United States Department of Agriculture

Luna Restoration Project

Draft Environmental Impact Statement

Forest Service Apache National Forest (Administered by Gila National Forest) 

Quemado Ranger District Publication # MB-R3-06-10 March 2018
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at 575-773-4678. 

Cover photo is from the northern portion of Luna planning area. View looking east and south of Spur Lake 

Basin taken from a point near Bill Knight Gap. To the left is Freeman and Dillon Mountains and to the right is 

Bishop Mountain. The ranch in the middle is part of the Spur Lake Cattle Company called Gribble Head 

Quarters.
Luna Restoration Project

Draft Environmental Impact Statement

Catron County, New Mexico 

Lead Agency: USDA Forest Service

Responsible Official: Adam Mendonca, Forest Supervisor

Gila National Forest

3005 E. Camino del Bosque, Silver City, NM 88061 

For Information Contact: Emily Irwin, District Ranger 

Quemado Ranger District

P.O. Box 159, Quemado, NM 87829

575-773-4678 

Abstract: The Gila National Forest proposes to conduct restoration activities within the 185,586 acre 

Luna planning area on the Quemado Ranger District. Four alternatives are being considered. Alternative A 

proposes no action; there would be no changes in current management. Alternative B, modified proposed 

action, proposes forest, woodland, fuels, watershed, motorized transportation, and range and wildlife 

habitat activities, which includes mechanical treatments and prescribed fire. Alternative C includes all of 

the same proposed in alternative B, but adds the use of herbicides for vegetation treatments of rabbitbrush 

and alligator juniper. Alternative D includes all of the same activities proposed in alternative B with the 

exception of not adding closed and user-created routes to the motorized transportation system. This 

exception does not include the routes required by Tucson Electric Power for utility line maintenance. The 

Gila National Forest has identified alternative C as the preferred alternative. A description of the preferred 

alternative may be found in chapter 2 of this document. 

Date comments must be received: The 45-day comment period begins the day after the notice of 

availability is published in the Federal Register. Comments on this draft environmental impact statement 

must be received or postmarked before the end of the 45th calendar day following publication to 

participate in the administrative review process (36 CFR 218.25(a)(1)(ii)). The notice of availability will 

be posted on the forest web site: Luna Restoration Project, Gila National Forest . 

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

to the Agency’s preparation of the environmental impact statement. Therefore, comments should be 

provided prior to the close of the comment period and should clearly articulate the reviewer’s concerns 

and contentions. The submission of timely and specific comments can affect a reviewer’s ability to 

participate in subsequent administrative judicial reviews. Comments received in response to this 

solicitation, including names and addresses of those who comment, will be part of the public record for 

this proposed action. Comments submitted anonymously will be accepted and considered; however, 

anonymous comments will not provide the respondent with standing to participate in subsequent 

administrative or judicial reviews.

Send Comments to: Gila National Forest; Attn: Luna Restoration Project

3005 E. Camino del Bosque; Silver City, NM 88061 

Fax number: 575-388-8222 

Email address: comments-southwestern-gila@fs.fed.us 
Luna Restoration Project 

Draft Environmental Impact Statement

i 

Summary 

Background 

The Gila National Forest proposes to implement a wide range of restoration activities throughout the 

Luna planning area. Treatments include vegetation and fuels (mechanical and prescribed fire), watershed, 

motorized transportation, range, and wildlife habitat activities. The area affected by the proposal includes 

the western portion of the Quemado Ranger District around the area of Luna, New Mexico. Within the 

planning area, there are electronic and communication sites, the community of Luna and private 

inholdings, active grazing allotments and associated infrastructure, and natural and cultural resources. 

Much of the landscape is departed and is at risk to moderate- to high-severity wildfire. Wildfires burning 

at these intensities and severities could impact watersheds, habitats, infrastructure, the community, and 

the livelihoods of people living in this landscape. Treatments are designed to restore the structure, 

function, and resilience in vegetative communities; improve function of riparian areas and streams; 

improve water quality; and reduce the impacts from roads across the project area. 

In response to Congressional, agency, and regional emphasis on all-lands restoration level planning, the 

Gila and Apache-Sitgreaves National Forests responded by proposing ecological restoration treatments 

across a large landscape encompassing both national forests. The Luna Restoration Project area was 

identified by the Gila National Forest as the highest priority for landscape restoration planning. The 

purpose of the project is to create and maintain a healthy resilient landscape and watersheds capable of 

delivering benefits to the public, including clean air and water, habitat for native fish and wildlife, forest 

products, and outdoor recreation opportunities.

Public Involvement 

This project has been listed on the Gila’s schedule of proposed actions since October 2015 and 

periodically updated. The Quemado Ranger District staff hosted two open houses and a meeting with 

members of the Luna Community in Luna, New Mexico, to have discussions with stakeholders on 

identifying issues, concerns, and restoration and recreation opportunities. Between the open houses, over 

200 letters were sent to individuals, Tribes, organizations, and agencies introducing the planning area and 

providing opportunity to provide input. The notice of intent was published in the Federal Register on May 

19, 2016. Gila National Forest staff received 27 comments during the scoping period. Twelve Tribes were 

consulted with and provided the opportunity to participate in the planning process. Gila National Forest 

staff will continue to engage in Tribal consultation. 

Significant Issues 

Significant issues form the basis of alternatives to the proposed action. Three significant issues were 

identified from the scoping comment letters: 

1. Vegetation treatments for rabbitbrush and alligator juniper: Mowing rabbitbrush and cutting 

alligator juniper may not be effective treatment methods. 

2. Fuels treatments: Treatment of mixed conifer stands east of highway 180 may result in high 

severity fires impacting wildlife and limited burning and thinning may not improve or protect 

Mexican spotted owl habitat. 

3. Motorized transportation system: The 50-inch motorized trail size limits access by utility task

vehicles and side-by-side vehicles, Tucson Electric Power needs motorized access for 

maintenance, and no additional motorized routes should be added to the National Forest System 

of roads and trails.
Summary 

Luna Restoration Project 

Draft Environmental Impact Statement

ii

Alternatives 

Alternative A is the no-action alternative representing the existing condition. 

Alternative B is the modified proposed action. This alternative was modified to address all or portions of 

significant issues related to fuels treatments and motorized transportation system. 

Alternative C is the preferred alternative. Alternative C is similar to alternative B except it addresses the 

significant issue of vegetation treatments by utilizing herbicides to treat rabbitbrush and alligator juniper.

Alternative D is similar to alternative B except it addresses the part of the motorized transportation 

system significant issue of not adding more miles to the National Forest System of motorized roads and 

trails.

Conclusions Related to Impacts 

Over time, the action alternatives move vegetative trends towards desired conditions. Tree and brush 

encroachment into grasslands and riparian systems decreases. Tree densities decrease with the trend being 

stands are more resilient to disturbances. Mechanical and prescribed fire treatments would reduce the 

crown fire potential from approximately 67 percent of the landscape (alternative A) to approximately 16 

percent of the project area. 

Trends to the soils, riparian, and water quality resources suggest there could be some short-term impacts 

to these resources including soil compaction and soil exposure. However, the long-term trend is an 

improvement of impaired soil conditions as well as help in maintaining satisfactory soil conditions in 

riparian areas, wetlands, upland wet meadows, and degraded uplands. 

The action alternatives show a net road mile reduction of 94 miles of road in alternatives B and C, and 

126 miles in alternative D. 

As described in chapter 3, implementing the action alternatives would improve forest and woodland stand

health and improve wildlife habitat, including habitat for threatened, endangered, and sensitive species. 

There would be reduction in the risk of large uncharacteristic wildfires and their impacts to the landscape, 

watersheds, species, and human health and quality of life. As described throughout chapter 3, the overall 

implementation of the action alternatives would improve resources such as range condition, wildlife and 

aquatic habitat, soil conditions, and others. Erosion control and reducing risk of wildfire would reduce 

impacts to sensitive resources like water quality, cultural resources, and air quality.

Based upon the effects of the alternatives, the responsible official will decide whether to select the noaction alternative; whether to select the modified proposed action, another action alternative, or an action 

alternative that is modified as described in the final decision, and which forest plan amendments to 

include in the final decision. 
Luna Restoration Project 

Draft Environmental Impact Statement

iii

Contents 

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

Background ................................................................................................................................... i

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

Significant Issues .......................................................................................................................... i

Alternatives .................................................................................................................................. ii

Conclusions Related to Impacts .................................................................................................. ii

Acronyms ....................................................................................................................................... vii

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

Structure of this Document .......................................................................................................... 1

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

Location and Description of Planning Area ................................................................................ 2

Background .................................................................................................................................. 5

Existing and Desired Conditions ................................................................................................. 5

Purpose and Need for Action ..................................................................................................... 14

Previous Decisions .................................................................................................................... 14

Modified Proposed Action......................................................................................................... 15

Decision Framework.................................................................................................................. 16

Public Involvement .................................................................................................................... 16

Tribal Consultation .................................................................................................................... 16

Issues ......................................................................................................................................... 17

Chapter 2. Alternatives, Including the Proposed Action .............................................................. 19

Introduction ............................................................................................................................... 19

Alternatives Considered in Detail .............................................................................................. 19

Comparison of Alternatives ....................................................................................................... 36

Chapter 3. Affected Environment and Environmental Consequences .......................................... 59

Introduction ............................................................................................................................... 59

Vegetation .................................................................................................................................. 60

Fire and Fuels ............................................................................................................................ 75

Wildlife ...................................................................................................................................... 81

Air Quality ............................................................................................................................... 105

Watershed and Soils ................................................................................................................ 107

Roads ....................................................................................................................................... 140

Range ....................................................................................................................................... 144

Recreation ................................................................................................................................ 146

Recreation – Inventoried Roadless Areas ................................................................................ 149

Heritage Resources .................................................................................................................. 156

Social and Economics .............................................................................................................. 162

Short-term Uses and Long-term Productivity.......................................................................... 167

Unavoidable Adverse Effects .................................................................................................. 167

Irreversible and Irretrievable Commitments of Resources ...................................................... 168

Preparers and Contributors .......................................................................................................... 169

List of Preparers ...................................................................................................................... 169

List of Contributors ................................................................................................................. 170

Federal, State, and Local Agencies ......................................................................................... 171

Tribes ....................................................................................................................................... 171

Others ...................................................................................................................................... 171

Distribution of the Environmental Impact Statement .................................................................. 172

Glossary ....................................................................................................................................... 173
Contents

Luna Restoration Project 

Draft Environmental Impact Statement

iv

References .................................................................................................................................... 175

Index ............................................................................................................................................ 179

List of Tables

Table 1. Existing acres of vegetation types within the Luna planning area. The percent change 

from existing conditions are shown for each cover type that would maintain variety and 

reach desired conditions per cover type in the planning area. ................................................. 6

Table 2. Existing and desired stand density index (SDI) percent of maximum for the Luna project 

area. .......................................................................................................................................... 7

Table 3. Vegetation structural stage existing and desired conditions in percent acres of ponderosa 

pine cover type in the Luna planning area. .............................................................................. 8

Table 4. Ponderosa pine cover type existing and desired conditions for canopy density classes by 

percent. ..................................................................................................................................... 8

Table 5. Woodland cover type existing and desired conditions for canopy density classes by 

percent. ..................................................................................................................................... 8

Table 6. Percentage of identified Mexican spotted owl threshold stands currently meeting all 

features and percent of stands meeting each of the features in mixed-conifer and ponderosa 

pine-oak cover types within the Luna planning area. .............................................................. 9

Table 7. Existing and desired old growth structural attributes by cover type group expressed in 

percent area within the Luna planning area. .......................................................................... 10

Table 8. Acres by fire type within the Luna planning area. ........................................................... 11

Table 9. Existing fuel conditions by vegetation type within Luna planning area. ......................... 11

Table 10. Desired fuel conditions by vegetation type within Luna planning area. ........................ 12

Table 11. 6th code watersheds in the Luna planning area. Summary of the 2015 watershed 

condition rating and number of streams in non-attainment of New Mexico State water 

quality standards. ................................................................................................................... 13

Table 12. Acres of vegetation treatments by action alternative and map reference number. ....... 20

Table 13. Acres of rabbitbrush, alligator juniper, and herbicide use by alternative and map 

reference number. .................................................................................................................. 21

Table 14. Acres of prescribed fire only and activity fuels treatments by alternative and map 

reference number. .................................................................................................................. 23

Table 15. Rangeland improvements proposed under alternative B, C, and D by allotment and 

pasture. Map symbols correspond to labels found on MAP 7. .............................................. 26

Table 16. Summary of range improvements by type per allotment. .............................................. 26

Table 17. Types of treatments to the motorized transportation system in miles common to 

alternatives B, C, and D; and map reference number for each alternative. ............................ 28

Table 18. Changes to road system in miles by alternative. ........................................................... 29

Table 19. Summary of the type, number and location, including MAP 10 reference symbols, in [ 

], of stream and riparian treatments for all action alternatives. .............................................. 30

Table 20. Comparison of the vegetation resources by alternative. ................................................ 37

Table 21. Comparison of the fire and fuels resources by alternative. ............................................ 41

Table 22. Comparison of the wildlife resources by alternative ..................................................... 43

Table 23. Comparison of management indicator species resources by alternative ........................ 49

Table 24. Comparison of the watershed and soils resources by alternative ................................... 51

Table 25. Comparison of the National Forest System roads by alternative. .................................. 55

Table 26. Comparison of the range resources by alternative ......................................................... 55

Table 27. Comparison of recreation resources by alternative ........................................................ 55

Table 28. Comparison of heritage resources by alternative ........................................................... 57

Table 29. Comparison of the social and economic resources by alternative ................................. 57
Contents

Luna Restoration Project 

Draft Environmental Impact Statement

v 

Table 30. Average width of roads and trails by type or maintenance level. .................................. 59

Table 31. Forest cover type acres and percent change in 20 and 40 years under alternative A, no 

action. ..................................................................................................................................... 62

Table 32. Stand density index (SDI) percent of landscape in 20 and 40 years under alternative A, 

no action. ................................................................................................................................ 62

Table 33. Ponderosa pine percent of area by canopy density class under alternative A, no action, 

from existing to 20 and 40 years compared to desired condition; where Canopy Density 

Class A = Open (0-39%); B = Moderately closed (40-59%); and C = Closed (60% +). ....... 63

Table 34. Woodlands percent of area by canopy density class under alternative A, no action, 

from existing to 20 and 40 years compared to desired condition; where Canopy Density 

Class A = Open (0-39%); B = Moderately closed (40-59%); and C = Closed (60% +). ....... 63

Table 35. Vegetation structural stages (VSSs) by percent area for ponderosa pine cover type for 

existing, 20-year and 40-year conditions compared to desired conditions under alternative A, 

no action. ................................................................................................................................ 64

Table 36. Percent of Mexican spotted owl threshold stands meeting minimum habitat 

characteristic(s) by cover type within 20 years under alternative A, no action. .................... 64

Table 37. Percent of Mexican spotted owl threshold stands meeting minimum habitat 

characteristic(s) by cover type within 40 years under alternative A, no action. .................... 65

Table 38. Percent of designated 20% (identified) old growth area meeting minimum criteria of 

structural attributes by group from existing through 20 and 40 years under alternative A, no 

action. ..................................................................................................................................... 66

Table 39. Percent change from existing forest cover type acres at 1 year, 20 years, and 40 years 

post harvest compared to range of desired percent for alternatives B, C, and D. .................. 67

Table 40. Percent of maximum stand density index (SDI) 1 year, 20 years, and 40 years postharvest for alternatives B, C, and D compared to desired percent of the landscape. ............. 68

Table 41. Ponderosa pine percent of area by canopy density class under alternatives B, C, and D, 

1; 20; and 40 years post harvest compared to desired condition; where canopy density class 

A = Open (0-39%); B = Moderately closed (40-59%); and C = Closed (60% +). ................. 70

Table 42. Woodlands percent of area by canopy density class under alternatives B, C, and D, 1; 

20; and 40 years post harvest compared to desired condition; where canopy density class A = 

Open (0-39%); B = Moderately closed (40-59%); and C = Closed (60% +). ........................ 70

Table 43. Vegetation structural stages by percent area for ponderosa pine cover type for 1-year, 

20-year and 40-year post harvest conditions for alternatives B, C, and D compared to desired 

conditions. .............................................................................................................................. 70

Table 44. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 1 year post-harvest under alternatives B, C, and D. ............................................. 71

Table 45. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 20 years post-harvest under alternatives B, C, and D........................................... 71

Table 46. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 40 years post-harvest under alternatives B, C, and D........................................... 72

Table 47. Percent of designated 20% (identified) old growth area meeting minimum criteria of 

structural attributes by group in 1; 20; and 40 years post-harvest under alternatives B, C, and 

D. ............................................................................................................................................ 73

Table 48. Summary of fire regime groups within the Luna planning area. ................................... 77

Table 49. Vegetation condition class distribution in the Luna planning area. ............................... 77

Table 50. Summary comparison of all alternatives for fire related concerns in the Luna planning 

area. ........................................................................................................................................ 79

Table 51. Vegetation project treatments acres, type, and implementation date within the last 12 

years within the Luna planning area. ..................................................................................... 80
Contents

Luna Restoration Project 

Draft Environmental Impact Statement

vi

Table 52. Summary of federally listed species (endangered, threatened, and experimental) within 

Catron County and within the Luna planning area. ............................................................... 81

Table 53. Gila National Forest management indicator species with associated habitat type and 

rational for including or excluding from analysis. ................................................................. 92

Table 54. List of migratory bird species occur or have the potential to occur within the Luna 

planning area and associated habitat types. ......................................................................... 103

Table 55. Summary of watersheds and condition ratings that overlap the Luna planning area. 

Watershed condition ratings are Class 1 = Functioning Properly; Class 2 = Functioning at 

Risk; and Class 3 = Impaired Function. ............................................................................... 110

Table 56. Summary of general ecosystem survey soil condition within the Luna planning area.112

Table 57. Summary of general ecosystem survey erosion hazard within the Luna planning area.

 ............................................................................................................................................. 112

Table 58. Acres of disturbance by alternative from motorized transportation treatments. .......... 122

Table 59. Existing Gila National Forest System roads by operation maintenance level (OML) and 

general description of each maintenance level..................................................................... 141

Table 60. Roads under other jurisdiction within the Luna Restoration Project area. .................. 141

Table 61. Existing National Forest System roads within the Luna Restoration Project area broken 

down by operation maintenance level and general description of each maintenance level. 141

Table 62. Changes to National Forest System road miles by alternative ..................................... 142

Table 63. Grazing allotments located within the Luna planning area. ......................................... 144

Table 64. Racial and ethnic breakdown of counties within the analysis area .............................. 163

Table 65. Per capita income and percentage of labor or non-labor source and unemployment for 

counties in the analysis area, state, and nation ..................................................................... 164

Table 66. Median household income and percentage of persons in poverty in 2015 .................. 164

List of Figures

Figure 1. Luna Restoration Project vicinity map and planning boundary. ...................................... 3

Figure 2. Map displaying the Escudilla Landscape planning boundary which extends across both 

the Apache-Sitgreaves and Gila National Forests. ................................................................... 4
Luna Restoration Project 

Draft Environmental Impact Statement

vii

Acronyms

ATV all-terrain vehicle

ca circa 

CEQ Council on Environmental 

Quality

CFR Code of Federal Regulations 

DEIS draft environmental impact 

statement

EIS environmental impact 

statement

E.O. Executive Order 

FOIA Freedom of Information Act 

FR Federal Register

FSR Forest System Road

FVS Forest Vegetation Simulator

GES general ecosystem survey

GIS geographical information 

system

MSO Mexican spotted owl

NEPA National Environmental Policy 

Act

NFMA National Forest Management 

Act

NFS National Forest System

NFSR National Forest System road

NHPA National Historic Preservation 

Act

NOI Notice of Intent 

NRHP National Register of Historic 

Places

OML operation maintenance level 

SDI stand density index

SNOTEL snow telemetry

SOPA Schedule of Proposed Actions 

TEP Tucson Electric Power

TES terrestrial ecosystem survey

TMDL total maximum daily load

USDA United States Department of 

Agriculture 

U.S.C. United States Code

UTV utility task vehicle

VSS vegetation structural stage
Luna Restoration Project 

Draft Environmental Impact Statement

1 

Chapter 1. Purpose of and Need for Action

Structure of this Document 

The Forest Service has prepared this draft environmental impact statement in compliance with 

the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and 

regulations. This document discloses the direct, indirect, and cumulative environmental impacts 

that would result from the proposed action and alternatives. This document consists of the 

following:

• Chapter 1. Purpose of and Need for Action: This chapter briefly describes this project’s 

background, its purpose and need, and our initial proposal for achieving the purpose and 

need. It then describes how we informed the public of the proposal and how they 

responded. 

• Chapter 2. Alternatives, including the Proposed Action: This chapter describes the 

proposed action and alternatives—including no action—in detail. These alternatives were 

developed based on significant issues raised by the public and other agencies. The chapter 

ends with a summary of the environmental consequences for each alternative. 

• Chapter 3. Affected Environment and Environmental Consequences: This chapter 

describes the environmental effects of each alternative in detail.

• Preparers and Contributors: This chapter contains a list of preparers and the agencies 

we consulted with during its development. It contains a list of agencies, organizations, and 

persons to whom copies of the draft environmental impact statement were sent.

• Glossary

• References

• Index

In addition to this document, there are a series of separate large-size map documents included on 

a compact disc (CD), displaying the proposed activities by alternatives that are referred to in 

chapter 2. 

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

found in the project planning record located at the Gila National Forest Supervisor’s Office, 

3005 E. Camino del Bosque, Silver City, New Mexico 88061. Documents are available pursuant 

to the provisions of the Freedom of Information Act. 

Introduction 

In response to Congressional, agency, and regional emphasis on all-lands restoration level 

planning, the Gila and Apache-Sitgreaves National Forests have responded by proposing 

ecological restoration treatments across a large landscape encompassing both national forests. 

The Luna Restoration Project is located along the western portion of the Quemado Ranger 

District around the community of Luna (figure 1). The 185,586 acre Luna planning area is part 

of the larger Escudilla Landscape, a 279,470 acre landscape planning area that extends across 

both the Gila and Apache-Sitgreaves National Forests (figure 2). The two national forests 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

2 

worked together and identified a number of treatments that cross between the two forest 

boundaries including vegetation and fuels (mechanical and prescribed fire), watershed, 

motorized transportation, range, and wildlife habitat activities. 

Beginning in 2014, the Quemado Ranger District reached out to the public and County, State, 

and Federal agencies inviting all to assist with the development of proposed activities within the 

planning area. These stakeholders identified areas of concern related to wildfire potential and 

community protection; locations for motorized (for example, all-terrain vehicle and utility task

vehicle) trails; maintenance needs for roads and trails; and maintenance needs for sediment 

control features and structures. Stakeholders also identified locations for vegetation restoration 

treatments, and locations and type of range and wildlife improvements. 

Location and Description of Planning Area 

The Luna Restoration Project is located along the western portion of the Quemado Ranger 

District around the community of Luna (figure 1). The 186,586-acre planning area is bounded to 

the north by the Gila National Forest boundary, the west by the Arizona and New Mexico state

lines, the south by the Quemado Ranger District boundary, and the east along a series of 

ridgelines along watershed boundaries. There are 14,226 acres of private inholdings within the 

planning area. The project lies within the area of Townships 2 South through 7 South and Ranges 

19 West through 21 West. 

The community of Luna is located in the southern portion of the planning area. There is

important infrastructure located in the vicinity of Luna. A large electronic and communication 

site is situated on the San Francisco Divide on the southern boundary of the planning area. This 

site supports systems for the Forest Service; Catron County Sheriff’s Department and 

Emergency Management Services; New Mexico State Police; and private enterprises. Tucson 

Electric Power interstate has two transmission lines that extend through the entire length of the 

project area. The El Paso Electric interstate transmission line runs approximately 3 miles 

northeast of the planning area. A local service line managed by Navopache Electric Power 

Company extends in and around Luna. 

The community of Luna and key infrastructure and natural resources are located in a forested, 

ponderosa pine setting and on mountain tops. Prevailing winds, alignment of topography, and 

dense forest vegetation place the community and infrastructure at risk of a wildfire starting in the 

southwest corner of the project area and rapidly burning northeast. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

3 

Figure 1. Luna Restoration Project vicinity map and planning boundary.
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

4 

Figure 2. Map displaying the Escudilla Landscape planning boundary which extends across both 

the Apache-Sitgreaves and Gila National Forests. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

5 

Background 

Luna and surrounding private inholdings are identified as “high” on the priority list for 

protection from wildfires in both the 2005 Catron County and 2006 Luna Community Wildfire 

Protection Plans. In the late 1990s to early 2000s, the Quemado Ranger District personnel 

implemented some hazardous fuels reduction projects around Luna which included prescribed 

burning, thinning of ponderosa pine stands, and construction of a 300-foot fuelbreak on the south 

and west sides of the community. 

In 2011, the Wallow Fire burned onto the Gila National Forest from Arizona, west of the 

community of Luna, burning approximately 15,400 acres in New Mexico. The fire burned across 

the landscape with varying levels of severity. High-severity fire impacted numerous natural 

resources. Flooding occurred immediately after the fire, and numerous sediment trap and tanks 

across the fire area were silted in. 

Within the larger Escudilla Landscape area (Arizona and New Mexico), approximately 39,385 

acres were burned. Post-fire satellite imagery indicates 1,757 acres were burned by high-severity 

fire and 4,039 were burned by moderate-severity fire. The impacts of the Wallow Fire have 

resulted in degraded watershed conditions on thousands of acres; substantially altering future 

yields of clean water. Future vegetative communities; thus land use opportunities, especially on 

the heavily impacted areas, will continually change as the severely degraded areas move through 

successional stages of recovery and various vegetative communities develop. 

The Wallow Fire and post-fire impacts on the landscape, watersheds, habitat, forest facilities, 

infrastructure, and community of Luna highlights the range of possible future impacts from 

wildfires on stakeholders and land managers. 

Existing and Desired Conditions 

Vegetation 

Forest Cover Types 

The Luna planning area contains a wide range of vegetation communities. The broad forest 

cover types are grassland, Douglas fir, oak woodland, pinyon pine -juniper woodland, ponderosa 

pine and white fir (table 1). 

The desired condition is to maintain a variety of forest cover types within the project area, while 

increasing acres of grasslands that have been encroached by woodland species (table 1). It is also 

desired to increase the oak, herbaceous, forb, and shrub components within individual stands and 

manage for uneven-aged characteristics (multi-storied) across the majority of the landscape with 

the exception being areas having high levels of dwarf mistletoe and areas adjacent to private 

land. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

6 

Table 1. Existing acres of vegetation types within the Luna planning area. The 

percent change from existing conditions are shown for each cover type that would 

maintain variety and reach desired conditions per cover type in the planning area.

Forest Cover Type Existing Acres

Desired Percent Change 

from Existing Condition

Grassland/Meadow 21,941 +0-2 % 

Douglas fir 6,323 +0-2 % 

Engelmann Spruce 109 +0-2 % 

Oak Woodland 1,414 ± 2 % 

Pinyon pine-Juniper 41,713 ± 5 % 

Ponderosa pine 87,195 ± 5 % 

Riparian 784 N/A

Southwestern White Pine 69 +0-2 % 

White Fir 6,887 +0-2 % 

Reforestation Area 3,954 N/A

Rocky Area 942 N/A

Total 171,3311 NA

1 Acreage does not include private land.

Stand Density Index 

Stand stocking density is the measurement of tree spacing within a stand and can be thought of 

in terms of the degree of crowding among trees in a stand. This can be measured in square feet of 

basal area, or expressed as an index of stocking, such as stand density index (SDI). For a given 

tree species of a given size (average stand diameter) there is a maximum number of trees that can 

be supported on an acre, or maximum stand density index. 

Current and desired relative densities within the various zones across the Luna planning area are 

provided below in table 2. Currently 48 percent of the area is at full site occupancy. Most of the 

full site occupancy is concentrated in zones 3 and 4; both zones are within their desired 

respective ranges. The existing condition for zone 2 is slightly above the desired range, while

zone 1 is within the desired range. 

A variety of density conditions are desired across the landscape to meet various management 

objectives. 

There is a desire to maintain areas in zones 3 and 4 to provide higher tree densities and canopy 

cover for wildlife species, including northern goshawk and Mexican spotted owl. Zones 3 and 4 

also promote the development of old growth characteristics. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

7 

Table 2. Existing and desired stand density index (SDI) percent of maximum for the Luna project 

area. 

Zone

Maximum 

SDI in 

Percent 

(%)

Existing 

Percent of 

Landscape

Desired 

Percent of 

Landscape Biological Implications

1 0 - 25 19 10-20 Less than full site occupancy, maximum forage

No competition among trees, little crown differentiation

Maximum individual tree diameter and volume growth

Minimum whole stand volume growth

Shade intolerant seedlings favored

2 25 - 35 33 20-30 Less than full site occupancy, intermediate forage

Onset of competition among trees, onset of crown 

differentiation

Intermediate individual tree diameter and volume 

growth

Intermediate whole stand volume growth

Shade tolerant and intolerant seedlings favored

3 35 – 551 38 30-50 Full site occupancy, minimum forage

Active competition among trees, active crown 

differentiation

Declining individual tree diameter and volume growth

Maximum whole stand volume growth

Shade tolerant seedlings favored

Upper range marks the threshold for the onset of 

density-related mortality

4 551 - 100 10 10-20 Full site occupancy, minimum forage

Severe competition among trees, active competition 

induced mortality

Minimum individual tree diameter and volume growth, 

stagnation

Declining whole stand volume growth due to mortality

Shade tolerant seedlings favored

1 Zones 3 and 4 upper/lower ranges vary between 55-60% based on review of the existing research 55% was used as 

the respective upper and lower thresholds for zones 3 and 4 for the Luna Analysis.

Vegetation Structural Stage

Vegetation structural stage pertains to how treatments meet or improve wildlife habitat including 

Mexican spotted owl and northern goshawk. Vegetation structural stage (VSS) is the metric used 

to show how the treatments move ponderosa pine stands toward the desired conditions (table 3).

Existing conditions shows a surplus of acres in vegetation structural stages 1, 3 and 4 for the 

ponderosa pine cover type in comparison to the desired condition. All other structural stages are 

deficit to varying degrees (table 3). 

For canopy density classes in the ponderosa pine cover type, class B is in surplus in comparison 

to the desired condition. Classes A and C are deficit and are not meeting desired conditions (table 

4). For the woodland canopy density class A, B, and C do not meet desired condition (table 5). 

Both ponderosa pine and woodland cover types are deficit in uneven-aged structure, 46 percent

and 40 percent respectively, compared to desired conditions (90 percent and 100 percent). With 

both being deficit in uneven-aged structure, means both are exceeding their even-aged structures 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

8 

compared to desired conditions. Ponderosa pine has 54 percent and woodlands 60 percent evenaged structure. The desired is to have 10 percent and 0 percent, respectively, even-aged structure.

Table 3. Vegetation structural stage existing and desired conditions in percent acres of 

ponderosa pine cover type in the Luna planning area. 

Vegetation Structural Stage

(Diameter class in inches)

Existing Condition

(percent acres)

Desired Condition

(percent acres)

VSS 1 (0.0-0.9”) 22 10

VSS 2 (1.0-4.9”) <1 10

VSS 3 (5.0-11.9”) 30 20

VSS 4 (12.0-17.9”) 25 20

VSS 5 (18.0-23.9”) 16 20

VSS 6 (24” +) 8 20

Table 4. Ponderosa pine cover type existing and desired conditions for canopy density classes by 

percent. 

Canopy Density 

Class Class description

Existing Condition

(Percent) 

Desired Condition

(Percent) 

A Open (0-39%) 36% 40%

B Moderately Closed (40-59%) 51% 40%

C Closed (60% +) 12% 20%

Table 5. Woodland cover type existing and desired conditions for canopy density classes by 

percent.

Canopy Density 

Class Class description

Existing Condition

(Percent)

Desired Condition

(Percent)

A Open (0-39%) 13% 55%

B Moderately Closed (40-59%) 63% 30%

C Closed (60% +) 24% 15%

Habitat Features for Mexican Spotted Owl (Threshold Stands) 

There are approximately 48,260 acres that are being managed for Mexican spotted owl habitat 

which includes protected activity centers, recovery habitat, and threshold habitat. Threshold 

habitat includes areas to be managed for nest and roost features. Under the Mexican Spotted Owl 

Recovery Plan, First Revision (2012), the goal it to manage stands identified for nesting and 

roosting habitat to meet or exceed area requirements outlined in Table C.3 of the recovery plan. 

To determine if stands meet area requirements, four features were assessed for Mexican spotted 

owl nesting and roosting habitat in mixed-conifer and pine-oak forest cover types. Of the stands 

identified, no stands currently meet all features. However, all of the stands meet some of the 

minimums, to varying degrees, for the two cover types (table 6). The desire is to have 100

percent of the identified stands meeting or exceeding the area requirements for nest and roost 

habitat. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

9 

Table 6. Percentage of identified Mexican spotted owl threshold stands currently meeting all 

features and percent of stands meeting each of the features in mixed-conifer and ponderosa pineoak cover types within the Luna planning area. 

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class 

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 0 52% 6% 48% 30% 

Ponderosa Pine-Oak 0 49% 41% 29% 43% 

Old Growth Stand Structural Attributes

Old growth stand structure attributes include number of live trees of a given size, snags, basal 

area, and canopy cover by vegetation type. These minimum criteria for the structural attributes 

vary between vegetation types for mixed species, ponderosa pine, and woodland species. 

The Gila forest plan identifies a minimum of 20 percent of the forest cover types within the 

planning area must be managed for meeting old growth features. The area of forest cover types 

identified to be managed are: approximately 7,965 acres of the mixed-species group which 

includes Douglas fir, white fir, Engelmann spruce, limber/southwestern white pine); 

approximately 14,952 acres of the woodland group including juniper species; and approximately 

20,177 acres of the ponderosa pine group. 

Desired future condition in areas identified as potential old growth management areas include 

reduction of risk of high intensity wildfire while maintaining and increasing key old growth 

attributes. Existing and desired condition of structural attributes and respective minimum criteria 

to determine old growth for each cover type for the Luna planning area is displayed in table 7. 

Presently, approximately 12 percent of the ponderosa pine group; 19 percent of the mixedspecies group; and 87 percent of the woodland group designated as old growth simultaneously 

meet all minimum criteria of the structural attributes (table 7). For the remaining areas, the 

structural attributes are met to varying degrees.
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

10

Table 7. Existing and desired old growth structural attributes by cover type group expressed in 

percent area within the Luna planning area.

Old Growth Group

Minimum Criteria of Structural 

Attributes1

Percent 

Existing 

Condition of 

Designated 

20% Old 

Growth Area

Percent 

Desired 

Condition of 

Designated 

20% Old 

Growth Area

Ponderosa pine 20 live trees in main canopy at least 14

inches in diameter at breast height (DBH) 

70 100

Ponderosa pine 1 standing dead tree per acre at least 14

inches DBH and at least 15 feet

46 100

Ponderosa pine 70 to 90 square feet per acre total basal 

area

98 100

Ponderosa pine 40 to 50% total canopy cover 34 100

Ponderosa pine Percent area simultaneously meeting all 

attributes2 

12 100

Mixed-species 12-16 live trees in main canopy at least 18

inches DBH

45 100

Mixed-species 2.5 standing dead tree per acre at least 14

inches DBH and at least 20 feet

85 100

Mixed-species 80 to 100 square feet per acre total basal 

area

100 100

Mixed-species 50 to 60% total canopy cover 43 100

Mixed-species Percent area simultaneously meeting all 

attributes2

19 100

Woodland 12 to 30 live trees in main canopy at least 

9 inches in diameter at root collar (DRC) 

99 100

Woodland 1 standing dead tree per acre at least 9 

inches DRC and at least 8 feet

88 100

Woodland 6 to 24 square feet per acre total basal 

area

100 100

Woodland 20 to 35% total canopy cover 97 100

Woodland Percent area simultaneously meeting all 

attributes2

87 100

1 Low site productivity values were used as threshold for each old-growth group for the Luna planning area.

2 Age and down dead trees are unknown for the group.

Fuels and Fire

Fire behavior modeling results suggest current vegetative conditions in the planning area could 

result in torching and passive and active crown fires that are uncharacteristically intense and 

severe (table 8, MAP 1). Vegetation and fuel conditions across the planning area include dense 

stands, closed canopies, ladder fuels (canopy base height), and high surface fuel loadings (table 

9). 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

11

Table 8. Acres by fire type within the Luna planning area.

Fire Type Description Acres at Risk

Surface Fire Fire that burns predominately across the 

surface litter and undergrowth

44,183

Torching/Passive 

Crown Fire

Type of crown fire in which the crowns of 

individual trees or small groups of trees 

burn, but solid flaming in the canopy cannot 

be maintained except for short periods

86,842

Active Crown Fire Also referred to as running crown fire or 

continuous crown fire. An active crown fire 

presents a solid wall of flame from the 

surface through the canopy fuel layers

36,566

Table 9. Existing fuel conditions by vegetation type within Luna planning area.

Vegetation Type

Surface fuel 

loading1

(tons per acre)

Coarse Woody 

Debris2

(tons per acre)

Canopy Base 

Height3

(feet) 

Canopy Bulk 

Density4

(kg/m3)

Pinyon juniper 5 4 5 0.08

Ponderosa pine 5 3 11 0.07

Mixed conifer 11-18 7-13 4-7 0.11-0.14

1

Surface fuels include the total amount of fuels on the forest floor. Surface fuels include duff, grass, needles, sticks, and

small branch wood. Surface fuel loads are measured in tons per acre. 

2

Course woody debris consists of fallen dead trees and the remains of large branches on the ground in forests and 

woodlands. Course woody debris is measured in tons per acre.

3

Canopy base height is the average height from the ground surface to a forest stand's canopy bottom. 

4

Canopy bulk density is the mass of the available canopy fuel. Canopy bulk density is used to predict crown fire. 

The desired conditions for fuels and fire are to: 

• reduce the number of acres at risk to crown fires (table 8); 

• use wildland fire as a disturbance agent; 

• have the mean fire return intervals ranging from 2 to 24 years in ponderosa pine and dry

mixed conifer stands; and 

• move the planning area fuel conditions towards values or ranges described in table 10. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

12

Table 10. Desired fuel conditions by vegetation type within Luna planning area.

Vegetation Type

Surface fuel 

loading1

(tons per acre)

Coarse Woody 

Debris2

(tons per acre)

Canopy Base 

Height3

(feet) 

Canopy Bulk 

Density4

(kg/m3)

Pinyon juniper 5 5-10 4-6 <0.05

Ponderosa pine 7-14 5-7 >18 <0.05

Mixed conifer 2-4 10-15 >5-10 <0.08

1

Surface fuels include the total amount of fuels on the forest floor. Surface fuels include duff, grass, needles, sticks, and

small branch wood. Surface fuel loads are measured in tons/acre. 

2

Course woody debris consists of fallen dead trees and the remains of large branches on the ground in forests and 

woodlands. Course woody debris is measured in tons/acre.

3

Canopy base height is the average height from the ground surface to a forest stand's canopy bottom. 

4

Canopy bulk density is the mass of the available canopy fuel. Canopy bulk density is used to predict crown fire. 

Watershed and Aquatics

All or portions of nine 6th code watersheds are in the Luna planning area (table 11). In 2015, 

watershed condition ratings were determined by a qualitative assessment of twelve indicators. 

These indicators include water quality, water quantity, aquatic habitat, aquatic biota, riparian and 

wetland vegetation, roads and trails, soils, fire regime and wildfire, forest cover, rangeland 

vegetation, terrestrial invasive species, and forest health. The indicators were given a rating of 

functioning properly, functioning at risk or impaired. A composite score was derived from these 

ratings to give an overall watershed condition rating. Watersheds that are rated in Class 2 or 

Class 3 condition have several indicators that are not functioning properly. Examples of this 

include poor road drainage, high erosion rates, degraded riparian conditions, fragmented aquatic 

habitat, recent high severity wildfire, noxious weed infestation, decline in perennial water, and 

road and stream conflicts.

Aquatic and riparian obligate species are being impacted by impaired watersheds. High sediment 

loads and temperatures, lack of woody debris in the channel, lack of mature, multi-story riparian 

vegetation, and exotic species are some of the conditions present. 

The desired conditions for watershed and aquatics are:

• all 6th code watersheds are rated as class 1, functioning properly; 

• all streams meet New Mexico State water quality standards; and 

• have a healthy, diverse riparian corridor that supports aquatic species and riparian 

obligates 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

13

Table 11. 6th code watersheds in the Luna planning area. Summary of the 2015 watershed 

condition rating and number of streams in non-attainment of New Mexico State water quality 

standards. 

6th Code Watershed1

2015 Watershed 

Condition Rating(*)

Number of Streams / Stream Name 

in Non-Attainment of State Water 

Quality Standards (**)

Trout Creek Class 2 0 

Stone Creek-San Francisco River Class 2 1 / San Francisco River

SA Creek Class 2 0 

Outlet Centerfire Creek Class 3 1 / Centerfire Creek

Big Canyon-San Francisco River Class 2 1 / San Francisco River

Headwaters Centerfire Creek Class 2 1 / Centerfire Creek

Spur Draw Class 2 0 

Dry Blue Creek Class 2 0 

Canovas Creek-Coyote Creek Class 2 0 

1 The nine watersheds listed make up the majority of the project area. Several other watersheds are impacted by the 

project, however less than 5 percent of the project area is within each of these watersheds.

(*)Class I = Functioning Properly; Class 2 = Functioning at Risk; Class 3 = Impaired Function 

(**)2016-2018 State of New Mexico Clean Water Act section 303(d)/305(b) Integrated List and Report: San Francisco 

River listed for exceedances of benthic-macroinvertebrate bioassessments, water temperature, Escherichia coli and 

turbidity; Centerfire Creek listed for exceedances of Escherichia coli, nutrient/eutrophication biological indicators, 

sedimentation and siltation, specific conductance, water temperature, and turbidity. 

Wildlife

The Luna planning area is located in the Upper Gila Mountain recovery unit for the Mexican

spotted owl. On the Gila National Forest, the Mexican spotted owl occupies mixed conifer and 

ponderosa pine/Gambel oak vegetation types, usually characterized by high canopy closure, high 

stem density, multi-layered canopies within the stand, numerous snags, and downed woody 

material.

One of the primary concerns for the Mexican spotted owl is the potential loss of habitat from

uncharacteristic wildfire (USFWS 2012). Crown fire potential was analyzed, approximately 68 

percent of the planning area is at risk to torching and passive and active crown fire (table 7). 

The habitat outside Mexican spotted owl protected activity centers is managed for northern 

goshawk habitat. Portions of the northern goshawk post-fledging family areas is characterized as 

having dense, small-diameter, young ponderosa pine trees. Many of these stands are also at risk 

to torching, passive, and active crown fire. 

Browse for big game species across the planning area is decadent with little regeneration to 

provide forage for wildlife. 

The desired conditions for wildlife are:

• having a range of diverse habitats for fish and wildlife populations; 

• improving habitat for threatened or endangered species; 

• reducing the risk of high severity fire within Mexican spotted owl and northern goshawk 

acres identified for treatment;
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

14

• increasing diversity in age, size, and structure of stands within northern goshawk habitat; 

and 

• increasing diversity, productivity, and abundance of browse species (e.g., mountain 

mahogany, Gambel oak) for wildlife game species

Purpose and Need for Action 

The purpose of the Luna Restoration Project is to create and maintain a healthy resilient 

landscape and watersheds capable of delivering benefits to the public including clean air and 

water, habitat for native fish and wildlife, forest products, and outdoor recreation opportunities. 

There is a need to:

• reduce the impacts of high severity fire on natural and cultural resources, private 

inholdings, communities, infrastructure, and livelihoods within the planning area; 

• implement vegetative treatments to restore departed landscapes that are, overstocked, 

encroached, and at risk to fire, disease, insects, and climate stressors;

• implement treatments in watersheds that are not properly functioning;

• improve water quality by hardening stream crossings and performing road maintenance; 

• continue to provide the wide range of forest products that are important to the culture, 

tradition and livelihoods of local communities; 

• protect and restore threatened and endangered species and habitats; 

• provide opportunities for off-highway vehicle use, enjoyment, and access from the 

community of Luna; 

• provide permanent water supplies to support wildlife and livestock; and 

• improve rangeland, wildlife, aquatic and riparian habitat. 

The Gila forest plan as amended (USDA Forest Service 1986) will need “project-level” 

amendments specifically applicable to the Luna Restoration Project. 

Previous Decisions 

This project is proposing restoration to grasslands and watersheds however, this analysis will not 

change the range management decisions for allotments within the planning area. 

The Gila National Forest travel management record of decision was signed in 2013 and has 

implemented the decision with publication of motor vehicle use maps forestwide. The Travel 

Management Rule (USDA Forest Service. 2005) provides for flexibility and revision of 

designations to the motorized system (36 CFR 212.54), which states 

Designations...pursuant to section 212.51 may be revised as needed to meet changing 

conditions. Revisions of designations shall be made in accordance with the requirements 

for public involvement in section 212.52, the requirements for coordination with 

governmental entities in section 212.53, and the criteria in section 212.55, and shall be 

reflected on a motor vehicles use map pursuant to section 212.56. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

15

Modified Proposed Action 

The proposed action for the Luna Restoration Project was published on May 19, 2016. The 

proposed action has been modified and fully described under alternative B in chapter 2. 

Changes between the proposed action and the modified proposed action include acres of

prescribed fire only; removal of site preparation activities in the Wallow Fire; clarification of 

stream, riparian, and wet meadow activities; additional water systems and wells; a change in 

route designations for all-terrain vehicle and utility task vehicle use; no heavy maintenance on 

level 2 roads; and re-opening roads, decommissioning roads, or both. 

The modified proposed action is designed to achieve the purpose and need with proposed 

treatments to move toward the improvement and restoration of the structure and function of 

vegetation and watersheds in the project area. Treatments are briefly described below. 

Restoration treatments and the general locations are described in chapter 2. Initial and 

maintenance treatments will take place over the next 8 to 10 years, extending up to 20 years or 

until objectives are met. 

Restore the Structure, Function, and Resilience of Forests 

• Mechanically treat (cut and remove) trees to reduce tree density and provide age and size 

class diversity within the stands. 

• Use prescribed fire to create and maintain open conditions, restore natural fire, and reduce 

natural and activity fuels. 

• Enhance and promote browse species including gamble oak and mountain mahogany for 

wildlife through cutting, burning, or both. 

Improve the Function of Riparian Areas and Streams, Vegetative 

Diversity, and Water Quality 

• Plant trees, shrubs, and native grasses to enhance native riparian vegetation. 

• Place structures, plant vegetation, or both in or near stream channels to stabilize 

streambanks. 

• Improve or harden road and motorized trail crossings at streams to reduce sedimentation. 

• Maintain erosion control or stabilization structures located across the planning area. 

• Develop waters to improve livestock and wildlife distribution. 

• Remove encroaching pine and juniper species from meadow margins to restore and 

increase meadow habitat. 

• Reduce density of rabbitbrush to improve grassland habitat. 

Reduce Impacts from Roads and Project-Related Access

• Decommission roads. 

• Maintenance of existing National Forest System roads used for project-related access. 

• Construct temporary roads and decommission them after use. 

• Re-open existing closed roads and close or decommission them after use. 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

16

Forest Plan Amendments 

Chapter 2 has a detailed discussion of the forest plan amendments needed for implementation. 

Decision Framework 

The forest supervisor is the responsible official for this decision. Based on the environmental 

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

• whether to select the no-action alternative; 

• whether to select the modified proposed action, another action alternative, or an action 

alternative that is modified as described in the final decision; and 

• which forest plan amendments to include in the final decision 

Public Involvement 

This project has been listed on the Gila National Forest’s schedule of proposed actions (SOPA)

since October 2015 and periodically updated. It was originally listed as Luna Planning Area and

was changed to its current name of Luna Restoration Project in the July 2016 schedule of 

proposed actions. 

Prior to scoping the proposed action, the Quemado Ranger District staff hosted two open houses 

in the community of Luna, New Mexico on December 10, 2014 and May 7, 2015 to have 

discussions with stakeholders on identifying issues, concerns, and restoration opportunities 

within the planning area. In between those open houses, over 200 letters, dated February 2, 2015, 

were sent to individuals, Tribes, organizations, and agencies introducing the planning area and 

requesting help in identifying and shaping the activities needed within the area. Also, on July 21, 

2015, Gila National Forest staff met with members of the Luna Community who had great 

interest in all-terrain vehicle and utility task vehicle recreational-related access opportunities. 

The comments received during these events assisted in the development of the proposed action. 

The notice of intent was published in the Federal Register on May 19, 2016. The notice of intent 

asked for public comment on the proposal for 45 days ending on July 5, 2016. We mailed the 

proposed action to approximately 270 people and held an open house on June 8, 2016 at the 

Luna Community Center, in Luna, New Mexico. The open house provided an opportunity for 

interested parties to review project maps, ask questions, and provide input to the proposed 

project. In response, we received 27 letters and emails. The content of the letters and emails 

formed the basis of the alternatives (see “Issues” section) and environmental analysis. 

Tribal Consultation 

Tribal consultation for the Forest Service is guided by a variety of laws, executive orders and 

memoranda, as well as case law. Laws include the National Historic Preservation Act of 1966 

and subsequent amendments (Public Law 89-665, 15 October 1966), Archaeological Resources 

Protection Act of 1979 (Public Law 96-95, 16 U.S.C. 470aa-mm, 31 October 1979), American 

Indian Religious Freedom Act of 1978 (Public Law 95-341, U.S.C. 1996 and 1996a, 11 August 

1978), National Environmental Policy Act of 1969 (NEPA) (Public Law 91-190, 42 U.S.C. 

4321-4347, 1 January 1970), Native American Graves Protection and Repatriation Act of 1990 

(Public Law 101-601, 16 November 1990), and National Forest Management Act of 1976 

(NFMA) (Public Law 94-588, 22 October 1976, codified in 36 CFR 219). Executive orders and 
Chapter 1. Purpose of and Need for Action 

Luna Restoration Project 

Draft Environmental Impact Statement

17

memoranda include a 1994 memorandum on government-to-government relations with Native 

American Tribal Governments (59 FR 85, 4 May 1994), Executive Order 13007 on 

accommodation of sacred sites (61 FR 104, 29 May 1996), and Executive Order 12898 on 

environmental justice (59 FR 32, 16 February 1994). 

The Gila National Forest staff is committed to, and has conducted, Tribal consultation and 

provided documents associated with the National Environmental Policy Act during the scoping 

period. These consultations were carried out at the government-to-government level, ensuring 

that interested Tribes were given the opportunity to participate in the planning process as 

required in the National Environmental Policy Act and elsewhere. The Gila National Forest staff 

will continue to engage in ongoing Tribal consultation through all of the National Environmental 

Policy Act phases for this project. The following 12 Tribes or chapters were consulted with: 

• Alamo Navajo Chapter

• Fort Sill Apache Tribe

• Mescalero Apache Tribe

• Pueblo of Acoma

• Pueblo of Laguna

• Pueblo of Zuni

• Ramah Navajo Chapter

• The Hopi Tribe

• The Navajo Nation

• San Carlos Apache Tribe

• White Mountain Apache Tribe

• Ysleta Del Sur Pueblo

Issues 

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

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

proposed action. Non-significant issues were identified as those: 1) outside the scope of the 

proposed action; 2) already decided by law, regulation, forest plan, or other higher level 

decision; 3) irrelevant to the decision to be made; or 4) conjectural and not supported by 

scientific or factual evidence. The Council on Environmental Quality National Environmental 

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

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

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

their categorization as non-significant may be found in the project record.

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

Vegetation Treatments 

• Just cutting juniper is not an effective means of treatment (Comment 7.3) 

• Mowing does not reduce rabbitbrush (Comment 11.11; 27.11) 

Result: Develop an alternative to include use of herbicides as part of proposed activities within 

juniper and rabbitbrush treatment areas. 
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Draft Environmental Impact Statement

18

Fuels Treatments

• Burning mixed conifer canyons east of U.S. 180 could result in high-severity fire, 

impacting wildlife travel routes (Comment 27.16)

• Proposed activities are not improving or protecting Mexican spotted owl habitat 

(Comment 26.18; Comment 27.12) (less than 9 inches thinning, limited burning) 

Result: Modify the proposed action to add acres south of Luna along Frisco Divide for 

prescribed fire only. Burning prescriptions will include high-moisture and low-intensity

parameters.

Routes 1 

• 50 inches limits access by utility task and side-by-side vehicles (Comment 10.1; Comment 

25.1) 

Result: Modify the proposed action to change proposed motorized routes less than 50 inches to 

routes allowing for the use of utility task and side-by-side vehicles. 

Routes 2

• Provide motorized access for Tucson Electric Power maintenance (Comments 20.4, 20.5, 

20.7) 

Result: Modify the proposed action to provide access for Tucson Electric Power (TEP) to 

perform powerline maintenance activities. 

Routes 3

• User routes should not be added to the National Forest System of roads and trails 

(Comment 26.12; 26.14) 

• The proposed loop route roads (4134, 4019 H, etc.) should not be opened to motorized use 

due to going through wet meadows and Dillman Creek. (Comment 27.29) 

• Opening user all-terrain vehicle route down Adair Canyon will increase wildlife 

disturbance and multiple drainage crossings (Comment 27.30) 

Result: Develop an alternative which does not add user routes or closed roads to the open 

motorized National Forest System roads except for those providing access to Tucson Electric 

Power powerline. 
Luna Restoration Project 

Draft Environmental Impact Statement

19

Chapter 2. Alternatives, Including the 

Proposed Action 

Introduction 

This chapter describes the alternatives considered for the Luna Restoration Project. The 

interdisciplinary team used the significant issues identified under the “Issues” section of chapter 1 to 

modify the proposed action or develop alternatives to the modified proposed action. 

There are many similarities in proposed activities between all action alternatives. Because of this, the 

alternatives will be described in the following manner: 

• Alternative A, no action, is a stand-alone description. 

• Alternatives B, C, and D are displayed and described by each proposed activity type

(vegetation, fire, range management, stream and riparian, etc.). 

This chapter is outlined this way to minimize describing similarities between alternatives and to 

maximize attention to the differences of proposed activities within their specific alternative. 

Alternatives Considered in Detail 

Alternative A – No Action

The no-action alternative is required by 40 CFR 1502.14(d). There would be no changes in current 

management and the forest plan would continue to be implemented. There are currently no ongoing 

vegetation, prescribed fire, or other restoration type projects within the planning area. Activities such 

as road maintenance, recreation, and fuelwood gathering would continue. Activities that have been 

authorized in separate decisions such as special use permits (for example, powerline corridors, 

communication towers, etc.), travel management implementation, and authorized livestock grazing 

would continue. Alternative A is the baseline for assessing and comparing effects of the action 

alternatives B, C, and D. 

Alternatives B, C, and D by Proposed Activity Types

Activities Common to all Action Alternatives

All proposed activities may require the use of varying types and sizes of motorized vehicles off of 

roads or trails designated open to the public or for administrative use only; that is, travel crosscountry or on closed roads during implementation. Cross-country travel will be authorized by the line 

officer on a case-by-case basis. 

Vegetation Treatments 

The following vegetation treatments are the same for alternatives B, C, and D (table 12, MAP 2 and 

MAP 3). There are no differences in the location, acres, or proposed treatments between alternatives. 
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Table 12. Acres of vegetation treatments by action alternative and map reference number.

Vegetation Treatments Alternative B Alternative C Alternative D MAP Number

Woodland (juniper and pinyon pine) 

mechanical treatments [acres] 20,328 20,328 20,328 MAP 2

Forested (ponderosa pine and mixed 

conifer) mechanical treatments [acres] 53,529 53,529 53,529 MAP 2

Total acres mechanical treatments 73,856 73,856 73,856 NA

Grassland tree removal (ponderosa 

pine, juniper spp.) [acres] 20,283 20,283 20,283 MAP 3

Grassland wet/upland meadow and 

valley bottoms tree removal (ponderosa 

pine, juniper spp.) [acres] 2,842 2,842 2,842 MAP 3

Total acres grassland treatments 23,125 23,125 23,125 NA

Mexican spotted owl protected activity 

centers - thin trees <9 inches, pile or 

broadcast burn [acres] 1,319 1,319 1,319 MAP 2

Treat gambel, gray oak and mountain 

mahogany stands by cutting and/or 

prescribed burning Yes Yes Yes N/A

Woodland and Forest – Maintenance and Restoration: Woodland (for example, juniper, pinyon 

pine) and forest (ponderosa pine and mixed conifer) maintenance and restoration treatments are 

proposed on approximately 73,856 acres. Cutting of vegetation will be accomplished by hand or 

mechanized equipment. In forested systems activities would include thinning and group selections 

(for example, creating 1/8- to 4-acre openings). 

Treatments would favor healthy co-dominant and dominant trees for retention 

Treatments could be accomplished through commercial, noncommercial, and fuelwood gathering 

activities. 

Grassland – Maintenance and Restoration: Grassland maintenance and restoration treatments are 

proposed on approximately 23,125 acres. Ponderosa pine and pinyon-juniper have encroached, 

become established, and continue to spread into the grasslands. Proposed activities consist of cutting 

ponderosa pine and pinyon-juniper by hand or mechanized equipment, to reduce tree canopy cover to 

less than 10 percent in grasslands. Treatments located in upland wet meadows and valley bottoms 

primarily associated with Jenkins Creek, Badger Creek, Romero Creek, Stone Creek, Dry Blue, San 

Francisco River, Dillman Creek, and Trout Creek areas

Material may be lopped and scattered or chipped and scattered in upland wet meadows and valley 

bottoms. 

Mexican Spotted Owl Protected Activity Centers: Thin small diameter trees less than 9 inches on 

approximately 1,319 acres within protected activity centers. No activities would take place from

March 1 to August 31 to avoid disturbance to owls during the breeding season.

Wildlife Habitat: Cut and prescribe burn Gambel oak and mountain mahogany stands to promote 

new growth and sprouting in various locations across the planning area. This would occur in 

conjunction with other vegetation and fuel treatments.
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Design Features Common to Vegetation Treatments: 

• Follow appropriate best management practices for vegetation management activities (e.g., 

forestry, logging, roads). 

• Retain hardwoods and minimize damage during operations. 

• All proposed activities may require the use of motorized vehicles off designated or 

administrative roads or trails; that is, cross country during implementation. 

• To avoid impacts on southwestern willow flycatcher critical habitat, critical habitat would be 

buffered and no vegetation treatments would be implemented within critical habitat. 

• To avoid impacts on narrow-headed gartersnake proposed critical habitat, critical habitat would 

be buffered and no vegetation treatments would be implemented within critical habitat. 

Vegetation Treatments – Herbicide Treatments

The following treatments are for rabbitbrush and treatment of rabbitbrush and alligator juniper using 

herbicide (table 13, MAP 3 and MAP 4). There are differences in proposed treatments in alternative 

C. Treatments in alternative B and D are the same. 

Table 13. Acres of rabbitbrush, alligator juniper, and herbicide use by alternative and map reference 

number.

Vegetation Treatments Alternative B Alternative C Alternative D

MAP 

Number

Rabbitbrush treatment with mowing 

only [acres]

20,283 0 20,283 MAP 3 1

Rabbitbrush herbicide application with 

or without mechanical assistance (e.g. 

mowing) [acres]

0 Up to 20,283 0 MAP 4

Alligator juniper herbicide application in 

grassland meadows [acres] 2

0 30 0 MAP 4

Alligator juniper herbicide application in 

woodlands and grasslands [acres] 2

0 up to 8,000 0 MAP 4

1 Grassland polygons on MAP 3 correspond to same treatment areas for rabbitbrush.

2 Acres for alligator juniper are a subset of the acres in table 12 describing acres of vegetation treatments. 

Rabbitbrush Overview: There are approximately 23,125 acres of grassland vegetation community 

within the planning area. Of that, approximately 20,283 has been proposed for the treatment of 

rabbitbrush under all of the action alternatives. Green and rubber rabbitbrush are native shrubs that 

grow widely across western United States rangelands. Though they can appear as a weedy 

monoculture (especially following disturbance), they are early colonizers, and their presence can be 

reduced under improved management regimes (USDA Forest Service, 2015). The objectives of the 

proposed treatments are to manage rabbitbrush and reduce the occurrence of dense stands or 

monocultures of rabbitbrush; not to eliminate rabbitbrush across the planning area. The objectives can 

be met by treating existing stands to allow for the replacement of rabbitbrush by desired herbaceous 

vegetation and shrubs; and through management of grasslands to prevent the establishment of dense 

stands of rabbitbrush. 
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Alternatives B and D 

Alternatives B and D would only include mowing for rabbitbrush treatment. Under these alternatives 

dense stands of rabbitbrush would be identified for mowing and reseeding to break up these 

communities and allow for the replacement by more desirable vegetation. Mowing alone could 

require multiple entries into the site to deplete the plants energy stores enough to achieve limited 

mortality in rabbitbrush. Single-entry mowing would only suppress top growth in rabbitbrush and 

would not result in long term alteration of the plant community. Mowing would be limited to those 

areas that are accessible to mowing equipment and where mowing would not result in resource 

concerns. 

Alternative C

Alternative C would incorporate the application of herbicide on rabbitbrush and alligator juniper. Pretreatment of vegetation may be needed before application of herbicide using such things as 

chainsaws, mowing, or other type of mechanical equipment to assist in exposing the part of the plant 

recommended for effective treatment. For alligator juniper, herbicide could be applied in identified 

acres in conjunction with mechanical treatments. For rabbitbrush, herbicide could be used in 

conjunction with mowing or on its own in locations where mowing is not feasible. The herbicide 

selected, timing of application, species and subspecies treated, and soil type are important factors for 

success. 

The application of herbicide would follow all Federal, State, and local laws and all herbicide label 

requirements. Herbicides selected for use for the management of rabbitbrush and alligator juniper

would be those approved through the environmental assessment for noxious weed management on the 

Gila National Forest (USDA Forest Service 2000). 

No aerial application of herbicides will occur. All applications will be by hand spraying (liquid), hand 

spreading (granular or powder), or broadcast using a small tractor or all-terrain or utility task vehicle 

towing a spreader. Rubber-tired mechanical equipment will be used.

Design Features Specific to Herbicide Treatments

The following design features and best management practices would be considered in the use of 

herbicide: 

• Avoid or minimize the risk of soil sand surface water or groundwater contamination by 

complying with all label instructions and restrictions required for legal use.

• Herbicide application would occur under the supervision of a licensed applicator and in 

accordance with Federal, State, and local laws, regulations, and policies. 

• When applying near private lands, maintain a buffer between treatments and private land to 

avoid effecting vegetation on private lands. 

• When applying near private lands, provide adequate notification and post appropriate signing. 

• Evaluate surface drainage patterns in treatment area and establish 300-foot buffer zones from 

surface water, wet meadows, and riparian areas. Avoid treatment in channel or ditch 

connections that lead to surface water, wet meadows, and riparian areas.

• Do not direct spray toward any open water. 

• Mixing and loading would not occur near streams or other standing water. 
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• To avoid impacts on southwestern willow flycatcher critical habitat, critical habitat would be 

buffered and no herbicide treatments would be implemented within critical habitat. 

• To avoid impacts on narrow-headed gartersnake proposed critical habitat, critical habitat would 

be buffered and no herbicide treatments would be implemented within critical habitat. 

• Apply chemicals under favorable weather conditions as identified in the label instructions and 

in accordance with equipment manufactures specifications. To reduce the risk of non-target 

species being impacted, all spraying should occur with winds less than 10 miles per hour and 

greater than 1 mile per hour unless otherwise indicated in the label instructions. 

• Avoid applying chemicals before forecasted severe storm events to limit runoff and ensure the 

chemical reaches intended targets. Suspend operations if project prescription or weather 

limitations have been exceeded.

• Select herbicides that are appropriate for treating the target species and prioritize chemicals for 

use that have the following features limited half-life, limited soil mobility and limited residual 

activity. 

• Identify public water supplies, private domestic water supplies, and threatened, endangered, 

and sensitive aquatic dependent species and fish populations near or downstream of chemical 

treatment areas.

• Consider soil type, chemical mobility, distance to surface water, and depth to groundwater to 

avoid or minimize surface water and groundwater contamination. 

• Manage, store and transport chemicals in accordance with all applicable Federal, State, or local 

regulations, including label directions. 

• Prior to herbicide application identify resource concerns and mitigations specific to the 

individual treatment area.

• Herbicide application including the use of mechanical equipment for application will avoid all 

known archaeological sites.

Prescribed Fire Treatments

Alternatives B, C, and D propose the same treatment (table 14, MAP 5 and MAP 6). There are no 

differences in the location, amount or types of treatments between alternatives.

Table 14. Acres of prescribed fire only and activity fuels treatments by alternative and map reference 

number. 

Prescribed Fire Treatments Alt B Alt C Alt D MAP Number

Prescribed fire only - mixed severity 

[acres]

11,996 11,996 11,996 MAP 5

Prescribed fire only - low severity 

[acres]

24,026 24,026 24,026 MAP 5

Prescribed fire only (total) 36,022 36,022 36,022 --- 

Mexican spotted owl protected 

activity centers - broadcast burn 

(subset of prescribed fire only total)

8,399 8,399 8,399 --- 

Prescribed fire and mechanical 

treatments – low and mixed 

severity [acres]

70,000 - 

100,000

70,000 - 

100,000

70,000 - 

100,000

MAP 6
Chapter 2. Alternatives, Including the Proposed Action

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Draft Environmental Impact Statement

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Prescribed Fire - Mixed Severity: Mixed-severity prescribed fire is proposed to treat natural fuels 

and activity fuels. Mixed severity prescribed fires typically burn in a mosaic, resulting in a highly 

variable pattern of mortality on the landscape that fosters development of diverse communities. 

Pockets of tree mortality, and reduction of surface and ladder fuels is desired. 

Prescribed fire would be initiated using hand-ignition devices (drip torches, fusees, pen flare or very 

pistol, terra torch, matches), aerial-ignition devices (helicopter – ping pong balls), or both. 

Prescribed Fire - Low Severity: Low-severity prescribed fire is proposed on approximately 24,026 

acres on the north aspect of the San Francisco Divide, and southwest of Luna in the Dry Blue and 

Frieborn Canyon areas extending south to the planning area boundary. This area has limited access, 

steep topography, sensitive soils, high fuel loads, and potential for high-severity wildfire. The 

community of Luna and key infrastructure are located to the northeast. The objective of implementing 

prescribed fire is to create a mosaic of burned and unburned patches of vegetation, of varying 

acreages, on the landscape to protect values at risk. 

Low-severity prescribed fire would be introduced when fuel conditions, weather conditions, or both 

minimize fire spread across the landscape. These conditions could include rain and monsoon season; 

fall and early spring when low temperatures, high humidity, and residual snow patches limit fire 

growth. Ignitions would be patterned after a lightning storm; a number of ignitions (dots) scattered 

across an area. Desired results would be reduction of surface and canopy fuels. The end state would 

be areas treated with prescribed would eventually merge together and breakup the fuel continuity 

across a larger area. Multiple entries and time would be needed to meet these objectives. 

Prescribed fire would be initiated using aerial-ignition devices (helicopter – ping pong balls), handignition devices (drip torches, fusees, pen flare or very pistol, terra torch, matches), or both. 

Design Features Specific to Low-severity Prescribed Burning Activities

• Coordinate with Natural Resource Conservation Service to manage vegetation and fuels around 

the snow telemetry (SNOTEL) site. 

• There would be no tree removal or burning within 400 feet around the SNOTEL site except to 

cut hazard trees that have the potential to fall on the facility. 

• Notify and coordinate with infrastructure permit holders on the San Francisco Divide. 

Design Features Common to All Prescribed Burning Activities

• Prescribed fire would be implemented in any season of the year provided the burn is conducted 

within the weather and fuel conditions prescribed in the burn plan. 

• Consider using ignition patterns that allow fire to back through ponderosa pine and mixed 

conifer stands, especially on slopes greater than 40 percent, in efforts to reduce burn severity 

within the watershed.

• All slash piles (hand and machine) will be constructed to minimize disturbance to existing 

ground cover, surface soil and rock material and any existing surface organic matter material 

(surface litter and duff and old branches and logs). Piles will be constructed to minimize 

residual heat, to minimize the effects on soils. 

• Firelines would be used to facilitate broadcast burns or pile burning operations as needed. 
Chapter 2. Alternatives, Including the Proposed Action

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• Notify and coordinate with Tucson Electric Power and Navopache when burning near or within 

their powerline rights-of-way. 

• During development of burn plans, consult soil scientist and soils map for locations of soils of 

concern to determine appropriate prescriptions to minimize impacts to sensitive soils.

• Notify and coordinate with allotment permittees when scheduling and implementing treatments. 

• All burning would be coordinated and conducted in accordance with New Mexico 

Environmental Department, Air Quality Bureau smoke management rule. Emission reduction 

techniques would be utilized when possible to minimize impacts to sensitive receptors. 

• Use low-intensity prescribed fire along trails corridors to minimize the creation of snags. 

• Prescribed fire can occur within Mexican spotted owl core areas however, prescribed fire 

ignitions cannot be initiated within Mexican spotted owl core areas. Initiate firing patterns 

within and adjacent to protected activity centers which result in low-severity prescribed fire. No 

activities would take place from March 1 to August 31 to avoid disturbance to owls during the 

breeding season. 

• To minimize smoke impacts to nesting northern goshawk, no prescribed fire would take place 

from March 1 to September 30 within post-fledging family areas. 

• To avoid impacts on southwestern willow flycatcher critical habitat, critical habitat would be 

buffered and no prescribed fire treatments would be implemented within critical habitat. 

• To avoid impacts on narrow-headed gartersnake proposed critical habitat, critical habitat would 

be buffered and no prescribed fire treatments would be implemented within critical habitat. 

Range Management

Alternatives B, C, and D propose the same range improvements (table 15, MAP 7). There are no 

differences in the location, amount or types of improvements between alternatives. The types and 

quantity of improvements are summarized by allotment in table 16. 

Alternatives propose adding new or upgrading existing water systems on the Centerfire, 

Dillman/Trout Creek, Luna, Mangitas, and Spur Lake allotments to increase livestock and wildlife 

distribution to benefit rangeland conditions, including watershed, soils, and stream resources. A 

pasture division fence is proposed on the Spur Lake allotment. The proposed improvements would 

improve livestock distribution, forage utilization and management flexibility. This proposal would not 

alter the management (livestock kind, class, number or season of use) or desired conditions outlined 

in each allotment’s corresponding grazing analysis.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

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Table 15. Rangeland improvements proposed under alternative B, C, and D by allotment and pasture. 

Map symbols correspond to labels found on MAP 7.

Allotment Pasture 

Map Symbols

on MAP 7 Rangeland improvement description

Centerfire SA Pasture CF1 Bury .75 miles of existing pipeline.

Centerfire Centerfire CF2 Install 1 new well and 1 storage tank, and 1 drinker*. 

Centerfire Freeman 

Mountain 

CF5 Install 2 new trick tanks.

Centerfire Freeman CF3 Install 1 new well and 1 storage tank, and 1 drinker*. 

Dillman/Trout 

Creek 

Mesa DTC1 Install 1 new well and 1 storage tank, 2 drinkers*, and 1 

mile of pipeline

Luna Hy Clark LUNA1 Install 1 storage tank, 2 drinkers* and 1.25 miles of 

pipeline. Install 1 new well in section 12. 

Luna Sawmill, 

Kiehne, Adair 

LUNA2 Install 1 new well and 2 storage tanks, 4 drinkers*, and 

2.75 miles of pipeline.

Luna Stone Creek LUNA3 Install 1 new well and 1 storage tank, 2 drinkers*, and 

.75 miles of pipe. 

Luna Dry Blue LUNA4 Install 1 new well and 1 storage tank, 4 drinkers*, and 

2.5 miles of pipeline.

Mangitas Jones MANGITAS1 Install 1 new well and 1 storage tank, 2 drinkers*, and .5 

miles of pipeline.

Spur Lake Canovas SL5 Install 2.25 miles of pasture division fence.

Spur Lake Black Peak SL4 Install 1 new well and 1 storage tank, 2 drinkers*, and 2 

miles of pipeline.

Spur Lake SA SL1 Install 1 new well and 1 storage tank, 3 drinkers*, and 2 

miles of pipeline.

Spur Lake Jenkins Creek SL2 Install 1 new well and 1 storage tank, 3 drinkers*, and 

2.5 miles of pipeline.

* Additional storage tanks may be placed with drinkers if needed to improve functionality of water systems. 

Table 16. Summary of range improvements by type per allotment.

Allotment

Wells

(number)

Storage 

Tanks

(number)*

Drinkers

(number)

Trick 

Tanks

(number)

Pipeline 

(miles)

Fence 

(miles)

Centerfire Allotment 2 4 2 2 0.75 0 

Dillman/Trout Allotment 1 1 2 0 1 0 

Luna Allotment 4 4 10 0 7.25 0 

Mangitas Allotment 1 1 2 0 0.5 0 

Spur Lake Allotment 3 3 8 0 6.5 2.25

Total 11 13 24 2 16 2.25

* Additional storage tanks may be placed with drinkers if needed to improve functionality of water systems.

Eleven of the proposed water systems include the installation of new wells (table 16). Installation of 

these improvements is contingent on the Gila National Forest’s ability to meet the requirements of the 

New Mexico Office of the State Engineer. The improvements would require the appropriate licenses 

or water use agreements prior to implementation. In the event the Gila National Forest is unable to 

obtain a license, an alternative water source could be considered provided the effects of using that 

water source do not differ from the effects disclosed in this analysis.
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Storage tanks are available in a variety of sizes and construction materials. For the purposes of this 

project, one storage tank refers to approximately 10,000 gallons of storage capacity. This can be 

achieved through a single tank or multiple smaller tanks. Additional storage capacity may be 

necessary for the water system to function properly. Design will be reviewed prior to implementation. 

Drinkers or troughs located away from the water source and primary storage could have an associated 

3,000 to 5,000 gallon storage to improve functionality of the water system. 

All pipelines proposed within this analysis would be buried unless resource concerns or terrain would 

not allow for the ability to bury the lines below the frost level. Pipelines are buried to improve the 

functionality of the system and reduce maintenance needs.

Drinkers would be maintained to provide a year-round water source to wildlife except: 

• where the possibility of freezing could compromise the integrity of the water system; 

• where the water source is limited and not adequate to support year-round use; 

• for resource management purposes; limit water or availability so livestock, wildlife, or both

have to disperse; or 

• for general maintenance needs. 

Implementation of proposed improvements will require using motorized equipment. Motorized 

equipment will vary depending on improvement type, ranging from all-terrain vehicles and utility 

task vehicles, full-size vehicles, large trucks, up to small dozers. A helicopter may be used to deliver 

materials into some locations. 

Fence construction or reconstruction will be wildlife-compatible; that is, constructed in a manner to 

facilitate wildlife access over, under, or through the fence while minimizing chances of becoming 

entangled. The following specifications (or the most current Forest Service specifications) would be 

used during construction, where needed: 

• a top wire or rail preferably no more than 38 inches above the ground, and absolutely no more 

than 42 inches

• at least 12 inches between the top two wires 

• at least 16 inches between the bottom wire or rail and the ground 

• smooth wire on the bottom 

• posts 16 to 20 foot intervals

• utilize gates, drop-downs, or other passages where wildlife concentrate and cross

Motorized Transportation System

Alternatives B, C, and D

The following transportation activities are the same for alternatives B, C, and D (table 17, MAP 8 and 

MAP 9). There are no differences in the location, miles, or proposed treatments between alternatives.
Chapter 2. Alternatives, Including the Proposed Action

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Table 17. Types of treatments to the motorized transportation system in miles common to alternatives B, 

C, and D; and map reference number for each alternative.

Transportation Treatments Alternative B Alternative C Alternative D

MAP Number MAP 8 MAP 8 MAP 9

Road decommissioning 116 116 116

Change Admin/Written Authorization road 

segments from open to decommissioned 

(Tucson Electric Power) (miles subset of 

decommissioning)

1.7 1.7 1.7

Leave horse, hiking and foot trail tread during 

decommissioning of roads

4.23 4.23 4.23

Reopen maintenance level 1 closed roads for 

administrative or permitted use for proposed 

treatment activities and close or decommission 

after activities are completed

34.5 34.5 34.5

Maintenance Level 1 Administrative or permitted 

use roads to be closed after activities completed

22.6 22.6 22.6

Maintenance Level 1 Administrative or permitted 

use roads to be decommissioned after activities 

completed (miles are subset of total road 

decommissioning)

12 12 12

Add user-created route and designate as 

administrative use or written authorization only 

(Tucson Electric Power) 

0.5 0.5 0.5

Construct temporary roads - obliterate after 

vegetation treatments are completed

3-5 3-5 3-5 

Reopen closed roads for periodic administrative 

use or written authorization only (Tucson 

Electric Power) 

3.5 3.5 3.5

Road decommissioning are activities that result in the stabilization and restoration of unneeded roads 

to more natural states (36 CFR section 212.1). Decommissioning includes utilization of heavy 

equipment to install signs, gates, rock barriers, or ripping and recontouring of slopes and installing 

drainage features such as water bars. Routes that have established vegetation may need minimal 

treatment while others may need to be entirely ripped, seeded and slopes recontoured. 

A trail tread for horse and hiking or foot access would be maintained on National Forest System 

Roads 4023 V, 4029 E, and 4030 W during design and implementation of decommissioning. 

Heavy equipment would be used to re-open closed roads for project activities or administrative uses. 

These roads would be returned to closed status once activities are completed expect for those needed 

by Tucson Electric Power Company to access powerlines. To restrict motorized access such things as 

berms, gates, or other barriers would be installed. 

Add user routes as part of the national forest road system to facilitate Tucson Electric Power 

Company to access lines. These roads would be designated administrative use only. 

Construct temporary roads to access treatment activity areas and obliterate after treatments are 

completed. Obliteration is a full restoration of entire temporary roadbed, utilizing the same equipment 

and methods described in decommissioning. 
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Alternative D

Alternatives B and C provide the same motorized transportation opportunities to address recreation 

and public motorized uses (table 17, MAP 8). Alternative D was developed in response to a scoping 

comment to not increase miles of forest system roads (table 18, MAP 9). The decision for re-opening 

of 0.2 miles of National Forest System Road 3050 was made in the 2013 travel management record of 

decision, so remains in alternative D unlike the other routes (table 18). The type of work and 

equipment to re-open 3050 is the same as described in alternatives B and C. 

Under alternative D, the 13.6 miles of maintenance level 1 road will be added to the decommissioning 

miles, bringing the total miles of roads to be decommissioned to 130 miles for alternative D. 

Table 18. Changes to road system in miles by alternative.

Transportation Treatments Alternative B Alternative C Alternative D

Reopen national forest system

maintenance level 1 closed roads to open 

to all motor vehicle types

13.8 13.8 0.2

Add user-created routes and designated 

as National Forest System roads open to 

all motor vehicle types

4.2 4.2 0 

Construct motorized 4x4 trail (Dillman 

Creek Re-route)

0.3 0.3 0 

The Dillman Creek reroute is a 4x4 motorized trail, to be constructed to a maximum trail tread width 

of 60 inches, with an obstacle clearing limit width of 72 inches, utilizing mechanized equipment. 

Barriers would be installed at each end of the 4x4 trail segment to limit vehicle size access.

Design Features Common to All Road Activities

• All roads, temporary or permanent, will be located sufficiently far from streams or other water 

bodies (except for portions of such roads which must cross water bodies) to minimize 

discharges of dredged or fill material into waters. 

• All temporary roads would be designed to minimize impacts to natural resources. 

• Follow appropriate best management practices for roads management. 

Stream and Riparian Treatments

Alternatives B, C, and D propose the same stream and riparian treatments (table 19, MAP 10). There 

are no differences in the type, number or location of treatments between alternatives. Although route 

LATV-9 would not be implemented under alternative D, work is still proposed on the crossing in 

alternative D to address sedimentation concerns.
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Table 19. Summary of the type, number and location, including MAP 10 reference symbols, in [ ], of 

stream and riparian treatments for all action alternatives. 

Type of Work Number Location

Crossing 10 National Forest System Road882 Head of Ditch CG; [Map Symbol X2]

Dry Blue Trail #61 (6 crossings); [Map Symbol DB1-DB6]

County Road B-012; [Map Symbol X1]

FSR4127U; [Map Symbol X3]

LATV-9; [Map Symbol X4] 

Diversion 1 Luna Ditch Diversion point in Head of Ditch Campground; [Map 

Symbol X2]

Exclosure 4 Stone Creek

Centerfire Creek

Spur Lake Draw

Adair Spring

Barriers 2 Construct motor vehicle barriers Frieborn Trail [Map Symbol DB7]

Construct motor vehicle barriers Blue Spring Trail; [Map Symbol DB8]

Riparian 2 Centerfire Creek, Spur Lake Draw

Erosion Control

Maintenance

157 Existing erosion control features located across the planning area

[Map symbol yellow triangles]

Seeding multiple Spur Lake Draw

Stream and bank 

structures 

9 streams, 

multiple

Instream structures, bank stabilization, or both: Bishop Canyon, 

Romero Creek, Dry Blue, Pace Creek, Centerfire Creek, San 

Francisco River, Stone Creek, Spur Lake Draw, Jenkins Creek, 

Canovas Creek

Surface erosion 

reduction

2 Head of the Ditch Campground roads; [Map Symbol X2]

Trout Creek dispersed camping area; [Map Symbol Trout Creek]

Crossings: Within the Dry Blue, harden 6 motorized trail crossings to reduce impacts to aquatic 

habitat and improve water quality. Hardening of crossing may consist of such things as interlocking 

concrete blocks, concrete planks, prefabricated bridges, rock rip-rap, or other engineered design. 

Equipment such as a Kabota or small backhoe may be used to dig footings for bridge type structures 

or carrying in construction materials. A helicopter may be used to transport pre-fabricated structures. 

Road crossings at County Road B-012; National Forest System Road 4027 U, LATV-9 will be 

designed to facilitate adequate water passage and reduce erosion. Work may include such things as 

replacement or upgrade of existing structures or material or placement of structures or material (for 

example, culverts, rock, rip-rap, and fill). All work will utilize some type of heavy equipment such as 

dozers, backhoe, trucks, etc. 

National Forest System Road 882 (Head of Ditch campground road) will be relocated due to being 

located within the proposed Luna Irrigation Ditch diversion facility project area. The new crossing 

will be located upstream of its current location and hardened to provide safe ingress and egress for the 

public and landowners, and improve aquatic habitat and water quality. All work will utilize some type 

of heavy equipment such as dozers, backhoe, trucks, etc.

Diversion: The Luna Irrigation Ditch Association owns water rights on the San Francisco River 

which allows them to store water in Luna Lake, upstream in Arizona, and release this water 

downstream into New Mexico during irrigation season. The diversion is located in the Head of Ditch 

Campground downstream of National Forest System Road 882. 
Chapter 2. Alternatives, Including the Proposed Action

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The current diversion is a “push-up” style native soil dam located on the Gila National Forest that 

requires frequent maintenance by heavy equipment, particularly following flood events. The diversion 

takes all of the stream flow (except for floods) from May 1 to September 30th of each year, leaving no 

water in the main channel until the stream reaches the first tributary downstream. 

The proposal is to construct a permanent diversion facility in the same location, replacing the existing 

diversion, out of durable material, such as concrete, steel, etc. The base would extend the width of the 

stream channel and be tied into the stream banks and protected with concrete wings, riprap, or both. 

The facility would be a dual channel system with easy to move and install panels for easy channel 

switching between irrigation and non-irrigation periods. The proposal includes construction of a 

sediment retention pool upstream of the facility. Construction of the diversion facility, sediment 

retention pool and any other associated activities would require use of heavy equipment (for example,

backhoe, dozer). There would be activities within and adjacent to the stream channel to implement 

this project. Best management practices and design features will be implemented to reduce impacts to 

stream resources and appropriate permitting obtained to conduct instream work. 

Exclosures: Exclosure fences are proposed to be constructed along segments of Stone Creek, 

Centerfire Creek, Spur Lake Draw, and Adair Spring. Exclosures would exclude both wildlife and 

livestock providing time for proposed riparian, stream and bank restoration projects to establish. 

Exclosures would be from 0.5 acres up to 200 acres. Once the area stabilizes or vegetation becomes 

established, the exclosure would be relocated to the next reach to continue restoration work. 

Where access to water is needed for livestock management, the Gila National Forest staff and 

permittees will coordinate to identify appropriate location(s) for water access points. 

Fencing would be 8 feet or taller to exclude both wildlife and livestock. Motor vehicles may be 

needed to haul fencing materials. A small drill rig or hand drill rig may be used for digging post holes. 

Barriers: The Frieborn and Blue Spring Trails are designated and constructed for use by hikers and 

horses. These trails intersect the Dry Blue Trail, which is designated for all-terrain vehicle use. 

Motorized vehicles off of the Dry Blue Trail have been accessing the nonmotorized Frieborn and Blue 

Spring Trails causing resource concerns and conflict of recreational uses. 

Barriers are proposed to block access by motorized vehicle to these trails. Access for hikers and 

horses would be maintained. 

Motor vehicles may be needed to haul barrier construction materials. A hand drill rig (auger) may be 

used for digging post holes. 

Riparian: Proposed riparian restoration includes planting riparian species in Spur Lake Draw in areas 

above Centerfire Bog and in Centerfire Creek near the vicinity known as Pinpoint 40 and within 

perennial headwater reaches. Planting would provide bank stabilization, improve water temperature, 

and enhance overall water quality. 

Motor vehicles may be needed to haul equipment and plants. Most planting activities would utilize 

handtools, but there may be a need for a small backhoe to dig trenches.

Erosion Control Features: Numerous erosion control or stabilization structures exist within the 

planning area. It is proposed to conduct maintenance on existing structures. Maintenance of structures 

will vary depending on condition of the structure. Work may include such things as removing 
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accumulated sediment, repairing or replacing breeched sections where new head cuts and gullies are 

developing. 

Seeding: Improve water quality and quantity by seeding the uplands in multiple locations in Spur 

Lake Draw. The objective is to increase herbaceous ground cover to slow down overland flow and 

reduce erosive processes. Sourcing of seed material will follow Region 3 guidance on weed free 

materials. Seeding activities would be by hand or trailer type seeders pulled behind motorized 

vehicles appropriately sized for the trailer type. 

Stream and Bank Stabilization Structures: Structures in the uplands may be constructed out of onsite native material, rock rip-rap, rock and wire rip-rap, or other proven methods. In-channel 

structures may be constructed utilizing on-site native material, rock rip-rap, rock weirs, bendway 

weirs, wooded material or other proven methods. 

Surface Erosion Reduction: To reduce surface erosion, gravel would be placed on roads within 

Head of Ditch Campground and on the access route to the dispersed camping area along Trout Creek. 

Heavy equipment would be used to transport and spread gravel over the proposed locations. 

Design Features Common to Stream and Riparian Treatments

• Surveys for loach minnow and narrow-headed and northern Mexican gartersnakes will occur 

prior to implementation of stream and riparian treatments within Dry Blue Creek and its 

tributaries, where applicable. Appropriate methods to reduce impacts to the species would be 

applied prior to implementation if detected. 

• Surveys for narrow-headed and northern Mexican gartersnakes will occur prior to 

implementation of stream and riparian treatments within the San Francisco River and its 

tributaries, where applicable. Appropriate methods to reduce impacts to the species would be 

applied prior to implementation if detected. 

Forest Plan Amendments

Alternatives B, C, and D propose the same forest plan amendments. There are no differences in 

amendments between alternatives.

Project-specific amendments to the Gila forest plan will be prepared under the 2012 Planning Rule. 

These project-specific amendments are a one-time amendment to the Gila forest plan for related 

activities proposed and to be implemented under the Luna Restoration Project only. These projectspecific amendments include:

• Allow a one-time, project-specific amendment to the forest plan to allow the Gila National 

Forest to deviate from forest plan standard and guidelines for Management Areas 3B (p. 105-

106), 3C (p. 112), and 3D (p.118) to exceed the acres per decade for the amount of activity 

fuels treated (10,000, 4,000, and 12,000 respectively) and fuels treated with prescribed fire 

(10,000, 3,000, and 10,000 respectively).

♦ Replace with: “No more than 25 percent of a 6th code watershed within a 3-year period 

would be treated. Percentage may be adjusted up or down based on monitoring and 

assessment of watershed conditions, after treatments.” 
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• Allow a one-time, project-specific amendment to the forest plan to allow the Gila National 

Forest to deviate from forest plan standard and guidelines in Management Area 3D (p. 115) to 

exceed the amount of wildlife habitat development numbers (water developments-1 structure; 

wetland developments-8 structures; brush pile development-10 structures; prescribed burns1,000 acres; planting browse/riparian-10 acres; control of habitat access-10 miles).

♦ The standard and guidelines will be removed and will not be replaced with another. 

• Allow a one-time, project-specific amendment for Mexican spotted owl protected activity 

center fuel accumulation treatments to abate fire risk (page 29a 1995 Mexican spotted owl 

recovery plan elements): 

♦ Select for treatment 10 percent of the protected activity centers where nest sites are known 

in each recovery unit having high fire risk conditions. Also select another 10 percent of the 

protected activity centers where nest sites are known as a paired sample to serve as control 

areas.

♦ Select and treat additional protected activity centers in 10 percent increments if monitoring 

of the initial sample shows there were no negative impacts or there were negative impacts 

which can be mitigated by modifying treatment methods. 

 Replace with 2012 Mexican spotted owl recovery plan (page 74): Conduct restoration

and fuels treatments in up to 20 percent of the protected activity center’s within each 

ecological management unit that exhibits high fire risk conditions. 

♦ Designate a 100-acre “no treatment” area around the known nest site of each selected 

protected activity center. Habitat in the no-treatment area should be as similar as possible 

in structure and composition as that found in the activity center.

♦ Use light prescribed burns in nonselected protected activity centers on a case-by-case basis. 

Burning should avoid a 100-acre “no-treatment” area around the activity center.

 Replace with 2012 Mexican spotted owl recovery plan (page 263): Planned ignitions 

(prescribed fire) and unplanned ignitions (wildland fire) should be allowed to enter 

core areas only if they are expected to burn with low fire severity and intensity. Fire 

lines, check-lines, backfiring, and similar fire management tactics can be used to 

reduce fire effects and to maintain key habitat elements (e.g., hardwoods, large 

downed logs, snags, and large trees). 

Design Features Common to All Action Alternatives

The Forest Service also developed the following design features to be used as part of all of the action 

alternatives. The following were developed to protect and enhance various resources during and after 

proposed activities. 

Forest Stakeholders

• Project activities will be coordinated with all affected stakeholders including grazing permit 

holders, private landowners, federal, state, and local governments. 

• Advanced notification of projects, especially prescribed fire, will be completed through 

methods such as letters, emails, flyers, or newspaper or world wide web publications. 
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Watershed, Water Quality, Riparian, and Soils

• Appropriate best management practices would be properly implemented for all project activities 

to prevent or minimize impacts to soil and water resources and to maintain or improve water 

quality on National Forest System lands. 

• Limit ground disturbance by all heavy equipment work when soils are wet or are saturated to 

reduce compaction and soil displacement (rutting). 

Invasive and Noxious Weeds

• Prevent the spread of potential and existing noxious or invasive weeds by vehicles used in 

management activities by incorporating weed prevention and control into project contracts, 

layout, design, and implementation. 

• Avoid existing noxious or invasive weeds during soil disturbing activities to reduce the risk of 

spread. 

Wildlife

• Strive to retain snags of various size and condition for various wildlife species. 

• Mitigate loss of individuals and groups of sensitive plants during management activities by 

avoiding or buffering known locations. If found during implementation, plants will be avoided 

or buffered. 

• Mexican gray wolf

♦ The U.S. Forest Service will coordinate with the Mexican gray wolf field team on wolf 

activity, especially denning detection during implementation of projects. 

♦ If denning activities are detected within vicinity of projects, appropriate actions would be 

implemented in coordination with Mexican gray wolf field team to minimize or avoid 

impacts. Actions may include such things as temporarily suspending work or moving 

activities to another part of the treatment area.

• Mexican spotted owl protected activity centers - Avoid noise disturbing or other activities 

within protected activity centers during the breeding season (March 1 – August 31). 

• Northern goshawk post-fledging family areas - Avoid noise disturbing or other activities within 

post-fledging family areas during the breeding season (March 1 – September 30).

• Helicopter operations will be coordinated with wildlife biologist. 

Cultural Resources

• All archaeological sites will be avoided and protected to avoid potential impacts.

• Avoid piling slash or activity fuels on sites. For prescribed burning, no ignition points will be 

within archaeological sites.

• If cultural or historic sites are discovered during implementation, work will cease until 

appropriate treatment is identified and consultation with the State Historic Preservation Office 

is completed. 

• Use of mechanical treatments for all project types will avoid all known cultural and historic 

sites. 
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Recreation and Scenery Management: 

• Closure and information signs will be placed on all trail access points and along the trail where 

activities are occurring.

• Shape of individual units, edges of individual units, and patterns created by multiple units will 

appear natural when viewed by forest visitors. 

• Character trees and trees that define the trail corridor would be retained wherever feasible.

• Minimize both short and long-term impacts to recreation infrastructure and use. Keep 

temporary roads, skid trails, and landing construction to a minimum. Minimize the long term 

visual impact of access roads, skid trails, and landings along trail corridors.

• Where feasible activity slash will be piled 150 feet from system trails. 

• Minimize “leave tree” marking along Highway 180 corridor, County roads, concern level 1 

roads, trails, and Head of the Ditch Campground. 

• When trails are temporarily closed due to harvesting, trail tread will be cleared of all slash. 

Changes to trail alignment and surfacing will be minimized; the trail will not be straightened 

nor its surface be changed with an alternate material unless such actions are needed to enhance 

the trail and protect resources. 

• When skid trails intersect national forest system trails, after implementation skid trails will be 

obscured with slash. If skid trails don’t revegetate naturally, then ripping and seeding would be 

considered. 

• Stump heights within 150 feet of trails will be cut to 6 inches or less. Ideally, stumps 

immediately adjacent to trail would be flush cut.

• Where the trail tread crosses the transmission line corridor, a distinguishable trail tread across 

the corridor would be maintained to ensure users stay on the trail system. If activities involving 

mechanized equipment or ground disturbance obscures or alters the trail tread, the trail tread 

will be restored to maintain its trail class design parameters. Additionally, any access used to 

cross a system trail will be maintained at right angles to the trail. 

Implementation

Implementation is estimated to begin in late 2018 with initial treatments over the next 8 to 10 years 

and extending 20 years or until objectives are met, including maintenance. Amount, frequency and 

duration of work would occur as funding, favorable conditions, or both allow. 

Monitoring

• Conduct implementation and effectiveness monitoring for best management practices. Review 

of a selection of effectiveness monitoring sites will be accomplished as a part of either the 

annual project review or Gila National Forest activity review by Gila National Forest watershed 

personnel. 

• Monitoring projects, including effectiveness monitoring for best management practices, 5-year 

review of forestwide watershed condition classification documentation, or both, would be 

reviewed to determine if the limitation of landscape treatment acres to no more than 25 percent

of a 6th code watershed within a 3-year period could be adjusted. Documentation and consensus 

by review team and approval by the district ranger is required for percentage adjustment.
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• Mexican spotted owl habitat implementation and effectiveness monitoring – In coordination 

with U.S. Fish and Wildlife Service personnel, monitoring of treatments will be accomplished 

to determine the effects of treatments on constituent elements of Mexican spotted owl habitat.

• Surveys to detect presence of loachminnow and narrow-headed and northern Mexican 

gartersnakes will occur prior to implementation of stream and riparian treatments. Appropriate 

methods to minimize impacts to species will be applied during implementation. 

• After treatments are completed, areas will be periodically monitored for detection of invasive 

and noxious weed infestations and the effectiveness of implementing weed prevention and 

control measures during activities. 

• Conduct implementation and effectiveness monitoring of avoidance and protection design 

features for heritage resources. If sites are found to be impacted, appropriate mitigation 

measures will be developed in coordination with the appropriate agencies and applied to 

relative remaining project implementations. 

Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in table 

20 through table 29 is focused on activities and effects where different levels of effects or outputs can 

be distinguished quantitatively or qualitatively among alternatives. 
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Table 20. Comparison of the vegetation resources by alternative.

Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Composition - 

Forest Cover Type

No vegetation management 

activities would occur under 

this Alternative. Tree densities 

would continue to increase and 

there would be an associated 

decline in understory species 

diversity and herbaceous 

growth, which may lead to 

increased conifer 

encroachment in 

grassland/meadow areas. 

Without disturbance activecompetition induced mortality 

could occur in high density 

areas and predispose areas to 

bark beetle outbreaks. Fuels 

would continue to build and 

could increase the fire hazard 

within the project area.

Group Selection, thinning and 

prescribed burning treatments 

would reduce density, and 

create more open forest 

conditions, with increased 

herbaceous, forb, and woody 

vegetation production. These 

treatments would favor seral 

species retention and would 

create conditions conducive for 

seral species regeneration 

establishment in openings. 

Grassland and meadow 

treatments would also see 

increased grass and forb 

production. Change in 

vegetation composition will 

increase diversity at both the 

stand- and landscape-scale.

In addition to activities listed in 

alternative B, herbicide use is 

proposed to treat rabbitbrush in 

grassland/meadow restoration 

treatments, and sprouting 

juniper in forested areas. 

Herbicide use will increase 

treatment effectiveness by 

creating growing space for 

desirable species to regenerate 

such as grasses and forbs in 

grassland/meadow treatments, 

and conifer seedlings in 

forested areas. Herbicide 

application would also be 

targeted within the wildland 

urban interface where 

sprouting of juniper postthinning could create ladder 

fuels. In this case herbicide 

treatment will help increase the 

effectiveness of fuel reduction 

treatments with treatments 

lasting longer than with tree 

cutting alone. 

Effects same as alternative B
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Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Diversity and 

Structure – Relative 

Stand Density

No vegetation management 

activities would occur under 

alternative A. in the absence of 

disturbance stand density 

levels would continue to 

increase over time. A large 

portion of the project area will 

be at or above 55 percent of 

SDI max in the long-term and

there will be active competition 

induced mortality. Stand growth 

and individual tree vigor will 

decline as density increases as 

there is increased competition 

for site resources. Risk of loss 

from bark beetles could also 

increase at high densities.

Vegetation management 

activities under alternative B 

will move the landscape 

towards the desired condition 

more than the no action 

alternative over time. Stand 

density will be reduced, 

individual tree vigor and stand 

growth would be enhanced in 

forested areas. Stand structural 

complexity and heterogeneity 

would be increased at both the 

stand-and landscape-scale 

under alternative B. This will 

help create more resilient 

ecosystems that are better 

suited to future disturbances

Effects are the mostly the same 

as alternative B except for 

treatment of rabbitbrush and 

alligator juniper. 

Under alternative C, herbicide 

use will increase the length of 

time targeted species are 

controlled reducing competition 

related tree mortality more 

effectively than alternative B. 

Same effects as alternative B.
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Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Diversity and 

Structure for Wildlife 

Habitat Improvement 

– Vegetation 

Structural Stage

No vegetation management 

activities would occur under 

alternative A. The existing 

distribution of vegetation 

structural stages for ponderosa 

pine and woodland cover types 

would change slowly through 

time without disturbance and 

would trend towards denser 

stages and canopy density 

classes. The risk of loss of 

trees and possibly entire 

stands from insect epidemic or 

wildfire could increase as stand 

densities within the project area 

continue to increase. Over time 

tree mortality from disturbance, 

or competition-induced 

mortality would create large 

enough openings for 

regeneration establishment and 

representation of the 

vegetation structural stages1 

and A canopy density class.

There are approximately 

76,218 acres of proposed 

treatments within forested 

areas managed for northern 

goshawk under alternative B. A 

variety of treatments are 

proposed including thinning, 

group selection and/or 

prescribed burning. These 

treatments will help promote 

uneven-aged structure and

increase heterogeneity at the 

stand- and landscape-scale. 

This will help move the project 

area towards desired 

conditions which is to create 

diverse stand structures at both 

the stand- and landscape scale 

for northern goshawk 

management.

Effects are the mostly the same 

as alternative B except for 

treatment of rabbitbrush and 

alligator juniper. 

Under alternative C, herbicide 

use will increase the length of 

time targeted species are 

controlled reducing competition 

related tree mortality more 

effectively than Alternative B.

Same effects as alternative B.
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Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Diversity and 

Structure for Wildlife 

Habitat Improvement 

– Stand Density

No wildlife habitat improvement 

treatments including thinning 

and prescribed fire activities 

would occur in Mexican spotted 

owl threshold stands. There 

would not be a reduction in 

stand densities or fuel loadings. 

The risk of loss of habitat for 

the Mexican spotted owl due to 

high intensity wildfire would not 

be reduced and could increase 

over time as stand densities 

continue to increase.

Alternative B proposed wildlife 

habitat improvement activities 

on approximately 4,073 acres 

including thinning and 

prescribed fire to move 

Mexican spotted owl threshold 

stands to desired conditions. 

Treatments would be designed 

to enhance diversity in both 

species composition and 

structure to increase key 

habitat components for the owl. 

Fuel loadings would be 

reduced and the risk of loss of 

habitat from future 

disturbance(s); for example,

wildfire may be reduced under 

alternative B. 

This alternative would not use 

herbicide in stands targeted to 

be managed for Mexican 

spotted owl nest characteristics 

(target threshold stands) or in 

mixed-conifer stands. Effects 

of this alternative in these 

areas would be the same as 

alternative B. In Mexican 

spotted owl ponderosa pine – 

Gambel oak recovery habitat 

that is not managed for the 

threshold nest roost 

characteristics, herbicide use 

when needed to control juniper 

sprouting in openings will 

increase the length of time 

sprouting is controlled more 

effectively than alternative B. 

Same effects as alternative B.
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Resource Element Alternative A Alternative B Alternative C Alternative D

Old Growth – Stand 

Density, Canopy 

Cover, and Snag 

Density

There would be no vegetation 

management activities under 

alternative A. As a result as 

stand densities continue to 

increase over time there would 

be a high risk of loss of dead 

and down material, dead 

standing material, and live 

vegetation from disturbance(s) 

e.g., wildfire occurrence due to 

the high average tree densities.

Individual tree growth and vigor 

would also decline and could 

predispose areas with high 

densities to competitioninduced mortality and other 

biotic agents such as bark 

beetle outbreaks.

Alternative B proposes to treat 

approximately 24,780 acres of 

areas designated to be 

managed to develop old growth 

characteristics with a variety of 

treatments including thinning, 

regeneration treatments and/or 

prescribed burning. Density 

reduction would increase 

residual tree vigor and increase 

old-growth characteristics at a 

faster rate than untreated 

areas. Density reduction would 

lower the average basal area 

and provide a reduction of fuels

which may reduce potential 

damage to old growth 

components in the event of a 

wildfire. Treatments would 

increase structural 

heterogeneity with project 

design features emphasizing 

clumps, gaps and openings.

Alternative C proposes to treat 

a maximum of 333 acres of 

stands designated to be 

managed toward an old growth 

condition with herbicide in 

ponderosa pine and woodland 

areas. Herbicide use when 

needed to control juniper 

sprouting in openings will 

increase the length of time 

sprouting is controlled more 

effectively than alternative B. 

Effects of this alternative in the 

remaining 24,447 acres 

designated for management 

toward an old growth condition 

would be the same as 

alternative B. 

Same effects as alternative B.

Table 21. Comparison of the fire and fuels resources by alternative.

Resource Element Alternative A Alternative B Alternative C Alternative D

Reduce Impact of 

High Severity Fire – 

Percent of modeled 

crown fire (passive 

and active) 

67% 16% 16% 16%

Reduce Impact of 

High Severity Fire – 

Percent of modeled 

surface fire

24% 84% 84% 84%
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Resource Element Alternative A Alternative B Alternative C Alternative D

Restore Departed 

Landscapes that are 

at Risk of Fire – Total 

acres treated in Fire 

Regime Group I

0 116,000 116,000 116,000

Fire and Fuels 

Management

Fuel conditions and crown fire 

potential in the project area 

would continue to be of 

concern and may be 

exacerbated by on-going insect 

and disease activity, natural 

disturbances and the 

progression of forest growth 

and change. Canopy and 

ladder fuels and surface fuel 

loading levels would continue 

to increase throughout the 

project area. There would be 

no reduction in potential fire 

behavior and it would be 

expected crown fire potential 

would increase. No progress 

would be made toward 

reducing the impact of high 

severity fire. This alternative 

would not assist in returning 

fire as a natural process in firedependent ecosystems. It 

would not allow land managers 

to help to restore or maintain 

desired conditions. 

Ecosystems, that are not 

adapted to high intensity/high 

severity wildfires, would remain 

at risk.

Treatments would decrease 

potential crown fire activity, 

reduce fuel loading levels and 

understory ladder fuels thereby 

reducing the impacts of high 

severity wildfire on resources. 

Approximately 36,022 acres 

would be prescribed burned. 

Additionally, 95,997 acres 

would receive mechanical 

treatments, of which may also 

include a subsequent 

prescribed burning treatment 

(pile, under burning). Potential 

crown fire behavior and the 

threat of high severity fire 

would be reduced. Modeling 

results show approximately 

16% of the project area would 

exhibit crown fire and 84% 

would exhibit surface fire, as 

compared to 67% and 24% 

respectively with the existing

condition. Approximately 

115,926 acres would be treated 

in fire regime group I. Initiating 

prescribed burning on the 

landscape will help initiate the 

restoration of ecological 

processes in fire-dependent 

ecosystems.

Same effects as alternative B Same effects as alternative B
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Table 22. Comparison of the wildlife resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Mexican Gray Wolf No project activities would be 

implemented and therefore 

there would be no effect to the 

Mexican gray wolf. 

Under all action alternatives, 

disturbance to potential 

denning sites are minimized 

through avoidance or other 

features developed in 

coordination with the field team 

in relation to the activity being 

implemented. There are 

beneficial effects to the species

and its habitat through 

reduction of habitat 

fragmentation through road 

decommissioning and 

improvement of native ungulate 

(prey species) habitat. A 

determination of “not likely to 

jeopardize” is made for all 

action alternatives. 

Same effect as alternative B Same effect as alternative B
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Resource Element Alternative A Alternative B Alternative C Alternative D

Mexican Spotted Owl No project activities would be 

implemented and therefore 

there would be no effect to the 

Mexican spotted owl. However 

the habitat would continue to 

be at risk of being impacted by 

wildfires.

Thinning and burning activities 

associated with the Luna 

Restoration Project will reduce 

basal area in protected activity 

centers during the short term 

(but not drop below threshold 

values) and will adjust the 

structure and thermal 

characteristics. Reducing fuel 

loading in designated critical 

habitat could impact prey 

species in the short term. 

Reducing juniper could reduce 

food sources for prey species. 

Performing actions outside of 

the breeding season, or after 

confirming non-breeding status, 

will prevent disturbing nesting 

owls.

The Luna Restoration Project 

would reduce habitat needs in 

protected activity centers in the 

short term, but improve 

conditions in the long term, 

therefore the Luna Restoration 

Project may affect, likely to 

adversely affect the Mexican 

spotted owl.

Treatments in designated 

critical habitat would align with 

the forest plan, which 

complements the 1995 

Mexican spotted owl recovery 

plan, therefore the Luna 

Restoration Project may affect, 

not likely to adversely affect the 

designated critical habitat for 

the Mexican spotted owl. 

Same effect as alternative B Same effect as alternative B
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Resource Element Alternative A Alternative B Alternative C Alternative D

Southwestern Willow 

Flycatcher

There will be no effect to the 

species due to southwestern 

willow flycatchers not being 

observed within the project 

area for the last 10 years and 

the designated critical habitat 

within the planning area does 

not contain the primary 

constituent elements to support 

the birds.

No activities are being 

implemented, therefore there 

will be no effect to designated 

critical habitat.

There will be no effect to the 

species due to southwestern 

willow flycatchers not being 

observed within the project 

area for the last 10 years and 

the designated critical habitat 

within the planning area does 

not contain the primary 

constituent elements to support 

the birds.

The removal of riparian 

vegetation and short-term 

disturbances from other stream 

restoration activities and 

decommissioning within 

designated critical habitat 

would be insignificant and 

discountable. These sites are 

small and localized, but have 

the potential to provide longterm benefits, although would 

not greatly improve or change 

the primary constituent 

elements of the critical habitat. 

Project activities may affect, 

not likely adversely affect the 

designated critical habitat.

Same effect as alternative B. 

Application of design feature 

for buffering the critical habitat 

from herbicide treatments 

would not change the habitat 

constituents or alter the 

vegetation.

Same effect as alternative B
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Resource Element Alternative A Alternative B Alternative C Alternative D

Narrow-headed 

Gartersnake

No activities are being

implemented, therefore there 

will be no effect to the narrowheaded gartersnake or its 

proposed critical habitat.

The removal of riparian 

vegetation and short-term 

disturbances from other stream 

restoration activities and 

decommissioning within 

proposed critical habitat would 

be insignificant and 

discountable. These sites are 

small and localized, but have 

the potential to provide longterm benefits. Surveying for the 

gartersnake prior to 

implementation and applying 

buffer around habitat will 

reduce the risk of disturbance 

and harm. Project activities 

may affect, not likely adversely 

affect the narrow-headed 

gartersnake and its proposed 

critical habitat.

Same effect as alternative B. 

Application of applicable design 

features for water related 

resources and the buffer for 

proposed critical habitat from 

herbicide treatments would 

minimize risk of impacts to the 

narrow-headed gartersnake 

and its proposed critical 

habitat.

Same effect as alternative B. 

Northern Mexican 

Gartersnake

No activities are being 

implemented, therefore there 

will be no effect to the northern 

Mexican gartersnake.

The removal of riparian 

vegetation and short-term 

disturbances from other stream 

restoration activities and 

decommissioning are small and 

localized, but have the potential 

to provide long-term benefits. 

Surveying for the gartersnake 

prior to implementation and 

applying design feature buffers 

and other water related 

measures will reduce the risk of 

disturbance and harm. Project 

activities may affect, not likely 

adversely affect the northern 

Mexican gartersnake.

Same effect as alternative B. 

Application of applicable design 

features for water related 

resources and the buffer for 

proposed critical habitat for the 

narrow-headed gartersnake; 

minimizes the risk of impacts to 

the northern Mexican 

gartersnake 

Same effect as alternative B. 
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Resource Element Alternative A Alternative B Alternative C Alternative D

Loach Minnow No activities are being 

implemented, therefore there 

will be no effect to loach 

minnow or its designated 

critical habitat, but the risk of 

being impacted by wildfires 

would continue.

Project activities will cause 

short-term negative impacts to 

loachminnow and its critical 

habitat. Stream, riparian, and 

hardening crossings activities, 

and reducing the risk 

sedimentation, ash, and debris 

from uncharacteristic wildfires 

through vegetation and 

prescribed fire, will provide 

long-term benefit to the specie 

and habitat. The project will 

result in a may affect, likely to 

adversely affect to the 

loachminnow and its 

designated critical habitat.

Same effect as alternative B. Same effect as alternative B. 

Spikedace There will be no effect to 

spikedace. Spikedace have not 

been found occupying streams 

within the planning area.

No activities are being 

implemented, therefore there 

will be no effect to designated 

critical habitat, but the risk of 

being impacted by wildfires 

would continue.

There will be no effect to 

spikedace. Spikedace have not 

been found occupying streams 

within the planning area.

Project activities will cause 

short-term negative impacts to

spikedace critical habitat. 

Stream, riparian, and 

hardening crossings activities, 

and reducing the risk 

sedimentation, ash, and debris 

from uncharacteristic wildfires 

through vegetation and 

prescribed fire, will provide 

long-term benefit to the habitat. 

The project will result in a may 

affect, likely to adversely affect 

to the designated critical 

habitat.

Same effect as alternative B. Same effect as alternative B. 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

48

Resource Element Alternative A Alternative B Alternative C Alternative D

Region 3 Sensitive 

Species

No activities are being 

implemented, therefore there 

will be no impact to Region 3 

sensitive species that occur or 

may occur within the planning 

area.

Implementation of activities 

result in a determination of may 

impact individuals or habitat, 

but will not likely contribute to 

trend in federal listing for 

Region 3 sensitive species that 

occur or may occur within the 

planning area.

Same effect as alternative B. Same effect as alternative B.

Migratory Bird 

Species

For migratory bird species that 

occur or potential to occur in 

the planning area, there would 

be no change to the habitat or 

disturbance to the species, but 

there is still exists the risk of 

wildfire impacts to forested and 

woodland cover types. A 

determination of “no impact” for 

migratory bird species.

Individuals may be disturbed by 

project equipment noise and 

human presence in the short 

term. Proposed treatments 

would improve habitat and 

reduce wildfire threat in long 

term. 

There may be short-term 

impacts to individual migratory 

birds, but alteration to their 

habitats or being disturbed 

during treatments, will not 

negatively affect population 

levels.

Same effect as alternative B. 

Herbicide application may 

disturb individuals by noise and 

human presence in the short 

term. Rabbitbrush and alligator 

juniper would be reduced, 

providing opportunity for growth 

and increase of herbaceous 

plants in treatment areas.

There may be short-term 

impacts to individual migratory 

birds, but alteration to their 

habitats or being disturbed 

during treatments, will not 

negatively affect population 

levels.

Same effect as alternative B. 

Not adding user-proposed

routes would not impact habitat 

nor disturb the species. There 

would be beneficial effects by 

not having routes crossing 

through habitats causing 

fragmentation. Although routes 

are not added under this 

alternative, other activities are 

still being implemented, 

therefore there may be shortterm impacts to individual 

migratory birds, but alteration 

to their habitats or being 

disturbed during treatments, 

will not negatively affect 

population levels.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

49

Table 23. Comparison of management indicator species resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Mule Deer No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to 

mule deer.

Foraging would be disrupted in 

the short term, but there would 

be long term improvement of 

habitat conditions for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Applying design features and 

best management practices 

pertaining to herbicide 

treatments will reduce or 

prevent impacts to the species.

Same effect as alternative B. 

Also, not adding routes would 

result in less habitat 

fragmentation.

Mearn’s Quail No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to 

Mearn’s quail.

Forage and nesting and hiding 

cover would be reduced in the 

short term, but would increase 

in the long term. Individuals 

may be affected, but at the 

forest level, these affects would 

not adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Additional forage may be 

established in treated areas for 

Mearn’s quail.

Applying design features and 

best management practices 

pertaining to herbicide 

treatments will reduce or 

prevent impacts to the species.

Same effect as alternative B. 

Not adding routes would result 

in less habitat fragmentation.

Long-tailed vole No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to the 

long-tail vole

Some long-tail voles may be 

inadvertently crushed during 

implementation, but proposed 

activities will improve

conditions in and surrounding 

habitat in the long term for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Applying design features and 

best management practices 

pertaining to herbicide 

treatments will reduce or 

prevent impacts to the species. 

Wet meadows will be buffered 

300 feet, and no herbicide 

would be used in the buffer 

zone, reducing risk to the 

species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

50

Resource Element Alternative A Alternative B Alternative C Alternative D

Beaver No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to 

beaver.

Some disturbance and loss of 

riparian vegetation in the short 

term, but will have improved 

habitat conditions in the long 

term for this species. 

Individuals may be affected, 

but at the forest level, these 

affects would not adversely 

affect population trends on the 

Gila National Forest.

Same effect as alternative B.

Applying design features and 

best management practices 

pertaining to herbicide 

treatments and water and 

aquatic resources will minimize 

effects to beaver.

Same effect as alternative B. 

Not adding routes would not 

impact the species.

Plain Titmouse No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to 

plain titmouse.

Since fire has the potential to 

increase the number of snags, 

there would be long-term 

improvement of habitat 

conditions for this species. 

Individuals may be affected, 

but at the forest level, these 

affects would not adversely 

affect population trends on the 

Gila National Forest.

Same effect as alternative B. 

Herbicide utilization may affect 

some food sources in the shortterm. Applying design features 

and best management 

practices pertaining to 

herbicide treatments will 

reduce or prevent impacts to 

the species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.

Hairy Woodpecker No activities are being 

implemented within associated 

vegetation types, therefore 

there would be no impact to 

beaver.

Since snags will primarily be 

retained and fire has the 

potential to increase the 

number of snags there would 

be long term improvement of 

habitat conditions for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Herbicide utilization may affect 

some food sources in the shortterm. Applying design features 

and best management 

practices pertaining to 

herbicide treatments will 

reduce or prevent impacts to 

the species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

51

Resource Element Alternative A Alternative B Alternative C Alternative D

Air Quality – Clean 

Air Act Compliance

Compliance with Clean Air Act. 

No activities are being 

implemented, so no air quality 

impacts from fugitive dust. But 

still higher risk of air quality 

impacts from uncharacteristic 

high-intensity wildfire.

Overall, compliance with Clean 

Air Act is maintained. For 

vegetation and prescribed fire 

activities, short-term additional 

particulate matter, but longterm benefit form reduced 

wildfire risk. Short-term fugitive 

dust from road-related 

treatments.

Same effect as alternative B. 

No additional impacts from 

herbicide use.

Same effect as alternative B.

Table 24. Comparison of the watershed and soils resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Soil Resources No short term disturbance and 

no long-term benefit to soil 

condition or trend.

For treatments excluding 

decommissioning, there would 

be short-term impacts to soils 

resources, but long-term 

benefit to soil condition and 

trend. Short-term impacts to 

soils resources from 

decommissioning; long-term 

localized impacts from 

increased routes. Project-wide 

long-term benefits to soil 

condition and trend outweigh 

minor localized impacts.

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B.

Short-term impacts to soils 

resources from 

decommissioning. Project-wide 

long-term benefits to soil 

condition and trend. Slightly 

better than alternatives B and

C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

52

Resource Element Alternative A Alternative B Alternative C Alternative D

Riparian Areas and 

Wetlands / Wet 

Meadows

No short-term or long-term 

benefit to riparian functionality. 

Without vegetation and 

prescribed fire treatments, no 

long-term benefit to riparian 

functionality; higher risk of 

downward trend in event of 

uncharacteristic wildfire.

With vegetation and prescribed 

fire implementation, there 

would be no negative impacts 

with implementation of best 

management practices; longterm benefit to riparian 

functionality with reduced risk 

of uncharacteristic wildfire.

With stream, riparian, and 

erosion control treatments will 

have positive benefit to riparian 

functionality; upward trend and 

improved conditions.

With range management 

treatments, there would be no 

benefit to riparian functionality.

With motorized transportation 

treatments will be minor 

impacts to riparian areas that 

will be mitigated with 

implementation of best 

management practices. 

Project-wide long-term benefits 

to riparian areas, wetlands, wet 

meadows outweigh minor 

localized impacts

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B.

Motorized transportation 

treatments - Project-wide longterm benefits to riparian areas, 

wetlands, wet meadows. 

Slightly better than alternatives 

B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

53

Resource Element Alternative A Alternative B Alternative C Alternative D

Water Quality and 

Quantity

Without vegetation and 

prescribed fire treatments - no 

short-term disturbance; no 

changes in compliance with 

Clean Water Act, no long-term 

benefit to water quality; 

continuation of potentially less 

stable hydrologic regime.

Without stream, riparian, and 

erosion control treatments - no 

short-term disturbance; no 

changes in compliance with 

Clean Water Act, no long-term 

benefit to water quality; 

continuation of unstable 

hydrologic regimes

Without range management - 

No changes in compliance with 

Clean Water Act, no changes 

to water quality; no changes to 

hydrologic regime

Without motorized 

transportation treatments - no 

short term disturbance; no 

changes in compliance with 

Clean Water Act, and no long 

term benefit to water quality

With vegetation treatments - 

short-term additional sediment, 

long-term benefit to water 

quality and hydrologic regime 

with reduced risk of 

uncharacteristic wildfire and no 

changes in compliance with 

Clean Water Act. 

With prescribed fire - shortterm added sediment and ash, 

long-term benefit to water 

quality and hydrologic regime 

with reduced risk of 

uncharacteristic wildfire and no 

changes in compliance with 

Clean Water Act. 

With stream, riparian, and 

erosion control treatments - 

short–term additional sediment; 

long-term benefit to water 

quality and improved 

hydrologic regime. Improved 

compliance with Clean Water 

Act. Potential to meet State 

water quality standards

Range management 

treatments would result in no 

changes in compliance with 

Clean Water Act. 

With motorized transportation 

treatments - short-term impacts 

to water quality from 

decommissioning; long-term 

localized impacts from 

increased routes. Project-wide 

long-term benefits to water 

quality and quantity outweigh 

minor localized impacts.

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B. 

Short-term impacts to water 

quality from decommissioning; 

Project-wide long-term benefits 

to water quality. Slightly better 

than alternatives B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

54

Resource Element Alternative A Alternative B Alternative C Alternative D

Watershed 

Cumulative Effects

Without vegetation and 

prescribed fire treatments - no 

change to watershed condition 

classification; higher risk of 

downward trend in event of 

uncharacteristic wildfire. 

Without other treatments – no 

change to watershed condition 

classifications

With vegetation and prescribed 

fire treatments - Improvement 

in terrestrial biological 

indicators resulting in minor 

upward trend in watershed 

condition classification in 

multiple watersheds; reduced 

risk of downward trend 

resulting from potential 

uncharacteristic wildfire. 

With stream, riparian, and 

erosion control treatments - 

Improvement in aquatic 

biological and aquatic physical 

indicators resulting in upward 

trends and improved watershed 

condition classifications in 

multiple watersheds.

Range management 

treatments would result in no 

change to watershed condition 

classification

With motorized transportation 

treatments - Improvement in 

Terrestrial Physical indicators 

resulting in upward trends and 

improved watershed condition 

classifications in multiple 

watersheds

Same effects as alternative B Same effects as alternative B. 

With motorized transportation 

treatments, slightly more 

improvement in terrestrial 

physical indicators than 

alternatives B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

55

Table 25. Comparison of the National Forest System roads by alternative.

Resource Element Alternative A Alternative B Alternative C Alternative D

Miles added to the 

national forest road 

system on the Gila

0 22 22 4 

Net reduction in miles 

of national forest 

system roads on the

Gila 

0 94 94 126

Table 26. Comparison of the range resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Range Resources No activities are being 

implemented, therefore there 

are no effects to range 

resources. Without vegetation 

and prescribed fire treatments, 

there would be continued 

encroachment into grasslands 

and risk of wildfire would 

continue. 

With vegetation and prescribed 

fire activities, there may be a 

need to rest all or part of 

pastures for a short duration. 

Long-term benefit from 

grassland restoration and water 

improvement.

Effects same as alternative B. 

Herbicide application would 

move the landscape toward 

desired conditions in a shorter 

timeframe compared to only 

mowing in alternatives B and 

D.

Effects same as alternative B.

Table 27. Comparison of recreation resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Recreation 

Opportunity – Quality 

of national forest 

system trails

0 miles constructed 4.5 mile of trail is constructed 

through road to trail conversion 

and 0.3 mile of new 

construction connecting 

motorized trail in Dillman Creek 

area

4.5 mile of trail is constructed 

through road to trail conversion 

and 0.3 mile of new 

construction of connecting 

motorized trail in Dillman Creek 

area

4.2 mile of trail is constructed 

through road to trail 

conversion. No new 

construction of connecting 

motorized trail (0.3 miles)

Recreation 

Opportunity – 

Increased opportunity 

for motorized 

recreation for offhighway vehicles 

0 miles added to the motorized 

transportation system

18 total miles of national forest 

system roads (13.8 mi) and 

user-created routes (4.2 mi) 

added to the motorized 

transportation system

18 total miles of closed national 

forest system roads (13.8 mi) 

and user-created routes (4.2 

mi) added to the motorized 

transportation system

0.2 miles added to the 

motorized transportation 

system from previous travel 

management decision
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

56

Resource Element Alternative A Alternative B Alternative C Alternative D

Inventoried Roadless 

Areas 

No activities would be 

implemented, therefore current 

roadless character would be 

unchanged. Without prescribed 

fire, the risk of wildfire would 

continue. The potential of a 

wildfire could impact 

naturalness and/or recreation 

values of roadless areas.

With low severity prescribed 

fire there would be some short 

term effect to the undeveloped, 

natural, and opportunities for 

solitude or primitive unconfined 

recreation attributes of the 

Nolan and Mother Hubbard 

Inventoried Roadless Areas; 

but would result in a long term 

beneficial effect. Temporary 

effects to solitude and 

recreation could occur along 

the roadless boundaries, by 

such things as sights and 

sounds of people working, 

chainsaws, dust, and smoke.

Approximately 0.46 miles of 

road would be changed to trail 

during decommissioning in 

Frisco Box Inventoried 

Roadless Area, improving 

undeveloped quality.

Same effect as alternative B.

No herbicide treatments are 

located in any of the roadless 

areas.

Same effect as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

57

Table 28. Comparison of heritage resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Heritage Resources – 

Relative Risk

No activities would be 

implemented, therefore would 

be no relative risk of potential 

impact to sites. Without 

vegetation and prescribed fire 

treatments, the risk of wildfire 

and erosion episodes following 

fire events would continue. 

With that, the probability that 

heritage resources may be 

adversely affected in the future 

increases.

The relative risk of potential 

impacts to sites based on acres 

of archaeological inventory is 

approximately 76,554 acres of 

projects using heavy 

equipment; a subtotal of 

prescribed fire acres (130,000 

to 160,000 acres) determined 

by high site probability; and 

approximately 20,283 acres of 

mowing rabbitbrush. There is a 

potential for direct and indirect 

effects to heritage resources 

with implementation of the 

various types of projects and 

associated equipment. Effects 

would be minimized or 

prevented through application 

of design features and best 

management practices.

The relative risk is the same as 

alternative B. Herbicide acres 

are the same as rabbitbrush 

mowing area. Plus an 

additional 8,030 acres may be 

treated with herbicide for 

alligator juniper. Effects are 

same as alternative B.

The relative risk and effects are 

the same as alternative B.

Table 29. Comparison of the social and economic resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Environmental 

Justice – Economics

No activities would be 

implemented, therefore there 

would be no change from the 

current condition and therefore 

no disproportionate adverse 

economic effects to minority or 

low-income populations.

With implementation of various 

projects there is potential for 

economic benefit to local 

contractors or industries and

increased employment 

including timber or other forest 

products, fire, or other 

restoration projects that could 

be contracted. With potential 

increase in employment 

opportunities, there would be 

no disproportionate adverse 

economic effects to minority or 

low-income populations.

Same effects as alternative B Same effects as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Draft Environmental Impact Statement

58

Resource Element Alternative A Alternative B Alternative C Alternative D

Environmental 

Justice – Health and 

Quality of Life 

Without implementation of 

prescribed burning, smoke 

emissions would not have 

health and quality of life 

consequences to vulnerable 

populations such as children, 

the elderly, and individuals with 

health and respiratory issues.

The risk of wildfire would 

continue and the intensity and 

duration of smoke emissions 

will be greater than prescribed 

burning treatments and will 

have consequences to 

vulnerable populations.

With prescribed fire treatments, 

vulnerable populations will be 

affected by smoke emissions. 

But intensity and duration of 

smoke emissions will be 

minimized with implementing 

burn prescriptions, coordination 

with the state Air Quality 

Department and advanced 

notification to allow individuals 

to engage other methods of 

reducing smoke impacts.

Same effects as alternative B Same effects as alternative B

Environmental 

Justice – Fuelwood 

as Household Heat 

Source 

Without vegetation treatments, 

opportunities for fuelwood 

collection would continue and 

would not affect low income 

families who depend on 

fuelwood for primary heat 

source.

With vegetation treatments, the 

opportunity for additional 

sources of fuelwood would 

become available. Families 

who depend on fuelwood for 

primary heat source would not 

be affected.

Same effects as alternative B Same effects as alternative B
Luna Restoration Project 

Draft Environmental Impact Statement

59

Chapter 3. Affected Environment and 

Environmental Consequences

Introduction 

This chapter summarizes the physical, biological, social, and economic environments of the 

project area and the effects of implementing each alternative on that environment. The complete 

analysis documents are part of the project record. It also presents the scientific and analytical 

basis for comparing alternatives as presented in chapter 2. Analyses looked at changes from the 

no-action alternative (alternative A).

Notes on Effects Analysis

This draft environmental impact statement examines effects on a landscape scale. 

Specialists presented any limitations and assumptions in their analyses in accordance to the 

Council on Environmental Quality; Regulations for Implementing the National Environmental 

Policy Act; 40 CFR section 1502.22; and incomplete or unavailable information [51 FR 15625, 

Apr. 25, 1986]. 

There may be variations in values displayed by some of the resource areas for alternatives. The 

numbers may vary due to resource spatial data compared to planning area data not matching 

perfectly. Also, depending on the resource area and measure for analysis of effects, the resource 

area of consideration may be more, less, or a subset of the planning area. 

Assumptions and Limitations Common to All Resources

For analysis purposes, the average width of roads and trails by type or maintenance level used 

were as shown in table 30. 

Table 30. Average width of roads and trails by type or maintenance level.

Existing and Proposed Roads and Trails Average Width (feet) 

Decommissioned* 0 

Operation maintenance level 1 – Closed 12

Operation maintenance level 2 12

Operation maintenance level 3 14

Operation maintenance level 4 20

Operation maintenance level 5 20

Unauthorized roads 16

4x4 trail 6 

Temporary roads 10

*Decommissioned is defined as a route in its natural (pre-road) condition
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Draft Environmental Impact Statement

60

Vegetation 

Assumptions and Limitations 

Model Limitations

The Forest Vegetation Simulator (FVS) model is a semi-distance-independent, individual tree 

growth yield model. Stand exam data was used as the model input. For this project, a limitation 

of Forest Vegetation Simulator modeling is that the forest does not have a 100 percent sample of 

the project vegetation by stand and alternative. The intensity and level of stand exam data 

collected versus the amount of acres proposed for treatment is not a one-to-one relationship; 

rather, the data is an inventory to represent stand-level conditions by proposed activity.

For stands in which data was not collected, data from stands exhibiting similar features based 

upon National Agricultural Imagery Program in geographic information systems was used for 

analysis. Field validation was then performed on a limited number of stands for accuracy. A 

minimum of 20 stands was selected per treatment model run, or if less than 20 stands was 

available for a given model run then all stands were used in simulations. Professional judgement 

based on local experience has verified that model outputs are reasonable with values and 

indicators aligned with desired conditions. 

Model results and interpretations must still be tempered with professional judgment for full 

analysis of effects. Model outputs display per-acre average results for the specific data sets that 

were modeled for each project treatment category. These per-acre results can generally be 

applied to represent the full acres listed for each forest type within the appropriate treatment 

category. All numbers, acres, and percentages used throughout this document are strictly 

estimates.

Analysis Assumptions

There are basic assumptions associated with modeling silvicultural prescriptions and stand 

growth. It is important to understand that parameters describing stand conditions and the 

underlying growth of stands are outcomes of an empirical growth model (Forest Vegetation 

Simulator). These outcomes are statistical in nature and are an attempt to represent future stand 

conditions over time. Outputs from the modeling represent an average of “what” might occur 

over time and interpretation should consider the modeling a tool in understanding ecological 

processes. The output data reflects silvicultural assumptions (model’s underlying equations) and 

the variability inherent in the input data (common stand exam inventory plots). 

• Assumption 1: The collected inventory plot data (common stand exam) represent the 

current “average” stand conditions in the project area.

• Assumption 2: The Forest Vegetation Simulator model and the underlying equations of 

the chosen variant statistically represent future tree and stand growth and mortality. The 

model’s output of stand conditions provides a statistically non-biased representation of 

silvicultural activities and stand conditions over time.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Draft Environmental Impact Statement

61

• Assumption 3: The modeled outputs from Forest Vegetation Simulator should not be 

assumed to be exact for all stands where the outputs are applied due to limitations in data 

collection mentioned above. The results are meant to be interpreted as general trends on 

the landscape. During implementation site-specific stand level prescriptions will be written 

for each stand and will be in compliance with authorized activities. 

• Assumption 4: Forest Vegetation Simulator was used to model the first entry for 

treatments however some stands may require subsequent entries to move towards or attain 

desired conditions. Anticipated effects are displayed 20 and 40 years post-harvest; 

however, it is plausible and likely that future planning efforts will overlap with the project 

area and could identify areas needing re-treatment to maintain or move towards desired 

conditions. 

Data Limitations

To describe current conditions for Mexican spotted owl habitat available stand data was used. 

There is limited stand data therefore; the stand information does not encompass the entire 

acreage of designated Mexican spotted owl habitat within the planning area. 

Environmental Consequences

The vegetation affected environment is described in chapter 1, “Existing and Desired Condition” 

section. 

Alternative A

Forest Cover Types

Forest cover type changes would occur over time as trees die through natural mortality and 

disturbance events from insect, disease, or wildfire. Tree growth, sprouting, regeneration of other 

species, and climatic variation may also cause a change in the forest cover type. 

Under the no-action alternative, there would not be an increase in growing space and conditions 

would remain the same in the short-term. In the long-term where existing density levels are 

currently high competition-induced mortality would occur as densities continue to increase. 

Depending on the extent of the mortality newly created growing space would either create 

openings large enough for new regeneration to establish or be quickly occupied by residual trees. 

Many of the forest cover types within the Luna project area don’t tend to persist at high densities 

for long periods as they are generally affected by natural disturbance events such as insects, 

disease and wildfire.

Under the no-action alternative, the grassland cover type would experience a decline from the 

existing acreage by about 1 percent in 20 years as woody vegetation continues to regenerate into 

the grassland and meadow edges (table 31). The grassland would undergo little or no change 

over the remaining 40-year period due to the slow rate of regeneration and tree canopy closure. 

All other cover types would be within desired ranges over the 20- and 40-year periods. 

Ponderosa pine and pinyon-juniper woodlands would experience a slight decrease. Oak 

woodland, southwest white pine and white fir cover types would experience a slight increase

over the 20- and 40-year periods. There would also be a slight decrease in 20 years and overall 

increase in the 40-year period for the Douglas fir cover type. 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Draft Environmental Impact Statement

62

Table 31. Forest cover type acres and percent change in 20 and 40 years under alternative A, no 

action.

Forest Cover Type Acres

Percent Change (%)

in 20 years

Percent Change (%)

in 40 years

Grassland/Meadow 21,941 -1 -1 

Douglas fir 6,323 -0.4 +0.2

Engelmann Spruce 109 0 0 

Oak Woodland 1,414 +1.3 +1.7

Pinyon-Juniper 41,713 -0.2 -0.1

Ponderosa pine 87,195 -0.4 -1.2

Riparian 784 N/A N/A

Southwestern White Pine 69 +0.4 +0.4

White Fir 6,887 +0.2 +0.2

Reforestation Area 3,954 N/A N/A

Rocky Area 942 N/A N/A

171,3311

1 Acreage does not include private land.

Stand Density Index

As density continues to increase, competition among trees would result in density-induced 

mortality. Health and vigor of the trees would also decline as density increases and stands 

approach maximum stand density index. Existing grasses, shrubs, and forbs would decline in 

vigor and growth and individual trees would begin to die creating small openings in the tree 

canopy as stands reach the threshold of density dependent mortality. Minimum forage would 

likely be produced under tree canopies without a large-scale disturbance and existing trees would 

quickly capture the newly available growing space.

Under the no-action alternative, in 20 years, approximately 70 percent of the Luna project area 

would reach full site occupancy in zones 3 and 4 (table 32). In 40 years, approximately 80

percent of the landscape would reach full site occupancy in zones 3 and 4 (table 32). The percent 

of the landscape in zones 1 and 2 do not meet desired conditions over the 40-year period. 

Table 32. Stand density index (SDI) percent of landscape in 20 and 40 years under alternative A, 

no action. 

Zone

Maximu

m SDI 

(%)

Percent of 

Landscape

Existing 

Percent of 

Landscape in 

20-years

Percent of 

Landscape in 

40-years

Percent of 

Landscape

Desired

1 0 - 25 19 12 9 10-20

2 25 - 35 33 18 11 20-30

3 35 - 55 38 46 41 30-50

4 551 - 100 10 24 39 10-20

1 Zones 3 and 4 upper and lower ranges vary between 55 and 60percent based on review of the existing research 55

percent was used as the respective upper and lower thresholds for zones 3 and 4 for the Luna analysis. 

Vegetation Structural Stage

With the no-action alternative the existing distribution of vegetation structural stages within the 

analysis area for ponderosa pine and woodland cover types would change as trees grow. Barring 

any natural disturbances, both stand density index (table 32) and canopy density (table 33 and 
Chapter 3. Affected Environment and Environmental Consequences

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63

table 34) would continue to increase until site capacity is reached. Over a long period (more than 

40 years), vegetation structural stage 1 and canopy density class A percentages may increase 

slowly as older trees die and deteriorate leaving large openings for regeneration. Also, openings 

may come from mortality from tree competition at high densities, or from abiotic and or biotic 

causes such as insect or disease infections, wildfire, or other damaging agents. 

Table 33. Ponderosa pine percent of area by canopy density class under alternative A, no action, 

from existing to 20 and 40 years compared to desired condition; where Canopy Density Class A = 

Open (0-39%); B = Moderately closed (40-59%); and C = Closed (60% +).

Canopy 

Density Class

Desired 

Condition

(Percent) 

Existing 

Condition

(Percent) 

Condition at 20 

Years

(Percent) 

Condition at 40 

Years

(Percent) 

A 40% 36% 31% 25%

B 40% 51% 43% 27%

C 20% 12% 25% 48%

Table 34. Woodlands percent of area by canopy density class under alternative A, no action, from 

existing to 20 and 40 years compared to desired condition; where Canopy Density Class A = Open 

(0-39%); B = Moderately closed (40-59%); and C = Closed (60% +).

Canopy 

Density Class

Desired 

Condition

(Percent) 

Existing 

Condition 

(Percent) 

Condition at 20 

Years

(Percent) 

Condition at 40 

Years

(Percent) 

A 55% 13% 3% 3% 

B 30% 63% 43% 26% 

C 15% 24% 55% 71% 

Based on modeling the no-action alternative, canopy density for ponderosa pine and woodland 

cover types would become less open (class A) over 20 and 40 years (table 33 and table 34). Over 

the 40-year period, open and moderately closed classes will drop below desired conditions, with 

the open category displaying the greater departure. Canopy density for both cover types would 

greatly exceed desired conditions for the closed class (class C) over the 40 years (table 33 and 

table 34), following the trend of the stand density index (table 32). 

Within the Luna planning area, the model for vegetation structural stages shows changes in 

percent acres in all diameter classes of ponderosa pine cover type from existing through 20 and 

40 years (table 35). In year 20, diameter classes 1 and 5 for ponderosa pine decline and are 

deficient when compared to desired conditions; unlike vegetation structural stage diameter 

classes 2, 3, and 4, which are in surplus (table 35). In 40 years, vegetation structural stage classes 

1 and 2 are both deficit compared desired conditions. As trees grow over the 20 to 40 years, the 

percent acres in vegetation structural stage classes 3, 4, and 5 increase, exceeding desired 

conditions. Vegetation structural stage 6 percent acres does not change over the 40-year 

modeling period. 
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Table 35. Vegetation structural stages (VSSs) by percent area for ponderosa pine cover type for 

existing, 20-year and 40-year conditions compared to desired conditions under alternative A, no 

action. 

Vegetation Structural 

Stage (VSS) 

(Diameter class in 

inches)

Desired 

Condition

(percent acres)

Existing 

Condition

(percent acres)

Condition at 20 

Years

(percent acres)

Condition at 40 

Years

(percent acres)

VSS 1 (0.0-0.9”) 10 22 <1 0 

VSS 2 (1.0-4.9”) 10 <1 20 <1

VSS 3 (5.0-11.9”) 20 30 26 30

VSS 4 (12.0-17.9”) 20 25 38 34

VSS 5 (18.0-23.9”) 20 16 7 27

VSS 6 (24” +) 20 8 8 8 

The existing condition of uneven-aged stand structure for both ponderosa pine and woodland 

cover types are deficit, 46 percent and 40 percent respectively, compared to desired conditions 

(90 percent and 100 percent). Over the 20 and 40 year period, the percent for each increase from 

the existing condition, 53 percent and 43 percent, respectively, at year 40. It is only a small 

increase and still far below desired conditions of 90 percent and 100 percent. 

Habitat Features for Mexican Spotted Owl (Threshold Stands)

Under the no-action alternative, fuel loadings in Mexican spotted owl recovery habitat would not 

be reduced. Consequently, the risk of loss of habitat due to high severity wildfire, would increase 

over time. 

In 20 years, there will be an increase to 33 percent mixed-conifer stands and 6 percent of 

ponderosa pine stands that meet all minimum habitat features (table 36). The remaining stands in 

the mixed conifer and ponderosa pine meet minimum habitat features to varying degrees. 

Table 36. Percent of Mexican spotted owl threshold stands meeting minimum habitat 

characteristic(s) by cover type within 20 years under alternative A, no action.

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class 

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 33% 58% 48% 76% 79%

Ponderosa Pine-Oak 6% 47% 45% 90% 73%

In 40 years, the modeling results suggest a reduction in the percent (6 percent) of mixed conifer 

stands that meet all minimum habitat features (table 37). The stand reduction is due to not 

meeting more than 30 percent basal area in the 12 to 18 inches diameter at breast height class,

and more than 30 percent basal area in the 18 inches or larger tree class. 

The number of ponderosa pine stands meeting minimum habitat features would increase to 20

percent of the stands in year 40 (table 37). 
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Table 37. Percent of Mexican spotted owl threshold stands meeting minimum habitat 

characteristic(s) by cover type within 40 years under alternative A, no action.

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class 

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 6% 33% 39% 94% 94%

Ponderosa Pine-Oak 20% 47% 65% 96% 88%

Old Growth Stand Structural Attributes

Under the no-action alternative, the percentage of area simultaneously meeting the minimum old 

growth stance structural attributes (excluding down dead trees which is unknown) would begin 

to move toward the desired condition during the 40-year period (provided a large scale 

disturbance such as wildfire does not occur). Under this alternative, all minimum old growth 

variables would be simultaneously met in 20 years in 15 percent of the interior ponderosa pine 

group, 12 percent of the mixed-species group, and 96 percent of the woodland species group 

(table 38). Compared to the existing condition the percentage of the ponderosa pine group 

simultaneously meeting old growth conditions remains would remain unchanged, decreasing 

slightly for the mixed-species group by 7 percent and increasing for the woodland species group 

by 8 percent (table 38). 

In 40 years, all minimum old growth variables would be simultaneously met over 31 percent of 

the interior ponderosa pine group, 12 percent of the mixed-species group, and 95 percent of the 

woodland species group. The degree to which the old growth groups meet various stand 

structural attributes fluctuates throughout the 40-year period, and tends to increase for all 

attributes except for meeting the standing dead tree requirements for a give old growth group. 

Although the minimum variable of down dead is unknown for the various groups, given the 

amount of standing dead in the area it is concluded that this variable would be met as the other 

variables are simultaneously met. There would be a high risk of loss of dead and down material, 

dead standing material, and live vegetation through wildfire occurrence due to the increasing tree 

densities over time. 

Overall, table 38 shows the trend for old growth under the no-action alternative from existing to 

20 and 40 years; with no treatments and no disturbances. All stands are moving towards desired 

conditions over the 40 year period, with the exception being the mixed species group. Model 

outputs suggest the degree to which the old growth groups meet various stand structural 

attributes, fluctuates throughout the 40-year period, and tends to increase for all attributes except 

for meeting the standing dead tree requirements. 
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Table 38. Percent of designated 20% (identified) old growth area meeting minimum criteria of 

structural attributes by group from existing through 20 and 40 years under alternative A, no action.

Old Growth 

Group

Minimum Criteria of Structural 

Attributes1

Percent of 

Identified 

Old Growth 

Area – 

Existing 

Condition

Percent of 

Identified 

Old Growth 

Area – 

20 years

Percent of 

Identified 

Old Growth 

Area – 

40 years

Ponderosa pine 20 live trees in main canopy at least 

14 inches in diameter at breast 

height (DBH) 

70 91 98

Ponderosa pine 1 standing dead tree per acre at 

least 14 inches in diameter at breast 

height and at least 15 feet

46 36 61

Ponderosa pine 70 to 90 square feet per acre total 

basal area

98 99 100

Ponderosa pine 40 to 50% total canopy cover 34 48 70

Ponderosa pine Percent area simultaneously meeting 

all attributes2 

12 15 31

Mixed-species 12 to 16 live trees in main canopy at 

least 18 inches in diameter at breast 

height

45 61 75

Mixed-species 2.5 standing dead tree per acre at 

least 14 inches in diameter at breast 

height and at least 20 feet

85 40 19

Mixed-species 80 to 100 square feet per acre total 

basal area

100 100 100

Mixed-species 50 to 60% total canopy cover 43 51 65

Mixed-species Percent area simultaneously meeting 

all attributes2

19 12 12

Woodland 12 to 30 live trees in main canopy at 

least 9 inches in diameter at root 

crown

99 100 100

Woodland 1 standing dead tree per acre at 

least 9 inches in diameter at root 

crown and at least 8 feet

88 99 96

Woodland 6 to 24 square feet per acre total 

basal area

100 100 100

Woodland 20 to 35% total canopy cover 97 97 99

Woodland Percent area simultaneously meeting 

all attributes2

87 96 95

1 Low site productivity values were used as threshold for each old-growth group for the Luna planning area.

2 Age and down dead trees are unknown for the group.

Effects Common to Alternatives B, C, and D

Forest Cover Types

As in the no-action alternative, changes in tree growth, sprouting, regeneration of other species, 

and climatic variation, may cause a change in the forest cover type acreage within the Luna 

project area. Under all action alternatives, there would not be a decline in the grassland cover 

type, at 20 years, as woody vegetation is cut and burned through grassland maintenance 

treatment. Restoration of the grasslands currently regenerating into pinyon pine-juniper 
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67

woodlands and ponderosa pine forests would increase the grassland component in the Luna 

project area by 1 percent in the first 20 years. Continued grassland maintenance would retain the 

1 percent increase in the grassland cover type forty years post-harvest (table 39).

The majority of the species would fall within the desired percent range for management over the 

40-year period (table 39). There would be slight increases for several of the mixed-species cover 

types including Douglas-fir, white fir and southwest white pine for both the 20- and 40-year 

periods. These cover types fall within Mexican spotted owl recovery habitat in the Luna project 

area where it is desirable to have a variety of species present. Pinyon-juniper and oak woodlands 

would also increase in the 20-year period by approximately 0.9 and 0.8 percent, respectively. 

This increase would be sustained through the 40-year period. The ponderosa pine cover type 

would sustain the largest decline in cover type decreasing by 4 percent at 20 years, and 6.2 

percent at 40 years. This is slightly outside of the desired range for management at 40 years postharvest.

The decrease in the ponderosa pine cover type is predicted through modeling, but actual 

prescriptions would be implemented to favor ponderosa pine in the ponderosa pine cover type 

and where ponderosa pine has transitioned to woodlands. There might be a slight decrease in the 

ponderosa cover type in some areas due to favoring of other species in Mexican spotted owl 

recovery habitat, transition from ponderosa pine to Douglas-fir in no-treatment areas, and also in 

removing encroaching conifers in grassland and meadow restoration treatments. Therefore, while 

model outputs and professional experience show a net overall reduction in the ponderosa pine 

cover type under various thinning regimes, the actual amount is largely dependent on the 

individual stand conditions pre-treatment and how the treatment is applied. 

Table 39. Percent change from existing forest cover type acres at 1 year, 20 years, and 40 years 

post harvest compared to range of desired percent for alternatives B, C, and D.

Forest Cover Type

Acres (Range 

of Desired 

Percent 

Change)

Percent Change

(%)

1-year Postharvest

Percent Change 

(%)

20 years Postharvest

Percent Change 

(%)

40 years Postharvest

Grassland/Meadow 21,941 (+0-2%) +1% +1% +1% 

Douglas fir 6,323 (+0-2%) +0.4 +0.2% +2.2% 

Engelmann Spruce 109 (+0-2%) 0% 0% 0% 

Oak Woodland 1,414 (+/-2%) +0.2% +0.9% +0.9% 

Pinyon-Juniper 41,713 (+/-5%) +1.6% +0.8% +0.8% 

Ponderosa pine 87,195 (+/-5%) -3.9% -4.0% -6.2% 

Riparian 784 (NA) N/A N/A N/A

Southwestern White Pine 69 (+0-2%) 0% +0.3% +0.3% 

White Fir 6,887 (+0-2%) +0.7% +0.8% +0.9% 

Reforestation Area 3,954 (NA) N/A N/A N/A

Rocky Area 942 (NA) N/A N/A N/A

171,3311

1 Acreage does not include private lands.

Note: The summarization of results includes all stands as part of the modified proposed action alternative including not 

no treatment stands and prescribed burn-only stands. Prescribed burn only stands were not directly modeled in FVS and 

were modeled as no action stands.

Results were given 1 year post-harvest since mortality was not modeled for the prescribed burning modeled postthinning treatments.
Chapter 3. Affected Environment and Environmental Consequences

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68

Forest stands would be treated, following principles described in the Rocky Mountain Research 

Station general technical report GTR-310 (Reynolds et al. 2013) where applicable. 

Implementation of principles provided in GTR-310, where appropriate, that restore the 

composition and structure of frequent-fire forests will result in a more open forest structure with 

a decreased potential for stand-replacing wildfire and epidemic outbreaks of insects and diseases 

(Fitzgerald 2005; Fulé et al 2002, 2004; Graham et al 2004; Roccaforte et al 2008; Strom and 

Fulé 2007 as cited in Reynolds et al. 2013). 

Stand Density Index

Under all action alternatives, 1 year post-harvest, zones 1 and 2 would be above the desired 

range (table 40), while 23 percent of the landscape in zones 3 and 4 would be at full site 

occupancy, but are below the desired range. 

Modeling for changes in stand density over 20 and 40-year periods show a transitioning of the 

landscape from zone to zone over time (table 40). The model does not include the possibility of 

re-entry into areas for treatment activities. Within 20-years, all zones would be within or very 

close to desired percent of the landscape. Zone 1 would be in surplus by roughly 1 percent, and 

zone 2 would be at the upper end of the desired range. In 40 years, the percent of the landscape 

at full site occupancy would increase to roughly 67 percent, with zone 3 still being with the 

desired range, but zone 4 would be 10 percent in surplus. 

Table 40. Percent of maximum stand density index (SDI) 1 year, 20 years, and 40 years post-harvest 

for alternatives B, C, and D compared to desired percent of the landscape.

Zone

Maximum 

SDI (%)

Desired 

Percent of 

Landscape

Percent of 

Landscape 

1 year Postharvest

Percent of 

Landscape 

20 years Postharvest

Percent of 

Landscape 

40 years Postharvest

1 0 - 25 10-20 35 21 16

2 25 - 35 20-30 42 30 18

3 35 - 55 30-50 17 32 37

4 55 - 100 10-20 6 16 30

The decreases to the stand density indicator are in alignment with recommendations for the 

management of southwestern forests (Reynolds et al. 2013) because increased density levels 

create conditions for wildland fires or insects and disease outbreaks. Drought is also a significant 

stressor to vegetation communities in this area of the United States; the effects of drought are 

amplified by higher vegetation density levels, as the need for moisture is increased by greater 

numbers of plants. 

Thinning would reduce tree competition, create openings, and release residual trees. The direct 

effects of thinning would be increased stand and landscape level resistance and resiliency to fire, 

insects, and disease. Additionally, decreased stand densities would maintain healthy forest 

conditions during drought cycles. These effects would be apparent immediately following 

thinning. 

Grassland maintenance or meadow restoration treatments would result in a decrease in tree 

density which would allow for an increase in native grasses and forbs. There would also be an 

increase in grasses and forbs in forested areas as the canopy would be open allowing light and 
Chapter 3. Affected Environment and Environmental Consequences

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moisture to reach the forest floor. The restoration of grass-forb-shrub interspaces and resultant 

separation of tree canopies and increase in herbaceous plant cover will provide fuels to carry 

frequent surface fires. Restoration of the characteristic fire regimes should sustain forest 

composition, structure, processes, and functions (Reynolds et al. 2013). 

The direct effects to vegetation from thinning and subsequent fuels treatments would be a 

reduction to the stand density indicator. Active management, through forest thinning, maintains 

healthy trees that are less susceptible to high levels of mortality. Individual or small groups of 

trees may die, but the forest would be retained. Forests managed with appropriate residual 

density are able to withstand the effects of fire (Agee and Skinner 2005).

Additionally, aside from the changes to the indicator measures for vegetation, fuels reduction 

work would create landscapes with residual fuel loadings closer to desired conditions. 

Subsequent prescribed burning treatments post-thinning would result in less surface, ladder, and 

canopy fuels. This would change the fuel content within the stands and across the landscape, 

which would affect future wildland fires. These stand and landscape level changes in the thinned 

stands will result in a discontinuous canopy and decreased crown bulk densities. Research has 

shown that this along with a reduction in surface fuels and increase in canopy base height from 

prescribed fire will help create fire resilient landscapes (Agee and Skinner 2005). Maintenance 

treatments including prescribed fire and mechanical treatments would be needed to maintain or 

move towards desired conditions. 

Vegetation Structural Stage

The action alternatives would result in more uneven-aged ponderosa pine and woodland stands 

through thinning, burning, and group selection silvicultural treatments. Thinning and prescribed 

burning stands would reduce competition and release trees to grow at faster rates, than stands 

that are left untreated. Increases in vegetation structural stage class from one structural stage to 

the next would occur at a slightly more rapid rate than with the no action alternative. Creating 

small openings (regeneration groups up to 4 acres in size outside northern goshawk post-fledging 

family areas and up to 2 acres in size within northern goshawk post-fledging family areas) by 

tree cutting and removal and burning would provide an opportunity for regeneration of small 

clumps of trees and increase the percentage of the landscape in vegetation structural stage 1. 

Treatments would be designed to promote structural heterogeneity leaving a mosaic of groups of 

trees providing areas of higher basal areas and canopy cover, in addition to scattered individual

trees, and openings. 

One year post harvest, canopy density within the ponderosa pine cover type would be more open 

(67 percent in class A) (table 41). Over time, canopy density would progress towards moderately 

closed and closed classes (table 41). Based on modeling, the ponderosa pine canopy density 

would near desired conditions over 40 years. 

For the woodland cover type, the open (class A) and closed (class C) canopy density classes are 

deficit from desired conditions (table 42). Moderately closed density class (class B) is the 

condition over majority of the area. Over 20 to 40 years, post-harvest would progress towards 

more percent area of closed canopy density (class C), but would not near desired conditions 

(table 42). 
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Table 41. Ponderosa pine percent of area by canopy density class under alternatives B, C, and D, 1; 

20; and 40 years post harvest compared to desired condition; where canopy density class A = Open 

(0-39%); B = Moderately closed (40-59%); and C = Closed (60% +).

Canopy 

Density Class

Desired 

Condition

(Percent) 

Condition at 1-

year Post Harvest

(Percent) 

Condition at 20-

Years Post 

Harvest

(Percent) 

Condition at 40-

Years Post 

Harvest

(Percent) 

A 40% 67% 51% 43%

B 40% 31% 45% 45%

C 20% 1% 4% 11%

Table 42. Woodlands percent of area by canopy density class under alternatives B, C, and D, 1; 20; 

and 40 years post harvest compared to desired condition; where canopy density class A = Open (0-

39%); B = Moderately closed (40-59%); and C = Closed (60% +).

Canopy 

Density Class

Desired 

Condition

(Percent) 

Condition at 1-

year Post Harvest

(Percent) 

Condition at 20-

Years Post 

Harvest

(Percent) 

Condition at 40-

Years Post 

Harvest

(Percent) 

A 55% 2% 3% 2%

B 30% 93% 70% 50%

C 15% 5% 27% 47%

Structural stages for ponderosa cover type for 1 year, 20 years, and 40 years post-harvest are 

shown in table 43. In year one post-harvest, vegetation structural stages 1 and 5 are surplus of 

desired conditions. Immediately post-treatment, there would be an increase in vegetation 

structural stage 1 from established openings. Over time, this acreage would progress to 

vegetation structural stages 2 through 6. Prescribed burning in the surplus categories in 

vegetation structural stages 4 and 5 would reduce the amount of smaller trees and enhance the 

growth and vigor of residual trees promoting their ascendancy into larger size classes over time. 

This would facilitate stand structural development while also enhancing stand health and vigor 

through reducing tree density. Stand would become more resilient to disturbances, like insect and 

diseases. Post-harvest, there would be an increase in the percentage of acres in uneven-aged 

structure for ponderosa pine from 46 percent to 64 percent and only a slight increase for 

woodland 40 percent to 41 percent. 

Table 43. Vegetation structural stages by percent area for ponderosa pine cover type for 1-year, 20-

year and 40-year post harvest conditions for alternatives B, C, and D compared to desired 

conditions.

Vegetation Structural 

Stage (VSS)

(Diameter class in 

inches)

Desired 

Condition

(percent acres)

Condition at 1 

year Post 

Harvest

(percent acres)

Condition at 20 

Years Post 

Harvest

(percent acres)

Condition at 40 

Years Post 

Harvest

(percent acres)

VSS 1 (0.0-0.9”) 10 34 10 3 

VSS 2 (1.0-4.9”) 10 <1 23 4 

VSS 3 (5.0-11.9”) 20 21 14 34

VSS 4 (12.0-17.9”) 20 19 27 21

VSS 5 (18.0-23.9”) 20 24 20 26

VSS 6 (24” +) 20 1 6 12
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In 20 years post treatment, vegetation structural stages 1 and 5 would meet the desired condition, 

and classes 2 and 4 would be surplus of desired conditions. Vegetation structural stages 3 and 6 

would be below desired conditions (table 43). For uneven and even aged stand structure, the 

ponderosa pine and woodland cover type remain relatively the same as one year post treatment, 

67 percent and 40 percent respectively. 

In 40 years post treatment, vegetation structural stages 1, 2 and 6 would be deficit; vegetation 

structural stages 3 and 5 would be surplus; and vegetation structural stage 4 would be almost at 

desired conditions (table 43). For uneven-aged structure ponderosa pine remains unchanged from 

20 years at 67 percent and the woodland group would increase slightly to 44 percent. 

Over the 40-year period, the landscape supports a forest composed of uneven aged stands with 

larger diameter trees. However, the amount of forest openings are reduced. 

Habitat Features for Mexican Spotted Owl (Threshold Stands)

There are a variety of treatments proposed within some of the habitat being managed for 

Mexican spotted owl threshold stands including prescribed burning and small diameter thinning 

with follow up slash treatments. Treatments would reduce fuel loadings and the risk of loss of 

habitat from wildfires. Additional benefits of density reduction, diversity of forest composition 

and structure would also be realized with implementation of the action alternatives. 

Under the action alternatives none of the target threshold stands would simultaneously meet all 

the minimum habitat parameters as outlined in the first revision of the Mexican spotted owl 

recovery plan (2012) 1-year post-harvest (table 44). One-year post harvest individual habitat 

parameters would be met to varying degrees for the two cover types.

Table 44. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 1 year post-harvest under alternatives B, C, and D.

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class 

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 0% 61% 15% 45% 33% 

Ponderosa Pine-Oak 0% 49% 43% 27% 43% 

In year 20 post-harvest, approximately 24 percent of the Mexican spotted owl threshold stands in 

the mixed-conifer and 6 percent of the stands in the ponderosa pine stands would simultaneously 

meet all the minimum habitat features (table 45). Individual stand variables would be met to 

varying degrees for the two cover types. Variables would improve from 1-year post-harvest 

values (table 44). 

Table 45. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 20 years post-harvest under alternatives B, C, and D. 

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class 

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 24% 58% 52% 67% 51%

Ponderosa Pine-Oak 6% 47% 49% 88% 73%
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In year 40 post-harvest, approximately 18 percent of the Mexican spotted owl threshold stands in 

the mixed-conifer and 22 percent of the stands in the ponderosa pine would simultaneously meet 

all the minimum habitat features (table 46). Individual stand variables would also be met to 

varying degrees for the two cover types. Variables would improve from 20-years post-harvest 

(table 45) except for basal area for trees in the 12 to 18 inches in diameter at breast height class

in the mixed-conifer stands (table 46).

Table 46. Percent of Mexican spotted owl threshold stands meeting minimum habitat features by 

cover type 40 years post-harvest under alternatives B, C, and D.

Forest Cover Type

% Stands 

Meeting all 

Features

Basal Area

Size Class 

of 12-18" 

DBH

Basal Area

Size Class

>18" DBH

Stand Avg. 

Basal Area

Stand Avg. 

Trees per 

Acre 18”+

Mixed-conifer 18% 33% 55% 100% 94%

Ponderosa Pine-Oak 22% 47% 71% 96% 88%

Old Growth Stand Structural Attributes

Under the action alternatives, the percentage of area simultaneously meeting the minimum old 

growth variables (excluding down dead trees which is unknown) would begin to move toward 

the desired condition during the 40-year period (providing a disturbance doesn’t occur e.g. stand 

replacing). 

After the 1-year post treatment (table 47) there would be a slight decrease in stand densities and 

for some of the other structural attributes in comparison to the no-action alternative (table 38). 

However, the percentage of groups meeting all minimum old growth minimum criteria changed 

from none to the most 2 percent from no action alternative. 

In 20 and 40 years post treatment, under the action alternatives, all minimum old growth 

variables would trend towards desired conditions for all vegetation groups. However, the mixedspecies group stays relatively static. Individual structural attributes would increase for all old 

growth variables to varying degrees. Although the minimum variable of down and dead trees is 

unknown for the interior ponderosa pine group, the mixed-species group, and the woodland 

species group, given the amount of standing dead in the area it is concluded that this variable 

would also be met as the other variables are simultaneously met. 

Although the area would be managed with low to moderate average basal areas across the 

landscape, project design would provide high basal areas and tree canopy cover retaining clumps 

of dense trees throughout the area. Openings would also be enhanced where feasible and would 

lower the average basal area and provide a reduction of fuels to reduce potential damage to old 

growth components in the event of a wildfire. There would be a low to moderate risk of loss of 

dead and down material, dead standing material, and live vegetation in treated areas through 

wildfire occurrence due to the low to moderate average tree densities. 
Chapter 3. Affected Environment and Environmental Consequences

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73

Table 47. Percent of designated 20% (identified) old growth area meeting minimum criteria of 

structural attributes by group in 1; 20; and 40 years post-harvest under alternatives B, C, and D.

Old Growth 

Group

Minimum Criteria of Structural 

Attributes1

Percent of 

Identified 

Old Growth 

Area – 

1 year postharvest

Percent of 

Identified 

Old Growth 

Area – 

20 years

postharvest

Percent of 

Identified 

Old Growth 

Area – 

40 years

postharvest

Ponderosa pine 20 live trees in main canopy at least 

14 inches in diameter at breast 

height (DBH) 

68 89 95

Ponderosa pine 1 standing dead tree per acre at 

least 14 inches DBH and at least 15 

feet

46 37 62

Ponderosa pine 70 to 90 square feet per acre total 

basal area

95 95 96

Ponderosa pine 40 to 50 percent total canopy cover 31 41 55

Ponderosa pine Percent area simultaneously meeting 

all attributes2 

13 16 30

Mixed-species 12 to 16 live trees in main canopy at 

least 18 inches DBH

46 59 75

Mixed-species 2.5 standing dead tree per acre at 

least 14 inches DBH and at least 20 

feet

45 48 55

Mixed-species 80 to 100 square feet per acre total 

basal area

53 100 100

Mixed-species 50 to 60 percent total canopy cover 22 52 64

Mixed-species Percent area simultaneously meeting 

all attributes2

10 12 12

Woodland 12 to 30 live trees in main canopy at 

least 9 inches diameter at root crown 

(DRC) 

99 100 100

Woodland 1 standing dead tree per acre at 

least 9 inches DRC and at least 8 

feet

88 95 97

Woodland 6 to 24 square feet per acre total 

basal area

100 100 100

Woodland 20 to 35 percent total canopy cover 97 93 99

Woodland Percent area simultaneously meeting 

all attributes2

87 89 96

1 Low site productivity values were used as threshold for each old-growth group for the Luna planning area. 2 Age and down dead trees are unknown for the group.
Chapter 3. Affected Environment and Environmental Consequences

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Alternative C – Herbicide Utilization

All other effects are the same as alternative B and D. 

Under this alternative, the direct effect to vegetation would be a reduced amount of shrub and 

woodland tree species. Reducing the presence of these species would have the indirect effect of 

creating growing space for grass and forb species in grasslands, and also for conifer seedlings in 

forested areas. The objective of this treatment would be to remove competing species in 

grassland restoration treatments and to create ideal conditions for grass and forb species to 

regenerate. Herbicides would also be applied to sprouting alligator juniper in forested areas 

which would create growing space for conifer establishment and growth. By decreasing plant 

competition, the planted and naturally regenerated conifer species would have increased growth 

rates as they would have more available soil moisture, nutrients and sunlight. 

Herbicide application would increase treatment effectiveness and help set back succession of 

competing shrub and juniper species which should help maintain grassland treatments for a 

longer period of time, and also help facilitate conifer establishment and growth in forested areas. 

Herbicide application would also be targeted within the wildland urban interface where sprouting 

of juniper post-thinning could create ladder fuels. In this case herbicide treatment would help 

increase the effectiveness of fuel reduction treatments to meet fuels objectives, with treatments 

lasting longer than with tree cutting alone. 

Cumulative Effects

The 185,586-acre Luna planning area is part of the larger Escudilla Landscape, a 279,470-acre 

landscape planning area that extends across both the Apache-Sitgreaves and Gila National 

Forests. Twenty-five years was chosen as a benchmark for assessing cumulative effects as this 

allows adequate time for vegetation to respond to forest vegetation treatment activities such as 

timber harvest and pre-commercial thinning. There have been numerous vegetation management 

activities, including mechanical treatments and prescribed fire treatments, within the Luna 

Restoration Project area over the past 25 years. 

Overall the number of treatments has decreased in the last 25 years compared to the amount of 

treatments occurring in the 1980s. This decline can be partially attributed to reduction in 

commercial timber activities across the Gila National Forest and throughout the Southwestern 

Region. Timber harvest activities across the Gila have declined by over 50 percent, going from 

an average of 25,000 CCF (100 cubic feet) per year in the early 1980s, to a current average of 

10,000 CCF per year. This reduction in timber harvest has, in turn, reduced the number of roads 

constructed in support of these activities. 

Current activities range from fuelwood collection, commercial thinning, salvage cutting, precommercial thinning for wildlife, watershed, vegetation and forest health improvement, precommercial thinning, overstory removal, road closures, and fuels reduction thinning. In recent 

years (2006 to current), timber sale activities have included the decommissioning of non-system 

roads following completion of harvest operations. Current and future planning projects also 

analyze the closure of non-system roads following completion of harvest activities. In addition, 

incorporation of best management practices and design features is required on all vegetation 

management projects. Best management practices address Gila National Forest staff

responsibilities to implement the Clean Water Act, which is accomplished through 

implementation and monitoring of best management practices. 
Chapter 3. Affected Environment and Environmental Consequences

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75

On the adjacent Apache-Sitgreaves National Forest, there are 35,105 acres of vegetation 

improvement, thinning, and prescribed burning projects planned. A recent decision was signed 

for the 68,000 acre West Escudilla Restoration Project which includes thinning trees and 

prescribed fire on the Alpine and Springerville Ranger Districts along the New Mexico-Arizona 

state line. In addition, it is likely there is “Fire Wise” hazardous fuels reduction work occurring 

on private lands within and adjacent to the project area. This project would be important to the 

success of future fire suppression efforts and complements past treatments and those currently 

occurring or being proposed on adjacent Federal, State, and private lands. 

Cumulatively, the above activities in combination with prescribed fire would facilitate restoring 

and sustaining ecological processes in fire-dependent ecosystems and move vegetation and fuel 

conditions towards their historic fire regimes. Treatments would reduce density, creating more 

open forest conditions, with increased herbaceous, forb, and woody vegetation production. These 

treatments would also facilitate regeneration in openings and increase stand structural 

complexity and diversity at both the stand- and landscape-scale. Change in vegetation 

composition, stand density, and structure would help create more resilient ecosystems that are 

better suited to future disturbances. These combined treatments would complement the purpose 

and need goals for vegetation restoration and fire and fuels management by restoring departed 

vegetation communities, and reducing the impact of high-severity fire on private inholdings, 

communities, infrastructure, cultural resources, and livelihoods within the planning area. It 

should be noted there would be no effects to vegetation outside of the analysis area boundary as 

a result of this project. 

Fire and Fuels 

Assumptions and Limitations

Assumptions

A number of assumptions were made in this analysis and are listed below:

• Current forest plan and other management direction would continue in the future. 

• No major disturbance, such as wildfire, blow down or insect epidemics would occur from 

the baseline year of 2016 until implementation is completed. This analysis discusses future 

risk and probable effects if a disturbance occurs, it is not a future projection of the 

occurrence.

• The project area is sufficient to analyze and discuss effects to fire and fuels. 

♦ The low-intensity prescribed burning treatments were not modeled in this analysis as 

they are not within a delineated unit or stand boundary, and due to the uncertainty of 

the exact location of where the prescribed burns would occur and the size of burn 

units. 

♦ Where appropriate, the vegetation characteristics (canopy base height, canopy cover, 

stand height, crown bulk density, and fuel model) were modified in treatment units to 

reflect the expected vegetation conditions after treatment.

♦ Acres of private land and lands of other ownership that lie within the Luna Restoration 

project area boundary were included in the discussion.
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

76

Limitations of the Models

“It should be noted a model is a simplification or approximation of reality and hence will not 

reflect all of reality” (Stratton 2006). The use of models depends upon sample data, validity of 

the model itself, and assumptions made by the modeler. All three affect the results. The use of 

FlamMap 5 in this analysis is to generally characterize and display existing conditions and the 

nature and magnitude of treatment effects to inform decisions to be made. The modeling results 

are not to be taken as reality. Fire models are tools to help depict relative change in fire behavior 

and growth across the landscape. Although there are limitations to fire behavior modeling, the 

model outputs provide useful information for planning, assessing and prioritizing fuel treatments 

(Stratton 2004 and 2006). While we have a good general understanding of the factors that govern 

fire behavior, the interactions among these factors and the way in which fire behaves on the 

landscape are highly complex. As a result, fire behavior and severity can be understood and 

predicted in general terms, but exact predictions are not possible. Different models have been 

developed that are widely used and useful to assist in managing fires and developing fuel 

treatment plans. However, there are key uncertainties in how the simplifying assumptions of 

models affect their accuracy and as well as uncertainties that result from difficulties of providing 

adequate input data to operate the models (Graham et al. 2004). Given the uncertainty of any 

modeling exercise, the results are best used to compare the relative effects of the alternatives, 

rather than as an indicator of absolute effects (Graham et al. 2004). 

Affected Environment

Fire regime groups and acres of each for the Luna planning area is displayed in table 48. A fire 

regime is the pattern, frequency, and intensity of the wildfires that prevail in an area over long 

periods of time. A fire regime describes the spatial and temporal patterns and ecosystem impacts 

of fire on the landscape.

LANDFIRE was used to conduct this assessment of fire regime groups within the project area. 

Approximately eighty-three percent of the project area is classified as Fire Regime Group I with 

a 0 to 35 year fire return interval with low/mixed fire severity. Approximately two percent is 

classified as Fire Regime Group II with 0-35 yeas fire frequency and replacement severity. 

Seven percent is classified as Fire Regime Group III with a 35 to 200 year fire frequency and 

mixed/low severity. Almost eight percent of the project area is classified as Fire Regime Group 

IV with a 35- to 200-year frequency and stand replacement severity and less than one percent is 

classified as Fire Regime Group V with 200+ year frequency and replacement to any type of 

severity. 
Chapter 3. Affected Environment and Environmental Consequences

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Table 48. Summary of fire regime groups within the Luna planning area.

Fire 

Regime 

Group Frequency Severity Severity Description

Acres of 

Project Area

Approximate 

percentage 

of Project 

Area

Group I 0 to 35 

years

Low/mixed Generally low-severity 

fires replacing less than 

25% of the dominant 

overstory vegetation; can 

include mixed-severity 

fires that replace up to 

75% of the overstory. 

153,800 83

Group II 0 to 35 

years

Replacement High-severity fires 

replacing greater than 

75% of the dominant 

overstory vegetation. 

3,592 2 

Group III 35 to 200 

years

Mixed/low Generally mixed severity; 

can also include lowseverity fires. 

12,890 7 

Group IV 35 to 200 

years

Replacement High-severity fires 14,292 8 

Group V 200+ years Replacement/

any severity

Generally replacementseverity; can include any 

severity type in this 

frequency range. 

444 <1

Condition classes are used to categorize how much key ecosystem components such as species 

composition, structural stage, and stocking level, have changed in an area due to changing fire 

regimes. One or more activities, such as fire exclusion, insects and disease, and past 

management activities, can cause a change in fire regimes (Schmidt et al. 2002). 

Vegetation condition class (VCC) distribution in the project area is shown below in table 49. 

Approximately 38 percent of the project area is within vegetation condition class Ia and Ib and 

has a low departure from the reference condition. Approximately 18 percent is classified as 

vegetation condition class IIa and IIb and is moderately departed from the reference condition; 

and approximately 43 percent is classified as vegetation condition class IIIa and is highly 

departed from the reference condition. 

Table 49. Vegetation condition class distribution in the Luna planning area.

Vegetation Condition Class 

(VCC) Acres* 

Approximate Percentage of 

Project Area

VCC Ia, Very Low 1,034 <1

VCC, Ib Low 69,455 37

VCC IIa, Moderate-Low 20,408 11

VCC IIb, Moderate -High 12,835 7 

VCC, IIIa, High 80,565 43

VCC IIIb, Very High 0 0 

*Unburnable acres were not included; lands of other ownership within the Luna project area 

boundary are included. 
Chapter 3. Affected Environment and Environmental Consequences

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78

Environmental Consequences

Alternative A 

There would be no changes in current management and forest plan would continue to be 

implemented. There would be no direct effect to fuels under this alternative and no reduction of 

potential fire behavior. There are no foreseeable vegetation projects or prescribed fire projects 

proposed within the next five years. The no-action alternative would not move the project area 

towards desired conditions, nor would it meet the purpose and need; to reduce the impacts of 

high-severity fire and to implement vegetative treatments to restore departed landscapes at risk 

of fire. 

In the absence of human-caused or natural disturbance such as vegetation treatment activities 

and wildfire, there would be an increased accumulation of surface and ladder fuels from insect 

and disease activity, storm damage, and the progression of forest succession, growth and change. 

Structural changes in vegetation may lead to increase departure from historic fire regimes and 

ecosystem function. Vegetation condition class departure would be expected to continue away 

from the desired condition. The result would be increased surface and ladder fuels that affect 

flame length, surface fuel loading levels (tons/acre) that affect fire intensity and severity, as well 

as increased tree crown density that make crown fire initiation more likely. Denser crown 

spacing and ladder fuels may contribute to uncharacteristic wildfire events. Increased fuel 

loading levels would continue to pose a threat to adjacent private land and ecosystems as fire 

suppression becomes more difficult. It is likely the ability of firefighters to safely and effectively 

suppress wildland fire would become more difficult as fire behavior characteristics intensify. 

Once wildfire transitions to the tree crowns, direct suppression tactics are not effective. Wildfires 

burning under these conditions would have greater potential to become large and have adverse 

effects. 

Modeling results suggest the majority of the planning area is at risk to crown fire (table 8, MAP 

1). In alternative A, the percent of the landscape susceptible to crown fire activity would increase 

over time. 

Wildfires may impact private lands and other resources. Direct suppression tactics by firefighting 

forces may not be as effective in the project area under the no-action alternative. Tree mortality, 

as a result of insect and disease activity and natural forest succession, would continue into the 

future and would exacerbate the amount of standing and downed fuels in the project area. 

Effects Common to Alternatives B, C, and D

Implementing Alternative B, C or D would result in a reduction in fuel loading and decrease fire 

behavior characteristics when compared to the existing condition. Treatments will help to 

maintain or shift areas towards the desired condition; reducing crown fire potential (table 50).

Crown fire potential refers to the conditions that allow fire to spread through the forest canopy. 

Modeling results suggest crown fire potential would be reduced to 16 percent of the project area

compared to 67 percent under alternative A. Also, model results show 84 percent of the project 

would transition to surface fire, as compared to 24 percent under the no-action alternative (table 

50). 

Approximately 83 percent (153,800 acres) of the project area is classified as fire regime group I 

with a 0 to 35 year fire frequency (low-mixed fire severity) (table 48). With implementation of 
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

79

alternatives B, C, or D, approximately 116,000 acres classified in fire regime group 1 would be 

treated, moving towards restoring the natural and historical fire regime (table 50). Additionally 

approximately 19,000 acres would be treated in areas classified as fire regime groups II through 

V. The project area would benefit from the proposed treatments with respect to ecosystem 

function, forest health, resiliency and reduction in potential fire behavior. 

Table 50. Summary comparison of all alternatives for fire related concerns in the Luna planning 

area.

Concern Indicator/Measure Alt A Alt B,C,D

Reduce impact of high 

severity fire

Percent of modeled crown fire (passive 

and active)

67% 16%

Reduce impact of high 

severity fire

Percent of modeled surface fire 24% 84%

Restore departed landscapes 

that are at risk of fire.

Approximate acres treated in fire regime 

group I 

0 116,000

Implementation of low-severity prescribed fire in the Dry Blue and along the San Francisco

Divide is expected to result in mortality of smaller diameter understory trees, brush (ladder 

fuels), and consumption of dead and down fuels. Single tree torching, isolated group tree 

torching, or both may occur. After multiple entries, it is anticipated there would be open 

interspaces of various sizes, groups of trees with interlocking crown, multi-storied canopies, and 

retention of larger-diameter over story trees. Overall, the treatments would move towards the 

ability to reintroduce fire into a fire-adapted ecosystem.

Mixed-severity prescribed burns are expected to create a mosaic of burned and unburned patches 

of vegetation. Prescribed burns would result in multi-storied canopies, and early seral 

grass/forb/shrub openings. 

It is expected mechanical and prescribed fire treatments would reduce surface, ladder and crown 

fuels and change the fuel model profile. Raising canopy base heights and reducing tree density in 

mechanical thinning units would reduce ladder fuels and potential for crown fire initiation. 

Cutting trees for vegetation health and reduction of canopy closure would initially result in 

increased surface fire intensity and spread rate due to residual activity fuels contributing to 

existing surface fuel loadings. Treatments would begin to restore ecological processes, including 

the frequent low- to mixed-severity fire regimes. Proposed treatments are expected to reduce 

fire behavior potential and the risk of wildfire impacting adjacent private lands, natural 

resources, and infrastructure. 

The resulting treatments would allow the increased use of wildfires to maintain this landscape. 

The risk of wildfire impacting private lands, natural resources, and infrastructure would be 

reduced; the landscape would become more resilient. 

National Forest System land and adjacent private land would be positively affected from the 

reduction of hazardous fuels and subsequent modification of potential fire behavior. 

Forest Plan Amendment

Amending the forest plan to allow a one-time exceedance in the amount of activity fuels treated 

and prescribed burning implemented would beneficially benefit fire and fuels management. 
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

80

Allowing a greater amount of acres to be treated is correlated to a larger reduction in potential 

fire behavior across the project area, and acres treated to facilitate restoration towards desired 

conditions and historic fire regimes. 

Cumulative Effects 

The cumulative effects analysis area was determined to be the area within the project analysis 

boundary, because it is of sufficient size to manage vegetation, fire behavior and effects on a 

landscape level. Past, current, and future activities include such things as use and maintenance of

trails; developed and dispersed recreation; and administrative facilities, motorized vehicle use, 

all range management activities, rural and urban development, prescribe burning, fuelwood 

cutting, and mechanical vegetation management. 

For analyzing cumulative impacts to fire and fuels management, only those activities including 

vegetation treatments, and prescribed burning will be used in the analysis. Within the Luna 

planning area approximately 25,000 acres have received mechanical or burning treatments in the 

past 25 years. Over 6,000 acres has been treated in the last 12 years (table 51). 

Table 51. Vegetation project treatments acres, type, and implementation date within the last 12 

years within the Luna planning area.

Name Acres Type of Treatment Year(s) Treated

East Centerfire 

Prescribed Burn

5,420 Broadcast burn 2006, 2011, 2012

Wallow Site Preparation 181 Piles 2014

Tucson Electric Power 

Company Transmission 

Vegetation Project

192 Thinning 2014

Canovas Thinning 636 Thinning 2006

The Wallow Fire in 2011 burned approximately 15,000 acres within the Luna Restoration 

Project. In 2016, two wildfires totaling 2,394 acres burned within the planning area. 

On the Apache-Sitgreaves National Forest, there are 35,105 acres of vegetation improvement, 

thinning, and prescribed burning projects planned. A recent decision was signed for the 68,000-

acre West Escudilla Restoration Project which includes thinning trees and prescribed fire on the 

Alpine and Springerville Ranger Districts along the New Mexico-Arizona state line. In addition, 

hazardous fuels reduction work occurring on private lands within and adjacent to the project 

area. 

Cumulatively, these activities result in reductions in fire behavior potential to a greater degree 

than described in the effects of the action alternatives. Activities discussed would cumulatively 

break up fuel continuity (surface, ladder, and crown fuels) across the landscape. These combined 

activities would greatly facilitate restoring and sustaining ecological processes in fire-dependent 

ecosystems and move vegetation and fuel conditions toward their historic frequent low- to 

mixed-severity fire regimes. These combined treatments would complement the purpose and 

need goals for fire and fuels management by reducing the impact of high-severity fire on private 

inholdings, communities, infrastructure, cultural resources and livelihoods within the planning 

area. It would also support the reintroduction of fire into fire-dependent ecosystems. 
Chapter 3. Affected Environment and Environmental Consequences

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81

Past wildland fire events and management activities have affected the landscape and would 

continue into the future. The existing condition was influenced by events including; wildfires, 

fire suppression, fire exclusion, insects and disease, prescribed burning and past timber 

management activities. 

The effects of future wildland fires in the analysis area was not analyzed in detail because it is

impossible to predict when and where a wildfire may occur in the future, or the subsequent 

effects of that fire. 

Wildlife

Species assessed for this project include:

• federally listed endangered, threatened, or proposed (Forest Service Manual 2672.4), and 

designated critical habitat for these species

• Region 3 regional forester sensitive species (Forest Service Manual 2670.5) 

• Gila National Forest management indicator species as listed in the Gila forest plan as 

amended (1986) 

• migratory bird species that occur within the planning area.

Federally Listed Species

The U.S. Fish and Wildlife Service county list of endangered and threatened species were 

reviewed to determine the federally listed species that would need to be considered in this 

evaluation. Table 52 lists the threatened and endangered species and their critical habit, if 

applicable, that may be within the planning area. 

Table 52. Summary of federally listed species (endangered, threatened, and experimental) within 

Catron County and within the Luna planning area.

Scientific Name Common Name Status 

Critical 

Habitat

Canis lupus baileyi Mexican gray wolf Endangered 

Experimental

N/A

Strix occidentalis lucida Mexican spotted owl Threatened Yes

Empidonax traillii extrimus Southwestern willow flycatcher Threatened Yes

Thamnophis rufipunctatus Narrow-headed gartersnake Threatened Proposed

Thamnophis eques megalops Northern Mexican gartersnake Threatened N/A1

Tiaroga cobitis Loach minnow Threatened Yes

Meda fulgida Spikedace Threatened Yes

1

There is proposed critical habitat for northern Mexican gartersnake, but none is located within or adjacent to the 

planning area.

Mexican Gray Wolf

The Mexican gray wolf is in the process of being reintroduced on the Gila National Forest in 

New Mexico and on the Apache-Sitgreaves National Forest in Arizona. These wolves have been 

designated as a non-essential experimental population, pursuant to section 10(j) of the 

Endangered Species Act as amended.
Chapter 3. Affected Environment and Environmental Consequences

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82

Re-introduced wolves have been located periodically in the planning area. Multiple wolf packs 

have used the area for denning and single wolves have been detected moving through the area. 

The planning area has suitable habitat for hunting and reproducing for the Mexican gray wolf. 

Key prey species, elk and deer, for the wolf are present in the planning area. 

Environmental Consequences

Alternative A 

Under alternative A, no project activities would be implemented; therefore, there would be no 

effect to the Mexican gray wolf.

Effects Common to Alternatives B, C, and D 

As defined in the Endangered Species Act section 10 (j) rule for the Mexican gray wolf, 

“disturbance causing land use activity” means any land use activity that the U.S. Fish and 

Wildlife Service determines could adversely affect reproductive success, natural behavior, or 

survival of Mexican gray wolves. The following activities are specifically excluded from this 

definition under the Endangered Species Act section 10 (j) rule for the Mexican gray wolf:

• legally permitted livestock grazing and use of water sources by livestock

• livestock trailing or drives (only if no reasonable alternative route exists)

• vehicle access over established roads to private property and to areas on public land where 

legally permitted (only if no reasonable alternative route exists)

• use of lands within the national park or national wildlife refuge systems as safety buffer 

zones for military activities

• prescribed fire and associated management actions (except in the vicinity of wolf release 

pens) 

• any authorized, specific land use that was active and ongoing at the time wolves chose to 

locate a den or rendezvous site nearby

Project activities would not preclude occupancy of the area by the Mexican gray wolf. Human 

disturbance to the Mexican gray wolf as a result of the proposed activities at this time seems 

unlikely. However, there have been documented wolf dens in the project area. If wolves are 

found denning during implementations of projects, the Quemado Ranger District staff will 

coordinate with the Mexican gray wolf field team to minimize or eliminate adverse effects to 

denning activities. 

The decommissioning of roads across the planning area will decrease habitat fragmentation for 

both the wolf and native ungulates. Implementation of the alternatives may indirectly affect 

wolves through disturbance to their primary prey base, native ungulates like elk and deer. 

Activities may cause native ungulates to temporarily move to other locations or further from 

denning locations, therefore resulting in greater distances to forage.

One of the goals of this project is to improve wildlife habitat conditions through improving 

browse components for wild ungulates. In the short term, while vegetation is responding to 

treatments, the change to native ungulates may be relatively undetectable. Compared to the 

potential long-term benefits to native ungulates and the wolf prey base. 
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

83

Rationale for determination: Under all action alternatives, disturbance to potential denning 

sites are minimized through avoidance or other features developed in coordination with the field 

team in relation to the activity being implemented. There are beneficial effects to the species and 

its habitat through reduction of habitat fragmentation through road decommissioning and 

improvement of native ungulate (prey species) habitat. A determination of “not likely to 

jeopardize” is made for all action alternatives. 

Mexican Spotted Owl

The Luna Restoration Project is located in the Upper Gila Mountains Recovery Unit/Ecological 

Management Unit. Primary constituent elements of Mexican spotted owl critical habitat are high 

basal area (square footage of trunk) of large-diameter trees; moderate to high canopy closure; 

wide range of tree sizes (uneven-age stands); multi-layered canopy with large overstory trees of 

various species; high snag basal area; high volumes of fallen trees and other debris; high plant 

species richness, including hardwoods; adequate levels of plant cover to maintain fruits, seeds, 

and regeneration to provide for the needs of Mexican spotted owl prey species within mixed 

conifer, pine-oak, and riparian forest types. 

Currently, Mexican spotted owl habitat on the Gila National Forest is managed according to the 

direction in the Gila forest plan, which was amended by elements of the 1995 recovery plan for 

the Mexican spotted owl. With 2 exceptions, current forest plan direction will be followed. 

Mexican spotted owl habitat discussed in this report are analyzed using the current forest plan 

and two project-specific amendments to the forest plan from the 2012 Mexican spotted recovery 

plan. These 2 amendments will be as follows: 

• 1995 Mexican spotted owl recovery plan precludes cutting conifers in the protected 

activity centers. This amendment will follow the 2012 Mexican spotted owl recovery plan 

and allow cutting conifers in protected activity centers, while leaving a 100-acre core area 

untreated in the protected activity center. A fire risk analysis was done showing the 

potential for high-intensity wildfire that could severely affect protected activity centers. 

• 1995 Mexican spotted owl recovery plan, as incorporated and amended into the forest plan

allows for treating up to 10 percent of protected activity centers in a recovery unit. This 

amendment will follow the 2012 Mexican spotted owl recovery plan to allow for more 

treatments in protected activity centers. 

Within the Luna Restoration Project boundaries, there are 64,293 acres of designated Mexican 

spotted owl critical habitat. Approximately 17,003 acres are within protected activity centers. 

Outside protected activity centers, 6,984 acres have been identified as protected habitat under the 

1995 recovery plan consisting of mixed conifer (4,725 acres of slopes greater than 40 percent) 

and ponderosa pine-Gambel oak (2,259 acres of slopes greater than 40 percent). There is 

approximately 21,816 acres of restricted habitat consisting of mixed conifer (3,018 acres); 

riparian (784 acres); and ponderosa pine-Gambel oak (18,014). 

For the Mexican spotted owl, reducing risk of high-intensity wildfire and reintroducing a fire 

regime into the ecosystem to maintain fuel loadings at a low level is desirable. The desired future 

conditions in areas identified as habitat for Mexican spotted owl include reduction of risk of high 

intensity wildfire while maintaining key habitat components. 

Within the acres of protected activity centers, "prescribed burning only" treatment is proposed on 

approximately 8,399 acres and an additional 1,319 acres treated with a combination of 
Chapter 3. Affected Environment and Environmental Consequences

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84

prescribed burning, thinning, and associated slash treatments to reduce fire risk. Approximately 

31 percent (1,489 acres) of mixed conifer protected (potential recovery) habitat and 19 percent

(428 acres) of ponderosa pine- Gambel oak protected habitat would be managed toward 

threshold habitat conditions within the Luna Restoration Project area. Twenty-nine percent 

(1,212 acres) of mixed conifer restricted (potential recovery) habitat, and 5 percent (1,033 acres) 

of ponderosa-Gambel oak restricted (potential recovery) habitat will be designated to be 

managed toward threshold habitat conditions. 

Outside protected activity centers, of the 25,058 acres of restricted (potential recovery) habitat 

associated with the project, 923 acres have prescribed burning proposed. Within the restricted or 

recovery habitat associated with the Luna Restoration Project area, treatment of these areas will 

be managed to promote the primary constituent elements for nesting, roosting, foraging, and 

dispersing. The remaining 24,135 acres of Mexican spotted owl restricted or recovery habitat 

will be managed according to the Mexican spotted owl recovery plan recommendations which 

call for management of the landscape to maintain and create replacement owl habitat, while 

providing a diversity of stand conditions and stand sizes across the landscape. 

Other activities associated with the Luna Restoration Project in Mexican spotted owl protected 

activity centers include 6.2 miles of road decommissioning, 0.9 miles of fence construction, 1.2 

miles of pipeline, 0.1 miles of a trail reroute (with culvert) to eliminate 2 stream crossings, and 1 

well with storage and drinkers. In Mexican spotted owl designated critical habitat, other 

activities would include 47.2 miles of road decommissioning, 2.0 miles of temporary roads for 

thinning activity access, 4.5 miles of pipeline, 1.1 miles of fence, 0.1 miles of a trail reroute 

(with culvert) to eliminate 2 stream crossings, 5 wells with storage and drinkers, hardening of 2 

stream crossings, 1 French drain sediment structure, and 1 trail barrier to prevent motorized use. 

Environmental Consequences

Alternative A 

Taking no action would have no effect to Mexican spotted owls, but the habitat would continue 

to be at risk of being impacted by wildfires. 

Effects Common to Alternatives B, C, and D 

All activities in Mexican spotted owl protected activity centers will be performed outside of the 

breeding season (March 1 to August 31). If activities are needed to be done during the breeding 

season, survey protocols would be implemented to determine if there are owls present or are not 

breeding before work is allowed to proceed. All activities in Mexican spotted owl habitat, are 

subject to the forest plan amendment in regards to not treating more than 25 percent of a 6th 

code watershed in a 3-year period which may be adjusted as monitoring dictates.

Mechanical and hand thinning are proposed in Mexican spotted owl habitat. Thinning trees less 

than 9 inches in diameter at breast height would reduce basal area in protected activity centers, 

which in turn would reduce thermal properties. Thinning in protected activity centers would not 

go below threshold levels of 150 basal area in ponderosa pine/Gamble oak, and 170 basal area in 

mixed conifer. Thinning less than 9-inch trees in protected activity centers would allow the 

remaining trees to grow at a more rapid pace, increasing the percentage of basal area in the larger 

trees. Proposed treatments in protected and restricted habitats, would help restore the forest to a 

fire adapted ecosystem, lessening the probability of a damaging wildfire. The treatments in 

protected and restricted habitats would leave appropriate percentages for meeting primary 
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constituent elements in the future. Thinning would allow herbaceous plants to establish, 

providing a food source for prey species. Human activity and noise associated with chainsaws or 

other mechanized equipment could disturb nesting owls. Performing these actions outside the 

breeding season will prevent disturbing nesting owls. The potential for vehicles to collide with 

owls has a very low possibility. This would be minimized due to motorized activity would be 

occurring during daylight hours when owls are less likely foraging.

Prescribed fire in Mexican spotted owl protected activity centers and designated critical habitat 

is proposed to be low intensity. This low intensity would remove excess fuels from the forest 

floor, raise the low-live limb on remaining trees, thus reducing the threat of devastating wildfire 

to Mexican spotted owl habitat. Some snags might burn up during implementation, while others 

may be created to take their place. Removing some of the fuels from the forest floor, would 

allow herbaceous plants to establish, providing additional food sources for prey species. Smoke 

from prescribed burning might cause owls to leave the nest, possibly putting nestlings at risk. 

Human activity and noise associated with chainsaws or other mechanized equipment could 

disturb nesting owls. Implementing these actions outside the breeding season will prevent 

disturbances to the owls. 

Long-term effects would include a reduction of fuel loading which would lessen wildfire 

intensities, and thinning and prescribed fire would allow for healthier habitat.

For all other proposed treatments, noise and human presence may disturb individual owls, 

movement of prey species, or modify habitat components for either the owl or their prey species 

within critical habitat. Activities such as maintenance of sediment control features, road 

decommissioning, stream and riparian projects within critical habitat would improve and restore 

habitat conditions and improve watershed conditions. These activities would cause short-term 

impacts, but there would be long-term benefits to habitat for both Mexican spotted owl and its 

prey species as areas stabilize and recover. 

Alternative C – Herbicide Utilization 

Herbicide treatments are proposed on approximately 1,270 acres of designated critical habitat for 

the Mexican spotted owl in conjunction with thinning of juniper. Treating juniper with herbicide 

would reduce competition with ponderosa pine and mixed conifer species, which in turn would 

allow for more rapid growth. Reducing juniper would reduce feed for prey species. Herbicide 

manufactures produce label processes on application to prevent effects to Mexican spotted owl, 

wildlife, and Mexican spotted owl prey species. Human activity and noise associated with 

mechanized equipment could disturb nesting owls. Performing these actions outside the breeding 

season will prevent disturbing nesting owls. 

Cumulative Effect: 

Short-term cumulative impacts are anticipated to come from reduced basal area in protected 

activity centers and a reduction in snags, with ongoing activities coupled with proposed projects. 

Projects that will decrease basal area short term include thinning conifers (less than 9 inches 

diameter) in protected activity centers and prescribed fire. Prescribed fire would also reduce 

snags. Over time, the cumulative impacts from lowered basal area and fewer snags would 

improve. This improvement would occur because the implementation of these projects are 

projected to accelerate growth in remaining trees, and prescribed fire would create new snags. 
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Rationale for determination: Thinning and burning activities associated with the Luna 

Restoration Project will reduce basal area in protected activity centers during the short term (but 

not drop below threshold values) and will adjust the structure and thermal characteristics. 

Reducing fuel loading in designated critical habitat could impact prey species in the short term. 

Reducing juniper could reduce food sources for prey species. Performing actions outside the 

breeding season or after confirming non-breeding status will prevent disturbing nesting owls. 

Core areas of 100 acres have been identified, and will not receive mechanical treatment and will 

not have prescribed fires ignited within them. Modeling has shown thinning treatments in 

protected activity centers would increase the growth in larger-diameter trees, which in turn 

would increase the basal area in the larger size classes over the long term. 

The Luna Restoration Project would reduce habitat needs in protected activity centers in the 

short term, but improve conditions in the long term; therefore, the Luna Restoration Project may 

affect, likely to adversely affect the Mexican spotted owl. 

Treatments in designated critical habitat would align with the forest plan, which complements 

the 1995 Mexican spotted owl recovery plan, therefore the Luna Restoration Project may affect, 

not likely to adversely affect the designated critical habitat for the Mexican spotted owl. 

Southwestern Willow Flycatcher

The southwestern willow flycatcher is federally listed and a migratory bird species. 

Environmental Consequences

Alternatives A, B, C, and D 

There will be no effect to the species due to southwestern willow flycatchers not being observed 

within the project area for the last 10 years. Also, the designated critical habitat within the 

planning area does not contain the primary constituent elements to support the birds. 

Designated Critical Habitat

There are 208 acres of designated southwestern willow flycatcher critical habitat within the 

planning area, located along the San Francisco River. The designated critical habitat does not 

contain the primary constituent elements to support southwestern willow flycatchers. Willow 

species are in small quantities and not densely grouped. Tree canopy does not fall within the 

density range of 50 percent to 100 percent. Also, the area does not have open water or marsh 

openings meeting the 0.25-acre minimum size.

Alternative A 

There will be no effect to southwestern willow flycatcher critical habitat due to no activities 

being implemented under this alternative. 

Effects Common to Alternatives B, C, and D 

No impacts would occur to critical habitat with the implementation of vegetation and prescribed 

burning treatments and herbicide utilization under alternative C. By applying the design feature 

of buffering the critical habitat from project implementation activities, no treatments would 

occur within critical habitat. Therefore no changes to the habitat constituents or vegetation would 

be altered. 
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The following activities would occur within critical habitat: construction of new road crossing in 

Head of Ditch campground, applying rock to roads within Head of Ditch campground, irrigation 

ditch diversion construction, road decommissioning, and stream restoration activities within San 

Francisco River and Stone Creek. 

The irrigation ditch construction and campground new road stream crossing would remove 

riparian vegetation during implementation altering the vegetative components in the critical 

habitat at those specific locations. Those areas would be permanently void of vegetation. The 

placement of a permanent diversion structure compared to the multiple disturbances to the 

stream channel from maintenance of the earthen diversion berm; provides an opportunity for the 

banks to stabilize and over the long-term allow recruitment and establishment of vegetation. 

Approximately 0.2 miles of road that run along and cross the San Francisco River would be 

decommissioned under the action alternatives. Road decommissioning and other stream 

restoration activities within critical habitat would cause short-term disturbances but in the long 

term would have improved stream habitat components and an increase in riparian through 

planting and natural recruitment. 

The removal of riparian vegetation and short-term disturbances from other stream restoration 

activities and decommissioning within designated critical habitat would be insignificant and 

discountable. These sites are small and localized but have the potential to provide long-term 

benefits, although the benefits would not greatly improve or change the primary constituent 

elements of the critical habitat. Project activities may affect, not likely adversely affect the 

designated critical habitat.

Narrow-Headed and Northern Mexican Gartersnakes 

The narrow-headed and northern Mexican gartersnakes are federally listed as a threatened 

species. Critical habitat for the narrow-headed and northern Mexican gartersnakes is proposed. 

Only proposed critical habitat for the narrow-headed gartersnake is found within the Luna 

planning area. There are approximately 2,781 acres of proposed critical habitat in the Luna 

planning area located on the San Francisco River and Dry Blue Creek.

For this analysis, it is assumed the northern Mexican gartersnake occupies the same area and 

within the proposed critical habitat for the narrow-headed gartersnake.

Surveys for narrow-headed and northern Mexican gartersnakes were conducted at the Head of 

the Ditch campground along the San Francisco River (July 25 through 28, 2016). None of these 

species were caught or observed during the survey. Also, very few prey fish were caught. During 

the surveys, other terrestrial and checkered gartersnakes were found.

Environmental Consequences

Alternative A 

There will be no effect to the northern Mexican gartersnake or the narrow-headed gartersnake 

and its proposed critical habitat due to no activities being implemented under this alternative. 

Effects Common to Alternatives B, C, and D 

The risk of impacts would be minimized to the northern Mexican gartersnake and the narrowheaded gartersnake and its proposed critical habitat with the implementation of vegetation and 
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prescribed burning treatments and herbicide utilization under alternative C. By applying the 

design feature of buffering the proposed critical habitat from project implementation activities, 

no treatments would occur within proposed critical habitat, therefore no disturbance to the 

stream or shoreline habitat would be altered. 

The following activities would occur within proposed critical habitat: construction of new road 

crossing in Head of Ditch campground, applying rock to roads within Head of Ditch 

campground, irrigation ditch diversion construction, road decommissioning, hardening of 

motorized trail crossings in Dry Blue Creek, and variety of stream restoration activities within 

San Francisco River and Dry Blue Creek. 

During the implementation of these activities, the potential risk to gartersnakes is being harassed 

by human presence and various machinery sounds or vibrations or crushed between rocks as 

material is moved or run over by vehicles. Implementation could generate fine sediment 

impacting proposed critical habitat and also prey species habitat. This is expected to be a shortterm impact.

The placement of the irrigation ditch diversion would continue to alter natural flows during 

periods of irrigation water usage but reduces fine sediment input and habitat disturbances that 

resulted from the multiple entries to maintain the earthen diversion berm. Some fine sediment 

would still be produced during periodic clean-out of the sediment trap but to a lesser degree than 

previous activities.

The irrigation ditch construction and the new road-stream crossing in the campground would 

remove riparian vegetation during implementation, altering the vegetative components along the 

shoreline of the proposed critical habitat at those specific locations. Those areas would be 

permanently void of vegetation. 

Approximately 0.2 miles of road that run along and cross the San Francisco River would be 

decommissioned under the action alternatives. Road decommissioning and other stream 

restoration activities within proposed critical habitat would cause short-term disturbances but in 

the long term would have improved stream habitat components and an increase in riparian 

through planting and natural recruitment. 

The removal of riparian vegetation and short-term disturbances from other stream restoration 

activities and decommissioning within proposed critical habitat would be insignificant and 

discountable. These sites are small and localized, but have the potential to provide long-term 

benefits. Surveying for the two gartersnake species prior to implementation and applying buffer 

around habitat will reduce the risk of disturbance and harm. Project activities may affect, not 

likely adversely affect the northern Mexican garternske and narrow-headed gartersnake and its 

proposed critical habitat. 

Spikedace

Spikedace is federally listed as a threatened species. Critical habitat has been designated and 

designation included both spikedace and loachminnow. 

The Luna Restoration Project will have no effect to spikedace. Spikedace have not been found 

occupying streams within the planning area and closest they have been detected on the San 

Francisco River is near Alma, New Mexico. Effects to designated critical habitat will be 

discussed with loachminnow. 
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Loachminnow

Loachminnow is federally listed as a threatened species. Critical habitat has been designated and 

designation included both spikedace and loachminnow. 

Loachminnow have been found within Dry Blue Creek but have not been found in the since the 

Wallow Fire in 2011. It is thought that after the fire; ash, debris, and sediment entering the 

system impacted the fish and its habitat (personal communication Gila National Forest: Dustin

Myers, fish biologist and Jerry Monzingo, wildlife program manager). Loachminnow are located 

approximately 2 miles downstream of the planning boundary on the San Francisco River. 

Environmental Consequences

Alternative A 

Under the no-action alternative, there would no effect from project activities to loachminnow or 

to designated critical habitat for spikedace and loachminnow. The risk of the loachminnow and 

the designated critical habitat being impacted by wildfires would continue. 

Effects Common to Alternatives B, C, and D 

On the San Francisco River, loachminnow and the spikedace and loachminnow designated 

critical habitat would be indirectly impacted from project activities related to vegetation 

treatments, prescribed fire, road decommissioning, and stream and riparian treatments. Impacts 

would primarily relate to runoff of sediment or ash from upland sources or sedimentation 

directly related to activities within the stream channels. Implementation of design features and 

best management practices will reduce the amounts of material entering the system and flowing 

downstream. Compared to alternative A, the amount of sediment, ash, and debris would be much 

less than the potential impacts after a wildfire.

Within Dry Blue Creek, loachminnow and the designated critical habitat would be directly and 

indirectly impacted from project activities. As in the San Francisco River, vegetation treatments, 

prescribed fire, and some stream and riparian treatments may introduce sediment, ash, or debris 

causing indirect impacts to loachminnow and the critical habitat. Hardening of motorized 

crossings and stream and riparian projects will have direct impacts. If fish are present, there is a 

risk of being crushed while rocks are being moved or by equipment driving across the channel. 

Fine sediment would be suspended for a short while during work; the sediment could impact fish 

and fill or cover habitat niches for the fish or its prey species. 

The impacts would be minimized with the application of the design feature to survey prior to 

implementing instream activities. If fish are found, they would be captured and held upstream or 

off-site until work is completed. Also if fish are detected, block nets would be set-up to keep fish 

from entering the active work site. 

Project activities will cause short-term negative impacts to loachminnow and spikedace and 

loachminnow critical habitat. Stream, riparian, and hardening crossings activities, and reducing 

the risk sedimentation, ash, and debris from uncharacteristic wildfires through vegetation and 

prescribed fire, will provide long-term benefits to the species and habitat. The project will result 

in a may affect, likely to adversely affect to the loachminnow and to designated critical habitat 

for spikedace and loachminnow. 
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Region 3 Sensitive Species

Sensitive species are defined as “those plant and animal species identified by a Regional Forester 

for which population viability is a concern, as evidenced by: (a) significant current or predicted 

downward trends in population numbers or density, or (b) significant current or predicted 

downward trends in habitat capability that would reduce a species’ existing distribution (Forest 

Service Manual 2670.5(19)).” 

Environmental Consequences

Alternative A

Under alternative A, there would be no activities implemented; therefore, there would be no risk 

of disturbance and therefore no impact to any Region 3 sensitive species. Risk of disturbance 

from ongoing activities and risk of wildfire would continue. 

Effects Common to Alternatives B, C, and D

The following Region 3 sensitive species occur or may occur within the Luna planning area: 

• northern goshawk 

• burrowing owl

• common blackhawk

• American peregrine falcon

• bald eagle

• gray vireo

• desert sucker

• Rio Grande sucker

• pale Townsend’s big-eared bat

• Gunnison’s prairie dog

• Allen’s lappet-browed bat 

• Arizona montane vole 

• Arizona gray squirrel 

• Goodding’s onion 

• villous groundcover milkvetch

• Mogollon clover

Implementation of the Luna Restoration Project activities results in a determination for each of 

these species: may impact individuals or habitat, but will not likely contribute to trend toward 

federal listing or loss of viability.

In general, the fauna species may be impacted from the increase in human presence and 

equipment use and noise. This may cause a change in the species behavior and if applicable, its 

prey base. Prey species may move away from areas of work causing increased forage distances 

or times. If species forage on vegetation or seeds, these sources may be reduced from vegetation 

and prescribed fire treatments. Noise effects will be of short duration, but vegetation and 

prescribed fire effects may be longer. But overall in the long-term vegetation conditions would 

improve. 

Currently northern goshawk habitat within ponderosa pine cover type is departed from desired 

conditions. Modeling of the treatments within the ponderosa cover type shows that the 

vegetation structural stages after 1 year post harvest begin to move toward desired conditions 

over 20 years (see Vegetation section of this chapter), displaying the potential for treatments to 

improve habitat conditions for the goshawk.
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If any of the sensitive plants species are found during project implementation, they will be 

avoided, removing the risk of any disturbance. The risk of disturbance to these plant species 

include such things as being crushed, pulled from the ground, or habitat changes from vegetation 

or prescribed fire treatments resulting in unfavorable conditions for survival. In the long-term 

restoration activities would improve conditions and depending on the species has the potential of 

increasing preferred habitat types.

Management Indicator Species 

Management indicator species are identified in the Gila National Forest Plan as amended (USDA 

1986). Management indicator species are addressed in order to implement National Forest 

Management Act regulations. They are selected because their population changes are believed to 

indicate the effects of management activities (36 CFR 219.19(a) (1). The management indicator 

species approach is designed to function as a means to provide insight into effects of forest 

management on plant and animal communities. Species are selected to represent several 

categories, such as commonly hunted or fished species, non-game species, and threatened and 

endangered species. They may be used as a tool for assessing changes in specialized habitats, 

formulating habitat objectives, and establishing standards and guidelines to provide for a 

diversity of wildlife, fish, and plant habitats. 

The Gila forest plan amendment #10 for management indicator species amended the 

management indicator species list for the Gila National Forest to represent the major vegetation 

types potentially affected by management actions. Table 53 identifies the management indicator 

species for the Gila National Forest and rationale for including or eliminating them from the 

Luna Restoration Project analysis. 

Mule Deer

The mule deer is a management indicator species for desert shrub, pinyon-juniper shrub, and 

shrub oak woodland communities. However, there can be other limiting factors to deer 

population levels other than vegetative conditions. New Mexico’s climate and weather patterns 

are extremely important to deer survival. Periods of significant rainfall produce ample forage and 

vegetative cover, which improves fawn survival. However, harsh winters or prolonged periods of 

drought can have devastating effects on fawn survival and overall deer numbers. Other limiting 

factors such as lack of water, predation, and competition with other species also contribute to the 

decreasing trend in the mule deer population. The New Mexico Department of Game and Fish 

manages mule deer populations through annual hunting permits, which also affects population 

levels. The department is currently striving to achieve increased deer survival, and higher 

population numbers. 

The Luna Restoration Project proposes to treat pinyon/juniper, ponderosa pine, and associated 

grasslands within the project area utilizing a variety of methods. Primary objectives of this 

project are to improve watershed condition, wildlife habitat, and to reduce accumulated fuels. 

The desired condition is restored grasslands and more open and healthier forests having a mix of 

tree species and tree sizes. Uneven aged structural characteristics having low to moderate tree 

densities are desirable throughout the area. These structural characteristics are important to mule 

deer because they provide forage that are readily available, critical winter range, and travel 

corridors. 
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Table 53. Gila National Forest management indicator species with associated habitat type and

rational for including or excluding from analysis.

Management Indicator

Specie Vegetation Type

Analysis

(Yes/No) 

Rationale for Elimination or 

Inclusion

Mule deer

(Odocoileus hemionus)

Desert shrub, 

pinyon/juniper, shrub 

oak woodland 

communities

Yes Habitat exists for this species

Mearn’s quail

(Cyrtonyx montezumae 

mearnsi)

Plains and mountain 

grassland communities

Yes Habitat exists for this species

Long-tailed vole

(Microtus longicaudus)

Wet meadows and 

wetlands

Yes Habitat exists for this species

Beaver

(Castor candensis)

Low and mid elevation 

riparian areas

Yes Habitat exists for this species

Plain [Juniper] titmouse

(Baeolophus ridgwayi)

Pinyon/juniper and 

shrub oak woodlands

Yes Habitat exists for this species

Hairy woodpecker

(Picoides villosus)

Ponderosa pine and 

mixed conifer snag 

component

Yes Habitat exists for this species

Mexican spotted owl

(Strix occidentalis lucida)

Mixed conifer 

community

Yes1 Habitat exists for this species

Black hawk

(Buteogallus anthracinus 

anthracinus)

Riparian habitat at low 

and mid elevations

Yes2 Habitat exists for this species

Northern goshawk

(Accipiter gentiles)

Ponderosa pine 

community

Yes2 Habitat exists for this species

Gila trout

(Oncorhynchus gilae)

Riparian habitat at high 

elevations

No Habitat for this species does 

not exist in the planning area. 

San Francisco River and its 

tributaries are not considered 

for recovery areas for Gila 

Trout. Currently there is no 

plan to re-establish Gila Trout 

in perennial streams within 

the planning area.

Rio Grande cutthroat

(Oncorhynchus clarki 

virginalis)

Riparian habitat at high 

elevations

No Habitat for this species does 

not exist in the planning area.

Also, the planning area is not 

within the historical range of 

the species. 

1 Analysis for Mexican spotted owl is located under the “Federally Listed Species” section of this document. 

2 Analysis for black hawk and goshawk are located under “Region 3 Sensitive Species” section of this document. 

Alternative A

Under alternative A, no treatments would be implemented within associated vegetation types;

therefore, there would be no impact to mule deer population from this project. 

Effects Common to Alternatives B, C, and D

For all treatment activities, the presence of human activity and mechanized equipment use and 

noise could disturb mule deer foraging, distribution patterns, and rearing of young. These 

disturbances would be over short periods. Treatments would not occur within the various mule 
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deer habitat at the same time, therefore providing the opportunity to utilize other areas without 

disturbances to the species or its habitat. Disturbances to mule deer from each treatment activity 

would be short-term.

Mechanical Thinning and Hand Thinning: The result of the mechanical treatments, such as 

slash on the ground, ground disturbance, and piles, could disrupt the available forbs for deer for 

a short period of time. 

Prescribed Burning: The project will have fire take place on all units but not at the same time. 

This could result in a short term disturbance to the mule deer. Fire can effectively alter 

vegetation structure and composition thereby affecting foraging habitat. The short-term effects of 

fire are likely to be unfavorable as plant foraging species are initially being reduced; however, 

mule deer have long evolved with fire and the long-term effects of prescribed fire will help 

reduce devastating wildfire and would improve foraging habitat. 

Sediment Control: Installing and maintaining sediment control features would create a short 

term disturbance to foraging mule deer through noise and human presence. These activities are 

spaced out across the project area, and would not all occur at the same time, giving mule deer 

opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes, and decommissioning 

roads would create a short term disturbance to foraging mule deer through noise and human 

presence. These activities are spaced out across the project area, and would not all occur at the 

same time, giving mule deer opportunities to utilize other areas in the project. Decommissioning 

roads would reduce habitat fragmentation, and increase forage where bare dirt currently exists.

Fences and Water Improvement: Installing fences, and water improvements would create a 

short term disturbance to foraging mule deer through noise and human presence. These activities 

are spaced out across the project area, and would not all occur at the same time, giving mule deer 

opportunities to utilize other areas in the project. Water improvements would improve habitat for 

deer, allowing them to forage in previously un-watered areas.

Summary of Effects: Short-term disturbances will occur during implementation through human 

presence and reduction of forage. Long term habitat conditions will improve. 

Alternative C – Herbicide Utilization

Herbicide application would cause short term disturbances to foraging mule deer through human 

presence. These activities are spaced out across the project area, and would not all occur at the 

same time, giving mule deer opportunities to utilize other areas in the project. Forage would 

increase in the long term, due to decreased canopy closure. Manufacturer labels would be 

followed to prevent impacts to wildlife.

Alternative D

Not implementing the user-proposed routes would result in less habitat fragmentation to mule 

deer. 

Cumulative Effect:

This project and the Escudilla West Project located in Arizona would increase short-term 

disturbances to foraging mule deer through thinning and prescribed burning. Both projects would 
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lead to improved habitat conditions for mule deer in the long term. Livestock grazing activities, 

fuelwood collection, road maintenance, and recreation activities could increase disturbance to 

foraging mule deer. 

Determination of Impact to the Species

Foraging would be disrupted in the short term, but there would be long term improvement of 

habitat conditions for this species. For alternatives B, C, and D, individuals may be affected, but 

at the forest level, the activities proposed under these alternatives would not adversely affect 

population trends on the Gila National Forest. 

Mearn’s (Montezuma) Quail

The Mearn’s quail was picked as a management indicator species for plains and mountain 

grassland communities because good Mearn’s habitat reflects the herbaceous conditions in these 

communities that the Forest is striving to attain/maintain; based on the types of management that 

is occurring today under the direction of the forest plan. 

There can be other limiting factors to Mearn’s population other than vegetative conditions. Quail 

populations fluctuate from year to year for a number of reasons, primarily local weather 

conditions and predators. Limiting factors for quail populations include predation, habitat 

modification and annual precipitation. Annual population fluctuations are positively correlated 

with the amount of summer precipitation in any given year. The New Mexico Department of 

Game and Fish manages quail through annual small game hunting licenses. The species is hunted 

in New Mexico from November through February, which is another factor affecting Mearns’ 

quail population levels. 

Spatial arrangement of both grassland and woodland cover types is very important for this 

species due to its survival strategy, small home range, dispersal distances, and food habits. 

Adequate horizontal and vertical grass cover must be well distributed across the landscape to 

meet the cover needs of this species. Excessive cover removal can affect the species by limiting 

nest building habitat and escape cover. 

Alternative A

Implementing the no-action alternative would have no impact to Mearn’s quail.

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase herbaceous plants in the 

long term, providing additional food sources for Mearn’s quail. Some hiding and nesting cover 

could be removed, displacing Mearn’s quail. Thinning activities would not occur across the 

entire project area at the same time. This gives Mearn’s quail the opportunity to utilize other 

areas until treatments are done. 

Prescribed Burning: The prescribed burn vegetative treatments would decrease forage and 

nesting and hiding cover in the short term. The project will have fire take place on the majority 

of the project area, but not at the same time. This would allow Mearn’s quail to utilize other 

areas during implementation. Mearn’s quail has long evolved with fire and the long-term effects 

of prescribed fire will help reduce devastating stand replacing wildfire and would overall 

improve foraging and nesting and hiding cover. 
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Irrigation Ditch Diversion: The diversion structure and associated road re-route do not occur in 

Mearn’s quail habitat.

Sediment Control: Installing and maintaining sediment control features could reduce forage and 

nesting and hiding cover in the short term but would lead to better habitat conditions in the long 

term due to improved watershed conditions. 

Road and All-terrain Vehicle Trail: Installing user-proposed routes could create habitat 

fragmentation, and a slight reduction in forage and nesting and hiding cover. Decommissioning 

roads would decrease habitat fragmentation, and lead to more forage and nesting and hiding 

cover in the long term. These activities are spaced out across the project area, and would not all 

occur at the same time, giving Mearn’s quail opportunities to utilize other areas in the project.

Fences and Water Improvement: Installing fences, and water improvements would not impact 

Mearn’s quail and its habitat.

Summary of Effects: Forage and nesting and hiding cover will decrease over the short term.

Forage and nesting/hiding cover will increase over the long term.

Alternative C – Herbicide Utilization

Utilizing herbicide on alligator juniper and rabbit brush will create conditions that will allow 

herbaceous plants to establish, providing additional forage for Mearn’s quail. Manufacturer 

labels will be followed in applying herbicide.

Alternative D

Not implementing the user-proposed routes would not increase habitat fragmentation, nor 

remove forage and nesting and hiding cover. 

Cumulative Effect:

This project and the Escudilla West project located in Arizona would remove forage and nesting 

and hiding cover in the short term, but both are expected to improve habitat conditions in the 

long term. Livestock grazing activities, fuelwood collection, road maintenance, and recreation 

activities could decrease available forage and nesting/hiding cover for Mearn’s quail.

Determination of Impact to the Species

Forage and nesting and hiding cover would be reduced in the short term but would increase in 

the long term. For alternatives B, C, and D, individuals may be affected, but at the forest level, 

the activities proposed under these alternatives would not adversely affect population trends on 

the Gila National Forest. 

Long-tailed Vole

The long-tailed vole is an indicator of wet meadows and wetlands. Within the Gila National 

Forest, there are estimated 1,710 acres of wet meadows and wetlands. Distribution of the longtailed vole across the Gila is likely to be larger than delineated wet meadow and wetland 

vegetation types because the species is also found in moist habitats and along the edges of 

spruce/fir vegetation and some mixed conifer habitats. On the Gila National Forest, the longtailed vole has previously been found near Willow Creek in the Mogollon Mountains and in the 

Mimbres. More recently, surveys conducted by Frey (2005) included a number of additional 

observations. Long-tailed voles have a very small home range, generally less than 100 meters. 
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Devastating fire also has the potential to be a major impact on the long-tailed vole since fire 

within the spruce-fir/mixed-conifer landscape is often stand replacing and thus has dramatic and 

moderate duration effects to surrounding ecosystem. 

Alternative A

Implementing the no-action alternative would have no impact to the long-tailed vole. 

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Limited thinning activities are anticipated to occur 

in long-tailed vole habitat. Long-tailed voles could be inadvertently crushed by humans or 

equipment during implementation. Thinning would reduce the threat for devastating wildfire 

surrounding long-tailed vole habitat, which could lead to habitat losing moisture. Loss of 

moisture could occur through increased sunlight and increased sediment. 

Prescribed Burning: Prescribed burning would trend current vegetative conditions towards 

desired conditions. Moving towards desired conditions would improve watershed conditions, 

which in turn should allow moist conditions in long-tailed vole habitat. 

Irrigation Ditch Diversion: The diversion structure and associated road re-route do not occur in 

long-tailed vole habitat.

Sediment Control: Sediment control structures do not occur in long-tailed vole habitat.

Road and All-terrain Vehicle Trail: Decommissioning roads could result in Long-tail voles 

being inadvertently crushed. Decommissioning roads would allow the areas to heal naturally and 

increase habitat. User-proposed routes do not occur in long-tailed vole habitat.

Fences and Water Improvement: Fences and water improvements do not occur in long-tailed

vole habitat. 

Summary of Effects: Long-tailed voles may be crushed during implementation. Long-tailed

vole habitat would have a lower chance of being impacted by devastating wildfire.

Alternative C – Herbicide Utilization

Herbicide is proposed to be used to treat alligator juniper. Wet meadows will be buffered 300 

feet, and no herbicide will be used in the buffer zone. Manufacturer labels will be followed to 

prevent impacts to wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to the long-tailed vole. 

Cumulative Effect

This project and the Escudilla West project located in Arizona could inadvertently run over longtailed voles. Both projects would lead to improved watershed conditions. Livestock grazing 

activities, fuelwood collection, road maintenance, and recreation activities could increase 

disturbance to long-tailed voles. 
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Determination of Impact to the Species

Some long-tailed voles may be inadvertently crushed during implementation, but proposed 

activities will improve conditions in and surrounding habitat in the long term for this species. For 

alternatives B, C, and D, individuals may be affected, but at the forest level, the activities 

proposed under these alternatives would not adversely affect population trends on the Gila 

National Forest. 

Beaver

The beaver was selected as a management indicator species for the mid elevation riparian areas 

that occur in the project area. 

Beaver are semi-aquatic. They prefer streams and small lakes having nearby growths of willow, 

aspen, cottonwood, birch or alder. They often are thought of as the “engineers” of the animal 

kingdom, because they build dams, lodges, and canals. A dam provides an area of still, deep 

water where a lodge can be conveniently constructed and protected from terrestrial predators, 

and where building materials and food supplies can be easily floated and kept from being 

washed away. The impounded water may form ponds many hectares in area. 

Beavers are active throughout the year. They feed on the bark, cambium, twigs, leaves, and roots 

of deciduous trees and shrubs, such as willow, alder, birch, and aspen, and on various parts of 

aquatic plants, especially the young shoots of water lilies. Beavers anchor sticks and logs 

underwater to feed on during winter. 

North American beavers were among the most widely distributed of mammalian species. 

Beavers declined drastically in recent centuries, mainly because of excessive human hunting for 

their valuable pelts. By the early 1900s, only scattered and greatly reduced populations 

remained. Subsequent programs of regulated harvesting and transplantation have resulted in 

large-scale reestablishment of the beaver in many parts of the United States and Canada, though 

not always of the subspecies native to the areas involved. 

Observations by Quemado District personnel and New Mexico Department of Game and Fish 

personnel indicate a drop in beaver population with fewer occupied sites. This may, in part, be 

due to drought conditions that have reduced stream flow and pond retention below levels that are 

comfortable for beaver security. In addition, many watershed gradient control structures, when 

first built, provided habitat for beaver have now silted in. Silt catches in these structures 

decreased the potential reservoir below levels acceptable to beaver. Beaver continue to be 

trapped and relocated from private land and irrigation ditches to locations on Gila. Few of these 

relocations have resulted in permanent occupancy of new sites, probably due to the lower 

potential of the habitat present in these relocation sites. 

Alternative A

Implementing the no-action alternative would have no impact to the beaver. 

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

presence and could cause a disturbance to the beaver. The disturbances will be short term and 

will not occur across the entire project area at the same time. 
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Prescribed Burning: Prescribed burn vegetative treatments would increase the occurrence of 

human presence and could cause a disturbance to the beaver. The disturbances will be short term 

and will not occur across the entire project area at the same time. The short-term effects of fire 

are likely to be unfavorable as fire could potentially impact the riparian vegetation. The beaver 

has long evolved with fire and the long-term effects of prescribed fire will help reduce 

devastating stand replacing wildfire and would overall improve the riparian habitat.

Irrigation Ditch Diversion: The diversion structure and associated road re-route would remove 

some riparian vegetation and increase human presence which could disturb beaver. The 

vegetation removal is anticipated to be minimal and not have a noticeable impact to the beaver. 

Sediment Control: Installing and maintaining sediment control features such as hardening 

stream crossings would create a short term disturbance to beavers through human presence. 

Road and All-terrain Vehicle Trail: Installing user-proposed routes and decommissioning roads 

would create a short term disturbance to beavers through noise and human presence. These 

activities are spaced out across the project area and would not all occur at the same time. 

Fences and Water Improvement: Installing fences, and water improvements would not occur 

in beaver habitat.

Summary of Effects: Beavers will be disturbed from human presence and have a loss of some 

riparian vegetation in the short term during project implementation. Risk of devastating wildfire 

would be lowered in and around beaver habitat.

Alternative C - Herbicide Utilization

Herbicide is proposed to be used to treat alligator juniper. Human presence may disturb beavers. 

No live waters will be sprayed. Manufacturer labels will be followed to prevent impacts to 

wildlife. 

Alternative D

Not implementing the user-proposed routes would have no impact to beaver. 

Cumulative Effect:

This project and the Escudilla West Project located in Arizona would increase disturbance to 

beaver, and would result in loss of riparian vegetation in the short term. Both projects would lead 

to improved habitat conditions for beaver in the long term. Livestock grazing activities, 

fuelwood collection, road maintenance, and recreation activities could increase disturbance to 

beaver and result in loss of riparian vegetation. 

Determination of Impact to the Species

Some disturbance and loss of riparian vegetation in the short term, but will have improved 

habitat conditions in the long term for this species. For alternatives B, C, and D, individuals may 

be affected, but at the forest level, the activities proposed under these alternatives would not 

adversely affect population trends on the Gila National Forest. 

Plain [Juniper] Titmouse

The plain [Juniper] titmouse was selected as management indicator species for the 

pinyon/juniper and shrub oak woodlands habitat found on the Gila National Forest. 
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Plain titmouse, also known as juniper titmouse, is a resident of deciduous or mixed woodlands, 

favoring oak and pinyon/juniper. The plain titmouse inhabits evergreen trees in dry woodlands of 

the Southwest. It usually builds nests in natural cavities or old woodpecker holes, primarily in 

oak trees, but it is capable of excavating its own cavity in rotted wood. Current estimates of 

habitat indicate approximately 1,630,930 acres of pinyon-juniper/shrub oak woodland on the 

Gila National Forest. 

The juniper titmouse is omnivorous preferring insects, but uses fruits and seeds in the fall and 

winter. The species mates for life and defends territories year-round. 

Alternative A

Implementing the no-action alternative would have no impact to the juniper titmouse. 

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

activity, trucks and chainsaws for example, could cause a disturbance in the nesting and roosting 

of the juniper titmouse. Each of the disturbances will be short term and will not occur in all of 

the project area at once. This gives the juniper titmouse the opportunity to nest and roost in other 

areas until treatments are done. The removal of snags that pose a hazard during implementation 

may also cause the temporary loss of some nesting habitat.

Prescribed Burning: The prescribed burn vegetative treatments would increase the occurrence 

of human activity and could cause a disturbance in the nesting and roosting of the juniper 

titmouse. The project will have fire take place on the majority of the project area but not at the 

same time. This could result in disturbance to the juniper titmouse. The short-term effects of fire 

are likely to be unfavorable as nesting and roosting species can initially being reduced. Fire 

activity has the potential to reduce the amount of snags in which the titmouse nests but 

prescribed burning could promote the hardening of other snags suitable for nesting and create 

new snags. The juniper titmouse has long evolved with fire and the long-term effects of 

prescribed fire will help reduce devastating stand-replacing wildfire and would overall improve 

nesting and roosting habitat. 

Irrigation Ditch Diversion: The diversion structure and associated road re-route do not occur in 

juniper titmouse habitat.

Sediment Control: Installing and maintaining sediment control features would create a short 

term disturbance to nesting and roosting for the juniper titmouse through noise and human 

presence. These activities are spaced out across the project area, and would not all occur at the 

same time, giving the titmouse opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes, and decommissioning 

roads would create a short term disturbance to nesting and roosting for the juniper titmouse 

through noise and human presence. These activities are spaced out across the project area and 

would not all occur at the same time, giving the titmouse opportunities to utilize other areas in 

the project.

Fences and Water Improvement: Installing fences, and water improvements would create a 

short term disturbance to nesting and roosting for the juniper titmouse through noise and human 
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presence. These activities are spaced out across the project area, and would not all occur at the 

same time, giving the titmouse opportunities to utilize other areas in the project.

Summary of Effects: Snags will be removed, reducing habitat for the juniper titmouse. Short 

term disturbances will occur during implementation. New snags are expected to be created 

through prescribed burning activities. 

Alternative C – Herbicide Utilization

Herbicide would not affect snags utilized by the juniper titmouse, but may temporarily affect 

some food sources in the short term. Manufacturer labels would be followed to prevent impacts 

to wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to the juniper titmouse. 

Cumulative Effect

This project and the Escudilla West Project located in Arizona would remove snags, but both are 

expected to create new snags in prescribed burning. Both projects would lead to improved 

habitat conditions for the juniper titmouse. Fuelwood collection and road maintenance could lead 

to more snag removal. 

This project and the Escudilla West Project located in Arizona could impact the juniper titmouse 

through noise or human presence. Livestock grazing activities, fuelwood collection, road 

maintenance, and recreation activities could increase disturbance to the juniper titmouse, and 

result in more snag removal. 

Determination of Impact to the Species

Since fire has the potential to increase the number of snags, there would be long term 

improvement of habitat conditions for this species. For alternatives B, C, and D, individuals may 

be affected, but at the forest level, the activities proposed under these alternatives would not 

adversely affect population trends on the Gila National Forest. 

Hairy Woodpecker 

The hairy woodpecker was selected as management indicator species for the ponderosa pine and 

mixed conifer forest snag component habitat found on the Gila National Forest. 

It nests in holes dug mostly by the male in live or dead trees or shrubs, at an average height of 30 

above ground. In most areas, it favors dying parts of live trees, especially where fungal heart rot 

has softened the heartwood. Limiting factors for the hairy woodpecker include predation and 

habitat modification. Snags (10 inches or more in diameter at breast height) and an average of 

five snags per hectare are assumed optimal for woodpecker reproduction, but may not be 

adequate for foraging. With over 1,341,662 acres of ponderosa pine and mixed conifer 

vegetation on the Gila National Forest, snag habitat is abundant for this species. 

The hairy woodpecker is omnivorous, preferring insects but using fruits and seeds in fall and 

winter. 
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Alternative A

Implementing the no-action alternative would have no impact to the hairy woodpecker. 

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

activity, trucks and chainsaws for example, could cause a disturbance in the nesting and roosting 

of the hairy woodpecker. Each of the disturbances will be short term and will not occur in all of 

the project area at once. This gives the hairy woodpecker the opportunity to nest and roost in 

other areas until treatments are done. The removal of snags that pose a hazard during 

implementation my also cause the temporary loss of some nesting habitat. 

Prescribed Burning: The prescribed burn vegetative treatments would increase the occurrence 

of human activity and could cause a disturbance in the nesting and roosting of the hairy 

woodpecker. The project will have fire take place on the majority of the project area, but not at 

the same time. This could result in disturbance to the hairy woodpecker. The short-term effects

of fire are likely to be unfavorable as nesting and roosting species can initially being reduced. 

Fire activity has the potential to reduce the amount of snags in which the woodpecker nests, but 

prescribed burning could promote the hardening of other snags suitable for nesting and create 

new snags. The hairy woodpecker has long evolved with fire, and the long-term effects of 

prescribed fire will help reduce devastating stand replacing wildfire and would overall improve 

nesting and roosting habitat. 

Irrigation Ditch Diversion: The diversion structure and associated road re-route do not occur in 

hairy woodpecker habitat.

Sediment Control: Installing and maintaining sediment control features would create a short 

term disturbance to nesting and roosting hairy woodpeckers through noise and human presence. 

These activities are spaced out across the project area, and would not all occur at the same time, 

giving the woodpecker opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes, and decommissioning 

roads would create a short term disturbance to nesting and roosting hairy woodpeckers through 

noise and human presence. These activities are spaced out across the project area, and would not 

all occur at the same time, giving the woodpecker opportunities to utilize other areas in the 

project.

Fences and Water Improvement: Installing fences, and water improvements would create a 

short term disturbance to nesting and roosting hairy woodpeckers through noise and human 

presence. These activities are spaced out across the project area, and would not all occur at the 

same time, giving the woodpecker opportunities to utilize other areas in the project.

Summary of Effects: Snags will be removed, reducing habitat for hairy woodpeckers. Short 

term disturbances will occur during implementation. New snags are expected to be created 

through prescribed burning activities. 

Alternative C - Herbicide Utilization

Herbicide would not affect snags utilized by hairy woodpeckers, but may temporarily affect 

some food sources in the short term. Manufacturer labels would be followed to prevent impacts 

to wildlife.
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Alternative D

Not implementing the user-proposed routes would have no impact to hairy woodpeckers. 

Cumulative Effect:

This project and the Escudilla West Project located in Arizona would remove snags, but both are 

expected to create new snags in prescribed burning. Both projects would lead to improved 

habitat conditions for hairy woodpeckers. Fuelwood collection and road maintenance could lead 

to more snag removal. 

Determination of Impact to the Species

Since snags will primarily be retained and fire has the potential to increase the number of snags 

there would be long term improvement of habitat conditions for this species. For alternatives B, 

C, and D, individuals may be affected, but at the forest level, the activities proposed under these 

alternatives would not adversely affect population trends on the Gila National Forest. 

Migratory Bird Species

This assessment identified migratory bird species that occur or have the potential to occur within 

the Luna planning area. The Forest Service Memorandum of understanding with the U.S. Fish 

and Wildlife Service (December 8, 2008) identifies specific activities for bird conservation, 

pursuant to Executive Order 13186, signed January 10, 2001, including striving to protect, 

restore, enhance, and manage habitat of migratory birds, and prevent the further loss or 

degradation of remaining habitats on National Forest System lands. This includes identifying 

management practices that impact populations of high priority migratory bird species on 

National Forest System lands. Agencies shall identify potential impacts to migratory birds and 

their habitats, avoid or minimize adverse impacts, restore and enhance habitats, and evaluate the 

effects of actions on migratory birds. Table 54 identifies the species considered in this analysis.

The analysis for following migratory birds: 

• Mexican spotted owl and southwestern willow flycatcher are located under the 

“Federally Listed Species” section of this document

• Gray vireo, burrowing owl, peregrine falcon, bald eagle, and black hawk are located 

under the “Region 3 Sensitive Species” section of this document
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Table 54. List of migratory bird species occur or have the potential to occur within the Luna 

planning area and associated habitat types.

Species Habitat Association

Bendire’s thrasher Inhabits sparse desert shrubland and degraded grassland vegetation. 

It may also occur in open woodland with scattered shrubs

Black-chinned sparrow Moderately dense shrubs from 3-7 ft. tall mixed with rocky 

outcroppings, a large grass component, and scattered large shrubs or 

trees.

Black-throated gray warbler Primarily pinyon-juniper and, in the far southwest, pine-oak woodland. 

Prefers large, closed canopy woodland stands, but it often uses edge 

habitat

Cassin’s finch Associated with mature coniferous forests and woodlands

Chestnut-collared longspur Uses level to rolling mixed-grass and shortgrass uplands, and, in 

drier habitats, moist lowlands. Prefers open prairie and avoids 

excessively shrubby areas

Clark’s nutcracker Inhabits montane forests where preferred, large-seeded pines are

locally abundant

Common nighthawk Associated with open woodlands, clearings, and fields.

Evening grosbeak Occupies mature and second-growth coniferous forests including 

spruce-fir, pine-oak, pinyon-juniper, and aspen forests

Flammulated owl Associated with open ponderosa pine forest. At higher elevations, the 

species may be found in mixed conifer habitat, in association with 

Douglas-fir, white fir, or blue spruce.

Grace’s warbler Prefers park-like stands of mature tall pines

Juniper titmouse Open, mixed woodland areas at mid-elevations, and is most common 

where juniper is dominant. may be present where pinyon-juniper is 

interspersed with oaks, and occurs in largely pine-oak habitat

Lewis’s woodpecker Requires open canopy forests with large dead or decaying trees for 

nesting. It breeds in both lowland riparian and montane forest 

habitats. In New Mexico, breeding occurs most commonly in riparian 

woodland with large, mature cottonwoods. At higher elevations, 

Lewis’s Woodpecker occurs in ponderosa pine forests with large 

trees and an open canopy.

Loggerhead shrike Associated with open country and with short vegetation, including 

desert grasslands and shrublands and open woodlands or juniper 

savannahs

Mexican whip-poor-will Pinon/juniper woodlands, ponderosa/oak forests, and mixed conifer 

forests

Mountain bluebird Pinyon-juniper woodlands, mountain meadows, and sagebrush 

shrublands. Associated with high open habitats with a scattered tree 

or shrub component, including savannahs, prairie-forest ecotones, 

and meadow and alpine tundra edges, and cool desert shrublands.

Mountain plover Prefers large, flat grassland expanses with sparse, short vegetation, 

and bare ground

Olive-sided flycatcher Associated with openings and edges in coniferous forest habitat. it is 

generally more abundant in mixed conifer, late-successional forest 

with less than 40% canopy cover

Painted redstart Middle- and upper-elevation riparian woodlands, and adjacent pineoak woodlands, generally prefers areas with rugged slopes and 

deeply-shaded canyon bottoms.

Pinyon jay Associated with pinyon-juniper habitat
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Species Habitat Association

Pygmy nuthatch Occurs in forests of pine mixed with oak, quaking aspen, maple, 

Douglas-fir, or white fir

Red-faced warbler Mixed conifer and ponderosa pine forests, typically with a Gambel 

oak or other deciduous tree component

Red-headed woodpecker Associated with both deciduous woodlands and open areas with 

surrounding trees or isolated woodlots. prefer woodlands and areas 

with tall trees with large circumferences, high basal area, and low 

density of stems in understory

Vesper sparrow Found in open habitats, including old fields, shrub-steppe, 

grasslands, and cultivated crop fields. Generally prefers short, 

sparse, and patchy herbaceous vegetation with some bare ground, 

and low to moderate shrub or tall forb cover

Virginia’s warbler Occurs at middle elevations, where coniferous woodland or forest 

mixes with deciduous shrubs or trees.

Whiskered screech-owl Occupies canyon areas in montane forests

Williamson’s sapsucker Inhabits open, mixed coniferous and deciduous forests in mountain 

areas up to 10,000 feet in elevation.

Environmental Consequences

Alternative A

For all migratory bird species listed in table 54, there would be no change to the habitat or 

disturbance to the species, but there is still exists the risk of wildfire impacts to forested and 

woodland cover types. A determination of “no impact” is made for alternative A.

Effects Common to Alternative B, C, and D

For all migratory bird species listed in table 54, individuals may be disturbed by project 

equipment noise and human presence in the short term. Proposed treatments would improve 

habitat and reduce wildfire threat in long term. Some habitat elements may decline such as the 

amount of bare ground, juniper cover types or increase such as amount of larger and mature tree 

stands, grasslands. Depending on the bird species and their habitat preference, this may either be 

a positive or a negative impact. During implementation, not all associated habitat types will be 

treated at the same time, providing opportunity for birds to utilize adjacent or nearby habitat, 

therefore reducing disturbance and impacts to individuals from activities and habitat treatments. 

There may be short-term impacts to individual migratory birds, but alteration to their habitats or 

being disturbed during treatments, will not negatively affect population levels.

Alternative C – Herbicide Utilization

All other effects are the same as alternative B.

Herbicide application may disturb individuals by noise and human presence in the short term. 

Rabbitbrush and alligator juniper would be reduced, providing opportunity for growth and 

increase of herbaceous plants in treatment areas. During implementation, not all associated 

habitat types will be treated at the same time, providing opportunity for birds to utilize adjacent 

or nearby habitat, therefore reducing disturbance and impacts to individuals from activities and 

habitat treatments. To further reduce impacts manufacturer labels will be followed during 

application. There may be short-term impacts to individual migratory birds, but alteration to their 

habitats or being disturbed during treatments, will not negatively affect population levels.
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Alternative D

All other effects are the same as alternative B.

Not adding user-proposed routes would not impact habitat nor disturb the species. There would 

be beneficial effects by not having routes crossing through habitats causing fragmentation. 

Although routes are not added under this alternative, other activities are still being implemented, 

therefore there may be short-term impacts to individual migratory birds, but alteration to their 

habitats or being disturbed during treatments, will not negatively affect population levels.

Air Quality

Incomplete or Unavailable Information

The following discusses where information is incomplete or unavailable and its relevance to 

environmental effects analysis.

Air Quality: Smoke analysis was unavailable for prescribed burning treatments. 

Gila National Forest personnel did not attempt any smoke modeling related to prescribed 

burning treatments. A review was done of smoke monitoring information during past prescribed 

fires to ascertain length of smoke disturbance. Gila National Forest personnel would also follow 

the New Mexico smoke management program guidelines to determine burning windows that 

allow for proper ventilation and dispersion of smoke to protect air quality and human health. 

This existing information and mitigation is adequate to determine the effects of the action 

alternatives.

Alternative A – No Action

This alternative has no direct effect on air quality because no treatment activities are proposed.

Under this alternative, no treatments would occur and there would be no anthropogenic emission 

contribution to degrade air quality. However, this alternative could lead to increased 

accumulation of ground fuel due to insect and disease activity and continuous natural forest 

succession. This accumulation of ladder and ground fuels may lead to an increased probability of 

high intensity wildfire in the future which could result in air quality degradation. Air quality can 

be degraded by smoke from wildfires to the point of human illness in some instances. Hardy et 

al. (2001) noted emissions from wildfire are typically greater than emissions from a prescribed 

fire on the same acreage due to greater emission factor, fuel consumption, and fire intensity. 

Wildfires are also known to result in high levels of emissions, and associated violations of 

national ambient air quality standards. Smoke from wildfire can cause visual impacts to the 

surrounding area and create hazardous driving conditions on adjacent state, county, and Forest 

Service roads for extended periods of time. Should a wildfire occur, dust emissions from fire 

suppression equipment could also increase. In the short-term air quality impacts from alternative 

A would be less because prescribed burning treatments and project activities would not occur. In 

the long term, the no-action alternative would not meet the purpose and need of this project. 

Previous wildfire activity, natural forest succession and increasing conifer mortality due to insect 

and disease can influence the amount of material available for consumption in the event of a 

future wildfire.

Emissions sources contributing to particulate matter and other pollutants would continue to be 

present. These sources include wood burning stoves, vehicle exhaust, emissions from 
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recreational campfires, emissions associated with prescribed fire, fugitive dust, and wildfires 

within or near the project area. Wildfire frequency is expected to continue as it has been 

observed in the past. A wildfire could lead to negative cumulative effects and would be 

dependent upon the size and intensity of the wildfire. Visibility impairment and human health 

impacts due to sudden and dramatic pollutant release are likely with a large wildfire event.

Cumulative effects of smoke are unknown because the intensity and size of a wildfire is 

unknown. Research indicates wildfires can produce nearly twice the amount of smoke as 

prescribed fire (Huff et al. 1995).

Alternatives B, C, and D

A small amount of fugitive dust is likely to be generated from project activities. This dust is 

expected to settle quickly and result in minimal short-term impacts to air quality. 

Prescribed burning treatments would have direct, short-term impacts on air quality in the project 

area. All proposed prescribed burning would occur when weather conditions and dispersion 

forecasts are favorable. Transitory smoke as a result of implementing alternative B, C, or D 

could produce some smoky days in the local area, and nuisance smoke (smell, see, or haze). 

Smoke would also be expected to settle into the lower draws and drainages during the evening 

hours following ignition. 

The project is 24 air miles northeast of the Gila Wilderness Class I airshed and is not within a 

recognized area of nonattainment for particulate matter 10, carbon monoxide, sulfur dioxide, 

ozone or total suspended particulates. Therefore, no analysis is necessary or provided to 

determine conformity with the State implementation plan for air quality. 

Smoke generated from prescribed fire is likely to impact human populations towards the 

northeast and east; due to predominant wind direction. Some wind variability would occur due 

to the surrounding topography. If the winds follow the prevailing direction during burning, 

smoke would drift and disperse over mostly unsettled portions of the Gila National Forest. 

The communities of Luna, Cruzville, Apache Creek, Aragon, Reserve, Rancho Grande Estates, 

and Alpine, Arizona are all within approximately 8 to 15 miles of the Luna Restoration Project

and would likely experience the greatest impact from prescribed burning and pile burns. There 

are other communities greater than 15 miles in any direction in which residents could see, smell, 

and experience smoke and haze. 

In contrast to wildfire, prescribed fires follow a written prescription which allows managers to 

minimize smoke impacts. Emission reduction techniques, can reduce the impacts to air quality 

while meeting fire-related objectives. These techniques are outlined in New Mexico’s smoke 

management plan (NM 2005). The Gila National Forest personnel are responsible for following

the state’s smoke management requirements. 

Overall, there are no measurable differences in regards to air quality between the alternatives. 

One aspect of the purpose and need for this project is to reduce the impacts of high-severity fire. 

Smoke from wildfires can present a risk to public health. Wildfires often result in high levels of 

emissions, poor visibility, and associated violations of national ambient air quality standards. 

Vegetation management treatments provide the opportunity on a long-term basis to reduce the 

magnitude of wildfire air quality concerns. According to Wiedinmyer and Hurteau (2010) widescale prescribed fire application can reduce carbon dioxide fire emissions for the western U.S. by 
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107

18 to 25 percent. The total amount of pollutants released by prescribed burning under alternative 

B, C or D would be spread out over several years and would occur when emissions would be 

unlikely to have adverse effects on human health and visibility. After implementation, it is 

estimated that subsequent wildfires in the project area would produce less pollutants due to less 

fuel available to burn. 

Fugitive dust may be generated in areas where mechanical operations are occurring and with 

associated vehicle travel. These impacts are expected to stay within the analysis area as dust 

from roads settles out relatively quickly. There is no measurable difference expected between 

alternatives as related to dust generated from restoration activities. Best management practices 

should be effective in retaining protective ground cover, reducing exposed soil susceptible to 

wind erosion and creation of dust in all action alternatives. This project is not within a Statedesignated nonattainment area; therefore, no conformity assessment was necessary or completed. 

Compliance with Clean Air Act would continue. 

Air quality as a result of implementing alternatives B, C, or D would result in a short-term 

increase in pollutants from prescribed fire smoke emissions and fugitive dust. When considering 

past, present, and reasonably future activities, the activities proposed in the alternatives are not 

anticipated to result in cumulative effects to air quality. 

Watershed and Soils

General Assumptions

• No more than 25 percent of a 6th code watershed within a 3-year period would be treated. 

This percentage may be adjusted up or down based on monitoring and assessment of 

watershed conditions, after treatments.

• The reduction or elimination of vehicle traffic on a road or trail near a stream will result in

less sediment delivered from the road to the stream over time. This relates to the reduction

of the amount of loose material on the road surface and also the increase in the amount of 

vegetative litter and other cover on the road surface. Erosion rates from a closed road may 

decrease to near background levels as the density of vegetation on the surface of the road 

increase (Dissmeyer, 2000).

• Closed routes without fixed barriers are expected to revegetate minimally. These routes 

will not disappear from the landscape until decommissioned, and will continue to be a 

source of sediment and erosion to some degree. They will still be included in road density 

calculations. 

• Best management practices would be properly implemented to aid in mitigating negative 

impacts to water quality and quantity, soil resources, riparian and wetland resources, and air 

resources.

• Existing road system has already committed soil resources to loss of productivity.

• Routes that are connected to the drainage network provide some level of sediment 

transport, regardless of whether drainage is perennial, intermittent, or ephemeral. These 

sediment inputs vary based on duration and frequency of flow events. During short 

duration, high intensity storm events, ephemeral drainages can carry a considerable 

amount of sediment, some of which is generated by roads. 
Chapter 3. Affected Environment and Environmental Consequences

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108

• The 2015 watershed condition classification incorporated management activities and

watershed events that occurred in the past or that are on-going. The final assessment of 

watershed condition in 2015 constituted a culmination of these activities, events, or both 

leading to current watershed condition. The condition classification of each 6th code 

watershed is considered a result of cumulative watershed effects up to 2015.

Incomplete or Unavailable Information

The following discusses where information is incomplete or unavailable and its relevance to 

environmental effects analysis.

Soils: The general ecosystem survey map and associated soil interpretations were partially used 

to evaluate soils within the Luna Restoration Project. 

The general ecosystem survey is mapped at a scale of 1:250,000 and was designed for general 

assessments and evaluation of projects at the landscape or forestwide level similar to the scope 

of the proposed action. It is key to acknowledge the general ecosystem survey is a very broad 

scale survey (1 inch equals approximately 4 miles) and many differences in soils, geology and 

topography can occur within very short distances. The draft forest terrestrial ecosystem survey 

map was used to identify erosive soils formed from volcanic sediments. Currently no soil map 

unit interpretations have been developed to accompany the draft terrestrial ecosystem survey 

map.

Gila National Forest personnel did not attempt any sedimentation modeling by alternative due to 

incomplete data. Although complete data was unavailable, ongoing survey information and past 

ecosystem survey data were evaluated. Best professional judgment was applied to determine the 

likelihood of soil disturbance from treatments as well as review of best available science and 

current literature related to vegetation treatments. Best management practices were developed by 

the interdisciplinary team to mitigate any expected impacts to soils. Therefore, the existing 

information is adequate to determine the effects of the action alternatives.

Riparian: Some riparian systems within the project area did not have a recent or completed 

proper functioning condition assessments. 

These include Romero Creek, Centerfire Creek, and some reaches of the San Francisco River.

Design for stream stabilization treatments will occur following completion of environmental 

analysis. Site-specific disturbance related to design implementation is unavailable.

Field inspections, photographic documentation, or both for all riparian systems within the project 

area had been made within the past three years by members of the project’s interdisciplinary

team. Best professional judgment was applied to determine resource conditions, trends, proposed 

treatments, and effects from proposed treatments. The existing information is adequate to 

determine the effects of the action alternatives.

Affected Environment

Watershed Condition

This analysis will address effects at the sixth code watershed level, which range in size from 

approximately 7,000 acres to 38,000 acres within the project area. 
Chapter 3. Affected Environment and Environmental Consequences

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109

Watershed condition encompasses both aquatic and terrestrial processes and functions as the 

quality of water and aquatic habitat are inseparably linked to the integrity of uplands and riparian 

areas within a watershed. Aspects of a watershed related to geomorphic integrity can be defined 

in terms of attributes such as slope stability, soil productivity, channel morphology and other 

upslope, riparian and aquatic habitat characteristics. Hydrologic integrity of a watershed is 

related primarily to flow, sediment and water quality attributes. Biological integrity can be 

defined by the aquatic characteristics that influence the diversity and abundance of species. In 

each case, integrity must be evaluated in the context of the natural disturbance regime, 

geoclimatic setting and other important factors. The geomorphic, hydrologic, and biologic 

components are then combined and evaluated as a whole to assess watershed integrity and 

health. 

Three classes are used to describe watershed condition (USDA Forest Service 2004, Forest 

Service Manual 2521.1): 

• Class 1 watersheds exhibit high geomorphic, hydrologic, and biotic integrity relative to 

their natural potential condition.

• Class 2 watersheds exhibit moderate geomorphic, hydrologic, and biotic integrity relative 

to their natural potential condition. 

• Class 3 watersheds exhibit low geomorphic, hydrologic, and biotic integrity relative to 

their natural potential condition.

In March 2011, watershed condition classification was initially completed across the Gila 

National Forest at the subwatershed level (6th code). A review and reclassification of all Gila 

National Forest watersheds was completed in December 2015. The watersheds were classified as 

being in one of the three condition classes noted above, as translated to functionality. 

• Class 1 = Functioning properly, 

• Class 2 = Functioning at risk, and 

• Class 3 = Impaired function. 

The Luna Restoration Project occupies a portion of nineteen 6th code watersheds, however the 

majority (98 percent) of the project area falls within 11 of the following 6th code watersheds: 

Canovas Creek – Coyote Creek, Trout Creek, Stone Creek – San Francisco River, Dry Blue 

Creek, Spur Draw, SA Creek, Headwaters Centerfire Creek, Outlet Centerfire Creek, Big 

Canyon – San Francisco River, Hay Vega, Cow Springs Draw. Table 55 provides the percentage 

of the project area found in all of the 6th code watersheds along with the 2015 watershed 

condition classification rating. 

Watersheds with less than 2 percent of the area in the project will not be evaluated further. 

Activities in the Luna Restoration Project will not affect all of the indicators used to derive the 

watershed condition rating. 

Current watershed conditions are the culmination of historic activities since the late 1800s and 

early 1900s, ongoing management activities, climate fluctuations, roads, and recent wildfire. 
Chapter 3. Affected Environment and Environmental Consequences

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110

Table 55. Summary of watersheds and condition ratings that overlap the Luna planning area. 

Watershed condition ratings are Class 1 = Functioning Properly; Class 2 = Functioning at Risk; and 

Class 3 = Impaired Function.

6th Code 

Watershed / 

Hydrologic Unit 

Code

Acres in 

Watershed

Project Acres 

in Watershed 

(includes 

private land 

acres)

% of Project 

within 

Watershed

% of 

Watershed 

Occupied by 

Project

Watershed 

Condition 

Rating

Hay Vega

150200010301

7,091 3,236 2% 46% Class 1 

Canovas Creek – 

Coyote Creek

32,466 10,834 6% 33% Class 2 

Cow Springs 

Draw

150200030703

31,273 6,568 4% 21% Class 1

Mangitas Creek

150200030505

23,062 2,235 1% 10% Class 1

Campbell Blue 

Creek

150400040503

34,218 617 <1% 2% Class 3

Trout Creek

150400040302

20,934 13,174 7% 63% Class 2

Stone Creek-San

Francisco River

150400040303

35,769 24,276 13% 68% Class 2

Spur Draw

150400040304

26,179 26,179 14% 100% Class 2

SA Creek

150400040305

22,560 22,560 12% 100% Class 2

Headwaters

Centerfire Creek

150400040306

18,536 18,536 10% 100% Class 2

Outlet Centerfire

Creek

150400040307

20,591 20,591 11% 100% Class 3

Big Canyon-San

Francisco River

150400040308

16,418 16,418 9% 100% Class 2

Dry Blue Creek

150400040502

25,048 19,104 10% 76% Class 2

Starkweather 

Canyon 

150400040309

25,279 636 <1% 3% Class 2

Cienega CanyonSan Francisco 

River

150400040311

36,089 188 <1% 1% Class 2

Centerfire Creek 

– Blue River 

150400040504

17,311 329 <1% 2% Class 1
Chapter 3. Affected Environment and Environmental Consequences

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6th Code 

Watershed / 

Hydrologic Unit 

Code

Acres in 

Watershed

Project Acres 

in Watershed 

(includes 

private land 

acres)

% of Project 

within 

Watershed

% of 

Watershed 

Occupied by 

Project

Watershed 

Condition 

Rating

Headwaters Saliz 

Canyon

150400040401

26,228 98 <1% <1% Class 1

Steeple CanyonBlue River

150400040506

37,760 5 <1% <1% Class 2

Upper Pueblo 

Creek

150400040601

21,554 3 <1% <1% Class 2

In 2011, the Wallow Fire burned across acres of the Gila National Forest, within the Luna 

Restoration Project boundary. This fire originated on the adjacent Apache-Sitgreaves National 

Forests, and burned during drought conditions, resulted in severe negative impacts to watershed 

conditions on both national forests along the state line.

Watershed conditions have improved over the last century across the project area, and within the 

last several years within the Wallow Fire burn scar. However, there are still many localized areas 

throughout the project area where restoration of ecosystem health and watershed functionality is 

necessary. Headcuts and gullies are still active in many of the streams, ephemeral drainages, and 

low-lying swales. A great effort was placed on restoration of these sites in the 1980s. More than 

150 erosion control structures were constructed, however little maintenance has occurred on 

these sites to date. Additional areas have since been identified for erosion control measures and

other restoration treatments. The Escudilla Landscape watershed restoration action plan has been 

developed concurrently with this analysis that details many specifics related to the watershed 

condition rating for eight of these watersheds and four on the adjacent Apache-Sitgreaves 

National Forests (USDA Forest Service, 2017). 

Soils 

Soils within the Luna Restoration Project can be characterized as highly variable. They have 

been formed primarily from volcanic sediments, basalt, rhyolite, sandstone, and recent alluvium. 

The soils range from shallow to deep and stable to unstable in nature, with varying amounts of 

surface and subsurface rock fragments. The topography within the project area ranges from 

gently sloping elevated plains, valley bottoms, and hills to steep mountains and scarp slopes. 

The project area has many acres of soils that were formed from volcanic sediments which are 

oftentimes referred to as Datil soils. These soils are highly erosive and are typically not very 

productive. 

Table 56 and table 57 display acres and percent of project area by soil condition and erosion

hazard rating. 
Chapter 3. Affected Environment and Environmental Consequences

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112

Table 56. Summary of general ecosystem survey soil condition within the Luna planning area.

Soil Condition Satisfactory Unsatisfactory Unsuited

Acres 155,550 27,560 3,927

Percent 83% 15% 2%

Table 57. Summary of general ecosystem survey erosion hazard within the Luna planning area.

Erosion Hazard Slight Moderate Severe

Acres 78,422 79,502 27,113

Percent 42% 43% 15%

Aquatic Resources

Water resources within the project area include streams, wetlands, riparian areas, ponds, and 

numerous stock ponds and tanks. There are approximately 75 miles of perennial streams and 39 

miles of intermittent streams in the project area. The remaining drainages are considered 

ephemeral, of which there are approximately 634 miles of these systems. There are 

approximately 205 surface acres of open water within the project area. These acres are mainly 

associated with stock ponds, and other larger storage reservoirs, when filled to capacity. 

The major drainages within the project area are San Francisco River, Stone Creek, Jenkins 

Creek, Romero Creek, SA Creek, Trout Creek, Canovas Creek, Spur Draw, Centerfire Creek, and 

Dry Blue Creek. The San Francisco River, Dry Blue Creek, and Stone Creek have experienced, 

direct or indirect effects from the 2011 Wallow Fire. These effects included increased stream 

flow volumes and peak flow magnitudes, with accompanying excess channel erosion and 

sedimentation. Spring discharge, a source of perennial water for a number of streams, has 

increased from the decreased transpiration associated with the loss of over story vegetation. 

Recovery of the hydrologic regime following wildfire generally occurs within a 5 to 10 year 

period, however it can take longer. 

Riparian, Wetlands, and Upland Wet Meadows

Riparian areas found within the Luna Restoration Project were evaluated using site visits by 

members of the interdisciplinary team, proper functioning condition surveys (USDI 1993), or 

both to determine both riparian potential and functionality. Areas evaluated within the project 

area are Jenkins Creek, Trout Creek, San Francisco River, Stone Creek, Centerfire Creek, SA 

Creek, Pace Creek, Dillman Creek, Adair Canyon, Spur Basin Draw, Romero Creek, Dry Blue 

Creek, and Canovas Creek. Most of the drainages within the planning area are ephemeral in 

nature, and only flow in response to precipitation or runoff events. 

Water Quality

The potential adverse effects from most forest management activities are non-point sources, as 

opposed to point sources of water pollution. To ensure compliance with the Clean Water Act, 

water quality standards are set by the New Mexico Water Quality Control Commission. New 

Mexico’s surface water quality standards define water quality goals by designating uses for 

waterbodies, setting criteria to protect those uses, and establishing provisions to preserve water 

quality. These water quality standards are examined for changes on a 3-year rotating basis. The 

current standards are documented in the New Mexico Administrative Code (NMAC) Title 20, 

Chapter 6, Part 4 "New Mexico Standards for Interstate and Intrastate Surface Waters" (New 

Mexico Water Quality Standards). Under section 303(d)(1) of the Clean Water Act, States are 
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

113

required to develop a list of waters within a state that are not in compliance with water quality 

standards and to establish a total maximum daily load for each pollutant. Reaches of streams that 

are in some state of nonattainment are documented in "2016-2018 State of New Mexico Clean 

Water Act Section 303(d)/Section 305(b) Integrated Report Appendix B - Integrated List” (State 

of New Mexico 2016). Currently there are two waterbodies within the project area that are 

included in this report.

Headwaters Centerfire Creek and Outlet Centerfire Creek 6th code watersheds

Centerfire Creek (San Francisco River upstream to headwaters) is in non-support of its 

designated use of “high quality coldwater aquatic life” and “primary contact”.

• Probable causes of impairment are identified as nutrient/eutrophication, 

sedimentation/siltation, specific conductance, water temperature, turbidity, and E. coli. 

• Probable sources of impairment include low water crossings, channelization, recreational

pollution sources, source unknown, drought-related impacts, silviculture, fire suppression, 

silviculture activities, road and bridge runoff, rangeland grazing, natural sources, and 

streambank modifications and destabilization.

• Total maximum daily loads for plant nutrients and conductivity were completed in 2002. 

Total maximum daily loads for turbidity and E. coli were scheduled in 2014. Water 

temperature standards are currently under review. 

Stone Creek – San Francisco River and Big Canyon – San Francisco River 6th code 

watersheds

San Francisco River (Centerfire Creek upstream to Arizona State Line) is in non-support of its 

designated use of coldwater aquatic life. 

• Probable cause of impairment is identified as water temperature and benthic macroinvertebrate community.

• Probable sources of impairment are silviculture, fire suppression, rangeland grazing, and 

source unknown. 

• Total maximum daily loads for temperature and plant nutrients were completed in 2002. 

The reach was delisted for nutrients during the 2010 listing cycle. Water temperature 

standards are currently under review. 

Water quality related to stream temperature is of major concern in the perennial and intermittent 

streams located in the Luna Restoration area. Often related to riparian health, temperature is 

important because it governs the kinds and types of aquatic life that can be present in the stream, 

regulates the maximum dissolved oxygen concentration of the water, and influences the rate of 

chemical and biological reactions. Seasonal variations in stream temperature may be caused by 

changing air temperature, solar angle, meteorological events, and a number of physical aspects 

related to the stream and watershed. These physical features include upland watershed condition, 

velocity, vegetation types and canopy cover, stream configuration, and land use.

Summary of Resource Conditions

Existing stream crossings – Negative impacts to riparian areas is occurring as current stream 

crossings go directly through riparian areas and wetlands. Negative impacts to vegetation in 
Chapter 3. Affected Environment and Environmental Consequences

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Draft Environmental Impact Statement

114

these areas include rutting of wetlands, damage to riparian woody and herbaceous vegetation, 

and increased sedimentation downstream of crossings. 

Encroaching conifers in riparian areas and upland wet meadows – Conifers are currently 

encroaching into floodplains, riparian areas, and fringes of the wet meadows, taking available 

water, nutrients, and energy that would otherwise be available to riparian and wetland species. 

Continuation of this encroachment will eventually lead to an ecological conversion of the site to 

more upland vegetation species, thus reducing wetland and riparian habitat within the project 

area. This would limit water quantity, in particular, from being available for valuable wetland 

and riparian habitats. 

Ungulate utilization in degraded riparian and uplands – Several degraded riparian areas and 

upland sites have been identified for restoration needs. Water quality impairments have been 

identified by the State as a result of rangeland grazing with some of the probable causes of 

impairment notes as sedimentation or siltation and temperature. These causes can be both a 

direct and indirect result of inadequate woody and herbaceous vegetation, both in uplands and on 

streambanks. 

Stream and wet meadow stabilization structures – Stream reaches throughout the project area 

that have been experiencing increased water flows and sediment delivery due to wildfire and 

flood events would not receive any treatments. These streams would have to continue to recover 

at a natural rate. In some of these streams, such as Stone Creek and Centerfire Creek, slow to no 

recovery is currently occurring. It would take decades for these systems to move towards upward 

trends without multiple treatments. 

Riparian tree planting – There are riparian areas and stream systems that currently have 

excessive sedimentation, unstable banks, lack of vegetation, and high temperatures. Areas that 

are currently not functioning or in downward trends would maintain this condition and in areas 

where there are temperature and siltation impairments, these would not improve without 

improvement to riparian vegetation.

Head of Ditch irrigation diversion reconstruction – The current diversion has negative 

impacts on the adjacent riparian area as heavy equipment is in the channel several times every 

year, constructing and deconstructing the push-up dam. This disturbance does not allow longterm recovery of riparian woody species, and results in excessive sedimentation at the site and 

downstream. 

Wet meadows – Currently there are locations in wet meadows that receive motorized traffic 

several times throughout the year, even though the routes are closed. Motorized use in wet 

meadows poses a threat to soil productivity and vegetation. Repeated motorized use can cause 

soil compaction in these areas, which may result in long-term adverse effects to riparian and wet 

meadow conditions. 

Erosion stabilization structures – Currently, the effectiveness of a majority of the existing 

erosion control structures has diminished over the years or they are no longer functional. Several 

of these structures have breached, and new headcuts have formed. This has caused excessive 

sediment that ultimately moves downstream and into riparian areas and wet meadows. Some of 

the structures are located in upland wet meadows and resultant new headcuts are proceeding to 

dewater these areas. 
Chapter 3. Affected Environment and Environmental Consequences

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Degraded uplands – Downstream negative impacts to riparian areas are occurring with 

excessive sedimentation being generated from degraded uplands. These areas will continue to 

produce sediment and higher overland flows if herbaceous vegetation is not restored. 

Campgrounds – Existing road and campsite drainage leads directly to the adjacent waterways of 

San Francisco River and Trout Creek, thus providing a direct input of sediment. This influx of 

sediment will continue to hamper improvement of riparian conditions in these areas as it impacts 

bank stability and riparian vegetation growth. 

Range Management – Livestock would continue to provide the same pressure at existing water 

sources including where water source is spring-fed with associated riparian vegetation. 

Motorized Transportation – There are negative impacts occurring where motorized routes 

coincide with riparian areas and wetlands/wet meadows. Closed routes continue to discharge 

runoff and sediment to adjacent waterways. Some closed roads are located in the drainage 

bottoms of perennial streams, with associated riparian vegetation, where unauthorized use is 

occurring. Other closed roads cross or are adjacent to wet meadow areas. These routes still 

receive some amount of unauthorized use and cross-country travel, although unauthorized. 

Environmental Consequences

Soil Resources 

Alternative A

Mechanical Vegetation Treatments

The existing condition of soils and soil loss rates will continue under the no-action alternative. 

Trends would remain stable in vegetation types where there is adequate vegetative ground cover 

and canopy cover. Organic soil carbon will accumulate at potential rates and soil fertility will 

slowly improve if accumulation of organic matter continues at its present rate. Existing amounts 

of coarse woody material would remain constant, with an increasing amount likely within the 

Wallow Fire scar as dead trees begin to topple. There would be no disturbance to soils from 

vegetation treatments as vegetative ground cover would remain intact, with no disturbance from 

landings, skid trails, heavy equipment, or other treatment related impacts. No mowing of 

rabbitbrush would occur, thus canopy cover in these areas would remain high with very little 

herbaceous understory in impacted rangelands. No herbicide treatment would occur on either 

rabbitbrush or alligator juniper, there would be no risk to the soil resource or soil crusts from 

potential chemical interactions. Infiltration rates would remain the same as there would be no 

increase in surface runoff from soil disturbing activities. 

Tree encroachment will continue in grasslands and meadows. A study on the Cibola National 

Forest concluded competition for limited site resources (nutrient stock, water, sunlight, etc.) 

from a relatively dense juniper overstory was the principal cause for decline in understory 

productivity and deterioration of soil quality at their study site (Brockway et al 2001). As woody 

species encroachment occurs, grass biomass and cover decrease as woody species biomass and 

cover increase. Additionally, herbaceous species richness and diversity tends to decline as woody 

species density increases (Van Auken 2009). If site conditions such as this persist, infiltration 

rates may gradually decrease as water-compacted, bare soil increases and organic matter 

accumulation decreases. 
Chapter 3. Affected Environment and Environmental Consequences

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116

Ponderosa pine and mixed conifer vegetation types will remain at risk for future soil loss as high 

tree density and heavy fuel loading in forested stands increases the risk of uncharacteristic highintensity wildfire. High-severity fire can result in large areal extents of high soil burn severity 

which can pose negative impacts to soil productivity and site stability. High tree densities can 

also create conditions where herbaceous ground cover is out-competed for sunlight,

precipitation, and nutrients. A reduction in grass under these thick canopies could result in less 

favorable site conditions over the long term. 

Overall in the no-action alternative there would be no long-term benefit to soil resources, 

resulting in a potential downward trend in soil condition. 

Prescribed Fire Treatments

Ponderosa pine and mixed conifer vegetation types which have high tree densities and canopy 

cover tend to exhibit heavy fuel loading in the understory. As surface and ladder fuels increase, 

and tree density increases, the probability of high-intensity uncharacteristic wildfire increases 

resulting in the potential for high soil burn severity. The loss of canopy cover, ground cover, and 

organic debris on the soil surface, together with the possible occurrence of hydrophobic soil 

layers in these areas, would likely lead to considerable increases in soil erosion, loss of soil 

organic matter, and reduction in long-term soil productivity. This would result in a greater risk of 

negative impacts to the soil resource under alternative A compared to all action alternatives. 

Soils under dense, closed canopy, stands pinyon-juniper and in heavily encroached meadows 

would not realize any increase in herbaceous ground cover or site productivity. Soil condition in 

these areas would likely stay the same or experience a downward trend. Similar to ponderosa 

pine and mixed conifer vegetation, if heavy surface fuel loading are present, these areas would 

be at a higher risk to high soil burn severity in the event of a wildfire. 

Soils in grassland and meadow vegetation types would not be affected under alternative A since 

surface fuel loading is relatively low in these areas. Soils would remain in their existing 

conditions with the same trends. 

Stream, Riparian, and Erosion Control Treatments 

Restoration activities would not occur in alternative A. Degraded soil conditions, including 

excessive erosion and destabilization would continue at their current rate. 

In areas where conifers are beginning to encroach into upland wet meadows and riparian areas, 

soil conditions would likely remain stable for a period of time. However, conifer encroachment 

would continue to compete with riparian, wetland, and wet meadow species for sunlight, water 

and nutrients. 

In areas where degraded soils are negatively impacting riparian areas, streams, wetlands, and wet 

meadows, these conditions would continue and cause further detriment to water quality. 

Sediment control structures would not be cleaned or maintained, and those that are breached 

would continue to headcut upstream. Soil stability would lessen, stream bank stability would 

decrease, and erosion rates would continue or worsen. 

At the Head of Ditch diversion site, ground disturbance would persist multiple times per year as 

native soil push-up dams would be installed and removed repeatedly to accommodate irrigation 

season and in response to flooding events. 
Chapter 3. Affected Environment and Environmental Consequences

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117

The potential for a downward trend in areas currently having negative soil resource issues would 

occur with implementation of alternative A. 

Range Management Treatments 

New range improvements consisting of storage tanks, wells, drinkers, pipeline, and pasture 

division fences would not occur under the no-action alternative. Currently, isolated areas around 

existing water points receive heavier use from livestock and wildlife, resulting in less herbaceous 

vegetation and soil compaction. These areas would remain the same as there would be no 

improvement in distribution of livestock and wildlife. However, the acres associated with these 

areas are minimal across the project area. No soil disturbance would occur under this alternative. 

Soil conditions and trend would remain the same.

Motorized Transportation Treatments 

There would be no change to the motorized vehicle transportation system. 

This alternative results in the least amount of soil disturbance related to motorized transportation 

system. However, the absence of road improvements, decommissioning, or reroutes under this 

alternative would result in negative soil impacts to occur in many locations across the project 

area. With no road decommissioning, closed routes would still continue provide a pathway for 

erosion to occur and for sediment to enter the waterway.

Negative impacts to the soil resource would continue at locations where current road conditions 

are poor and where motorized stream crossings are creating both erosion and water quality 

issues. Some locations currently have impaired site conditions due to instability / erosion 

problems resulting from structural crossing issues, heavy ground disturbance from motorized 

traffic, or both. If these conditions persist in these locations, a downward trend in soil conditions 

is likely.

Effects Common to Alternatives B, C, and D

In the development of these alternatives, sensitive soils were identified and considered. 

Vegetation treatments were excluded from these areas. Prescribed fire was excluded from most 

areas with sensitive soils; with the exceptions being the north aspect of the San Francisco Divide, 

and southwest of the community of Luna in Dry Blue Creek and Frieborn Canyon, extending 

south to the planning boundary. In these areas, low-severity fire may be introduced when fuel 

conditions, weather conditions, or both lessen fire spread across the landscape. 

Mechanical Vegetation Treatments

In these alternatives, where soils are in satisfactory condition, they would continue to be 

maintained or improved with implementation of best management practices. Vegetation with 

dense canopies and heavy coarse woody debris fuel loading would see enhancement from 

vegetation treatments. Vegetative ground cover would be reduced and/or spatially rearranged by 

proposed vegetation treatments. 

Restoration thinning would reduce the risk of forests and woodlands to intense, high-intensity 

uncharacteristic wildfire behavior which would increase the potential for high soil burn severity. 

Thinning would also help reduce competition for light, nutrients and water by creating gaps in 

canopies and reducing woody vegetation basal area. This would aid in restoring an herbaceous 

component to the understory which would help carry low-intensity fires. 
Chapter 3. Affected Environment and Environmental Consequences

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118

Heavy equipment used in vegetation treatments will cause varying degrees of soil compaction 

which can temporarily increase water runoff and delay, reduce, or both the establishment and 

growth of desired herbaceous vegetation. Short-term increases in soil loss related to ground 

cover and soil disturbance are expected from mechanical thinning and skidding operations, as 

well as from the use of existing roads by logging equipment. 

Long-term negative impacts to the soil resource from compaction or soil loss are not expected.

Site stability and long-term soil productivity are expected to be maintained. Skid trails, staging 

areas, and landing sites will be scarified and seeded as necessary to reestablish vegetative cover. 

This should reduce the potential for erosion and sedimentation that could originate from these 

areas. Roads that are currently adding sediment to the stream system could receive additional 

erosion control treatments during project implementation. Activity slash can help mitigate some 

impacts from ground disturbance on site stability and productivity and activity slash would 

provide long term soil nutrient cycling. 

Mowing of rabbitbrush under this alternative is not expected to have any adverse impacts to the 

soil resource. This activity will be done with rubber-tired equipment, with organic matter 

generated from mowing left largely in place, serving as organic matter and mulch across the soil 

surface. These areas of treatment are fairly flat, thus little soil movement is expected to be 

generated. 

It is anticipated that overall soil condition and trends across the project area will be maintained, 

and over the long term, the trend will improve. 

Prescribed Fire Treatments

Proposed prescribed fire treatments within ponderosa pine, mixed conifer, and pinyon-juniper 

vegetation types across the project have the potential to help maintain and/or improve soil 

conditions. Prescribed fire treatments would reduce surface and ladder fuels. These treatments 

would reduce the severity of future wildfires that could impact soils. 

Pile burning will likely result in localized, negative effects including soil sterilization and total 

consumption of fine organic materials which can result in loss of litter layer, oxidation of soils, 

hydrophobic soils, loss of soil structure, minimal return of native grasses, and an increase in 

forbs. These effects could also cause a localized decrease in infiltration and an increase in runoff. 

Soil conditions in riparian areas, wetlands, and wet meadows would be maintained as these areas 

would be buffered. Buffer distances are designed to provide adequate distance for ash and 

mobilized sediment to drop out prior to reaching riparian and water resources. 

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources. Soil conditions are expected 

to remain the same, with a lessening of risk to high severity wildfire. High-severity wildfire 

often results in negative effects to the soil resource. Upward trends would occur over the longterm if canopy covers are reduced and more herbaceous ground cover can be restored in these 

areas.

Prescribed fire can also stimulate more vigorous growth of grass and forb vegetation as well as 

reduce fuel loading. This can lead to overall improvements in herbaceous cover and maintenance 

of coarse woody debris into the future. These benefits would not occur under alternative A. 
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The prescribed fire activities proposed under these action alternatives would help reduce fuel 

loading and ladder fuels and reduce the risk of future high-severity wildfire; providing for longterm soil protection and soil productivity. 

Stream, Riparian, and Erosion Control Treatments 

Proposed riparian, stream, and erosion control treatments would maintain satisfactory soils and 

have the potential to improve impaired soils and reduce current soil loss rates. 

These treatments are designed to restore areas where site conditions are currently degraded. The 

treatments described in chapter 2 of this document would result in improving infiltration rates, 

bank stabilization, increase residence time of water in the system, control erosion, reduce

sediment movement into the stream, vegetation diversity along stream channels, increase 

herbaceous ground cover in the uplands, reduce direct motorized impacts on riparian and stream 

channels, and reduce sediment movement into stream channels from motorized crossings. 

The action alternatives provide for the improvement of impaired soil conditions as well as help 

in maintaining satisfactory soil conditions in riparian areas, wetlands, upland wet meadows, and 

degraded uplands. Upward trends are expected in all of these restoration areas. 

Range Management Treatments 

Additional watering sites in selected grazing allotments within the project area, are anticipated to 

improve livestock and wildlife distribution. Improvements would not completely eliminate 

concentrated use at existing watering locations. At new sites, some soil compaction and loss of 

herbaceous vegetation is likely to occur. 

Motorized Transportation Treatments 

Road improvements, reroutes, and decommissioning activities proposed under the action 

alternatives are designed to improve the soil resource over the long term. Road improvements 

are planned in areas where current routes are leading to erosion and contributing to movement of 

sediment into the stream system. 

Reroutes have been planned in areas where the current route crosses live streams, riparian areas, 

or both. Reroutes would be in a more stable locations with less water and soil resource impacts. 

Approximately 116 miles of decommissioning is planned where currently closed routes are no 

longer necessary for forest management activities. In the short term, approximately 104 miles 

would be available for decommissioning, while an additional 12 miles could be decommissioned 

following vegetation and prescribed fire treatments. 

Currently, these closed routes continue to provide a pathway for sediment delivery into the 

stream system and remain a source of ongoing erosion. Decommissioning would provide a 

barrier thus allowing the roaded area to return to its natural state. In these areas, there would be 

an increase in vegetation, infiltration rates, soil stability, and a reduction in overland flow and 

soil loss. Soil conditions that are currently unsatisfactory within the road bed would improve, 

with upward trends over the long term. 

These alternatives provide for several other motorized transportation treatments, for which the 

following direct and indirect effects would be realized. 
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Construction of 3 to 5 miles of temporary roads which would be obliterated following vegetation 

treatments. Short-term this temporary road construction would have negative impacts to the soil 

resource with removal of herbaceous vegetation and compaction during use. Subsequent 

obliteration should return the temporary road scar to its natural state. Construction and 

decommissioning of these temporary roads would result in 3.6 to 6.1 acres of new soil 

disturbance. 

Approximately 4.2 miles of trail tread (3 feet wide) would remain on roads that are scheduled for 

decommissioning. This motorized treatment would have short-term impacts to the soil resource 

during decommissioning, long term impacts would remain from the trail tread. This would result 

in approximately 1.4 acres of long-term disturbance with possible connectivity to waterways.

Reopening of 13.8 miles of motorized routes to all vehicle types would result in long-term 

continued negative impacts to the soil resource. These closed routes are not currently 

decommissioned, with only a signed closure in place. Compaction, lack of infiltration, loss of 

soil productivity, and lack of vegetative ground cover would persist in the long-term. This results 

in approximately 20.1 acres of continue commitment of the soil resource. 

Addition of 4.2 miles of user-created routes to the motorized system would result in long-term 

impacts to the soil resource, similar to the above-mentioned reopening of motorized routes. This 

results in approximately 6.1 acres of continued commitment of the soil resource. 

Reopen then close and/or decommission 34.5 miles of currently closed routes for vegetation 

and/or prescribe fire treatments (22.5 miles would be reclosed and 12 miles would be 

decommissioned) – this motorized treatment would have short-term negative impacts to the soil 

resource. Reopening a currently closed route would subject it to renewed compaction and 

removal of any vegetation gains it might have seen during its closure. Follow-up closure would 

negate these impacts, however it may be a few years before this occurs. The roadbed scar would 

continue to result in some level of soil disturbance in the long term. Roads that would be 

decommissioned following treatments would see more benefit to the soil resource as they would 

be returned to their natural state, with an increase in vegetation, infiltration, and some restoration 

of soil fertility and productivity over the long term. This would affect approximately 51.6 total 

acres. Approximately 32.7 acres would realize benefits of being reclosed while 17.5 acres would 

realize benefits of decommissioning. 

Construction of 0.3 miles of all-terrain vehicle routes would have both positive and negative 

impacts to the soil resource. The new routes are being constructed to avoid riparian areas, 

stream crossings, and perennial water. The reroutes would improve the soil and water resources 

in these areas over the long-term. However, there would be 0.3 miles of new construction and 

commitment of 0.2 acres of the soil resource to the all-terrain vehicle routes. Overall, the 

positive outweighs the negative for soil and water resources as the soil, riparian, and water 

quality benefits are greater than the 0.2 acres of new disturbance across the landscape. 

Reopening of 3.5 miles of previously closed routes for administrative use or single purpose use 

(Tucson Electric Power line access) would have negative impacts on soil resources over the 

long-term as these roads would not be decommissioned in the future. Compaction, lack of 

vegetation, reduce infiltration, and loss of soil productivity would persist on these routes. This 

amounts to 5.1 acres of continued commitment of the soil resource.
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Alternative B would have negative impacts between 87.5 to 90 acres to the soil resource, some 

of which may be mitigated by decommissioning. The same amount of acres would be impacted 

in alternative C. The 87.5 to 90 acres is more than alternative A and 27.2 acres more than 

alternative D. 

Alternative C – Herbicide Utilization

Mechanical Vegetation Treatments 

Alternative C vegetation treatments are similar to alternative B, with the exception of the 

following treatments: 

• Herbicide may be used on 30 acres of meadow treatment that is currently proposed under 

alternative B for mechanical treatment. 

• Herbicide may be used in lieu of, or in addition to, all 20,283 acres of rabbitbrush

treatment areas proposed under alternative B, dependent on the site.

• Herbicide may be used on up to 8,000 acres of juniper that is currently proposed under 

alternative B for mechanical treatment.

Herbicide use is proposed in grasslands with rabbitbrush and woodlands with alligator juniper. 

Herbicides can persist in soils from a few months up to three years depending on soil type and 

environmental conditions such as soil moisture and temperature. The mobility of herbicides in 

the soil is determined by the adsorption capacity of the soil, soil moisture, and post application 

rainfall. Residence time in soils is also dependent soil texture and on the amount of microbial 

activity occurring in the soil. Soils associated with the rabbitbrush treatments have relatively 

high clay contents which will limit the mobility of the herbicide in the soil profile. Herbicide 

labels and application rates will be strictly adhered to. No negative effects to the soil condition or 

trend is anticipated with herbicide use in this alternative. 

Direct and indirect effects are the same as described in the common to all alternative section, 

above for prescribed fire, stream, riparian, and erosion control, range management, and 

motorized transportation. 

Alternative D 

Direct and indirect effects are the same as described in the common to all alternative section, 

above for mechanical vegetation; prescribed fire; stream, riparian, and erosion control; and range 

management treatments. 

Motorized Transportation Treatments 

Alternative D motorized transportation treatments are similar to alternative B, with the exception 

of the following treatments:

• There would be no reopening of 13.6 miles (19.8 acres) of motorized routes to all vehicle 

types under this alternative (0.2 miles would be reopened). Instead, these 13.6 miles would 

added to road decommissioning miles, bringing the total decommissioned miles to 

approximately 130 (189 acres) in alternative D. One hundred and eighteen miles would be 

immediately available for decommissioning, while 12 miles would be ready for 

decommissioning following vegetation and prescribed fire treatments. There would be an 
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increased benefit to the soil resource under alternative D, compared to alternatives B and 

C, with almost 14 more miles of road or approximately 20 acres returned to a natural state. 

• There would be no addition of 4.2 miles of user-created routes to the motorized system. 

There would no long-term impacts to the soil resource from continued use of these routes. 

Currently, all user-created routes are planned to be returned to their natural state. 

Alternative D has more positive benefits to the soil resource under this activity, then do 

alternatives B and C. 

• There would be no construction of 0.3 miles of all-terrain vehicle routes. There would be 

continued negative impacts to the soil resource at the crossing locations of Dillman Creek. 

However, no construction of a reroute would occur that would negatively impact soil 

resources in a new road bed. This area would remain undisturbed and soil productivity, 

stability, and fertility would remain the same. The current location of the route would 

continue to have negative impacts over the long-term to soil resources. Overall, the 

negative impacts of leaving this route in the same location would be greater than the 

negative impacts that 0.3 miles of new motorized trail would have, as the small 

disturbance of the landscape in uplands would not cause as lasting and continued harm as 

motorized stream crossings have to multiple resources. 

Alternative D provides close to 30 more acres of positive benefit to the soil resource than 

alternatives B or C, but allows from between 60.6 to 63.1 more acres soil disturbance than 

alternative A.

Table 58 provides a comparison of acres of disturbance from motorized transportation treatments 

by alternative. These acres were derived from miles of road and assumed road widths (table 25).

Table 58. Acres of disturbance by alternative from motorized 

transportation treatments.

Alternative 

Total Acres of Disturbance Related to 

Motorized Transportation Treatments

Alternative A 0 

Alternative B 86.7 – 89.2

Alternative C 86.7 – 89.2

Alternative D 60.6 – 63.1

Riparian Areas and Wetlands/Wet Meadows

Alternative A

Mechanical Vegetation Treatments

This alternative would not provide for any mechanical vegetation treatments to reduce heavy 

fuel loadings and promote conditions that reduce risk of uncharacteristic high-intensity wildfire. 

High soil burn severities are often a result of uncharacteristic wildfire, leading to severe negative 

effects to downstream water resources, including riparian areas, wetlands, and wet meadows. 

Increased overland flow as a result of hydrophobic soils and high soil burn severities can 

produce excessive flood flows in channels, from even minor precipitation events. Increased 

runoff volumes and velocities in streams lead to damaged streambanks and riparian areas, often 

changing channel geometry. Riparian vegetation can be severely damaged during these flood 

events and often take years to recover. Repeated flooding until watershed stabilization occurs in 
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burned areas will continually set back riparian recovery. This was evident during field review of 

several streams on the western boundary of the Luna Restoration Project. These streams are 

currently experiencing increased water flows and sediment delivery from the effects of the 2011 

Wallow Fire. The increased flows are causing both vertical and lateral stream instabilities, which 

have led to tremendous losses of riparian vegetation and have compromised floodplain access. 

These channels have experienced losses to much of their riparian habitat, with full recovery not 

expected for decades without restoration efforts. Without vegetation treatments, riparian areas 

will be placed at high risk for loss and associated downward trends in functionality in the event 

of an uncharacteristic wildfire. 

The existing condition of riparian areas, wetlands, and wet meadows would continue and 

potentially decline under the no action alternative. In areas where overstory densities are high, 

little long-term improvement in hydrologic flow regime will occur without mechanical treatment 

or other vegetation treatment methods. Wildfires in untreated areas pose a greater risk of 

negative impacts to riparian areas, wetlands, and wet meadows than wildfire occurring after 

implementation of vegetation treatments in alternatives B, C, and D. 

Prescribed Fire Treatments

Lack of prescribed fire treatments would result in effects similar to those noted above in the 

“Mechanical Vegetation Treatments” section. Not implementing prescribed fire treatments will 

continue to allow heavy fuel loading in the understory. As understory fuels build up and tree 

density and cover increases, the risk of higher intensity, uncharacteristic wildfire increases as 

well as the potential for high soil burn severity. The resultant loss of canopy cover, ground cover, 

and organic debris on the soil surface, together with the possible occurrence of hydrophobic soil 

layers in these areas, would likely lead to considerable increases in soil erosion, storm runoff 

response, and sediment movement into waterways. This would result in a greater risk of negative 

impacts to riparian areas, wetlands, and wet meadows under alternative A compared to all action 

alternatives. 

Stream, Riparian, and Erosion Control Treatments 

Restoration activities to address ongoing negative impacts to streams and riparian areas would 

not be implemented under alternative A. 

Effects Common to Alternatives B, C, and D

Mechanical Vegetation Treatments

Current conditions of riparian areas, wetlands, and wet meadows would be maintained or 

improved with the proper implementation of best management practices. 

Similar to the “Soils” and “Water Quality and Quantity” sections, areas across the project area 

with dense canopies and heavy coarse woody debris loading in the understory would see 

enhancement from vegetation treatments. Restoration thinning would reduce the risk of 

uncharacteristic wildfire that harms riparian function. Meadow thinning treatments are planned 

in upland meadows and terraces adjacent to riparian areas. These treatments are designed to thin 

out conifers that are encroaching upon riparian systems and not for commercial purposes. 

Limited equipment would be used in these area with no conifers removed that provide for bank 

stability. Piles would be located outside floodplains. 
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Heavy equipment used in vegetation treatments is not expected to be used near riparian areas or 

within wetlands or wet meadows. There may be some temporary increases in runoff and soil 

movement related to ground cover and soil disturbance from mechanical thinning and skidding 

operations, as well as from the use of existing roads by logging equipment. Skid trails, staging 

areas and landing sites will be scarified and seeded as necessary to reestablish vegetative cover. 

This should reduce the potential for erosion and sedimentation that could originate from these 

areas and move downstream. Buffer strips have been incorporated into the Best Management 

Practices and design features to provide protection of waterways and riparian areas. Mowing of 

rabbitbrush under this alternative is not expected to have any adverse impacts to riparian or 

wetland resources. These activities are not proposed near these sensitive resources. With proper 

implementation of best management practices and design features, riparian and wetland 

resources would be protected from both short-term and long-term negative impacts.

It is anticipated that current conditions of riparian areas, wetlands, and wet meadows would be 

maintained with implementation of mechanical vegetation treatment, with a lowered risk for 

long-term negative impacts as a result of uncharacteristic wildfire and encroachment of tree 

species.

Prescribed Fire Treatments 

Prescribed fire treatments would result in effects similar to those noted in the “Mechanical 

Vegetation Treatments” section. Heavy fuel loading would be reduced in the understory, 

lowering the risk of uncharacteristic wildfire, and reducing the possibility for high soil burn 

severity. 

Best management practices and design features restrict the location of pile sites from waterways, 

riparian areas, and wetlands. Pile burning would not impact these resources. This treatment 

would not impact riparian areas or wet meadows. Buffer distances are designed for landings and 

staging areas to provide adequate distance for ash and mobilized sediment to drop out prior to 

reaching stream courses. 

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources in these locations. There are 

not expected to be negative impacts to downstream riparian resources, with a lessening of risk to 

high-severity, uncharacteristic wildfire in these areas. 

The prescribed fire activities would help reduce fuel loading in the understory, thus reducing the 

risk from uncharacteristic wildfire, providing for long-term protection for riparian and wetland 

resources. 

Stream, Riparian, and Erosion Control Treatments 

Under all action alternatives, a suite of restoration activities to improve water quality and 

quantity are planned in streams, riparian areas, and uplands to improve degraded conditions. The 

following would be the effects to riparian areas, wetlands, and wet meadows with 

implementation of proposed projects: 

• Upgrading, relocating, or hardening of existing stream crossings – Implementation of 

these action will provide positive benefits to riparian areas, wetlands, and wet meadows. 

Similar to positive benefit to water quality and quantity, hardening of crossings will help to 

alleviate impacts to native vegetation growing on the approaches. Less sediment and 
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gravels will be transported downstream of the crossing, which impacts vigor of different 

types of vegetation. While riparian woody plants may prefer coarser substrate, herbaceous 

vegetation may not. Several of the proposed crossings include small bridge designs and 

French drains that will enhance wet meadow habitats or avoid them altogether. This 

activity poses a positive benefit to riparian areas, wetlands, and wet meadows. 

• Removal of encroaching conifers in riparian areas and upland wet meadows – Removal of 

conifers that are currently encroaching into floodplains, riparian areas, and fringes of the 

wet meadows would free up available water, nutrients, and energy that could be used by 

riparian and wetland species. This would also lower the risk these sites currently have for 

ecological conversion to upland vegetation species, which would reduce wetland and 

riparian habitat within the project area. This activity protects riparian areas, wetlands, and 

wet meadows. 

• Construction of ungulate exclosures in riparian areas and degraded uplands – This activity 

will have positive benefits to riparian areas and wetland/wet meadows in the degraded 

riparian areas and upland sites that have been identified for restoration needs. Effects are 

similar to those under “Water Quality and Quantity”. The areas proposed for exclusion 

have a suite of additional restoration activities (riparian planting, stream stabilization, 

seeding) that will be implemented to improve resource conditions. By alleviated grazing 

pressure within this areas, it will provide a needed period of rest and recovery for riparian 

woody and herbaceous vegetation to grow, upland vegetation to recover, and stream banks 

to stabilize. These restoration efforts, combined, will aid in reversing erosion, lack of 

ground cover, and destabilized channels. Riparian areas, wetlands, and wet meadows will 

benefit over the long term. It will likely take several years for these improvements to be 

realized. 

• Construction of stream and wet meadow stabilization structures – This activity would 

allow stabilization techniques to be employed on several degraded stream reaches and 

meadows throughout the project area. These activities will aid in restoring stream banks, 

and channel shape, form, and function back to proper functioning conditions. Sediment 

input from eroding banks would be reduced, channels would narrow, and flows would be 

reduced, allowing for an increase in productivity and vigor of riparian and wetland 

vegetation. 

• Riparian tree planting – Riparian tree planting is proposed in locations where there is 

currently lack of riparian woody vegetation and streambank instability, leading to higher 

water temperatures and movement of sediment into the stream. By restoring riparian 

vegetation to these areas, the increased shade would help to reduce stream temperatures. 

The increased deep root system provided by these types of plants would aid in bank 

stability, helping to improve channel shape, form, and function, thus providing for stream 

stabilization and moving these systems in an upward trend and closer to proper 

functioning condition. 

• Reconstruction of Head of Ditch irrigation diversion – A permanent diversion is planned at 

the current location for Head of Ditch to eliminate the need for repeated implementation of 

a native soil push-up dam that diverts all of the water from the San Francisco River (spring 

to fall). The new facility design would minimize activity in the active channel once it is 

constructed, thus reducing impacts to riparian vegetation in the immediate vicinity. The 

current diversion takes all of the stream flow for much of the summer months, with 

exception of flooding events. The new diversion would provide an opportunity for water 
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right owners to leave their share of water in the river if they do not need it for irrigation. 

While this may not occur immediately, the new design provides the opportunity for some 

water to remain in the channel year long, thereby increasing water availability for riparian 

species yearlong. 

• Construction of all-terrain vehicle barriers to protect wet meadows – This activity is 

planned to deter motorized traffic into sensitive resource locations where the road is 

currently closed but unauthorized traffic persists. The barriers would help protect wet 

meadows which are currently receiving subject to rutting and disturbance of associated 

hydric soils. Wet meadow conditions would improve fairly quickly with elimination of 

unauthorized use, as compaction and rutting would be eliminated, infiltration and 

percolation would be improved, and movement of sediment would be reduced. This 

activity would move these systems quickly in an upward trend towards proper functioning 

condition. 

• Maintenance and implementation of new erosion stabilization structures – There are 

currently more than 160 erosion control structures that were constructed within the Luna 

Restoration Project area over the last several decades. Many of these are in upland areas, 

away from riparian areas, wetlands, and wet meadows, however there are several located 

in upland wet meadows. Maintenance, reconstruction, or both of these upland wet meadow 

structures would ensure the longevity of the structures and lower the risk of them 

breaching which could result in headcutting and subsequent dewatering of the meadow. 

This activity will be a benefit to these fragile ecosystems and maintain functional 

conditions, improve functional conditions, or both. 

• Native grass seeding in degraded uplands – These activities are planned primarily in 

uplands that would be adjacent to riparian systems. Improvement in these upland areas 

would benefit the downstream riparian areas by restoring herbaceous vegetation which 

will slow down overland flows and filter water. A reduction in flow velocities and 

dropping out of sediment prior to reaching the channels will aid in improving riparian 

condition and moving these areas in an upward trend towards proper functioning 

condition. 

• Water quality improvements in campgrounds – Existing road and campsite drainage that 

leads directly to the adjacent waterways of San Francisco River and Trout Creek would be 

improved, thus reducing or eliminating a direct input of sediment. This would also provide 

a buffer for riparian vegetation from excessive flows off roads and campsites, thus 

providing riparian protection. This activity would provide improvement to riparian 

conditions. 

Range Management Treatments 

The action alternatives propose 14 additional watering sites within the project area. While this 

activity is expected to improve livestock distribution in allotments within the project areas, there 

are not expected to be any impacts to riparian areas, wetlands, and wet meadows. New water 

sites are planned in upland locations and no streamside watering sites are being eliminated. 

Motorized Transportation Treatments 

Road improvements, reroutes, and decommissioning activities proposed under the action 

alternatives are designed to protect and improve riparian areas, wetlands, and wet meadows. 

Road improvements are planned in areas where current routes are leading to erosion and 
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contributing to movement of sediment into the stream system. Reroutes have been planned in 

areas where the current route crosses live streams and/or riparian areas. Reroutes would be in 

more stable locations with less water and soil resource impacts. Decommissioning is planned 

where currently closed routes are no longer necessary for forest management activities. 

Currently, these closed routes continue to provide a pathway for sediment delivery into the 

stream system and remain a source of ongoing erosion. Local traffic continues to use these 

closed routes as they lack an effective closure barrier. Decommissioning would provide the 

necessary barrier and serve as a deterrent for continued use, thus allowing the roaded area to 

return to its natural state. In these areas, there would be an increase in vegetation on these former 

routes, an increase in infiltration rates, and increase in soil stability, and a reduction in overland 

flow and soil loss. Soil conditions that are currently unsatisfactory within the road bed would 

improve, with upward trends over the long term. 

There are several other motorized transportation treatments, for which the following direct and 

indirect effects would be realized for riparian areas, wetlands, and wet meadows. 

• Construction of 3-5 miles of temporary roads which would be obliterated following 

vegetation treatments – these motorized treatments are not planned to occur in riparian 

areas, wetlands, and wet meadows. Best management practices and design features are 

incorporated into the project that would prevent indirect impacts from these temporary 

roads from impacting downstream riparian areas and wetlands. There would be no change 

to riparian functional condition as a result of this treatment. 

• Approximately 4.2 miles of trail head would be left on roads that are scheduled for 

decommissioning, with a trail tread of approximately 3 feet in width remaining– this 

motorized treatment would not have detrimental impacts to riparian areas, and wetland/wet 

meadows. Decommissioning of a majority of the road bed would lessen direct connections 

to riparian areas. The remaining tread would be designed with best management practices

and design features that would mitigate water flow from the trail. This treatment is not 

anticipated to have any measurable impact to the functionality of riparian areas, wetlands, 

or wet meadows. 

• Reopening of 13.8 miles of motorized routes to all vehicle types – this motorized 

treatment would result in little negative impact to riparian resources. One of the routes 

proposed crosses a small wetland area of Dillman Creek. This crossing is proposed for 

hardening, with uninhibited water passage through the crossing. These two treatments, 

implemented in tandem will minimize negative impacts to this riparian area. The crossing 

is currently receiving unauthorized use so this treatment will be an improvement over 

alternative A. The other routes included in the 13.8 miles do not cross riparian areas, 

wetlands, or wet meadows, thus would have no negative impacts to this resource area.

• Addition of 4.2 miles of user-created routes to the motorized system – The user-created 

routes proposed for addition in this alternative were all evaluated in the field by Gila 

National Forest watershed personnel for resource concerns. None of these routes cross 

riparian areas, wetlands, or wet meadows. The addition of these miles is not anticipated to 

impact these resources. 

• Reopen then close and/or decommission 34.5 miles of currently closed routes for 

vegetation and/or prescribe fire treatments (22.5 miles would be reclosed and 12 miles 

would be decommissioned) – this motorized treatment may have short-term minor impacts 

to riparian resources, where the current road bed and riparian resources coincide. 
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Reopening a currently closed route would subject it to renewed compaction and removal 

of any vegetation gains it might have seen during its closure, thus increasing flow 

velocities down the roadbed and possibly into downstream waterways. Follow-up closure 

would negate these impacts, however it may be a few years before this occurs. The 

roadbed scar would continue to result in some level of disturbance in the long term. Roads 

that would be decommissioned following treatments would see more benefit to the soil 

resource as they would be returned to their natural state, with an increase in vegetation, 

increase in infiltration, and some restoration of soil fertility and productivity over the long 

term. While long-term impacts are not expected with this treatment, until the roads are 

decommissioned, benefits to riparian areas, wetlands and wet meadows would not occur. 

• Construction of 0.3 miles of all-terrain vehicle routes – this motorized treatment would 

have positive impacts to riparian resources. The locations of these miles are in Dillman 

Creek where the current route path crosses several times. The reroute will avoid several 

stream crossings, thus eliminating direct effects to the riparian resource. A reduction in 

stream crossings will help improve riparian resource functionality. The new reroute is 

being constructed to avoid riparian areas, stream crossings, and perennial water. 

• Reopening of 3.5 miles of previously closed routes for administrative use (Tucson Electric 

Power line access) – this motorized treatment is not anticipated to have negative impacts 

to riparian areas, wetlands, and wet meadows as the locations do not coincide. 

Alternative C - Herbicide Utilization

Mechanical Vegetation Treatments

This alternative’s vegetation treatments are common to all action alternatives with the exception 

applying herbicide treatments on 30 acres of meadow; appropriate areas of 20,283 acres of 

rabbitbrush; and up to 8,000 acres of juniper. 

Herbicide use is proposed in upland rangelands and woodlands. Riparian areas, wetlands and wet 

meadow areas are not expected to be impacted by use of herbicide as their locations will not 

coincide. Application of best management practices will avoid negative effects to waterways. 

These include mitigation measures such as buffering waterways, avoiding precipitation events,

limit use to low winds, and identification and avoidance of any drinking water supplies and 

sensitive aquatic species locations. No negative impacts to riparian areas and wetlands/wet 

meadows are anticipated with implementation of alternative C. 

Alternative D 

Motorized Transportation Treatments 

This alternative’s motorized transportation treatments are similar to all action alternatives with 

the exception of the following treatments: 

• There would be no re-opening of 13.6 miles of motorized routes under this alternative. 

Only 0.2 miles would be reopened. Instead, these 13.6 miles would be added to road 

decommissioning miles, bringing the total decommissioned miles to approximately 130 in 

alternative D. Approximately 118 miles would be immediately available for 

decommissioning, while 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. There would be an increased benefit, although 

minor, to the riparian areas, wetlands, and wet meadows under alternative D, compared to 
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alternatives B and C. Although almost 14 more miles of road would be returned to a 

natural state, very few of these miles currently are within or adjacent to riparian areas or 

wet meadows. 

• There would be no addition of 4.2 miles of user-created routes to the motorized system. 

There would no long-term impacts to the riparian areas, wetlands, and wet meadows from 

continued use of these routes. Currently, all user-created routes are planned to be returned 

to their natural state. Some short-term impacts may occur during obliteration of these 

routes where they are within or adjacent to riparian areas or wet meadows. Alternative D 

has more positive benefits to these resources under this activity, then do alternatives B and 

C; however, only approximately 1⁄4 mile of these proposed additions are within a riparian 

area in Dillman Creek. 

• There would be no construction of 0.3 miles of all-terrain vehicle routes. There would be 

continued negative impacts to the riparian areas, wetlands, and wet meadows crossing 

locations of Dillman Creek. The proposed reroute is outside of drainages with no impacts 

to riparian areas, wetlands, and wet meadows. Leaving this route in the same place would 

continue to provide long-term negative impacts to these resources. 

Water Quality and Quantity 

Alternative A 

Mechanical Vegetation Treatments

This alternative would not provide for any mechanical vegetation treatments to reduce heavy 

fuel loadings and promote conditions that reduce risk of uncharacteristic high-intensity wildfire. 

High soil burn severities are often a result of uncharacteristic wildfire, leading to severe negative 

effects to water quality and quantity. 

Post fire effects would result in increased runoff volumes and velocities in streams leading to 

damaged streambanks and riparian areas, and pose risks to downstream values such as inchannel structures and infrastructure adjacent to and/or within floodplains. Several streams on 

the western boundary of the Luna Restoration Project area are currently experiencing increased 

water flows and sediment delivery from the effects of the 2011 Wallow Fire. The increased flows 

are causing both vertical and lateral stream instabilities, which contribute negatively to water 

quality, in particular, temperature and turbidity. Stream flows are not able to dissipate effectively, 

thus runoff rates and velocities are high. Stabilizing riparian vegetation has been scoured away 

causing detachment and movement of channel and bank material. 

In addition, within the project area, Centerfire Creek and the San Francisco River do not meet 

New Mexico State water quality standards. Any future high-intensity wildfires would hamper 

any water quality improvement to these streams. 

The existing condition of water quality and quantity would continue and potentially decline 

under the no-action alternative. In areas where overstory densities are high, little long-term 

improvement in hydrologic flow regime will occur without mechanical treatment or other 

vegetation treatment methods. Wildfires in untreated areas pose a greater risk of negative 

impacts to water quality, channel stability, and changes to hydrologic regimes than wildfire 

occurring after implementation of vegetation treatments in alternatives B, C, and D. 
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Prescribed Fire Treatments

Lack of prescribed fire treatments would result in effects similar to those noted above under 

“Mechanical Vegetation Treatments”. Not implementing prescribed fire treatments will continue 

to allow heavy fuel loading in the understory. As understory fuels build up and tree density and 

cover increases, the risk of higher intensity, uncharacteristic wildfire increases as well as the 

potential for high soil burn severity. The resultant loss of canopy cover, ground cover, and 

organic debris on the soil surface, together with the possible occurrence of hydrophobic soil 

layers in these areas, would likely lead to considerable increases in soil erosion, storm runoff 

response, and sediment movement into waterways. This would result in a greater risk of 

negative impacts to water quality under alternative A compared to all action alternatives, with 

potential for destabilized hydrologic regime.

Stream, Riparian, and Erosion Control Treatments 

Restoration activities to address ongoing negative impacts to streams and riparian areas would 

not be implemented under alternative A. 

Motorized Transportation Treatments 

This alternative results in the least amount of new disturbance related to motorized transportation 

as equipment would not be used for road-related ground-disturbing activities. However, the 

absence of road improvements, road decommissioning, or reroutes under this alternative would 

continue to allow negative impacts to water quality and water quantity to occur in many 

locations across the project area over the long term 

The lack of road decommissioning would continue to allow currently closed routes to remain on 

the landscape. Current road closures do not immediately eliminate hydrologic impacts, 

especially when unauthorized use continues to occur. Rather, the disturbed surface takes years to 

stabilize, which depends on the level of success in the closure, underlying soils, vegetative 

regrowth, and other factors. Roads, including those behind gates and dropped from inventories, 

continue to produce sediment until they are totally revegetated. The primary effect to water 

quality related to roads is sedimentation originating from road erosion. Roads are a major source 

of sediment and contribute more off-site sediment than any other land management activity 

(Gibbons and Salo 1973; Meehan 1991). Numerous researchers have established that roads are a 

major source of sediment delivered to streams in otherwise relatively undisturbed watersheds, 

such as forests and rangelands. Because routes intercept and concentrate water the closer they 

are to a drainage channel, the quicker water is delivered to the stream channel, potentially 

increasing runoff response. Roads can also disrupt a watershed’s natural hydrologic flow by 

capturing surface and subsurface runoff on hillslopes. Unmitigated, the captured runoff can be 

delivered to stream systems more rapidly, at higher rates of flow, and can impact the timing and 

magnitude of natural stream flows. Stream channels will respond to increases in flow rates by 

widening or deepening in order to carry these greater flow rates. Roads directly alter natural 

sediment and hydrologic regimes by changing streamflow patterns and amounts, sediment 

loading, transport, and deposition, channel morphology and stability, water quality and riparian 

conditions within a watershed (Gibbons and Salo 1973, Dunne and Leopold 1978, Copstead et 

al. 1997). This can lead to higher peak flows, which may then lead to a higher risk of channel 

erosion. 

The closed routes that are proposed for decommissioning in all action alternatives would 

continue to discharge runoff and sediment to adjacent waterways in this alternative, in particular 
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where the road bed is within 300 feet of a stream, or has inadequate drainage features, or is 

hydrologically connected to the stream network. Road densities would not be decreased thereby 

reducing potential for improved hydrologic flow regimes. This alternative provides the least 

benefit to water quality and quantity than any of the action alternatives due to lack of 

decommissioning alone.

Effects Common to Alternatives B, C, and D

Mechanical Vegetation Treatments 

For all action alternatives, where water quality and quantity are currently meeting State water 

quality standards and display a stable flow regime, these indicators would continue to be 

maintained or improved with the proper implementation of best management practices and 

design features.

Similar to the “Soils” discussion for all action alternatives, areas across the project area with 

dense canopies and heavy coarse woody debris loading in the understory would see enhancement 

from vegetation treatments. Vegetative ground cover would be reduced, spatially rearranged, or 

both by proposed vegetation treatments. Restoration thinning would reduce the risk of highseverity wildfire that can have severe impacts to water quality as described in alternative A. 

Heavy equipment used in vegetation treatments will cause varying degrees of soil compaction 

which can temporarily increase water runoff and delay, reduce, or both the establishment and 

growth of desired herbaceous vegetation. Short-term increases in soil loss related to ground 

cover and soil disturbance are expected from mechanical thinning and skidding operations, as 

well as from the use of existing roads by logging equipment, which can pose a threat to water 

quality. Project-specific best management practices and design features are designed to mitigate 

negative impacts from these activities. There is not expected to be long-term negative impacts to 

water quality or quantity as a result of mechanized vegetation treatments.

Mowing of rabbitbrush is not expected to have any adverse impacts to water quality and 

quantity. This activity will be done with rubber-tired equipment, with organic matter generated 

from mowing left largely in place, serving as organic matter and mulch across the land surface. 

These areas of treatment are fairly flat, thus there is not expected to be increases in runoff 

generated from these treatments. 

It is anticipated that overall water quality condition and trends and hydrologic regimes across the 

project area will be maintained and the risk lowered for long-term negative impacts as a result of 

uncharacteristic wildfire.

Prescribed Fire Treatments

Prescribed fire treatments would result in effects similar to those noted above under “Mechanical 

Vegetation Treatments”. Heavy fuel loading would be reduced in the understory, lowering the 

risk of uncharacteristic wildfire, and reducing the possibility for high soil burn severity. 

Prescribed fire would initially reduce the level of organic debris and mobilize some sediment and 

nutrients. However careful attention to burning conditions during a prescribed fire is designed to 

limit the potential of short-term loss of soils and nutrients. 

Pile burning will likely result in localized, negative effects to soil resources as described under 

the “Soils” section. Some effects of pile burning could also cause a localized decrease in 
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infiltration and an increase in runoff. Buffer distances are designed for landings and staging areas 

to provide adequate distance for ash and mobilized sediment to drop out prior to reaching stream 

courses. 

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources in these locations. There are 

not expected to be negative impacts to water quality and quantity, with a lessening of risk to 

high-severity, uncharacteristic wildfire in these areas. 

The prescribed fire activities would help reduce fuel loading in the understory, thus reducing the 

risk from uncharacteristic wildfire, providing for long-term protection for water quality and 

hydrologic regimes. 

Stream, Riparian, and Erosion Control Treatments 

A suite of restoration activities to improve water quality and quantity are planned to improve 

currently degraded conditions in streams, riparian areas, and uplands. The following would be 

the effects to water quality and quantity with implementation of proposed projects: 

• Upgrading, relocating, or hardening existing stream crossings – Implementation of these 

actions will provide positive benefits to water quality and quantity. Hardening of crossing 

will help to alleviate the short-term negative impacts of vehicle tires disturbing and 

mobilizing stream bottom sediments. Improvement at these crossings will also aid 

hindering the direct flow path of water into the stream by either filtering out some of the 

sediment or relocating the crossing to a more stable location. Crossings will not be 

eliminated thus there will still be a hydrologic connection of water and sediment into the 

stream systems, at a reduced rate. This will be an improvement to water quality and water 

quantity from alternative A. 

• Removal of encroaching conifers in riparian areas and upland wet meadows – Removal of 

conifers that are currently encroaching into floodplains, riparian areas, and fringes of the 

wet meadows would free up available water, nutrients, and energy that could be used by 

riparian and wetland species. This would also lower the risk these sites currently have for 

ecological conversion to upland vegetation species, which would reduce wetland and 

riparian habitat within the project area. This activity protects hydrologic regimes in these 

areas.

• Construction of ungulate exclosures in riparian areas and degraded uplands – This activity 

will be a positive benefit to water quality and quantity in the degraded riparian areas and 

upland sites that have been identified for restoration needs. The areas proposed for 

exclusion have a suite of additional restoration activities (riparian planting, stream 

stabilization, seeding) that will be implemented to improve resource conditions. By 

alleviating grazing pressure within these areas, it would provide a needed period of rest 

and recovery for riparian woody and herbaceous vegetation to grow, upland vegetation to 

recover, and stream banks to stabilize. All of these restoration efforts, combined, will aid 

in reversing erosion, lack of ground cover, and destabilized channels. Water quality and 

quantity will benefit over the long term. Streams currently not meeting New Mexico’s 

State water quality standards would improve over the long-term, in particular where the 

probably causes for listing have been identified as sedimentation, siltation, and 

temperature. Increased vegetation within these areas will also reduce runoff rates, allowing 
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more subsurface water to remain in place, improving water quantity and stabilizing 

hydrologic regimes. It will likely take several years for these improvements to be realized. 

• Construction of stream and wet meadow stabilization structures – This activity would 

allow stabilization techniques to be employed on several degraded stream reaches and 

meadows throughout the project area. These activities will aid in restoring stream banks, 

and channel shape, form, and function back to proper functioning conditions. Sediment 

input from eroding banks would be reduced, channels would narrow, and flows would be 

reduced, allowing for improvement in water quality (decreased temperature and 

sedimentation) and water quantity (reduction in flow velocities). 

• Riparian tree planting – Riparian tree planting is proposed in locations where there is 

currently lack of riparian woody vegetation and streambank instability, leading to higher 

water temperatures and movement of sediment into the stream. By restoring riparian 

vegetation to these areas, the increased shade would help to reduce stream temperatures. 

The increased deep root system provided by these types of plants would aid in bank 

stability, helping to improve channel shape, form, and function, thus providing for stream 

stabilization. Water quality and quantity under this alternative would improve with this 

activity. 

• Reconstruction of Head of Ditch irrigation diversion – A permanent diversion is planned at 

the current location for Head of Ditch to eliminate the need for repeated implementation of 

a native soil push-up dam that diverts all of the water from the San Francisco River (spring 

to fall). The new facility is planned to minimize maintenance, provide an easy way to 

switch flows from the main channel to the diversion, minimize effects on the stream and 

aquatic biota, and to eliminate water ponding behind the facility. The current diversion 

takes all of the stream flow for much of the summer months, with exception of flooding 

events. The new diversion would provide an opportunity for water right owners to leave 

their share of water in the river if they do not need it for irrigation. While this may not 

occur immediately, the new design provides the opportunity for some water to remain in 

the channel year long, thereby improving water quality and water quantity. In addition, the 

improvement to the diversion structure will improve stream channel geometry and reduce 

negative impacts to the site caused by repeated rebuilding of the push-up dam. 

• Construction of all-terrain vehicle barriers to protect wet meadows – This activity is 

planned to deter motorized traffic into sensitive resource locations where the road is 

currently closed but unauthorized traffic persists. The barriers would help protect wet 

meadows which are currently receiving loss of soil productivity and soil compaction due 

to this unauthorized use. Water quality and water quantity would benefit from these 

barriers, as compaction and rutting would be eliminated, infiltration and percolation would 

be improved, and movement of sediment would be reduced. This ongoing threat to the 

identified wet meadows would be removed. 

• Maintenance and implementation of new erosion stabilization structures – There are 

currently more than 160 erosion control structures that were constructed within the Luna 

Restoration Project area over the last several decades. Lack of maintenance on these 

structures has led them to reach storage capacity, breach, new headcuts and gullies, or a 

combination of these things. Maintenance of existing structures and construction of new 

structures will reduce erosion, control headcutting and gullying, and stabilize uplands 

where lack of stability and excessive flows have led to severe erosion issues. This activity 
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will reduce sedimentation and siltation downstream into waterways and provide for 

favorable conditions of flow, thereby improving both water quality and water quantity 

• Native grass seeding in degraded uplands – Negative impacts to water quality and quantity 

in currently degraded uplands would be reversed if herbaceous ground cover increases on 

these sites. Herbaceous cover would slow down overland flow, thereby improving 

infiltration and reducing erosive processes. Some of these sites are severely denuded of 

vegetation so this would be a slow process, with improvement over the long term to water 

quality and quantity. 

• Water quality improvements in campgrounds – Existing road and campsite drainage that 

currently leads directly to the adjacent waterways of San Francisco River and Trout Creek, 

would be improved, thus reducing or eliminating a direct input of sediment. This 

interrupted connection to the drainage would slow down storm-generated runoff to these 

streams, providing for a stable hydrologic flow regime and reducing the opportunity for 

runoff related erosion. This activity would provide improvement to water quality and 

hydrologic regimes under this alternative. 

Range Management Treatments 

There are 14 additional watering sites proposed within the project area. In watering locations 

where the water source is spring fed, less pressure on these springs may occur. The proposed 

treatments, however, do not provide fencing any of these areas, but rather provide alternate water 

sources to reduce pressure. This may relieve some water quality and quantity impacts; however, 

they may not be measurable. Effects to water quality and quantity are expected to improve 

slightly or not at all under all action alternatives. 

Motorized Transportation Treatments 

Road improvements, reroutes, and decommissioning activities are designed to improve water 

quality and quantity over the long term. Road improvements are planned in areas where current 

routes are leading to erosion and contributing to movement of sediment into the stream system. 

Reroutes have been planned in areas where the current route crosses live streams, riparian areas, 

or both. Reroutes would be in more stable locations with less water and soil resource impacts. 

Approximately 116 miles of decommissioning is planned where currently closed routes are no 

longer necessary for forest management activities, with 104 miles being immediately available 

for decommissioning. The additional 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. Currently, these closed routes continue to provide a 

pathway for sediment delivery into the stream system and remain a source of ongoing erosion. 

Local traffic continues to use these closed routes as they lack an effective closure barrier. 

Decommissioning would provide the necessary barrier and serve as a deterrent for continued use, 

thus allowing the roaded area to return to its natural state. Proper road obliteration or 

decommissioning, which returns the road bed and fill slope to the contours of the land and 

replaces culverts with natural stream channels, offers the best opportunity to restore health to 

heavily roaded watersheds and to aquatic habitat downstream. In these areas, there would be an 

increase in vegetation on these former routes, an increase in infiltration rates, and increase in soil 

stability, and a reduction in overland flow and soil loss. Long-term sediment reduction would 

benefit from these activities. Sediment production from roads diminishes over time after proper 

closure and non-use. Water quality would see improvements and hydrologic regimes would no 

longer be influenced by water flow from the road beds’ unnatural flow paths. 
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There are several other motorized transportation treatments, for which the following direct and 

indirect effects would be realized: 

• Construction of 3 to 5 miles of temporary roads which would be obliterated following 

vegetation treatments – this motorized treatment would have negative short-term impacts 

to water quality and water quantity with removal of herbaceous vegetation and compaction 

during use. These temporary roads can provide a conduit for surface flows to be directed 

down the road bed rather than dissipated across the land surface. Subsequent obliteration 

should return the temporary road scar to its natural state within a short period of time with 

proper implementation of best management practices and design features. 

• Approximately 4.2 miles of trail head would be left on roads that are scheduled for 

decommissioning, with a trail tread of approximately 3 feet in width remaining– this 

motorized treatment would have benefits to water quality and quantity with 

decommissioning of a majority of the road bed. Some impacts to water quality and 

quantity may occur as flows may be directed down the remaining trail bed. However, 

proper implementation of trail tread and drainage should alleviate these impacts. There 

would be minimal long-term disturbance related to the trail tread that may have possible 

connectivity to waterways.

• Reopening of 13. 8 miles of motorized routes to all vehicle types – this motorized 

treatment would result in some long-term negative impacts to water quality and quantity, 

somewhat similar to what is occurring under alternative A. These closed routes are not 

currently decommissioned, with only a signed closure in place. Unauthorized use 

continues on closed routes, albeit less than an open route receives. The current condition 

of these routes still provides a conduit for surface water to travel down these routes into 

waterways. Field review in 2015 determined that most of these routes were in upland 

areas, with little impacts to water quality and quantity. One route, however, does cross 

Dillman Creek in a perennial location. This crossing is proposed for hardening under 

alternatives B and C, which would mitigate concerns to water quality and quantity. Soil 

compaction and a lack of vegetation would still be present on all of these routes. None of 

these routes would realize the improvements to water quality and quantity that 

decommissioning would offer. Compaction, lack of infiltration, loss of soil productivity, 

and lack of vegetative ground cover would persist in the long term.

• Addition of 4.2 miles of user-created routes to the motorized system – this motorized 

treatment would result in some long-term impacts to water quality and water quantity. A 

field review of these roads determined that little water resource issues were currently 

occurring on these routes. They were located in upland locations, and would have effects 

similar to those in the above-mentioned reopening of motorized routes. 

• Reopen then close and/or decommission 34.5 miles of currently closed routes for 

vegetation and/or prescribe fire treatments (22.5 miles would be reclosed and 12 miles 

would be decommissioned) – this motorized treatment would have some short-term and 

long-term negative impacts to water quality and quantity. Reopening a currently closed 

route would subject it to renewed compaction and removal of any vegetation gains it might 

have seen during its closure. Follow-up closure would negate these impacts however, it 

may be a few years before this occurs. The roadbed scar would continue to result in some 

level of water transport down its surface over the long-term if it is not decommissioned. 

Roads that would be decommissioned following treatments would see long-term benefits
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to water quality and quantity as they would be returned to their natural state, with an 

increase in vegetation, increase in infiltration, and disconnected paths to waterways over 

the long-term. Unauthorized use remains a concern on closed roads that would not be 

decommissioned. 

• Construction of 0.3 miles of all-terrain vehicle routes – this motorized treatment would 

have positive impacts to water quality and quantity. The new route is being constructed to 

avoid riparian areas, stream crossings, and perennial water of Dillman Creek. Local riding 

groups have expressed support in using an alternative route if available rather than 

continuing unauthorized use of Dillman Creek. The reroute provides alternate access to 

desirable locations without negative resource effects to the stream.

• Reopening of 3.5 miles of previously closed routes for administrative use (Tucson Electric 

Power line access) – this motorized treatment would have minor negative impacts to water 

quality and water quantity over the long-term as these roads would not be decommissioned 

in the future. Compaction, lack of vegetation, reduced infiltration, and loss of soil 

productivity would persist on these routes. 

Alternative C – Herbicide Utilization

Mechanical Vegetation Treatments

This alternative’s vegetation treatments are common to all action alternatives with the exception 

applying herbicide treatments on 30 acres of meadow; appropriate areas of 20,283 acres of 

rabbitbrush; and up to 8,000 acres of juniper. 

Herbicide use is proposed in upland rangelands and woodlands. Best management practices and 

design features have been incorporated into the Luna Restoration Project to protect water quality. 

These include mitigation measures such as buffering waterways, avoiding precipitation events, 

limit use to low winds, and identification and avoidance of any drinking water supplies and 

sensitive aquatic species locations. No negative impacts to water quality are anticipated with 

implementation of alternative C. 

No changes are anticipated to water quantity with the implementation of herbicide. Water use by 

rabbitbrush and juniper would be replaced with water use by herbaceous plants, if the herbicide 

treatment is effective. There would be no measurable change to water quantity; hydrologic 

regimes would remain unchanged. 

Alternative D 

Motorized Transportation Treatments 

This alternative’s motorized transportation treatments are similar all action alternatives with the 

exception of the following treatments:

• There would be no reopening of 13.6 miles of motorized routes to all vehicle types under 

this alternative (0.2 miles would be reopened). Instead, these 13.6 miles would be added to 

road decommissioning miles, bringing the total decommissioned miles to approximately 

130 in alternative D. One hundred and eighteen miles would be immediately available for 

decommissioning, while 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. There would be an increased benefit to the water 
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quality and quantity under alternative D, compared to alternatives B and C, with almost 14 

more miles of road returned to a natural state. 

• There would be no addition of 4.2 miles of user-created routes to the motorized system – 

There would be no possible long-term impacts to water quality and quantity from 

continued use of these routes. Impacts currently are minor on these routes, with the 

exception of one crossing of Dillman Creek. This route would be obliterated as all usercreated routes are planned to be returned to their natural state. Alternative D has more 

positive benefits to water quality and quantity under this activity, then do alternatives B 

and C. 

• There would be no construction of 0.3 miles of all-terrain vehicle routes – There would be 

continued negative impacts to water quality and water quantity at the crossing locations in 

Dillman Creek, similar to alternative A. The Dillman Creek route is currently closed 

however, unauthorized use continues to occur. 

Watershed Cumulative Effects

Watershed cumulative effects analyses are focused on the 6th code watersheds of Canovas Creek 

– Coyote Creek, Trout Creek, Stone Creek – San Francisco River, Dry Blue Creek, Spur Draw, 

SA Creek, Headwaters Centerfire Creek, Outlet Centerfire Creek, Big Canyon – San Francisco 

River, Hay Vega, and Cow Springs Draw as more than 2 percent of the project area was within 

these watersheds. 

The existing conditions related to water quality, water quantity, aquatic habitats and biota, 

riparian areas, roads and trails, soils, range vegetation, forest cover, forest health, fire regime 

condition class, and invasive species within the Luna Restoration Project area contribute, in 

whole or part, to cumulative impacts on watershed condition. In 2015, 6th code watershed 

condition classifications incorporated information related to twelve watershed indicators. This 

recent assessment provides a “baseline” at which to assess all of the action alternatives versus 

the alternative A. 

Alternative A

Under alternative A, there would be no implementation of mechanical vegetation treatments; 

prescribed fire treatments; stream, riparian, and erosion control treatments; range management 

treatments; or motorized transportation treatments. Current watershed condition classifications 

(table 55) would remain the same, with no improvements to any of the watershed indicators. 

Watersheds with high concentrations of fuel loading would remain at risk of negative impacts to 

watershed health if uncharacteristic wildfire occurs. 

Implementation of alternative A would result in no change in cumulative impacts to watershed, 

soil and aquatic condition at the 6th code level, and thus no change to watershed condition 

classification of any watershed. 

Alternative B 

Alternative B proposes implementation of mechanical vegetation treatments; prescribed fire 

treatments; stream, riparian, and erosion control treatments; range management treatments; or 

motorized transportation treatments. This alternative addresses forest and watershed health issues 

at a landscape scale. These activities do result in varying amounts of ground disturbance. 

Impacts related to mechanical vegetation and prescribed fire treatments, including construction 
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of 3 to 5 miles of temporary roads and temporary reopening and then closing or 

decommissioning of 34.5 miles of roads and skid trails are expected to be short-lived, with 

implementation of recommended best management practices and design features, and would not 

result in negative cumulative impacts. Localized short-term impacts to water quality and soils 

would occur during implementation of stream, wetland, and upland stabilization projects, as well 

as disturbance to soils during construction of range improvements. These short-term impacts 

would result in long-term benefits by stabilizing these degraded systems, thus resulting in 

positive cumulative impacts. The addition of 0.3 miles of all-terrain vehicle route would have 

long-term impacts to the soil resource in its location, however the long-term positive cumulative 

impacts the relocation of routes provides to stream systems would outweigh the localized 

negative soil impacts. The addition of 4.2 miles of user-created routes, reopening of 3.5 miles of 

closed routes for administrative use, and reopening of approximately of 13.8 miles of currently 

closed routes would continue long-term impacts related to these road beds that are currently in 

place. While these road activities would provide no positive cumulative effects to watershed 

resources, there would be no additional negative impacts as the disturbance currently exists. 

Overall, implementation of alternative B with all of the restoration activities planned to benefit 

watershed, soil, riparian and aquatic resources would result in positive cumulative impacts to 

watershed conditions. The limited amount of road disturbance remaining would not negatively 

impact cumulative effects. The treatments project-wide would result in upward trends in 

watershed condition classification to all of the watersheds with proposed restoration treatments, 

with some watersheds likely moving to an improved condition class. 

Alternative C – Herbicide Utilization

Alternative C would have the same cumulative effects as alternative B. The only difference in 

this alternative is the use of herbicide on rabbitbrush and juniper trees, in addition to, or in lieu 

of, mechanized removal of these species. There would be no additional positive or negative 

cumulative effects to watershed conditions with the added use of herbicide to vegetation. 

Alternative D 

Alternative D is similar to alternatives B and C, minus 4.2 miles of user-created routes added to 

the system, minus construction of 0.3 miles of all-terrain vehicle routes, and minus reopening of 

13.6 miles of closed routes (which would instead be decommissioned). The absence of these 

activities provides the least amount of disturbance to soils of any action alternative over the 

long-term. The 13.6 miles of closed routes would be decommissioned and the 4.2 miles of user 

routes would receive restoration treatments. Long-term impacts related to these road beds would 

be reduced and positive cumulative effects would result. The lack 0.3 miles of reroute would result 

in existing negative impacts remaining in Dillman Creek related to stream crossings. As this 

disturbance currently exists, there would be no additional negative impacts, but no positive benefits 

to the stream resource. Similar to alternatives B and C, this alternative would receive all of the 

other restoration activities planned to benefit watershed, soil, riparian and aquatic resources, 

which would result in positive cumulative impacts to watershed conditions. This alternative 

provides the most positive cumulative effects of all action alternatives by reducing the proposed 

motorized transportation treatments. However, considering the scale of the project area and the 

reduced number of proposed routes and disturbed acreage between alternatives B, C, and D, the 

difference in positive cumulative effects is minor. 
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Summary of Cumulative Effects

Past and ongoing activities on the Gila National Forest include a variety of actions such as 

fuelwood harvest, timber sale activities, mining, prescribed burns, fires, road and trail 

construction and maintenance, rangeland grazing, hunting and camping, wildlife use, offhighway vehicle use, other recreational uses, and water impoundments. Current timber sale 

activities have been minimal and small, and fuelwood cutting has been dispersed and would 

continue to be. Mining activities are minimal to nonexistent within the eleven watersheds. 

Existing National Forest System roads receive periodic maintenance designed to improve 

drainage and reduce excessive runoff and sediment into connected drainages. Future runoff and 

sediment are not expected to increase on existing improved National Forest System roads. 

The average road density within the watersheds is fair, ranging between 1 and 2.4 miles per 

square mile. Roads remain one of the larger contributors of sediment to the drainage network. All 

action alternatives propose to reduce road densities, mostly through decommissioning of 

maintenance level 2, high-clearance routes. As noted prior, two stream reaches are currently not 

attaining State water quality standards. With many roads across the Gila National Forest lacking 

adequate drainage features, roads have been identified by the State as being one probable source 

of impairment for Centerfire Creek. Water quality issues would continue to be a concern in these 

watersheds for stream reaches that are impaired and for those that have designated or occupied 

habitat for threatened, endangered, and sensitive species. While other perennial streams are not 

listed as impaired, many of these stream reaches have not yet been assessed by the State of New 

Mexico. Sediment input would be reduced by decommissioning of routes under all action 

alternatives but would still remain a concern in all perennial and intermittent streams impacted 

by remaining routes. Motorized crossing will be reduced under all action alternatives, as well as 

a reduction in stream miles adjacent to perennial, intermittent, ephemeral, and impaired water 

bodies. 

Livestock grazing across the Gila has seen reductions, with added measures taken to either 

exclude riparian areas or implement riparian specific management along streams. Future impacts 

should be consistent with current impacts. Fires managed for benefit of natural resources and 

vegetation treatments would continue to play a role in these watersheds, when possible, in 

attempts to restore ecosystem health. There are several localized areas within the project area at 

high risk for current and/or future resource degradation without attention to best management 

practices and design features. In particular those areas having sensitive soils, riparian areas, and 

wetlands would be most vulnerable. 

Reasonable foreseeable actions that are expected to occur include reauthorization of livestock 

grazing permits, vegetation management projects, and watershed and road/trail improvement 

projects. In addition, the adjacent Apache-Sitgreaves National Forests are conducting the similar 

West Escudilla Restoration Project, and are expected to improve watershed conditions at a 

landscape scale via vegetation, watershed, and motorized transportation treatments. This 

neighboring Forest shares four sixth code watersheds with the Gila National Forest, and 

improvements on its adjacent National Forest System lands would have beneficial cumulative 

impacts, watershedwide. 

Existing watershed, soil, and aquatic conditions were used to determine current watershed 

condition classification which can be viewed as a collective assessment of all prior activities, 

both natural and human caused, that have cumulatively impacted watershed, soil, and aquatic 
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resources. Careful planning should occur in watersheds that are Functioning at Risk or Impaired 

to ensure that future projects are distributed over space and time. Some programs and activities 

in the project area have localized, short-term, adverse effects to watershed, soil, and aquatic 

resources, however the cumulative effects of past, present and reasonable foreseeable future 

activities, including the implementation of the Luna Restoration Project, would be beneficial. 

In comparison to alternative A, selection of any of the action alternatives would result in positive 

cumulative effects to watershed condition classification as they provide for the benefit and 

restoration of multiple watershed resources. Several watersheds are anticipated to move to an 

improved watershed condition classification over the life of the project due to restoration 

activities.

Roads 

Transportation Specific Assumptions

• Motor vehicle use authorized by state law is occurring on National Forest System roads 

unless there are Gila-National-Forest-specific prohibitions. Analysis assumes compliance.

• There is some cost for maintenance that will have to be borne by the Forest Service for all 

National Forest System roads. 

• There will be implementation costs regardless of the alternative selected.

Affected Environment

National Forest System roads are managed for the use and administration of National Forest 

System lands. Although generally open and available for public use, that use is at the discretion 

of the Secretary of Agriculture. Through authorities delegated by the Secretary, the Forest 

Service may restrict or control traffic to meet specific management direction (USDA Forest 

Service 2008). Roads in the National Forest Transportation System are not public roads in the 

same sense as roads under the jurisdiction of State and County road agencies. National Forest 

System roads are designed, constructed, and maintained to provide access for the utilization and 

management of the national forest and are tracked in the Gila National Forest transportation 

atlas. National Forest System roads are managed in one of three ways: as closed long-term to 

motor vehicles (closed roads), roads maintained for high-clearance vehicles only (high-clearance 

roads), and roads maintained for passenger car vehicles. 

As of January 1, 2017, the Gila National Forest fully implemented the record of decision for the 

Travel Management Rule (USDA Forest Service 2005). Across the entire forest, there are 3,657 

miles of National Forest System roads designated open (operation maintenance levels 2 through 

5) to motor vehicle use by the public or by written authorization and 1,407 miles of roads closed 

to motor vehicle use (operation maintenance level 1) (table 59). 
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Table 59. Existing Gila National Forest System roads by operation maintenance level (OML) and 

general description of each maintenance level.

Operation Maintenance Level Miles

1 - Intermittent service roads during the time they are closed to vehicular traffic 1,407 

2 - Roads open for use by high-clearance vehicles 3,261 

3 - Roads open and maintained for travel by prudent drivers in standard passenger cars 247

4 - Roads that provide a moderate degree of user comfort and convenience at moderate 

travel speeds 

125 

5 – Roads that provide a high degree of user comfort and convenience 24 

Total Miles 5,064 

Miles open to motor vehicle use (OML 2-5) 3,657 

There are approximately 587 miles of roads that lie within the Luna Restoration Project area 

(table 60). The majority, 478 miles, are under Forest Service jurisdiction, of which 

approximately 298 miles are open to all motor vehicle use (table 61). The remaining 109 miles 

are a mix of Federal, County, or private jurisdiction. Many of these roads provide access for 

local communities as well as access to and through the area for recreational and business 

purposes. National Forest System roads within the project area are also used for research, fish 

and wildlife habitat management, range management, timber harvesting, fire protection, mining, 

insect and disease control, and private land use. 

Table 60. Roads under other jurisdiction within the Luna Restoration Project area.

Road Jurisdiction Miles

National Forest System Roads 478

County 76

Private 20

U.S. Highway 14

Total Miles 587

Source: INFRA, GIS 

Table 61 depicts the breakdown of the existing 478 miles of National Forest System roads by 

operational maintenance level within the Luna Restoration Project area. 

Table 61. Existing National Forest System roads within the Luna Restoration Project area broken 

down by operation maintenance level and general description of each maintenance level.

Operation Maintenance Level (OML) Miles

1 - Intermittent service roads during the time they are closed to vehicular traffic 180 

2 - Roads open for use by high-clearance vehicles 250 

3 - Roads open and maintained for travel by prudent drivers in standard passenger cars 35

4 - Roads that provide a moderate degree of user comfort and convenience at moderate 

travel speeds 

13 

5 – Roads that provide a high degree of user comfort and convenience 0 

Total Miles 478 

Miles open to motor vehicle use (OML 2 through 5) 298 

Source: INFRA, GIS 
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Environmental Consequences

Alternative B and C are the same in regards to proposed changes to the National Forest road 

system. The differences between all of the alternatives are summarized in table 62. 

Table 62. Changes to National Forest System road miles by alternative

Proposed Changes Alt A Alt B Alt C Alt D

Road decommissioning 0 116 116 130

Re-open operation maintenance level 1 closed National 

Forest System roads for permitted use for proposed 

treatment activities and decommission after activities are 

completed (included in road decommissioning above) 

0 12 12 12

Total road miles removed from national forest road system 0 116 116 130

Re-open operation maintenance level 1 closed National 

Forest System roads to all vehicle types 

0 13.8 13.8 0.2

Add unauthorized roads to National Forest System roads

open to all vehicle types

0 4.2 4.2 0 

Total additional road miles open to all vehicle types 0 18 18 0.2

Re-open operation maintenance level 1 closed National 

Forest System roads for permitted use for proposed 

treatment activities and close after activities are completed 

(no net change to national forest road system mileage)

0 22.6 22.6 22.6

Construct 3 to 5 miles of temporary roads for proposed 

treatment activities and decommission upon completion of 

activities (no change to system miles as temporary roads 

are not tracked in the forest transportation atlas) 

0 3 to 5 3 to 5 3 to 5

Add unauthorized road to National Forest System roads for 

administrative use or by written authorization only (Tucson 

Electric Power Company) 

0 0.5 0.5 0.5

Re-open operation maintenance level 1 closed National 

Forest System roads for administrative use or by written 

authorization only (Tucson Electric Power Company) 

0 3.5 3.5 3.5

Total additional road miles for administrative use or by 

written authorization only 

0 4.0 4.0 4.0

Total road miles added to national forest road system 0 22 22 4.0

Net reduction in National Forest System road miles 0 94 94 126

Tucson Electric Power Company has a main transmission line that runs through the project area 

that they need to access for maintenance, emergency repair, and structure replacements. To 

accommodate Tucson Electric Power Company needs, all action alternatives (B, C, and D) 

would reopen 3.5 miles of closed roads and add 0.5 miles of unauthorized roads to the forest 

transportation atlas. 

Other publics provided comments requesting additional access for recreational activities. Those 

comments resulted in proposals to re-open 13.8 miles of closed National Forest System roads 

and add 4.2 miles of unauthorized roads under alternatives B and C. In alternative D, the 13.8 

miles are proposed for decommissioning, putting the decommissioning total miles at 130 miles 

while the 4.2 miles of unauthorized roads would be subject to decommissioning. 
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The table does not address the decommissioning of unauthorized roads as they are not 

recognized as National Forest System roads and are not tracked in the forest transportation atlas. 

The same can be said for the 3 to 5 miles of proposed temporary roads (common to all action 

alternatives). Temporary roads are not tracked as they are not intended to become part of the 

national forest road system. Temporary roads are used for a short period for a specific purpose 

and then obliterated. 

The proposal to re-open 22.6 miles of National Forest System roads in alternatives B, C, and D is

to access proposed treatment sites. Reopening these roads, will not result in an increase of miles 

to the road system; because these roads would be closed as treatments are completed. 

Trends

Under alternatives B and C, the proposal is to decommission 116 of the 180 existing miles of 

operation maintenance level 1 roads within the planning area (table 62). Decommissioning 116 

miles of roads would be completed once all landscape treatments have been accomplished. The 

same 116 miles plus an additional 13.8 miles would be decommissioned in alternative D. 

The reopening of previously closed roads and adding unauthorized roads to the forest’s 

transportation atlas would result in more flexibility and increased opportunity for the recreating 

public. Alternatives B and C would add 18 miles to the existing 298 open miles (table 53) within 

the planning area. The additional 18 miles would result in an increase of approximately 6 percent 

of open National Forest System roads within the planning area. The 4 miles that would be added 

on behalf of Tucson Electric Power Company in all action alternatives would assist them in 

operating and managing their transmission line. These 4 miles would seldom see traffic as they 

would be under written authorization to Tucson Electric Power Company and wouldn’t be added 

to the motorized vehicle use map. 

Regardless of which action alternative is selected, the reduction to the overall national forest 

road system is negligible and would do little to help align the Gila National Forest road budget 

with the maintenance needs. Alternatives B and C would reduce the overall system by 94 miles, 

approximately 2 percent of the existing national forest road system, and alternative D would 

reduce the mileage by 126 miles or nearly 2.5 percent. Even though these reductions are small, 

the watersheds they reside in would benefit (less sediment migration from roadbeds, better water 

quality, reduced road density, etc.) as well as wildlife habitat (less fragmentation). The Travel 

Management Rule (USDA Forest Service 2005) provides flexibility when designating the 

motorized system. Roads previously closed may be reopened and roads designated for motorized 

use may be closed at a later date. Even though all the action alternatives propose to reopen roads 

and add unauthorized routes, the proposals net effect to the national forest road system would 

result in a mileage reduction due to the decommissioning proposals in all the action-alternatives. 

There would be some implementation costs associated with the use of the National Forest 

System roads within the planning area including National Forest System Road 3050 (0.2 mile) 

where drainage features would be maintained and existing berms would be removed or reworked 

to allow passage (applicable to all action alternatives).

There are also several bridges within the project area which may be used if any of the action 

alternatives are selected. Six are located on Catron County Road B007 and one is located along 

National Forest System Road 220 at Romero Creek. All these bridges have been evaluated and 

approved for highway legal loads. The additional traffic associated with proposed treatments 

(including logging trucks, semi tractors hauling heavy equipment, etc.) could also result in the 
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need for additional maintenance on roads operated and maintained by Catron County, 

specifically Catron County Roads B007, B080, and B024. Some of the roads on the ApacheSitgreaves National Forests could also see additional traffic associated with proposed treatments. 

There are no measureable maintenance cost savings associated with any of the action 

alternatives. The Gila National Forest will continue to seek opportunities to better balance the 

national forest road system with available funding. The more significant benefit is likely to be 

seen over time once the decommissioned roads identified in any of the action alternatives have 

been fully reclaimed by the natural landscape. Some of the anticipated benefits include reduced 

habitat fragmentation, better watershed conditions, reduced road density, etc. 

Range 

Range Resources 

The Luna Restoration Project area includes portions of eight range allotments. Table 63 indicates 

how many acres of each allotment are located within the project area and have the potential to be 

impacted by project activities. The Centerfire, Dillman/Trout Creek, Luna, Spur Lake and 

Underwood Lake allotments are located entirely or almost entirely within the analysis area. The 

Laney and Mangitas allotments have large portions of the allotment within the analysis area and 

the Toriette allotment has minimal acres located within the analysis area.

Table 63. Grazing allotments located within the Luna planning area.

Allotment Name

Total 

Allotment 

Acres

Acres Within the Luna 

Analysis Area

Percent of Allotment 

within the Luna Analysis 

Area

Centerfire 20,551 20,307 99%

Dillman/Trout Creek 9,589 9,589 100%

Laney 26,449 13,343 50%

Luna 44,927 44,927 100%

Mangitas 25,116 6,144 24%

Spur Lake 74,457 62,874 84%

Toriette 39,442 256 less than 1%

Underwood Lake 13,053 13,053 100%

Environmental Consequences

Alternative A

Under the no-action alternative, none of the proposed treatments or activities would be 

implemented within the planning area. There would be no direct effects to the range resource. 

Indirect effects associated with the no-action alternative would include continued encroachment 

of woody vegetation into neighboring grasslands and canopy closure of forested and woodland 

vegetation types that could lead to the decrease in the amount and diversity of herbaceous 

vegetation on the landscape. The fuels reduction projects and prescribed fire activities would not 

occur, increasing the opportunity for high-severity fire to occur across the landscape and 

negatively impact the range resource. The proposed watershed treatments would not be 

implemented allowing for continued degradation of these systems. This could present negative 
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effects to the range resource through continued erosion and loss of soil productivity in these 

systems. Water availability to vegetation, livestock and wildlife could be reduced by down 

cutting of stream banks that can cause the water table to recede and decrease the duration in 

which precipitation is available for infiltration and use by the surrounding vegetation. 

There would be no cumulative effects to the range resource under this alternative. 

Effects Common to Alternatives B, C, and D 

The direct effects of action alternatives would include disturbance to the herbaceous vegetation 

and soils during implementation of the proposed projects that could require rest of a pasture or 

portion of a pasture. These effects are expected to persist for a short duration and have minimal 

impacts through the proposed mitigations. This effect is mitigated through the coordination of 

activities with the range management specialist and the affected permittee to allow for adaptive 

management to be incorporated into the allotment management plan and to ensure that the timing 

and scale of the project would not place an undue burden on the range resource and livestock 

management. Adaptive management actions that may occur to mitigate effects include 

adjustments in pasture rotation schedules, herding, salting and reduced numbers. 

The indirect effects of the action alternatives would primarily be of benefit to the range resource. 

The proposed vegetation, prescribed fire and watershed activities would increase the opportunity 

for the occurrence and diversity of herbaceous vegetation throughout the analysis area. This, 

along with the proposed water developments and pasture division, would lead to the 

improvement of livestock distribution and use across the landscape, allowing for improved 

livestock management and resilience of the range land vegetation during times of drought and 

unforeseen climate conditions. With any soil disturbing activity the opportunity exists for 

noxious weeds to become established. The proposed activities would implement strategies to 

reduce or eliminate the opportunity for introducing weed seed through the implementation of 

proposed projects. Reseeding when necessary and appropriate would also occur within 

disturbance sites to decrease the opportunity for noxious weeds to establish and to reduce the 

exposure of soils to erosion. If noxious weeds immerge within the analysis area, they would be 

addressed through the environmental assessment for noxious weed management (Gila National 

Forest 2000 and 2015 supplement plant list). 

Alternatives B and D

In alternatives B and D, rabbitbrush treatment by mowing alone would likely require several 

consecutive years of reentry to achieve measurable mortality of rabbitbrush within a given 

treatment area and has the potential to expose the soils and associated vegetation to increased 

disturbance. Single entry mowing would likely change the physical structure of the plant 

community allowing for the growth of herbaceous vegetation for a short duration until the 

rabbitbrush becomes reestablished. Some acres identified for rabbitbrush treatment cannot be 

accessed with mowers exclusively, therefore desired conditions may not be reached on these 

acres. 

Cutting of alligator juniper from grasslands will initially result in increased herbaceous ground 

cover. This species re-sprouts and within a decade may be of size where it competes with 

herbaceous ground cover. 
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Alternative C 

The use of herbicides to treat rabbitbrush and alligator juniper will move the landscape towards

desired conditions in a shorter timeframe than alternatives B and D. Herbicide treatments would 

increase mortality in rabbitbrush and alligator juniper therefore, minimizing re-sprouting of these

species. More acres of rabbitbrush treatments could be accomplished utilizing herbicides versus 

mowing in alternatives B and D; due to access not being limited by topography or other features.

The use of herbicides reduces the potential for increased ground disturbance from the need of 

repeated mowing. 

Cumulative Effects

There would be an increase in herbaceous cover, acres of grassland, and water availability and 

distribution from implementing alternatives B, C, or D. When considering past, present, 

reasonably future activities, and activities proposed in the alternatives it is anticipated to result in 

a positive cumulative effect for range management. 

Recreation 

Affected Environment

The primary recreational opportunities, as identified in the 2011 Gila national visitor use 

monitoring data and district staff, are dispersed in nature and include; driving to view scenery 

and wildlife, dispersed camping, big game hunting, hiking cross country and on system trails, 

horseback riding, off-highway vehicle riding, shed hunting, photography, night sky viewing, bird 

watching, botanizing, and general nature observation. 

There is one developed recreation site in the project area: Head of the Ditch Campground. The 

campground offers an easily accessible rustic streamside camping experience. It is located 

approximately 1.5 miles west of Luna, New Mexico on U.S. Highway 180. Its proximity to this 

major thoroughfare, makes it popular with folks traveling through the region. The campground 

also receives substantial use during the hunting seasons.

Dispersed camping and picnicking are popular in the Stone Creek, San Francisco River and 

Trout Creek corridors.

There are fifteen National Forest System trails in the planning area, totaling approximate 39.4 

miles. Most trails are restricted to horses, hiking and mountain biking. Two motorized trails are 

located in the Dry Blue drainage. 

Off-highway vehicle riding is popular in the Luna area. Roads provide opportunities for all 

vehicle types, this includes off-highway vehicles greater than 50 inches in width. The popular 

utility task vehicles, which provide side-by-side operation, fall into the greater-than-50-inches 

category. Low maintenance level roads (maintenance level 2) provide the opportunity for this 

width of vehicle class as well as the unimproved trail-like experience desired by the off-highway 

vehicle rider.

Hunting is a major recreational use in the Luna planning area. Hunting seasons and restrictions 

are administered by the New Mexico Department of Game and Fish. Big game is the primary 

type of hunting: elk, bear, mountain lion, and deer. Wild turkey hunting is also popular. There are 
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24 special use permits for outfitter and guides in the project area. Hunting is dispersed in nature; 

however, some hunting parties revisit the same areas annually. 

Environmental Consequences

Alternative A – No Action

Under the no-action alternative, there would continue to be approximately 39.4 miles of National 

Forest System trail. Head of the Ditch Campground would remain open. Visuals would mostly 

remain unchanged due to being constrained by existing vegetation conditions, such as tree 

densities. Hunting and other recreational pursuits would continue. The motorized transportation 

network would not change from the 2013 travel management decision. Driving for pleasure 

would continue. Off-highway vehicle recreation would continue on low level maintenance roads 

open to the public. 

Without vegetation and prescribed fire treatments the potential risk for high severity, wildfires, 

such as the Wallow Fire, would continue. These fires adversely could affect recreation by 

damaging infrastructure, including damaging trail networks and accessibility; and heavily 

modifying the recreational setting. 

Low-water fords on the Dry Blue Creek (trails #61 and #64) and Head of the Ditch would 

remain in their current state and location. Issues with sedimentation and aquatic resource damage

would continue. 

Cumulative Effects

There are no cumulative effects to recreation due to no activities proposed under the no-action 

alternative. 

Effects Common to Alternatives B, C, and D

In the short-term, there would be some inconvenience to visitors to the Luna Restoration Project 

area during implementation. Areas or facilities may be temporarily closed to help ensure public 

safety. Project implementation would likely result in a more aesthetically pleasing recreational 

setting.

Thirteen of the 15 trails are located within active treatment areas or would be worked on. 

Treatments would alter the visuals in the immediate foreground. Affected portions of the trails 

would be temporarily closed to help ensure public safety. Prescribed fire may result in the 

creation of snags along trails. If snags fall they could impact the accessibility along the trail. 

People recreating within the planning area could encounter the sights and sounds of equipment 

and workers during implementation. There would likely be temporary effects to the flow of 

traffic on these travel ways, such as delays or detours. Treatments would alter the visuals in the 

immediate foreground such as; slash, piles, landings, skid trails and disturbed ground would be 

evident in the short term. In the long term, scenic integrity would be improved by restoring 

structure to vegetation communities, with sight lines becoming more open. 

Implementation would temporarily displace opportunities for recreation and hunting. However, 

implementation would be localized; while work is implemented in one area, other areas within 

the project area would be open. Some visitors may choose to avoid the area entirely. 
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Head of the Ditch Campground would temporarily close during construction of the low-water 

crossing and diversion to help ensure public safety. This is the only developed campground 

within the project area. During implementation there are no other opportunities for developed 

camping within the planning boundary. Relocation of the low-water crossing would improve 

access to campground sites located across the San Francisco River. 

Motorized trails in the Dry Blue Creek (trails #61 and #64) would be improved through design 

and construction of six water crossing and rerouting 0.1 mile of trail. This would move towards 

reducing impacts to threatened and endangered species and their habitat, and reducing 

sedimentation. 

Decommissioned roads would be available to the public to hike, bike, or ride horses on. This 

recreational experience would likely be enhanced due to the absence of motorized vehicles. In 

addition 4.2 miles would be added to the foot and horse trail system by leaving a trail tread on 

National Forest System Roads 4023 V; 4029 E, and 4030 W during decommissioning. 

Roads open for administrative use only are available to the public to hike, bike or ride horses on.

Roads and trails could be temporarily closed during prescribed fire activities to help ensure 

public safety. The presence of active fire and smoke could cause some visitors to change their 

travel plans. Smoke could linger for days in some areas, causing visitors to avoid those locations.

Smoke from prescribed fires may have a direct effect to the quality of the recreation experience 

by temporarily reducing air quality and visibility. 

Effects Common to Alternatives B and C 

In collaboration with the Luna Riders, 18.0 miles of closed and user-created routes were 

identified to be added to motorized transportation system. These select closed system roads and 

user-created routes were identified for provide access from the community of Luna, access into 

Arizona, loop opportunities, and to access favorite spots for scenic views and picnicking. 

Opening existing closed and user-created routes would enhance recreational opportunities 

through improving connectivity of the road system and enhancing riding experience. 

The proposed action during scoping limited the 18.0 miles of road to all-terrain and utility task 

vehicles less than50 inches in width. As proposed in alternative B, these 18.0 miles would be 

open to all motorized vehicle types; which includes popular utility task vehicles that allow for 

side-by-side riding. Therefore, adding roads of this class provides more opportunity for this type 

of recreation. 

In collaboration with the Luna Riders, a new route was identified to connect an open road in the 

Luna rodeo grounds to a system of open roads in the Stone Creek area. Construction of a 0.3 

miles of 4x4 trail addresses sensitive riparian resource concerns in Dillman Creek and enhances 

connectivity of road systems for recreational opportunities. The tread width of 60 inches would 

provide utility task vehicle opportunities. 

Alternative C - Herbicide Utilization

The use of herbicides to increase effectiveness of restoration would have a few effects to 

recreation opportunities. The sights and sounds of herbicide application would be apparent 

during implementation. Following manufacture instructions and design features related to 
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notification and posting, would minimize any potential negative impacts to Gila National Forest 

visitors during or from herbicide applications. 

Herbicide treatment activities may temporarily displace visitors. Visitors may choose to avoid an 

area where herbicide treatments have been applied. 

Proposed herbicide treatments would likely have an overall beneficial effect to visual quality. 

Short-term impacts from chemical treatments would include dying vegetation that could be 

visible. Long-term effects would be beneficial through the enhancement and restoration of areas 

of grasslands, forested, and woodland areas.

Alternative D - No Addition of Motorized Routes

The 18.0 miles of closed and user-created routes that were identified in collaboration with the 

Luna Riders would not be added to motorized transportation system under this alternative to 

address an issue identified from scoping comments. Therefore, access from the community of 

Luna, access into Arizona, loop opportunities, and access to favorite spots for scenic views and 

picnicking would not be provided. Connectivity of the road system to enhance riding experience 

would remain a public concern, including the connection between the Luna rodeo grounds to a 

system of open roads in the Stone Creek area. 

Cumulative Effects

Recreation opportunities and scenic quality as a result of implementing alternative B, C, and D 

would result in cumulative impacts, when considering past, present, reasonably future activities, 

activities proposed in this alternative, and activities identified in the West Escudilla Project on 

the Apache-Sitgreaves National Forests. 

Recreation opportunities could be cumulatively impacted due to the increased management 

activities. Road networks along the state line of New Mexico and Arizona could be utilized by 

both national forests for implementation of projects. This could result in traffic, dust, and noise 

which could lead to a slight inconvenience and displacement of visitors. This would be of 

episodic and extent is dependent upon what activity treatment(s) are being implemented. 

Cumulative impacts to scenic quality are possible if evidence of multiple activities are visible 

during the same season. Similar vegetation treatments are planned in the West Escudilla Project. 

Cumulative impacts to visual resources along the state line would likely only last during 

implementation. Long-term cumulative impacts are likely to be beneficial as healthy forest 

conditions are restored. 

Climate Change

Climate change influences such things as the weather, vegetation, habitat, water, and wildlife 

across the landscape. Depending on the changes to these resources due to climatic change, 

recreational opportunities or users may change or alter those opportunities and uses. But 

determining the relation of climate change and recreation uses is not easily identifiable.

Recreation – Inventoried Roadless Areas 

Inventoried roadless areas are designated pursuant to 36 CFR section 294, subpart B, section 

294.11. Inventoried roadless areas are identified in a set of maps contained in Forest Service 
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Roadless Area Conservation, final environmental impact statement, and volume 2 (USDA Forest 

Service 2000a). 

This analysis describes the existing condition of the three inventoried roadless areas within the 

Luna Restoration Project area. This includes all of the Mother Hubbard portions of the Nolan 

and Frisco Box Inventoried Roadless Areas. 

Low-severity prescribed fire is proposed in the Mother Hubbard and Nolan Inventoried Roadless 

Areas. There is none prescribed within the Frisco Box Inventoried Roadless Area, but a short 

section of trail is proposed to be enhanced by reducing its width from a road to single-track trail. 

This roadless analysis also describes the potential effects to the roadless characteristics and 

wilderness attributes of the inventoried roadless areas from the proposed treatment activities 

identified in the alternatives.

The recreational opportunity spectrum classes are not mapped and therefore unavailable. The 

Gila forest plan prescribes a forestwide standard to manage the three inventoried roadless area to 

semi-primitive spectrum of recreation opportunities. 

Affected Environment

The inventoried roadless area contain a variety of vegetation types including pinyon-juniper, 

riparian, ponderosa pine, and mixed conifer at higher elevations. There are no municipal 

watersheds, but there are perennial water features such as Blue and Colyer Springs, and reaches 

of Pace, Dry Blue, and Centerfire Creeks in these areas. All roadless areas contain habitat for 

threatened and endangered species such as Mexican spotted owl, Mexican grey wolf, narrowheaded and northern Mexican gartersnakes and loachminnow but is not the only habitat for these 

species on the Gila National Forest. Dispersed recreation, such as hiking, hunting, and observing 

nature, are the main recreational uses. 

Nolan Inventoried Roadless Area

The Nolan Inventoried Roadless Area is 13,050 acres in size with 8,912 being situated along the 

southwestern boundary south of the Dry Blue Canyon with a portion of the San Francisco 

Mountains of the planning area. This roadless area also extends across the state line into the 

Apache-Sitgreaves National Forests. 

Summary of the roadless area characteristics and wilderness attributes of Nolan Inventoried 

Roadless Area: 

• Natural - The extent to which long-term ecological processes are intact and 

operating: Due to decades of fire suppression, ecological processes have departed from 

historical norms. Forest stand densities have high crown fire potential which promotes 

high severity fire. The current state of this attribute is degrading.

• Undeveloped - The degree to which development and uses are apparent to most 

visitors: Evidence of human activity is present across much of the area but is subtle in 

appearance. Fuelwood cutting, recreation use, private land and road building are a few 

examples of what has contributed to defining the degree to which development and uses 

are apparent to most visitors and departure from the undeveloped characteristic within the 

roadless area.
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• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation; 

Solitude is a personal, subjective value defined as the isolation from sights, sounds, and 

presence of others and from developments and evidence of humans. Primitive recreation is 

characterized by meeting nature on its own terms, without comfort and convenience of 

facilities. 

Nolan includes areas with more potential for solitude than others. Topographically 

constrained areas such as Frieborn and Colyer Canyons provide more isolation from the 

sight and sounds of civilization than do areas near U.S. Highway 180 or the motorized Dry 

Blue Creek Trail, where noise associated with motorized vehicles are common. 

The area is managed for semi-primitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semi-primitive nonmotorized 

(interior) and the periphery would likely qualify for semi-primitive motorized or roaded 

natural (areas near Horse Mesa and Dry Blue Creek Trail). 

• Special Features: Colyer Spring is a perennial source of water, which is considered 

special in the arid region.

• Manageability: Nolan Inventoried Roadless Area within the planning area is defined 

mostly by landform and the presence of road and motorized trail. This shape renders it 

easily manageable. The portion of the roadless area outside the planning area was not 

considered for manageability. 

Mother Hubbard Inventoried Roadless Area

The Mother Hubbard Inventoried Roadless Area is 5,895 acres in size and is situated entirely 

within the planning area along the southwestern boundary north of Dry Blue Canyon. 

Summary of roadless area characteristics and wilderness attributes of Mother Hubbard 

Inventoried Roadless Area: 

• Natural - The extent to which long-term ecological processes are intact and 

operating: Due to decades of fire suppression, ecological processes have departed from 

historical norms. Forest stand densities have high crown fire potential which promotes 

high-severity fire. The current state of this attribute is degrading.

• Undeveloped - The degree to which development and uses are apparent to most 

visitors: Evidence of human activity is present across much of the area but is subtle in 

appearance. Fuelwood cutting, recreation use, private land, and road building are a few 

examples of what has contributed to defining the degree to which development and uses 

are apparent to most visitors and departure from the undeveloped characteristic within the 

roadless area. 

• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation: 

Mother Hubbard has areas with more potential for solitude than others. Topographically 

constrained areas such as Pace Creek and Dry Blue Creek canyons provide more isolation 

from the sight and sounds of civilization than do areas near the north boundary or the 

motorized Dry Blue Creek Trail, east boundary, where noise associated with motorized 

vehicles are common. 

The area is managed for semi-primitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semi-primitive nonmotorized 

(interior) and the periphery would likely qualify for semi-primitive motorized or roaded 
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natural (areas near north, east and Dry Blue Creek Trail). 

• Special Features: Blue Spring is a perennial source of water which is considered special 

in the arid region. 

• Manageability: Mother Hubbard Inventoried Roadless Area is defined mostly by 

landform and the presence of road and motorized trail. This shape renders it easily 

manageable. The exception would be the northern and eastern boundaries might be 

difficult to locate on the ground. 

Frisco Box

The Frisco Box Inventoried Roadless Area is 38,977 acres in size with 8,312 and is situated on 

the eastern boundary of the planning area. The roadless area contains the Centerfire Creek Valley 

and contains Upper Cottonwood, Joshua, Howell, and Curio Canyons. 

Summary of roadless area characteristics and wilderness attributes of Mother Hubbard 

Inventoried Roadless Area: 

• Natural - The extent to which long-term ecological processes are intact and 

operating: Due to decades of fire suppression, ecological processes have departed from

historical norms. Forest stand densities have high crown fire potential which promotes 

high-severity fire. The current state of this attribute is degrading.

• Undeveloped: The degree to which development and uses are apparent to most visitors.

Evidence of human activity is present across much of the area but is subtle in appearance. 

Fuelwood cutting, recreation use, private land and road building are a few examples of 

what has contributed to defining the degree to which development and uses are apparent to 

most visitors and departure from the undeveloped characteristic within the inventoried 

roadless area. 

• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation: 

Frisco Box has areas that have more potential for solitude than others. Topographically 

constrained areas such as Upper Cottonwood, Joshua, Howell, and Curio Canyons provide 

more isolation from the sight and sounds of civilization than do areas near the northern 

boundary where noise associated with motorized vehicles are more common. 

The area is managed for semi-primitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semi-primitive nonmotorized 

(interior) and the periphery would likely qualify for semi-primitive motorized or roaded 

natural (areas near Centerfire Creek Valley and northern boundary). 

• Special Features: Centerfire Creek is a perennial stream, which is considered special in 

the arid region.

• Manageability: The Frisco Box Inventoried Roadless Area is defined mostly by landform 

and the presence of road. This shape renders it easily manageable. The exception is the 

northern boundary, which is difficult to locate on the ground. 

Environmental Consequences

The effects to the inventoried roadless areas were analyzed using the duration and trend of the 

effect on roadless area characteristics and wilderness attributes.
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Alternative A – No Action

Under alternative A, no activities would occur. Consequently, fuel loading would continue to 

increase over the project area. This would create an increased risk of wildfire. The potential 

event of an uncharacteristic wildfire could impact the naturalness, recreation values, or both in 

the area. 

Alternative A would leave the current roadless character and potential wilderness values 

unchanged. Any direct or indirect effects of this alternative would be the result of continued 

natural processes in the area. 

• Natural - The extent to which long-term ecological processes are intact and 

operating: Prescribed fire and vegetation treatments would not be reintroduced. The 

existing downward trend of species diversity, age diversity, and tree density diversity 

would continue. High-severity wildfire could result in large homogenous burned areas. 

• Undeveloped - The degree to which development and uses are apparent to most 

visitors: No treatments would occur under this alternative, and no new development or 

uses would become apparent to visitors. 

• Outstanding opportunities for solitude or primitive unconfined recreation: The 

existing condition for solitude would not be immediately affected under this alternative. 

However, over time conditions could become challenging for visitors to recreate due to 

forest stand conditions. Forest stand conditions could increase opportunities for solitude, 

for those who are able and willing to negotiate an increasingly dense and inaccessible area. 

Wildfires could dramatically change the landscape, changing how people access or 

recreate in the roadless areas. In the case of wildfires, sight distance and topography 

screening could be changed for decades, impacting solitude, as sights and sounds of 

visitors in the area as well as activities on adjacent lands would more easily be seen and 

heard. 

• Special Features: The existing springs and perennial water sources would not be affected 

under this alternative. However, existing stand conditions would render them susceptible 

to the effects of high-severity fire.

• Manageability: Choosing the no-action alternative would not change the manageability of 

the area.

Cumulative Effects

Since there are no activities being implemented under alternative A, current activities (for 

example, grazing, hunting, and hiking) would continue, but there would be no cumulative effects 

to roadless characteristics and wilderness attributes. 

Effects Common to Alternatives B, C, and D 

There are no differences in proposed activities between the alternatives B, C and D within the 

three inventoried roadless areas. Each alternative proposes low-severity prescribed fire within 

the Mother Hubbard and Nolan Inventoried Roadless Areas and a road to trail conversion in the 

Frisco Box. All alternatives would have some short-term effect to the undeveloped, natural, and 

opportunities for solitude or primitive unconfined recreation attributes of the area but would 

result in a long-term beneficial effect. 
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In summary, the effects from low-severity prescribed fire are expected to be minor and short 

term. Few characteristics such as plant and animal communities, habitat for threatened and 

endangered species, and recreation opportunities would expect slightly degrading effects in the 

short-term and then improving in the long term. Prescribed fire may cause direct short-term 

impacts to air resources from smoke. 

Temporary effects to solitude and recreation could occur along roadless boundaries from the 

greater Luna Restoration Project activities, including sights and sounds of people working, 

chainsaws, dust and smoke; however, long-term impacts to recreation and opportunities for 

solitude are not expected to occur. 

• Natural - The extent to which long-term ecological processes are intact and 

operating: Prescribed fire would begin modifying the trends caused from past fire 

suppression and reduce the potential probability of severe wildfires. Prescribed fire would 

enhance the characteristic of “naturalness” throughout the area, by re-establishing forest 

characteristics typical of frequent fire ecosystems. 

Low intensity prescribed fire would be classified as a type of human manipulation with

methods of ignition emulating a lightning fire. No fire line is expected to be constructed. 

Fire behavior is expected to be low creeping through the understory. The resulting pattern 

on the landscape would be small patch sizes of burned area (mosaic) with irregular shapes. 

Over time, as multiple entries are made to meet fuel objectives, vegetation communities 

within the Nolan and Mother Hubbard roadless would begin to move towards conditions 

that include mosaic of various size and age classes which and more resilient to changing 

environmental conditions and stressors. 

The road to trail conversion in Frisco Box roadless area would restore the subsurface 

hydrology to the existing road prism that trail number 119 currently uses. Portions of the 

decommissioned road would revegetate through successional processes.

• Undeveloped - The degree to which development and uses are apparent to most 

visitors: In the short term, visitors to the areas would see isolated patches of blackened

and charred vegetation and soils. Although these visible effects of prescribed burning can 

mimic natural fire disturbances, such blackened landscapes are often perceived negatively 

by the public. In the long term, the prescribed burning actions would reduce fuel loading 

and promote regeneration of trees, shrubs, wildflowers, and other herbaceous plants. This 

activity would diversify the mosaic of vegetation.

Soil and vegetation disturbance associated from road to trail conversion would be evident 

to visitors. However this would be a short-term effect, as the disturbed area would revegetate, leaving single-track trail that is appropriate for the design use (pack and saddle 

and hiking). 

• Outstanding opportunities for solitude or primitive unconfined recreation: It is likely 

portions of the Mother Hubbard and Nolan Inventoried Roadless Areas may be 

temporarily closed during prescribed fire implementation to ensure public safety and 

welfare. This would be a short-term effect. Visitors that are temporarily displaced would 

find comparable opportunities within and outside of the planning area. The degree of 

primitive recreation is not expected to be affected. 

Multiple prescribed fire entries over time would be needed to achieve objectives of 

reducing the probability of high-severity fire. With multiple entries over time the sight 

distance may change from current; but this change would not be to the extent of the 
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potential effects of a wildfire. 

Solitude of segments of trail # 119 would be affected during implementation while work is 

completed. This is a short-term effect, as solitude would quickly be restored after

implementation.

It is possible that visitors to, and outside, the inventoried roadless areas would experience 

the sights and sounds of on-the-ground staff and aerial operations implementing the 

prescribed fires. Smoke emissions from prescribed fires across the planning area. The 

duration is expected to be short term and solitude would be restored shortly after 

implementation. 

• Special Features: Springs, perennial water sources, and cultural resources are the only 

known special features in the three inventoried roadless areas. It is not expected that there 

would be impacts to these features during implementation. 

• Manageability: All action alternatives would not affect the existing manageability of the 

roadless areas. Roadless boundaries are not clearly definable on the ground; therefore, the 

issue of manageability along boundaries is anticipated to continue. 

Cumulative Effects

Cumulative effects to roadless resources from all action alternatives would generally be short

term and related to an increased presence of people, noise that may affect solitude. These effects 

would be more evident along the boundaries of the roadless areas where treatments are both 

inside and outside the areas. In some of the units, there would be a greater sight distance than 

existing conditions. For several years, visitors could become more aware of other activities in the 

area as well as on private lands. This effect would not be as great as potential effects from a large 

wildfire, which would likely denude the landscape of all vegetation. An indirect effect of 

proposed prescribed fire activities could be displacement of visitors to untreated areas for 

recreation, mostly because of visuals however, this effect would last for about 1 to 2 years after 

prescribed fire activities when green-up would occur. 

The long-term forest health and resiliency would be most improved under the action alternatives 

than the no-action alternative due to the development of a less homogenous forest, more 

diversity of species, and a mosaic of age classes. In the long term, treated areas would be more 

resilient to wildfire and other natural disturbances, which would more likely maintain the quality 

of soil, water, and air in the future. 

Climate Change

The effects of climate change were considered during the effects analysis of proposed actions to 

roadless resources. It is expected that climate change effects would increase the length of fire 

season and increase likelihood of high-severity fire. As discussed in the no-action alternative, 

the existing vegetation conditions within the roadless areas have potential for a high-severity fire

with high crown fire potential. Roadless resources could be at risk to irretrievable outcomes 

including species and habitat loss until vegetation becomes re-established 

Roadless Rule Consistency

All alternatives comply with the Roadless Area Conservation Rule and applicable forest plan 

standards as amended by this rule. All action alternatives are within the exceptions identified in 

36 CFR section 294.13(b)(1), in paragraphs (b)(2) through (b)(4), or both. Management activities 
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focus on restoring the characteristics of ecosystem composition and structure, such as to reduce 

the risk of uncharacteristic wildfire effects, within the range of variability that would be expected 

to occur under natural disturbance regimes of the current climatic period. 

Heritage Resources 

Gila National Forest History

The Gila National Forest has a rich archaeological and cultural history. The Gila National Forest 

includes lands that have been used and occupied by humans through the prehistoric era, 

beginning with the Paleoindian period (circa 10000 B.C. to 5500 B.C.), into the Archaic period 

(circa 5500 B.C. to A.D. 200). Both the Paleoindian and Archaic period peoples were relatively 

mobile on the landscape. However, during the Archaic period the transition from a huntergatherer lifeways to agricultural lifeways occurred. 

Over time, Archaic period peoples began to develop cultural lifeways that would come to be 

known as the Mogollon Culture. The Mogollon Culture spans two broad time periods: the 

Pithouse period (circa A.D. 200 to 1000) and the Pueblo period (circa A.D. 1000 to 1450). As 

the name implies, Pithouse period structures were at least partially subterranean, and dug subgrade below the surrounding surface. The beginning of the Pueblo period (circa A.D. 1000 to 

1400) is marked primarily by the appearance of above ground architecture. 

The historic period began in New Mexico with Spanish contact in 1539. On the Gila National 

Forest and elsewhere in New Mexico, the historic period is divided by the rise and fall of 

political control by the Spanish (A.D. 1539 to 1821), Mexican (A.D. 1821 to 1848), and 

American (A.D. 1848 to present) governments (Opler 1983). 

Contemporary and historic land uses include mining, ranching, grazing, logging, frontier 

settlement, frontier military activities, and government land management. Evidence of these 

activities persists in the archaeological record today. Since the establishment of the Gila 

National Forest in 1905, ranger stations, administrative sites, lookouts, and recreational areas 

have been built as well. Finally, Civilian Conservation Corps (CCC) camps and their constructed 

infrastructure (for example, roads, bridges and campgrounds) are found across the Gila. 

Today, land use in the Gila National Forest continues to follow the multiple use mission of the 

Forest Service, including grazing, mining, ranching, and vegetation and fuels management. 

Native American Tribes also continue to intermittently use the Gila for traditional activities 

including plant gathering and visits to special places. Tribes have not identified any traditional 

cultural properties or sacred sites within the Luna Restoration Project area through consultation, 

nor have any been identified as being affected by other projects within the planning area.

Affected Environment

For around the past 50 years, Forest Service cultural resource specialists, in compliance with 

sections 106 and 110 of the National Historic Preservation Act of 1966, as amended, have 

inventoried approximately 17,415 (10 percent) of the 185,586 acre Luna planning area to current 

professional standards. An additional 50,638 acres have been inventoried within the Luna 

planning area; these inventories do not meet current standards. 

For the Gila National Forest and the Southwest Region (Region 3) of the Forest Service, a 

cultural resource site is defined as “a locus (location) of purposeful human activity which has 
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resulted in a deposit of cultural material beyond one or a few accidentally lost artifacts” (USDA 

Forest Service, Southwestern Region 1987). In practical terms, cultural resource sites include 

such entities as prehistoric surface structures (pueblos); concentrations of broken pottery sherds, 

stone tool waste flakes, grinding implements, or a combination of these things; or the remains of 

historic structures or mines. 

The survey endeavors discussed above have recorded 513 heritage resource sites within the 

planning area. No properties listed in the National Register of Historic Places are located within 

the Luna planning area. About 209 sites located in the planning area have been determined to be 

eligible for inclusion in the National Register of Historic Places, about 37 sites have been 

determined to be not eligible. About 278 sites remain unevaluated and will require further study 

before a formal determination of eligibility for inclusion in the National Register of Historic 

Places can be made. For this project, only sites considered eligible for inclusion in the National 

Register of Historic Places, and those sites whose eligibility is undetermined, will require 

treatments to protect them from potentially adverse effects associated with project activities.

Analysis

The National Environmental Policy Act analysis considers only the change to the existing 

condition. Changes include proposals for vegetation treatment through mechanical means, hand 

thinning, prescribed burning, herbicide application, or a combination of these treatments. Other 

treatments include the construction of temporary roads; the decommissioning of roads; the 

construction, installation, or both of various range management features (wells, fences, storage 

tanks, etc.); and watershed improvement activities (construction of hardened crossings, erosion 

control features, riparian exclosure areas, etc.).

For the intent of the current analyses, the area of potential effect for the Luna planning area 

environmental analysis is considered to be those areas where:

• heavy equipment will be used to implement project activities (vegetation thinning, 

watershed restoration treatments, range management treatments, treatments to the 

transportation system, etc.); 

• there is a high probability of site location for prescribed burning activities (if these areas 

fall outside of those where heavy machinery will be used during implementation); 

• there is a high probability of site location for areas to be opened up for personal fuelwood 

collection (if these areas are greater than 500 acres in size); or 

• there is a high probability of site location for other methods of herbicide application (with 

hand pumps, spread from back of all-terrain and utility task vehicles, etc.).

Gila National Forest personnel believe this area of potential effect adequately measures and 

addresses the potential direct, indirect, and cumulative effects of the proposed undertakings and 

are in agreement with those identified section I, appendix J, of the Region 3 first amended 

programmatic agreement (USDA Forest Service, Region 3 2010).

Relative Risk Analysis

This report uses a relative risk analysis to compare alternatives. Relative risk is considered the 

potential impact that can result from one action (alternative) measured against the potential 

impact that might result from a different action (alternative).
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For cultural resources, the measure for direct and indirect effects for all actions will be based on 

the total survey acres needed by different proposed project activities. Since only 10 percent of 

the Luna planning area has been intensively surveyed, simply using the number of sites 

potentially affected by undertakings would leave vast areas of the planning area unaccounted for. 

However, the number of known sites is positively correlated with the miles or acreage of survey, 

as one increases so does the other. Therefore, the alternatives proposing more miles or acres per 

action will pose a higher risk of direct and indirect effects to cultural resources. Conversely, 

those posing fewer miles or acres per action will pose a lower risk of these effects.

Background Assumptions

Only 25 percent of 6th code watershed will be treated within a three-year period. While this 

stipulation is posed in efforts to lessen direct, indirect, and cumulative effects to watersheds, it 

provides a maximum amount of work that can be conducted within each 6th code watershed 

within a three-year span. This stipulation also allows for areas to be monitored for treatment 

effects to resources and lessen the potential for adverse cumulative effects to various program 

resources.

We assume all areas listed within a particular treatment category (for example, grassland 

maintenance and restoration, group select commercial and noncommercial thinning, 

woodland/ponderosa pine transition maintenance and restoration vegetation treatments; 

decommissioning of roads; pipeline installation; etc.) will receive treatments. This assumption is 

made due to uncertainties concerning local conditions within the larger planning area. Thus 

while an area may be listed to receive group select commercial and noncommercial thinning, 

local conditions may not favor these activities across the entire proposed treatment area.

Measures

The measure for determining the relative risk of different alternatives is the total acres of 

archaeological survey needed for different activities associated with the different proposed 

alternatives. Over much of the larger Luna planning area, there is general correlation between the 

proportion of an area that has been covered by intensive cultural survey and the proportion of 

known sites within the planning area. ArcGIS was used to determine how many acres of 

inventory were needed for the different alternatives.

Environmental Consequences

Alternative A

No activities would be implemented under this alternative, therefore no acres of archaeological 

inventory are required and therefore no relative risk of potential impact to sites.

The main concern with respect to heritage resources under the no-action alternative is the 

potential for high-severity wildfire to affect deposits associated with archaeological sites within 

the proposed project area. Under this alternative, fuel loads within the project area would be 

allowed to accumulate, increasing the severity and duration of fires that may spread into the area. 

These concerns are potentially exacerbated if one considers the possibility of increased fire 

susceptibility brought about by disease and deterioration which could occur if treatments are not 

implemented in the project area. If a wildland fire does not spread into the area, these concerns 

could still adversely affect heritage resources as trees within site boundaries are more prone to 

decay, uprooting, partially collapsing on or within deposits, or a combination of these things. 
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Similarly, poorly functioning watershed in the planning area are more prone to severe erosion 

episodes. Such episodes have the potential to adversely affect heritage resources due to arroyo 

head-cutting and channel cut-bank scouring. These effects will be allowed to continue under the 

no-action alternative. In short, the no-action alternative increases the probability heritage 

resources will be adversely affected in the foreseeable future.

Effects Common to Alternatives B, C, and D

Amount of Archaeological Inventory Needed per Alternative

In general, all action alternatives will require extensive survey for heritage resources and most

proposed activities are common to all action alternatives. All areas where heavy machinery will 

be used in project implementation will require 100 percent intensive inventory. Mechanical 

treatments shared by all action alternatives include roughly 73,856 acres of mechanical 

vegetation treatments. The following acres may require heavy machinery for implementation: 

• approximately 344 acres of range management treatments 

• roughly 1,354 acres of treatments to the transportation system 

• in excess of 1,000 acres of watershed restoration treatments 

The implementation of treatments using traditional hand tools may require additional inventory 

especially if these activities require substantial ground disturbance (for example, construction of 

prescribed fire control line, construction of fence lines, etc.) or if they are located in areas 

determined to contain a high probability for archaeological site location. Hand thinning of 

vegetation may require additional inventory if heavy machinery (for example, skidder, 

masticator, etc.) will be used afterwards to treat activity fuels. Approximately 25,400 acres of 

grassland and portions of Mexican spotted owl protected activity centers may be treated by hand 

thinning. Likewise, areas that are to be burned by prescription will require inventory if these 

locales are determined to contain a high probability of site location and if these areas were not 

inventoried previously for other treatments. Roughly 36,000 acres in all action alternatives are 

planned to be treated solely by prescribed burning. An additional 70,000 to 100,000 acres will be 

burned by prescription following mechanized treatments in all action alternatives. 

The amount of survey needed for the implementation of the different action alternatives is the 

same with respect to the proposed treatments. The main difference between action alternatives is 

the potential for additional inventory to implement the treatment of vegetation by the application 

of herbicide as proposed in alternative C. In alternative C, there is the potential need to survey 

areas where herbicide will be applied if these areas are determined to contain a high probability 

of site location. At present, areas where herbicide may potentially be applied cover an area of 

roughly 43,000 acres. Within this approximately 43,000 acre area, roughly 28,000 acres have 

been determined to be high site probability areas. Under alternatives B and D, roughly 20,283 

acres of grassland will be mowed to treat rabbitbrush. These treatments may require additional 

inventory depending on the type of equipment used during implementation. Alternative C may 

actually require only 8,000 more acres of inventory for areas where herbicide will be applied to 

treat juniper encroachment than alternatives B and D. However, this depends on where 

implementation will occur within the larger 43,000 acre potential herbicide treatment area. 

Under alternatives B and C, roughly 13.8 miles of level 1 closed roads will be reopened to all 

motor vehicles types, roughly four miles of user-created roads will be designated as National 
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Forest System roads and opened to all motor vehicle use, and roughly a half a mile of 4x4 trail 

will be constructed. These changes are not proposed under alternative D. However, under 

alternative D, the 13.8 miles of level 1 closed roads that are proposed to be reopened under 

alternatives B and C will be decommissioned. Under these circumstances, alternative D may 

require an additional 167 acres of inventory for the additional 13.8 miles of road. However, 

maintenance work may need to be conducted along these road sections that will be reopened 

under alternatives B and C to make them operable. Thus, the discrepancies with respect to 

treatments to the transportation system under all action alternatives amount to negligible changes 

in the amount of inventory needed prior to implementation. 

Direct Effects

Direct effects to heritage resources associated with the proposed undertakings under all action 

alternatives include those brought about ground-disturbing activities, those potentially associated 

with the increased visibility of archaeological sites on the landscape, and those potentially 

associated with the introduction of either prescribed fire or riparian woody species within the 

planning area. These activities all have the potential to adversely affect deposits associated with 

heritage resources.

To mitigate the effects associated with the proposed undertakings heritage resources within the 

different project areas, such things as flagging may be utilized to avoid sites or other alternative 

methods depending on the activity being performed. In most instances, avoidance of sites will be 

the preferred mitigation measure. However, in certain circumstances like vegetation thinning and 

the prescribed burning of areas, other measures may be implemented, such as hand thinning of 

vegetation within archaeological sites following mechanized treatments or removing additional 

fuels from archaeological sites. This will increase the likelihood that treatment measures will 

attain the desired outcome. This is particularly true for areas where high site densities are 

avoided. This will increase the likelihood that prescribed fire treatments will not adversely affect 

heritage resources. Hand treatments (for example, cutting rabbitbrush, herbicide application, and 

other similar activities) would pose no adverse effect to heritage resources.

In the event new heritage resources are discovered during the implementation of any of the 

activities outlined above, work would cease in the area and a Forest Service archaeologist 

notified as to its presence. Work may resume in the area surrounding the newly identified 

archaeological site once appropriate treatment measures have been identified and consulted 

upon. 

Indirect Effects

The primary indirect effects associated with proposed undertakings with respect to heritage 

resources are the potential for increased erosion rates within or near heritage resources resulting 

from the loss of canopy and ground cover; the increased visibility of archaeological sites during 

and after treatment implementation which could lead to increased looting; and the potential for 

increased cattle grazing within archaeological sites due to changes in vegetation communities 

and ground cover. However, because the proposed action stipulates activities will be conducted 

in stages (for example, in units or individual stands within units), the indirect effects of previous 

treatments can be monitored to determine if heritage resources are being adversely impacted.

Cumulative Effects

As stated above, cumulative effects refer to the impact of an action on the environment which 

results from the incremental impact of the action when added to other past, present, and 
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reasonably foreseeable future actions. Since the National Historic Preservation Act was fully 

implemented in the 1970s, cultural resource surveys have been conducted and potential effects to 

cultural resources addressed through consultation between the Gila National Forest staff, State 

Historic Preservation Officer, the Tribes, Advisory Council on Historic Preservation personnel, 

and interested members of the public. Future projects occurring on National Forest System lands 

will require appropriate compliance with National Historic Preservation Act including cultural 

resources inventories and evaluation of effects of the undertaking. If effects are identified, they 

will be addressed under the section 106 process of the act. Adverse effects will be minimized 

through avoidance or mitigation measures, as appropriate. 

To date, approximately 400 previous projects have been conducted within the planning area and 

cover a variety of resource areas (for example, engineering, timber, range, heritage, recreation, 

etc.). Those that have been conducted within the past five years have dealt with impacts

associated with the Wallow Fire of 2011 (for example, hazard tree salvage sales, prescribed 

burning of hazardous fuel loads, etc.), those associated with implementation of the Travel 

Management Rule, and those seeking to improve the rangeland management infrastructure (for 

example, water systems, tank cleaning, etc.). At present, the only projects slated for the 

foreseeable future are those proposed as part of the current landscape restoration proposal. 

Implementation of the proposed treatments, combined with past, present, and reasonably 

foreseeable activities is not expected to negatively impact heritage resources within the project 

area. The greatest potential for cumulative impacts to heritage resources in the area come from 

the potential for increased erosion rates associated with decreased canopy and ground cover. 

However, archaeological sites in the larger Mogollon area are, more often than not, located on 

stable landforms which do not experience sediment transfer rates greater than five tons per acre 

per year regardless of the canopy, ground cover conditions, or both (Toney 2012; Toney and 

Taliaferro 2008). This value (five tons per acre per year) was that determined to be the extreme 

erosion rate based on Z-score values for areas on the Gila National Forest and surrounding lands 

(Toney 2012; Toney and Taliaferro 2008). The majority of heritage resources tend to be located 

on landforms that experience less than this amount of erosion in a year. 

Beneficial Effects

As stated in the analysis of effects associated with the no-action alternative (alternative A), if 

current conditions are allowed to continue, heritage resources stand a greater chance of being 

adversely affected by severe erosion episodes as well as wildland fire. The proposed treatments 

will mitigate the possibility of a catastrophic wildland fire affecting heritage resources and the 

proposed watershed restoration treatments will lessen the probability that heritage resources are 

adversely affected by arroyo head cutting and stream channel scouring within the treatment 

areas. Similarly, the changes to the transportation system will decrease the probability that 

motorized travel will impact heritage resources due to the fact that more miles of road are slated 

for decommissioning than are being added to the road system.

Effects of Climate Change on Cultural Resources

The Intergovernmental Panel on Climate Change posits that if emission of greenhouse gasses 

(for example, carbon dioxide, methane, nitrous oxide, etc.) continues along its current trajectory, 

that global temperatures will continue to rise (IPCC 2014). This will lead to a decrease in cold 

temperature extremes, an increase in warm temperature extremes, an increase in extreme high 

sea levels, and an increase in the number of heavy precipitation events in some regions of the 

world. In some portions of the world, heat waves are expected to increase in frequency and 
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duration and precipitation events are expected to increase in intensity though will become 

sporadic in their frequency of occurrence (IPCC 2014). All of these general trends have the 

potential to adversely affect heritage resources in the planning area. 

Perhaps the greatest threat that climate change poses to heritage resources is the increased threat 

of erosion. As temperatures rise, vegetation communities are likely to be affected. Elevational 

shifts in vegetation communities, extreme fire events, or both could lead to reduced canopy 

cover available to intercept precipitation and reduce raindrop impact energies and loss of 

vegetative ground cover (basal area plus litter). This loss of vegetative ground cover combined 

with more of the precipitation falling in higher intensity storms increases the risk of erosion. This 

erosion risk can lead to increased sediment delivery to stream channels and potentially altered 

flow regimes and stream channel dynamics such as degradation (downcutting) or aggradation. 

Channel downcutting events, increased arroyo formation, and shifts in stream channel dimension 

or location have the potential to destroy or damage heritage resources located in the Luna 

planning area. 

Social and Economics 

Affected Environment

The Luna Restoration Project is located entirely within Catron County. The main community 

within the planning area is Luna, New Mexico, a non-incorporated area of Catron County with a 

population of 158 (U.S. Census Bureau 2010). The project is adjacent to Apache and Greenlee 

Counties in Arizona along the state line. These three counties form the social and economic 

analysis area. County-level data are used for the analysis, since reliable demographic and 

economic data are readily available. 

Population and Demographics

Each of the counties have experienced positive population growth between 2000 and 2015. 

Catron County had the smallest estimated change of 1.1 percent over that period compared to 

Apache County at 3.9 percent and Greenlee County, 5.6 percent. But all are far below the 

national growth of 12.5 percent (U.S. Department of Commerce 2016, Economic Profile System 

2017). 

The median age of the population in Catron County and the community of Luna is 

approximately 57. The median age of the population in Catron County is much older compared 

to the other two Arizona counties (median age 33), both states (median age 37), and the nation 

(median age 37) (U.S. Department of Commerce 2016, Economic Profile System 2017). 

The racial and ethnic composition of the study area offers context for the social analysis. Table 

64 shows the racial and ethnic breakdown of the counties and their respective states. The 

majority of the residents self-identify as white in Catron and Greenlee Counties. Apache County 

differs with having a higher percentage of American Indians than the others. Greenlee County 

almost half of their population self-identified as Hispanic or Latino. Racial identification within 

Catron and Greenlee Counties are similar, but for ethnic composition Catron and Apache 

Counties had similar trends. 

Compared to state information, different ethnic and racial compositions of the counties varied 

from state percentages. Noticeable differences between each of the states and their respective 
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counties are the variability of the ethnic breakdowns and the difference in percent population in 

White and American Indian populations across the analysis area. 

Table 64. Racial and ethnic breakdown of counties within the analysis area 

Area

Ethnicity 

NonHispanic

Ethnicity 

Hispanic

Race 

White

Race 

African 

American

Race 

American 

Indian

Race 

Asian 

Pacific 

Islander

Race 

Other

Catron County 82% 18% 96% <1% <1% 0% 1%

Greenlee 

County

53% 47% 89% 2% 4% <1% 1%

Apache County 94% 6% 23% 1% 72% <1% 2%

New Mexico 52% 48% 39% 2% 9% 1% 2%

Arizona 70% 31% 56% 4% 4% 3% 2%

Note: Ethnicity relates to identification as either Hispanic/Latino or not. Hispanic/Latino individuals may identify as any 

members of any racial groups. The “Other” group includes two or more races.

Sources: U.S. Department of Commerce 2016, Economic Profile System 2017a

Lifestyles, Values, Beliefs, and Attitudes

Firewood gathering on the Gila National Forest is particularly tied to livelihoods in some of the 

communities. Wood for fires continues to be widely used either aesthetically or as the primary 

heat source within homes. Approximately 46 percent of the housing units in Catron County rely 

on wood as their primary heat source (U.S. Census Bureau 2000). In comparison, the community 

of Luna, New Mexico within Catron County estimates 60 percent of the housing units rely upon 

wood (U.S. Census Bureau 2006-2010 American Community Survey). Apache County also has 

a high reliance of wood as heat source at 50 percent. In contrast, Greenlee County reports more 

than 75 percent of the housing units rely on utility gas as primary heat source (U.S. Census 

Bureau 2000). The use of wood for heating homes may be tied to long-term customs, traditions, 

and culture of the community. 

The Gila National Forest is currently undergoing forest plan revision. Participants relayed 

concerns regarding the forest and natural resource management (USDA Forest Service 2017): 

• there is a desire for the maintenance of quality recreational experiences

• there is wide recognition of the overgrown conditions of many of the forest types and 

juniper encroachment of the grasslands

• there is concern about the increased risk of uncharacteristic wildfire, and threats to 

private property and adjacent communities 

• there is broad interest in fuel management strategies such as thinning and prescribed fire 

• many people would like to see more timber harvesting and grazing to support local 

economies 

• there is concern about diminishing water supplies and water quality, and conditions of 

the forest, wildlife habitat and watershed health 

Employment and Income

Per capita income in the study area is lower than the per capita income per state and nation. 

Apache County has the lowest per capita income compared to other two counties (table 65). 
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Table 65. Per capita income and percentage of labor or non-labor source and unemployment for 

counties in the analysis area, state, and nation

Geographic Area

Per Capita 

Income (2015 

Dollars) Labor (2015)

Non-Labor 

(2015)

Unemployment 

(2016)

Catron County $20,685 38% 62% 8.2%

Greenlee County $21,994 77% 23% 7.6%

Apache County $13,011 62% 38% 11.3%

New Mexico $24,012 75% 25% 5.3%

Arizona $25,848 75% 25% 6.7%

United States $28,930 78% 22% 4.9%

Source: Economic Profile System 2017a

The percentage of people below the poverty level in Catron County is 17 percent, which is less 

than the New Mexico level of 21 percent. Poverty level in Greenlee County is 14 percent and 

Apache County 37 percent, with Arizona being at 18 percent. Apache County has the highest 

percentage of people below the poverty line. Catron and Greenlee Counties are comparable to 

the national level of 16 percent (table 66). 

Table 66. Median household income and percentage of persons in poverty in 2015 

Geographic Area Median Household Income

Percentage of persons below 

poverty line

Catron County $42,973 17%

Greenlee County $51,628 14%

Apache County $31,757 37%

New Mexico $44,963 21%

Arizona $50,255 18%

United States $53,889 16%

Sources: U.S. Department of Commerce 2016; Economic Profile System 2017a

Forest Products Related Employment

According to the Gila National Forest Assessment Report (USDA Forest Service 2017): 

“...the mill in Reserve, New Mexico employs eight people at the mill and up to ten 

people on timber sales. There are also approximately five active smaller mills that 

purchase timber to produce rough cut lumber and other forest products on a limited scale 

and at least seven fuelwood businesses based upon sales of permits. The number of 

employees in these businesses is not known and many may be self-employed businesses 

with no paid employees. In 2013, timber-related jobs accounted for less than one percent 

of private sector employment within the four counties: Catron, Sierra, Grant and

Hidalgo; that the Forest is situated (Headwaters Economics 2016). Catron County has 

the largest percent of the total timber-related employment due to the number of permits 

sold and the location of these businesses.”

Employment in timber related jobs for 2015 (U.S. Dept. of Commerce 2017, Economic Profile 

System 2017b) in Catron County was approximately 3.5 percent of the total private employment 

and 1.3 percent in Apache County. No timber-related employment comprised private 

employment in Greenlee County. 
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Environmental Consequences

Alternative A

There would be no change in management within the planning area. Fuelwood gathering would 

still be allowed, access on the current motorized road and trail transportation system would 

continue. However, no restoration projects would occur. If a high-severity wildfire were to occur 

in the area, there is a potential for temporary impacts to recreational uses or enjoyments such as 

hunting, scenery or visual conditions. Smoke emissions generated would be greater and 

unplanned, causing impacts to those sensitive to smoke. Damage to infrastructure such as power 

lines, communication systems, etc. within the planning area as well as property damage could 

result in substantial costs for repair, replacement, or restoration.

With no proposed vegetation treatments, there would be no opportunity generated for economic 

benefit to local contractors or industries and employment associated with timber or other forest 

products that could be contracted. This lack of opportunity would be the same for not 

implementing any of proposed treatments.

Cumulative Effects

There are no activities being implemented under alternative A, current activities (for example, 

grazing, hunting, hiking) would continue. There are currently no other management activities 

within the planning area that would improve forest and watershed health relative to existing 

conditions. The Apache-Sitgreaves National Forests is currently implementing the West 

Escudilla Project which includes vegetation management projects, prescribed burning, and other 

restoration activities. Since alternative A would not prescribe additional treatments, it would not 

cause cumulative effects related to smoke emissions from prescribed fire. However, the risk of 

uncharacteristic wildfire and associated smoke emissions would be highest under this alternative. 

Effects Common to Alternatives B, C, and D

The supply and demand for timber is driven by regional and national needs and markets. 

Demand for woody material is largely driven by fuelwood needs and other local demand for 

woody material for rough cut lumber, fuelwood, and other specialty products from local mills. 

With approximately 74,000 acres of forest and woodland to be treated, the Forest would be able 

to contribute to the demand for forest products and needs of local mills located in or adjacent to 

the planning area. There is the potential for economic benefit to local contractors or industries 

and increased employment associated with timber or other forest products that could be 

contracted. 

The range of projects to be implemented under all action alternatives of the Luna Restoration 

Project have the potential for providing various employment and economic opportunities for 

local individuals, contractors, or industries. 

Activities such as herbicide utilization under alternative C, smoke from prescribed fires, 

increased vehicle traffic on roads, and increased noise from equipment and vehicles have the 

potential for social consequences. Activities would be periodic and occurring across differing 

locations across the planning area. This may prevent individuals from partaking in various 

outdoor activities or recreating in their favorite places and may be displaced for short periods 

and may have less pleasure in their alternate locations. 
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Under alternative D, there would be a loss of motorized recreational opportunity compared to 

alternatives B and C. Alternative D does not add to the motorized transportation system closed 

and user-created routes that would provide loop and access in and around the community of 

Luna. This would not be favorable for members of the community who collaboratively worked 

with the Forest Service to identify these routes.

Environmental Justice

The goal of environmental justice is for agency decision makers to identify impacts that are 

disproportionately high and adverse with respect to minority and low-income populations and 

identify alternatives that will avoid or mitigate those impacts. None of the alternatives would 

reduce employment and income relative to current conditions, therefore, no disproportionate 

adverse economic effects would occur. 

Smoke emissions from prescribed fire or wildfire can have health and quality of life 

consequences and is most likely to affect vulnerable populations – children, the elderly, and 

individuals with health or respiratory issues. The intensity and duration of emissions are variable, 

but prescribed fires follow a written prescription which allows managers to minimize smoke 

impacts. The Forest Service is also required to work with the State Air Quality Department to 

ensure smoke impacts to human health are avoided or minimized. The advance notice associated 

with prescribed burns allows individuals with sensitivity to smoke to engage in averting 

behavior, reducing the negative quality of life impacts. 

Households that rely upon fuelwood as their primary heat source would be able to continue to 

collect fuelwood and with vegetation treatments, the opportunity for additional sources may be 

realized. None of the alternatives are expected to adversely affect low-income families who 

depend on fuelwood.

Forest Plan Amendments

The amendments to exceed acres per decade to treat activity fuels with prescribed fire; wildlife 

habitat improvement structures and acres; vegetation treatments in Mexican spotted owl habitat 

would have both negative and beneficial impacts on social and economic considerations and 

environmental justice. The ability to treat more acres of activity fuels with prescribed fire will 

contribute to negative impacts of smoke emissions on social and environmental justice 

considerations but would contribute to the associated vegetation treatments by reducing the risk 

of wildfire. The amount and type of restoration activities and employment and income would not 

change from previously described under alternatives. Amendments would assist in 

accomplishing restoration efforts across the landscape. 

Cumulative Effects

Within the planning area, current activities (for example, grazing, hunting, and hiking) would 

continue. There are no other ongoing vegetation or prescribed burning activities within the Luna 

planning area, but restoration efforts within the larger Escudilla Landscape have started on the 

Apache-Sitgreaves National Forests with implementation of the West Escudilla Project. There is 

a potential for increase in employment and income, but it is not expected to significantly change 

the current percentages of forest product related employments in the three counties.

Ongoing prescribed fires from the Apache-Sitgreaves National Forests and Luna Restoration 

Project will contribute to smoke emissions, potentially affecting the health and quality of life of 
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individuals who live near or visit the Gila National Forest. Together, both could cause 

cumulative effects to health and quality of life for individuals who are sensitive to smoke. 

However, the cumulative effect of these treatments would go toward decreasing the risk of a 

wildfire, decreasing the impacts of smoke emissions from that type of event.

Short-term Uses and Long-term Productivity 

The National Environmental Policy Act requires consideration of “the relationship between 

short-term uses of man’s environment and the maintenance and enhancement of long-term 

productivity” (40 CFR 1502.16). As declared by the Congress, this includes using all practicable 

means and measures, including financial and technical assistance, in a manner calculated to 

foster and promote the general welfare, to create and maintain conditions under which man and 

nature can exist in productive harmony, and fulfill the social, economic, and other requirements 

of present and future generations of Americans (National Environmental Policy Act section 101). 

The implementation of any of the treatments within the action alternatives does not jeopardize 

the long-term productivity of the Gila National Forest. As described in chapter 3, implementing 

the action alternatives would improve forest and woodland stands health and improve wildlife 

habitat, including habitat for threatened, endangered, and sensitive species. There would be 

reduction in the risk of large uncharacteristic wildfires and its impacts to the landscape, 

watersheds, species, and human health and quality of life. As described throughout chapter 3, the 

overall implementation of the action alternatives would improve resources such as range 

condition, wildlife and aquatic habitat, soil conditions, and others. Actions like erosion control 

and reducing risk of wildfire would reduce impacts to sensitive resources like water quality, 

cultural resources, and air quality. 

Unavoidable Adverse Effects

For all action alternatives, smoke emissions are an unavoidable adverse impacts that have the 

potential to affect health and quality of life for individuals who are sensitive to smoke. The 

potential impacts of smoke are addressed in the “Air Quality”, “Recreation”, and “Social and 

Economics” sections. The adverse effect would be reduced or minimized with the Gila National 

Forest personnel following written prescriptions for prescribed fires, working with State Air 

Quality Departments, and advance notice, allowing individuals with sensitivity to smoke to 

engage in averting behavior, to reduce the negative impacts of smoke. 

There is a risk of introduction, establishment and spread of invasive plants to new locations with 

ground disturbing activities with mechanical equipment, prescribed fires, and adding new 

motorized routes. Implementation of design features and monitoring were included to reduce this 

risk.

Adding motorized routes to the system may cause a loss of soil productivity under all 

alternatives. Alternative B and C with 13.8 miles of roads being added to the system will result 

in more bare ground than alternative D, which adds 0.2 miles. There will be a loss of soil 

productivity in varying degrees and time for the other motorized transportation activities like 

temporary roads, reopening roads and then closing again, and decommissioning. 
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Irreversible and Irretrievable Commitments of Resources 

Irreversible commitments of resources are those that cannot be regained, such as the extinction 

of a species or the removal of mined ore. Irretrievable commitments are those lost for a period of 

time, such as the temporary loss of timber productivity in forested areas that are kept clear for 

use as a power line rights-of-way or road. 

All resources were evaluated to determine if there would be irreversible or irretrievable 

commitment of resources. Except for following resources, no other resources identified 

irreversible or irretrievable commitments.

Watershed and Soils

Alternative A already possesses an intrinsic commitment of the soil resource from closed roads 

that are not decommissioned. Continuation of closed roads, without attempts to decommission 

would allow this commitment to continue, with little possibility of soil conditions returning to 

their natural state. 

The selection of any of the action alternatives allows for decommissioning of between 114 and 

130 miles of travel routes which would aid in reversing and retrieving soil resource conditions. 

Time frames for recovery will vary, dependent on type of decommissioning implemented and 

site conditions, including parent material, soil depth, available nutrients, climatic conditions, and 

herbaceous recovery. 

The addition of roads for administrative and recreation opportunities range from 4.2 to 17.8 

miles for the action alternatives. Impacts to soil conditions on these miles would result in 

additional area of irreversible and irretrievable commitment of soil resources.

Heritage

There is a relatively low risk of irreversible commitment of heritage resources across all action 

alternatives. This risk of irreversible commitment primarily arises from the potential for ground 

disturbing activities to completely destroy archaeological sites. In general, this risk of 

irreversible commitment of resources is the same across all action alternatives as they essentially 

share similar proposed ground disturbing activities. 

Inventoried Roadless Areas

Irreversible or irretrievable commitments of roadless resources could occur under alternative A. 

In the event of a wildfire due to continuing existing stand conditions (crown fire potential), the 

roadless resources could be at risk to irretrievable outcomes including species and habitat loss 

until vegetation becomes established. Special features, such as perennial water sources, could be 

affected by post fire erosion and debris flows. There are no irreversible commitments. 

There would be no irreversible or irretrievable commitments to roadless resources with action

alternatives B, C, or D. The likelihood of severe wildfire and the associated impacts would be 

reduced in the treated areas, lowering the risk of an irretrievable effect.
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Preparers and Contributors

List of Preparers

T. H. Buhl – Fire Management Specialist, USDA Forest Service, Enterprise Program. 

Education: Undergraduate education in Fire Technology, American River College and Range 

Science, Montana State University. Experience: Fire Management Specialist (2009 to present) 

Enterprise Program; Assistant Fire Management Officer (2006-2009). Other Forest Service 

experience includes fire operations positions on national forests in Region 1 and Region 2 (2000-

2006) and Timber and Range Management (1998-2000). 

Ralph Fink - District Range Staff, USDA Forest Service, Quemado Ranger District, Gila 

National Forest. Education: B.S. Secondary Education, Natural Sciences from Chadron State 

College and M.S Range Science, Plant Systematics and Floristics from New Mexico State 

University. New Mexico Licensed Pesticide Applicator. Experience: 10 years as a Forest Service

Range Management Specialist in Southern New Mexico, Forest Botanist (1 year) and District 

Range Staff (2016 to present).

David Fothergill – Forest Landscape Architect, USDA Forest Service, Enterprise Program. 

Education: B.S. Biology, University of Kentucky; Master of Landscape Architecture, University 

of Oregon. Experience: 15 years public land management in recreation planning and ecological 

restoration. 

Kathleen Hawkos – GIS Specialist, USDA Forest Service, Gila National Forest. Education: 

M.S. Geography with emphasis in GIS. Experience: Technical background in GIS spatial 

analysis, special management areas needs assessments, ABV survey; GIS data collection, 

organization, maintenance and distribution; GIS and Infrared Imagery Interpretation for fire 

support; Southwestern Regional cartographic map production and technical support; project lead 

on Quad Atlas production for Southwestern Region forests; development and maintenance of the 

Southwestern Region Motor Vehicle Use Map website. GIS Specialist (2004-2012; 2016 to 

present) and Cartographic specialist (2012-2016) with the Forest Service, Region 3.

Timothy Hendricks – District Wildlife Biologist, USDA Forest Service, Gila National Forest, 

Quemado Ranger District. Education: B.S. Forestry and Wildlife Management with a minor in 

chemistry. Experience: Firefighter (2 years); Fuels Specialist (9 years); Wildlife Biologist (4 

years) working on habitat and endangered species management, species consultation, and NEPA 

projects. 

Emily Irwin – Quemado District Ranger, USDA Forest Service, Gila National Forest, 

Quemado Ranger District. Education: B.S. Forestry Northern Arizona University. Experience: 

30 years of service with the Forest Service in Region 3, with 3 years as the Quemado District 

Ranger. Background in fire and fuels management. 

Carolyn Koury – Hydrologist, USDA Forest Service, Gila National Forest. Education: B.S. 

Speech Communication, Northern Arizona University; M.S. Hydrology, University of Arizona. 

Experience: hydrologist on the Apache-Sitgreaves National Forests (1994-2002); forest 

hydrologist (2002 to present) on the Gila National Forest. 
Preparers, Contributors, and Distribution

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Natalie Morgan – Silviculturist, USDA Forest Service, Enterprise Program. Education: B.S. 

Forest Resource Management and B.A. in Spanish Literature from the University of Montana; 

M.S. Forestry, Northern Arizona University. Experience: 11 years in the Forest Service in 

Regions 1 and 2. Forester trainee (2008-2011); Forester (Silviculture) (2011-2016); Silviculturist 

(2016 to present) with the Enterprise Program. 

Lisa Mizuno – Environmental Coordinator, USDA Forest Service, Gila National Forest. 

Education: B.S. Oceanography with a minor in biology, Humboldt State University; M.S. 

Interdisciplinary degree in fisheries and estuaries, Humboldt State University. Experience: 

fisheries biologist on the Six River (1991 to 1999) and San Bernardino (1999 to 2003) National 

Forests. Interdisciplinary planner and assistant NEPA coordinator (2003 to 2011) and 

environmental coordinator (2011 to present) on the Gila National Forest, assisting, reviewing, 

and team leading various forest projects. 

Michael Natharius – Soil Scientist, USDA Forest Service, Gila National Forest. Education: 

B.S. Agriculture with major in soil science. Experience: terrestrial ecological unit inventory, 

riparian inventory, vegetation inventory and monitoring, burned area emergency response team 

leader and member, and interdisciplinary team specialist. Soil scientist (1991 to present) with the 

Forest Service, Region 3.

Rex A. Null – Civil Engineer, USDA Forest Service, Gila National Forest. Education: B.S. 

Civil Engineering, New Mexico State University. Experience: project manager for Burn 

Construction (2 years) and Civil Engineer (1991 to present) on the Gila National Forest. 

Matthew Taliaferro - Archaeologist USDA Forest Service, Gila National Forest. Education: 

B.A. Anthropology; M.A. Anthropology; Ph.D. Anthropology. Experience: 15 years of Section 

106 and 110 CRM work in the southern United States, geographic information sciences, peerreview process, lithic analysis, ceramic analysis. Archaeologist (2010 to present) with the Forest 

Service.

List of Contributors 

Jason Cress – Fuels, USDA Forest Service, Tonto National Forest (Formerly Gila National 

Forest, Quemado Ranger District).

Colleen Nicholas – District Archaeologist, USDA Forest Service, Gila National Forest, 

Reserve and Quemado Ranger Districts

Brian Park – GIS Coordinator, USDA Forest Service, Gila National Forest.

Gabe Partido – Timber and Fuels Program Manager, USDA Forest Service, Gila National 

Forest. 

Laura Vallejos – Resource Forester, Silviculturalist, USDA Forest Service, Gila National 

Forest.

Roger A. Williams - District Natural Resource Officer, USDA Forest Service, Gila National 

Forest, Quemado Ranger District. 

Wayne Witty – Range Technician, USDA Forest Service, Malheur National Forest (formerly 

Range Management Specialist, Gila National Forest, Quemado Ranger District).
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The Forest Service consulted the following Federal, State, and local agencies, tribes and other 

organizations during the development of this environmental impact statement: 

Federal, State, and Local Agencies 

Apache-Sitgreaves National Forests

Bureau of Land Management, Socorro Field Office

Catron County Commission, County Manager, and Emergency Manager

New Mexico Department of Game and Fish

New Mexico Environmental Department 

New Mexico State Forestry Division

U.S. Fish and Wildlife Service 

Tribes 

Alamo Navajo Chapter

Fort Sill Apache Tribe

Mescalero Apache Tribe

Pueblo of Acoma

Pueblo of Laguna

Pueblo of Zuni

Ramah Navajo Chapter

The Hopi Tribe

The Navajo Nation

San Carlos Apache Tribe

White Mountain Apache Tribe

Ysleta Del Sur Pueblo

Others 

Luna Irrigation Ditch Association

Luna OHV Riders
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Distribution of the Environmental Impact 

Statement

This draft environmental impact statement has been distributed to individuals who specifically 

requested a copy of the document and those who submitted comments during scoping. The draft 

environmental impact statement is available on the worldwide web at Luna Restoration Project

and available for review at the Quemado Ranger District office. In addition, copies have been 

sent or provided electronically to the following Federal agencies, federally recognized Tribes, 

State and local governments, and organizations representing a wide range of views: 

Advisory Council on Historic Preservation 

Alamo Navajo Chapter

Apache-Sitgreaves National Forests

Bureau of Land Management 

Catron County 

Center for Biological Diversity

Ecological Restoration Institute

Federal Aviation Administration

Federal Highway Administration

Fort Sill Apache Tribe

Mescalero Apache Tribe

New Mexico Department of Agriculture

New Mexico Department of Game and Fish

New Mexico Department of Transportation

New Mexico Environmental Department 

New Mexico Environmental Department, 

Air Quality Bureau

New Mexico Environmental Department, 

Surface Water Quality Bureau

New Mexico Farm and Livestock Bureau

New Mexico State Forestry Division

New Mexico Wilderness Alliance

NOAA Fisheries Service

Pueblo of Acoma

Pueblo of Laguna 

Pueblo of Zuni

Ramah Navajo Chapter

Salado Soil and Water Conservation District

San Carlos Apache Tribe

San Francisco Soil and Water Conservation 

District 

State Historic Preservation Office

The Hopi Tribe

The Nature Conservancy

The Navajo Nation

The Quivera Coalition

U.S. Army Corps of Engineers 

U.S. Coast Guard 

U.S. Department of Energy 

U.S. Department of the Navy, Energy and 

Environmental Readiness Division

U.S. Environmental Protection Agency 

U.S. Fish and Wildlife Service 

USDA APHIS PPD/EAD

USDA National Agricultural Library

USDA Natural Resources Conservation 

Service

USDI Office of Environmental Policy and 

Compliance 

White Mountain Apache Tribe

WildEarth Guardians 

Ysleta Del Sur Pueblo
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Glossary

Administrative use - Authorized motor vehicle use on roads or trails to carry out forest 

management activities. This also includes use by permittees as authorized by permit or written 

authorization to conduct authorized activities.

Decommission - Demolition, dismantling, removal, obliteration, disposal, or a combination of 

these things of a deteriorated or otherwise unneeded asset or component, including necessary 

cleanup work. This action eliminates the deferred maintenance needs for the fixed asset. Portions 

of an asset or component may remain if they do not cause problems nor require maintenance. 

(Financial Health - Common Definitions for Maintenance and Construction Terms, July 22, 

1998). 

Forest Transportation Atlas - A display of the system of roads, trails and airfields of an 

administrative unit. (36 CFR 212.1, Forest Service Manual 7705) 

National forest transportation system - The system of National Forest System roads, National 

Forest System trails, and airfields on National Forest System lands. (36 CFR 212.1, Forest 

Service Manual 7705) newly added to glossary 

Maintenance levels - Defines the level of service provided by, and maintenance required for, a 

specific road, consistent with road management objectives and maintenance criteria. (Forest 

Service Handbook 7709.59, 62.32) 

• Level 1 - These are roads that have been placed in storage between intermittent uses. The 

period of storage must exceed 1 year. Basic custodial maintenance is performed to prevent 

damage to adjacent resources and to perpetuate the road for future resource management

needs. Emphasis is normally given to maintaining drainage facilities and runoff patterns. 

Planned road deterioration may occur at this level. Appropriate traffic management 

strategies are "prohibit" and "eliminate" all traffic. These roads are not shown on motor 

vehicle use maps. Roads receiving level 1 maintenance may be of any type, class, or 

construction standard, and may be managed at any other maintenance level during the time 

they are open for traffic. However, while being maintained at level 1, they are closed to 

vehicular traffic but may be available and suitable for nonmotorized uses. 

• Level 2 - Assigned to roads open for use by high clearance vehicles. Passenger car traffic, 

user comfort, and user convenience are not considerations. Warning signs and traffic 

control devices are not provided with the exception that some signing, such as W-18-1 “No 

Traffic Signs,” may be posted at intersections. Motorists should have no expectations of 

being alerted to potential hazards while driving these roads. Traffic is normally minor, 

usually consisting of one or a combination of administrative, permitted, dispersed 

recreation, or other specialized uses. Log haul may occur at this level. Appropriate traffic 

management strategies are either to: 

♦ discourage or prohibit passenger cars; or 

♦ accept or discourage high clearance vehicles. 

• Level 3 - Assigned to roads open and maintained for travel by a prudent driver in a 

standard passenger car. User comfort and convenience are not considered priorities. The 

Manual on Uniform Traffic Control Devices (MUTCD) is applicable. Warning signs and 
Glossary

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Draft Environmental Impact Statement

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traffic control devices are provided to alert motorists of situations that may violate 

expectations. Roads in this maintenance level are typically low speed with single lanes and 

turnouts. Appropriate traffic management strategies are either "encourage" or "accept." 

"Discourage" or "prohibit" strategies may be employed for certain classes of vehicles or 

users. 

• Level 4 - Assigned to roads that provide a moderate degree of user comfort and 

convenience at moderate travel speeds. Most roads are double lane and aggregate surfaced. 

However, some roads may be single lane. Some roads may be paved and/or dust abated. 

Manual on Uniform Traffic Control Devices is applicable. The most appropriate traffic 

management strategy is "encourage." However, the "prohibit" strategy may apply to 

specific classes of vehicles or users at certain times. 

• Level 5 - Assigned to roads that provide a high degree of user comfort and convenience. 

These roads are normally double lane, paved facilities. Some may be aggregate surfaced 

and dust abated. Manual on Uniform Traffic Control Devices is applicable. The appropriate 

traffic management strategy is "encourage." 

Motor vehicle - Any vehicle that is self-propelled, other than: (1) A vehicle operated on rails; 

and (2) Any wheelchair or mobility device, including one that is battery-powered, that is designed 

solely for use by a mobility-impaired person for locomotion, and that is suitable for use in an 

indoor pedestrian area. (36 CFR 212.1, 36 CFR 261.2, Forest Service Manual 7705, Forest 

Service Handbook 2309.18.05) 

National Forest System road (NFSR) - A forest road other than a road which has been 

authorized by a legally documented right-of-way held by a State, County or other local public 

road authority. (36 CFR 212.1, 36 CFR 251.51, 36 CFR 261.2, Forest Service Manual 7705, 

Forest Service Handbook 7709.56.40.5) newly added to glossary 

Road decommissioning (1) - Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state. (36 CFR 212.1) 

Road decommissioning (2) - Activities that result in restoration of unneeded roads to a more 

natural state. (Forest Service Manual 7705, Forest Service Manual 7734) 

Temporary road or trail - A road or trail necessary for emergency operations or authorized by 

contract, permit, lease, or other written authorization that is not a forest road or trail and that is 

not included in a forest transportation atlas. (36 CFR 212.1, Forest Service Manual 7705) 

Unauthorized road or trail - A road or trail that is not a forest road or trail or a temporary road 

or trail and that is not included in a forest transportation atlas. (36 CFR 212.1, Forest Service 

Manual 2353.05, Forest Service Manual 7705) 

Written authorization - A written document that authorizes specific activities; may be a permit, 

letter or other written document. 
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Draft Environmental Impact Statement

175

References

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electronic ed.

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Federal Regulations, Part 218. 2018 electronic ed. 

36 CFR 219. “Planning,” Title 36 Code of Federal Regulations, Part 219; Planning, Subpart A; 

National Forest System Land Management Planning, published April 9, 2012 (77 FR 

21162). 2018 electronic ed. 

36 CFR 294. “Special Areas” Title 36 Code of Federal Regulations, Part 294, Special Areas, 

Subpart B, State Petitions for Inventoried Roadless Management Area Management. 2018 

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40 CFR 1501. “NEPA and Agency Planning,” Title 40 Code of Federal Regulations, Part 1501. 

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1502. 2018 electronic ed.

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scientific literature. General Technical Report SRS-39. Asheville, North Carolina: 

U.S.Department of Agriculture, Forest Service, Southern Research Station. 246 p. 

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Economic Profile System. 2017. A Profile of demographics, county region: Catron County, NM; 

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RMRS-GTR-120. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, 

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Hardy, C.C., Schmidt, K.M., Menakis, J.M., Samson, N.R. 2001. Spatial data for national fire 

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Luna Community Wildfire Protection Plan. 2006. A supplement to the Catron County 

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Meehan, W.R. 1991. Influences of forest and rangeland management on salmonid fishes and their 

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based framework for improving ecosystem resiliency. USDA Rocky Mountain Research 

Station. General Technical Report RMRS-GTR-310. 86pp. 

Schmidt, Kirsten M.; Menakis, James P.; Hardy, Colin C.; Hann, Wendall J.; Bunnell, David L. 

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177

Toney, E. M. 2012. Small sites in the Mimbres Region: a GIS and landscape theory approach. 

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Draft Environmental Impact Statement

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Index

6th code watersheds, iv, 12, 13, 109, 113, 

137 

action alternatives

design features, 33, 34, 35 

effects on air quality, 106 

effects on aquatic resources, 124, 125, 

126, 127, 128, 133 

effects on fire and fuels, 78, 79 

effects on heritage resources, 159, 160

effects on inventoried roadless areas, 153

effects on management indicator species, 

93, 94, 96, 97, 98, 99, 101 

effects on Mexican gray wolf, 43, 83 

effects on Mexican spotted owl, 86

effects on Mexican spotted owl habitat, 

71 

effects on migratory birds, 104 

effects on narrow-headed gartersnake, 87

effects on northern Mexican gartersnake, 

87 

effects on old growth, 72 

effects on range resources, 145

effects on recreation, 147, 148 

effects on roads, 142, 143

effects on sensitive species, 90

effects on social and economic resources, 

165 

effects on soils, 117, 118, 119, 121, 122 

effects on southwestern willow flycatcher, 

87 

effects on spikedace and loachminnow, 89 

effects on vegetation, 66, 67, 68, 69, 70 

effects on water quality and quantity, 125, 

126, 131, 132, 133, 134, 135, 136, 137 

monitoring, 35 

vegetation treatments, 19, 20 

alligator juniper, 21, 22 

allotments, 144 

alternative C

effects of herbicide use, 74

effects of herbicide use on management 

indicator species, 96, 98, 100, 101 

effects of herbicide use on Mexican 

spotted owl, 85 

effects of herbicide use on migratory 

birds, 104 

effects of herbicide use on range 

resources, 146

effects of herbicide use on recreation, 149 

alternative D

effects on recreation, 148, 149 

aquatic resources, 112

beaver, 50, 92, 97, 98

birds

migratory, vi, 48, 81, 86, 102, 103 

climate change, 149, 155, 162, 176 

cumulative effects

to watersheds, 137, 139 

Dillman Creek reroute, 29 

ecological restoration treatments, i, 1

employment and income, 164 

environmental justice, 17, 166

Escudilla Landscape, vi, 1, 4, 5, 74, 111, 

166 

fire regime groups, v, 76, 77, 79 

fire return interval, 11, 76 

firewood gathering, 163 

fish

threatened, 36, 47, 88, 89, 150

forest plan

amendments, ii, 16, 32 

fuel conditions, iv, 10, 11, 12, 24, 75, 80, 

117 

Gila National Forest

heritage resources, 157 

history, 156 

hairy woodpecker, 100, 101, 102 

herbicide treatments

design features, 22, 23 

inventoried roadless areas

Frisco Box, 152 

Mother Hubbard, 151, 152 

Nolan, 150 

juniper titmouse, 99, 100 

landscape-scale restoration, i, 1

loachminnow, 36, 47, 88, 89, 150 

long-tailed vole, 95, 96, 97 

management indicator species, iv, vi, 49, 81, 

91, 92, 94, 97, 98, 100

meetings, i, iii, 16 

Mexican gray wolf, 34, 43, 81, 82 

Mexican spotted owl, 13 

Mexican spotted owl critical habitat, 83

migratory birds, vi, 48, 81, 86, 102, 103 

modeling 

fire, 76 
Index

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Draft Environmental Impact Statement

180

Forest Vegetation Simulator, 60 

vegetation structural stage, 63 

modified proposed action, i, ii, 15, 16, 19, 

67 

motor vehicle use map, 14, 173 

motorized transportation system, 27 

design features, 29 

mule deer, 49, 91, 92, 93 

narrow-headed gartersnake, 21, 23, 25, 46, 

87, 88 

National Forest System roads, 141 

no-action alternative

description, 19 

effects on air quality, 105 

effects on aquatic resources, 122, 123, 

130 

effects on fire and fuels, 78

effects on heritage resources, 158

effects on inventoried roadless areas, 153

effects on management indicator species, 

49, 92, 94, 96, 97, 99, 100, 101

effects on Mexican gray wolf, 82

effects on Mexican spotted owl, 84

effects on Mexican spotted owl habitat, 

64 

effects on northern Mexican gartersnake, 

46, 87 

effects on old growth, 65 

effects on range resources, 144

effects on recreation, 147 

effects on sensitive species, 90

effects on social and economic resources, 

165 

effects on soils, 115, 116, 117 

effects on southwestern willow flycatcher, 

86 

effects on spikedace and loachminnow, 89 

effects on vegetation, 61, 62, 63 

effects on water quality and quantity, 129, 

130 

northern Mexican gartersnake, 32, 36, 46, 

81, 87, 150 

old growth, iv, v, 6, 9, 10, 41, 65, 66, 72, 73 

plain titmouse, 50, 99 

population growth, 162

prescribed fire treatments, 23, 24

design features, 24, 25 

project area

description, 2 

location, 1, 2 

public involvement, i, iii, 2, 16 

rabbitbrush, 21, 22 

race and ethnicity, 162

range improvements, 25 

drinkers, 26, 27 

fences, 27 

wells, 26 

recreation

hunting, 146 

off-highway vehicles, 146 

trails, 146 

riparian areas, 112 

riparian treatments, 31

road decommissioning, 28, 43, 83, 84, 85, 

87, 88, 89, 117, 121, 128, 130, 136, 142, 

174 

roads, 141 

road-stream crossings, 30

scoping comments, i, iii, 16 

sensitive species, ii, 48, 81, 90, 139, 167 

significant issues

fuels treatments, i, ii, 1, 17, 19 

motorized transportation system, i, ii, 1, 

17, 19 

vegetation treatments, i, ii, 1, 17, 19

smoke emissions, 58, 107, 165, 166, 167 

soils, 111 

southwestern willow flycatcher, 21, 23, 25, 

45, 86, 102 

spikedace, 47, 88, 89 

stand density index, iv, v, vii, 6, 7, 62, 63, 

68 

stream and riparian treatments, 29

design features, 32, 36 

erosion control, 31, 32 

exclosures, 31

irrigation diversion, 30, 171 

seeding, 32 

stream and bank stabilization, 30, 32 

total maximum daily load, 113 

Travel Management Rule, 14, 140, 143, 161 

Tribal consultation, i, 16, 17 

Tucson Electric Power, i, vii, 2, 18, 25, 28, 

80, 120, 128, 136, 142, 143 

vegetation condition class, v, 77, 78 

vegetation structural stage, iv, v, vii, 7, 8, 

39, 62, 63, 64, 69, 70, 71, 90

vegetation treatments

design features, 21 

herbicide use, 21 
Index

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181

Wallow Fire, 5, 15, 80, 89, 111, 112, 115, 

123, 129, 147, 161 

water quality

total maximum daily load, 113 

water quality standards, iv, 12, 13, 53, 112, 

129, 131, 132, 139 

watershed condition classification, 35, 54, 

108, 109, 137, 138, 139, 140 

watershed condition rating, iv, 12, 13, 109, 

111 

wildland fire, 11, 33, 68, 69, 78, 81, 158, 

161, 176 

wildlife

management indicator species, iv, vi, 49, 

81, 91, 92, 94, 97, 98, 100 

Mexican gray wolf, 34, 43, 81, 82

narrow-headed gartersnake, 21, 23, 25, 

46, 87, 88 

northern Mexican gartersnake, 32, 36, 46, 

81, 87, 150 

sensitive species, ii, 48, 81, 90, 139, 167 

southwestern willow flycatcher, 21, 23, 

25, 45, 86, 102 

threatened and endangered species, 81