage to shrubs (Li et al. 2009). Additionally, soil disturbance and erosion could result in areas 

favoring colonization by weeds, which would compete with native perennial vegetation.

Soil disturbing activities would be authorized with proper mitigation to protect air and water quality. Soil 

disturbances would likely lead to loss of vegetative cover, which would typically be temporary and 

limited to the construction phase of a project. Rehabilitation of vegetation on sites following surface 

disturbing activities would depend on the specific project, and would be analyzed on a site-specific basis.

Impacts from Vegetation – Noxious weed invasions and increases of shrub species in a manner that is 

out of balance with desired ecological condition results in increased competition with desired herbaceous 

plants for water and nutrients. Under Alternative A, the management action to control noxious weeds is 

to use chemical herbicides. Currently, no known populations of Class A or B noxious weeds have been 

identified within the Monument. Individual plants and small populations of the Class C noxious weed 

saltcedar (Tamarix ramosissima) have been discovered in an earthen reservoir within the Monument and 

in ephemeral drainage areas within and adjacent to the Monument. Continued monitoring of the 

Monument by the BLM would allow for the discovery and rapid treatment of noxious weeds. When 

future weed surveys are conducted on the Monument, particular emphasis would continue to be placed on 

areas most susceptible to invasion and spread of noxious weeds, including trails, trailheads, livestock 

watering points, corrals, roads, and any other developed visitor facilities.

Vegetation management treatments under this Alternative would primarily be carried out using 

herbicides, and would certainly result in a shift of the species dominating treated areas. In many areas of 

the Monument, creosotebush dominates the landscape. Recent mapping of vegetation states indicates that 

there is potential for restoration in shrub-dominated areas in the Limestone Hills ecological site, which 

makes up approximately 53 percent of the Monument. However, given the rugged terrain and the 

prescription for using herbicides on areas with slopes less than 10 percent, much of the Monument would 

not be treatable using chemical control methods. There might be opportunity to treat creosotebush on 

level or gently sloping areas, while leaving the steeper slopes and draws untreated, resulting in a mosaic 

of vegetation types.

Existing long-term monitoring transects are established on the Monument. These transects would be 

revisited periodically to track changes in cover, production, and utilization of vegetation in the 

Monument. Large-scale shrub treatments would likely have paired plot monitoring transects established 

to track shrub mortality and the response of herbaceous vegetation.

Impacts from Wildlife – Under all Alternatives, the Robledo Mountains Habitat Management Plan

(HMP) (for deer, antelope, upland game species) would be developed and implemented. Mule deer 

would continue to graze herbaceous plants and browse palatable woody plant species. Areas dominated 

by shrub cover tend to be at a higher risk of plant seedling predation by rodents in the Chihuahuan Desert 

(Bestlemeyer et al. 2007); as a result, continued shrub invasion by creosotebush and mesquite could 

potentially result in decreased establishment of perennial forage plants through this mechanism. The 

potential exists for wildlife to introduce and contribute to the spread of noxious and invasive weeds. 

Typically this can occur when animals travel through weed infested areas, and seeds are picked up and 

become stuck to the fur, or when seeds are consumed and then later excreted. Subsequently, seeds can 

then be transported and dropped in areas free of weed infestations.
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4.4.14.2 ALTERNATIVE B

Impacts from Education and Interpretation – Under Alternative B, the impacts to vegetation from 

Education and Interpretation would be similar to those described under Alternative A.

Impacts from Trails and Travel Management – Under Alternative B, the Monument would be closed 

to motorized or mechanized recreation and SRPs, and this would reduce the potential for damage to 

vegetation adjacent to existing roads and trails. The risks associated with introduction and spread of 

noxious weeds by vehicles would be reduced.

Impacts from Lands and Realty – Under Alternative B, no surface disturbing authorizations would be 

allowed, therefore, no disturbance to vegetation would occur and there would be no impacts from lands 

and realty. The subsurface estate would be acquired, and no surface disturbing activities would impact 

vegetation from any lands and realty actions.

Impacts from Lands with Wilderness Characteristics – Under Alternative B, approximately 576 acres 

would be managed as lands with wilderness characteristics. Additional protections to vegetation from 

limiting surface disturbance would be provided to lands with wilderness characteristics. Therefore, 

impacts to the vegetation would be minimal.

Impacts from Livestock Grazing – Under Alternative B, the Monument would be closed to livestock 

grazing, and this would reduce the amount of plant biomass utilized. The 456 AUMs of forage allotted to 

livestock annually would not be harvested from the Monument. Over time, it is expected that cover, plant 

density, species diversity and plant production would increase, although the magnitude of the increase 

would vary. Changes to plant community composition are likely to be more noticeable in high impact 

areas near livestock watering facilities. Given the fact that the vegetation within the majority of the 

Monument is lightly utilized, widespread changes to the vegetation are not expected from removing 

livestock grazing pressure. The risks associated with introduction and spread of noxious weeds by 

livestock would be reduced. In addition, there would be an increase in fine fuels, which would allow fires 

to burn more readily in the Monument.

Impacts from Soils – Under Alternative B, surface disturbing activities within the Rio Grande watershed 

and areas with high potential for soil erosion would be prohibited. These limitations on surface disturbing 

activities would result in maintenance of ground cover and could lead to increased production of 

vegetation.

Impacts from Vegetation – Under Alternative B, vegetation would be managed according to an 

integrated approach primarily using passive methods, but also employing manual and biological strategies 

in order to move toward the potential natural community of ecological sites. Plant community shifts 

toward the desired condition would occur at a reduced rate compared with the other alternatives, and 

ultimately goals for plant community composition may not be achieved through passive means alone. 

Treatment options would be limited for noxious weed control, and strategies would be dependent on the 

species present and the size of the infestation.

Impacts from Wildland Fire Management – Impacts to vegetation under Alternative B would be the 

same as those discussed under Alternative A.

Impacts from Wildlife – Under all Alternatives, the Robledo Mountains HMP (for deer, antelope, 

upland game species) would be developed and implemented. It is anticipated that wildlife populations 

would increase due to increased forage availability and cover from lack of livestock grazing in 
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Alternative B. This could result in a shift in use patterns, with increased utilization of plant species 

favored by wildlife.

4.4.14.3 ALTERNATIVE C

Impacts from Education and Interpretation – Under Alternative C, the development of interpretive

facilities such as a visitor contact station and interpretive trails and exhibits would require the removal of 

vegetation to accommodate these facilities, and the continued removal as maintenance. It is also possible 

that visitors to these facilities, especially if in large groups, will trample or crush vegetation in areas 

adjacent to interpretive facilities. Visitors engaging in self-guided interpretive activities may venture into 

areas not serviced by a constructed trail, and could trample and crush vegetation as a result. 

Impacts from Recreation and Visitor Services – Under Alternative C, disturbance to vegetation would 

occur in order to construct visitor facilities. Disturbance to vegetation would mainly occur during 

construction activities; however, increased use in high traffic areas may result in continual disturbances 

that would reduce vegetative cover in some areas. Vegetation would be lost in areas where permanent 

visitor facilities would be constructed.

Impacts from Trails and Travel Management – Under Alternative C, disturbance to vegetation would 

occur in order to construct or develop new trails. Increased use on these new trails or routes would result 

in reduced vegetative cover.

Impacts from Lands and Realty – Impacts to vegetation from lands and realty under Alternative C

would result from vegetation disturbance including damage or removal that would occur within or 

adjacent to new rights-of-way or land use authorizations. The subsurface estate would be acquired and no 

surface disturbing activities would impact vegetation from any lands and realty actions.

Impacts from Lands with Wilderness Characteristics – Under Alternative C, approximately 253 acres 

would be managed as lands with wilderness characteristics. Additional protections to vegetation from 

limiting surface disturbance would be provided to lands with wilderness characteristics. Therefore, 

impacts to the vegetation would be minimal.

Impacts from Livestock Grazing – Impacts to vegetation from livestock grazing under Alternative C 

would be the same as those identified under Alternative A.

Impacts from Soils – Under Alternative C, mitigation of soil-disturbing activities would help to protect 

vegetation from excessive disturbance.

Impacts from Vegetation – Under Alternative C, vegetation management would focus on maintaining 

vegetative cover and production with regard to the current ecological potential of land within the 

Monument using passive and active treatments. Particular emphasis would be placed on maintaining and 

enhancing native plant populations and habitat for special status species.

Impacts from Wildland Fire Management – Impacts to vegetation from wildland fire management 

under Alternative C would be the same as those discussed under Alternative A.

Impacts from Wildlife – Impacts to vegetation from wildlife under Alternative C would be the same as

those described under Alternative A.
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4.4.14.4 ALTERNATIVE D

Impacts from Education and Interpretation - Impacts to vegetation would be similar to those 

described under Alternative C, except that invertebrate fossil collecting is allowed as an organized 

educational activity. Although this activity would be conducted with agency or partner oversight, and 

very little vegetation usually grows in these areas of the Monument, it is still possible that trampling of 

vegetation would occur. 

Impacts from Recreation and Visitor Services – Impacts to vegetation would be the same as those 

described under Alternative C.

Impacts from Trails and Travel Management – Impacts to vegetation would be the same as those 

described under Alternative C.

Impacts from Lands and Realty – Impacts to vegetation would be similar to those discussed under 

Alternative C.

Impacts from Lands with Wilderness Characteristics – Impacts to vegetation would be the same as

those described under Alternative A.

Impacts from Livestock Grazing – Impacts to vegetation from livestock grazing under Alternative D 

would be to the same as those described under Alternative A.

Impacts from Soils – Impacts to vegetation from soil resources under Alternative D would be the same 

as those described under Alternative A.

Impacts from Vegetation – Under Alternative D, vegetation management objectives would focus on 

maintaining cover and production with regard to the current potential of ecological sites found within the 

Monument using active and passive restorative methods. Emphasis would be placed on maintaining or 

enhancing habitat for special status species in conjunction with maximizing plant production for use by 

livestock.

Impacts from Wildland Fire Management – Under Alternative D, fire would have a more prominent

role in maintaining the health of the ecosystem by allowing prescribed fire and mechanical thinning. Fire 

would help to reduce shrub cover, and would favor re-establishment of fire-adapted perennial plant 

species. Fire has been found to have negative impacts to black grama (Allred and Snyder 2008); however 

the impact fire has to the survival and health of black grama is dependent on precipitation, fire 

temperature and grass patch size (Drewa et al. 2006).

Impacts from Wildlife – Impacts to vegetation from wildlife under Alternative D would be the same as

those described under Alternative A.
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4.4.15 VISUAL AND SCENIC RESOURCES

Assumptions and Incomplete Information: The number of visitors to the Monument would probably 

increase over time.

Per BLM policy, all land within WSAs is managed under a Visual Resource Management (VRM) Class I 

management objective until such time as the Congress decides to designate the area as wilderness or 

release it for other uses. This impact analysis assumes under all Alternatives that those lands that fall 

within the Robledo WSA (789 acres) would be managed to preserve the existing visual character of the 

landscape – where management activities would be limited, very low, and not attract attention.

Contrast ratings would be required for proposed projects in highly sensitive areas and for projects with the 

potential for high impact. Visual design considerations such as siting, color selection, and reclamation 

would be incorporated into all surface disturbing projects regardless of the anticipated size of the impact.

The location(s) of the proposed visitor contact station (Alternative C) and visitor center (Alternative D) 

are unknown at this time. Should future activity level planning propose locating such facilities within the 

Monument boundary, a visual contrast rating and impact analysis would be required to determine 

compliance or the need to amend the VRM class objective.

Scenic Resources are identified as one of the resources, objects, and values for which the Monument was 

established and are defined as the distinct geologic exposures of the Robledo Mountains in the context of 

the Permian fossils.

Management Decisions with No Impacts to Visual Resource Management: The following 

resources and uses would have little or no impact on Visual Resource Management within the Planning 

Area: Paleontological Resources, Air Resources, Cultural Resources, Special Status Species, SocioEconomic Conditions, Soils, Vegetation Management, Water Resources, Wildland Fire Management, and

Wildlife.

IMPACTS OF THE ALTERNATIVES

4.4.15.1 ALTERNATIVE A

Under Alternative A, the potential level of visual resource impacts are as follows: 

 15 percent of the Planning Area (789 acres) would be managed under a VRM Class I objective 

where impacts from management activities should be very low,

 17 percent of the Planning Area (932 acres) would be managed under a Class II objective where 

impacts from management activities should be low, 

 50 percent of the Planning Area would be subject to a moderate degree of visual impacts where 

2,627 acres would be managed under a VRM Class III objective, and

 18 percent of the Planning Area would be subject to a high degree of visual impacts where 932 

acres would be managed under a VRM Class IV objective.
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Table 4-2 provides an overall indication of the level of potential visual impacts with a comparison of the 

VRM objective to the corresponding visual inventory class rating.

Table 4-2 VRM Objectives Compared to Visual Resource Inventory Class Ratings Alternative A

TABLE 4-2

VRM OBJECTIVES COMPARED TO VISUAL RESOURCE INVENTORY CLASS RATINGS

ALTERNATIVE A

PROPOSED VRM 

CLASSES (ACRES)

VRI CLASS I

(ACRES)

VRI CLASS II

(ACRES)

VRI CLASS 

III (ACRES)

VRI CLASS IV

(ACRES) TOTAL

789** % 4,466 % 0 % 0 % 5,255

VRM I 789* 789 100% 0 0% 0 0% 0 0% 789

VRM II 907 0 0% 907 20% 0 0% 0 0% 907

VRM III 2,627 0 0% 2,627 59% 0 0% 0 0% 2,627

VRM IV 932 0 0% 932 21% 0 0% 0 0% 932

Totals 5,255 789* 100% 4,466 100% 0 0% 0 0% 5,255

NOTES: * Robledo Mountains WSA

 ** Default VRI Class I for WSA

Impacts from Education and Interpretation – Under Alternative A, most interpretation and education 

activities would occur off-site and outside of the Planning Area. Overall, the anticipated or potential 

visual impacts resulting from interpretive activities would be low and meet or exceed all VRM Class 

objectives.

Impacts from Recreation and Visitor Services – Under Alternative A, visual impacts resulting from 

dispersed recreational use (e.g., establishment of primitive campsites, fire rings, and pioneered foot trails)

would continue and likely increase proportionally with the levels of visitor use. Overall, the anticipated 

or potential visual impacts resulting from recreational activities would be low and meet or exceed all 

VRM Class objectives.

Impacts from Trails and Travel Management – Under Alternative A, continued use of the existing 

road and trail network (37.6 miles) within the Monument would result in low level, site-specific visual 

impacts such as trail widening and vehicle pullouts. These anticipated impacts would not affect BLM’s 

ability to manage visual resources to meet the proposed VRM objectives.

Impacts from Lands and Realty – Under Alternative A, the non-Federal minerals are subject to mining

and the impacts commonly associated with mineral development (e.g., excavation, road construction, 

installation of facilities, etc.) would impact visual resources by causing visual disturbances that would not 

retain the existing visual character of the landscape. If new surface disturbing authorizations are issued, 

prior to construction, VRM objectives would be incorporated into design features so as to not impair the 

visual qualities of the landscape.

Impacts from Livestock Grazing – Under Alternative A, visual impacts related to livestock grazing 

activities and the range improvements would continue. The use of the area for livestock grazing is light;

grazing intensity is at a more moderate level near watering points, but most places see slight to light use 

by livestock due to terrain. This is based on both historic utilization data, and more recent observations 

during range health assessments and allotment inspections. Construction of range improvements 

including fences, pipelines, and watering facilities would introduce short-term visual impacts resulting 

from soil disturbance and removal of vegetation; these impacts would diminish over time as disturbed 

soils darken, stabilize, and flatten, and natural regeneration of vegetation begins to occur. Long-term 
VISUAL AND SCENIC RESOURCES

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impacts would result from continued visibility of fence posts, wire, and watering facilities. Further 

NEPA analysis would be required to determine site-specific impacts, appropriate mitigation, and 

compliance with VRM objectives.

4.4.15.2 ALTERNATIVE B

Under Alternative B, 73 percent of the Planning Area (3,915 acres) would be managed as VRM II as to 

retain the existing character of the landscape and where impacts from management activities should be 

low. The remaining 27 percent (1,365 acres) would be managed to preserve the existing character of the 

visual landscape where impacts from management activities should be very low (VRM I).

Table 4-3 provides an overall indication of the level of potential visual impacts with a comparison of the 

VRM objective to the corresponding visual inventory class rating.

Table 4-3 VRM Objectives Compared to Visual Resource Inventory Class Ratings Alternative B

TABLE 4-3

VRM OBJECTIVES COMPARED TO VISUAL RESOURCE INVENTORY CLASS RATINGS

ALTERNATIVE B

PROPOSED VRM 

CLASSES (ACRES)

VRI CLASS I 

(ACRES)

VRI CLASS II

(ACRES)

VRI CLASS 

III (ACRES)

VRI CLASS 

IV (ACRES) TOTAL

789** % 4,466 % 0 % 0 % 5,255

VRM I 1,365* 789 100% 576 13% 0 0% 0 0% 1,365

VRM II 3,915 0 0% 3,915 87% 0 0% 0 0% 3,915

VRM III 0 0 0% 0 0% 0 0% 0 0% 0

VRM IV 0 0 0% 0 0% 0 0% 0 0% 0

Totals 5,255 789 100% 4,466 100% 0 0% 0 0% 5,255

NOTES: * Includes Robledo Mountains WSA and Lands with Wilderness Characteristics

 ** Default VRI Class I for WSA

Impacts from Education and Interpretation – Most interpretation and education activities would occur 

off-site. The overall potential for visual impacts resulting from interpretive and educational activities 

would be low to very low and meet with all proposed VRM Class objectives.

Impacts from Recreation and Visitor Services – Under Alternative B, the Monument would be closed 

to mechanized and motorized vehicle use and dispersed camping, which would reduce visual impacts 

resulting from tire tread and the establishment of primitive campsites, fire rings, and other recreation 

activities that impair the visual impacts to the land. The overall potential for visual impacts resulting 

from recreational activities would be low to very low and meet with all proposed VRM Class objectives.

Impacts from Trails and Travel Management – Under Alternative B, recreational motorized and 

mechanized vehicle use would not be allowed, and no new routes would be developed. Therefore, there 

would be no measureable impacts on visual resources.

Impacts from Lands and Realty – The non-Federal minerals would be acquired, and there would be no 

impacts from mineral development. Surface disturbing land use authorizations are not allowed, so there 

would be no impacts from visual resources on the Lands and Realty program.
VISUAL AND SCENIC RESOURCES

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Impacts from Livestock Grazing – Under Alternative B, the BLM would no longer authorize livestock 

grazing on the Monument. If a fence is built to facilitate implementation of Alternative B, then fence

construction would introduce short-term visual impacts resulting from soil disturbance and removal of 

vegetation; these impacts would diminish over time as disturbed soils darken, stabilize, and flatten, and 

natural regeneration of vegetation begins to occur. Long-term impacts would result from posts and wire. 

An environmental assessment would be required to determine site-specific impacts, appropriate 

mitigation, and compliance with VRM objectives.

4.4.15.3 ALTERNATIVE C

Under Alternative C, 80 percent of the Planning Area (4,213 acres) would be managed as VRM II to 

retain the existing character of the landscape where impacts from management activities should be low 

and not attract attention. The remaining 20 percent of the Planning Area (1,042 acres) would be managed 

as VRM I to preserve the existing character of the visual landscape where impacts from management 

activities should be very low and must not attract attention.

Table 4-4 provides an overall indication of the level of potential visual impacts with a comparison of the 

VRM objective to the corresponding visual inventory class rating.

Table 4-4 VRM Objectives Compared to Visual Resource Inventory Class Alternative C

TABLE 4-4

VRM OBJECTIVES COMPARED TO VISUAL RESOURCE INVENTORY CLASS RATINGS

ALTERNATIVE C

PROPOSED VRM 

CLASSES (ACRES)

VRI CLASS I 

(ACRES)

VRI CLASS II 

(ACRES)

VRI CLASS 

III (ACRES)

VRI CLASS 

IV (ACRES)

TOTAL

789* % 4,466 % 0 % 0 % 5,255

VRM I 1,042* 789 100% 253 6% 0 0% 0 0% 1,042

VRM II 4,213 0 0% 4213 94% 0 0% 0 0% 4,213

VRM III 0 0 0% 0 0% 0 0% 0 0% 0

VRM IV 0 0 0% 0 0% 0 0% 0 0% 0

Totals 5,255 789* 100% 4,466 100% 0 0% 0 0% 5,255

NOTES: * Includes Robledo Mountains WSA and Lands with Wilderness Characteristics

 ** Default VRI Class I for WSA

Impacts from Education and Interpretation – Under Alternative C, visitor facilities such as wayside 

exhibits and information kiosks, would be developed. These facilities would introduce varying degrees of 

visual contrasts. Site-specific impacts, mitigation, and a determination of compliance with VRM 

objectives would be disclosed through activity level planning, associated NEPA documentation, and 

visual contrast ratings.

Impacts from Recreation and Visitor Services – Under Alternative C, visitor facilities such as a 

primitive campsites, toilets, shade shelters, trail markers, and picnic sites would potentially be developed. 

All of these facilities would introduce varying degrees of visual contrasts to the landscape. Site-specific 

impacts, mitigation, and a determination of compliance with VRM objectives would be disclosed through 

activity level planning, associated NEPA documentation, and visual contrast ratings.

Impacts from Trails and Travel Management – Under Alternative C, continued use of approximately 

32.2 miles of the existing route and trail network would result in low level, site-specific visual impacts 
VISUAL AND SCENIC RESOURCES

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such as trail widening and vehicle pullouts. These anticipated impacts would not affect BLM’s ability to 

manage visual resources to meet the proposed VRM objectives. Construction of new routes or foot trails 

to improve access and meet visitor use demands would introduce varying degrees of visual contrasts (line, 

color, form, and texture) across the landscape. The location of any new routes or trails would be 

restricted to those areas outside of VRM Class I. Site-specific impacts, mitigation, and a determination of 

compliance with VRM objectives would be disclosed through activity level planning, associated NEPA 

documentation, and visual contrast ratings.

Impacts from Lands and Realty – Under Alternative C, the non-Federal minerals would be acquired 

and eliminate the opportunity for mineral development(s) and the associated impacts. If new surface 

disturbing authorizations are issued, prior to construction, VRM objectives would be incorporated into 

design features as to not impair the visual qualities of the landscape.

Impacts from Livestock Grazing – Impacts would be the same as described in Alternative A.

4.4.15.4 ALTERNATIVE D

Under Alternative D, 85 percent of the Planning Area (4,466 acres) would be managed as VRM II to 

retain the existing character of the landscape where impacts from management activities should be low 

and not attract attention. The remaining 15 percent (789 acres) would be managed as VRM I to preserve 

the existing character of the visual landscape where impacts from management activities would be very 

low. Table 4-5 provides an overall indication of the level of potential visual impacts with a comparison 

of the visual resource management objective to the corresponding visual inventory class rating.

Table 4-5 VRM Objectives Compared to Visual Resource Inventory Class Alternative D

TABLE 4-5

VRM OBJECTIVES COMPARED TO VISUAL RESOURCE INVENTORY CLASS RATINGS

ALTERNATIVE D

PROPOSED VRM 

CLASSES (ACRES)

VRI CLASS I 

(ACRES)

VRI CLASS II 

(ACRES)

VRI CLASS 

III (ACRES)

VRI CLASS 

IV (ACRES)

TOTAL

789** % 4,466 % 0 % 0 % 5,255

VRM I 789* 789 100% 0 0% 0 0% 0 0% 789

VRM II 4,466 0 0% 4466 100% 0 0% 0 0% 4,466

VRM III 0 0 0% 0 0% 0 0% 0 0% 0

VRM IV 0 0 0% 0 0% 0 0% 0 0% 0

Totals 5,255 789* 100% 4,466 100% 0 0% 0 0% 5,255

NOTES: * Robledo Mountains WSA

 ** Default VRI Class I for WSA

Impacts from Education and Interpretation – Impacts to visual resources would be the same as those 

described under Alternative C.

Impacts from Recreation and Visitor Services – Impacts would be the same as described in 

Alternative C.

Impacts from Trails and Travel Management – Impacts to visual resources would be the same as 

those described under Alternative C.
VISUAL AND SCENIC RESOURCES

4-72

Impacts from Lands and Realty – Impacts to visual resources would be the same as those described 

under Alternative C.

Impacts from Livestock Grazing – Impacts to visual resources would be the same as those described 

under Alternative A. 
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4.4.16 WATER RESOURCES

Assumptions and Incomplete Information: The analysis of impacts on water resources was based on 

the following assumptions:

Hydrologic processes would be managed to meet New Mexico Standards for Public Land Health and 

Guidelines for Livestock Grazing Management (New Mexico Standards and Guidelines).

Surface disturbance of soil, including compaction of soil or loss of vegetation cover, might increase water 

runoff and downstream sediment loads and lower soil productivity, which may degrade water quality, 

alter channel structure, and affect overall watershed health.

The degree of impact attributed to any one disturbance or series of disturbances would be influenced by 

several factors, including location within the watershed, soil characteristics, time and type and degree of 

disturbance, existing vegetation type and quantities, and climatic conditions.

Currently, there is incomplete information regarding groundwater associated within the Monument. 

Given the history of the Robledo Mountains, the inferred lack of aquifer potential, and the absence of 

groundwater data within the Monument, there is still a high degree of uncertainty regarding groundwater 

resources. Therefore, impacts to groundwater from management actions cannot be analyzed in detail. 

Additionally, the absence of perennial and intermittent surface waters in the Monument also limits the 

ability to analyze impacts to surface water resources from management actions. The analysis below 

focuses on impacts to the Rio Grande from management actions produced within the Rio Grande 

watershed.

Management Decisions with No Impacts to Water Resources: The following resources or uses have 

little or no impact on water resources for all alternatives: Air Resources, Special Status Species, Visual 

Resources, and Wildlife.

Effects Common to All Alternatives: Impacts to the Rio Grande could occur if nonpoint source 

pollutants (NPS) are produced from surface disturbing activities and transported to the River. Surface 

disturbing activities often result in decreased infiltration, increased runoff and erosion, degradation of 

vegetation, alteration of soil characteristics, changes in water flow patterns, and decreased watershed 

health. This could cause elevated concentrations of NPS to be transported to the Rio Grande. The degree 

of impact attributed to any one disturbance or series of disturbances under Alternatives A, C, and D could 

be highly variable and would be influenced by several factors, including location within the watershed, 

soil characteristics, time and type and degree of disturbance, existing vegetation type and quantities, and 

climatic conditions. Each one of these variables would be accounted for when developing mitigation 

measures for all surface disturbing activities occurring in the Rio Grande watershed. The greatest 

anticipated impacts on water resources would occur from surface disturbance associated with 

paleontological resources, trails and travel management, livestock grazing, and recreation and visitor 

services.

All resource management actions that propose limitations or restrictions on surface disturbing activities 

would help soil stability and productivity and aid vegetation communities necessary to slow water 

velocities and hinder erosion. Therefore, the proposed actions under Alternative B would have the 

greatest capabilities for reducing surface disturbance, resource degradation, and NPS pollutants. 
WILDLAND FIRE MANAGEMENT

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4.4.17 WILDLAND FIRE MANAGEMENT

Assumptions and Incomplete Information: There is no known wildland fire event within the area of 

the Robledo Mountains. The occurrence of a wildland fire in the Monument would be uncommon. 

Predicting future wildland fire occurrence is highly speculative. Many factors influence wildland fires 

such as fuel source availability, ignition sources (human and natural caused), and weather conditions.

Protecting cultural and paleontological resources from prescribed fire would require small site-specific 

fuels modifications where necessary to reduce the imminent threat of fire. This could include removing 

vegetation down to mineral soil around known cultural sites for planned fire events.

Management Decisions with No Impacts to Wildland Fire Management: The following resources 

or uses have no or little impact on Wildland Fire Management: Paleontological Resources, Education and 

Interpretation, Air Resources, Lands and Realty, Lands with Wilderness Characteristics, Socio-Economic

Conditions, Soils, Special Status Species, Visual Resources, Water Resources, and Wildlife.

Effects Common to All Alternatives: 

Impacts from Special Designations-Area of Critical Environmental Concern – In the ACEC, natural 

ignited fires would only be allowed to continue to burn in areas designated as Fire Management Unit 

Categories C and D. The ACEC within the Monument is Fire Management Unit Category C.

Impacts from Vegetation – Vegetation restoration, through herbicide application could result in 

recovery of, and increase in herbaceous vegetation and grasses within the Monument. This increase in 

fine fuels could also increase potential for naturally ignited and man-caused fires.

IMPACTS OF THE ALTERNATIVES

4.4.17.1 ALTERNATIVE A

Impacts from Recreation and Visitor Services – Visitor facilities would be practically non-existent. 

Dispersed camping along with campfires would be allowed. Recreation activities could increase the 

potential for human-caused wildfire events. Dispersed camping in areas where designated campfires 

rings have not been created would be allowed, however; lack of a fuel reduction strategy in these areas

represents a high risk for human-caused fire ignitions.

Impacts from Trails and Travel Management – The existing routes would continue to be used for 

motorized, mechanized, and pedestrian travel. Recreation activities could increase the potential for mancaused wildfire events through OHV use. Motorized vehicle use on existing trails could increase 

potential for human-caused fires, due to mechanical instances such as overheating.

Impacts from Livestock Grazing – Livestock would continue to graze public land forage. The 

understory that could carry fire would be eaten, reducing the possibility of a wildfire.

4.4.17.2 ALTERNATIVE B

Impacts from Recreation and Visitor Services – Under Alternative B, the Monument is closed to 

SRPs, camping and campfires. Closure of the Monument to all permitted recreational events and 

campfires would reduce the potential for human caused fire. Recreation activities such as hunting and 
WILDLAND FIRE MANAGEMENT

4-75

recreational target shooting would continue and could increase the potential for man-caused wildfire 

events.

Impacts from Trails and Travel Management – Under Alternative B, the Monument is closed to 

motorized or mechanized recreation. Closure of the Monument to all motorized and mechanized vehicles 

would reduce the potential for human caused fire.

Impacts from Livestock Grazing – Livestock grazing would not be permitted within the Monument. 

Elimination of livestock grazing activities would increase the amount of herbaceous plant materials. Fuel 

continuities would increase as herbaceous plant material increases. Potential for wildfire, both naturally 

ignited and human caused would be greatest and potentially larger in size under this Alternative.

4.4.17.3 ALTERNATIVE C

Impacts from Recreation and Visitor Services – Visitor facilities such as toilets, shade shelters, 

information kiosks, trail markers, and picnic sites would be developed and maintained. Campfires would 

be limited to designated campfire rings. Visitor use would likely increase as facilities, are developed, 

which could result in increased fire ignitions. Designated campfire rings would reduce the chance of 

human-caused fire ignitions as compared to Alternative A. Recreational target shooting would not be 

allowed, therefore decreasing the chance of a human-caused wildfire from this recreational activity.

Impacts from Trails and Travel Management – Under Alternative C, visitor facilities such as new 

routes and trails would have the potential to be developed and maintained. Visitor use would likely 

increase as routes and trails are developed, which could result in increased fire ignitions.

Impacts from Livestock Grazing – Grazing would continue except where excluded to protect 

paleontological resources, campsites, or other specified locations. Impacts to wildland fire management

from livestock grazing under Alternative C would be similar to those described under Alternative A; 

except that grazing could be eliminated from camping areas with fire rings. This could increase the fire 

behavior of human-caused fires in that immediate area. Increased fuel loading around campfires could 

increase the potential for human-caused fires.

4.4.17.4 ALTERNATIVE D

Impacts from Recreation and Visitor Services – Impacts to wildland fire management from recreation 

and visitor services under Alternative D would be the same as those described under Alternative C.

Impacts from Trails and Travel Management – Impacts to wildland fire management from Trails and 

Travel Management under Alternative D would be the same as those described under Alternative C.

Impacts from Livestock Grazing – Impacts to wildland fire management from livestock grazing under 

Alternative D would be similar to those described under Alternative A except prescribed fire is a 

management alternative under Alternative D.

If fire is used as a management tool, existing uses such as livestock grazing would have to be considered. 

Designated burn areas may need to be rested from grazing pressure to allow for grass densities to become

favorable to carry fire and meet resource objectives. Proper grazing practices through the removal of 

herbaceous material usually favor less intense wildfire and wildfire potential.
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4.4.18 WILDLIFE

Management Decisions with No Impacts to Wildlife: Under all Alternatives, the following resources 

and uses have no or little impact on Wildlife: Air Resources, Cultural Resources, Lands with Wilderness 

Characteristics, Socio-Economic Conditions, Soils, Special Designations, Visual Resources, and Water

Resources.

Effects Common to All Alternatives:

Impacts from Vegetation – Any vegetation treatment would benefit wildlife by increasing forage and 

improving grassland habitat.

IMPACTS OF THE ALTERNATIVES

4.4.18.1 ALTERNATIVE A

Impacts from Paleontological Resources – Casual collecting of common invertebrates and plant 

paleontological resources and scientific research would continue, which would continue to affect wildlife.

Continuation of these activities would temporarily displace wildlife in areas that are being used; however,

this would be of short duration and would not cause wildlife species to permanently vacate the area.

Impacts from Recreation and Visitor Services – Under Alternative A, visitor facilities would be 

practically non-existent and dispersed camping along with campfires would be allowed. Wildlife would 

continue to be affected by casual recreational use of the Monument. Continuation of these activities 

would temporarily displace wildlife in areas that are being used; however, this would be of short duration 

and would not cause wildlife species to permanently vacate the area.

Impacts from Trails and Travel Management – Under Alternative A, approximately 32.2 miles of 

motorized and mechanized vehicle use routes and 5.3 miles of trails for mechanized vehicles only are

designated for use. Use of motorized and mechanized vehicles could potentially cause injury or mortality 

of slow moving wildlife such as reptiles that may inhabit areas near roads.

Impacts from Livestock Grazing – Under Alternative A, livestock grazing and range improvements 

would continue. Grazing activities such as water facilities would benefit wildlife due to continued 

availability of water in an area in which water would not naturally occur. Any preexisting fences that do 

not follow BLM wildlife friendly fence specifications would pose a risk to wildlife through entanglement. 

If existing fences are to be replaced or rebuilt, they would be required to be built to BLM specifications 

using proper wire spacing and to mitigate and prevent entanglement by wildlife. Any new fences 

constructed within the monument would be required to follow the same specifications. There are no large 

migrating wildlife populations that would be impeded by fences on the Monument. 

Providing water can change the composition, sizes, and abundance of wildlife populations. While some 

species will benefit from the increased availability of water, other species that are not dependent on water 

availability may see little or no benefit. Research shows that animals such as desert bighorn sheep and 

pronghorn are not dependent on water being present but will use it if available. Studies found that 

pronghorn do not rely on wildlife waters whenever the moisture content in plants found in their diet is 

high, but will heavily rely on wildlife waters when the moisture content is low (Beale et al. 1970). 

Throughout the Desert Southwest, prolonged dry periods with little or no precipitation exist not only 

outside of the monsoon season, but can occur over several years. In these desert environments, freestanding water is an important habitat component for ungulates (Bleich et al. 2006) and other species of 
WILDLIFE

4-77

wildlife such as migratory birds. This is especially apparent through the dry spells that often occur. The 

closest perennial water source is the Rio Grande, but in dry years, the river has become intermittent 

depending on the amount of water released from upstream dams for irrigation use. There are no naturally 

occurring springs within the Robledo Mountains. In order for wildlife to access the nearest natural water 

sources, they would have to cross busy roadways and populated areas.

As stated by Joan Scott (1997), to claim a wildlife benefit, a livestock water must be designed and 

managed to provide wildlife values. Currently, livestock waters on the Monument are fitted with wildlife 

escape ramps and are left on year-round to provide an additional source of water for wildlife use. 

Impacts from Wildland Fire Management – Under Alternative A, there would be no management 

actions for Wildland Fire Management that would impact the Wildlife Program.

4.4.18.2 ALTERNATIVE B

Impacts from Paleontological Resources – Casual collecting of common invertebrates and plant 

paleontological resources would not be allowed, but scientific research would be allowed. Scientific 

research could be minimally invasive to wildlife, but research could temporarily displace wildlife.

Impacts from Recreation and Visitor Services – Under Alternative B, recreational use would be 

limited to hunting, hiking, equestrian use, and sightseeing. Aside from the animals being hunted, this use 

would be minimally disturbing to wildlife in general. No camping would be allowed; therefore,

displacement would be limited to day-use associated with dispersed recreation. This temporarily 

displaces wildlife in areas where the recreation is occurring.

Impacts from Trails and Travel Management – Under Alternative B, motorized and mechanized 

vehicular use of the Monument would be prohibited thus minimizing the chance of injuries to slow 

moving wildlife on or near travel routes. 

Impacts from Livestock Grazing – Under Alternative B, livestock grazing would not be allowed within 

the Monument. Prohibiting grazing and its associated activities would both benefit and stress wildlife. 

Availability of forage and cover would increase as grasses and forbs would be expected to increase in 

certain areas. This would be beneficial to wildlife. Throughout the Monument, biodiversity is low and 

populations are not large; as would be expected for a shrub invaded Chihuahuan Desert ecosystem (Baez

2008). Wildlife that inhabit the Monument has become accustomed to utilizing artificial water sources 

and the removal of these sources would cause wildlife to leave the Monument and find water sources 

elsewhere. Should pipelines and troughs be retained for use by wildlife, modifications to the facilities 

may be needed, or a new water source would need to be found to supply water to these facilities, as the 

existing source is a well on private land not under the jurisdiction or control of the BLM. 

Impacts from Wildland Fire Management – Under Alternative B, there would be no management 

actions for Wildland Fire Management that would impact the Wildlife Program.

4.4.18.3 ALTERNATIVE C

Impacts from Paleontological Resources – The impacts of Alternative C would be the same as 

described in Alternative B.
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Impacts from Education and Interpretation – Under Alternative C, pedestrian trails and interpretation 

kiosks that are developed would potentially bring an increase in human traffic causing wildlife to 

temporarily vacate the area near the trails and kiosks.

Impacts from Recreation and Visitor Services – Under Alternative C, visitor facilities such as toilets, 

shade shelters, information kiosks, trail markers, and picnic sites would be developed and maintained. 

This could displace wildlife where these facilities would be built and used. Dispersed recreation would 

continue to temporarily displace wildlife in areas where the recreation is occurring. The establishment of 

a primitive campground would displace any wildlife that inhabits the area where the campground would 

be built. An increase in human activity would cause wildlife to vacate areas frequented by humans.

Impacts from Trails and Travel Management – Under Alternative C, vehicular use of the Monument 

would continue on a portion of the existing routes, and new routes could be developed; therefore, there 

would be potential for slow moving wildlife to be injured on and near travel routes. This risk would 

increase during special events where a greater number of vehicles would be utilizing the routes.

Impacts from Livestock Grazing – Impacts to the Wildlife Program from livestock grazing under 

Alternative C would be the same as those described under Alternative A.

Impacts from Wildland Fire Management – Under Alternative C, there would be no management 

actions for Wildland Fire Management that would impact the Wildlife Program.

4.4.18.4 ALTERNATIVE D

Impacts from Paleontological Resources – Under Alternative D, casual collecting of common 

invertebrates and plant paleontological resources would be allowed in conjunction with prior BLM 

authorized interpretive or educational programs or activities. This would direct fossil collectors to 

specific locations, which would potentially increase wildlife and human interaction. This may cause 

certain wildlife to vacate the collection areas.

Impacts from Education and Interpretation – Under Alternative D, pedestrian trails, interpretation 

kiosks, and a motorized tour route that could be developed would potentially bring an increase in human 

traffic causing wildlife to temporarily vacate the area near the routes, trails, and kiosks to avoid 

confrontation. The establishment of an on-site visitor center would displace wildlife from the site chosen 

for the visitor center. Activities associated with the construction of the visitor center could potentially 

lead to mortality of slow moving wildlife unable to quickly vacate the area.

Impacts from Recreation and Visitor Services – Under Alternative D, impacts to the Wildlife Program

would be similar to those described under Alternative C.

Impacts from Trails and Travel Management – Impacts to the Wildlife Program from Trails and 

Travel Management under Alternative D would be the same as those described under Alternative C.

Impacts from Livestock Grazing – Impacts to the Wildlife Program from livestock grazing under 

Alternative D would be the same as those described under Alternative A.

Impacts from Wildland Fire Management – Under Alternative D, prescribed fire is allowed as a 

management tool. Prescribed fire could displace, kill, and render habitat unsuitable for wildlife for longer 

durations of time than a one-time event, road construction, or some other short duration disturbing 

activity. The long-term positive benefits of prescribed fire to the overall ecosystem would be substantial.
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4.5 CUMULATIVE IMPACTS

The Council on Environmental Quality regulations state that the cumulative impact analysis should

include the anticipated impacts on the environment resulting from “the incremental impacts of the 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 1508.7).

Impacts of the Alternatives presented in this RMP/EIS are assessed for cumulative impacts along with 

other actions conducted in the Analysis Area.

4.5.1 Methodology

The cumulative impacts discussion that follows considers the Alternatives in the context of the broader 

human environment and, specifically, actions that occur outside the scope and geographic area covered by 

the Planning Area. Because of the programmatic, comprehensive nature of the RMP, this assessment is 

broad and generalized to address potential effects that could occur from the Alternative management 

actions when combined with other activities or projects. This assessment is primarily qualitative for 

many resources because of the lack of detailed information that would result from project-level decisions 

and other activities or projects.

Cumulative impact analysis is limited to important issues of national, regional, or local significance. 

Therefore, not all issues identified for direct or indirect impact assessment in this EIS are analyzed for 

cumulative effects. The spatial boundaries of each resource’s cumulative analysis, known as the 

cumulative impact analysis area, vary by resource and are larger for resources that are mobile or migrate 

(i.e., air quality or wildlife species) compared to resources that are stationary (i.e., paleontological 

resources). The spatial boundaries of resources and resource uses may be contained within the Planning 

Area or may extend beyond the Planning Area. Evaluation of potential impacts considers incremental 

impacts that may result from the proposed project, while also considering impacts from past, present, and 

reasonably foreseeable future actions. Reasonably foreseeable future actions are those future actions that 

have been committed to or that are known proposals that could take place within the planning period. 

These are not actual planning decisions or resource commitments.

The BLM land surrounding the PTNM is undergoing an RMP revision. This RMP is not approved nor 

funded, so it will not be included in cumulative impacts. Reasonable Foreseeable Future Actions must be 

approved or funded to be considered.

Chapter 3 Affected Environment considers the impacts of past and present actions on the current 

conditions within the Monument. Past events/actions and reasonably foreseeable actions that have or are 

occurring in the Analysis Area are documented in the following table:
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Table 4-6 Reasonably Foreseeable Future Actions in Doña Ana County

REASONABLY FORESEEABLE FUTURE ACTIONS IN DOÑA ANA COUNTY (2010 TO 2030)

PROJECTED 

POPULATION GROWTH

The population of Doña Ana County is anticipated to increase through the life of the Plan.

Below are population projections for the Analysis Area.

POPULATION PROJECTIONS BY YEAR

COUNTY 2010 2015 2020 2035 2030

Doña Ana 227,009 253,548 282,152 313,073 345,458

SOURCE: Bureau of Business and Economic Research, University of New Mexico 2004

VISION 2040 REGIONAL 

PLANNING PROJECT

The Vision 2040 Comprehensive Regional Plan is the first long-range regional plan to 

include Doña Ana County and its four municipalities: the City of Las Cruces, Village of 

Hatch, Town of Mesilla, and City of Sunland Park. The study addresses a wide range of 

growth-related issues, such as transportation, utilities and water, economic development, 

affordable housing, environmental protection, hazard mitigation, and intergovernmental 

cooperation. It includes extensive analysis of the current situation and a range of possible 

growth scenarios. Recommendations from Vision 2040 will be used for updates to the 

City of Las Cruces and Doña Ana County comprehensive plans.

NEW MEXICO RIO 

GRANDE TRAIL

New Mexico State Parks is in the process of establishing a trail which would roughly 

parallel the Rio Grande. The basic infrastructure of the trail already exists in many 

locations via the levee systems and informal trail networks of the irrigation districts and 

on some publicly-owned land. The river and its bosque attract and sustain a wide variety 

of recreation -- from hunting and fishing to river rafting to hiking, biking, and horseback 

riding. The trail will ultimately link all these sites and tie into the new Mesilla Valley 

Bosque State Park near Las Cruces. Communities in southern New Mexico, such as in 

Doña Ana County, have been actively pushing trail planning and development locally.

STATE GRAVEL PIT Approximately 240 acres of New Mexico State trust land are leased to a sand and gravel 

operator that is directly adjacent to the southeast of the Monument. It is located in

T. 22 S., R. 1 E., Section 32. The current operation has been has been permitted with the 

State of New Mexico since 2000.

BLM COMMUNITY PIT 

NO. 1

In 2008, an Environmental Assessment (NM-030-2009-0042) was completed by the BLM 

Las Cruces District Office for the purpose of improving public safety; reducing visual 

impacts; returning the Community Pit to multiple-use; and reducing erosion and other 

resource impacts. The proposed action is for the BLM to design and reclaim Community 

Pit No.1. The exposed fossil bearing strata around the quarry body would be mapped and 

recorded as a component of the reclamation design.

DOÑA ANA COUNTY 

BLM RECREATION 

AREAS

Within Doña Ana County, the BLM has several recreation areas: Picacho Peak, Doña Ana 

Mountains, A-Mountain, Organ-Franklin Mountains, Dripping Springs, Aguirre Spring, 

and Aden Hills OHV area. Some areas have dispersed recreation while others have 

maintained trails. Hiking, picnicking, and sightseeing are offered at all of the sites. Doña 

Ana Mountains are best known for their mountain bike trails. Aden Hill OHV Area is 

used by motorcycles, and Aguirre Spring offers a campground. Picacho Peak and 

Dripping Springs offer picnic areas, trails, and beautiful views.

NM STATE PARKS AND 

MONUMENTS

New Mexico State Parks manages three areas within Doña Ana County: Mesilla Valley 

Bosque State Park; Fort Selden State Monument; and Leasburg Dam State Park. Mesilla 

Valley Bosque State Park is south of PTNM, encompassing 300 acres of bosque (riverside 

forest) along the Rio Grande and 600 acres of adjacent Chihuahuan Desert. Leasburg 

Dam, constructed in 1908, channels water from the Rio Grande for irrigation in the 

Mesilla Valley. Fort Selden State Monument has a museum and ruins at the site of a 19th 

century army outpost. The fort was abandoned in 1891 after decommissioning.
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4.5.2 Cumulative Impacts

Based on the table of Reasonably Foreseeable Future Actions, the primary three categories of issues 

impacting resources associated with the PTNM are (1) increased urban development and population size, 

(2) an increased demand for outdoor recreational facilities such as trails, and (3) the closure of two gravel 

quarries. The assessment area for Cumulative Effects is Doña Ana County.

4.5.2.1 Cumulative Impacts - Paleontological Resources

Alternative A: As the population of the County increases, as well as the demand for OHV routes, an 

increased use of rock crawling within the Monument may lead to further damage to fossils and seriously 

degrade the amount and quality of research conducted in the Monument.

All Alternatives: Increases in population and other recreational facilities will bring more people into 

contact with the Monument and its fossil resources.

The reclamation of Community Pit No. 1 may eliminate an important fossil site for science and research 

that would benefit research conducted in the Monument itself.

4.5.2.2 Cumulative Impacts - Education and Interpretation

Alternatives A & B: Increases in population and nearby recreational facilities will bring more people into 

contact with the Monument and its fossil resources; however, a lack of facilities and programs on-site 

may not meet the demand or need for interpretation and education and may stress partners such as the 

City of Las Cruces Museum of Nature and Science.

Alternatives C & D: The BLM would be better equipped to handle an increased demand for 

interpretation and education and the PTNM would perhaps become an important tourist destination.

All Alternatives: Reclamation and closure of the Apache Canyon quarry and Community Pit No. 1 would 

eliminate an important opportunity for showcasing the fossil resources of the Robledo Mountains and 

would increase the amount of interpretation within the boundary of the Monument.

4.5.2.3 Cumulative Impacts - Recreation and Visitor Services and Trails and Travel Management

Alternative A: The increased local and regional population may lead to an increase of extreme OHV rock 

crawling events.

Alternative B: By closing the Monument to OHV recreation and Special Recreation Permits, these 

activities would shift to other public land areas that would not offer the same types of challenges, and the 

BLM would not be meeting an important regional recreational demand. 

Alternatives C & D: Continued use of most of the Monument for OHV recreation would meet the 

regional demand for rock crawling activities.

4.5.2.4 Cumulative Impacts - Climate

Emission of GHGs is a cumulative issue with potential long-term effects. Although emission of GHGs 

from activities in the Analysis Area would contribute to the total greenhouse gases in the global pool, the 

models used by climate scientists are not precise enough to: (1) predict impacts on climate or the natural 
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environment from increased or decreased emissions occurring from a specific region, or (2) determine the 

effects in a localized area. It is probable that these impacts would not be from the BLM activities 

proposed within the Monument.

Global mean surface temperatures have increased nearly 1.0°C (1.8°F) from 1890 to 2006 (Goddard 

Institute for Space Studies 2007). However, observations and predictive models indicate that average 

temperature changes are likely to be greater in the Northern Hemisphere. Without additional 

meteorological monitoring systems, it is difficult to determine the spatial and temporal variability of 

climatic conditions, but increasing concentrations of greenhouse gases (GHGs) are likely to accelerate the 

rate of climate change.

In 2007, the Intergovernmental Panel on Climate Change (IPCC) predicted that by the end of the 21st 

Century, global average surface temperatures would increase 1.1 to 6.4°C (2.0 to 11.5°F) above 

1980-1999 levels under a range of potential emissions scenarios (IPCC 2007b). The US Global Change 

Research Program, in its 2009 Report on Global Change Impacts in the United States explains that actual 

warming levels within this range depend on the future level of emissions and the sensitivity of climate 

systems to those emissions. The National Academy of Sciences (2006) points out that there are 

uncertainties regarding how climate change may affect different regions. Computer model predictions 

indicate that increases in temperature will not be equally distributed, but are likely to be accentuated at 

higher latitudes and in the middle of continents. The US Global Change Research Program Report 

indicates the most of the US will experience greater warming in summer than winter although Alaska will 

experience more warming in winter. It is not, however, possible to predict with any certainty regional or 

site-specific effects on climate relative to the proposed action.

Potential impacts to natural resources and plant and animal species due to climate change are likely to be 

varied, including those in the southwestern United States. For example, if global climate change results 

in a warmer and drier climate, increased particulate matter impacts could occur due to increased 

windblown dust from drier and less stable soils and decreased vegetative cover. Cool season plant 

species’ spatial ranges are predicted to move north and to higher elevations, and extinction of endemic 

threatened or endangered plants may be accelerated. Due to loss of habitat or competition from other 

species whose ranges may shift northward, the population of some animal species may be reduced or 

increased. Less snow at higher elevations would likely impact the timing and quantity of snowmelt, 

which, in turn, could impact water resources and species dependent on historic water conditions. When 

compared to baseline information for 1961-1990, periods between 1991 and 2005 show temperature 

increases in over 95 percent of the geographical area of New Mexico. Warming is greatest in the 

northwestern, central, and southwestern parts of the state (Enquist and Gori 2008).

The assessment of GHG emissions, their relationship to global climatic patterns, and the resulting impacts 

is an ongoing scientific process. The inconsistency in results of scientific models used to predict climate 

change at the global scale coupled with the lack of scientific models capable of predicting climate change 

on regional or local scales, limits the ability to quantify potential future impacts of decisions made at this 

level. Determining the significance of any discrete amount of GHG emissions is beyond the limits of 

existing science. However, scientists are increasingly able to isolate likely scenarios for climate change 

and its impacts on a regional scale. The U.S. Global Change Research Program Report on Impacts of 

Climate Change in the United States (2009) focuses on broad areas of the country and greatest points of 

vulnerability as well as looking at Climate Change Impacts in different sectors of the economy. In the 

Southwest, a particular concern is the uncertainty around precipitation and the potential for extended 

periods of drought stressing already uncertain water supplies.
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4.5.2.5 Cumulative Impacts - Air Resources

Alternative A: In Alternative A, roads within the Monument that would access visitor facilities would not 

be improved. Increased visitation to the area would contribute to regional dust concentration levels.

Alternatives B, C and D: Improved road conditions (in Alternatives C and D) and an OHV permit 

system, or closed routes (Alternative B) would mitigate levels of dust generated in the Monument despite 

the growing level of public use of the Monument. Airborne dust particles would probably increase in the 

County, caused by development and construction, but dust associated with the Monument would be a 

minor component.

4.5.2.6 Cumulative Impacts - Lands and Realty

All Alternatives: It is anticipated that approximately 640 acres of mineral estate could be acquired and 

transferred into public ownership over the life of this Plan in all Action Alternatives. Cumulative impacts 

from this acquisition, the withdrawal of the Federal minerals within the Monument and any other 

acquisitions or withdrawals within Doña Ana County would minimally decrease the mineral land 

development opportunities.

All Alternatives: Legislation directs the exclusion of land use authorizations that do not benefit the

Monument. Project proponents would be required to seek alternate routes or sites outside the Monument. 

This would be a minor cumulative effect by reducing routing options through the Monument and possibly

increasing construction costs for utilities. This would not impact the number of land use authorizations, it

would only affect the permitted location, and would possibly increase construction costs.

4.5.2.7 Cumulative Impacts - Lands with Wilderness Characteristics

All Alternatives: Mineral activities and motorized recreational use adjacent to the Monument could 

impact the outstanding opportunities for solitude and primitive unconfined recreation in the areas found to 

have wilderness characteristics. In the Analysis Area, as population growth continues, conflicting uses or 

activities are likely to diminish wilderness characteristics in areas that are not being protected for their 

wilderness characteristics. In Alternatives A, C, and D, those areas not being protected for their 

wilderness characteristics may potentially be affected by cumulative impacts from such activities as

recreational use, development of visitor facilities, interpretation and education development, and scientific 

research.

4.5.2.8 Cumulative Impacts - Livestock Grazing

Alternatives A, C and D: There are 62 grazing allotments within Doña Ana County. Continued 

expansion of the City of Las Cruces and other towns, and development of private land in Doña Ana 

County, has resulted in an urban interface that impacts these allotments. Increased recreational use on 

public land has resulted in damage to allotment pipelines and fences used in managing cattle. Future 

population growth would potentially result in continued conflicts with livestock grazing in the 

Monument.

4.5.2.9 Cumulative Impacts - Socio-Economic Conditions

The assessment area for socio-economic conditions is Doña Ana County.

Since 1990, the population in the Analysis Area has increased substantially. Continued population growth 

is expected. This growth would increase the demand for recreational opportunities in the area. As a 
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result, recreational use of the Monument would increase. Conflicting values related to public land uses 

(e.g., motorized recreation and preservation of wilderness characteristics) require managers to make 

tradeoffs, which may reduce some individuals’ quality of life. Population growth would make these 

pressures more acute.

Increased urbanization would affect the viability of public land grazing. As addressed in Cumulative 

Impacts to Livestock Grazing, constraints on grazing would affect the economic well-being of permittees.

In Alternative B, motorized vehicle use and SRPs are not allowed within the Monument, which would 

either push the use outside of the Monument or outside of Doña Ana County. If the use leaves Doña Ana 

County, the economic stimulus from this use would be lost.

4.5.2.10 Cumulative Impacts - Water Resources, Vegetation, and Soils

All Alternatives: Surface disturbance and loss of vegetation are key contributors to decreased water 

infiltration, increased soil erosion, and degradation to watershed health. Population growth around Las 

Cruces could have direct and indirect negative impacts on water resources and watershed health resulting 

from increases of paved roads, parking lots, buildings, and other impermeable surfaces due to the 

expansion of residential, commercial, and industrial development. It is inferred that recreational 

activities, such as camping and OHV use, outside city limits would increase proportionally to population 

growth. Negative impacts would primarily be derived from surface disturbance such as new roads and 

trails, in which the magnitude of the impacts would be dependent on the type, intensity and duration of 

the disturbance. Alternative B has the most potential for positive impacts to water resources and 

watershed health within the Monument, due to the prohibition of motorized and mechanized vehicle use 

and livestock grazing. Limiting these two uses could result in decreased surface disturbance and soil 

erosion within the Monument. However, these impacts would likely be transferred to land outside of the 

Monument.

4.5.2.12 Cumulative Impacts - Wildlife and Special Status Species

All Alternatives: Wildlife and special status species in the Monument may be affected by offsite use and 

development regardless of the RMP alternative selected. Development of lands within the County would 

reduce habitat availability and may reduce special status species populations. The habitat values of the 

Monument would become more important as similar habitats in the County were utilized for urban and 

agricultural development.

4.6 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF

RESOURCES

A discussion of irreversible or irretrievable commitments of resources which would be involved in the 

proposal should it be implemented is required by Section 102 (2) (C) of NEPA. Irreversible commitment 

of a resource is a resource commitment that cannot be reversed such as an extinction of a species or 

destruction of a paleontological resource. An irretrievable commitment of a resource is one that is lost for 

an amount of time such as a mineral withdrawal.

By allowing collecting of invertebrate paleontological resources this could result in an irreversible 

commitment of resources. Although this collecting has to result in only negligible disturbance to the 

Earth’s surface or other resources, it could result in loss of vertebrate paleontological resources also. By 

allowing scientific collecting of significant paleontological resources, this will mitigate the possibility of 

an irretrievable loss to these resources. Those fossils will be curated in a Federal repository, studied, and 
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possibly displayed for the public to view. Development of interpretation, educational, and recreational 

resources and approving land use authorizations and research permits that result in surface disturbance 

would create irreversible or irretrievable results for soil and vegetation. In order to reduce these impacts, 

best management practices would be used. During all surface disturbing activities, the laws protecting 

cultural and paleontological resources would be adhered to in order to reduce or eliminate impacts on 

these resources. The withdrawal of the Monument from mineral development would preclude the 

extraction and use of these resources. It is possible, but unlikely the withdrawal would be removed by 

Congress and therefore this action is considered an irretrievable commitment of resources.

4.7 UNAVOIDABLE ADVERSE IMPACTS

Section 102 (2) (C) of NEPA also requires that any adverse environmental effects which cannot be 

avoided should this proposal be implemented are disclosed. Unavoidable adverse impacts are those that 

remain following the implementation of mitigation measures.

Casual collecting of common invertebrates in Alternative D would cause unavoidable loss, but the 

educational gain from this activity would outweigh the loss. Unavoidable loss for other paleontological 

resources could occur due to looting, vandalism, erosion, and inadvertent destruction. This impact is 

expected to be reduced as surveys of the Monument are completed and necessary precautions are put in 

place. Unavoidable adverse impacts from increased visitation are increased soil compaction and erosion, 

disturbance to vegetation, wildlife, and livestock, wildfire ignition, and conflicts between users. Vehicle 

use within the Monument could inadvertently destroy cultural or paleontological resources if the resource 

was not detected and protected. Travel management restrictions such as route closures have an adverse 

impact on recreational motorized or mechanized use within the Monument. Should livestock grazing be 

eliminated within the Monument as proposed in Alternative B, it would have an adverse impact on the 

livestock grazing permittee.
CONSULTATION AND 

COORDINATION

CHAPTER 

5

tHE 
5-1

CHAPTER 5

CONSULTATION AND COORDINATION

5.1 INTRODUCTION

The focus of this Chapter is the coordination and consultation that has taken place since scoping began in 

the January 2010, through the development and analysis of alternative planning strategies. This Proposed 

RMP/ Final EIS document has been developed with a broad range of participants.

5.2 PUBLIC SCOPING

The formal scoping process began with the publication of a Notice of Intent (NOI) in the Federal Register

on January 5, 2010 (Volume 75, Number 2, Pages 431-432). This NOI announced the Las Cruces District 

Office’s intent to prepare an RMP, an associated EIS, and to hold a public scoping meeting. Press 

releases, flyers, paid advertisements in newspapers, and the BLM New Mexico and Las Cruces District 

project web sites all announced the public scoping period and public scoping meeting also.

An initial public scoping packet was sent to approximately 337 interested parties describing the BLM’s 

intent to prepare an RMP/EIS for the Monument. Throughout the scoping period, an additional 82 

scoping packets were mailed. The mailing list included adjacent landowners, grazing permittees, special 

recreation permittees, interested public, local agencies, government representatives, tribes, and interested 

organizations. The letter announced the beginning of the formal scoping period, the public Open House, 

and it requested comments regarding the Plan. Inserted in this mailing was a preaddressed “Scoping 

Comment Form” that individuals could complete and return to the BLM.

One formal scoping meeting was held on January 26, 2010 to share information about the Monument, 

preliminary issues, and the planning process. The BLM asked the public for comments and suggestions 

regarding the management of the natural, cultural, recreation, and scientific resources within the 

Monument. Approximately 100 people attended the public scoping meeting. The BLM received 17,388 

total comment submittals, of which 17,287 were a variety of repeat form letters. The themes expressed in 

these form letters are summarized as follows:

• Monument Legislation should take precedence over any multiple-use mandate

• Move Off-Highway Vehicle (OHV) routes outside of the Monument in order to protect the 

Trackways

• Keep OHV trails within the Monument

• Improve non-motorized access and interpretive information

• Encourage public involvement

• Both do and do not incorporate “Expanded Boundary Possibilities for Adjacent Areas” within the 

RMP

• Consider all cumulative impacts such as loss of motorized recreation opportunities and 

Community Pit No. 1 reclamation

The other 99 comments followed several common themes about the natural resources within the 

Monument and the management of those resources.

Informal meetings with a number of groups and agencies have been held prior to and since the public 

meeting. The initial “formal scoping” period closed on February 10, 2010. Although the formal 
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comment period ended, the BLM has continued to accept and consider all comments received throughout 

the planning process.

The public was again invited to participate in the review of preliminary management alternatives for the 

PTNM RMP/EIS through a workshop held on September 22, 2010 from 3:00 p.m. to 7:00 p.m. The 

workshop was conducted as an open forum, with BLM specialists on hand to discuss resource 

management alternatives. A total of 30 people were in attendance. The comments from the September 

workshop often reiterated those comments stated at the scoping meeting. This workshop also provided a 

time for the public to see that the alternatives presented were a wide range of management actions.

5.3 CONSULTATION AND COORDINATION EFFORTS

Consultation and coordination with Federal and intergovernmental agencies, organizations, American 

Indian Tribes, and interested groups and individuals is important to (1) ensure that the most appropriate 

data have been gathered and employed for the analyses and (2) ensure that agency and public sentiment 

and values are considered and incorporated into decision making. During the planning process for this 

RMP/EIS, formal and informal efforts were made by the BLM to involve tribes, other Federal agencies, 

State and local governments, and the public. The BLM has met its Section 106 responsibilities for the 

implementation decisions in this document.

5.3.1 Cooperating Agencies

In January and February 2010, letters were sent to the following agencies inviting recipients to become a 

cooperating agency for this project: City of Las Cruces, Doña Ana County, New Mexico Museum of 

Natural History and Science, New Mexico Department of Game and Fish, New Mexico State Parks.

By definition, a cooperating agency is any Federal, state, or local government agency or Indian tribe that 

has either jurisdiction by law or special expertise regarding environmental impacts of a proposal. As a 

cooperating agency, it provides the formal framework for governmental units to engage in active 

collaboration with the lead Federal agency during the NEPA process. Although the request was sent to 

these agencies, no agency has pursued cooperating agency status.

5.3.2 Tribal Consultation

In January and February 2010 and September 2011, the BLM initiated consultation with the tribes.

Included in the consultation letter was a request for the recipients to become a cooperating agency for the 

Monument RMP/EIS. The invitation will remain open to tribes as planning continues.

Consultation/cooperating agency letters were sent to the following tribes: 

• Fort Sill Apache Tribe of Oklahoma

• Comanche Indian Tribe

• White Mountain Apache

• Ysleta del Sur Pueblo

• Isleta Pueblo

• Mescalero Apache Tribe

• Navajo Nation

• Acoma Pueblo

• Laguna Pueblo

• Tesuque Pueblo
5-3

Several tribes expressed interest in continued notification of planning activities, but no tribe has requested 

Cooperating Agency status. The State Historic Preservation Office was also notified of the planning 

process, as required by Section 106 of the National Historic Preservation Act.

5.4 ADDITIONAL COLLABORATION

Although the following groups are not defined as cooperating agencies, the BLM has been working with 

these groups in addition to the general public to encourage input for this RMP. Groups that have helped 

by providing valuable information are:

New Mexico Museum Natural History and Science

Las Cruces Museum of Nature and Science

Las Cruces Four-Wheel Drive Club

New Mexico State University

Paleozoic Trackways Foundation

Smithsonian Institute

During July and August 2013, BLM staff met with numerous individuals and groups regarding a variety 

of proposals for closure to target shooting and broader discharge of firearms (including hunting). The 

focus of the meetings was to clarify and distinguish between a proposed Temporary Closure to target 

shooting in and around PTNM; the specific alternatives in the PTNM Draft RMP/EIS that would make 

longer term management decisions; and the alternatives presented in the Draft TriCounty RMP, which 

would encompass additional areas further from the boundary of PTNM.

The groups that were involved in these discussions included: Mesilla Valley Shotgun Sports, Inc., 

Picacho Gun Club, Doña Ana County Associated Sportsmen, Southwest Consolidated Sportsmen, and the 

Las Cruces District Office Resource Advisory Council.

Discussions centered on explaining the differences and likely outcomes from the three different actions. 

There was general understanding of the reasons behind the proposed closures, as well as modest support 

for the closures. There was also a general concern voiced for how to effectively enforce the closures, how 

to provide alternative locations that were viable, and how to provide needed education/outreach to 

improve public awareness and safety.

5.4.1 State and Local Government Plans Summaries

Doña Ana County, New Mexico Natural Events Action Plan (NEAP) Reevaluation 2005

The New Mexico Environment Department's (NMED) Air Quality Bureau has monitored numerous 

exceedances of the 24-hour National Ambient Air Quality Standard (NAAQS) concentration limit for 

Particulate Matter 10 microns or less (PM10) in Doña Ana County, New Mexico. Since the number of 

days with exceedances is more than the number allowed by the standard, the County is in violation of the 

PM10 NAAQS. The Air Quality Bureau’s analysis of wind data and other information regarding 

conditions during the exceedances indicated that all but a few were caused by high winds, which lift and 

carry dust from exposed dry soil. In response to these exceedances, the NMED, along with the City of 

Las Cruces and Doña Ana County, developed and submitted to the U.S. Environmental Protection 

Agency a Natural Events Action Plan (NEAP) for Doña Ana County in 2000.
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Statewide Comprehensive Outdoor Recreation Plan (SCORP)

The intent of this plan is to define how State, Federal, local, and Tribal governmental agencies cooperate 

to provide for the outdoor recreation needs and demands of the State and justify State and Federal 

expenditures for outdoor recreation within the State.

New Mexico Historic Preservation Plan- Preserving the Enchantment: 2007-2012

This plan is a compilation of ideas of historic preservation for New Mexico. It is a planning tool for 

future development of advocacy and preservation of cultural resources.

The 2006 Comprehensive Wildlife Conservation Strategy

This Strategy is dedicated to expressing sensible approaches to conserving biological diversity in New 

Mexico in context with surrounding areas. It identifies focus points on species and habitats warranting 

conservation actions. Further, it organizes existing information and recognizes where important 

information gaps remain. From that foundation, it identifies cooperative and collaborative approaches to 

addressing the most important wildlife and habitat conservation needs in time and cost effective ways.

2000 City of Las Cruces Extraterritorial Zoning Comprehensive Plan 2000-2020

To prepare for population growth in Las Cruces and Doña Ana County, the managers and overseers of the 

Extraterritorial Zone (ETZ) seek to identify goals, objectives, and strategies that will preserve open space, 

protect the environment, and accommodate the most number of people with the least amount of adverse 

impact on the area’s character and culture.

2005 Las Cruces Metropolitan Planning Organization Transportation Plan

This Plan identifies and develops a long-range transportation plan for the Las Cruces area. This 

document covers a planning horizon of 20 years and focuses on mobility and access, efficient system 

performance, and quality of life. It includes planning for all aspects of the transportation system, 

including roads, bicycle and pedestrian facilities, public transit, and the airport.

2004 Rio Grande Riparian Ecological Corridor Project Report 

The Rio Grande Corridor Project has three components: a Comprehensive Plan for development along an 

11-mile corridor of the Rio Grande and two pilot projects -- construction of a 14-acre wetland, and 

construction of a 1.1-mile multi-use pathway. The Comprehensive Plan is intended as a blueprint and 

guide for proposed projects along the Corridor which may impact the environment, economic 

development and quality of life of the region. These two pilot projects complement the larger objectives 

of the Comprehensive Plan for sustainable development along the Corridor by creating opportunities for 

multi-jurisdictional cooperation and public involvement.

Vision 2040 Regional Planning Project - City of Las Cruces and Doña Ana County

The 2040 Regional Plan serves as an advisory document intended to act as a guiding framework for 

making mindful decisions when planning and implementing future development within Doña Ana 

County. It covers the broad aspects of how the residents of Doña Ana County would like to see the 

County develop. This document serves as a platform for use in developing more detailed comprehensive, 

master, and site plans. It may also serve as guidance on policy, programming, and capital improvement 

decisions to local elected and administration officials.
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5.5 COMMENTS ON THE DRAFT RMP/EIS

On July 20, 2012, concurrent with the distribution of the Draft PTNM RMP/EIS, the EPA notice of 

availability was published in the Federal Register announcing the availability of the draft document for a 

90-day public review and comment period. During the review period for the Draft PTNM RMP/EIS, the 

BLM held a public meeting on August 7, 2012, for the purpose of assisting the public in their review of 

the draft document and soliciting comments.

All comments received by the BLM during the 90-day comment period on the Draft PTNM RMP/EIS

have been compiled, analyzed, and summarized. The BLM received 45 comment letters. Appendix H 

presents all comments received and provides a response to substantive comments indicating how the 

document was modified or why the comment did not warrant a change to document.

The following agencies, organizations, and individuals were notified that the Proposed PTNM RMP/Final 

EIS would be available in paper copy, on compact disc (CD), and on the BLM’s Web site. Some have 

requested and will receive a paper copy or CD for review and comment.

5.6 PROPOSED RMP/FINAL EIS DISTRIBUTION LIST

FEDERAL AGENCIES

Department of the Interior

Bureau of Indian Affairs

Albuquerque, New Mexico

Bureau of Land Management

Albuquerque District Office, New Mexico

Pecos District Office, New Mexico

Farmington District Office, New Mexico

New Mexico State Office

Las Cruces District Office

Resource Advisory Council

Bureau of Reclamation

International Boundary and Water Commission Upper Rio Grande Project

Fish and Wildlife Service

Las Cruces, New Mexico

Albuquerque, New Mexico

National Park Service

White Sands National Monument

U.S. Army Corps of Engineers

Albuquerque District

STATE AGENCIES AND ORGANIZATIONS

Governor, State of New Mexico

New Mexico Department of Agriculture

New Mexico Department of Game and Fish 

New Mexico Environment Department

New Mexico Energy, Minerals, and Natural Resources Department

Mining and Minerals Division

New Mexico State Historic Preservation Office

New Mexico State Land Office
5-6

New Mexico State Parks

New Mexico State University

Office of the President

Animal and Range Sciences Department

Geography Department

Geology Department

University Museum

Fish, Wildlife & Conservation Ecology

Institute for Energy & the Environment

New Mexico Natural Museum of Natural History

University of Texas at El Paso, Texas

Center for Environmental Resource Management

LOCAL GOVERNMENTS

City of Las Cruces, New Mexico

Museum of Nature and Science

Doña Ana County, New Mexico

Town of Mesilla, New Mexico

TRIBAL GOVERNMENTS

Comanche Indian Tribe

Kiowa Tribe of Oklahoma

Mescalero Apache Tribe

Fort Sill Apache Indian Tribe

White Mountain Apache Indian Tribe

Jicarilla Apache Tribe

Hopi Tribal Council

Isleta Pueblo

Navajo Nation

Ysleta del Sur Pueblo

Acoma Pueblo

Laguna Pueblo

Tesuque Pueblo

CONGRESSIONAL/LEGISLATORS

Senator Tom Udall, State of New Mexico

Senator Martin Heinrich, State of New Mexico

Representative Steve Pearce, 2nd Congressional District of New Mexico

Lee S. Cotter, State Senator District 36

Mary Kay Papen, State Senator District 38

Joseph Cervantes, State Senator District 31

William P. Soules, State Senator District 37

Bill McCamley, NM State Representative District 33

Doreen Y. Gallegos, NM State Representative District 52

Jeff Steinborn, NM State Representative District 35

Phillip M. Archuleta, NM State Representative District 36

Terry H McMillan, NM State Representative, District 37

Mary Helen Garcia, NM State Representative District 34

Nate Cote, NM State Representative District 53
5-7

OTHER INTERESTED ORGANIZATIONS

Coalition of Arizona/New Mexico Counties

Paleozoic Trackways Foundation

Asombro Institute

New Mexico Wilderness Alliance

Center for Biological Diversity

Continental Divide Trail Alliance

New Mexico Farm Bureau

New Mexico Wilderness Alliance

League of Women Voters

Southwest Consolidated Sportsmen

Doña Ana County Associated Sportsmen’s Association

Sierra Club, Rio Grande Chapter

Sierra Club, Southern NM Group

Earth Justice

Southwest Environmental Center

The Wilderness Society

Chihuahuan Desert Nature Park

Las Cruces 4-Wheel Drive Club

Wild Earth Guardians

Rim Rattlers Mountain Bike Club

Shooting Sports Roundtable

Doña Ana Soil and Water Conservation District

5.7 LIST OF PREPARERS AND REVIEWERS

Table 5-1 lists the PTNM RMP/EIS preparers and members of the interdisciplinary team. 
5-8

Table 5-1 List of Preparers and Reviewers

TABLE 5-1

LIST OF PREPARERS AND REVIEWERS

NAME TITLE RMP/EIS RESPONSIBILITY

BUREAU OF LAND MANAGEMENT – LAS CRUCES DISTRICT OFFICE INTERDISCIPLINARY TEAM

Jennifer Montoya Planning and Environmental Specialist Team Leader 2013 to Present

Lori Allen Planning and Environmental Coordinator Team Leader 2010 to 1012

Dwayne Sykes Planning and Environmental Coordinator Technical Assistance

Michael Bailey Outdoor Recreation Specialist Wilderness

Kathryn Lloyd Wilderness Specialist Wilderness

Greg Bettmann Rangeland Management Specialist Rangeland Resources, Livestock, Vegetation/ 

Noxious Weeds

McKinney Briske Park Ranger Recreation and Visitor Services

Ricky Cox Fire Management Specialist Fire Management 

Cory Durr Hydrologist Soil And Water Resources

Rena Gutierrez Writer and Editor Editor/Document Management

Patricia Hester and Sherrie Landon Paleontologist Paleontology

Ray Hewitt GIS Specialist Geographic Information System

Tom Holcomb Archeologist Cultural Resources 

Lorraine Salas and Kendrah Penn Realty Specialists Lands And Realty

Mike Smith Geologist Geology and Minerals

Chris Teske AML/HazMat/Safety Abandoned Mine Lands & Hazmat

John Thacker Outdoor Recreation Planner Trails And Travel Management, Visual Resource 

Management

Steven Torrez Wildlife Biologist Wildlife and Special Status Species

Jane Childress NMSO Interpretation and Heritage Education Lead Interpretation and Education

BUREAU OF LAND MANAGEMENT – LAS CRUCES DISTRICT OFFICE MANAGEMENT OVERSIGHT

William Childress District Manager

Jim McCormick Assistant District Manager, Renewable Resources

Dave Wallace Assistant District Manger, Multi-Resources

Tom Phillips Recreation/Cultural Supervisor

Rusty Stovall Engineering/Operations/GIS Supervisor

Ray Lister Supervisory Natural Resource Specialist

Leticia Lister Supervisory Rangeland Resource Specialist

Edward Seum Lands & Minerals Supervisor

Mark Bernal Fire Management Officer

BUREAU OF LAND MANAGEMENT – NEW MEXICO STATE OFFICE REVIEWERS

Megan Stouffer Planning & Environmental Coordinator

Melanie Barnes Planning & Environmental Coordinator

Dave Goodman Planning & Environmental Coordinator

William Auby Geologist

Roger Cumpian Rangeland Management Specialist

Jeanne Hoadley Air Resources

Mary Uhl Air Resources

Roger Jaggers Outdoor Recreation Planner

Powell King Mining Engineer

Billy “Link” Lacewell Soil/Air/Water, Hazmat

Philip Gensler Regional Paleontologist

Sherrie Landon Paleontologist

Signa Larralde Archeologist

Sheila Herhahn Archeologist

Debby Lucero Lands and Realty Team Leader

John Selkirk Fire Management Specialist

Lisa Bye Fuels Specialist

John Sherman Wildlife Biologist

Mary Kay Ramsay T&E Wildlife Biologist

James Sippel NLCS Program Lead

Jay Spielman Geologist
GLOSSARY

tHE 
GL-1

GLOSSARY

A

Active treatment methods: Actions taken to reestablish vegetation and ecosystem balance.

Administrative Use: Use by any Bureau of Land Management employee.

Agency: Any Federal, State, or county organization with jurisdictional responsibilities.

Allotment (range): A designated area of land available for livestock grazing upon which a specified 

number and kind of livestock may be grazed under management of an authorized agency. An allotment 

generally consists of Federal rangeland, but may include intermingled parcels of private, State, or Federal 

land. The Bureau of Land Management and the U.S. Forest Service stipulate the number of livestock and 

season of use for each allotment.

Allotment Management Plan (AMP): A written program of livestock grazing management including 

supportive measures, if required. An allotment management plan is designed to attain specific 

management goals in a grazing allotment and is prepared cooperatively with the permittee(s) or lessee(s).

All-terrain vehicle (ATV): A small motor vehicle with wheels or tractor treads often used for crosscountry travel, including traveling over rough ground, snow, or ice. For the purposes of this document, 

an all-terrain vehicle is defined as a motor vehicle that: (a) is designed primarily for recreational 

nonhighway all-terrain travel, (b) is 50 or fewer inches wide, (c) has an unladen weight of 800 pounds or 

less, (d) travels on three or more low-pressure tires, and (e) has a seat designed to be straddled by the 

operator, and handlebars for steering control. An all-terrain vehicle is a type of off-highway vehicle 

(OHV).

American Indian tribe (or tribe): Any American Indian group in the conterminous United States that 

the Secretary of the Interior recognizes as possessing Tribal status (listed periodically in the Federal 

Register).

Alternative: One of at least two proposed means of meeting planning objectives.

Analysis Area: The term Analysis Area is used for some resources and resource use discussions outside 

the Planning Area. The Analysis Area, Doña Ana County, includes public, private, and other government 

lands, and consists of about 2,436,595 acres.

Animal Unit: One mature (1,000-pound) cow or the equivalent based on an average forage consumption 

of 26 pounds of dry matter per day. For authorization calculation purposes, an animal unit is one cow and 

her calf, one horse, or five sheep or goats. Depending on the composition and weight of animals in the 

herd, actual forage use may vary.

Animal unit month (AUM): A standardized unit of measurement of the amount of forage necessary for 

the complete sustenance of one animal unit for a period of one month; also, a unit of measurement of 

grazing privileges that represents the privilege of grazing one animal unit for a period of one month.. 
GL-2

Archaeology: The scientific study of the life and culture of past, especially ancient, peoples, by 

excavation of ancient cities, relics, artifacts, etc.

Archaeological site: A discrete location that provides physical evidence of past human use.

Area of critical environmental concern (ACEC): An area of public land designated by the Bureau of 

Land Management for special management attention to protect and prevent irreparable damage to 

important historic, cultural, or scenic values; fish and wildlife resources; or other natural systems or 

processes or to protect life or provide safety from natural hazards. Areas designated as areas of critical 

environmental concern have met criteria for importance and relevance that are outlined in Title 43 Code 

of Federal Regulations (CFR) Section 1610.7-2(b).

Artifact: A human-made object. 

Arroyo: A dry gully. 

Authorized Officer: Any Bureau of Land Management employee who has been delegated the authority 

to perform defined duties. 

Available Forage (or available forage species): Forage that can be grazed and still allow sustained 

forage production on rangeland. Available forage may or may not be authorized for grazing. 

Avoidance area: An area where rights-of-way may be granted only when no feasible alternative route is 

available.

B

Basin: A depressed area having no surface outlet (topographic basin); a physiographic feature or 

subsurface structure that is capable of collecting, storing, or discharging water by reason of its shape and 

the characteristics of its confining material (water basin); a depression in the earth’s surface, the lowest 

part often filled by a lake or pond (lake basin); a part of a river or widened canal (drainage, river, or 

stream basin). 

Best management practices (BMPs): A suite of techniques that guide, or may be applied to, 

management actions to aid in achieving desired outcomes and help to protect the environmental resources 

by avoiding or minimizing the impacts of an action. BMPs are often developed in conjunction with land 

use plans, but they are not considered a land use plan decision unless the land use plan specifies that they 

are mandatory. They may be updated or modified without a plan amendment if they are not mandatory. 

BLM Sensitive Species: Species designated by a state director, usually in cooperation with the state 

agency responsible for managing the species and state natural heritage programs, as sensitive. They are 

those species that: (1) could become endangered in or extirpated from a state. Or within a significant 

portion of or distribution; (2) are under status review by the U.S. Fish and Wildlife Service and/or 

National Marine Fisheries Service; (3) are undergoing significant current or predicted downward trends in 

habitat capability that would reduce a species’ existing distribution; (4) are undergoing significant current 

or predicted downward trends in population or density such that federal listed, proposed, candidate, or 

State listed status may become necessary; (5) typically have small and widely dispersed populations; (6) 

inhabit ecological refugia or other specialized or unique habitats; or (7) are State listed but which may be 

better conserved through application of BLM sensitive species status.
GL-3

Bureau of Land Management (BLM): An agency of the U.S. Department of the Interior responsible 

for managing most Federal government subsurface minerals. It has surface management responsibility 

for Federal land designated under the Federal Land Policy and Management Act of 1976. 

C

Carrying Capacity: The maximum stocking rate possible without inducing permanent or long-term 

damage to vegetation or related resources. The rate may vary from year-to-year in the same area as a 

result of fluctuating forage production.

Casual Collecting: Collecting of a reasonable amount of common invertebrate and plant paleontological 

resources for non-commercial personal use, either by surface collection or the use of non-powered hand 

tools resulting in only negligible disturbance to the Earth’s surface and other resources. Collection must 

be consistent with the laws governing the management of those Federal lands.

Casual Use: An activity that does not require authorization and does not ordinarily result in appreciable 

resource damage.

Closed: Generally denotes that an area is not available for a particular use or uses; refer to specific 

definitions found in law, regulations, or policy guidance for application to individual programs. For 

example, 43 CFR 8340.0-5 sets forth the specific meaning of “closed” as it relates to off-highway vehicle 

use, and 43 CFR 8364 defines “closed” as it relates to closure and restriction orders. 

Code of Federal Regulations (CFR): The official legal compilation of regulations directing Federal 

Government agencies. 

Cooperating Agency: Assists the lead Federal agency in developing an Environmental Assessment or 

Environmental Impact Statement. The Council on Environmental Quality regulations implementing the 

National Environmental Policy Act (NEPA) define a cooperating agency as any agency that has

jurisdiction by law or special expertise for proposals covered by NEPA (40 CFR 1501.6). Any Federal, 

State, or local government jurisdiction with such qualifications may become a cooperating agency by 

agreement with the lead agency.

Cuesta: A ridge with a steep face on one side and a gentle slope on the other, especially in the 

southwestern United States

Cultural Resource: Any definite location of past human activity, occupation, or use, identifiable 

through inventory, historical documentation, or oral evidence. Cultural resources include archaeological, 

historic, or architectural sites, structures, places, objects, and artifacts.

Cultural Site: A physical location of past human activities or events, more commonly referred to as an 

archaeological site or a historic site. Such sites vary greatly in size and range from the location of a single 

cultural resource object to a cluster of cultural resource structures with associated objects and features.

Cumulative Effects: “...the impact on the environment which results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such actions” (40CFR 1508.7).
GL-4

D

Decision Area: The area for which decisions will be made in the Resource Management Plan (RMP).

Developed Campsite: Amenities might include: restroom, showers, electric hook-ups, RV dump 

stations, tables, shade area, fire grills, reservation system, and campground host. Fees may be associated 

with such campground

Direct Effects: Those effects “...which are caused by the action and occur at the same time and place” 

(40 CFR 1508.8(a)).

Dispersed Pedestrian Recreation: Outdoor recreation in which pedestrian visitors are diffused over 

relatively large areas. Where facilities or developments are provided, they are primarily for access and 

protection of the environment rather than the comfort or convenience of the user. 

Dispersed Recreation: Outdoor recreation diffused over relatively large areas. Where facilities or 

developments are provided, they are primarily for access and protection of the environment rather than 

the comfort or convenience of the user.

Discovery Site: “The Discovery Site” is where Jerry MacDonald found long, intact trackways in the mid1980s. Under the supervision of the Smithsonian and Carnegie Museums, MacDonald excavated many 

layers of trackways and removed thousands of slabs of tracks that now make up the Jerry MacDonald 

Paleozoic Trackways Collection at New Mexico Museum of Natural History and Science. There are still 

a variety of tracks and plant impressions visible at the site. It is the most frequently visited best known of 

the paleontological sites in the Monument.

Docent: A person who is trained to lead tours especially through a museum. 

E

Early Seral Condition Class: Stage of development of an ecosystem, usually poor ecological 

conditions.

Easement: An authorization for a non-possessory, nonexclusive interest in lands that is usually granted 

for a specific use. This authorization specifies the rights of the holder and the obligation of the Bureau of 

Land Management to use and manage the lands in a manner consistent with certain terms.

Ecological Site: A kind of land with specific physical characteristics which differs from other kinds of 

land in its ability to produce distinctive kinds and amounts of vegetation and in its response to 

management.

Ecoregion: Ecological area. An area defined by environmental conditions and natural features; a region 

defined by its ecology.

Ecosystem: A dynamic complex of plant, animal, fungal, and microorganism communities and their 

associated nonliving environment interacting as an ecological unit. 
GL-5

Ecotourism: Tourism that essentially focuses on natural rather than developed attractions with the goal 

of enhancing the visitor’s understanding and appreciation of nature and natural features. Such tourism 

often attempts to be environmentally sound and to contribute economically to the local community.

Effects and Impacts: Effects and impacts in the regulations are synonymous. An effect on a resource 

upon the implementation of an action

Endangered Species: A plant or animal that is in danger of extinction throughout all or a significant 

portion of its range. 

Entry: An application to acquire title to public land.

Environmental Impact Statement (EIS): An analytical document that portrays potential impacts on the 

human environment of a particular course of action and its possible alternatives. Required by the 

National Environmental Policy Act (NEPA), an EIS is prepared for use by decision makers to assess the 

environmental consequences of a potential decision.

Environmental Justice: The fair treatment and meaningful involvement of all people, regardless of race, 

color, national origin, or income in developing, implementing, and enforcing environmental laws, 

regulations, and policies. 

Ephemeral: Lasting for only a short period of time and leaving no permanent trace.

Ephemeral Stream: A stream that flows only in direct response to precipitation, and whose channel is at 

all times above the water table.

Erosion: The wearing away of the land surface or soil by running water, waves, or moving ice and wind, 

or by such processes as mass wasting and corrosion (solution and other chemical processes).

“Accelerated erosion” generally refers to erosion in excess of what is presumed or estimated to be 

naturally occurring levels, and which is a direct result of human activities.

Exclusion Area: Areas with sensitive resource values where rights-of-way would not be authorized, 

except where mandated by law.

Exotic: All species of plants and animals not naturally occurring, either presently or historically, in any 

ecosystem of the United States.

Extensive Recreation Management Area (ERMA): Areas designated and managed to support and 

sustain the principal recreation activities and the associated qualities and conditions.

F

Fauna: The animal life of a particular region or period, considered as a whole.

Federal Land: Land, or interests in land (such as easements and rights-of-way), owned by the United 

States.
GL-6

Federal Land Policy And Management Act (FLPMA): Public Law 94-579, the Act that (1) 

established, for the Bureau of Land Management, standards for managing the public lands including land 

use planning, sales, withdrawals, acquisitions, and exchanges; (2) authorized the setting up of local 

advisory councils representing major citizens groups interested in land use planning and management, (3) 

established criteria for reviewing proposed wilderness areas, and (4) provided guidelines for other aspects 

of public land management such as grazing.

Federal Register: The Federal Government’s official daily publication for rules, proposed rules, and 

notices of Federal agencies and organizations, as well as executive orders and other presidential 

documents.

Fire Management Plan: A strategic plan that defines a program to manage wildland and prescribed fires 

and documents the fire management program in the approved land use plan. The fire management plan is 

supplemented by operational procedures such as preparedness plans, preplanned dispatch plans, 

prescribed fire plans, and prevention plans.

Fire Management Unit: A fire planning unit in which preparedness strategies are designed to meet 

watershed or resource management objectives, designated by logical fire control or containment criteria 

such as watershed basins, sub-basins, ridgetops, topographic features, roads, or vegetation changes.

Fire Regime: Periodicity and pattern of naturally occurring fires in a particular area or vegetative type, 

described in terms of frequency, biological severity, and area of extent.

Fire Regime Condition Class (FRCC): A standardized interagency tool for determining the degree of 

departure from reference condition vegetation, fuels, and disturbance regimes. Assessing FRCC can help 

guide management objectives and set priorities for treatments.

Fire Intensity: The effects of fire on the above ground vegetation, generally described in terms of 

mortality.

Fire Severity: Fire effects at and below the ground surface. It describes the impacts on organic material 

on the ground surface, changes to soils, and mortality of below ground vegetative buds, roots, rhizomes, 

and other organisms.

Fire Suppression Tactics: The tactical approaches regarding suppression of a wildland fire. Tactics can 

control, confine, contain, or monitor fire. Control is the most aggressive tactic, while monitoring is the 

least.

Fire Use: The combination of wildland fire use and prescribed fire application to meet resource 

objectives.

Forage: All browse and herbage that is available and acceptable to grazing animals or that may be 

harvested for feed; the act of consuming forage.

Fossil: Any remains, trace, or imprint of a plant or animal that has been preserved by natural process in 

the earth’s crust since some past geologic time.

Friable: Easily crumbled or crushed into powder.
GL-7

G

Geographic Information System (GIS): A computer application used to store, view, and analyze 

geographical information, especially maps.

Grazing Permit or Lease: A contractual agreement between the Bureau of Land Management and 

another party that permits grazing of a specific number and class of livestock for a specified period on a 

defined rangeland. The permit allows grazing use of public land, subject to permit stipulations and annual 

adjustment based on current rangeland condition.

Greenhouse Gases: Are those gaseous constituents of the atmosphere, both natural and anthropogenic, 

that absorb and emit radiation at specific wavelengths within the spectrum of infrared radiation emitted by 

the Earth's surface, the atmosphere and clouds. This property causes the greenhouse effect. Water vapor 

(H2O), carbon dioxide (CO2), nitrous oxide (N2O), methane (CH4) and ozone (O3) are the primary 

greenhouse gases in the Earth's atmosphere. Beside CO2, N2O and CH4, the Kyoto Protocol deals with 

the greenhouse gases sulphur hexafluoride (SF6), hydro fluorocarbons (HFCs) and perfluorocarbons 

(PFCs).

Ground Cover: Plants or plant parts, living or dead, on the surface of the ground.

Groundwater: Subsurface water that is in the zone of saturation. The top surface of the ground water is

the water table. Groundwater is the source of water for wells, seepage, and springs. 

H

Habitat: A specific set of physical conditions that surround a species, group of species, or a large and 

living space.

Herbaceous: Of, relating to, or having the characteristics of a vascular plant that does not develop 

woody tissue; non-woody vegetation such as grasses and forbs.

I

Ichnofauna: The animals that made ichnofossils.

Ichnofossil: Fossils that document animal behavior by the presence of trackways, footprints, dung and 

other indicators rather than fossilized bones or body parts.

Ichnogenus: A group of trace fossils that is given a name because the similarity of the traces suggests 

they were made by closely related species of organisms.

Ichnotaxon Invertebrate: An animal that does not have a backbone, e.g. an insect or worm.

Indirect Effects: Those effects “...which are caused by the action and are later in time or father removed 

in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and 

other effects related to induced changes in the pattern of land use, population density, or growth rate, and 

related effects on water and air and other natural systems, including ecosystems” (40 CFR 1508.8 (b)).
GL-8

In-situ: In its natural or original place.

Interim Management Policy for Lands under Wilderness Review (IMP) (BLM 1995): The Bureau 

of Land Management’s strategy for managing wilderness study areas following their recommendation for 

designation but before Congress designates them as wilderness or releases them to multiple-use 

management.

Invasive Species: An alien species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health.

K

Karst: A limestone landscape, characterized by caves, fissures, and underground streams.

L

Lamination: In geology, lamination is a small scale sequence of fine layers (so called laminae) that 

occurs in sedimentary rocks. Laminations are normally smaller and less pronounced than bedding 

layering. Lamination is often regarded as planar structures one centimeter or less in thickness, whereas 

bedding layers are greater than one centimeter.

Land Use Authorization: An authorization the Bureau of Land Management issues authorizing 

nonpossessory, non-exclusive right to use Federal lands for a specific use such as right-of-way, lease, 

temporary use permit, film permit, etc.

Land Use Plan: A set of decisions that establish management direction for land within an administrative 

area, as prescribed under the planning provisions of the Federal Land Policy and Management Act; an 

assimilation of land-use-plan-level decisions developed through the planning process outlined in 

43 CFR 322 1600, regardless of the scale at which the decisions were developed. Also see Resource 

Management Plan.

Leasable Minerals: Minerals whose extraction from Federally-managed land requires a lease and the 

payment of royalties. Leasable minerals include coal, oil and gas, oil shale and tar sands, potash, 

phosphate, sodium, and geothermal steam.

Lithic Scatter: Pertaining to or composed of stone flakes created by human flint knapping that are 

dispersed on the ground; a type of archaeological resource.

Lithology: The scientific study of rocks.

Locatable Minerals: Minerals subject to exploration, development, and disposal by staking mining 

claims as authorized by the Mining Law of l872 (as amended). Locatable minerals include valuable 

deposits of gold, silver, and other uncommon minerals not subject to lease or sale.

Location: The act of taking or appropriating a parcel of mineral land, including the posting of notices, 

the recording thereof when required, and marking the boundaries so they can be readily traced.

Long-Term Impacts: Impacts projected to occur 10-20 years.
GL-9

M

Mineral Entry: The filing of a claim on public land to obtain the right to any minerals it may contain.

Mineral Estate: The ownership of the minerals at or beneath the land’s surface.

Mineral Materials: Materials such as common varieties of sand, stone, gravel, pumice, pumicite, and 

clay that are not obtainable under the mining or leasing laws but that can be acquired under the Materials 

Act of 1947, as amended. Also, known as salable minerals.

Mining Claims: Portions of public land claimed for possession of locatable mineral deposits by locating 

and recording under established rules and pursuant to the Mining Law of 1872. 

Mining Law of 1872 (General Mining Law): The Federal act that, with its amendments, formed the 

framework for the mining of locatable minerals on the public land. This law declared that “valuable” 

mineral deposits rather than simply "mineral deposits" were to be free and open to exploration and 

purchase, limited individual claims to 20 acres, required $100 worth of assessment work yearly, and 

allowed milling or processing claims of 5 acres or less to be entered on nonmineral lands.

Museum Property: Museum collections come in many forms, all with characteristics that make them 

worthy of long-term preservation and management. Once an item is added to a museum collection it must 

be documented and treated in a specific way as property. Paleontological resources collected from public 

land and added to a museum collection, although still government property, must be treated in a specific 

way that will preserve and manage them for long-term preservation for the public benefit. 

N

National Ambient Air Quality Standards: The allowable concentrations of air pollutants in the 

ambient (public outdoor) air specified in 40 CFR 50. National ambient air quality standards are based on 

the air quality criteria and divided into primary standards (allowing an adequate margin of safety to 

protect the public health including the health of "sensitive" populations such as asthmatics, children, and 

the elderly) and secondary standards (allowing an adequate margin of safety to protect the public 

welfare). Welfare is defined as including effects on soils, water, crops, vegetation, human-made 

materials, animals, wildlife, weather, visibility, climate, and hazards to transportation, as well as effects 

on economic values and on personal comfort and well-being.

National Environmental Policy Act of 1969 (NEPA): The Federal law, effective January 1, 1970, that 

established a National policy for the environment and requires Federal agencies: (1) to become aware of 

the environmental ramifications of their proposed actions, (2) to fully disclose to the public proposed 

Federal actions and provide a mechanism for public input to Federal decision making, and (3) to prepare 

environmental impact statements for every major action that would significantly affect the quality of the 

human environment. 
GL-10

National Historic Preservation Act (NHPA) of 1966, as amended: A Federal statute that established a 

Federal program to further the efforts of agencies and individuals in preserving the Nation’s historic and 

cultural foundations. The National Historic Preservation Act: (1) authorized the National Register of 

Historic Places, (2) established the Advisory Council on Historic Preservation and a National Trust Fund 

to administer grants for historic preservation, and (3) authorized the development of regulations to require 

Federal agencies to consider the effects of Federally-assisted activities on properties included in or 

eligible for the National Register of Historic Places. Also see NATIONAL REGISTER OF HISTORIC 

PLACES.

National Register of Historic Places (NRHP): The official list, established by the National Historic 

Preservation Act, of the Nation’s cultural resources worthy of preservation. The National Register lists 

archaeological, historic, and architectural properties (i.e., districts, sites, buildings, structures, and objects) 

nominated for their local, state, or national significance by state and Federal agencies and approved by the 

National Register Staff. The National Park Service maintains the National Register. National Register

eligible property is referred to as an historical, cultural, archaeological, or listed property. Also, see 

NATIONAL HISTORIC PRESERVATION ACT. 

Non-Impairment of Wilderness Values Criteria: A set of criteria regulating land use to protect the 

wilderness values and characteristics of an area until Congress determines whether to preserve it as a 

wilderness. The nonimpairment criteria are as follows. 

 The use, facility, or activity must be temporary. (This means a temporary use that does not create 

surface disturbance or involve permanent placement of facilities may be allowed if such use can 

easily and immediately be terminated upon wilderness designation. 

 When the use, activity, or facility is terminated, the wilderness values must not have been 

degraded so far as to significantly constrain the area’s suitability for preservation as wilderness. 

 The only permitted exceptions to the nonimpairment criteria are the following: 

 wildfire or search and rescue emergencies, 

 reclamation to minimize impacts of violations and emergencies, 

 uses and facilities that are considered grandfathered or valid existing rights under the Interim 

Management Policy for Lands under Wilderness Review, 

 uses and facilities that clearly protect or enhance the land’s wilderness values or are the least 

needed for public health and safety, and 

 reclamation of pre-Federal Land Policy and Management Act impacts. 

Notice of Intent (NOI): A notice that an environmental impact statement will be prepared and 

considered. The notice shall briefly: (a) Describe the proposed action and possible alternatives. (b) 

Describe the agency's proposed scoping process including whether, when, and where any scoping meeting 

will be held. (c) State the name and address of a person within the agency who can answer questions 

about the proposed action and the environmental impact statement. 

Noxious Plant (Weed): An unwanted plant specified by Federal or state laws as being undesirable and 

requiring control. Noxious weed refers to any plant that, when established, is highly destructive, 

competitive, or difficult to control by cultural or chemical practices. Noxious weeds are usually nonnatives and highly invasive.
GL-11

O

Off-Highway Vehicle: Any motorized vehicle capable of or designed for travel on or immediately over 

land, water, or other natural terrain, excluding (1) any nonamphibious registered motorboat; (2) any 

military, fire, emergency, or law enforcement vehicle while being used for emergency purposes; (3) any 

vehicle whose use is expressly authorized by the authorized officer, or otherwise officially approved or 

permitted; (4) vehicles in official use by administering agencies such as the Bureau of Land Management 

or other agency; and (5) any combat or combat support vehicle when used in times of National defense 

emergencies. 43 CFR Section 8340.05.

Ostracods: A tiny crustacean that lives inside a hard outer shell made of two hinged halves.

P

Paleontological Resources: The remains of plants and animals preserved in soils and sedimentary rock. 

Paleontological resources are important for understanding past environments, environmental change, and 

the evolution of life. 

Paleozoic: The era of geologic time, about 542 million to 251 million years ago, during which fish, 

insects, amphibians, reptiles, and land plants first appeared.

Particulate Matter: Fine liquid (other than water) or solid particles suspended in the air, consisting of 

dust, smoke, fumes, and compounds containing sulfur, nitrogen, and metals.

Passive Treatment Methods: Allowing resources to naturally regenerate over time without taking direct 

action. 

Payment in Lieu of Taxes (PILT): Federal payments to local governments to offset their inability to 

collect taxes for federally owned land.

Permian: The period of geologic time, 299 million to 251 million years ago. 

Permitted Use: Any use by an entity such as scientist, livestock permittee, or Special Recreation 

Permittee that is authorized by the local Bureau of Land Management office.

Planning Area: The area for which decisions made in the PTNM RMP will apply. The Planning Area

consists of 5,255 acres of Federal surface estate and 4,886 acres of Federal subsurface estate designated as 

the Prehistoric Trackways National Monument.

Planning Criteria: The constraints or ground rules that guide the developing of a resource management 

plan. The criteria determine how the planning team develops alternatives and ultimately selects a 

Preferred Alternative.

Preferred Alternative: The alternative in this EIS that BLM has initially selected because it best fulfills 

BLM’s mission and responsibilities and offers the most acceptable resolution of the planning issues and 

management concerns.

Prescribed Fire: Any fire ignited by management actions to meet specific objectives.
GL-12

Primitive Recreation: Recreation that occurs in a natural-appearing environment and that allows visitors 

to achieve solitude and isolation from human civilization. Primitive recreation may include hunting, 

horseback riding, wildlife viewing, nature study, photography, hiking, and backpacking.

Primitive Campground: No facilities just designated campsites.

Public Land: Any land administered by the Secretary of the Interior through the U.S. Bureau of Land 

Management or by the Secretary of Agriculture through the U.S. Forest Service.

Q

Quaternary: The current period of geologic time, beginning 1.6 million years ago and characterized by 

the appearance and dominance of humans. 

R

Realty Avoidance Area: An area where rights-of-way may be granted only when no feasible alternative 

route is available.

Realty Exclusion Area: An area where rights-of-way would be granted only in cases where there is a 

legal requirement to provide such access.

Reasonably Foreseeable Development (RFD): A projected development scenario for an activity in a 

defined area and period of time.

Record of Decision: A document signed by a responsible official recording a decision that was preceded 

by the preparing of an environmental impact statement.

Recreation Management Area (RMA): Designated land units where Recreation and Visitor Services 

objectives are recognized as a primary resource management consideration and specific management is 

required to protect the recreation opportunities. RMAs are classified as either special recreation 

management areas (SRMAs) or extensive recreation management areas (ERMAs).

Recreation Management Zone: In recreation management, an area with four defining characteristics: 

(1) it serves a different recreation niche within the primary recreation market, (2) it produces a different 

set of recreation opportunities and facilitates attaining different experiences and benefit outcomes, (3) it 

has a distinctive recreation setting character, and (4) it requires a different set of recreation provider 

actions to meet primary recreation market demand. 

Recreation Opportunity Spectrum (ROS): A planning process that provides a framework for defining 

classes of outdoor recreation environments, activities, and experience opportunities. In ROS, the setting, 

activities, and opportunities for experiences are arranged along a spectrum of six classes: Primitive, SemiPrimitive Non-Motorized, Semi-Primitive Motorized, Roaded Natural, Rural, and Urban. The resulting 

ROS analysis defines specific geographic areas on the ground. In this Resource Management Plan, the 

Ecosystem Restoration and Preferred Alternatives also propose a Backcountry class, which is a 

combination of Semi-Primitive Non-Motorized and Semi-Primitive Motorized.
GL-13

Resource Advisory Council (RAC): Advisory councils appointed by the Secretary of the Interior and 

consisting of representatives of major public land interest groups (e.g. commodity industries and 

recreation, environmental, and local area interests) in a state or smaller area. RACs advise BLM, focusing 

on a full array of multiple use public land issues. RACs also help develop fundamentals for rangeland 

health and guidelines for livestock grazing.

Resource Management Plan (RMP): A land use plan as described by the Federal Land Policy and 

Management Act. The RMP generally establishes in a written document: (1) land areas for limited, 

restricted or exclusive use; designations, including ACEC designations; and transfer from the Bureau of 

Land Management administration; (2) allowable resource uses (either singly or in combination) and 

related levels of production or use to be maintained; (3) resource condition goals and objectives to be 

attained; (4) program constraints and general management practices needed to achieve the above items; 

(5) need for an area to be covered by more detailed and specific plans; (6) support actions, including such 

measures as resource protection, access development, realty action, and cadastral survey., as needed to 

achieve the above; (7) general implementation sequences, where carrying out a planned action depends on 

prior accomplishment of another planned action; and (8) intervals and standards for monitoring and 

evaluating the plan to determine its effectiveness and the need for amendment or revision. It is not a final 

implementation decision on actions that require further specific plans, process steps, or decisions under 

specific provisions of law and regulations.

Right-of-Way (ROW): A permit or an easement that authorizes the use of public land for specified 

purposes, such as pipelines, roads, telephone lines, electric lines, communication sites, reservoirs, and the 

lands covered by such a permit.

Rills: A little stream or brook or a small channel cut in soil.

S

Saleable Minerals: See Mineral Materials.

Santa Fe Group: Basin-fill sediments associated with the Rio Grande Rift deposited from late 

Oligocene to middle Pleistocene (25 MY to ~1.8 MY). 

Scoping: An early and open process for determining the scope of issues to be addressed in an 

environmental impact statement and the significant issues related to a proposed action. 

Section 106 of the National Historic Preservation Act: The section of the National Historic 

Preservation Act that requires that Federal agencies having direct or indirect jurisdiction over a proposed 

Federal, Federally-assisted, or Federally-licensed undertaking, before approving the spending of funds or 

issuing a license, consider the effect of the undertaking on any district, site, building, structure, or object 

included in or eligible for inclusion in the National Register of Historic Places, and give the Advisory 

Council on Historic Preservation a reasonable opportunity to comment on the undertaking. Also see 

NATIONAL HISTORIC PRESERVATION ACT and NATIONAL REGISTER OF HISTORIC 

PLACES, and SECTION 110 OF THE NATIONAL HISTORIC PRESERVATION ACT. 
GL-14

Section 110 of the National Historic Preservation Act: The section of the National Historic 

Preservation Act that concerns the managing of Federally-owned historic properties. Among other 

provisions, Section 110 requires each Federal agency to establish a program to locate, inventory, protect, 

restore and nominate to the Secretary of the Interior Standards all properties under its control that appear 

to qualify for the National Register of Historic Places. Also see NATIONAL HISTORIC 

PRESERVATION ACT, NATIONAL REGISTER OF HISTORIC PLACES, and SECTION 106 OF 

THE NATIONAL HISTORIC PRESERVATION ACT.

Seral Stages: The development stages of ecological succession.

Short-Term Impacts: Impacts projected to occur from 0-10 years 

Sphenacodont Pelycosaur: A large extinct reptile that was common in Europe and North America 

during the Permian period, 245 to 290 million years ago. 

Standards for Rangeland Health: A description of conditions needed to sustain public land health; 

relates to all uses of the public land. These standards address soils, streams, water quality, riparianwetlands, and biodiversity.

State Historic Preservation Officer (SHPO): The state official authorized to act as a liaison to the 

Secretary of the Interior for implementing the National Historic Preservation Act of l966.

Succession: The progressive replacement of plant communities on an ecological site that leads to the 

climax community. Early seral stages are normally dominated by perennial grasses and annual as well as 

perennial forbs with few shrubs. During mid seral the woody species that the site supports such as shrubs 

and trees begin to make an obvious appearance, and annual forbs are dominated by perennial forbs. 

During late seral the shrubs normally dominate the cover on the site, but the perennial grasses still provide 

the most annual production on into the potential natural community. 

T

Taylor Grazing Act: An act passed in 1934 that provides for the regulation of grazing on the public 

lands (excluding Alaska) to improve rangeland conditions and stabilize the western livestock industry. 

Tectonism: Faulting or folding or other deformation of the outer layer of a planet. It happens very 

slowly, on the scale of millions of years.

Threatened Species: Any species defined through the Endangered Species Act (ESA) as likely to 

become endangered within the foreseeable future throughout all or a significant portion of its range. Also 

see ENDANGERED SPECIES.

Trackway: This is a trace fossil made by an organism and indicates motion or direction. They include 

footprints, tail drags, belly drags, and body imprints.

Trace Fossil: Geological records of biological activity. Trace fossils may be impressions made on the 

substrate by an organism; for example, burrows borings, footprints and feeding marks, and root cavities.
GL-15

V

Valid Existing Rights: Locatable mineral development rights that existed when the Federal Land Policy 

and Management Act was enacted on October 21, 1976. Mining claims that existed as of the effective 

date of the segregation may still be valid if they can meet the test of discovery of a valuable mineral 

required under the Mining Law. Determining the validity of mining claims located in segregated lands 

requires BLM to conduct a validity examination and is called a “valid existing rights” determination.

Vertebrate: An animal with a segmented spinal column and a well-developed brain (e.g., a mammal, 

bird, reptile, amphibian, or fish). 

Viewshed: The entire area visible from a viewpoint.

Visitor Contact Station: A facility that is generally a low-impact development often requiring no 

utilities or personnel to operate it. For the purposes of this Resource Management Plan, a visitor contact 

station could be as minimal as a kiosk with or without brochures, or an open-air structure such as a 

ramada or pavilion that contains tables, and possibly all-weather exhibits and printed materials offering 

maps and interpretive information. In addition to this, educational and interpretive events and 

opportunities would be offered here on a limited basis depending on the availability of staffing, and 

probably only for planned events.

Visitor Center: A full-service facility requiring the full array of utilities (electric, water, phone) and 

staffing to meet the needs of visitors. It would serve as a museum for the resources of the Prehistoric 

Trackways National Monument and would be a facility where a full-array of educational and interpretive 

events and opportunities would be available during operating hours.

Vug: A small hole in a rock or vein that often contains a mineral lining that differs from that of the 

surrounding matrix.

W

Watershed: An area of land from which water drains toward a single stream. The watershed is a 

hydrologic unit often used as a physical-biological unit and a socioeconomic-political unit for planning 

and managing natural resources.

Wilderness: An area of undeveloped Federal land retaining its primeval character and influence, without 

permanent improvement or human habitation, that is protected and managed so as to preserve its natural 

conditions and that (1) generally appears to have been affected primarily by the forces of nature, with the 

imprint of man’s work substantially unnoticeable; (2) has outstanding opportunities for solitude or a 

primitive and unconfined type of recreation; (3) has at least 5,000 acres of land or is of sufficient size as 

to make practicable its preservation and use in an unimpaired condition; and (4) may also contain 

ecological, geological, or other features of scientific, educational, scenic, or historical value.

Wilderness Study Area (WSA): A roadless area that has been inventoried and found to be wilderness in 

character, has few human developments, and provides outstanding opportunities for solitude and primitive 

recreation, as described in Section 603 of the Federal Land Policy and Management Act of 1976 and in 

Section 2(c) of the Wilderness Act of l964.
GL-16

Wilderness Values: Values established in the Wilderness Act, such as solitude and naturalness.

Wildfire: An unplanned and unwanted wildland fire including unauthorized human-caused fires, escaped 

wildland fire use events, escaped prescribed fire projects, and all other wildland fires where the objective 

is to put the fire out.

Wildland Fire Use: The application of the appropriate management response to naturally ignited 

wildland fires to accomplish specific resource management objectives in predefined designated areas 

outlined in fire management plans. Operational management is described in the wildland fire 

implementation plan.

Withdrawal: An action that restricts the use of public land by removing them from the operation of 

some or all of the public land or mining laws.
GL-17

ACRONYMS

ACEC Area of Critical Environmental 

Concern

ADA Americans with Disabilities Act

AMP Allotment Management Plan

ATV All-Terrain Vehicle

AUM Animal Unit Month

BLM Bureau of Land Management 

BMP Best Management Practice 

CEQ Council on Environmental 

Quality 

CFR Code of Federal Regulations

CTTM Comprehensive Trails and Travel 

Management

EIS Environmental Impact Statement

ERMA Extensive Recreation 

Management Area

ESA Endangered Species Act

FLPMA Federal Land Policy and 

Management Act

FMP Fire Management Plan

FMU Fire Management Unit

FRCC Fire Regime Condition Class

GIS Geographic Information System

GHG Green House Gases

GPS Global Positioning System

IMP BLM’s Interim Management 

Policy for Lands under 

Wilderness Review

LGMP Livestock Grazing Management 

Practices 

LWC Lands with Wilderness 

Characteristics

MLRA Major Land Resource Area

NEPA National Environmental Policy 

Act 

NHPA National Historic Preservation 

Act 

NLCS National Landscape 

Conservation System 

NOI Notice of Intent 

NRCS Natural Resources Conservation 

Service 

NRHP National Register of Historic 

Places

OHV Off-highway Vehicle

PILT Payments in Lieu of Taxes 

PDM Predator Damage Management

PM2.5 Particulate matter less than 2.5

micrometers in diameter 

PM10 Particulate matter less than 10

micrometers in diameter

PTNM Prehistoric Trackways National 

Monument

RMA Recreation Management Area

RMP Resource Management Plan 

RNA Research Natural Area

ROD Record of Decision

ROS Recreation Opportunity 

Spectrum 

SHPO State Historic Preservation 

Officer

SHS Standard Habitat Sites

SSS Special Status Species

T&E Threatened and Endangered

USC United States Code

USDA U. S. Department of Agriculture 

USDI U. S. Department of the Interior 

USGS U.S. Geological Survey 

USFWS U.S. Fish and Wildlife Service

UTV Utility Vehicle

VRM Visual Resources Management

WSA Wilderness Study Area
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tHE 
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Management. BLM/NM/PL-00-001-1020. Las Cruces, New Mexico: Bureau of Land Management 

Las Cruces District Office.

_________. 2000. Instruction Memorandum No. 2000-096: “Use of Visual Resource Management 

Class I Designation in Wilderness Study Areas.” Las Cruces, New Mexico: BLM Las Cruces 

District Office.
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_________. 1998a. Doña Ana County Mountain Bike Trails Environmental Assessment

(NM-036-98-29). Las Cruces, New Mexico: BLM Las Cruces District Office.

_________. 1998b. Handbook 8270-1 General Procedural Guidance for Paleontological Resource 

Management. Las Cruces, New Mexico: BLM Las Cruces District Office.

_________. 1997. Robledo Mountains Off-Highway Vehicle Implementation Plan and Environmental 

Assessment (NM-036-1997-083). Las Cruces, New Mexico: BLM Las Cruces District Office.

_________. 1995. Handbook 8550- Interim Management Policy for Lands under Wilderness Review. 

Las Cruces, New Mexico: BLM Las Cruces District Office.

_________. 1993. Mimbres Resource Management Plan. Las Cruces, New Mexico: Bureau of Land 

Management Las Cruces District Office.

_________. 1992. Introduction, Transplant, Augmentation, and Reestablishment of Fish, Wildlife, and 

Plants Manual 1745.

_________. 1986. Handbook 8410-1 Visual Resource Inventory. Washington DC: United States 

Printing Office.

_________. 1983. Draft Management Framework Plan Amendment EIS on Energy Minerals Leasing 

and Rangeland Management in the Las Cruces/ Lordsburg Resource Area, March 1983. Las Cruces, 

New Mexico: BLM Las Cruces District Office.

U.S. Department of the Interior and U.S. Department of Agriculture. 1995. The Federal Wildland Fire 

Management Policy and Program Review. Las Cruces, New Mexico: BLM Las Cruces District.

U.S. Department of the Interior, Fish and Wildlife Service (USFWS). 2006. National Survey of Fishing, 

Hunting, and Wildlife-Associated Recreation. Albuquerque, New Mexico: 

U.S. Global Change Research Program. 2009. “Impacts of Climate Change in the United States.” 

Cambridge University Press. 196 pp. http://www.globalchange.gov/publications/reports/scientificassessments/us-impacts.

U.S. Government Printing Office. April 18, 2008. “Emergency Closure to Unpermitted Collection of 

Petrified Wood and Plant Fossils in the Robledo Mountains on Federal Land, Dona Ana County, 

NM.” Federal Register, Vol. 73, Number 76, page 21151.

U.S. Government Printing Office. January 10, 2010. “Notice of Intent to Prepare a Resource 

Management Plan for the Prehistoric Trackways National Monument, Las Cruces District Office, 

New Mexico and Associated Environmental Impact Statement.” Federal Register, Vol. 75, 

Number 2, pages 431-432.

Vallentine, J. F. 1989. Range Development and Improvements. San Diego, CA: Academic Press Inc.

Westbrooks, R. 1998. “Invasive plants, changing the landscape of America: Fact book. Federal 

Interagency Committee for the Management of Noxious and Exotic Weeds (FICMNEW).”

Washington, DC.
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Whitson, T. D., L. C. Burrill, S. A. Dewey, D. W. Cudney, B. E. Nelson, R. D. Lee, and R. Parker. 2006.

Weeds of the West. 9

th ed. Newark, CA : Western Society of Weed Science in cooperation with the 

Western United States Land Grant Universities Cooperative Extension Services, 628 p.

Witcher, J.C. 1995. Geothermal resource database for New Mexico: Southwest Technology 

Development Institute.” Las Cruces, New Mexico: New Mexico State University, 38 p.
APPENDICE

S

tHE 

APPENDIX A

The Omnibus Public Lands Management Act 2009

APPENDIX B

Acts of Authority and Mandates for the BLM

APPENDIX C

Prehistoric Trackways National Monument Comprehensive Trails

and Travel Management Plan

APPENDIX D

Paleontology

APPENDIX E

Best Management Practices

APPENDIX F

Public Scoping Report

APPENDIX G

Safety Zones for Recreational Target Shooting Analysis

APPENDIX H

Public Comments on Draft RMP/EIS and Responses
THE OMNIBUS PUBLIC LANDS 

MANAGEMENT ACT OF 2009

APPENDIX 

A

tHE 
A-1

APPENDIX A

THE OMNIBUS PUBLIC LANDS MANAGEMENT ACT 

2009

Subtitle B—Prehistoric Trackways National Monument

SEC. 2101. FINDINGS.

Congress finds that—

(1) in 1987, a major deposit of Paleozoic Era fossilized footprint megatrackways was discovered in the 

Robledo Mountains in southern New Mexico;

(2) the trackways contain footprints of numerous amphibians, reptiles, and insects (including previously 

unknown species), plants, and petrified wood dating back approximately 280,000,000 years, which 

collectively provide new opportunities to understand animal behaviors and environments from a time 

predating the dinosaurs;

(3) title III of Public Law 101–578 (104 Stat. 2860)—

(A) provided interim protection for the site at which the trackways were discovered; and

(B) directed the Secretary of the Interior to—

(i) prepare a study assessing the significance of the site; and

(ii) based on the study, provide recommendations for protection of the paleontological 

resources at the site;

(4) the Bureau of Land Management completed the Paleozoic Trackways Scientific Study Report in 1994, 

which characterized the site as containing ‘‘the most scientifically significant Early Permian tracksites’’ 

in the world;

(5) despite the conclusion of the study and the recommendations for protection, the site remains 

unprotected and many irreplaceable trackways specimens have been lost to vandalism or theft; and 

(6) designation of the trackways site as a National Monument would protect the unique fossil resources 

for present and future generations while allowing for public education and continued scientific research 

opportunities.

SEC. 2102. DEFINITIONS.

In this subtitle:

(1) MONUMENT. — The term ‘‘Monument’’ means the Prehistoric

Trackways National Monument established by section 2103(a).

(2) PUBLIC LAND. — The term ‘‘public land’’ has the meaning given the term ‘‘public lands’’ in 

section 103 of the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1702).

(3) SECRETARY. — The term ‘‘Secretary’’ means the Secretary of the Interior.
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SEC. 2103. ESTABLISHMENT.

(a) IN GENERAL.—In order to conserve, protect, and enhance the unique and nationally important 

paleontological, scientific, educational, scenic, and recreational resources and values of the public land 

described in subsection (b), there is established the Prehistoric Trackways National Monument in the 

State of New Mexico.

(b) DESCRIPTION OF LAND.—The Monument shall consist of approximately 5,280 acres of public 

land in Doña Ana County, New Mexico, as generally depicted on the map entitled ‘‘Prehistoric 

Trackways National Monument’’ and dated December 17, 2008.

(c) MAP; LEGAL DESCRIPTION.—

(1) IN GENERAL.—As soon as practicable after the date of enactment of this Act, the Secretary shall 

prepare and submit to Congress an official map and legal description of the Monument.

(2) CORRECTIONS.—The map and legal description submitted under paragraph (1) shall have the same 

force and effect as if included in this subtitle, except that the Secretary may correct any clerical or 

typographical errors in the legal description and the map.

(3) CONFLICT BETWEEN MAP AND LEGAL DESCRIPTION.—In the case of a conflict between the 

map and the legal description, the map shall control.

(4) AVAILABILITY OF MAP AND LEGAL DESCRIPTION.—Copies of the map and legal description 

shall be on file and available for public inspection in the appropriate offices of the Bureau of Land 

Management.

(d) MINOR BOUNDARY ADJUSTMENTS.—If additional paleontological resources are discovered on 

public land adjacent to the Monument after the date of enactment of this Act, the Secretary may make 

minor boundary adjustments to the Monument to include the resources in the Monument.

SEC. 2104. ADMINISTRATION.

(a) MANAGEMENT.—

(1) IN GENERAL.—The Secretary shall manage the Monument—

(A) in a manner that conserves, protects, and enhances the resources and values of the Monument, 

including the resources and values described in section 2103(a); and

(B) in accordance with—

(i) this subtitle;

(ii) the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1701 et seq.); and

(iii) other applicable laws.

(2) NATIONAL LANDSCAPE CONSERVATION SYSTEM.—The

Monument shall be managed as a component of the National Landscape Conservation System.
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(b) MANAGEMENT PLAN.—

(1) IN GENERAL.—Not later than 3 years after the date of enactment of this Act, the Secretary 

shall develop a comprehensive management plan for the long-term protection and management of 

the Monument.

(2) COMPONENTS.—The management plan under paragraph (1)—

(A) shall—

(i) describe the appropriate uses and management of the Monument, consistent with the 

provisions of this subtitle; and

(ii) allow for continued scientific research at the Monument during the development of 

the management plan; and

(B) may—

(i) incorporate any appropriate decisions contained in any current management or activity 

plan for the land described in section 2103(b); and

(ii) use information developed in studies of any land within or adjacent to the Monument 

that were conducted before the date of enactment of this Act.

(c) AUTHORIZED USES.—The Secretary shall only allow uses of the Monument that the Secretary 

determines would further the purposes for which the Monument has been established.

(d) INTERPRETATION, EDUCATION, AND SCIENTIFIC RESEARCH.—

(1) IN GENERAL.—The Secretary shall provide for public interpretation of, and education and 

scientific research on, the paleontological resources of the Monument, with priority given to 

exhibiting and curating the resources in Doña Ana County, New Mexico.

(2) COOPERATIVE AGREEMENTS.—The Secretary may enter into cooperative agreements 

with appropriate public entities to carry out paragraph (1).

(e) SPECIAL MANAGEMENT AREAS.—

(1) IN GENERAL.—The establishment of the Monument shall not change the management status 

of any area within the boundary of the Monument that is—

(A) designated as a wilderness study area and managed in accordance with section 603(c) 

of the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1782(c)); or

(B) managed as an area of critical environmental concern.

(2) CONFLICT OF LAWS.—If there is a conflict between the laws applicable to the areas 

described in paragraph (1) and this subtitle, the more restrictive provision shall control.

(f) MOTORIZED VEHICLES.—

(1) IN GENERAL.—Except as needed for administrative purposes or to respond to an 

emergency, the use of motorized vehicles in the Monument shall be allowed only on roads and 

trails designated for use by motorized vehicles under the management plan prepared under 

subsection (b).
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(2) PERMITTED EVENTS.—The Secretary may issue permits for special recreation events 

involving motorized vehicles within the boundaries of the Monument—

(A) to the extent the events do not harm paleontological resources; and

(B) subject to any terms and conditions that the Secretary determines to be necessary.

(g) WITHDRAWALS.—Subject to valid existing rights, any Federal land within the Monument and any 

land or interest in land that is acquired by the United States for inclusion in the Monument after the date 

of enactment of this Act are withdrawn from—

(1) entry, appropriation, or disposal under the public land laws;

(2) location, entry, and patent under the mining laws; and

(3) operation of the mineral leasing laws, geothermal leasing laws, and minerals materials laws.

(h) GRAZING.—The Secretary may allow grazing to continue in any area of the Monument in which 

grazing is allowed before the date of enactment of this Act, subject to applicable laws (including 

regulations).

(i) WATER RIGHTS.—Nothing in this subtitle constitutes an express or implied reservation by the 

United States of any water or water rights with respect to the Monument.

SEC. 2105. AUTHORIZATION OF APPROPRIATIONS.

There are authorized to be appropriated such sums as are necessary to carry out this Act.
ACTS OF AUTHORITY AND MANDATES 

FOR THE BLM

APPENDIX B

tHE 
B-1

APPENDIX B

ACTS OF AUTHORITY AND MANDATES

FOR THE BLM

A number of Federal statutes have been enacted over time to establish and define the authority of the

Bureau of Land Management (BLM) to make decisions on the management and use of resources on 

public land. Following is a list of major legal authorities relevant to BLM land use planning.

Federal Land Policy and Management Act (FLPMA) of 1976, as amended (43 United States Code 

[U.S.C.] 1701, et seq.) provides the authority for BLM’s land use planning. This statute and its

implementing regulations define principles for the management of public land and its resources. This Act 

directs the Secretary of the Interior to develop, maintain, and when appropriate, revise land use plans that 

provide for the use of public land managed on the basis of multiple-use and sustained yield unless

otherwise specified by law. Through FLPMA, BLM is responsible for the balanced management of the

public land and resources and their various values. FLPMA specifically states that public land will be

managed under the principles of multiple-use, and it further indicates that multiple-use includes

harmonious and coordinated management of the various resources without permanent impairment of the 

productivity of the land and the quality of the environment.

• Section 102 (a) (7) and (8) sets forth the policy of the United States concerning the 

management of BLM land.

• Section 201 requires the Secretary of the Interior to prepare and maintain an inventory of all 

BLM land and its resources and other values, giving priority to areas of critical 

environmental concern and, as funding and workforce are available, to determine the 

boundaries of the public land, provide signs and maps to the public, and provide inventory 

data to State and local governments.

• Section 202 (a) requires the Secretary of the Interior, with public involvement, to develop,

maintain, and when appropriate, revise land use plans that provide by tracts or areas for the

use of the BLM land.

• Section 202 (c) (9) requires that land use plans for BLM land be consistent with Tribal plans

and, to the maximum extent consistent with applicable Federal laws, with State and local 

plans.

• Section 202 (d) provides that all public land, regardless of classification, is subject to

inclusion in land use plans, and that the Secretary of the Interior may modify or terminate

classifications consistent with land use plans.

• Section 202 (f) and 309 (e) provide that Federal, State, and local governments and the public 

be given adequate notice and an opportunity to comment on the formulation of standards and

criteria for, and to participate in, the preparation and execution of plans and programs for the

management of the public land.

• Section 302 (a) requires the Secretary of the Interior to manage BLM land under the

principles of multiple-use and sustained yield in accordance with (when available) land use 

plans developed under Section 202 of FLPMA, except that, where a tract of BLM land has 

been dedicated to specific uses according to any other provisions of law, it shall be managed 

in accordance with such laws.

• Section 603 specifically directs BLM to carry out a wilderness review of public land and

directs the BLM to manage such land in a manner so as not to impair the suitability of such

area for preservation as wilderness.
B-2

The National Environment Policy Act of 1969, as amended (42 U.S.C. 4321, et seq.), requires the

consideration and public availability of information regarding the environmental impacts of major Federal

actions significantly affecting the quality of the human environment. The law further requires the Federal

authorized officers to identify and describe the significant environmental issues associated with their

decisions and to develop alternatives to a proposed action (including the alternative of no action). Federal

authorized officers must disclose the direct, indirect, and cumulative effects of the decisions; adverse 

environmental effects that cannot be avoided; the relationship between short-term uses of the human

environment and the maintenance of long-term productivity; and any irreversible or irretrievable

commitments of resources made by the decision.

The Clean Air Act of 1990, as amended (42 U.S.C. 7418), requires Federal agencies to comply with all

Federal, State, and local requirements regarding the control and abatement of air pollution. This includes

abiding by the requirements of State implementation plans. The Clean Air Act provides that each State is

responsible for ensuring achievement and maintenance of air quality standards within its borders so long

as such standards are at least as stringent as Federal standards established by the U.S. Environmental

Protection Agency (EPA).

The Clean Water Act (CWA) of 1987, as amended (33 U.S.C. 1251), establishes objectives to restore

and maintain the chemical, physical, and biological integrity of the Nation’s water. Upon passage of the

Environmental Quality Acts and adoption of the water quality standards, State agencies were empowered

to enforce water quality standards as long as they are at least as stringent as the Federal standards 

established by the EPA. The State of New Mexico has not been delegated authority from the Federal

Government for any of the major water quality programs under the CWA, including the National

Pollutant Discharge Elimination System, Pretreatment, Sludge Management, and Wetlands. Also, 

Section 404 of the CWA, administered by the U.S. Army Corps of Engineers, requires that waters of the 

United States be protected by permits prior to dredge or fill activities in such areas. Waters include 

intermittent streams, mud flats, and sand flats. Wetlands that meet jurisdictional criteria of Section 404 of 

the CWA are partially protected in that a permit is required before any dredge or fill activity can occur in 

such areas.

The Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531, et seq.), provides a means 

whereby the ecosystems upon which threatened and endangered species depend may be conserved and to 

provide a program for the conservation of such threatened and endangered species (Section 1531(b),

Purposes). The ESA requires all Federal agencies to seek to conserve threatened and endangered species,

use applicable authorities in furtherance of the purposes of the ESA (Section 1531(c) (1), Policy), and

avoid jeopardizing the continued existence of any species that is listed or proposed for listing as 

threatened and endangered or destroying or adversely modifying its designated or proposed critical 

habitat (Section 1536(a), Interagency Cooperation). The U.S. Fish and Wildlife Service (USFWS) is 

responsible for administration of this Act, which also requires all Federal agencies to consult (or confer) 

in accordance with Section 7 of the ESA with the Secretary of the Interior, through the USFWS and/or the 

National Marine Fisheries Service, to ensure that any Federal action (including land use plans) or activity

is not likely to jeopardize the continued existence of any species listed or proposed to be listed under the

provisions of the ESA, or result in the destruction or adverse modification of designated or proposed

critical habitat (Section 1536(a), Interagency Cooperation, and Title 50 Code of Federal Regulations Part

402 [50 CFR 402]). Mitigation measures are developed through the consultation process and are put forth

as suggested conservation measures included in a formal USFWS Biological Opinion, which addresses

whether the proposed action would jeopardize the continued existence of any officially listed endangered

or threatened species.
B-3

The Statewide Resource Management Plan Amendment/Environmental Impact Statement for New

Mexico Standards for Public Land Health and Guidelines for Livestock Grazing Management

(Standards and Guidelines) established a set of standards and guidelines for public land health and

guidelines for livestock grazing management in New Mexico. Standards of land health are expressions of

physical and biological conditions or degrees of function required for healthy and sustainable land and 

define minimum resource conditions that must be achieved. Standards describe conditions needed for

healthy sustainable public rangelands and relate to all uses of public land. They provide the measure of

resource quality and functioning condition by which the health of public land will be assessed. To

measure the effectiveness of each standard, a set of indicators and associated criteria were identified. 

Specific standards and indicators are defined for upland sites, biotic communities (including native,

threatened, endangered, and special status species), and riparian sites.

Guidelines are practices, methods, or techniques determined to be appropriate to ensure that standards can

be met or that significant progress can be made toward meeting those standards. Guidelines are tools 

such as grazing systems, vegetative treatments, or improvement projects that help managers and 

permittees achieve standards. Guidelines for livestock grazing are described in the Standards and 

Guidelines. The livestock grazing guidelines were designed to improve public land health and are to be 

implemented at the watershed, allotment, or pasture level if it is determined that the standards are not 

being met and that livestock grazing is the cause. Guidelines for activities other than livestock grazing 

are not mandated through regulation; however, they may be developed should the need arise. If it is 

determined that the standards are not being met as a result of another activity (i.e., road placement, 

recreation, etc.), program leads would determine appropriate actions to ensure that standards can be met 

or that significant progress can be made toward meeting those standards.

The Federal Water Pollution Control Act (33 U.S.C. 1323) requires the Federal land manager to

comply with all Federal, State, and local requirements, administrative authority, process, and sanctions

regarding the control and abatement of water pollution in the same manner and to the same extent as any

nongovernmental entity.

The Safe Drinking Water Act (42 U.S.C. 201) is designed to make the Nation’s waters “drinkable” as

well as “swimmable.” Amendments in 1996 established a direct connection between safe drinking water

and watershed protection and management.

The Resource Conservation and Recovery Act of 1976 (Public Law [P.L.] 89-72) gave the EPA the

authority to control hazardous waste from “cradle to grave.” This includes the generation, transportation,

treatment, storage, and disposal of hazardous waste. The Act also set forth a framework for the

management of nonhazardous wastes.

The Wilderness Act, as amended (16 U.S.C. 1131, et seq.) authorizes the President to make

recommendations to Congress for Federal land to be set aside for preservation as wilderness.

The Antiquities Act of 1906 (16 U.S.C. 431-433) protects cultural and paleontological resources on

Federal land and authorizes the President to designate national monuments on Federal land.

The Archaeological Resources Protection Act of 1979 (16 U.S.C 470) secures, for the present and

future benefit of the American people, the protection of archaeological resources and sites that are on

public land and American Indian land, to foster increased cooperation and exchange of information

among governmental authorities, the professional archaeological community, and private individuals

having collections of archaeological resources and data that were obtained before October 31, 1979.
B-4

The National Historic Preservation Act, as amended (16 U.S.C. 470), expands protection of historic and 

archaeological properties to include those of National, State, and local significance and directs Federal

agencies to consider the effects of proposed actions on properties eligible for or included in the National

Register of Historic Places. The Act mandates that when Federal undertakings (i.e., Federal projects or

Federally-funded or licensed projects) are planned and implemented, the responsible Federal agencies 

give due consideration to historic properties (i.e., resources eligible for the National Register of Historic

Places), regardless of land status. Regulations for Protection of Historic Properties (36 CFR 800) define 

a process for demonstrating such consideration by consulting with the State Historic Preservation 

Officers, Federal Advisory Council on Historic Preservation, and other interested organizations and 

individuals.

The American Indian Religious Freedom Act of 1978 (42 U.S.C. 1996) establishes a National policy to

protect and preserve the right of American Indians to exercise traditional Indian religious beliefs or

practices.

The Historic Sites Act of 1935 (16 U.S.C. 461-467) defines a National policy to identify and preserve

historic sites, buildings, objects, and antiquities of National significance. The law authorizes the 

Secretary of the Interior to conduct surveys, collect and preserve data, and acquire historic and 

archaeological sites.

The Archaeological and Historic Preservation Act of 1974 (16 U.S.C. 469-469c) provides for

preservation of archaeological and historical information that might otherwise be lost as a result of

Federal construction projects and other Federally-licensed activities and programs. This Act stipulates 

that up to 1 percent of the funding appropriated by Congress for Federal undertakings can be spent to 

recover, preserve, and protect archaeological and historical data. A subsequent amendment authorized the 

1 percent limit to be administratively exceeded under certain circumstances.

The Native American Grave Protection and Repatriation Act of 1990 (25 U.S.C. 3001-3013) protects

the human remains of indigenous peoples and funerary objects, sacred objects, and items of cultural

patrimony on Federal land. The Act also provides for the repatriation of such remains and cultural items

previously collected from Federal land and in the possession or control of a Federal agency or Federallyfunded repository.

The Curation of Federally-Owned and Administered Archaeological Collections (36 CFR 79)

stipulates standards for facilities that curate Federally-owned archaeological collections, which include 

not only artifacts but also all associated records and reports, to ensure long-term preservation of such

collections.

The White House Memorandum on Government-to-Government Relations with Native American

Tribal Governments of 1994 set forth guidelines requiring Federal agencies to adhere to directives 

designed to ensure that the rights of sovereign Tribal governments are fully respected.

The Land and Water Conservation Fund (LWCF) of 1964 (16 U.S.C. 460l-4, et seq.) provides 

funding to assist in preserving, developing, and assuring accessibility to outdoor recreation resources 

including but not limited to parks, trails, wildlife land, and other land and facilities desirable for 

individual active participation. It also authorized BLM to collect fees for recreational use and to issue 

special recreation permits for group activities and recreation events and limits the services for which 

BLM may collect fees.
B-5

The Federal Lands Recreation Enhancement Act (FLREA) replaced LWCF as BLM’s authority to 

collect fees in 2004. Under FLREA, Congress has authorized the BLM to collect two types of recreation 

fees, Amenity Recreation fees and Special Recreation Permit fees. FLREA also authorizes the BLM to 

retain these fees locally so they can be used to repair, maintain, and upgrade recreational facilities and 

services to meet public demand.

The Taylor Grazing Act of 1934 (43 U.S.C. 315) establishes grazing districts of vacant, unappropriated

and unreserved land in any parts of the public domain, excluding Alaska, that are not National forests,

parks and monuments, American Indian reservations, railroad grant land, or revested Coos Bay Wagon 

Road grant land, and that are valuable chiefly for grazing and raising forage crops; the Act uses a

permitting system to manage livestock grazing in the districts. In addition, the Act provides for the

protection, administration, regulation and improvement of the grazing districts; promotes the adoption of

regulations and cooperative agreements necessary to accomplish the purposes of the Act; regulates

occupancy and use; preserves the land and resources from destruction or unnecessary injury; and provides

for orderly improvement and development of the range. The Act also allows for the continuing study of

erosion and flood control and performance of work to protect and rehabilitate areas subject to the Act. 

Willful violations of the Act, or of its rules and regulations, are punishable by fine.

The Public Rangelands Improvement Act of 1978 (43 U.S.C. 1901) provides that the public rangeland

be managed so that it becomes as productive as feasible in accordance with management objectives and

the land use planning process established pursuant to 43 U.S.C. 1712.

The Federal Cave Resource Protection Act of 1988 (43 CFR 37.11[C] and [F]) provides protection for

caves containing significant geological, biological, historical, cultural, and other resources.

The Carlson-Foley Act of 1968 (P.L. 90-583) directs Federal agencies to enter upon land under their

jurisdiction that has noxious plants (weeds) and to destroy noxious plants growing on such land.

The Federal Noxious Weed Act of 1974 (7 U.S.C. 2801-2814) provides for the control and management

of nonindigenous weeds that injure or have the potential to injure the interests of agriculture and

commerce, wildlife resources, or the public health. The Act requires that each Federal agency develop a

management program to control undesirable plants on Federal land under the agency’s jurisdiction;

establish and adequately fund the program; implement cooperative agreements with State agencies to

coordinate management of undesirable plants on Federal land; establish integrated management systems

to control undesirable plants targeted under cooperative agreements. A Federal agency is not required to

carry out management programs on Federal land unless similar programs are being implemented on State

or private lands in the same area. The Act also directs the Secretaries of Agriculture and the Interior to 

coordinate programs for control, research, and educational efforts associated with noxious weeds. The 

Secretaries must identify regional control priorities and disseminate technical information to interested 

State, local, and private entities.

The Plant Protection Act of 2000 (P.L. 106-224) prohibits the import, export, and movement in 

interstate commerce or mailing of any plant pest unless authorized by the Secretary of Agriculture;

authorizes the Secretary to prohibit or restrict the import, export, or movement in interstate commerce of

any plant, plant product, biological control organism, noxious weed, or means of conveyance to prevent

the introduction or dissemination of a plant pest or noxious weed; and combines all or a portion of 11

Acts or resolutions into one Act.
B-6

The Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. 703-712), implements various treaties

and conventions between the United States and Canada, Japan, Mexico, and the former Soviet Union for

the protection of migratory birds. Under the Act, taking, killing, or possessing migratory birds is 

unlawful.

The Fish and Wildlife Coordination Act of 1958, as amended (16 U.S.C 661-667), proposes to assure

that fish and wildlife resources receive equal consideration with other values during the planning of water

resources development projects. The Act requires coordination with USFWS by the U.S. Department of

Energy when a project is planned that may affect a body of water. It also requires coordination with the

head of the State agency that administers wildlife resources in the affected state.

The Sikes Act of 1960, as amended (16 U.S.C. 670, et seq.), seeks to promote effectual planning,

development, maintenance, and coordination of wildlife, fish, and game conservation and rehabilitation 

on military reservations.

The Fish and Wildlife Conservation Act of 1980 (16 U.S.C. 2901-2911) authorizes financial and

technical assistance to the States for the development, revision, and implementation of conservation plans

and programs for nongame fish and wildlife.

Paleontological Resources Preservation Act - Public Law 111-11, Title VI, Subtitle D 270 

Legislation establishing requirements that the Secretary of the Interior manage and protect paleontological 

resources on Federal land using scientific principals and expertise. This Act specifically requires the 

Secretary to develop plans for the inventory, monitoring, and scientific and educational use of 

paleontological resources; addresses the collection and curation of resources; identifies prohibited acts, 

and establishes criminal and civil penalties. This Act is contained in Public Law 111-11, Title VI, 

Subtitle D, which was enacted in March 2009.

Executive Order 11644: Use of Off-Road Vehicles on the Public Lands (as amended by Executive

Order 11989) (37 Federal Register [FR] 2877 [1971]) establishes policies and provides for procedures

that will ensure that the use of off-road vehicles on public land will be controlled and directed so as to

protect the resources of those land, promote the safety of all users of those land, and minimize conflicts

among the various uses of those land.

Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations

and Low-Income Populations (49 FR 7629 [1994]) requires that each Federal agency consider the

impacts of its programs on minority populations and low-income populations.

Executive Order 13007: Indian Sacred Sites (61 FR 26771 [1996]) requires Federal agencies to the

extent practicable, permitted by law, and not clearly inconsistent with essential agency functions to

accommodate access to and ceremonial use of American Indian sacred sites by Indian religious

practitioners and avoid adversely affecting the physical integrity of such sacred sites.

Executive Order 13287: Preserve America directs Federal agencies to provide leadership in preserving

the Nation’s heritage by actively advancing the protection, enhancement and contemporary use of historic

and paleontological properties owned by the Federal Government, emphasizing partnerships. Under this

order, agencies shall cooperate with communities to increase opportunities for public benefit from, and

access to, Federally-owned historic and paleontological properties.
B-7

Executive Order 13084: Consultation and Coordination with Indian Tribal Governments provides,

in part, that each Federal agency shall establish regular and meaningful consultation and collaboration

with Indian Tribal governments in the development of regulatory practices on Federal matters that

significantly or uniquely affect their communities.

Executive Order 13112: Invasive Species provides that no Federal agency shall authorize, fund, or carry

out actions that it believes are likely to cause or promote the introduction or spread of invasive species

unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its

determination that the benefits of such actions clearly outweigh the potential harm caused by invasive

species; and that all feasible and prudent measures to minimize risk or harm will be taken in conjunction

with the actions.

Executive Order 11988: Floodplain Management requires each agency to provide leadership and take

action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and

welfare, and to restore and preserve the natural and beneficial values served by floodplains. Each agency

must evaluate the potential effects of any actions it may take in a floodplain; to ensure that its planning

programs and budget requests reflect consideration of flood hazards and floodplain management; and to

prescribe procedures to implement the policies and requirements of this order.

Executive Order 11990 Protection of Wetlands required each Federal agency to provide leadership and

take action to minimize the destruction, loss or degradation of wetlands, and to preserve and enhance the

natural and beneficial values of wetlands.

Executive Order 12906: Coordinating Geographic Data Acquisition and Access: The National 

Spatial Data Infrastructure requires that the Federal Government avoids wasteful duplication of 

geospatial data and effort and promote effective and economical management of resources by Federal, 

State, local and Tribal government.

Secretarial Order 3206: American Indian Tribal Rights, Federal-Tribal Trust Responsibilities, and

the Endangered Species Act requires U.S. Department of the Interior agencies to consult with American

Indian Tribes when agency actions to protect a listed species, as a result of compliance with the ESA,

affect or may affect American Indian land, Tribal trust resources, or the exercise of American Indian 

Tribal rights.

Regulations governing BLM’s Special Recreation Permit program can be found in Title 43 Code of 

Federal Regulations, Part 2930 (43CFR2930).
B-8

INSTRUCTION MEMORANDUMS

Instruction Memorandum (IM) No. 2008-009 (October 15, 2007) – Subject: Potential Fossil Yield 

Classification (PFYC) System for Paleontological Resources on Public Lands. This Instruction 

Memorandum (IM) transmits the Bureau of Land Management (BLM) classification system for 

paleontological resources on public land. The classification system is based on the potential for the 

occurrence of significant paleontological resources in a geologic unit, and the associated risk for impacts 

to the resource based on Federal management actions.

Instruction Memorandum 2009-110 – Subject: Assessment and Mitigation of Potential Impacts to 

Paleontological Resources. This IM provides guidelines for assessing potential impacts to 

paleontological resources in order to determine mitigation steps for Federal actions on public land under 

the Federal Land Policy and Management Act (FLPMA) and the National Environmental Policy Act 

(NEPA). These guidelines also apply where a Federal action impacts split-estate land. In addition, this 

IM provides field survey and monitoring procedures to help minimize impacts to paleontological 

resources from Federal actions in the case where it is determined that significant paleontological 

resources will be adversely affected by a Federal action.

Instruction Memorandum No. 2009-113 – (April 24, 2009) Subject: Casual Collecting of Common 

Invertebrate and Plan Paleontological Resources under the Paleontological Resources Preservation 

Act of 2009. This IM provides guidelines regarding casual collecting under the provisions of the 

Paleontological Resources Preservation Act (PRPA) of 2009.

Instruction Memorandum No. 2009-138 (June 5, 2009) – Subject: Confidentiality of Paleontological 

Locality Information under the Omnibus Public Lands Act of 2009 (123 Stat. 991), Title VI, Subtitle D, 

Paleontological Resources Preservation (OPLA-PRP). This IM establishes policy regarding the 

confidentiality of paleontological locality information under the provisions of the OPLA-PRP.

Instruction Memorandum No. 2012-067 – Subject: Clarification of Cultural Resource 

Considerations for Off-Highway Vehicle Designations and Travel Management. As part of its 

comprehensive travel management program, the Bureau of Land Management (BLM) incorporates road 

and trail access guidance into every Land Use Plan (LUP). At a minimum, by regulation, every plan 

designates all public land as open, limited, or closed to off highway vehicle (OHV) use. For limited use 

areas, the BLM designates a network of roads and trails and may establish other limiting criteria, such as 

the volume and type of vehicular use and the time and season of use. The BLM considers designations of 

travel areas, roads and trails to be undertakings for the purposes of Section 106 of the National Historic 

Preservation Act (NHPA). Therefore, the Section 106 consultation process must be completed before the 

BLM authorized officer signs the decision record for the designation.
B-9

BLM HANDBOOKS AND MANUALS

BLM Manual 8270 and BLM Handbook H-8270-1 contain the agency's guidance for the management 

of paleontological resources on public land. The Manual has more information on the authorities and 

regulations related to paleontological resources. The Handbook gives procedures for permit issuance, 

requirements for qualified applicants, information on paleontology and planning, and a classification 

system for potential fossil-bearing geologic formations on public land.

BLM Handbook 1601-1 Land Use Planning Handbook provides supplemental guidance to the Bureau 

of Land Management (BLM) employees for implementing the BLM land use planning requirements 

established by Sections 201 and 202 of the Federal Land Policy and Management Act of 1976 (FLPMA, 

43 U.S.C. 1711-1712) and the regulations in 43 Code of Federal Regulations (CFR) 1600. Land use plans 

and planning decisions are the basis for every on-the-ground action the BLM undertakes. Land use plans 

include both resource management plans (RMPs) and management framework plans (MFPs).

BLM Handbook H-1790-1 National Environmental Policy Act helps the BLM comply with the 

National Environmental Policy Act (NEPA), the Council on Environmental Quality’s (CEQ) NEPA 

regulations (40 CFR Parts 1500-1508) and the Department of the Interior NEPA manual.

Manual 6220 National Monuments, National Conservation Areas, and Similar Designations 2012 

provides general policies for the administration and management of these designations: Data Standards, 

Records Maintenance, Land-Use Planning, Compatibility of Uses, and General Principles for 

Management.

Manual 6310 Conducting Wilderness Characteristics Inventory on Public Lands provides policy and 

guidance for conducting wilderness characteristics inventories under Section 201 of FLPMA.

Manual 6320 Considering Lands with Wilderness Characteristics in the BLM Land Use Planning 

Process provides policy and guidance for considering lands with wilderness characteristics in the BLM’s 

land use planning process under FLPMA. 

Manual 6330 Management of Wilderness Study Areas (2012) provides general policies for 

administration and management of these designations: Data Standards, Records Maintenance, Land-Use 

Planning, Compatibility of Uses, and General Principles for Management.

Manual 8270 Management of Paleontological Resources (1998) provides guidelines for implementing 

the Paleontological Resources Program: Land-Use Planning, Environmental Review, Assessment and 

Mitigation, Permitting, Partnerships, and Law Enforcement.

Manual 6840 Special Status Species Management (2008) establishes policy for management of species 

listed or proposed for listing pursuant to the Endangered Species Act and Bureau sensitive species found 

on BLM-administered land.

Manual 1745 Introduction, Transplant, Augmentation, and Reestablishment of Fish, Wildlife, and 

Plants (1992) requires that land use plans identify fish, wildlife, and plants species for introduction, 

transplant, augmentation, and reestablishment into suitable habitats.
PREHISTORIC TRACKWAYS NATIONAL 

MONUMENT COMPREHENSIVE TRAILS 

AND TRAVEL MANAGEMENT PLAN

APPENDIX 

C

tHE 
C-1

APPENDIX C

PREHISTORIC TRACKWAYS NATIONAL MONUMENT

COMPREHENSIVE TRAILS AND TRAVEL 

MANAGEMENT PLAN

INTRODUCTION AND BACKGROUND INFORMATION

The Prehistoric Trackways National Monument (PTNM) was created on March 30, 2009 by 

Congressional action as part of the 2009 Omnibus Public Land Management Act, more commonly 

referred to as Public Law 111-11. Title II, Subtitle B, Section 2103(a) of the Act states:

In order to conserve, protect, and enhance the unique and nationally important 

paleontological, scientific, educational, scenic, and recreational resources and values of 

the public land described in subsection (b), there is established the Prehistoric 

Trackways National Monument in the State of New Mexico.

The Monument encompasses approximately 5,255 acres in the southern Robledo Mountains in Doña Ana 

County, New Mexico. The primary objective of the Act is to conserve the unique fossil resources of the 

area, however; the Robledo Mountains have long provided the local recreational community with a 

variety of convenient opportunities for hiking, riding horses, mountain biking, and off-highway vehicle 

(OHV) activities. Management of OHVs within the Monument must be addressed to protect the 

important fossils, minimize conflicts between various user groups, and provide recreational opportunities.

The Robledo Mountains Off-Highway Vehicle Implementation Plan (NM-036-1997-083) identified and 

designated routes by association with various chile peppers, e.g., Patzcuaro’s Revenge Trail, and Hopping 

Jalapeno. Of these routes, approximately 32 miles are within the Monument. In addition to the

designated system of OHV routes, there is also a designated bicycle trail (SST).

PURPOSE AND NEED

The BLM Manual 1626 – Travel and Transportation Manual (Public) Section A(2)(a)(3)(b) states:

Travel Management Plans must be completed for all national monuments and 

congressionally designated national conservation areas, national recreation areas, 

cooperative management and protections areas, outstanding natural areas, forest 

reserves, and the Conservations Lands of the California Desert (in accordance with the 

establishing statute or Presidential Proclamation).

A Comprehensive Trails and Travel Management (CTTM) Plan is a dynamic approach to resource 

management that can be adjusted and modified to accommodate changes in resource allocations. A Trails 

and Travel Management Plan is not intended to provide evidence bearing on or addressing the validity of 

any Revised Statute 2477 (R.S. 2477) assertions. R.S. 2477 rights are determined through a process that 

is entirely independent of the BLM’s planning process. Consequently, travel management planning 

should not take into consideration R.S. 2477 assertions or evidence. Currently, the Monument does not 

have any R.S. 2477 assertions.

Considerations of both social and physical elements help define the criteria for a CTTM Plan. The social 

aspects include public demands, historical uses, existing rights-of-way, permitted uses, resource 
C-2

development, law enforcement and safety, conflicts between existing or potential users, recreation 

opportunities, and cultural and economic issues. Physical considerations include such things as terrain, 

soils, resource conflicts, vegetation, watersheds, special designations (such as Wilderness Study Areas), 

and public interest in specific types of vehicle use.

The Bureau of Land Management (BLM) has the responsibility to prepare a Resource Management Plan 

(RMP) for the Monument. The RMP establishes guidance, objectives, policies and management actions 

and contains two types of land management decisions for Travel Management: (1) land use decisions, and 

(2) implementation decisions. The land use decision for the Prehistoric Trackways National Monument is 

shown in Table C-1.

Table C-1 OHV Use Categories by Alternative

Federal regulations (43 CFR §8340) require the BLM to identify public land as Open, Limited, or Closed

to OHV use. The BLM designates areas as “Open” for intensive OHV use where there are no compelling 

resource protection needs, user conflicts, or public safety issues to warrant limiting cross country travel. 

The “Limited” designation is used where OHV use must be restricted to meet specific resource 

management objectives. An area is designated as “Closed” if all vehicle use is prohibited as a necessary 

measure to protect resources, reduce user conflicts, or provide for public safety. 

Management common to Alternatives A, C, and D include the following:

• In Limited areas, only designated routes would be open for motorized and mechanical use.

• No cross-country travel by motorized and/or mechanical vehicles would be permitted. This 

includes cross-country travel associated with dispersed camping activities.

• Emergency fire, medical, and law enforcement vehicles are exempt from the prohibition of crosscountry travel. 

• Cross-country travel may be authorized for official use. 

A CTTM Plan contains implementation decisions and is a component of the RMP and incorporates by 

reference all analysis (including Alternative Analyses) contained in that RMP. CTTM planning is the 

comprehensive process of developing and managing access and travel systems on public land at the 

implementation level. While motorized and OHV activities are most frequently associated with travel 

management strategies, the CTTM planning process is an interdisciplinary approach that takes into 

account all resource values/uses along with all modes of transit; motorized, mechanical, pedestrian, and 

equestrian.

TABLE C-1

OHV USE CATEGORIES BY ALTERNATIVE

CATEGORY ALTERNATIVE A ALTERNATIVE B ALTERNATIVE C ALTERNATIVE D

Closed 0 acres 5,255 acres 0 acres 0 acres

Limited to 

Designated 5,255 acres 0 acres 5,255 acres 5,255 acres

Open 0 acres 0 acres 0 acres 0 acres

Total Acres 5,255 5,255 5,255 5,255
C-3

PLANNING AREA DESCRIPTION

The Monument’s rugged terrain includes 32 miles of designated OHV routes within the Monument that 

have received National recognition by OHV enthusiasts as a prime and challenging place to drive. All of 

the routes within the Monument require high clearance, four-wheel drive vehicles; with approximately 50 

percent of these trails rated as extreme, or difficult, requiring modified vehicles, knowledge and skills. 

Approximately 45 percent of these trails are rated as easy or moderate but still require a certain degree of 

skill and four-wheel drive vehicles. Five percent of the trails have no difficulty rating but still require 

four-wheel drive. Low clearance, two-wheel drive vehicles cannot navigate within this area. The 

Monument also offers a 5.5-mile mountain bike trail and many undesignated hiking trails, paths, and 

canyon bottoms that appeal to outdoor recreationists.

Two previously designated OHV routes parallel or intersect with the Robledo Mountain Formation of the 

Hueco Group, which is where trackways and other trace fossils are preserved in the red siltstones.

There are no designated OHV routes in the Wilderness Study Area (WSA) portion of the Monument. The 

Robledo Loop Road forms the southern boundary of the Robledo Mountains WSA within the Monument.

IMPLEMENTATION DECISIONS

The following information and implementation plan is presented as Alternative C (Preferred 

Alternative) for the PTNM Draft RMP/EIS.

As provided in Instruction Memorandum (IM) 2006-173, “Implementation of the Roads and Trails 

Terminology Report”:

A linear route is a linear route declared a road by the owner, managed for use by low clearance vehicles 

having four or more wheels, and maintained for regular and continuous use. 

A primitive road is a linear route managed for use by four-wheel drive or high-clearance vehicles. 

Primitive roads do not normally meet any BLM road design standards.

A trail is a linear route managed for human-powered, stock, or off-highway vehicle forms of 

transportation or for historical or heritage values. Trails are not generally managed for use by four-wheel 

drive or high clearance vehicles. The hybrid utilization of single routes by a variety of users (OHV rock 

crawlers, mountain bikers, casual day hikers, equestrian enthusiasts and livestock) provides for multipleuse access and minimum surface disturbance.

The implementation portion of the CTTM Plan designates routes (including length). See Table C-2 for a 

summary of the designated routes for Alternative C, with the common and the official BLM names. The 

Plan also identifies sign placement, describes map content, and provides a monitoring strategy. 

See Map 2-3 for route placement within Monument.

Whenever the authorized officer determines that OHV use will cause or is causing considerable adverse 

effects on resources (such as soil, vegetation, wildlife, wildlife habitat, cultural, paleontological, historic, 

scenic, recreation, or other resources), the area must be immediately closed to the type of use causing the 

adverse effects (43 CFR §8341.2). Such limitation or closure is not an OHV designation. By regulation 

(Executive Order 11644--Use of off-road vehicles on the public lands), any fire, military, emergency, or 

law enforcement vehicle when used for emergency purposes is exempted from OHV decisions.
C-4

Table C-2 Designated Routes and Allowed Uses Within the Prehistoric Trackways National Monument

TABLE C-2

DESIGNATED ROUTES AND ALLOWED USES WITHIN

THE PREHISTORIC TRACKWAYS NATIONAL MONUMENT

Route’s Common 

Name

BLM Route 

Identification 

Name

UTMs

(beginning and 

ending points if 

possible)

Length

(miles)

Use:

1-motorized

2-mechanized

3-non-motorized/

non-mechanized OHV Rating

Previously 

Designated 

(Yes or No)

Robledo Loop or 

Chile Canyons 

Loop

PTNM 1 8.0 1,2,3 Easy Yes

Patzcuaro’s 

Revenge

PTNM 2 E0323 994, N3582 

775 to

E0320 757, N3583 

632

1.8 3 Extreme Yes

Rocotillo Rapids PTNM 3 E0323 762, N3582 

772 to

E0323 567, N3582 

891.

E0323 175, N3583 

055 to

E0322 350, N3583 

545.

1.0 1,2,3 Extreme Yes

Big Jim PTNM 4 E0321 703, N3583 

045 to

E0322 118, N3583 

650

0.7 1,2,3 Moderate Yes

Hopping Jalapeno

(up segment)

PTNM 5 E0321 388, N3583 

207 to

E0321 622, N3584 

129

0.7 1,2,3 Moderate Yes

Hopping Jalapeno

(down segment)

PTNM 6 E0321 333, N3583 

297 to

E0321 372, N3584 

255

0.7 1,2,3 Moderate Yes

Amatista Ledges PTNM 7 E0320 757, N3583 

632 to

E0320 733, N3584 

668

1.6 1,2,3 Moderate Yes

Habanero Falls 

(entrance)

PTNM 8 E0320 696, N3584 

136 to 

E0320 130, N3584 

635

0.6 1,2,3 Extreme Yes

Habanero Falls PTNM 9 E0320 751, N3583 

636 to

E0319 836, N3584 

191

0.8 1,2,3 Extreme Yes

Tabasco Twister PTNM 10 E0322 234, N3580 

901 to

E0319 553, N3583 

733

2.9 3 Extreme Yes
C-5

TABLE C-2

DESIGNATED ROUTES AND ALLOWED USES WITHIN

THE PREHISTORIC TRACKWAYS NATIONAL MONUMENT

Route’s Common 

Name

BLM Route 

Identification 

Name

UTMs

(beginning and 

ending points if 

possible)

Length

(miles)

Use:

1-motorized

2-mechanized

3-non-motorized/

non-mechanized OHV Rating

Previously 

Designated 

(Yes or No)

Pasado PTNM 11 E0322 305, N3581 

980 to

E0323 113, N3582 

350

0.7 1,2,3 Easy Yes

Sandia Gulch PTNM 12 E0323 600, N3581 

203

1.0 1,2,3 Difficult Yes

Cayenne Crawler PTNM 13 E0323 017, N3582 

203 to

E0322 894, N3582 

508

0.4 3 Difficult Yes

Unnamed PTNM 14 E0323 309, N3581 

566

to

E0323 012,

N3582 196

0.5 Will not be 

designated for any 

designated use.

Yes

Discovery Trail PTNM 15 E0323658,

N3583787

to

E0323136, 

N3584384

3 No

Rocks Thru Time 

Trail

PTNM 16 3 No

Ridge Line

Trail

PTNM 17 E0323763, 

N3583717 to

E0321367, 

N3584299

3 No

Hidden Canyons 

Trail

PTNM 18 E0319661, 

N3585481 to

E0319136, 

N3585350

3 No

SST PTNM 19 Beginning point 

outside of 

Monument:

E0323945, 

N3583196.

Potential intersection 

of trail at Monument 

boundary: 

E0323183, 

N3583243

2 Yes
C-6

Data collection and verification of the transportation network was accomplished using a combination of 

GIS and GPS technology. Designated routes were originally identified on 1:24,000 topographic maps. 

This data was systematically ground-truthed by the BLM during the preparation of the Robledo 

Mountains Off-Highway Vehicle Trail System Implementation Plan. These routes were later digitized on 

1:24,000 digital orthophoto-quads (DOQQ) map images. Inasmuch as the routes follow either drainage 

bottoms or ridge lines, visual confirmation of the relationship between the original topographic maps and 

the later aerial images was reliable (See Map 2-3).

The ultimate result of the proper application and interpretation of these combined technologies is a highly 

reliable map of the designated OHV routes in the PTNM. Detailed imagery enables accurate (± 5 meters) 

measurement of route distances. There is some latitude for route distance measurements owing to slight 

seasonal variations in drainage channel bottoms. 

The quality of the data enabled subsequent identification of unauthorized “braids” or obstacle bypasses 

that have evolved through more than a decade of almost daily non-permitted use.

Signs and Maps

The BLM will establish a system of trail signs to identify designated routes. These signs will be 

positioned at trailheads and route intersections. Comprehensive Trail maps will be available at the BLM 

Las Cruces District Office and on-line. Implementation of trail signs and maps will be accomplished 

within 1 year of the approval of the RMP or of the BLM obtaining public access to the Monument, 

whichever is later. The combination of proper sign installation and maps with accompanying UTM 

descriptions will allow for confident public navigation of the Monument routes. 

Current Levels of Utilization

Vehicle counters have been placed at three major access points into the Trackways. One of the counters 

placed at a major access point to the Monument, near the eastern boundary, counted over 10,000 vehicle 

crossings in a year. However, the exact number of visitors crossing into the Monument is difficult to 

determine because there are several other routes for vehicles to enter and leave the Monument. The 

accepted conversion for visitor trips based on vehicle counts is 2.5 visitors per car. The BLM estimates 

that somewhere between 40 to 60 percent of the vehicles that crossed the vehicle counter actually entered 

into the Monument proper, or 10,000 to 15,000 people. Visitors entering the Monument as hikers or on 

mountain bikes were not counted.

Since 1997, an annual commercial OHV event (the Chile Challenge) has been authorized through the 

Special Recreation Permit program. This 4-day event typically attracts 200-300 participants. For the 

other 361 days out of the year, there are no estimates of non-permitted OHV use that takes place. The 

BLM has not issued any Special Recreation Permits for use of the SST mountain bike trail. There is no 

information regarding how frequently, or in what volumes, the local mountain bike community may use 

this trail.

Anecdotal information suggests that most camping activity occurs in direct association with OHV use, 

i.e., overnight trail runs.

Day hikes whether they are organized or casual, are usually confined to the eastern periphery of the 

Monument due to issues of motorized access and points of interest (the Discovery Site is most accessible 

from the eastern edge of the Monument). In Alternative C, there are plans for designated hiking trails in 

the Monument. Currently, hikers may follow abandoned mining routes, designated OHV trails, or may 

choose to explore canyons and ridgelines where no formal pathways have been worn.
C-7

Equestrian use of the Monument occurs, but again, there are no supporting statistics to estimate frequency 

and intensity of use. There are no designated bridle paths.

Monitoring and Issuance of No Fee-Day Pass

In 2008, the BLM began periodic monitoring of sensitive paleontological areas within the Monument. 

Those monitoring efforts have been largely photographic in nature, with monthly or quarterly 

photographic sequences from fixed UTM locations.

The BLM modified the original monitoring regime by expanding the effort to better correspond with the 

New Mexico Museum of Natural History and Science’s (NMMNHS) documented paleontological 

resource sites. The BLM continues to develop a Monument monitoring plan in partnership with 

NMMNHS that will be comprehensive and implemented within 2 years of the signing of the PTNM 

RMP/EIS ROD.

Routes within the Monument that are accessible to conventional 4 wheel-drive vehicles have been added 

to the monitoring activity. Monument Rangers also conduct visual inspections of Monument boundary 

areas that receive frequent visitation. The BLM will monitor and evaluate the number of visitors that

camp, hike, and use motorized and mechanized access, which could lead to development of additional 

designated routes through 43 CFR 8365.1-6, Supplementary Rules, subject to the appropriate level of 

NEPA analysis.

In order to assess the variety and nature of resource impacts, the BLM will institute a system of no-fee 

day passes for motorized and mechanized use of the Monument trails. This system of day passes is 

authorized through 43 CFR 8365.1-6, Supplementary Rules. Passes will be available at the BLM Las 

Cruces District Office, on-line at the BLM website and potentially at informational kiosk(s) at the 

approved access point(s) to the Monument. Statistics gathered from these passes will allow the BLM to 

accurately assess the level of public interest in motorized and mechanized activities within the 

Monument, and will contribute to the validity of periodic monitoring inspections designed to document 

and predict resource impacts and conditions. Each motorized (OHV) and mechanized (mountain bike) 

vehicle will be required to have a no-fee day pass to use routes within the Monument. Comprehensive 

trail maps will be a part of the day pass, as well as information on other recreational or educational 

activities, rules, and regulations. The BLM will continue to administer organized groups and commercial 

ventures through the Special Recreation Permit program.

Required information for issuance of a no-fee day pass will include the name of the vehicle operator, the 

number of visitors in the vehicle, the license plate number (for OHV), proposed route(s) and destination if 

known, and expected length of visit. Optional information would include such things as the reason for the 

visit (OHV recreation, mountain biking, sightseeing, camping, etc.). Implementation of the no-fee day 

pass will occur within 2 years of approval of the RMP or of the BLM obtaining an easement for public 

access to the Monument, whichever is later.
C-8
PALEONTOLOGY

APPENDIX D

tHE 
UNITED STATES DEPARTMENT OF THE INTERIOR 

BUREAU OF LAND MANAGEMENT 

WASHINGTON, D.C. 20240

October 10, 2008 

In Reply Refer To: 

8270, 1790 (240) P 

EMS TRANSMISSION 10/29/2008 

Instruction Memorandum No. 2009-011 

Expires: 09/30/2010 

To: All State Directors

From: Assistant Director, Renewable Resources and Planning

Subject: Assessment and Mitigation of Potential Impacts to Paleontological Resources

Program Areas: Paleontological Resources Management, Environmental Assessment

Purpose: This Instruction Memorandum (IM) provides guidelines for assessing potential impacts to 

paleontological resources in order to determine mitigation steps for federal actions on public lands 

under the Federal Land Policy and Management Act (FLPMA) and the National Environmental Policy Act 

(NEPA). These guidelines also apply where a federal action impacts split-estate lands. In addition, 

this IM provides field survey and monitoring procedures to help minimize impacts to paleontological 

resources from federal actions in the case where it is determined that significant paleontological 

resources will be adversely affected by a federal action. 

Policy/Action: It is the policy of the BLM that potential impacts from federal actions on public lands, 

including land tenure adjustments, be identified and assessed, and proper mitigation actions be 

implemented when necessary to protect scientifically significant paleontological resources. This policy 

also applies to federal actions impacting split-estate lands and is subject to the right of landowners to 

preclude evaluation and mitigation of paleontological resources on their land. Paleontological 

resources removed from public lands require a Paleontological Resources Use permit for 

collection. Significant paleontological resources collected from public lands are federal property and 

must be deposited in an approved repository. Paleontological resources collected from split-estate 

lands are the property of the surface-estate owner, and their disposition will be in accordance with the 

surface agreement between the landowner and the permittee. 

Timeframe: This guidance is effective immediately for all BLM offices. 

Background: Surface disturbing activities may cause direct adverse impacts to paleontological 

resources through the damage or destruction of fossils; or loss of valuable scientific information by the 

disturbance of the stratigraphic context in which fossils are found. Indirect adverse impacts may be 

created by increased accessibility to important paleontological resources leading to looting or 

vandalism. Land tenure adjustments may result in the loss of significant paleontological resources to 

the public if paleontological resources pass from public ownership. Generally, the project proponent is 

responsible for the cost of implementing mitigation measures including the costs of investigation, 

salvage and curation of paleontological resources. 

This IM together with the Potential Fossil Yield Classification system (PFYC; see IM 2008-009) will 

provide guidance for the assessment of potential impacts to paleontological resources, field survey 

and monitoring procedures, and recommended mitigation measures that will better protect 

paleontological resources impacted by federal actions. This guidance expands and clarifies the 

D-1

APPENDIX D

PALEONTOLOGY
guidance in the Handbook H-8270-1 (General Procedural Guidance for Paleontological Resource 

Management) Chapter III (Assessment & Mitigation) and will be incorporated into the next Handbook 

revision. 

Impact on Budget: Costs are minimal for implementation of this guidance since mitigation of 

paleontological resources is already part of any approval of surface-disturbing actions on public lands. 

Manual/Handbook Affected: Supersedes Handbook H-8270-1 (General Procedural Guidance for 

Paleontological Resource Management) Chapter III.B. 

Coordination: Washington Office Division of Cultural and Paleontological Resources and Tribal 

Consultation. 

Contact: For questions regarding application of this policy and guidance, please contact Lucia Kuizon, 

National Paleontologist, at (202) 452-5107 or lkuizon@blm.gov. 

Signed by: Authenticated by: 

Edwin L. Roberson Robert M. Williams 

Assistant Director Division of IRM Governance,WO-560

Renewable Resources and Planning 

2 Attachments 

1- Guidelines for Assessment and Mitigation of Potential Impacts to Paleontological Resources (19 

pp)

2- Paleontological Resources Assessment Flowchart (2 pp)

D-2
Attachment 1-1 

Guidelines for Assessment and Mitigation of 

Potential Impacts to Paleontological Resources 

Contents: 

Introduction 

I. Assessment of Potential Impacts to Paleontological Resources 

A. Scoping

B. Analysis of Existing Data 

C. Determining the Need for Field Surveys and Mitigation 

II. Procedures for Conducting a Paleontological Field Survey

A. Definition of Field Survey 

B. Conducting Field Survey 

C. Report of Survey Findings 

D. Report Approval 

III. Determination of Further Mitigation Requirements

A. Relocation

B. Deferred Fossil Collection 

IV. Procedures for Field Monitoring

A. Monitoring Plan 

B. Types of Monitoring 

C. Types of Field Personnel 

D. Work Stoppage 

V. Final Project Report When Paleontological Resources are Collected 

VI. Completion of Mitigation Responsibility

VII. Collections Resulting from Mitigation and Monitoring

VIII. Resource Management Updates

Appendix A – Definitions 

Introduction

Surface disturbing federal actions on public and split-estate lands may cause direct adverse 

impacts to paleontological resources through the damage or destruction of fossils or the 

disturbance of the stratigraphic context in which they are located. Indirect adverse impacts may 

be created from increased accessibility to fossils leading to looting or vandalism activities. Land 

tenure adjustments may result in the loss of significant paleontological resources to the public if 

fossils pass from public ownership. 

Under the Federal Land Policy and Management Act (FLPMA) and the National Environmental 

Policy Act (NEPA), federal actions and land tenure adjustments that may impact or result in a 

loss of paleontological resources on public or split-estate lands are evaluated, and necessary 

mitigation is identified.

D-3
Attachment 1-2 

I. ASSESSMENT OF POTENTIAL IMPACTS TO PALEONTOLOGICAL RESOURCES

The following sections outline general steps designed to assist in the analysis and assessment of 

possible impacts to paleontological resources from proposed actions. These sections are 

sequential in order and provide for termination of the assessment at various stages if the analysis 

indicates no impacts are likely to occur. 

A. Scoping. Field Offices must assess all proposed federal actions to identify possible effects to 

significant paleontological resources (see Appendix A for definition) that are potentially 

recoverable and are likely to be within the zone of expected surface disturbance or relatively 

close to the surface. The direct effects of all surface activities and the indirect effects of 

increased public access and land tenure adjustments must be considered in any paleontological 

assessment. The assessment will determine whether further analysis will be necessary. The 

Paleontology Program Coordinator (Paleontology Coordinator – see Appendix A for definition) 

has primary responsibility for the scoping process for projects within the Field Office area, but 

the Paleontology Program Lead (Paleontology Lead – see Appendix A for definition) may be 

responsible for projects that span multiple Field or District Offices, and can support the 

Paleontology Coordinator as requested. 

1. Surface only activities – If the proposed project will not disturb potentially fossilyielding bedrock or alluvium, no additional work is necessary. The project file should be 

documented as appropriate. Examples of such projects include weed spraying, mechanical brush 

treatment, geophysical exploration, or surface disturbing activities such as road construction 

when the fossil resource is expected to be buried well below project compression or excavation 

depth or when surface fossil resources would be left undamaged. 

2. Land Tenure Adjustments – If parcels are identified to pass from public ownership in

a proposed land tenure adjustment action but contain no potential for recoverable, significant 

paleontological resources, no additional work is necessary. The project file should be 

documented as appropriate, and conclusions addressed in the environmental document. This 

situation may arise, for example, in areas consisting only of granitic bedrock where 

paleontological resources would not normally occur.

3. Young alluvial deposits or deep soils may cover and obscure sedimentary bedrock,

and any fossils that may occur in that bedrock would be unidentifiable or irretrievable prior to 

disturbance actions. In most of these cases, the fossil resources cannot be quantified, but the 

potential for impacting paleontological resources should be mentioned in the evaluation of the 

proposal, i.e., the planned disturbance will pass through the soil layer and impact a bedrock unit 

which is known to contain significant fossils elsewhere. 

If the initial scoping identifies the possibility for adversely affecting significant paleontological 

resources, further analysis is necessary. If there will be no impact or potential impact based on 

the action or the fossil resource may be impacted, but is too deep to be recovered, e.g., deep well 

bore passing through a fossil formation, the project file must be documented, and no additional 

assessment is necessary. 

D-4
Attachment 1-3 

B. Analysis of Existing Data. If scoping suggests the possibility of disturbing fossil-yielding 

bedrock or alluvium that is near to the surface and that may contain significant paleontological 

resources that are potentially recoverable, more in-depth analysis is necessary. Geologic 

mapping reflecting the Potential Fossil Yield Classification (PFYC) should be consulted, along 

with any other easily accessible information, such as GIS-based locality data, other known 

paleontological locality information, and existing paleontological reports for the area, aerial 

photos, or soils maps. 

1. Potential Fossil Yield Classification (PFYC) – This is a system for categorizing the

probability of geologic units to contain scientifically significant paleontological resources or 

noteworthy fossil occurrences. It has five levels or Classes, with Class 1 applied to geologic 

units that are not likely to contain significant fossils through Class 5 for geologic formations that 

have a high potential to yield scientifically significant fossils on a regular basis (see IM No. 

2008-009). This classification does not reflect rare or isolated occurrences of significant fossils 

or individual localities, only the relative occurrence on a formation- or member-wide basis. Any 

rare occurrences may require additional assessment and mitigation if they fall within the area of 

anticipated impacts. 

2. If the results of the preliminary analysis determine that the proposed project will only

affect geologic units not likely to contain significant fossils or that have a very low or low 

potential for significant fossils (PFYC Class 1or 2), and no scientifically important localities are 

known to occur in the area, the project file should be documented, and no additional 

paleontology assessment is necessary. 

3. The results of an analysis of a proposed project may indicate the potential to disturb

PFYC Class 3, 4, or 5 formations or potentially fossil-bearing alluvium, or known significant 

localities, which may then suggest the need for field surveys and/or other mitigation measures. 

The results may also identify areas where little or nothing is known of the fossil record so that 

additional attention may be given to these areas during field survey. The analysis should 

consider the likely impacts on the known or potential fossil resource and should be the basis for 

determining the need for or level of additional assessments. 

C. Determining the Need for Field Surveys and Mitigation. The previously discussed 

procedures may result in the determination that the project may encounter bedrock or an alluvial 

zone that has a moderate or high potential to contain significant paleontological resources. 

However, it does not determine the appropriate action, such as a field survey, on-site monitoring, 

special stipulations, avoidance, or other mitigation. 

1. If the need for further work is not clearly evident after the analysis, the Authorized

Officer and/or Project Leader should be consulted for a final decision. The Paleontology Lead or 

Regional Paleontologist may also be consulted. A brief written report of findings should be 

prepared, including the rationale for supporting the decision not to require a field survey or 

additional monitoring. The report should be signed by the Authorized Officer and placed in the 

project file. For example, a seismic survey using vibroseis trucks may be proposed on areas of 

deep soils, or a temporary recreational event may be planned in an area of low fossil potential. 

These types of projects are not likely to have a reasonable potential to adversely affect important 

D-5
Attachment 1-4 

paleontological resources. The file should be documented and a standard discovery stipulation 

attached to the permit proposal. 

2. If the analysis in Sec. I.B indicates a reasonably high expectation of not just

encountering a potential fossil-bearing zone and also causing adverse impacts to significant 

paleontological resources, the determination must be made as to (1) whether adverse effects 

cannot be avoided; (2) whether the adverse impacts can be avoided by altering the location or 

scope of the project; (3) whether the impacts can be mitigated through development of special 

stipulations such as requiring on-site monitoring; or (4) whether field surveys will be necessary 

to determine the presence or absence of significant paleontological resources. 

3. In the case where it is known that significant paleontological resources will be

adversely impacted, the preferred course of action is avoidance of the impact by moving or 

rerouting the site of construction, or eliminating or reducing the need for surface disturbance. 

4. Application of specific stipulations may reduce or eliminate adverse impacts in many

cases. A standard discovery stipulation should be included in any permit approval that is likely 

to affect significant paleontological resources. The stipulation should mandate an immediate 

work stoppage in the area of discovery, notification to the Authorized Officer, and protection of 

the material and geological context. Other stipulations may be appropriate on a case-by-case

basis. 

(a) A suggested standard discovery stipulation for a discretionary federal action is: 

The permittee shall immediately notify the BLM Authorized Officer of any 

paleontological resources discovered as a result of operations under this authorization. 

The permittee shall suspend all activities in the vicinity of such discovery until notified to 

proceed by the Authorized Officer and shall protect the discovery from damage or 

looting. The permittee may not be required to suspend all operations if activities can be 

adjusted to avoid further impacts to a discovered locality or be continued elsewhere. The 

Authorized Officer will evaluate, or will have evaluated, such discoveries as soon as 

possible, but not later than 10 working days after being notified. Appropriate measures to 

mitigate adverse effects to significant paleontological resources will be determined by the 

Authorized Officer after consulting with the operator. Within 10 days, the operator will 

be allowed to continue construction through the site, or will be given the choice of either 

(1) following the Authorized Officer’s instructions for stabilizing the fossil resource in 

place and avoiding further disturbance to the fossil resource, or (2) following the 

Authorized Officer’s instructions for mitigating impacts to the fossil resource prior to 

continuing construction through the project area. 

Note: C.1 and C.2 above would be conducted at the permittee's expense. By regulation, after a 

3809 plan of operations is approved or where there is no plan, the BLM is responsible for the 

cost of any investigation and recovery of fossil materials. 

(b) Other stipulations may be developed to reduce potential impacts, preferably 

in consultation with the project proponent. These may include (1) techniques to reduce surface 

D-6
Attachment 1-5 

disturbance, (2) briefings for all personnel about the potential for discovery, (3) requiring all 

finds be reported, and (3) using a "light touch" in sensitive areas. These should be made a formal 

part of the authorization for the project and discussed at a preconstruction meeting or an on-site 

meeting in the case of oil and gas operations. 

 (c) All proponents should be directed to share the current rules and regulations 

regarding fossil theft and the limitations to free use collecting of invertebrate and plant fossils on 

BLM-administered lands with all employees and subcontractors under their direction. Unlawful 

removal, damage, or vandalism of paleontological resources will be prosecuted by federal law 

enforcement. Theft or damage to government property by a proponent, a proponent’s employee, 

or a subcontractor that is under a proponent’s direction may lead to legal actions against the 

proponent. 

 5. If avoidance actions or stipulating measures are insufficient to protect known 

paleontological resources, a written assessment must be completed to determine the need for 

field survey or monitoring. This assessment must include the anticipated direct or indirect 

impacts associated with the project, the inadequacies of avoidance or special stipulations to 

protect the resource, existing paleontological information and known localities, relevant geologic 

information, and the potential for additional discoveries. The assessment must be completed by

the Paleontology Coordinator. 

 (a) In some cases, bedrock will not be visible at the surface in the project area 

(for example, where thin soils or alluvium obscure all outcrops), but the proposed excavation 

will likely penetrate into bedrock with known significant paleontological resources. Because 

fossil material will not be visible at the ground surface in these cases, it may be appropriate to 

forego a field survey prior to excavation, but require on-site monitoring or spot-checks when 

bedrock is finally encountered. If construction monitoring is proposed, the written assessment 

must include a thorough justification for the recommendation. 

 (b) The State Office may require the Paleontology Coordinator to notify the 

Paleontology Lead that a field survey or monitoring is deemed appropriate prior to the final 

decision to require the survey or monitoring. The notification should minimally include the 

name of the project, the legal description of the location or other locational information, a brief 

summary of the proposed action, reason(s) for the decision to require a survey or monitoring, and 

any other relevant information. Concurrence of the Paleontology Lead or Regional 

Paleontologist may be required prior to the final decision for requiring a survey or monitoring. 

 (c) A standardized assessment document may be developed that can be applied to 

projects that are similar in nature, relatively small, and repetitive in approach for use within a 

Field Office or District. This written assessment is intended to simplify the documentation 

process for those projects that are likely to have minimal impacts, and may be structured as a 

programmatic assessment, a form, a checklist, or other document with standard items. This 

assessment must include the name of the project, the legal description of the location or other 

locational reference, a brief summary of the proposed action, reason(s) for the decision, and any 

other relevant information. The parameters in the assessment should be designed to identify the 

need for a field survey. For example, the parameters may indicate a field survey may be required 

D-7
Attachment 1-6 

for road and well pad construction activities occurring on Class 4 or 5 formations where the 

formation is likely to be encountered during surface disturbing activities. The Field Manager, in 

consultation with the Paleontology Lead, must approve the use of a programmatic assessment 

prior to initial implementation. 

 6. The decision to require a field survey or monitoring must be made by the Authorized 

Officer and documented in the project file. If required, a copy of the decision must be furnished 

to the Paleontology Lead. 

II. PROCEDURES FOR CONDUCTING A PALEONTOLOGICAL FIELD SURVEY

If the assessment of existing data indicates: (a) the presence or high probability of occurrence of 

vertebrate fossils or uncommon nonvertebrate fossils (PFYC Class 4 or 5), or that the probability 

is unknown (Class 3), in the area of a proposed federal action or transfer of title, and (b) a 

reasonable probability that those resources will be adversely affected by the proposed action, a 

paleontological field survey should be conducted. 

A. Definition of Field Surveys. Field Surveys are pedestrian surveys to be performed in areas 

where significant fossils can be expected to occur within the boundary and immediate vicinity of 

the anticipated disturbance, or where the probability of encountering significant fossils is 

unknown. 

 1. Field surveys are performed prior to any surface disturbing activities. Before 

conducting field surveys, the project location should be as final as possible and any staking of 

the location should be complete. 

 2. Surveys are conducted by a BLM Regional Paleontologist, Paleontology Lead, 

Paleontology Coordinator, appropriately trained and supervised BLM staff, or by a BLMpermitted consulting paleontologist hired by the project proponent. 

 (a) At the Field Manager’s discretion, other qualified BLM staff may conduct 

surveys on small projects. Performance of surveys by BLM staff must also be approved by the 

Regional Paleontologist, Paleontology Lead, or Paleontology Coordinator. 

 (b) Surveys that are complex in nature, constrained by construction schedules, or 

otherwise cannot be performed by BLM staff should be performed by a consulting paleontologist 

holding a valid BLM Paleontological Resources Use Permit. Submission of reports may be done 

directly by the paleontologist to the BLM. The project proponent is also responsible for all costs 

associated with the survey, including the consulting paleontologist’s fees and charges, all survey 

costs, fossil preparation to the basic identification stage, analyses, reports, and curation costs 

directly related to mitigation of the project’s anticipated impacts. Any required monitoring and 

mitigation costs are also the responsibility of the project proponent. These costs are to be 

negotiated between the project proponent and the consulting paleontologist prior to beginning 

any data gathering, analysis, or field work, and these negotiations do not require BLM 

D-8
Attachment 1-7 

involvement or approval. Any new, additional, or modified curation agreements between the 

paleontologist and the official repository must be in place prior to starting field work. 

 (c) Authorization for an activity to proceed cannot be given by a consulting 

paleontologist. Performance of the survey, either by a consulting paleontologist or BLM staff, or 

submission of the report DOES NOT constitute approval for the activity to proceed. The BLM 

must review the report, including adequacy of the field methods and findings. The Authorized 

Officer must approve the findings and determine the need for monitoring prior to approval to 

proceed. 

B. Conducting Field Surveys. Field surveys must be performed by the Principal Investigator or 

an approved Field Agent or Field Monitor (see section IV.C., Types of Field Personnel for 

descriptions of these individuals) as authorized under a Paleontological Resource Use Permit, or 

by a BLM Regional Paleontologist or qualified BLM designee. Field surveys and collections 

performed as a mitigation measure are not intended to be scientific research studies, but are 

meant to identify, avoid, or recover paleontological resources to prevent damage or destruction 

from project activities. However, proper scientific techniques and procedures must be utilized 

during all mitigation efforts. Safety should be an important consideration; therefore, surveys 

should not be attempted on cliff faces, in open, non-reinforced trenches deeper than five feet, or 

other unsafe areas. 

 1. The scope of the survey is dependent upon the scale of the project. Small projects are 

defined as less than 10 acres, or, if linear, less than five miles; large projects exceed those 

dimensions. 

 2. At the start of field work, the consulting paleontologist (paleontologist) must contact 

the Paleontology Coordinator in each affected Field Office who may require a visit to that office.

After an initial visit each year, the paleontologist may contact the Field Office by telephone or 

email prior to subsequent field trips, at the discretion of the Field Office. Information about the 

survey schedule, additional personnel, emergency field contact information, and any other 

pertinent data should be provided to the Paleontology Coordinator. The Field Office will inform 

the paleontologist of any conditions that may impact the survey, such as fire danger or 

restrictions, drought restrictions, wildlife timing restrictions, management restrictions, road 

restrictions or construction, and any other relevant information. 

 3. During the field survey, the paleontologist surveys, locates, and documents all 

paleontological resources within 200 feet of the proposed project location or corridor, or less 

distance upon approval. 

 (a) Where significant paleontological resources are at risk, data collection alone 

does not constitute mitigation of damage. All significant fossils that may be damaged or 

destroyed during project activities must be collected, along with all relevant contextual and 

locational data. Specimens must be collected during the survey or prior to commencement of 

any surface-disturbing activities. 

D-9
Attachment 1-8 

 (b) In many cases, isolated gar scales, chelonid (turtle) carapace or plastron 

fragments, crocodile and fish teeth, and unidentifiable bone fragments do not need to be 

collected. The location must be recorded and a description of the fossil material noted in the 

field notes and on a BLM Locality Form as part of the report. The context of these types of 

fossils should be considered, as they may represent rare occurrences or unusual faunal 

associations, and thus may be scientifically important and must be documented and voucher 

specimens collected where appropriate. 

 (c) Occurrences of plant or invertebrate fossils should be recorded and 

representative examples or voucher specimens collected where appropriate. Additional 

mitigation measures may be appropriate in some cases for these types of localities. 

 (d) If a large specimen or a concentration of significant fossils is located during 

the field survey, the available time and/or personnel may not allow for full recovery during the 

survey. The specimen(s) and locality(ies) should be stabilized as needed, and a determination 

made as to whether avoidance is necessary or whether full recovery of the specimen is required 

at a later time prior to disturbance activities. The Authorized Officer and project proponent must

be notified, the mitigation alternatives discussed including funding for recovery, and a decision 

reached as soon as possible. If avoidance or later recovery is selected for mitigation, the find 

should be stabilized, buried if needed to protect the fossils and context, and appropriate measures 

implemented to reduce adverse effects from natural or human causes. 

 4. During the survey, locations or areas that exhibit a lithology suggesting a high 

probability of subsurface fossil material must be recorded, and a recommendation for the need 

for on-site monitoring, spot-checking, or testing should be made in the report. This may include 

areas where no fossil material was found on the surface during the survey. The recommendation 

should consider the size and type of planned disturbance, such as the depth of a trenching 

operation or the acreage of surface disturbance. 

 5. Surveys must be performed only during times when the ground is visible and not 

frozen. This will often preclude surveys during winter months in many areas. Biological timing 

restrictions, such as critical nesting or birthing times, may confine or delay field activities. 

Project proponents should be informed of BLM’s requirement for performing any field surveys 

as soon as possible and should be advised of the possibilities for delays in survey completion 

based on seasonal weather conditions or other management restrictions to allow for adequate 

scheduling of available time.

C. Report of Survey Findings. After completion of the field survey, the paleontologist must file 

a written report with the BLM and the designated repository. If required, a copy should also be 

filed with the project proponent. This report must summarize the results of the survey as well as 

appropriate geological and paleontological background information as described below. It 

should also include any recommendations for on-site monitoring or other mitigation. For small 

projects (less than 10 acres), the report must be filed within 30 days after completion of the 

survey unless specific approval for a different time frame has been received from the BLM. The 

time frame for submission of the report for large projects should be negotiated during project 

scoping. On a case-by-case basis, approval to begin project activities may be granted for those 

D-10
Attachment 1-9 

portions of the project area noted to be less paleontologically sensitive prior to final approval of 

the report. 

 1. Reports of the general findings and the background information must be submitted to 

the BLM project manager or Authorized Officer (if appropriate), the Paleontology Lead or 

Regional Paleontologist, and each affected Field Office. Reports must include the following 

details, as applicable. Items (a) and (b) should appear at the beginning of the report and may be 

presented as a title page in multi-page reports. Some of these categories may be combined. 

(a) Name, affiliation, address, date of report, and permit number (if consultant) of 

paleontologist doing the survey. 

(b) Project name and number (if used), name of proponent, and general location 

of project. 

(c) Date(s) of survey and names of any personnel assisting with the survey. 

(d) Brief description of the proposed project, emphasizing potential impacts to 

paleontological resources. 

(e) Description of background research conducted. (Include overview of known 

paleontological information, institutions consulted, previous surveys in the area, 

previous projects of similar nature in the area, and general description of survey 

techniques employed). 

(f) Summary of regional and local geology. May reference earlier projects for 

relevant information. 

(g) Summary of regional and local paleontology. May reference earlier projects 

for relevant information. 

(h) Summary of the survey results. 

(i) Significance of findings. 

(j) Potential impacts to paleontological resources resulting from the project. 

(k) Detailed mitigation recommendations that may lessen potential adverse 

impacts.

(l) Potential fossiliferous areas to allow for future assessment of sites if 

applicable. 

(m) Cited and other pertinent references. 

(n) Map of project area, indicating areas surveyed, known localities, and new 

discoveries. 

(o) Relevant photos, diagrams, tables to aid in explaining, clarifying, or 

understanding the findings. 

(p) Listing of collected material, including field numbers, field identifications, 

and elements, cross-referenced to locality field numbers. This list may be 

submitted in electronic format, preferably in spreadsheet format. 

(q) BLM locality form (8270-3) or equivalent for each new locality (including 

localities where fossils were observed but not collected) with a 1:24000 scale map 

showing the localities (not reduced in scale during photocopying) (see items 2 and 

3 below). 

 2. Exact locations of fossil localities contained in these reports are considered sensitive 

and must not be included in any public document. The BLM locality form (8270-3) or 

D-11
Attachment 1-10 

equivalent, 1:24000 scale map showing the localities, and any other information containing 

specific fossil locations may be bound separately or placed in a separate section to allow for 

preservation of confidential locality data. A copy of this confidential section must be submitted 

to the Paleontology Lead (in some cases, two copies may be required). A copy for each affected 

Field Office may be required. Another copy must be submitted to the official repository with the 

collected materials. 

 3. BLM GPS recording and data standards must be used to report paleontological 

locality data. Existing USGS topographic maps are often based on the NAD27 standard, so 

locality data calculated from a map base must be converted before submission. Data must be 

recorded and reported with a mean error of +/- 12.5 meters or less, at a 95 percent confidence 

level. For small localities, data should be reported as point data. Larger polygonal localities 

should be reported using coordinates of a centroid and a description of the approximate size, or 

the key coordinate points of a bounding polygon. Linear features, such as roads or surveyed 

project boundaries, must be reported as line data. The 1:24000 scale map(s) accompanying the 

locality forms should graphically illustrate the locality, either as a point or an outline of the 

locality as appropriate, and be clearly labeled with the locality or field number. 

D. Report Approval. The Authorized Officer will analyze the Survey Report for adequacy 

within 10 working days of receipt. Notification accepting the report, or explaining any identified 

deficiencies, will be sent to the consulting paleontologist and the project proponent with a copy 

placed in the project file. Any deficiencies must be corrected as soon as possible, usually 

initiated within five working days, and the report must be resubmitted for approval. Any 

resubmissions must be prompt, but consideration will be made for the amount of time needed for 

major corrections. Deficiencies directly affecting the survey, such as inadequate survey 

procedures or incomplete data, must be corrected before granting approval for the project to 

proceed. Deficiencies not directly affecting the survey, such as curation issues, will not prevent 

approval of the project, but must be corrected as soon as possible. 

III. DETERMINATION OF FURTHER MITIGATION REQUIREMENTS

The need for additional mitigation to protect paleontological resources will be determined on a 

case-by-case basis. The Authorized Officer, in consultation with Regional Paleontologist or the 

Paleontology Lead, will analyze the Survey Report for survey findings and any mitigation 

recommendations. If no further mitigation is needed, the Authorized Officer will promptly 

notify the project proponent that there are no additional paleontological surveys or mitigation 

measures required, and the project may proceed pending any other approvals. The project file 

must be documented indicating acceptance of the survey report and identifying any additional 

mitigation requirements. If it is determined that additional mitigation efforts are needed to 

protect or preserve the paleontological resources, the project proponent will be notified as soon 

as possible. The Authorized Officer and/or the Paleontology Lead usually develop and approve

the mitigation procedures or recommend a project be redesigned in consultation with the project 

proponent. Factors such as locality or specimen significance, economics, safety, and project 

urgency will be considered when developing mitigation measures. Additional mitigation 

D-12
Attachment 1-11 

measures will be developed and implemented as timely as possible so as not to delay project

actions. 

 A. Relocation. The preferred mitigation technique is to change the project location 

based on the results of the field survey. Relocation, however, may necessitate a field survey of 

the new area, as well as resurveys by other resource specialists. Anticipation of this contingency 

prior to or during the original survey may allow for survey of an expanded area at the same time. 

If relocation will eliminate impacts and is acceptable to all parties, then a report to the file, 

including a map showing the original and revised locations, must be completed documenting the 

change. Approval for the project to proceed in the revised location may then be granted by the 

Authorized Officer to the project proponent. When avoidance is not possible, appropriate 

mitigation may include excavation or collection (data recovery), stabilization, monitoring, 

protective barriers and signs, or other physical and administrative protection measures. 

 B. Deferred Fossil Collection. In some cases, fossil material may have been identified, 

but not completely collected during the initial field survey, such as a partial dinosaur or other 

large fossil assemblage. It may be possible to complete the recovery of this material and all 

related data prior to beginning construction activities, and thus mitigate the adverse impact. This 

may require a shift in the project schedule and must be coordinated with the project proponent. 

Approval by the Authorized Officer for the project to proceed will only be granted when 

recovery of the fossil material and field data is completed. A report to the file and the project 

proponent documenting the recovery and indicating that no further mitigation is required must be 

completed, and the report signed by the Authorized Officer. If the discovery cannot be fully 

collected within the available time frame, it may have to be avoided by relocating or redesigning

the project. 

IV. PROCEDURES FOR FIELD MONITORING

The purpose of on-site monitoring is to assess and collect any previously unknown fossil 

material uncovered during the project activities or soon after surface-disturbing actions. Based 

on the initial scoping, the field survey and recommendations, and the plan of operations, it may 

be necessary to require monitoring of surface-disturbing activities. Monitoring may be required 

as part of an overall mitigation for a project which was developed during the NEPA process, or 

upon the discovery of paleontological resources during project activities. 

A. Monitoring Plan. A monitoring plan can be developed by a BLM paleontologist or a 

qualified paleontologist hired by the proponent. The plan must be appropriately scaled to the 

size and complexity of the anticipated monitoring. If developed by a third party, the appropriate 

Paleontology Lead or Regional Paleontologist shall review the plan for sufficiency prior to 

acceptance. Monitoring of the project may proceed when the monitoring plan is approved by the 

Authorized Officer. A monitoring plan indicates the treatments recommended for the area of the 

proposed disturbance and must minimally address the following: 

 1. The recommended approach to additional specimen collection, such as total or partial 

recovery or sampling; and 

D-13
Attachment 1-12 

 2. The specific locations and intensity of monitoring or sampling recommended for each 

geologic unit, stratigraphic layer, or area impacted. 

Monitoring intensity is determined based on the analysis of existing data and/or field surveys and 

any previous monitoring efforts. 

B. Types of Monitoring. There are two types of monitoring: 1) on-site, performed during 

ongoing operations, and 2) spot-checks, performed during or after disturbance, or at key times 

during the progress of the project. 

 1. On-site monitoring – In areas with a high probability for buried fossils, the presence of 

a monitor at the site of disturbance at all times that disturbance is occurring may be warranted. 

The need for a full-time monitor is based on the findings of the survey, the local geology, and the 

proposed actions. Efforts will be made to complete fossil recovery with minimal work stoppage. 

However, in some cases, an extended period of work stoppage may be required, so coordination 

with the project proponent or representative is important (see D below). Prior to beginning the 

monitoring work, the monitor, company supervisor, and machinery operators should agree on 

procedures for brief work stoppages to allow for examination of finds. It is critical that safety be 

of utmost concern because of the presence of heavy machinery and open trenches. 

 The monitor must assess any finds, collect loose fossil material and related data, and take 

appropriate steps to mitigate any current or potential damage. Consideration of the size of the 

expected fossils must also be considered; for example, microfossils may not be visible during 

excavation activities. It may be appropriate to collect samples of matrix for later recovery of 

microvertebrate fossils or other analyses. Activities planned to occur during night time should 

be assessed relative to the potential to uncover significant fossils. Fossils may not be visible at 

night in trenching or grading operations, so construction activities may need to be suspended 

during night time in sensitive areas. 

 2. Spot-checking – In areas with a moderate to high probability for unknown fossil 

material, it may be more appropriate to check only at key times rather than maintain continuous 

monitoring of operations. Key times for scheduling spot-checking are when the fossil-bearing 

bedrock is exposed to view or prior to placing spoil material back into the excavation. Examples 

of these key times may be when a pipeline trenching operation is complete but before pipe is 

placed and the trench backfilled or prior to redistribution of topsoil. Spot-checking requires 

close coordination with the project proponent and the paleontologist, and usually requires the 

paleontologist to be available on short notice. In some instances, it may be advantageous to 

allow rain and/or wind to erode away loose matrix and concentrate fossil material to increase 

visibility. The paleontologist will coordinate with the project proponent to allow sufficient time 

for this action to occur, as appropriate to conditions, expected fossil material, and construction 

schedules. 

The paleontologist should report potentially fossiliferous areas in the final report to allow for 

future assessment of sites, even if no fossils were located during the project monitoring. 

 

D-14
Attachment 1-13 

C. Types of Field Personnel. Depending on the complexity of the project, it may be necessary 

to employ a number of paleontology field personnel simultaneously. There may be a lack of 

fully qualified paleontologists to perform all the necessary monitoring during the scheduled 

times of construction. Use of additional personnel for field work is permissible, but Field Agents 

and Field Monitors (described below) must be requested by the Permittee and authorized by the 

BLM prior to field work. 

 1. Principal Investigator – The person listed as Permittee (Permit item 1a) on the 

Paleontological Resources Use Permit is the Principal Investigator (PI) and is responsible for all 

actions under the permit, for meeting all permit terms and conditions, and for the performance of 

all other personnel. This person is also the contact person for the project proponent and the 

BLM.

 2. Field Agent – Other qualified paleontologists may perform field work independently 

of the PI under the conditions of this permit. Résumés must be submitted to BLM and must 

demonstrate qualifications equivalent to those of Permittees. Field Agents must be listed on the 

permit under “Name(s) of individual(s) responsible for planning, supervising, and carrying out 

fieldwork” (Permit item 8) or authorized in a separate letter from BLM. They must follow all the 

permit terms and conditions applicable to field work and must carry a copy of the permit, 

included terms and conditions, and separate authorizing letter (if used) while in the field. Field 

work results must be reported to the PI, who will then submit required reports. 

 3. Field Monitor – Field Monitors may be utilized for supplemental on-site monitoring 

of surface-disturbing activities when the PI or a Field Agent is performing field work elsewhere. 

Field Monitors must have sufficient field experience to demonstrate acceptable knowledge of 

fossil identification, collection methods, and paleontological techniques. The PI must supply a 

summary of each person’s experience to the BLM prior to field work. Field Monitors must be 

approved by the BLM prior to performing field work and must carry a copy of the permit while 

in the field. The PI or Field Agent must be in communication with the Field Monitor using a 

portable communication device, such as a cell phone or two-way radio, and are required to be 

near enough to the Field Monitor to allow for prompt examination of all fossil discoveries (no 

more than two hours away) by the PI or Field Agent. 

 4. Field Assistant – Additional personnel not meeting the previously cited experience or 

knowledge levels may be utilized during field work, but must be under direct, on-site supervision 

of either the PI or a Field Agent as part of a supervised crew. Field assistants must have at least 

four to eight hours of training or experience received from a qualified paleontologist in 

identifying paleontological resources prior to performing field work or when first utilized in this 

capacity. A listing of all Field Assistants (including contact information) must be supplied prior 

to any field work. All discoveries made by a Field Assistant must be immediately reported to the 

PI or Field Agent on site. To ensure proper supervision, an appropriate ratio of Field Assistants 

per PI or Field Agent must be maintained. The complexity of the project, the area to be covered, 

and the experience of the assistants are some of the factors that should be considered in 

determining the proper ratio, but commonly five to seven assistants is the maximum number that 

can be supervised by one PI or Field Agent. 

D-15
Attachment 1-14 

D. Work Stoppage. If significant fossil material is discovered during construction activities, the 

PI, Field Agents, and Field Monitors have the authority to temporarily halt surface disturbing 

actions until an assessment of the find is completed and appropriate protection measures taken. 

Efforts will be made to complete fossil recovery with minimal work stoppage. However, in 

some cases, an extended period of work stoppage may be required. If the paleontological 

resource can be avoided, mitigated, or collected within approximately two hours, work may 

resume after approval from the PI or Field Agent, and the Authorized Officer must be notified as 

soon as possible of the discovery and any mitigation efforts that were undertaken. If the find 

cannot be mitigated within a reasonable time (two hours), the concurrence of the Authorized 

Officer or official representative for a longer work stoppage must be obtained. Work may not 

resume until approval is granted from both the PI or Agent and the Authorized Officer. 

V. FINAL PROJECT REPORT

Upon completion of all field work, including survey and monitoring, the PI must submit within 

30 days, a written final report to the Authorized Officer, Paleontology Lead, and the designated 

repository. A copy of the report may be provided to the project proponent if required, but 

without the BLM Locality forms. Reports must include the following details. Items 1 and 2

should appear at the beginning of the report, and may be presented as a title page in multi-page 

reports. 

1. Name, affiliation, address, date of report, and permit number (if consultant) of the 

paleontologist doing the survey. 

2. Project name and number (if used), name of proponent, and general location of 

project.

 3. Date(s) of the survey and names of any personnel assisting with the survey. 

 4. Brief description of project and expected impacts to paleontological resources. 

 5. A summary of mitigation performed. 

 6. A summary of findings, including important discoveries. 

7. A description of potentially fossiliferous areas to allow for future assessment of sites, 

even if no fossils were located during the project monitoring. 

8. A completed BLM locality form 8270-3 or equivalent for each new locality using 

Universal Transverse Mercator (UTM) NAD 83 coordinates, and 1:24000 scale maps 

with new localities plotted using points or polygons as appropriate. Locality forms, 

maps, and any other information containing specific fossil locations should be bound 

separately or assembled as a separate section to allow for preservation of confidential 

locality data. 

9. List of specimen field numbers and field identifications of collected material, crossreferenced to the locality field number. This list may be submitted in electronic format, 

preferably in a spreadsheet format. 

If the survey was performed by BLM, a report similar in contents must be written and filed in the 

project file, and the project proponent notified as soon as possible upon completion. 

D-16
Attachment 1-15 

VI. COMPLETION OF MITIGATION RESPONSIBILITY

When the final report with the specimen inventory and the signed receipt of confirmation of 

museum deposition are accepted by the BLM, mitigation for paleontological resources related to 

the project will be considered completed. The project proponent will be notified in writing as 

soon as possible by the Authorized Officer after consulting with the Paleontology Lead or 

Regional Paleontologist and a copy of the notification placed in the project file. 

The responsibility of the project proponent ends when appropriate mitigation related directly to 

the project is completed and final approval is received from the Authorized Officer. Any 

additional field collection, quarrying, final specimen preparation, etc. will be considered to be 

research, and will be the responsibility of the consulting paleontologist or another approved 

party. The project proponent will not be held responsible for completion of any research project. 

However, the project proponent can choose to sponsor further research. A separate research 

permit will be required for additional research activities. 

VII. COLLECTIONS RESULTING FROM ASSESSMENT AND MITIGATION

Fossil specimens and related data collected from public lands during field surveys and mitigation 

remain the property of the Federal government. They must be placed in the approved 

repository(s) identified on the Paleontological Resource Use Permit held by the consulting 

paleontologist as soon as practical and receipt(s) of collections submitted to the BLM, but no 

later than 60 days after all field work is completed. Written approval from the Paleontology 

Lead or Regional Paleontologist is required if additional time is needed for transfer of all 

specimens and field data. 

VIII. RESOURCE MANAGEMENT UPDATES

Based on findings resulting from any of the above steps, the project file, locality and specimen 

information, and other BLM data should be updated to reflect any new or modified information. 

Paleontology permit files should be checked and updated, as well as any other administrative 

information. 

The PFYC Class assignments can be assessed based on the analysis, survey, and monitoring 

results. New information may indicate a change in the PFYC Class is appropriate for one or 

several geologic units. Other applications of the PFYC system should be considered, such as the 

use for impact analyses in planning documents or for survey and mitigation determinations for 

other projects. Any changes in classification must be made in consultation with the Paleontology 

Lead or Regional Paleontologist to maintain consistency across Field Office boundaries. 

D-17
Attachment 1-16 

APPENDIX A – DEFINITIONS 

(As applicable to BLM management of paleontological resources)

Alluvium – A general term for clay, silt, sand, gravel, or similar unconsolidated detrital material 

[fragments of rock or mineral material derived from older rocks] deposited during relatively 

recent geologic time by a stream or other body of running water as a sorted or semi-sorted 

sediment in the bed of the stream or its flood plain or delta, or as a cone or fan at the base of a 

mountain slope; especially, such a deposit of fine-grained texture (silt or silty clay) deposited 

during a time of flood (from American Geological Institute (AGI), Glossary of Geology, 1972 

ed.) 

Alluvium may contain paleontological resources in older alluvial deposits. The location on the 

landscape often will provide clues to the potential for paleontological resources within alluvial 

deposits. As an example, alluvium developed near major river courses or lake margins has a 

much higher potential to contain significant paleontological resources than alluvium (colluvium) 

formed from slope wash. 

Approved Repository – Meets the Department of the Interior 411 Departmental Manual (DM) 

provisions for museum property, including capability for providing adequate long-term curatorial 

services, such as a physically secure environment, and maintaining professional staff qualified to 

catalog, care for, preserve, retrieve, and loan, where appropriate, these materials and associated 

records. 

Bedrock – A general term for the rock, usually solid, that underlies soil or other unconsolidated, 

surficial material (from American Geological Institute (AGI), Glossary of Geology, 1972 ed.) 

For paleontological purposes, bedrock generally excludes alluvium, colluvium, sand dunes, and 

loess (fine-grained blanket deposit of marl or loam). In certain situations, bedrock may contain 

recent soils/sediments with fossils. 

Colluvium – A general term applied to any loose, heterogeneous, and incoherent mass of soil 

material or rock fragments deposited chiefly by mass-wasting, usually at the base of a steep slope 

or cliff; e.g., talus, cliff debris, and avalanche material. Also, alluvium deposited by 

unconcentrated surface run-off or sheet erosion, usually at the base of a slope (from American 

Geological Institute (AGI), Glossary of Geology, 1972 ed.) 

Field Agent – Other qualified paleontologists may perform field work independently of the PI 

under the conditions of this permit. Résumés must be submitted to BLM and must demonstrate 

qualifications equivalent to those of Permittees. Field Agents must be listed on the permit under 

“Name(s) of individual(s) responsible for planning, supervising, and carrying out fieldwork” 

(Permit item 8) or authorized in a separate letter from BLM. They must follow all the permit 

terms and conditions applicable to field work and must carry a copy of the permit, included 

terms and conditions, and separate authorizing letter (if used) while in the field. Field work 

results must be reported to the PI, who will then submit required reports. 

Field Assistant – Additional personnel not meeting the previously cited experience or 

knowledge levels may be utilized during field work, but must be under direct, on-site supervision 

D-18
Attachment 1-17 

of either the PI or a Field Agent as part of a supervised crew. Field assistants must have at least 

4 to 8 hours of training or experience received from a qualified paleontologist in identifying 

paleontological resources prior to performing field work or when first utilized in this capacity. A 

listing of all Field Assistants (including contact information) must be supplied prior to any field 

work. All discoveries made by a Field Assistant must be immediately reported to the PI or Field 

Agent on site. To ensure proper supervision, an appropriate ratio of Field Assistants per PI or 

Field Agent must be maintained. The complexity of the project, the area to be covered, and the 

experience of the assistants are some of the factors that should be considered in determining the 

proper ratio, but commonly five to seven assistants is the maximum number that can be 

supervised by one PI or Field Agent. 

Field Monitor – Field Monitors may be utilized for supplemental on-site monitoring of surfacedisturbing activities when the PI or a Field Agent is performing field work elsewhere. Field 

Monitors must have sufficient field experience to demonstrate acceptable knowledge of fossil 

identification, collection methods, and paleontological techniques. The PI must supply a 

summary of each person’s experience to the BLM prior to field work. Field Monitors must be 

approved by BLM prior to performing field work and must carry a copy of the permit while in 

the field. The PI or Field Agent must be in communication with the Field Monitor using a 

portable communication device, such as a cell phone or two-way radio, and are required to be 

near enough to the Field Monitor to allow for prompt examination of all fossil discoveries (no 

more than two hours) by the PI or Field Agent. 

Field Survey – Pedestrian (walking) surveys performed in areas where significant fossils are 

expected to occur within the boundary or immediate vicinity of an anticipated disturbance. 

Surveys are performed by a qualified paleontologist or BLM Regional Paleontologist or other 

officially appointed BLM employee prior to any surface disturbing activities. Survey activities 

also include concurrent collection of significant fossils. 

Land Tenure Adjustments/Change in Title – Changes in ownership or administration of 

surface or mineral estates, typically exchanges or sales, which may result in a change in 

ownership or control of paleontological resources. 

Monitoring – a) On-site observation during all surface disturbing activities to assess and collect 

any previously-unknown fossil material uncovered by the project activities. b) Examination of 

excavation or spoil piles at key times during project activities. Monitoring must be performed by 

a permitted paleontologist, field agent, or field monitor (see section IV.C.), Regional 

Paleontologist, or other officially appointed BLM employee, and occurs during or soon after 

surface disturbing actions. 

Paleontological Locality (Locality) – A geographic point or area where a fossil or associated 

fossils are found in a related geological context. A paleontological locality is confined to a 

discrete stratigraphic layer, structural feature, or physiographic area. 

Paleontology Program Coordinator (Paleontology Coordinator) – The employee designated 

by the local BLM Office Manager to manage paleontological resource issues, including 

planning, mitigation, budget, and other administrative duties. The local point of contact for 

D-19
Attachment 1-18 

paleontological resource use permittees, the State Office Paleontology Program Lead, and the 

Regional Paleontologist. The employee is usually a geologist or archaeologist. 

 (a) In some offices, additional employees may be designated by the supervisor to 

determine the need for field surveys and monitoring for some projects, or other duties in support 

of the paleontology program. The scope of duties for these additional employees must be 

approved by the Paleontology Program Lead and closely coordinated with the Paleontology 

Coordinator. 

 (b) A few current BLM employees may meet the same professional qualifications that 

are required for a BLM Paleontological Resources Use Permit applicant. BLM-approved 

training and field experience may also allow employees to gain sufficient background to achieve 

competency in the field. With the approval of the Regional Paleontologist and the Office 

Manager or Deputy State Director, these employees may be designated as qualified to perform 

field surveys or monitoring. The current availability of these employees must also be approved 

by the unit manager or Deputy State Director, typically on a project-by-project basis or within a 

defined time period. Depending on official duties, local roles and responsibilities, and 

management preferences, these employees may or may not be the Paleontology Coordinator. 

Paleontology Program Lead (Paleontology Lead) – Any one of the following: the Regional 

Paleontologist in the states with an identified position; the paleontologist at Grand StaircaseEscalante National Monument; or the State Office Archeologist in the states without a Regional 

Paleontologist. 

Principal Investigator – The person listed as Permittee (Permit item 1a) on the Paleontological 

Resources Use Permit is the Principal Investigator (PI) and is responsible for all actions under 

the permit, for meeting all permit terms and conditions, and for the performance of all other 

personnel. This person is also the contact person for the project proponent and the BLM. 

Regional Paleontologist – The BLM paleontologist that provides professional expertise in 

paleontology, and is responsible for interpreting relevant laws, authorities, and policy for the 

administration of the BLM paleontology program for all States in his/her respective region, and 

as the program interface between Field and/or District Offices, State Offices, and the 

Washington Office. In some cases, the Regional Paleontologist also serves as the State Office 

Paleontologist.

Significant Paleontological Resource (syn. Significant Fossil Resource) – Any paleontological 

resource that is considered to be of scientific interest, including most vertebrate fossil remains 

and traces, and certain rare or unusual invertebrate and plant fossils. A significant 

paleontological resource is considered to be scientifically important because it is a rare or 

previously unknown species, it is of high quality and well-preserved, it preserves a previously 

unknown anatomical or other characteristic, provides new information about the history of life 

on earth, or has identified educational or recreational value. Paleontological resources that may 

be considered to not have paleontological significance include those that lack provenience or 

context, lack physical integrity because of decay or natural erosion, or that are overly redundant 

or are otherwise not useful for research. 

D-20
Attachment 1-19 

Vertebrate fossil remains and traces include bone, scales, scutes, skin impressions, burrows, 

tracks, tail drag marks, vertebrate coprolites (feces), gastroliths (stomach stones), or other 

physical evidence of past vertebrate life or activities. 

Soil – The natural medium for growth of land plants (from American Geological Institute (AGI), 

Glossary of Geology, 1972 ed.) Generally, well-developed soils do not contain paleontological 

resources. However, the C horizon (the substratum above bedrock that is little affected by soil 

forming processes) may occasionally contain Pleistocene-aged fossils. 

Stipulations – Written conditions that may restrict or impose limits on approved activities, or 

require that certain procedures be followed. The general usage herein encompasses several 

formal terms specific to other use authorizations such as Mitigation, Terms and Conditions, 

Conditions of Approval, and Standard Stipulations. 

Surface disturbance – Disruption of the ground surface and subsurface. Disruption may 

damage or destroy significant paleontological resources and their geological context. 

– Generally excludes: fire (but not fire activities, see below), vegetation mowing, weed

spraying, grazing, natural erosion, fence building 

– Some activities that may impact the ground surface and must be assessed on a case-bycase basis are: 

* Mechanized vegetative treatments – chaining, sagebrush chopping, etc

* Seismic activities – vibroseis techniques, cross-country travel

* Fire management activities – line building, brush removal and thinning using

mechanized equipment 

* Recreational activities – OHV, rock collecting, mountain biking, public events

Voucher Specimen – A representative sample that verifies the kind of fossil material found 

during a field survey, and is collected and curated in an approved repository along with its 

associated field data. 

D-21
Attachment 2-1 

Paleontological Resources Assessment Flowchart 

Are Paleontological Resources Affected? 

Unknown YES NO

 B 

Analyze Affected Surface Geology 

(apply PFYC – conduct a separate assessment 

for each affected geological unit) 

PFYC Class: 1 2 3 4 5 

YES NO YES NO YES NO

 

 A B A C A C 

 A

C 

Assessment of Project or Land Management Action

Prior to Permit or Other Approval

(Includes proponent-initiated projects, land tenure 

adjustments, and other actions)

Can the proposed action potentially affect 

paleontological resources?

Very Low/ Low Potential

Are significant paleo 

resources known to occur 

in the project area?

Moderate/ Unknown Potential

Is there adequate information 

to evaluate affects to paleo 

resources?

High/ Very High Potential

Is there a reasonable 

expectation of adverse 

impacts to paleo resources?

Analyze Affected Surface Geology

(Apply PFYC – Conduct separate assessment 

for each affected geological unit.)

Can the paleo resource be avoided?

Can the project be re-routed or 

redesigned? 

Can the need for surface disturbance be 

reduced or eliminated?

D-22
Attachment 2-2 

Paleontological Actions 

 C 

No Yes 

 B D 

 Yes 

No

 Yes 

 B 

No

 

No further assessment 

required.

Document case file. Include 

standard/ special paleo 

stipulations as appropriate.

Monitoring plan for on-site 

monitoring or spot checking as 

appropriate.

Determine the need for field survey

or monitoring. 

Written assessment.

Is the action likely to affect 

significant paleo resources?

Can the paleo resource be avoided?

Can the project be re-routed or 

redesigned? 

Can the need for surface 

disturbance be reduced or 

eliminated?

Conduct paleontological field 

survey.

Survey Report.

Is the action likely to affect 

significant paleontological 

resources?

D-23
BEST MANAGEMENT PRACTICES

APPENDIX 

E

tHE 
E-1

APPENDIX E

BEST MANAGEMENT PRACTICES

INTRODUCTION

Best management practices (BMPs) are those land and resource management techniques designed to

maximize beneficial results and minimize negative impacts of management actions. BMPs are defined as 

methods, measures, or practices selected on the basis of site-specific conditions to provide the most

effective, environmentally sound, and economically feasible means of managing an activity and

mitigating its impacts. Interdisciplinary site-specific analysis is necessary to determine which

management practices would be necessary to meet specific goals. Selection and implementation of any

BMPs will be evaluated against the New Mexico Public Land Health Standards to ensure progress toward 

public land health attainment. BMPs include, but are not limited to, structural and nonstructural controls, 

operations, and maintenance procedures. BMPs can be applied before, during, and after pollution 

producing or surface-disturbing activities to reduce or eliminate the introduction of pollutants into 

receiving waters (40 Code of Federal Regulation 130.2(m), Environmental Protection Agency Water

Quality Standards Regulation) or to prevent unnecessary or undue degradation of resources such as water 

and air.

BMPs are identified as part of the National Environmental Policy Act process, with interdisciplinary

involvement. Because the control of nonpoint sources of pollution and prevention of damage to other

resources is an ongoing process, continual refinement of BMP design is necessary. This process can be

described in five steps, which are:

1. selection of design of a specific BMP;

2. application of BMP;

3. monitoring; 

4. evaluation; and

5. feedback. 

Data gathered through monitoring are evaluated and used to identify changes needed in BMP design, 

application, or in the monitoring program.

BMPs described in this appendix are a compilation of existing policies and guidelines and commonly

employed practices designed to assist in achieving the objectives for maintaining or minimizing water

quality degradation from nonpoint sources; preventing the loss of soil productivity; providing guidelines 

for aesthetic conditions within watersheds; reducing particulate matter and emissions; and mitigating 

impacts to soil, vegetation, or wildlife habitat from surface-disturbing activities. BMPs are selected and 

implemented as necessary, based on site-specific conditions, to meet a variety of resource objectives for 

specific management actions. Therefore, this document does not provide an exhaustive list of BMPs, as 

additional BMPs or modifications may be identified to minimize the potential for negative impacts when 

evaluating site-specific management actions through an interdisciplinary process.

In addition, implementation and effectiveness of BMPs need to be monitored to determine whether the

practices are achieving resource objectives and accomplishing desired goals. Adjustments will be made 

as necessary.

Each of the following BMPs are a part of the coordinated development of land use plans in the Las 

Cruces District and may be updated as new information becomes available to ensure objectives are met 
E-2

and to conform with changes in Bureau of Land Management (BLM) regulations, policy, direction, or 

new scientific information. Applicants also may suggest alternative procedures that could accomplish the 

same result. These guidelines will apply, where appropriate, to all use authorizations, including BLM 

initiated projects. Any BMP listed may be used in any program wherever it may be effective.

ROAD DESIGN AND MAINTENANCE

 Design roads to minimize total disturbance, to conform to topography, and to minimize disruption 

of natural drainage patterns.

 Base road design criteria and standards on road management objectives such as traffic 

requirements of the proposed activity, overall transportation objectives, and to meet 

environmental objectives such as minimizing damage to natural surroundings. Locate roads on 

stable terrain such as ridge tops, natural benches, the flatter transitional slopes near ridges and 

valley bottoms, and moderate side slopes. Locate roads away from slumps, slide-prone areas, 

concave slopes, clay beds, and places where rock layers dip parallel to the slope. Locate roads on 

well-drained soil types; avoid wet areas.

 Construct cut-and-fill slopes to be approximately 3(h):1(v) or flatter where feasible. Locate roads 

to minimize heights of cutbanks. Avoid high, steeply sloping cutbanks in highly fractured 

bedrock.

 Avoid head walls; midslope locations on steep, unstable slopes; fragile soils; seeps; old 

landslides; sideslopes in excess of 70 percent; and areas where the geologic bedding planes or 

weathering surfaces are inclined with the slope. Implement extra mitigation measures when these 

areas cannot be avoided. Construct roads for surface drainage by using outslopes, crowns, grade 

changes, drain dips, waterbars, or in sloping to ditches as appropriate.

 Sloping the road base to the outside edge for surface drainage is normally recommended for local 

spurs or minor collector roads where traffic volume is low and low traffic speeds are anticipated. 

This is also recommended in situations where long intervals between maintenance will occur and 

where minimum excavation is wanted. Outsloping is not recommended on steep slopes. Sloping 

the road base to the inside edge is an acceptable practice on roads with steep sideslopes and 

where the underlying soil formation is very rocky and not subject to appreciable erosion or 

failure.

 Crowning and ditching are recommended for arterial and collector roads where traffic volume, 

speed, intensity, and user comfort are considerations. Recommended gradients range from 0 to 

15 percent where crowning and ditching may be applied, as long as adequate drainage away from 

the road surface and ditch lines is maintained.

 Where possible, reroute or reengineer vehicle routes that divert overland flow and contribute to 

declines in public land health (watershed and vegetation standards).

 Minimize excavation when constructing roads through balancing earthwork, narrowing road 

widths, and end-hauling where sideslopes are between 50 and 70 percent.

 If possible, construct roads when soils are dry and not frozen. When soils or road surfaces 

become saturated to a depth of 3 inches, BLM-authorized activities should be limited or cease 

unless otherwise approved by the Authorized Officer.
E-3

 Consider improving inadequately surfaced roads that are to be left open to public traffic during 

wet weather by using gravel or pavement to minimize sediment production and maximize safety.

 Retain vegetation on cutslopes unless it poses a safety hazard or restricts maintenance activities. 

Roadside brushing of vegetation should be done in a way that prevents disturbance to root 

systems and visual intrusions (i.e., avoid using excavators for brushing).

 Retain adequate vegetation between roads and streams to filter runoff caused by roads. Avoid 

riparian/wetland areas where feasible; locate in these areas only if the roads do not interfere with

the attainment of proper functioning condition and riparian management objectives.

 Minimize the number of unimproved stream crossings. When a culvert or bridge is not feasible, 

locate drive-thru (low-water crossings) on stable rock in the drainage channel. Harden crossings 

with rock and gravel if necessary. Use angular rock if available.

 Locate roads and limit activities of mechanized equipment within stream channels to minimize 

their influence on riparian areas. When stream crossing is necessary, design the approach and 

crossing perpendicular to the channel, where practical. Locate the crossing where the channel is 

well defined, unobstructed, and straight.

 Avoid placing fill material in a floodplain unless the material is heavy enough to remain in place 

during flood events.

 Use drainage dips instead of culverts on roads where gradients would not present a safety issue. 

Locate drainage dips in such a way that water will not accumulate or where outside berms will 

prevent drainage from the roadway. 

 Locate and design drainage dips immediately upgrade of stream crossings and provide buffer 

areas and catchment basins to prevent sediment from entering the stream.

 Construct catchment basins, brush windrows, and culverts so as to minimize sediment transport 

from road surfaces to stream channels. Install culverts in natural drainage channels in a way that 

conforms with the natural streambed gradients so the drainage flows to outlets that discharge onto 

rocky or hardened, protected areas.

 Design and locate water-crossing structures in natural drainage channels to offer adequate 

passage for fish, provide for minimum impacts to water quality, and be capable of handling a 

100-year event for runoff and floodwaters.

 Use culverts that will withstand, at a minimum, a 50-year storm event and/or that have a 

minimum diameter of 24 inches for permanent stream crossings and a minimum diameter of 

18 inches for drains that cross roads.

 Replace undersized culverts and repair or replace damaged culverts and downspouts. Provide 

energy dissipaters at culvert outlets or drainage dips.

 Locate culverts or drainage dips to avoid discharging onto unstable terrain such as head walls or 

slumps.
E-4

 Provide adequate spacing to avoid accumulation of water in ditches or road surfaces. Place 

culverts on solid ground to avoid road failures.

 Use properly sized aggregate and riprap during culvert construction. Place riprap at culvert 

entrance to streamline water flow and reduce erosion.

 Establish adapted vegetation on all cut–and-fill slopes immediately following road construction 

and maintenance.

 Remove berms from the downslope side of roads, consistent with safety considerations.

 Leave abandoned roads in a condition that provides adequate drainage without further 

maintenance. Close abandoned roads to traffic. Physically obstruct the road with gates, large 

berms, trenches, logs, stumps, or boulders as necessary to accomplish permanent closure.

 Abandon and rehabilitate roads no longer needed. Leave these roads in a condition that provides 

adequate drainage and remove culverts.

 When plowing snow for road use during winter, provide breaks in snow berms to allow for road 

drainage.

 Avoid plowing snow into streams. Plow snow only on existing roads.

 Perform maintenance to conserve existing surface material; retain the original crowned or 

outsloped, self\draining cross-section; and prevent or remove rutted berms (except those designed 

for slope protection) and other irregularities that retard normal surface runoff. Avoid casting 

loose ditch or surface material past the shoulder where it can cause stream sedimentation or 

weaken slump-prone areas. Avoid undercutting backslopes.

 Do not disturb the toe of cutslopes while pulling ditches or grading roads. Avoid side casting 

road material into streams.

 Grade roads only as necessary. Maintain drain dips, waterbars, road crown, insloping, and 

outsloping, as appropriate, during road maintenance.

 Maintain roads in special management areas according to special management area guidance. 

Generally, retain roads within existing disturbed areas and side cast material away from the 

special management area.

 When landslides occur, save all soil and material usable for reclamation and stockpile it for future

reclamation needs. 

 Avoid side casting slide material where it can damage, overload, or saturate embankments or flow 

into downslope drainage courses. 

 Reestablish vegetation as needed in areas where it has been destroyed due to side casting.

 Strip and stockpile topsoil before construction of new roads, if feasible. Reapply soil to cut-andfill slopes prior to revegetation.
E-5

SURFACE-DISTURBING ACTIVITIES

 Require special design and reclamation measures, as appropriate, to protect scenic and natural 

landscape values. This may include transplanting trees and shrubs, mulching and fertilizing 

disturbed areas, removing surfacing material, imprinting, irrigating, using low-profile permanent 

facilities, and painting to minimize visual contrasts. Surface-disturbing activities may be moved 

to avoid sensitive areas or to reduce the visual effects of the proposal.

 Design aboveground facilities that requiring painting to blend in with the surrounding 

environment.

 Restrict surface disturbances in areas that have special topographic (steep or broken terrain and/or

benches) and soil concerns in order to reduce impacts caused by soil erosion and habitat 

disturbance.

 Development in these areas will be considered on a case-by-case basis and will contain sitespecific mitigation designed to prevent increased sediment from being transported into drainages 

and to prevent fragmentation of areas determined to provide important wildlife habitat.

 Excavate topsoil and subsoil only where it is absolutely necessary. Consider brush-beating, 

mowing, and/or parking on vegetation for surface disturbing activities.

 Contour disturbed areas to blend with the natural topography. Blending is defined as reducing 

form, line, and color contrast associated with surface disturbance. Disturbances should be 

contoured to match the original topography, where matching is defined as reproducing the 

original topography and eliminating the form, line, and color caused by the disturbance as much 

as possible.

 Implement interim reclamation concurrent with construction and site operations to the extent 

possible.

 Initiate final reclamation actions within six months of the termination of operations unless 

otherwise approved in writing by the Authorized Officer.

 Push the fill material into cut areas and over backslopes. Do not leave depressions that could trap 

water or form ponds unless the authorized officer has determined that dips or depressions may be 

used to assist reclamation and seed propagation efforts.

 Stabilize open storage piles and disturbed areas by covering and/or applying water or 

chemical/organic dust palliative where appropriate at active and inactive sites during workdays, 

weekends, holidays, and windy conditions.

 Make certain that reclaimed soil is free of contaminants and has adequate depth, texture, and 

structure for successful reclamation of vegetation. Vegetation reclamation will be considered 

successful when healthy, mature perennials are established with a composition and density that 

closely approximates the surrounding vegetation, as prescribed by the BLM, and the reclamation 

area is free of noxious weeds.

 Install wind fencing and phase grading operations where appropriate, and operate water trucks for 

stabilization of surfaces under windy conditions.
E-6

 In compliance with E.O.13112 and BLM Manual 1745, and subject to future revisions to Bureau 

policy and guidance, where restoration, rehabilitation, or reclamation efforts (including Bureau 

authorized actions such as rights-of way) require reseeding activities, or use of other plant 

materials (such as potted plants, poles, etc.), non-native plant species would be used only if native 

species are not readily available in sufficient quantities. Care would be taken in selecting nonnative species that are not likely to become invasive. If non-native plant species are used or 

identified for use in restoration, rehabilitation, or reclamation projects, the BLM, through the 

Bureau Plant Conservation Program and partner organizations, would work to identify and 

develop native replacements for the non-native species. Additionally, seed mixes used in these 

actions would use the closest locally adapted selections, varieties, or cultivars of native species 

available to improve success of the seeding effort.

 Prevent spillage when hauling material and operating non-earthmoving equipment and limit 

speeds to 15 miles per hour. Limit speed of earthmoving equipment to 10 mph.

 Construct a BLM-standard barbed-wire fence if necessary to exclude livestock for a minimum of 

at least two successful growing seasons after reclamation.

 Plan construction scheduling to minimize vehicle trips.

 Limit idling of heavy equipment to less than 5 minutes and verify through unscheduled 

inspections.

 Maintain and tune engines per manufacturer’s specifications to perform at EPA certification 

levels, prevent tampering, and conduct unscheduled inspections to ensure these measures are 

followed.

 Include a restoration plan for habitat of special status species when the BLM determines it is 

appropriate. Develop the restoration plan, in consultation with BLM, for BLM approval.

 Require additional reclamation measures, if needed, based on the conditions existing at the time 

of abandonment.

 Carefully handle and dispose of oil and fuel from equipment and vehicles to prevent 

contamination of soil or water.

 Develop a spill contingency plan that identifies all actions to be taken in the event of a chemical 

spill, including phone numbers for Federal, State, and local agencies that must be notified.

 Time activities to avoid wet periods of the year, if possible.

RIGHTS-OF-WAY 

 Use areas adjoining or adjacent to previously disturbed areas for rights-of-way whenever possible 

rather than traverse undisturbed vegetation communities.

 Construct waterbars or dikes on all rights-of-way and across the full width of the disturbed area, 

as directed by the Authorized Officer.
E-7

 Stabilize disturbed areas within road rights-of-way by implementing vegetation practices 

designed to hold soil in place and minimize erosion.

 Construct sediment barriers when needed to slow runoff, allow deposition of sediment, and 

prevent transport from the site. Employ straining or filtration mechanisms as needed for the 

removal of sediment from runoff.

FIRE SUPPRESSION

 Minimize surface disturbances and avoid the use of heavy earth-moving equipment where 

possible, on all fire suppression and rehabilitation activities, including mop-up, except where high 

value resources (including lives and property), are being protected.

 Install waterbars and seed all constructed fire lines with native or adapted nonnative species as 

appropriate and in accordance with the BLM’s Emergency Fire Rehabilitation Handbook (BLM 

1999).

 Avoid dropping fire retardant that is detrimental to aquatic communities on streams, lakes, ponds 

and in riparian/wetland areas.

 Locate and construct handlines to result in minimal surface disturbance while effectively 

controlling the fire. Hand crews should locate lines to take full advantage of existing land 

features that represent natural fire barriers. Whenever possible, handlines should follow the 

contour of the slope to protect the soil, provide sufficient residual vegetation to capture and retain 

sediment, and maintain site productivity.

PRESCRIBED BURNING

 Protect soil productivity by using a low-intensity burn, if possible, to accomplish stated 

objectives. Burn only when the organic surface or duff layer has adequate moisture to minimize 

effects on the physical and chemical properties of the soil. When possible, maximize the 

retention of the organic surface or duff layer.

 Do not pile or burn slash within riparian/wetland areas. If riparian/wetland areas are within or 

adjacent to the prescribed burn unit, piles should be fire lined or scattered prior to burning.

 Avoid piling concentrations of large logs and stumps when preparing the unit for burning; pile 

small material (3 to 8 inches in diameter) instead. Burn slash piles when soil and duff moisture 

are adequate to reduce potential damage to soil resources.

 All fire management activities will be subject to the BMPs identified in the Decision Record and

Resource Management Plan Amendment for Fire and Fuels Management on Public Land in New 

Mexico and Texas (BLM 2004c). BMPs are identified in these documents, which can be viewed 

online at http://www.nm.blm.gov.
E-8

LIVESTOCK GRAZING MANAGEMENT

 All rangeland projects and vegetation land treatments will meet current BLM policy and 

objectives of the Prehistoric Trackways National Monument Resource Management Plan. This 

includes the BMPs for Surface Disturbing Activities and Invasive/Noxious Weed Management. 

Other BMPs may be required depending on the rangeland improvement project.

 Rangeland improvements projects and vegetation treatments are constructed as a portion of 

adaptive management to reduce resource conflicts and to achieve multiple-use objectives. They 

have been standardized over time to mitigate impacts and will be adhered to in the construction 

and maintenance of rangeland projects within the Planning Area. Rangeland improvements are 

structures, facilities, and practices intended to improve or facilitate grazing management and 

improve resources.

 Grazing management practices are developed through consultation on allotment-specific 

objectives and progress toward multiple-use objectives and sustainability of resources. Grazing 

management practices may include herding, grazing, and deferment periods; use of supplements; 

change of class of livestock; and increase or decrease of livestock numbers.

INVASIVE/NOXIOUS WEED MANAGEMENT

 Inspect and clean all surface-disturbing equipment prior to its coming onto public lands. This is 

especially important on vehicles from out of state or coming from a weed-infested area.

 Make sure the source of fill dirt or gravel brought onto public land is free of noxious weeds.

 Monitor construction sites for the life of the project for the presence of invasive/noxious weeds 

(including maintenance and construction activities). If weeds are found, the BLM Las Cruces 

District Office will be notified and will determine the best method for the control of the particular 

weed species.

 Certify all seed as noxious-weed free. Areas will be monitored to determine the success of revegetation and the presence of invasive/noxious weeds and will be reseeded if necessary.

 Consider livestock quarantine, removal, or timing limitations in areas infested with 

invasive/noxious weeds.

 Certify all seed, hay, straw, mulch, or other vegetation material transported and used on public 

land for site stability, rehabilitation, or project facilitation as free of all reproductive parts of 

noxious weeds upon the passage of a weed-free law by the State of New Mexico. All baled feed, 

pelletized feed, and grain used to feed livestock also shall be certified as free of the seeds of 

noxious weeds.

 Consider having all vehicles that travel in or out of weed-infested areas clean their equipment 

before and after use on public land, including off-road and all-terrain vehicles. (This precaution 

is recommended.)
E-9

DEVELOPED RECREATION

 Construct recreation sites and provide appropriate sanitation facilities to minimize impacts on 

resource values and on public health and safety and to minimize user conflicts concerning 

approved activities and access within an area, as appropriate.

 Minimize impacts on resource values or enhance the recreational setting and recreation 

experience.

 Harden sites and locations subject to prolonged/repetitive, concentrated recreational uses with 

selective placement of gravel or other porous materials and allow for dust abatement, paving, and 

engineered road construction.

 Use public education and/or physical barriers (such as rocks, posts, vegetation) to direct or 

preclude uses and to minimize impacts on resource values and the quality of recreation 

experience.

 Employ land use ethics programs and techniques such as “Leave No Trace” and “Tread Lightly” 

programs. Use outreach efforts of such programs to lessen needs to implement more stringent 

regulatory measures to obtain resource protection and a quality recreation experience.

WILDLIFE AND RIPARIAN HABITAT

 Before a surface-disturbing activity begins, the project area will be surveyed for raptor nests or 

active prairie dog towns. Surveys will be conducted by professional biologists approved by the 

Authorized Officer. All raptor nests and active prairie dog towns will be avoided by the 

following distances and seasonal periods:

 Eagle – 0.5 mile, February 1-July 15

 Prairie falcon – 0.5 mile, March 1-August 1

 Ferruginous hawk – 0.5 mile, February 1-July 15

 Aplomado falcon – 0.5 mile, January 1-July 31

 Gunnison prairie dog – 0.25 mile, February 15-June 15

 Black-tailed prairie dog – 0.25 mile, January 1-June 15

 All other raptor species – 0.25 mile, during observed nest establishment through fledging

 Require site-specific mitigation to avoid disturbance within a half mile of occupied special status 

species habitat.

 Make all livestock waters on public land available to wildlife yearlong, so long as this meets 

grazing rotation objectives and there is no danger of damage to facilities from freezing.

 Situations where the rotation of livestock is achieved through turning off of water sources, a fence 

will be constructed around the watering facility to allow for opening/closing of a gate to facilitate 

movement of livestock. This will allow wildlife yearlong access to the watering facility. If 

freezing of the pipeline/trough system is a concern, fill up trough once a month during winter 

period to allow wildlife continued access to a water source. All watering facilities on public land 

will be fitted with an escape ramp to keep small mammals and birds from becoming trapped.
E-10

 Avoid constructing new roads within critical wildlife habitats. Permanent or seasonal closures 

may be instituted where problems exist or are expected. Where major road projects are proposed 

in wildlife corridors, use fencing and wildlife passes to mitigate wildlife impacts.

 Manage wildlife habitat on lands identified for disposal as a low priority, unless site specific 

analysis determines that changes in the existing situation have resulted in higher resource values 

warranting retention of these lands to protect fish and wildlife habitat values consistent with 

existing laws, regulations, and policies. Conduct a site specific assessment of environmental 

impacts before disposal of Department of Game and Fish (NMDGF).

 Construct protective exclosures/fences around riparian areas, wildlife watering facilities, and 

other areas of resource concern.

 Long-term land use activities will not be allowed within the species-specific buffer zones 

surrounding the active raptor nests or occupied prairie dog towns of the identified species. Shortterm activities will be avoided within the species-specific buffer zones during the listed dates. 

Short-term activities will be limited to the buffer zone outside the boundary of an occupied prairie 

dog town and will not occur within the occupied town. All raptor nests, including those of nonlisted species, will be avoided within the vicinity is defined as an activity that would begin 

outside a given breeding season and end prior to initiation of a given breeding season. A longterm activity is defined as an activity that would continue into or beyond a given nesting/breeding 

season. An active nest is defined as any nest that has been occupied in the last 7 years. A nest 

will be determined active or inactive by the Authorized Officer. Surveys will be conducted by 

professional biologists approved by the Authorized Officer.

 Ensure that all fences are constructed to the fence specifications of the BLM Socorro Field Office 

to mitigate impacts on wildlife.

 Ensure that escape wildlife ramps are installed and maintained on all applicable water 

development projects on public lands (see the BLM Water Developments Handbook dated 

November 6, 1990 and IM No. 2004-156).

 Construct all new water improvements so they are located a minimum of 30 meters away from 

fences or other structures likely to pose a collision threat to bats.

 Do not allow surface disturbance within 0.5 mile of the outer edge of 100-year floodplains, 

playas, all artificial water developments (tanks, guzzlers, etc.), and riparian habitats (seeps, 

arroyos, etc.). Exceptions to this requirement will be considered on a case-by case basis.

 Avoided adverse impacts on the landscape by minimizing or excluding certain surface-disturbing

activities that may degrade the objectives or intent of the project in areas where habitat or 

rangeland enhancement projects have been implemented, with the exception of large landscape 

projects (prescribed burns, chemical treatments, and mechanical treatments). Exceptions to this 

requirement will be considered on a case-by-case basis.

 Achieve habitat enhancement by limiting and/or mitigating existing and proposed commodity 

uses and by proactive habitat management practices including, but not limited to, fire 

management; water development; chemical, mechanical, or biological brush control; and fence 

modifications.
E-11

 Avoid all surface-disturbing activities, permanent or temporary, during the appropriate time 

periods in crucial calving, lambing, kidding, and fawning areas and wintering ranges.

 Survey the area for the presence of raptor nests prior to initiating geophysical or other preliminary 

surveys during the raptor breeding season.

 Follow these measures when siting facilities:

1. In areas that constitute occupied or potential aplomado falcon habitat, a protocol survey for 

this species will be conducted along with the above general raptor nest survey prior to

surveying/flagging locations.

2. During operations at any time, all habitat features (pinnacles, cliffs, ledges, caves, and trees

and shrubs greater than 6 feet high) containing or capable of containing raptor nests or bat

habitat will be avoided by vehicular traffic or other surface-disturbing activities likely to

remove or destroy them, unless approved by the BLM Authorized Officer.

3. Tree and vegetation clearing will be limited to the minimum area required.

4. Construction activities will be timed to avoid wet periods.

5. Power lines will be constructed to standards outlined in the most recent version of Suggested

Practices for Raptor Protection on Power Lines published by the Edison Electric

Institute/Raptor Research Foundation, unless otherwise agreed to by the Authorized Officer. 

The holder is responsible for demonstrating that power pole designs not meeting these

standards are raptor safe. Such proof will be provided by a raptor expert approved by the

Authorized Officer. BLM reserves the right to require modifications or additions to power 

line structures constructed under this authorization, should they be necessary to ensure the 

safety of large perching birds. The modifications or additions will be made by the holder 

without liability or expense to the United States.

6. All equipment installed on Federal lands will be constructed to prevent birds and bats from

entering them and, to the extent practical, to discourage perching and nesting.

7. Open-top tanks, reserve pits, disposal pits, or other open pits will be required to be equipped 

to deter entry by birds, bats, or other wildlife.

 Continue to coordinate arroyo habitat management with other programs and activities throughout 

the Monument, as needed. Specific programs include Range, Wildlife, Watershed, Recreation, 

and Lands. Riparian and arroyo habitat values will be addressed in all surface and vegetationdisturbing actions. 
E-12

VISUAL RESOURCES MANAGEMENT

BMPs to address visual resource concerns have been incorporated into the preceding resource

discussions, as appropriate. To the extent practicable, existing facilities or substantial existing visual

contrasts would be brought into visual resource management class conformance as the need or

opportunity arises. Additional BMPs dealing with visual resource management considerations in oil and

gas development can be found on the BLM Web site at www.blm.gov/bmp.

BMPs dealing with visual resource management considerations in general are available at 

www.blm.gov/nstc/VRM/destech.
PUBLIC SCOPING REPORT

APPENDIX 

F

tHE 
BLM

United States Department of the Interior

Bureau of Land Management

Las Cruces District Office

1800 Marquess Street

Las Cruces, New Mexico 88005

PREHISTORIC TRACKWAYS NATIONAL 

MONUMENT

Resource Management Plan/

Environmental Impact Statement

PUBLIC SCOPING REPORT

July 2010
Table of Contents

Executive Summary.......................................................................................................................................i

Acronyms......................................................................................................................................................ii

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

1.1 Overview.......................................................................................................................................1

1.1.1 Background & Purpose and Need.........................................................................................1

1.2 Planning Area................................................................................................................................2

1.2.1 Location ................................................................................................................................2

1.2.2 Description............................................................................................................................2

1.3 Scoping Process............................................................................................................................4

1.3.1 Description of Process ..........................................................................................................4

1.3.2 Mailings ................................................................................................................................5

1.3.3 Public Notices.......................................................................................................................5

1.3.4 Media Releases and Public Service Announcements............................................................5

1.3.5 Web Site................................................................................................................................7

1.3.6 Public Meeting......................................................................................................................7

1.4 Cooperating Agencies...................................................................................................................7

1.5 Tribal Consultation .......................................................................................................................8

Issue Summary..............................................................................................................................................9

Comment Summary ......................................................................................................................................9

2.1 Method of Comment Collection and Analysis..............................................................................9

2.2 Summary of Public Comments Received ...................................................................................10

Issues Identified Prior to and During Scoping............................................................................................10

2.3 Issue 1- Paleontological and Cultural Resource Research and Protection..................................10

2.3.1 Issue Questions ...................................................................................................................11

2.4 Issue 2- Interpretation and Education .........................................................................................11

2.4.1 Issue Questions ...................................................................................................................12

2.5 Issue 3- Travel and Access..........................................................................................................12

2.5.1 Issue Questions ...................................................................................................................13

2.6 Issue 4-Habitat and Its Users ......................................................................................................13

2.6.1 Issue Questions ...................................................................................................................13

2.7 Issue 5- Visual Resources...........................................................................................................14

2.7.1 Issue Questions ...................................................................................................................14
2.8 Issue 6- Socioeconomic ..............................................................................................................14

2.8.1 Issue Questions ...................................................................................................................15

2.9 Issue 6- Recreation......................................................................................................................15

2.9.1 Issue Questions ...................................................................................................................16

2.10 RMP/EIS Process........................................................................................................................17

2.11 Issues Raised that Will Not Be Addressed..................................................................................17

Draft Planning Criteria................................................................................................................................19

Data Summary/Data Gaps...........................................................................................................................21

Summary of Future Steps in the Planning Process.....................................................................................21

For Further Information ..............................................................................................................................22

Table 1 Public Notices in Newspapers of Record.........................................................................................5

TABLES

Table 2 Articles in Newspapers of Record ...................................................................................................6

Table 3 Public Scoping Meeting Date, Location, Attendance ......................................................................7

Figure 1 Map of Monument in relation to Las Cruces, New Mexico ...........................................................3

FIGURES

Figure 2 Sequence of Planning Activities for the Prehistoric Trackways National Monument RMP........23

Appendix A: Notice of Intent.............................................................................................................. APP-1

APPENDICES

Appendix B: Scoping Letter and Packet............................................................................................. APP-3

Appendix C: Public Notice ................................................................................................................. APP-8

Appendix D: Public Meeting Flyer......................................................................................................APP-9

Appendix E: BLM News Release ..................................................................................................... APP-10
i

Executive Summary

The Bureau of Land Management (BLM), Las Cruces District Office in Las Cruces, New Mexico is 

preparing the Prehistoric Trackways National Monument Resource Management Plan (RMP) and an 

associated Environmental Impact Statement (EIS). An RMP for public land is more effectively 

implemented if the management decisions made by BLM reflect the values and interests of the public. 

However, for this Monument, the management plan also must address and is guided by the Legislation

designating the Monument.

The formal scoping process began with the publication of a Notice of Intent on January 5, 2010. This 

Notice indicated the Las Cruces District Office’s intent to prepare an RMP, an associated EIS, and to hold 

a public scoping meeting in conjunction with that process. One formal scoping meeting was held on 

January 26, 2010 to share information about the Monument, preliminary issues, and the planning process.

The BLM asked the public for comments and suggestions regarding the management of the natural, 

cultural, recreation, and scientific resources within the Monument. Approximately 100 people attended 

the public scoping meeting. BLM received 17,388 total comment submittals, of which 17,287 were a 

variety of repeat form letters. The themes expressed in these form letters are summarized as follows:

• the Legislation should take precedence over any multiple-use mandate

• move Off-Highway Vehicle (OHV) routes outside of the Monument in order to protect the 

trackways

• keep OHV trails within the Monument

• improve non-motorized access and interpretive information

• encourage public involvement, both do and do not incorporate “Expanded Boundary Possibilities 

for Adjacent Areas” within the RMP

• consider all cumulative impacts such as loss of motorized recreation opportunities and 

Community Pit #1 reclamation

The other 99 comments followed several common themes about the natural resources within the 

Monument and the management of those resources.

At their request, informal meetings with a number of groups and agencies have been held prior to and 

since the public meeting. The initial “formal scoping” period closed on February 10, 2010, and this report 

will address comments from this initial scoping period. Although the formal comment period has ended, 

BLM will continue to accept and consider all comments received throughout the planning process. The 

comments will become a part of the administrative record.

This Scoping Report is intended to provide a summary of the comments received, to refine the 

preliminary issues, and to identify new issues. The report will provide direction to the planning team in 

order to clearly identify issues and to aide in the development of alternatives for the environmental impact 

analysis.
ii

Acronyms

ACEC Area of Critical Environmental Concern

AMS Analysis of the Management Situation

BLM Bureau of Land Management

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

EIS Environmental Impact Statement

FLPMA Federal Land Policy and Management Act

GIS Geographic Information System

GPS Global Positioning System

LCDO Las Cruces District Office

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

NLCS National Landscape Conservation System

NOI Notice of Intent

OHV Off-Highway Vehicle

RMP Resource Management Plan

ROD Record of Decision

VRM Visual Resource Management

WSA Wilderness Study Area
1

Introduction

1 Overview

Although the Prehistoric Trackways National Monument is relatively small (5,280 acres), there is 

considerable public interest in managing the area. Conflicting opinions regarding Off-Highway Vehicle 

(OHV) use and protection of paleontological resources in the Monument are of interest. In order to 

address these uses, resource protection, long-term management of the area, and to fully analyze all 

impacts, the Bureau of Land Management (BLM) Las Cruces District Office (LCDO) in New Mexico is 

preparing a Resource Management Plan (RMP) for the Prehistoric Trackways National Monument 

(Monument) as required by the Omnibus Public Lands Management Act of 2009 (Legislation). This 

Legislation, signed into law by the President on March 30, 2009, states: “Not later than 3 years after the 

date of enactment of this Act, the Secretary shall develop a comprehensive management plan for the longterm protection and management of the Monument.” Under the National Environmental Policy Act 

(NEPA) of 1969 (Public Law 91-190) and the Council on Environmental Quality (CEQ) regulations for 

implementing NEPA, Federal agencies are required to consider the environmental impacts of their 

proposed actions prior to taking action. Pursuant to NEPA, the BLM will prepare an Environmental 

Impact Statement (EIS) associated with the Monument RMP. 

The BLM understands that an RMP for public land is more effectively implemented if the management 

decisions made by the BLM reflect the values and sentiment of the public. The first step in the BLM’s 

planning process is to identify issues from agency and public comments. These issues were identified 

during scoping, a process intentionally conducted early in the planning process to solicit comments and 

translate the information gathered into meaningful input into the planning process and to guide the BLM’s 

actions.

In accordance with 43 Code of Federal Regulations (CFR) 1610.2(d), the BLM must document the results 

of scoping. The BLM’s land use planning guidance (Handbook H-1601-1) requires the preparation of a 

Scoping Summary Report to capture public input into one document. This report summarizes the 

comments received during the formal external scoping period. It also must describe the issues and 

management concerns derived from the public scoping meeting, internal scoping meetings, the 

Preparation Plan; and discuss how these comments will be incorporated into the RMP. In addition, this 

report provides information about the purpose and need for the RMP/EIS, the Planning Area, and BLM’s 

collaborative planning process. This includes a description of the scoping process; an explanation of the 

planning criteria developed to guide and direct the planning effort; a brief description of the data available 

for the studies and data needs; and summary of the future steps in the planning process.

1.1 Background & Purpose and Need

The Monument was established by Congress in the Legislation as a unit of the National Landscape 

Conservation System (NLCS). It encompasses 5,280 acres and was established to conserve, protect, and 

enhance the unique and nationally important paleontological, scientific, educational, scenic, and 

recreational resources and values. The Legislation that designated the Monument directs the BLM to 

develop a management plan for the Monument. Current BLM policy dictates that for units of the NLCS, 
2

of which the Monument is a part, a comprehensive management plan will be developed in the form of a 

“stand alone” RMP and an associated EIS.

The purpose of the Monument RMP is to address management of the natural, biological, and cultural 

resources and resource uses while protecting paleontological resources and being consistent with the 

Legislation. Specific legislative points to be addressed in the RMP include the following:

• Manage the Monument in a manner that conserves, protects, and enhances the resources and 

values of the Monument...

• The management plan...shall describe the appropriate uses and management of the Monument, 

consistent with the provisions of the Legislation.

• The use of motorized vehicles in the Monument shall be allowed only on roads and trails 

designated for use by motorized vehicles under the management plan. 

• The Secretary may issue permits for special recreation events involving motorized vehicles within 

the boundaries of the Monument to the extent the events do not harm paleontological resources; 

and subject to any terms and conditions that the Secretary determines to be necessary.

The associated RMP/EIS will propose alternative solutions to planning issues, in addition to identifying

potential impacts associated with each alternative. The RMP/EIS will also identify BLM’s preferred 

alternative, which will be based on both public input and BLM’s need to adhere to current laws, 

regulations, Legislation, and planning guidance. The direction developed in the plan will facilitate 

management of the Monument as a component of the NLCS.

1.2 Planning Area

1.2.1 Location

The Monument contains 5,280 acres of public land in Doña Ana County, New Mexico, and is 

approximately 5 miles northwest of Las Cruces in the southern third of the Robledo Mountains, see 

Figure 1.

1.2.2 Description

In 1987, a major deposit of Paleozoic Era fossilized footprint megatracks was discovered in the Robledo 

Mountains. The trackways contain footprints of numerous amphibians, reptiles, and insects (including 

previously unknown species), plants, and petrified wood dating back approximately 280 million years. 

This collectively provides new opportunities to understand animal behaviors and environments from a 

time predating the dinosaurs. It is also a popular regional recreation area for hiking, mountain biking, and 

off-highway use (OHV), and through special use permitting, it is used for annual OHV events, which 

have drawn as many as 1,000 participants for a multiple-day event.
3

Figure 1 Map of Monument in relation to Las Cruces, New Mexico
4

1.2.2.1 Description of the Monument and Planning Area

The Planning Area is defined as Doña Ana County, which includes the Prehistoric Trackways National 

Monument, 8 Wilderness Study Areas (WSAs), 11 Areas of Critical Environmental Concern (ACECs), 

and several towns. The Planning Area includes both public, private, other government land, and consists 

of approximately 2,436,595 acres. The Decision Area, that is the area for which decisions will be made in 

the RMP, consists entirely of the 5,280 acres of public land, both surface and subsurface, within the 

designated National Monument.

1.3 Scoping Process

1.3.1 Description of Process

The formal scoping process began with the publication of a Notice of Intent (NOI) in the Federal Register 

on January 5, 2010 (Volume 75, Number 2, Pages 431-432). The NOI is contained in Appendix A and on 

the project web site, referenced below. This Notice indicated the Las Cruces District Office’s intent to 

prepare an RMP, an associated EIS, and to hold a public scoping meeting in conjunction with that 

process. Press releases, flyers, paid advertisements in newspapers, and the BLM New Mexico, Las 

Cruces District project web site, 

http://www.blm.gov/nm/st/en/fo/Las_Cruces_District_Office/trackways_rmp.html announced the public 

scoping period and public scoping meeting also.

One formal scoping meeting was held to share information about the Monument, preliminary issues, and 

the planning process. The BLM asked the public for comments and suggestions regarding the 

management of the natural, cultural, recreation, and scientific resources within the Monument. At their 

request, informal meetings with a number of groups and agencies have been held prior to and since the 

public meeting. The initial “formal scoping” period closed on February 10, 2010, and this report will 

address comments from this initial scoping period. Although the formal comment period has ended, 

BLM will continue to consider all comments and information on resource management issues received

during the planning process. The comments will become a part of the administrative record.

During scoping, preliminary planning issues and criteria were identified by BLM personnel, other 

agencies, and in meetings with individuals. These planning issues and criteria will be used to guide the 

identification and development of management alternatives. Preliminary planning issues and criteria may 

be refined or new ones added as a result of the public scoping process.

This scoping report describes the public scoping process for the Prehistoric Trackways National 

Monument RMP/EIS. It documents outreach efforts, summarizes the comments received, and identifies 

any issues raised and suggested alternatives. These issues are the scope of analysis for the RMP. The 

document does not make decisions nor does it set forth policies.
5

1.3.2 Mailings

An initial public scoping packet was sent to approximately 337 interested parties announcing the BLM’s 

intent to prepare an RMP/EIS for the Monument. Throughout the scoping period, an additional 82 

scoping packets were mailed. The mailing list included adjacent landowners, grazing permittees, special 

recreation permittees, interested public, local agencies, government representatives, tribes, and interested 

organizations. The letter announced the beginning of the formal scoping period, the public Open House, 

and also requested comments regarding the Plan. Inserted in this mailing was a preaddressed “Scoping 

Comment Form” that interested individuals could complete and return to BLM. The form contained two 

questions, plus ample writing space to guide individuals as they submitted their comments regarding the 

Monument. The public scoping letter is presented in Appendix B.

1.3.3 Public Notices

Public notices in the form of Display Ads were published in the newspapers of record. Table 1 shows the 

newspapers that printed the public notice (contained in Appendix C) on the dates indicated.

Table 1 Public Notices in Newspapers of Record

TABLE 1 Public NOTICES IN NEWSPAPERS OF RECORD 

PUBLICATION DATE PUBLICATION PUBLICATION LOCATION 

January 17, 2010 Las Cruces Sun-News Las Cruces, NM 

January 15, 2010 Las Cruces Bulletin Las Cruces, NM 

1.3.4 Media Releases and Public Service Announcements 

Announcement regarding the public scoping meetings and scoping process were issued as news releases 

on January 5 and January 19, 2010, to local and regional newspapers, radio stations and TV stations in 

New Mexico.

1.3.4.1 Newspapers

Articles and feature stories announcing the Public Scoping Open House and scoping process were 

published in local newspapers. 
6

Table 2 Articles in Newspapers of Record

TABLE 2. ARTICLES IN NEWSPAPERS OF RECORD 

PUBLICATION DATE PUBLICATION PUBLICATION LOCATION 

January 7, 2010

January 8, 2010

January 25, 2010

January 27,2010

Las Cruces Sun-News Las Cruces, NM 

January 22, 2010 Las Cruces Bulletin Las Cruces, NM 

January 10, 2010 Albuquerque Journal Albuquerque, NM

1.3.4.2 Informational Flyers

Flyers were distributed throughout Las Cruces, which advertised the location and time of the Public 

Scoping Open House. An example of the flyer can be found in Appendix D.

Locations where flyers were posted are as follows:

• Mesilla Park Post Office

• Thomas Branigan Library

• Las Cruces Natural History Museum

• Las Cruces BLM front desk

• Mesilla Valley Bosque State Park

• Doña Ana County Government Center

• Picacho Post Office, Las Cruces

• Dripping Springs Recreation Area (BLM)

1.3.4.3 Radio Stations

On January 21, 2010 at 4:00 p.m. the Prehistoric Trackways National Monument was the feature story for 

the live radio talk show called “The Bulletin on the Radio” on the local radio station, KSNM AM570. 

The planning process, public scoping meeting, and the paleontological resources were discussed for 

approximately an hour.
7

1.3.5 Web Site

BLM prepared news releases to introduce the project, announce the scoping period, and publicize the 

scoping meeting. The news releases and informational flyer were posted on the New Mexico BLM 

project web site (see BLM News Releases contained in Appendix E).

1.3.6 Public Meeting

BLM hosted one public meeting on January 26, 2010 to provide planning and NEPA information to the 

public and agencies and allow them to identify issues and concerns to BLM. The Public Scoping Meeting 

was advertised on the BLM project web site and through the local media. The meeting was conducted in 

an open-house style format including display materials concerning preliminary planning issues, natural 

resources, and the planning activities. Resource specialists were on-hand for discussion. Each individual 

was asked to sign in for the meeting and/or to request various materials that will be distributed throughout 

the planning process. Those not already on the mailing list were added to the project mailing list. 

Scoping packets were available to all who attended the public meeting and was also available on the 

BLM’s web site. The public scoping packet is located in Appendix B.

As summarized in Table 3, approximately 100 members of the public attended the public meeting.

Table 3 Public Scoping Meeting Date, Location, Attendance

TABLE 3. PUBLIC SCOPING MEETING DATE, LOCATION, AND ATTENDANCE 

MEETING DATE MEETING LOCATION ATTENDANCE 

January 26, 2010 Las Cruces, NM 100

1.4 Cooperating Agencies

In January and February 2010, letters were sent to the following agencies inviting recipients to become a 

cooperating agency for this project:

• City of Las Cruces

• Doña Ana County

• New Mexico Museum of Natural History and Science

• New Mexico Department of Game and Fish

• New Mexico State Parks

By definition, a cooperating agency is any Federal, state, or local government agency or Indian tribe that 

has either jurisdiction by law or special expertise regarding environmental impacts of a proposal. As a 

cooperating agency, it provides the formal framework for governmental units to engage in active 

collaboration with the lead Federal agency during the NEPA process. Although the request was sent to 

these agencies, no agency has pursued cooperating agency status as of yet.
8

1.5 Tribal Consultation

In February 2010, the BLM initiated consultation with the tribes. Included in the consultation letter was a 

request for the recipients to become a cooperating agency for the Monument RMP/EIS. The invitation 

will remain open to tribes as planning continues. Consultation/cooperating agency letters were sent to the 

following tribes:

• Fort Sill Apache Tribe of Oklahoma

• Comanche Indian Tribe

• White Mountain Apache 

• Ysleta del Sur Pueblo

• Pueblo of Isleta

• Mescalero Apache Tribe

• Navajo Nation

Several tribes expressed interest in continued notification of planning activities, but no tribe has requested 

Cooperating Agency Status.
9

Issue Summary

2 Comment Summary

All scoping comments documented in this report were received or postmarked by March 23, 2010. 

However, BLM will continue to accept scoping comments throughout the planning process. BLM 

received 17,388 total submittals, of which 17,287 were a variety of repeat form letters. In summary, the 

themes expressed in these form letters included:

• the Legislation should take precedence over any multiple-use mandate 

• move OHV routes outside of the Monument in order to protect the trackways

• keep OHV trails within the Monument

• improve non-motorized access and interpretive information

• encourage public involvement

• both do and do not incorporate “Expanded Boundary Possibilities for Adjacent Areas” within the 

RMP

• consider all cumulative impacts such as loss of motorized recreation opportunities and

Community Pit #1 reclamation.

The other 99 comments followed several common themes about the natural resources within the 

Monument and the management of them.

2.1 Method of Comment Collection and Analysis

Individuals were encouraged to submit comments in writing to the Las Cruces District Office. Comments 

were collected through various sources including: 

• Regular US Mail

• E-mail

• Fax

• Hand-delivery

Comments were organized by letter and issue. A majority of individual comment letters included 

numerous distinct comments. The form letters and the associated comments were analyzed and 

documented once per associated form letter, which resulted in a total of 101 comment forms/letters 

analyzed. There were a total number of 152 consolidated comments depicted for analysis. After all 

comments were received, reviewed, and documented, individual comments were entered into a database 
10

to assist with the analytical review. The database is structured to depict comments into separate resource 

categories (issues), document the source of the submittal; and consolidate comments of those previously 

mentioned.

Then the issues were placed into one of three categories.

1. Issues to be resolved in the plan;

2. Issues to be resolved through policy or administrative action; or

3. Issues beyond the scope of the plan.

The focus of this report is to thoroughly review the comments and, based on this review, develop 

overarching themes in order to develop a list of possible alternatives based on public, BLM, and 

collaborative and cooperative agency and tribal input.

2.2 Summary of Public Comments Received

For this scoping report, the specific comments were grouped into similar topics and briefly summarized. 

As a result of the high volume and similarity of many comments, included is only a summary of the

comments from each category and does not include all of the comments, suggestions, or concerns raised 

by the public. For a comprehensive summary, please refer to the Monument RMP Scoping Comment 

Table S-1. Copies of original comments are available for review at the Las Cruces District Office.

Comments were categorized into six planning issues. The following section represents a summary of 

public comments provided to the BLM during the public scoping period. Questions that need to be 

answered to aid in resolving the comments have been generated to help focus development of planning 

criteria, development of alternatives, and guide impact analysis.

Issues Identified Prior to and During Scoping

2.3 Issue 1- Paleontological and Cultural Resource Research and Protection

The Paleontological Resource section of the RMP will include a discussion of paleontological resources 

within the Monument. Resource protection and research will be an integral part of this section due to the 

Legislation stating that the BLM will provide for research and protection of paleontological resources. 

Cultural resource management also involves site protection, surveys for identification and evaluation, 

scientific research, interpretive development, and public education. A summary of the comments for 

paleontological and cultural resources follows.

• In favor of protecting the paleontological resources while allowing research to continue

• Emphasize protecting Monument objects as stated in the (paleontological, scientific, educational, 

scenic, and recreational resources) over other uses

• Preserve the ecology and natural resources to the extent that is compatible with scientific research 

activities
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• Preserve cultural resources

• Make fossilized areas of the Monument off-limits to vehicles

• Improve awareness of cultural resources

• Provide adequate enforcement

2.3.1 Issue Questions

The following questions need to be addressed in resolving the Paleontological and Cultural Resources 

issue:

 How will paleontological and cultural objects located within the Monument be protected?

 How will BLM address inadvertent paleontological discoveries within the Monument?

 How will user groups be educated through paleontological objects located within the Monument? 

 How will paleontological and cultural objects contained within the Monument be interpreted?

 Will the Plan encourage the preservation for in situ paleontological objects and sites?

 How can the public become more invested in the protection of these resources?

 What is a long-term strategy for the implementation of resource protection?

 How will paleontological resources be managed to allow for research and preservation to coexist?

 What is the strategy for the identification of paleontological resources in un-surveyed areas?

 Where and how should paleontological resources be curated?

 Where and how should paleontological resources be displayed to allow for viewing and education 

by the local public?

 How will Native American interests and knowledge be conserved, encouraged, fostered, 

respected, and applied to interpretation of sites?

 What type of law enforcement and monitoring is necessary to protect the Monument’s resources?

2.4 Issue 2- Interpretation and Education

As stated in the Legislation, “the Secretary shall provide for public interpretation of, and education and 

scientific research on, the paleontological resources of the Monument...” A majority of the comments 

supported interpretation of the trackways and other resources within the Monument. The ideas for 

interpretation and education varied from interpretive park rangers, signs, visitor center, brochures, and 

websites. A summary of the comments follows.
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• Include interpretive information to improve visitor experiences

• Have interpretive park rangers

• Display the paleontological resources in-situ

• Construct an on-site visitor center

• Do not construct an on-site visitor center

• Create an appealing and educational website

• Prepare publications on the resources

• Permanent housing for the Monument personnel and/or volunteers

2.4.1 Issue Questions

The following questions need to be addressed in resolving the Interpretation and Education issue:

 How should educational/interpretation opportunities be accomplished?

 Where should visitors increase their knowledge of the Monument’s resources?

 Is there an opportunity for local community members to assist with monitoring?

2.5 Issue 3- Travel and Access

Comments regarding travel and access were widely varied and covered many concerns. Travel and 

access comments varied from wanting improved access to keeping the Monument primitive. Others want 

the Monument to be closed to vehicular access. Comments associated with this issue are as follows.

• Put specific conditions on all forms of motorized use

• Consider and improve access from Interstate 10 and/or Rocky Acres Trail

• Build a parking lot

• Create a driving route with short hikes to the resources

• Keep the roads and trails primitive

• Build a fence to keep vehicular traffic out of the Monument

• Install signs to inform users to stay on existing, designated routes
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2.5.1 Issue Questions

The following questions need to be addressed in resolving the Travel and Access issue:

 What is the current demand for motorized and non-motorized access and what is it likely to be in 

the future?

 What is the best way to provide for that access? 

 Is there a need to provide vehicle access to exposed or excavated locations?

 Where should the main access points of the Monument be located?

 How will motorized vehicular use be managed within the Monument?

2.6 Issue 4-Habitat and Its Users

BLM guidance requires that desired outcomes for vegetative resources are identified in land use plans. 

This includes desired mix of vegetative types, structural stages, and landscape functions, and to provide 

for wildlife habitat and livestock forage. The Robledo Mountains contain habitat that is associated with a 

great number of mammals, birds, reptiles and several plants and other wildlife species. Currently and 

prior to the enactment of the Legislation, the Monument is grazed by livestock. The Legislation states

BLM “may allow grazing to continue in any area of the Monument in which grazing is allowed before the 

date of enactment of this Act, subject to applicable laws (including regulations).” There are no known 

special status species that are specific to the Monument although the habitat is present.

Only a few comments were made on vegetation, wildlife, and livestock grazing.

• Protect the cactus

• Protect the wildlife

• Consider mule deer for hunting in the Plan

• Cattle grazing should not be allowed or set more stringent limits in order to promote natural plant 

communities

• Allow cattle grazing in the Monument

• Remove cattle in the Monument

2.6.1 Issue Questions

The following questions need to be addressed in resolving the Habitat and Its Users issue: 

 Are special status species plants present, and if so, how should they be managed?

 What is current grazing use within the Monument boundary and can this use be continued without 

impacting Paleozoic resources?
14

 Will public use of the Monument impact livestock grazing?

 What are the economic impacts to the grazing permittee due to the Monument designation?

 How will habitat be managed for vegetation, wildlife and livestock?

 Are special status wildlife species and associated habitat present and if so, how should they be 

managed?

 How will management of domestic livestock be accomplished in consideration of wildlife needs?

 How can public safety be assured while providing the full spectrum of recreational opportunities?

2.7 Issue 5- Visual Resources

BLM guidance requires that visual resources are managed in accordance with visual resource 

management (VRM) objectives. Currently, the Monument is classified and managed as VRM Classes I, 

II, and III. A limited number of comments were received on visual resources and are as follows.

• Preserve visual resources

2.7.1 Issue Questions

The following list identifies issue statements for Visual Resources:

 How will the visual nature of the Monument be preserved while providing protection for the 

resources within the Monument?

 How will the visual nature of the Monument be preserved while providing areas for 

paleontological research and recreational use?

2.8 Issue 6- Socioeconomic 

Comments regarding the opportunities for economic benefit to the community via the Monument were 

noted by a number of citizens. A representative group of comments follows.

• There are opportunities for cultural heritage economic opportunities with the local community

• Consider local guides, horseback tours, safaris, etc.

• There is a socioeconomic benefit to Las Cruces from having visitor services located locally

• There are socioeconomic benefits to Las Cruces from having the existing OHV trails

• Include tourism in the Plan
15

2.8.1 Issue Questions

The following questions need to be addressed in resolving the Socioeconomic issue:

 What opportunities for economic growth are available for the communities that are associated 

with the Monument?

2.9 Issue 6- Recreation

The Robledo Mountains have historically been used for many recreational pursuits such as hiking, biking, 

OHV use, fossil hunting, target-practicing, hunting, and camping. The Legislation states that recreational 

resources and values within the Monument will be conserved, protected, and enhanced. It also states 

“The Secretary may issue permits for special recreation events involving motorized vehicles within the 

boundaries of the Monument- (A) to the extent the events do not harm paleontological resources; and (B) 

subject to any terms and conditions that the Secretary determines to be necessary.” A concern in years 

past with the issuance of a BLM special recreation permit for an annual OHV event called the Chile 

Challenge was about spectators in reference to their safety and the possibility of resource damages. With 

the designation of the Monument, along comes the quandary of entrance fees also.

A summary of the comments follows:

• Continue to allow recreational activities within the Monument

• Restrict target shooting within the Monument

• Cross-country dog, horse, and foot traffic should be allowed

• Dispersed camping should continue to be allowed

• Disperse the recreation instead of concentrating it

• Prevent any group event that risks damage to the resources

• Recreational use should be restricted to hiking only

• Maintain primitive atmosphere

• Move the Chile Challenge outside the Monument

• Continue the Chile Challenge as it has in the past

• Evaluate alternatives for this event, which would still allow the Chile Challenge and protect the 

Monument

• Restrict the Chile Challenge to participants only
16

• Observers of the OHV event should be restricted to an observation site

• Build a self-pay station at the parking lot

• No fees

2.9.1 Issue Questions

The following questions need to be addressed in resolving the Recreation issue:

 How can recreational demands be met while ensuring that irreplaceable paleontological and 

cultural resources are not damaged?

 What range of recreational opportunities should be provided to meet visitors’ needs?

 What facilities will be needed to support the full spectrum of recreational opportunities provided 

by Monument resources?

 Should the Monument be advertised for tourism and recreation?

 What level/amount of use is appropriate for each recreational use to allow for varied activities 

and to meet resource objectives?

 How should recreationists be educated to protection of the Monument’s resources?

 How should multiple recreational uses (for foot, horseback, motorized, mechanized) be managed?

 How can primitive recreational experiences be provided within Monument?

 How is firearm use, including hunting, to be managed?

 How will law enforcement on Monument land affect hunting?

 How will safety risks resulting from hunting be managed?

 How will transportation associated with hunting and game retrieval be addressed?

 What is the current demand for off-highway use (OHV)?

 What range of recreational opportunities should be provided to meet OHV user needs?

 What is the best way to accommodate this use and still be consistent with the Legislation?

 Should OHV use continue within the Monument boundary?

 What learning opportunities about the Monument’s natural resources will be available for OHV 

users?

 During special permitted events how will spectators be managed in order to protect the 

Monument’s resources?

 How should the Special Recreation Permit System be addressed and managed to meet the goals 

of the Monument?

 Should the BLM charge an entrance fee for the Monument? If yes, how, where, and how much?
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2.10 RMP/EIS Process

Several comments received were in the interest of how the BLM should manage the RMP/EIS process. A 

representation of the comments follows.

• Maximize public involvement in the RMP process

• Make analysis available to the public before issuing the Draft RMP

• Planning Area should be limited to the Decision Area

• Incorporate “Cumulative Loss of Motorized Recreation Opportunities”, this would include more 

than just BLM land

• Take a landscape view approach

• Planning process needs to approach it as if there are no monetary constraints for ideas

• Compromise, so all parties get something

2.11 Issues Raised That Will Not Be Addressed

As a result of scoping, the BLM has refined the preliminary planning issues and has determined which 

issues are to be carried forward and which issues will not be addressed in the RMP process.

Some comments received refer to implementation decisions made through administrative or resource 

program guidance and do not require land use planning decisions in order to be resolved. Other 

comments are beyond the scope of this planning effort and/or outside of the BLM’s decision making 

authority (Authority is with another agency or entity).

Comments urging the BLM to organize or support a volunteer and/or advisory group for the Monument 

were documented in the Scoping Report Summary Table, but will not be addressed in the RMP/EIS. 

Such actions can be resolved through administration or policy action. The BLM is committed to 

coordinating and collaborating with local groups, clubs, educational institutions, and agencies to promote 

the resources of the Monument.

A management concern for the BLM is the possibility of the Monument boundary changing due to new 

Legislation. This concern was mentioned in the Scoping Packet to bring to light this possibility. There 

were several comments regarding this issue stating that BLM should not consider upcoming Legislation

in the RMP. This issue will be documented in the RMP as an Issue Considered, but Not Further 

Analyzed.

Actions regarding the adjacent Community Pit #1 are beyond the scope of the RMP because the 

Community Pit #1 is outside the RMP Decision Area. Cumulative Impacts from the actions taken in 

Community Pit #1 will be addressed in the RMP/EIS.
18

The Legislation allows the Secretary of the Interior to make minor boundary adjustments to the 

Monument if additional paleontological resources are discovered on public land adjacent to the 

Monument. The Secretary of the Interior has the authority to make these adjustments, outside the 

RMP/EIS process. This issue is beyond the scope of this planning effort and will not be addressed in 

detail in the RMP.

As discussed earlier in this document, the development of the Monument Plan will occur in the following 

phases according to the BLM Land Use Planning Handbook, H-1601:

• Making pre-scoping preparations and organizing the staff

• Identifying issues and data gaps, conducting scoping, and completing a Scoping Report

• Formulating alternatives, doing impact analysis, and identifying mitigation measures, 

monitoring and evaluation requirements

• Preparing and releasing the Draft Monument Plan/EIS 

• Conducting public review and comment on Draft Monument Plan/EIS

• Analyzing public comment and preparing the Proposed Monument Plan and Final EIS

• Releasing the Proposed Monument Plan/Final EIS and initiating the protest period and 

Governor’s consistency review

• Responding to any protests

• Completing and releasing the approved Monument Plan/EIS/ROD

The public are encouraged to participate throughout the planning process and the BLM is mandated to

support and allow for public participation and review.
19

Draft Planning Criteria

The BLM’s land use planning guidance (Handbook H-1601-1) states that planning criteria are the 

constraints or ground rules that guide and direct the development of the plan. The draft planning criteria 

ensure that plans are tailored to the identified issues and ensure that unnecessary data collection and 

analyses are avoided. Draft planning criteria for the Monument RMP/EIS are as follows:

• The RMP will be in compliance with the Federal Land Policy and Management Act (FLPMA), 

NEPA, New Mexico Standards for Public Land Health and Guidelines for Livestock Grazing 

Management and all other applicable laws, regulations, and policies.

• The RMP will be in compliance with the Omnibus Public Land Management Act of 2009 

(Legislation). While the multiple-use mandates of FLPMA, NEPA, and all other applicable laws, 

regulations, and policies will be followed to the extent appropriate, the provisions of the 

Legislation will prevail in managing the Monument.

• The Monument Plan will be in compliance with the Potential Fossil Yield Classification (PFYC) 

Manual and Handbook.

• Land use decisions in the Monument Plan will apply to the surface and subsurface estate 

managed by the BLM.

• For program-specific guidance for decisions at the land use planning level, the process will 

follow the BLM’s policies in the Land Use Planning Handbook, H-1601.

• BLM staff will strive to make decisions in the plan compatible with the existing plans and 

policies of adjacent local, state, and Federal agencies and local American Indian tribes, as long as 

the decisions are consistent with the Legislation.

• The BLM and cooperating agencies will jointly develop alternatives for resolution of resource 

management issues and management concerns. 

• BLM staff will work cooperatively and collaboratively with cooperating agencies and all other 

interested groups, agencies, tribal entities, and individuals.

• The planning process will provide for ongoing consultation with American Indian tribal

governments and the public regarding strategies for protecting recognized traditional uses and 

heritage resources.

• Broad-based public participation and collaboration will be an integral part of the planning 

process.

• In the RMP, the BLM will recognize the state’s responsibility and authority to manage wildlife. 

The BLM will consult with the New Mexico Department of Game and Fish.

• The Monument Plan will recognize valid existing rights.
20

• The Monument Plan will incorporate, where applicable, management decisions brought forward 

from existing planning documents.

• The BLM will consider public welfare and safety when addressing hazardous materials and fire 

management.

• Wilderness Study Areas will continue to be managed under the BLM’s Interim Management 

Policy for Lands under Wilderness Review (IMP) until Congress either designates all or portions 

of the WSAs as wilderness or releases the land from further wilderness consideration.

• Where practicable and timely for the planning effort, the best available scientific information, 

GIS and metadata information will meet Federal Geographic Data Committee (FGDC) standards, 

as required by Executive Order 12906. All other applicable BLM data standards will also be 

followed. 

• Fire management strategies will be consistent with the Las Cruces District Fire Management Plan 

(2009) 

• Planning and management direction will focus on the relative values of resources and not the 

combination of uses that will give the greatest economic return or economic output.

• Actions must comply with all applicable laws and regulations and must be reasonable, 

achievable, and allow for flexibility while supporting adaptive management principles.

• The Economic Profile System (EPS) will be used as one source of demographic and economic 

data for the planning process. EPS data will provide baseline data and contribute to estimates of 

existing and projected social and economic conditions.

• The Monument Plan will identify specific goals, objectives, and actions for the use, conservation, 

protection, and possible restoration of the Monument’s resources.

• The Monument Plan will identify Best Management Practices and/or mitigation measures to be 

applied to existing uses and planned uses to ensure protection of the Monument’s objects, such as 

the paleontological, scientific, educational, scenic, and recreational resources and values of the 

Monument.

As stated in Instruction Memorandum No. 2009-215, “according to Section 302(a) of FLPMA, the 

National System of Public Lands is to be managed under the principles of multiple use and 

sustained yield “except that where a tract of such public land has been dedicated to specific uses 

according to any other provisions of law it shall be managed in accordance with such law.” This 

section of FLPMA directs that when an area of public land is set aside by a presidential 

proclamation issued under the Antiquities Act of 1906 or an Act of Congress, the designating 

language is the controlling law. Therefore, as a general rule, if the management direction of the 

proclamation or Act of Congress conflicts with FLPMA’s multiple-use mandate, the designating 

language supersedes that section of the FLPMA.”
21

Data Summary/Data Gaps

Geographical Information System (GIS) maps are the building blocks to quantify resources and display 

information during alternative formulation. Existing and available resource information will be used in 

formulating resource objectives and management alternatives. Additionally, the data will be used as the 

basis for analyzing unresolved conflicts. Most of this information needs to be compiled and put into 

digital format for use in the planning process and developing resource maps. This must be done before 

actual analysis can begin.

Data gaps were not specifically identified during scoping; however, data for GIS layers associated with 

the Las Cruces District Office are routinely updated and can be found in the Las Cruces GIS Corporate 

Data List.

Additional information on the geospatial database and development, GIS applications, and data standards 

is contained in the Prehistoric Trackways National Monument RMP Preparation Plan (January 2010), 

which is available upon request.

Summary of Future Steps in the Planning Process

A concurrent step in the planning process is to complete the “Analysis of the Management Situation” 

(AMS). The AMS analyzes available inventory data, portrays the existing management situation, and 

identifies management opportunities to respond to identified issues. As stated in 43 CFR 1610.4-4, this is 

the basis for formulating reasonable alternatives, including the types of resources for development or 

protection. This analysis will also result in identification of the “No Action Alternative” - the baseline 

(current) management condition, which includes management designated thru the Legislation.

Following development of the AMS and the Scoping Report, the next phase of the BLM’s planning 

process is to develop management alternatives based on the issues presented in the Issue Summary 

section of this report. These alternatives will address planning issues identified during both internal and 

external scoping and will be designed to meet the goals and objectives developed by the interdisciplinary 

team. In compliance with NEPA, CEQ regulations, and the BLM planning regulations and guidance, 

alternatives should be reasonable and capable of implementation. The BLM will also continue to meet 

with collaborating agencies, interested tribes, community groups and individuals during development of 

the alternatives.

A detailed analysis of the alternatives will be documented in a Draft RMP/EIS. Based on the analyses of 

the alternatives, the BLM’s Preferred Alternative will then be selected. The Preferred Alternative, a 

stand-alone Alternative, is often made up of a combination of management options from the various 

alternatives to provide the best management for the resources and Monument objects, which would also

implement the guidance from the Legislation. 
22

Although the BLM welcomes public input at any time during the planning process, the next official 

public comment period will begin when the Draft RMP/EIS is published, which is anticipated for Spring 

2011. The draft document will be widely distributed to elected officials, regulatory agencies, and 

members of the public, and will be available on the project website 

(http://www.blm.gov/nm/st/en/fo/Las_Cruces_District_Office/trackways_rmp.html).

The availability of the draft document will be announced via a Notice of Availability in the Federal 

Register

At the conclusion of the public comment period, the Draft RMP/EIS will be revised as necessary based on 

public comment. A Proposed RMP/Final EIS will then be published. The availability of the proposed 

document will be announced in the 

and local news media. A 90-day public comment period will follow. A public meeting will be 

held during this 90-day period. 

Federal Register, and a 30-day public protest period will follow. 

Concurrently, the Governor of New Mexico will review the document for consistency with approved state 

or local plans, policies, or programs. At the conclusion of the public protest period and Governor’s 

consistency review, the BLM will resolve all protests and any inconsistencies and revise the document as 

needed. The Record of Decision/RMP will be approved by the State Director and published. The 

availability of these documents will be announced in the Federal Register and local news media. Figure 2

outlines the major milestones of the Monument RMP/EIS planning process and public participation. All 

publications, including this report, newsletters, the Draft RMP/EIS, and the Notices of Availability, will 

be available on the official Prehistoric Trackways National Monument RMP web site 

(http://www.blm.gov/nm/st/en/fo/Las_Cruces_District_Office/trackways_rmp.html) as they are 

completed.

For Further Information

The public is invited and encouraged to participate throughout the planning process for the RMP. 

Some ways to participate include:

• Reviewing the progress of the RMP at the official Prehistoric Trackways National Monument

RMP/EIS web site at

http://www.blm.gov/nm/st/en/fo/Las_Cruces_District_Office/trackways_rmp.html

• The website will be updated with information, documents, and announcements throughout the 

duration of the RMP preparation; and

• Requesting to be added to or to remain on the official RMP project mailing list in order to 

receive future mailings and information.

Anyone wishing to be added to or deleted from the distribution list or requesting further information may 

e-mail their request to Lori_Allen@blm.gov or contact Lori Allen, RMP Planner at (575) 525-4454. 

Please provide your name and mailing address.
Figure 2 Sequence of Planning Activities for the Prehistoric Trackways National Monument RMP
APP-1

Appendix A: Notice of Intent
APP-2
APP-3

Appendix B: Scoping Letter and Packet
APP-4
APP-5
APP-6
APP-7
APP-8

Appendix C: Public Notice
APP-9

Appendix D: Public Meeting Flyer
APP-10

Appendix E: BLM News Release
APP-11
SAFETY ZONES FOR RECREATIONAL 

TARGET SHOOTING ANALYSIS

APPENDIX 

G

tHE 
G-1

APPENDIX G

SAFETY ZONES FOR 

RECREATIONAL TARGET SHOOTING ANALYSIS

Recreational target shooting contains many hazards based on predictable projectile physics and 

unpredictable human behavior. The following information depicts industry standards for predictable 

projectile physics, given a single point of weapon discharge. These standards are used during 

construction of safe shooting ranges. Surface Danger Zone (SDZ) is a depiction of the mathematically 

predicted area a bullet will return to earth by direct fire (Gun Target Line or GTL) or ricochet.

PROJECTED AMMUNITION CAPABILITIES

Standardized industry tables exist identifying a host of variations in Distance X, Distance Y, and Distance 

W for different calibers, types of bullets, and powder charges resulting in a wide range of variability in 

SDZs. Distance X provides for the maximum distance along GTL that a projectile will travel. Distance 

Y provides the depth of ricochet area along the GTL and likewise is not a significant concern because 

most likely the target location is against a hillside. Distance W defines the ricochet area width where 

uncontrolled projectiles can place the public in harm. However, Distance W is the dominant factor when 

considering target shooting on public land near developed recreations sites or areas where the public 

congregate for extended periods of time. Distance W varies from 1/16-mile for the .45 caliber to 1⁄2-mile 

for the 7.62 or .30 caliber, which is North America’s most common rifle caliber.

Table G-1 identifies distances, in meters, used to construct a typical SDZ for commonly used calibers and 

factory ammunition.

TABLE G-1

SDZ ELEMENT DISTANCES, IN METERS

Caliber Distance X Distance Y Distance W Distance W + Area A

.22 long rifle 1400 1125 386 404

9 mm 1800 1211 399 579

.38 1806 1258 389 569

.45 1690 1111 290 470

5.56 (or .223) 3437 2029 462 642

7.62 (or .30) 4100 4053 861 1041

RICOCHET AREA

The types of ammunition, targets, and firing activities dictate SDZ dimensions. A basic SDZ consists of 

three parts: impact area (dispersion area), ricochet area (Area W), and secondary danger area (Area A 

and Area B) (see Figure 1). The primary dispersion area established for the impact of all rounds extends 

five degrees to the left and right limits of weapon discharge and downrange to the maximum range of the 

ammunition (Gun Target Line or GTL) used. The ricochet area lies to both sides of the dispersion area 

and extends downrange to the maximum distance of the ammunition used. The ricochet area contains two 

angles determined specifically by the type and caliber of ammunition being fired. This analysis assumes 

the following: a single firing point, compliance with shooting safety protocol, using a hillside for a target 

backdrop, predictable human behavior, and no steel targets. Any of these assumptions, when violated, 

could greatly increase distance and negate the previously described SDZ. Distance W plus Area A 

identifies a secondary danger area with decreasing probability of receiving a projectile or debris. This 

secondary danger area is that area paralleling and 90 meters outside of the outermost limits of the ricochet 

area and extending downrange to the maximum distance of any ammunition used.
G-2

FIGURE 1. BATWING SURFACE DANGER ZONE (SDZ) FOR FIRING SMALL ARMS DIRECT-FIRE 

WEAPONS.

Distance X: maximum distance along GTL that a projectile will travel.

Distance Y: maximum distance downrange of which a lateral ricochet is expected to occur when a 

projectile is fired given elevation.

Angle P: beginning angle for the ricochet area measured from the firing point downrange along the edge 

of the dispersion area.

Angle Q: angle measurement downrange, beginning at distance Y along the edge of the dispersion area.

Distance W: distance between the outside edge or border of the ricochet area and the outside edge or 

border of the dispersion area on the SDZ.

Area A: identifies a secondary danger area with decreasing probability of receiving a projectile or debris
G-3

CONCLUSION

The development of SDZs is used primarily for the construction and management of outdoor 

shooting ranges, but the BLM used this data to determine a safety zone around areas where the 

public congregates. In regards to the most common North American rifle caliber, the maximum 

Distance X for a .30 caliber is approximately 21⁄4-mile although typical target shooting occurs at 

distances of 25 to 100 yards. Typically, shooters use hills for backstops and identify their targets 

so the Distance X is not the main concern regarding target shooting on public land around 

developed recreation sites or areas where the public congregate. However, this technical data is 

used to synthesize a practical definition of a rectangle entailing a 21⁄4-mile by 1⁄2-mile SDZ for the 

most commonly owned rifle caliber. Again, the greatest concern for an area used for target 

shooting would be the 1⁄2-mile lateral deflection or ricochet area.

REFERENCES:

1) Department of Army Pamphlet 385-63. Range Safety. 30 January 2012.

2) Range Design Criteria. US Department of Energy-Office of Health, Safety and Security. 18 

November 2008.

3) USMC Range Safety Pocket Guide-Version 1.0. Full version of MCO 3570.1B and DA PAM 

385-63.
Public Comments on the Draft RMP/EIS

and Responses

APPENDIX 

H

tHE 
H-1

APPENDIX H

PUBLIC COMMENTS ON DRAFT RMP/EIS

AND RESPONSES

The Draft RMP/EIS was released for a 90-day public review and comment period on July 20, 2012. 

During this period, the Las Cruces District received 45 comment letters, forms, or emails. Each 

submission was carefully reviewed to identify substantive comments.

In accordance with regulations on the implementation of the National Environmental Policy Act (40 CFR 

1503.4), all substantive comments must be addressed in the Proposed RMP/Final EIS. Substantive 

comments are generally those that:

 Question, with reasonable basis, the accuracy of the information in the Draft EIS.

 Question, with reasonable basis, the adequacy of, methodology for, or assumptions used for the 

environmental analysis.

 Present new information relevant to the analysis.

 Present reasonable alternatives other than those analyzed in the Draft EIS.

 Cause changes or revisions in one or more of the alternatives.

These criteria were used as a guide for the evaluation of comments submitted by the public. The Las 

Cruces District Office made every effort in its comment analysis to be inclusive of comments. It should 

be noted that comments are not treated or tallied as “votes.” Rather the substances of the comments help

the BLM to understand and weigh the multiple factors considered as part of its decision making process.

Table H-1 identifies comment letter/emails received during the public review period. Comment letters 

are printed in their entirety. Some personal addresses have been redacted under Exemption 6* of the 

Freedom of Information Act. Responses are presented adjacent to the comments in each letter.

*Exemption 6 protects information about individuals when the disclosure of such information “would constitute a 

clearly unwarranted invasion of personal privacy”.
H-2

TABLE H-1

PTNM DRAFT RMP/EIS COMMENTS RECEIVED

ASSIGNED 

NUMBER IN ORDER 

OF RECEIPT

NAME OF COMMENTOR TYPE

RESPONSE 

REQUIRED

1 Dara Parker, Field Representative

Senator Jeff Bingaman’s Office

Email No

2 Mark T Altaha

White Mountain Apache Tribe

Email & letter No

3 Greg Buntain Email No

4 Clint Cates Email No

5 Greg McNeil Email No

6 Resa Johnson Email No

7 Jim Kinnerup Email Yes

8 John Rice Email Yes

9 Environmental Protection Agency Letter Yes

10 David Smith Email Yes

11 Joshua Simmons

WSTF

Email Yes

12 Chery Eckhardt 

National Park Service

Email No

13 Lance Harkey Email Yes

14 William Massie Email No

15 New Mexico Off Highway Vehicle Alliance Letter Yes

16 Western Watersheds Project Letter Yes

17 Mark & Joan Wolf Letter Yes

18 Dirk Keeper Email No

19 Angelia Steelman Email No

20 Linus Brewer Email No

21 Curtis Hill Email No

22 Tracy Hooker Email No 

23 Bob Reich Letter Yes

24 Jim Huff

Hytech 4x4

Letter No

25 James Huff Letter No

26 Marlene Mayfield Letter Yes

27 Billy Steelman Email No

28 Larry Candelaria President

Paleozoic Trackways Foundation

Letter Yes

29 Connie & Larry Candelaria Letter No 

30 The Wilderness Society Letter Yes

31 NM Department of Game and Fish Letter No

32 M Florence Dougherty Letter No

33 Jim Enright Letter Yes

34 Robert Mathis Letter Yes

35 Joan Smith Letter Yes 

36 Jeffrey Smith Letter No

37 James Berryman Letter No

38 Beba Richardson Letter No

39 Les Owen

NM Department of Agriculture

Letter No

40 Alexandra Nason Hall Letter No

41 David Nivek Comment Form No

42 Allison Smith Comment Form No

43 Gregory Smith Comment Form No

44 Carole Grady Comment Form No

45 Shooting Roundtable Letter Yes
H-3

1
H-4

2 2
H-5

3 4
H-6

5 6
H-7

7

7-1 Thank you for your comment. Your comment will be taken into consideration 

when we are making our decisions for management of the Monument. 7-1
H-8

8-1

8-1 Rocotillo has access from the east. Rocotillo and Patzcuaro fork off of 

Permian Tracks Way.

8
H-9

9 9
H-10

9
H-11

9-1

9-1 The specific measures recommended by the EPA have been added to Best 

Management Practices in Appendix E, and a more detailed discussion 

appears in Chapter 3.

9
H-12

9-2 Information on habitat suitability is stated in Section 3.2.15, and BLM’s

process for survey and clearance was added to Chapter 2, Special Status 

Species Management Common to All Alternatives.

9

9-1

9-2
H-13

10-1

10-1 The location of the sensitive fossil areas was not published in the Draft 

RMP/EIS because this information is considered proprietary. Information on 

monitoring and damage to fossils has been updated in Chapter 4, 

Alternative A Impacts to Paleontological Resources. Also, Impacts of Trails 

and Travel alternatives on Trails and Travel have been added to Chapter 4 to 

further clarify the slight differences between trail closures in Alternatives C 

and D. In Appendix C, you noted a mistake in Table C-2. Motorized and 

mechanized use of Patzcuaro’s Revenge has been removed for the Proposed 

RMP/Final EIS. Thank you for your comment.

10
H-14

10
H-15

11

11-1

11-2

11-3

11-4

11-5

11-6

11-1 During the EIS analysis, we aggregated a variety of monitoring data that 

specifically demonstrate that OHV use damages fossil resources. Chapter 4, 

Alternative A Impacts to Paleontology, has been re-written to better describe 

the problems associated with simultaneously protecting significant fossil 

outcrops and managing off-highway vehicles.

11-2 The environment is too dynamic. During monsoon flood events, boulders and 

erosion will continually alter any kind of barrier system.

11-3 The BLM previously explored by-pass alternatives but the impacts would have 

been damaging to watershed and fossil resources, and mitigation techniques 

would have been prohibitively expensive.

11-4 This was analyzed in Chapter 4, Impacts to Paleontological Resources from 

Recreation and Visitor Services alternatives.

11-5 The scientific approach will employ a systematic removal of overburden when 

necessary. This process preserves the paleontological resources. Research 

designs will be prepared by qualified institutions and will be assessed for 

compatibility with fossil conservation. Any additional ground disturbing 

activity will have to go through NEPA analysis.

11-6 Please see the response to 11-4.
H-16

12
H-17

13

13-1

13-2

13-3

13-1 Please see response to Comment Letter 10.

13-2 Please see Comment Letter 11, response 11-3

13-3 The BLM analyzed the economics of OHV use in Chapters 3 and 4.
H-18

14
H-19

15
H-20

15

15-1

15-1 While the CEQ regulations do not refer to viability as a characteristic of 

alternatives, the word was used in this context to underscore and emphasize the 

need for alternatives that are practical or feasible from the technical and 

economic standpoint (and this is further described as an aspect of reasonableness 

in the CEQ 40 Most Asked Questions, #2a). The context of the bulleted list of 

Alternative characteristics is introductory in nature and meant to set the stage for 

the reader. The difference between “viable” and “reasonable” are slight in this 

context and narrowed the BLM’s alternative only to exclude activities the BLM 

could not implement. The word viable has been removed.
H-21

15

15-1

15-2

15-2 Regarding the use of Patzcuaro’s Revenge and Tobasco Twister, recent 

monitoring results of the important Permian fossil resources demonstrate the 

degradation and loss of various ichnofossils. The Proposed RMP/Final EIS

demonstrates this in a revised Chapter 4 analysis of the impacts of Travel and 

Transportation alternatives on fossil resources. Analysis of the information 

during the RMP process shows that current levels of OHV use do not meet the 

Monument objectives, or the goals and objectives as described in the Proposed 

Final RMP/EIS.

The enabling legislation specifically directs the BLM to develop a new Resource 

Management Plan for the PTNM.
H-22

15

15-3

15-3 The 1997 Environmental Assessment (EA) does not identify the Paleozoic 

fossils as a resource in the Affected Environment, but the Environmental 

Consequences section states that paleontological resources would not be 

adversely impacted. Since the signing of the 1997 EA, several factors have 

improved the BLM‘s ability to assess, monitor, and conserve the important 

Paleozoic fossils of the Robledo Mountains: 

1. The Paleontological Resources Preservation Act (PRPA) was passed by the 

US Congress and signed into law in 2009, requiring the Secretary of the 

Interior to manage and protect paleontological resources on Federal land 

using scientific principles and expertise.

2. Concurrent with the passage of the PRPA, the Prehistoric Trackways 

National Monument (PTNM) was also signed into law. The PTNM was 

established to primarily conserve important fossil resources, which are 

further defined by the BLM as Monument Objects. Please see Chapter 1, 

Section 1.9 for a definition of the Monument Objects.

3. The Las Cruces District Office implemented a fossil monitoring program in 

2008 and results from the program are incorporated into the Proposed 

RMP/Final EIS.

4. Establishment of the area as a Research Natural Area does not have the 

same requirements as a Monument.

In Chapter 4 of the Proposed RMP/Final EIS, the BLM has inserted the results 

of monitoring data and descriptions of the on-going damage OHVs cause to the 

significant fossils of the Abo Formation.
H-23

15

15-3
H-24

15

15-4

15-5

15-4 The PTNM designating language directs the Secretary to manage the Monument 

“in a manner that conserves, protects and enhances the resources values of the 

Monument and in accordance with the provisions in the Act and FLPMA. 

FLPMA 302(a) requires that public land “shall be managed under principles of 

multiple use and sustained yield...except that where a tract of land has been 

dedicated to specific uses according to any other provisions of law it shall be 

managed in accordance with such law.” The PTNM legislation directs the BLM 

to conserve, protect, and enhance the important paleontological resources, as 

well as recreational resources. The priority for the Monument is 

paleontological. The Proposed RMP Final EIS analyzes impacts from a range 

of recreational activities and describes the consequences of continued and 

regular OHV use on the important paleontological values (Chapter 4).

15-5 The estimates for annual visitation were inaccurate and have been revised with 

actual use figures derived from vehicle counters and other visitation 

documentation. Additionally, the number of visitors is not determinative of the 

uses that should occur in the area in the future. Recreation is a Monument 

Object only to the extent that it is recreation that supports paleontological 

resources; this type of OHV use is not such an Object.
H-25

15
H-26

16

16-1

16-1 The RMP/EIS process began in 2009 and the most recent BLM guidance on 

National Monuments was published in 2012 (BLM Manual 6220). The Final 

RMP/EIS has been revised and updated to reflect the most recent guidance 

throughout. Specific examples are found in our approach to defining Monument 

Objects and establishing Monument Goals. 
H-27

16

16-3

16-2

16-1

16-4

16-2 Section 2104 (h) of the Monument Legislation reads “GRAZING.—The 

Secretary may allow grazing to continue in any area of the Monument in which 

grazing is allowed before the date of enactment of this Act, subject to applicable 

laws (including regulations).” Under the Preferred Alternative, Alternative C, 

grazing would be allowed to continue. If it is determined that livestock are 

impacting the fossil resources, those areas would be fenced off from livestock to 

remove the direct impact. See Section 4.4.1.3.

16-3 Grazing has been removed from the list of protected resources. Livestock are 

not an Object but see Comment 16-2. Also, we have added discussions on the 

susceptibility levels of the fossils to livestock hoof action in Chapter 4,

Paleontological Resources.

16-4 An Allotment Health Assessment was performed in 2012 and those data have 

been added to the description of Vegetation in Chapter 3 and the analysis of 

Impacts to Vegetation from Livestock Grazing in Chapter 4. The additional 

information provides a more complete picture of the environment and 

demonstrates that continued grazing is compatible with the Monuments Goals 

and Objectives.
H-28

16

16-5

16-6

16-7

16-8

16-5 The majority of the land base for both Picacho Peak and Altamira Allotments 

lies outside the Trackways boundary. Closure of either grazing allotment within 

PTNM would be based on livestock grazing decisions in the Mimbres RMP

(which is currently under revision so any proposed changes to the allotment 

would be considered in the TriCounty RMP process). Based on data in the 

recent Allotment Health Assessment presented in Chapter 3 of the PTNM 

Proposed RMP, current management does not warrant changes to the grazing 

permit.

16-6 While important resources, plants and animals are not Monument Objects. It is 

reasonable to assume that livestock grazing surrounding the Monument would 

continue but the impact of this would not have an effect on Monument Objects. 

To emphasize this point, the US Fish and Wildlife Service has concurred with 

the BLM’s determination in the TriCounty Draft RMP/EIS that livestock grazing 

in Alternative C (the Preferred Alternative) would have no effect on Special 

Status Species.

16-7 The BLM may maintain waters without active livestock grazing in an allotment 

through use of range improvements or the addition of water collection systems 

known as “guzzlers.” We have added this concept in Chapter 2 to Alternative B, 

Livestock Grazing, and Alternatives B and C, Wildlife.

16-8 Chapter 2 Wildlife now includes the specific recommendation of installing water 

developments as needed for wildlife if livestock are excluded from the 

Monument. Similarly, in Livestock Alternative B, the BLM would maintain 

livestock waters for wildlife. The Chapter 3 Wildlife section has been updated 

to describe the benefits of artificial waters in the Las Cruces District.
H-29

16-8

16-9

16-10

16-11

16-12

16-13

16-9 The costs of administering the grazing program have been updated in Chapters 3 

and 4 in the Socio-Economics sections.

16-10 The livestock section has been re-written to describe the complexity of 

analyzing the Monument as a subset of two larger grazing allotments. The 

current stock rate of 272 was used in the socio-economics analysis to portray 

actual billing. Also, as described in WWP Point 5 BLM Response, the grazing 

authorization spans beyond the planning unit. The appropriate planning unit 

for changes to the allotment permit would be in the TriCounty RMP process.

16-11 The Chapter 4 analyses on impacts to wildlife have been updated to more fully 

consider impacts. 

16-12 The Alternative B livestock decision in Chapter 2 has been revised to show that 

visual impacts would be mitigated by the use of solid green posts. The Chapter 

4 impacts of livestock grazing (a fence) on VRM has been revised to show that 

the mitigation and a new line would be noticeable to anyone near the perimeter 

of PTNM the sunlight is correct and that the wire may be visible until it 

tarnishes. The VRM inventory considers the impacts of the current fence.

16-13 This section has been rewritten to highlight the importance of controlling 

livestock with or without a fence. However, the perimeter fence is a reasonable 

alternative and a practical solution to exclude livestock because both allotments 

also exist outside the boundary of the PTNM. Any allotment closures or 

reductions would be considered in the TriCounty RMP process as described in 

BLM Response 16-5.

16
H-30

16-14

16-15

16-13

16-16

16-17

16-14 In Chapter 2, a monitoring process is proposed that will assist the BLM in both 

inventory and management. 

16-15 Chapter 3 descriptions of monitoring data have been updated in the Vegetation 

Section to reflect the recent 2012 Allotment Health Assessment.

16-16 The BLM does not analyze in detail the impacts of GHG from livestock on the 

Monument for the following reasons; (1) while it is possible to estimate the 

amount of methane and CO2 produced from the livestock in the Monument, it 

is difficult to quantify the degree of air quality impact (negative or positive) 

from those livestock in conjunction with other nearby livestock (cows, horses, 

sheep, etc.) on public and private lands, large ruminants, and dairy farms in the 

area for each alternative, and (2) while livestock would be removed in 

Alternative B, many of the cattle could be moved to other locations 

surrounding the Monument. A detailed analysis would be needed to determine 

any adjustments to the stocking rate, and thus any change to GHG emissions 

from cattle under Alternative B. Additional information regarding livestock 

induced dust emissions has been added (4-42). The soils in the Monument do 

not have any well-formed, complex, or unique biological soil crusts. However, 

additional information regarding the type of soil crust that is present has been 

added (page 3-30). 

16-17 Please see BLM Response to Comment 16-16.

16
H-31

16-18

16-17

16-19

16-20

16

16-18 The land within the Monument boundary has shown little evidence of past 

cultures and artifacts (see Chapter 3- Cultural Resources section), and cultural 

resources are not a legislated Monument Object. Impacts to cultural resources 

caused by on-going grazing in the Picacho Peak and Altamira Allotments have 

not been documented. As described in Section 4.4.6 of the FEIS, BLM will 

comply with Section 106 of the NHPA as projects with the potential to 

adversely affect significant cultural resources are proposed. Although impacts 

from grazing are expected to be minimal, based on the location of the 

paleontological resources (see Section 4.4.1.1), the Monument Monitoring Plan 

will assist the BLM in determining whether livestock are impacting the fossil 

resources. If such impacts exist, those areas would be fenced off from 

livestock to remove the direct impact (Section 4.4.1.3). 

16-19 Impacts of Livestock Grazing on Vegetation have been re-written in Chapter 4 

to include a more detailed assessment. This section now uses new data 

presented in the Chapter 3 Vegetation section, such as State and Transition 

models that consider historic climax vegetation.

16-20 The pro rata reduction on grazing has been re-written in Chapter 3, 

Vegetation and Livestock Grazing, to more clearly characterize the BLM 

forage availability assessment process.
H-32

16-21

16-22

16-23

16

16-21 Impacts of livestock removal in the PTNM have been further evaluated in

Section 4.4.18.2.

16-22 More detailed information describing the characteristics of the soil

 classifications found within the Monument have been updated in Section 

3.2.13. Additional impacts from livestock grazing on soils have been 

addressed in Section 4.4.11.1 and 4.4.11.2. Although it is stated that the 

continuation of grazing within the Monument will increase the likelihood of 

soil movement, soil loss and degradation, and decreases in soil moisture, based 

on the high surface rock content of the Monument, overall erosion is expected 

to be slight.

16-23 There are no riparian areas in the PTNM. Chapter 3 has been re-written to 

make this clearer. The salt cedar is not associated with a riparian area, as 

described in Chapter 3-Vegetation. Also, the BLM does not favor the use of 

non-native species but provides the language that non-natives may be used in 

the unlikely event that if native species are not effective, other species may be 

considered.
H-33

16-24

16-25

16-23

16-24 Watershed conditions and potential impacts have been updated in Chapter 3 

sections on Vegetation, and Soils, and in Chapter 4, Impacts to Vegetation and 

Impacts to Soils. Specific mitigation has not been proposed because there is no

finding that watersheds are impacted by grazing or a finding that water quality 

is polluted. 

16-25 The Chapter 4 analysis of Impacts to Paleontological Resources has been 

updated to show that in rare cases, hoof action could cause chipping or abrasion 

of fossils. Because there are not expected to be major impacts from grazing on 

the paleontological resources, based on the location of the grazing and the 

paleontological resources, BLM made the decision in the preferred alternative 

to allow grazing on the Monument. Although the analysis finds impacts to be 

unlikely, if such impacts are discovered, BLM will take measures to fence 

areas to prevent future impacts.

16
H-34

16-26

16-23

16-27

16-23

16-28

16-23

16-29

16-23

16

16-26 Section 4.4.13 discusses impacts to Special Status Species, which have been 

rewritten and more specific analyses added. As described in Section 3.2.15 and 

Appendix B, BLM has acted in accordance with procedures set forth in BLM 

Manual 6840: Special Status Species Management. Also, see BLM Response 

to Comment 16-8.

16-27 A more thorough assessment of Livestock Grazing impacts on Recreation and 

Visitor Services has been added to Chapter 4.

16-28 This viewpoint has been added to the social values discussion of grazing in 

Chapter 4.

16-29 Current fencing is considered in the existing VRM. The impacts of fencing are 

fully disclosed in Chapter 4, Impacts of Livestock Grazing on Visual 

Resources.
H-35

16 16
H-36

17
H-37

17

17-1

16-23

17-1 These estimates are based on surveys of visitors to National Forest Service land. 

This is the best available scientific information (White and Stynes 2010b, pg. 5).
H-38

17-2

16-23

17-1

16-23

17

17-2 Visitation data have been updated in Chapter 3- Recreation and Visitor Services. 

The Impacts to Socio-Economics have been re-analyzed in Chapters 4.
H-39

18 19
H-40

20 21
H-41

22
H-42

23
H-43

23

23-1

16-23

23-1 See response to Letter 11, Comment 11-2.
H-44

24 25
H-45

26

26-1

16-23

26-2

26-1

16-23

26-3

16-23

26-1 The BLM has proposed road closures only in areas where OHV use is known to 

degrade the fossil resources. If degradation to fossils on other routes is known, 

this information should be provided to the BLM.

26-2 A closure to recreational target shooting is analyzed in Alternatives C and D 

because it has been identified as a safety issue for visitors. Hunting has not been 

identified as a safety issue.

26-3 The Community Pit #1 is outside the boundary of the Planning Area and cannot 

be added through the RMP process.
H-46

27
H-47

28
H-48

28

28-1

16-23

28-2

16-23

28-3

16-23

28-1 Please see the response to Letter 26, response 26-2.

28-2 Please see the response to Letter 26, response 26-1.

28-3 Please see the response to Letter 26, response 26-3.
H-49

28
H-50

29 29
H-51

29
H-52

30 30
H-53

30

30-1 The RMP/EIS process began in 2009 and the most recent BLM guidance was 

published in 2012. The Proposed RMP/Final EIS has been revised and updated 

to reflect the most recent guidance. Monument Objects have been more clearly 

articulated in Chapter 1 and emphasized in the goals and objectives in Chapter 2. 

Chapter 4 of the Proposed RMP/Final EIS discusses the impacts of how Objects 

would be impacted by management actions. Under each of the alternatives, 

protection of the Monument Objects is prioritized over other management 

decisions.

30-1

16-23
H-54

30

30-2

16-23

30-2 A narrative of the Monument and important facets of its establishment are 

documented in a booklet by Spencer G. Lucas, Traces of a Permian Seacoast, 

found on the BLM Las Cruces website. The Paleozoic Trackways 

Foundation also maintains a website that contains background on the 

establishment of the Monument.
H-55

30

30-3 In Chapter 3 Recreation and Visitor Services, the BLM explains that the Las 

Cruces Museum of Nature and Science, in the nearby community, would be the 

in-town visitor center for PTNM. Chapter 4 discusses the benefits and costs of a 

visitor contact station, such as an on-site presence deterring vandalism and litter, 

and providing amenities such as toilets for sanitation reasons, as well as 

information and permits.

30-3

16-23
H-56

30

30-4

16-23

30-4 The Science and Research sections of Chapter 2 have been combined with 

Paleontological Resources to strengthen the interdependency of these two 

objects. Additionally, a science plan is under development but has not been 

completed for the Proposed RMP/Final EIS.

30-5 Although hiking trails and trail signs may be considered substantially 

unnoticeable in most situations, and therefore compatible with managing for 

wilderness characteristics, a trail developed with interpretive signs or kiosks is 

not considered compatible with managing for wilderness characteristics. These 

types of facilities are substantially noticeable and are unrelated to the 

preservation or enhancement of wilderness characteristics. Construction of 

interpretive facilities are generally understood as incompatible within a setting 

managed to protect wilderness values. The BLM has provided a range of 

alternatives for managing the wilderness characteristics identified in the 

Planning Area, and Alternative B would provide protection for some of the 

lands with wilderness characteristics while also forgoing protection of 

wilderness characteristics so that interpretive facilities may be installed.

30-5

16-23
H-57

30

30-5

16-23
H-58

30

30-6

16-23

30-7

16-23

30-6 The minimum route network is not a BLM objective and is not recommended in 

Manuals 6100 or 6220.

30-7 Monument Objects have been re-stated in Chapters 1 and 2. The Proposed 

RMP/Final EIS redefines Monument Objects; the Recreation Object is defined 

as Recreational opportunities that do not damage fossil resources.

The route designations were designed to protect the Monument Objects. Fossil 

localities are proprietary so were not published in the Draft RMP/EIS. If the 

preferred alternative is selected, Monument Objects of significant fossil 

resources would be protected from impacts from OHVs through route closures.
H-59

30
H-60

30

30-8

16-23

30-8 The analysis of impacts to Monument Objects from issuing SRPs for OHV use 

have been strengthened in Chapter 4. SRPs that harm Monument resources and 

values will not be permitted under the prescriptions of the Proposed RMP/Final 

EIS.
H-61

30 30
H-62

30 30
H-63

30 30
H-64

30 30
H-65

30 30
H-66

30 30
H-67

30 30
H-68

30 30
H-69

30 30
H-70

31 32
H-71

33

33-1

16-23

33-1 The establishment of a fee site is authorized under the Federal Lands Recreation 

Enhancement Act (REA), which has explicit requirements for a site to provide, 

prior to establishment of fee collection. For a Standard Amenity Recreation Site to 

be established, items such as designated developed parking, permanent toilet 

facilities, permanent trash receptacles, interpretive signage, picnic tables, and 

security services must be in place. While a few of these items are in place now, 

approval for establishment of a fee site would not be considered unless all were in 

place. Fees could then be considered, as a means to supplement the cost of 

management of those facilities/services. Any fee proposal would follow specific 

steps that include development of a business plan, public involvement, 

Washington Office approval, and Resource Advisory Council 

consideration/recommendation. At this point, fee collection consideration would 

be premature.
H-72

33

33-2

16-23

33-3

16-23

33-2 Since the publication of the Draft RMP/EIS, the BLM has obtained an access 

easement to the Monument.

33-3 These editorial changes have been made. Thank you.
H-73

34 34
H-74

34 34
H-75

34 34
H-76

34 34
H-77

34 34
H-78

34 34
H-79

34
H-80

35
H-81

35

35-1

35-1 In NEPA documents, the use of the word “will” is considered pre-decisional. 

The Draft RMP/EIS is an analysis document and the final decisions will be made 

in the Record of Decision.
H-82

35
H-83

36
H-84

37 37
H-85

38
H-86

39 39
H-87

39
H-88

40 40
H-89

41 42
H-90

43 44
H-91

45
H

-92

45

45-1

45-1 Alternatives were developed for target shooting based on a safety analysis. The 

results of the analysis, described in detail in Appendix G and Map 4-1, illustrate 

that public safety is at risk from target shooting throughout the Monument, with 

the exception of one small inaccessible location at the southern edge.

45-2 The PTNM was designated primarily to protect significant paleontological 

resources while continuing to support recreation that also supports or does not 

damage paleontological resources. Motorized trail systems, as well as non-

motorized trail systems, provide access for continuing education, interpretation, 

and research associated with the fossil resources. The PTNM designation does 

not direct the BLM to provide opportunities for target shooting.

45-3 The conclusions of the shooting analysis are unique to the unusual terrain 

associated with the PTNM. The Draft RMP clearly describes the dissected nature 

of the canyons and ridges and the safety risks associated with that particular 

landscape. The safety analysis was performed after several “near misses” where 

target shooting has taken place concurrent with school field trips. The safety 

analysis confirmed what the BLM has experienced in the field- that the terrain 

conditions in the PTNM are unsuitable for safely furthering the legislative goals

of research, education and interpretation.

45-4 The BLM would like to emphasize that within the 5.5 million acres the Las 

Cruces District manages, the Prehistoric Trackways constitutes just 0.1 percent of 

the whole. In this southwestern landscape, the 5,000 acres of the PTNM is 

dwarfed by the remaining lands available. The PTNM has offered a 

convenient, accessible spot for local target shooters. The Proposed RMP/EIS

discusses the availability of other similar sites within a 10-mile radius of the 

Monument, in Chapter 4, impacts of Recreation and Visitor Services on 

Recreation and Visitor Services Alternative C.

The BLM must manage the PTNM in a manner that “conserves, protects, and 

enhances” fossil resources and other uses that also conserve, protect, and enhance 

fossil resources. Providing backstops and target holders for target shooting 

would not achieve this management objective (See Final RMP/EIS, Chapter 2, 

Paleontological Resources Goals and Objectives).

The BLM has initiated dialogue with local shooting clubs and the New Mexico 

Department of Game and Fish to explore lore the possibility of providing 

recreational target shooting sites outside the boundary of PTNM, but in the 

vicinity.

45-2

16-23

45-3

45-4
H-93

45

45-5

45-6

45-7

45-5 Chapter 4, Impacts to Recreation and Visitor Services from Travel and

Transportation Alternative A, has been updated to reflect the availability of 

off-highway vehicle routes and challenging terrain outside of the PTNM

boundary.

45-6 The Proposed RMP/EIS includes a stronger discussion of target shooting in 

Chapter 4, Recreation and Visitor Services Impacts to the Alternatives. Since 

the publication of the Draft RMP/EIS, BLM has conducted further outreach to 

shooting sports organizations relating to the proposed closure to target 

shooting. This outreach is described in Section 5.4

45-7 The Draft RMP/EIS describes other target shooting opportunities in 

Section 4.4.3.3.
H-94

45

45-8 45-8 Please see response to Comment 45-2.
INDEX

tHE 
IN-1

INDEX

A D

Air Quality 2-21, 2-37, 2-50, 3-10, 4-11, 4-35,

4-77, 4-81, 4-84, 4-90

Allotment 2-3, 2-22, 2-30, 2-31, 2-52, 3-15, 3-

17, 3-28, 3-33, 4-48, 4-60, 4-67, 4-85, 4-92

Allotment Management Plan (AMP) 2-3, 2-30,

3-15, 3-17, 4-50

American Indian 2-47, 2-51, 3-11, 4-3, 4-54,

5-2

Alternatives 1-1, 1-4, 1-13, 1-14, 1-15, 2-1, 2-2,

2-4, 2-6, 2-23, 2-30, 2-32, 2-33, 2-35, 2-37, 2-

39, 2-44, 2-45-47, 2-50, 2-52, 3-1, 3-29

Area of critical environmental concern (ACEC) 

1-2, 1-4, 1-11, 1-16, 2-5, 2-35,2-53, 3-8, 3-14, 3-

30, 3-32, 3-41, 3-46, 4-2, 4-5, 4-31, 4-43-46, 4-

48, 4-63, 4-67, 4-78

Avoidance area 3-14

B

Best management practices (BMPs) 1-10, 4-2,

4-3, 4-35, 4-58, 4-86, 4-95

BLM Sensitive Species 2-35, 2-37, 2-38

C

Casual Collecting 2-2, 2-3, 2-6, 2-13, 2-48, 2-

49, 2-53, 4-5, 4-6, 4-12, 4-13, 4-18, 4-19, 4-22,

4,-31, 4-32, 4-39-41,4-59, 4-60, 4-81, 4-82,

4-95

Cooperating Agency 1-14, 5-2

Cultural Resources 2-6, 2-14, 2-21, 2-32, 2-35,

2-38, 2-51, 3-11, 3-12, 4-39

Cumulative Impacts 1-1, 1-9, 4-4, 4-84,

4-89-94, 5-2

Decision Area 2-1, 2-4, 2-22, 2-51, 2-52, 2-53,

3-1, 3-14, 3-19, 3-20, 3-41, Chapter 4

Dispersed Recreation 2-9, 2-54, 4-52, 4-65, 4-

73, 4-82

Discovery Site 1-7, 2-7, 3-7, 3-8, 3-18, 4-6, 4-

12, 4-13, 4-16, 4-29, 4-31, 4-47

E

Easement 1-2, 2-10, 2-22, 2-23, 2-51, 3-14, 4-

11, 4-15, 4-18, 4-28, 4-31, 4-33, 4-43, 4-44

Endangered Species 2-14, 3-30, 3-35, 3-38

Environmental Consequences 1-14, 3-29,

Chapter 4

Environmental Justice 2-52, 2-53, 3-19, 3-21, 3-

22, 4-54

F

Federal Land Policy and Management Act 

(FLPMA) 1-1, 2-1, 2-21, 2-22, 2-23, 3-14, 3-18

Federal Register 1-11, 5-1, 5-7

Fire Management Plan 1-15,2-45, 2-50, 2-55,

3-1, 3-46, 4-47

Fossil 1-4, 1-7, 1-8, 1-9, 1-16, 2-6, 2-48, 3-2,

3-6-8, 3-13, 3-18, 4-3, 4-5-8, 4-12, 4-14-16,

4-19, 4-22, 4-26, 4-28-32, 4-40, 4-46, 4-82,

4-86, 4-88, 4-89, 4-95

G

Geographic Information System (GIS) 1-4, 

2-32, 4-2, 4-3, 4-19, 4-25

Greenhouse Gases 2-50, 4-90

Groundwater 2-44, 3-43, 4-77
IN-2

I N

Interpretation and Education 2-3, 2-7, 2-48,

2-49, 3-7,3-8, 4-11

Interim Management Policy for Lands under 

Wilderness Review (IMP) 1-10, 2-1, 2-4, 2-10,

2-14, 2-21, 2-22, 2-34, 3-35, 4-2, 4-63

Impacts 2-47-50, 2-53-55, 3-1, 3-5, 3-6, 3-10,

3-22, 3-30, 3-41, Chapter 4

Issues 1-1, 1-6, 1-8,1-9,1-11, 1-13, 1-14, 2-2,

2-45, 2-51, 3-28, 3-50, 4-3, 4-43, 4-84, 4-86, 4-

87, 4-91

J

National Ambient Air Quality Standards: 3-10

National Environmental Policy Act (NEPA)

1-1, 2-1, 2-12, 2-23, 3-8, 4-3, 4-75, 4-94-95,

5-2

National Historic Preservation Act (NHPA) 

2-21, 2-22, 4-39

National Register of Historic Places (NRHP) 

2-21, 2-22, 4-39

Notice of Intent (NOI) 1-11, 5-1

O

Jurisdiction 1-6, 1-14, 3-14, 4-44, 4-85, 5-2

L

Legislation 1-9, 1-11, 1-13, 1-14, 2-1-4, 2-22,

2-23, 2-30, 2-35, 2-36, 2-53, 3,14, 3-32, 4-2,

4-7, 4-18, 4-19, 4-25, 4-43, 4-63, 4-92, 5-2

Livestock Grazing 1-8, 1-9, 1-15, 2-2, 2-30,

2-33, 2-35, 2-46, 2-50, 2-52-55, 3-15, 3-32, 4-48

Long-Term 1-1, 1-4, 1-11, 2-55, 3-29, 3-40

M

Minerals 1-17, 2-5, 2-23, 2-47, 2-55, 3-1, 3-8,

3-13, 3-14, 3-27, 3-29, 4-3, 4-13, 4-26, 4-35-37,

4-39, 4-40, 4-43, 4-44, 4-58, 4-67, 4-73-74,

4-89 4-91

Mission 1-17, 2-21

Mitigation 1-8, 1-10, 1-14, 2-21, 2-34, 2-37,

2-44, 3-5, 4-58, 4-59, 4-61, 4-68, 4-70, 4-74,

4-75, 4-77, 4-87, 4-95

Monitoring 1-14, 2-11, 2-30, 2-45, 3-8, 3-10,

3-17, 3-18, 3-43, 3-50, 4-18, 4-35, 4-59, 4-68,

4-90 4-93

Off-Highway Vehicle 2-2, 2-14, 2-49, 3-8-10,

3-29, Chapter 4, 5-1

P

Paleontological Resources 1-1, 1-2, 1-4, 1-6,

1-7, 1-8, 1-9, 1-16, 1-17, 2-2-4, 2-6, 2-9, 2-12,

2-15, 2-30, 2-36, 2-48, 2-52, 2-53, 3-1, 3-5,

3-18, 3-30, 4-5

Paleozoic 2-36, 3-6, 3-13, 3-14, 3-32, 4-6, 4-7,

4-15, 4-63

Planning Criteria 1-9, 1-13, 2-2

Planning Issues 1-6, 4-3

Planning Area 1-4, 2-2, 2-4, 2-22, 2-23, 2-50,

3-8-11, 3-13, 3-28, 3-35, 3-38, 3-43, 3-44, 3-50,

4-2, 4-19, 4-35, 4-72-74, 4-76, 4-84

Planning Process 1-11, 2-2, 3-1, 5-1

Preferred Alternative 1-13, 2-3, 2-48

Purpose and Need 1-4, 2-2, 4-1
IN-3

R V

Record of Decision 1-14, 2-1

Recreation 1-1, 1-4, 1-6, 1-7, 1-8, 1-10, 1-13,

1-15, 1-16, 2-2-4, 2-6, 2-7, 2-9, 2-10, 2-12,

2-14,2-15, 2-35, 2-48, 2-52, 2-54, 2-55, 3-15,

3-19, 3-20, 3-27, 3-32, 3-40, Chapter 4

Recreation and Visitor Services 2-9, 2-49, 3-8,

4-17

Recreational Target Shooting 2-4, 3-9, 4-19,

4-21-22, 4-25, 4-27-29, 4-79

Research Natural Area (RNA) 1-2, 2-36, 2-48,

2-53, 3-32, 4-63

S

Scoping 1-6, 1-8, 1-9, 1-11, 1-13, 2-2, 2-4, 4-3,

5-1

Short-Term 1-11, 3-29, 4-21, 4-27, 4-35, 4-36,

4-58-60, 4-62, 4-74

Soils 2-29, 2-33, 2-34, 2-37, 2-50, 2-53, 3-29,

3-38, 3-46, 4-58

Stakeholders 1-15, 5-4

Standards and Guidelines 1-9, 1-10, 1-13,

1-15, 2-2, 2-33, 2-46, 3-46, 4-58, 4-77

Surface Water 2-44, 3-30, 3-44, 4-61, 4-77

T

Vertebrate 2-2, 2-3, 2-6, 2-48, 2-49, 2-53, 3-5,

3-6, 3-7, 3-32, 4-6, 4-95

Visual Resources 1-8, 2-39, 2-51, 2-54, 2-55, 3-

40, 3-41, 3-43, 4-72

Vision 1-17, 4-87, 4-91, 4-94

W

Water Resources 2-44, 2-55, 3-38, 3-43, 3-44,

4-77

Wildfire 2-50, 2-55, 3-46 

Wildland Fire Management 4-78

Wildlife 1-8. 1-10, 1-16, 2-14, 2-30, 2-31, 2-37,

2-38, 2-46, 2-55, 3-28, 3-35, 3-38, 3-40, 3-44, 3-

50, 4-81

Wilderness Study Area (WSA) 1-2, 1-4, 1-10,

1-16, 2-4, 2-10, 2-14, 2-27, 2-30, 2-39, 2-50,

2-53, 3-10, 3-15, 3-30, 3-32, 3-35, 3-41, 3-46,

4-63

Withdrawal 3-14, 4-91, 4-92, 4-95

Threatened Species 2-14, 3-35

Topography 3-30, 3-38, 4-29, 4-61

Trackways 1-1, 1-2, 1-7, 1-15, 1-16, 2-1, 2-30,

2-36, 2-37, 3-7, 3-8, 3-13, 3-14, 3-17, 3-27, 4-6,

4-7, 4-15, 4-18, 4-63, 4-86, 4-87, 4-89, 5-1, 5-3,

5-7, 5-8
UNITED STATES

Department of the Interior

BUREAU OF LAND MANAGEMENT

LAS CRUCES DISTRICT OFFICE

1800 MARQUESS ST

LAS CRUCES NM 88005-3371

OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE $300