Abbreviated Final 

General Management 

Plan / Environmental 

Impact Statement

January 2008

NATIONAL PARK SERVICE

U.S. DEPARTMENT OF THE INTERIOR

SAGUARO NATIONAL PARK

ARIZONA

Saguaro

National 

Park
Abbreviated Final 

General Management Plan / Environmental Impact Statement 

Saguaro National Park 

Pima County, Arizona 

________________________________________________________________________ 

Saguaro National Park was established by President Herbert Hoover on March 1, 1933. Originally 

named Saguaro National Monument, the status was changed to Saguaro National Park by an act 

of Congress on October 14, 1994. The last general management plan for the park was completed 

in 1988. Much has changed since 1988 — visitor use patterns and types have changed, the 

population of the city of Tucson has doubled, and an additional 7,577 acres have been added to 

the park. Each of these changes has implications for how visitors access and use the national park 

and the facilities needed to support those uses, how resources are managed, and how the National 

Park Service manages its operations. A new plan is needed. 

The Draft General Management Plan / Environmental Impact Statement examines three 

alternatives for managing the park for the next 25 years. It also analyzes the impacts of 

implementing each of the alternatives. The “no-action” alternative, alternative 1, consists of 

continuing the existing park management and trends and serves as a basis for comparison in 

evaluating the other alternatives. The concept for park management under alternative 2 would 

be to protect the park’s ecological processes and biological diversity by reducing fragmentation of 

wildlife and plant habitats and protecting wildlife corridors. The concept for park management 

under alternative 3 would be to provide a wider range of opportunities for visitors that would be 

compatible with the preservation of park resources and wilderness characteristics. Alternative 2 is 

the National Park Service’s preferred alternative. 

The Draft General Management Plan / Environmental Impact Statement was distributed to other 

agencies and interested organizations and individuals for their review and comment. This 

Abbreviated Final General Management Plan / Environmental Impact Statement presents the 

comments and agency responses and a correction (errata) sheet that shows the minor changes 

that need to be made to the draft. The draft and the abbreviated final constitute a full final 

document. Because these changes were minor, the National Park Service has permission to print 

this abbreviated document. 

For further information, please contact the superintendent, Saguaro National Park, 3693 South 

Old Spanish Trail, Tucson, AZ 85730-5601. 

U.S. Department of the Interior • National Park Service 

i 

CONTENTS 

INTRODUCTION 1 

CONSULTATION AND COORDINATION 2 

PUBLIC REVIEW 2 

COMMENTS AND RESPONSES 3 

DRAFT GMP/EIS CORRECTIONS 7 

AGENCY AND ORGANIZATION LETTERS 13 
ii
1 

INTRODUCTION 

This is an abbreviated Final General 

Management Plan / Environmental Impact 

Statement for Saguaro National Park. The 

material included here is to be combined with 

the Draft General Management Plan / 

Environmental Impact Statement, which was 

distributed for public review August 1, 2007. 

The 60-day public review period ended 

October 3, 2007. The abbreviated format has 

been used because the changes to the draft 

document are relatively minor and do not 

modify the analysis provided in the Draft 

General Management Plan / Environmental 

Impact Statement. 

Use of this format is in compliance with the 

1969 National Environmental Policy Act 

regulations (40 Code of Federal Regulations or 

CFR 1503.4 (c)). The draft and abbreviated 

final documents together present the full Final 

General Management Plan / Environmental 

Impact Statement, its alternatives, associated 

environmental impacts, and comments that 

have been received and evaluated and 

responses to them. 

Following the announced release of this 

Abbreviated Final General Management Plan / 

Environmental Impact Statement in the Federal 

Register, there will be a 30-day no-action 

period. A “Record of Decision” of the 

approved final plan will then be signed by the 

regional director, Intermountain Region, 

National Park Service (NPS), and copies will 

be made available to the public. 

For further information, please contact the 

superintendent, Saguaro National Park, 3693 

South Old Spanish Trail, Tucson, AZ 85730-

5601. 
2

CONSULTATION AND COORDINATION 

This section summarizes the agency, 

organization, and public comments received 

on the Draft General Management Plan / 

Environmental Impact Statement. These 

comments allow interested parties (including 

NPS decision-makers) to review and assess 

how other agencies, organizations, and 

individuals have responded to the proposed 

actions and alternatives and their potential 

impacts. The National Park Service provides 

responses to those comments that are 

considered substantive or when responses are 

helpful for clarification or other purposes. 

Substantive comments are those that (1) 

question, with reasonable basis, the accuracy 

of information in the environmental impact 

statement, (2) question, with reasonable basis, 

the adequacy of environmental analysis, (3) 

present reasonable alternatives other than 

those presented in the environmental impact 

statement, or (4) cause changes or revisions in 

the proposal. 

PUBLIC REVIEW 

A notice of availability of the Draft General 

Management Plan/ Environmental Impact 

Statement was published in the Federal 

Register on August 1, 2007. The draft 

document was distributed to the public 

August 2, 2007. The official review and 

comment period began on August 5, 2007, and 

ended October 3, 2007. Approximately 3,000 

individuals received either a copy of the 

document or a CD-ROM version of the 

document or were notified by postcard that 

the document was available on the NPS 

Planning, Environment, and Public Comment 

(PEPC) website. These individuals also 

received information about the dates, times, 

and locations of three public open house 

meetings held in the Tucson area. The 

availability of the document and information 

about the public meetings were also 

announced in the local newspaper. 

Three public meetings were held. On 

September 5, 2007, meetings were held from 

11:00 a.m. to 1:00 p.m. at Pima Community 

College Downtown and from 4:00 p.m. to 7:00 

p.m. at Picture Rocks Intermediate School. On 

September 6 a meeting was held from 4:00 

p.m. to 7:00 p.m. at Pima County Community 

College East. At each of these open house 

meetings, a separate station was provided for 

those members of the public who were 

interested in the Comprehensive Trails Plan

being conducted as a separate planning effort. 

A total of 84 individuals attended the 

meetings. Public comments were recorded by 

the planning team. 

The Draft General Management Plan/ 

Environmental Impact Statement was also sent 

out certified return receipt mail on August 1, 

2007, to 12 tribes (federally and state 

recognized) that have been identified as 

having a cultural affiliation with the park. The 

tribes were asked to review the draft 

document and provide the National Park 

Service with comments. One tribe responded 

with no comments on the draft document. 

Approximately 190 written and electronic 

comments were received. The public did not 

present any new alternatives and public 

comment analysis did not result in any 

modifications to the current alternatives. 

Letters from federal, state, and local 

governments and organizations are 

reproduced on the following pages, as 

required. These entities either supported 

alternative 2 or had no comment. The 

Environmental Protection Agency 

commented on climate change; the NPS 

response is included in the comments and 

responses below. 
3 

The public’s comments have been considered 

by the Park Service in preparing this 

Abbreviated Final General Management Plan/ 

Environmental Impact Statement, consistent 

with the requirements of 40 CFR 1503. The 

following section summarizes substantive 

comments and contains the NPS response. 

The National Park Service responses make 

factual changes, clarify or provide new 

information, or explain why the public 

comments do not warrant further agency 

response. 

COMMENTS AND RESPONSES 

Comment: The United States Environmental 

Protection Agency rated the draft document 

as LO — Lack of Objections. However, they 

recommended that the “plan address the 

potential effects of climate change on park 

resources and how the National Park Service 

will adaptively manage affected resources.” 

(This letter is reproduced in this document.) 

NPS Response: Because the issue of global 

climate change is an emerging scientific 

field, the General Management Plan did not 

address this topic specifically. As part of 

NPS inventorying and monitoring efforts 

the park staff will establish a program to 

track associated effects on park resources 

as a result of climate change. If and when 

effects are identified through this program, 

the park staff would then recommend 

necessary changes in management policies, 

but at this stage, there is not enough 

information to calculate or quantify 

impacts or to recommend management 

strategies at the general management 

planning level. This is true for all associated 

resources mentioned related to climate 

change, including but not limited to water 

resources, vegetation, habitat, wildlife, and 

cultural resources. Therefore, no change is 

needed to the General Management Plan / 

Environmental Impact Statement. 

Comment: Several individuals commented 

on the proposed restriction of off-trail hiking 

below 4500’ in the Tucson Mountain District 

(page 83). The commenters suggested that this 

restriction limits opportunities for solitude 

and unconfined recreation, freedom, 

orienteering, and that it reduces wildlife and 

nature observation opportunities. They also 

suggested it was a violation of the Wilderness 

Act that is intended to promote high-quality 

opportunities for solitude and primitive 

recreation.

NPS Response: The National Park Service 

is mandated to protect resources while 

allowing for appropriate recreational 

opportunities. The Tucson Mountain 

District in Saguaro National Park contains 

natural and cultural resources that are 

highly sensitive to recreation-related 

impacts. The General Management Plan

proposes a restriction of “off-trail” activity 

below 4,500 feet for both districts to 

concentrate use and associated impacts 

along designated trails, which are designed 

and maintained to minimize resource 

impacts. As noted throughout the 

environmental consequences section, even 

small amounts of off-trail travel causes 

vegetation loss, soil compaction, and 

habitat fragmentation, and such travel 

facilitates intentional, as well as 

unintentional, loss of archeological and 

other sensitive cultural and natural 

resources. As residential development 

around the Tucson Mountain District 

increases and more people seek to explore 

the park off-trail, these impacts would 

increase. 

Providing the highest level of protection 

for the park’s sensitive vegetation and 

cultural resources below 4,500 feet is the 

motivation for restricting travel in the park 

to designated trails. The intent is to keep 

areas outside the designated trail system in 

a relatively undisturbed state. This is also 

consistent with management of the Rincon 

Mountain District. The Wilderness Act 
4

(Public Law 88-577) does not prohibit the 

management of visitor use to protect 

resources, and it allows for primitive 

facilities such as trails and campsites to 

facilitate travel and concentrate recreationrelated impacts. As referenced throughout 

the document, the National Park Service is 

evaluating new trail opportunities as part 

of the Saguaro National Park 

Comprehensive Trails Plan in some areas of 

the Tucson Mountain District that 

currently lack designated trails. These new 

trail opportunities will be designed to 

sustain visitor activity, and will provide 

access to areas of the park that currently 

are only accessible through off-trail 

activities. Further, the park will increase 

efforts to educate visitors about less 

crowded times of the day, week, and year 

and use levels on different trails to help 

them find plentiful opportunities for 

solitude and immersion in nature while 

staying on the designated trail system. 

Therefore, no change is needed to the 

General Management Plan / Environmental 

Impact Statement.

Comment: A commenter favored the 

creation of ADA-accessible trails (page 83), 

but felt that any trail developed in the 

southwestern section of the Tucson Mountain 

District (natural zone on alternative map) was 

in the park’s only badger habitat and possible 

construction of a paved trail was unadvisable. 

The commenter further indicated that this 

area was the only place in either district where 

badgers were observed and where dens and 

digging could be found. 

NPS Response: The park staff appreciates 

the commenter’s concern for the identified 

species; NPS resource managers are also 

concerned about the continued well-being 

of this species and the habitat required for 

its survival. Although badgers have been 

identified in this location, the historic 

range for this animal was throughout the 

area, including both park districts and the 

Tucson Mountain Park. Contemporary 

sightings indicate that, while uncommon, 

badger populations are more widespread, 

especially in the Tucson Mountain District, 

so this is not the only location where 

badgers have been observed. Where trails 

are proposed as part of the Comprehensive 

Trails Plan, NPS staff would seek trail 

alignments that avoid badger habitat and 

dens and implement best management 

practices to minimize disruptions to 

known populations. If specific potential 

impacts on badgers are identified, NPS 

staff would develop methods to mitigate 

these impacts. It is unlikely that trail 

construction or subsequent use would 

appreciably impact badgers, and more 

unlikely that such an activity would alter 

their population. Therefore, no change is 

needed to the General Management Plan / 

Environmental Impact Statement.

Comment: A commenter expressed their fear 

that the “facts were being shaped to support 

the park’s preferred alternative regarding the 

road kill count-by-extrapolation, which 

makes it seem worse than we who are on these 

roads daily have observed.” 

NPS Response: The General Management 

Plan does not quantify animals killed under 

the existing conditions or proposed 

alternatives. Rather, it recognizes the relative 

impacts of the alternatives on wildlife 

populations. We do know that park wildlife is 

killed by automobile traffic, and that one of 

several objectives in this General Management 

Plan is to improve conditions that adversely 

impact park wildlife. The preferred alternative 

would do this if roadway improvements are 

put into operation. In addition, animals killed 

on park roads, referred to in the document as 

“road kill,” was only one of several criteria the 

park staff considered when looking at 

methods to improve the existing conditions 

on Picture Rocks Road as described on pages 

25 and 61. Therefore, no changes are needed 

to the General Management Plan / 

Environmental Impact Statement.
5 

Comment: A comment was received 

concerning air quality issues (page 34) as 

follows: 

“Chapter 1 addresses air quality issues 

in the Natural Resources Section of the 

Plan. EPA is proposing revisions to the 

primary ozone standard and is also 

proposing the addition of a secondary 

ozone standard to protect public 

welfare, including limiting environmental damage to sensitive vegetation, 

and ecosystems. EPA timelines project a 

June 2008 effective date for the revision. 

While the Park may have only limited 

ability to affect the ozone levels in the 

area, it is important to consider such 

impacts in finalizing the Plan. To the 

extent alternatives are available that 

have lower air emissions those should 

be favorably considered. EPA 

projections show that the Tucson area 

may become a nonattainment area if the 

standards are finalized as currently 

proposed. All management and control 

strategies that result in lower air 

emissions will help to improve our air 

quality and will be especially important 

with the promulgation of new ozone 

standards.” 

NPS Response: Under the current 

regulations, the park meets National 

Ambient Air Quality Standards. Although 

current projections for revising standards 

indicate June 2008 as the effective date, the 

regulations have yet to be revised and so 

current regulations apply. The park is 

required by law and policy to meet or 

exceed regulations and will continue to 

monitor conditions. Under all proposed 

actions outlined in the Draft General 

Management Plan, park contributions to 

this problem would be negligible both in 

the short term during construction and/or 

implementation and in the long term as 

part of general management. If conditions 

and/or standards change in the future, the 

park would reassess and adjust management actions and activities accordingly. 

Therefore, no changes are needed to the 

General Management Plan / Environmental 

Impact Statement.

Comment: Concurrently with the General 

Management Plan, the National Park Service is 

conducting a Comprehensive Trails Plan for 

Saguaro National Park. Some members of the 

public developed an “alternative C” as part of 

the trail plan effort. Several commenters on 

the General Management Plan requested 

feedback on this alternative. 

NPS Response: Alternative C is not part 

of the General Management Plan / 

Environmental Impact Statement. This 

alternative contains a detailed description 

of specific trail recommendations (e.g., 

new trails to open, trails to delete, trails to 

reopen, and new access points to develop) 

and is being considered and analyzed as 

part of the comprehensive trails planning 

project. The General Management Plan

does not include this level of specificity for 

trail planning. The General Management 

Plan does provide long-term, general 

guidance on the park’s desired natural and 

cultural resource conditions and visitor 

experiences, as well as general types/levels 

of development that direct subsequent trail 

planning efforts. Therefore, no changes are 

needed to the General Management Plan / 

Environmental Impact Statement. However, 

the goal of the Comprehensive Trails Plan

has been included in the General 

Management Plan as indicated in the 

correction sheet. 

Comment: A commenter questioned the 

acreage of a use and occupancy reservation 

(page 11). The document states there is an 

outstanding reservation of use and occupancy 

(life estate) on a 40-acre tract in the Rincon 

District while NPS policy states that such 

reservations are limited to the homesite and 3 

acres. 
6

NPS Response: The 40-acre tract located 

in the Rincon Mountain District became a 

life estate in 1972 and is still in effect. At 

that time there were no policies on the size 

of life estates. The 1979 Land Acquisition 

Policy did limit the size of life estates to 3 

acres plus the structures. In 2001, a new 

life estate was added to the Tucson 

Mountain District under the 1979 policy. 

This clarification has been included in the 

correction sheet in this document. 

Comment: One commenter did not support 

the proposal to build a new section of the 

Bajada Loop Drive (page 78) to move park 

visitor traffic off Sandario Road to improve 

safety. It was mentioned that no 

documentation for this action was provided. 

NPS Response: The Draft General 

Management Plan does refer to the high 

accident rate on the section of Sandario 

Road where Bajada Loop Road travelers 

must enter and exit Sandario Road on 

pages 165 and 205-206. Although the park 

and county maintain safety records for this 

section of roadway (among others), the 

references were not cited in the document. 

These references have been included in the 

correction sheet in this document. 

Comment: A number of commenter’s 

expressed concern about the use of the rightof-way of the El Paso Gas Company — shown 

on the alternative 2 map for Tucson Mountain 

District, page 79 — as a horse, bicycle, and 

hiking trail. They were concerned about 

safety. 

NPS Response: The gas line right-of-way 

is currently being used as a trail. The El 

Paso Gas Company has expressed an 

interest in cooperating with the park to 

develop a multiuse trail along this right-ofway. Aside from vehicles involved in 

pipeline maintenance, no motorized, offroad vehicles would be permitted. The trail 

is identified in the Eastern Pima County’s 

Trail System Master Plan. However, the 

alternative map for the Tucson Mountain 

District incorrectly shows a proposed 

trailhead at the southern terminus of the 

gas line right-of-way. This trailhead is not 

planned and will not be developed. A 

corrected version of the Tucson Mountain 

District alternative 2 map has been 

included in this document 

Comment: A commenter questioned the 

absence of two articles on the flora and 

vegetation of the park’s two districts in the 

selected references. 

Response: Thank you. We will add these 

references. 
7 

DRAFT GMP/EIS CORRECTIONS 

This section contains those changes that should be made to the Draft General Management Plan/ 

Environmental Impact Statement. Some of these changes are a result of public comments while 

others are editorial in nature. Please make the following changes: 

Page 10 — The Primary Interpretive Themes 

The themes have been further refined. Please replace them with the following: 

• The dichotomy of the Saguaro Wilderness, so close to a rapidly expanding urban area, 

provokes and welcomes us to explore the mysteries of nature for spiritual renewal and 

healing, and also inspires us to protect and preserve similar places. 

• Saguaro National Park’s Rincon Mountains are the largest road-less “Sky Island” in the 

Sonoran Desert — a uniquely pristine and diverse biotic community that provides 

exceptional opportunities for exploration, education, research, and wonder. 

• People have adapted to, influenced, and lived in the Sonoran Desert since prehistoric 

times; fruit harvesting and hunting, homesteading and grazing, urbanizing and mining, 

recreating and exploring, resource and fire management are but a few examples of 

decisions and subsequent impacts that continue to affect this unparalleled landscape. 

• The saguaro, the most recognizable cactus in the world, is a symbol with emotional 

significance spanning centuries and cultures, and it is a keystone species in an 

interdependent community (of plants, animals, and humans) adapted for living and 

thriving in this harsh arid environment. 

Page 11 — Life Estates 

Please replace the sentence with the following. The park contains two life estates or 

reservations of use and occupancy: a 40-acre parcel in the Rincon Mountain District and a 

5-acre parcel in the Tucson Mountain District. Both of these life estates are still in effect. 

The 40-acre parcel was added in 1972. At that time there were no policies regarding size 

of life estates. In 1979, the Land Acquisition Policy limited the size of life estates to 3 acres 

plus the structures. A life estate was added to the Tucson Mountain Distict in 2001 under 

the 1979 policy. This life estate is 5 acres, including the structures. 

Page 20 — Comprehensive Trail Plan Goal 

Please add the following in the first column, before the last sentence: The goal of 

comprehensive trail plan is to provide a comprehensive, well-designed, sustainable trail 

system that provides reasonable access and a variety of visitor trail recreation experiences, 

consistent with the purpose and significance of the park. 

Page 79 — the Tucson Mountain District Alternative 2 Map 

This map has been revised. The words “proposed trailhead” on the southern terminus of 

the gas line right-of-way were removed. Please insert the new map provided. 

Page 87 — the Tucson Mountain District Alternative 3 Map 

This map has been revised. The words “proposed trailhead” on the southern terminus of 

the gas line right-of-way were removed. The location of state and county land has been 

indicated. Please insert the new map provided. 
8

Page 104 — Future Studies and Implementation Plans Needed 

Please delete the second bulleted item in the first column — the Fire Management Plan. 

This plan has been completed. Add “boundary study” as the last bullet. 

Page 165 — Roadway Issues and Concerns 

Please add the following sentence to column one, the first paragraph: Since 2003, there 

have been 20 accidents and 11 injuries in the vicinity of the Sandario/Kinney Road 

intersection, and 6 accidents and 3 injuries on Golden Gate Road. 

Pages 304 and 305 — Appendix A: Legislation 

The legislation should be in chronological order. Pages 304–305 should become pages 

302–303, and pages 302–303 should become pages 304–305. 

 

Page 368 —Selected References 

Please add the following: 

Bowers, Janice E. and McLaughlin, Steven P. 

1987 “Flora and Vegetation of the Rincon Mountains, Pima County, Arizona”. Desert 

Plants. 8(2): 50-94. 

Renée Rondeau, Thomas R. Van Devender, C. David Bertelsen, Philip Jenkins, Rebecca K. 

Wilson, and Mark A. Dimmitt 

1996 “Annotated Flora and Vegetation of the Tucson Mountains, Pima County, 

Arizona.” University of Arizona for Boyce Thompson Southwestern Arboretum. 
Picture Rocks Road

Golden

Gate

Trail

Signal Hill

Valley View Overlook Trail

Mile Wide Road

Desert Discovery Nature Trail

Sus

Kinney Road

Sandario Road

Cam-Boh

(Picnic Area)

Ez-Kim-In-Zin

(Picnic Area)

Mam-A-Gah

(Picnic Area)

Proposed trailhead

Proposed conversion to trail

Gas Line 

Right-of-Way

Proposed trail and trailhead

Proposed trailhead

(Picnic Area) Possible paved trail

Possible paved trail

within the zone

(Picnic Area)

CCC Camp Area

Proposed Interpretive 

trail

Visitor Center

Scenic

Bajada

Loop Drive

King Canyon Trail

United States Department of the Interior • National Park Service

DSC / JUNE 2006 / 151 / 20059

General Management Plan

Saguaro National Park

Alternative 2 - Preferred Alternative

Tucson Mountain District

0 1

Mile

North

PARK BOUNDARY

TRAIL

STATE LAND

COUNTY LAND

PRIVATE LAND

SENSITIVE ZONE

PRIMITIVE ZONE

SEMI-PRIMITIVE ZONE

NATURAL ZONE

SIGHTSEEING CORRIDOR ZONE

DEVELOPED ZONE

Legend

Management Zones

Golden

Gate

Roa

d

Picture Rocks Road

Valley View Overlook Trail

Mile Wide Road

Kinney Road

Sandario Road

Cam-Boh

(Picnic Area)

Ez-Kim-In-Zin

(Picnic Area)

Mam-A-Gah

(Picnic Area)

Signal Hill

(Picnic Area)

Sus

(Picnic Area)

Desert Discovery Nature Trail

Visitor Center

Scenic

Bajada

Loop Drive

(Proposed One-way)

CCC Camp 

Area

King Canyon Trail

Proposed trail and trailhead

Gas Line Right-of-Way

 General Management Plan

Saguaro National Park

U.S. Department of the Interior • National Park Service

DSC / JUNE 2006 / 151 / 20061

Alternative 3 - Tucson Mountain District

0 1

Mile

North

PARK BOUNDARY

TRAIL

STATE LAND

COUNTY LAND

PRIVATE LAND

SENSITIVE ZONE

PRIMITIVE ZONE

SEMI-PRIMITIVE ZONE

NATURAL ZONE

SIGHTSEEING CORRIDOR ZONE

DEVELOPED ZONE

Legend

Management Zones

13 

AGENCY AND ORGANIZATION LETTERS 
FEDERAL AGENCIES

14
Federal Agencies 
FEDERAL AGENCIES

16
Federal Agencies 

17